The URL can be used to link to this page

Home My WebLink AboutPC Listening Notes and Letters April 30 - May 5, 20211 Betsy Brown From:Jessica Louisos Sent:Monday, May 3, 2021 9:47 PM To:Betsy Brown Cc:Marla Keene Subject:Fw: EXTERNAL: Planned road through a wetland Public input received. Jessica Louisos South Burlington Planning Commission Chair Notice - Under Vermont’s Public Records Act, all e-mail, e-mail attachments as well as paper copies of documents received or prepared for use in matters concerning City business, concerning a City official or staff, or containing information relating to City business are likely to be regarded as public records which may be inspected by any person upon request, unless otherwise made confidential by law. If you have received this message in error, please notify us immediately by return email. Thank you for your cooperation. From: Loretta Marriott <lmarriot@uvm.edu> Sent: Friday, April 30, 2021 3:36 PM To: Marla Keene Cc: Paul Conner; Paul S. Engels; Bernie Gagnon; Jessica Louisos; Duncan MacDonald; Michael Mittag; Monica Ostby; Ted Riehle; Helen Riehle; Meaghan Emery; Tim Barritt; Tom Chittenden; Matt Cota; Kevin Dorn Subject: EXTERNAL: Planned road through a wetland This message has originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or responding to this email. Hi Marla, Thank you for your message. Is there really a "planned road Tilley Drive Extension" across Potash Brook, through the wetland, to Community Dr. and then on to Kimball Ave? See CCRP envision I-89 map below. Currently there is pedestrian/bike path and wooden bridge there. I have read South Burlington’s Comprehensive Plan and the City's proposed Environmental Protection Standards update including Article 12 and the Interactive Map Viewer. Also I am familiar with the CCRP envision I-89 document and Burlington International Airport’s 2030 Master Plan. Kevin Dorn sent me the Mission, Vision and Values statement for the City of South Burlington which is different than that in the Comprehensive Plan. I can send it to you if you want. Re: the Interactive Map Viewer… 2 *Does (yellow) existing mean these areas will not change? *How accurate are the color boundaries? I find the interactive map…unclear (as well as difficult to use). It would be helpful to clarify not only what is existing but what is proposed to stay existing. I understand blue is proposed and yellow is existing. I hope my question is clear. The narrative of Article 12 says (in a general sort of way) roads through wetlands are permitted if they are necessary and there is a plan to mitigate damage. Is this really correct? For example: *The CCRP envision I-89 map has a “planned road Tilley Drive Extension” across Potash Brook, through the wetland, to Community Dr. and then on to Kimball Ave? See the CCRP envision I-89 map. *Again the CCRP envision I-89 map has a “Planned City Street Connection” from Tilley Drive heading north roughly parallel to Old Farm Road (to the airport according to last evening’s zoom meeting presenter). I have added some screen shots to help. Will these roads be permitted? Thank you, Loretta Marriott 13 Mills Ave 3 4 On Apr 30, 2021, at 1:06 PM, Marla Keene <mkeene@sburl.com> wrote: Hi Loretta, from a planning perspective, our Comprehensive Plan might be the document you’re looking for. https://cms6.revize.com/revize/southburlington/document_center/planning/SB_Comprehensive_Pl an_Complete_Adopted_2-1-2016.pdf Marla Keene, PE Development Review Planner City of South Burlington (802) 846-4106 From: Loretta Marriott [mailto:lmarriot@uvm.edu] Sent: Wednesday, April 28, 2021 10:10 AM To: planning <planning@sburl.com> Subject: EXTERNAL: Fwd: Does South Burlington have a unified mission and core values statement? This message has originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or responding to this email. Greetings, I received a message that Paul is out of the office and a suggestion to use this email address for messages. Thank you, Loretta Begin forwarded message: 5 From: Loretta Marriott <lmarriot@uvm.edu> Subject: Does South Burlington have a unified mission and core values statement? Date: April 28, 2021 at 9:39:19 AM EDT To: Paul Conner <pconner@sburl.com> Cc: Paul Engles <psengels@sburl.com>, Bernie Gagnon <bgagnon@sburl.com>, Jessica Louisos <jlouisos@sburl.com>, Duncan Macdonald <dmacdonald@sburl.com>, Michael Mittag <mmittag@sburl.com>, Monica Ostby <monicaostby@gmail.com>, Ted Riehle <triehle@sburl.com> Hi Paul, Here is a message that I sent to Kevin Dorn with a cc to the SB City council yesterday. Thank you for all the work you and the Planning Commission do. The work on updating the Comprehensive Plan and