to:                state of nh, des, nh wetlands bureau

      from:                David Nieman, conservation commission Vice chairman

subject:                conservation commission comments – Proposed Dredge and fill application
                         Map 5 LOT 14, elm street, Goffstown, NH

      date:                August 29, 2005

________________________________________________________________________________________

The Goffstown Conservation Commission has reviewed the Dredge and Fill Application
for the property at Map 5 Lot 14, Elm Street, Goffstown, NH which is the proposed site
for construction of a school building.  We have also conducted a site inspection. 

We have serious concerns about the proposed use of the property, and strongly urge the
DES to consider the following issues. 

-         The site does not meet Goffstown’s zoning regulations for buildable area that are
normally applied to subdivision proposals.  More than half of the proposed site for
the 10 room kindergarten building would lie within the wetland conservation
overlay district.  Building at this location would not be a minor waiver of the
requirement, but a complete disregard of the intent and functional purpose of the
wetland buffer zone.

-         Although the applicants currently claim they are only looking at the site for a 10
room kindergarten, previous presentations clearly indicated that the kindergarten
would be expanded to an Elementary school (previous presentations at
deliberative sessions, and the application package to the state for kindergarten
construction aid).  Expanding to a larger school will significantly increase the
impacts above and beyond what is submitted in the application.

-         There is no alternative site proposed for the layout of the loop road with 3 wetland impacts.  A similar-sized area of buildable land is located on the same property,
closer to Elm Street, which would not require any of the crossings.  Note,
however, that this alternative location on this site still lacks adequate space for a
school building – it only improves the situation by avoiding the wetland crossings
and requiring less alteration of terrain. 

-         A least impacting alternative analysis has not been performed, for using other
town-owned lands. 

-         Since the proposed development resides within the wetland buffers, the functions
that the buffer zones provide are lost. Yet this is a development where such
buffers are very important due to the large extents of impervious areas that would
be introduced. 

-         The runoff from impervious surfaces will not receive adequate treatment, and will
flow into the stream draining this area directly into the Glen Lake reservoir on the Piscataquog River.  Furthermore, this flow into the river is located at the only
public beach on Glen Lake. 

-         There will need to be significant removal of material into a slope north of the
building site to construct the proposed building.  There is also a playground area
proposed in wet soils where water is moving though shallow soils over ledge, and
will require drainage to develop.  How these changes will modify the hydrology
of the site has not been addressed, and is also a concern due to the direct drainage
of the stream into the Piscataquog River. 

-         Since the water table is so shallow on much of the site, we are not convinced that
treatment swales for storm water runoff will perform well on this site.  We urge
you to look closely at the plans for managing and processing the runoff. 

-         We (the Goffstown Conservation Commission) routinely request open bottom
culverts for stream crossings, but open bottom culverts are not a part of this plan. 

Thank you for your consideration. 

David Nieman 

Vice-Chairman, Goffstown Conservation Commission