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Home My WebLink About48 SE48_3115 Epsilon Clarity of property status 03_25_19 PRINCIPALS Theodore A Barten, PE Margaret B Briggs Dale T Raczynski, PE Cindy Schlessinger Lester B Smith, Jr Robert D O’Neal, CCM, INCE Andrew D Magee Michael D Howard, PWS Douglas J Kelleher AJ Jablonowski, PE Stephen H Slocomb, PE David E Hewett, LEED AP Dwight R Dunk, LPD David C Klinch, PWS, PMP Maria B Hartnett ASSOCIATES Richard M Lampeter, INCE Geoff Starsiak, LEED AP BD+C Marc Bergeron, PWS, CWS 3 Mill & Main Place, Suite 250 Maynard, MA 01754 www.epsilonassociates.com 978 897 7100 FAX 978 897 0099 21597/2018/Expanded Project/NOI/Public Hearing Comments April 19, 2019 Nantucket Conservation Commission Via Electronic Mail and U.S. Mail 2 Bathing Beach Road Nantucket, MA 02554 Subject: Clarification of Property Status by Property Line Length in Response to the March 25, 2019 Hearing on the Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project (DEP File No. SE 48-3115) Dear Commission Members: On behalf of the Siasconset Beach Preservation Fund (“SBPF”), Epsilon Associates, Inc. (“Epsilon”) submits this letter to clarify a discussion about the status of properties in the project area. This was a discussion topic during the Nantucket Conservation Commission (“Commission”) March 25, 2019 Public Hearing for the Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project (“Expanded Project”). Review of Properties Along East Side of Baxter Road During the 25 March 2019 Public Hearing we discussed the status of homes in the Expanded Project area. There continues to be some questions about which properties are eligible for protection under Massachusetts Wetlands Protection Act (“State Act”) and the Town of Nantucket Bylaw for Wetlands (“Local By-Law”), including which properties would be protected as “gap lots”. While this information has been presented several times previously, given the complexity of having 22 properties in the Expanded Project area (and seven properties in the Existing Project area) with different reasons for their eligibility for protection, we believe it is useful to summarize the information again. During the March 25 discussion we referred to Table 1 - Construction Dates of Structures on East Side Baxter Road (Lots 67 – 119 Baxter Road), previously submitted to the Commission on 16 November 2018. That table evaluates the status of each property by number of homes on the east side of Baxter Road, but not length. In response to the recent discussion we submit the attached revised Table 1 that includes the easterly properties, including property line length (based on Assessor’s data) and an evaluation of lots by length. Also attached is Figure 1 - Aerial Locus with Top of Bluff Property Line Lengths (55 - 109 Baxter Road), which depicts the properties evaluated in Table 1. Some lots are eligible because they contain pre-1978 Nantucket Conservation Commission 2 Re: DEP File No. SE 48-3115 April 19, 2019 buildings, some because further erosion would threaten infrastructure including utilities that are essential to pre-1978 homes, and two are so-called “gap lots” with long stretches of protectable Coastal Bank on either side of them. A jurisdictional status of lots by length is summarized below for the Local By-Law and the State Act. Local By-Law 68% (1,731 lf of 2,548 lf) of the Expanded Project length (15 properties) is comprised of locally eligible pre-1978 dwellings (By-Law and State Regulation pre-1978 dwellings).1 24% (612 lf of 2,548 lf) of the Expanded Project area length (5 properties) is comprised of vacant lots, which are eligible for protection to protect public infrastructure – Baxter Road and public utilities in the road which are essential to the protection of pre-1978 buildings. 8% (205 lf of 2,548 lf) to protect two lots 69 & 81 Baxter Road with non-locally eligible dwellings and considered to be “gap lots.” These are both flanked by lots with Local and State eligible pre-1978 structures. State Act 76% (1,936 lf of 2,548 lf) of the Expanded Project length is comprised of State Regulation defined pre-1978 dwellings 24% (612 lf of 2,548 lf) of the Expanded Project area length is comprised of vacant lots, to protect road and infrastructure which are essential to the habitability of pre-1978 buildings, per the precedent established in SOC SE48-2610 (By-Law allows protection of public infrastructure) Jurisdictional Status The Expanded Project is eligible to receive an Order of Conditions (“OOC”) pursuant to both the Local By-Law and State Act as described below. 