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Board/CommissionConservation Commission
Meeting DateFebruary 24, 2022
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WATERFORD WOODS SITE MODIFICATION 
 
384 & 394 WILLETTS AVE. EXT. 
 
WATERFORD, CONNECTICUT 
1 
APPLICATION FOR INLAND WETLAND/WATERCOURSE PERMIT 
MODIFICATION SUPPLEMENTAL NARRATIVE 
DETAILED DESCRIPTION OF PROPOSED ACTIVITY 
 
Waterford Woods, LLC is proposing to construct Phase 2 of a residential multi-family development 
on two (2) parcels of land located at 384 & 394 Willetts Avenue Extension totaling 26.64 acres. The 
second phase of the development will consist of the construction of three (3) apartment buildings with 
a total of 106 additional units. 
WATERFORD APPROVALS 
• Conservation Commission Inland Wetland Permit C-20-19, approved 1/28/21 
o Approval of regulated activities associated with a proposed multi-family development 
consisting of 98 units in 3 apartment buildings with incidental site improvements. 
• Planning & Zoning Commission Application PL-21-1, approved 3/9/21 
o Site plan approval associated with a proposed multi-family development consisting of 
98 units in 3 apartment buildings with incidental site improvements. 
• Conservation Commission Inland Wetland Permit C-21-06, approved 7/8/21 
o Approval for installation of a gravity sewer main. 
• Conservation Commission for Inland Wetland Permit C-21-12, approved 11/18/21 
o Phase 1 site plan modification for addition of Clubhouse 
• Planning & Zoning Commission Application PL-21-12, approved 12/14/21 
o Phase 1 site plan modification for additional of Clubhouse 
DETAILED DESCRIPTION OF PROPOSED MODIFICATIONS 
 
The proposed site modifications consist of Phase 2 of Waterford Woods with the addition of Building 
D at the north end of the property and Buildings E and F at the southwest corner of the property. Phase 
2 will continue to use the Phase 1 access driveway approved with the original development with minor 
widening of the exit lane to allow for separate right and left turn movements. The Phase 2 site 
modifications will include: 
• Clearing and grubbing. 
• Construction of Buildings D, E and F with an additional 106 residential units. 
• Extension of the 24’ wide main access drives to serve parking facilities adjacent to the new 
buildings. 
• Outdoor recreation areas including community spaces. 
• Additional paved parking spaces adjacent to the new buildings. Reconfiguration of parking 
spaces sitewide consistent with recently adopted Zoning Regulations to minimize impervious 
surfaces. 
• Concrete pedestrian sidewalks connecting the apartment buildings to the adjacent parking areas 
and amenities. 

 
WATERFORD WOODS SITE MODIFICATION 
 
384 & 394 WILLETTS AVE. EXT. 
 
WATERFORD, CONNECTICUT 
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• Drainage improvements including a stormwater collection network, subsurface infiltration, 
and detention ponds. 
• Extension of private water, sewer, electric, gas and telecom mains. 
• Landscaping including a mixture of street trees, shrubs, foundation plantings and planting beds 
• Building and street lighting. 
• Erosion and sedimentation control measures. 
PURPOSE OF PROPOSED ACTIVITY 
 
The purpose of the proposed activity is to meet the increasing housing needs of the surrounding 
community within the existing development footprint. 
DESCRIPTION OF REGULATED AREA & ACTIVITIES 
 
Inland wetlands and watercourses are located along the west and southern boundaries of the site and 
were field delineated by James Sipperly, Certified Soil Scientist. In total, 9.19 acres, or approximately 
35% of the 26.63-acre Site lies within delineated inland wetland areas. 
The western and southern portion of the Site are within a mapped FEMA Special Flood Hazard Area 
(SFHA) Zone A, which indicates that no base flood elevations (BFE) were determined. In general, the 
limits of the SFHA Zone A align with the wetlands and parallel existing contours. A portion of the 
Zone A is perpendicular to existing contours and passes over an elevated peninsula at the southwest 
corner of the site where the Buildings E and F are proposed. A portion of the designated Zone A area 
has been removed per FEMA Letter of Map Amendment (LOMA) 22-01-0111A. No structures are 
proposed within the remaining Zone A area on the Site. 
Wetlands, watercourses, and FEMA SFHA Zone A are delineated on maps prepared by Franklin 
Surveys for the subject parcels and submitted as part of the original approved application.  
No work, including clearing, grubbing, filling, grading, or excavation, is proposed within the 
delineated inland wetlands or watercourses on the subject Site. A portion of work related to 
modifications will occur within the 100’ Upland Review Area as shown on the site modification plans 
enclosed this application. The total area of activity within the 100’ upland review area associated with 
the Phase 2 site modifications is approximately 0.20 acres. Impacts associated with the proposed 
modifications are described below. 
o Clearing and grubbing 
o Stripping and stockpiling of topsoil 
o Excavation and construction of a portion of Building E 
o Rough and finish grading 
o Landscaping 
LIST ALTERNATIVES CONSIDERED 
  
