DRAFT Waterford 2025 Annual MS4 Report_Permit No GSM000023 (ID 3542375)

855 Winding Brook Drive 2nd Floor 
Glastonbury, CT  06033 
T: 860.633.8770 
bartonandloguidice.com 
DRAFT 
 
 
2025 ANNUAL REPORT 
 
General Permit for the Discharge of Stormwater from  
Small Municipal Separate Storm Sewer Systems (MS4) 
 
Registration No. GSM000023 
 
for 
 
Town of Waterford, CT 
15 Rope Ferry Road 
Waterford, CT 06385 
 
 
 
 
 
 
 
 
 
Prepared By: 
 
 
 
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Town of Waterford 2025 Annual Report 
Page 1 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
MS4 General Permit 
Town of Waterford 2025 Annual Report 
Existing MS4 Permittee 
Permit Number GSM000023 
January 1, 2025 – December 31, 2025 
Primary MS4 Contact:  Gary J. Schneider; Director of Public Works; (860) 444-5864; gschneider@waterfordct.org 
 
 
This report documents the Town of Waterford’s efforts to comply with the conditions of the MS4 General Permit to the maximum extent practicable (MEP) from 
January 1, 2025 to December 31, 2025. 
 
Executive Summary 
Submission of this report by the Town Waterford maintains compliance with the reporting requirements and registration (no. GSM000023) under the General Permit 
for the Discharge of Stormwater from Small Municipal Separate Storm Sewer Systems (MS4), submitted to the State of Connecticut Department of Energy and 
Environmental Protection (‘CT DEEP’) Commissioner for activities located within the Town of Waterford.  The Town of Waterford certifies by this report that the 
terms and conditions of the General Permit are being met to the maximum extent practicable (MEP).  
 
The Town of Waterford hired a Professional Engineering Consultant, Barton & Loguidice, LLC (B&L), who has completed much of the dry weather screening and 
sampling of the Town’s existing and newly identified outfalls (428 municipally-owned, an increase from 376 in 2022).  Through the efforts of B&L, the Town continues 
working toward the completion of all dry weather outfall Illicit Discharge Detection and Elimination (IDDE) screening and sampling, and wet weather impaired outfall 
sampling efforts for all of the municipally-owned outfalls identified in the Town to the MEP. 
 
From 2021 through 2025, the Town made significant updates to the MS4 system mapping based on street map as-built drawings and field observations made by B&L.  
Through the field investigation process, large areas of the MS4 system that were previously mapped in GIS were identified as needing significant updates based on 
actual field conditions.  These areas of the Town’s system mapping were able to be resolved by adding missing structures and correcting piping to match the true 
conditions.  B&L also identified several large areas in Waterford that were missing mapping entirely and meetings were conducted with the Waterford DPW to locate 
“as-built” drawings for the missing areas.  This is a long and tedious process that exhausts a lot of resources, however, large uncertain areas of the Town’s system 
mapping were able to be resolved, missing structures added, and piping corrected to match the true conditions.  B&L’s efforts assisted in reducing the burden on the 
Town for mapping locations that could be resolved in the field allowing the Town to focus on other aspects of the MS4 permit.  By performing the actions listed 
above, B&L located approximately 50 new outfalls in 2023 and 2024, including 14 new drop down catch basins (catch basins that discharge directly into a waterway 
with no other piping connected to the system).  These newly identified outfalls have been updated in the databases and catchment ranking tables.  In 2026, efforts 
will continue to be made to complete the delineation of the outfall catchment areas. 
 
B&L’s primary focus in 2023 through 2025 was to screen all new outfalls located from 2021 through 2025.  B&L screened an additional 190 outfalls during dry weather 
events in 2023 through 2025.  To date, dry weather screening and sampling efforts were completed at 416 (an increase from 403 in 2025) Town-owned outfalls and 
a total of 80 samples were collected.  Seven outfalls sampled were identified with suspected illicit discharges and were ranked at the top of the high priority category 
for further investigations.   
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Town of Waterford 2025 Annual Report 
Page 2 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
 
B&L initiated efforts on the 12 highest priority ranked outfalls for IDDE investigations.  During these efforts, two catchments were screened completely, three 
catchments were partially screened, and seven catchments were unable to be completed because they were dry during the follow-up screening events.  More 
attempts will be made for the incomplete investigations, most likely during the spring season of 2026, when the groundwater levels are higher. 
 
In 2025, B&L continued sampling efforts during wet weather events.  In 2024, three additional samples were collected and were identified with suspected illicit 
discharges.  To date, wet weather screening and sampling efforts were completed at 34 of the 62 known impaired outfall locations.  The initial number of suspected 
outfalls discharging to impaired waters was 29, which has been increased to 62 during the mapping updates.  Of the 34 outfalls sampled, 24 were identified with 
suspected illicit discharges and were ranked at the top of the high priority category for further investigations.  Due to the limited amount of qualifying storm events, 
issues experienced out in the field, and the fact that most of the outfalls are tidally influenced, in 2026, B&L will continue its focus on collecting wet weather samples 
from the remaining outfalls and from the most upgradient structure from the waterbody as possible.  B&L will continue to attempt to collect wet weather samples 
from the impaired outfalls until all known locations are sampled.  In addition to continuing to collect initial wet weather samples, B&L was able to collect all six annual 
outfalls samples in 2025. 
 
In 2024, the Niantic River Watershed Committee tracked high occurrences of bacteria in July and August at selected stormwater outfalls to Niantic River.  They then 
collected samples in November 2024 from Banning Cove and Kiddee’s Beach and analyzed with an e/DNA sample kit.  The draft results were forwarded to the Town 
of Waterford on December 20, 2024.  Results from the Niantic River Watershed Committee efforts are attached to this report.  Follow up on these results are 
continuing, particularly regarding the detected swine DNA and potential sources of human DNA. 
 