1 It should be noted that 740 lf of the Project length (contained in 6 properties) or 29% of the 2,548 lf Expanded Project length is protected as both pre-1978 homes threatened by the erosion of the toe of the bluff and disappearance of all remaining dune as verified by the State under the Natural Heritage and Endangered Species Program, and infrastructure in the form of the Bluff Walk. While the face of the bluff has not slid yet, along some of this segment the bluff homes are considered to be in obvious danger and therefore are eligible for protection. This length is included as part of the 1,731 lf and 68% above. Nantucket Conservation Commission 3 Re: DEP File No. SE 48-3115 April 19, 2019 Local By-Law As described in the Notice of Intent (“NOI”) and subsequent submittals, the Local By-Law allows the construction of a coastal engineering structure (“CES”) to protect eligible pre-1978 dwellings and public infrastructure [2.05.B.]. As presented in Table 1 attached, and summarized above, 92% of the Coastal Bank in the Expanded Project area, as measured along the property lines of the subject parcels, is eligible for protection by the By-Law under the following categories: 1) to protect eligible pre-1978 dwellings, or 2) to protect public infrastructure, i.e. the vacant lots. This infrastructure is also essential to the habitability of pre-1978 buildings as an additional aspect of eligibility. Only two lots (No. 81 – 99 feet, and No. 69 – 106 feet) totaling 205 linear feet (or 8% of the Expanded Project area length) are “gap lots.” Gap lots are parcels which by themselves may not contain a pre-1978 house, but across which a CES can be constructed to install a contiguous linear CES to protect eligible dwellings and public infrastructure. North of 81 Baxter Road, there is approximately 2,140 linear feet of Coastal Bank comprised of pre-1978 dwellings, or vacant lots across which the geotube system is proposed to protect public infrastructure. South of 81 Baxter Road, between 81 and 69 Baxter Road, there are five pre-1978 dwellings (499 linear feet) eligible for protection by a CES. South of 69 Baxter Road are five pre- 1978 dwellings (740 linear feet) plus the public Bluff Walk (which can be considered to be infrastructure eligible for protection that used to run north to the Sankaty Lighthouse used extensively by hundreds of walkers each day). Clearly these two short gaps (about 100 feet each) are critical to installing a several thousand foot long geotube system to ensure the integrity of the geotube system and long-term protection of the Coastal Bank. The Superseding Order of Conditions (“SOC”) issued for DEP File No. SE48-2610, establishes the ability of install the geotubes across a lot with a non pre-1978 dwelling to protect a pre-1978 dwelling from loss or damage by erosion. The SOC reads in part, “Geotubes may remain on the adjoining lot 91 to provide an adequate level of storm damage protection to the dwelling on lot 93.” [Page 2 of 3] State Act As summarized above, 76% of the Expanded Project area length is comprised of pre-1978 dwelling as defined by the State Regulations, and therefore construction of the geotube system to prevent erosion on those lots is allowed by 310 CMR 10.30(3). Furthermore, the remaining 24% of the Expanded Project is needed to protect public infrastructure, a standard established in SOC for DEP File No. SE48- 2610 which reads in part, “In the northern project area (lots 101 and 105) and in the southern project area (lot 87) where the existing three tiers of Geotubes directly Nantucket Conservation Commission 4 Re: DEP File No. SE 48-3115 April 19, 2019 protect Baxter Road (and essential public utilities) the Geotubes may remain for up to 6 years or until such time when alternative access to the northern end of Baxter Road has been provided and the imminent threat to public