HomeMy WebLinkAboutAttachment JCA Letter to Barnstable Conservation Commission Sep 4 2023JOHN C. ALE
P.O. BOX 671, HYANNIS PORT, MA 02647
September 4, 2023
VIA EMAIL—conservation@town.barnstable.ma.us, darcy.karle@town.barnstable.ma.us
Barnstable Conservation Commission
Town of Barnstable
367 Main Street
Hyannis, Massachusetts 02601
RE: Quarterra Multifamily Communities, LLC – 35 Scudder Avenue
Dear Commissioners:
In section 2.6 of its Notice of Intent (page 2-4), Quarterra Multifamily Communities, LLC makes
several assertions regarding groundwater and nitrogen loading. Some of these were also made to the
Cape Cod Commission, whose decision to approve a development agreement for the applicant’s project
is now the subject of a pending appeal with the Superior Court for Barnstable County.
First, I am not an engineer and cannot comment on the source or accuracy of the applicant’s
figure for current groundwater removal rates at the site. But it does not take an engineering expert to
recognize that, even assuming the existing golf course requires more water than the lawn areas of the
proposed apartment project, the applicant’s discussion does not take into account water consumption by
the residents of the proposed apartment complex. Even if on-site withdrawals diminish, I strongly
suspect that adding 312 dwelling units with 510 bedrooms and therefore hundreds of residents will add
up to a much greater volume than any reduction from lawn area. The Town supplies the water to the
apartment complex, and that water must come from somewhere. To the extent that groundwater
withdrawals are relevant to the Commission’s decision, I urge you to look at the impact of the project
off-site as well as on-site.
Second, the applicant’s nitrogen loading calculations in Appendix B assume that golf courses
apply fertilizers at exactly the same rate as owners and renters do to residential lawns. This assumption
rests on decades-old golf course practices. Evidence presented to the Cape Cod Commission in its
hearings on this project showed that current golf courses practices indicate a lower nitrogen loading rate
from this golf course than the applicant’s calculation for its proposed project. (A copy of engineering
expert calculations is attached.) Regardless, these calculations are based on assumptions rather than the
golf course’s current actual practice in applying fertilizer. Surely the applicant can obtain those figures,
just as it has actual data on groundwater withdrawals. The Commission should require the applicant to
calculate current nitrogen loading based on actual usage—how else will you know whether projections
for the project are higher or lower?
Respectfully,
John C. Ale
Attachment – Report of BETA Group, Inc.
MEMORANDUM
BETA GROUP, INC.
www.BETA-Inc.com
BETA Group, Inc. (“BETA”) was engaged by Save Twin Brooks1, Inc., to review and respond to the Cape Cod
Commission (the Commission) Memorandum dated January 05, 2023 regarding clarification of nitrogen
loading from golf course fertilizer. BETA has evaluated our original calculations to verify the findings of the
commission and revise our analysis accordingly. To establish the actual distribution of use on the golf
course, BETA has developed an overlay of the course based upon satellite imagery. The base plan for
comparison is the Existing Conditions Plan submitted by the Applicant’s engineer Pesce Engineering &
Associates, Inc. (Pesce Engineering) dated February 11, 2021. Based upon these plans, the course areas
and use are:
Total Course Area12 1,130,030 sq. ft. Cape Cod Commission
Greens 69,650 70,666
Tees 35,324 17,237
Sand Traps 22,040
Fairways 106,070 13,156
Ponds 70,900
Forested 365,880
Rough 456,360 710,270
Cart Paths 3,500
Roof 306
Managed Turf Totals:
(Greens, Tees, Rough, Fairways) 689,444 811,270
1 Save Twin Brooks, Inc. represents a group of Barnstable citizens advocating to save the 40 -acre property at the
Twin Brooks as an open space preserve for conservation and community use.
2 The course area is that portion of the course that is located withi n the limits of the parcel that will be developed.
106,000 sq. ft. that is currently used in the course is located outside the proposed parcel property limits.
