HEARINGS, MEETINGS, LICENSES 8/10/2020 6:30 PM JOINT MEETING w/ Planning Board and Southcoast Rail ` August 6, 2020 Ms. Leeann Bradley Town Planner Town Hall Annex 20 Center Street Middleborough, MA 02346 RE: South Coast Rail – Middleborough Pilgrim Station Peer Review Dear Ms. Bradley, This letter is to advise that we have reviewed the revised materials submitted for the proposed South Coast Rail Pilgrim Station project prepared by various consultants for the Massachusetts Department of Transportation. The revised materials submission includes the following documents: • Plans entitled “Massachusetts Bay Transportation Authority, SCR MS/NBML. Commuter Rail Expansion Project, Middleborough to New Bedford, MA, Contract No. K78CN04, Middleborough Secondary, Middleborough Station,” sheets LM-101, LM-102, GD-101, and GD-102, prepared by the VHB/HNTB Team, dated 3/16/2020. • Sheet indicating station parcel and driveway easements prepared by the VHB/HNTB Team, dated 3/16/2020. • Response to comments letter prepared by VHB dated April 2, 2020. • Report entitled “Stormwater Report, Middleborough Station, Middleborough, Massachusetts,” prepared by VHB, dated February, 2020. • Plans entitled “Massachusetts Bay Transportation Authority, SCR MS/NBML. Commuter Rail Expansion Project, Middleborough to New Bedford, MA, Contract No. K78CN04, Middleborough Secondary, Middleborough Station, Lighting Photometrics Plan” prepared by the VHB/HNTB Team, dated 3/16/2020. We understand that the project is not undergoing a formal review process associated with obtaining local approvals. However, Environmental Partners has been asked to review the documents listed above for consistency with the 2008 Massachusetts Stormwater Handbook, Middleborough Zoning Bylaws –amended through 10/5/15 Town Meeting; Middleborough, Massachusetts; and standard engineering and land development best practices. envpartners.com Page 2 BACKGROUND The proposed Pilgrim Station is located at an existing MBTA facility adjacent to Grove Street (Route 28) in Middleborough. The Station is proposed to be located at the intersection of two existing rail lines, the Middleborough Secondary Line and the Middleborough Main Line. The Middleborough Main Line is currently active and provides service to the Middleborough/Lakeville Station. The Middleborough Secondary Line is proposed to be upgraded between the Cotley Junction Station in East Taunton and the proposed station. The property is currently operated as an MBTA rail facility and includes stockpiles of materials related to MBTA operations. This station is one component of the much larger South Coast Rail project that has been undergoing design and permitting for years. The proposed Middleborough – Pilgrim Station project is part of the MBTA’s strategy to provide commuter rail service to the Fall River and New Bedford areas on a faster timeframe than originally contemplated and approved. The project originally received approvals from the Massachusetts Office of Energy and Environmental Affairs on the Final Environmental Impact Statement (FEIS)/Final Environmental Impact Report (FEIR) in 2013. The Middleborough Station is proposed to include 501 new parking spaces, a new 800 foot long station platform with associated canopies, sidewalks, access driveways, lighting, open space, and associated utilities including a stormwater management facility. An access driveway to the facility is proposed from the existing intersection of the Route 495 on ramps and South Main Street (Route 105) to the proposed parking areas. This intersection would be redesigned to include four legs rather than the three that currently exist. Other offsite traffic improvements are also proposed to accommodate the increased traffic generated by the station. The project is located in the General Use District per the Town of Middleborough Zoning Bylaw. The project is located in the Water Resources Protection District, WPRD-Z2. It is also located in a Zone II to a public drinking water supply. This letter is in regards to the civil/site improvements only. A subsequent letter will be issued regarding transportation and traffic related impacts. COMMENTS Please see our comments below regarding the proposed project. Our comments note missing items and noncompliance with various standards. Middleborough Zoning Bylaws 1. Per Section 3.1 of the Zoning Bylaw, the proposed use is an allowed by-right use in the General Use District. VHB Response 4/2/20: For comments 1 through 12 in this section, MBTA is exempt from local zoning by-laws. Where clarifications or more detail is applicable to the comment, we have provided that information. The MBTA will attempt to satisfy the intent of the by-law to the extent practicable regardless of the exemption, provided that this does not conflict with standard operating procedures on the system or capacity requirements of the train station facility. This is reflected in our responses. envpartners.com Page 3 EP Response 8/6/20: Consistent with our discussions with the Town of Middleborough, EP was requested to review the project for consistency with local requirements. 