health and safety has abated, whichever is earlier.” [Page 2 of 3] Subsequent to the issuance of the SOC, a back-up plan with so-called “springing easements” was put in place for alternative access which would be available only if the geotube project failed. The understanding has been that the Expanded Project, now under consideration, would be requested and the permitting process completed within this 6 year time period. We understand that some commenters have argued the existing project is a “temporary” project, however, also acknowledged by the Massachusetts Department of Environmental Protection is the ability for SBPF to pursue an extension to the existing geotube array as stated in the SOC (SE48-2610) which reads in part, “The Geotube proposal has been represented to be a temporary project lasting for approximately 3-6 years. The SBPF indicated that this timeframe will allow a long-term protection project, such as a longer Geotube or rock revetment [emphasis added] to be identified, permitted and implemented.” [Page 1 of 3] This same language is included in the OOC issued to maintain the three tier geotube system and install a fourth tier (SE48-2824), see Special Condition 41 which reads: “Approval for the project is for three years, with the option to request a three-year extension upon expiration of the initial three-year term. The applicant shall not apply for a long term or long length expansion of the Project prior to January 1, 2018 [emphasis added] and shall not begin construction of such until after September 1, 2018. The Applicant may apply for localized alterations to the Project as may be appropriate based on site conditions, and may apply for any alteration or expansion necessary to address an emergency or imminent danger.” These previous approvals, although using the term “temporary” envisioned the future request to extend the project to the full 4,000 linear feet as proposed in the original revetment NOI. Modification of Pre-78 Homes – There continues to be some confusion about the eligibility of four lots under the Local By-Law as containing pre-1978 homes (83, 79, 77, and 73 Baxter Road) which had building permits issued since 1978. The question is whether the work done on those homes exceeded the 20% increase in habitable space standard. We have submitted specific calculations based on the Building Department files (see memo dated 28 February 2019, submitted to the Commission on 01 March 2019) showing that the extent of renovations is less than the 20% standard. Commissioner Golding reviewed the same Building Department files, but has not presented calculations based on data in the files that supports his assertion that the renovations of those four structures exceed 20% of the habitable Nantucket Conservation Commission 5 Re: DEP File No. SE 48-3115 April 19, 2019 space. Both Commissioner Golding and we agree that two other properties (81 and 69 Baxter Road) that had new homes constructed to replace pre-1978 buildings exceed the 20% expansion standard and are not eligible lots under the Local By- Law, however they are eligible under the State Act. These are the two “gap lots” referenced above. Conclusion In closing, the above demonstrates that the entire length of the Expanded Project can be approved pursuant to the Local By-Law because 92% can be authorized to protect pre-1978 dwellings and public infrastructure, and the remaining 8% is needed to construct a continuous geotube system to ensure the integrity of the geotube system. Also, the entire length of the Expanded Project can be authorized pursuant to the State Act to protect pre-1978 dwellings (76% of the total length) and public infrastructure (24%), a standard established for the existing geotube system in accordance with SOC SE48-2610. We respectfully request that the Nantucket Conservation Commission close the Public Hearing and issue an Order of Conditions allowing the proposed Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project to be built, and establish pragmatic Special Conditions consistent with those issued for the existing Project (SE48-2824) to protect the Interests of the Act and the By-law. Sincerely, EPSILON ASSOCIATES, INC. Dwight R. Dunk, LPD, PWS, BCES Principal