Supplemental Information, DEP File #290-1048 Park Central, 0 Turnpike Road, Southborough, MA

Southborough Conservation Commission March 5, 2020 Southborough Town Hall 17 Common Street Southborough, MA 01772

Re: Supplemental Information, DEP File #290-1048 Park Central, 0 Turnpike Road, Southborough, MA

Dear Southborough Conservation Commission:

Goddard Consulting, LLC is pleased to submit this Full Re-Submittal Packet, on behalf of the applicant, Capital Group Properties, LLC and owner, Park Central, LLC, for (“Park Central”) DEP File #290-1048 located at 0 Turnpike Road in Southborough, MA.

Nine (9) copies of the documents have been included. Titles of all enclosed documents are as follows:

1. Response to Comments from LE Environmental Memorandum #4. Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, Mass DEP File #290-1048, Goddard Consulting LLC, 3/5/2020 2. [Figure] Location of Impact Areas, Park Central – Southborough, MA, Goddard Consulting LLC, 3/4/2020 3. Construction Document: Wetland Replication and Streambed Crossing Plan – Park Central, Goddard Consulting LLC, 1/9/2020 • Appendix A: Wetland Replication Checklist, Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, Mass DEP File #290-1048, Goddard Consulting LLC, 1/9/2020 • Appendix B: John Boland Wetland Replication Plan, 11x17 To Scale Plan, dated 3/5/2020 4. Snow Storage Exhibit, Bohler Engineering, LLC, 3/2/2020

Please feel free to contact us if you have any questions. Very truly yours, by

Scott Goddard, Principal & PWS

CC: • Wetlands Section, MassDEP Central Regional Office, 8 New Bond Street, Worcester, MA 01606 • William Depietri, Capital Group Properties, 259 Turnpike Road, Southborough, MA 01772

March 5, 2020 Southborough Conservation Commission Southborough Town Hall 17 Common Street Southborough, MA 01772

Re: Response to Comments from LE Environmental Memorandum #4 Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, DEP File #290-1048

Introduction

• February 20, 2020, Memorandum #4, Project Review – NOI , Park Central, MassDEP File #290-1048, Lucas Environmental, LLC.

Response to “Stormwater Management System Discussion” by LE:

Goddard disagrees with Lucas’s analysis on compliance with the Stormwater Standards. Most of the discussion is repeating previously submitted discussion.

LE fails to understand the basis for the question of compliance when it comes to the legal standing of the permitted and constructed stormwater basins and their continued function that was permitted and thereby cannot and has not been rescinded or revoked under the revised WPA regulations and Stormwater Standards.

LE omits the fact that the Commission in 1983 cited 310 CMR 10.00 in approved and issued Order of Conditions. Therefore the project was constructed under and allowed by 310 CMR 10.00. Therefore LE is incorrect that “the stormwater management system was not constructed in compliance with the provisions of 310 CMR 10.00.” and that “10 CMR 10.00 would not have allowed the stormwater basins to be constructed as approved in 1983. ”

Goddard believes the issue of stormwater compliance has repeatedly been sufficiently and thoroughly answered from a legal, technical, and performance standard prospective. No further comment is necessary.

Response to Numbered Comments by LE:

Original LE comments are restated in italics and underlined (were underlined in Memorandum #4), and, Goddard Consulting LLC responses are in bold.

All comments by Lucas with newest comment stating “LE has no further Comment…..”, “LE defers to Fuss & O’Neill…..”, “LE maintains its comment…”, “LE Maintains this recommendation”, “The Commission to discuss.” Or “See response to Comment….” are omitted, except when the applicant felt further response was needed for clarification.

LE Environmental Memorandum #4

Comment #8: The NOI states that the project is not subject to the By-law as the project has been classified under M.G.L. Chapter 40B; however, it is not clear if that applies to the entire project site. LE recommends the Commission seek a legal opinion or clarification from the Massachusetts Department of Housing and Community Development (DHCD). The Commission to discuss.

Previous Goddard Response: The Notice of Intent application was filed solely under the WPA. The Zoning Board voted on 8/24/16 to waive the Southborough Wetlands Protection Bylaw for the whole project.

As the Commission has engaged Special Counsel, LE recommends a legal opinion from said counsel be prepared for the Commission’s consideration.

Response: No decision of the ZBA with regards to the waiver of the Wetlands Bylaw has resulted in litigation.

Comment #11: LE has the following comments on notes and details provided on Sheet 33 of the project plans:

a. The project construction sequence lists building construction prior to installation of curbing and roadways. LE recommends the Applicant provide a more detailed construction sequence with accompanying detailed phasing plans.

Previous Goddard Response: The anticipated construction sequence lists building construction along with the installation of roadways and curbing. It is anticipated that the roadways will be brought up to subgrade and construction of units (foundations etc.) will commence at that time. Based upon the extent of the project it is anticipated that building work and roadway work will be ongoing simultaneously for portions of the project. 2 An Overall Construction Phasing Plan has been added to the Site Development Plans outlining the anticipated sequence of construction. See sheet 45, Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020

LE maintains its comment pertaining to the language contained on Sheet 33 of the project plans. LE recommends the Commission discuss the language provided on Sheet 45 of the Overall Construction Phasing Plan, specifically Items 1.16 and 1.17 of the Phase I description. The Applicant states “it is anticipated that unit construction will run concurrent with other sequences.” LE recommends the Commission discuss the need to specify under what circumstances unit construction may run concurrently. Furthermore, LE recommends the Overall Construction Phasing Plan state that disturbed soils shall be stabilized within 14 days of completion of temporary or final grading activities. The Overall Construction Phasing Plan lists three phases. However, Phases 2 and 3 are not differentiated on the plan. LE recommends the Applicant differentiate between all phases on the Phasing Plan.

Response: Phasing plan is consistent with SWPPP requirements. An updated Phasing Plan can be submitted as a condition of approval.

Comment #11c: Erosion and Sedimentation Note #13 states: “All areas within 100 feet of a flagged wetland or stream shall have an exposure window of not more than 7 days.” Although LE concurs with the concept of this note, LE recommends the Applicant re-affirm that such a requirement can be met throughout the construction of the project.

Previous Goddard Response: Note #13 has been revised to state all areas within 100 feet of a flagged wetland or stream shall be stabilized in accordance with the Stormwater Pollution Prevention Plan (SWPPP). See sheet 33, Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020.

LE finds the revised Note #13 to be satisfactory. However, LE maintains its recommendation that a draft SWPPP be submitted as part of the review of the application (see Comment #64).

Response: Applicant accepts LE recommendation in Comment #64 in regards to the SWPPP. The SWPPP will be submitted 30-days prior to construction.

Comment #13: Section 5.3 of the project narrative states that there are six (6) impacts in BVW. From a review of the plans, it appears only two direct BVW impact

3 areas are proposed. LE recommends the Applicant clarify total impacts and provide consistency throughout the report.

Previous Goddard Response: Narrative had a typo. There are only three (3) BVW impact areas.

1. John Boland Road, station 4+50 2. Webber Circle, station 11+75 3. Park Central Drive, station 34+00

See sheets 13, 16, 17, 40-42, Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020

The application remains inconsistent with regard to the total number of wetland impact areas proposed as part of the project. In their response, the Applicant states there are three BVW impact areas. However, in Section 4.1 of the Project Narrative, the Applicant states: “There will be a total of two wetland resource area locations that will be altered by the proposed project (see attached “Location of Impact Areas”). The attached “Location of Impact Areas figure identifies eight discreet “impact areas.” From a review of the site plans, LE identifies three discreet areas of direct BVW and/or Bank impacts. LE maintains its comment regarding the Applicant maintaining consistency throughout the report.

Response: Narrative corrections overlooked the paragraph in Section 4.1. LE is correct that there are three BVW impact areas. An updated version for “Location of Impact Areas” is enclosed. An updated figure was accidently omitted from the last submittal.

Comment #16: LE notes that the current condition of the site provides significant wildflower habitat, significant to pollinator species. LE recommends the Applicant provide a pre- and post- construction evaluation of wildflower habitat areas on the site.

Previous Goddard Response: WPA doesn’t regulate upland areas with wildflower habitat. Large areas of B-series pond are planned to be left undisturbed which are areas with wildflowers.

In recent years, the Town of Southborough has placed significant emphasis on the preservation of native pollinator habitat. Under the WPA, the Conservation Commission has jurisdiction of portions of the site which would appear to contain wildflower habitat, valuable to native pollinators. The Commission has discretion to require analysis of Buffer Zone areas to determine if work within said area will contribute to the protection of the

4 interests identified in M.G.L. c. 131, § 40. LE maintains its recommendation for the Applicant to provide a pre- and post- construction evaluation of wildflower habitat areas on the site within jurisdictional areas, which includes Buffer Zones.

Response: No further comment.

Comment #17: The Applicant should provide additional details on the mechanism for the preservation of the Open Space, and identify the area on the project plans.

Previous Goddard Response: The Open Space was created under the Agreement and Declaration of Restrictive Covenants, condition 7.2 Page 9 of 21 (Book 54292, Page 9). This is a recorded binding document.

LE recommends the Applicant submit a copy of the Agreement and Declaration of Restrictive Covenants for the record file. LE maintains its recommendation that the limits of the Open Space parcels be depicted on the project plans.

Response: No further comment. See submitted Site Plans Sheets 1, 4, 11 and 12.

Comment #18: The Alternatives Analysis submitted with the previous site design should be submitted as part of this NOI.

Previous Goddard Response: The previous alternative analysis is attached. See “Park Central Alternatives Analysis (MassDEP File #: 290-0981) 0 Turnpike Road, Southborough, MA”, Goddard Consulting LLC 6/14/16. It should be noted impact areas have changed. In addition, wetland impacts have been significantly decreased at the 2 impact areas.

The Applicant’s response states “wetland impacts have been significantly decreased at the 2 impact areas.” LE notes there are currently three BVW impact areas and one BLSF impact area. LE has no further comment.

Response: See above response to #13.

Comment #19. The Applicant should confirm that the Massachusetts Department of Transportation was notified as an abutter, particularly with the work proposed near the outfall near Interstate 495 within Wetland AA/BB.

The applicant gave notice to all abutters listed in the certified abutters list as required by the WPA. Nevertheless the applicant has had informal meetings with MassDOT and MassDOT is expected to issue a permit for construction once the local project approvals are issued.

5 LE recommends the Commission include a Special Condition in any Order of Conditions that requires a copy of any permits/agreements with MassDOT be provided to the Commission prior to the start of construction.

Response: Applicant is willing to accept the above as a condition of approval.

Comment #20: The Applicant has provided documentation of the presence of five discreet vernal pool habitat areas on the site, based upon studies performed in the spring of 2019. Portions of IVW R (5), and BVWs D (2), F (1), and R (4) have been identified as vernal pools. The limits of the vernal pool habitat areas are shown on the site plans for Areas 1, 4, and 5. LE recommends the limits of the vernal pool habitat be depicted on the project plans for area 2 as well. LE further recommends the Applicant depict a 100-Foot Buffer Zone around the vernal pool habitat areas to demonstrate compliance with Standard 6 of the Stormwater Management Policy Standards.

Previous Goddard Response: Goddard has field delineated the boundary of vernal pool 2 (within D series wetland) and site plans show the delineated vernal pool and 100-foot buffer associated with it. The Project is in compliance with Stormwater Management Standard 6 except for BMPs that only treat off-site stormwater from Route 495 and Blackthorn Drive. This is to improve the water quality within the wetlands over and above existing conditions. See Sheet 17, Site Development Plans for Park Central. Prepared by Bohler Engineering, 1/9/2020

LE performed a site inspection on February 12, 2020 to inspect the flagged limits of Vernal Pool #2. LE could find no evidence of flagging in the vicinity of the vernal pool. BVW flags were also missing in the area. LE did note that the extent of standing water observed during the inspection appears to be larger than that shown on the project plans. LE recommends the Applicant revisit the site and flag all areas of open water that are likely to serve as vernal pool habitat within Wetland D. Upon completion of survey of the Vernal Pool #2 boundary (and modification of associated Buffer Zone), LE recommends the stormwater management design be modified to remove any portion of the stormwater management basin from the Buffer Zone of Vernal Pool #2. It appears there may be sufficient room to modify grading to avoid vernal pool Buffer Zone impacts.

Response: Flagging was hung and surveyed. Deer are suspected as the culprit of flags disappearing. Flags have been re-established with wooded stakes.

6 Comment #21: During the previous application, the Goddard Consulting indicated there were additional potential vernal pool survey dates in 2016. LE recommends the documentation be submitted for review, particularly for Area 3.

Previous Goddard Response: Goddard has attached additional photos from the spring of 2016. See “Vernal Pool Documenting Photos, Park Central, Spring 2016” by Goddard Consulting LLC. From Goddard’s review of its files, it appears that no photo documentation was taken at Area 3. Mark Arnold (present during one of the 2016 VP checks) doesn’t recall any vernal pool species findings in Area 3 when he was onsite). Site visits occurred as following:

• Renee McDonough, March 7, 8, 9, 10, 11, 18, May 19, 20, 2016. • Julie Lisk, March 11, 25, 2016. • Dan Wells, March 16, 2016, March 27, April 2, 12, 17, 22, 25, 2019. • Mark Arnold, March 11, 2016.

The Applicant’s vernal pool observations documentation is inconsistent. The above response states that Area 3 was inspected by Mr. Arnold during one site inspection (presumably March 11, 2016). However, the Applicant’s “2019 Vernal Pool Survey Report,” dated April 19, 2019 (included as Appendix E) states: “I did not observe any evidence of breeding by obligate or facultative species on any of the four survey dates.” LE recommends the Applicant submit any field notes verifying Mr. Arnold’s (and other’s) recollection or inspections. Based upon the fact that Mr. Arnold visited Vernal Pool #3 only one time (early in the season), his observations appear to be limited. LE recommends the Commission enquire as to if Area 3 was, in fact, inspected on other dates or not. As the question of adequate inspections of Area 3 is in doubt, LE recommends Area 3 be inspected in the spring of 2020 for the presence of vernal pool indicator species use and documentation be submitted to the Commission for review.

Response: LE is confusing the statements from the year “2016” and “2019” surveys. Note that “Area 3” was surveyed 6 times in 2019 by Dan Wells and therefore clearly and adequately documented that area not being a vernal pool. Below are photos of this area from March 4, 2020 confirming Goddard’s previous conclusion that this area is not a vernal pool.

Photo 1: Looking northeast at R24 to R29 "Area 3", 3/4/2020

Photo 2: Looking southwest from R24 to R29 "Area 3", 3/4/2020

Photo 3: Looking northwest from R24 to R29 "Area 3", 3/4/2020

Comment #22: LE notes that the Existing Land Cover Types figure included with the application does not depict all five of the vernal pools identified on the project site. LE recommends the figure be revised.

Previous Goddard Response: Goddard has updated the figure. See attached “Proposed Buffer Zone Impacts, Park Central, Southborough, MA”, dated 1/9/2020

The figure has been revised to depict four vernal pools. Vernal Pool Area 3 remains in question (see Comment #21).

Response: No further comment.

Comment #23: The site plans depict the following proposed activities within 100 feet of the vernal pool habitat on the site:

a. Construction of stormwater managements BMPs and a portion of the Blackthorn Drive Extension roadway within 100 feet of Vernal Pool Area 1.

Previous Goddard Response: The revised plans have reduced proposed work around Vernal Pool Area 1 to protect the upland near the vernal pool. The revised plans show that all BMPs within 100-feet of Vernal Pool 9 Area 1 are to upgrade the existing BMPs for Blackthorn stormwater runoff. The upgraded BMPs are for stormwater overflowing from Vernal Pool 1 and the catch basins from Blackthorn. The BMPs will not discharge to the vernal pool and will improve water quality. See Sheet 17, Site Development Plans for Park Central. Prepared by Bohler Engineering, 1/9/2020

The Applicant has calculated that 17.2% of the vernal pool Buffer Zone to Vernal Pool Area 1 will be lost as a result of the project. LE recommends the Commission discuss if the proposed work within the vernal pool Buffer Zone has been minimized to the extent practicable, and if so, if the Applicant has provided adequate mitigation to offset impacts to wildlife habitat associated with Vernal Pool Area 1. LE notes that a significant portion of the “undisturbed” vernal pool Buffer Zone to Vernal Pool Area 1 is vegetated wetland, which likely does not serve the same habitat functions as adjacent upland habitat.

