Conservation Commission Agenda (linked)
agenda center agenda
| Board/Commission | Conservation Commission |
|---|---|
| Meeting Date | June 12, 2025 |
| Pages | 57 |
| File Size | 5.4 MB |
| OCR Status | Searchable (OCR processed) |
| Source URL | Original |
Document Preview
Full Text (OCR Extracted)
DETERMINATION OF NO REGULATED ACTIVITY OR, IN THE
ALTERNATIVE, REQUEST TO CONDUCT REGULATED
ACTIVITIES ASSOCIATED WITH A PROPOSED NEW PUBLIC
SCHOOL LOCATED AT 51 DANIELS AVENUE
MAY 1, 2025
Kate Ericson
kericson@learn.k12.ct.us
Executive Director
LEARN
44 Hatchetts Hill Road
Old Lyme, CT 06371
Phone: 860 434 4800
Dean Gustafson, Soil Scientist
dgustafson@allpointstech.com
567 Vauxhall Street Extension — Suite 311
Waterford, CT 06385
Phone: 860 552 2033
Mark Vertucci PE, PTOE
mark.vertucci@fando.com
One Financial Plaza, 15" Floor
Hartford, CT 06103
Phone: (860) 783 4756
Katelyn Chapin AIA
kchapin@newmanarchitects.com
Newman Architects
265 Church Street, 15" Floor
New Haven, CT 06510
Phone:
Kathryn Gagnon PE, LEED AP
kgagnon@Langan.com
Long Wharf Maritime Center
555 Long Wharf Drive, 9th Floor
New Haven, CT 06511-6107
Phone: (203) 562 5771
Matthew Ranelli, Esq., LEED AP
mranelli@goodwin.com
Shipman & Goodwin LLP
265 Church Street, 12'" Floor
New Haven, CT 06510
PHONE: (860) 251-5748
TABLE OF CONTENTS
May 1, 2025
1. Transmittal letter
2. Application form
EE Statewide Inland Wetlands and Watercourses Activity Reporting Form
4. Plan Sheet CS100 showing proposed new lot lines, photo-reduced to 11" x 17"
5. Plan sheet CS101-CS102 showing proposed activities and upland review area, photo
reduced to 11" x 17"
6 Wetland Assessment Map, prepared by All-Points Technology Corp., dated September
2024
7. Environmental Assessment Report (excerpt), prepared by All-Points Technology Corp.,
dated May 1, 2025
8. Stormwater Management Report (excerpt), prepared by Langan, dated May 1, 2024
9. Narrative Response to Pre-Application Review Comments from Town Environmental
Planner.
10. Notification letter to Waterford Utilities Commission/Water Company
SUBMITTED UNDER SEPARATE COVER
Application Fee
Full-Size Plan Sets
Stormwater Management Report, prepared by Langan, dated May 1, 2025.
Environmental Assessment Report, prepared by All-Points Technology Corp., dated May 1,
2025
TAB 1
SHIPMA
Matt Ranelli 265 Church Street
Phone: (203) 836-2805 Suite 1207
MRanelli@goodwin.com New Haven, CT 06510
May 1, 2024
Richard Muckle, Chair and Commission Members Maureen FitzGerald
Waterford Conservation Commission Environmental Planner
15 Rope Ferry Road 15 Rope Ferry Road
Waterford, CT 06385 Waterford, CT 06385
Re: — Request For Determination Of No Regulated Activities Or, In The Alternative,
Request For Approval To Conduct Regulated Activities Associated With A
Proposed New School Facility; 51 Daniels Avenue, Waterford CT
Dear Chair Muckle and Commission Members:
On behalf of our client, LEARN Regional Education Service Center (“LEARN”), we are
pleased to submit to the Conservation Commission the enclosed request for determination of no
regulated activities or on the alternative application for approval to conduct regulated activities
associated with the redevelopment of the existing Southwest School property into a new public,
magnet elementary school and daycare facility.
As discussed in greater detail below, the proposed plan for the new school building does
not involve any direct wetland or watercourse activities and no activities in the 100-foot upland
review area that will adversely impact the wetland resources. There are no on-site wetlands
however the 100-foot upland review area of three off-site wetlands extends onto the existing site.