Date: February 02, 2023 Job No.: 21.10238.00
To: Cape Cod Commission
c/o Subcommittee for CCC File No: 20065
3225 Main Street
Barnstable, MA 02630
Cc: Laura Krause, Project Manager (BETA)
Emily Slotnick, Associate (BETA)
Save Twin Brooks, Inc.
From: Gary D. James, P.E., Sr. Project Manager
Subject: 35 Scudder Avenue
Nitrogen Loading Evaluation
Date: February 02, 2023
Page 2 of 4
The course areas generated through BETA’s calculations closely match the areas reported by Pesce
Engineering (675,000 sq. ft.), which are approximately 125,000 square feet less than the areas used by
the Commission in their analysis. As reported in the table above, BETA has estimated that the active area
of the course is 211,044 sq. ft., as opposed to the 101,059 sq. ft. generated by the Commission’s analysis.
The Commission prepared nitrogen loading rate calculations using three (3) different methodologies. For
comparison, BETA has reviewed at the anticipated loading rate based upon the MVP model loading rates
and the rates that were previously presented to the Commission by Kevin Doyle, of the Golf Course
Superintendents of America (GCSOA). The results of BETA’s supplemental analysis are as follows:
Calculation of Fertilizer Nitrogen Per WatershedMVP Tool
Turf Type Measured Turf Area Fertilizer Application Rate Applied Nitrogen
(ft2) (Lbs/1000 ft2 / year) (lbs/year)
Greens 69,650 2.75 192
Tees 35,324 2.61 92
Fairways 106,070 2.48 263
Rough 456,360 1.84 834
Total 689,444 1,381
Using the nitrogen loading rates presented in the Watershed MVP model and using BETA’s calculated
course turf areas (see attached figures), which are generally consistent with Pesce Engineering’s
calculations, the total pounds of fertilized applied per year is calculated to 1,381 lbs/yr, as compared to
the 1,579 lbs/yr calculated by the Commission.
Based upon the above, and correcting the usage areas as shown on the attached maps, BETA has shown
a reduction of approximately 200 lbs/yr using the WatershedMVP model rates, as compared to the Cape
Cod Commission’s calculations.
Calculation of Fertilizer Nitrogen Per Golf Course Superintendents of America
Turf Type Measured Turf Area Fertilizer Application Rate Applied Nitrogen
(ft2) (lbs/1000 ft2 / year) (lbs/year)
Greens 69,650 2.50 174
Tees 35,324 2.50 88
Fairways 106,070 1.75 186
Rough 456,360 0.88 399
Total 689,444 847
Using the fertilizer application rates previously presented to the Commission by Kevin Doyle, of the Golf
Course Superintendents of America, the calculations show a 47% reduction of the existing loading rate
reported by the Commission (847 lbs/yr vs. 1,579 lbs/yr).
Date: February 02, 2023
Page 3 of 4
It is BETA’s opinion that the application rates previously presented to the Commission by Kevin Doyle, of
the Golf Course Superintendents of America, are representative of current application rates being
implemented by golf courses. The rates quoted in the MVP model are in line with the rates quoted by Golf
Course Superintendent Association in 2006, 16 years ago. The references quoted by the Commission in
their analysis of the fertilizer application rates are from 2000, and 2007, the same period. However, the
golf course management industry has become more aware of the issues associated with irrigation water
demands and nutrient loading requirements, and have adjusted their application rates accordingly.
Calculation of Existing Site-Wide Nitrogen Loading with Different Fertilizer Inputs
As one component of the site-wide nitrogen loading calculation, changes to the fertilizer nitrogen input
will change the overall site-wide nitrogen loading result. BETA completed additional sitewide nitrogen
loading calculations according to Appendix A using the three different estimates for applications of
fertilizer nitrogen described above. Other inputs to the calculation include a managed turf area of 689,444
ft2 as determined from aerial photography, roof and paving areas provided by the applicant (360 ft2 and
3,500 ft2, respectively) and natural area of 1,534,733 ft2 that reflects the balance of project site land not
covered by paving or rooftops. The following Table shows the nitrogen input estimated by each modeled
fertilizer nitrogen method, and the corresponding sitewide nitrogen loading.