In 2021, B&L conducted baseline inspections at 35 municipal stormwater treatment structures.  B&L has since identified five new stormwater treatment structures.  
B&L will continue to review the existing structures against available mapping to accurately map all known treatment structures for the Town and will update the 
mapping and list of structures accordingly. In 2021, B&L provided the Town with a spreadsheet of all structures inspected with the conditions of each structure listed 
and estimated costs for annual maintenance for each of the municipal structure inspected.  
 
In 2021, B&L identified the top 40 Town-owned properties with the greatest amount of impervious area.  These sites were then evaluated to determine whether or 
not runoff from the impervious areas discharge to the MS4.  The next phase of the desktop analysis was to confirm the presence of directly connected impervious 
areas (DCIA) at each site, as well as determine the suitability and capacity of site soils for supporting the implementation of retrofit projects.  Many of these sites 
were ruled out because of low depth to groundwater, they already contained treatment systems, or they were not connected to the MS4.  In 2026, the Town will 
continue working with its consultant to identify and prioritize potential projects for the Retrofit Program to the maximum extent practicable.  A new DCIA tracking 
worksheet was prepared by B&L in 2021 for inclusion in the Town’s land development applications.  The worksheet would confirm compliance of applicants with site 
stormwater runoff retainage requirements, as well as determine the total change in site DCIA. The change in site DCIA would then be incorporated into the Town’s 
overall DCIA tracking spreadsheet for determining progress towards the Town’s DCIA disconnection goal. The Town is in the process of reviewing and implementing 
the new DCIA tracking worksheet. 
 
In 2021, B&L identified all industrial and commercial facilities within the Town that likely needed to be registered for CT DEEP’s Industrial and Commercial Stormwater 
General Permits, who are not currently registered.  B&L then prepared educational brochures regarding these stormwater permits, which the Town mailed to all of 
the applicable industrial facilities in 2021 and the Town will be distributing to the commercial facilities. 
 
B&L is in the process of preparing an MS4 Pollution Prevention and Good Housekeeping Protocols document for the Town.  This document will optimize some of the 
best management practices (BMPs) that are currently being carried out by the Department of Public Works to minimize the discharge of pollutants to the Town’s 
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Town of Waterford 2025 Annual Report 
Page 3 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
MS4 and waters of the State.  BMPs for the following protocols are covered in this document: cleaning and maintenance of vehicles and equipment, leaf management, 
streets and parking lot sweeping, catch basin inspection and cleaning, and snow management. 
 
B&L evaluated the Town’s land use regulations with respect to construction stormwater runoff control and post-construction stormwater management.  A report 
was prepared comparing existing regulations to MS4 General Permit requirements.  Recommended regulatory revisions were included in this report.  The Town will 
continue to periodically review its stormwater management regulations and makes revisions, if necessary, to meet MS4 general permit requirements. 
 
 
Part I: Summary of Minimum Control Measure Activities  
 
1. PUBLIC EDUCATION AND OUTREACH (Section 6 (a)(1) / page 19) 
 
1.1 BMP Summary 
 
BMP 
Activities in current reporting 
period 
Sources Used  
(if applicable) 
Method of Distribution 
Audience 
(and number 
of people 
reached) 
Measurable goal 
Department/ 
Person 
Responsible 
Additional 
details 
1-1 Implement 
public education 
and outreach 
Link was created for accessing 
the Town’s Stormwater 
Regulations website.  Links were 
added discussing Stormwater & 
Water Quality, Impervious 
Cover, Urban Runoff, the NPDES 
Program and Save the Sound.  
Planning & Development and 
Recreation & Parks added a 
webpage link to the Stormwater. 
Informational material is also 
present at Town offices.  
Additionally, the Town continues 
to publish educational 
pamphlets on stormwater and 
fertilizer use in the quarterly 
newsletter distributed by the 
Recreation & Parks Department. 
CT DEEP, 
NRDC, UConn 
NEMO, NOFA, 
NH DES, 
Clemson 
Cooperative 
Extension, 
Minnesota 
PCA, Long 
Island Sound 
Study, Save the 
Sound, 
Connecticut 
Conservation 
Districts, EPA 
Town Offices and Webpage: 
https://www.waterfordct.org/ 
426/Stormwater-Regulations 
General 
Public 
Continue 
distributing 
educational 
brochures as bill 
inserts, mailings, 
and fact sheets 
at town offices 
and with building 
permits, and on 
the town 
website. 
Department of 
Public Works 
 
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Town of Waterford 2025 Annual Report 
Page 4 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Activities in current reporting 
period 
Sources Used  
(if applicable) 
Method of Distribution 
Audience 
(and number 
of people 
reached) 
Measurable goal 
Department/ 
Person 
Responsible 
Additional 
details 
1-2 Address 
education/ 
outreach for 
pollutants of 
concern* 
Weblinks regarding nitrogen, 
phosphorus, turbidity and 
bacteria are available on the 
Town’s Stormwater webpage. 
What residents can do to 
mitigate these pollutants is also 
discussed on the Stormwater 
webpage. 
See BMP 1-1 
Town Webpage: 
https://www.waterfordct.org/ 
426/Stormwater-Regulations 
General 
Public 
Develop and 
Distribute 
Information on 
Nitrogen and 
Bacteria 
Pollution 
Department of 
Public Works 
 
1-3 Town 
Website 
The SMP and draft Annual 
Report are also available 
through the Town’s website.  
Public educational documents 
are available on the Town’s 
Stormwater Regulations 
webpage (see BMP 1-1 and BMP 
1-2).  A notification/link for the 
Construction Stormwater 
General Permit is also available 
on the Town’s Stormwater 
Regulations webpage (see BMP 
4-6). 
See BMP 1-1 / 
BMP 1-2 
Town Webpage: 
https://www.waterfordct.org/ 
426/Stormwater-Regulations 
General 
Public 
Update website 
to include 
additional 
stormwater 
information.  
Department of 
Public Works 
 