As part of the proposed school project there will be a small portion of a sidewalk located
approximately 90 feet from the wetlands. That very limited disturbance is upland from an
existing access road to the cell tower located on site and will not have any adverse impact on the
wetlands as confirmed by in the attached wetland report.
The Proposed Project
LEARN is a Connecticut regional educational service center! that provides educational
resources, programs and services to help meet the needs of the towns it service, including
Waterford. The Town of Waterford has agreed to sell a portion of the former Southwest School
site at 51 Danial Avenue to LEARN for the purpose of constructing new school facility which is
the subject of this application. The Town of Waterford will also retain a portion of the 51
' Regional educational service centers were authorized by state statute starting in 1972 and based on voluntary
partnerships with local towns and schools. LEARN serves Waterford and parts of other nearby towns.
Shipman & Goodwin LLP | Connecticut | New Yerk | www.shipmangoodwin.com
April _, 2025
Page 2
Danials Avenue site to be merged with adjacent Town-owned open space land and in part for
recreational use to construct two new pickleball courts — which are the subject of a separate
wetland application filed simultaneously with this application and pending before the
Commission.” The areas to be sold to LEARN and the areas to be retained by the Town are
shown on plan sheet CS100 (attached at Tab 4).
LEARN is proposing to replace the existing Southwest School building with a new
combine magnet elementary school and daycare center. The new elementary school building be
an upgrade over the existing building by meeting all the current building, life safety, efficiency
and accessibility codes. In addition, the proposed plan includes replacing the existing conditions
with a modern stormwater management system that satisfies Waterford’s stormwater ordinances
and the state guidance documents. The entire building, parking lot and stormwater management
system is located outside the 100-foot upland review area for the two off-site wetlands and will
have no adverse impacts (and will improve conditions compared to the existing facility). The
proposed school facility layout and stormwater design is shown on plan sheets CS101and CS102
(attached at Tab 5).
The Off-Site Wetlands
LEARN retained a leading wetland expert, Dean Gustafson of All-Points Technology
Corp., with statewide and local experience to evaluate the site and the off-site wetlands and
advise LEARN with regard to avoiding wetland impacts. See attached report (Tab 6).
All-Points identified and evaluated three off-site wetlands as shown on the wetland
inspection map at Tab 6. Wetland 1 is the largest of the three wetlands and is located to the
northeast of the site and abutting Daniels Avenue. It is a mostly wooded wetland dominated by
red maple and black gum trees. Wetland | contains an imbedded vernal pool that provides
breeding habitat for wood frogs and spotted salamanders. Wetland 2 is located off the southeast
corner of the site. It is a smaller wetland dominated by red maple trees and multiflora rose and
green briar understory. Wetland 2 has been historically altered by the presence of a stonewall
that alters the natural drainage. Wetland 3 is located off the southwest corner of the site (toward
High Street) on a sloped hillside with rocky soils. Like the other wetlands, the canopy is
dominated by red maple trees.
As detailed in All-Point’s report, there are no proposed activities located in the wetlands
or in the 100 foot upland review are with the small exception of a portion of the sidewalk
approximately 90 feet away from Wetland 2. All of All-Points’ recommendations to safeguard
the associated wetland are accepted and/or incorporated into the application. All-Point
evaluation and report concludes that there will not be any adverse impact to the off-site wetland
or vernal pool from the proposed activities.
? As filed, neither of LEARN’s two wetland applications warrant a public hearing under the Commission’s
regulations. However, if the Commission determines that a public hearing is needed for one application but not the
other, LEARN respectfully request that the Commission not delay action on the application that does not require a
hearing. If the Commission determines that a hearing is required for both applications, LEARN consents to the
Commission conducting those hearing simultaneously, if it so chooses, provided it still votes on each application
separately.
Shipman & Goodwin LLP | Connecticut | New York | www.shipmangoodwin.com
April _, 2025
Page 3
Stormwater Management
As detailed in the LEARN’s stormwater report prepared by, Langan, (attached at Tab 8)
the proposed stormwater management system is an improvement over existing condition. The
new system will provide better stormwater treatment and management that controls and reduces
the peak runoff rate and total volume across all storm events up to and including the 100-year
storm. The system meets all of the requirements contained in the Waterford Stormwater
Ordinance and is consistent with the updated 2024 state Stormwater Quality Manual guidance
document.
