Berkshire Regional Planning Commission Clearinghouse Review Report

Transcription

1 August 19, 2013 SUBJECT: Reconstruction of Housatonic Street, Dalton, MA EOEA#: LOCATION: Dalton ESTIMATED COST: $8.1 million REVIEW TYPE: ENF PROPONENT: MassDOT and Town of Dalton COMMENTS DUE: August 27, 2013 PROJECT DESCRIPTION: The proposed project involves the reconstruction of a 1.9-mile section of Housatonic Street in Dalton, beginning at the intersection of Routes 8 & 9 / Main Street to just west of the intersection of Housatonic Street with Route 8. The proposed work will reconstruct and widen the roadway, improve roadway drainage, improve intersection and roadway geometrics, increase safety and provide improved pedestrian and bicycle connectivity. The final result of the project will be 11- foot wide travel lanes, five- foot (5 ) shoulders on each side, and a concrete sidewalk on the north side of the roadway for much of its length The proposed roadway improvements include pavement reclamation through a majority of the corridor, along with box widening, full depth reconstruction and realignment to a point just east of the Housatonic River Bridge. This will result in a new roadway alignment, both vertical and horizontal, improved sight distance and meet the 40-mph design speed criteria. This project does not include any bridge improvements. The ENF states that the project is proceeding through the MEPA review process because it exceeds the following MEPA review thresholds: 1) the project entails widening an existing roadway by four or more feet for one-half or more miles, 2) the cutting of five or more living public shade trees of 14 or more inches in diameter and 3) includes the alteration of a ½ acre or more of wetlands. CONSIDERATIONS AND POTENTIAL ISSUES: Transportation Impacts The proposed Housatonic Street project provides positive and beneficial improvements to the regional transportation system. The project will widen the roadway, improve existing roadway geometry, improve roadway drainage, replace poor pavement, provide for non-motorized travel through the rehabilitation of sidewalks and box widening to provide for 5 shoulders along each side of Housatonic Street. Housatonic Street is classified as an Urban Collector in the Federal Aid Classification System and the proposed 40 MPH design speed is reasonable. However, given the much wider feel of the proposed roadway, provided by addition of the 5 shoulders and in some areas new sidewalk, combined with the much improved pavement condition, the Page 1 of 5

2 Town should be aware that speeding will be an issue and should provide for strict enforcement of the speed limit. The ENF indicates that a 5 5 sidewalk and/or provisions for a future 5 5 concrete sidewalk will be constructed along the north side of Housatonic Street. However, the site plans indicate that there are no sidewalk improvements for a section of roadway west of Depot Street. The project narrative does not mention the missing segment (approximately 2,500 ) of sidewalk between South Carson Avenue and Depot Street, yet the discussion on existing conditions and land use mentions that Housatonic Street serves school children accessing the middle school through various modes of transportation including busses, cars, bicycles and by foot. Additionally, pedestrian accommodations are not included at any of the bridges on Housatonic Street as they are not part of the project. The ENF does not specify when these missing sidewalk connections, which are almost 30% of the total length of the project, will be made nor does it indicate when proposed future sidewalks will be constructed. More elaboration should have been included in the document. Additionally, the design places the sidewalk immediately adjacent to the curb. The lack of any offset between the curb and sidewalk discourages pedestrian use due to safety perceptions attributed to being close to traffic travelling at 40 MPH. It is stated that traffic volumes are expected to increase from 5,413 ADT (average daily traffic) in 2012 to 8,044 ADT in It is our position that this increase of 48% is exaggerated given that regional and national trends in vehicle miles travelled are actually decreasing. Even if these predictions are attained, the air quality impacts associates with this increase are considered as being negligible. The project includes roadway widening, approximately 5 6 over the length of this project. This will provide for 5 wide shoulders on each side of the road and will accommodate bicyclists. BRPC is pleased to see that these accommodations have been incorporated into the project design. Environmental Impacts The wetland impacts are fairly extensive for a project of this size, totaling 3,225 square feet (sf) of permanent bordering vegetated wetlands (BVW), 54,622 sf of riverfront and 199,688 sf (approx. 4.5 acres) of BVW buffer. Some bank and land under water will also be affected. The ENF indicates that most of the BVW impacts are associated with seven intermittent stream systems that flow into the East Branch Housatonic River, while the riverfront areas are associated with the river crossings. Inserting a table into the ENF outlining the areas of impact would have been helpful, especially given that more than four acres of BVW buffer appear to be permanently altered. At BRPC s request, the Town of Dalton did provide a table of wetland impacts to clarify the total impacts. Reviewing the plans with the table, it appears that much of the impacts are due to widening of the road. Page 2 of 5