1-4 Catch Basin 
Stenciling/Badges 
All catch basins have been 
stenciled.   
Not Applicable 
Not Applicable 
General 
Public 
Continue an on-
going stenciling 
program in which 
basins in Town 
are prioritized 
and stenciled. 
Department of 
Public Works 
The Town will 
continue its 
catch basin 
stenciling 
program, as 
needed. 
1-5 Household 
Hazardous Waste 
Collection Days 
HHW Collections Days in 2025 
were conducted on 4/5, 5/3, 
6/14, 7/12,  8/2, 9/13, 10/4 and 
11/1. 
Southeastern 
Connecticut 
Regional 
Resources 
Recovery 
Authority 
(SCRRRA) 
Town Webpage:  
www.waterfordct.org/ 418/Hazardous-
Household-Waste-Paper-Shreddin 
 
SCRRRA provided fliers. 
General 
Public 
Continue 
program in an 
effort to remove 
household 
hazardous waste 
safely from the 
waste stream 
using a 
Qualifying Local 
Program 
Department of 
Public Works 
 
 
 
 
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Town of Waterford 2025 Annual Report 
Page 5 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
1.2 Describe any Public Education and Outreach activities planned for the next year, if applicable 
• 
Continue to update the Town’s Stormwater webpage with new/updated stormwater related information  
• 
Continue distributing educational brochures 
• 
Attempt to coordinate efforts with local schools for presentation on stormwater management 
• 
Continue the catch basin stenciling/badges program, as needed 
• 
Continue to coordinate HHW program 
 
 
2. PUBLIC INVOLVEMENT/PARTICIPATION (Section 6(a)(2) / page 21) 
 
2.1 BMP Summary 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Location Posted 
Additional details 
2-1a Final 
Stormwater 
Management Plan 
publicly available  
Complete 
Notice of the SMP was published in 
The Day newspaper and on Town’s 
Stormwater website.   
Notify public of 
published SMP and 
document comments 
received. 
Department of 
Public Works 
April 1, 2017 
 
The Day, Planning & 
Development and Town Clerk’s 
Offices, Department of Public 
Works Complex, the Library and 
https://www.waterfordct.org/ 
426/Stormwater-Regulations 
The Stormwater 
Management Plan 
will be reviewed 
periodically and 
updated, as 
necessary. 
2-1b Comply with 
public notice 
requirements for 
Annual Reports 
(annually by 2/15) 
Complete 
Notice of the draft 2024 Annual 
Report was posted on the Town’s 
website on 1/15/25 and the report 
was available on the Town’s 
website from 2/13/25 through 
3/25/25. 
 
Notify public of draft 
Annual Report and 
document comments 
received. 
Department of 
Public Works 
2024 Report: 
Feb 13, 2025 
 
2025 Report: 
Feb 16, 2026 
 
Planning & Development and 
Town Clerk’s Offices, 
Department of Public Works 
Complex, the Library and 
https://www.waterfordct.org/ 
411/Public-Works 
Notice of the draft 
2025 Annual Report 
was posted in The 
Day newspaper on 
2/2/26 and the 
report was made 
available on the 
Town’s website on 
2/16/26. 
2-2 Community 
Group 
Engagement 
Complete 
The Planning Department and 
Public Works department 
coordinated with the State of CT 
and Eastern CT Conservation District 
to installed BMP educational 
signage for a vegetated swale and 
tree filters at public parking area in 
Mago Point. 
Identify and reach 
out to local 
organizations that 
may want to 
participate in review 
and implementation 
of this SMP. 
Department of 
Public Works 
On-going 
 
 
2-3 Interagency 
Meetings 
Complete 
Meetings were held throughout the 
year with Public Works and 
Planning & Development. 
Continue to facilitate 
a panel of staff and 
volunteers. 
Department of 
Public Works 
On-going 
Not Applicable 
 
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Town of Waterford 2025 Annual Report 
Page 6 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
2.2 Describe any Public Involvement/Participation activities planned for the next year, if applicable.  
• 
Continue to provide notice of updated SMPs and draft Annual Reports 
• 
Continue to engage Community Groups 
• 
Continue interagency meetings 
• 
Continue to publish educational pamphlets on stormwater and fertilizer, used in quarterly newsletters distributed by the Recreation & Parks Department.  
 
 
3. ILLICIT DISCHARGE DETECTION AND ELIMINATION (Section 6(a)(3) and Appendix B / page 22) 
 
3.1 BMP Summary  
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
3-1 Develop written IDDE 
program (Due 7/1/19) 
Complete 
The Town finalized its IDDE program. 
Development and 
implement an IDDE Program  
Department of 
Public Works 
Apr 29, 2020 
 
3-2 Develop list and maps 
of all MS4 stormwater 
outfalls in priority areas 
(Due 7/1/20) 
Substantially 
Complete 
From 2021 through 2025, with 
assistance from the Town’s consultant, 
Barton & Loguidice, the Town 
conducted significant efforts to confirm 
and locate additional outfalls in priority 
areas that were either incorrect or not 
previously identified. 
Finalize mapping of all MS4 
Outfalls 
Department of 
Public works 
Substantially 
Complete 
December 
2024 
In 2026, the Town will 
continue to update its 
mapping as new 
information is gathered. 
3-3 Implement citizen 
reporting program  
(On-going) 
In Progress/ 
On-going 
Currently, citizens can call the 
Department of Public Works to report 
any activities.  
Develop an online method 
for citizens to report spills 
and illicit dischargers 
Department of 
Public Works  
February 2025 
The Town is adding an 
email and phone contact 
on the stormwater page 
for reporting illicit 
discharges.  
3-4 Establish legal authority 
to prohibit illicit discharges 
(Due 7/1/19) 
Substantial 
Complete 
Current ordinance generally meets 
requirements.  The Town reviewed its 
ordinance against the template 
provided by UConn CLEAR and may 
make slight changes to be more 
consistent with the template. 
Review and update 
ordinances. 
Department of 
Public Works  
December 
2024 
 
