Mr. John McNicholas

Town of Medfield

Zoning Board of Appeals

459 Main St.

Medfield, MA 02052

 

March 2025

 

Dear Mr. McNicholas,

We, the undersigned, oppose the proposed 40B development at 86 Plain St, Medfield.

We ask that the Zoning Board of Appeals deny the comprehensive permit that the developer is requesting on the basis that it threatens our health, safety and welfare, and additionally threatens the sensitive nature and existing environmental conditions of the site they are applying for a permit.  Additionally, we see no way that these risks can be reasonably mitigated.  Consequently, we feel that the local concerns outweigh the regional need for affordable housing for this specific proposal.

The issue of safety as it relates to the traffic and location of the egress has not satisfactorily been addressed by the traffic study that was submitted.  We are confident that an additional traffic study, by an independent licensed firm, will yield different results.

Some items that cause concern are the site lines and the intersecting road.  The method used does not account for the grade of the road.  The submitted study is for a level road.  The road is not level.  The stopping distance formula for a level road is not the same as a road with a grade.  When you factor in the downgrade, the stopping distance is increased.  Also, they did not factor in what the stopping distance is in wet conditions, nor did they account for the variation with trucks.  The AASHTO goes so far as to state that “every effort should be made to provide stopping distances greater than the minimum design value”.

The report also does not account for the narrowing of the road when snow is being plowed which further reduces the sight distance.

Below are additional examples of inaccuracies in the report.

Report: Site Driveway is a private roadway that runs in an east-west direction between private property to the east and Plain Street to the west. It is a two-way concrete driveway with no lane markings and no sidewalks. The full length of the driveway is surrounded by trees and measures over 600 feet in length. 

Fact: It is a 12’ wide driveway, not a two-way concrete driveway.  Generally, a two way road needs to be no less than twenty feet.

Report: Plain Street/Briar Hill Road is an unsignalized three-legged intersection. The Briar Hill Road eastbound approach is STOP-controlled and consists of one left-turn/right-turn lane. The Plain Street northbound approach consists of one shared left-turn/through approach. The Plain Street southbound approach consists of one through/right-turn approach. On-street parking is provided along the Briar Hill Road approach. A sidewalk is provided along the north side of the Briar Hill Road approach.

Fact: There are no STOP signs on Briar Hill, and it is not STOP-controlled.

Site Access and Parking

The Site plan for the proposed Project is shown in Figure 8. Vehicles arriving at the Site will continue to utilize the existing driveway. A proposed new driveway on Plain Street, north of the existing driveway, will provide egress to all vehicles. Each residential home will provide two offstreet parking spaces per Town of Medfield Zoning Bylaws.

Fact: The existing driveway is only 12’ wide.  The proposed driveway is 20’ wide.  How could the existing driveway be used for two way traffic when it is only 12’ wide?

Suffice to say, a  report from an independent company, that is factual and is intended to offer an assessment on whether, or not, the proposed driveway is safe, conforms to the standards as outlined by AASHTO, or any other state or federal guidelines, is necessary, and that we should not rely on a report that leaves out important details in order to present a case that the proposed driveway is in conformance.  

Additionally, the traffic study was done during COVID when presumably there was less traffic than there is today.

Furthermore, here is their conclusion:

The proposed development is expected to have de minimis impact on the local transportation network. The Project is anticipated to generate approximately 17 new vehicle trips during the a.m. peak hour and 22 new trips during the p.m. peak hour. All peak hours are forecasted to generate approximately one to two vehicles every 15 minutes. The existing network has the capacity to accommodate the minimal additional trips without resulting in any noticeable delays to the study area intersections.

Is it reasonable to expect that there will be only 39 trips from a development that has 24 homes?  It is safe to assume that each home will have two cars, and even if each home only took three round trips per day, that would amount to 72 trips.  The likelihood is that it would be much greater since these homes are presumably intended for families who have children going back/forth to school and activities, and parents who are going to work and running errands.  Also, this does not account for delivery services, trash removal trucks, service vehicles and visitors.  The number of trips wills surely be a multiple of 39 per day.

This added element of additional traffic also puts at risk all our residents that use the Medfield Gardens in the warmer months.  If you travel on this road, which is a very narrow old “farm” road and designated as a Scenic Road, you are well aware that when two vehicles come from opposite directions, each one must move to the very edge of the road to let the other by.  When a truck is one of those vehicles, one of the vehicles actually has to go off the road.  This is exacerbated when there are pedestrians and bicycles on the road, and when the users of the Medfield Gardens park on the side of the road.  Adding what will be thousands of more trips on this road if this development was approved surely puts all of us at higher risk.

This project indicates the existing driveway will be widened from a 12’ road to a 20’ road.  The plan indicates it will be an asphalt driveway.  Almost, all, if not all, of this driveway will be located in the buffer zone which is intended to protect the wetlands and very sensitive vernal pools.

