[From the U.S. Government Printing Office, www.gpo.gov]




           An Environmental Assessment
                     of an Industrial Area
                  Fairfidd                A Waterfront Study





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             TD
             224      by Baltimore City
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             F35     ent of Planning                                     *VRY -TK4T RM
             1991
                     reeman, AICP, Director                  Kurt L. Schmoke, Mayor






                            FAIRFIELD
                            WATERFRONT
                            STUDY







                            Prepared by the
                            Baltimore City Planning Department
                            Ernest Freeman, AICP, Director






                            This study was funded by the Coastal Resources Division
                            of the Maryland Department of Natural Resources
                            through a grant from the National Oceanic and
                            Atmospheric Administration, Office of Coastal Resources
                            Management.

                            JANUARY, 1991






         si




                                        FAIRFIELD ENVIRONMENTAL




                                           Table of Contents




              I. EXECUTIVE SUMMARY




              Il. BACKGROUND AND OVERVIEW


                  A.   Boundary of the Study Area

                  B.   Overview of Report

                  C.   Historical Background




              III.EXISTING CONDITIONS


                  A.   Land Use


                       1.   Existing land uses and zoning

                       2.   Infrastructure


                       3.   Environmental Regulations/Existing Conditions

                            a.   Air Quality

                            b.   Water Quality


                            C.   Critical Areas


                  B.   Environmental Conditions


                       1.   Soils/Fill

                       2.   Stormwater Drainage

                       3.   Streams and Wetlands


                       4.   Condition of Waterfront


                       5.   Water depth










               IV. ECONOMIC DEVELOPMENT/FUTURE ENVIRONMENTAL REGULATIONS

                   A.   Growth in the Critical Area


                        1.   General Growth


                        2.   Port Liberty

                        3.   Masonville


                        4.   CSX coal terminal


                        5.   Patapsco Wastewater Treatment Plant

                   B.   Economic Development Strategies for Fairfield

                        1.   General Scope

                        2.   Assessment of City owned Sites

                        3.   Old Fairfield - City policy

                   C.   New Federal/Local Regulations Regarding Environment

                        1.   Clean Air Act - Amendments of 1990


                        2.   Clean Water Act - Amendments to storm water regulations

                        3.   Critical Area Habitat Protection Requirements - Baltimore City




               V. CONCLUSIONS AND ASSESSMENT


                   A.   Environmental Goals & Objectives

                        1.   Improve Shoreline

                        2.   Protect Habitat


                        3.   Encourage buffers/wildlife corridors

                        4.   Improve quality of storm water runoff

                        5.   Remove discharges except Patapsco WWTP

                        6.   Improve Patapsco's discharge

                        7.   Use offset funds to improve area

                   B.   Findings - Potential Measures for Environmental Improvement

                        1.   Changes to zoning



                                                     2









                       2.   Suggested places to use offset funds

                       3.   Use of Critical Area regulations and Habitat Protection

                            Program to enforce/encourage needed changes

                       4.   Stormwater changes



                  Appendix I

                  1.   The Clean Air Act


                  2.   The Clean Water Act


                  3.   The Permit Program and Enforcement

                  4.   Resource Conservation and Recovery Act (RCRA)

                  5.   Superfund Amendments Reauthorization Act (SARA, 1986)



                  Appendix II

                  Baltimore City Critical Area Management Program (CAMP) -

                  Section III "Development Requirements"



                  Appendix III

                  Summary of the Clean Air Act Amendments of 1990



                  Appendix IV

                  Baltimore Integrated Environmental Management Project Phase II

                  Report: Baltimore Harbor Data Analysis














                                                    3















                   EXECUTIVE SUMMARY


                   Environmental Goals and Objectives



                        1.   Improve Shoreline - Areas that are not bulkheaded can be

                        improved through vegetative plantings and removal of derelict

                        structures. Existing bulkheads can be rehabilitated as properties

                        turn over and are redeveloped.



                        2.   Protect Habitat - Despite the heavy industrial nature of the

                        Fairfield area, some areas of high habitat value exist. It is the

                        goal of this plan to preserve and enhance these areas where


                        feasible.




                        3.   Encourage buffers/wildlife corridors - Existing wildlife

                        habitat can be greatly served by creation of a corridor/buffer

                        system throughout the peninsula. Such corridors and buffers can

                        serve the dual use of increasing habitat values while also

                        improving water quality and drainage.



                        4.   Improve quality of storm water run off - Through the use of a

                        buffer and naturalized drainage system, as well as the EPA

                        stormwater regulations, it is hoped that stormwater quality can be

                        improved.



                        5.   Remove discharges except Patapsco's WWTP - As part of the

                        effort to improve water quality around the Fairfield peninsula, all



                                                     4







                       all existing NPDES discharges should be tied into the City's

                       Pretreatment program, where feasible.



                       6.   Improve Patapsco's discharge - Planned expansion of

                       capacity, improved treatment operations and construction of a

                       dechlorination plant will all help to improve effluent discharge.



                       7.   Use Offset funds to improve specific areas - Offset funds

                       are available to complete specific projects for wetlands creation

                       and habitat improvements.




                  Potential Measures for Environmental Improvement



                       1.   Changes to Zoning



                       There are several alternatives within the zoning code which could

                       be used to address problems resulting from industrial

                       development:

                       (1) changing to a less intensive industrial zoning category; for

                       example, from M-3 to M-2;

                       (2) changing the definition of permitted uses within the existing

                       category; for example, eliminating some uses in M-3 or M-2 (this

                       alternative may involve the formation of a new zoning category);

                       (3) changing which uses are conditional in existing zoning

                       categories;

                       (4) creating performance standards for certain uses. Land use

                       control changes such as these are now being explored by a task





                                                    5









                        force representing area community, industry, city, and State

                        officials.




                        2.   Suggested Places to Use Offset Funds

                        The Fairfield Peninsula contains two significant waterfowl staging

                        and concentration areas - Masonville and Stonehouse Cove.




                        Since the proposed development for Masonville has been postponed

                        for the present time, it is suggested that efforts be directed to

                        Stonehouse Cove and the intermittent stream which flows into it.


                        As part of this overall assessment, it is recommended that the

                        feasibility of establishing a greenway link with Masonville via

                        an existing intermittent stream be evaluated.



                        In addition to the on-site mitigation expected to be driven by new

                        development and redevelopment, the City will be working with

                        property owners who wish to use portions of their shore line for

                        enhanced vegetation as a means of achieving overall water quality

                        and wildlife improvements. The City is committed to using offset

                        funds derived from elsewhere or development projects to match the

                        efforts of private property owners to improve shoreline

                        conditions. The City is also prepared to negotiate conservation

                        easements with cooperating property owners to provide property tax

                        relief and to insure that revegetated portions of the City's

                        shoreline remain forever green.








                                                     6









                       3.   Use of Critical Area regulations and Habitat Protection

                       Program to enforce/encourage needed changes



                       The Baltimore City Habitat Protection Program identifies and

                       locates each of these habitat areas which exists in Baltimore City,

                       establishing protection policies for each.




                       The open spaces within the Critical Area include approximately 70

                       acres of high and low marsh habitat in Masonville and a 5 acre

                       undeveloped wooded lot adjacent to and east of Fairfield Homes.



                       Baltimore City has identified the presence of two general

                       categories of habitats in Fairfield as established in COMAR

                       14.15.09 and they are the Critical Area 100-foot buffer and

                       historic waterfowl staging and concentration areas. The City is

                       proposing that these areas be designated as Habitat Protection

                       Areas (HPA) and that protective measures be adopted to protect

                       these areas from the adverse impact of development.



                       4.   Stormwater Changes

                       Urban streets contain many toxic contaminants (non-point source

                       pollution) which enter streams during a storm's peak, and this

                       pollution poses a serious detriment to wildlife. A few potential

                       solutions for reducing these shock loads may include the following:



                       (a) select roadway sites so as to minimize the area draining

                            directly into the receiving body of water;



                                                    7









                        (b) utilize low curbs when the road is adjacent to flat, unpaved

                            areas or areas that slope gently away from the street

                            surface. This will facilitate the deposition of the dust and

                            dirt into grass and gravel areas and reduce the rate of

                            deposition in runoff water;

                        (c) consider the use of porous pavement in areas where the soil

                            type permits it;

                        (d) intensify and improve street-cleaning operations to reduce

                            urban roadway runoff effects;

                        (e) design curbs and gutters to facilitate concentration and

                            collection of particulate material;

                        (f) investigate various approaches to detention and storage of

                            storm runoff and separation of solids from stormwater.


































                                                    8










              II. BACKGROUND AND OVERVIEW


                  A. Boundaries of the Study Area



                  Fairfield is a large, flat peninsula located approximately four miles

                  south of downtown Baltimore. It is surrounded on three sides by water,

                  and is physically separated from adjacent landward neighborhoods by a

                  wide expanse of railroad tracks. (See Figure 1.) Although originally

                  known for farming and cannery operations, the area was converted

                  primarily to heavy industry beginning in the early 1900's.



                  The total study area included in this report covers 2000 acres; however,

                  much of the content of the report will focus on lands adjacent to the

                  waterfront. The study area is delineated on the east and north by the

                  Patapsco River and on the western side by Frankfurst Avenue. At the

                  intersection of Frankfurst and Patapsco Avenues the boundary line turns

                  east, following Patapsco Avenue to Stonehouse Cove (See Figure 2).

                  Another concentrated area of heavy industry is located adjacent to the

                  study area in Curtis Bay. This area is mentioned from time to time in

                  this report, especially as it contributes to Fairfield's conflicts

                  with adjacent residential areas.



                  B. Overview of Report




                  Economic and environmental conditions In the Fairfield area combine to

                  create a wide variety of issues in need of discussion. The type of

                  industry which is concentrated in this area requires large amounts of

                  flat impervious land to operate, and tends to create noxious or



                                                    9









                   hazardous substances as by-products of their operations. This places

                   the economic growth of Fairfield at-odds with surrounding residential

                   neighborhoods and the environment. To deal with these issues, the City

                   of Baltimore has initiated two studies of the Fairfield area. The first

                   report titled "Strategy for the Fairfield Industrial Area" was completed

                   in a joint effort by BEDCO and the Planning Department, and focuses on

                   economic development issues.



                   This report will concentrate on environmental issues in Fairfield and

                   propose ways to deal with water quality and habitat issues. This study

                   includes existing and future economic conditions; the environmental

                   condition of the study area, particularly the waterfront; existing

                   environmental legislation and proposed new environmental legislation

                   which will affect the number and type of industrial development in

                   Fairfield; and recommendations for environmental improvement.



                   C.  Historical Background



                   The first recorded non-indigenous settlement of Fairfield was in 1663

                   when Paul Kinsey recorded 200 acres of land on the northern shore of

                   Marley Creek. He named the estate Curtis's Neck. Following Kinsey

                   was John Cromwell in 1670, with the recordation of 6000 acres of land

                   north of Marley Creek, encompassing most of the remainder of the study

                   area. Cromwell named his estate Plantation Fairfield.




                   The Cromwell family sold most of the land south and west of what is now

                   Chesapeake Avenue to the Crisp family in the early 1800's. By the



                                                     10











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                 mid-1800's, the land to the south became the site of "Freetown," reputed

                 to the be first settlement of free African-Americans in the eastern


                 United States. During this period, land in the study area was devoted

                 to agricultural uses, primarily vegetable and tobacco farming, and

                 cutting timber for maritime uses in the City of Baltimore.

                 Transportation to the City was by ship or road (through present day

                 Linthicum Heights).



                 In the 1870's. the Patapsco Land Company of Baltimore City (formerly the

                 Patapsco Company) began to promote industrial development in the

                 Stonehouse Cove/Curtis Bay area. Two events enhanced the area's

                 desirability for industrial uses: 1) the construction in 1856 of the

                 Light Street Bridge (and the 1878 removal of its toll), which connected

                 the peninsula to the City of Baltimore, and 2) the construction of the

                 B&O railroad bridge across the Perry Branch of the Patapsco in 1882.

                 These projects opened the study area for industrial development.



                 From the 1880's until the onset of World War I, development of

                 industrial and residential uses in the area grew at a rapid pace as

                 steel, chemical, and railroad-related businesses located operations in

                 Fairfield. The industrial development also spurred rapid growth in

                 nearby residential areas with Fairfield, Curtis Bay and Brooklyn gaining

                 the most new residents. By 1893, Fairfield had grown into a town of 260

                 people.



                 In 1896, the Martin Wagner Company constructed a fruit and oyster

                 canning plant on part of the site of the present day Patapsco Waste



                                                    11










                  Water Treatment Plant. Rapid growth of the cannery and associated

                  businesses necessitated the development of company housing (now Wagner's

                  Point) in the area. The cannery closed in 1929 and the site is now

                  occupied by the City's Waste Treatment Plant and Delta Chemical.



                  The petroleum industry first came to Fairfield in 1906 with the Ellis

                  Company, which was subsequently bought by U.S. Asphalt Refinery

                  Company. Today terminal operations for B.P. Oil, Texaco, Socony-Mobil

                  and American Oil Company are located on the site. Land just to the east

                  of Stonehouse Cove was purchased by U.S. Industrial Chemical and

                  Alcohol Company, the predecessor of FMC Corporation. Other nearby

                  parcels of land were purchased by Shell Eastern Petroleum Products,

                  Prudential Refinery Company, Raisin Monumental Chemical Company,

                  Royster Guano Company, American Bitumals and the Chesapeake Sugar

                  Refinery. The City of Baltimore purchased the site of the Chesapeake

                  Sugar Refinery in 1924 to construct the Patapsco Treatment Plant, a

                  modern version of which occupies the site today.



                  Land along the northern shore of Fairfield was the last to be developed

                  for industrial uses. Due to the area's proximity to the City of

                  Baltimore and the availability of timber, this section of Fairfield had

                  originally been developed for wharves, ship building, and related uses.

                  Union Shipbuilding was the first large employer to locate on the

                  northern shore of Fairfield. Following it were Maryland Shipbuilding,

                  Maryland Drydock, and Weyerhauser Timber Company.







                                                    12









                  The study areas were annexed by the City of Baltimore from Anne Arundel

                  County in 1917.




                  From 1930 to 1940, industrial development in Fairfield was stagnant.

                  With the onset of World War II, however, the U.S. government chose

                  Fairfield as a site for the production of Liberty Ships, making it the

                  largest shipyard on the East Coast. Peacetime functions returned to

                  Fairfield in 1946 with the return of property to its original owners.

                  Although most temporary war worker housing was removed, the City of

                  Baltimore retained Fairfield and Brooklyn Homes for public housing.



                  The Baltimore Harbor tunnel, which followed along the Ferry Branch of

                  the Patapsco River and through Fairfield was constructed between

                  1955-1957. It bisected the Fairfield Peninsula separating the Arundel

                  Corporation, Weyerhauser, Maryland Shipbuilding and Drydock and the

                  Bethlehem properties from the petroleum and chemical companies and

                  residential areas to the south.




                  The 1960's and 1970's were a time of transition for Fairfield. By the

                  1980's most of the shipyard-related businesses had closed. However,

                  Fairfield's waterfront evolved as new uses took advantage of its deep

                  water access. Shipping rather than shipbuilding again became important

                  in Fairfield. The Island Creek Coal Terminal was developed in 1982 as a

                  major coal export facility. In the same year, Hobelman Port Services

                  purchased 41 acres of land on the north shore, just east of

                  Masonville, and developed an automobile import and storage facility.

                  Hobelman's operations have continued to expand since then.



                                                    13








                  In the late 1970's, the Maryland Port Administration began planning for

                  a new container terminal to occupy 350 acres in Masonville, on the

                  northern shore of Fairfield. However, construction of the container

                  terminal has been put indefinitely on hold. Reasons for the post-

                  ponement include the development of another terminal (Seagirt) in the

                  interim, as well as uncertainty over the prospects for the Port of

                  Baltimore's future share of East Coast container traffic. Also, shallow

                  water conditions and the constant input of sediment from the Patapsco

                  make excessive dredging necessary and difficult to maintain. In 1988,

                  MPA purchased the closed Maryland Shipbuilding and Drydock property

                  and developed an auto import facility for Toyota. At the present

                  time, the MPA is trying to market a large section of the property to one

                  or more additional auto importers.


































