2022-11-15 SOUTH_LaBella_Response_Letter900 Route 146 Clifton Park, NY 12065
(P) 518.371.7621 edpllp.com
November 15, 2022
Mr. Craig Brown, Zoning Administrator and Code Compliance Officer
Town of Queensbury
742 Bay Road
Queensbury, NY 12804
Regarding: Southern Gateway Renewables, LLC
Town of Queensbury, Warren County, New York
LaBella Project #:2220706.37
Queensbury Ref #: SP55-2022
Dear Mr. Brown,
The Environmental Design Partnership is in receipt of a comment letter from LaBella, dated October 4, 2022,
for the above referenced project. On behalf of the applicant, Southern Gateway Renewables, we offer the
following response to comments:
STORMWATER MANAGEMENT AND EROSION AND SEDIMENT CONTROL COMMENTS:
1. In response to comment 3 of the August 11, 2022 LaBella comment letter, the Applicant has provided
the 50-year design storm. It appears that the volume for OFF 1 increase in the 50 -year storm as the
pre-development model is 6.174 ac-ft and the post-development model is 6.175 ac-ft. The Applicant
to revise accordingly.
Response: Comment noted. The post-development HydroCAD model and stormwater design have
been revised.
2. In response to comment 7 of the August 11, 2022 LaBella comment letter, the Applicant states, that
the wet swales are proposed in lieu of pocket ponds. While we do not take exception to this, the
grading plan and design do not appear to match the intent. Wet swales, by NYSDEC definition, are
open channel systems. The latest submission grading plan still depicts grading that is typical of pocket
ponds (a basin) not a wet swale channel. Therefore, the grading plan and design of the wet swales
do not appear to meet the requirements of the NYS SMDM. Further Section 6.5.4 of the SMDM
requires that an open channel system to be designed with a bottom width no greater than eight feet
to avoid potential gullying and channel brading, but no less than two feet. It appears that SMA #1 and
SMA #2 have bottom widths exceeding 8 feet. The Applicant to revise accordingly. Also, in support of
the wet swale design, the NYS SMDM section 6.5.2 and 6.5.4 prescribe the peak velocity, temporary
ponding, and temporary WQV storage times. The Applicant shall submit calculations in support of
those sections.
Response: Comment noted. The proposed wet swales have been reclassified as pocket ponds.
In response to the previous comments, forebays have been added to the ponds which have been
sized to hold 10% of the contributing water quality volume (shown on WQV calculation sheet
and as embedded volume in HydroCAD) and the ponds have been regraded to meet the 1.5L:1V
requirements. The proposed pocket ponds have been regraded to show an aquatic bench . See
details 2 and 3 on sheet C-407. Warning signs have been added to the site plans in the area of
the permanent pool, see detail 4 on sheet C-407. According to the NYS Stormwater Design
Manual, a pond drain is not required where local slopes prohibit this design. An adjustable gate -
2 900 Route 146 Clifton Park, NY 12065
(P) 518.371.7621 edpllp.com
Mr. Craig Brown
November 15, 2022
valve has been added to the pocket pond . See Detail 2 on Sheet C-501 for additional details on
the signage. Yes, cold climate considerations were considered including but not limited to using
a perforated 24” riser pipe with a minimum orifice diameter of ¾” and increasing the slope of
the outlet pipes to greater than 1% where practical.
3. In response to comment 14 of the August 11, 2022 LaBella comment letter, the Applicant states,
“NYSDEC provided their wetland validation in May 2022. The validation is include d with this submittal.
The USACE wetland validation is pending and will be submitted once it is received.” The Applicant to
provide documentation of the USACE wetland validation once it becomes available.
Response: Comment noted.
4. A legally binding and enforceable maintenance agreement shall be executed between the
landowner and the Town ensuring that proper maintenance measures will be implemented for all
proposed stormwater management practices in accordance with Section 147-10.D. of the Town
Code.
Response: Comment noted.
5. In response to comment 16 of the August 11, 2022 LaBella comment letter, the Applicant includes
the panel specifications in the submission. The panel specification provided does not support the
applicant’s claim that the interior panel materials are not hazardous. The specification indicates
the panel complies with IEC and UL standards on durability and long-term operation in open-air
environments. While this is of utmost importance to ensuring the interior materials are contained
within the modules throughout the life of the facility, this does not provide the requested
information regarding the classification of the materials themselves. The applicant should either
provide documentation supporting the claim that the interior materials are non-hazardous or
remove that claim from the decommissioning plan.
Response: Comment noted. The Decommissioning plan has been updated to remove this
statement.
6. The Applicant to itemize the decommissioning cost estimate to support a comprehensive review.
Response: Comment noted. The decommissioning amount of $283,500 has been confirmed and
approved through the Warren County RFP due to this project being located on County property.
In addition, Nexamp has provide a cost estimate.
7. A restoration plan shall be included in the site plan set for review by the Planning Board. The plan
should include not only the restoration practices, but also the erosion and sediment control best .
Response: Additional details have been provided within the decommissioning plan which
discussed the proposed restoration practices which will take place at the time of
decommissioning.
In addition to our response to LaBella’s comments, we have included the following information with this
submission:
• Two (2) copies of the revised stormwater management narrative
• Two (2) copies of the revised site plans
• Two (2) copies of the revised decommissioning plan.
3 900 Route 146 Clifton Park, NY 12065
(P) 518.371.7621 edpllp.com
Mr. Craig Brown
November 15, 2022
If additional information is required or if you have any questions, please contact our office at your earliest
convenience. Thank you.
Regards,
Environmental Design Partnership, LLP
Stephanie Alessandrini, P.E.
Project Engineer
Cc: D. Manson, T. Mitchell