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FAR comments on the Notice of Intent for the Storm Water Basin:
Questions to Proponents and Commission
February 8, 2004
Cambridge Conservation Commission
RE: Notice of Intent, CambridgePark Drive Area Drainage Project
Dear Commission Members:
The Friends of Alewife Reservation (FAR) are pleased to see this Notice of Intent (NOI) for CambridgePark Drive Area moving ahead in a timely manner. The FAR is dedicated to the preservation and enhancement of the Alewife Reservation. The Reservation is a rare resource in such an urbanized region. With appropriate improvements, it has the potential for even greater value for wetland functions, wildlife and passive recreation. FAR appreciates the opportunity to comment and the opportunities for public presentation.
The reduction in volume of about 84% in a typical year of CSO discharges is a considerable improvement. The Reservation has been degraded and defiled, for years. This plan provides restoration and improvements in a wide range of areas from habitat to recreation.
I am not sure it is prudent to forge ahead with the Conservation Commission without presenting the opinions from the other regulatory authorities. It would be more comprehensive if they could be at the table together.
Our concerns fall into a few categories:
Coordination with the MDC:
There is no specific discussion of amenities - walking trails, boardwalks, scenic overlooks, interpretive signage, etc. in the NOI.
Stormwater Management Standards - What is the Dept. of Environmental Protection's (DEP) policy of using wetland basins for stormwater treatment? Why does this project qualify as a redevelopment project?
Section 1 Introduction: end of first paragraph "a new stormwater outfall is required" (Why is it required? Who required it?) ...to be constructed prior to sewer separation beginning in the upstream neighborhood."
During the stabilization period of the planted site, road runoff with high salt content can damage plant and animal life. Salinity and sediment should be monitored from road outfalls contributing to this system and prevented from entering the water. Plowing and location of snow piles are also critical because as snow from roads with salt melts, it releases toxic levels of salt. This is especially bad in the spring when plants and animals are young and most susceptible.
The sampling plan does not sample for TSS in the forebay. The inspection should be more frequent than once a year until the site is stabile and conditions are known.
What are the NPDES discharge requirements for this project?
The proponent should attach the EPA required Storm Water Pollution Prevention Plan to this NOI.
The NOI lacks a map of specific soil conditions, and knowledge of specific fill areas which may affect the ground water and the plantings. Show the soils coverage in relation to plantings. Will the soils support the plantings?
Is the Cambridge DPW subject to the Asbestos Bylaw? What soils/ contamination tests have been done?
Page 3-50. How will soil be dug, tested and removed? Has the soil been tested for its suitability to settle in stormwater without advanced treatment methods such as flocculation? This would let the Commission know whether silt fence, silt curtains will be adequate in preventing release of suspended solids.
The construction sequencing plan is good. It is difficult to review the document without the specifications and over-all lay out of the various contracts with sub-consultants. Who will be responsible for day to day environmental compliance, who will be inspecting for permit compliance? How are erosion control items priced?
Dust control methods are not discussed in the NOI.
What construction method will be used in Little River to construct the oxbow?
Will the tree roots in the channel affect water up take rate? Discuss the viability of the plantings for the specific locations, for the soils and orientation of the site. Elms and Hemlocks may be subject to diseases. Wouldn't plants more native to the site for the site to be more successful and require less maintenance? How will we be assured they will not run out of money for plantings and cut back?
There is not a monitoring plan for the invasive species. The invasive species in the upper meadows and other adjacent properties will need to be removed so that the constant seed source does not re-contaminate the newly planted site.
The ground water seems to have been monitored during a dry period or one rebounding from a drought. Additional data analysis of wells in the area should be compared to determine whether the hydrologic design is adequate. Provide more detail on the conditions of the ground water monitoring plan (frequency, duration)
Sedimentation and Erosion Control from Sheet No. L-1B, Sedimentation and Erosion Control Plan: East
Note #13. "Repairs to soil erosion control devices shall be completed within 2 days from notification." This is not acceptable. Repairs shall be made immediately upon notification from Owner's Representative, or Conservation Commission Agent, member or representative, or other entity so entitled.
16. "Erosion Control devices shall be checked once per week and after each rain fall" Please add - of 0.5 inches to ensure working order. A data sheet noting date, inches of rain, inspector, and site conditions and repairs made shall be kept and reported to the Commission.
What functions are provided by the two wetlands at the eastern border of the west end of the project site? Are these functions being compensated?
Fish & Wildlife
How will presently residing animals and birds and their habitat areas be assessed before construction takes place? Will there be any relocation of animals or re-creation of dens, any vernal areas, duck boxes?
Page 3-55. How does the water feature for mosquito control affect other aquatic insects? Please describe it.
The oxbow is good for fishes; won't they prefer a gravel substrate? Wouldn't project designers discuss or coordinate the depth and breath of Alewife spawning area with MA Div of Marine Fisheries
More care is also needed to keep sediment out of the water and adequate flow also in Sept. - Oct. as fish are migrating.
Is the flow rate of the stormwater discharge from the basin into the river steady enough for the Alewife?
Where is the money for training of DPW staff for maintenance? Is there a clear maintenance and monitoring plan?
Public education must be provided and be on-going. This should be clearly outlined and include regular postings on the web, newsletter, public meetings etc.
All neighbors in the watershed need to be held to high stormwater control standards for recharge and reuse of stormwaters. Education should be provided on rain garden construction, rain barrels and other innovative uses. Education for control of pollutants from properties is necessary as well. A fats, oil, and grease program was mentioned, how will this be conveyed to the public?
In summary, we are pleased to see a plan that can achieve a significant reduction in CSO discharges to Little River and Alewife Brook, but we believe that improvements can and must be made to protect the Alewife Reservation. The MWRA, City of Cambridge and the MDC must be more vigilant that high standards submitted from commenters to the Notice of Project Change be incorporated into the detailed designs to this project with such high impact on public parkland. Just as important, funding for continued monitoring, maintenance and repairs must be guaranteed.
Thank you for your close attention to these issues.