Fertilizer Nitrogen Method Fertilizer Nitrogen Input Sitewide Nitrogen Loading
(lbs / yr) (mg / L)
Appendix A Fertilizer Nitrogen 2,068 3.58
WatershedMVP Fertilizer Nitrogen 1,381 2.39
GCSOA Fertilizer Nitrogen 847 1.47
Applying the application rates above to the existing conditions analysis, the results of the nitrogen loading
for the Twin Brooks Golf are reported in the table above.
Conclusions
As reported by the Commission in their review, the project application rate is 2.21 mg/l. Thus, when
comparing the proposed and existing nitrogen loading rates, the nitrogen loading rate calculated using
the MVP rates shows a slight decrease from existing to proposed (from 2.39 mg/l to 2.21 mg/l). However,
using current typical application rates (as provided by GCSOA), the project will result in an increase from
1.47 mg/l up to 2.21 mg/l.
It is unclear how the Cape Cod Commission determined the areas of fertilizer application rates, so BETA is
unable to comment on how the areas presented in the CCC’s memorandum were generated. Looking
realistically at satellite imagery of the course, BETA was able to determine the areas that were being
managed in conjunction with the course. In addition, the fertilizer rates referenced in the CCC models are
based upon data from 15 years ago. While BETA agrees that the application rates reported for this period
were consistent for that time, current fertilization rates are significantly lower. Accordingly, it is BETA’s
opinion that the development will result in an increase in total nitrogen loading on the surrounding coastal
resource.
Date: February 02, 2023
Page 4 of 4
Sample Calculation - GCSOA Fertilizer Nitrogen:
IMPERVOUS SURFACES
𝑅𝑜𝑜𝑓 𝑎𝑟𝑒𝑎 = 360 𝑠.𝑓. 𝑥 40 𝑖𝑛
𝑦𝑒𝑎𝑟𝑥 28.32 𝐿
𝑐𝑢.𝑓𝑡.𝑥 1 𝑦𝑟
365 𝑑𝑎𝑦𝑠= 93.1 𝐿
𝑑𝑎𝑦𝑥 0.75 𝑚𝑔
𝑙= 69.8 𝑚𝑔/𝑑
𝑃𝑎𝑣𝑒𝑑 𝑎𝑟𝑒𝑎 = 3500 𝑠.𝑓.𝑥 40 𝑖𝑛
𝑦𝑒𝑎𝑟𝑥 28.32 𝐿
𝑐𝑢.𝑓𝑡.𝑥 1 𝑦𝑟
365 𝑑𝑎𝑦𝑠= 905.21 𝐿
𝑑𝑎𝑦𝑥 0.75 𝑚𝑔
𝑙= 1357.81 𝑚𝑔/𝑑
NATURAL
𝑁𝑎𝑡𝑢𝑟𝑎𝑙 𝑎𝑟𝑒𝑎 = 1,534,733 𝑠.𝑓.𝑥1.5′
𝑦𝑟𝑥 28.32 𝑙
𝑐𝑓 𝑥 1 𝑦𝑟/365 𝑑𝑎𝑦𝑠= 178,617.69 𝑙/𝑑𝑎𝑦
CALCULATION OF NITROGEN LOADING
𝑆𝑢𝑚𝑚𝑎𝑟𝑦=[69.80 +1357.81]+{263,382}
79.14 +905.21 +178617.69 =264,809.61 𝑚𝑔
179602.04𝑙=1.47 𝑚𝑔/𝑙
GOLF COURSE NITROGEN INPUT FOR LOADIN CALCULATION
From analysis- Appendix A 643,063 mg/d
MVP 429,434 mg/d
GCSOA 263,382 mg/d