HomeMy WebLinkAbout260402_3rd_SWPeerReview_Zero_Prescott - Horsley Witten - Consultant Review - 0 Prescott Street 4/2/2026
April 2, 2026
Ms. Jean Enright, Planning Director
Planning Department
Town of North Andover
120 Main Street
North Andover, Massachusetts 01845
Re: ThirdTechnical Peer Review–Comprehensive Permit Application
Zero PrescottStreet
North Andover, Massachusetts
Dear Ms. Enright and Board Members:
The Horsley Witten Group, Inc. (HW) is pleased to provide the North Andover ZoningBoardof
Appeals (ZBA) with this report summarizing ourthirdreview of theComprehensivePermit
Applicationfor Zero PrescottStreet.The plans and calculations were prepared by Civil Design
Group, LLC, dated October 2025, revised March2026, on behalf of RCG,LLC (Applicant).The
project proposes to replace the existing garage at 10 Prescott Street with two new buildings
housing 296 rental units and a multi-story parking garage on a 6.13-acre parcel.The Applicant
is proposing catch basins, hydrodynamic separators, and a subsurface infiltration system to
capture and mitigate the stormwater from the proposedincrease inimpervious areas.
The project is located within the Downtown Overlay Historic Mill Area:Subdistrict A with
underlying zoning districts Industrial S (IS)and Residential 4(R4).The proposed improvements
do not appear to be withinthe 100-foot buffer zone of a wetland resource area therefore arenot
within the jurisdiction of the North Andover Conservation Commission.
The following additional documents and plans were receivedby HWin response to our second
review letter dated March 3, 2026:
Response to Comments letter, issued to Jean Enright, prepared by Civil Design Group,
LLC, dated April 1, 2026 (4 pages);
Grading & Drainage Plan, Avalon North Andover Mills, prepared by Civil Design Group,
LLC,revised throughJuly 28, 2021(2Sheets);
Comprehensive Permit, Site Development Plans, for Zero Prescott, Residential
Development,0 Prescott Street, North Andover, MA,prepared byCivil Design Group,
LLC,dated October 21, 2025, revised March 30, 2026 (2sheets), which includes:
o Grading &Drainage Plan5
o Photometric CalculationL3.0
horsleywitten.com
Town of North Andover
April 2,2026
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Stormwater Management Design Peer Review
HW offers the following comments concerning the stormwater management design as per the
Massachusetts Stormwater Handbook (MSH) dated February 2008, and the North Andover
Chapter 165 Stormwater Management and Erosion Control Bylaw (Bylaw), and the Chapter 250
Stormwater Management and Erosion Control regulations (Stormwater Regulations) adopted
June 21, 2022.
The following comments correlate to our secondpeer review letter dated March 3, 2026. Follow
up comments are provided in boldunderlinedfontwhere applicable.
1.Standard 1: No new stormwater conveyances (e.g., outfalls) may discharge untreated
stormwater directly to or cause erosion in wetlands or waters of the Commonwealth.
a.The Applicant has analyzed the pre-and post-development stormwater runoff to four
pointsof analysis(POA).
(1)POA-1 is an existing 18-inch culvert that carries stormwater from the existing
garage roof and a portion of the existing parking lot (EX-1) under the western
driveway and discharges into the existing municipal drainage system in High Street
(POA-2). The culvert will remain under proposed conditions.The proposed
catchment area (PR-1) is reduced significantly from the existing catchment area
because it does not include the proposed building.
March 3, 2026: No further action is requested.
(2)POA-2 is the existing municipal drainage system in High Street. The stormwater
from a large portion of the existing and proposed site is directed into the municipal
system(EX-2).Under proposed conditions a portion of the development is directed
towards a subsurface chamber system (SIS-1) and a portion of the building is
piped directly towards the closed drainage system.The catchment areas directed
towards POA-2 include most of the proposed development.HW notesthat the
stormwater from a portion of the southern parking lot within EX-2 and PR-2
appears to flow offsite via the center driveway. It is not obvious how this runoff is
directed into the drainage system defined by POA-2.
March 3,2026: The Applicant has clarifiedthat the proposed contourswill
redirect flow in the drainage system defined by POA-2.The runoff from the
area will flow down the center driveway and then in the westerlydirection
towardsHigh Street. No further action is requested.
(3)POA-3 is the portion of the project area onthe east side of the site that flows
towards the east and the adjacent Meadow View Condominium property(EX-3).
Under proposed conditionsthis area is reduced slightly(PR-3).
