Hanover

Engineering

Assoc

ates

Inc

April IS, 2016

Mary Anne Clausen, Chair

Board of Supervisors
Eldred Township
P.O. Box 600
490 Kunkletown Road
Kunkletown, PA 18058

RE:

Special Exception Review

Deer Park - Chestnut Springs Project
Hanover Project ELD15-21

Dear Marl' Anne:

We are in receipt of the following materials related to the abO\'e-referenced project:

A Site Plan consisting of fifteen (15) sheets, prepared by Miller Bros. Construction,
Inc., dated December 10, 2015, with most but not all sheets ha"ing a latest revision
date of February 22, 2016.

One (1) copy of the Deer Park - Chestnut Springs Project Volume 1 of 3
Application, Em-ironmental Impact Statement, and Erosion and Sediment
Control/Stormwater Management Plans.

One (1) copy of the Deer Park - Chestnut Springs Project Volume 2 of 3
Hydrogeological Report, prepared by EarthRes Group, Inc., dated December 2015.

One (1) copy of the Deer Park - Chestnut Springs Project Volume 3 of 3 Traffic
Impact Study, prepared by Pennoni Associates, Inc., dated December 2015,

A Wellhead Protection Area Zone 1 and Zone 2 Map dated February 2, 2016.

A Wellhead Protection Regulation Analysis Table.

Response letters dated March II, 2016 to our review letters dated February 15, 2016,

This site is located in Eldred Township, Monroe County, south east of the intersection of
Chestnut Ridge Drive (SR 3001) and Kunkletown Road (SR 3004). The Applicant proposes to
access the site da an unlabeled Stone Arch Bridge Road to Chestnut Ridge Drive.
We have reviewed this Special Exception Use Application with respect to the applicable
Township Ordinances and general engineering practice and h.,'e the follO\ving comments to offer,
numbered in accordance ,,~th the comments provided in our previous general engineering letter
dated February IS, 2016:

252 Brodhead Road, Suite 100 Bethlehem, PA 18017-8944610.691.5644 Fax 610.691.6968 www.hanovereng.com

Mary ~\nne Clausen

Eldred Township

April 15, 2016

SUBDIVISION AND LAND DEVELOPl\lENT ORDINANCE:

.\ land de,-elopment plan will be required for this project if zoning approval is received. A
subdivision and land development review will be performed upon receipt of the land development
application. Please note that the written application and narrative contain a description of features
to address many ordinance requirements which will need to be shown on these land development
plans.
ZONING ORDINANCE:
J.

Section 303 - Water extraction/bottling is considered light manufacturing for the

purposes of the Zoning Ordinance.

2.

Section 404.1 - Light manufacturing in the Commercial District is petmitted by

Special Exception. The defInition of "l\lanufacturing, Light" indicates that the use is
to be "carried on entirely within a fully enclosed building," which is not proposed for
this application.
The Applicant's response indicates that two (2) other uses exist on the site. One (1)
of the uses is noted as a "truck garage use." Any current zoning approvals or land
development plans should be teferenced, or the Applicant should certify that no use
establishment or expansion has occurred since the passing of the Zoning Ordinance.
The Zoning OffIcer and/or solicitor should be consulted regarding the total number
of uses on site "chich must demonstrate compliance to be on a separate lot (see
Section 502.1.A).

3.

Section 502.1.A - The total number and type of uses must be identifIed on the
property. Two (2) or more principal buildings or uses located on a parcel in single
ownership shall conform to all the requirements of this Ordinance which would
normally apply to each building or use if each were on a separate district lot,
including but not limited to setbacks, parking, lot coverage, and sewage disposal
requirements. Each use should identify these features as if it was on its own separate
lot. This may include street frontage requirements, such as Section 502.2 and
SALDO Section 606.3c.
The Designer's response indicates that each use would comply with requirements
relati,"e to existing property boundaries and that the minimum lot size would be
prodded. Howe,-er, neither the response letter nor the plan show how each use
would be compliant if it were on its own separate lot. The plan must show how the
lot couId be subdivided so as to have each use on a complying lot, each with its own
setbacks, frontage, sewage system, etc.

5.

Section 504.6.A - The plan must show the parking as would comply with Comment
3 above.
The plans indicate employee parking in an area of gravel and grass. All spaces
should be delineated to determine compliance with the required number of spaces.
Also, Section 504.10.B requires that all parking spaces be payed as noted.

Mary Anne Clausen

Eldred Township

A.pril15, 2016

7.

Section 504.7.H - Fire lanes should be identified on the plan; the plan currently
proposes the circulation driveway as the fire lane. The fire company should be
consulted to ,-erify compliance with their accessibility requirements.

8.

Section 504.8.C - A Highway Occupancy Permit will be required.

9.

Section 504.8.D - Turning templates shall be provided to assure adequate circulation

for the expected vehicles at all intersections and access points, including the alternate
route, Kunkletown Road (SR 3004) between Siker Spring Road (SR 3003) and
Correll Road.

14.

Section 701.1.C - The landscape buffer must prm-ide a dense screen within three (3)
years per this section. The Designer must identify the size of the rrees expected in
three (3) years and demonsrrate that they will screen all existing adjoining uses to a
minimum height of six feet (6').

15.

Section 701.8.C.3.d - The building elevation view on Sheet A-2.1 shows wall pack
lighting mounted on the proposed building. These fixtures are not accounted for on
the Lighting Plan Sheet LL-1.

16.

Section 701.11 - The application narrative states "Consistent with state law (Act 124
of 2009) and NWNA policy, tanker trucks will not be allowed ro idle their engines
when not engaged in vehicle movements." The response letter identifies that signs
will be placed at the Tanker Loading Building to remind operators of the idling
resrrictions; these should be shown on the plan.