No Regulated Activities
As noted above, LEARN is not proposing any regulated activities for the school project.
There are no direct wetland or watercourse activities located in the three off-site wetlands. There
are no proposed activities in the 100-foot upland review aera for Wetlands | or 3 and only a
small portion off a proposed sidewalk skirts the very edge of the upland review area for Wetland
2. That portion of the sidewalk is located upland from the existing cell tower access road
approved by this Commission in 2012 and it will not have any adverse impact on Wetland 2. As
detailed in the report of LEARN’s wetland expert, the proposed sidewalk area will not adversely
impact the associated, off-site wetlands.
LEARN did evaluate eliminating the proposed portion of the sidewalk but determined
that doing so would not have less impact on the wetland and would frustrate LEARN’s purpose
of providing a save walking area for student, families and faculty.
Conclusion
Based on the above, LEARN respectfully requests that the Commission find that there are
no regulated activities associate with the proposed school. In the alterative, to the extent the
Commission determines that a potential adverse impact exists, we request that the Commission
approve such activity on the basis that LEARN has minimized or avoided adverse impact to the
wetlands and that that no feasible and prudent alternative with less impact exist.
We have included an application of $160, if a different fee is due please let us know and
we will pay it promptly. We look forward to the opportunity to present LEARN’s application to
you at the Commission next meeting. Thank you for consideration.
Sincerely,
UWatthew Ranelli
Matthew Ranelli
Enclosures
Shipman & Goodwin LLP | Connecticut | New York | www.shipmangoodwin.com
TAB 2
TOWN OF WATERFORD
Application for Inland Wetland / Watercourse Permit
‘Type of Application; Agency Use:
Permitted Use, Section 4.1 Date Received:
Unregulated Activities, Section 4.2 V Received By:
Regulated Activities, Section 6 Fee: Application Number:
1. Applicant; _LEARN Regional Education Service Center Phone: 860 434 4800 x1345
Agaveas? 44 Hatchetts Hill Road, Old Lyme State: CT Zip: _ 06371
Fax: E-Mail; kericson@learn.k12.ct.us
2, Owner; Town of Waterford Phone:
Addras 15 Rope Ferry Road, Waterford State: CT Zip: 06385
Fax: E-Mail:
3. Agent: _ Shipman & Goodwin LLP Attn: Matt Ranelli Phone: _ 860 251 5748
Address: One Constitution Plaza, Hartford CT State: CT Zip: 06103-1919
Fax: E-Mail: Mranelli@goodwin.com
4. Property Address: _51 Daniels Avenue
5. Abutting Property Owners — Complete Attached Form
6. Activity to be Reviewed and / or Licensed (attach sheet if necessary):
No direct wetland activities or distubance. Very small area of sidewalk and grading in a portion of the 100-foot upland}
review area. No adverse impacts to the wetland resource.
7. Description of Proposed Activity (attach sheet if necessary):
Construction activites related to a new school building located outside the upland review area. A small portion of the!
proposed sidewalk is located in the outer edge of the upland review area but will not adversely impact the wetland
8. Purpose of Activity (attach sheet if necessary): Public regional magnet school and daycare facility
9a. Acreage of Property: Appox. 15.3 acres 9b. Acreage of Wetlands: _No on-site wetlands
10. Acreage of Wetlands Altered: 0
11, Wetland Mitigation Proposed: Yes. See attached reports regardign soil and erosion control, stormwater management and wetlands
12. Section 7 and sections 8.1 & 8.2 of the Town of Waterford “Inland Wetlands and Watercourse Regulagjons’
have been complied with: (Review attached check list) Yes: No:
The applicant / owner hereby gives the Commission, its agent and consultants the right of free access to any
part of the property under consideration. The undersigned warrants the truth of all statements contained
herein and iy supp orting documents according to the best of his / her knowledge, information and belief.
pate: 5/1/2025
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51 Daniel Ave Adjacen
4/16/2025 12:59:55 PM
Scale: 1"=376'
Scale is approximate
The information depicted on this map is for planning purposes only
Itis not adequate for legal boundary definition, regulatory
interpretation, or parcel-level analyses.