the natural resources map is remarkable! Loretta Forwarded message: It seems to me that the proposed I-89 12B interchange is backward thinking and counter to the values supporting work of various South Burlington departments and committees. To evaluate my thinking I searched the South Burlington City website and found the Mission Statement and core values for the South Burlington Police Department which I have included below. Does South Burlington have a unified mission and core values statement? Thank you, Loretta Marriott 13 Mills Ave Welcome to the South Burlington Police Department MISSION STATEMENT It is the mission of the South Burlington Police Department to foster a safe environment which promotes a high quality of life within our community. We will accomplish this by reducing the level and fear of crime and facilitating safe highways; by addressing community concerns; by actively seeking input and responding to issues brought to our attention; by managing our organization responsibly utilizing effective efficient, and rational planning; by recruiting, retaining, and nurturing the development of the most qualified personnel to meet the needs of the community and the police department. We will abide by a core set of values, being: integrity, loyalty, dedication to duty, professionalism, teamwork, fairness, and respect. 6 1 Betsy Brown From:Jessica Louisos Sent:Monday, May 3, 2021 9:49 PM To:Ted Riehle; Duncan MacDonald; Monica Ostby; Paul S. Engels; Michael Mittag; Bernie Gagnon Cc:sarah.morganhouse@comcast.net; Marla Keene; Betsy Brown Subject:Fw: EXTERNAL: Please share with the Planning Commission before Tues., Thanks! Attachments:LDR comments 2-15-21 (pdf).pdf; Letterhead version of article 12 sblt email 8-17-2020 pdf - Shortcut.lnk.pdf Please see attached and below public comment received. Jessica Louisos South Burlington Planning Commission Chair Notice - Under Vermont’s Public Records Act, all e-mail, e-mail attachments as well as paper copies of documents received or prepared for use in matters concerning City business, concerning a City official or staff, or containing information relating to City business are likely to be regarded as public records which may be inspected by any person upon request, unless otherwise made confidential by law. If you have received this message in error, please notify us immediately by return email. Thank you for your cooperation. From: Sarah Dopp <sarah.morganhouse@comcast.net> Sent: Sunday, May 2, 2021 10:56 PM To: Jessica Louisos Subject: EXTERNAL: Please share with the Planning Commission before Tues., Thanks! This message has originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or responding to this email. Dear Planning Commissioners: Thank you for holding the listening sessions for the public to weigh in on the proposed LDR's, Chapters 9, 10 and 12, related to Environmental Protection Standards. We in the So. Burlington Land Trust are grateful to have had opportunities to share our perspectives in person and in writing. I am attaching two pertinent communications sent earlier and hope you will review them, because they are still pertinent to your process. We fervently hope that they have been or will be incorporated in your final product. Several other important items for consideration are: protections of agricultural soils, protection of grasslands and shrub lands, and inclusion of the "supporting habitats" surrounding the habitat blocks, as articulated by Arrowwood Environmental . Since the Comprehensive Plan adopted in 2016 is the plan under which we operate until the next cycle (2024), the LDR's adopted now must regulate and relate to the vision for the City as articulated there, we also feel that there is a need to reference and explain some changes in terminology which now differ between the Comp Plan and the proposed LDR's, namely "Level I, Level II and Hazards" and how they relate to the still 2 current Maps 7 and 8, which speak instead of "Primary and Secondary Conservation." It should be clear to any reader of the new LDR's how these differ and how they remain similar. One additional comment is to note that these are LDR's for the whole City, not just the SEQ. There are remaining open lands all over the City, though it is true that the majority of open space is in the SEQ. Dear Councilors, We have been following the good work of the Planning Commission as they revise and dra< land regula=ons, in par=cular Ar=cle 12 and Ar=cle 15. In an=cipa=on of this being discussed at Tuesday’s council mee=ng, and in the interest of clarity, we offer some observa=ons and sugges=ons, and have a few ques=ons. Even though some of us have been reading LDRs for years, the