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Strysky, Alexander (EEA)
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Cc:
Subject:
Petitpas, Christian (FWE)
Thursday, April 09, 2015 9:14 AM
Strysky, Alexander (EEA)
'Chatham Conservation Commission'; 'Chatham Conservation Commission'; Ford, Kathryn
(FWE); Lehan, Richard (FWE); Chin, Ken (DEP); Boeri, Robert (EEA);
[email protected]; [email protected]
EEA# 15338, Town of Chatham Ryder's Cove Parking Lot
Secretary Matthew A. Beaton
Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office
Alexander Strysky, EEA No. 15338
100 Cambridge Street, Suite 900
Boston, MA 02114
Dear Secretary Beaton:
The Division of Marine Fisheries (MarineFisheries) has reviewed the Environmental Notification Form by the
Town of Chatham for proposed expansion and improvements to the Ryder's Cove Parking Lot at 784 Orleans
Road in the Town of Chatham. The project was reviewed with respect to potential impacts to marine fisheries
resources and habitat.
The scope of work as currently proposed is not expected to impact marine resources, so MarineFisheries has no
recommendations for sequencing, timing, or methods that would avoid or minimize impact at this time.
Questions regarding this review may be directed to John Logan in our New Bedford office at 508-990-2860
ext. 141.
Sent on behalf of John Logan
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Strysky, Alexander (EEA)
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Attachments:
Tom & Heidi Quill [[email protected]]
Sunday, April 12, 2015 4:54 PM
Strysky, Alexander (EEA)
Ryder's Cove chatham,MA.
BookScanCenter.pdf; ATT00002.htm
Please confirm receipt of this email and advise what the response is to these comments.
April 11, 2015
Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs [EEA]
Attn: MEPA Office
Alex Stryski EEA#15338
100 Cambridge Street, Suite 900
Boston, MA 02114
Ryder’s Cove Chatham
Dear Mr. Secretary,
Please accept these comments in response to the Environmental Notification Form on this project.
Please see the Letter to the Editor of the Cape Cod Chronicle of April 24, 2014 submitted by Mr. Tim Boland, a
noted plant ecologist and taxonomist in reference to the site which the current plan before MEPA calls for
turning into a parking lot. Mr. Boland makes several important points which I feel require close scrutiny by
MEPA before a certification is considered. He refers to further fragmentation and disconnection of habitat
which is ‘the last hope for ecosystems services’; to the detriments of asphalt paving or open parking; and to the
impact on the capacity of the land to filtrate pollutants.
In my opinion, the information submitted by the proponent does not adequately address the important points
brought out Mr. Boland. Nor did it appear that Mr. Stryski evaluated these matters during his April 9 site visit.
I respectfully request that an Environmental Impact Report be carried out for this project.
There are several other problems with this proposal:
Lack of data to justify taking such a large portion of the site. This site gets heavy usage by vehicles with trailers
only a few [maybe 15-20] days a year depending on the fishing action. Even the information in proponent’s
submission does not seem to justify the need for an ADDITIONAL 34 parking spaces.
The proponent’s plan calls for a 50’ buffer between the parking area and the top of the bank. Is this sufficient?
The town has not given serious, public consideration of Alternatives. Some have been proposed by supporters
of conserving the land , but the town seems fixated on this plan which , with minor changes , has been roundly
rejected by Town Meeting at least twice in the last 12 years. A difference for this year’s Town Meeting [May
11] is that funds [$900,000] are included in the proposed budget.
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For numerous reasons, an environmentally devastating, costly parking lot is not appropriate here. I respectfully
suggest that a full scale analysis by MEPA is in order for the public to learn just how critical this site is in the
ecosystem of adjacent land and waterway.
Very truly yours,
Thomas H. Quill, Jr.
85 Stillwater Rd.
Chatham, MA 02633
401 965-6025
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Strysky, Alexander (EEA)
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Cc:
Subject:
Michele Molony-Kitts [[email protected]]
Monday, April 20, 2015 8:40 AM
Strysky, Alexander (EEA)
'Joe Kitts'
EPA application Ryders Cove parking lot Chatham Ma.