17.

Section 701.12 - A hydro-geologic srudy is required which clearly establishes that the
proposed use will not cause a reduction in the quantity or the quality of ground water
supplies available to other properties located within 1000 feet of any portion of this
property. It is our understanding that the submitted srudy is under review by
another Township consultant. We have provided general comments via separate
letter.

21.

Section 701.21 - The Applicant shall prm-ide evidence that they have obtained all
required permits and authorizations.

22.

Section 703.4 - An Environmental Impact Statement (EIS) has been prepared. The
consultants must be previously approved by the Zoning Hearing Board.
'We have provided a review of the EIS via separate letter.

24.

Section 707.7 - The Applicant has provided a chart showing land use resrrictions
imposed on other properties by this project (Special Exception or outright
prohibition) as well as the existing prohibitions independent of tlus project. l\!ost of
the permitted uses are unaffected. Several agricultural uses permitted by right would
become Special Exceptions (or prohibited if Concenrrated Animal Feeding
Operations). Accessory storage tanks may be prohibited.
The sewage system for the existing house should be identified and evaluated for
isolation distance for Wellhead Protection. An approximate location is shown on the

Mary Anne Clausen

Eldred Township

April 15, 2016

'X'ellhead Protection Area Map (but not the plans) that appears to he near the
boundary of Zone I/Zone 2 Protection around Well PB-l.
The proposed sewage disposal system is located within Zone 2 and requires a Special
Exception. It should be noted that any new sewage disposal systems proposed
anywhere within the identified Zone 2 by other property owners will require Special
Exception.
The solicitor should be consulted as to whether any "bulk storage of regulated
substances" exists on the site's commercial operation. This storage would be
prohibited in Zone 2.
The solicitor should be consulted as to whether the proposed "silos" are regulated as
"storage tanks, aboveground" within the Wellhead Protection Zone regulations
which would prohibit them being located in Zone 1 and Zone 2.
25.

Section 708 - The following comments relate to the Traffic Impact Study ([IS):

26.

Section 708.C - The Intersection Sight Distance (ISD) for all intersections reviewed
shall be revised in accordance with the A..'\.STHO Green Book to reflect the primaty
type of vehicle for this use. The Applicant shall provide recommenda tions to
eliminate or minimize any noted constraints and whether there is a willingness to
participate with PennDOT and the Township to modify these constraints.

27.

Section 708.C - The Applicant shall update the Sight Distance Table summarizing
the sight distances for all intersections analyzed as outlined abon.

33.

Section 1208.4.E.6 The Planning Commission should review the standards and
criteria for Special Exceptions in this section.
One sewage disposal system is proposed to selTe the commercial truck and the water
extraction use. Independent se\\"age disposal may be required by the Zoning
Ordinance (see Comment 3).

34.

Section 503.1.A 504.2.B. and 8.D - Existing interior unimproved streets must be
shown on the plan. Adequate setbacks must be provided berween these streets and
proposed structures if they are classified as a "private ROW."

35.

Section 700.C and 1208.4.C - Existing traffic circulation for example, the existing
residence, Sandy Hill Path and Sandy Hill Lane, must be accommodated in the
design. See comment on Sections 503.l.A, 504.2.B, and 8.D.

36.

Section 707.4. 5.C and 7 - The water storage silos may qualify as abO\-eground
storage tanks. Aboveground storage tanks are prohibited in Well Head Protection
Zone 2, (and within a 50-foot setback from the 100-year floodplain).

fary Anne Clausen

Eldred To,,"nship

April 15, 2016

STORl\fWATER MANAGEMENT ORDINANCE:

A Stormwater Management review will be performed upon receipt of the land development
application. We noted that the following items were not addressed in the stormwater analysis
prm"ided:
1.

The plan must clarify what filrer fabric will be provided around the infiltration
trench, if the stone around the tanks are to be considered storage volume.

2.

The plan must clearly identify whether pavement will be graded to direct water to the
proposed inlets. A label to this effect has been provided. Contours and spot
ele\-ations must also show how this ,,-j]] be accomplished.

3.

The plan shows a "temporary sediment trap" on the grading plan. If this trap is
temporary (e.g. for erosion control during construction), the plan must show the
postdevelopment condition.

4.

The endwall near the Buckwha Creek is proposed to discharge on a steep slope.
Permanent provisions must be provided for this discharge (e.g. on the PCSM Plans,
not just Erosion Control Plans), and should not discharge onto a slope (e.g. by
discharging into a partially submerged endwall in the Buckwha Creek).

GENERAL COMMENTS:
1.

The Applicant shall address any improvements required by PennDOT for the access to
Chestnut Ridge Drive (SR 3001). Stone Arch Bridge Road (T-361) and its right-of-way must
be labeled on the plan, and the Applicant must provide all frontage and connection
irnprm"emenrs the Township would require.

2.

The existing 48-inch culvert is shown to change directions at several locations. The plan
should sho,," any points of access into the pipe. If no accesses exist, the Designer should
clarify how these changes were determined, and how the elevation was determined at the
waterline crossing.

3.

What is the stams and purpose of the existing sewage system shown across Stone Arch
Bridge Road?
Please note that the review of the application is ongoing and is, therefore subject to further

comment.

If you have any questions or comments regarding this information, please contact this office.

Respectfully,
GI EERING .'\SSOCIATES, I C.

tmk:jam/jle/aat
S:\Pro,n:l> \ -'lunlClf'.oI\EIdrnlT"l' \EId I!i21->':~""\\-~lerEJ;lncloon\Do.;~\20160-11 ~_>.: =k_SpcaaI_E~ccpl'>(JI'I_R. '"tC\o'.doo.:

cc:

Eric Andreus