encl: Table 1 - Construction Dates of Structures on East Side Baxter Road (Lots 67 – 119 Baxter Road) Revised 19 April 2019 Figure 1 - Aerial Locus with Top of Bluff Property Line Lengths (55 - 109 Baxter Road) cc: MassDEP-SERO J. Posner, SBPF A. Gasbarro, Nantucket Eng. & Survey S. Cohen, Cohen & Cohen Law, PC G. Wood, Ruben and Rudman, LLP G. Thomson, W.F. Baird & Assoc. L. Smith, Epsilon R. Hamilton, Woods Hole Group Page 1 of 7 Table 1. Construction Dates of Structures on East Side Baxter Road (Lots 67 – 119 Baxter Road) - Revised 19 April 2019 Date of Initial Construction of Main Dwelling & Cottages/Garages as Noted Alterations, etc. per Building Dept. Records & (References to other outbuildings are only noted if they were referenced in HDC files)Moves per Building Dept. Records and Historic Structures Files (Note: year noted is year applied/permit issued)State Regulations Local Regulations (Linear feet) 1987 – Moved to 82 Baxter Road NOW VACANT House: By 1923/1978 – Single family dwelling 1978 1988 – Moved on same lot Garage: By 1923 2001 – New deck piers & rails (issued?) 2005 – Moved to 116 Baxter Road NOW VACANT House: By 1923/1983 – Structural repairs, new deck, interior renovation 1925 1987 – Alter and renovate, raise roof, new windows & doors 1988 – 2nd floor addition, window & door changes 1988 – Relocate house on same lot, add steps - sewer 113 Baxter Road House: Since 1940 1988 – Move on same lot Yes Yes 93 1988 – Moved from “Lot A to Lot B”/111 Baxter Road (109 & 111 are combined) 1988 – Alter and repair dwelling 1996 – Renovate 1st 1012 sf, basement 980 sf, rec room, bath, storage, add 450 sf 2nd 2 br, bath, 1 du (note: plans show new dormers, replace windows, new porch, etc.) 107A Baxter Road NOW VACANT No No 71 107 Baxter Road NOW VACANT No No 91 Property Address Wetland Regulations Pre-1978 Status Property Line Length along Bluff Zone 2: Lots 107 - 119 119 Baxter Road No No 64 117 Baxter Road No No 113 115 Baxter Road Yes Yes 105 109 Baxter Road Since 1940 Yes Yes 163 Page 2 of 7 Date of Initial Construction of Main Dwelling & Cottages/Garages as Noted Alterations, etc. per Building Dept. Records & (References to other outbuildings are only noted if they were referenced in HDC files)Moves per Building Dept. Records and Historic Structures Files (Note: year noted is year applied/permit issued)State Regulations Local Regulations (Linear feet) Property Address Wetland Regulations Pre-1978 Status Property Line Length along Bluff 1975 – Moved per HDC file 1988 – Moved on same lot; add & alter (per plans, alterations appear to be new decks and lattice at large deck) 1998 – Moved to 106 Baxter NOW VACANT 1984 – Permit noted on file cover, but permit is not in file (work performed is not indicated) 1988 – Moved per HDC file 1989 – “Move” noted on file cover, but permit is not in file 2001 – Emergency move to 104 Baxter NOW VACANT 1975 – Moved per HDC file 1988 – Moved on same lot 1999 – Renovate entire DU (no exterior changes per application) 2005 – Moved to 112 Baxter Road 2010 – Move 400 sf storage shed onto lot from 97 Baxter and place on slab foundation – no plumbing 2013 – Emergency demolition of garage due to coastal erosion NOW VACANT Zone 1: Lots 87 - 105 (Existing Project Area) 105 Baxter Road By 1940 No No 168 99 Baxter Road House: By 1940 Garage: Since 1940 No No 171 101 Baxter Road By 1940 No No 189 Page 3 of 7 Date of Initial Construction of Main Dwelling & Cottages/Garages as Noted Alterations, etc. per Building Dept. Records & (References to other outbuildings are only noted if they were referenced in HDC files)Moves per Building Dept. Records and Historic Structures Files (Note: year noted is year applied/permit issued)State Regulations Local Regulations (Linear feet) Property Address Wetland Regulations Pre-1978 Status Property Line Length along Bluff House and Guesthouse: Since 1940 1972 - Addition Garage: 1982 1975 – Moved per HDC file 1982 – Garage 1982 – Addition (enlarge one room, enclose porch) 1988 – Moved on same lot 1988 – Move garage 1989 – Addition 1996 – Renovate 2nd floor bath & deck and mudroom additions 1998 – Add 839 sf unfinished 2nd floor to 3 br 1 du, 297 sf 1st addition, reno 160 sf kitchen area 2005 – demo 24’ x 16’ section of studio due to bank erosion 2010 – Move 400 sf storage building off lot to 99 Baxter 2010 – Moved part to 7 Plainfield leaving 720 sf portion for conversion to 1 DU 2010 – Convert & relocate existing remaining elements per plans for new 1 DU . . . 