                                                    14













             III.EXISTING CONDITIONS


                 A.   Land Use




                      1.   Existing Land Uses

                      The entire study area is now zoned M-3, heavy industrial. Over the

                      years Fairfield's flatness and its excellent waterfront access

                      have made it attractive to a variety of businesses that require

                      these features: ship building in the past, now replaced largely

                      by marine terminals (especially auto import terminals), water-

                      dependent manufacturing, and petroleum distribution operations.

                      These companies utilize the deep water access for barging large

                      shipments of supplies, and use the flat, isolated land for tank

                      farms. Chemical companies have also been attracted by the area's

                      excellent transportation network, which includes deep water access,

                      interstate highways and railroad lines. (See Figure 3)



                      Today, three heavy industries dominate the Fairfield Peninsula:

                      petroleum product manufacturing and distribution, chemical

                      manufacturing, and shipping-related industries (auto import

                      terminals, storage areas and trucking operations). Major employers

                      include FMC Corporation, a manufacturer of pesticides and

                      herbicides (320 employees), Vista Chemical, a manufacturer of

                      industrial detergents (190 employees), and Alcolac, a

                      manufacturer of both chemicals for the cosmetic and personal care

                      industry and industrial cleaners (110 employees). Remaining

                      industries include: animal feed and steel drum manufacturing, a



                                                    15










                       Maryland Toll Authority operation, scrap metal storage, as well as

                       an assortment of small industrial service operations (equipment,

                       construction, auto parts, etc.) (see Figure 4).



                       Within this concentration of heavy industry are two extremely small

                       residential enclaves -- Old Fairfield and Wagner's Point. Each of

                       these communities is surrounded by petroleum product distributors,

                       chemical companies and scrap metal dealers. Old Fairfield covers

                       30 acres and is home to about 12 remaining households -- most of

                       them elderly. Wagner's Point covers about 10 acres and is home to

                       about 235 people. Adjacent to, but outside, the study area are two

                       much larger residential areas, Curtis Bay and Brooklyn, with 5,110

                       and 19,030 inhabitants, respectively. (See Figure 5.)




                       2.    Infrastructure

                       This section describes Fairfield's existing infrastructure and

                       identifies any shortcomings which have negative effects on the

                       areals environmental conditions.







                       Roads




                       Roads in heavy industrial areas endure constant and severe

                       wear-and-tear from truck traffic. Not surprisingly, the complaint

                       most often voiced by companies during interviews with businesses

                       was road conditions. Table II-A summarizes roadway conditions

                       based on a Planning Department field survey. In addition,



                                                     16




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                                                  Fairfield Street Condition Evaluation



                   Street                 From                   TO                      Condition               Importance to
                                                                                                                 Circulation7

                   Brady Avenue           Sun Street             Weedon Street           Poor                    3

                   Carbon Avenue          Sun Street             Remley Street           Poor                    3

                   Chesapeake Ave.        Sun Street             Vera Street             Poor                    I

                   Chesapeake Ave.        Shell Road             Chesapeake Ave.         Poor                    I

                   Childs Street          Shell Road             Chesapeake Ave.         Poor                    x

                   Fairfield Road         Chesapeake Ave.        Carbon Ave.             Poor                    3

                   Remley Street          Chesapeake Ave.        Carbon Ave.             Poor                    x

                   Sun Street             Chesapeake Ave.        Carbon Ave.             Poor                    2

                   Tate Street            Chesapeake Ave.        Carbon Ave.             Poor                    x

                   Weedon Street          Chesapeake Ave.        Brady Ave.              Poor                    3

                   Asiatic Avenue         Southport Ave.         Northbridge Ave.        Fair                    3

                   Cannery Avenue         Fourth Ave.            Northbridge Ave.        Fair                    3

                   Childs Street          Frankfurst Ave.        (Dead End)                air                   2

                   Frankfurst Ave.        Shell Road             Childs Street           Fair                    I


                   Frankfurst Ave.        Childs Street          Vera Street             Fair                    I

                   Frankfurst Ave.        Potee Street           Shell Road              Fair                    I

                   Leo Street             Northbridge Ave.       Southport Avenue        Fair                    3

                   Shell Road             Frankfurst Ave.        Patapsco Avenue         Fair                    I

                   Southport Ave.         Fourth Ave.            Northbridge Ave.        Fair                    3

                   Vera Street            Frankfurst Ave.        Chesapeake Ave.         Fair                    2

                   8th Avenue             Asphalt Street         (Dead End)              Good                    3

                   Asphalt Street         Fairfield Road         (Dead End)              Good                    3

                   Childs Street          Chesapeake Ave.        (Cul-de-sac)            Good                    3

                   Fairfield Road         Chesapeake Ave.        Northbridge Ave.        Good                    2

                   4th Avenue             Northbridge Ave.       Southport Ave.          Good                    3

                   Northbridge Ave.       Fairfield Road         Asiatic Ave.            Good                    2

                   Patapsco Avenue        Shell Road             Fairfield Road          Good                    I


                                                                Table H-A



                      '1 =Principal access road; 2=Secondary access road; 3=Local road; X=Future status in
                 question.









                       deteriorated roads generate sediment carrying pollution often

                       referred to as non-point source pollution.



                       Based on this information, the top priorities for roadway work are

                       Chesapeake Avenue from Shell Road to Sun Street and from Sun Street

                       to Vera Street, Sun Street from Chesapeake Avenue to Carbon Avenue,

                       all of Frankfurst Avenue (from Potee Street to Vera Street), and

                       Shell Road from Frankfurst to Patapsco Avenue. A more detailed

                       plan and schedule for improving these roads should be developed and

                       included in next year's review of the Six-Year Capital Improvement

                       Plan.





                       Water




                       Water service to the study area is provided by the City of

                       Baltimore. The system of mains and feeder lines was developed to

                       serve the entire peninsula for industrial purposes. Water service

                       is also provided to the two residential communities in the primary

                       study area.




                       Sanitary Sewers




                       The study area is fully served by the municipal sanitary sewer

                       system. All properties are either already served by the system, or

                       need only to hook into the existing lines that run throughout the

                       peninsula.





                                                     17









                       Waste water treatment for the study area is provided by the

                       Patapsco Waste Water Treatment Plant on the lower part of the

                       Fairfield Peninsula. Current capacity at the treatment plant is

                       adequate for existing levels of activity. Capacity of the plant is

                       70 million gallons per day (MGD) to be expanded to 87.5 MGD in
                       1992-93. The City shares available capacity with the surrounding

                       counties. Planned capacity should be sufficient to cover service

                       needs into the next century, given current development patterns and


                       pace.




                       Storm Sewers



                       The most notable aspect of Fairfield's topography is its almost

                       uniform flatness. The highest point -- Shell Road at Childs

                       Street -- is only 35 feet above sea level, while vast portions of

                       the peninsula rise only 9 to 12 feet above sea level.



                       Installed during the 1970's, storm sewers are a fairly recent

                       public investment in Fairfield. Storm water management in

                       Fairfield is made difficult by the extremely flat, low-lying nature

                       of the topography, and the compact nature of the soils.



                       The Fairfield study area is divided into two major drainage basins,

                       identified as P3-B and P3-A on City storm drain maps (see Figure

                       6). P3-B follows the shoreline of Stonehouse Cove, then

                       continues northward in the vicinity of Shell Avenue to the

                       Masonville area. All land east of this line to the Patapsco



                                                    18



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                                         vA
                                                                                       lo-a                                      v






                                                                      AV.


                                                                                           to

                                                                                                                                                                                   luo"W'sp 1@
           STORM DRAIN                              SYSTEM
                    DRAINAGE DISTRICTS                                                                     JL-v
            P3-BDRAINAGE DISTRICT NUMBERS
                                                                                                                                    N
              -4CSTORM WATER DRAIN /CUTFALLS

                    SANITARY SEWER

                                                                                                               L                                                                                                       BAY
                                                                                                                   IL
                                                                                                                                                                                                    cumr,s
       FAIRFIELD AREA 9TUDY
                                            Fig. 6
                           1500'
                               mom
       AN I








                       River is included in the drainage basin. P3-B contains 8 outfall

                       points. Two flow northward through Masonville, five points

                       discharge along the Eastern side of the peninsula, and one empties

                       at the mouth of Stonehouse Cove. The north and eastern outfalls

                       discharge directly to the Patapsco River.



                       The drainage basin identified as P3-A is much smaller, and extends

                       out of the study area to include portions of the Curtis Bay

                       neighborhood. This drainage basin contains 4 outfall points.

                       Three drain easterly into Stonehouse Cove, and one northerly

                       through the Masonville property. The stormwater system and

                       drainage patterns will be discussed in more detail in Section II -

                       Drainage.







                       Summar




                       In summary, basic utility service to Fairfield appears to be

                       adequate to serve the area with some room for growth. However, the

                       existing storm drainage system must be studied in more detail.

                       Flat areas where drainage is poor and where ponding of water

                       occurs should be addressed. A detention basin and vegetated

                       swale system may improve water quality of stormwater run-off.



                  3. Environmental Regulations/Existing Conditions








                                                    19









                  The following section provides an overview of environmental regulations

                  that directly affect many of the industries in Fairfield. The list is

                  not exhaustive, but includes the major regulatory programs. Federal

                  laws which affect most industry includes the Clean Air Act, Clean Water

                  Act, Resource Conservation and Recovery Act, and SARA Title III of

                  1986. The basic legislative requirements of these laws are described in

                  Appendix I, and firms which fall under their purview Will be

                  identified. This information is valuable because it can be used to

                  identify those firms which may be responsible for a greater share of

                  environmental problems.



                  In addition, there are other federal regulations that require compliance

                  by Baltimore's chemical industries. The Toxic Substances Control Act

                  was enacted in 1976 and remains in force through continuing resolution

                  of Congress. There are two significant areas which affect the chemical

                  industry. Section 5 requires that an industry submit a

                  premanufacturing notice for each covered chemical under the Generic

                  Significant Use Rule (GNUR). The Comprehensive Assessment Information

                  Rule (CAIR) allows the EPA to collect information on 47 chemicals

                  already on a site.



                  The other two areas of regulatory compliance are OSHA and the

                  Chlorofluorocarbon Protocol. OSHA requires that industries document

                  and label chemicals in the work place under the Hazard Identification

                  Standards. In 1988, the EPA established rules and a schedule for the

                  reduction of production of chlorofluorocarbons to comply with the




                                                    20








                  provisions of the international agreement to limit such production

                  signed in Montreal in 1987.



                  The industries must also comply with the laws of the State of Maryland

                  and the City of Baltimore.






                  a. Air Quality



                  In 1989, twelve firms in Fairfield required an air quality permit as

                  part of their operations. This number has dropped from sixteen total

                  firms in 1980. The reduction in the number of permits caused the

                  relocation of firms out of the area or changes in operations at permit

                  sites. Tables 2A and 2B provide lists of firms that required air

                  quality permits in 1980 and 1989, and the amount of emissions released

                  by each. Table 2C outlines changes in emissions through the 1980-1989

                  time period.



                  Emissions of the 4 major categories of pollutants (particulates, SOx,

                  NOx, CO and Volatile Organic Compounds) were reduced substantially,

                  from 4,970 tons/year in 1989 to 872 tons/year in 1989. The most

                  substantial reduction occurred in the category of Volatile Organic

                  Compounds, which dropped from 2468 tons/year to 297 tons/year. In both

                  1980 and 1989, FMC Corp. had the largest amount of equipment and

                  released the greatest amount of pollutants into the air. FMC also

                  produced the greatest reduction in emissions, reducing output 1,752

                  tons/year without reducing the total amount of equipment. All firms



                                                    21









                  reduced their emissions or operations between 1980 and 1989, except for

                  the Patapsco WWTP and Vista Chemical (Formally Essex Chem). These
                  two operations expanded their capacity during the 80's which increased

                  their level of emissions slightly.






                  b. Water Quality



                  The information in this section of the report was obtained from the

                  document Baltimore Integrated Environmental Management Project - Phase

                  II Report, Baltimore Harbor produced in 1987. This document utilizes

                  comprehensive data from a variety of harbor water quality studies

                  conducted over an extended period of time. Unfortunately, much of the

                  data regarding water quality used in the report is old, some of it

                  dating back to 1973. This is because no comprehensive analysis of water

                  quality in the study area has been completed since that time. Compared

                  to other areas of the Harbor, the situation in Fairfield has changed

                  little over time, therefore the data is still useful for the purposes of

                  this report. (Excerpts from the EPA document outlining the data

                  analysis in more detail are provided in Appendix IV of this report.)



                  The EPA document is based on a matrix system which compares a group of

                  water oriented uses with a list of environmental parameters necessary to

                  sustain such uses. For example, a desired use such as Fish Quantity

                  requires environmental parameters such as low turbidity, and fairly
                  high habitat values. The Report divided the Harbor into thirteen study

                  areas, and assigned values for each use and parameter. Water oriented



                                                   22











                                                       1980
                                                 ACTUAL EMISSIONS
                                                    (tons/yr.)




                                              Units of
         Company Name                  TYPE    Equipment   Particulates        sox        NOX      CO       VOC
      FMC                                C        19              47           560        707      25       746
      Continental oil                    P         9              40           452        258      33         25
      Buffalo Tank                       M         3               0             1         0        0          0
      Amoco                              P         8              17           108         94      21       796
      Alcolac Chemical                   C         6               1             16        8        2          3
      Essex Industrial  (Minerec Corp.)  C        10               4             0         0        0          7
      Delta Chemical                     C        10              30             4         2        0          5
      Patapsco Wastewater Plant          S         3               0             1         1        0          18
      Mobil Oil                          P         1               0             0         0        0       328
      B. P. Oil                          P         2               4             0         0        0       546
      Seaboard Asphalt                   P         3               0             5         1        0          2
      Fruehauf Trailer                   M         2               0             0         0        0          5
      Hoblemann Port Services            D         5               0             0         0        0          27
      Fraco Coating Company              C         1              18             0         0        0          0
      Hoblemann-2000 Chesapeake          D         1               0             0         0        0          1
      MD Tire Co.                        M         1               0             0         0        0          1


         Annual Total                             84              161         1,147     1,071      81      2,510


      C - chemical
      D - Distribution
      M - manufacturing
      P - petroleum
      S - service

      Source: Maryland Department of the Environment


                                                    TABLE II-B











                                                       1989
                                                ACTUAL EMISSIONS
                                                    (tons/yr.)




                                              Units of
         Company Name                  TYPE   Equipment    Particulates       sox        NOX     Co        VOC
      FMC                                C         19             8             49       183     21         72
      Vista Chemical                     C         4              3             61        37      6         15
      Amoco                              P         2              0             5         3       1          1
      Rhone Pouleno Specialty Chemicals  C         6              0             7         7       2          0
      Delta Chemical                     C         9             13             1         0       0          3
      Patapsco Wastewater Plant          S         9              5             47        47     30         30
      Mobil Oil                          P         1              0             0         0       0         75
      B. P. Oil                          P         1              0             0         0       0         114
      Seaboard Asphalt                   P         2              0             1         1       0          3
      Fraco Coating Company              C         1             18             0         0       0          0
      Hoblemann-2000 Chesapeake          D         2              0             0         0       0          1
      MD Tire Co.                        M         2              1             0         0       0          1


         Annual Total                              58            48            171       278     60         315




      C - chemical
      D - Distribution
      M - manufacturing
      P - petroleum
      S - service

      Source: Maryland Department of the Environment






                                                    TABLE II-C










                                                       1980/1989
                                                   ACTUAL EMISSIONS
                                                       (tons/yr.)



