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HomeMy Public PortalAboutStormwater Mgt and Erosion Control TOWN OF 1630 WATERTOWN Office of the Town Manager (':' . i H_ '"; � Administration Building r 149 Main Street Watertown,MA02472 Phone:617-972-6465 • www.watertown-ma.gov Michael J.Driscoll townmerChvatertomn-ma.sov Town Manager - To: Honorable Town Council From: Michael J. Driscoll, Town Manager �u Date: February 4, 2016 RE: First Reading on an Ordinance Establishing Requirements for Stormwater Management and Erosion Control The Committee on Public Works presented a report at the October 13, 2015 Town Council Meeting (see attached Committee Report and an excerpt from the October 13ttt Town Council minutes). As a follow-up to the above, I respectfully request a First Reading on the attached Ordinance establishing requirements for Stormwater Management and Erosion Control be placed on the February 9,2016 Town Council Meeting. Thank you for your consideration in the matter. cc: Stormwater Advisory Committee Gerald S. Mee, Jr., Superintendent of Public Works Matthew Shuman,Town Engineer Dennis J. Sheehan, Director of Administration and Finance, Department of Public Works Steven Magoon,Director of Community Development and Planning/Assistant Town Manager Mark R. Reich, Esquire, Kopelman and Paige,P.C. ORDINANCE# AN ORDINANCE ESTABLISHING REQUHZtVIENTS FOR STORMWATER MANAGEMENT AND EROSION CONTROL Whereas, the establishment of minimum requirements and procedures to regulate land disturbance associated with construction activities serves the public interest by reducing the adverse impacts of soil erosion and sedimentation from stormwater runoff; and Whereas, such regulation serves the objective of preventing pollutants from entering into, and discharging from,the Town of Watertown's storm drainage system; and Whereas, the Town wishes to ensure that best management practices for stormwater controls, including long-term operation and maintenance practices for stormwater facilities, are incorporated into land development and redevelopment; and Whereas,regulations adopted by the United States Environmental Protection Agency under the Federal Clean Water Act require the Town to regulate stormwater runoff related to construction and post-construction activities, as a condition of the federal General Permit for Municipal Separate Storm Sewer Systems. NOW THEREFORE BE IT ORDAINED by the Town Council of the City Known as the Town of Watertown that Title IX of the Watertown Code of Ordinances, "Business Regulations," is hereby amended by the insertion of a new Chapter 98 as follows: CHAPTER 98: STORMWATER MANAGEMENT AND EROSION CONTROL §98.01 GENERAL PROVISIONS (A) Purpose The purpose of this Ordinance is to control stormwater runoff into the Town of Watertown's Municipal Separate Storm Sewer System (MS4) and Iocal water bodies to minimize stormwater runoff and prevent pollution. Specifically, the objectives are: (1) To protect, maintain, and enhance the public safety, environment, health, and general welfare by establishing minimum requirements and procedures to reduce the adverse impacts of soil erosion and sedimentation and manage stormwater runoff, (2) To control and prevent soil erosion and sedimentation resulting from construction site stormwater runoff; (3) To promote infiltration and the recharge of groundwater in order to minimize flooding; (4) To prevent pollutants from entering the Town's MS4 and to minimize I discharge of pollutants from the MS4; (5) To ensure that stormwater management techniques, including Best Management Practices, are incorporated into the land disturbance, development, and redevelopment planning and design process in order to control soil erosion and sedimentation and stormwater runoff; (6) To ensure that the adequate long-term Operation and Maintenance of Best Management Practices (BMPs) is incorporated into the land disturbance, development, and redevelopment process and implemented in the future so that they work as designed; and (7) To comply with state and federal statutes and regulations relating to stormwater runoff discharges. This Ordinance establishes the Town's legal authority to ensure compliance with the provisions of this Ordinance through permitting, inspection, maintenance, and enforcement. (B) Applicability A Stormwater Management and Erosion Control Permit shall be required prior to undertaking any alteration or land disturbance activity that: (1) Will result in land disturbances of 5,000 square feet of total area or more, or smaller activities that are part of a larger common development plan that will disturb 5,000 square feet or more; (2) Will cause a net increase in site impervious surface area by more than 500 square feet; (3) Proposes to create or modify a direct connection to the MS4; or (4) In the opinion of the Department of Public Works, may result in an adverse impact on the MS4 or water resources of the Town of Watertown. (C) Exemptions The following activities are exempt from the requirements of this Ordinance,provided that such work must utilize the best practical measures to avoid any negative impacts on stormwater quality or runoff rate or volume: (1) Repairs to