Engineering Responses900 Route 146 Clifton Park, NY 12065
(P) 518.371.7621 (F) 518.371.9540 edpllp.com
Date: January 18, 2022
To: Mr. Craig Brown
Zoning Administrator and Code Compliance Officer
Town of Queensbury
742 Bay Road
Queensbury, NY 12804
Re: West Residence – Main House
Queensbury Ref #SP51-2021
Dear Mr. Brown:
The Environmental Design Partnership, LLP (EDP) is providing you this letter in response to review
comments provided by the Chazen Companies dated August 18, 2021. On behalf of the applicant Brett
West, we offer the following response to comments and additional information:
1. According to the site plan review application, the proposed site improvements will disturb less than one
(1) acre and thus the project is not required to obtain coverage under the NYSDEC SPDES General
Permit for Stormwater Discharges from Construction Activity (GP-0-20-001). However, this project falls
within the Lake George watershed and therefore is subject to the stormwater management
requirements set forth in Section 147-11 of the Town Code for projects within the Lake George Park.
Comments related to the stormwater management and erosion and sediment control features proposed
for the site are offered below:
No response required.
2. According to the site plan limit of disturbance and proposed limit of disturbance on the site plan
application, this project proposes to disturb 23,630 SF. Projects that disturb greater than 15,000 SF
are considered Major Projects per Town code section 147-11.E.(2). In accordance with Town code
section 147-11.I.(3)(c), Major Project stormwater control measures shall be designed so that there will
be no increase in runoff volume from a ten-year-frequency/twenty-four-hour-duration storm event
following development over the predevelopment volume, and for storm events exceeding the ten-year
design storm, the stormwater controls measures shall function to attenuate peak runoff flow rates for a
twenty-five-year frequency storm to be equal to or less than predevelopment flow rates. The Applicant
has provided a stormwater analysis for review .
No response required.
3. Labeling does not match between the post-development routing diagram and the associated
subcatchment map. This office was able to discern for review; however, the Applicant should update.
Response: The subcatchment map has been updated to match the model.
4. The area descriptions for Subcatchment 3 – as described in the stormwater model – do not appear to
accurately portray the proposed conditions. Subcatchment 3 is modeled as having 705 sf of Paved
parking; the post-development SC map indicates there is at least 930 sf of parking, and additional
impervious from Bay Parkway. The Applicant shall revise the model.
Response: The HydroCAD model has been updated.
5. Rain Garden (SMA#1) does not appear to be modeled as shown on the site plans. As depicted, the rain
garden has a basal elevation of 322.90’ but is modeled at 323.00’. An overflow weir is modeled at
2 900 Route 146 Clifton Park, NY 12065
(P) 518.371.7621 (F) 518.371.9540 edpllp.com
Mr. Craig Brown
January 18, 2022
Page 2
323.25’, but no overflow weir is shown on the plans. A top of pond elevation modeled at 323.50’
indicates that the rain garden would include portions of the proposed driveway. As described in the
detail the rain garden has a maximum ponding depth of 6”, which does not align with the site plan. The
Applicant to revise accordingly.
Response: The HydroCAD model has been updated and the weirs are now shown on the plans.
6. Depending on where the overflow weir is tributary to may affect the number of design points. This will
be analyzed once the applicant depicts the location of the overflow weir on the plans and clarifies where
the overflow weir outflow is tributary to.
Response: The HydroCAD model has been updated.
7. Town Code Section 147-11.I(3)(c)[3] states, “infiltration devices shall be designed such that the bottom
of the system will be a minimum of two feet above the seasonal high groundwater level to be realized
following development.” Further, Town Code Section 147-11.I(3)(c)[6] states “Infiltration devices shall
be designed based on the infiltration capacity of the soils present at the project site.” It does not appear
any soil test pits or infiltration testing was conducted. The Applicant shall provide soil test pits and
infiltration testing within the bounds of the infiltration practice to determine the soil’s infiltration capacity,
and verify that adequate vertical separation distances exist. The test pits and infiltration tests shall meet
the standards prescribed in the NYS Stormwater Management Design Manual, Appendix D .