3-5 Develop record keeping 
system for IDDE tracking 
(Due 7/1/17) 
Complete 
The Town currently uses excel and 
access spreadsheets, along with GIS, for 
IDDE tracking.   
Record illicit discharge 
abatement activities.  
Develop and maintain an 
SSO inventory.  
Department of 
Public Works 
Jul 1, 2017 
On-going 
 
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Town of Waterford 2025 Annual Report 
Page 7 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
3-6 Address IDDE in areas 
with pollutants of concern 
In Progress 
From 2021 through 2025, B&L 
continued IDDE investigations for 
catchment areas that discharge to 
impaired waters.  It is anticipated that 
B&L will complete the initial 
investigations started and will continue 
to investigate additional suspected illicit 
discharges in 2026 to the maximum 
extent practicable. 
Identify which areas in Town 
are most likely to contribute 
nitrogen phosphorous, and 
bacteria to the MS4 (IDDEs). 
Department of 
Public Works 
On-going 
The Town continues to 
identify structures that 
are not connected to the 
sanitary sewer system 
which are located near 
the MS4. 
3-7 Map MS4 System in 
Priority Areas 
Substantially 
Complete 
From 2021 through 2025, with 
assistance from B&L, the Town 
conducted significant efforts to confirm 
and locate additional outfalls in priority 
areas that were either not mapped 
correctly or were not previously 
identified.  The Town also conducted 
efforts for updating the mapping for 
catch basins, piping and stormwater 
structures in priority areas. 
Map Priority Areas 
Department of 
Public Works 
Substantially 
Complete 
December 
2025 
In 2026, the Town will 
continue to update its 
mapping as new 
information is gathered. 
 
3.2 Describe any IDDE activities planned for the next year, if applicable. 
• 
Post IDDE Program to the Stormwater webpage and include link in next year’s Annual Report 
• 
Post an Illicit Discharge Reporting link on the Stormwater webpage 
• 
Continue updating the MS4 outfall and system mapping 
• 
Maintain master IDDE tracking system 
• 
Continue to investigate illicit discharges in areas with pollutants of concern 
 
3.3 Provide a record of all citizen reports of suspected illicit discharges and other illicit discharges occurring during the reporting period and 
SSOs occurring July 2017 through end of reporting period using the following table.  
No citizen reports of suspected illicit discharges were reported during 2025. 
No other illicit discharges were reported during 2025. 
 
 
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Town of Waterford 2025 Annual Report 
Page 8 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
Location 
(Lat long/ street crossing 
/address and receiving 
water) 
Date and 
duration of 
occurrence 
Discharge to 
MS4 or 
surface water  
Estimated 
volume 
discharged 
Known or suspected cause / 
Responsible party 
Corrective measures planned and 
completed (include dates) 
Sampling data (if 
applicable) 
The following SSOs were reported from 2017 through 2025 
Magonk Point Road 
Started 8/31/21 
Ended 9/1/21 
No 
51-500 
gallons 
Pump station equipment failure 
(reported by neighbor) / 
Utility Commission Office 
Force main was drained, tanker was used 
to by-pass the pump station, and 
staff/contractor repaired the pipe. 
N/A 
Cross Road 
Started 9/26/21 
Ended 9/27/21 
No 
51-500 
gallons 
Sewer Line Blockage – A spill out a 
manhole located on a large grass area 
outside BJs in Waterford was reported 
by BJs property manager.   
Cleared the backup and cleaned the 
pipe.  It appears that non-flushable 
materials are being discharged into the 
collection system. 
N/A 
SMH 15-18A located at 
the corner of Uncas Ave 
and Rt 32 
Started 8/23/24 
Ended 8/23/24 
Yes – majority 
of discharge 
went to the 
ground 
~1000 gallons 
Blockage prohibiting discharge from 
surrounding properties including fats, 
oils and grease and rags/wipes.  
Cleared the clog with jet rodder.  
Conduct aggressive preventative 
maintenance program cleaning and 
camera’ing 10-20% of the system 
annually, including areas of low slope. 
Increasing FOG awareness literature and 
creating a marketing campaign 
surrounding it for all users. 
N/A 
253A Shore road 
Started 
8/23/2025 
Ended 8/25/2025 
No 
100 gallons 
Sewage line break or failure 
Cracked 45 was removed and replaced 
by contractor 
N/A 
 
3.4 Provide a summary of actions taken to address septic failures during the Reporting Period using the table below. 
Method used to track illicit 
discharge reports 
Location and nature of structure with 
failing septic systems 
Actions taken to respond to and address the 
failures 
Impacted waterbody or 
watershed, if known 
Dept. / Person 
responsible 
Septic Installation Log 
24 Williams   
Blocked sewer pipe from house to street., plumber 
snaked out sewer pipe 
Unknown 
Ledge Light Health 
District 
Septic Installation Log 
8 Baldwin 
Grinder pump failure, new grinder pump installed 
12/29/2025 
Unknown 
Ledge Light Health 
District 
Septic Installation Log 
246 Bloomingdale 
Repairs were initiated by the septic installer 
Unknown 
Ledge Light Health 
District 
 
 
 
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Town of Waterford 2025 Annual Report 
Page 9 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
3.5 Briefly describe the method and effectiveness of said method used to track illicit discharge reports.  
Currently, phone calls and emails are received by the Department of Public Works from citizen’s reporting possible illicit discharges.  The Town will continue tracking illicit discharges using an 
excel table.   
 
