~.VERMONT. Town ofwaitsfield, Vermont Waitsfield Community Wastewater Loan Fund Program Decentralized Wastewater Project, Winter Park System

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1 ~.VERMONT Vermont Department of Environmental Conservation EC7 Facilities Engineering Division 1 National Life Drive Main Building, 1st Floor Montpelier, VT Agency of Natural Resources David Chin USEPA New England 5 Post Office Square Suite 100, OEP Boston,MA May 13, 2013 Re: Town ofwaitsfield, Vermont USEPA Special Grant No. EM (federal fiscal years 2004,2005 and 2006 appropriations) Dear Mr Chin: Enclosed is our updated and signed for the Waitsfield, Vermont, decentralized wastewater project, on State of Vermont letterhead. We are requesting a Finding of No Significant Impact (FNSI) for this project. Please call me directly, at (802) , if you have any further questions, comments or concerns. Sincerely, Thomas G. Joslin, P.E. Environmental Engineer Design Section TGJ/tgj enclosure: Updated (by VT-DEC) To preserve, enhance, restore, and conserve Vermont's natural resources, and protect human health, for the benefit of this and future generations.

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3 ~.VERMONT Vermont Department of Environmental Conservation EC7 Facilities Engineering Division 1 National Life Drive Main Building, 1st Floor Montpelier, Vf Agency of Natural Resources Town ofwaitsfield, Vermont Waitsfield Community Wastewater Loan Fund Program Decentralized Wastewater Project Winter Park System USEPA Special Grant No. EM (federal fiscal years 2004,2005 and 2006 appropriations) May 13, 2013 UJ!dated August 5, 2013, to rejject relocation of advanced treatment facility. Upaated August 13, 2013, to reflect Vermont wetlands permitting requirements. This updated document has been prepared by: ~ Thomas G. Joslin, P.E., VT #4208 Environmental Engineer Vermont Department of Environmental Conservation Facilities Engineering Division Design Section To preserve, enhance, restore, and conserve Vermont's natural resources, and protect human health, for the benefit of this and future generations.

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5 Page 1 of 10 Project Identification: Town of Waitsfield, Vermont Waitsfield Community Wastewater Loan Fund Program Decentralized Wastewater Project Winter Park System USEPA Grantee Mailing Address: Valerie Capels, Town Administrator Authorized Representative Town of Waitsfield 9 Bridge Street Waitsfield, Vermont Project Location: Winter Park commercial neighborhood, in the unincorporated village of Irasville, in the Town of Waitsfield, Vermont. USEP A Special Grant No. : USEPA Special Grant No. EM (federal fiscal years 2004, 2005 and 2006 appropriations)

6 Page 2 oflo Summary ofenvironmental Review The Vermont Department of Environmental Conservation, Facilities Engineering Division, has reviewed the following planning documents for the Town of Waitsfield, Vermont, Community Wastewater Loan Fund Program, Decentralized Wastewater Project: Updated environmental information document (EID) titled "Waitsfield Community Wastewater Loan Fund Program (CWLFP), Environmental Iriformation Document', and dated March 11, , by Stone Environmental, Inc, ofmontpelier, Vermont. Updated facilities plan (FP) titled "Town ofwaitsfield Wastewater Facilities Plan Update, Community Wastewater Loan Fund Program, Waitsfield Village and Irasville, Vermont', and dated March 19, 2013, by Stone Environmental, Inc, of Montpelier, Vermont. This environmental assessment document has been prepared by the Facilities Engineering Division of the Vermont Department of Environmental Conservation. This document will provide commentary on the above planning documents prepared by the project owner's consulting team, and will provide additional information as appropriate. Description of the Project The Town of Waitsfield has established a community wastewater loan fund program that will use Vermont/USEP A clean water revolving loan funds to fund decentralized, neighborhood-scale wastewater collection and subsurface treatment projects in the unincorporated villages of Waitsfield and Irasville. The project will also make use of an existing USEPA state and tribal assistance grant (STAG) that had been appropriated to Waitsfield in federal fiscal years 2004, 2005 and 2006, for the purpose of funding a community-scale drinking water system and a centralized "Big Pipe" wastewater collection and treatment system to serve the villages of Waitsfield and Irasville. The "Big Pipe" wastewater project was rejected by Waitsfield voters in March 2008, and subsequently abandoned by the Town in favor of a smaller-scale decentralized wastewater project. The purpose of the currently proposed decentralized wastewater project is to abate existing water pollution control problems, to facilitate changes of use of existing properties in Waitsfield and Irasville villages, and to accommodate limited new development in Waitsfield and Irasville villages. The intent of the Town is to implement the overall decentralized wastewater project in multiple phases, over several years, as individual project phases are identified and developed. Some project phases may be