Response: As the Massachusetts Wildlife Habitat Protection Guidance for Inland Wetlands states we are not proposing any work within vernal pool wildlife habitat. Per page 7, Section “F. Vernal Pool Habitat” it states “Vernal pool habitat does not extend into non-jurisdictional upland or in the buffer zone of a resource area. [Emphasis added]”

Comment #23b: b. Construction of stormwater management BMPs, portions of the Park Central Drive roadway, a maintenance shed and dumpster, covered parking structures, and a pocket park within 100 feet of Vernal Pool Area 2.

Previous Goddard Response: The revised plans have reduced work around Vernal Pool Area 2 to protect the upland near the vernal pool. All the stormwater BMPs have been moved outside the 100-foot setback from the vernal pool except for the proposed stormwater forebay for off-site untreated stormwater which will improve water quality by pre-treating it prior to entering the wetland. The proposed shed and dumpster have also been removed from the 100-foot setback to the vernal pool. See Sheet 17, Site Development Plans for Park Central. Prepared by Bohler Engineering, 1/9/2020

Although the Applicant has reduced impacts within the Buffer Zone to Vernal Pool Area 2, portions of the surrounding uplands remain to be altered. The Applicant has calculated that 36.3% of the vernal pool Buffer Zone to Vernal Pool Area 2 will be lost as a result of the project. LE recommends the Commission discuss if the proposed work within the vernal pool Buffer Zone has been minimized to the extent practicable, and

10 if so, if the Applicant has provided adequate mitigation to offset impacts to wildlife habitat associated with Vernal Pool Area 2. LE notes that a significant portion of the “undisturbed” vernal pool Buffer Zone to Vernal Pool Area 2 is vegetated wetland, which likely does not serve the same habitat functions as adjacent upland habitat.

Response: See response to #23a.

Comment #23c: c. Construction of three residential buildings within 100 feet of Vernal Pool Area 4.

Previous Goddard Response: Acknowledged.

The Applicant has made no modifications to the project plans to reduce impacts to Buffer Zone areas to Vernal Pool Area 4. The Applicant has calculated that 29.4% of the vernal pool Buffer Zone to Vernal Pool Area 4 will be lost as a result of the project. LE recommends the Commission discuss if the proposed work within the vernal pool Buffer Zone has been minimized to the extent practicable, and if so, if the Applicant has provided adequate mitigation to offset impacts to wildlife habitat associated with Vernal Pool Area 4. LE notes that the remaining upland area to Vernal Pool Area 4 is between the vernal pool and Interstate 495.

Response: See response to #23a.

Comment #23d: d. Construction of two residential buildings within 100 feet of Vernal Pool Area 5.

Previous Goddard Response: Acknowledged.

The Applicant has made no modifications to the project plans to reduce impacts to Buffer Zone areas to Vernal Pool Area 5. The Applicant has calculated that 33.5% of the vernal pool Buffer Zone to Vernal Pool Area 5 will be lost as a result of the project. LE recommends the Commission discuss if the proposed work within the vernal pool Buffer Zone has been minimized to the extent practicable, and if so, if the Applicant has provided adequate mitigation to offset impacts to wildlife habitat associated with Vernal Pool Area 5.

Response: See response to #23a.

Comment #23-end: LE recommends the Applicant provide an Alternatives Analysis to describe why these features cannot be constructed outside of the 100-Foot Buffer Zone to the vernal pool areas.

11 Previous Goddard Response: WPA and its regulations does not require an alternatives analysis for the features shown on the revised plans. See Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020.

Under Section 10.03(1)(a) of the WPA, “Any person who files a Notice of Intent to perform any work within an Area Subject to Protection under M.G.L. c. 131, § 40 or within the Buffer Zone has the burden of demonstrating to the issuing authority:

1. that the area is not significant to the protection of any of the interests identified in M.G.L. c. 131, § 40; or 2. that the proposed work within a resource area will contribute to the protection of the interests identified in M.G.L. c. 131, § 40 by complying with the general performance standards established by 310 CMR 10.00 for that area. 3. that proposed work within the buffer zone will contribute to the protection of the interests identified in M.G.L. c. 131, § 40, except that proposed work which lies both within the riverfront area and within all or a portion of the buffer zone to another resource area shall comply with the performance standards for riverfront areas at 310 CMR 10.58. For minor activities as specified in 310 CMR 10.02(2)b.1. within the riverfront area or the buffer zone to another resource area, the Department has determined that additional conditions are not necessary to contribute to the protection of the interests identified in M.G.L. c. 131, § 40.”

Although the regulations do not specifically cite the requirement for an alternatives analysis, the issuing authority (i.e., the Southborough Conservation Commission) is tasked with requiring an Applicant to demonstrate that proposed work will contribute to the protection of the interests of the WPA. LE recommends the Applicant demonstrate that the proposed work within the Buffer Zone to known vernal pools will not impact said vernal pools. LE is primarily concerned with the loss of non- breeding upland habitat for obligate and facultative vernal pool species. LE believes that demonstrating alternatives is part of a comprehensive analysis.

Response: In light of the WPA and Massachusetts Wildlife Habitat Protection Guidance for Inland Wetlands, an alternative analysis is not applicable for work within buffer zone to vernal pools.

Comment #24: LE is concerned that the development surrounding the pools associated with Wetland R (4 & 5) may isolate the features from other regulated

12 wetland resource areas that the vernal pools species are migrating to/from and have an adverse impact on wildlife habitat. LE is also concerned the most of the upland surrounding the pool associated with Wetland D (2) is proposed for development, which will have an adverse impact on the amphibians utilizing the adjacent upland areas. The Applicant should consider re-examining the design at these locations to avoid adverse impacts to the vernal pools and wetland dependent wildlife as part of the Alternatives Analysis.

Previous Goddard Response: The revised plans have reduced work around wetland D to protect the upland near the vernal pool. All stormwater BMPs have been removed from the 100-foot setback to the vernal pools except for a small portion of the proposed stormwater forebay for off-site untreated stormwater from Route 495 and Blackthorn Drive which will improve water quality by pre-treating it prior to entering the wetlands. The vernal pool within BVW R still has direct connections to other regulated resource areas, isolated wetlands and the upland slopes along 495. No impacts to Resource Areas are proposed in the area of the vernal pools and proposed work in the Buffer to the vernal pools has been designed to minimize work within 20-feet of the wetlands. See Sheet 14, 17, Site Development Plans for Park Central. (61 sheets) Prepared by Bohler Engineering, 1/9/2020.

See Comment #23 above.

Response: In light of the WPA and Massachusetts Wildlife Habitat Protection Guidance for Inland Wetlands, an alternative analysis is not applicable.

Comment #25: LE recommends the Applicant demonstrate that the project will not adversely impact the hydrology of each vernal pool. LE further recommends the Applicant provide pre- and post-construction conditions of non-breeding forested habitat within the 100-foot Buffer Zone of each vernal pool. LE recommends the Applicant describe if the project will alter migratory pathways of obligate vernal pool species between non- breeding habitat and the vernal pools as well as overland connections between the vernal pools on the site.

Previous Goddard Response: See section 5.7 of the Project Narrative – Park Central, Goddard Consulting LLC, 1/9/2020.

The Applicant states that “Under the WPA, vernal pool habitat is within 100-feet of the vernal pool if the vernal pool is within a Resource Area.” More accurately, under Section 10.04 of the WPA regulations, Vernal

13 Pool Habitat “means confined basin depressions which, at least in most years, hold water for a minimum of two continuous months during the spring and/or summer, and which are free of adult fish populations, as well as the area within 100 feet of the mean annual boundaries of such depressions, to the extent that such habitat is within an Area Subject to Protection under M.G.L. c. 131, § 40 as specified in 310 CMR 10.02(1). These areas are essential breeding habitat, and provide other extremely important wildlife habitat functions during non breeding season as well, for a variety of amphibian species such as wood frog (Rana sylvatica) and the spotted salamander (Ambystoma maculatum), and are important habitat for other wildlife species.”

Although the Applicant provides calculations purportedly demonstrating that there will be no change to the hydrology of the vernal pools, there is no discussion with regard to the potential loss of non- breeding habitat, migratory pathways, and overland connections that may exist surrounding and between vernal pools on the project site. The Applicant has not provided any evidence that the project will not adversely impact the resource areas associated with the vernal pools. LE recommends the Applicant provide evidence to demonstrate that the project will not adversely impact the “extremely important wildlife habitat functions” provided by the Buffer Zones associated with the vernal pools. If the Applicant wishes to demonstrate that non-breeding habitat of obligate vernal pool species is not within the proposed development areas within jurisdictional areas, LE recommends a pitfall trap study be developed and implemented in the spring of 2020 to document the direction of incoming amphibians to the vernal pool areas.

Response: In light of the WPA and Massachusetts Wildlife Habitat Protection Guidance for Inland Wetlands, an alternative analysis is not applicable.

Comment #33: The Applicant has quantified the proposed area of LUWW proposed to be restored as part of the project. LE recommends the Applicant provide quantification of anticipated lengths of Bank to be restored and describe if there are opportunities for BVW restoration within these areas.

Previous Goddard Response: The site plans quantify the LUWW proposed to be restored. The WPA Form 3 has also been revised to reflect the restoration number. See sheets 42 and 43 of the Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020

LE recommends the Applicant consider relocating the proposed Wetland Replication Area #3 (Park Central Drive). As the Applicant is proposing a

14 stream daylighting activity immediately adjacent to the impact area, LE recommends that the BVW mitigation be constructed in association with the restored stream channel, between Wetlands E and G, rather than disturbing an entirely separate area. LE believes constructing the BVW mitigation in concert with the channel restoration has the potential to result in higher value mitigation than if the areas were to be constructed independent of one another.

Response: Wetland replication adjacent to the stream restoration, although considered and re-reviewed by Goddard and Bohler, is unfortunately not practicable. The proposed restored stream location, channel and bank elevations to grade the restored stream to naturally join the upgradient and downgradient natural stream channels conflict with the existing delineated wetlands in the surrounding area, which prevents a natural and robust wetland hydrology within any potential replication area. This possibility was therefore dismissed as a viable option to comply with the performance standards for wetland replication under the WPA.

Comment #34: The Section Views of each of the wetland crossings depict the use of “stacked fiber logs” within the crossing. LE recommends the Applicant provide additional detail on the materials and installation of such materials.

Previous Goddard Response: Straw wattles will be used. See sheet 40, Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020

LE recommends the use of coir logs for stream bank stabilization in lieu of straw wattles. Typical straw wattles are not designed for stresses related to stream flows. In LE’s experience, coir logs are a preferred BMP.

Response: Applicant is willing to accept the requirement of coir logs at the crossings as a condition of approval.

Comment #35: The Applicant is proposing the daylighting of two segments of existing culverted stream channel on the site. Daylighting may afford the opportunity for meaningful restoration of both Bank and BVW in the area. Although the Applicant has provided detailed plans on the box culverts proposed in association with the proposed daylighting (at Stations 1+15 and 31+25), there are no details on the stream channel restoration itself. LE recommends detailed engineering design of the restored stream channels be submitted. Stream restoration design should be prepared by a

15 qualified fluvial geomorphologist with experience in stream restoration design.

Previous Goddard Response: For Park Central Drive, the proposed stream restoration is replacing a 24” concrete culvert. The proposed 8-foot Box Culvert detail shows a stream width (from bottom of bank) at 4.5-feet, 12- inch bank depth with a 2:1 slope were conditions allow to provide necessary bank capacity as modeled by Bohler Engineering. For the stream restoration (removing oversized 36” twin culverts) from E-series to G-series the proposed stream detail shows a stream width (from bottom of bank) at 6-feet, 12-inch bank depth with a 2:1 slope were conditions allow to provide necessary bank capacity as modeled by Bohler Engineering. Both streams have been modeled by Bohler Engineering to confirm needed widths, with site characteristics expanding width to blend with natural bank width conditions. See the Wetland Replication and Streambed Restoration Plan by Goddard Consulting LLC, 1/9/2020, Site Development Plans for Park Central. (61 Sheets) prepared by Bohler Engineering, 1/9/2020 and Drainage Report, Bohler Engineering, 1/9/2020.

LE defers to Fuss & O’Neill for review of engineering calculations provided pertaining to the sizing of the proposed stream channels depicted on Plan sheets 42 and 43. Both the project plans and project narrative remain deficient in the level of detail provided for successful restoration of the stream channels. Although the plan set includes a typical cross sectional detail, it does not include any notes pertaining to the proposed channel substrate. The narrative describes utilizing topsoil from the area to be excavated above the existing culvert pipes. Such soil is not suitable for stream bed substrate. The construction narrative describes the channel to be constructed as “gentle and meandering” but provides no greater detail on the creation of valuable stream characteristics such as pool-riffle complexes or appropriately designed sinuosity (based on anticipated flows). LE recommends the stream channel design be reviewed and updated by a qualified fluvial geomorphologist and include details such as design reference sites, proposed bed specifications (including substrate type, proposed source of materials, and material sizing), inclusion of geomorphic features and stream restoration BMPs, and temporary stabilization measures. LE believes that comprehensive and qualified design (and construction) is essential to long-term success of stream restoration efforts.

Response: The revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated

16 March 5, 2020 provides for further details on stream restoration and stream substrate.

Comment #38: The Applicant should demonstrate that the impacts to the BVW, Inland Bank, and Buffer Zone will have no adverse impact to the interests identified under Section 310 CMR 10.01(2) of the WPA.

Previous Goddard Response: See the documents included in this response submittal which provide the information to document no adverse impacts.

LE defers to the Conservation Commission to decide of the Applicant has substantially met the requisite performance standards for direct alterations of BVW, Bank, LUWW, and BLSF through the proposed mitigation areas (pending additional recommended modifications described herein). However, LE recommends the Commission also consider the scope and locations of proposed Buffer Zone alterations. LE believes that such alterations have the potential to cause adverse impacts to the interests of the Act, as currently proposed.

Response: See response to #23 and #25.

Comment #39: The Applicant should assess all temporary impacts at each Impact Area.

Previous Goddard Response: No temporary impacts have been assessed, as permanent impacts have been assessed for all impact areas within the limits of work. Restoration of any areas temporarily impacted within the limit of work will be assessed by the wetland scientist supervising the work within the impact areas. At this time all impacts have been assumed to be permanent. See the Wetland Replication and Streambed Restoration Plan by Goddard Consulting LLC, 1/9/2020.

Although the Applicant may be considering all wetland resource area impacts to be permanent, the fact remains that a portion of the impacts are temporary. As such, they should be adequately restored in order to minimize permanent impacts. LE recommends the Applicant provide a detailed narrative and plan description depicting how temporary impacts will be restored. In particular, LE recommends a robust plan be prepared for the temporary impacts associated with Impact Area #3 (within Wetland E). Within this area, it appears there is approximately 600 square feet of disturbed area that can be restored to wetland functionality.

Response: All wetland losses are accounted for in this NOI filing with required mitigation provided. If additional BVW can be restored at the time of construction it will be restored as an added benefit.

17 Comment #40: The application includes a discussion of Regulatory Compliance Standards (Section 5). Within this section of the application, the Applicant reviews the specific performance standards for BVW (per 310 CMR 10.55(4)(b)). LE recommends that the responses provided for each performance standard include greater specificity as to how the standards are met, including areas, elevations, etc. LE recommends a similar narrative be provided for the specific performance standards for Inland Bank and Land Under Water Bodies and Waterways.

Previous Goddard Response: See the documents included in this response submittal which provide the information to document compliance with applicable performance standards.

The Applicant has provided a partial performance compliance analysis for project impacts. LE maintains its comment and recommends the Commission require a complete and detailed analysis for all resource area performance standards.

Response: Applicant can only address a specific comment. This comment is non- specific. Information provided by Goddard and Bohler is in compliance with the required regulations.

Comment #42: LE recommends that the Applicant include a completed MassDEP Replication Guideline Checklist. Although some of the checklist items have been submitted, it appears that many of the requirements listed in the checklist have not been submitted. For example, the proposed Wetland Crossing Plan and Profile does not appear to include any cross-sectional plans to guide the construction of the mitigation areas. Such plans are critical to the review and implementation of the design. It is the experience of LE that a plan sheet dedicated to the proposed wetland mitigation is valuable for both review and eventual construction of the area. Such a dedicated plan should also include all proposed notes, details, specifications, and planting schedules. LE recommends the Applicant provide a completed checklist, demonstrating that each item listed on the checklist is included in the application or provide reasoning as to why such information is not included. It is LE’s experience that having multiple “report-type” documents may be useful during the permitting phase of a project, but is not recommended during bidding and construction of the project.

Previous Goddard Response: See the attached Wetland Replication Checklist Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, Mass DEP File #290-1048 by Goddard Consulting LLC, dated 1/9/2020.