any stormwater treatment practice that are deemed necessary by the Department of Public Works. (2) Normal maintenance and improvement of land for the primary purpose of agriculture, horticulture, floriculture, or viticulture, or the use, expansion, 2 or reconstruction of existing structures for the primary purpose of agriculture, horticulture, floriculture, or viticulture,to the extent protected under the Zoning Act,M.G.L Chapter 40A, Section 3. (3) Normal maintenance of landscaping, gardens, or lawn areas. (4) Reclamation and replacement of lawfully located, existing pavement at single-family or two-family residences, as well as reclamation and replacement of lawfully located, existing pavement at any parking lot containing fewer than 10 spaces. (5) Overlaying of existing pavement, with no increase in impervious area. (6) Construction of a fence or wall that does not alter the existing terrain or drainage patterns. (7) Emergency activities necessary for the protection of the health and safety of the public, provided that(a) the work is to be performed by or has been ordered by an agency of the Commonwealth of Massachusetts or a political subdivision thereof, (b) advance notice, oral or written, has been given to the Department of Public Works prior to commencement of work or within 24 hours after commencement, (c) the Department of Public Works or its duly authorized designee certifies the work as an emergency activity, and (d) the work is performed only for the time and place ' certified by the Department of Public Works for the limited purposes necessary to abate the emergency. (8) Maintenance, repair or replacement of an existing and lawfully located structure or facility used in the service of the public to provide electric, gas, water, telephone, telegraph or other telecommunication services, provided that (a) there is no alteration in the terrain, ground cover or drainage patterns; and (b) written notice has been given to the Department of Public Works prior to commencement of work. (9) Maintenance, repair or replacement of existing drainage infrastructure, provided that(a) there is no alteration of the existing terrain or drainage patterns; (b) there is no increase in the size or capacity of the pipe; (c) there is no change in the drainage area contributing to the pipe; and (d) best practical measures are utilized to avoid any negative impacts on stormwater quality or runoff rate or volume. (10) Operation and maintenance of stormwater Best Management Practices, in accordance with an approved Operations and Maintenance Plan. (11) Normal maintenance of Town-owned public land, right-of-ways, public utilities, and appurtenances, including roadway reconstruction. 3 (D) Simplified Permit The Department of Public Works shall have the authority to develop a Simplified Permit for specific types of projects. (1) The purpose of the Simplified Permit is to streamline the permitting process under this Ordinance by waiving certain submission requirements,provided a set of predetermined design standards are met. (2) The predetermined design standards shall be outlined in the Rules and Regulations authorized in accordance with Section 3.3 of this Ordinance. (3) By meeting the predetermined requirements and performance standards, the proposed project will be presumed to meet the requirements and intent of this Ordinance. (E) Compatibility with Other Permit and Ordinance Requirements This Ordinance is not intended to interfere with, abrogate, or annul any other Ordinance, Rule or Regulation, Statute, or other provision of law in whole or in part. The requirements of this Ordinance should be considered minimum requirements, and where any provision of this Ordinance imposes restrictions different from those imposed by any other Ordinance, Rule or Regulation, Statute or other provision of law, whichever provisions are more restrictive or impose higher protective standards for human health or the environment shall be considered to take precedence. §98.02 DEFINITIONS Alter or Alteration: Any activity, which will change the ability of a ground surface to absorb water or will change existing surface drainage patterns. Alter may also be referred to as "alteration of drainage characteristics," and "conducting land disturbance activities." Applicant: Any person, as defined in this Ordinance, who has filed an application for a Stormwater Management and Erosion Control Permit. Best Management Practice (BMP): A structural or nonstructural technique for managing stormwater to prevent or reduce nonpoint source pollutants from entering surface waters or ground waters. A structural stormwater Best Management Practice includes a basin, discharge outlet, swale,rain garden, filter, or other stormwater treatment practice or measure either alone or in combination, including without limitation any overflow pipe, conduit, weir control structure that: (a) is not naturally occurring; (b) is not designed as a wetland replication area; and (c)has been designed, constructed, and installed for the purpose of conveying, collecting, storing, discharging, recharging, or treating stormwater. Nonstructural stormwater Best Management Practices include source control and pollution prevention measures. 