                                                 Units of
         Company Name                    TYPE    Equipment    Particulates        sox        NOX       CO        VOC
      FMC                                  C       19/19           47/8          560/49    707/183    25/21   746/72
      Amoco                                P        8/2             17/0          108/5      94/3      21/1   796/1
      Patapsco Wastewater Plant            S        3/9             0/5            1/47      1/47      0/30    18/30
      Mobil Oil                            P        1/1             0/0            0/0       0/0       0/0    328/75
      B. P. Oil                            P        2/1             4/0            0/0       0/0       0/0    546/114
      Seaboard Asphalt                     P        3/2             0/0            5/1       1/1       0/0       2/3
      Fraco Coating Company                C        1/1            18/18           0/0       0/0       0/0       0/0
      Hoblemann-2000 Chesapeake            D        0/0             0/0            0/0       0/0       0/0       1/1
      MD Tire Co.                          M        1/2             0/1            0/0       0/0       0/0       1/1






      C - chemical
      D - Distribution
      M - manufacturing
      P - petroleum
      S - service

      Source: Maryland Department of the Environment









                                                      TABLE II-D







                                                                   TABLE
                                                        Water Quality Conditions

    Area                     Activit                   Current Status                       Preferred Status

    Lower Middle             Fish Quality              2 Slight contamination,              4 Slight tainting (flavor impairment
      Branch                                             occasional lesions                   but no measurable contaminants)

                             Fish Quantity/Diversity   1 None                               4 Moderate numbers, 4+ species

                             Habitat                   1 Water column and sediments         3 Water column and sediments of
                                                         contaminated, no shelter             acceptable quality but no
                                                                                              shelter


                             Recreational Crabbing     1 None, or contaminated and          3 Scarce; no more than trace
                                                         sickly                                contamination


    Middle Harbor            Fish Quality              2 Slight contamination,              3 Slight contamination (exceeds FDA
                                                         occasional lesions                   Advisory) no lesions

                             Fish Quantity/Diversity   1 None                               3 Moderate numbers, 2 to 3 species

                             Habitat                   1 Water column and sediments         2 Water column acceptable but sediments
                                                         contaminated, no shelter             contaminated and no shelter

                             Recreational Crabbing     1 None, or contaminated and          2 Scarce or plentiful; some
                                                         sickly                               contamination


    Curtis Bay and           Fish Quality              2 Slight contamination,              2 Slight contamination, occasional
      Creek                                              occasional lesions                   lesions

                             Fish Quantity/Diversity   2 Few fish, 1 to 2 species           3 Moderate numbers, 2 to 3 species

                             Habitat                   1 Water column and sediments         4 Water column and sediments of
                                                         contaminated, no shelter             acceptable quality but limited shelter

                             Recreational Crabbing     3 Scarce; no more than trace         3 Scarce; no more than trace
                                                         contamination                        contamination


    [See Appendix IV of report for details regarding numerical rating system of habitat]









                  uses included Fish Quality, Fish Quantity, Habitat, Recreational

                  Boating, Recreational Crabbing, and Swimming. Water Quality parameters

                  include Bacteriological Contamination, Boat Traffic, Dissolved Oxygen,

                  Dredging Frequency, Enrichment, Floating Debris, Sediment Quality, Shore

                  Type, Substrate Type, Turbidity, Vegetative Habitat, and Water Column

                  Metals.




                  Recreational boating and swimming were not considered to be desired uses

                  in the Fairfield area, and therefore we did not include that data as

                  part of this report.



                  For each major area of the Harbor, the EPA study established existing

                  levels of water quality for each use category, as well as the necessary

                  improvements needed to meet the level of quality required for each use.

                  A Table with these values is listed in Appendix IV. This Table shows

                  that the waters surrounding Fairfield are of low environmental quality,

                  and do not support a wide range of aquatic species or habitat. Water

                  quality is generally poor in the area of the Lower Middle Branch and the

                  Middle Harbor. (Please note that data covers the entire Lower Middle

                  Branch area across the river to Fort McHenry. Isolated areas of habitat
                  and higher water quality such as Masonville have a tendency to 'wash

                  out' of the statistics.) Sediments in the area are contaminated, the

                  water is generally deep, little habitat exists and the water suffers

                  from low Dissolved Oxygen (DO) and high nutrient and chemical loading

                  from drainage. Water Quality in the Curtis Creek/Bay area is slightly

                  better, with more natural habitat and Do.





                                                    23









                  There is little or no natural habitat or vegetation along most of the

                  Fairfield shoreline because the area has been bulkheaded. The

                  Masonville property and Curtis Creek are two exceptions, containing

                  shallow areas and some wetlands vegetation. (See section on habitat

                  areas).



                  Methods of improving the quality of run off and limiting the load of

                  pollutants from Fairfield into the Harbor will be discussed in the final

                  chapter of the report.



                  Nine industrial operations in Fairfield presently have NPDES permits

                  to discharge to area waters. These include Amoco Oil company, Delta

                  Chemical, Essex Chemical, Vista Chemical, FMC Corporation, Seaboard

                  Asphalt Products, Mobil Oil, Buffalo Tank Co., and the Patapsco Waste

                  Water Treatment Plant. Most firms discharge directly to the Patapsco

                  River (8 firms), but effluent is also released to Curtis Creek, the

                  Cabin Branch and Curtis Bay. There are a total of 18 outfall points in

                  Fairfield.




                  Most permits cover pollutants in storm water run off, non contact

                  cooling water and other discharges not directly involved in the

                  manufacturing process. Typical items covered in the permits include

                  TSS, COD, and pH. Major exceptions to this are FMC, and the

                  Patapsco Waste Water Treatment Plant. The FMC permit includes 59

                  different items, most of which are chemicals. The Patapsco Treatment

                  Plant includes nine items.






                                                    24











                  Violations:

                  Virtually all of the permit holders have received some violation notices

                  since 1980. In most cases, the number of violations have decreased

                  significantly since the early 1980's. These reductions are probably due

                  to firms entering the City Pre-treatment Program or cut backs in

                  production. FMC Corporation and the Patapsco Waste Water Treatment

                  Plant each have been cited with many violations. The Patapsco Plant has

                  had difficulty removing adequate amounts of chlorine before releasing

                  its effluent. The Plant has entered into a consent agreement with the

                  State, and is in the process of constructing a Declorination Facility,

                  which will be completed by July, 1991. FMC Corporation has violated
                  its permit obligations many times, generally caused by 'glitches' in the

                  waste processing system. FMC must keep a certified technician on

                  staff to operate its waste processing facilities as part of the NPDES

                  permit agreement.



                  Presently only FMC Corporation is operating with a RCRA Controlled

                  Hazardous Substance Permit. Most other firms have arranged to have

                  wastes stored on the site for a period of time which is within the

                  Igrace period' (30 days) time limits. Firms that recently held permits,

                  but no longer require them include Essex Chemical, Alcolac and Vista

                  Chemical (This list is not exhaustive). Both Alcolac and Essex have

                  reduced their total liability by closing their hazardous waste

                  processing facilities, and shipping the waste out of state for treatment

                  and disposal. FMC produces such a large amount of waste that it is

                  economically feasible for them to process the wastes themselves on

                  site.




                                                    25











                   C.  Critical Areas

                   In 1984, the Maryland General Assembly enacted the Chesapeake Bay

                   Critical Area Protection Law to restrict new development and

                   redevelopment within 1000 feet of the tidal waters of the Chesapeake

                   Bay. State regulations were promulgated in 1986 and Baltimore City

                   began implementing its local program in 1988. Since this peninsula is

                   surrounded by such waters on three of its sides,, this environmental law

                   will have a fairly significant impact on development in Fairfield.



                   The law also designates all land within 100 feet of tidal waters as the

                   Critical Area Buffer and imposes even greater restrictions on new

                   development and redevelopment within this area.



                   Under Baltimore's Critical Area Management Program (CAMP) there are

                   essentially two types of mitigation required for development projects.

                   The first is that the project reduce by 10% the amount of pollutants

                   running off the site via stormwater. The second applies only to

                   development projects within the Buffer. All such projects must meet the

                   10% pollution reduction requirement and mitigate for the impact of the

                   development by either providing mitigation on site or by paying $2.50

                   for each square foot of Buffer area that is developed or redeveloped.



                   The restrictions on development within the Critical Area also depend on

                   the particular sub-area in which the project is located. The Critical

                   Area Law requires the City to define these sub-areas based on existing
                   and proposed land uses and development densities. This particular study

                   area falls entirely within the Waterfront Industrial Area and as such



                                                     26









                 development projects will be subject only to those requirements

                 established in Section III.D.2 of the CAMP and any Best Management

                 Practices imposed owing to the nature of the industrial process or

                 operation involved.



                 Owing to the relatively large size of most of the waterfront properties

                 in the study area, it is expected that most development projects will be

                 able to provide adequate mitigation on site, thereby introducing water

                 quality and wildlife habitat benefits to improve existing conditions on

                 this peninsula.



                 To accurately gauge the impact of this law on development projects

                 within the study area, Section III of the CAMP is provided in Appendix

                 11. The complete document may be obtained from the Baltimore City

                 Department of Planning.




                 B.    Environmental Conditions


                       1. Soils/Fill



                       The soils of the Fairfield peninsula have been dramatically altered

                       by human activity over the past 150 years. Originally dominated by

                       a mixture of highly organic, moderately or poorly drained soils,

                       the area now is primarily paved with impervious surfaces. Urban

                       Land (Ub) is now the dominant soil type of the area covering

                       approximately 80% of the land. (See Figure 7.) Ub, is defined as

                       areas where "more than 80 percent of the surface is covered by

                       asphalt, concrete, buildings, or other impervious surfaces." The



                                                    27








                        second most common soil type, 'W-Udorthents, covers roughly 10

                        percent of the study area. This soil type is found primarily in

                        the Masonville area and along the CSX Railroad tracks. These

                        soils are generally made up of earthy fill material which was

                        placed on top of land to provide firm sites for buildings and

                        roads. The fill is not less than 20 inches thick. The remaining

                        10 percent of the site is a mixture of WoB- Woodstown-urban

                        land complex, KyB- keyport-Urban land complex, and

                        Sd-Sulfaquepts, dredge. Woodstown soil consists of layers of

                        organic loam and silty clay material, with mottling occurring at

                        approximately 20 inches of depth. The Keyport soil is similar,

                        but contains a sandier loam and is better drained. Sulfaquepts

                        which are dredge material are described as very deep, very poorly

                        drained soils developed from sulfur-rich dredged harbor sediments.

                        This soil is found exclusively in the Masonville section of

                        Fairfield, where extensive dredged material disposal has occurred.

                        Finally, two small strips of Hs-Histic Sulfaquents, are located

                        along the water's edge. These soils are almost identical in

                        composition to the Sd-Sulfaquepts, the primary difference being

                        that Hs is inundated for some part of the year.



                        In summary, the soil classifications for the Fairfield peninsula

                        indicate that the area is primarily flat and poorly drained. Even

                        if asphalt were replaced with a more pervious material, the

                        silt/clay content and compaction of the substrata would make

                        adequate percolation of drainage difficult.




                                                     28




                                                                          L INE      ESr 1915







   00                                                                                    U

                    Hs                                  Hs
                                                                                                                                    U9



          Hs                       U9
                                                                                                                                           U b
                        U to
                                                                                                                                                                        AL
                                                                        9
                                                                                                                                                                      1A
                                                                                                Ub                Wob
                        @N-

   2L
                                  401

                                                                                           K   B
                                                                                                                                             Ub
                                                                                                                                                                           rL


                                                                                                                                                     A
                                                                                                                                                      Uv
                                                                                                    U9            ob U9
                                                                                                          Hs                      vf;

                                                                                                                                                                  U9
                                                                                                                                                    Be ts


                     SOIL SURVEY, APRIL                 1990                                               U9
                                                                                                                             Ub
                                                                          elf                                                                                      Ub
                                                                         to
                                                                                 ."
            Be 13    Seltsvillo-Urban land complex, 0-8% slopes
             H 8     Typical Sultaquents, frequently flooded
            KYB      Keyport-Urban land complex, 0-8% slopes
             Sd      Sulfaquepts, dredge
                                                                                                             U b
             Ub      Urban land
             U 9     Udorthents
                                                                                                                                     C,
            Wob      Woodstown-Urban land complex, 0-8% slopes                                                                         6-
                                                                                                                                                                            #Av
       FAIRFIELD AREA @TUDY                                                                                                                                        B A Y
                1, -1500'            Fig. 7










                       2. Stormwater Drainage



                       Section I, Storm Sewers, provided an overview of the general layout

                       of storm drainage areas in Fairfield. This section of the report

                       will discuss topography and drainage patterns in more detail.

                       Generally, zone P3-B encompasses 3/4 of the study area. This

                       basin includes most of the land east of Shell Road, and includes

                       drainage points to the north, east and south. The majority of

                       these outfall points consist of concrete piping systems that empty

                       directly into the waterway. Only two of the outfalls utilize any

                       overland flow through vegetated swales. This basin drains

                       virtually all of the industry in Fairfield, including FMC Corp.,

                       Amoco, Vista Chemical, Shell, Delta Chemical, Port Liberty,

                       Hobelman Properties, Old Fairfield and a portion of Fairfield

                       homes (residential). The second drainage basin serving Fairfield

                       labeled P3-A, drains only the western edge of the peninsula, and

                       includes mostly the CSX Railroad tracks and the Curtis Bay

                       neighborhood. Three outfalls from this area drain into

                       Stonehouse Cove. The fourth outfall empties into the

                       Masonville area through a drainage swale.



                       Stormwater management in Fairfield is somewhat difficult and often

                       unpredictable. The topography follows no general pattern, varying

                       only slightly. The area containing Fairfield homes and Old

                       Fairfield contains adequate slopes for drainage. From here the

                       peninsula becomes generally flat, with many depressions where





                                                    29









                       ponding can occur. This is especially true where there are large

                       tank farms.




                       The historic use of the area for chemical and heavy industry has

                       left the soils and storm systems somewhat soiled with residue. It

                       is not uncommon for hazardous chemicals, oil or other petroleum

                       products to turn up in the drainage systems. (Seen in the State

                       NPDES files).




                       This combination of factors will make alterations and improvements

                       to the system more complicated.




                       3. Streams and Wetlands



                       Despite the dramatic amount of fill, compaction and paving of the

                       Fairfield peninsula, some small areas of wetlands still persist.

                       Most are concentrated along the intermittent stream which feeds

                       Stonehouse Cove, and at its outlet. A couple of small strips of

                       emergent estuarine plants are identified on NWI maps along the

                       southern edge of the FMC property. The presence of these

                       wetlands have not been field verified because the City could not

                       gain access to the property. The NWI maps also indicate that

                       various ponds occur throughout the Fairfield area. These areas

                       should also be field verified, the ponding may result from

                       stormwater and may change when development and grading occur. The

                       NWI maps also indicated that the Masonville property contains

                       some isolated pockets of wetlands. The upland pockets are brackish



                                                    30








                       and.semi-permanent. Many exist because of inadequate diking

                       systems. Extensive mudflats are located just off of the

                       Masonville property.




                       4. Condition of Waterfront




                       The Critical Area Management Program of Baltimore City (effective

                       January 1988) requires that the City take measures to prevent or

                       minimize erosion of the shoreline in the Critical Area, which

                       literally means the entire shoreline within the boundaries of

                       Baltimore City.



                       In accordance with the Critical Area Management Program (CAMP), the

                       City has adopted the following two basic policies in regard to

                       shore erosion protection measures:

                            (1) Encourage the protection of rapidly eroding portions of

                            the shoreline in the City by public and private landowner,

                            and;

                            (2) where such measures can effectively and practically reduce

                            or prevent shore erosion, encourage the use of

                            non-structural shore protection measures in order to

                            conserve and protect plant, fish and wildlife habitat.



                       The problem of shoreline erosion, however, is not as severe in

                       Baltimore City for the mere fact that most of the shoreline, if not

                       all, has either been altered or bulkheaded.





                                                    31








                       The Department of Planning of Baltimore City conducted an

                       exhaustive survey in October 1986 of the approximately 26 miles of

                       shoreline. This was augmented with aerial photographs taken from

                       the City Police helicopters in summers 1985 through 1989, and other

                       materials obtained from various State and Federal agencies. Only

                       8.5 miles exist in a "natural" condition, some of which can be


                       found in Stonehouse Cove.




                       Only three sites with a total of 4,600 linear feet has been

                       identified as having "slight" erosion problems and they are outside

                       the Fairfield Area Study. However, there may be a few sites in the

                       Study area already witnessing erosion problems or may be subject to

                       erosion in the near future. A field survey will need to be

                       conducted to locate and evaluate these sites.