March 3, 2026: No further action is requested.
(4)POA-4 is the portion of the project area that flows southeast onto the southern
parking lot(EX-4).Under proposed conditions this catchment area is reduced
slightly (PR-4). HW notes that the narrative and Figure 3 describeEX-4as
consisting of 0.24 acres. However, it is approximately 0.39 acres as listedin the
HydroCAD model.HW further notes that it appears that the western side of EX-4
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and PR-4 flows towards an 18-inch corrugated metal pipe (CMP)that is directed
into EX-1 and PR-1. HW recommends that the Applicant revisit the catchment
areas to POA-4under existing and proposed conditions.
March 3, 2026: The Applicant has revised the EX-4 and PR-4 subcatchment
areas. No further action is requested.
b.Theclosest resource area is Mill Pond to the southeast of the project area. The
proposed development is greater than 100 feet from this pond. HW recommends that the
Applicant clarify where the closed drainage system modeled as POA-2 discharges to.
HW further recommends that the Applicant confirm that the final discharge point is not
currently causing erosion in wetlands or waters of the Commonwealth.
March 3,2026: The Applicant has clarifiedthat the closed drainage system
modeled as POA-2 travels south down High Street and connects into the large
culvert that conveys runoff to West Mill Ponds. No further action is requested.
2.Standard 2: Stormwater management systems shall be designed so that post-
development peak discharge rates do not exceed pre-development peak discharge rates.
a.The Applicant has included a Peak Flow Rate ComparisonTable in Section 7.0of the
Stormwater Management Narrative. ThePost-developmentpeak flows do not exceed
the pre-developmentvalues. HW recommends that the Applicant update the Table,if
applicable,after responding to the other comments in this letter.
March 3,2026: The Applicant has updated the Tableas suggested. No further
action is requested.
b.Per §250-22 B. (5)(b) and §250-23 A. (1) of the North Andover Stormwater Regulations,
Low-Impact development (LID) site planning and design strategies must be implemented
to the maximum extent feasible. The Applicant has incorporated onesubsurface
infiltration chambersystemas an LID technique. HW recommends that the Applicant
document other LID options it considered withinthe Project Area.
March 3,2026: The Applicant has stated that theLID measures utilized include
reusing the existing swale to capture and convey runoff and matchingthe existing
impervious area in the proposed condition.The Applicant is also maintaining
most of the wooded area on the north side of the building.
c.In accordance with §250-22 B. (5)(c),HW recommends that the Applicant identify the
watershed basin and the downgradient water body that stormwater from the project site
discharges into.
March 3,2026: The Applicant has stated that the watershed basin associated with
this site is the Merrimack River. Runoff from this site drains in a westerly direction
to Osgood Pond behind the West Mill Campus. Runoffthen continues to Sutton
Pond and eventually into the Merrimack River. No further action is requested.
d.In accordance with §250-22 C. (4)(c),HW recommends that the Applicant delineate any
existing or proposed slopes between 15% and 25% and over 25%.
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March 3, 2026: The Applicant has stated that the existing and proposed developed
portions of the site are less than 5% and the sloped area to the rear is less than
10%. The 3:1 side slope of the existing swale willremain. No further action is
requested.
e.In accordance with §250-22 C. (4)(g),HW recommends that the Applicant call out any
significant or unique trees or tree clusters.
March 3, 2026: The Applicant has requested a waiver from the local Stormwater
Bylaw. During the ZBA hearing on February 25, 2026, the Applicant stated that it
will be removing approximately 0.5 acres of trees.The HydroCAD model indicates
that there are approximately 1.22 acres of woods under pre-development
conditions and 1.85 acres of grass cover. Under post-development conditions the
Applicant has modeled 2.34 acres of grass and 0.70 acres of woods. HW defers
the granting of this waiver to the ZBA.
April 2, 2026: Waiver requested.
f.In accordance with §250-22 C. (5)(b),HW recommends that the Applicant includes
profiles of the drainage truck lines.
March 3, 2026: The Applicant has requested a waiver from the local Stormwater
Bylaw. The Applicant has not included profiles of the drainage truck lines,butit
hasreviewed thepotential conflictswith other utilities. HW defers the granting of
this waiver to the ZBA.
April 2, 2026: Waiver requested.
g.In accordance with §250-22 D. (1 and 4),the calculations provided should include peak
flow rates and volumes. HW has confirmed that the peak volumes have been reduced
over existing conditions. However, werecommend that the Applicant includesa table
with the pre-and post-peak volumes of stormwater runofffor documentation purposes.