Dear Mr. Strysky,
I am writing as I understand that the EPA will be reviewing the proposal by the Town of Chatham to place a large
concrete parking lot at Ryder’s Cove town landing to accommodate out-of-town fisherman during the peak season. My
husband and I would like to share with you our concerns. We are home-owners in the neighborhood – 35 Lords Pond
Lane - and while we are currently based in Arlington Va, we look forward to the near future when we will be able to call
Chatham home. We bought our house because of the peaceful land it sits on, stretching back across a small stream and
the proximity to Ryder’s Cove and the beautiful and historic Marconi Center. We are daily visitors – on foot – to both
Ryder’s Cove and the park. At any time of day or weather the walk is lovely. The mornings are quiet, tree filled and
lovely and the evening light is spectacular. It is so hard to imagine why a community that is so protective of the
environment – especially given the already fragile ecosystem and noise and pollution thanks to Route 28 – would
approve taking an acre of such beautiful land for a concrete parking lot. Approval of this plan will require the removal of
many trees and laying down almost an acre of concrete, very near the fragile ecosystem of the inlet which is rich in bird
life including osprey nests. Of course we defer to the expertise of the EPA to determine the potential effect on flooding,
in an area already at high risk.
Our understanding is that there has never been a study to truly assess the need for such a large lot, which essentially
destroys vital land for what amounts to several weeks of use during peak season. (A plan that I would add has been
turned down by voters in the past.) As a daily walker for almost 10 months of the year from August to mid-June, I can
assure you that parking is not an issue and the majority of the existing parking spots are always empty. But what makes
this worse, is that there is a strong alternative plan that does not require this level of destruction for peak periods of
parking need.
We have had the opportunity to review the plan proposed by the Friends of Ryder’s Cove Marconi Waterside Triangle
and it seems like a reasonable approach. It preserves the natural habitat while providing strong alternative parking
provisions. It will make the space more user friendly to all types of visitors. In addition we are pleased the Town
recently approved using resources to improve the triangle park. As residents of the neighborhood, we also risk our lives
everyday when we cross Route 28 so we are highly supportive of the effort to accommodate not only seasonal large
trucks and trailers but also year-round pedestrians and walkers! The pedestrian operated light will be a huge
improvement. Above all the new plan will also help to create a feeling of unity between Ryder’s Cove, the historically
important Marconi Center and the lovely park and overlook.
On an added note, we have recently been approved by the Conservation Commission to do a significant restoration
project on our own acre of land to try to remove the invasives and regain its natural beauty – at great expense! We
have countless birds in the area including red tail hawks, herons, and owls along with migrating birds. I can assure you
that a private citizen would NEVER get approval for what is proposed by the town. If you are considering agreeing to
this proposal, before you do, I ask you to come and visit this lovely historic spot filled with natural beauty and seriously
look at the parking in the alternative plan. The proposed compromise plan demonstrates that balance between
appropriate development and accommodation of fishermen and boat owners while protecting a piece of nature that,
once removed, can never be returned….as Joni Mitchell so eloquently stated “pave paradise and put up a parking lot”.
We hope you will seriously consider our position as residents and reject this request.
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Thank you so much for your consideration.
Best
Michele and Joe Kitts
35 Lord’s Pond Lane
Chatham, MA.
p.s. can you please let us know that you received this email – I am not certain of the address!
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FRIENDS of RYDER’S COVE MARCONI WATERFRONT TRIANGLE
Secretary Matthew A. Beaton
Executive Office of Energy and Environmental Affairs
Attn: Alex Strysky, MEPA Unit
100 Cambridge Street, Suite 900, Boston, MA 02114
EEA#15338.
Re: Ryder’s Cove Parking Improvements/Expansion, Former Marconi-RCA Property, 784
Orleans Road, Chatham, 02650
Dear Mr. Strysky,
Thank you for your April 3rd site visit to Ryders Cove, Chatham. I hope the following
information helps with the review process and requirements for the Ryder’s Cove Project from
the standpoint of environmental impact.
Background. The Marconi Ryder’s Cove Triangle is part of the Town of Chatham, 1999
purchase from MCI, International. The sale encompassed the entire Marconi/RCA National
Register of Historic Places land and 10 buildings. It is the only remaining, unaltered Marconi
wireless station complex left in the world. This unique site is significant not only locally, but
nationally and internationally. Friends of Ryder’s Cove Marconi Waterfront Triangle (Friends)
are a grass roots group of Chatham residents working to improve the triangle for general public
enjoyment. Since 1999, improvements on the triangle and public property betterment projects
done by Friends’ volunteers and by AmeriCorps have been approved by the Conservation
Commission and the Selectmen. A Town approved Woodland Trail was created in 2011. In the
past, two town commissions, and ten organizations have written letters of support for a park on
the upland. Since the 1999 purchase, two parking lots have been created on the triangle to serve
the Town Landing. Thus, the recommendation of the Town of Chatham Comprehensive Plan of
2003, to increase parking for the Town Landing, has been addressed. But significantly,
additional parking lots on the upland have been turned down three times at Town Meeting.