3.6 IDDE reporting metrics 
Metrics 
Estimated or actual number of MS4 outfalls 
428 
Estimated or actual number of interconnections 
21 
Outfall mapping complete 
~99% - Substantially complete 
Interconnection mapping complete 
~99% - Substantially complete 
System-wide mapping complete (detailed MS4 infrastructure)  
~99% - Substantially complete 
Outfall assessment and priority ranking 
428 outfalls have initial rankings 
Dry weather screening of all High and Low priority outfalls complete 
416 of 428 
Catchment investigations complete 
12 investigations were initiated and are on-going 
Estimated percentage of MS4 catchment area investigated 
Approximately 5% 
 
3.7 Briefly describe the IDDE training for employees involved in carrying out IDDE tasks including what type of training is provided and how 
often is it given (minimum once per year). 
An MS4 and IDDE training program was developed for presentation to all Town personnel that may come into contact with stormwater or that may review applications and plans that impact 
stormwater quality.  Typically, this training is conducted on an annual basis for members of Public Utility, Board of Education, Department of Public Works, Parks and Recreation, Police 
Department, and Fire Department.  Many IDDE topics are discussed during the Town’s annual SPCC and SWPPP training events.  B&L provided an in-person training event with members of 
Public Utility, Department of Public Works, and Parks & Recreation on the general topics of the MS4 and IDDE program and the annual SPCC and SWPPP on November 11, 2025.  
 
 
 
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Town of Waterford 2025 Annual Report 
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Permit Number GSM000023 
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4. CONSTRUCTION SITE RUNOFF CONTROL (Section 6(a)(4) / page 25) 
 
4.1 BMP Summary  
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
4-1 Implement, 
upgrade, and enforce 
land use regulations or 
other legal authority to 
meet requirements of 
MS4 general permit  
(Due 7/1/20) 
Complete 
P&Z updated the Subdivision and 
Zoning Regulations to incorporate 
LID, green infrastructure, and 
stormwater design requirements.  
B&L, the Town’s consultant, 
evaluated the Town’s land use 
regulations and provided 
recommended updates.  
Review and update the 
regulations to be consistent 
with the requirements of the 
permit. 
 
Planning 
April 2018 
The Town periodically reviews its 
stormwater management regulations 
and makes revisions, if necessary, to 
meet MS4 general permit requirements. 
4-2 Develop/Implement 
plan for 
interdepartmental 
coordination in site 
plan review and 
approval (On-going) 
Complete 
Site applications are forwarded to 
Town Officials for review and 
comment during application process. 
Plans are not signed by commission 
until all departments have signed off 
on project plan.  
Document Current 
Procedure 
Planning 
Jul 1, 2017 
On-going 
 
4-3 Review site plans 
for stormwater quality 
concerns  
(On-going) 
Complete 
Commercial and residential site plans 
involving greater than 0.5 acre of 
land disturbance were reviewed for 
stormwater quality control 
measures. 
Continue to review all design 
plans for consistency with 
town and state guidelines 
for erosion and sediment 
control. 
Planning 
Jul 1, 2017 
On-going 
Application review checklists have been 
revised to include stormwater 
management regulation requirements  
4-4 Conduct site 
inspections  
(On-going) 
Complete 
Zoning and Inland Wetland 
enforcement staff verify site 
development practices are in 
accordance with approved plans. 
Planning staff employ an inspection 
checklist to document compliance 
and to identify measures requiring 
repair/additional control measures. 
Inspections occur after every 
significant rainfall event.  
Document Inspections 
Performed 
Continue existing program of 
construction inspections. 
Planning 
Jul 1, 2017 
On-going 
 
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Town of Waterford 2025 Annual Report 
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Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
4-5 Implement 
procedure to allow 
public comment on site 
development  
(On-going) 
Complete 
All agendas and minutes are noticed 
in compliance with State 
requirements for public notice. 
Public hearings announced in 
newspaper. Complaints regarding 
land-disturbance are forwarded to 
Planning and Development 
Department. 
Document Public Comments 
Planning 
Jul 1, 2017 
 
4-6 Implement 
procedure to notify 
developers about DEEP 
construction 
stormwater permit  
(On-going) 
Complete 
Town agencies notify developers of 
stormwater requirements. When 
applicable, developers submit 
notification of registration to State.  
P&Z application checklist was revised 
to require applicant’s determination 
if a Construction Stormwater GP is 
required. 
Update application forms to 
include determining if 
Construction Stormwater GP 
is required.  Updated 
webpage.  
Planning 
Jul 1, 2019 
A note was added to the website 
regarding need for a Construction 
Stormwater GP: 
https://www.waterfordct.org/426/ 
Stormwater-Regulations 
 
4.2 Describe any Construction Site Runoff Control activities planned for the next year, if applicable. 
• 
Continue to update land use regulations to improve compliance with MS4 General Permit. 
• 
Continue to review all design plans for consistency with Town and State guidelines for erosion and sediment control. 
• 
Continue existing program for construction inspections. 
• 
Continue to follow all State public notice and hearing requirements and follow up on all comments and complaints received. 
 