March 3, 2026: The Applicant has added a volume mitigation table to the
Stormwater Reportas suggested. The peak stormwater volume will decrease at
each point of analysis. No further action is requested.
h.HW notes that the Applicant has used a direct entry of 6 minutes for the times of
concentration (Tc) values for all Pre-development and Post-development catchment
areas.HW recommends that the Applicant revisit the Tc values for catchment areas EX-
2 and PR-2in accordance with §250-23 E. (18)and provide the flow paths on Figures 3
and 4.
March 3, 2026: The Applicant has revised the Tc values in the HydroCAD model
andadded the flow pathtothe planas suggested. No further action is requested.
i.In accordance with §250-23 E. (19),the Applicant must utilize the 24-hour rainfall data
taken from National Oceanic and Atmospheric Administration (NOAA) Atlas 14 for the
rainfall precipitation depths. The Applicanthas used theNortheast Regional Climate
Center(NRCC)values,which are similar.
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YearNRCCValuesNOAA Atlas 14 Values
2-year3.15 inches3.15 inches
10-year4.83 inches5.00 inches
25-year6.16 inches6.15 inches
100-year8.94 inches7.93 inches
March 3, 2026: No further action is requested.
j.In accordance with §250-23 E. (22),HW recommends that the Applicant providespipe
sizing calculationsusing Mannings Equation and confirmsthat the drainage pipes can
accommodate a 25-year storm event.
March 3, 2026: The Applicant has requested a waiver from the local Stormwater
Bylaw. The Applicant has stated that the drainage connection in High Street
consistsof 12-inchpipesand increasing the pipe sizes based on onsite pipe
capacity would be ineffective. The Applicant has stated that itwill continue its
conversation with the Department of Public Works(DPW) regarding the regional
flood management study and to explore alternatives to maximize runoff
conveyance through the campus. HW recommends that the ZBA request updates
on the conversations between the Applicant and the DPW.
April 2, 2026: The Applicant has stated that it has been coordinating with the
North Andover DPW. It has proposed an alternative drainage plan that includes
the installation of an 18-inch pipe crossing High Street at the end of Prescott
Street from proposed DMH-6. The 18-inch pipe will discharge stormwater via an
existing 18-inch drain line that increases to a 36-inch drain lineat DMH-3D on the
AVB West Mill property andthen crosses through the AVB West Mill property.The
18-inch pipe directed west from DMH-6is 1.65 feet lower than the 12-inch pipe
directed south, therefore able to redirectmost of the stormwater from the
proposed development.An 18-inch pipe with a slope of 3%can manage
approximately 18 cfs.It appears that the alternative design will redirect the
proposed building and patio area from storm events up to and including a 25-year
event.HW agrees that the alternative design will reduce the peak flows and
volumesdirected towards the High Street municipal system. HW recommends that
the ZBA confirm that the DPW is in agreement with the alternative design plan.
k.HW notes that the existing pipe configuration at the intersection with High Street and the
driveway access drive is confusing. HW requests that the Applicant clarify how the
various catch basins and manholes are connected. Furthermore, the Applicant is
connecting anew18-inch drainpipeto the existing drainage system at an existing catch
basin, it is not clear the size of the existing drainpipes and if the existing system can
manage the proposed runoff.HW recommends that the Applicant providesadditional
documentation on the existing drainpipes.If feasible,HW recommends that the
Applicant tie into the existing system at a manhole.
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March 3, 2026: The Applicant has reducedthe proposed 18-inchpipe to a 12-inch
pipe. Since the watershed to the swale has been reduced by 2 acres, the existing
18-inchpipe is oversized as compared to the contributing flow. The discharge to
the municipal stormwater system should be part of the ongoing discussions with
the DPW.
April 2, 2026: The Applicant has been in discussions with the DPW. No further
action is requested.
l.In accordance with §250-23 E. (30),all drainpipes are to be reinforced concrete pipe
(RCP)with a minimum diameter of 12 inches.HW notes that the Applicant is proposing
high-density polyethylene (HDPE) pipes.
March 3, 2026: The Applicant has requested a waiver from the local Stormwater
Bylaw. HW notes that HDPE pipes are frequently used in Massachusetts
municipalities.HW defers the granting of this waiver to the ZBA.
April 2, 2026: Waiver requested.