TAB 3
Connecticut Department of
GISCODE#:
ENERGY & ForDEEP Use Only
ENVIRONMENTAL
PROTECTION
79 Elm Street * Hartford, CT 06106-5127 www.ct.gov/deep Affirmative Action/Equal Opportunity Employer
Statewide Inland Wetlands & Watercourses Activity Reporting Form
Please complete this form in accordance with the instructions on pages 2 and 3 and mail to:
DEEP Land & Water Resources Division, Inland Wetlands Management Program, 79 Elm Street, 39 Floor, Hartford, CT 06106
Incomplete or incomprehensible forms will be mailed back to the inland wetlands agency.
PARTI: Must Be Completed By The Inland Wetlands Agency
DATE ACTION WAS TAKEN: year: month:
ACTION TAKEN (see instructions - one code only):
WAS A PUBLIC HEARING HELD (check one)? yes [] no ()
NAME OF AGENCY OFFICIAL VERIFYING AND COMPLETING THIS FORM:
(print name), (signature)
PART Il: To Be Completed By The Inland Wetlands Agency Or The Applicant
TOWN IN WHICH THE ACTIVITY IS OCCURRING (print name): _ Lown of Waterford
does this project cross municipal boundaries (check one)? —_-yes (1) no J
if yes, list the other town(s) in which the activity is occurring (print name(s)):
LOCATION (see instructions for information): USGS quad name: ___Niantic. or number: 104
subregional drainage basin number: 2204
NAME OF APPLICANT, VIOLATOR OR PETITIONER (print name): _LEARN Regional Education Service Center
NAME & ADDRESS OF ACTIVITY / PROJECT SITE (print information): 51 Daniels Avenue
briefly describe the action/project/activity (check and print information): temporary] permanent [¥] description:
Public school facility with no wetland activiites or disturbance
ACTIVITY PURPOSE CODE (see instructions - one code only): [2
40. ACTIVITY TYPE CODE(S) (see instructions for codes): __12 14
11. WETLAND / WATERCOURSE AREA ALTERED (see instructions for explanation, must provide acres or linear feet):
wetlands: 0 acres open water body: 0 acres stream: 0 linear feet
12. UPLAND AREA ALTERED (must provide acres): <0.1___ acres
13. AREA OF WETLANDS / WATERCOURSES RESTORED, ENHANCED OR CREATED (must provide acres): 0 acres
D.ATE RECEIVED: PART Ill: To Be Completed By The DEEP DATE RETURNED TO DEEP:
FORM COMPLETED: YES NO FORM CORRECTED / COMPLETED: YES NO
fev. 1/2024 pdf
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Wetland Inspection Map
51 Daniels Avenue
Waterford, Connecticut
LANGAN
ALL-POINTS
(OLGUY CONORATION
TAB 7
a WETLAND ASSESSMENT
ALL-POINTS
TECHNOLOGY CORPORATION
May 1, 2025
Katy Gagnon, Senior Project Manager
Langan Engineering and Environmental Services
Long Wharf Maritime Center
555 Long Wharf Drive
New Haven, CT 06511
Re: LEARN - Early Childhood School
51 Daniels Avenue, Waterford, Connecticut
APT Job No: CT3611350
Dear Ms. Gagnon,
All-Points Technology Corporation, P.C. (‘APT’) understands that LEARN - Early Childhood School is
acquiring +15.36 acres of a +19.32-acre parcel at 51 Daniels Avenue in Waterford, Connecticut to be
utilized for a proposed elementary school which will include demolition of the existing buildings,
reconfiguration to existing drive aisles and parking areas, along with upgrades to the stormwater
infrastructure (the “Project”). This wetland and vernal pool assessment report supplements other
materials submitted under separate cover by others as part of the Waterford Conservation Commission
(WCC’) Application for Permit (“Application”). The remaining +3.96 acres will be retained by the
Town of Waterford for development of pickleball courts and a parking area, details of which will be
submitted under a separate application. This document provides an assessment of three (3) wetlands
and an embedded vernal pool proximate to the Project, which includes a description of the functions
and values of the wetlands and vernal pool, a discussion of the Project's proposed activities located in
the upland review area and nearby, and an analysis of potential resource impacts associated with the
proposed regulated activities. The findings of this report are based on inspections performed of the
Project area and nearby wetland/vernal pool resource on September 24, 2024 and April 12, 2025 and
review of project site plans prepared by Langan Engineering, dated May 1, 2025 for the Application.