language used in these dra< Ar=cles is confusing, and in some places, seemingly contradictory. We even heard a Planning Commissioner admit he didn!t understand the meaning of some of the provisions. If people who deal with LDRs are confused, one can assume that many of the general public will not understand these ar=cles or their implica=ons. This could result in fewer comments. Or, it may take a considerable amount of =me during the public comment period to explain the meaning of the Ar=cles. Since these LDRs will have significant impacts on South Burlington’s future land use, it is essen=al they are understandable and have no unintended consequences. Sugges=ons 1.Include an Execu=ve Summary wriQen in lay terms for each Ar=cle which states the goals for the Ar=cle and how the Ar=cle achieves those goals. 2.Re-dra< the Ar=cles using non-technical and straighSorward language; or add a supplemental layperson version—similar to what is now required with other explanatory documents dealing with legal and medical maQers. 3.Include a graphic or photo of selected parcels of land which depicts what the proposed language would allow. For example, give one or two examples of proper=es which could be developed using these new regula=ons, and how these proper=es would look if maximally developed under Ar=cle 12 and 15. 4.Spell out all acronyms before first using them, and include a glossary with these commonly used acronyms and terms. Ques=ons The answers to these general ques=ons are fundamental for the public to know in order to understand the issues and the implica=ons of the proposed Ar=cles. 1.Do the ar=cles result in more land being conserved? Where is this land? 2.Do the ar=cles list stronger environmental protec=ons? What are these measures? 3.Do the ar=cles con=nue to protect the land areas iden=fied in the Comprehensive Plan as “Primary and Secondary Conserva=on Areas” (Maps 7 and 8)? How do the new regula=ons do this? 4.Do Ar=cles 12 and 15, as well as Ar=cles 10 and 18, complement each other? Have any contradic=ons among them been resolved? Are they completely in synch and suppor=ve? 5.Would new PUD regs effec=vely "up-zone" the SEQ from a base of 1.2 to as much as 16 units per acre, vs. the 4 or 8 per acre now allowed in certain circumstances? 6.In a Conserva=on PUD, where 70% of the acreage would be conserved, is that 70% of buildable land (excluding hazards and level I and II resources) OR the total land in the parcel? 7.What is the difference between density based on Building Type and density based on District or Zone Density? South Burlington Land Trust dedicated to preserving South Burlington’s forests, wetlands, farmlands and oth- er natural areas through landowner preservation agreements and other conser-vation vehicles to maintain city residents’ high quality of life. August 18, 2020 South Burlington Planning Commission 575 Dorset Street South Burlington, VT 05403 Dear Commissioners, The South Burlington Land Trust (SBLT) welcomes the Planning Commission’s invitation to comment on the draft Article 12 of the Land Development Regulations (LDR). As an organization whose mission it is to preserve natural resource lands in South Burlington, we are well suited to provide input to this “Environmental Protection Standards” chapter of the LDRs, and we look forward to partnering with the city in crafting this environmental article. In line with the Planning Commission Chair’s direction, we will relegate our comments in this letter to only high-level topics and general areas. Overall, we applaud the work done on this article and are grateful that at long last there will be a chapter in the LDRs devoted to measures which will result in the protection and preservation of our natural resources. Every other chapter/article in the LDRs is devoted to various aspects of development. Having one chapter in the LDRs which enumerates speciﬁc environmental protection standards is not only welcome, but necessary in light of the destruction and damage to the environment from habitat loss and climate change. Preserving our natural environments becomes THE highest priority that responsible planners and citizens should have. No other issue or cause, regardless of their merit, rises to the priority of saving our environment. Therefore, we approach article 12 with the serious threats and dangers of habitat degradation and climate change in mind. 1.While Article 12 goes into detail on water issues, this chapter should be broadened to become a comprehensive document addressing all areas of our natural environmental. It rightly devotes considerable treatment to wetlands, forest blocks, and habitat areas. But there are other natural resources needing environmental protection, such as riparian areas, ﬁelds and meadows, soils, etc. Past studies commissioned by the city address these areas and are a source to be drawn from to make this chapter complete. South Burlington Land Trust Inc. is a 501 (c) (3) non profit organization: Tax ID # 75-3133866. 