3.Standard 3 requires that the annual recharge from post-development shall approximate
annual recharge from pre-development conditions.
a.The Applicant has provided a Natural Resources Conservation Service (NRCS) Soils
map which documented that the soils on site are classified as Urban Land and
Woodbridge. The Applicant conductedsoil test pits within the footprint of the infiltration
system to confirm the Estimated Seasonal High Ground Water (ESHGW)and the
exfiltration rate used in the HydroCAD model.The soil in the test holes was listed as
sand and the Applicant has used an exfiltration rate of 2.41 inches per hour (iph) in the
HydroCAD model. HW finds the exfiltration rate to be reasonable.
March 3, 2026: No further action is requested.
b.HW notes that bottom of the infiltration system is set at elevation 95.0 and the ESHGW
in test pit T-1indicates thatESHGW is at approximately elevation 91.0 providing the
required four feet of separation.No further action is requested.
March 3, 2026: No further action is requested.
c.The Applicant has provided drawdown calculations in Section 9.0 of the Stormwater
Management Narrative.HW notes that the Applicant has stated that the increase in
impervious area is approximately 0.03+acres. The HydroCAD calculations indicate the
increase is 0.041 acres. HW could notconfirm the volume of stormwater being retained
in the subsurface infiltration system with the information provided. HW recommends that
the Applicant provide the stage storage area printout from the HydroCAD model for
confirmation.
March 3, 2026: The Applicant has provided the subsurface infiltration system
stage storage table. There is a 0.04 acre increase in impervious area, requiring 50
CF of storage, the Applicant has demonstrated that approximately 588 CF of
storage is provided,exceedingthe requirement. No further action is requested.
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4.Standard 4 requires that the stormwater system be designed to remove 80% Total
Suspended Solids (TSS) and to treat 1-inch of volume from the impervious area for water
quality.
a.The Applicant has provided waterquality calculationsto confirm that the treatment trains
exceed the 80% TSS removal requirement per the MSHand §250-23 C. (1) of the North
Andover Stormwater Regulations.HW recommends that the Applicant provides
documentation confirming the TSS removal provided by the proposed proprietary
devices.HW notes that the Applicant has provided a detail of a Hydroworks HS4.
However, we could not locate where this device is proposed.
March 3, 2026: The Applicant has clarified the location of the water qualityunitin
front of the garage portion of the buildingat drain manhole (DMH)9and provided
documentation confirming the TSS removal provided. HW recommends that a
second water quality unit be provided for the closed drainage system on the east
side of the parcel,possibly at DMH2.
April 2, 2026: The Applicant has provided a water quality unit to manage the
driveway runoff collected by the trench drain. No further action is requested.
b.In accordance with §250-23 B. (1)(b),HW recommends that the Applicant provides
calculations to verify that the proposed stormwater chamber systemscan captureand
retainthe volume of runoff generated by 1-inch times the increase in impervious area of
the site.HW could notconfirm the volume of stormwater retained with the
documentation provided.
March 3, 2026: The proposedinfiltration system will need to capture and retaina
minimum of149 CF of stormwater runoff generated from the 0.041 acres of
increased impervious area. The infiltration system is designed to retain588 CF of
stormwater runoff.No further action is requested.
c.HW recommends that the Applicant address the Phosphorous removal calculations in
accordance with §250-23 C. (1) of the North Andover Stormwater Regulations.
March 3, 2026: The proposed infiltration system is designed to capture the 1-inch
volume from the proposed increase in impervious area. No further action is
requested.
5.Standard 5 is related to projects with a Land Use of Higher Potential Pollutant Loads
(LUHPPL).
a.Theproposed projectis not considered a LUHPPL. Standard 5 is not applicable.
March 3, 2026: No further action is requested.
6.Standard 6 is related to projects with stormwater discharging into a critical area, a Zone II,
or an Interim Wellhead Protection Area of a public water supply.
a.The proposed development is not discharging near or into a critical area, Zone II or an
IWPA area. Standard 6 is not applicable.
March 3, 2026: No further action is requested.
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7.Standard 7 is related to projects considered Redevelopment.A redevelopment project is
required to meet the following Stormwater Management Standards only to the maximum
extent practicable: Standard 2, Standard 3, and the pretreatment and structural best
management practice requirements of Standards 4, 5, and 6. Existing stormwater
discharges shall comply with Standard 1 only to the maximum extent practicable. A
redevelopment project shall also comply with all other requirements of the Stormwater
Management Standards and improve existing conditions.
a.This project is considered a mix of new development and redevelopment. The Applicant
is required to comply with the new development standards for the increase in impervious
areas as described under Standards 3 and 4 above. The Applicant is required to meet
the standards for the remainder of the site to the maximum extent practicable and
improve existing conditions.HW recommends that the Applicant describe how it is
improving existing conditions.