The Project area consists of a +19.32-acre area on the south side of Daniels Avenue currently
developed with a school building, associated impervious parking, drive aisles and pervious areas within
the north eastern half of the rectangular-shaped parcel. A telecommunications tower facility is also
located in the southeastern corner of the property and partially within the upland review area of
Wetland 2 as discussed below. Remaining undeveloped portions of the property consist of an athletic
field, open grassy and wooded/scrub-shrub areas. Wetlands were identified in proximity to the
property along the northeastern, southeastern and southwestern boundaries. Within the northeastern
wetland complex, Wetland 1, in proximity to Daniels Avenue, vernal pool habitat was identified and
confirmed during the spring 2025 breeding season. Stormwater runoff from the school building and
parking areas generally run overland to the west and toward Daniels Avenue to the north and not
toward Wetland 1.
ALL-POINTS TECHNOLOGY CORPORATION, P.C.
567 VAUXHALL STREET EXTENSION - SUITE 311 - WATERFORD, CT 06385 « PHONE 860-663-1697
Wetla: id Vernal Px
Matthew Gustafson and Emily Perko, Connecticut registered Soil Scientists with APT, performed a
wetland inspection of the subject property on September 24, 2024 to identify and delineate wetland
resources located on and proximate to the subject property. The wetland delineation methodology
was performed in accordance with the Connecticut Inland Wetlands and Watercourses Act. A copy of
the Wetland Inspection report, dated October 18, 2024, is enclosed along with representative
photographs of the wetland features.
Three distinct wetland areas were identified on or immediately adjacent to the subject property located
along the northeastern property boundary (identified as Wetland 1), off property along the
southeastern boundary (Wetland 2) and off property near the southwestern boundary (Wetland 3).
The 100-foot upland review area for all three delineated wetlands encroach into the subject property.
Imbedded within Wetland 1, obligate vernal pool species breeding was also confirmed during a follow-
up investigation performed on April 12, 2025. The limits of inundation associated with the vernal pool
habitat were surveyed during the spring 2025 inspection. Although potential vernal pool habitat was
identified in Wetland 2 during the October 18, 2024 wetland investigation, no vernal pool habitat was
identified during the spring 2025 vernal pool inspection as those suspect areas were either found dry
or had less than 2 inches of inundation and no evidence of any amphibian breeding. A detailed
description of three wetland and one vernal pool resources identified is provided below.
Wetland Descriptions
Wetland 1 is located in the northeastern portion of the subject property, primarily located on the
adjacent parcel, consisting of a forested complex dominated by red maple and black gum, with co-
dominant of swamp white oak. The understory contains sweet pepperbush and highbush blueberry
with multiflora rose along the delineated wetland boundary. The complex is characterized by
seasonally saturated edges with a distinct slope break separation to the abutting upland forest to the
west that is located on the property. A relatively large depressional area located entirely off the subject
property is present within the interior of the wetland generally devoid of vegetation and presents
indicators that a foot or more of inundation is present during peak flooding periods. Indicators include
buttressed roots and moss trim lines. This depressional area was re-evaluated during the April 12,
2025 inspection to verify vernal pool breeding activity, during which time two (2) vernal pool indicator
species spotted salamander (Ambystoma maculatum) and wood frog (Lithobates sylvaticus) were
observed breeding within the flooded extents. Two distinct pockets of breeding within the central and
southern portions of the flooded areas were observed with water depths ranging from 1.5 to 3 feet.