 
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Town of Waterford 2025 Annual Report 
Page 12 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
5. POST-CONSTRUCTION STORMWATER MANAGEMENT (Section 6(a)(5) / page 27) 
 
5.1 BMP Summary 
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
5-1 Establish and/or 
update legal authority 
and guidelines 
regarding LID and 
runoff reduction in site 
development planning 
(Due 7/1/22) 
Complete 
P&Z updated the Subdivision and 
Zoning Regulations to incorporate 
LID, green infrastructure, and 
stormwater design requirements.   
B&L, the Town’s consultant, 
evaluated the Town’s land use 
regulations and provided 
recommended updates. 
Review and update the 
regulations to be consistent 
with the requirements of the 
Permit. 
Planning 
April 2018 
The Town periodically 
reviews its stormwater 
management regulations 
for effective LID 
implementation and run-
off reduction. 
5-2 Enforce LID/runoff 
reduction requirements 
for development and 
redevelopment 
projects  
(Due 7/1/22) 
Complete 
Section 25.6 Stormwater 
Management regulations require LID, 
run-off control and stormwater 
treatment to the maximum extent 
practicable for all new development 
>0.5 acre.   
B&L, the Town’s consultant, 
evaluated the Town’s LID/runoff 
reduction requirements and 
provided recommended updates. 
Review current regulations 
to identify and, where 
appropriate, reduce or 
eliminate existing regulatory 
barriers to implementation 
of LID and runoff reduction 
practices to the MEP. 
Planning 
April 2018  
On-Going 
The Town periodically 
reviews its regulations 
requiring run-off 
reduction for 
development and 
redevelopment projects 
and revises requirements 
affecting impervious 
surface area, as needed. 
5-3 Identify retention 
and detention ponds in 
priority areas  
(Due 7/1/20) 
Substantially 
Complete  
Known ponds under the control of 
the Town have been mapped.  In 
2021 through 2025, B&L continued 
to review the mapping and made 
updates to the ponds, as necessary. 
Inventory Town retention/ 
detention ponds 
Department of 
Public Works 
Mar 23, 2018 
 
DRAFT

 
Town of Waterford 2025 Annual Report 
Page 13 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
5-4 Implement long-
term maintenance plan 
for stormwater basins 
and treatment 
structures  
(On-going) 
Complete/ 
On-going 
Inspection reports and water quality 
monitoring for stormwater and 
treatment basins continue to be 
completed. Town maintains an 
inventory of required stormwater 
management control practices for 
completed site developments.  
Documentation of inspection and 
maintenance of stormwater 
treatment is requested as part of 
land use and building permit 
approvals.  Town employees receive 
instruction on maintenance for rain 
gardens, stormwater detention 
/treatment systems. 
All basins and structures are 
inspected and maintained at least 
annually.  
Develop a maintenance plan 
for retention/ detention 
ponds and stormwater 
treatment structures that it 
owns or over which it holds 
an easement or other 
authority and that are 
located in the Permittee’s 
priority areas to ensure their 
long-term effectiveness. 
Planning 
Feb 15, 2018 
On-going 
A plan for routine 
inspections and 
maintenance for the 
Town’s basins and 
structures is in place.  In 
2021, B&L conducted 
stormwater structure 
inspections for all ~40 
stormwater treatment 
structures identified.  
Based on the inspections 
conducted, B&L provided 
the Town with a cost 
spreadsheet for budgeting 
annual maintenance. 
5-5 DCIA mapping  
(Due 7/1/20) 
Substantially 
Completed 
The DCIA for the priority areas have 
been calculated using the available 
impervious cover layers. 
Calculate DCIA 
Department of 
Public Works 
Jul 1, 2020 
On-going 
The DCIA mapping will be 
updated, as necessary, to 
include retrofit, 
development and 
development projects. 
5-6 Address post-
construction issues in 
areas with pollutants of 
concern 
Not Started 
None 
Document issues identified 
and address. 
Prioritize areas for the DCIA 
retrofit program under 
MCM-6 
Department of 
Public Works 
On-going 
 
 
5.2 Describe any Post-Construction Stormwater Management activities planned for the next year, if applicable. 
• 
Continue to periodically review and update land use regulations for compliance with MS4 General Permit. 
• 
Continue to enforce LID/runoff reduction requirements for development and redevelopment projects. 
• 
Review Stormwater Structures Management Plan for areas of optimization. 
• 
Continue to conduct inspections and water quality monitoring for stormwater and treatment basins. 
• 
Continue updating the DCIA mapping, as necessary. 
 
 
 
DRAFT

 
Town of Waterford 2025 Annual Report 
Page 14 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
5.3 Post-Construction Stormwater Management reporting metrics 
Metrics 
Baseline (2012) Directly Connected Impervious Area (DCIA) 
240 
acres 
DCIA disconnected (redevelopment plus retrofits) 
Unknown 
acres this year / acres total 
Retrofits completed 
Unknown 
# 
DCIA disconnected 
TBD 
% this year / % total since 2012 
Estimated cost of retrofits 
Unknown 
$ 
Stormwater treatment structures identified (including detention/retention ponds, 
oil water separators, hydrodynamic separators, green infrastructure, etc.) 
56 total treatment structures  
16 retention/detention ponds 
# total 
 
5.4 Briefly describe the method to be used to determine baseline DCIA. 
To calculate the baseline DCIA for the Town of Waterford, the Town used the process found on the CT NEMO website.  CT NEMO developed 5 formulas to calculate the DCIA and Impervious 
Cover (IC) independently for each basin in the Town using the percent DCIA for the basin with the state DCIA removed from the equation.  The Town took the formulas and created a bell 
curve to input the calculated percent of DCIA for each basin and calculate the total DCIA and IC amounts for the Town.  Each basin value was added together to create the baseline for the 
DCIA and IC for the Town. 
 
 
6. Pollution Prevention/Good Housekeeping (Section 6(a)(6) / page 31) 
 
6.1 BMP Summary  
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
6-1 Develop/implement 
formal employee 
training program  
(On-going) 
Complete/ 
On-going 
A training program has been 
developed.   
B&L provided an in-person training 
event with members of Public Utility, 
Department of Public Works, and 
Parks & Recreation Department on 
the general topics of the MS4 and 
IDDE program and the annual SPCC 
and SWPPP on November 11, 2025. 
Track Town employee 
training 
DPW, Parks and 
Rec., Utility 
Commission, 
Waterford 
Buildings and 
Grounds, and 
Waterford BOE.  
On-going 
 