March 3, 2026: The proposed development will improveexisting conditions by
reducing the impervious areaof the top-level parking deck and providing water
quality.The open garage parking area has been reduced from 2 acres to 0.60
acres. The infiltration system captures the 1-inch volume from the increased
impervious area.The proposed stormwater system will include measures to
improve water quality prior to discharging from the site.
8.Standard 8 requires a plan to control construction related impacts including erosion,
sedimentation, or other pollutant sources.
a.The Applicant has provided a Site Demolition & Erosion Control Plan. HW recommends
that the Applicant clarify the type of erosion control barrier proposed. The plans call for a
wattle, and the detail references a silt sock with a silt fence. It is HW’s opinion that the
silt sock with a silt fenceis the preferred method.
March 3, 2026: The Applicant has updated the planas suggested, a 12-inchsilt
sock with a silt fence is proposed. No further action is requested.
b.HW recommends that the Applicant includesa detail of the construction fence that is
proposed on the northern limit of work.
March 3, 2026: The Applicant has added a construction fence detailas suggested.
No further action is requested.
c.HW recommends that the Applicant includesinlet protectionin allexisting catch basins
within 100 feet ofthe construction entrance.
March 3, 2026: The Applicant has added a noteto include inlet protection in all
existing catch basins within 100 feet of the construction entrance.No further
action is requested.
d.The limit of disturbance will be greater than 1 acre therefore aConstruction General
Permit (CGP) and a Stormwater Pollution Prevention Plan (SWPPP) is required by EPA.
TheZBAmay choose to require a final signed SWPPP a minimum of 14 days prior to
land disturbance.
March 3, 2026: Suggested condition of approval.
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9.Standard 9 requires a Long-Term Operation and Maintenance (O & M) Plan to be
provided.
a.The Applicant has provided anOperation and Maintenance Planwithin the Stormwater
Management Report. The plan liststhe property ownerand site engineer. The ZBAmay
choose to require receipt of a signed O&M Plan prior to occupancy as a condition of
approval.
March 3, 2026: The Owner’s signature has been added to the O&M plan. The ZBA
may still choose to require receipt of the final O&M Plan as a condition of
approval.
b.The O&M Plan indicates that solid waste materials will be stored in dumpsters provided
on site. It is not obvious onthe Site Plan where the dumpsters are located.
March 3, 2026: The Applicant has stated that the dumpsters will be located inside
the garage building. The ZBA may choose to require this as a condition of
approval.
c.HW notes that the O&M Plan states that Pet Waste is not anticipated based on the
proposed use of the site. HW recommends that the Applicant clarify if dogs will be
prohibited from the residential units.
March 3, 2026: The Applicant has stated pets are not prohibited and that pet waste
baskets are to be provided. The Operation and Maintenance Plan has been
updated. The ZBA may choose to require this as a condition of approval.
d.Section 3 of the O&M Plan references yard drains. However,it is not clear how these
should be maintained.
March 3, 2026: The maintenance of the yard drains has been added to the O&M
Plan. No further action is requested.
e.The Applicant has noted that the Hydrodynamic Separator should be cleaned per the
manufacturer’s recommendation. HW recommends that the Applicant includes the
manufacturer’s recommendations with the O&M Plan.
March 3, 2026: The Applicant has added the manufacture’srecommendations to
the O&M plan. No further action is requested.
f.The Applicant has included a Quarterly Stormwater Inspection Report. HW recommends
that the Applicant include the catch basins,the yard drains, and the deep sump drain
manholesas part of this Report.
March 3, 2026: The Applicant has updatedthe Quarterly StormwaterInspection
Report as suggested. No further action is requested.
g.HW recommends that the Applicant includesthesnow storage locations on the Figure-1
BMP Location Plan.
March 3, 2026: The Applicant has included snow storage locations on Figure-1.
HW recommends that the Applicant include the snow storage location for the roof
deck of the proposed garage.
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April 2, 2026: The Applicant has noted that the snow on the roof deck will be
removed by hand and allowed to melt. HW assumes that there will be no
stockpiling of snow on the garage roof deck.
h.HW recommends that the Applicant providesthe O&M Plan as a standalone document
that can be provided to theproperty owner(s).
March 3, 2026: The O&M Plan is a standalone document and can be extracted from
the Stormwater Report as needed. No further action is requested.