3 Four of the intermittent streams are conveyed across the road through culverts, and the project is proposing to replace two of these with natural bottomed culverts. The ENF does not identify which two will be open bottomed nor why all four are not being replaced with open bottoms. MassDOT staff have indicated to BRPC that the two culverts that will remain piped are small (24 and 30 ) and that open bottoms for culverts of this size are not practical. The roadway will continue to channel road runoff through stormdrain systems, and deep sump catch basins are proposed along the length of the project to capture some sediment. The project also proposes a sediment forebay to further reduce sediment discharge. To mitigate wetland impacts, replication areas for 3,600 sf wetlands and 52 feet of bank will be constructed. The wetlands replication area is proposed where an existing stand of invasive phragmites is located. Proposing to create a beneficial native wetland at this site is laudable, but will undoubtedly require removal of existing invasive plants and several years of monitoring and active removal of new phragmites sprouts. The project has gone through the local wetland and DEP appeals permitting process and has received its Order of Conditions from the Dalton Conservation Commission. The Special Conditions issued by the Conservation Commission requires: 1) the wetland replication is to be constructed at the beginning of the project, 2) an annual vegetated growth report of the replication area to ensure coverage, and 3) that a culvert cleaning plan be developed for the town. The project met MEPA threshold, {301 CMR 11.03(6)(b)2.b.} removal of existing live trees greater than fourteen (14 ) inches in diameter, specifically the removal of approximately eleven (11) public shade trees greater than fourteen (14 ) inches at breast height. The summary of mitigation measures for the preferred alternative does not mention the planting of replacement trees, although the plans show several areas where trees will be removed and replanted. MassDOT and the town should review the planting plan to ensure that the trees planted are tolerant of road conditions and are not expected to interfere with overhead power lines. Consistency with Local & Regional Plans The Housatonic Street project is included in the Berkshire Metropolitan Planning Organization s FFY Transportation Improvement Program (TIP) for construction in 2016 and continuing through For clarification purposes, this project was previously programmed for construction beginning in FFY 2013 and continuing through 2014; however, delays with finalizing the design resulted in this project being pushed back. The ENF does not reference the inclusion of this project in the 2012 Berkshire Regional Transportation Plan (RTP); however, this project is included in the 2012 RTP. This project is consistent with RTP objectives of improving safety, maintaining existing roadways, and supporting the use of non-motorized forms of travel. As stated throughout the ENF, improved sidewalks and shoulders to promote walking and biking throughout the town is a goal of the Town of Dalton s Comprehensive Master Plan. Page 3 of 5

4 COMMENTS AND RECOMMENDATIONS: As an overall comment, which has been made in the past concerning MassDOT roadway projects, MassDOT projects should be required by MEPA to go through MEPA review prior to reaching the 100% design stage. For all practical purposes having projects reviewed at this late stage severely limits the opportunities to fully avoid, reduce, or mitigate issues subject to MEPA jurisdiction. MassDOT should be instructed to modify its design process to bring projects to MEPA prior to the 100% design stage (75% design is probably a reasonable benchmark). Similarly, MassDOT should not be pursuing wetland permits prior to the MEPA process. Transportation Share the road signage and pavement markings should be included as part of the project s improvements. The ENF site plans show future sidewalk along most of the Carson-to-Depot Street segment (except for an approximately 500 foot gap where no sidewalk is proposed, now or in the future), but BRPC has learned from the proponent that the project is no longer providing provisions for even a future sidewalk. According to the proponent there is no provision for a sidewalk because the existing bridge does not have pedestrian accommodations. Sidewalk can only be constructed in locations that have a reasonable and ADA compliant terminus. We disagree with this reasoning. We recommend that the design and construction of sidewalk along the road s length (with the exception of the bridge) be conducted as part of this current project, as it will be the most cost-effective manner in which to do so. Sidewalk should be provided in this project, with a note that bicyclist and pedestrian accommodations will be added to the bridge during any substantial future bridge work. While we are sensitive to the fact that it is more costly to provide sidewalks for the entire length of the project and that there will continue to be a very short gap crossing the bridge, this project should provide as much sidewalk as possible without reconstructing the bridge. It makes no financial sense to design and prep (clear & grub, loam and seed) areas for sidewalk for almost 1/3 of the project length but not then to construct them, or to leave such a sizable gap. In fact, the narrative states that the project is not being proposed to be constructed in phases. In support of the GreenDOT Complete Streets initiative and the Town of Dalton s Master Plan, MassDOT should at a minimum design the sidewalk for the missing segment and provide a date specific commitment for these improvements if they are not constructed as part of this project. We also note that five years ago South Street in Dalton was reconstructed in much the same manner as is being proposed on Housatonic Street, with wider shoulders and a sidewalk on one side of the road. However, in the previous project the town constructed a sidewalk along the entire length of South Street, despite the fact that no sidewalk was provided along the road for the short stretch under the existing narrow railroad bridge. Like South Street, a sidewalk should be provided on both sides of the existing bridge on Housatonic Street. We also note that while Page 4 of 5

5 accommodation for bicyclists is being provided right up to the bridge on both sides, the bridge itself does not have adequate width to totally safely accommodate bicycles. Dalton should have a speed enforcement program in place and strictly enforce the posted speed limit once this project is completed. Environment In addition to the vegetation growth monitoring required by the Dalton Conservation Commission, the BRPC requests that monitoring for, and continued removal of, invasive species be conducted at the wetland and bank replication sites beyond the two-year timeline ordered by the Dalton Conservation Commission. It will take several years of dedication to insure that phragmites will not become re-established at the site. BRPC suggests that monitoring and removal of invasive plants be conducted for at least three years after complete re-establishment of the site with indigenous wetland plant species. The proponent should identify all opportunities to add shade trees to the corridor, which will help to mitigate the wider feel of the new roadway and provide cooling shade and community character along the corridor. The MassDOT should provide to the Dalton Tree Warden and Conservation Commission a planting plan that states how replanted trees will be cared for in their first few critical years and the protocols by which sick or dead replacement trees will be replanted if they fail. Replacement trees should be selected which are native, tolerant of roadside conditions (compaction, heat, winter salt), are not expected to be susceptible to invasive species, and which can adapt to expected climate change. Gingko trees are not native,, and sugar maples will likely struggle due to intolerance of roadside conditions and continued climate change, and white pines suffer in areas where salt spray is heavy (the area down slope of the road on the corner of Main and Housatonic street will be prone to spray). We are unsure what water elms are, but only native hybrid disease-resistant elms should be considered. We note that little leaf lindens are not native to the Berkshires, but lindens were actively planted throughout the town, so these may be appropriate in this instance. Typically replacement of trees is with at least a 2:1 ratio. These comments were approved by the BRPC Clearinghouse Review Committee on August 19, 2013, as authorized by the BRPC Executive Committee on August 8, Page 5 of 5