4 Conveyance: Any structure or device, including pipes,drains,culverts, curb breaks, paved swales and man-made swales, natural and man-made channels, and ditches designed or utilized to move or direct stormwater runoff or existing water flow; any impervious surface/sheet flow utilized to remove rainfall (for example, a parking lot) which drains directly onto a vegetated surface or public road without any curbing or drainage system to intercept the flow. Erosion Control: The prevention or reduction of the movement of soil particles or rock fragments due to stormwater runoff. Impervious Surface or Area: Any material or structure on or above the ground that prevents water from infiltrating through the underlying soil. Impervious surface is defined to include, without limitation: paved surfaces (parking lots, sidewalks, driveways, etc.), roof tops, swimming pools, and patios, as well as paved, gravel, and compacted dirt surfaced roads. Infiltration: Percolation of water into the subsurface. Also referred to as"Recharge." Land Disturbance Activity: Any activity that causes a change in the position or location of soil, sand, rock, gravel, or similar earth material. Low Impact Development (LID): A site design strategy for managing stormwater by maintaining or replicating the predevelopment hydrologic functions through the use of design techniques to create a functionally equivalent hydrologic landscape. Maintenance: Maintenance of a stormwater management system means the work necessary to keep a stormwater management system fimctional and in good repair so that it may continue to operate as originally designed. Maintenance of a stormwater management system does not include work that(a)reduces the capacity of the system to treat stormwater, provide recharge, or attenuate peak flow; (b) increases the total or peak rate or volume of the stormwater managed by the system; (c) directs additional stormwater discharges to the system; or(d) results in reduced use of above ground stormwater Best Management Practices. Massachusetts Stormwater Management Standards: The Standards issued by the Massachusetts Department of Environmental Protection(DEP), codified in regulations at 310 CMR 10.05(6)(k)-(q) and further defined and specified in the Massachusetts Stormwater Handbook, Volumes 1 through 3, issued by the DEP. The Standards address stormwater impacts through implementation of performance standards that reduce or prevent pollutants from reaching water bodies and control the quantity of runoff from a site. Municipal Senarate Storm Sewer System (MS4): The system of conveyances designed or used for collecting or conveying stormwater, including any road with a drainage system, street, gutter, curb, inlet,piped storm drain,pumping facility, retention or detention basin, natural or man-made or altered drainage channel, reservoir,and other drainage structures 5 that together comprise the storm drainage system owned or operated by the Town of Watertown. Oneration and Maintenance Plan: A plan setting up the functional, financial, and organizational mechanisms for the ongoing operation and maintenance of a stormwater management system to ensure that it continues to function as designed. Overlay of Pavement: The placement of pavement on top of an existing impervious surface. The underlying surface is sometimes milled (partially ground down in thickness) before the overlay is placed. Owner: A person with a legal or equitable interest in land, structures, or equipment. Permittee: The person who is issued a permit by the Watertown Department of Public Works pursuant to this Ordinance. Person: An individual, partnership, association, firm, company, trust, corporation, agency, authority, department, or political subdivision of the Commonwealth or the federal government, to the extent permitted by law, and any officer, employee, or agent of such person. Pollutant: Any substance, either man-made or man-induced,that alters the chemical, physical, biological, or radiological integrity of water. Reclamation of Pavement: A procedure whereby existing pavement is broken and pounded into small fragments. Redevelopment: Development, replacement, rehabilitation, expansion, demolition, or phased projects that disturb the ground surface on previously developed sites. Sediment: Mineral or organic soil material that is transported by wind or water from its origin to another location; the product of erosion processes. Sedimentation: The process or act of depositing sediment. Simnlifted Permit: A permit issued for an application that meets a set of predetermined standards adopted by the Department of Public Works in accordance with Section 98.01(B) of this Ordinance. Stormwater Manaeement and Erosion Control Permit: A permit issued by the Department of Public Works, after review of an application,plans, calculations, and other supporting documents, in accordance with the provisions of this Ordinance. Stormwater Manaeement Plan: A plan submitted as part of an application for a 6 Stormwater Management and Erosion Control Permit, as required by Section 98.04(A) of this Ordinance. Stormwater Management Svstem: the collective system for