18 LE has reviewed the Checklist submitted by the Applicant. Although most of the items have been submitted, LE recommends the Applicant provide greater detail with respect to the cross-sections of the proposed mitigation areas. According to the checklist, the cross-sections should include “subsurface soil types, depths, and locations, 100-year floodplain using both horizontal and vertical scale, existing and predicted high and low water groundwater elevation, perched water conditions and other indicators of hydrology.” Additionally, based on the checklist item related to preservation of mature trees within mitigation areas, LE recommends the mitigation construction notes be amended to include an action item that the wetland scientist inspect the area prior to tree clearing to identify any mature vegetation to be preserved.

Response: The revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 provides for further details on the replication cross sections.

Comment #43: LE recommends that the wetland mitigation plan(s) include details on proposed restoration of Buffer Zone areas disturbed as part of the wetland replication construction efforts. Plans should depict grading, as well as plantings with appropriate native species that will provide adequate slope stabilization.

Previous Goddard Response: The Wetland Replication and Streambed Crossing Plan – Park Central by Goddard Consulting LLC, 1/9/2020 [superceeded] states that conservation seedmix will be used on graded slopes around the replication area to naturalize slopes. Site plans show grading around replication area. See sheets 40-43, Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020.

LE recommends the Commission discuss if seed mix alone is satisfactory for stabilization of Buffer Zone areas upgradient of wetland replication areas. Due to the proposed extensive disturbance of Buffer Zone across the site (including within 100 feet of several vernal pools), LE recommends the Commission consider requiring planting of woody species within disturbed areas of Buffer Zone. Such plantings provide a vegetative buffer to the replication area as well as reduce the likelihood of colonization by invasive species. At a minimum, conservation seed mixes should include a nurse seed to provide rapid vegetative stabilization.

Response: The revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated

19 March 5, 2020 provides details on plantings (trees and shrubs) within the access path of the replication to mimic natural Buffer Zone.

Comment #44: Grading associated with proposed wetland mitigation areas is not depicted on the Grading and Drainage plan sheets. LE recommends such proposed grading be shown.

Previous Goddard Response: Site Plan sheets 13-19, 40-43 for details on grading. See Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020.

LE recommends that if the scale does not allow grading to be shown on the plans, each wetland mitigation area should be better called out on the Grading and Drainage plan sheets.

Response: Please see Sheets 1-19, 40-43 of the site plans. Details were provided as necessary.

Comment #45: Any proposed plantings within replication areas should not include any cultivars. The Massachusetts Programmatic General Permit (PGP) does not permit plantings of cultivars in mitigation. LE recommends consistency with the current MA PGP.

Previous Goddard Response: No response necessary.

LE recommends a Special Condition be included in any Order of Conditions specifying the requirement that no cultivars be used within the wetland mitigation areas.

Response: No further comment.

Comment #46: The replication design includes specification for ranges of organic content in soils (12-20%). LE recommends that all proposed soils be tested to determine actual organic content by a qualified laboratory.

Previous Goddard Response: Goddard has revised Wetland Replication and Streambed Crossing Plan – Park Central, by Goddard Consulting LLC, 1/9/2020 to include this requirement.

LE could find no mention of the requirement for laboratory testing of soils to ensure adequate organic content in the Wetland Replication and Streambed Crossing Plan. LE recommends a Special Condition be included in any Order of Conditions specifying such testing of wetland

20 mitigation area soils, and revise the plan to include this note in the specifications.

Response: The revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 provides the following language “NOTE: Organic content must be tested by a qualified laboratory to confirm organic content in soils (12-20%).”

Comment #47: LE recommends the Applicant provide test pit data for each proposed wetland replication area. Such data is necessary to determine the depth necessary for excavation to achieve wetland hydrology. Test pits may be advanced by machine or by hand, as long as suitable depth is achieved and relevant data collected.

Previous Goddard Response: Goddard has reviewed area and soils. Each area has natural subsoils and hydrology or the area shows hydrology is in the area. The following documentation was collected:

• John Boland wetland replication area (Wetland Flags C50/C51) o Test Pit Location: upgradient of stonewall. Adjacent dry stream/BVW o 0-18", Ap, 10YR3/4, sandy loam o 18-28", Bw, 7.5YR4/6, sandy loam o 28-39", BC, 10YR5/6, sandy loam o 39-46", C, 10YR5/3, sandy loam o Conclusion: Soils conditions are natural. Ground water is present deeper, but is similar elevation to delineated and peer reviewed wetland. Replication will replicate conditions of existing wetland.[superseded see below soil profile in response] • Webber Circle wetland replication area (wetland flags M34 to M37- 13) o Test Pit Location: center of replication area. o 0-12", Ap, 10YR3/3, sandy loam o 12-18", C, 10YR5/2, sandy loam Redox, 5YR4/6 Standing water at 12” • Park Central Drive wetland replication area (Wetland Flags G1/G2) o Test Pit Location: 20-feet upgradient of wetland line (G1/G2), o 0-16”, Fill, sandy gravel (10YR4/4 o 16-20”, Cd,10YR5/2, sandy loam Weeping at 16” Redox 7.5YR5/8

21 The test pit information for the John Boland Road wetland replication area indicates that groundwater is not likely to be encountered in the excavation of the mitigation area. The existing BVW fringe of the channel is likely hydrologically supported by overland flows from the stream, not interception of groundwater. The proposed shape of the wetland replication area is not comparable to the impact area and is not likely to benefit from the same overland hydrological conditions. LE recommends the Applicant describe how the area will become a functioning wetland under the current design if suitable wetland hydrology is unlikely to be encountered. As needed, the design of the John Boland Road replication area should be revised. Suitable hydrological conditions appear to exist for the other two proposed mitigation areas.

Response: The revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 has been updated to show the John Boland wetland replication area on the northwest side of the crossing. Replication will be along the front of the retaining wall and will thereby minimize disturbance of upland forest.

• New John Boland wetland replication area o Test Pit Location: 4-feet upgradient of wetland line (Wetland Flags C15/C14). Stream flowing o 0-6", Ap, 10YR2/2, sandy loam o 6-24", Bw, 10YR3/6, sandy loam o 24-36+", BC, 10YR3/3, sandy loam Standing water at 24” Redox 10YR6/8

Comment #49b: At Crossing #2 (Webber Circle), the entirety of the proposed mitigation area is currently infested with Japanese knotweed (Fallopia japonica). Unless the Applicant is fully committed to eradication of the knotweed in all areas surrounding the proposed mitigation area, LE recommends a different location be found. In LE’s experience, knotweed can quickly overtake disturbed soils such as those found in wetland mitigation, resulting in significantly lowered value of the constructed replacement wetland.

Previous Goddard Response: The applicant has (At LE’s request) chosen a different location, with the understanding that this is approvable by LE. The location is therefore proposed in an upland finger that has wetlands on 2-sides adjacent to M34 to M37-13. This area has no Japanese Knotweed nearby and therefore should be able to establish and function better than the impacted wetland does currently.

22 LE notes that LE made no “request” to relocate the Webber Circle wetland mitigation area, only the Commission consider it. LE advised the Commission of the existing infestation of invasive species in the area and recommended that a preferable location be found. LE performed an inspection of the revised location of the Webber Circle mitigation area and found the conditions to be acceptable for construction of replicated wetlands.

Response: No further comment.

Comment #51: The By-law requires 2:1 mitigation for wetland impacts. The Applicant proposes roughly 1:1 mitigation. The Commission to discuss as 2:1 was proposed in the previous application.

Previous Goddard Response: Project complies with the WPA 1:1 replication requirements. Replication areas have been designed to meet the 2:1 ratio where possible, for example at Webber Circle. The replication areas at John Boland Road and Park Central Drive are closer to 1:1 to minimize the disturbance of additional buffer zone near the project work.

LE recommends the Commission discuss if the quantity of proposed mitigation is adequate to meet applicable performance standards.

Response: No further comment.

Comment #57: The Applicant should quantify the impacts within the 100-Foot Buffer Zone. The total acreage of the Buffer Zone within the site (excluding the Open Space areas) should be quantified to examine the potential impacts of the entire site development.

Previous Goddard Response: The attached “Proposed Buffer Zone Impacts– Park Central”, Goddard Consulting LLC, 1/9/2020 shows that the project will permanently disturb 764,694 SF of Buffer Zone and leave undisturbed 779,515+ SF of Buffer Zone of the delineated wetlands. Note that these numbers do quantify temporary disturbance for wetland replication, stream restoration, BLSF compensatory storage and access to these areas.

23 1. that the area is not significant to the protection of any of the interests identified in M.G.L. c. 131, § 40; or

2. that the proposed work within a resource area will contribute to the protection of the interests identified in M.G.L. c. 131, § 40 by complying with the general performance standards established by 310 CMR 10.00 for that area.

3. that proposed work within the buffer zone will contribute to the protection of the interests identified in M.G.L. c. 131, § 40, except that proposed work which lies both within the riverfront area and within all or a portion of the buffer zone to another resource area shall comply with the performance standards for riverfront areas at 310 CMR 10.58. For minor activities as specified in 310 CMR 10.02(2)b.1. within the riverfront area or the buffer zone to another resource area, the Department has determined that additional conditions are not necessary to contribute to the protection of the interests identified in M.G.L. c. 131, § 40.”

LE recommends the Commission discuss if the proposed work within the Buffer Zone will contribute to the protection of the interests identified in the WPA. If the Commission is not satisfied that the Applicant has met the standard, LE recommends the Commission advise the Applicant to revise the project design to reduce Buffer Zone impacts.

Response: No further comment.

Comment #59: The By-law requires an alternatives analysis for work within the 20-Foot No Disturb Zone. The Commission to discuss.

Previous Goddard Response: No response necessary. The Project is not filed under the Bylaw. Nevertheless the applicant has designed the proposed work to avoid all work in the 20-foot Buffer Zone for all units and buildings. The project has also been designed to avoid isolated vegetated wetlands (IVW) not protected under the WPA and the 20-foot Buffer around he IVWs.

LE maintains its recommendation for the Commission to further discuss the need for an alternatives analysis for work within the 20-Foot No Disturb Zone. See response to Comment #8.

Response: Not applicable. The 20-foot buffer is a bylaw consideration, which does not apply to this project.

24 Comment #60: LE notes the following work within the 20-Foot Buffer Zone (not including the two wetland crossings):

a. Sheet 13. A portion of John Boland Road, adjacent to wetland flags WF C8 through WF C12.

Previous Goddard Response: Acknowledged. It should be noted that each of these impacts is for site roadway access. Other work is strictly for off- site stormwater mitigation onsite, stream restoration, BLSF compensatory storage, stream restoration and wetland replication.

LE notes the Applicant has not modified the design to reduce or eliminate this impact.

Response: LE’s original comment noted only work within 20’ of the wetland and the applicant acknowledged. The road has been designed with a retaining wall to minimized impacts to the Resource Areas and Buffer Zone.

Comment #60b: Sheet 16. A portion of the grading associated with Webber Circle, adjacent to wetland flags WF O13 through WF O15.

LE notes the Applicant has not modified the design to reduce or eliminate this impact. LE recommends the Applicant extend the retaining wall associated with the wetland crossing #2 (Webber Circle) to the north to further minimize impacts to the 20-Foot No Disturb Area in the vicinity of wetland flags O13 through O15.

Response: The initial request did not request a reduction of work or that side slopes be restored. No further comment.

Comment #60c: Sheet 17. A portion of the grading associated with Park Central Drive, adjacent to wetland flag WF E26 through WF E29.

25 LE notes the Applicant has not modified the design to reduce or eliminate this impact.

Response: No further comment.

Comment #61c: The Applicant should examine options to provide additional undisturbed buffer zone between the treatment buildings and Wetland I.

Previous Goddard Response: The project design has kept work 20-feet away from Wetland I. Additionally, large areas outside the Buffer Zone to Wetland I are proposed to remain undisturbed.

LE notes the Applicant has not modified the design to reduce or eliminate this impact, nor have they given evidence why the buildings cannot be moved further from the wetland resource area. LE maintains its comment.

Response: 100% of the 20’ Buffer Zone was preserved in this area. See Sheet 25. Buildings cannot be shifted due to location of pre-treatment tanks.

Comment #62: All snow storage areas should be clearly identified on the project plans. The Applicant should provide a detail on how they will be clearly demarcated throughout the site.

1. The Applicant should confirm the areas are sufficient for snow storage for the entire site, or document alternative off-site snow removal operations.

Previous Goddard Response: Snow will be plowed and stored along the edge of the roads and parking areas as is typical with this type of development. Refer to the draft Snow and Ice Management Contract enclosed with this submittal for the outline of anticipated operations. As noted in the Operation and Maintenance Plan:

• Snow shall not be plowed, dumped and/or placed in forebays, infiltration basins or similar stormwater controls. • In no case shall snow be disposed of or stored in resource areas (wetlands, floodplain, streams or other water bodies).

Excess snow that cannot be stored on site shall be removed in accordance with local, state and federal standards. In addition, to further reduce the potential of snow being stored in resource areas snow storage signs have been added to the Site Plans where the limit of development is within close proximity to the wetland resource areas. See sheets 6-11, Site

26 Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020.

LE recommends the Applicant provide a figure (for inclusion with the Operations and Maintenance Plan) that depicts the locations of proposed snow storage areas across the project site.

Response: A figure is attached for the O&M Plan. This can also be a condition of approval.

Comment #64: The Applicant notes that the Stormwater Pollution Prevention Plan (SWPPP) will be submitted before land disturbance begins. Due to the size of the site and proposed work in close proximity to wetland resource areas, a Draft SWPPP should be submitted during the NOI review, otherwise, it should be submitted at least 30 days prior to land disturbance to allow the Commission sufficient time to review and comment. Land disturbance and construction should not begin until the SWPPP is approved by the Conservation Commission.

Previous Goddard Response: The applicant is amenable to a condition of approval that the SWPPP be provided to the Commission for review prior to the start of construction. The SWPPP will contain procedures in accordance with the Construction General Permit.

LE maintains its comment that the SWPPP be submitted for review and approval at least 30 days prior to the start of any work on the site. LE notes that due to the fact that the site discharges to an Outstanding Resource Water, the Applicant is required to submit the NPDES Construction General Permit application to both the EPA and MassDEP.

Response: Applicant is glad to accept a condition as outlined by LE.

Comment #66: The Landscape Plans note that “all disturbed areas not otherwise treated shall be loamed & hydroseeded with quality lawn mix.” LE recommends that areas disturbed for grading and other temporary work that will not consist of lawn be identified on the plans and restored to a natural condition upon completion (i.e., grading near the WWTP and recreational fields).

Previous Goddard Response: Areas for Conservation Seed mix have been clarified on site plans. See L-1 to L-9, Site Development Plans for Park Central. (61 Sheets). Prepared by Bohler Engineering, 1/9/2020.

27 LE believes there are numerous areas of the 100-Foot Buffer Zone on the site that could be seeded with conservation wildlife seed mix that would mitigate portions of the proposed Buffer Zone impacts. An example of such an area is the area to the west of the Phaneuf Drive units. LE recommends the Applicant review the plans for additional opportunities to minimize lawn and provide restoration of some level of wildlife habitat in disturbed areas of Buffer Zone.

Response: No further comment.

Comment #69: The Applicant states in the supplemental report that the five (5) basins that were created in the 1980’s were viewed as existing stormwater basins in the drainage design. Specifically, in Section 1.1, the Applicant refers to “pre-existing stormwater basins/ponds.” During the wetland delineation process for the site, the Applicant acknowledged that all resource areas on the site qualify as regulated resource areas under the WPA and/or local Bylaw and are shown on the existing conditions plan as such. The Applicant is clear in the intention of utilizing the basins for stormwater mitigation.

The Applicant states: “the previously developed stormwater basins with outlet structures and associated flagged wetlands will see very small elevation changes due to the existing outlet control structures and one (1) modified stormwater culvert.” LE maintains that due to the fact that all modifications to the wetland resources on the site were completed prior to November 18, 1996 and not in compliance with 310 CMR 10.00, no portion of the wetland resource areas are eligible to be viewed or utilized as existing stormwater management basins. LE was under the impression that the Applicant had designed the project to provide complete stormwater mitigation (including TSS removal and peak flow mitigation) prior to any discharge to the wetland resource areas. LE maintains its opinion that the use of wetland resource areas for stormwater management purposes is prohibited under 310 CMR 10.05(6)(k). LE defers to the stormwater management review by Fuss & O’Neill (F&O) for review of all engineering calculations and related documents and a discussion of standard engineering practices related to the treatment of stormwater.