7 Page 3 of10 constructed on private property, while others may be constructed on municipal property. A project phase intended to replace a failed subsurface treatment system serving the Winter Park commercial neighborhood in Irasville village has been officially designated by the Town as a funded project. It is hoped that that project will proceed to construction in The sewer service area of the existing Winter Park neighborhood system in Irasville may be expanded somewhat. Legal agreements for construction funding and maintenance of the Winter Park decentralized wastewater system will be developed. Federal grant funds from the existing STAG are currently available only through December 30, The Town is considering expediting its overall decentralized wastewater project schedule in order to maximize use of the available STAG funds. Finding of No Significant Impact (FNSI) Required The Vermont Department of Environmental Conservation (VT-DEC), Facilities Engineering Division, has established "Environmental Review Procedures for Projects Funded Through the Vermont/EPA Revolving Loan Program", in accordance with NEPA (National Environmental Policy Act), for projects receiving clean water revolving loan (CWSRF) funding. CWSRF loans are supported by USEPA capitalization grants. VT-DEC has not established separate environmental review procedures for USEPA state and tribal assistance grant (STAG) wastewater projects, so the CWSRF environmental review procedures will be applied to the Waitsfield project. Under the VT-DEC CWSRF environmental review procedures, a wastewater project is ineligible for Categorical Exclusion (CATEX) from detailed environmental review if the project includes a new discharge to groundwater or surface water. The VT -DEC Facilities Engineering Division has determined that the Waitsfield decentralized wastewater project will include new discharges to groundwater, and will therefore be ineligible for CATEX. Instead, a Finding of No Significant Impact (FNSI) will be required for the Waitsfield project. As additional phases of the overall decentralized wastewater project are identified and developed, the environmental information document (EID) will be updated by the Town's consulting team, and this environmental assessment (EA) document will be updated by the VT-DEC Facilities Engineering Division. The VT-DEC Facilities Engineering Division will request amendment of the overall project FNSI, by USEPA Region 1, as additional project phases are identified and developed. A properly warned public meeting, to hear public comments on the environmental effects of the project, will be required for the original FNSI and for each FNSI amendment. FNSI public hearings will be co-scheduled with Waitsfield selectboard meetings whenever feasible.

8 Page 4 oflo Alternatives to the Project There are currently no state enforcement orders that require water pollution abatement in Waitsfield or Irasville villages, but the existing Winter Park subsurface wastewater treatment system in Irasville has failed and needs to be corrected. There may be other existing subsurface treatment systems that need to be corrected. Waitsfield voters have rejected a centralized "Big Pipe" wastewater collection and treatment system. Although individual property owners could be left to deal with water pollution control problems on their own properties, as best they can, with limited financial resources and site-limited technical solutions, the Town of Waitsfield has chosen to establish a community wastewater loan fund program, with community-scale fmancial, technical and legal support, in order to assist individual property owners and to advance community environmental protection and economic development goals. Direct Environmental Effects of the Project The potential direct environmental effects of the overall decentralized wastewater project are addressed by the March 11, 2013, updated environmental information document (EID) prepared by Stone Environmental, Inc. The outer limits of an overall decentralized wastewater project area encompassing all of Waitsfield and Irasville villages are shown in Figure 2 of the main text of the EID. Archeological sensitivity and environmental resources within this project area, and beyond, were addressed during environmental review for the nearly completed Waitsfield municipal drinking water project and the rejected "Big Pipe" wastewater project. As of this writing, the proposed Winter Park project in Irasville is the only component of the current decentralized wastewater project that has been mapped. The overall layout of the Winter Park project is shown in Figure 7 ofthe main text of the EID. Environmentally sensitive areas within the decentralized wastewater overall project area, and beyond, are shown in Figure 8 of the main text of the EID. Within the Winter Park project area, as shown in Figure 7 of the main text ofthe EID, excavation will be limited to that needed for construction of an advanced treatment facility and replacement leachfields and associated buried piping, to the east of Vermont Route 100, and an advanced treatment facility and a possible new forcemain from the Irasville Business Park to the existing Winter Park sewer system, to the west ofroute 100. The potential archeological resource effects of the proposed Winter Park construction to the east of Route 100 are addressed by a November 27, 2012, end of field letter from the University of Vermont Consulting Archaeology Program, which concludes with a statement that "No archaeological artifacts were recovered during the Phase I testing. As a result, no significant cultural resources will be disturbed by the proposed project and no additional work is recommended." Subsequent to issuance of the original, the proposed location of the advanced treatment facility was changed from the east side of Route 100 to the west side of Route 100, as a result of