                       5. Water Depth



                       The Fairfield peninsula is accessed by two deepwater channels.

                       These are the Fort McHenry Channel and Ferry Bar Channel. (See

                       Figure 8.) The Fort McHenry Channel crosses in a northwesterly

                       direction along the edge of the peninsula. Three private channels

                       extend from the main channel into the Fairfield area serving the

                       Shell, Struever Brothers and Vista Chemical properties. These

                       channels are approximately 35 feet deep. The Ferry Bar Channel
                       provides water access to the northern portion of Fairfield,
                       crossing in an easterly direction above the peninsula's northern

                       face. Two private channels extend to serve the Struever Brothers



                                                    32








                       property, the Toyota Auto Terminal and the Forest Products

                       company. The water depth in this area is consistently deeper than

                       in other areas of the peninsula, averaging roughly 20 feet up to

                       the existing bulkhead.



                       Water depth along the edge of dry land is generally shallow,

                       averaging between 1 and 4 feet at mean low tide. The most

                       extensive shallow areas are located at the mouth of the Patapsco

                       River, within Curtis Creek and along the edges of the FMC

                       property at the southwestern edge of the peninsula. In Curtis

                       Creek the shallow ledge drops off approximately 375 feet from the

                       lands edge, sloping to depths of 15 to 21 feet. Coast Guard maps

                       identify a 1200' x 750' section of land in front of FMC area as a

                       'Spoil Area', with water depth registered at 9 feet m1w. It is

                       not currently known what type of dredge spoil has been placed there.



























                                                    33












              IV. ECONOMIC DEVELOPMENT/FUTURE ENVIRONMENTAL REGULATIONS

                  A.   Growth in the Critical Area


                       1.   General Growth




                       Other than existing industry expansion and modernization and with

                       the exception of four major projects described in the following

                       paragraphs, very little economic development activity has occurred

                       in the Fairfield peninsula's extensive critical areas. All the

                       major chemical and petroleum industries have maintained their

                       status quo. The sole exception is Amoco Oil, encompassing a 60

                       acre site at the southeastern tip of the peninsula. This facility

                       ceased operations as of July, 1990 and is in the process of

                       planning a dismantling and clean-up operation to ready the property

                       for future re-sale or re-use.




                       2.   Port Liberty



                       In 1989, Buffalo Tank sold 31 of its 38 acres to a private

                       developer who is marketing the site as the "Port Liberty Industrial

                       Center." In an agreement with the City not to permit any

                       recreational marina use, the developers hoped to renovate an

                       existing warehouse into office use along with a boat/tug repair and

                       new boat preparation facility on the property. In a recent

                       development, the owners have begun to negotiate with a used oil

                       recycler for the sale of a 20-25 acre parcel in Port Liberty.

                       The recycling operation would process 75 million gallons per year



                                                    34









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         FAIRFIELD AREA STUDY
                                                                                Fig. 8









                      (mgy) of used motor oil brought in from various waste oil

                      generators along the east coast. This operation would lie within

                      the 100 year floodplain but it would be kept out of the 100 foot

                      critical area buffer. The operator suggested that the plant may be

                      expanded to 150 mgy a few years after start up.




                      3.   Masonville




                      In 1987 the Maryland Port Administration (MPA) purchased 60.5 acres

                      of land from the Arundel Corporation to augment its container

                      handling operations. Due to the idle capacity at the new Seagirt

                      Terminal in Dundalk and the overall economic slowdown, MPA has

                      decided not to develop this site for the present time. Although

                      Toyota is utilizing part of the property for its auto import

                      distribution center, no major expansion is anticipated.




                      4.   CSX Coal Terminal




                      In 1983 a coal storage area was built by Island Creek Coal Company

                      on CSX property south of Stonehouse Cove on Curtis Bay. This

                      export terminal can handle up to 12 million tons of coal per year.

                      The coal, used for steam generation, is brought in by 130 car-long

                      unit trains, and is stored in large open piles.



                      5.   Patapsco Wastewater Treatment Plant







                                                   35








                       In 1924, 29 acres of land at the present site of the Patapsco Plant

                       on Wagners Point was purchased for $115,000. Construction began in

                       1937 and a new 10 million gallon per day (mgd) treatment plant

                       began operations in 1940. This plant served the Brooklyn, Curtis
                       Bay and Fairfield communities as well as contiguous areas of Anne

                       Arundel County. Residential and industrial customers alike

                       received central sewer service. The plant was later expanded to

                       treat 14 mgd from an enlarged service area which included
                       portions of Baltimore, Anne Arundel, and Howard counties situated

                       within the Patapsco River Valley.



                       A series of studies and master plans in the late 1950's and 1960's

                       laid the groundwork for the overall planning and design of the
                       present plant. The primary goals were to upgrade the quality of

                       treatment to meet the more stringent water quality requirements for

                       the Chesapeake Bay, and to have sufficient capacity for future

                       growth anticipated in the service area.



                       In June 1985, the new 70 mgd secondary treatment plant was

                       formally dedicated. More than 90 percent of waste water pollutants

                       are now removed from the sewage flowing to the facility. Current

                       construction totalling $4 million is 90 percent complete. This new

                       Chlorination/Dechlorination system is engineered to control

                       discharged levels of residual chlorine and phosphorus entering the
                       Patapsco River, and to keep pace with growth occurring in the
                       service area. The resultant sludge is burned in the plant's

                       incinerators and the ash is buried in the Quarantine Road landfill.



                                                    36








                 B.   Economic Development Strategies for Fairfield

                      1.   General Scope

                      The level of future development in Fairfield will be determined by

                      the size and number of developable parcels that are available. A

                      previous study has identified and inventoried such properties and

                      included them in the City's computerized database of industrial

                      development sites. Also, the study revealed some interesting

                      overall trends affecting industries in Fairfield:

                        o Fairfield's chemical industry is strong presently and is

                           optimistic about the future. This is consistent with national

                           trends, as reported in the 1989 U.S. Industrial Outlook:



                           "The strong market for U.S. chemical products, both at home

                           and abroad, is placing a heavy burden on operating

                           capacities. As a result, the industry is expanding its

                           production facilities. The Bureau of Economic Analysis

                           (BEA) of the Department of Commerce estimates that the

                           chemical industry increased its capital expenditures for new

                           plant and equipment by 11.7 percent in 1988, substantially

                           more than the 8.4 percent increase the industry had planned in

                           1987 to spend in 1988.



                        o  Compliance with environmental regulation is increasingly

                           difficult on companies in Fairfield, since the area is

                           dominated by industries (chemicals and petroleum) that attract

                           close scrutiny by environmental agencies. Almost every

                           company interviewed in these two industries cited the



                                                   37









                            increasing cost of complying with environmental regulations as

                            a major concern.



                         o  The petroleum industry seems gradually to be adopting a

                            strategy in response to environmental regulation. More and

                            more, different companies are consolidating like operations to

                            achieve economies of scale in complying with environmental

                            laws. For example, two petroleum companies, each of which is

                            engaged in both heating oil distribution and asphalt

                            production, may agree that one company will handle all the

                            asphalt and the other handle all of the heating oil. By doing

                            so, each company has only to comply with one set of

                            environmental regs, rather than two. If this consolidation

                            strategy continues, it could render obsolete some existing

                            facilities, creating redevelopment opportunities and an

                            overall improvement in environmental quality. However, the

                            environmental contamination often associated with such

                            operations certainly will limit redevelopment or require

                            additional clean-up costs.




                       2.   Assessment of City Owned Sites



                       The City of Baltimore controls two development sites totalling 25

                       acres that are across from each other on the 1300-1400 blocks of

                       Chesapeake Avenue. Each one is large enough for independent

                       industrial development. Victory Elementary School (closed in June

                       of 1989) sits on a 4.25 acre lot at the northwest corner of



                                                    38









                      Chesapeake and Sun Streets. The one story brick and block building

                      will probably need to be demolished because conversion to

                      industrial use is very unlikely. There is no current knowledge of

                      environmental contamination on the site. The property does not

                      fall within the State's "critical area." An evaluation of the

                      existing structure for asbestos contamination revealed that there

                      is a small quantity in the boiler room and in the ceiling and floor

                      tiles.




                      The second of the City-controlled sites is the 20.8 acre Fairfield

                      Homes public housing project which is located just across

                      Chesapeake Avenue to the southwest of Victory Elementary.

                      Originally constructed in 1942 to provide for wartime housing for

                      workers in the nearby shipbuilding industry, the development has

                      been used as public housing since soon after the war. Federal and

                      City officials decided that rather than invest additional funds for

                      extensive housing repairs, it was best to relocate these families

                      and make the site available to the City for industrial

                      redevelopment. It is expected that all remaining residents will be

                      moved out by the early part of 1991. The entire site will need to

                      be demolished. There are currently no known environmental problems

                      with the Fairfield Homes site. The property does not fall within

                      the Critical Area. The market for industrial land in Fairfield is

                      fairly strong based on information about the local real estate

                      market, and the redevelopment of Victory Elementary School and

                      Fairfield Homes seems promising.






                                                    39










              The most significant potential complication for redevelopment for both sites

              is the stormwater management system because of the flatness of the terrain.

              The Fairfield Homes site is especially complex because the site straddles

              two drainage areas. Sizable drainage pipes are located nearby and can be

              utilized, but parts of the public housing site may have to be filled to

              achieve proper drainage.








                       3.   Old Fairfield City Policy



                       Old Fairfield is a 30 acre residential enclave surrounded by

                       industry. Today only 12 households remain after many years of

                       steady decline. For years, Old Fairfield has posed a dilemma for

                       the City. Although it was zoned for heavy industry, people still

                       lived there. City policy over the years was to resist resident's

                       demands for essential City services. The City's long standing

                       offer to purchase properties from willing sellers has netted the

                       City a "patchwork quilt" of small parcels each of which is too

                       small to develop. The joint study developed by BEDCO and the

                       Planning Department's Economic Development section identified three

                       options for addressing the situations:

                       a.   Designate Old Fairfield an Urban Renewal Area. Under this

                            scenario, the City would seek to bring about the comprehensive

                            and rapid industrial redevelopment of Old Fairfield by using

                            condemnation powers to assemble and then sell off the land.





                                                    40








                       b.   Continue the current gradual approach to land assembly and

                            make limited capital improvements to improve conditions for

                            the residents who remain. Under this scenario, the City would

                            continue to buy voluntarily offered properties as they become

                            available.



                       C.   Sell the parcels that the City has already acquired and leave

                            redevelopment to the buyer. Under this scenario, the City

                            would work to achieve redevelopment of Old Fairfield by

                            enabling a private party to develop the land. The City would

                            draft an RFP document that would outline the City's goals

                            for the area and would evaluate offers based on their

                            compatibility with these goals.



                  C.   New Federal/Local Regulations Regarding the Environment

                       1.   CLEAN AIR ACT AMENDMENTS of 1990




                       The following section of the report provides an overview of the

                       recent Clean Air Act amendments, and briefly discusses changes they

                       will create regarding air pollution controls in the Fairfield area.



                       The current amendments are aimed primarily at Ozone, Volatile

                       Organic Compounds and Nitrogen Oxides. Jurisdictions which exceed

                       EPA standards must comply with new requirements depending on the

                       level of severity of pollution in their area. Baltimore is

                       designated as a Severe Nonattainment area for Ozone





                                                    41









                        contamination. This designation establishes the following

                        requirements:
                        - The State must identify 'Major Sources' of Volatile Organic

                        Chemicals (those firms emitting 25 tpy or more) in the City.

                        - The MDE will require all Major Sources to install Reasonably

                        Available Control Technology (RACT).

                        - The MDE must require offsets at a rate of 1-3:1



                        Regardless of a jurisdiction's Air Quality designation, all sources

                        of VOC must reduce their emissions 15 percent by 1996.



                        Other provisions which may effect industries in Fairfield include

                        additions to the Air Toxic's section of the Act, and requirements

                        for Nitrogen Oxides. The Air Toxic Amendments include a list of

                        189 chemicals which will be added to those already being

                        regulated. Within one year EPA will establish a list of major

                        sources for each chemical. Firms emitting the pollutants will be

                        required to obtain permits similar to the existing process.



                        Nitrogen Oxides- provisions are included for controlling the

                        release of nitrogen oxides from new and existing facilities. These

                        sources are subject to the same technological requirements as those

                        required for VOC.



                        The new Clean Air Act requirements will primarily affect four firms

                        in Fairfield, all of which emit over 25 tpy VOC and Nitrogen





                                                     42









                      Oxides. These firms include FMC, the Patapsco Wastewater

                      Treatment Plant, BP Oil and Mobil Oil.



                      These new requirements mandate the State to adapt tighter controls

                      which will result in a 15% emissions reduction within 6 years and

                      3% annually thereafter until attainment in the year 2007. The

                      requirement to obtain 3% per year emission reductions in the

                      Baltimore area poses a real challenge and will impact these

                      industries financially. The Amendments require States to develop

                      RACT which is an emission limitation for small sources (25

                      tpy). The bottom line is that these industries will have to

                      spend more dollars for pollution control equipment.



                      2.   CLEAN WATER ACT - Amendments to Storm Water Regulations



                      The 1990 Clean Water Act amendments require that all jurisdictions

                      with a population over 250,000 people submit a program to the EPA

                      for monitoring and permitting stormwater outfalls. Rather than

                      submit a large number of individual permits, the regulations allow

                      municipalities to apply for one general permit to cover all

                      outfalls.




                      As part of the permitting process, the City must submit a plan

                      which describes existing facilities, stromwater quality, proposed

                      monitoring programs and the proposed processes for permitting

                      pollutant sources, especially in industrial areas such as Fairfield.





                                                   43








                        As part of the permitting process, the City will establish drainage

                        basins, sample outfalls, and identify the source of any illicit

                        chemicals or substances. This may not be possible in larger

                        watersheds, and the City will probably focus on high pollutant

                        areas such as industrial areas rather than sampling all outfalls.



                        3. Critical Area Habitat Protection Requirements - Baltimore Cit



                        In addition to the existing Critical Area requirements, certain

                        waterfront properties within the study area will be subject to

                        Habitat Protection Plan requirements. (See figure 9.) These
                        additional requirements are proposed as an amendment to the City's

                        CAMP but have not been, as yet, approved by the Chesapeake Bay

                        Critical Area Commission nor have they been formally adopted by the

                        Mayor and City Council.



                        Under terms established by the Chesapeake Bay Critical Area

                        Protection Law and Regulations, Baltimore City is required to

                        prepare and adopt as part of its approved CAMP, special measures to
                        conserve fish, wildlife and habitat where such wildlife is found to

                        exist within the Critical Area. Within the study area, such

                        pockets of wildlife habitat have been identified by various state
                        and federal agencies in two sections of the peninsula. These areas

                        are Masonville and Stonehouse Cove and are described below.

                        (See figure 10.)







                                                     44









                       Masonville - This Habitat Protection Area (HPA) has been

                       identified as a colonial water bird staging and concentration

                       area. The area includes all waters to the mean high water line

                       which lie within the cove formed by the irregular shoreline of 3100

                       Childs Street (Block #7043, Lot #1) and all lands within 100 feet

                       of the mean high water line. In addition, the area includes a

                       100-foot buffer on both sides of the tributary stream which empties

                       into this cove at the south end of the property. This 100-foot

                       buffer shall extend from the north side of Frankfurst Avenue and

                       continue northeast to the point where the stream intersects the

                       Critical Area Buffer.




                       Stonehouse Cove - This HPA has been identified as a colonial

                       water bird roosting and concentration area as well as a waterfowl

                       staging and concentration area. The cove contains vegetated tidal

                       wetlands bordering on upland forested areas. The upper reach of

                       the cove contains an intermittently tidal stream which is heavily

                       vegetated along both banks. The area includes all the waters of

                       the cove extending out into Curtis Creek to a point located

                       approximately 1,750 feet when measured perpendicularly from East

                       Patapsco Avenue. The area also includes all lands within 100 feet

                       of the tidal waters described above and all lands within 50 feet of


                       the intermittently tidal stream extending from the southeast side

                       of the East Patapsco Avenue bridge and continuing upstream to the

                       limits of the Critical Area. In addition to the above, this

                       habitat protection area includes the forested areas along the

                       western side of the cove extending from East Patapsco Avenue and



                                                    45









                       bounded on the west by the access road to the B&O Railroad coal

                       terminal, further extending southward along the access road to a

                       point located approximately 1,000 feet from the intersection of the

                       access road with East Patapsco Avenue and extending diagonally

                       southeast from this point to where it intersects with the 100-foot

                       buffer and then extending to a point along the shoreline situated

                       approximately 1,700 feet from East Patapsco Avenue when measured

                       perpendicularly.