As a point of information, the previous owner never filed a Notice of Intent, nor does their file at the Building Dept include any permitting for the construction of the current asphalt driveway.  Prior to that driveway, the road was a hard packed dirt road.  Is there any reason the Conservation Commission (Issuing Authority) should not consider actions to restore this current driveway to its former condition?  This type of activity on private roads, where a landowner engages in activities contrary to the regulations, is predictive of future activity of new owners who are not under active scrutiny, that can have an adverse impact to these sensitive areas.

Essentially, the proposed entire driveway is within the buffer zone, and according to 310 CMR, “ … alterations may only be permitted if they will have no adverse effects on wildlife habitat…”.

The continued use of this road, and the increased volume will predictably cause an adverse effect to the vernal pools.  Prior to any consideration of the application, we ask that an independent study be done to determine if the widening, and increased use of this proposed road will cause an adverse effect.

A published report by the Metropolitan Conservation Alliance (Maine Audubon Society, University of Maine, Metropolitan Conservation Alliance and the Wildlife Conservation Society), titled Best Development Practices for the Conservation of Pool-Breeding Amphibians in Residential and Commercial Developments in the Northeastern United States, it clearly states the following:

Roads (and associated development) within this zone limit the amount of terrestrial habitat available to amphibian populations, fragment and isolate remaining pieces of habitat, facilitate further development, and directly result in mortality of individuals.

Recent research conducted within Rhode Island has demonstrated that vernal poolbreeding amphibians may be extremely sensitive to roads constructed within 0.62 miles (1 km) of the vernal pools in which they breed (Egan 2001; Egan and Paton, in prep.).

Within this area, a mere 16 linear feet of road per acre (12 m/ha) was linked to significant declines in numbers of wood frog egg masses; only 25 feet of road per acre (19 m/ha) appeared to cause significant declines in numbers of spotted salamander egg masses. Beyond these thresholds, even slight increases in road density severely limited the potential of the areas surrounding pools to serve as nonbreeding habitat. Research by Klemens (1990) has suggested that actual road configuration and pattern (i.e., “roads to nowhere” and cul-de-sacs servicing subdivisions vs. linear roads connecting urban centers), as well as road density, likely factors into amphibian population declines.

Road mortality is a major contributing factor in amphibian declines. This occurs by direct mortality from vehicular traffic as well as increased vulnerability to depredation and desiccation when amphibians cross roads.

A number of studies have shown that roads (and urbanization) limit amphibian dispersal and abundance (Gibbs 1998; Lehtinen et al. 1999; deMaynadier and Hunter 2000; Egan and Paton, in prep.). Certain species are reluctant to cross open, unvegetated areas, including roads. Roads create barriers to amphibian dispersal.  Curbs and catch basins act as traps that funnel and collect amphibians and other small animals as they attempt to cross roads.

Roads are sources of chemicals and pollutants that degrade adjacent aquatic and terrestrial habitats. These pollutants include, but are not limited to, salts, particulate matter, and heavy metals. Eggs and larval amphibians are especially sensitive to changes in water quality. Influxes of sediment can smother eggs, while salts and heavy metals are toxic to larvae (Turtle 2000).

Roads create zones of disturbance characterized by noise and light pollution. Both of these pollutants interfere with the ability of amphibians to disperse across the landscape. Noise pollution can also interfere with frog calling activity, which is an essential part of their reproductive ecology.

Roads can change hydrology (thus changing vernal pool quality and hydroperiod).

Roads and driveways should be excluded from the vernal pool depression and vernal pool envelope.

There is no way to mitigate this risk, and the road and the increased traffic will have an adverse impact on this sensitive area.

310 CMR also states:

3. Work in those portions of bordering land subject to flooding found to be significant to the protection of wildlife habitat shall not impair its capacity to provide important wildlife habitat functions. Except for work which would adversely affect vernal pool habitat, a project or projects on a single lot, for which Notice(s) of Intent is filed on or after November 1, 1987, that (cumulatively) alter(s) up to 10% or 5,000 square feet (whichever is less) of land in this resource area found to be significant to the protection of wildlife habitat, shall not be deemed to impair its capacity to provide important wildlife habitat functions. Additional alterations beyond the above threshold, or altering vernal pool habitat, may be permitted if they will have no adverse effects on wildlife habitat, as determined by procedures contained in 310 CMR 10.60.

The disruption of more than 5,000 sq ft., in the buffer zone, which is likely given the plan to add 8’ of width to the existing driveway, and work done in the area for utilities, would require that they have no adverse effect on wildlife habitat.

We ask that you do not approve the application since our local concerns to protect our health, safety and welfare, and to protect the ecologically sensitive areas health outweigh the regional need for affordable housing.

The developer has indicated, at the outset of this process, that they knew a previous attempted development was denied by the Town.  The representative indicated they wanted to do a conforming development to our local by-laws, but, if necessary, would submit a 40B application to skirt many of the local rules and to more heavily rely on the State & Federal regulations.  During this entire process, they have never focused on how this proposal would be beneficial to the town.  To the contrary, all indications is that their objective is purely profit.

The laws and regulations have been enacted for a reason.  Developments that do not conform, and cause harm to people and our environment should not be approved.  We think the Town and State can overcome the burden of proving that our local interests outweigh the regional need for affordable housing.