conveying, collecting, storing, discharging, recharging, or treating stormwater on-site, including stormwater Best Management Practices and any pipes and outlets intended to transport and discharge stormwater to the groundwater, a surface water, or a municipal separate storm sewer system. Also referred to as "drainage." Stormwater Runoff: Flow over the ground surface resulting from precipitation or snow and ice melt or through a drainage system. §98.03 AUTHORITY AND ADMINISTRATION (A) Authority This Ordinance is adopted under authority granted by the Home Rule Amendment of the Massachusetts Constitution, and the Home Rule Statutes and pursuant to the regulations of the federal Clean Water Act found at 40 CFR 122.34. (B) Administration The Watertown Department of Public Works shall administer, implement, and enforce this Ordinance. Any powers granted to or duties imposed upon the Department of Public Works may be delegated to the Department's employees or agents. (C) Rules and Regulations The Town Manager may adopt, and periodically amend, Rules and Regulations relating to the detailed requirements, procedures, and administration of this Ordinance, including application and inspection fees. Failure by the Town Manager to promulgate such Rules and Regulations, or a declaration of their invalidity by a court of law, shall not have the effect of suspending or invalidating the provisions of this Ordinance or any permit issued hereunder. Such Rules and Regulations (or amendments thereto) shall become effective five days after being filed with the Town Clerk. (D) Appeals A decision of the Department of Public Works shall be final. A request for relief of a decision of the Department of Public Works shall be reviewable in the Superior Court in an action filed within 60 days thereof. §98.04 PERMIT PROCEDURES (A) Permit Required 7 No land disturbance activity that meets the criteria specified in Section 98.01(B) may commence prior to issuance of a Stormwater Management and Erosion Control Permit subject to this Ordinance. (B) Procedures and Requirements Permit procedures and requirements—including but not limited to application, fee schedules, actions, right-of-entry, Stormwater Management Plan contents, technical requirements, inspections, and project closeout—shall be included as part of the Rules and Regulations promulgated under Section 98.03(C) of this Ordinance. §98.05 PERFORMANCE STANDARDS Criteria for Stormwater Management and Erosion Control Performance Standards shall be defined and included as part of the Rules and Regulations promulgated under Section 3.3 of this Ordinance. §98.06 ENFORCEMENT The Department of Public Works shall have authority to enforce this Ordinance and resulting Rules and Regulations, and shall issue orders,violation notices, and enforcement orders, and may pursue all available civil and criminal remedies for such violations. (A) Notices and Orders (1) The Department of Public Works may issue a written order to enforce the provisions of the Stormwater Management and Erosion Control Ordinance or the Rules and Regulations, which may include requirements to: (a) Cease and desist from construction or land disturbance activity until there is compliance with the Stormwater Management and Erosion Control Ordinance and the Stormwater Management and Erosion Control Permit; (b) Repair, maintain, or replace the stormwater management system or portions thereof in accordance with the approved Operation and Maintenance Plan; (c) Perform monitoring, analyses, and reporting; and/or (d) Remediate adverse impacts resulting directly or indirectly from malfunction of the stormwater management system. (2) If the Department of Public Works determines that abatement or remediation of adverse impacts is required,the order shall set forth a deadline by which such abatement or remediation must be completed. 8 (3) If a person violates the provisions of this Ordinance, regulations, permit, notice, or order issued thereunder, the Department of Public Works may seek injunctive relief in a court of competent jurisdiction restraining the person from activities which would create further violations or compelling the person to perform abatement or remediation of the violation. (B) Penalties Pursuant to Section 10.99 of the Town Code, any person who violates any provision of the Stormwater Management and Erosion Control Ordinance, or order or permit issued thereunder, may be ordered to correct the violation and/or shall be punished by a fine of not more than$300.00 per violation, excluding the cost of damages. Each day or part thereof that such violation occurs or continues shall constitute a separate violation. (C) Non-Criminal Disposition As an alternative to criminal prosecution, the Department of Public Works may elect to utilize the non-criminal disposition procedure set forth in M.G.L. c. 40, § 21D, which has been adopted by the Town in § 35.05 of the Town Code, for which purpose the Director of the Department of Public Works and the Department's employees shall be enforcing persons. The specific penalties under this provision shall be (a) $25 for the first offense, (b) $50 for the second offense, and (c) $100 for the third and any