Reject Gas Station Proposal or Apply Conditions to Approval

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Whereas

Tullahoma citizens have the following concerns about the proposed gas station/convenience store at the intersection of Clement and Westside Drive:

1.     Traffic – already congested area

a.     Does design allow for delivery trucks (including fuel trucks), boat trailers, RVs, and other large vehicles to safely enter and exit property without disrupting traffic or encroaching on neighboring properties?

2.     Safety for pedestrians and bicyclists, including children walking and biking to school at Farrar and West Middle

3.     Pollution – nearby creek and wetlands, discharge to impaired stream, karst terrain and nearby residential wells, homes with basements

a.     Underground storage tanks leak. As of September 2017, the EPA lists 538,193 confirmed cases of leaking USTs There are currently 555,000 USTs operating in the US.

b.     Incidental spills from vehicle fueling operations are not insignificant. A 2014 study estimated approximately 40 gal/year of spillage at a typical gas station.[1]

c.      A 2002 study determined the average travel distance from discharge sites for gasoline constituents in groundwater to be 295 feet; approximately 1/3 of MtBE contamination plumes and ¼ of gasoline plumes traveled more than 300 feet.[2]

d.     Tullahoma Municipal Code (7-406): (3) No person shall negligently discard, dispose, discharge, deposit, inject, dump, spill, leak, spray, place or otherwise cast into or upon any land, whether improved or unimproved, upon public or private street, roadway or highway, into any drain, gutter, sewer or culvert, into any lake, pond, water course, or ditch, or into any pit or excavation, or into or atop of any aquifer, any hazardous waste within the corporate limits of the City of Tullahoma. The site plan does not appear to incorporate design controls to prevent contamination from accidental spills from entering stormwater, where it could pollute soil, groundwater, and surface waters.

4.     Character of Neighborhood –

a.     A quiet, residential area of town will be permanently transformed; this development will set a precedent for how properties will be developed in the future in this part of town.

b.     Light pollution – Exposure to light at night disrupts sleep patterns and may have long term effects on health.

c.      Noise – Increased noise levels from delivery trucks, garbage trucks, and increased traffic will change the character of the nearby neighborhoods and disrupt residents’ use of their properties.

d.     Gas station/convenience store in a residential area inconsistent with intents of Comprehensive Development Plan[3], which lists among its goals:

           i.     Locate commercial activities on sites which are accessible, adequately served by utilities and are compatible with adjacent/area land uses (7.1.2)

            ii.     Ensure aesthetic and functional compatibility of uses (7.1.1.1.13)

            iii.     Develop and maintain viable neighborhoods as the primary element of the residential system (7.5.3)

                                            iv.     Preserve property rights by ensuring use of properties developed in compliance with the City’s Comprehensive Plan and Land Development Regulations (7.7.3)

5.     Property Values – some homes will be rendered ineligible for FHA mortgage insurance due to close proximity to underground storage tank with flammable materials[4]

6.     Crime – Convenient store holdups account for 6% of all robberies nationwide (US Dept of Justice, 2002). This development would contribute to the spread of crime and threaten nearby neighborhoods.

We, the undersigned residents and concerned citizens of Tullahoma, do hereby oppose the construction of said gas station and convenience store and request that the Planning Commission reject the site plan for the proposed project.

If the Planning Commission approves the project, we request the following contingencies and/or changes to the site design:

1.     Traffic Impact Study, to be performed by an independent, third-party traffic engineer.

2.     Small Area Study, as recommended in Tullahoma Comprehensive Development Plan (2011) “in areas experiencing development pressure” (7.5.1.3.2).

3.     Crosswalks in all directions, and ADA curb cuts with detectable warning strips.

4.     Improved stormwater control, based on best practices – Relatively clean stormwater, such as from roofs and canopies, should not be allowed to run onto the fuel dispensing area. Total suspended solids (TSS) should be treated prior to entering the detention basin.

5.     Monitoring of USTs and stormwater outfall to ensure rapid detection of leaks or failures of stormwater control measures

6.     Vegetative screening – A mixed evergreen barrier, 15’ in width, should be planted along the South, East, and where space allows, along the West sides of the property as a screen and noise barrier to nearby residential lots. Shrubs to be planted 5’ on center, and trees every 10’ on center. Minimum height of tree 8’, minimum container size of shrub 3-gallon size. A maintenance agreement should be put in place to ensure this border is preserved (and dying or underperforming plants replaced) in perpetuity.

7.     Placement of screened dumpster on SE side of lot, away from roadways.

8.     Lighting designed to not affect nearby residences. Require fixtures to have zero uplight, 0-1 glare, and zero trespass onto adjacent residential properties.

9.     Limited hours of operation and deliveries (6am-10pm), to reduce impacts to surrounding residential areas.

10. Sign height and design – no taller than 4’, brick, to “ensure aesthetic compatibility” with funeral home and church (7.1.1.1.13).

11. Building with brick façade, to “ensure aesthetic compatibility” with adjacent neighborhoods, as well as funeral home and church(7.1.1.1.13).

12. More landscaping along road frontage, to “ensure aesthetic compatibility” with adjacent neighborhoods(7.1.1.1.13).



[1] Journal of Contaminant Hydrology 170(2014) 39-52.
[2] Bureau of Remediation and Waste Management, Maine Department of Environmental Protection, “Historical Oil Contamination Distances in Groundwater at Sensitive Geological Sites in Maine,” April 30, 2002.
[3] adopted by the Board of Mayor and Aldermen, July 25, 2011.
[4] Federal Housing Authority Single Family Housing Policy Library, 4000.1.II.D.3.c.iii(C)(7)



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