500 Cheese Factory Rd., South Burlington VT 05403 Board of Directors President Sarah Dopp Treasurer Michael Mittag Secretary Karen Ryder Janet Bellavance Alyson Chalnick Rosanne Greco Allan Strong Page 2 2.The rationale and purpose for drafting Article12 as stated in the Article and in the cover memo from Paul Conner, provide valuable insights into the need for environmental protections. However, in many areas of the current draft there is a lack of speciﬁcity needed in a regulatory document. As currently written, decisions on environmental protections are frequently left to the subjective opinions of the members of the Development Review Board (DRB). We have heard many times from DRB members that they are there to make sure that development applications comply with city regulations. They are not supposed to create or interpret regulations. They have stated that without clear and speciﬁc regulations, they are left to deduce what the planners intended, or to come up with their own interpretation. General or ambiguous terminology in LDRs has led to confusion and uncertainty among DRB members and has even resulted in legal challenges—the JAM Golf lawsuit being one prime example among others. 3.In the cover memo, Paul Conner states that the Environmental Protection Standards draft is “intended to be clear and user-friendly”. This is refreshing to read. However, some of the foundational terminology used is confusing and ambiguous. In particular, using the word “hazard” for high-value natural resource areas is problematic. The common dictionary deﬁnition of that word is “potential source of danger”. It is likely that the average citizen would think that hazard areas are dangerous areas. Other nomenclature, such as “level 1 and level 2” are ambiguous. Without a clear deﬁnition and speciﬁc regulations associated with these numbers, they are merely numerals. Using “clear and user-friendly” words, such as “high or medium or low priority” along with the statutes associated with each will make these levels understandable. 4.The recent Arrowwood study is cited as a source for some of the draft. As valuable as the study was, it focused on only one area of the environment. Regarding our ﬁrst comment on having this article provide protections for the total natural environmental, more environmental areas need to be addressed using more environmental studies and reports. There are dozens of past environmental studies commissioned by the city, including the recent studies done under Interim Zoning. To ignore them would be foolhardy and a waste of taxpayer money. 5.Past environmental standards based on older science, or before climate change impacts were understood, need to be updated. The amount of buffer areas is an example. Even in Vermont, extreme weather events are becoming more frequent, Lake Champlain is in peril, as are all of South Burlington’s waterways. Further, arable land is being lost, wetlands and riparian areas have been damaged, wildlife is disappearing, and more. More stringent protection measures based on improved and enlightened assessments need to be incorporated into this Article. 6.It is unclear what role the city’s Natural Resource Committee plays in this Article. As the only city entity devoted to natural resources, we think it appropriate that this committee have input on all developments which threaten to impact the natural environment. Page 3 The SBLT ﬁrmly believes that South Burlington needs to put in place clear and powerful standards to protect our natural environment. The city’s Comprehensive Plan, as has every environmental study commissioned by the city in the past, advocates for land preservation. It is past time to codify these requirements into the city LDRs. Article 12 is the ideal way to do that. The SBLT will use our knowledge and experience to partner with the Planning Commission in drafting the necessary language to accomplish this. We look forward to hearing how we can best support making Article 12 a successful environmental protection document. Thank you for giving us this opportunity. Sincerely, The Directors of the South Burlington Land Trust 1 Betsy Brown From:Jessica Louisos Sent:Monday, May 3, 2021 9:59 PM To:Betsy Brown; Marla Keene Subject:Fw: EXTERNAL: Review of Habitat Blocks Received public comment below. Jessica Louisos South Burlington Planning Commission Chair Notice - Under Vermont’s Public Records Act, all e-mail, e-mail attachments as well as paper copies of documents received or prepared for use in matters concerning City business, concerning a City official or staff, or containing information relating to City business are likely to be regarded as public records which may be inspected by any person upon request, unless otherwise made confidential by law. If you have received this message in error, please notify us immediately by return email. Thank you for your cooperation. From: Francis MacDonald <fmacdonald@verizon.net> Sent: Monday, May 3, 2021 4:10 PM To: Jessica Louisos; Bernie Gagnon; Michael Mittag; Ted Riehle; Paul S. Engels; Duncan MacDonald; Monica Ostby Subject: EXTERNAL: Review of Habitat Blocks This message has originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or responding to this email. Dear Commissioners, I am disappointed in the Planning Commission’s assessment of the Forest Habitat Blocks identified in the Arrowwood Environmental LLC report. The review of 20 blocks during working sessions on September 29 and October 13, 2020 seemed biased in favor of land development rather than looking at the value for conservation, habitat and open space. The Forest Blocks reviewed were identified by using two different shades of green: dark green for “core”; light green for “buffer”. The “buffer” used was 100 meters (300 feet) and was subtracted from the Arrowwood block. Using two shades of green creates two different “values” of forest block– “important” and “not so important”–in place of the single shade of green used by Arrowwood. Also, the concept of “buffer” has taken on two different meanings depending on who is interpreting the value of the Forest Block. The Arrowwood report first uses “buffer” as a “ranking” parameter to compare blocks in order of importance by comparing the size of the core with the size of the outer 300 feet. A large roundish block has a higher rating than a long thin block. In a March 26, 2021 letter to the City Council and Planning Commission, Arrowwood adds clarification and indicates a “buffer” as “undeveloped lands adjacent to habitat blocks”. And states that “these adjacent lands serve to add wildlife value to the mapped blocks”. This would indicate a “buffer” area be used as an addition to the outer edge of the block. The Planning Commission uses “buffer” as a 300-foot subtraction from the identified block reducing the size and importance of areas within the block. And as a tool for “lopping off” or removing areas of the originally identified habitat area. 2 During the review of the 20 blocks, the phrase “is this change likely to affect development?” was often heard. In those areas where “it is not likely to affect development”, the buffer was kept. In areas where “this land is suitable for development”, the buffer was removed. In the evaluation of the 20 blocks, 9 blocks had sections removed allowing development, and in 11 blocks no changes were made. In many of these 11, other restrictions such as steep slopes, river corridor or flood plain were also present. The following are three examples where protections were removed by “lopping off” the light green “buffer” area in favor of development: 1. 1720/1730 Spear St – Property between South Pointe and South Village: A “light green” forested buffer was removed to allow development of 49 homes. 2. Wheeler/Hill Farm – “Light green” buffer areas with trees and shrub were removed to “straighten the demarcation” and allow future development. 3. Meadowland – A large “light green” buffer of shrub and grassland was removed to allow future development. During these discussions, the commissioners seemed to be advocating for development rather than for wildlife habitat and open space. This seems contrary to the intent of Interim Zoning where the City paused development to identify and protect open space and natural resource wildlife habitat. Respectfully submitted, Francis MacDonald 57 Moss Glen Lane South Burlington, VT 05403 South Burlington Planning & Zoning 575 Dorset Street South Burlington, VT 05403 Dear Commissioners: RE: SB Proposed Environmental Protection Standards update This update shows detailed work. As a piece of a larger puzzle, it should be presented in context with important/attendant PUD updates. Perhaps the PC/Council being “on the clock” (with IZ considerations) requires something to be delivered this month. As a stand-alone, this update shows an earnest map exercise that creates new categories of indeterminate need. Habitat blocks/habitat connectors – Be mindful of the 2003 Arrowhead study that supported NRP protections and resulted in a 10 year battle with JAM over golf course homes -- costing the City 7 acres of the 3rd highest ridgeline in town in exchange for 21 acres of unmitigated stormwater swamp that JAM could absolve itself of responsibility for. Long litigation and contention with large parcel owners may not always end well. The protections are for what exactly? Mammals, reptiles, birds, or all of them? For this level of categorization, there should be an explicit determination of whether 5 flocks of turkeys are worth the potential living space of 50 human mammals. 