Forest River Pool Replacement Plans RECEIVED
I� JAN 3 0 2020
'llon CIT
Y Y OF SALEM
ASSOCIATES INC . BOARD OF HEALTH
January 29, 2020
PRINCIPALS
Ms. Purvi Patel
Theodore Barten,PE MEPA Office
Margaret B Briggs 100 Cambridge St.,Suite 900
Dale T Raczynski,PE Boston, MA 02114
Cindy Schlessinger Purvi.Patel@state.ma.us
Lester B Smith,Jr
Robert D O'Neal,CCM,INCE VIA EMAIL
Michael D Howard,PWS
Douglas J Kelleher Subject: EEA No. 16147—Forest River Pool Replacement,Salem, MA
AJ Jablonowski,PE
Dear Ms. Patel:
Stephen H Slocomb,PE
David E Hewett,LEED AP Pursuant to the MEPA Office's request for additional information about the Forest River
Dwight R Dunk,LPD Pool Replacement Project, we are please to provide the following details regarding the
David C Klinch,PWS,PMP Project and the alternatives evaluated in the Environmental Notification Form ("ENF').
Maria B Hartnett The MEPA Office specifically requested "expanded details on the alternatives analysis
provided in the Project's ENF to quantify and compare and contrast the environmental
ASSOCIATES impacts associated with each alternative (i.e. No-Build, Expanded Shoreline Alternative,
and Preferred Alternative). The impact comparison can be provided in tabular format."
Richard M Lampeter,INCE
As was described in the Project's ENF, the Proponent evaluated three alternatives: 1) a
Geoff Starsiak, LEED AP BD+C
No-build Alternative, i.e., leaving the Site in its current condition, 2) an Expanded
Marc Bergeron,PWS,CWS
Shoreline Alternative that would increase the size and tidal depth of the shoreline
Alyssa Jacobs,PWS
restoration area beyond that of the Project and otherwise construct the proposed pool
Holly Carlson Johnston
and bathhouse renovations; and, 3) the Proposed Alternative which consists of the
Brian Lever
Project. Table 1, below, provides comparisons of the alternatives.
Table 1 Alternatives Impacts Comparison
3 Mill&Main Place,Suite 250 No Build Expanded Proposed
Maynard,MA 01754 Shoreline
www.epsilonassociates.com
Building Program
978 897 7100
FAX 978 897 0099 Gross Square Footage 4,268 6,118 6,118
Impervious Area 64,033 sf 58,100 sf 58,100 sf
SILON ASSOCIATES INC, ENGINEERS®ENVIRONMENTAL CONSULTANTS
Forest River Pool Replacement(EEA#16147) 2
City of Salem
January 29, 2020
No Build Expanded Proposed
Shoreline
Stormwater Recharge 0 sf 4,750 sf FT
750 sf
Impacts
Coastal Bank Alteration 0 If 40 If 40 If
Land Under the Ocean 0 sf 12,800 sf 8,500 sf
Rocky Intertidal 0 sf 8,000 sf 4,500 sf
Salt Marsh 0 sf 850 sf 50 sf
Land Containing Shellfish 0 sf 5,900 sf 1,600 sf
Land Subject to Coastal 0 sf 17,530 sf 16,100 sf
Storm Flowage
Dredge Volume N/A 1,800 cy 440 cy
Dredge Area N/A 10,500 sf 4,000 sf
(160'x66'x1.5') (160'X24'X1.5')
Trips Per Day 120* 176 176
Parking Spaces 0 16 16
Water Use 13,860 gpd* 4,780 gpd 4,780 gpd
Wastewater 15,246 gpd* 5,258 gpd 5,258 gpd
* Based on facility operations prior to 2018.
The No Build Alternative would retain the existing Site conditions, which consist of a
secured and inaccessible public pool facility that continues to deteriorate.
