Transportation Land Development Environmental S e r v i c e s 7056 US Route 7, PO Box 120 North Ferrisburgh, Vermont 05473 Telephone 802‐425‐7788 Fax 802‐425‐7799 www.vhb.com
Memorandum
To: GMP/Kingdom Community Wind Project File
Date: February 11, 2011 Revised March 10, 2011 Project 57346.05 No.:
From: Adam R. Crary, PWS, PWD, Patti B. Kallfelz‐Werts
Re: Proposal for Wetland and Stream Impact Mitigation
INTRODUCTION On behalf of Green Mountain Power (GMP), Vanasse Hangen Brustlin, Inc. (VHB), has prepared this memorandum in order to describe the proposed permanent mitigation approach for unavoidable impacts to wetlands and streams which would result from implementation of the GMP Kingdom Community Wind Project (KCW or Project). Located in the Towns of Lowell, Westfield, and Jay, Vermont, the Project, as proposed, incorporates both Wind Farm and Transmission Line components. The Wind Farm would include the construction of 21 2.5 to 3 megawatt (mW) wind turbines along an approximately 3.2‐ mile section of the Lowell Mountain ridgeline, improvement of existing access roads, construction of new access roads and crane paths, installation of both underground and overhead collector lines, construction of an electrical substation, and construction of a operational phase stormwater management system. The Transmission Line includes the reconductoring or realignment of approximately 16.2 miles of existing electrical transmission line, the majority of which will be within existing utility or roadway rights‐of‐way (ROW). The Transmission Line extends from the end of the proposed collection system on Vermont Route 100 in Lowell, to the planned Vermont Electric Co‐op (VEC) Jay Tap Switching Station (currently under construction) adjacent to Vermont Route 105 in Jay. In addition to the transmission line upgrades, two substations will be re‐built within their existing footprints. Although the Project has undergone several design revisions in order to minimize impacts to wetlands and streams to the greatest extent practicable, implementation of the Project will still result in certain unavoidable impacts to wetlands and other jurisdictional waters. Therefore, GMP has identified and is proposing the permanent conservation of an approximately 178‐acre parcel adjacent to the Project site as compensatory mitigation for these unavoidable impacts (see Site Location Map on page 1 of the Attachment). The following sections describe the existing conditions, resource functions and values provided, credit determination methods, and discussion. Supporting documentation is included in the Attachment.
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Kingdom Community Wind Project Proposal for Wetland and Stream Impact Mitigation Project No.: 57346.05 Page 2 February 11, 2011 Revised March 10, 2011
EXISTING CONDITIONS The proposed conservation parcel is located south of the existing access road (see Proposed Wetland, Stream, and Necessary Wildlife Habitat Conservation Area Map on page 2 of the Attachment). The elevation of the conservation parcel ranges from approximately 1,700 feet above mean sea level (fasl) in the western portion of the parcel to 1,300 fasl in the east. The topography is rolling, with small knobs interspersed with streams and wetlands. The site generally slopes to the southwest; the water features found within the conservation parcel drain to tributaries of the East Branch Missisquoi River, a tributary to the Missisquoi River (8‐digit HUC: 02010007). VHB conducted a reconnaissance‐level survey to approximately map the locations and extent of wetland and stream resources within the parcel in May 2010, and identified 25 wetland features, 15 stream segments, and one vernal pool within the proposed conservation parcel. Potential wetland features were identified based on a dominance of hydrophytic vegetation and evidence of wetland hydrology. Stream channels were identified following U.S. Army Corps of Engineers (USACE) guidance (USACE 2005). VHB personnel GPS‐surveyed the approximate wetland boundaries within the conservation parcel, and collected cursory vegetation and hydrology notes. Observations were recorded regarding potential functions and values of the wetlands, as defined in the USACE Highway Methodology Workbook Supplement (USACE 1999) (Highway Methodology). Representative photographs were taken of wetland types found within the conservation parcel. Many of the on‐site wetlands provide a suite of principal functions and values, but for classification purposes, only the primary principal function was chosen. Based on this assessment the wetlands identified within the conservation parcel may be classified into four groups: 1. groundwater recharge/discharge 2. sediment/ shoreline stabilization 3. wildlife habitat 4. uniqueness The Wetland Function and Value Map on page 3 and Wetland Function and Value Evaluation Forms on pages 4 through 7 of the Attachment present the findings of the function and value assessment, and are described in more detail below. Groundwater Recharge/Discharge The wetlands identified as having a primary principal function of groundwater discharge are generally found at the bases of slopes where ground water tables intersect the land surface, and at the origins of perennial and intermittent stream channels (see Wetland Function and Value Evaluation Form on page 4 of the Attachment). This