50 humans commuting from Georgia displace as much wildlife there, if not more, and contribute vastly more to the degradation of the planet. Marking sightings on the map ignores that humans can cohabit with turkeys – many big cities see turkeys and coyotes in their streets now (especially during the reduced traffic times of the pandemic quarantine) – coexistence works. South Burlington shouldn’t treat habitat as a zero-sum scenario; we’ve created sufficient public, park and open space to achieve balanced goals. This step encourages further destruction of Vermont’s unique landscape, settings, and lifestyles in outer towns that have not managed their planning and zoning as well as South Burlington. Worry that this is a selected sampling that misses the larger discussion of what value humans have for living space within the same realm – is there a specific level at which animals become more important – what is that level (acreage per animal? Population count of animal?)? Humans have learned to live with less space and most animals have shown the same ability. Unlike cars, is it harmful to push a percentage of the less-adaptable animals/habitat to other towns? These aren’t the same issues of social inequity that are involved as when SB plans to limit development beyond its present practical limits and pushes humans, rather than animals, to other towns. Floodplains – Why throw another layer of regulation on top of homeowners? If an existing structure is within the floodplain and seeks a permit for expansion, then it goes to the state review. This does not happen now. Labelling neighborhoods and industrial areas such as Dorset Farms, Dorset Village, Butler Farms, Ethan Allen Drive, White St/Pine Tree Terrace, Brookwood Drive, and CCRCF unnecessarily clamps down on in-fill and redevelopment. It will aggravate existing owners – introducing burdens, both perceived and real. Opens the City to more potential litigation. This update unnecessarily labels neighborhoods – based on modeling in 2011 by FEMA but not LIDAR. Hard to understand whether actual claims data is being extrapolated and included to achieve the percent probability that forms the “500 year” mark. The whole City was underwater at one time (20x longer than the “500yr mark”), so it’s hard to see the value of reaching back for a 500-yr benchmark when our crisis has shortened the 100-year floods to 50. Wetland/Riparian buffers – More of the same concerns under floodplains. If the state isn’t requiring SB to make these changes, then why are they being done? These appear targeted to large parcel owners and not to the local Zoning Administrator enforcement, although that is a first concern. The Vermont thing to do is to be talking with the various (and few) large parcel owners first before telling them what they can and cannot do. This practice is often omitted in a rush-to-judgement. Larkin with the lakefront property that is bisected by river corridor should have a conversation with the planning director or commission. Similarly, a former PC member John Belter who stands to have his whole farm designated as a hazard should be communicated with on a personal level. The last IZ neglected him and his expertise entirely for farming and for the use of the Underwood Property. This is not the Vermont way. The AuClairs and LeDucs have been consulted and included to a certain extent but may also feel dictated to. You’ve seen concerns from large parcel owners on Spear and Dorset who discuss their plans and the legacy they want for their families from their property holdings and how the City disrupts this with these updates. The personal touch is still important and even more so with this kind of update and where it leads. More conserved property is acquired and happens because of relationships and common communication than in dictating terms. We have a few large landowners and generational families left in SB and we should be categorizing and cultivating our planning discussions with them first and foremost. It would be good to identify these folks and the commercial developers to develop good communication pathways with them as a concurrent way forward in these