Moreover, a “haulout” located on the site was denied by the Zoning Board of Appeals in 2003.
History. The land has a long a history. The site was headquarters for the Monomoyicks, with
their headquarters at the head of Pleasant Bay near Ryder’s Cove and Crow’s Pond.1 The triangle
was part of William Nickerson’s First Purchase. The North Chatham Marconi wireless station
complex turned 100 years old in 2014. When it was constructed, Marconi had the foresight to
create a parkland on the triangle to benefit employees. It was later used by the U.S. Navy service
personnel in both World Wars 2 and by employees of the RCA Marine Wireless Station.
ATTACHMENT 1 MASSACHUSETTS ARACHAEOLOGICAL SOCIETY, INC., Volume XIX, NO.4, JULY, 1958. P.53, THE OLD SAGAMORE:
MATTAQUASON OF MONOMOYICK by W. SEARS NICKERSON
ATTACHMENT 2 EARLY 1916 PENCIL SKETCH OF U.S. NAVY PARKLAND & RCA EMPLOYEES & WW2 NAVY USE OF PARKLAND
2.
Alternatives. The Friends have proposed alternative suggestions for increased parking and for
easing congestion during peak Town Landing use, but they have been dismissed by the
Waterways Advisory Committee (WAC). At the MEPA site visit on April 3, 2015, Alex
Strysky was given a copy of the Friends Alternative Plan.3 Our plan for increased parking saves
most of the wide portion of the upland. Foremost, it is our objective to share the widest part of
the upland with residents/visitors who may not be boaters, but who enjoy the opportunity for
outdoor recreation and the natural setting that the site provides. The WAC plan is called a
compromise since there is a walking trail loop plan. We believe the narrow western section of
land 20’ to 30’ from the highway should be left naturally vegetated. It is apparent from the WAC
plan that it is not easy to get to the walking trail loop, the only entry is the internal roadway/
parking lot/maintenance area. At that point, the trail parking spaces could be filled with trucks
using the ramp (there will be no monitoring). Some of the existing vegetation would need to be
removed in order to create a 5’ trail loop. Friends plan narrower trails carefully designed to
avoid disturbance of vegetation. A ‘live lightly on the land’ option along the waterfront where
erosion is a concern. We believe research confirms that retaining the wooded landscape is more
in keeping with this environmentally sensitive site within the Pleasant Bay Area of Critical
Environmental Concern. Important environmental concerns are cited in a letter by Tim Boland
of the Polly Hill Arboretum, e.g., the wooded land removes 90% of hydrocarbons.4
The upland is marked by changes in elevation and would need extensive grading and soil
removal to create the permeable asphalt parking and asphalt roadways. Notes from WAC
meetings describe the parking problem as being caused by 90% out of Town rigs during Bass
fishing season for an estimated twenty-five days.5 Because of the resultant changes in topography
and the elimination of an over an acre of historic wooded landscape, we strongly believe the
WAC project will degrade the environmental, historic and aesthetic value of the site.6 A listing
of native plants currently on the parcel is included7. As it is, our waterside woodlands are fragile
and threatened by frequent storms due to changing weather patterns, as well as over
development. Most importantly, there is no current data on vehicular/traffic usage that justifies
this excessively large parking/roadway plan. Proponents of the WAC plan have relied on
anecdotes, rather than metrics, to make their case.