Kingdom Community Wind Project Proposal for Wetland and Stream Impact Mitigation Project No.: 57346.05 Page 3 February 11, 2011 Revised March 10, 2011
group of wetlands, totaling approximately 7.0 acres, is characterized by soils saturated to the surface with evidence of variable water levels, including water marks on vegetation. Wetland vegetation consists predominantly of herbaceous species including various sedges (Carex sp.), manna grasses (Glyceria melicaria and G. canadensis), jack‐in‐the pulpit (Arisaema triphyllum), jewelweed (Impatiens capensis), and spotted joe‐ pye‐weed (Eupatoriadelphus maculatus). Woody vegetation often includes balsam fir (Abies balsamea) and yellow birch (Betula alleghaniensis). Often, wetlands in this group occur at the origins of stream drainage ways and serve function and values important to providing source stream hydrology and maintaining downstream water quality. Because of the constant temperature of groundwater seep discharge, the vegetation tends to emerge earlier than in adjacent uplands or other wetlands with different sources of hydrology (Thompson and Sorenson 2005). Therefore, this type of wetland may also provide valuable, early spring feeding areas for black bear (Ursus americanus). Sediment/Shoreline Stabilization Several wetlands within the conservation parcel were identified as functioning principally for sediment and shoreline stabilization (see Wetland Function and Value Evaluation Form on page 5 of the Attachment). This group of wetlands, totaling approximately 1.5 acres, is similar in that they are located directly adjacent to streams and receive regular hydrology inputs from overbank lateral flows (hydrologically connected to stream inputs). The plant communities in these wetlands are predominantly composed of dense herbaceous vegetation including various sedges, manna grasses, horsetail (Equisetum arvense), soft rush (Juncus effusus), and various ferns including sensitive fern (Onoclea sensiblis), interrupted fern (Osmunda claytoniana), bulrushes (Scirpus spp.) and marsh fern (Thelypteris palustris). Woody vegetation is often composed of red maple (Acer rubrum), ash (Fraxinus spp.), yellow birch, and dogwoods (Cornus spp.). This vegetation acts to slow the flow of water into and through the streams and thus, protects water quality within the watershed.
Kingdom Community Wind Project Proposal for Wetland and Stream Impact Mitigation Project No.: 57346.05 Page 4 February 11, 2011 Revised March 10, 2011
Wildlife Habitat Two of the wetlands within the conservation parcel have a primary principal function of wildlife habitat (see Wetland Function and Value Evaluation Form on page 6 of the Attachment). The largest wetland within the conservation parcel, approximately 7.4 acres, is located near the west boundary and shows evidence of current beaver (Castor canadensis) activity. This wetland is mapped by the Vermont Significant Wetland Inventory (VSWI). Signs of beaver activity include several intact dams and lodges, signs of recent chews on trees and shrubs in the area, and paths made by beaver from the adjacent uplands. Another wetland within the conservation parcel contains a vernal pool, where at the time of the reconnaissance survey in May 2010, wood frog (Rana sylvatica) tadpoles, and egg masses were noted. In addition, other wetland features as well as the surrounding uplands, contain evidence of use by other species including moose (Alces alces) (moose droppings) and white‐tailed deer (Odocoileus virginianus) (deer droppings and buck rubs). Uniqueness One of the wetlands within the conservation parcel meets the criteria for being functionally unique, and therefore, valuable for landscape and habitat heterogeneity, along with providing a suite of other water quality functions. This wetland, located in the southwest section of the conservation parcel, is dominated by Sphagnum mosses (Sphagnum spp.) and has limited overstory compared to the majority of wetlands on site (see Wetland Function and Value Evaluation Form on page 7 of the Attachment). This feature is approximately 1.2 acres in size; feature size, cover type, and landscape position all combine to make this feature unique in the surrounding wooded mountain slopes. The streams found within the conservation parcel were GPS‐surveyed along the approximate stream centerline; observations were recorded describing general stream morphology and flow characteristics; photographs of representative features were taken. The streams within the conservation parcel are predominantly intermittent channels associated with wetlands. Stream
Kingdom Community Wind Project Proposal for Wetland and Stream Impact Mitigation Project No.: 57346.05 Page 5 February 11, 2011 Revised March 10, 2011
