RT ENVIRONMENTAL SERVICES, INC.
Gary R. Brown, P.E., President
December 7, 2006
Hilltown Township Board of Supervisors
Hilltown Township Municipal Building
13 West Creamery Road
P.O. Box 260
Hilltown, PA 18927-0260
RE: PROPOSED McGRATH DEVELOPMENT
RT PROJECT #70773-02
Dear Supervisors:
I have been retained by Cindy and Lawrence Owen to comment on the proposed McGrath Development, and, in particular, the Ordinance which proposes to allow a change in zoning to permit an age restricted community to be built on the property. For a number of reasons, which I will enumerate on, the proposed Zoning Ordinance is premature because the feasibility of the changes that would result from approval of the Ordinance, have yet to be determined and implementation of the proposed development may not be feasible.
Further, changes to the nature of the area could occur, unless the feasibility of water and wastewater utilities to service the proposed development are confirmed and defined. Soils at the site area are considered poorly drained, and are not considered suitable for conventional onsite septic systems. Although sand mound systems can be used, and have been used in the area, failures have occurred, including one at a nearby convenience store location. Given the high density of the proposed development, it is critical to determine whether or not an onsite sewage disposal system is or is not feasible. If the system is found not to be feasible, during the further site plan development process, McGrath will be requesting connection to an offsite existing wastewater collection and management system. This is definitely considered problematic, because, according to the Bucks County Health Department, by law, developers, when running sewer lines to distant treatment plants or pumping stations, have to connect not only the development properties, if lines were to run from this point, but also every home and building along the way, to those homes, making the cost of the sewage connection quite high.
The nearest connections to the site are at Dublin Borough, or, to the Hilltown Township Water and Sewage Authority connection on Blooming Glen Road, three quarters of a mile from the proposed McGrath site. However, the location of the connection would require one or more pumping stations, and a stream crossing.
Based on information from the Bucks County Planning Commission, as the property and surrounding area are currently in the rural residential zone, density of development is limited, which in-turn, limits sewer connections. Planner Van Ryker previously testified to the Board of Supervisors that the rural nature of the area, and continued preservation of farmland would not be impacted by approval of the McGrath development. However, according to Bucks County Health Department and Planning Commission information given to our firm, this is definitely not the case. Were McGrath to find onsite wastewater treatment and sewage disposal systems not to be feasible nor cost effective, the extension of wastewater collection systems to points where other connections are available, would permanently change the rural residential nature of the area. This is true because residential density along roadways virtually always increases when sewage service becomes available, especially in areas where the soils are classified as having very limited potential for sewage disposal.
It should be carefully noted that no provision has been made in proposed plans for the siting of any onsite wastewater or treatment facilities, and no information on the feasibility of onsite water or wastewater utilities, has been presented.
Based on this information, any proposal to change the zoning is clearly premature, as there is inadequate support for Van Ryker’s statements that the character of the area would not be expected to change.
Basic evaluation of the “By Right” Site Plan, causes one to think it is only “common sense”, that some type of wastewater collection and treatment system should be evaluated, and at least tentatively selected, and worked into the Site Plan, for the proposed zoning change to be considered minimally feasible. Wastewater treatment systems, for developments of this size, have been found to not be cost effective at a number of sites. Additionally, review of Penn State’s Soils Maps for several soil types in the area, all classify soil as having “very limited” potential, for sewage disposal. This is the worst rating possible, according to Penn State’s scale. Although sand mounds can be used, as previously indicated, the large size of the development proposed, as compared to maximum typical sizes for individual sewage disposal systems, causes one to question why a wastewater facility plan for the site hasn’t been developed and presented. As a very basic part of the planning and zoning process for a change in the zoning for the site to be seriously considered, at a minimum, land should be set aside for this.
Water withdrawal, through wells, to supply the size of the development proposed would definitely have an expected impact on the Morris Run Tributary. In addition to the impact on the Morris Run Tributary, the water withdrawal would potentially impact the existing MTBE groundwater plume associated with the known offsite release. These considerations would need to be addressed in the planning and zoning process.
In addition to little information on water and wastewater management, the layout of the “By Right” Plan, falls short in a number of areas. First, a basin or pond continues to be shown on the opposite side of the Morris Run Tributary from the proposed development, and no detention or retention stormwater facilities appear to be located at lower elevations to intercept stormwater, than the proposed development. The Pennsylvania Department of Environmental Protection (PADEP) has greatly expanded requirements for stormwater management controls, at all sites of this type, and the same limitations which apply to limited potential for sewage disposal, will undoubtedly also apply to the limited potential for stormwater infiltration. Limited infiltration site constraints can also make stormwater management systems for a development such as this expensive, but no feasible alternative Best Management Practices have even been proposed or recommended or are shown in the “By Right” Plan at this time.
In the last decade, considerable changes in water and wastewater planning, as well as stormwater planning, have greatly changed what can and cannot be built at development sites in the Commonwealth. Zoning changes of the magnitude and type proposed at the McGrath Development Site certainly warrant adequate evaluation as part of the “By Right” Plan presentation, along with enumeration of what wastewater and stormwater management plans will be implemented, before any conclusions could possibly be reached on the impacts of a major zoning change such as is proposed. With all due respect to statements made by the applicant at the last meeting, adequate support has not been provided which would allow one to believe that statements made about the lack of impact on the surrounding area, and roadway(s) of potential utility corridors leading to the development site, are really true.
Any proposal to change the 2003 Hilltown Township Comprehensive Plan should at least address key elements such as water, wastewater, and stormwater, given the known site constraints, but at this time, no demonstration has been made that the change in use contemplated by the proposed ordinance, is cost effective nor feasible.
In discussion with the Bucks County Planning Commission on the proposed ordinance change, a representative of the Planning Commission indicated that “you do not want this zoning change to happen regularly”, because the Township’s Comprehensive Plan for the development will change. The Comprehensive Plans set long term goals that should have the community’s best interest in mind, and should not be changed. The property is currently in the rural residential zone which limits density of development, and therefore limits sewer connections. Once this situation changes, the character of the area will clearly change, but even basic information on the feasibility of the change has not be presented to the Board of Supervisors, so, it is my opinion that until the planned change in zoning is found to result in a feasibly built age restricted community, and until it is confirmed that the character of the area will not change as the result of the need for offsite utility connections, the planned zoning ordinance change should not be further considered.
I appreciate the opportunity to comment.
Very truly yours,
RT ENVIRONMENTAL SERVICES, INC.
Gary R. Brown, P.E.
President
GRB\jw
Cc: L. Owen
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