Previous Goddard Response: DEP File #290-59 was filed on March 25, 1983, however the public hearings were held on April 19, 1983, the order was issued on May 4, 1983 and the Condition #4 cites 310 CMR 10.06(7). The public hearing and permit issuance therefore occurred after the promulgation of 310 CMR 10.00 occurred on April 1, 1983. The Commission therefore must have considered the project to be under 310

28 CMR 10.00, in order to cite a regulation outlined in 310 CMR 10.00 in the actual permit. The applicant has submitted a regulatory analysis in regards to 310 CMR 10.05(6)k.

See attached Park Central, 0 Turnpike Road DEP No. 290-1048, Stormwater Review Commentary, 10/30/19, Attorney Matthew Watsky.

The Applicant is making assumptions as to what evidence the Commission considered during the review in the 1980’s. LE defers to Special Counsel for the Commission on this topic, and maintains its comment.

Response: Please see letter titled “Park Central, 0 Turnpike Road DEP No. 290- 1048 Response to Attorney Lacey Legal Opinion.” WatskyLaw, 1/23/2020.

Comment #70: As requested by LE at the October 2, 2019 working session and agreed to by the Applicant’s representatives, the Applicant has not submitted a conceptual plan that shows the effects of the stormwater management system on the proposed development, if it were to be designed to match all rates and volumes across the site, prior to discharge to wetland resources. LE maintains its recommendation that such a plan be submitted for the Commission’s review.

Previous Goddard Response: The applicant agreed to evaluate the feasibility of meeting the local standard relative to matching volume reduction throughout all storms but not to provide full engineered plans. Based upon the evaluation, a design complying with the local standards would result in the loss of twenty seven (27) units of housing and would make the project financially unfeasible.

LE concurs that fully engineering plans were not requested; however, conceptual plans showing the project layout and limit or work were discussed. LE recommends the Commission discuss if greater documentation and detail is required to support the Applicant’s assertion that the project is “financially unfeasible” if the standard relative to matching volume reduction throughout all storms is met. LE recommends a conceptual drawing be submitted supporting the Applicant’s statements for review and discussion by the Commission.

Response: Please see letter titled “Park Central, 0 Turnpike Road DEP No. 290- 1048 Response to Attorney Lacey Legal Opinion.” WatskyLaw, 1/23/2020.

29 Comment #71: In Section 3.2.1, the Applicant states: “The wetlands on site were and remain well adapted to the flooding prior to the 1983 construction. Today, as discussed above, the conditions of the ponds show that they have continued to function and provide all the interests protected under the WPA as intended. The existing flooding that occurs within these ponds is the normal condition for these areas.” LE would argue that the current condition of the wetland resources on the site is one that has reached equilibrium over the past three decades. LE recommends the Applicant provide documentation of the flooding conditions for the site that existed prior to the 1983 construction. Furthermore, if the “existing flooding that occurs within these ponds is the normal condition for these areas,” LE recommends the Applicant describe how adding over sixteen (16) acres of impervious surface (with subsequent runoff) not result in an “abnormal” or impacted conditions?

Previous Goddard Response: It is not possible to document pre-1983 conditions and this information is not relevant to a 2019 project design. The drainage report addresses the current conditions under the stormwater management standards considering the historically permitted and constructed stormwater system.

It was the Applicant that raised the topic of discussing pre-1983 conditions in their application. LE’s comment pointed out that if statements are made as to whether or not impacts have occurred to wetland resource areas as a result of previous site activities, such statements need to be based on documented factual observations and not unsupported generalizations. LE does not dispute that pre- 1983 conditions may be irrelevant to the present application, presuming that the Applicant acknowledges that portions of the site that have been agreed to as regulated wetland resource areas are just that, without the caveat that they are somehow differently regulated as stormwater basins.

Response: No further comment.

Comment #72: The Applicant states that the original stormwater management system, for which a partial Certificate of Compliance was issued on November 20, 1987, has been receiving “ongoing maintenance of the system” from May 4, 1988 to the present. LE recommends the Applicant provide documentation of the maintenance of the system that has occurred over the past 31 years. Based upon site inspections, it does not appear any maintenance has occurred in recent years, and likely decades. As such, the Applicant’s statement is inaccurate and misleading. This information was also requested by the Applicant during the previous NOI review and has not been submitted to date.

30 Previous Goddard Response: The existing culverts on the project are continuing to function and kept clear. This has been the “ongoing maintenance of the system”. The volume and peak rates designed for in 1983 are reduced due to decreased development, but still function. No maintenance is necessary when a system is functioning normally. Since purchasing the property in 2013, Park Central LLC has regularly observed site culverts to confirm that they operate normally. No maintenance has been necessary based on these observations.

LE recommends the Applicant provide documentation that “Park Central LLC has regularly observed site culverts to confirm they operate normally.” The Commission should note that this information has been requested in the past and not provided.

Response: Documentation does not exist of these site visits, but the applicant has testified by firsthand knowledge that culverts have been operating normally.

Comment #76: Within the D-Series Wetland, the Applicant has previously identified and described functioning vernal pool habitat (Vernal Pool 2). Vernal Pool 2 appears to be located within the D-Series Basin 1. The project will result in modified hydrologic conditions within Basin 1. Vernal pools are extremely sensitive to hydrologic conditions and modifications may result in negative impacts to the area to provide vernal pool habitat. LE recommends the Applicant provide a detailed description of how the project will not adversely affect Vernal Pool 2. Such a description should include all known details on the existing hydroperiod of the vernal pool, the type of species utilizing the pool and a description of the existing vernal pool features (such as egg mass attachment points, etc.) that may be affected by a modification of the hydrology.

Previous Goddard Response: The drainage report outlines that there is no significant change to the hydroperiod for the vernal pool that would result in less water within the pool.

Table 1: Stormwater Hydrology Analysis: D-Series Basin #1

1-Year storm Q (cfs) Max. Elevation(ft) (Inflow/Outflow) Existing 7.0/3.1 414.3 Proposed 6.4/3.0 414.3

The above table shows that there is no significant change between the existing hydrology and proposed hydrology of the vernal pool for the 1- 31 year storm, which is the most frequent and important for vernal pools during the spring season. Principally the outflow (which is controlled by a culvert) is unchanged, so ponding elevation remains unchanged.

LE defers to Fuss & O’Neill for analysis of hydrological calculations provided by the Applicant. LE recommends the Commission include a Special Conditions in any Order of Conditions, requiring pre- and post- construction monitoring of vernal pool hydrology to determine if any actual adverse hydrological impacts are occurring.

Response: Hydraulic calculations provide evidence as to hydrology. Analysis is adequate rather than requiring monitoring. This condition is unwarranted.

Comment #78: In Section 3.2.1 of the report, the Applicant states that “the wetlands on site were and remain well adapted to the flooding prior to the 1983 construction.” LE recommends the Applicant provide the basis for this statement.

Previous Goddard Response: The wetlands on site were legally altered in 1983 and the site received a partial Certificate of Compliance (11/18/87). The conditions reviewed as part of the partial Certificate of Compliance were the expected conditions. Site reviews since 2016 have never noted adverse changes or impacts to the site resource areas that are different from the functions and values of the WPA.

LE maintains its general comment that the Applicant has not submitted any data that documents any ongoing analysis of impacts that may or may not have resulted from the 1983 construction activities authorized under the WPA. LE recommends that if the Applicant wishes to reference how the 1983 construction did or did not impact wetland resources on the site, they should present scientifically based data, not general, unsubstantiated statements.

Response: No further comment.

Comment #80: In Section 4.1.1, the Applicant states that, within Pond A-2, the mammal den observed likely was built by muskrat. LE has observed the presence of beaver within Pond A-2, and informed the Applicant’s representatives of such during the working session. LE recommends the Applicant modify their wildlife habitat observations to acknowledge the presence of an active beaver population on the site.

Previous Goddard Response: The den will be classified as a beaver den.

32 This is consistent with the Applicant’s previous Wildlife Habitat Evaluation (dated 10/18/16). LE notes that an active beaver lodge was observed on February 12, 2020 in the vicinity of flag B46. Significant Buffer Zone disturbance is proposed in this area which will likely adversely impact the habitat value utilized by the beaver population on the site.

Response: No further comment.

Comment #82: In Section 6.2, the Applicant states: “DEP has used constructed wetlands for stormwater treatment which shows that the scientific consensus is that wetland vegetation is very tolerate and will flourish even within constructed stormwater basins that see heavier stormwater flows.” Volume 2 Chapter 2: Structural BMP Specifications for the Massachusetts Stormwater Handbook states “like other stormwater BMPs, constructed stormwater wetlands may not be located within natural wetland areas other than riverfront area, land subject to coastal storm flowage, isolated land subject to flooding or bordering land subject to flooding.” The Handbook specifically states: “Do not locate constructed stormwater wetlands within natural wetland areas. These engineered stormwater wetlands differ from wetlands constructed for restoration or replication. Typically, constructed stormwater wetlands will not have the full range of ecological functions of natural wetlands.” LE recommends the Applicant provide a reference to the study which describes the “scientific consensus” that is referenced.

Previous Goddard Response: The submitted analysis cited the following studies:

• Armstrong, W., Brandle R., & Jackson M.B. (1994): Mechanisms of flood tolerance in plants. Acta Botanica Neerlandica 43: 307- 358. • Garssen A.G., Baattrup-Pedersen A., Voesenek L.A.C.J. et al. (2015): Riparian plant community responses to increased flooding: a meta-analysis. Global Change Biology 21: 2881-2890. • Greenway, M. (2010): Wetlands and ponds for stormwater treatment in subtropical Australia: their effectiveness in enhancing biodiversity and improving water quality? Journal of Contemporary Water Research & Education 146: 22-38. • Kreuzwieser, J. & Rennenberg, H. (2014): Molecular and physiological responses of trees to waterlogging stress. Plant, Cell and Environment 37: 2245-2259.

33 • Lichvar, Robert W., Melvin, Norman C., Butterwick, Mary L., & Kirchner, William N. (July 2012, National Wetland Plant List Indicator Rating Definitions, US Army Corps of Engineers • Talbot, R.J., Etherington J.R., & Bryant, J.A. (1987): Comparative studies of plant growth and distribution in relation to waterlogging. New Phytologist 105: 563-574. • Van der Valk, A.G., Squires L., & Welling C.H. (1994): Assessing the impacts of an increase in water level on wetland vegetation. Ecological Applications 4: 525-534.

Constructed wetlands do not always function as natural wetlands, because they were never constructed to be natural wetlands, however constructed wetlands do show that wetland vegetation can tolerate flooded conditions and continue to thrive. It is not proposed to construct stormwater basins within wetlands nor are there any alterations to the existing culverts that would impact the flooding within the wetland. The minor flooding increases (6-inches or less) and short durations are de minimis changes to wetland functions and values that will cause no adverse effect. Lastly the existing vegetation is primarily FACW where flooding is currently occurring and proposed and therefore the existing vegetation is adaptive to conditions where “water saturates the soils or floods the soil surface at least seasonally”. (National Wetland Plant List Indicator Rating Definitions, US Army Corps of Engineers)

LE has no further comment related to the Applicant’s reference; however, comparison of constructed wetlands is generally not comparable to naturally occurring wetland resource areas.

Response: No further comment. However it should be noted that all the basins are constructed wetlands. They were created by direct site manipulation and the addition of hydrological controls.

Comment #83: In Section 6 of the document, the Applicant provides a discussion on the topic of wetland and ponds as stormwater management systems. The general theme of the discussion is that wetland plants are suited to changes in flooding conditions, both in depth and in duration. LE does not dispute that natural wetland systems are dynamic systems the can withstand modifications due to hydrological changes from natural causes. As hydrological conditions change, the dominant plant species within a system will change as species that prefer either drier or wetter conditions flourish and find suitable conditions to expand their range. Associated wildlife that utilize various plant species and hydrological conditions will also change over time. LE makes no judgement as to if slight or significant changes to the ecological conditions of a given wetland system are

34 beneficial or detrimental. For example, the presence of beaver can radically modify a wetland system in a brief period of time. Depending on your viewpoint, these modifications can be viewed as positive or negative. As stated previously, LE believes that the language in 310 CMR 10.05(6)(k) is clear that BVW may not be altered for the impoundment or detention of stormwater. As such activities (as proposed by the Applicant) are expressly prohibited, LE believes that any resulting changes to the altered resource areas, be they negative, positive or neutral, are immaterial. Section 310 CMR 10.04 defines one aspect of alter as the changing of pre-existing drainage characteristics.

Previous Goddard Response: No work within the wetlands or the existing culverts that control the wetland overflows is proposed. Our analysis shows compliance with 310 CMR 10.05(6)(k). The short timeframe of flooding demonstrated in the analysis will not adversely impact the wetlands, as they are accustomed to brief periods of flooding. LE refers to prolonged flooding by a beaver dam as an alteration of a wetland system, whether positive or negative. However, the project proposes, as shown in the drainage report, that the predicted flooding (6-inches or less) is de minimis and that no impacts to the resource areas functions will occur. Contrary to LE’s assertion that 10.05(6)(k) imposes some absolute rule that prohibits any increase or decrease in peak rates of flow, regardless of whether that change results in positive or negative effects – the Stormwater Standards specifically permit a design that results in a reduction of peak rates at the property line. The rule in 10.05(6)(k) cannot logically be interpreted as LE insists, as that interpretation is inconsistent with provisions of the Stormwater Standards. The Project design meets the Stormwater Standards, and will cause no adverse effect to the on-site wetlands.

LE maintains its comment. LE is not debating the increases or decreases in peak rates under this Comment, but that changes in drainage characteristics (including short-term flooding and changes in hydrology) are in fact alterations, which are prohibited under 310 CMR 10.05(6)(k) as related to the impoundment of stormwater. LE defers to Fuss & O’Neill related to standard engineering practices that require evaluation only at the property line.

Response: Goddard disagrees. LE identified no area of wetland adverse impact due to proposed drainage change.

Comment #84: Table 7 of the document includes a “Flood Tolerant” column. LE recommends the Applicant cite a source for this data.

35 Previous Goddard Response: Under the DEP “Wetlands Program Policy 95-1: Bordering Vegetated Wetland Delineation Criteria & Methodology” “Wetland indicator plants are defined in the regulations at 310 CMR 10.55(2)(c) as one of three groups:

1. plant species listed in the Act; 2. plants in the U.S. Fish and Wildlife Service's National List of Plant Species that Occur in Wetlands: Massachusetts (Reed, 1988) with a wetland indicator category of FAC, FAC+, FACW-, FACW, FACW+, OBL, and; 3. plants with morphological or physiological adaptations to life in saturated conditions.”

Goddard can provide these lists if needed. The report has also been updated to provide additional citations on basis for “Flood Tolerant” species.

The documents cited by the Applicant include no specific categories as to whether or not a given species is “flood tolerant.” Not all species that are listed to qualify as “wetland species” (i.e., FAC, FACU, OBL) are necessarily flood tolerant. Floodplain species such as silver maple, black willow, and buttonbush and considered flood tolerant. Species such as red maple, swamp white oak, and black chokeberry are considered “somewhat tolerant” of flooding.1

Response: LE does not suggest that there will be a measurable adverse impact. No further comment.

Comment #86: The Applicant states that they are seeking approval from MassDOT to implement that portion of the work that will provide treatment to runoff from Interstate Route 495. LE recommends the Applicant provide an anticipated timeframe for any necessary approvals from MassDOT.

Previous Goddard Response: The applicant has had informal meetings with MassDOT, and MassDOT is expected to issue a permit for construction once the local project approvals are issued.

LE recommends the Commission include a Special Condition in any Order of Conditions that requires a copy of any permits/agreements with MassDOT be provided to the Commission prior to the start of construction.

Response: Applicant agrees this can be conditioned.

36 Comment #87: In Section 5.1, the Applicant states that the “Wetlands A-Series, D-series, and I-series are not tributary to a private or groundwater supply.” Furthermore, in Section 5.2, the Applicant states “Ponds B and H are not tributary to a private or groundwater supply.” LE recommends the Applicant provide evidence that the A-Series, D-Series, I-Series wetlands and Ponds B and H do not discharge surface water to the regional groundwater supply for at least some portion of the year and are, therefore, not significant to the protection of groundwater supply.

Previous Goddard Response: The site and the surrounding areas are not mapped for stratified drift soils which would show infiltration characteristics into deep water tables. The wetlands on site both drain quickly into marshes or rivers. Southborough water main map shows that all streets around the site are served by public water supply. The general area is a tributary to the Sudbury Reservoir and/or Framingham Reservoir #3.

