HomeMy WebLinkAbout20260090 Lexington Rd & Bemis Heights Rd Watercourse/Wetlands Permit NarrativePROJECT NARRATIVE
WATERCOURSE/WETLAND PERMIT APPLICATION
BEMIS POINT SUBDIVISION
In addition to approval of a modified (consolidated) subdivision, AAADMC Ventures,
LLC (the “Applicant”) also requires and is seeking a watercourse/wetland permit from the
Planning Board. Provided herewith for consideration are (i) a Wetland Delineation Map covering
the entirety of the project site, (ii) a Wetland Disturbance Map and (iii) a Water Course Permit
map which shows (by shading) a 50-foot buffer from the federal wetlands that will remain on the
project site within the Applicant’s proposed limits of disturbance. It should be noted that federal
wetlands under the jurisdiction of the United States Army Corps of Engineers (“USACOE”) do
not have a regulated buffer area or adjacent area. The 50-foot buffer is solely a function of the
City’s Unified Development Ordinance and is thus shown on the aforementioned map.
By way of previous correspondence to the Planning Board’s counsel, NYSDEC’s Region
5 counsel confirmed that DEC’s new freshwater wetland regulations (effective January 1, 2025)
do not apply to this project at present, such that there are no DEC regulated wetlands currently on
site. There are a total of 12.14± acres of federally regulated wetlands on the subject property,
11.7± acres of which will remain undisturbed as a result of the proposed project.
There are eight areas of wetland impacts totaling 0.44± acres, as shown on the Wetland
Disturbance Map. There are proposed permanent perennial stream impacts of 69± linear feet and
a proposed temporary perennial stream impact of 18± linear feet. With reference to the Wetland
Disturbance Map, wetland impact areas 1, 2, 3, 4 and 5 (a total of 0.39± acres) and 47± linear feet
of stream impact are all necessary for the grading and construction of the proposed roadway.
Wetland impact areas 6, 7 and 8 (a total of 0.05± acres) are necessary for the grading and
construction of the proposed homes on Lots 13, 10 and 8 respectively. To minimize impacts,
grading has been designed as steep as possible and silt fencing will be installed prior to site
construction. The proposed roadway has been designed to be 28 feet wide, as narrow as allowed
by the City for purposes of emergency access. To further minimize impacts and tree clearing, the
proposed lots have been designed to have minimal lawn area. To mitigate wetland and perennial
stream impacts, the proposed design calls for the installation of a culvert to allow for continued
hydrologic connectivity. The stream that the Applicant is proposing to cross is 3 feet wide at bank
full width. Therefore a 64 foot long 36 inch HDPE pipe will be installed. Installation of the culvert
will be done at a time of low flow. A temporary cofferdam will be installed upstream of the
culvert installation area, and water will be pumped downstream of the installation area. Straw
bales and silt fence will be used to prevent sedimentation. The culvert will be installed completely
at one time to minimize the duration of dewatering.
A portion of the wetlands that the Applicant is proposing to fill to facilitate construction of
the new road which comprises .28± acres was initially considered non-jurisdictional by USACOE
(meaning that it wasn’t a wetland at all for purposes of USACOE or by consequence the City’s
Water Protection Overlay District), but in 2022, due to a change in the federal rules, the wetland
became jurisdictional. Although it may be the case that this wetland will again be considered non-
jurisdictional by USACOE prior to final approval of the project due to another recent federal rule
change, all wetlands are being considered jurisdictional to USACOE for purposes of this
application.1 Based upon all of the communications between the Applicant’s representatives and
USACOE, it is the Applicant’s understanding that USACOE will be in a position to approve the
Applicant’s project upon final subdivision approval and the issuance of a watercourse/wetland
permit by the Planning Board. As mitigation required by USACOE, the Applicant will be
purchasing in lieu fee credits which will result in the creation of new wetlands within the watershed
at an anticipated ratio of 3 to 1 when compared to the wetlands to be disturbed as a part of this
project.
From a mitigation standpoint, perhaps most important is that the Applicant will forever
restrict and place into conservation 17.18± acres of the 21.78± acre project site which will prohibit
development, clearing or other disturbance in perpetuity. Of the 17.18± acres to be held in
conservation, 11.7± acres are federal wetlands. USACOE and the City of Saratoga Springs will
have the right to enforce the restrictions designed for conservation purposes. A draft Declaration
of Restrictive Covenants, which provides for the conservation style restrictions discussed herein,
is provided with this application. It should be noted that USACOE has its own form of restrictive
covenants that it typically requires. A copy of the USACOE’s form Declaration of Restrictive
Covenants is being submitted along with a “redline” showing the Applicant’s proposed changes
thereto, to provide for enforcement thereof by the City (in addition to USACOE) and to address
specific concerns of the Planning Board relating to beaver dams and the use of
pesticides/herbicides. Once finalized and following final approval, the Declaration of Restrictive
Covenants will be recorded in the Saratoga County Clerk’s Office and will be binding upon all
future owners within the subdivision who will receive notice thereof by way of mandatory
language that will be included in each deed of conveyance. Furthermore, the Applicant is required
to mark the limits of the property covered by the restrictive covenants in a manner acceptable to
USACOE.
1 The rule changes relate to whether isolated wetlands are considered wetlands and how isolated wetlands are
defined under federal regulations.