substrate varies by gradient with organic material and vegetation in low gradient channels to bedrock, cobble, and boulder, in high gradient reaches. All stream channels are stable and occur within forested watersheds including wooded riparian corridors. The remainder of the site is forested upland, and much of the eastern portion meets the description for Northern Hardwood Forest type, as described in Wetland, Woodland, Wildland (Thompson and Sorenson 2005). Upland forests often include American beech (Fagus grandifolia), yellow birch, and sugar maple (Acer saccharum); the shrub layer is characterized by striped maple (Acer pensylvanicum) and hobblebush (Viburnum lantanoides). The southwest portion of the conservation parcel is mapped by the Vermont Agency of Natural Resources (ANR) as deer wintering shelter (see Conservation Area Wetland Function and Value Map on page 3 of the Attachment). This area of deer wintering shelter roughly corresponds with upland communities characterized by the Red Spruce Northern Hardwood forest type. In addition to American beech and yellow birch, this area of the conservation parcel includes tree species such as red spruce (Picea rubens), balsam fir, and eastern hemlock (Tsuga canadensis). Many of the on‐site uplands (approximately 155 acres) are proposed to be permanently conserved for mitigation as protective buffers for the wetlands and stream within the conservation parcel. In addition to protection of water resources, on‐site uplands within the approximately 178‐acre parcel provide demonstrated value as deer, black bear, and moose habitat. Multiple Resource Management (MRM) conducted surveys for necessary wildlife habitat as part of the Project’s filing for a Certificate of Public Good from the Vermont Public Service Board. From MRM’s assessments, the parcel contains wetland area used by black bear for spring/summer forage habitat as well as some American beech stands that demonstrate past use by black bear as fall forage habitat. In the western extent of the parcel, where coniferous cover increases, MRM identified abundant evidence that both white‐tailed deer and moose actively use this portion the parcel as wintering habitat (see the accompanying MRM photograph of moose browsing taken in March 2010). Further, MRM has found that white‐tailed deer and moose habitat conditions will continue to improve as coniferous forest cover within this portion of the parcel mature.
Kingdom Community Wind Project Proposal for Wetland and Stream Impact Mitigation Project No.: 57346.05 Page 6 February 11, 2011 Revised March 10, 2011
As noted above, one vernal pool was confirmed in the eastern portion of the proposed conservation parcel (see the accompanying photograph). The 250‐foot upland envelope surrounding the pool is primarily forested, although the envelope does include a private logging road. The total envelope is approximately 5.4‐acres, 83 percent, or 4.5‐acres, of which will be permanently preserved as part of this mitigation plan. MITIGATION AREA SUMMARY AND DETERMINATION METHODS In order to calculate potential mitigation area, VHB consulted with the USACE (during a February 11, 2011 telephone call), and followed guidance presented in Table 1 of the USACE New England District Compensatory Mitigation Guidance (USACE 2010). Areas proposed for mitigation include wetlands, wetland buffers (from 0 to 100 feet and from 100 to 250 feet from wetland boundary), and stream buffers (from 0 to 100 feet and from 100 to 250 feet from stream edge) (see Proposed Wetland, Stream, and Necessary Wildlife Habitat Conservation Area Wetland and Stream Resource and Buffer Preservation Map on page 8 and Proposed Wetland/Stream Mitigation Area Summary – Onsite Conservation Parcel table on page 9 of the Attachment). The following areas are listed in the order in which areas were calculated when resources or buffers overlapped (to avoid double‐ counting), and are proposed as such: 1. Wetland Preservation 2. Stream Buffer (0‐100 feet) 3. Wetland Buffer (0‐100 feet) 4. Stream Buffer (100‐250 feet) 5. Wetland Buffer (100‐250 feet) As proposed, and using approximate resource mapping techniques (compared to detailed delineation and mapping), the 178‐acre conservation parcel offers a total of 168.69 acres of potential mitigation area. GMP is proposing to place this parcel under a deed restriction which would place the parcel in permanent conservation. Although the final deed restriction will not be completed until all permits are issued for the Project, it is known that the landowner to the south will need to retain his winter logging access across the property. A metes and bounds survey will be necessary to determine the exact limits and size of the conservation parcel. GMP and VHB conducted a site visit with agency personnel from the USACE and ANR on September 21, 2010. The purpose of this visit was to review the conservation parcel as proposed mitigation for the unavoidable impacts to wetlands and stream, which would result from implementation of the KCW Project. In addition, GMP wanted to familiarize each agency with the high quality of the conservation parcel’s resources and its suitability as a mitigation site. Evidence of the functions and values, including extensive wildlife sign and vegetation community types, and described above, were observed and discussed during the site visit.