The Applicant has not provided evidence that perched water tables (over ledge or other impervious soils layers) exist on the project site. The fact that waters flow from the site to off-site wetland resources does not mean that those waters are not contributing to private or public groundwater supplies. Therefore, LE maintains its opinion that all wetland resource areas on the project site are likely to discharge surface water to the regional ground water supply for at least some portion of the year and are, therefore, significant to the protection of groundwater supply.

Response: The applicant concedes that the wetland resource areas on site may be significant to the protection of groundwater supply, but the project has been designed to satisfy the infiltration standards for water quality. See drainage report. LE cites a performance standard that is non-regulatory.

Comment #92: The 100-Foot Buffer Zone does not appear on all graphics and should be updated.

Previous Goddard Response: The flooding analysis strictly considered the effect on the wetlands, so the 100-foot Buffer Zone is not relevant to the focus of the flooding analysis submittal. The focus was to analyze the elevation in ponds.

LE maintains its comment. Depicting the limit of Buffer Zone on all graphics is beneficial to advise the Commission on the limits of their jurisdiction.

Response: Site Plans sheets 6-32 show the 100-Foot Buffer Zone.

37 Comment #96: The Applicant has used a value of 7.0 inches over 24 hours to model the 100-year storm occurrence. The Southborough Conservation Commission has previously preferred that Applicants use the Point Precipitation Frequency Estimates from NOAA Atlas 14, Volume 10, Version 3, which uses a value a different value for the 100-year storm occurrence. The Commission to discuss.

Previous Goddard Response: The engineer has used stormwater data for the 100-year storm as mandated by MassDEP’s regulations.

The Commission to discuss.

Response: Bohler’s stormwater calculations exceed the regulatory requirement of 6.5” from TP-40/TR-55. Calculations used 7.0” which is more conservative.

Comment #97: The Applicant states in Section 1.1 that they are proposing “one modified stormwater culvert”. Please clarify and demonstrate how this meets the WPA and Stormwater Management Standards.

Previous Goddard Response: This statement is in regard to the installation of a proposed weir within the outlet structure to existing Basin #3. The enclosed revised Site Development plans include the construction of basin SW#11 and removal of the previously proposed weir (Sheet 19). With this revision, there are no proposed modifications to any of the existing culverts or structures associated with the existing basin / pond outlets. See sheet 19, Site Development Plans for Park Central. (61 Sheets), 1/9/2020.

Sheet 19 of the project plans describes that a concrete weir is proposed to be constructed within existing structure EOCS-1001. LE defers to Fuss & O’Neill that the Applicant has removed all structural modifications that are not permitted under the Stormwater Management Standards.

Response: LE is correct that this is an errant note on plan. Sheet 38 notes no proposed changes to EOCS-1001. This can be cited as a special condition that no alterations to the structure are permitted.

Comment #99: On the project plan and construction narrative, the Applicant describes that the native soils within Crossing #2 (Webber Circle) are to be excavated and stockpiled during the construction of the crossing. Based upon the cross-section, it appears all utilities are proposed to be constructed above the culvert. As such, it appears there is no need to disturb the native soils. LE recommends the plan and narrative be revised to describe measures to protect native wetland soils in place.

38 Response: A revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 is attached. This document notes the protection of natural soils, but also identifies the culvert footing construction area will need soils removed (See page 17, step 5)

Comment #100: For Replication Areas 2 and 3, the project plans include cross-section views of the proposed grading (sections B-B and C-C, respectively). As described in Comment Response #42, the cross sections should show anticipated groundwater levels. LE recommends the cross-sections also be revised to more accurately depict the proposed final elevations. In general, LE recommends the areas be much flatter than as shown currently.

Response: A revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 is attached. Figures 2, 4 and 6 show the replication cross sections and anticipated groundwater levels. (See pages 11, 13) As LE is aware, replication grading is dictated based on soils found in each area of proposed replication. Therefore, proposed grades were not changed, but the document outlines that the wetland scientist shall review hydrologic (redoximorphic features) conditions prior to placement of the organic topsoil (See page 4, Step 4).

Comment #101: The Applicant is proposing impacts to 2,835 square feet of BLSF. It appears a portion of the proposed BLSF impacts are avoidable. LE recommends the Applicant consider extending the proposed retaining wall to the west to allow avoidance of grading within BLSF in this area.

Response: This can be conditioned if the Commission deems it an improvement to the current design. See plan Sheet #13 and #44.

Comment #102: LE performed a site inspection of the proposed 3,886 square foot BLSF compensatory area. The area is currently mature forest with numerous mature trees (greater than 12-inch DBH). LE recommends the Applicant consider modifying the design to maintain as many mature trees as possible. Loss of tree canopy immediately adjacent to the BVW has the potential to result in adverse impacts.

Response: Trees must be removed to achieve grading required for compensatory storage, but trees will be restored with plantings. See response to #103.

39 Comment #103: The Applicant is proposing to seed the BLSF compensatory area with Conservation/Wildlife Seed Mix. LE recommends the Applicant provide a more robust planting plan for this area, including woody plantings, to mitigate for the loss of woody (forested) vegetation within the impact area (as well as the location of the mitigation area itself). The mitigation should be designed to mimic values of the impact area. Based upon the proposed grading, it appears a portion of the area is likely to have suitable hydrology to become BVW. As such, LE recommends the Applicant consider use of the New England Erosion Control/Restoration Mix for Detention Basins and Moist Sites seed mix, rather than the Conservation/Wildlife Seed Mix. LE defers to Fuss & O’Neill for review of area calculations pertaining to the proposed impact areas and compensatory storage area.

Response: A revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 is attached. This lists the proposed trees and shrubs in the BLSF area (See pages 25-26).

Comment #104: LE recommends the BLSF compensatory area be shown on the Erosion and Sedimentation Control Plans, including a proposed erosion control barrier to protect the area after construction.

Response: This can be a condition of approval. Shown on sheet #28. A revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 is attached and notes that ECB enclose the area to protect it after construction (See page 24, Step 3).

Comment #105: The Applicant has prepared a figure entitled “Existing 100-Yr Floodplain Elevation” (included as Appendix H of the re-submittal). LE recommends the limits of the 100-year floodplain be depicted on the Grading and Drainage Plans to demonstrate that no other BLSF impacts exist beyond those described in the application.

Response: The Applicant has provided details where work was proposed. Consistent with good engineering practices, line types were not added so as to avoid cluttering plans. See plan Sheet #44.

Comment #106: LE recommends the Applicant describe how the retaining wall proposed to be constructed south of Wetland P will be installed without any direct wetland impacts. As currently shown on Sheet 17 of the project plans, the wall appears to be three to four feet from the wetland boundary.

40 Response: This wall is a fill wall, 5-feet from the wetland. Applicant is comfortable with the Limit of Work as shown on plans. No work is needed closer to the BVW to construct this wall since it can be built from the upgradient side.

Comment #107: LE recommends the Applicant revise the plans to depict the re- naturalization of the 20-Foot No Disturb Zone surrounding the proposed stream restoration areas (specifically, the area to the west of Stream Restoration Area ‘B’). LE also recommends the proposed stream restoration areas be depicted on the Landscape Plans.

Response: A revised CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN dated March 5, 2020 is attached. This lists the proposed trees and shrubs in access points to Replication Areas (See Figures 1, 3, 5, 7 and 9)

41 Legend

Wetland/BLSF Impact #1 a

Date:Date: 1/9/2020 3/4/2020 Location of Impact Areas

April 30, 2019 Rev. 1/9/2020 Rev. 3/5/2020

CONSTRUCTION DOCUMENT: WETLAND REPLICATION AND STREAMBED RESTORATION PLAN

Park Central Southborough, MA DEP File #290-1048

PURPOSE: CONSTRUCTION PROCEDURES

PREPARED FOR: Park Central LLC

All construction work discussed in this document shall be supervised by a qualified wetland scientist with a minimum of five years’ experience.

Table of Contents I. WETLAND REPLICATION AREAS ...... 4 A. LOCATIONS: ...... 4 i. Wetland Replication – John Boland Road ...... 4 ii. Wetland Replication – Webber Circle ...... 4 iii. Wetland Replication – Park Central Drive ...... 4 B. GENERAL INSTALLATION PROCEDURES – WETLAND REPLICATION AREAS: ...... 4 C. PLANTING LIST: ...... 8 D. REPLICATION AND PLANTING PLAN: ...... 10 II. STREAM CROSSING – JOHN BOLAND ROAD ...... 15 A. LOCATION: ...... 15 B. GENERAL INSTALLATION PROCEDURES: ...... 15 C. SEEDING LIST: ...... 17 III. WETLAND CROSSING – WEBBER CIRCLE ...... 17 A. LOCATION: ...... 17 B. GENERAL INSTALLATION PROCEDURES: ...... 18 C. SEEDING LIST: ...... 20 IV. STREAM RESTORATION ...... 20 A. LOCATIONS: ...... 20 i. Stream Restoration – Park Central Drive ...... 20 ii. Stream Restoration – Blackthorn Extension ...... 20 B. GENERAL INSTALLATION PROCEDURES – STREAM RESTORATION ...... 20 C. SEEDING & PLANTING LIST: ...... 22 D. STREAM DETAIL AND PLANTING SKEMATICS ...... 23 V. BORDERING LAND SUBJECT FLOODING COMPENSATORY STORAGE ...... 25 A. LOCATION: ...... 25 B. GENERAL INSTALLATION PROCEDURES: ...... 25 C. PLANTING AND SEEDING LIST ...... 26

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D. BLSF DETAIL AND PLANTING SKEMATIC ...... 27 Appendix A: Wetland Replication Checklist, Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, Mass DEP File #290-1048, Goddard Consulting LLC, 1/9/2020...... 27 Appendix B: John Boland Wetland Replication Plan 11x17 To Scale Plan ...... 27

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I. WETLAND REPLICATION AREAS

References: See Site Plan cited in Order of Conditions DEP File #290-1048.

A. LOCATIONS:

Three (3) wetland replication areas are proposed as part of the Park Central project. Each location is outlined below. See Appendix A for Wetland Replication Checklist, Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, Mass DEP File #290-1048, Goddard Consulting LLC, 1/9/2020.

i. Wetland Replication – John Boland Road

This replication area is for the 372 square feet (SF) of wetlands impacted by the proposed stream crossing on John Boland Road. Replication area will be 420 SF and is directly adjacent to the impact area. Plan Sheet 13, 40 shows the general location, however Appendix B has the Scaled Drawing of actual wetland replication area. See below figures in Section I.D. for further details.

ii. Wetland Replication – Webber Circle

This replication area is for the 674 square feet (SF) of wetlands impacted by the proposed wetland crossing on Webber Circle. Replication area will be 1,482 SF and is near M34 to M37-13. See sheet 15, 41 of site plans. See below figures in Section I.D. for further details.

iii. Wetland Replication – Park Central Drive

This replication area is for the 1,097 square feet (SF) of wetlands impacted by the proposed wetland crossing on Park Central Drive. Replication area will be 1,625 SF and is near G1-G6 near the proposed Blackthorn Extension. See sheet 17, 42 of site plans. See below figures in Section I.D. for further details.

B. GENERAL INSTALLATION PROCEDURES – WETLAND REPLICATION AREAS:

The following procedures shall be followed for all the replication areas (John Boland Road, Webber Circle and Park Central Drive). See sheets 40-42 of site plans.

Supervision: All work within the replication area shall be supervised by a qualified wetland scientist with a minimum of five years’ experience. The supervisor shall submit monitoring reports to the Conservation Commission as described below. Reports shall contain details of all work performed and photographs of completed conditions.

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Timing: Work shall take place ideally when the altered wetlands are not seeing saturated conditions. If the wetlands are not dry and dewatering is necessary a dewatering plan shall be approved by the Conservation Commission and then implemented. The construction and installation of the replication area should be accomplished during the spring or fall growing seasons (between April 16 and May 31 or between September 16 and October 30). Planting during these periods is highly recommended. The replication area grading is advised not commence unless the contractor can guarantee completion of the work within the replication area within the same season.

Step 1: Stake Limits of Work, Confirm wetland flags in place & Install ECB Stake out limits of work for replication areas and confirm wetland flags are in place on site. Erosion control barriers shall then be installed in the form of staked siltation fence and mulch sock (or similar invasive-free barrier) placed at the limit of work for the replication area. These will remain in place and be maintained until the areas are completely stabilized and then may be removed after approval of the Conservation Commission. Wetland scientist shall have authority to require additional erosion control measures if deemed necessary.

Step 2a: Identify shrubs and woody debris to be re-used in replication area The wetland scientist shall identify and flag any native shrubs within the replication areas and/or the BVW alteration areas that may be dug up and stockpiled for use as additional plantings in the replication area. Any flagged specimens shall be removed and stockpiled in a designated area outside the replication area. Any large woody debris (rotting logs) shall also be identified and flagged for stockpiling and subsequent addition to the replication area.

Step 2b: Remove trees and vegetation Once flagged shrubs and woody debris specimens have all been removed and stockpiled, clear and remove all remaining vegetation within the replication areas and the BVW alteration areas in preparation for excavation and grading.

Step 3: Excavation of BVW Alteration Areas Prior to any soil excavation, a stockpile area for organic soils shall be prepared in the vicinity of the replication area, but immediately adjacent to the existing wetland resource area boundary. An excavator or backhoe shall remove existing organic soils up to the edge of the staked fill area boundary from the BVW alteration areas. Excavated soils shall be transported to and stored in the designated location near the replication areas. Care shall be taken to avoid contact with other non- wetland soils that may contain seeds of undesirable plant species. Soils the area of Webber Circle shall not be used at replication area due to presences of invasive species.

Step 4: Excavation of new BVW Replication Area An excavator or backhoe shall remove existing soils up to the edge of the staked BVW replication area boundary, to a depth at which redoximorphic features become visible in the C-horizon at the soil surface and at least one foot below proposed final grade, all of which shall be supervised and directed by the wetland scientist. During the excavation, leaf litter should be stockpiled separately for re-use in the replication area. Topsoil and subsoil shall be removed from the area for re-use elsewhere in the project site or removed from the site. Subsoil of the C-horizon shall be loosened

Page 5 of 27 prior to Step 5 to ensure soils aren’t compacted prior to topsoil placement. Soils the area of Webber Circle shall not be used at replication area due to presences of invasive species.

Step 5: Final Grading of Replication Area Upon removal of existing soils down to the proper depth (as determined by the wetland scientist), the organic soil should be sourced from the soils stockpiled from the impact area. If the transplanted soils do not fill entire replication area, supplement with organic soils from an offsite source. The soil may be amended with the primary source consist of organic materials composted of leaf litter from a reputable source and having an organic content of between 12-20%. NOTE: Organic content must be tested by a qualified laboratory to confirm organic content in soils (12- 20%). Topsoil shall be placed within the replication area to a depth 6-12” and even with the surrounding proposed elevation on design plan, to be determined by the supervising wetland scientist. Final grade shall be confirmed to be proper by the wetland scientist prior to plantings. Placement of soil shall be such that no equipment drives over or compacts placed wetland soils. Final grading will result in micro relief of pits and mounds. Slopes around the replication area shall be graded to less than 2H:1V where practical and shall have erosion control mats installed as necessary.

Step 6: Place woody debris and boulders Woody debris and boulders shall be randomly placed throughout the replication area to provide cover for wildlife and provide wildlife habitat. Deed wood shall consist of 2-4, 6”+ logs approximately 6-feet long.

Step 7A: Planting Replication Precise citing of plants may be determined by the wetland scientist in the field prior to installation. All plantings shall be distributed randomly throughout the area; trees spaced at 10-15’ on center; shrubs spaced at 6-10’ on center and herbaceous species 3’ or less on center. All plantings will be removed from burlap sacks, wire cages and plastic containers prior to planting. Each plant will have it roots loosened prior to planting to encourage root growth away from the planting bulb. Leaf litter shall be spread throughout area if available. Wetland seed mix shall be scattered evenly by hand throughout the replication area. Once all work is complete an erosion control barrier will be installed to enclose the replication area on the access side of the replication area.

Step 7B: Planting Replication Access Path Precise citing of plants may be determined by the wetland scientist in the field prior to installation. All plantings shall be distributed randomly to vegetate the disturbed 20-foot Buffer Zone to the wetland replication area that was used to access the area. All plantings will be removed from burlap sacks, wire cages and plastic containers prior to planting. Each plant will have it roots loosened prior to planting to encourage root growth away from the planting bulb. Leaf litter shall be spread throughout area if available. Wetland seed mix shall be scattered evenly by hand throughout the replication area. Once all work is complete an erosion control barrier will be installed to enclose the replication area on the access side of the replication area.