10.Standard 10 requires an Illicit Discharge Compliance Statement be provided.
a.The Applicant has provided a signed Illicit Discharge Compliance statement.No further
action is requested.
March 3, 2026: No further action is requested.
Site Plan Review:
A multifamily dwelling unit having seven or more units is allowed by Special Permit by the
Planning Board in Subdistrict A.The Comprehensive Permit application proposes two new
buildings housing 296 rental units connected by a multi-story parking garage.HW has the
following comments regarding the site plans.
11.Parking:
a.There are 100 surface level parking spaces,in the south side yardof the proposed
building. The typical size is 9-feet wide by 18-feet long with a 25-foot-wide aisle. These
spaces are in the same location as the existing parking spaces. Two of the proposed
surface spaces will be striped as van accessible.
March 3, 2026: No further action is requested.
b.There are 77 parking spaces on the first floor of the garage, 10 are marked for electric
vehicles (EV), and three are marked as accessible. HW notes that the Applicant has
listed 79 spaces, we recommend that the Applicant clarify the number of spaces
provided on the first floor.
March 3, 2026: The Applicant has clarified that there is a total of 80 parking spaces
on the first floor, 41 spaces on Level 1 and 39 spaces on Level 1.5.Nine spaces
are designated for electric vehicles (EV), and three are designated as accessible
parking spaces, including one van-accessible space. No further action is
requested.
c.There are 80 parking spaces on the second, third, fourth and fifth floors of the garage,
22 on each floor are marked for EV for a total of 88 spaces on the four floors, and two
spaces are marked as accessible. The Applicant has noted on the Site Plan,Sheet 4,
that 9 accessible parking spaces are provided. HW notes that per 521 CMR 23.2.1,497
spaces require a minimum of nineaccessible spaces. We only counted sevenand
recommend that the Applicant revisit the number of spaces marked as accessible.
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March 3, 2026: The Applicant has updatedthe submission to depict seven
accessible parking spaces in the garage, twoadditional accessible spaces are
provided at surface level. There isa total of nine accessible parking spaces, two
spaces are designated as van accessible. No further action is requested.
d.The Applicant has proposed a total of 497 parking spaces, 7 of which are marked as
accessible, and 98 are marked for electric vehicles (19.7%). HW agrees that thetotal
number of spaces proposed complies with Section 195-8.4 of the North Andover Zoning
Code. HW recommends that the Applicant confirm the sizes of the parking spaces and
aisles inside the garage.
March 3, 2026: The Applicant has updated the parking layout to include typical
parking space and aisle dimensions in the garage. No further action is requested.
12.Grading:
a.On the northwest corner of the garage there is a walkway that provides the pedestrian
connection from the garage to Prescott Street. The proposed grading in this area directs
the runoff from thelargearea on the north side of the site over this walkway and along
the north side of the west wing. HW recommends that the Applicant review this corner
and confirm that ponding and/or icing in this area will not be an issue.
March 3, 2026: The walkway has been removed from the proposed project. No
further action is requested.
b.The Applicant appears to have graded the walkways to be ADA compliant. Note 5 of the
Grading & Drainage Notes on Sheet 1 states the maximum slopes allowed.
March 3, 2026: No further action is requested.
13.Retaining Walls:
a.Proposed Retaining Wall #1 is approximately 164feet long and is located on the north
side of the amenity space for Building 1.Sections of this wall are greater than 10 feet
high and the wall will need to be designedby a structural engineer.HW recommends
that the Applicant includesRetaining Wall #1 incross section C-C provided on Sheet
A5.01.
March 3, 2026: The Applicant has included Wall #1 in the sectionC-C as
suggested. No further action is requested.
b.Proposed Retaining Wall #2is approximately 114feetlong and is locatedon the
northwest side of the proposed building parallel to Prescott Street. The wall appears to
be less than 4 feet high. Because of the length of the wall,HW recommends that a
structural engineer be involved in the final design.HW recommends that the Applicant
include Wall #2 on cross section B-B provided on Sheet A5.00.
March 3, 2026: The Applicant has included Wall #2 in the sectionB-B as
suggested. No further action is requested.
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c.Proposed Retaining Wall #3is approximately 45 feet long and is located on the north
side of the proposed garage adjacent to the proposed walkway and approximately 5 feet
from the property boundary with 39 Prescott Street.The wall appears to be only 2 feet
high.HW recommends that the Applicant include Wall #3 on cross section F-F provided
on Sheet A5.02.