Kingdom Community Wind Project Proposal for Wetland and Stream Impact Mitigation Project No.: 57346.05 Page 7 February 11, 2011 Revised March 10, 2011
REFERENCES
Thompson, E. H. and E. R. Sorenson. 2005. Wetland, Woodland, Wildland: A Guide to The Natural Communities of Vermont. The Nature Conservancy and the VT Dept. of Fish and Wildlife, Hanover, NH. U.S. Army Corps of Engineers (USACE) – New England District. 1999. The Highway Methodology Workbook: Supplement: Wetland Functions and Values – A Descriptive Approach. NAEEP‐ 360‐1‐30a. U.S. Army Corps of Engineers (USACE). 2005. Regulatory Guidance Letter. Subject: Ordinary High Water Mark Identification. No. 05‐05. Accessed online: http://www.usace.army.mil/cw/cecwo/reg/rglsindx.htm. USACE – New England District – Regulatory Division. 2010. New England District Compensatory Mitigation Guidance. ATTACHMENTS: • • • • • •
Site Location Map Wetland and Stream Resource and Buffer Preservation Map Wetland Function and Value Map Wetland Function‐Value Form(s) Proposed Wetland, Stream, and Necessary Wildlife Habitat Conservation Area Map Wetland/Stream Mitigation Area Summary – Onsite Conservation Parcel
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ATTACHMENT
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Kingdom Community Wind Lowell, Westfield, and Jay, Vermont Proposed Wetland, Stream and Necessary Wildlife Habitat Conservation Area Site Location Map March 11, 2011
KCW Project Site (Wind Farm Component) 44°45'33"N 72°25'55"W
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Kingdom Community Wind Lowell, Vermont Proposed Wetland, Stream, and Necessary Wildlife Habitat Conservation Area Wetland Map 600
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Sources: Background Orthophoto from VCGI (2008); Potential Conservation Limits provided by Krebs and Lansing (2/24/11), Direct Study Limits, Vernal Pools, Recon Wetlands and Streams, Wetland Continues, and Streams by VHBP (2009 and 2010); Delineated Wetlands by Krebs & Lansing survey and VHB GPS data collection (2009); Property boundary provided by Bruno (2009); proposed buffers created in ArcGIS by VHB (2011).
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Kingdom Community Wind Lowell, Vermont Proposed Wetland, Stream and Necessary Wildlife Habitat Conservation Area Wetland Function and Value Map March 10, 2011
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Sources: Background Orthophoto from VCGI (2008); Potential Conservation Limits provided by Krebs and Lansing (2/24/11); Direct Study Limits, Vernal Pools, Recon Wetlands and Streams, Wetland Continues, and Streams by VHB (2009 and 2010); Deer wintering shelter from ANR via VCGI (2006); Property boundary provided by Bruno (2009).
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KCW Wetland and Stream Conservation Area Wetland I.D.____________________________
✔ ✔
Visual Quality/Aesthetics
ES Endangered Species Habitat
3,5,7,10,11,12
6
1,2,4
-
1,2,3,4,5,7,13,14,17
13,15
7
3,9
6,9
1,2
2,3,5
2,3,6,7,9,12,13,15
Rationale (Reference #)* ✔
Comments
Corps manual wetland delineation ✔ completed? Y_____ N______
✔ ✔ Office_________ Field__________
Adapted from: U.S.Army Corps of Engineers - New England District. 1999. The Highway Methodology Workbook: Supplement: Wetland Functions and Values - A Descriptive Approach. NAEEP-360-1-30a.
* Refer to backup list of numbered considerations.