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Step 8: As-built Interim as-built plans, complete with one-foot contours, spot elevations, surface area, and cross sections of the replication area shall be prepared by a Registered Professional Land Surveyor of the Commonwealth and submitted to the Commission.

Step 9: Erosion Controls Removal Once replication area is stable a request shall be submitted to the Conservation Commission to remove the erosion controls around wetland replication area. Upon approval of stabilization erosion controls shall be removed promptly and any significant disturbance seeded with a wetland seed mix as specified in this plan.

Step 10: Replication Monitoring a. Seasonal monitoring reports shall be prepared for the replication area by a qualified wetland scientist for a period of 2 additional years after installation. This monitoring program will consist of early summer and early fall inspections, and will include photographs and details about the vitality of the replication area. Monitoring reports shall be submitted to the Commission by November 15th of each year. Monitoring reports shall describe, using narratives, plans, and color photographs, the physical characteristics of the replication area with respect to stability, soil characteristics (i.e. horizons, depths, texture, percent gravel and rock, organic matter, Munsell hue, value and chroma, consistence and evidence of hydrologic influence), survival of vegetation and plant mortality, aerial extent and distribution, species diversity and vertical stratification (i.e. herb, shrub and tree layers). Invasive species will be monitored and removed. The quantitative vegetative analysis should include a stem count for nursery stock, and vegetation plots to calculate percent cover and dominant species. b. At least 75% of the surface area of the replication area shall be re-established with indigenous plant species within two growing seasons. If the replication area does not meet the 75% re-vegetation requirement by the end of the second growing season after installation or the presences of invasive species, the Applicant shall submit a remediation plan to the Commission for approval that will achieve, under the supervision of a Wetland Specialist, replication goals. This plan must include an analysis of why the areas have not successfully re-vegetated and how the Applicant intends to resolve the problem.

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C. PLANTING LIST:

John Boland Road – Planting List – Access Path to Replication Area Common Name Scientific Name Number Size Trees* Red Oak (FACU) Quercus rubra 1 4-5’ Shrubs* Sweet Pepperbush (FAC+) Clethra alnifolia 2 3 Gal. pot Witch Hazel (FACU) Hamamelis virginiana 2 3 Gal. pot Seed Mix New England Erosion Control/Restoration Mix for Detention Basins 1 lbs and Moist Sites or equivalent* *Planting species and seedmixes may be substituted with Conservation Commission approval with similar native species with the same wetland indicator status if certain species are unavailable.

John Boland Road – Planting List – Replication Area (420 s.f.) 6 shrubs and 8 ferns provided for wetland edge at crossing culvert inlet and outlet.

Common Name Scientific Name Number Size Trees (n= 3)* Red Maple (FAC) Acer rubrum 3 4-5’ Shrubs (n=13)* Sweet Pepperbush (FAC+) Clethra alnifolia 5 18-24” Winterberry (FACW+) Ilex verticillata 4 18-24” Spicebush (FACW-) Lindera benzoin 4 18-24” Ground Cover (n=28)* Sensitive Fern (FACW) Onoclea sensiblis 14 1 gal. pot Cinnamon Fern (FACW) Osmundastrum cinnamomea 14 1 gal. pot Seed Mix New England Wetland Plants WETMIX or equivalent* (Replication 0.5 lbs area) New England Erosion Control/Restoration Mix for Detention Basins and 1 lbs Moist Sites or equivalent* (Side slopes of replication area) *Planting species and seed mixes may be substituted with Conservation Commission consent with similar native species with the same wetland indicator status if certain species are unavailable.

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Webber Circle – Planting List – Access Path to Replication Area Common Name Scientific Name Number Size Trees* Red Oak (FACU) Quercus rubra 3 4-5’ Shrubs* Sweet Pepperbush (FAC+) Clethra alnifolia 6 3 Gal. pot Witch Hazel (FACU) Hamamelis virginiana 6 3 Gal. pot Seed Mix New England Erosion Control/Restoration Mix for Detention Basins 1 lbs and Moist Sites or equivalent*

*Planting species and seedmixes may be substituted with Conservation Commission approval with similar native species with the same wetland indicator status if certain species are unavailable.

Webber Circle – Planting List – Replication Area (1482+/- s.f.) *6 shrubs and 8 ferns provided for wetland edge at crossing culvert inlet and outlet. Common Name Scientific Name Number Size Trees (n= 10)* Red Maple (FAC) Acer rubrum 10 4-5’ Shrubs (n=30)* Sweet Pepperbush (FAC+) Clethra alnifolia 10 18-24” Winterberry (FACW+) Ilex verticillata 10 18-24” Spicebush (FACW-) Lindera benzoin 10 18-24” Ground Cover (n=60)* Sensitive Fern (FACW) Onoclea sensiblis 30 1 gal. pot Cinnamon Fern (FACW) Osmundastrum cinnamomea 30 1 gal. pot Seed Mix New England Wetland Plants WETMIX or equivalent* (Replication 1 lbs area) New England Erosion Control/Restoration Mix for Detention Basins and 1 lbs Moist Sites or equivalent* (Side slopes of replication area) *Planting species and seed mixes may be substituted with Conservation Commission consent with similar native species with the same wetland indicator status if certain species are unavailable.

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Park Central Drive – Planting List – Access Path to Replication Area Common Name Scientific Name Number Size Trees* Red Oak (FACU) Quercus rubra 4 4-5’ Shrubs* Sweet Pepperbush (FAC+) Clethra alnifolia 7 3 Gal. pot Witch Hazel (FACU) Hamamelis virginiana 8 3 Gal. pot Seed Mix New England Erosion Control/Restoration Mix for Detention Basins 2 lbs and Moist Sites or equivalent*

*Planting species and seedmixes may be substituted with Conservation Commission approval with similar native species with the same wetland indicator status if certain species are unavailable.

Park Central Drive – Planting List – Replication Area (1,625+/- s.f.) Location near proposed Blackthorn Extension Common Name Scientific Name Number Size Trees (n= 11)* Red Maple (FAC) Acer rubrum 11 4-5’ Shrubs (n=25)* Sweet Pepperbush (FAC+) Clethra alnifolia 9 18-24” Winterberry (FACW+) Ilex verticillata 8 18-24” Spicebush (FACW-) Lindera benzoin 8 18-24” Ground Cover (n=60)* Sensitive Fern (FACW) Onoclea sensiblis 30 1 gal. pot Cinnamon Fern (FACW) Osmundastrum cinnamomea 30 1 gal. pot Seed Mix New England Wetland Plants WETMIX or equivalent* (Replication 1 lbs area) New England Erosion Control/Restoration Mix for Detention Basins and 1 lbs Moist Sites or equivalent* (Side slopes of replication area) *Planting species and seed mixes may be substituted with Conservation Commission consent with similar native species with the same wetland indicator status if certain species are unavailable.

D. REPLICATION AND PLANTING PLAN: Plantings shall be disturbed as follows with discretion give to the supervising wetland scientist. Trees spaced at 10-15’ on center; shrubs spaced at 6-10’ on center and herbaceous species 3’ or less on center. Shrubs shall be planted in clumps of 2-3 of same species. As a rule, plants of the same

Page 10 of 27 species will be placed in groupings to more closely mimic natural conditions. Trees planted on

mounds and shrubs and herbaceous cover in depressions.

T E

W G

W E

C C

B T

G W W

C C

& B

W G E CB

T E

E G C

C W PROP. RETAINING &

T E WALL (DESIGN BY

A OTHERS) (TYP.) G

C C

& W B T

& E T W

C E B PROP.

CURBLINE (TYP)

& T W 4

E A E + 5 C 0 B EXIST. WETLAND 41.7' LINE (TYP) PROP. WETLAND PROP. EROSION

CONTROL

REPLICATION AREA G

C PROP. 115 LF

BARRIER (TYP.) &

(410 SF / 1:1 RATIO) T W E OF BANK

E C ALTERATION B

EXIST. STREAM

BANK (TYP) C

& W T E

' E PROP. 431 SF LUW 2 C . B 1 ALTERATION

G PROP. GUIDERAIL & W

T E (TYP.) E C B PROP. GAS MAIN (TYP.)

C W

G C

& B

T PREVIOUSLY E PROPOSED WETLAND E C REPLICATION AREA B

E C

PLANTING LEGEND: B

*FERNS NOT SHOWN W

J G

& T O

1 – TREE E

C B N R

W C

O B

+/-3 – SHRUB CLUSTER G &

T E O

(13 WETLAND SHRUBS) A

E + L

D C

(4 UPLAND SHRUBS) PROP. RETAINING 4 B WALL (DESIGN BY A

OTHERS) (TYP.) C G

10 5 2.5 0 10 &

T D

PROP. ELECTRIC, E PROP. WATER Figure 1: John Boland Wetland Replication Area. See Appendix A for Scaled Drawing E TELEPHONE, & C MAIN (TYP.) B

1"= 10' CABLE (TYP.)

C W

G E &

T B E

Page 11 of 27

Figure 2: John Boland Wetland Replication Area A-C Cross Section Note: • Expected High Groundwater ~El. 391 • Estimated Low Ground Water ~El. 389 • Perched Water Conditions – No anticipated • Adjacent stream is intermittent showing surface saturation during the late fall to spring time.

Page 12 of 27

PLANTING LEGEND: *FERNS NOT SHOWN 1 – TREE

3 – SHRUB CLUSTER (30 WETLAND SHRUBS) (12 UPLAND SHRUBS)

Figure 3: Webber Circle Wetland Replication Area

PLANTING LEGEND: Figure 4: Webber Circle Wetland Replication*FERNS NO AreaT SHOW NC -C Cross Section 1 – TREE Note: • Expected High Groundwater ~El. 440 +/-3 – SHRUB CLUSTER • Estimated Low Ground Water ~El. 438 (25 WETLAND SHRUBS) (15 UPLAND SHRUBS) • Perched Water Conditions – Due to compact subsoil perched water at El. 440 may occur. • Adjacent wetland shows surface saturation during the late fall to spring time.

Page 13 of 27

PLANTING LEGEND: *FERNS NOT SHOWN 1 – TREE

3 – SHRUB CLUSTER (30 WETLAND SHRUBS) (12 UPLAND SHRUBS)

PLANTING LEGEND: *FERNS NOT SHOWN 1 – TREE

+/-3 – SHRUB CLUSTER (25 WETLAND SHRUBS) (15 UPLAND SHRUBS)

Figure 5: Park Central Drive Wetland Replication Area

Figure 6: Park Central Drive Wetland Replication Area C-C Cross Section Note: • Expected High Groundwater ~El. 391 • Estimated Low Ground Water ~El. 389 • Perched Water Conditions – Due to compact subsoil perched water at El. 391 may occur. • Adjacent wetland shows surface saturation during the late fall to spring time.

Page 14 of 27

II. STREAM CROSSING – JOHN BOLAND ROAD

References: See sheet 13, 40 of Site Plan cited in Order of Conditions DEP File #290-1048

A. LOCATION:

The stream crossing at John Boland Road and shown on the Grading & Drainage Plan “A”. The crossing includes a arch culvert that meets stream crossing standards.

B. GENERAL INSTALLATION PROCEDURES:

Supervision: All work shall be supervised by a qualified wetland scientist with a minimum of five years’ experience. The supervisor shall submit monitoring reports to the Conservation Commission as described below. Reports shall contain details of all work performed and photographs of completed conditions.

Timing: Work within the stream shall take place during low-flow to no-flow conditions, which is typically between June 15 and October 15. a. If flow is encountered, provide a temporary sand bag dam or pump system upstream to divert stream around construction area. b. Provide dewatering basin if pumping is required.

Step 1: Stake Limits of Work, Confirm wetland flags in place & Install ECB. Field stake limit of work, culverts and wing walls and confirm wetland flags are in place on site as shown on the project site plans.

Step 2: Photograph Pre-Construction Conditions Supervising Scientist shall take detailed photographic and/or video documentation of pre-existing streambed conditions. This will aid in the restoration of pre-existing streambed conditions within the culvert after installation.

Step 3: Install Erosion Control Barriers (ECB) Erosion control barriers shall then be installed in the form of staked siltation fence and mulch sock (or similar invasive-free barrier) placed at the limit of work. These will remain in place and be maintained until the areas are completely stabilized.

Step 4: Remove any potential wildlife habitat features This includes rocks, stones (at least 6-inches long +/-) and large woody debris. These features should be stockpiled nearby for later replacement within the culvert. Care should be taken to preserve moss on rocks. Wetland scientist will monitor mosses to prevent them drying out during culvert installation process.

Page 15 of 27

Step 5: Excavate stream bed material First excavate top 1-6 inches of organic, sandy or cobbly substrate. Stockpile material carefully in a designated location nearby for replacement in culvert. Then remove remainder of stream bed soils to desired grade. Where no excavation is not necessary cover natural soils and streambed with fabric to keep soils protected during work.

Step 6: Install Culvert Footings Perform the culvert footing installation in accordance with approved structural engineered plans and details.

Step 7: Restore Streambed Following culvert footing installation, restore historic stream channel and substrate. A. Grade stream channel to match pre-existing conditions. Final micro- topography of the channel should be a sinuous configuration to match the profiles of the existing stream above where the stream is in its natural state. B. If the topsoil has been stripped, replace with stockpiled material. C. Place rocks or stones (6-inch +/-) in the stream bed (try to use those existing on site if none were stockpiled) in a natural/random formation to approximate the existing historic stream bed. D. Prepare bank soil and stones for touching up bank along footings. E. Restore wetland and stream bank within the limit of work that is not impacted by the culvert structure. Areas to be seeded as noted below.

Step 8: Install Culvert Head Section Install the culvert installation in accordance with approved structural engineered plans and details. a. Once culvert section is installed on footing complete touchup of bank restoration by hand within culvert.

Step 9: Shift Erosion Controls to allow stream/surface water flow/movement Remove erosion controls that cross the stream, and tie line of new erosion controls to culvert/wingwall interface. Install new erosion controls over culvert to prevent erosion into the stream channel.

Step 10: Seeding of disturbed areas Hand seed disturbed areas of the stream bed and adjacent areas downgradient of the wing walls with New England Wetland Plants WETMIX or equivalent. Mulching with invasive free straw as necessary and as directed by the supervising wetland scientist.

Step 11: Complete roadway Following installation of utilities, culvert and completion of streambed restoration, complete the roadway with final grading, curbing, and paving.

Step 12: Restoration Monitoring a. Seasonal monitoring reports shall be prepared for the replication area by a qualified wetland scientist for a period of 2 additional years after installation. This monitoring program will consist of Page 16 of 27 a once-annual inspection, during spring or other time of year when the stream is flowing and vegetation is growing. Monitoring reports shall be submitted to the Commission by November 15th of each year. Monitoring reports shall describe, using narratives, plans, and color photographs, the physical characteristics of the streambed restoration area with respect to stability, soil characteristics (i.e. horizons, depths, texture, percent gravel and rock, organic matter, Munsell hue, value and chroma, consistence and evidence of hydrologic influence), survival of vegetation and plant mortality, aerial extent and distribution, species diversity and vertical stratification (i.e. herb, shrub and tree layers). Invasive species will be monitored and removed. The quantitative vegetative analysis should include a stem count for nursery stock, and vegetation plots to calculate percent cover and dominant species. b. At least 75%* of the surface area of the BVW restoration area shall be re-established with indigenous plant species within two growing seasons. If the replication area does not meet the 75% re-vegetation requirement by the end of the second growing season after installation or the presences of invasive species, the Applicant shall submit a remediation plan to the Commission for approval that will achieve, under the supervision of a Wetland Specialist, replication goals. This plan must include an analysis of why the areas have not successfully re-vegetated and how the Applicant intends to resolve the problem.

*It should be noted that portions of the restore stream bed (Land under Water Bodies) will consist of a muddy/gravel bottom and won’t have 75% vegetative coverage in these areas.

C. SEEDING LIST:

Proposed Seed Mixes for Stream Restoration

New England Wetland Plants WETMIX or equivalent * 3 lbs *Seedmix may be substituted with Conservation Commission consent

III. WETLAND CROSSING – WEBBER CIRCLE

References: See sheets 14, 16 and 41 of Site Plans cited in Order of Conditions DEP File #290- 1048.

A. LOCATION:

The wetland crossing at Webber Circle and shown on the Grading & Drainage Plan “B” & “C”. The crossing includes an arch culvert.

