The purpose of this letter is to express some of the public’s concerns as they relate to the stormwater management plan and other aspects of the proposed Maine Housing Authority, Knox County Homeless Coalition and Mid-Coast Habitat for Humanity experimental Firefly Field Subdivision located off Talbot Avenue in Rockland.

Concerning the peer review of the stormwater management plan by Wright-Pierce Consulting Engineers of Topsham, and a review of the report prepared by Landmark Engineers of Rockport as it pertains to stormwater management. The Grassed Underdrained Soil Filter or GUSF in the Wright-Pierce peer report appears to be the installation of an on-site stormwater retention pond or basin system for controlling the rate of the release of stormwater both during and after a storm event.

The problem is that over time they may potentially fail for one or more of the following reasons: the size and capacity are under-designed; lack of maintenance and annual cleaning; and the lack of experience by maintenance persons, owners, or managers in maintaining, repairing, replacing and properly cleaning retention ponds and theirappurtenances.

Regarding the rain gardens proposed as part of the stormwater management plan for the project, I have worked as a professional gardener for ten years, as well as maintaining the gardens at Rockland's Central Park as a volunteer for 12 years.

In doing so, I would like to state that the rain gardens need a maintenance plan and regular care to succeed, and not to be overwhelmed by invasive, nonnative plants.

I see no such plan in the documents Landmark has presented. As with retention ponds or basins, rain gardens and pervious pavement are subject to underperformance or failure if they are not properly maintained, cleaned out, repaired or replaced when damaged or reaching their life expectancy.

For this reason the Inspection and Maintenance Plan should specifically name who is responsible for the maintenance of the stormwater management system and list their experiences. In order to ensure proper maintenance the Planning Board should require the filing or submission of an escrow account with the City to ensure proper maintenance if the owners fail to do so. 

Next, a copy of the Landmark engineering report for the subdivision was also reviewed.

The engineering report does not contain a stormwater management maintenance agreement. A Maintenance Agreement is a legal entity that establishes as to who is responsible for inspecting and maintaining the stormwater system.

Presently, Habitat owns the property as well as any buildings to be constructed, and the rental homes will be managed by the Knox County Homeless Coalition, but will their ownership eventually be turned over to the Coalition as well? Nor does the report list the Coalition’s experience as rental property managers.

In summary, the Wright-Pierce peer review was not complete as it did not list the reasons as to why the stormwater management plan will fail if not properly maintained and who should be responsible for its maintenance.

Susan Beebe lives in Rockland