                       Provisions for obtaining variances from the mandatory set-back

                       requirements can be found in the Habitat Protection Plan which may

                       be obtained from the Baltimore City Department of Planning.



































                                                    46




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                                                64
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             IV. Conclusions and Assessment




                 A.   Environmental Goals and Objectives



                      1.   Improve Shoreline - In its present condition, the shoreline

                      around the Fairfield peninsula can use improvement for both

                      commerce and habitat uses. Many of the bulkheaded areas are

                      dilapidated, and many pier structures and dilapidated barges exist

                      along the shoreline, especially in Curtis Creek. Areas that are

                      not bulkheaded can be improved through vegetative plantings and

                      removal of derelict structures. Existing bulkheads can be

                      rehabilitated as properties turn over and are redeveloped. This

                      will reduce navigational hazards and erosion problems.



                      2.   Protect Habitat - Despite the heavy industrial nature of the

                      Fairfield area, some areas of high habitat value exist. It is the

                      goal of this plan to preserve and enhance these areas where

                      feasible.




                      3.   Encourage buffers/wildlife corridors - Existing wildlife

                      habitat can be greatly served by creation of a corridor/buffer

                      system throughout the peninsula. This type of system is not

                      difficult to implement if guidelines are built into existing

                      development restrictions. Such corridors and buffers can serve the

                      dual use of increasing habitat values while also improving water

                      quality and drainage.



                                                   47









                        4.   Improve quality of storm water run off - The historical

                        industrial uses on the Fairfield peninsula have created a situation

                        where soil compaction and contamination cause pollution problems in

                        stormwater runoff. Through the use of a buffer and naturalized

                        drainage system, as well as the EPA stormwater regulations, it is

                        hoped that stormwater quality can be improved.



                        5.   Remove discharges except Patapsco's WWTP - As part of the

                        effort to improve water quality around the Fairfield peninsula, all

                        existing NPDES discharges should be tied into the City's

                        Pretreatment program, where feasible.



                        6.   Improve Patapsco's discharge - The current discharge from

                        the Patapsco WWTP occasionally violates NPDES permit

                        requirements because of excess chlorine, or high Coliform counts

                        during storm flows. Planned expansion of capacity, improved

                        treatment operations and construction of a dechlorination plant

                        will all help to improve effluent discharge.



                        7.   Use Offset funds to improve specific areas - Offset funds are

                        available to complete specific projects for wetlands creation and

                        habitat improvements, which will be discussed in more detail in the

                        following section.



                  B.    Findings - Potential Measures for Environmental Improvement



                        1.   Changes to Zoning



                                                    48








                       Although land use controls via zoning are a viable means of

                       protecting the environment, it can also unduly limit the potential

                       growth of existing businesses. This section of the report examines

                       alternative land use controls for Fairfield by first describing the

                       existing zoning and then describing the existing land use pattern.

                       Finally, four alternatives for industrial land use control are

                       explored. All of the industrial land in Fairfield is zoned M-3 for

                       heavy industry which is the most permissive type of industrial

                       development. (See figure 11.)    Land use in Fairfield can be

                       described in terms of three subareas. The southern part of

                       Fairfield is the most heavily developed and has mostly M-3 uses.

                       In this area, east of Shell Road and south of Chesapeake Avenue,

                       almost all the land is used for manufacturing chemicals,

                       distributing petroleum, or producing asphalt.



                       The northern part of Fairfield, north of Frankfurst Avenue, has

                       large non-M-3 uses such as an automobile import/export marine

                       terminal and large outdoor storage lots for automobiles and lumber

                       (M-2 and M-1 uses). This part of Fairfield also contains the

                       Buffalo Tank manufacturing plant and Port Liberty, a multi-tenant

                       industrial redevelopment project.



                       The west-centrol part of Fairfield, between Frankfurst Avenue and

                       Chesapeake Avenue, has a mixture of small M-3 and M-2 uses and the

                       Old Fairfield residential community. In the western most part of

                       this subarea, west of Sun Street, is a number of medium sized

                       vacant parcels among a group of M-2 businesses. The City owns two



                                                    49








                        vacant sites here, the former Victory Elementary School (4-25

                        acres) and the former Fairfield Homes public housing project (20

                        acres). The general character of this part of Fairfield as

                        currently developed is less intense than a typical M-3 area.



                        The general purpose of zoning is to assure land use compatibility

                        within a zone and between adjacent zones. However, to respect the

                        rights of existing land uses and to meet public economic growth

                        objectives, zoning cannot ignore the long established pattern of

                        land use. There are several alternatives within the zoning code

                        which could be used to address problems resulting from industrial

                        development:

                        (1) changing to a less intensive industrial zoning category; for

                        example, from M-3 to M-2;

                        (2) changing the definition of permitted uses within the existing

                        category; for example, eliminating some uses in M-3 or M-2 (this
                        alternative may involve the formation of a new zoning category);

                        (3) changing which uses are conditional in existing zoning

                        categories;

                        (4) creating performance standards for certain uses. Land use

                        control changes such as these are now being explored by a task

                        force representing area community, industry, city, and State

                        officials.



                        2.   Suggested Places to Use Offset Funds

                        The Fairfield Peninsula contains two significant waterfowl staging

                        and concentration areas - Masonville and Stonehouse Cove.



                                                     50





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        FAIRFIELD AREA                                                        TUDY
                   r IN 15000                 Fig. 11









                       The Masonville Cove has significant habitat for wintering

                       waterfowl. The upland portion of the site has habitat attractive

                       to field species with significant potential for enhancement. The

                       site was created with dredge spoil and so the soils are extremely

                       acidic which would need to be addressed in any enhancement plan. A

                       significant part of the 70 acre tidal marsh is vegetated with

                       Phragmites which has limited habitat value.



                       The natural shoreline along parts of Curtis Creek are important

                       habitat for wintering waterfowl, wading birds, gulls, migrant

                       waterfowl, cormorants and grebes. In particular, Stonehouse

                       Cove has attractive wetlands with shore-wide vegetation for

                       roosting.



                       Due to the limited availability of funds, only one of these areas

                       is likely to receive financial assistance to examine future

                       enhancement potential and protection. Since the proposed

                       development for Masonville has been postponed for the present

                       time, it is suggested that efforts be directed to Stonehouse Cove

                       and the intermittent stream which flows into it. As part of this

                       overall assessment, it is recommended that the feasibility of

                       establishing a greenway link with Masonville be evaluated.



                       Linkage is an important variable in habitat areas. Habitat areas

                       which are either adjacent to each other or connected by a corridor

                       will have greater value to wildlife than Isolated patches. Streams

                       are a strong determinant in the linkage of habitat areas. The



                                                    51










                        intermittent stream may serve as a convenient means to establish a

                        greenway corridor in the Fairfield peninsula.



                        In addition to the on-site mitigation expected to be driven by new

                        development and redevelopment, the City will be working with

                        property owners who wish to use portions of their shore line for

                        enhanced vegetation as a means of achieving overall water quality

                        and wildlife improvements. The City is committed to using offset

                        funds derived from elsewhere or development projects to match the

                        efforts of private property owners to improve shoreline

                        conditions. The City is also prepared to negotiate conservation

                        easements with cooperating property owners to provide property tax

                        relief and to insure that revegetated portions of the City's

                        shoreline remain forever green.



                        3.   Use of Critical Area regulations and Habitat Protection

                        Program to enforce/encourage needed changes



                        The Maryland State Critical Area Law has established criteria for

                        the protection of eleven resource areas within the Critical Area.

                        The State law defines each of these areas and establishes


                        guidelines for protection. The Baltimore City Habitat Protection

                        Program identifies and locates each of these habitat areas which

                        exists in Baltimore City, establishing protection policies for each.



                        Virtually all of the natural habitat of Baltimore City's Critical

                        Area has been disturbed within the past century. For the majority



                                                     52








                      of the land area, shoreline habitat (84%) has been completely

                      removed and replaced with paved surfaces, bulkheading, filling,

                      rip-rap, or concrete rubble. Relatively small pockets of vegetated

                      open space comprised of various stages of secondary growth and

                      wetlands still exist and serve to support wildlife species.



                      The Critical Area Commission favors and encourages non-structural

                      shore-erosion control measures only be used in areas where wave

                      conditions permit.

                      Shoreline conditions will be taken into consideration whenever a

                      it significant" development project is subject to Critical Area

                      findings. New development or redevelopment that is undertaken

                      along the shoreline will be required to specify whether new or

                      replacement shoreline protection is contemplated. Bulkheading

                      will be allowed for water-dependent uses that expect to tie vessels

                      up to the shoreline, or in the Waterfront Revitalization Area,

                      where necessary for public safety or boat access. All other uses

                      will be required to use stone revetment or vegetative

                      stabilization, with a preference for the latter. The lower cost of

                      vegetative stabilization and the presence of viable examples

                      throughout the Chesapeake Bay area should assure that this method

                      is used more often.




                      The open spaces within the Critical Area include approximately 70

                      acres of high and low marsh habitat in Masonville and a 5 acre

                      undeveloped wooded lot adjacent to and east of Fairfield Homes.





                                                   53








                       Baltimore City has identified the presence of two general

                       categories of habitats in Fairfield as established in COMAR

                       14.15.09 and they are the Critical Area 100-foot buffer and

                       historic waterfowl staging and concentration areas. The City is

                       proposing that these areas be designated as Habitat Protection

                       Areas (HPA) and that the following protective measures be adopted

                       to protect these areas from the adverse impact of development.


                       Proposed Protection Requirements for Designated HPA's



                       The following protection measures are proposed to protect these

                       areas from the adverse impacts of development.



                       1.   A 100 foot buffer along vegetated tidal wetlands (shoreline)

                            and greenway corridors.

                       2.   A 50 foot buffer along intermittently tidal tributaries and


                            streams.

                       3.   A 25 foot buffer along non-tidal wetlands and streams.

                       4.   An expanded buffer area on selected parks and floodplain areas.

                       5.   An expanded buffer to include adjacent wooded areas where

                            woodlands are an integral part of the habitat of the buffer


                            area.




                       Habitat Protection Areas havinit sixnificant veizetation










                                                     54









                      In those designated habitat protection areas where the Director of

                      Planning determines that significant vegetation already exists,

                      there will be no disturbance of these areas.




                      In the event these restrictions would result in unwarranted

                      hardship to a property owner owing to special features of the site

                      or other circumstances, the property owner may file an appeal with

                      the Board of Municipal and Zoning Appeals for the grant of a

                      variance from the provisions set forth in the Critical Area

                      Management Program. The grant of such a program variance will be

                      subject to the conditions as established in Section 3C.2-2 of the

                      Zoning Ordinance of Baltimore City. The grant of such a program

                      variance is further conditioned upon certification by the Director

                      of Planning for Baltimore City that the proposed development could

                      not be located elsewhere on the property and that the development

                      activity is limited to the absolute minimum required for the

                      development.




                      Habitat Protection Area not having significant vegetation



                      In those portions of designated habitat protection areas where the

                      Director of Planning determines that no significant vegetation

                      exists , the developer may encroach upon the habitat protection area

                      providing that all the conditions set forth below are met.



                      Any proposed encroachment upon a designated HPA not having

                      significant vegetation will require that a zoning appeal be filed



                                                   55









                       with the Board of Municipal and Zoning Appeals for a conditional

                       use. The grant of a conditional use will require the developer to

                       demonstrate that the proposed development could not be located

                       elsewhere on the property and that the development activity is

                       limited to the absolute minimum required for the development as

                       determined by the Director of Planning for Baltimore City.



                       In order for the Director of Planning to certify for the Board that

                       the above conditions have been met and that the proposed

                       development will not adversely affect the Habitat Protection Area,

                       the developer must first prepare a habitat assessment and a

                       mitigation plan for the development site as explained below.



                       Habitat Assessment



                       Where a proposed development project has requested a variance from

                       the provisions set forth in the Critical Area Management Program,

                       the developer will be required to perform a habitat assessment of

                       the site to determine the impact of the proposed development on the

                       protected habitat located on or adjacent to the development site.

                       Any such assessment will be subject to field investigations and

                       other verification methods as determined by the department of

                       Planning.



                       The habitat assessment requirements and field survey form will be
                       published as an appendix to the City's Critical Area Development

                       Manual.




                                                    56










                       Mitigation




                       In addition, the grant of a program variance will require the

                       developer to provide appropriate environmental mitigation on a 1:1

                       basis. Any such mitigation for developing in or near a designated

                       habitat protection area is subject to the prior approval of the

                       Department of Planning.




                       Tree Replacement Requirement



                       Within the Critical Area of Baltimore City, any tree of a 4"

                       caliper or larger that is cut, removed or destroyed by a

                       development activity must be replaced and maintained by the

                       property owner. Replacement of all such trees shall be on a 1:1

                       basis where the combined total caliper of the replacement trees

                       equals the combined total caliper of the trees displaced. Any

                       trees cut, removed or destroyed without prior approval must be

                       replaced and maintained on a 2:1 basis.



                       Any tree replacement plan or reforestation program undertaken for

                       mitigation purposes must have the prior written approval of the

                       Director of Planning for Baltimore City. No occupancy permit shall

                       be issued until the tree replacement or reforestation program has

                       been completed or until an escrow account or, non-revocable

                       letter of credit has been established in the name of Major and City

                       Council. This account has be for an amount equal to the total

                       estimated costs of the tree replacement reforestation program plus



                                                   57








                        40% for contingencies and project management fees in the event the

                        developer fails to implement the plan.



                        4.   Stormwater Changes



                        Urban streets contain many toxic contaminants (non-point source
                        pollution) which enter streams during a storm's peak, and this

                        pollution poses a serious detriment to wildlife.



                        Motor vehicles are primarily responsible for depositing substantial

                        quantitites of materials on roadways, including significant
                        levels of toxic heavy metals, asbestos, and slowly biodegradable

                        petroleum products and rubber. Runoff from urban roadways induces

                        a shock effect upon the receiving waters and the biota of these

                        waters as the accumulated nutrients and toxic and oxygen-demanding

                        substances are introduced abruptly during a storm.



                        A few potential solutions for reducing these shock loads may

                        include the following:



                        (a) select roadway sites so as to minimize the area draining

                             directly into the receiving body of water;

                        (b)  utilize low curbs when the road is adjacent to flat, unpaved

                             areas or areas that slope gently away from the street

                             surface. This will facilitate the deposition of the dust and

                             dirt into grass and gravel areas and reduce the rate of

                             deposition in runoff water;



                                                     58








                      (c) consider the use of porous pavement in areas where the soil

                           type permits it;

                      (d)  intensify and improve street-cleaning operations to reduce

                           urban roadway runoff effects;

                      (e)  design curbs and gutters to facilitate concentration and

                           collection of particulate material;

                      (f)  investigate various approaches to detention and storage of

                           storm runoff and separation of solids from stormwater.











































                                                   59



























                                       APPENDIX 1







                                 1. The Clean Air Act







                                 2. The Clean Water Act






                                 3. The Permit Program and Enforcement





                                 4. Resource Conservation and Recovery Act (RCRA)





                                 5. Superfund Amendments Reauthorization Act

                                      (SARA, 1986)












                                                   60













                      The Clean Air Act




                      The major goals of the Clean Air Act are to identify air pollutants

                      that could endanger public health and welfare, to describe the

                      potential effects of these pollutants at varying levels, and to

                      establish "control techniques" to achieve and maintain appropriate

                      ambient air quality standards.



                      The Clean Air Act's complex processes are primarily focused upon

                      the setting, attainment, and maintenance of National Ambient Air

                      Quality Standards (NAAQS). "Ambient air" has been defined by EPA

                      as It that portion of the atmosphere external to buildings, to which

                      the general public has access."