Page 17 of 27

B. GENERAL INSTALLATION PROCEDURES:

Timing: Work within the wetland shall take place during low-ponding to no-ponding conditions, which is typically between June 15 and October 15. a. If ponding is encountered, provide a temporary sand bag dam or pump system upgradient to divert water around construction area. b. Provide dewatering basin if pumping is required.

Step 2: Photograph Pre-Construction Conditions Supervising Scientist shall take detailed photographic and/or video documentation of pre-existing wetland conditions. This will aid in the restoration of pre-existing wetland conditions within the culvert after installation.

Step 4: Remove any potential wildlife habitat features This includes rocks, stones (at least 6-inches long +/-) or large woody debris. These features should be stockpiled nearby for later replacement within the culvert. Care should be taken to preserve moss on rocks. Wetland scientist will monitor mosses to prevent them drying out during culvert installation process.

Step 5: Excavate wetland depression material Preserve all soils within the crossing where not within the needed culvert footing excavation. Soils excavated shall follow the following steps. First excavate top 6+ inches of organic substrate. Stockpile material carefully in a designated location nearby for replacement in culvert with appropriate erosion controls. Top soils shall be kept moist until placement. Then remove remainder of wetlands subsoils to desired grade. Where no excavation is not necessary cover natural soils with fabric to keep soils protected during work.

Step 6: Install Culvert Footings Perform the culvert footing installation in accordance with approved structural engineered plans and details.

Page 18 of 27

Step 7: Restore wetland Following culvert footing installation, restore historic wetland depression. A. Grade wetland depression to match pre-existing conditions. Final micro-topography of the depression should be a sinuous configuration to match the profiles of the existing wetland above where the wetland is in its natural state. B. If the topsoil has been stripped, replace with stockpiled material. C. Place rocks or stones (6-inch +/-) in the wetland depression (try to use those existing on site if none were stockpiled) in a natural/random formation to approximate the existing historic wetland depression. D. Restore wetland area at each end of culvert and seed as noted below.

Step 8: Install Culvert Head Section Perform the Culvert Head Section installation in accordance with approved structural engineered plans and details. b. Once culvert head section is installed on footing complete touchup of bank restoration by hand within culvert.

Step 9: Shift Erosion Controls to allow ponding to natural occur Remove erosion controls that cross the wetland, and tie line of new erosion controls to culvert/wingwall interface. Install new erosion controls over culvert to prevent erosion into the wetland.

Step 10: Seeding of disturbed areas Hand seed disturbed areas of the wetland and adjacent areas downgradient of the wing walls with New England Wetland Plants WETMIX or equivalent. Mulching with invasive free straw as necessary and as directed by the supervising wetland scientist.

Step 11: Complete roadway Following installation of utilities, culvert and completion of wetland restoration at culvert inlet and outlet, complete the roadway with final grading, curbing, and paving.

Step 12: Restoration Monitoring Annual monitoring reports shall be prepared for the restoration area by a qualified wetland scientist for a period of 2 additional years after installation. This monitoring program will consist of a once- annual inspection, during spring or other time of year when the wetland has hydrology near the surface and vegetation is growing. Monitoring reports shall be submitted to the Commission by November 30th of each year.

Monitoring reports shall describe, using narrative and color photographs, the physical characteristics of the wetland restoration area near inlet and outlet with respect to flow characteristics, wildlife habitat features, soil characteristics, and survival of vegetation from the seed mix.

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C. SEEDING LIST:

Proposed Seed Mixes for Stream Restoration

New England Wetland Plants WETMIX or equivalent * 3 lbs *Seedmix may be substituted with Conservation Commission consent IV. STREAM RESTORATION

References: See sheets 17, 42-43, Site Plan cited in Order of Conditions DEP File #290-1048. Note Section D for schematics of stream construction.

A. LOCATIONS: Two (2) stream restoration areas are proposed as part of the Park Central Project. Each location is outlined below.

i. Stream Restoration – Park Central Drive

This stream restoration re-connects wetland “P” with wetland “F” by removing a 24” culvert with a 4.5-foot (bottom of bank) wide natural stream channel of 158 linear feet (LF) (316 LF of Bank, 1,027 SF LUW) and providing for a culvert that meets stream crossing standards.

ii. Stream Restoration – Blackthorn Extension

This stream restoration re-connects wetland “E” with wetland “G” by removing two 36” culverts with a 6-foot (bottom of bank) wide natural stream channel of 100 linear feet (LF)(200 LF of Bank, 800 SF LUW) and providing for a culvert that meets stream crossing standards.

B. GENERAL INSTALLATION PROCEDURES – STREAM RESTORATION

The following procedures shall be followed for both replication areas (John Boland Road & Webber Circle).

b. Provide dewatering basin or silt bag if pumping is required and dewatering is caring sediment.

Step 1: Stake Limits of Work, Confirm wetland flags in place & Install ECB Stake out limits of work for the stream restoration area and confirm wetland flags are in place on site. Erosion control barriers shall then be installed in the form of staked siltation fence and mulch sock (or similar invasive-free barrier) placed at the limit of work. These will remain in place and be maintained until the areas are completely stabilized and then may be removed after approval of the Conservation Commission. Wetland scientist shall have authority to require additional measures if deemed necessary.

Step 2: Identify shrubs and woody debris to protected saved The wetland scientist shall identify and flag any native shrubs within the work area may be dug up and stockpiled for replacing along disturbed areas. Any flagged specimens shall be removed and stockpiled in a designated area outside the replication areas. Any large woody debris (rotting logs) shall also be identified and flagged for stockpiling and subsequent addition disturbed area.

Step 3: Excavation of stream channel An excavator shall cut the proposed channel from one wetland system to the next with a construction level used to ensure that the stream has a gentle and meandering channel. Topsoil will be stockpiled for re-use, while sub-soil will be removed and brought within the project site area. All rocks found will be saved to place in the constructed stream channel. Channel bed will be excavated 6” below final stream bed elevation. Channel location will generally follow the site plan design, but may slightly differ from proposed plans depending on the purpose of protection trees roots and conditions encountered.

Step 4: Final Grading of Stream Bed and Bank Upon removal of soil within the constructed channel the top soil will be placed back on the constructed banks and stream bed. Slopes with 4’ of stream bed should not exceed 2H:1V were practicable. Substrate will be 18” depth consisting of 20% Stone, 12”+, 35% stone 6-12”, 25% river rock, 2-6”, 20% very coarse washed sand. Slopes along Stream bed shall be graded to less than 2H:1V where practical and shall have erosion control mats installed as necessary. Any disturbed wetlands in below crossing wing walls and along the bank below the graded slopes shall be restored with original soils.

Step 5: Stream Restoration: Add woody debris and stones Prior to seeding woody debris of various sizes when available should be placed randomly along the stream bed, but not if they inhibit stream flow. Stones (~6”-12”) should be placed randomly but at regular intervals (~4’) to create a meandering stream bed. An import of stones for this purpose is expected, but will consist only of river rock.

Step 6: Disturbed areas seeding The bank, stream bed and wetlands will be seeded by hand with New England Wetmix. Wetland areas disturbed shall Seeding may need to be completed more than once to ensure good establishment of ground cover. Erosion mats will be use to ensure bank stabilization. Page 21 of 27

Step 7: As-built Survey The constructed stream channels will be surveyed for as-built conditions. Survey should show location of top of bank and centerline of channel. The as-built plan will be submitted to the Conservation Commission when completed.

Step 8: Restoration Monitoring Annual monitoring reports shall be prepared for the restoration area by a qualified wetland scientist for a period of 2 additional years after installation. This monitoring program will consist of a once- annual inspection, during spring or other time of year when the wetland has hydrology near the surface and vegetation is growing. Monitoring reports shall be submitted to the Commission by November 30th of each year.

*It should be noted that portions of the restore stream bed will consist of a muddy/gravel bottom and won’t have 75% vegetative coverage in these areas.

C. SEEDING & PLANTING LIST:

Proposed Seed Mixes for Stream Restoration See below planting plan. Common Name Scientific Name Stream Stream Size Channel A Channel B Number Number

Trees* Red Maple (FAC) Acer rubrum 3 3 4-5’

Shrubs* Sweet Pepperbush (FAC+) Clethra alnifolia 7 7 3 Gal. pot Silky Dogwood (FACW) Cornus amomum 8 8 3 Gal. pot

Seed Mix New England Erosion Control/Restoration Mix for 3 lbs 3 lbs Detention Basins and Moist Sites or equivalent*

*Planting species and seedmixes may be substituted with Conservation Commission approval with similar native species with the same wetland indicator status if certain species are unavailable.

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D. STREAM DETAIL AND PLANTING SKEMATICS

STREAMBED EL. 391

STREAM SUBSTRATE (18” DEPTH): 20% STONE – 12”+ STREAM RIFFLE WITH 35% STONE 6-12” LOG AND STONES (12-24”) 25% RIVER ROCK – 2-6” 20% VERY COARSE WASHED SAND

STREAM POOL. 12” DEEP. BOT. EL. 390

STREAM RIFFLE WITH STONES (12-24”) STREAM POOL. 12” DEEP. BOT. EL. 391

STREAM RIFFLE WITH

LOG AND STONES (12-24”)

PLANTING LEGEND: STREAMBED

EL. 393.5 1 – TREE

3-SHRUB CLUSTER

Figure 7: Blackthorn Stream Restoration Plan “STREAM CHANNEL “A”” Sheet 42

STREAM POOL. 12” DEEP. BOT. EL. 391 STREAMBED EL. 393.5 STREAM POOL. 12” DEEP. BOT. EL. 390

STREAMBED EL. 391

Figure 8: Blackthorn Stream Restoration Profile Page 23 of 27

STREAM SUBSTRATE (18” DEPTH): 20% STONE – 12”+ 35% STONE 6-12” STREAMBED 25% RIVER ROCK – 2-6” EL. 404.6 STR EAM POOL. 12” 20% VERY COARSE WASHED SAND DEE P. BOT. EL. 404

c c

STREAM RIFFLE WITH STONES (12-24”)

STREAMBED STREAM RIFFLE WITH STREAM RIFFLE WITH EL. +/- 405.7 LOG AND STONES (12-24”) LOG AND STONES (12-24”)

STREAM POOL. 12” DEEP. BOT. EL. 403

PLANTING LEGEND:

1 – TREE

STREAMBED EL. 406.8 3-SHRUB CLUSTER

Figure 9: Park Central Drive Stream Restoration Plan “STREAM CHANNEL “B”” Sheet 43

Culvert

STREAMBED STREAMBED EL. 404.6 EL. 406.8 STREAM POOL. 12” DEEP. BOT. EL. 403

STREAM POOL. 12” DEEP. BOT. EL. 404

Figure 10: Park Central Drive Stream Restoration Profile

Page 24 of 27

V. BORDERING LAND SUBJECT FLOODING COMPENSATORY STORAGE

References: See sheet 15, 44, Site Plan cited in Order of Conditions DEP File #290-1048.

A. LOCATION:

The Compensatory Storage area shown on Sheet 15, 44 of the site plans adjacent to Phaneuf Drive/John Boland Road. See below figures in Section V.D. for further details.

B. GENERAL INSTALLATION PROCEDURES: Supervision: All grading work for the Bordering Land Subject Flooding (BLSF) Compensatory Storage shall be supervised by a qualified wetland scientist with a minimum of five years’ experience.

Step 1: Stake Limits of Work, Confirm wetland flags in place & Install ECB Stake out limits of work for the Compensatory Storage.

Step 2: Habitat Feature Preparation The wetland scientist shall identify wood debris (rotting logs), tree trunks and rocks to be saved in the area of the compensatory storage to be placed after grading is completed.

Step 3: Excavation and Grading of Compensatory Storage. An excavator shall excavate the Compensatory Storage as shown on the site plans. Compensatory storage will be excavated 6” below final elevation and top soil shall be added 6” in depth. After grading is completed Erosion Controls shall be added around the parameter of the BLSF Compensatory Storage Area to protect it from erosion from the rest of the site.

Step 4: Add Wildlife Features Upon placement of topsoil, wood debris (rotting logs), tree trunks and large rocks shall be placed randomly around the Compensatory storage area to provide habitat as instructed by the wetland scientist.

Step 5: Planting Precise citing of plants may be determined by the wetland scientist in the field prior to installation. All plantings shall be distributed randomly throughout the area; trees spaced at 10-15’ on center; shrubs spaced at 6-10’ on center and herbaceous species 3’ or less on center. All plantings will be removed from burlap sacks, wire cages and plastic containers prior to planting. Each plant will have it roots loosened prior to planting to encourage root growth away from the planting bulb. Leaf litter shall be spread throughout area if available. Seed mix shall be scattered evenly by hand throughout the Compensatory Storage Area. Once all work is complete an erosion control barrier will be installed to enclose the Compensatory Storage Area. See Figure 11 for planting layout.

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Step 6: As-built Survey The Compensatory Storage area will be surveyed for as-built conditions with 1-foot contours. The as-built plan will be submitted to the Conservation Commission when completed.

C. PLANTING AND SEEDING LIST

Proposed Seed Mixes for Stream Restoration Common Name Scientific Name Number Size Trees (n= 18, 215 SF per tree)* Red Maple (FAC) Acer rubrum 9 4-5’ Red Oak (FACU) Quercus rubra 9 4-5’ Shrubs (n= 40, 97 SF per shrub)* Sweet Pepperbush (FAC+) Clethra alnifolia 14 3 Gal. pot Witch Hazel (FACU) Hamamelis virginiana 13 3 Gal. pot Winterberry (FACW+) Ilex verticillata 13 3 Gal. pot Seed Mix New England Erosion 3 lbs Control/Restoration Mix for Detention Basins and Moist Sites or equivalent*

*Planting species and seedmixes may be substituted with Conservation Commission approval with similar native species with the same wetland indicator status if certain species are unavailable.

Page 26 of 27

D. BLSF DETAIL AND PLANTING SKEMATIC

Figure 11: BLSF Planting Plan

Page 27 of 27

Appendix A: Wetland Replication Checklist, Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, Mass DEP File #290- 1048, Goddard Consulting LLC, 1/9/2020.

GODDARD CONSULTING Strategic Wetland Permitting LLC

January 9, 2020

Southborough Conservation Commission Southborough Town Hall 17 Common Street Southborough, MA 01772

Re: Wetland Replication Checklist Park Central Notice of Intent, 0 Turnpike Road, Southborough, MA, Mass DEP File #290-1048

Goddard Consulting, LLC is pleased to submit this letter in response to the comments received regarding the Notice of Intent for the mixed residential development project (“Park Central”) located at 0 Turnpike Road in Southborough, MA (Maps 33, 41, 24, 25; Lots 4, 4.A, 3, 5). Responses are provided for the following comment issued in the peer review letter dated August 21, 2019 by Lucas Environmental, LLC. Original comments are restated in italics, and Goddard Consulting LLC response below.

42. LE recommends that the Applicant include a completed MassDEP Replication Guideline Checklist useful during the permitting phase of a project, but is not recommended during bidding and construction of the project. Introduction The proposed wetland replication areas have been designed in accordance with the MassDEP Massachusetts Inland Wetland Replication Guidelines

Reference the following documents.

• Project Narrative – Park Central, Goddard Consulting LLC, 1/9/2020 • Wetland Replication and Streambed Crossing Plan – Park Central, Goddard Consulting LLC, 1/9/2020 • Site Development Plans for Park Central.. (61 Sheets), Bohler Engineering, LLC 1/9/2020

The following is a response to the Mass DEP Wetland replication Checklist in ittalics with comments are in Bold.

I. MASSDEP WETLAND REPLICATION CHECKLIST

A. Sequencing (See Section 1.3 for further guidance)

1. The Notice of Intent should include the following information:

Narrative on avoidance of wetland Impacts.

A narrative has been submitted as part of the NOI filing documents noting avoidance of wetland impacts.

Narrative and plans showing minimization of wetland impacts.

A narrative has been submitted as part of the NOI filing documents noting minimizing of wetland impacts.

Narrative/drawings of alternative replication designs to ensure success.

A narrative was previously submitted discussing monitoring for success.

Carefully designed replication plans with identified goals for unavoidable impacts.

A narrative was previously submitted noting ways of avoiding impacts.

B. Elements of a Complete Replication Plan (See Section 2.3 for further guidance)

1. The application should include the following general information:

Narrative description of the existing and proposed wetland;

A. John Boland Road: The existing wetland is fringe wetlands to an intermittent stream bank with invasive shrubs and overhanding upland trees. The proposed replication area will provide wetland trees, shrubs and herbaceous vegetation with food sources for wildlife. Woody debris from the impact area to ensure woody debris habitat is still present in the area.