6-2 Implement MS4 
property and operations 
maintenance  
(On-going) 
Complete/ 
On-going 
Salt piles are stored under cover and 
on impervious surfaces.  Town 
industrial stormwater discharges are 
monitored.  Vehicle maintenance is 
performed undercover. 
Continue the pattern of MS4 
property and operations 
maintenance in accordance 
with the Permit. 
Depart of Public 
Works, Police 
Depart, Fire 
Depart, Board of 
Ed, Parks and Rec 
Jul 1, 2017 
On-going 
The Town periodically 
reviews current practices 
and looking for areas for 
optimization. 
DRAFT

 
Town of Waterford 2025 Annual Report 
Page 15 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
6-3 Implement 
coordination with 
interconnected MS4s 
In Progress 
Through the outfall identification 
process, the Town has identified 
several interconnections with the 
neighboring towns/cities & the DOT. 
Coordinate pollution 
prevention activities with 
interconnected MS4s. 
Department of 
Public Works 
On-going 
As new data is collected at 
interconnections, the 
Town will provide that 
data to the neighboring 
towns/cities & the DOT. 
6-4 Develop/implement 
program to control 
other sources of 
pollutants to the MS4 
Substantially 
Complete 
The Town has identified industrial 
and commercial facilities not 
registered under DEEP’s Industrial 
Stormwater General Permit and 
Commercial Stormwater General 
Permit, respectively. Educational 
brochures were mailed to the 
industrial facilities in 2021, notifying 
them of their potential obligation to 
register. 
Develop and implement a 
program to control the 
contribution of pollutants to 
the MS4. 
Department of 
Public Works 
Aug 2021 
Spring 2022 
 
Commercial brochures 
will be mailed to facilities, 
notifying them of their 
potential obligation to 
register. 
6-5 Evaluate additional 
measures for discharges 
to impaired waters* 
On-going 
The Town prohibits the feeding of 
waterfowl to help manage 
populations at Town ponds. 
Identify potential project 
locations. 
Department of 
Public Works 
N/A 
 
6-6 Track projects that 
disconnect DCIA  
(On-going) 
In Progress 
A table was created for tracking 
disconnected DCIA. The Town 
continues filling out the DCIA 
tracking table with completed 
development projects dating back to 
2012. 
B&L reviewed all Town approved 
projects since 2012 to identify all 
potential projects completed during 
that time.  B&L created a DCIA 
tracking form that is to be completed 
for each new project. 
Annually track acreage of 
DCIA disconnected as a 
result of redevelopment/ 
retrofit projects within the 
Town.  
Department of 
Public Works 
Jul 1, 2019 
On-going 
The Town will continue to 
maintain records of all 
disconnected DCIA 
projects.   
DRAFT

 
Town of Waterford 2025 Annual Report 
Page 16 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
BMP 
Status 
Activities in current reporting 
period 
Measurable goal 
Department/ 
Person 
Responsible 
Date 
completed/ 
projected 
Additional details 
6-7 Implement 
infrastructure repair/ 
rehab program  
(Due 7/1/21) 
On-going 
In 2022, the Town installed a new 
catch basin in line with an already 
existing pipe at the corner of Leary 
Drive and Quarry Road. The Town 
replaced some piping on Gardiners 
Wood Road and also replaced two 
pipes and one center line catch basin 
top on Lakes Pond Road. 
The Town replaced numerous catch 
basin tops on Butlertown Road prior 
to paving. 
Identify MS4 structures to 
repair, rehabilitate, or 
upgrade to reduce pollutant 
discharge.  
Department of 
Public Works 
December 
2022 
On-going 
The Town periodically 
reviews current practices 
and to identify areas for 
optimization. 
6-8 Develop/implement 
plan to identify/ 
prioritize retrofit 
projects  
(Due 7/1/20) 
In Progress 
With the assistance of B&L, Town-
owned sites with the greatest 
amount of impervious area were 
identified as potential candidates for 
retrofit projects. 
Develop a retrofit project 
plan to identify and prioritize 
DCIA connection projects 
Department of 
Public Works 
December 
2023 
On-going 
The Town will continue to 
identify and prioritize 
potential projects for the 
Retrofit Program to the 
maximum extent 
practicable. 
6-9 Implement retrofit 
projects to disconnect 
2% of DCIA  
(Due 7/1/22) 
In Progress 
With the assistance of B&L, Town-
owned sites with the greatest 
amount of impervious area were 
identified as potential candidates for 
retrofit projects. 
Implement retrofit projects 
Planning  
Jul 1, 2023 
On-going 
The Town will continue to 
identify and prioritize 
potential projects for the 
Retrofit Program to the 
maximum extent 
practicable. 
6-10 Develop/ 
implement street 
sweeping program  
(On-going) 
Complete/ 
On-going 
Typically, all Town-owned roads are 
swept every year, starting after the 
last snow melt.  In 2025, the Town 
continued their typical sweeping 
program. 
Continue sweeping all 
streets at least once per 
year, as soon as possible 
after snowmelt. 
Department of 
Public Works 
Jul 1, 2017 
On-going 
The Town periodically 
reviews current practices 
to identify areas for 
optimization. 
6-11 Develop/ 
implement catch basin 
cleaning program  
(On-going) 
Complete/ 
On-going 
The Town cleans approximately 1/3 
of all of the catch basins annually.  
Continue current 
maintenance program in 
accordance with the Permit. 
Department of 
Public Works 
Jul 1, 2019 
On-going 
The Town periodically 
reviews current practices 
to identify areas for 
optimization. 
6-12 Develop/ 
implement snow 
management practices  
(Due 7/1/18) 
Complete/ 
On-going 
The Town follows the DEEP 
Guidelines on snow management, to 
the maximum extent practicable.  
The Town streets and municipal lots 
were plowed, as necessary.  Roads 
were treated with salt (no sand), as 
necessary. 
Develop/implement snow 
management practices 
Department of 
Public Works 
Jul 1, 2017 
On-going 
The Town periodically 
reviews current practices 
to identify areas for 
optimization. 
 
