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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