                      According to the Act, EPA is responsible for

                      1. Identifying air pollutants which endanger public health or

                      welfare,

                      2. Issuing scientific "air quality criteria" describing the effects

                      expected on public health from the presence of such pollutants in

                      the ambient air) and

                      3. Publishing "control techniques" for the pollutants.



                      EPA is required to promulgate primary and secondary NNAQS for

                      these air pollutants.







                                                   61









                        The Clean Air Act requires states (through State Implementation

                        Plans) to classify areas by pollutant into (1) those areas that

                        fail to meet primary or secondary ambient air quality standards,

                        (2) those that cannot be classified due to insufficient data or

                        information, and (3) those that have ambient air quality levels

                        better than any national primary or secondary ambient air quality

                        standard.




                        SIPs must also include emission limits, schedules of compliance,

                        preconstruction review of direct sources and the Prevention of

                        Significant Deterioration (PSD).



                        Activities Requiring Permits: Major Stationary Sources and Major

                        Modifications to existing sources are regulated under the permit

                        requirements. The program requires that prior to the commencement

                        of construction of any major stationary source or major

                        modification of such a source, a permit must be obtained for the

                        source or modification after undergoing preconstruction review,

                        which involves impact and technology analyses and an opportunity

                        for public hearing.



                        The PSD regulations generally define a "major stationary source"

                        as (1) any one of 28 listed industrial sources that emit or have
                        the "potential to emit" 100 tons per year or more of any pollutant
                        regulated under the Act, and (2) any other stationary source that

                        emits or has the potential to emit 250 tons a year or more of any

                        pollutant regulated under the Act.



                                                     62








                      A "major modification" is defined as "any physical change in or

                      change in the method of operation of a major stationary source that

                      would result in a significant net emissions increase of any

                      pollutant subject to regulation under the Act."














































                                                   63















                   2.  The Clean Water Act




                       Congress enacted the Water Quality Act of 1987 reauthorizing the

                       Clean Water Act. The new act extends deadlines for industry

                       compliance, amends the storm water permit program for industry

                       plants, and establishes administrative penalties for noncompliance.



                       It also sets schedules for State compliance with the reduction of

                       toxic discharge into streams and increases the penalties for civil

                       and criminal violations of the Act.




                       The Safe Drinking Water Act of 1986 requires EPA to set standards

                       for 83 chemicals within three years of enactment. The Act also

                       provides for ground water protection around public wells.



                       Under the Clean Water Act, the EPA or approved state agencies

                       regulate the out of pipe discharges of pollutants into U.S.

                       waters. Every discharger must obtain a permit and comply with

                       technology-based or water quality-based standards.



                       The primary federal law governing water pollution control is

                       contained in the Clean Water Act, also known as the Federal Water

                       Pollution Control Act (FWPCA). The Act authorizes federal and

                       state control of pollutant discharges into waters of the United

                       States (direct discharges) and of pollutants into sewer systems





                                                    64









                      (indirect discharges). These controls are established and enforced

                      through permits and regulations.



                      There are two basic regulatory controls on discharges within the

                      Clean Water Act: water quality-based requirements and

                      technology-based requirements.



                      Technology based requirements are designed to reflect the levels of

                      effluent quality achievable through the use of pollution control

                      technology. All existing dischargers of toxic pollutants are

                      generally required to meet limits based on the "best available

                      control technology" (BAT). There are also technology-based

                      standards for discharges to municipal sewer systems.



                      Water quality requirements consist of a set of rules designed to

                      achieve a given level of quality for natural body of water. They

                      are based on scientific information. Water quality standards are

                      adopted by the states and submitted to EPA for approval. The water

                      quality standards for different waters may vary depending on their

                      uses and local conditions.























                                                   65











                  3.    The Permit Projzram and Enforcement



                        A person responsible for a "discharge of pollutants" into any water
                        of the United States from a point source is subject to various
                        provisions of the Act. The key requirement is to obtain and comply
                        with a permit under the national pollution discharge elimination
                        system (NPDES) program pursuant to Section 402 of the Act.

                        Permits must be obtained from the MDE Section. NPDES permits
                        apply the technology and water quality-based requirements of the
                        Act to a particular discharger. Permits also contain schedules of
                        compliance, monitoring obligations, and reporting requirements.

                        Permits may be issued for a term of up to five years.



                        Discharges without a permit and violations of permit conditions are
                        subject to federal and state and civil and criminal penalties and

                        citizen suits.



                        The state of Maryland assisted by EPA water quality criteria, has

                        the primary role in establishing water quality standards to protect

                        the uses of a particular body of water. NPDES permits are
                        granted on the condition that state water quality standards will be
                        met. When a discharge would interfere with state standard, water

                        quality-based effluent limits on appropriate pollutants or
                        toxicity-based effluent limits may be established.








                                                     66









                       The NPDES permit program is the backbone of the Clean Water Act.

                       Every discharger must apply for and obtain a permit. The function

                       of a permit is to define a discharger's obligations.



                       As part of its enforcement authority under the Act, EPA can require

                       permittees to monitor and report their discharges and may enter

                       the discharger's premises to inspect and confirm those reports.



                       Discharges may opt to enter into a pretreatment program rather

                       than obtaining a NPDES permit. Rather than releasing effluent

                       directly to the water body, dischargers ties into the STP

                       system. If the firm is permitted to do this, they are required to

                       'Pre-Treat' the effluent to remove hazardous substances before


                       releasing it to the STP. Both the Back River and Patapsco STP

                       receive treated industrial wastes. The City of Baltimore operates

                       a local pre-treatment program. The pretreatment program sets

                       acceptable levels of pollutants for effluent, and establishes a

                       series of fines which can be levied if violations occur.




























                                                    67










                  4.    Resource Conservation and Recovery Act (RCRA)



                        Through the Resource Conservation and Recovery Act EPA has

                        established a comprehensive program for the management of hazardous

                        waste. The original law, passed in 1976, established a

                        comprehensive program for the cradle to grave management and

                        tracking of hazardous wastes. Waste generators and haulers must

                        complete a manifest which accompanies the waste to its final

                        destination, and documents its disposal. Firms are permitted a

                        grace period in which they can store hazardous waste without

                        needing to receive a RCRA permit. The waste must be removed

                        within the time limit of the grace period. Also, if firms store

                        less than 100 kilograms of waste on their site they are not subject

                        to RCRA regulations.



                        The Resource Conservation and Recovery Act, passed in 1984,

                        provides for: a ban on land disposal of hazardous waste in sties

                        where the substances will migrate, deadlines for Congressional

                        mandated decisions regardless of EPA action, more stringent

                        standards for handling and disposal of hazardous material, a

                        deadline for EPA decisions on adding substances to the hazardous

                        materials list, Criteria making it more difficult for EPA to remove

                        chemicals from the list, and regulatory standards and controls for

                        underground storage tanks.



                        Through the RCRA legislation the EPA was charged with

                        establishing a definition of those items which constitute hazardous



                                                     68






   I




                      waste, and procedural rules for the treatment, storage and disposal
                      of the waste.                                                                    1
                                                                                                       1
                                                                                                       1
                                                                                                       i
                                                                                                       I

                                                                                                       I

































































                                                     69









                  5.   Superfund Amendments Reauthorization Act (SARA, 1986)



                       The Superfund Amendments and Reauthorization Act of 1986

                       established a 5-year $8.5 billion fund to pay for the continued

                       cleanup of hazardous waste sites. The Act includes provisions for

                       citizen litigation to compel compliance. It also extends the

                       doctrine of strict, and joint and several liability to encompass

                       all federal agencies.



                       The Superfund Amendments Reauthorization Act contains specific

                       requirements in Title III, Section 312 which require that firms
                       producing, using or storing hazardous materials notify State and

                       local emergency management and health agencies. To gain an

                       understanding of the types of hazardous waste stored in Fairfield,

                       this data was compiled and placed in Table 4. Firms which store

                       wastes on site include Delta Chemical' Mobil Oil, Essex

                       Industrial Chemicals, Amoco, FMC Corporation, Vista Chemical, Air

                       Products & Chemicals, and Alcolac. Some of the most common items

                       stored included gasoline, Chlorine, Sulfuric Acid and Hydrochloric

                       Acid.























                                                    70






   I






                                          APPENDIX II




                                     Baltimore City Critical

                                  Area Management Program (CAMP)













                                           Section III


                                    Development Requirements







































                                                    71











                                              SECTION III




                                        DEVELOPMENT REQUIREMENTS





              The Chesapeake Bay Critical Area Law requires each local jurisdiction to
              include, as part of its local management program, provisions to guide and
              restrict new development and redevelopment ("development" hereinafter) in
              such a way as to minimize stormwater runoff pollution and to preserve and

              enhance natural habitat within the Critical Area. This Section summarizes

              the requirements that must be met by development projects. Details about
              these requirements and the review process can be found in the Critical Area

              Development Manual and the Stormwater Management Design Manual.



              A. Public Actions   That Trigger Critical Area Review



                   Development in the Critical Area will be subject to Critical Area review

                   only when, and at each time that, the development activity requires one

                   or more of the public actions listed below:




                   1.   Subdivision


                   2.   Rezoning

                   3.   Zoning Variance

                   4.   Conditional Use or Special Exception

                   5.   Building Permit within the Buffer
                   6.   Building Permit outside the Buffer which has not been granted an

                        exemption from Stormwater Management requirements.



                                                     72










              B. When Is A Development Project Subject To Critical Area Development


                   Requirements?




                   Once the Critical Area review process has been triggered by one of the

                   above public actions, the project will be evaluated by the Department of

                   Planning to determine whether the proposed development is "significant

                   development," so as to be subject to the provisions set forth herein.



                   Significant development is defined as development which would: 1)

                   meet or exceed 50% of the assessed value of the property, or 2) result

                   in a disturbance to land within the Buffer by 5,000 square feet, or 3)

                   result in a disturbance to land within the Critical Area by 10,000

                   square feet.




                   Although development requirements for meeting the Critical Area

                   provisions will vary from area to area, only significant development

                   will be subject to the requirements outlined in Section III.C and III.D


                   below.




              C. General Requirements:




                   1.   Baltimore City Code Requirements




                        All development located in the Critical Area shall comply with the

                        applicable provisions of the City Code (1983 Replacement Volume, as

                        amended) as follows:






                                                       73









                             (a) Article 26, Sections 117-139 - Stormwater Management

                        (formerly Ordinance 1130 - see Appendix H-2).



                             (b) Article 30, Chapter 3C - Critical Area Overlay District

                        Ordinance (formerly Ordinance 1132 - see Appendix H-3).



                             (c) Article 32, Section 521.0 - Chesapeake Bay Critical Area

                        Development - Building Code (formerly Ordinance 1131 - see

                        Appendix H-4).




                   2.   CAMP Requirements




                        All development located in the Critical Area shall reduce the

                        post-development pollutant loading to 90% or less than the

                        pre-development loading. Developers are encouraged to meet the

                        10% runoff pollution reduction requirement on-site whenever the

                        City determines it is practical and feasible.



                        Developers are encouraged to avoid development within the

                        Buiffer, particularly when such development would result in an

                        increase in the amount of impervious surface within the Buffer.

                        Throughout the City's Critical Area, developers will be required to

                        replace existing vegetation disturbed by development and to correct

                        any shore erosion problems. All development proposed for any

                        portion of the Buffer must be granted a Buffer exemption as

                        required by the Criticla Area REgulations (COMAR

                        14.15.09.01C(8)). Such exemptions may be granted by the City



                                                     74









                        providing that it can be sufficiently demonstrated the existing

                        conditions preclude a naturally vegetated Buffer and provided that

                        the developer agrees to an appropriate offset as described in

                        Section IV, so that water quality and habitat objectives can be met

                        elsewhere in the City's Critical Area.



                   These general requirements are in addition to the requirements listed

                   below.




              D.   Requirements By Development Area



                   The Critical Area legislation requires the City to designate sub-areas

                   within its Critical Area and to propose guidelines and restrictions to

                   govern development within each. Accordingly, specific development

                   requirements, according to the project's location within the City's

                   Critical Area, are set forth as follows:




                   I.   Waterfront Revitalization Area




                        (a) Requirements for Runoff Pollution Reduction: The developer

                              is required to meet the 10% runoff pollution reduction

                              requirement for stormwater. This reduction may be

                              accomplished on-site either by installing an adequate

                              stormwater management system or by restoring vegetation on a

                              portion of the site as specified in ARticle 26 of the

                              Baltimore City Code and the Storawater Management Design

                              Manual. These requirements shall be met on-site unless it



                                                       75








                             would be infeasible due to site conditions. The developer is

                             required to offset for any remaining pollution reduction to

                             meet the 10% standard.



                             Requirements for Buffer Establishment: A developer who
                             encroaches upon the Buffer is required to apply for a Buffer
                             exemption (see the Critical Area Development Manual). The
                             developer is encouraged to plant vegetation on as much of the
                             Buffer (i.e., total land area within the site which lies 100

                             feet or less from mean high tide, exclusive of the promeade

                             easement) as possible. Properly vegetated areas within the
                             Buffer portion of the site may be counted against the
                             developer's Buffer establishment requirement (see Appendix

                             A). In addition, porperly vegeted areas outside the
                             Buffer may be credited toward the Buffer requirement provided
                             they are contiguous to vegetated areas within the Buffer and

                             are no less than 25 feet in width.



                             The developer is required to contribute to the Buffer Offset
                             Fund or otherwise offset for any portion of the Buffer which
                             is not vegetated in an approved manner. All privately owned

                             lands within the Buffer for which the developer agrees to
                             grant a public access easement are excluded from this
                             requirement. Thus, the portion of any site which has been
                             dedicated for the public promenade or access to the promenade

                             will be excluded when calculating the net Buffer land areas
                             for a given development site (i.e., 100 feet back from the


                                                     76








                           water's edge, minus the promenade easement, as shown in Figure

                           8)




                 2.   Waterfront Industrial Area




                      (a) Requirements for Runoff Pollution Reduction: The developer

                           is required to meet the 10% runoff pollution reduction

                           requirement for stormwater. The reduction may be accomplished

                           on-site either by installing an adequate stormwater management

                           system or by restoring vegetation on a portion of the site as

                           specified in Article 26 of the Baltimore City Code and the

                           Stormwater Management Design Manual. The requirements shall

                           be met on-site unless it would be infeasible due to site


                           conditions. The developer is required to offset for any

                           remaining pollution reduction required to meet the 10%

                           standard.




                      (b)  Requirements for Buffer Establishment: Critical Area

                           requirements for significant development which has been

                           granted a Buffer exemption vary depending on whether the

                           development activity is proposed for a water-dependent or a

                           non-water-dependent use.



                            (i) Development Within the Buffer for a Water-Dependent Use

                                Development within the Buffer of the designated

                                Waterfront Industrial Area for a water-dependent use

                                requires that the developer offset onl for the land



                                                   77











                                 area within the Buffer which has been disturbed for new

                                 construction or paving associated with the

                                 water-dependent use. The developer is required to

                                 compensate (either on-site or through the offset program)

                                 for any existing vegetation disturbed by the development

                                 and to correct any shore erosion problems.



                                 As an alternative offset for disturbance to land in the

                                 Buffer, the developer may elect to increase the runoff

                                 pollution reduction requirement to 20% or more for the

                                 entire Buffer on the site. The 10% reduction requirement

                                 will be applied to the remainder of the site.



                           (ii)  Development Within the Buffer for a Non-Water-

                                 Dependent Use




                                 Development within the Buffer of the designated

                                 Waterfront Industrial Area for a non-water-dependent

                                 use is limited to 50% of the total Buffer area. Whenever


                                 a developer uses any portion of the Buffer as part of a

                                 significant development, the developer has the option

                                 of: 1) vegetating on-site so that 50% of the total

                                 Buffer area is established in vegetation in an approved

                                 manner, or 2) contributing to the Buffer Offset Fund an

                                 amount equal to the total Buffer area of the site which

                                 is not vegetated. In addition, the developer is required

                                 to further compensate (either on-site or through the



                                                    78









                                offset program) for any vegetation disturbed by

                                development and to correct any shore erosion problems.



                            Significant development outside the Buffer is required to

                            meet runoff pollution reduction requirements but not Buffer

                            requirements, unless the proposed development disturbs

                            existing vegetation and/or the site has shore erosion problems

                            (see Sections III.A and III.C).