1992 – Relocate garage on same lot 1992 – Relocate 1 DU on same lot 2005 – Renovate 140 sf kitchen, 2 full baths 100 sf, new walls living room & new floor in family room “interior only” 2010 – Relocate dwelling on same lot 2010 – Relocate garage on same lot 91 Baxter Road NOW VACANT No No 91 87 97 Baxter Road Yes Yes 170 93 Baxter Road House: 1950/1951 Garage Apt.: ND Yes Yes Page 4 of 7 Date of Initial Construction of Main Dwelling & Cottages/Garages as Noted Alterations, etc. per Building Dept. Records & (References to other outbuildings are only noted if they were referenced in HDC files)Moves per Building Dept. Records and Historic Structures Files (Note: year noted is year applied/permit issued)State Regulations Local Regulations (Linear feet) Property Address Wetland Regulations Pre-1978 Status Property Line Length along Bluff 1976 – One family dwelling 1988 – Add and alter dwelling 1988 – Enclose existing porch 1989 – Add 192 sf and alter 972 sf to existing dwelling 1990 – alterations (“interior change”) 2003 – renovate kitchen 1st floor & renovate 2nd fl master bedroom and bath area, shingle roof) 2007 – relocate 1 DU on same lot on 5 ft crawl space 2013 – Demolish 2 story single family dwelling NOW VACANT House: 1925/By 1940 2006 – Demo existing 748 sf dwelling Guesthouse: Since 1975 Garage: Since 1940 2010 – Prepare dwelling to move off lot; amended to reflect move off of primary structure to 47 Monomoy 2010 – Prepare dwelling for move off lot . . . (cottage) 2011 – Demo garage (amended to move off) Note: other permit numbers are noted on face of file, but are not inside file NOW VACANT 1982 – Extension of existing kitchen 1991 – Addition of sunroom and roof over dining room 2001 – Relocate dwelling and place on new foundation on same lot 87 Baxter Road House: 1976 No No 160 83 Baxter Road House: Since 1940 Yes Yes 131 Zone 3: Lots 69 - 85 85 Baxter Road No No 273 Page 5 of 7 Date of Initial Construction of Main Dwelling & Cottages/Garages as Noted Alterations, etc. per Building Dept. Records & (References to other outbuildings are only noted if they were referenced in HDC files)Moves per Building Dept. Records and Historic Structures Files (Note: year noted is year applied/permit issued)State Regulations Local Regulations (Linear feet) Property Address Wetland Regulations Pre-1978 Status Property Line Length along Bluff House: By 1923 1993 – Demolish 1393 sf 1 story 3 br 1 du New House: 1994 1993 – 2 story, 4 bedroom single family dwelling 2001 – addition to dwelling, add deck, renovate 1st floor House: 1916/By 1923 Per HDC file: 1987-1988 North Wing, Porch, Deck Roof Walk Reconstructed Shed: ND 1989 – Demo shed 1989 – Alter & add to single family dwelling 1997 – Add 278 sf to 1st floor deck 1 du 1999 – Replace windows, redo roof walk House: Since 1940 2005 – Demo 558 sf bunkhouse Shed: ND 2006 – Move existing house on same lot, add finished full basement, add sunroom & garage House: 1922/2002 – Add dormer, add 2 decks, reno interior By 1923 2004 – Add dormer & windows to existing garage, replace garage doors, add storage loft, construct pergola Garage: By 1923 House: 1920 1986 – Addition of 2nd story bathroom Garage: ND 1989 – Construct addition 1989 – Build 10’ x 14’ addition to garage for storage 2012 – Demolish 350 sf of 1st floor, relocate on same lot, add 150 sf 1st kitchen, reno baths, reside wall & roof House: 1932/1939 1982 – Bedroom addition 2004 – Repair/replace walls, reno bath (interior only) Garage: 1932 2005 – Construct deck at east entrance & outside shower 2009 – Dismantle cottage/garage 2009 – Relocate 1 du on same lot, remove additions, construct finished full cellar, reno 1st flr 1500 sf & add 2nd fl 400 sf 81 Baxter Road Yes No 99 79 Baxter Road Yes Yes 97 77 Baxter Road Yes Yes 82 75 Baxter Road Yes Yes 77 73 Baxter Road Yes Yes 147 71 Baxter Road Yes Yes 96 Page 6 of 7 Date of Initial Construction of Main Dwelling & Cottages/Garages as Noted Alterations, etc. per Building