March 3, 2026: The Applicant has stated that Wall #3 has been removed from the
project. No further action is requested.
d.Proposed Retaining Wall #4 is approximately265 feet long and is located on the east
side of the parcelapproximately 5 feet from the property line. Sections of the wall are
between 6 and 10 feet high, though the portion of the wall that runs parallel tothe
property line is less than 3 feet high.
March 3, 2026: No further action is requested.
e.Proposed Retaining Wall #5 is approximately 112 feet long and located to the east of
Building 2, across the driveway from Wall #4. The entire wallappears to be only 1 foot
high.
March 3, 2026: No further action is requested.
f.HW recommends that the Applicant confirmsour description of the walls and documents
any modifications it makes.
March 3, 2026: No further action is requested.
14.Building Setbacks:
The Applicant has included a Zoning Information table on the Site Plan, Sheet 4.
a.In accordance with Section 195-18.12 of the North Andover Zoning Code, an application
for a proposed project located within Subdistrict A may either use the standards in the
underlying zoning district in their entirety, or those standards contained within Part 2 in
their entirety.The Applicant has listed the three zoning districts it resides in and the
zoning waivers requested per district. As a Comprehensive Permit is not required to fully
comply with the local zoning requirements the ZBA may choose to consider the intent of
Subdistrict A: Historic Mill Area and whether the proposed project is inline with the
originalintent.
March 3, 2026: Suggested discussion by the ZBA.
b.Building 1 is located 18.8 feet from the western property boundary along Prescott Street.
This appears to be the closest front yard setback. The Applicant has listed the front yard
setback as 20.2 feet and has requested a waiverfrom the 30-foot requirement in a
Residential 4(R4)zoning district.HW recommendsthat the Applicant confirmsthe
minimum provided front yard setback.
March 3, 2026: The Applicant has stated that the property is bisected by both the
R-4 and Industrial-S Districts on Prescott Street which serves as a front setback
for the Property. The Zoning Information Table on the Site Plan has been updated,
and the waiver list will also be updated. As discussed during the ZBA hearing, HW
recommends that the waiver list includesthe specific sections that the Applicant
is requesting a waiver for and not theblanket waiver requestcurrently provided.
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April 2, 2026: HW suggests that a waiver list be provided that includes the specific
sectionsof the bylaws that waivers are being requested for.
c.Building 1 is located 16.5 from the southeast corner of 39 Prescott Street.A four-foot-
high black metal picket fence is proposed along the property boundary. The existing
East MillGarage is located approximately 45 feet from this same corner. This appears to
be the closest point to a residential property.It would be beneficial for the Applicant to
add the adjacent buildings including the residential garages to the plan set.The
Applicant has requesteda waiver from the35-footside yard setbackrequired for anew
building in Subdistrict A when the Subdistrict Aline abuts a residential zoning district
located outside Subdistrict A.The Applicant is also requesting a waiver from the 30-foot
front yardsetback required in a R4district.
March 3, 2026: The Applicant has added a locus plan on Sheet 13 to depictthe
adjacent buildings. Building 1 is very close to the garage of the abutter at 39
Prescott St. HW notes that the Applicant has proposed a 5-foot-high black picket
fence with plantingsalong the property line.
d.Building 2 is located 34.6 feet from the eastern property line adjacent to Meadow View
Condominiumwhich is in a residential 5 zoning district.This areamay be defined as the
rear yardrequiring 30 feet of setback from the R4 and the IS districtsand 35 feet from
Subdistrict A. Or it may be considered a side yardrequiring a 35-foot setback for a new
building in Subdistrict A when the Subdistrict A line abuts a residential zoning district
located outside Subdistrict A. The Applicant has not requested a waiver from the rear
yardsetback line but has requested a waiver from the sideyardsetback line. HW
recommends that a determination be made regarding thearea between the building and
theeastern property line.
March 3, 2026: The Applicant has stated that the Building Commissioner has
determined that the eastern property line is a rear yard setback requiringa 30-foot
setback withinthe R-4 District and the Industrial-S District.A34-foot 6-inch
setback has been proposed.A 35-foot setback is required for a new building in
Subdistrict A, therefore a waiver may be necessary to allow the34-foot 6-inch
setback within this district.
e.Thehighest proposed building height is approximately 54 feet 7 inchesfeetfrom the
average finish grade. The Applicant is requesting a waiver from the maximum height of
35 feet within an R4 district.The IS district and Subdistrict A appear to allow a maximum
height of 55 feet by right.
