Date: January 21, 2008

 From: Sunrise Coalition
 Submitted by: Doug Schworer

Subject: Bradley Green Public Hearing Agenda 3, January 23, 2008

We thank the staff for a very useful meeting (January 3, 2008) to clarify the issues we have raised on stormwater.  The substance of that discussion addressed the nature of the eastern portion of the property around the Potted Plant and extending downslope towards I-40, where the drainage line had previously been determined to be intermittent by Fred Royal, then subsequently reclassified as not intermittent. We contribute the following comments on the Stormwater Management section of Roger Stancil’s Memorandum (Agenda Item Public Hearing: Bradley Ridge Application for Preliminary Plat Cluster Subdivision (File No. 9880-96-7441) dated January 23, 2008  regarding this meeting as reported by staff:

 

  1. We wish to clarify that WE OBSERVED ACTIVELY flowing water (NOT "STANDING WATER" AS INDICATED IN THE STAFF MEMO) ALONG THE ENTIRE LENGTH OF THE  SMALL STREAM AND WETLANDS ON THE EASTERN PORTION OF THE PROPERTY DURING AND AFTER THE RAIN EVENT ON DECEMBER 30, 2007.   FLOWING WATER IS A STRONG INDICATOR OF hydrologic CONNECTION TO THE PERENNIAL STREAM THAT FLOWS UNDER I-40, rather than simply OF residual "wet areas" or "standing water."  The flowing water continues through the northern boundary of the property and ENTERS AN area where a previous road or farm pond existed, and in the constructed side slope to I-40.    This is a wet, boggy area with high groundwater tables that is immediately adjacent to and drains into the perennial stream.  THE AREA CONTAINS EVIDENCE OF SURFACE FLOW, SPECIFICALLY SMALL CHANNELS THAT CONNECT DIRECTLY WITH THE PERRENIAL STREAM.  While the secondary determination that this was not an intermittent stream was based on UNSPECIFIED CRITERIA OF  connectivity, OUR OBSERVATIONS OF direct  connection OF THE INTERMITTENT CHANNEL INTO the wet area IMMEDIATELY adjacent to the perennial stream INDICATES THAT THE CLASSIFICATION OF THE INTERMITTENT CHANNEL SHOULD BE REVISITED.    Specifically, a determination SHOULD BE MADE of whether the channel, twice scored above the threshold for an intermittent channel, is connected through a wetland to the perennial stream. We note that the only parcels that may be in question until this determination can be made are #11, 12, 13 and potentially 14.
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  3. We noted that the current drainage line serves as a stormwater control.  If it is currently “disconnected” from the perennial stream, then the current volume and peak runoff is minimized.  The method presented of computing pre-development runoff conditions using the Rational Runoff approach assumes a connected drainage line, which overestimates the runoff relative to the current condition.  This may require a re-evaluation of the amount of post-development runoff production as required by LUMO.
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  5. We asked for clarification of the locations of the soil borings relative to the location of the proposed stormwater facility (stormwater pond #1).  These borings were arranged following the road system of a previous (not the current) design.  The locations of the soil boring approximated by engineering staff and Warren Mitchell on the current design map during the meeting. We understand that these will be combined on the same map for more detailed evaluation, but note that borings 6 and 7 are above the stormwater facility, while boring 5 is on the same elevation contour (although it is closer to the perennial stream).  The soil boring report specifically noted that seasonal groundwater tables in the area may fluctuate significantly from the conditions at the time of the borings, which appear to have been made during the summer of 2004, which was likely at a time of lower groundwater levels.
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  7. We are concerned that information on the environmental status of the land previously developed and used by Habitat is not available.  Specifically, a previous determination of more extensive wetlands were used as an overlay for the planning charette held at Carol Woods.  We have asked for this material to be made available, as well as any background investigations used for its production.  We understand these determinations may not be relevant as Army Corps is the regulatory agency.  However, the material used to generate those maps is relevant.  HHOC officials deny the existence of these maps and preceding material, and they, the town and HHOC’s architectural consultants who used this material to produce alternative designs for the charette state that they did not keep any of the information and have no knowledge of a study.  However, in our discussion at the meeting with town staff, Warren Mitchell stated that the consultant that produced these maps was in the field with him and Army Corps staff for the USACE site determination.   We are concerned that potentially important information is lost or is being withheld.
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  9. Both HHOC consultants and town staff indicated at the meeting that the source of any standing water and the wetland (non-regulatory) at the origin of the drainage line were due to drainage water from Potted Plant irrigation.  We do not agree with this, but if this is the case, nursery potting operations use substantial amounts of fertilizer and pesticides.  The area of the upper wetland and any area receiving substantial drainage from the former nursery should be tested for contamination before houses and recreational areas are developed.

 

We understand that the stormwater proposal is preliminary and that the nature of the BMPs has yet to be determined (e.g. infiltration basin, bioretention pond, wet detention pond) and its location has been drawn in as a placeholder.  On the development of the next phase of evaluation, we request that borings should be done in the specific locations of the proposed stormwater controls and that the nature of the connection of the drainage line and the pre and post-development runoff estimates be considered.   We suggest that action can be taken on parcels not subject to these determinations, but that action on parcels 11, 12, 13, 14 should be postponed until these issues are resolved.