goals. This has often been missing from good planning practice. Their numbers are few. We have the time. It costs little and can achieve so much – and it is more in line with our ability to personally connect here. Outreach – actively seek out comment, input and feedback from large parcel owners. Thank you for the many hours of work and consideration that go into this. Hope my thoughts can help shape it more. Chris Shaw 864-1515 43 Great Road Bedford, MA 01730 May 3, 2021 South Burlington Planning Commission City of South Burlington 575 Dorset Street South Burlington, VT 05403 Dear Planning Commission Members, I write to express my concerns about the changes to the City’s wetland guidelines in the proposed new Land Development Regulations. As in my previous communications, my concerns are both general and specific – my family are South Burlington landowners and taxpayers, but we also have a development proposal for our property that is currently before the Development Review Board and the City Council. My general concern is that expanding the buffer around Class II wetlands from 50’ to 100’ and decreasing the size of exempted Class III wetlands from ½ acre to only 300 sq. ft. are changes that skew the already delicate balance between conservation and development. The new proposed LDRs are already removing almost 950 acres from potential development via adoption of the Arrowwood “habitat block” concept, and adding 50’ to the width of wetland buffers will remove a significant amount of additional acreage. It is easy to argue that wider buffers benefit wetland flora and fauna, but the undesirable side effect is that development must be squeezed into smaller plots, which often limits the diversity of building types that the new PUD standards are designed to provide. It is not clear why South Burlington needs to be an outlier in Chittenden County, where no other city or town requires wider buffers or smaller Class III wetland sizes than are specified in the Vermont Wetlands Rules. It also isn’t clear why the new LDRs propose a different standard for residential development than for commercial. Are houses more threatening to wetlands than office buildings? My understanding is that both are subject to the same regulations around pesticides, fertilizers, etc. if they are close to wetlands. A couple of your members toured our property on Spear Street last week and reminded the other members of the importance of site visits to assess the effects of the LDRs in real-life situations. In our particular case, for example, though we await an “official” wetlands certification, preliminary findings suggest that there are two narrow “fingers” of possible Class II wetland that extend close to or even into our proposed development. For these fingers, which are approximately 50’ wide, adding 100’ of buffer on each side will create two undevelopable swaths 250’ wide. Certainly a buffer doesn’t need to be four times as wide as the wetland finger it’s protecting, and I would hope that the PC could reconsider its proposal for the wider buffer, at least in the case of narrow fingers like these. It is also worth noting that one of the fingers on our plan crosses the right of way for a road connection and a bicycle path that the City has long anticipated as connections between the adjacent developments, South Village to the south and South Pointe to the north. Would those connections now be prohibited? Shrinking the threshold for exempting Class III wetlands from the same constraints as Class II areas is also troubling in our particular case. There is a small wet area in the center of our property, probably less than ½ acre, that would be developable under the appropriate State permit. There is a huge difference between ½ acre (approximately 20,000 sq. ft.) and 300 sq. ft., which is only about as big as two parking spaces. Why is the Commission suggesting such a radical change? I suspect that it will be difficult to even find a 300-sq. ft. wetland in the City, so the new proposed regulation effectively throws away the State’s Class III categorization. Our family has been responsible stewards of the property on Spear Street for 70 years now; the development we’re proposing will continue to conserve 22 of our 39 acres under the 2006 NRP statute and another ~6 acres of Arrowwood habitat block. Expanded buffers and recategorized Class III wetlands would restrict even more acreage. I hope that the Commission will reconsider these overly restrictive new regulations for wetlands. Their negative effects on responsible development far outweigh their positive attributes. Sincerely, Alan Long (on behalf of the Long family) Alanklong56@gmail.com 781-521-5429