Although the No-Build Alternative would not necessarily result in direct environmental
and community impacts, it would preclude improvements in Site resiliency and
environmental conditions at the Project Site. The No-Build Alternative would require
EPSILON ! ENGINEERS ®ENV[RONNIENTAL CONSULTANTS
Forest River Pool Replacement(EEA#16147) 3
City of Salem
January 29, 2020
additional expenditure of City funds in the short-term to continue to secure the Site,
and would likely result in the eventual removal of the pool and bathhouse as the failing
structures represent a public health and safety risk.
The No-Build Alternative also fails to provide significant community benefits with regard
to the reactivation of the Site and improved water quality through the proposed
stormwater management features. The No-Build Alternative would avoid the
temporary and minimal construction-period impacts of the other two alternatives
evaluated in the ENF but, as noted above, it is likely that Site degradation (e.g. erosion,
seawall failure, etc.) from sea level rise and coastal storms would result in permanent
and avoidable environmental impacts. It is also assumed that interim repairs to the Site
to protect public health and safety, such as stabilization of the deteriorating seawall, for
example,would have attendant impacts to wetland resource areas.
The No-Build Alternative is not considered a viable option based on its inability to
benefit residents of the City of Salem and surrounding communities and its
inconsistency with the City's Open Space and Recreation Plan Update.
The Expanded Shoreline Alternative was conceived as a means of constructing a more
dynamic inter-tidal area with a more pronounced elevation change from the toe of the
reconstructed coastal bank to the top of bank. More extensive removal of fill material
from around Mean Low Water to the toe of the coastal bank was evaluated as a way to
more closely replicate the condition shown in historic shoreline mapping. This
alternative included the construction of a reduced area of salt marsh, and the
construction of a coastal beach feature, as shown on Figure 1 and Figure 2, here
attached. The Expanded Shoreline Alternative would require the removal of
approximately 1,800 cubic yards ("cy") of material from a 10,500 square foot ("sf') area
of the Project Site, depicted as the "Limit of Dredge Area" on Figure 2 and Figure 4. As
shown in Table 1, below, the Expanded Shoreline Alternative would have additional,
temporary impacts to wetland resource areas.
The Expanded Shoreline Alternative would otherwise construct the pool and bathhouse
as described in the Proposed Alternative.
The City and members of the Project's design team met with staff from the
Massachusetts Department of Environmental Protection ("MassDEP") Northeast
Regional Office and the Massachusetts Office of Coastal Zone Management ("CZM") to
solicit feedback on the Expanded Shoreline Alternative. At that meeting, MassDEP and
CZM staff felt the Expanded Shoreline Alternative may not function as designed,
particularly considering projected sea level rise and coastal storm scenarios. As a result,
the Project team has determined the Expanded Shoreline Alternative is not the
preferred alternative.
ASSOCIATESEPSILON ENGINEERS 8 ENVIRONMENTAL CONSULTANTS
Forest River Pool Replacement(EEA#16147) 4
City of Salem
January 29, 2020
The Proposed Alternative has been carefully designed to minimize environmental
impacts, provide numerous public and environmental benefits, and incorporate design
feedback from MassDEP and CZM on the shoreline restoration component. The
Proposed Alternative reactivates the pool and bathhouse facility and provides for an
expanded range of public programming by constructing a community meeting room that
will operate during the shoulder seasons when the pool is otherwise not open to the
public.
As with the Expanded Shoreline Alternative, the Proposed Alternative will improve site
resiliency by replacing an aged seawall, elevating portions of the site approximately 3.0
feet above the FEMA 100-year flood level and by constructing a stormwater
management system that utilizes Best Management Practices to meet current
stormwater quality standards. Additionally, the Project will construct highly efficient
buildings that incorporate sustainable green building and design features aimed at
mitigating environmental impacts of the Project.
The Proponent thanks MEPA for their thoughtful review of the Project. Should you have
any further questions please feel welcome to contact me at your convenience at:
erexford@epsilonassociates.com or 978-897-6241.
Sincerely,
Erik Rexford, Senior Planner
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EPSILON ASSOCIATES, INC.
Cc Circulation List(via Fed Ex)
Edward Reiner, US EPA
Eric Carlson, MassDCR
EPSILON ! ENGINEERS ®ENVIRONNIENTAL CONSULTANTS