9 Page 5 of10 negotiation with the owner of the leachfield site on the east side of Route I 00. The site of the relocated' advanced treatment facility is the subject of a July I8, 20I3, archeological review letter by Charles Knight, PhD, Assistant Director of the University of Vermont Consulting Archaeology Program. In his letter, Dr Knight states that the new advanced treatment site is not archeologically sensitive. Close comparison of figures 7 and 8, in the main text of the EID, indicates that construction of the proposed Winter Park advanced treatment facility and replacement leachfields will not occur within an environmentally sensitive area. There is a mapped VSWI (Vermont Significant Wetlands Inventory) wetland nearby, adjacent to a pond on the east side of Route I 00, but the advanced treatment facility will be located on the west side of Route I 00, near a manmade and landscaped second pond with no mapped wetland at the construction end of the pond. To avoid a Vermont wetlands permit, the outer limits of the advanced treatment facility will need to be located at least 50 feet from the artificial pond itself, which is also considered a regulated wetland., while the a:fl: 1: The replacement leachfields could probably be located outside a 50 foot regulatory buffer zone surrounding the wetland on the east side of Route I 00 that wetland. If not, a state conditional 1:1se determination (CUD) v,ro1:1ld be req1:1ired for constrnction within a Class 2 'tvetland b1:1ffer. Close comparison of figures 7 and 8, in the main text of the EID, indicates that the possible new forcemain from the Irasville Business Park to the existing Winter Park sewer system, to the west of Route 100, would cross a small brook as well as a wetland area that had been delineated in In page 26 of the main text of the EID, there is a statement that the forcemain will be installed beneath that brook and wetland area, by directional drilling. To avoid a Vermont wetlands permit, the outer limits of all directional drilling construction, including all access pits, will need to be located at least 50 feet from the wetland. Any potential archeological resources located near the ground surface in that area could also be avoided by directional drilling. The Winter Park replacement system will be located on a plateau well above the Mad River floodplain. Construction erosion control and runoff control measures will be incorporated into each phase of the decentralized wastewater project. Each phase ofthe project will also be subject to Vermont indirect discharge permit conditions (at least 6,500 gpd per system) or Vermont wastewater system and potable water supply permit conditions (less than 6,500 gpd), all intended to protect groundwater quality and surface water quality. The EID by the consulting team, as well as this environmental assessment document by the VT -DEC Facilities Engineering Division, will be updated as additional project phases are identified and developed.

10 Page 6 oflo Indirect Environmental Effects of the Project The indirect (induced development) effects of the decentralized wastewater project are expected to be minimal. The currently mapped Winter Park project phase is expected to primarily or entirely serve existing development. Possibly some additional development could be accommodated by the Winter Park project phase, but Figure 7 in the main text of the EID only shows possible connection of the existing Irasville Business Park to the existing Winter Park sewer system. Any induced development that might occur would be subject to Town of Waitsfield zoning regulations and design review as well as applicable state permit conditions. Also, Figure 8 of the main text of the EID indicates that existing development and delineated wetlands limit future building sites in the vicinity of the existing Irasville Business Park. In addition, the Waitsfield-Fayston town line, located immediately west of the Irasville Business Park, limits westward commercial expansion in the area. Fayston is located outside the decentralized wastewater project area. Socio-Economic Effects ofproposed Project The proposed project will not require relocation of people. Area employment will not be disrupted by project construction, and may actually be temporarily enhanced by construction. In addition, limited economic development accommodated by the decentralized wastewater project may stimulate more permanent local job growth after construction. At this time there is not enough information to estimate the direct fmancial impact of the decentralized wastewater project on private property sewer rate payers or town taxpayers. The private property sewer user base of the Winter Park project phase in Irasville is not yet fully defmed. Potential additional project phases have not even been identified yet. The Town of Waitsfield is required to pay back, to the Vermont/USEPA clean water revolving loan fund, outstanding facilities planning and design costs that are unique to the rejected "Big Pipe" wastewater project only. That loan repayment obligation is independent of the scope of the current decentralized wastewater project. According to David Chin of USEPA Region 1 ( to Tom Joslin, VT-DEC Facilities Engineering Division, ), there is still $919,251 of state and tribal assistance grant (STAG) funding that remains available for reimbursement to Waitsfield. Some of that may be committed to the drinking water project nearing completion. Currently the STAG funding is only available for drawdown through December 30, The STAG may be used to reimburse up to 55 percent of eligible project costs, including facilities planning and design. A 45 percent of project cost local match to STAG funding is required. The Town plans to use clean water revolving loan funding to match its STAG funding. The Town's consulting team has developed a decentralized wastewater project financial worksheet that