March 3, 2026: No further action is requested.
f.The maximum lot coverage calculated by the Applicant is 34%. The maximum allowable
lot coverage within the IS district is 35%. The Applicant has requesteda waiver.
However,it is not apparent that one is needed.
March 3, 2026: The Applicant intends to update the waiver list.
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g.The Applicant is requesting a waiver from the Maximum Floor Area Ratio(FAR) and is
proposing a FAR of 1.70:1. A ratio of 1:1 is allowed by right in Subdistrict A. A ratio of
0.5:1 is allowed by right in an IS district. A FARof up to 2:1 is allowed by Special Permit
in Subdistrict A.
March 3,2026: The Applicant has requested a waiverfrom the allowable FAR.
15.Design Criteria:
a.The Applicant is using the same curb cuts as exists for the existing parking garage with
a 25-foot-wide driveway.
March 3, 2026: No further action is requested.
b.It is not obvious if bike racks are proposed. HW recommends that the Applicant includes
an interior storage location for bicycle accommodation in accordance with Section 195-
18.18 C.
March 3, 2026: The Applicant has stated that thebike racks will be located inside
the garage portion of the building. No further action is requested.
c.HW recommends that the Applicant consider a solid five-foot-high fence along the
property of 39 Prescott Street or additional trees for screening.
March 3, 2026: The Applicant has added a five-foot-high fence along the property
of 39 Prescott Street.
d.The Applicant has proposed two generators, one for each building that are located near
the surface parking spaces. The size of the generators looks small for the size of the
building. HW recommends that the Applicant confirm the size and determine if additional
screening or enclosureis necessary.
March 3, 2026: The Applicant has stated that the generator pads have been
removed from the plans. No further action is requested.
e.The Applicant has provided a Photometric Calculation Plan, Sheet L3.0. The light
candles appear to spill over onto the Meadow View Condominiums and slightly ontothe
property at39 Prescott. HW recommends that the Applicant confirm that the amount of
spillover will not be a nuisance for any abutting residents.
March 3, 2026: The Applicant has updated the light and landscape plan to prevent
light trespass. There still appears to be some spillover. HW recommends that the
Applicant confirm that the amount of spillover will not be a nuisance for any
abutting residents.
April 2, 2026: The Applicant has updated the lighting plan and has noted that it
cannotavoid light spillover along the southern lot unless a fence is installed. The
Applicant would prefer to request a waiver for the lighting. HW defers the granting
of the waiver to the ZBA.
f.HW recommendsthat the Applicant includesa locus plan showing the names of
abutters, land uses, and locations and width of all adjacent streets.
March 3, 2026: The Applicant has provided a locus plan onSheet 13of the plan
set. No further action is requested.
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g.The Applicant is proposing one new fire hydrant. There is an existing hydrant on
Prescott Street near 139 Prescottand an existing hydrant on High Street at the
intersection with Prescott Street. It appears that fire apparatus can reach three sides of
the proposed building. HW recommends that the Applicant coordinatewith the fire
department to confirm thatthe hydrant locations are adequate and that they canaccess,
circulate, and egressthe site and building safely.
March 3, 2026: The Applicant is in the process of coordinating with the Fire
Department. The ZBA may choose to request confirmation that the Fire
Department is satisfied.
h.HW recommends that the Applicant confirmwith the North Andover Department of
Public Works (DPW) that the municipal sewer and water systems have adequate
capacity to accommodate an additional296 residential units.
March 3, 2026: The Applicant is in the process of coordinating with the DPW.The
ZBA may choose to request confirmation that the DPWis satisfied.
i.HW recommends that the Applicant add the depth of gravel subbase tothe Typical
Bituminous PavementDetail, on Sheet 8.
March 3, 2026: The Applicant has added the gravel subbase depth to the Typical
Bituminous Pavement Detailon Sheet 8. No further action is requested.
j.HW recommend that the Applicant confirmshow trash and recycling operations will be
performed by the residents.
March 3, 2026: The Applicant has stated that the trash and recycling will be stored
within the garage and will be wheeled out to the driveway on trash and recycle
pick up day. The ZBA may choose to make this process a condition of approval.
Conclusions
HW is satisfied that the Applicant has adequately addressed our comments. TheZBAmay
choose to require that the Applicant providesa clear list of requested waivers as part of the
Board’s review process. Please contact Janet Bernardo at 508-833-6600 or at
jbernardo@horsleywitten.com if you have any questions regarding these comments.
Sincerely,
HORSLEY WITTEN GROUP, INC.
Janet Carter Bernardo, PE
Principal
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