B. Webber Circle

The existing wetland is narrow wetland with invasive shrubs on each side of the wetland. The proposed replication area will provide wetland trees, shrubs and herbaceous vegetation with food sources for wildlife. Location was chosen to ensure invasive species (specifically Japanese’s Knotweed) aren’t near by.

C. Park Central Drive The existing wetland is an early successional forest with dense herbaceous cover.

2 The proposed replication area will provide wetland trees, shrubs and herbaceous vegetation with food sources for wildlife. Location was chosen provide habitat directly to restored stream channel.

A site location map (such as a USGS locus) of existing and proposed wetlands;

Site plans show existing wetland and proposed wetland replication.

A 1”=10’ to 1” = 40’ plan including easily identifiable landmarks (e.g. surveyed flag locations, benchmarks, or structures), contour lines at 1-foot intervals, and locations of soil test pits and vegetation plots. A Professional Land Surveyor (PLS) and/or a Registered Professional Engineer (PE) should stamp plans.

Site plans show existing wetlands and proposed wetland replication areas.

Grading should demonstrate elevation differences for different vegetation classes (forested, shrub, herbaceous, open water);

Notes to the plans have been added as due to size of replication area micro grading wasn’t shown. Each replication area is a forested wetland replication to replicated woods.

Surface area calculations demonstrating a minimum 1:1 replacement to impact ratio (consider greater than 1:1 to ensure the success of at least 1:1). Do not count side slopes as part of the replication area;

Project plans show replacement greater than 1:1.

Cross-sections of subsurface soil types, depths and locations, 100-year floodplain using both horizontal and vertical scale, existing and predicted high and low groundwater elevation, perched water conditions and other indicators of hydrology. Indicate cross- section locations on plan view;

Project plans show a cross sections of the proposed wetland replication areas.

2. Hydrology – The narrative and plans should include the following:

The expected seasonal depth, duration, and timing of both inundation and saturation must be established for the existing wetland and for each of the proposed vegetation class in the mitigation area.

A narrative has been submitted descripting depth, duration and timing of inundation and saturation.

3 Evidence of soil including free water in a soil test hole, soil color, saturated soil or oxidized rhizospheres.

1) John Boland wetland replication area (Wetland Flags C50/C51) a) Test Pit Location: upgradient of stonewall. Adjacent dry stream/BVW b) 0-18", Ap, 10YR3/4, sandy loam c) 18-28", Bw, 7.5YR4/6, sandy loam d) 28-39", BC, 10YR5/6, sandy loam e) 39-46", C, 10YR5/3, sandy loam f) Conclusion: Soils conditions are natural. Ground water is present deeper, but is similar elevation to delineated and peer reviewed wetland. Replication will replicate conditions of existing wetland. 2) Webber Circle wetland replication area (wetland flags M34 to M37-13) a) Test Pit Location: center of replication area. b) 0-12", Ap, 10YR3/3, sandy loam c) 12-18", C, 10YR5/2, sandy loam i) Redox, 5YR4/6 ii) Standing water at 12” 3) Park Central Drive wetland replication area (Wetland Flags G1/G2) a) Test Pit Location: 20-feet upgradient of wetland line (G1/G2), b) 0-16”, Fill, sandy gravel (10YR4/4) c) 16-20”, Cd,10YR5/2, sandy loam d) Weeping at 16” e) Redox 7.5YR5/8

In addition, the inputs and outputs in the water budget should be described. Ideally, replication areas should not depend on precipitation and sheet runoff flow only, but must have a seasonal source of groundwater and should have a surface water source as well. Perched wetlands may be established without these latter inputs, but monitoring wells or piezometers should demonstrate that runoff and precipitation inputs would exceed infiltration rates into the summer.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses how grading will ensure a seasonal source of ground water to the replication area.

Demonstration that groundwater and surface water will have unrestricted hydraulic connections to the replication area;

Site plan grading shows the connection of the replication area to the existing wetland.

Only the flood storage that the existing BVW provides should be designed in the replication areas;

4 No flood storage is proposed within the replication areas except that which is to replication impacted BVW that provides flood storage.

3. Soils- the narratives and plans should include the following information:

Test pits of translocated soils including horizons, characteristics such as texture, organic matter, Munsell hue, value and chroma, consistence and evidence of hydrologic influence, e.g. mottles (frequency and color), gleying, and root depth;

See above soil pit information.

Replication areas should have a minimum of 6-12” of A- Horizon soil. If used, soil amendments for the A-Horizon consist of equal volumes of organic and mineral materials. No woodchips should be used, and organic material should be well or partially decomposed.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses proposed soil depths and amendments. Amendments require lab testing to confirm organic content.

Enough A and B-Horizon material (or A over a suitable composition of the C horizon) should be provided to create a suitable rooting medium, and to approximate the conditions at the nearest undisturbed existing wetland. Consistency should be loose to friable and texture should be loamy sand to silt loam.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses proposed soil depths.

Although not required, use of Redox and pH Meters in the replication area and adjacent wetlands may aid in replication success. Seek guidance of a professional experienced in this testing.

Not required. Replication areas have wetland areas on two sides of each for good hydrological connections.

A detailed schedule for collection, stockpiling and placement of soils, including a discussion of techniques used to prevent the drying out and contamination of hydric soils.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses soil placement.

Confirmation that invasive species listed in Section 2.3.3 are not present in the vicinity of the soil to be translocated. 5

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses monitoring for invasive species.

If soil amendments will be brought from off-site, a description of the source, preparation and placement should be included.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses that any amendments will be lab tested to ensure organic quantity.

Discussion of a method to ensure appropriate compaction levels and the final consistency and texture of mitigation soils, by horizon.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses proposed soil texture by horizon and avoidance of compaction.

Survey of finished elevations during construction should be conducted frequently and a proposed schedule included.

The construction sequence in the Wetland Replication And Streambed Restoration Plan has an as-built proposed after final grading is completed.

Discussion of post-construction soil characteristics such as horizons, depths, texture, organic matter, Munsell hue, value and chroma, consistence and evidence of hydrologic influence, e.g. mottles (frequency and color), gleying, percent gravel and rock, and root depth;

The construction sequence in the Wetland Replication And Streambed Restoration Plan outlines documenting post construction soil characteristics.

4. Vegetation- narratives and plans should include the following information:

The dominant plants in each layer of the existing and proposed wetland and the relative cover and wetland indicator status for each vegetative layer proposed (herbaceous, shrub, sapling, tree and climbing woody vine);

The construction sequence in the Wetland Replication And Streambed Restoration Plan outlines documenting of vegetative coverage during the monitoring.

Transplantation techniques including maintenance of viability of seeds, rootstock and plants during transplantation. Shrubs should be planted 8-10” on center and trees should be planted 10-15’ on center unless otherwise recommended by a nursery or wetland professional.

6 Plantings quantities have been specified in the Wetland Replication And Streambed Restoration Plan for the recommended spacing.

Consideration should be given to leaving mature trees on hummocks for shading if they are facultative or wetter.

The construction sequence in the Wetland Replication And Streambed Restoration Plan gives the wetland scientist discretion on leaving mature trees.

A detailed description of sources of off-site plant material, species list, and methods to be used for planting.

The construction sequence in the Wetland Replication And Streambed Restoration Plan provides details on plants, species list and methods of planting.

Schedule for planting (at the beginning or end of the growing season - before the first frost). Check each species for ideal planting times. See Appendix 2 for growing seasons.

The construction sequence in the Wetland Replication And Streambed Restoration Plan provides details on the timing of plantings during the growing seasons.

Wetland vegetation expected after two growing seasons as well as predicted community after natural succession.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses monitoring of the wetland replication area.

Contingency plan in case of mortality of vegetation, invasive species, complete failure, inadequate size, etc.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses when a contingency plan will be prepared based on replication review.

For larger projects micro topography should be shown in cross-sections including number of mounds and pools if proposed to replicate existing conditions.

The construction sequence in the Wetland Replication And Streambed Restoration Plan discusses micro topography and cross sections of the replication area are provided on the site plans.

5. Wildlife Habitat

Documentation of the Estimated Habitat Map of State-Listed Rare Wetlands Wildlife findings for the site should be included.

7 No habitat is mapped on the site for State-Listed Rare Wetlands Wildlife. This was noted in the NOI.

For projects impacting the wildlife habitat functions of BVW’s, wildlife habitat characteristics of the site, including vernal pools, should be described and replicated. Design should include diversity of vegetation structure and composition, and of hydrological conditions. Credentials of wildlife habitat specialist should be included.

A wildlife habitat evaluation has been conducted as part of the project.

6. Stormwater Management

Created wetlands for stormwater “best management practices” shall not be given credit as replication areas;

Replication areas are not near any stormwater discharges nor is it part of any stormwater “best management practices”.

7. Erosion Control- narratives and plans should include the following:

An erosion control plan that details stabilization techniques during construction and a contingency plan for construction and post- construction periods.

Site plans show erosion control. Wetland Replication And Streambed Restoration Plan also outlines erosion control plan.

A commitment to remove erosion control measures once the site is stabilized and following approval by the issuing authority.

The construction sequence in the Wetland Replication And Streambed Restoration Plan has this language in its sequence.

Embankment slopes should be no greater than 2H:1V unless structural stabilization.

Slopes will be graded to be less than 2H:1V unless boulders are present.

C. Considerations During Construction (See Section 3.0 for further guidance)

The erosion and sedimentation control plan must be implemented.

Site plans show erosion controls. Wetland Replication And Streambed Restoration Plan requires installation of erosion and sedimentation control prior to earth disturbance for the replication areas.

8 The wetlands and replication area should be reflagged prior to construction start date if the flags placed during permitting are not clearly visible.

The construction sequence in the Wetland Replication And Streambed Restoration Plan has this requirement.

A construction schedule listing the sequence of events for replication construction (preferably before work in the existing wetland);

The construction sequence in the Wetland Replication And Streambed Restoration Plan has this provided.

A project monitor with a minimum 5 years experience should be identified;

The construction sequence in the Wetland Replication And Streambed Restoration Plan and site plans have this requirement.

D. Monitoring Plan (See Section 6.0 for further guidance)

A plan to monitor the construction and subsequent growth for at least two years or until the 75% criteria is met following construction should be included (See Appendix 3 for example checklist). Include contingency plan in the event that the replication area does not meet the 75% reestablishment standard.

The construction sequence in the Wetland Replication And Streambed Restoration Plan has this requirement.

Colored photographs from established reference points should be included with each monitoring report.

The construction sequence in the Wetland Replication And Streambed Restoration Plan has this requirement.

Plan must include inspection of embankments to ensure that they are stable, properly vegetated and constructed as designed.

The construction sequence in the Wetland Replication And Streambed Restoration Plan outlines to review of stable conditions.

Appendix B: John Boland Wetland Replication Plan 11x17 To Scale Plan Dated 3/5/2020

T E

W G

W E

C C

B T

G W W

C C

& B

W G E CB

T E

E G C

C W PROP. RETAINING &

T E WALL (DESIGN BY

A OTHERS) (TYP.) G

C C

& W B T

& E T W

C E B PROP.

CURBLINE (TYP)

& T W 4

E E + A 5 0 C B EXIST. WETLAND 41.7' LINE (TYP) PROP. WETLAND PROP. EROSION

CONTROL

REPLICATION AREA G

C PROP. 115 LF

BARRIER (TYP.) &

(410 SF / 1:1 RATIO) T W E OF BANK

E C ALTERATION

EXIST. STREAM

BANK (TYP) C

& W T E

' E PROP. 431 SF LUW 2 C . B 1 ALTERATION

G PROP. GUIDERAIL & W

T E (TYP.) E C B PROP. GAS MAIN (TYP.)

C W

G C

& B

T PREVIOUSLY E PROPOSED WETLAND E C REPLICATION AREA B

E C

PLANTING LEGEND: B

*FERNS NOT SHOWN W

J G

& T O

1 – TREE E

C B N R

W C

O B

+/-3 – SHRUB CLUSTER G &

T E O

(13 WETLAND SHRUBS) A

E + L

D C

(4 UPLAND SHRUBS) PROP. RETAINING 4 B WALL (DESIGN BY A

OTHERS) (TYP.) C G

10 5 2.5 0 10 &

T D

PROP. ELECTRIC, E PROP. WATER E TELEPHONE, & C MAIN (TYP.) B

1"= 10' CABLE (TYP.)

C W

G E &

Date:C 3/5/2020 T B E P:\18\W181057\Drawings\Plan Sets\REV2\W181057_ss2.dwg, Snow Storage Exhibit, 10/6/2014, 4:26:00 PM, cdesocio, AutoCAD PDF (General Documentation).pc3, ARCH full bleed D (36.00 x 24.00 Inches), 1:1 Y-SERIES WETLAND 1. NOTES: 2. NON-JURISDICTIONAL EXCESS SNOWTHATCANNOTBESTOREDONSITESHALLREMOVEDINACCORDANCEWITH REFER TOSNOWANDICEMANAGEMENTCONTRACTFORANTICIPATEDOPERATIONS. LOCAL, STATEANDFEDERALSTANDARDS. SNOW WILLBEPLOWEDANDSTOREDALONGEDGEOFTHEROADSPARKINGAREAS. DRAINAGE DITCH SERIES AA-BB (I-SERIES WETLAND) EXIST. BASIN3 PROP. STORMWATER MANAGEMENT AREA (TYP.) G-SERIES WETLAND (H-SERIES WETLAND) EXIST. POND2 POND

H-SERIES WETLAND BLACKTHORN BLACKTHORND DRIVE

(PUBLIC ~ 50' WIDE) EXTE

E-SERIES WETLAND NSION 100' VERNALPOOL BUFFER (TYP.)

F-SERIES WETLAND

TARA ROAD ROAD TARA BERRY CIRCLE BERRY P-SERIES WETLAND (D-SERIES WETLAND) EXIST. BASIN1

100' VERNALPOOL BUFFER (TYP.) (PUBLIC ~ 40' WIDE) 40' ~ (PUBLIC DA-SERIES WETLAND

INTERSTATE ROUTE495

(1961 STATEHIGHWAYLAYOUT) "A" DRIVEWAY

WEBBER CIRCLE WEBBER BANTRY ROAD BANTRY B-SERIES WETLAND

O-SERIES WETLAND DRIVEWAY "B" DRIVEWAY R-SERIES WETLAND (B-SERIES WETLAND) EXIST. PONDA-2

POND

HOLMES DRIVE HOLMES (PUBLIC ~ 40' WIDE) 40' ~ (PUBLIC

PARK CENTRAL DRIVE Z-SERIES WETLAND

PHANEUF DRIVE

WEBBER CIRCLE (A-SERIES WETLAND) R-SERIES ISOLATED WETLAND EXIST. BASINA-1

PHANEUF DRIVE M-SERIES WETLAND N-SERIES ISOLATED WETLAND MANAGEMENT AREA PROP. STORMWATER (TYP.) Q-SERIES ISOLATED WETLAND

100' VERNALPOOL BUFFER (TYP.) FLAGG ROAD ROAD FLAGG

JOHN BOLAND ROAD

JOHN

C-SERIES WETLAND WIDTH) (PUBLIC-VARIABLE BOLAND

D ROAD PARKD CENTRAL DRIVE

D D 150

LEGEND LAYOUT) HIGHWAY STATE (1930

BOSTON AND WORCESTER TURNPIKE D WORCESTER AND BOSTON SNOW STORAGEAREA 75 9) (ROUTE

37.5 D

D 1"= D

D 0 D 150' D

D 150

D D

D REV 15 14 13 12 11 10 J.A. KUCICH DEVELOPMENT www. 9 8 7 6 5 4 3 2 1 DATE: DRAWN BY: PROJECT No.: SHEET TITLE: PROJECT: CAD I.D.: CHECKED BY: SCALE: SHEET NUMBER: TM PROFESSIONAL ENGINEER SOUTHBOROUGH, MA01772 LOCATION OFSITE DATE WORCESTER COUNTY, MASSACHUSETTS LICENSENo.41530 STORAGE MAP #33-PARCEL#4& Fax: (508)480-9080 BohlerEngineering Phone: (508)480-9900 MAP #24-PARCEL#3, 352 TURNPIKEROAD CONNECTICUT LICENSENo.26177 MAP #25-PARCEL#5, MAP #41-PARCEL4A RHODE ISLANDLICENSENo.9616 EXHIBIT PRELIMINARY MASSACHUSETTS SOUTHBOROUGH MAINE LICENSENo.12553 PARK CENTRAL REVISIONS SNOW REV 0-03/02/2020 PLANS SITE OF FOR

1 SITE CIVIL AND CONSULTING ENGINEERING

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