1. NO PHASE 2 DEVELOPMENT 
As stated above, the purpose of the proposed activity is to better meet the increasing housing 
needs of the surrounding community. The proposed Phase 2 development complies with 

 
WATERFORD WOODS SITE MODIFICATION 
 
384 & 394 WILLETTS AVE. EXT. 
 
WATERFORD, CONNECTICUT 
3 
Zoning Regulations and Plan of Conservation and Development. The potential alternative of 
“no development” would not be a feasible or prudent alternative. 
2. REDUCED DEVELOPMENT 
Per Section 18.3.2, the maximum density in the C-MF district is 8-dwelling units per acre of 
land, which would allow for 213 dwelling units on the 26.63-acre site. The proposed 
development with modifications will consist of 204 units, which is below the maximum 
density. Per Section 18.3.3, maximum lot coverage for buildings is 25%. The addition of the 
Buildings D, E, and F will increase coverage to 7.3%. The new apartment buildings are 
necessary to meet rising housing demands and have been situated on the site to use driveways 
and parking associated with Phase 1. Phase 2 will have minimal impact to surrounding 
properties and no direct impact on regulated areas. Reduction would not meet the purpose of 
the project and is not a feasible or prudent alternative. 
3. DEVELOPMENT RECONFIGURATION 
The development has been designed to accommodate the physical constraints of the subject 
property, including property dimensions, topography, and wetland areas to the west and south. 
The Phase 2 buildings, driveways and parking have been situated to have direct access to Phase 
1 driveway and parking areas with minimal expansion. As sited, the development minimizes 
infrastructure (impervious surfaces) within the 100’ upland review areas as part of the 
development and minimizes clearing. Reconfiguration of the development is not a feasible or 
prudent alternative. 
ENVIRONMENTAL IMPACT 
 
The disturbance and proposed work within the 100’ upland review area has been minimized to the 
greatest extent possible and there are no prudent or feasible alternatives. The site has been designed to 
minimize the impact on the environment as follows: 
• Areas of new impervious surfaces have been minimized to the greatest extent possible. 
Impervious area total 5.619 acres (21%) of the total site, which is on the low end of the 18% 
to 30% impervious cover referenced in Section 3.1.2.3 of the Jordan Brook Watershed 
Management Plan (JBWMP) for “intermediate” level uses such as multi-family. 
• Site drainage will be collected, treated, infiltrated, and detained, thereby minimizing impact on 
stormwater quality, and slightly reducing peak flow rates as compared to existing conditions. 
Base level and secondary controls are incorporated into the design to improve water quality as 
recommended by the JBWMP. Groundwater recharge is also encouraged through 
disconnection of impervious surfaces and the use of water quality swales to promote treatment 
and infiltration. 
• Clearing and grubbing is minimized to maintain native vegetation on site. In general, a 50’ 
natural wooded buffer has been maintained along the inland wetlands as recommended by the 
JBWMP. Where clearing of the mature tree vegetation is proposed within 50’ of the inland 
wetlands, native shrubs are proposed, and conservation seed mix will be placed as 
recommended in the JBWMP. 
• Landscaping and plantings are proposed throughout the development to encourage stormwater 
recharge and match with the surrounding landscape. 

 
WATERFORD WOODS SITE MODIFICATION 
 
384 & 394 WILLETTS AVE. EXT. 
 
WATERFORD, CONNECTICUT 
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There will be no adverse environmental impact from the project. Any potential impact of the project 
is related to short-duration construction activities. The potential environmental impact of these 
temporary disturbances will be mitigated through the proper installation and maintenance of erosion 
and sedimentation controls. 
APPLICANT CERTIFICATIONS 
• No portion of the property is located within 500-feet of the boundary of an adjoining 
municipality. 
• No Traffic attributable to the completed project on the site will use streets within the adjoining 
municipality to enter or exit the site. 
• No sewer or drainage from the project site will flow through and impact the sewage or drainage 
system within the adjoining municipality. 
• No water run-off from the improved site will impact streets or other municipal or private 
property within the adjoining municipality.