ATTACHMENT 3, 2015 FRENDS OF MARCONI WATERFRONT TRIANGLE PLAN
ATTACHMENT 4, TIM BOLAND LETTER
ATTACHMENT 5, WATERWAYS ADVISORY COMMITTEE NOTES & RIG PARKING DATA
ATTACHMENT 6. 1929 AERIAL PHOTO OF HEAVILY WOODED RYDER’S COVE TRIANGLE
ATTACHMENT 7, LISTING OF EXISTING NATIVE PLANTS AND PICTURES OF SITE WITH VISION OF A FUTURE PARK
MEMORANDUM
TO:
Alex Strysky, Environmental Reviewer, MEPA Unit
THROUGH: Jonathan Hobill, Regional Engineer, Bureau of Water Resources
Philip Weinberg, Regional Director
David Johnston, Deputy Regional Director, BWR
Maria Pinaud, Deputy Regional Director, BAW
Millie Garcia-Serrano, Deputy Regional Director, BWSC
Jennifer Viveiros, Acting Deputy Regional Director, ADMIN
CC:
Elizabeth Kouloheras, Chief, Wetlands and Waterways
Jim Mahala, Wetlands Program
Pamela Truesdale, Municipal Facilities
Leonard Pinaud, Chief, Site Management
Allen Hemberger, Site Management
FROM:
Sharon Stone, SERO MEPA Coordinator
DATE:
April 28, 2015
RE:
ENF EOEEA #15338 – CHATHAM – Ryder’s Cove Parking
Improvements/Expansion
784 Orleans Road
************************************************************************
"For Use in Intra-Agency Policy Deliberations"
The Southeast Regional Office of the Department of Environmental Protection
(MassDEP) has reviewed the Environmental Notification Form (ENF) for the proposed
“Ryder’s Cove Parking Improvements/Expansion” project to be located at 784 Orleans
Road, Chatham, Massachusetts (EOEEA #15338). The project proponent provides the
following information for the project:
Permits listed in the ENF to be sought for the project include the following:
MassDOT Highway Access Permit
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Wetlands and Waterways Program Comments
The Southeast Regional Office, Wetlands and Waterways Program have reviewed the
above-referenced Environmental Notification Form (ENF) and have the following
comments. The project proposes the expansion and improvements to the parking
facilities at the Town of Chatham’s Landing at Ryder’s Cove. Specifically, the project
proposes the expansion of the parking lot by 34 spaces and stormwater improvements.
According to the ENF, the proposed parking lot expansion is located in an upland area
within the buffer zone to a coastal bank. The project will impact approximately 42 linear
feet of man-made coastal bank in connection with moving five existing parking spaces
out of the proposed travel lane to Ryder’s Cove Road. The proposed work is also
partially within the FEMA-designated 100-year floodplain (Zone AE, elevation 11) and
within the Pleasant Bay Area of Critical Environmental Concern (ACEC).
The proposed parking lot expansion will utilize pervious pavement and stormwater
treatment BMP’s prior to subsurface infiltration. No new untreated stormwater runoff
will discharge to Ryder’s Cove.
The proposed project will require the filing of a Notice of Intent (NOI) and receipt of an
Order of Conditions under the Wetlands Protection Act. The proposed NOI will need to
demonstrate compliance with the Massachusetts Stormwater Standards at 310 CMR
10.05(6)(k-q).
Construction Stormwater Permit
The project construction activities may disturb one or more acres of land and therefore, may
require a NPDES Stormwater Permit for Construction Activities. The proponent can access
information regarding the NPDES Stormwater requirements and an application for the
Construction General Permit at the EPA website: http://cfpub.epa.gov/npdes/stormwater/cgp.cfm
Stormwater Mitigation
To the extent that it is feasible, it is recommended that permeable pavement be used to
minimize stormwater flow.
Bureau of Waste Site Cleanup
Based upon the information provided, the Bureau of Waste Site Cleanup (BWSC)
searched its databases for disposal sites and release notifications that have occurred at or
might affect the proposed project area. A disposal site is a location where there has been
a release to the environment of oil and/or hazardous material that is regulated under
M.G.L. c. 21E, and the Massachusetts Contingency Plan [MCP – 310 CMR 40.0000].
There are no listed MCP disposal sites located at or in the immediate vicinity of the
proposed project area. Interested parties may view a map showing the location of BWSC
disposal sites using the MassGIS data viewer (Oliver) at:
http://maps.massgis.state.ma.us/map_ol/oliver.php Under “Available Data Layers”
select “Regulated Areas”, and then “DEP Tier Classified 21E Sites”. The compliance
status of specific MCP disposal sites may be viewed using the BWSC Waste
Sites/Reportable Release Lookup at:
http://public.dep.state.ma.us/SearchableSites2/Search.aspx
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The Project Proponent is advised that if oil and/or hazardous material are identified
during the implementation of this project, notification pursuant to the Massachusetts
Contingency Plan (310 CMR 40.0000) must be made to MassDEP, if necessary. A
Licensed Site Professional (LSP) should be retained to determine if notification is
required and, if need be, to render appropriate opinions. The LSP may evaluate whether
risk reduction measures are necessary or prudent if contamination is present. The BWSC
may be contacted for guidance if questions arise regarding cleanup.