No endangered species located within these wetlands
Wetlands are not easily viewed or visually significant
Wetlands are not unique for forested groundwater seep features; high interspersion of vegetation
Wetlands not suitable for educational or research purposes; no public access
Wetlands not suitable for recreation; no off road parking/ private property
Evidence of wildlife is found outside of features; there is not a high concentration of wildlife evidence in wetland features.
Wetlands don't show evidence of receiving overflow from adjacent streams; small relative to the size of the watershed
No economically important products found in wetlands
Wetlands contain dense vegetation, but there are no known excess nutrient sources upslope from wetland features
Wetlands contain dense vegetation and organic soils but are small relative to the size of the watershed; features are not located in close proximity to upslope sources of sediment or toxicant
Water levels not sufficient to support fish or shellfish
Wetlands are small relative to the size of the watershed and are not suitable for floodflow alteration.
Features located in topographical depressions; wetlands contain drainage channels; variable water levels; stream origin and functional headwater provided
Principal Function(s)/Value(s)
Notes: Area is based on 18 survey wetland features mapped at reconnaissance level but generally following current federal wetland identification methods
Other
✔
✔
✔
✔
✔
Uniqueness/Heritage
Educational/Scientific Value
Recreation
Wildlife Habitat
Sediment/Shoreline Stabilization
Production Export
✔
Nutrient Removal
✔
✔
✔
✔
✔
Sediment/Toxicant Retention
Fish and Shellfish Habitat
Floodflow Alteration
Groundwater Recharge/Discharge
Function/Value
Suitability Y N
1 How many tributaries contribute to the wetland?____________Wildlife & vegetation diversity/abundance (see attached list)
Upper Is the wetland a separate hydraulic system?____________ If not, where does the wetland lie in the drainage basin?__________________ Evaluation based on:
Variable
Dominant wetland systems present_____________________________ Contiguous undeveloped buffer zone present________________ Type__________________Area____________
No 314,042 sf No No 44°45'45"N 72°26'39"W Total area of wetland_________ Human made? _______Is wetland part of a wildlife corridor?________ or a "habitat island"?_____ Latitude_________ Longitude___________ CMM 1-17-11 Prepared by:_________ Date_______________ Forested Area Adjacent land use__________________________________________ Distance to nearest roadway or other development_____________ 2,000 Wetland Impact: PEM/PFO Yes
Wetland Function-Value Evaluation Form
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KCW Wetland and Stream Conservation Area Wetland I.D.____________________________
✔ ✔
✔
✔
✔
✔
✔
✔
1,2,3,5,6,7,10,11,12
3,6,14,19
1,2,4,12
-
1,2,3,4,5,6,7,8,12,13,17, 20
2
7
1,2,3,5,12,13
3,5,6,9,7,9,10,11,12
1,2,3,4,5,7,8,14
1,2,3,5,6,7,8,13,15
7,9,15
Rationale (Reference #)*
✔
✔
Comments
Corps manual wetland delineation ✔ completed? Y_____ N______
✔ ✔ Office_________ Field__________
Adapted from: U.S.Army Corps of Engineers - New England District. 1999. The Highway Methodology Workbook: Supplement: Wetland Functions and Values - A Descriptive Approach. NAEEP-360-1-30a.
* Refer to backup list of numbered considerations.
No endangered species located within this wetland
Wetland contrasts with the surrounding landscape, open water visible from primary viewing locations
Wetland is not unique for large beaver influenced feature
Wetland is not suitable for educational or research purposes; no public access
Wetland is not suitable for recreation; no off road parking/ private property
Wetland utilized as beaver habitat; large amphibian populations identified in May at time of recon
Wetland does not show evidence of receiving overflow from adjacent streams
No evidence of usable products for humans or other living organisms
Wetland is suitable for nutrient removal however there are no known excess nutrient sources upslope from wetland feature
Wetland is a suitable for sediment retention. However there are no known sources of excess sediment upstream
Water levels are sufficient to support fish and shellfish habitat, however, beaver dams provide barriers and water levels may be temporary
Wetland feature is suitable for this function/value; however feature does not have a high density of vegetation and the wetlands watershed does not contain a high percent of impervious surfaces.
Wetland feature is beaver influenced with several dams, no seeps or groundwater discharge evident
Principal Function(s)/Value(s)
Notes: Area is based on 1 wetland feature mapped at reconnaissance-level but generally following current federal wetland identification methods.