subsequent offense. Notwithstanding the foregoing, the enforcing person shall have the discretion to issue a warning in lieu of the citation for$25 for the first offense. (D) Appeals The decisions or orders of the Department of Public Works shall be final. Further relief shall be to a court of competent jurisdiction. (E) Remedies Not Exclusive The remedies listed in this Ordinance are not exclusive of any other remedies available under any applicable federal, state, or local law. §98.07 SEVERABILITY Any finding of the invalidity of any section, provision, paragraph, sentence, or clause of this Ordinance shall not invalidate any other section, provision, sentence, or clause thereof,nor shall it invalidate any permit or determination that has been previously issued under this Ordinance. AND FURTHER BE IT ORDAINED that the Watertown Code of Ordinances, Title IX, Chapter 97, is hereby amended by changing the title of said Chapter 97 from"Stormwater Regulations"to "Regulation of Discharges to the Municipal Storm Sewer System". 9 Council Member I hereby certify that at a regular meeting of the Town Council for which a quorum was present, the above Ordinance was adopted by a roll call vote of_for, against, present on February 23, 2016. Marilyn W. Pronovost, Council Clerk Mark S. Sideris, Council President 10 Excerpt from October 13, 2015 Town Council Minutes b) Committee on Public Works report on a Stormwater ordinance—Cecilia Lenk, Chair. Councilor Leak read the Committee report. Councilor Woodland moved to accept the report, seconded by Councilor Dushku and adopted by unanimous voice vote with Councilors Aaron Dushku, Susan G. Falkoff, Anthony Palomba, Angeline B. Kounelis, Cecilia Lenk, Vincent J. Piccirilli, Jr., Kenneth M. Woodland, Vice President Stephen P. Corbett, and Council President Mark S. Sideris voting in the affirmative. The Chair stated that the Stormwater ordinance will need a publication and first reading prior to a public hearing and vote. The Committee on Public Works Monday, September 28 at 5:00 PM Town Council Chambers The Committee met to discuss"the Stormwater Management and Erosion Control ordinance and related data." Attending the meeting were Councilor Lenk, Chair,Councilor Corbett,Vice Chair,Councilor Palomba, Secretary,Town Council President Sideris,Councilor Piccirilli, Councilor Falkoff, DPW Director Gerry Mee, Matt Shuman,Town Engineer/DPW, Dennis Sheehan, Director of Finance and Administration/DPW,Tree Warden Chris Haywood,Stormwater Advisory Committee(SAC) members Ernesta Kraczkiewicz, Nancy Hammett,and David Stokes,representatives from SDE, Inc. Garrett Bersey and Stacey DePasquale, representatives from Stantec John Murpy and Robert Dunn, and a representative from the Concerned Citizens Group Lisa Feltner. SAC member Ernesta Kraczkiewicz made an opening statement(attached)that outlined the negative effects of stormwater on the Charles River,the new Green Infrastructure approach to stormwater management,and the need for the proposed ordinance to meet the requirements of the Town's National Pollution Discharge Elimination System (NPDES) permit from the Environmental Protection Agency(EPA). She also provided the Committee a history of the proposed ordinance noting that it is the result of combining two ordinances, the Erosion and Sedimentation Control Ordinance and the Post Construction Stormwater Runoff Ordinance, previously written by SAC and that it benefitted greatly from the expertise of Watertown Town Engineer Matt Schuman. She note that the major change in the proposed ordinance is the removal of the provision on administration, performance standards and enforcement which would be put into a Rules and Regulations document. This would allow for modification of the ordinance when there were changes in standards of practice or federal or state requirements. Mr.Shuman presented an informative power point presentation (attached) about stormwater, its effects on the environment,the challenges faced by Watertown to manage stormwater,and the existing DPW stormwater-related policies and procedures. Councilor Palomba raised a concern about the potential of the ordinance being amended without Town Council approval if the Rules and Regulations,which include the enforcement and performance standards, could be changed at any time. He was assured that changes in the Rules and Regulations would be published in a timely fashion and available for review by the Town Council. Councilor Corbett made the following motion: The Public Works Committee recommends that the Town Council approve the proposed Stormwater Ordinance. The motion was seconded by Councilor Lenk and passed 3-0. Note:These minutes reflect one portion of the meeting and were submitted by Councilor Palomba STORMWATER MANAGEMENT AND EROSION CONTROL ORDINANCE PRESENTATION TO PUBLIC WORKS COMMITTEE Presented by Ernesta Kraczkiewicz on behalf of the Stormwater Advisory Committee What is Stormwater and why do we need a Stormwater Management and Erosion Control Ordinance? Stormwater is by far the greatest remaining source of pollution in the Charles River,as it is in many water bodies;as the Charles River is a key asset to our community, I think we all