2. Per Section 4.1.1 of the Zoning Bylaw regarding dimensional requirements, there is a maximum of 60% impervious cover in the General Use District. Impervious surfaces are defined as land covered by buildings, roads, driveways, sidewalks, parking areas, loading areas, service yards or other improvements which do not allow precipitation or surface water to penetrate directly into the soil. The SDEIR describes the proposed station as having 71% impervious surface coverage in the proposed condition. VHB Response 4/2/20: Within the railroad parcels and permanent easements, the impervious coverage is 23% (410,000 SF +/- impervious versus 1,800,000 SF+/-). The total lot area is the combination of railroad property within and including the railroad rights of way between Route 28 and I-495, and the driveway permanent easements on 161 South Main Street as illustrated in the MST Parcels Impervious area.pdf attachment. While not required to comply with the by-law, we have confirmed that impervious cover will not exceed the 60% maximum set by the Town. EP Response 8/6/20: The applicant has submitted a plan that shows the lot extents. Based on this plan, their estimate of 23% impervious surface appears reasonable. 3. Section 5.3.10.1 of the Zoning Bylaw requires that all parking spaces be 10 feet wide and 20 feet long. However, the proposed project includes parking spaces that are only 8.5 feet wide and 17 feet long. This section also requires that the minimum aisle width be 24 feet. The proposed project provides aisle widths that are 26 feet or 30 feet wide, which exceeds this requirement and may contribute to additional impervious area. VHB Response 4/2/20: The station is required to follow the MBTA requirements for parking spaces and drive aisles at this station and at the other SCR station sites. The dimensions noted above provide for a functional parking and circulation area, which helps reduce the overall paved area required to meet the parking space count for this station. EP Response 8/6/20: As described in the applicant’s response, the project design does not comply – or intend to comply – with local regulations. This results in additional impervious surface and stormwater flows from the project when compared to design requirements outlined in the local regulations. 4. Section 5.3.10.2 of the Zoning Bylaw requires that parking spaces are not located within 15 feet of the rear or side lot lines in the GU District. It is unclear whether the proposed project meets this requirement since the property lines are not clearly shown on the plans. The Applicant should add the property lines to the layout plans and indicate the distances of the parking areas from the property lines. envpartners.com Page 4 VHB Response 4/2/20: The side lot lines are the outer boundary of active railroad right of way and State Highways. The offset from side lot line to parking is approximately 61’ from Route 28, 78’ from easterly Railroad R/W line, and 82’ from westerly railroad R/W line. Property lines have been added on the layout plans with offset dimensions from the edge of parking to the property lines (attached). EP Response 8/6/20: Item closed. No additional comments. 5. Section 5.3.10.10 of the Zoning Bylaw requires the maximum width of driveways at the street line to be 30 feet and have a minimum curb radius of 15 feet. The entrance to the facility at South Main Street (Route 105) is labelled as ‘Not in Contract’ and appears to exceed these requirements. The dimensions of this entrance are not labelled. We recommend the Applicant label the anticipated driveway width and curb radii. VHB Response 4/2/20: The 2-lane section is 30ft, the 3-lane section is 50ft (including shoulders and the median required by MassDOT highway). It is not labeled in these plans because it will be constructed in the contract package with the off-site mitigation improvements. Dimensional labels will be added for context as suggested. EP Response 8/6/20: As described in the applicant’s response, the project deviates from the local regulations. 6. Section 5.6.1.1 of the Zoning Bylaw requires a landscaped buffer of 25 feet along the street line and not less than 15 feet along the side and rear lot lines. It does not appear that the proposed project meets this requirement along the sides of the proposed parking areas. The proposed project provides some landscaped areas along the entrance drive consisting of eight trees. VHB Response 4/2/20: As noted above, the side yard lines are the outer boundary of the railroad right of ways and the only street line that the lot fronts on is West Grove Street (Route 28). There is an approximately 60-foot buffer on the site’s frontage with Route 28, which is interspersed with the pedestrian connections thereto, which we believe complies with the 25’ street line buffer bylaw intent.