Response: Test pits and infiltration tests were preformed on December 3rd, the results are
shown on the existing conditions plan.
8. Town Code Section 147-11.I(3)(c)[4] requires “infiltration devices for major projects to be located a
minimum of 100 feet from Lake George…” The proposed rain garden is within 100 feet of Lake George.
The Applicant to revise accordingly or seek a variance.
Further the Applicant shall depict within reason (200 feet) any neighboring or adjacent drinking water
supplies, if applicable, to facilitate a review for conformance to 147-11.I(3)(c)[4].
Response: Several infiltration devices are proposed within 100 feet of Lake George, we will be
requesting a variance for these devices. The location of the neighboring drinking water
supplies are being located and will be shown on the plans once located.
9. Further, Town Code Section 147-11.I(3)(c)[4] states “Stormwater recharge areas shall be located a
minimum of 100 feet from the subsurface treatment system of a wastewater treatment system…”. The
Applicant shall provide the locations of neighboring or adjac ent septic absorption fields, if applicable,
for review of separation distances.
Response: Approximate locations of the neighboring wastewater treatment systems are being
located and will be shown on the plans once they are located.
3 900 Route 146 Clifton Park, NY 12065
(P) 518.371.7621 (F) 518.371.9540 edpllp.com
Mr. Craig Brown
January 18, 2022
Page 3
10. Section 5.3.7 of the NYS Stormwater Management Design Manual discusses limitations of Rain
Gardens, stating, “A single rain garden system should be designed to receive […] flow from an
impervious area or from a roof drain downspout with a total contributing drainage area equal to or less
than 1,000 square feet. Treatment of larger drainage areas should incorporate the design elements of
bioretention practices.” The rain garden as proposed will receive runoff from a drainage area of
approximately 18,000 square feet. Further, “rain gardens should be located downgradient and at least
10 feet from basement foundations.” As shown, the rain garden is approximately 3 feet from the garage.
Applicant should revise the practice to meet the recommendations of the NYS SMDM .
Response: The rain gardens have been redesigned and now have a maximum contributing
drainage are of 1,400 square feet, although this is greater than the maximum 1,000 square
feet as defined by the NYS SMDM it is felt that this additional contributing area will not
adversely affect the performance of the device. All of the proposed buildings will not have
basements or crawl spaces and therefore the rain gardens being within 10 ft of the
buildings will not negatively impact the buildings.
11. In accordance with 147-11.I(3)(d)[3] pretreatment practices shall be provided for runoff from paved
areas or other areas subject to human-induced pollution. It is unclear what pretreatment practices are
provided to ensure sedimentation does not occur within the rain garden. The Applicant to clarify or
revise accordingly.
Response: Gravel filter strips are proposed along the edge of the drive where that is directly
contributing to the grass depression.
12. The HydroCAD model uses an exfiltration rate of 5 inches/hour for the rain garden. The exfiltration is
discarded meaning it infiltrates into the native soils. It is unclear if the modeled infiltration rate is
representative of the rain garden soil media infiltrative rate or the native soils, or both. The Applicant to
clarify or revise accordingly. If there are two infiltrative rates, one for the rain garden soil media and one
for the native soils, the HydroCAD model shall reflect that.
Response: The model has been updated to us 0.5 inches/hour to represent the slower more
restrictive infiltration rate through the soil media.
13. The Applicant should depict the locations of roof leaders if such are proposed.
Response: Roof leaders are shown on the Site Plan.
14. The Applicant may be required to execute a stormwater maintenance agreement with the Town in
accordance with Section 147-10.D of the Town Code. Applicant to submit a draft stormwater
maintenance agreement if required by the town.
Response: Comment noted.
If you have questions or require additional information, please contact our office at your convenience.
Very truly yours,
Gavin Vuillaume, R.L.A.