Proposed s.61 Findings
The “Certificate of the Secretary of Energy and Environmental Affairs on the
Environmental Notification Form” may indicate that this project requires further MEPA
review and the preparation of an Environmental Impact Report. Pursuant to MEPA
Regulations 301 CMR 11.12(5)(d), the Proponent will prepare Proposed Section 61
Findings to be included in the EIR in a separate chapter updating and summarizing
proposed mitigation measures. In accordance with 301 CMR 11.07(6)(k), this chapter
should also include separate updated draft Section 61 Findings for each State agency that
will issue permits for the project. The draft Section 61 Findings should contain clear
commitments to implement mitigation measures, estimate the individual costs of each
proposed measure, identify the parties responsible for implementation, and contain a
schedule for implementation.
The MassDEP Southeast Regional Office appreciates the opportunity to comment on this
proposed project. If you have any questions regarding these comments, please contact
Sharon Stone at (508) 946-2846.
April 28, 2015 Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office Alex Strysky, EEA No. 15338 100 Cambridge Street, Suite 900 Boston MA 02114 Dear Secretary Beaton: The Pleasant Bay Alliance wishes to submit this letter of comment regarding the Ryder’s Cove Parking Improvements/Expansion (EEA 15338). The Alliance develops and coordinates implementation of the Resource Management Plan for the Pleasant Bay Area of Critical Environmental Concern (ACEC). The Alliance’s projects, programs and studies promote healthy natural resources and safe public access throughout Pleasant Bay. The project proponent, the Town of Chatham, is a member town of the Alliance, along with Harwich, Orleans, and Brewster. Town officials representing the project briefed Alliance committees on the project on numerous occasions. More than a year ago the Alliance sent a letter to the Town outlining questions and issues regarding the project, which the Town has sought to address in project design. In addition, representatives of the Alliance participated in the MEPA site visit on April 3, 2015. The project is intended to enhance the flow of trailer traffic utilizing the boat ramp at Ryder’s Cove landing, particularly during the perennially busy bass fishing season. Ryder’s Cove landing is one of the busiest landings within the Pleasant Bay system. In view of the limited public access opportunities on Pleasant Bay, particularly for boat access, the Resource Management Plan calls for a high level of public maintenance and investment at town landings, especially those with heavily-­‐
used boat ramps such as Ryder’s Cove (RMP 2013, recommendation 8.4.1). However, the Resource Management Plan also recognizes that intense use of town landings can result in impacts on ACEC resources, which include Outstanding Resource Waters, wetlands and habitat. The proposed project is located entirely within the Pleasant Bay ACEC. Therefore the Alliance’s comments focus on measures to prevent, minimize and, when necessary, mitigate impacts to water quality and wetland resources resulting from the project. Minimization of Water Quality Impacts from Stormwater Run-­‐off The removal of .8 acres of natural vegetation, and replacement with porous pavement and impervious surface could increase the potential for stormwater run-­‐
off and disrupt the natural attenuation of nutrients and filtering of other pollutants. Therefore, the project should be held to the highest applicable standards under Massachusetts Stormwater requirements including, but not limited to: • Porous pavement should be constructed with the recommended depth of base materials to ensure the proper storage volume and treatment for stormwater as detailed in the Structural Best Management Practices, of the Massachusetts Stormwater Handbook (Vol. 2, Ch.2, p.119). • A plan for adequate maintenance and monitoring of the performance of the porous pavement should be designed with input from Massachusetts Department of Environmental Protection, and implemented. • All aspects of the stormwater design should meet the stringent standards for a Critical Area, as defined under the stormwater management guidelines, (e.g. slope of the site and design/construction of perimeter swale to limit run-­‐on as well as to provide overflow capacity (Vol. 2, Ch. 2, p 121)). The aforementioned measures should be addressed in a Stormwater Pollution Prevention Plan and Long Term Pollution Prevention Plan filed with the Notice of Intent. Wetlands and Habitat Protection The standard for wetlands protection within an ACEC is No Adverse Effect. The project will impact .09 acres of Bordering Vegetated Wetlands and provide disturbance within the buffer zone to a resource area. The removal of .8 acres of upland native habitat also will result from the project. To mitigate these impacts to wetland resources and habitat, it is proposed that additional invasive species removal be required, either at this location, or elsewhere in the project vicinity. Thank you for your consideration of these comments. 2 Sincerely, Carole Ridley Coordinator Cc: Chatham Conservation Commission Kristin Andres Ted Keon Bob Duncanson Jill Goldsmith 3