DRAFT

 
Town of Waterford 2025 Annual Report 
Page 17 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
6.2 Describe any Pollution Prevention/Good Housekeeping activities planned for the next year, if applicable. 
• 
Conduct annual MS4 training events. 
• 
Continue to periodically review MS4 property and operations maintenance practices for areas of optimization. 
• 
Notify commercial facilities of their requirements to register under the Commercial Stormwater GP. 
• 
Continue tracking disconnected DCIA using the table created. 
• 
Continue efforts to identify and prioritize potential projects for the Retrofit Program to the maximum extent practicable. 
• 
Continue street sweeping, catch basin cleaning and snow management practices. 
 
6.3 Pollution Prevention/ Good Housekeeping reporting metrics 
Metrics 
Employee training provided for key staff  
Yes – November 11, 2025 
Street sweeping 
 
Curb miles swept 
~200 miles were swept in 2025 
Volume (or mass) of material collected 
Unknown 
Catch basin cleaning 
 
Total catch basins in priority areas 
~3,000 
Total catch basins in MS4 
~3,000 
Catch basins inspected 
1,006 
Catch basins cleaned 
1,006 
Volume (or mass) of material removed from all catch basins 
~370 CY 
Volume removed from catch basins to impaired waters (if known) 
Unknown 
Snow management 
 
Type(s) of deicing material used 
Salt 
Total amount of each deicing material applied 
~1,500 tons 
Type(s) of deicing equipment used 
Truck/spreader 
Lane-miles treated 
242 miles 
Snow disposal location 
N/A 
Staff training provided on application methods & equipment 
Yes – as necessary 
Municipal turf management program actions (for permittee properties in basins with N/P 
impairments) 
 
Reduction in application of fertilizers (since start of permit) 
Unknown 
Reduction in turf area (since start of permit) 
Unknown 
Lands with high potential to contribute bacteria (dog parks, parks with open water, & sites with 
failing septic systems) 
 
Cost of mitigation actions/retrofits 
N/A 
 
 
 
DRAFT

 
Town of Waterford 2025 Annual Report 
Page 18 of 32 
Permit Number GSM000023 
Barton & Loguidice, LLC 
6.4 Catch basin cleaning program  
Provide any updates or modifications to your catch basin cleaning program. 
Catch basins have been inspected and cleaned out and the sumps have been measured.  The Town continues to clean and inspect approximately 1/3 of all of the catch basins annually, and 
the amount of material removed is recorded.  A list will be generated and the catch basins with the most material present will be put on a more frequent cleaning schedule to ensure that the 
50% design capacity for the sump is not exceeded. 
 
6.5 Retrofit program 
Briefly describe the Retrofit Program identification and prioritization process, the projects selected for implementation, the rationale for the selection of those projects and the total DCIA 
to be disconnected upon completion of each project. (Due 7/1/20) 
It should be noted that many of the Town of Waterford’s impervious areas already had stormwater treatment systems installed prior to the issuance of the 2017 MS4 General Permit and the 
Town continues to identify new projects and retrofit projects to the maximum extent practicable.  With the assistance of B&L, Town-owned sites with the greatest amount of impervious area 
were identified for potential retrofit projects.  Many of these sites were ruled out because of low depth to groundwater, they already contained treatment systems, or they were not 
connected to the MS4.   
 
In 2022, as part of the Niantic River Watershed 4-Town Bio-Infiltration, Filtration & Water Collection Project, in cooperation with the Eastern CT Conservation District and funded by a Section 
319 grant, the Town of Waterford installed 20 catch basin smart sponge inserts (storm drain filters) in the neighborhood around the avenues east of Niantic River and 2 tree filters were 
installed on Scenic View Drive, all to treat run-off draining to Niantic River.  Operation & Maintenance Plans were also created for both the storm drain filters and for the tree filters (wells) to 
assist with the inspection and maintenance of the filters.  The catch basin filter inserts that were installed were specially designed and installed to capture and filter stormwater runoff from 
impervious surfaces in the neighborhood around the avenues east of Niantic River to protect and improve water quality in an un-named brook and Niantic River.  These catch basin filter 
inserts provide the following benefits: reduces the frequency of maintenance required for BMPs downstream of the storm drain filters; captures trash, debris, and sediment, as well as 
removes fine sediment (TSS); removes phosphorous, hydrocarbons and oil; and, some filter media can remove heavy metals as well.  These catch basin filter inserts will filter stormwater 
runoff from the roadway and parking lots, removing up to 99% of common NPS pollution, prior to its discharge to Niantic River.  The tree wells installed are a Low Impact Development (LID) 
bio-retention practice that is used to capture and infiltrate stormwater.  The tree well plants absorb some of the water that flows into the unit and utilize some of the nutrients as well.  The 
top soil contains micro-organisms that are capable of breaking down a wide variety of common contaminants including hydrocarbons, fecal bacteria, pesticides, herbicides and fertilizer. The 
bark mulch provides carbon-rich organic material for both soil biota and the tree well plants.  The 2 tree well systems installed on Scenic View Drive intercept stormwater runoff from the 
roadway.  The Scenic View Drive tree wells are designed to infiltrate stormwater, preventing contaminated runoff from entering Niantic River and Bay via storm drain discharge.  Native 
ornamental grass (PANICUM VIRGATUM `RUBY RIBBONS`) was installed in the tree wells, which are drought-tolerant. 
 
In 2021, an area at the Town’s Transfer Station was redirected to a vegetated swale prior to discharge to the system at 1000 Hartford Turnpike.  This system then discharges to Jordan Brook.  
An approximate impervious area of 70,000 sqft is now treated. 
 
In 2021, improvements were made to the pond at the Town’s civic triangle included constructing a 2,500 sq. ft. forebay to pre-treat stormwater discharging from Rt 1 and adjacent homes and 
business