                            In hardship cases, where the Buffer comprises 15% or more of

                            the entire development site, the developer is allowed to

                            develop within the Buffer providing that he or she offsets for

                            the portion of the Buffer disturbed by such development.




                      (c)   Additional Provision:

                            Within the Waterfront Industrial Area, total liability for

                            Buffer offsets shall not exceed 2% of the cost of the proposed

                            development.




                 3.   Resource Conservation Areas




                       (a) Requirements for Development Outside the Buffer: Any

                            significant development outside the Buffer shall be limited to

                            open space and public recreational, cultural and educational

                            facilities. Any significant development outside the Buffer

                            which results in a vegetated area having habitat value being

                            disturbed by an impervious surface requires an offset for the



                                                    79









                            total vegetated area displaced by such development. In

                            addition, the developer is required to meet the 10% runoff

                            pollution reduction requirement for stormwater. In no case

                            may the overall acreage of forest or woodland within these

                            areas be decreased by such development.



                       (b)  Requirements for Development Within the Buffer: Development

                            within the Buffer of the Resource Conservation Areas which has

                            been granted a Buffer exemption is limited to water-dependent

                            facilities for public use. The developer is required to

                            offset for twice the total Buffer area disturbed by

                            development in addition to meeting the 10% runoff pollution

                            reduction requirement for stormwater.



              E. Buffer Establishment Credit for Vegetation Planted Outside The


                  Buffer




                  New vegetation planted outside the Buffer may be credited toward

                  development requirements for vegetation within the Buffer provided

                  that: 1) vegetation planted outside the Buffer is at least 25 feet in

                  width and, 2) it is contiguous to existing or planned vegetation within

                  the Buffer, and 3) existing or planned vegetation within the Buffer

                  includes at least 50 linear feet along the shoreline for the entire

                  depth of the Buffer, and 4) the planting plan receives prior City

                  approval.



              F. Future Development




                                                    80









                 Any subsequent redevelopment of a site already assessed an offset fee

                 for either the 10% runoff pollution reduction requirement or the Buffer

                 establishment requirement will require additional Critical Area review

                 if the further redevelopment is determined to be significant

                 development. Such additional redevelopment may require further offsets

                 if the redevelopment increases impervious surfaces or displaces

                 vegetation originally approved as part of a Critical Area determination.




             G.  Grandfatherin




                 All existing structures and operations, including bulkheads and piers,

                 located within the Critical Area may be maintained for existing uses

                 without having to comply with Critical Area requirements, provided that

                 these land uses are lawful under current zoning regulations and do not

                 constitute significant development.



                 All building permit applications submitted in acceptable form before

                 January 4, 1988, the effective date of the Ordinances implementing this

                 CAMP, are excluded from meeting the requirements of this CAMP. Those

                 projects receiving subdivision, rezoning, zoning variance, special

                 exception or conditional use approval prior to the effective date of

                 this CAMP are bound only by those requirements in place at the time of

                 application for building permits.




             H. Offsets for Certain Public Uses










                                                   81








                  Baltimore City plans a number of parks, educational and cultural

                  facilities within the Critical Area and some, especially the promenade,
                  will need exemption from the Buffer requirements of the Criteria under
                  Section 14.15.09.C(8). These areas are highly urbanized and are served
                  by storm drains. The establishment of a naturally vegetated Buffer
                  would not fulfill the functions of the Buffer as stated in the Criteria.



                  Baltimore City maintains a policy of requiring waterfront developers to
                  provide a pedestrian easement located from the harbor water's edge,
                  typically 20 feet landward in the Waterfront Revitalization Area. This
                  easement generally consists of twelve feet of pavement at the water's
                  edge and an eight foot planting bed. Cultural and educational
                  facilities will also need paved plaza areas to accommodate pedestrian
                  traffic, and due to the size of configuration of the site, reduced areas
                  maybe available for planting. In conformance with the spirit of the
                  Critical Area Management Program, developers and the City will be
                  required to mitigate for the water quality impacts of impervious
                  surfaces and provide habitat to the extent appropriate in these areas.
                  The requirements detailed in Appendix G will serve as the offset for the
                  exemption requested for constructing the promenade, parks, and other
                  educational and cultural facilities in the Buffer. In addition, these

                  facilities will provide educational and public awareness programming

                  which fulfills other Critical Area objectives as stated in the

                  Regulations.










                                                     82






   I     i.





















                                          APPENDIX III




                                     Summary of the Clean Air

                                     Act Amendments of 1990




















































                                                    83









               In general, the bill incorporates the provisions of the House version of
               Title I, with two exceptions that concern NOx Controls and Fees from
               Federal Facilities. The bill includes the House provisions for controlling
               nitrogen oxides from new and existing facilities which subject such sources
               to the same requirements as major stationary sources of volatile organic
               compounds but adds a provision allowing states to opt out of or opt down
               from the requirement if excess emissions will result. With respect to the
               fee provisions, the bill treats federal sources the same as other sources.
               In addition, some technical adjustments were made to certain provisions of

               the House proposal.



               Ozone nonattainment areas are classified into one of five categories;
               marginal, moderate, serious, severe and extreme. These classifications are
               based on the degree to which they exceed the ozone standard. Deadlines are
               extended providing from three to twenty years to reach attainment (one
               two-year deadline extension may be granted). States may voluntarily

               reclassify areas into higher categories.



               All but moderate nonattainment areas are required to reduce volatile
               organic compounds by 15 percent within six years. No credit is given for
               reductions resulting from exhaust/evaporative emission regulations
               promulgated prior to January 1, 1990, gasoline volatility programs, measures
               taken to correct a SIP or implementation of a previously required I/M
               program. After the initial six years, serious, severe and extreme
               nonattainment areas are required to achieve a 3-percent annual reduction
               in volatile organic compounds or oxides of nitrogen; a waiver or


                                                     84









             modification of this requirement may be allowed if a 3-percent reduction is

             technologically infeasible.



             A Northeast Transport Region has been established to include Connecticut,

             Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New

             York, Pennsylvania, Rhode Island, Vermont, the District of Columbia and

             northern Virginia (the DC metropolitan area). All areas included in a

             region (including those in attainment) are required, at a minimum, to meet

             the requirements for moderate ozone nonattainment areas, regulate sources

             emitting 50 tons per year or more, adopt an enhance I/M program (in

             specified areas), implement all Control Technique Guidelines (new and

             existing) and adopt measures that will achieve reductions comparable to

             those achieved as a result of implementation of Stage II Vapor Recovery. A

             transport commission is also established.



             EPA is provided with authority to establish requirements to control air

             pollution from Outer Continental Shelf sources along the Pacific, Arctic and

             Atlantic coasts and along the eastern Gulf coast of Florida. Sources

             located within 25 miles of state waters are to be subject to the same

             regulations as sources located onshore. For areas not covered by these

             regulations - Texas, Mississippi, Louisiana and Alabama, the Secretary of

             the Interior must consult with the EPA Administrator to ensure coordination


             of air pollution control regulations. In addition, a study is called for to

             examine the effects of toxic air pollutants on coastal waters; if necessary,

             control requirements must be promulgated to protect these waters.




             Air Toxics





                                                   85









               The bill lists 189 chemicals to be regulated, which include the substances

               in the Administration's proposal, with the exception of ammonia and hydrogen
               sulfide. EPA may add and delete chemicals from the list; the public may
               petition EPA to amend the list. In making additions, EPA must consider the
               threat of adverse human health effects or "adverse environmental effects,"

               defined as "any threat of significant adverse effects ... to wildlife, aquatic

               life or other natural resources, including disruption of local ecosystems,

               impacts on populations of endangered or threatened species, significant
               degradation of environmental quality over broad areas, or other comparable

               effects."



               Within one year of enactment, EPA must establish a list of major source
               categories and subcategories to be regulated. A major source generally is
               defined as stationary source that emits 10 or more tons per year, in the

               aggregate, of any hazardous air pollutant.



               MACT Standards



               For each source category, EPA must promulgate emission standards for new and
               existing sources calling for the installation of Maximum Achievable Control
               Technology (MACT). For new sources, MACT must be at least as stringent
               as the controls achieved in practice by the best controlled source in the

               same category,and may be more stringent when feasible.


               For existing sources, MACT may be less stringent than the standards for
               new sources in the same category, but may not be less stringent than that

               achieved by the best performing 12 percent of existing units.


                                                     86









             Determinations of the lowest Achievable Emission Rate made in the eighteen

             months prior to the proposal of the standard or 30 months prior to

             promulgation of the standard (whichever is shorter) are excluded from

             calculations made to determine the top existing sources. The standards must

             take into account the impacts on the environment, in addition to effects on


             human health.




             EPA may identify area sources of listed pollutants, along with major

             sources, that are required to install MACT. EPA must list sufficient area

             source categories to encompass 90 percent of emissions of the 30 most

             serious area source pollutants. Sources that present a substantial risk to

             health, but for which the required control technology is too expensive, may

             meet alternative controls. EPA must list area source categories within five

             years of enactment, with regulations to take effect within 10 years.



             EPA must conduct a study on toxic pollution of the Great Lakes, Lake

             Champlain, the Chesapeake Bay and coastal waters from atmospheric -

             deposition. Based upon the study, within three years EPA must take action

             to address this problem, including the effects due to bioaccumulation and

             indirect exposure pathways.




             Acid Rain




             The bill seeks to reduce emissions of sulfur dioxide in the 48 contiguous

             states by 10 million tons from 1980 emission levels by the year 2000 and,

             beginning in 1994, emissions of oxides of nitrogen by two million tons from

             1980 levels.




                                                   87








              The two phased emission reduction program for sulfur dioxide is based upon a
              system of allowances. Each utility will receive marketable allowances for
              the amount of pollution it is allowed to emit; utilities may sell these
              allowances to one another. The bill limits the number of allowances to   be
              issued nationally to 8.9 million tons and requires EPA to reduce annual
              allowances to individual plants on a pro rate basis, if necessary to comply

              with the national cap.




              Permits



              The permit program makes it unlawful to operate an affected source (i.e.,
              acid rain), a major source (10-100tpy), sources subject to sections 111
              and 112, or sources required to obtain a permit under Parts C or D without a
              permit. The Administrator may exempt certain source categories from these
              requirements if compliance is considered "impracticable, infeasible or
              unnecessarily burdensome..." However, the Administrator may not exempt any

              major source.



              While both the House and Senate bills originally called for a special permit
              program for small businesses, the final bill is limited to requiring that
              technical and environmental compliance assistance be provided to these
              businesses. EPA is required, within nine months of enactment, to establish
              a small business stationary source technical and environmental compliance
              assistance program to assist states in developing their programs, issue
              guidance for use by the states and provide for implementation of a program
              in any state that fails to submit a program to EPA.




                                                     88









             Sources eligible for inclusion in the small business technical and

             environmental compliance assistance program include those: (1) owned or

             operated by a person employing fewer than 100 employees; (2) defined as a

             small business by the Small Business Act; (3) not considered a major

             stationary source; (4) emitting less than 50 tons per year of any regulated

             pollutant; and (5) emitting less than 75 tons per year (total) of all

             regulated pollutants. In addition, a state may petition to include in its

             program sources emitting up to 100 tons (total) of all regulated

             pollutants. Further, both EPA and states, in consultation with one another

             and the Administrator of the Small Business Administration, may exclude from

             eligibility sources determined to have sufficient technical and financial

             capabilities to comply with requirements of the Act without special

             assistance.




             Stratospheric Ozone Depletion



             Within sixty days of enactment, EPA must publish initial lists of Class I

             and Class 11 materials. Class I includes all fully halogenated

             chlorofluorocarbons (CFCs), halons, carbon tetrachloride, and

             methyl chloroform. Class II includes HCFCs (i.e. "transitional

             substances"). Production of Class I substances must be terminated by

             January 1, 2000 (January 1, 2002 for methyl chloroform, except for certain

             exceptions, which must be capped at 10 percent). Exemptions are allowed for

             medical devices, aviation safety, export to developing countries, national

             security, fire suppression and explosion prevention. Production of Class II

             substances must be frozen in 2015 and banned in 2030. Use will be

             restricted in 2015 (except for refrigerants, which will be restricted by



                                                   89









              2020). Exceptions are allowed for medical devices and for developing

              countries. The schedule for freezes and bans may be accelerated if

              scientific information warrants it, the availability of substitutes make it

              feasible or the Montreal Protocol is amended.






















































                                                    90






   A     4

























                                           APPENDIX IV




                                 Baltimore Integrated Environmental

                                        Management Project




                                         Phase II Report

                                  Baltimore Harbor Data Analysis
































                                                    91




                                                                                                    f---








                                 Baltimore
            Integrated Environmental Management
                                   Project

                             Phase II Report


                            Baltimore Harbor







                                               CD













                               Pagh" kftp     DMWan
                                 MW Of ftky kq**
                           Ofka of Pc1W. PWvft, wW &WuWon
                                  V-4














                            U.S.         ftAKOW Aqvicy

                                      1987

                                       92












































                         C. Definition of Uses and Parameters


                         The harbor information matrix is composed of (1) the definition of harbor uses, (2)
                 the definition of water quality and use-rtlattd parameters that affect those uses, and (3) the
                 relationships between the uses and the parameters.

                         We considered six uses:

                                 Fish QuAlity: the health of fish Hying in the harbor and the fitness of those
                                 fish for human consumption, defined as the presence or absence of
                                 contaminants, such as heavy metals and organic toxicants, or lesions in their
                                 -flesh.



                                                             94











                              Floating Debris: debris can be both a swery and an aesthetic problem.
                              Sediment Qualily: this is a broad parameter used to define the presence of
                              organic and inorganic pollutants in sediments and their potential impact on
                              biota. Highly polluted sediments can contaminate biota, especially bottom
                              organisms.

                              Sham 1=: the quality of the shoreline affects both recreational access and
                              natural systems. Natural shoreline contributes to high habitat levels, while
                              the presence of boat ramps and piers will enhance recreational boating,
                              crabbing, and fishing.

                              Substrate T=: this is critical to development of biota, but it may also
                              influence recmation, especially swimming.

                              Turbidity: this has an influence on both recreation and biota. High turbidity
                              levels will adversely affect aesthetics and biota.

                              Vegetative Ejabitat: the presence of submerged and emergent aquatic
                              vegetation (SAV) influences biological systems as well as recreation. High
                              levels win enhance habitat, fish diversity and crabbing, but may be less
                              desirable for recreational boating and swimming.

                              Water Column Metals: metals in the water column may be bioaccurnulated in
                              fish and may therefore affect human health; high levels may also adversely
                              affect development of ecological systems, thus lowering habitat levels.

                      Some harbor conditions may lend themselves to being considered as either a use or
              a parameter. For instance, we consider boat traffic, measured by the prtsence of shipping
              channels and marinas, to be a parameter and we also consider recreational boating as a use
              that is influenced by boat traffic and nine other parameters. The perspective of
              consideration (and the definition) of the use is clearly different from the parameter.
              Simila ly, vegetative habitat is a parameter that influences habitat as a use. Mz habitat use
              is affected not only by the vegetative habitat parameter, but by every other parameter as
              wen.


                     Because of problems of measurement, data availability, and uncertainty about their
              potential effects, we made no attempt to include consideration of a-ace organic toxicants,
              such as pesticides, in the water column. In addition, the separate nutrient effects of
              nitrogen and phosphorus have been combined into a single "enrichment" parameter.