agree that we need to reduce the damage to the River and the local ponds caused by stormwater pollution.This is a major challenge for heavily built up areas like Watertown; EPA estimates that 49%of Watertown's land area is impervious. Because of this,water from rain storms and snow melt washes over our rooftops,streets and parking lots,taking chemicals, pet wastes, and a wide variety of pollutants, unfiltered and untreated,straight into the river and ponds. We now know that the previous practice of sending Stormwater into drains and straight to the river was short-sighted. The new Green Infrastructure approach to stormwater management works to reverse these effects and emphasizes "keeping rainwater local;" because it soaks into the ground, water gets filtered and cleaned as it moves through the soil.These natural systems can be less expensive than constructing hard infrastructure,and they reduce pollution,flooding and erosion. We have an important opportunity to use these approaches when new development or redevelopment occurs. During construction and reconstruction,there are cost effective methods to design sites in ways that improve stormwater management;various approaches can be used effectively,depending on conditions at the site. With this in mind,the proposed Ordinance requires property owners to retain all Stormwater runoff on-site to the maximum extent practicable when development or redevelopment occurs. The Town has been pursuing these policies for some time now but it has not been formalized in writing; it is important to do so to provide clarity and certainty. We need this Ordinance also because under the Town's NPDES permit from EPA,the Town is required to have enacted Ordinances governing erosion control during construction, and management of stormwater post-construction on sites being.developed or redeveloped (as well as Prohibition of Illicit Discharges to the Storm Drainage System,which the Town enacted in 2011). How did we aet to this point?(Previous stormwater Ordinances, and Ordinance update process) As you probably know we previously submitted two ordinances,the Erosion and Sedimentation Control Ordinance and the Post Construction Stormwater Runoff Ordinance,to the Town Council;these were reviewed by the Public Works Committee in the fall of 2013. They were then sent to the Town Lawyers who made some comments,which the SAC found agreeable. However, by that time the Town was in the midst of the hiring process for our Town Engineer and we felt it was worthwhile to wait the short additional time to allow input from the Town Engineer,who would be very involved in the administration of these ordinances. That hiring process turned out to be much longer than we anticipated; but it was indeed a good idea to wait until Matt Shuman appeared on the scene,as he came with some new perspectives, based on extensive experience. The committee,following his lead, deliberated on a number of questions,such as various performance standards,and looked into the coordination of the stormwater permit review process with the planning,zoning,and wetlands reviews. A subcommittee of the SAC composed of Matt, Nancy Hammett and Steve Magoon had meetings with the Mass. DEP Stormwater Director,and the stormwater staff of a number of our neighboring towns: Belmont,Cambridge, and Newton....to get feedback on their past experiences with different ordinance options. Matt will be giving you a much more detailed description of what came out of all these discussions,and resulted in what is now before you. But the most major changes are that: 1) there is now just one Ordinance combining the provisions of the two previous ones;this makes sense,as the two had a great deal of overlap making it difficult to ensure no conflicts or gaps. 2) the detailed provisions on administration,performance standards and enforcement which were included in the previously proposed ordinances have been removed to be put instead into a Rules and Regulations document,which can be promulgated by DPW. This is a much preferable option;it will provide the public with additional technical details and design standards that are beyond the scope of the enabling Ordinance. Also, because the Rules and Regulations can be modified more easily than an Ordinance, it can adapt better to changes in standards of practice or federal or state requirements.And some of these detailed requirements may need tweaking over time with experience;for instance, in the time allowed for DPW review of applications. If these requirements remain in the Ordinance rather than a Rules and Regulations document, then any tiny change would necessitate full review and approval by the Town Council once again. Finally,this proposed Ordinance has already been submitted to the Town lawyers for their review, as opposed to waiting until after your review as was done in the past. The lawyers' comments have been incorporated into this draft. F_ � Z f r. Y 3 1 s e [ tlz I�r _ 5 W-WS �F�'t.+Y }f � F O _ • µ�x� ® r C6. v cL c.n rt _ a r —013 Ai WE c A a� ����$r���ems*t��f#� *�•� } �� � . .:: x},E^ 1� sc 15, a r6 7-1 "a mom 42 p c(6 ., Ll.: ,; 01 -iR ,RPE 4�AD u vell�. 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