Dept. Records & (References to other outbuildings are only noted if they were referenced in HDC files)Moves per Building Dept. Records and Historic Structures Files (Note: year noted is year applied/permit issued)State Regulations Local Regulations (Linear feet) Property Address Wetland Regulations Pre-1978 Status Property Line Length along Bluff Dwelling & Garage Apt.: Since 1940 1996 – Build 2 story 5 br 1 du 1920 sf 1st 1830 sf 2nd New House: 1996 1997 – Move garage to 320R Milestone 1997 – Move house to 320R Milestone 1999 – Add wet bar and powder room in basement 1979 – Construct 5’6” x 9’ and 5’6” x 16’ additions 2001 – Relocate DU on same lot for setback compliance 2002 – Repairs and reshingle side & roof, red fire proof shingles on roof (note: it looks like this is permit is for the garage) 2002 – Reno of relocated DU, 2 new decks – sewer; add porch & 2nd floor deck 2001 – Raise house to provide cellar, completely renovate 3 story 1 DU 2001 – Reno shed 2001 – Reno garage House: 1890/1892 2002 – Reno existing dwelling unit approx.. 3000 sf reroof & shingle walls 2004 – Demo guest house/garage Garage Apt.: By 1923 (was a stable) 2004 – 2nd dwelling 2nd Dwelling: 2004 2005 – Demo shed Garage and Store Room: 2007 2007 – Garage and store room Shed: By 1923 House: 1893-4/1893 Beach house: ND Garage: By 1923 69 Baxter Road Yes No 106 Zone 4: Lots 55 - 67 65 Baxter Road House: 1895; Garage & Shed: ND Yes Yes 66 67 Baxter Road House: 1930; Garage: ND Yes Yes 79 63 Baxter Road Yes Yes 183 61 Baxter Road 2004 – Repair existing porch decking & joists – reroof 2800 sf trim 1 du & amendment to reshingle, renovate kit, laundry & 4 baths, foundation repairs, 1st flr girder replacement, insulate & add heat, upgrade plumbing & electrical Yes Yes 109 Page 7 of 7 Date of Initial Construction of Main Dwelling & Cottages/Garages as Noted Alterations, etc. per Building Dept. Records & (References to other outbuildings are only noted if they were referenced in HDC files)Moves per Building Dept. Records and Historic Structures Files (Note: year noted is year applied/permit issued)State Regulations Local Regulations (Linear feet) Property Address Wetland Regulations Pre-1978 Status Property Line Length along Bluff House: 1905/1991 – Rebuild shed By 1923 1991 – Rebuild front porch, alter windows & doors, reside & reroof & amendment to add 121 sf porch enclosure, bed, bath Shed: ND 1996 – Build garage/workshop Garage/Workshop:1999 – Remove enclosure on 166 sf porch – add steps and door 1996 2003 – Replace fixtures & tile in 3 baths 2011 – Raise dwelling & place on new full foundation; finish basement BR, 2 BA, LR; reno 495 sf, add 97 sf 1st, reno 153 sf 2nd 1973 – Addition (library) 1998 – Relocate dwelling on same lot, new finished cellar, renovate remaining 2 stories - porch Total Property Line Length of Expanded Project (Excludes Existing Project Area)2,548 Legend:Length of 2 "gap" lots per Local Regulations 205 Gap Lot Percent length of 2 "gap" lots per Local Regulations 8.05% Vacant Lot Length of vacant lots eligible to protect Public Infrastructure 612 Percent length of project to protect Public Infrastructure 24.02% Length of eligible pre-1978 houses (State and Local Regulations)1,731 Percent length of eligible pre-1978 houses (State and Local Regulations)67.94% 55 Baxter Road House: 1890 Yes Yes 148 59 Baxter Road Yes Yes 155 BAXTER ROADSANKATY ROADISABE L LE 'S WAY ISOBELS WAYSANKATY HEAD ROADPOL P I S R O A D BAYBERRY LANE 99 97 87 101 105 93 91 85 73 83 109 81 79 77 117 75 115 113 119 107 107A 53 51B 55 51A 63 59 69 61 71 67 65 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community G:\Projects\Lighthouse\2013\NOI\aerial.mxd Figure 1Aerial Locus with Top of Bluff Property Line Lengths (55 - 109 Baxter Road) Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project Nantucket, MA LEGEND Existing Project Lots Expanded Project Lots Property Boundary Basemap: 2016 Aerial Imagery, ESRI °0 150 30075 Feet1 inch = 300 feet Scale 1:3,600 64 feet 113 feet 105 feet 93 feet 163 feet 71 feet 91 feet 168 feet 189 feet 171 feet 170 feet 87 feet 91 feet 160 feet 273 feet 131 feet 99 feet 97 feet 82 feet 77 feet 147 feet 96 feet 106 feet 79 feet 66 feet 183 feet 109 feet 155 feet 148 feet