11 Page 7 of10 may be found in pages of the EID. The worksheet projects net annual cash flows for the Town through the year 2038, for an overall decentralized wastewater project including six project phases. Repayment of the "Big Pipe" planning and design loan is included in the net cash flow projection. The worksheet shows that the overall project becomes more fmancially viable as more project phases are added, allowing greater capture of STAG funding. The worksheet shows a total of $954,250 of available STAG funding, somewhat more than indicated by David Chin of USEPA Region 1, on March 14, Assuming that $900,000 in STAG funding will be available to Waitsfield for the decentralized wastewater project, the required 45 percent local match would be $736,364. In March 2012, Waitsfield voters approved a $250,000 bond article for the decentralized wastewater project. That bond article specifically refers to privately-owned on-site wastewater systems. At least one additional bond vote would be required in order to fully match the available STAG funding. Summary of Agency and Public Consultation (Public Meetings) A public hearing, to hear comments on the environmental effects of the project, was co-scheduled with the AprilS, 2013, Town of Waitsfield selectboard meeting. The environmental effects hearing was warned as an agenda item within the selectboard meeting and was also warned separately as a public hearing. The selectboard meeting was held at the town offices in the lower level of the Joslin Memorial Library building in Waitsfield village. About 31 adults were present for the environmental effects public hearing. A technical and fmancial presentation on the overall decentralized wastewater project was led by Juli Beth Hinds of Birchline Planning, LLC; Amy Macrellis of Stone Environmental, Inc; and Peter Lazorchak, P.E., of McCain Consulting, Inc. Specific potential projects to serve the Winter Park area in Irasville village, and the Town offices and Joslin Memorial Library in Waitsfield village, were described to the public. Since the public hearing, the Town has decided not to pursue federal or state funding for the Library wastewater project. Thomas Joslin, P.E., of the VT-DEC Facilities Engineering Division, recorded public comments on environmental effects. One selectboard member, Bill Parker, asked if future project phases would be limited by work already done, and how future environmental effects and costs would be minimized. At the hearing, there were no environmental effects comments or questions that were specific to the potential Winter Park or Library projects. Discussion of environmental effects ended after about 10 minutes, but discussion of other wastewater topics such as archeological study funding continued for about another 25 minutes before the environmental effects hearing was formally closed. The Town selectboard meeting was covered by public access cable television (Mad River Valley Public Access, channel44).

12 Page 8 of 10 List of Agencies and Groups Consulted (Direct Mailing) An electronic copy of this document, as well as an electronic copy of the consulting engineer's updated, March 11, 2013 environmental information document, have been distributed to the following individuals by . A hard copy of this document has been mailed to David Chin, Grants Project Officer, US Environmental Protection Agency, Region 1, Boston, Massachusetts. Federal Agencies US Environmental Protection Agency, Region 1, Boston, Massachusetts Grants Project Officer Smart Growth Coordinator State of Vermont Vermont Agency of Natural Resources, Department of Environmental Conservation Watershed Management Division Watershed Coordinator, Winooski River Basin and Northern Lake Champlain Watershed Floodplain Manager, Rivers Program River Management Engineer, Rivers Program Environmental Analyst, Storm water Program District Wetlands Ecologist, Wetlands Program Program Manager, Residuals Management, Wastewater Program

13 Page 9 oflo Drinking Water and Groundwater Protection Division Indirect Discharge Manager, Indirect Discharge Water Resources Section Chief, Source Water Protection Barre Regional Engineer Barre Assistant Regional Engineer Waste Management an d P rev e n t i o n Division Chief, Sites Management Section Facilities Engineering Division Director, Facilities Engineering Division Environmental Engineer, Design Section Chief, Financial Management Section Vermont Agency of Natural Resources, Department offish and Wildlife Information Manager, Wildlife Diversity Program Vermont Agency of Commerce and Community Development Department of Economic, Housing and Community Development Survey Archeologist, Division for Historic Preservation Local! Regional

14 Page 10 oflo Town of Waitsfield, Vermont Chair, Selectboard Town Administrator Planning & Zoning Administrator Road Foreman Community-Based Services Executive Director, Mad River Valley Planning DistriCt Central Vermont Regional Planning Commission Regional Planner Consulting T e am Stone Environmental, Inc, Montpelier, VT Birchline Planning, LLC, San Diego, CA McCain Consulting, Waterbury, VT Stitzel, Page & Fletcher, P.C., Burlington, VT Waitsfield Business Community Director, Mad River Valley Chamber of Commerce, General Wait House, Waitsfield