Other
ES Endangered Species Habitat
Visual Quality/Aesthetics
Uniqueness/Heritage
Educational/Scientific Value
Recreation
Wildlife Habitat
Sediment/Shoreline Stabilization ✔
✔
Nutrient Removal
Production Export
✔
✔
✔
Sediment/Toxicant Retention
Fish and Shellfish Habitat
Floodflow Alteration
Groundwater Recharge/Discharge
Function/Value
Suitability Y N
1 How many tributaries contribute to the wetland?____________Wildlife & vegetation diversity/abundance (see attached list)
Upper Is the wetland a separate hydraulic system?____________ If not, where does the wetland lie in the drainage basin?__________________ Evaluation based on:
No
Dominant wetland systems present_____________________________ Contiguous undeveloped buffer zone present________________ Type__________________Area____________
No 322,887 sf No No 44°45'32"N 72°26'24"W Total area of wetland_________ Human made? _______Is wetland part of a wildlife corridor?________ or a "habitat island"?_____ Latitude_________ Longitude___________ CMM 1-17-11 Prepared by:_________ Date_______________ Forested Area Adjacent land use__________________________________________ Distance to nearest roadway or other development_____________ > 700' Wetland Impact: PEM/PUBb Yes
Wetland Function-Value Evaluation Form
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Kingdom Community Wind 8 Lowell, Vermont Proposed Wetland, Stream, and Necessary Wildlife Habitat Conservation Area Wetland and Stream Resource and Buffer Preservation Map 11 0
0
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VHB Digitized Logging Road Vernal Pool Envelope (250')
Potential Conservation Area Limits 1700
KCW Vernal Pools
VHB Streams (Recon)
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Buffer Preservation Type (Width) Stream (0-100')
Stream (100-250') Wetland (0-100')
Wetland (100-250')
KCW Project Parcels
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KCW Wind Farm Direct Study Area 20 ft. Contour
Proposed Conservation Area 178 Acres
1600
100 ft. Contour
1800
1300
0 190
Sources: Background Orthophoto from VCGI (2008); Potential Conservation Limits provided by Krebs and Lansing (2/24/11); Direct Study Limits, Vernal Pools, Recon Wetlands and Streams, Wetland Continues, and Streams by VHBP (2009 and 2010); Delineated Wetlands by Krebs & Lansing survey and VHB GPS data collection (2009); Property boundary provided by Bruno (2009); proposed buffers created in ArcGIS by VHB (2011).
Prepared by: PBW
F:\57346.00\GIS\project\Site\Mitigation\KCW_NR_mitigation_Buffers New_2011.mxd
Conservation Area Type
1
TOTAL:
1,673,116 1,728,112 7,348,030
38.41 39.67 168.69
F:\57346.05 GMP KCW 404 Permitting\ssheets\KCW Wind Farm Mitigation\KCW Impact & Mitigation TablesOnsite Mit Parcel (3‐10‐11)
Buffer areas are based on Recommended Compensatory Mitigation Ratios for Direct Permanent Impacts Table in the ʺNew England District Compensatory Mitigation Guidanceʺ. 2010.
3
Wetland areas and streams are based on preliminary reconaissance‐level GPS‐surveying; Total Approximate Wetland Area = 17.28 acres; Total Approximate Stream Channel = 8,700 lf. Wetland and Stream Buffers were created and calculated in GIS mapping.
2
Approximately 178‐acre proposed mitigation/conservation area will be preserved using a deed restriction; mete and bounds survey will be completed once permit is approved.
1
NOTE: Included in the wetland, stream, and buffer conservation areas is a vernal pool which will be completely conserved with a 250ʹ buffer that will be 83% conserved.
100‐250ʹ from stream center
0‐100ʹ from stream center
Stream Buffer
27.37
1,192,439
3
45.95
2,001,711
17.28
ac.
100‐250ʹ from wetland edge
752,652
s.f.
Approximate Area 2
0‐100ʹ from wetland edge
Wetland Buffer
Uplands
(Emergent, Scrub‐shrub, & Forested Wetland Types)
Wetlands
March 10, 2011
Kingdom Community Wind (KCW) Lowell, Westfield, and Jay, Vermont Proposed Wetland/Stream Mitigation Area Summary ‐ Onsite 178‐acre Conservation Parcel Prepared by VHB
9