                                                              96









                                                                                                                                                        Table 3
                                                                                                                   Minimum Parameter Levels Required To
                                                                                                                                       Attain Each Use Level
                                                                                                                            Key para"efs Micated wAh an aslerisk

                                                                                                                                                  Fish Quality

                                                                                                                                                     Paramoters
                                 Use              OmadL                  AwL              Obighmd OmMin                          Eaddoml EbOiL biadWimt                                            ShmL             substraW                                Y2gwiiye WALQL
                               LoWs                 At"                 JEdk               Oxygen            FrggUM                  L2121               DIbm                pOhfi=                LM                   I=              TuFbW                 HA"                   U90
                             I                    * I                     I                * I                     I                 * I                . I                    . I                   I                a I                 * I                       I               - 2
                             Caftwomed         CWAW=*               100110111111101     om=brA*              VINIAW              14W aw"M            H-V                  WO* amoft           ft-                  UIIIIIIIND          3-100 OW             Oft SAV a           Leved of OW
                             1000seft FDA      3-M                  04*4 OWN            nodneoffeN                               *W=fW               VA&BOW               muck up                  1, '1           SWINNIIIIII                              some"               ft" now
                             Mom La"                    mwo         b"sumbas            "Pod                                     wow                 daftponows           bob GO Oft          dwallow              poned                                    Onalow              soniftner a
                             sowsw*            palivelnuff          PMUM                ftwomr.                                  I- -                OWNING@              swoo-               kwwwu*.              WAMOK VWV                                "Vows"In            Or        -    0
                             p                 d2v                                                                               13." WO.                                                          WNW"            go, atom                                 Was,                IEP&oeokft
                                                                                                                                                                          "M fc*.                  Ova.            SoOK was 0


                             2                         2                                        3                                      2                                                                                  2                    2                                       3
                             SWO               C-1010111OF          H" f"W              2-4sop               YGOV                TOW"b"M             H-P                  W#ft sogoo*         AMW                  samomm              WOODOW               Oft $AV of          F On           0
                             nrawdmft%         wanooftm             OVA" WAW                                                     IOM W40 Of          kwomw                poklikup                 W -             WNW"                                     ammwv               F PA'S
           00                                  INOW4                "a WWWAS                                                     o"                  dowsoposseas         Istaft d soft       41WISIPOW            onwereftlas
                             %sum              sommm.               PPOSM                                                        ONW-                Now as               sefoodon.           bm-omr.              -a"                                                In
                                               aloommmm                                                                        . a4-12 XWL           @$am                                     gm6wmwob             NWAP
                                               wenognow                                                                                                                   M" falm, W          No 0".               by vonew waft
                                               o@m                                                                                                                        I - I -in
                             3                    * 3                                          4                                       3                    2.                 * 3                                        3                   3                                        4
                             a"                0: novel             oftwomw             4-saw                VOIWV               TOW "bogn           modu@                "To WV*             AMON                 As"NO               som OW               Me SAV a
                             ONINNINAMN        V=                   own" OWN                                                     I-91was"            dabftpmmwd            9 - Wack           1 0 -,               sum emboma                               WWWV                umb d *mob
                             "=NORM                     was         W" Noun                                                      Ohno-               ONSWON               Wad@                dr-ftow              @W-ot"                                   sholsoft            Clonewba
                             Ad h ll on        se"Nosoft            poemoss.                                                     Ow"Oft              dow                  trmbdow             , - -       I        swoon% 11410                             V"Wisom"Ift         ONNW sew ok
                             hodoon            des"dame                                                                                                                   wow". CO            go owwoma            sum d                                                        EP&s dwooft
                                               ler mom"                                                                                                                   4-14.               Sodom.                           d
                                                                                                                                                                                                                   wo 4" OW
                             4                        3                                                                                                     2                     3                                   * 3                     3
                             IW NO"            F equeaft            Obay""N             ftemosemp            Y-ft                Towntown            kinimoo              ONO W#*             Moslem               NdMhm*              40M 0%4              NDSAVW
                             pow               W=                   se"awiff                                                     0-1-0-WOWIN         41110111 PMM4        "pokonick.          owopw*                                                            to              own6dwAmb
                             Wpdw&V W          edbWWON              WV WAMoss                                                    VOW                 IIIIIIIII as                             dDIVINOW             0-mohm                                                       CftW Ilk OVA
                             MffAMWNift        941019010WOO         PHOM                                                         phs@Pb-             ohm.                 bob d a&            bowobb*.             swankto                                  MOOMM" ft           ONNION sew 0%
                             awdood"was)       do"Glaose                                                                         *A"-OLIS                                 4180*8. CO          UmbLesmob            d                                                           EFA*s dww*
                                               Boo, esixom"                                                                      W40L                                                         a" phon.             fttwaod                                                      cdwfa
                                                                                                                                                                                                                   sove"Ook
                             5                                                                 5                                       4                    3                     4                                   a 3                                                              5
                             Heava"            onobrA*              ""-W                MOOSOW               Y-V                 uWab"M              9@owwo               mewom@d             AM@                  MOM*                W-4080               ft SAV or
                             cow               a,=                  WA" OWN                                                      alamw4per           d*Aft poomose        WSIIWC              1 0 -,                                                        same"
                                               COWWWWOd             O"s W"Mis                                                    NOW                 famet SOL)                               dftvkw                                                        somplohne
                                                                    piano                                                        0080-               NOUN                 fow"M at            , ,    ANY.          ININW0116 W                                        in
                                                                                                                                 0.0140.13           owmano               NNIC) C1 4-14       WAh bulkowleft       #nm d
                                                                                                                                 no                  d" al down.                              &,W pme              eAmosoo d
                                                                                                                                                                                                                   OW $ope lug.









                                                                                                                                                  Table 3
                                                                                                            Minimum Parameter Levels Required To
                                                                                                                                Attain Each Use Level
                                                                                                                      Key permosters Micaled wilh an asterisk

                                                                                                                                                  Habitat

                                                                                                                                               ParamWors
                             Use              ONIANdIL              IML             OWdist                DEsdaim          Loddawl EbdkxL SaImml.                                          Slim            fidwVAL                                 ye"Aft" WA CAL
                           Levels             SIAM                IEdk                 QUM             Ffsau@Pm                L21.2i             Qdxk                &lk"                 IMS                 INS                                      Hamm               NW"
                           I                  &I                  *1                   *1                 *1                   *1                 *1                    *1                 *1                  *1                 *1                    .1                 a,
                           WMNah@           Condom*            "-yomw               Omadomfla          11-ft               radoomple           mm                  NO* of%*            AN"                 UPAMM               DWHW                WSAVO               Lovololoop
                           adoodMOM         *31119             dilogumbor           mooft"Offo                             owswow              kk*Amw              vowkwo              amww*               sommom                                  WRIPSION            %a" now
                           momen"           own"Was            "D nowma             dwilospond                             wood                dftftomnM           IVA* GO ftft        dw#dIPW             I"d                                     ohomem              oomewpow a
                           mobillor                            PPOMM                "Pa.                                   omo@                wwftr as            monam.              N*A"*.              otowm& fty                              wepsoomb            a Owwwwong
                                            offt                                                                           IS44WO              dam                                     um6wwina            wk dwad                                 40,04L              b@tc"
                                                                                                                                                                   boomfNIN."          mdow.               INK MA 0                                                    boa
                                                                                                                                                                   POMM&AWiN                               on.
                           2                  *2                  *2                   61                 *2                   *2                 *2                    *1                 *1                  *2                 al                    *2                 *4
                           wwwookom         awwwwo             0- d**4              OnOWAW             &mabor              Iwasompla           ona@                WO* ago*            AW"                 seffa"              2,140myll           020=b"
                           wwwwooblo                           shwAft               =@"*a*             low.                seftwom             doftpmw             muckwo              ammow               command                                 Peon Go am          babdomb
                           ONSWASO                                                  Av"Powd                                                          do            0"40"*              domi*W              wMaGILIN                                wowevem             cbmwba
                           slowdown         wommoo.            awrava               $*Jan.                                 06*WW               amm                                                         weft                                    vagansm or          @oodft
                           womemw           sommoodo           owmawp                                                      s.06-11WOL                                                  oft bw*Aoft         SONAW-AW                                limeft              fift'S dMft
                                                               Namm
         0                                                                                                                                                         won                 wid Ow.             fjVvoodftft                                          d
                                                                                                                                                                   PMftV&40 IS                                                                     SAW.
                           3                  *2                  *3                   04                 *3                   *2                 03                    64                 *2                  *3                 *2                    *3                 04
                           fawakm           Camino*            ft@omo S-Impf                           nwft                T"Nompon            a@ng"               Obaft@d             #:AVMWAV            md*AV               w"Dwo               agomi"
                           mosesom          *=mows             ftwomim,                                awoobo              lSaW4$010           eaopomm             womb                drAftW 996          N*bsdMM                                 Poomd$W             babdomm
                           dan@PMb          not*               a" m *we                                $4ram               I"                  "=&a"               GWANIONINO          6WHOSO.             *mop"                                   WAOIndeleft         done lo, ono
                           Owwasons         blownw.            emsava                                  box"&               Onob@               &low                flowder                                                Ild                                          aftwompalk
                           *AIM             foomme@                                                    &AMNO.              "lamia              somebw              oft C14-K                                                                                           fpft
                                            mompow             no**#                                                                           swood
                                            emm
                           4                  0 2                 19 4                     4                   3               a 4                6 4                                        4                 a 4                    4                                        4
                           WAWGOM           conesow            ob@om                4-600              IIIIIIIIINIF        T41daimpon          Oman"               thdoMAMed           31 - WIL            OWWAMUM             SO-osmia            Neftm
                           SWGMMMWO         P=SdkM                  a"                                 doopo OFA           IL14"Now            and a sow           womb                mooKom              "of" oft,                               Po*jnd$W            lopoll, of Womb
                           a mandolin       IW*d*                                                      s4voom              sw                  ad"daft             awdaw&ANOW          ommos"              oba some                                OW QWAGGPW          CbMIL&A
                           eaft WA          bloom.                                                                         ongobw-             magehm              $mmodw              ownsolngo,                         6                        V"st.              FAMW sow %,
                           blood dhow       wasso@                                                     bdow".              "Wals                                   on". C14-K          nomnk                              ONO                                          Elaft
                                            mmvm@                                                                          ONO                                                                    -11            PMI-
                                            amm                                                                                                                                                            deow""
                                              *3                                       as                 *5                   as                 64                    *4                 as                  *5                 as                    05                 *4
                           wwww eaft        Fpsww*             One"                 Almoswo            mm dnovd.           140 mom"            Onotod              Oboulbood           a-IftrAm"           Vah" Go             am""                Abmnfto $AV
                           woonewme         pm                 amwom                                                       OA"ANNO             uWdWOW              mom*                "a wp               aboamqw                                 NWOWW@@N            mob of ore"
                           spoolob ONO      ong4ownsid                                                                     We"                 oolveddellft;       owawoamom           evelood             O*mm a Ow                               wagamon in          Come a. W
                           &ft"-            misionip6o         PPMWMWN                                                     00"-                ftellshow           Onawol a            Swul and            &mow.                                   Of"                 twow O"d oft
                           Shober           cftw4et@           49 d*PIR#                                                   SAW)040@                                lot) C14-14.        orwahm;Wor          WWA" OR                                                     [P&G
                                            III 010601"MI      Chowab.                                                     ONO                                                          10 "N              dwom"                                                       O"in.

















                                                                                                                           Table 5
                                                                                                   Swwmwy of Anst"kal Results For Sallbacre Ha&w

                                                                                                               OK - Plaraviaw bral scompube
                                                                                                            Paramieter 6W numb -     m appraft it Apmef
                                                                                                         #2. *3. #4 - P&WnsW         A- -*r Wpm*
                                                                                                         R.                                                                                                          SumwmT of Status
                                                                                                                                                                                                                Of All Herbw Subareas


                                                                                  1      2         3        4         6        0        7         a        0        10        11       12        13             Huff" fto "        Number
                                                                                                "Orm- mmft Curtis           how"                Upper    GOW      ftnwf       Roclk Ow Read      Cos  mm 68     mew*a tivotw% 0
                                                                             Odds     Odd& am            liaMcm loyarod     Fwnwa      Sew      SOW     !Wbw      C400        Coo"     Bw     Deek     clAnm 0- Mqm Research
                                 use                    PWONOW               Orwich   Worich    lkwlch             creek    Cobalt     CA001t   CMA                                                      Mir    Upraft Upwaft _E "art

                                                  ftm*b@W so"                     OK     Ox        CK       OK        M        *2       CK        CIK      c9c      Ox        Cl(      OK        R        I I        a        i         I
                                                  00111 Tieft                     M      OK        *2       OK        CK       CK       * I       OK       #1       M         OK       OK        OK       10         2        1         0
                                                  OmmondO Ig                      CIK    OK        #1       CK        OK       OK       CIK       OK       M        OK        A        OK        R        to         1        0         2
                                                  Em Id inso Level                a      OK        42       M         CK       OK       OK        OR       Ox       R         R        OK        R        6          0        1         4
                                                  Fkm* Ck6ft                      42     UK        #1       #1        #1       A        00C       OK       OK       OK        OK       Ok        CK       9          3        1         1
                                                  41 a       pakdon               CK     OK        CK       CK        OK       R        OK        Ox       OK       a         A        OR        R        9          0        0         4
                                                  am* TWO                         #1     OK        #1       Ox        OK       Ok       OK        OK       CK       OK        OK       OK        OK                  2        0         0
                                                  866wom too                      A      OK        #2       # I       R        OK       41        * I      OK       OK        OK       CK        OK                  3        1         2
                                                  Turtift                         CK     CK        OK       OK        CK       OK       UK        CK       CK       R         R        CK        R        10         0        0         3
                                                  vftwcdwmmgwo                    A      R         R        R         R        R        R         R        R        R         R        R         R        0          0        0         13

                                 flowealoW        SONTreft                        OK     cic       CIK      Ox        OK       CK       CIK       CK       OR       ON        OK       ON        CK       13         0        0         0
                                 C 01'            Date* Q@                        CIK    OK        +2     ..m         CK       #2       G(        OK       Ox       #1        A        OK        R        a          1        2         2
                                                  n do a Fm*onW                   OK     OK        #2       Ox        OK       0(       09        CK       OK       OK        OK       Ox        OK       12         0        t         0
               C)                                 Elvidmilm LOW                   R      CK        +2       OK        OK       CK       OK        OK       41       R         A        +2        R        6          1        2         4
               LO                                 F%O Dsbft                       *I     CK        CK       CK        OK       R        am        cm       CK       OK        OK       OK        OR       11         1        0         1
                                                  a I        pebAlln              CK     *1        *1       #1        CK       R        *1        #1       CK       R         A        #1        R        3          6        0         4
                                                  ShMTWO                          #2     ON        #1       ON        CK       Ok       CK        OK       OK       OK        Got      CK        OK       if         I        1         0
                                                  Sdmwm NO                        R      #1        #2       OK        R        CK       OK        OK       CK       CK        OR       # I       OK       0          2        1         2
                                                  Twwft                           #2     OR        *2       OK        CK       CK       CK        CK       CK       R         R        OK        A        0          0        2         3
                                                  v"ste"Now                       ON     CK        CK       OK        OK       *1       Ox        CK       # I      + I       OK       CK        OR       10         3        0         0
                                                  Wiser Ckam Wbab                 A      R         R        Ft        R        R        A         R        R        R         R        a         R        0          0        0         13

                                 Swb - M          Immemboodsm"                    #1     #1        cm       CK        OR       42       4         OK       (w       *2        *2       ON        R        6          2        4         1
                                                  ftINTMOC                        OK     OK        OK       OK        cm       cm       of        ON       41       OK        OK       OK        OK       11         2        0         0
                                                  CMN*WOAWM                       CK     OK        CK       OR        ON       CK       CK        OK       OK       OK        R        CK        R        I 1        0        0         2
                                                  Emtd LOW                       R      CK        OK       cm        CK       ON       CIK       cm       CK       R         a        #1        R        a          1        0         4
                                                  AnO 1) 1 -                      #2     +1        OK       OK                 R        +2        CIK      #2       OK        CK       #1        OK       a          3        3         1
                                                  8 @        poldow               of     #3        OK       OK                 R        +3        4        OK       A         R        #3        R        3          2        4         4
                                                  Shwe Type                       *I     QX        cm       CK        Ok       OK       ON        CK       CK       CK        OR       OK        CK       12         1        0         0
                                                  Mween Too                       R      M         M        OK        ft       M        *2        ON       * I      OK        CK       * I       CK       4          2        1         2
                                                  Twbk*                           # f    CK        OK       OK        c*       cm       CK        OK       CK       R         R        01(       A        9          1        0         3
                                                  VOISIN collm &AIIIII            Ft     R         A        R         R        R        R         R        A        A         R        R         R        0          0        0         13









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