Wetland 2 is located off the southeast corner of the subject property on the adjacent parcel. Similar
to Wetland 1, saturated edges border interior seasonally flooded areas, although much shallower than
Wetland 1. Portions of the complex have experienced varying degrees of historic alteration with a
stonewall intersecting the system resulting in altering of the drainage within the southern limits of the
identified wetland and a dominance of multiflora rose and green briar present. The overstory was
dominated by red maple with inclusions of black gum. The southern and central wetland extents are
characterized by a broad transitional area consisting of a shallow slope break.
Wetland 3 is located off the southwest corner of the subject property on the adjacent property. This
wetland feature is located at the base of a hillslope within a depressional area with a distinct slope
break and rocky poorly drained soils. This isolated feature is dominated by red maple with spicebush
and highbush blueberry within the understory. Small areas of shallow seasonal flooding were observed
within the depression, which were confirmed to not support vernal poo! breeding habitat due to their
shallow flooding and short-duration hydroperiod.
2|Page
Soil Classification
Soil survey information obtained from the Natural Resources Conservation Service (“NRCS”) did not
identify wetland soil types either within or proximate to the Project area. However, wetlands were
encountered during the wetland investigation along the eastern property boundary and off-Property
to the west. Based on available information collected during the wetland investigation the mapped
wetland soil associated with the wetlands are predominately Ridgebury, Leicester and Whitman soils.
Upland soils were examined along the wetland boundary and more distant upland areas during the
site investigation. Those soils dominated by the Udorthents-Urban land complex within existing
developed areas associated with the vacant school, Paxton and Montauck fine sandy loam in the
western half of the property and Woodbridge fine sandy loam in the undeveloped southeastern
portion. Detailed descriptions of wetland and upland soil types are provided below.
Wetland Soils:
Ridgebury, Leicester and Whitman (Soil Unit 3) soils consist of very deep, poorly to very
drained soils formed in coarse-loamy or lodgement till. They are nearly level or gently sloping
soils in depressions, drainageways, and low-lying positions on hills. A perched water table, or
excess seepage water, is at or near the surface much of the year.
Upland Soils:
Paxton and Montauck fine sandy loam (Soil Unit 84) consist of well drained loamy soils
formed in lodgement till landscapes. They are very deep to the underlying bedrock with a
moderate depth to a densic contact. They are nearly level to steep soils on hills, drumlins and
till plains.
Woodbridge fine sandy loam (Soil Unit 45) is a moderately well drained loam soil formed
in lodgement till. They are very deep to bedrock and moderately deep to a densic contact.
They are nearly level to moderately steep soils with slopes ranging from 0 to 25 percent on
hills, drumlins, till plains, and ground moraines.
Udorthents-Urban Land Complex (Soil Unit 306) is a miscellaneous land type consisting
mostly of disturbed soils (cutting, filling & grading) such that the original soil profile can no
longer be discerned, buildings, paved roads and parking lots.
Wetland Evaluation
There are many methods of evaluating wetlands, all incorporating different parameters to assess these
resources. This study uses methodology recommended by the Corps, 7he Highway Methodology
Workbook Supplement, Wetland Functions and Values: A Descriptive Approach issued by the Corps,
dated September 1999. This evaluation provides a qualitative approach in which wetland functions
can be considered Principal, Secondary, or unlikely to be provided at a significant level. Functions and
values can be Principal if they are an important physical component of a wetland ecosystem (function
only), and/or are considered of special value to society, from a local, regional, and/or national
perspective. The Corps recommends that wetland values and functions be determined through “best
professional judgment” based on a qualitative description of the physical attributes of wetlands and
the functions and values exhibited.
3|Page
The basis for APT’s determination of this qualitative approach relies on over 35 years of field
experience and extensive knowledge of other scientific methods used for wetland evaluation purposes.
These functions and values can be grouped into four basic categories as follows:
Biological Functions
Fish and Shellfish Habitat — This function considers the effectiveness of seasonal or
permanent waterbodies associated with the wetland in question for fish and shellfish
habitat.
Wildlife Habitat — This function considers the effectiveness of the wetland to provide
habitat for various types and populations of animals typically associated with wetlands
and the wetland edge.
Production Export (Nutrient) — This function relates to the effectiveness of the wetland
to produce food or usable products for humans or other living organisms.
Hydrologic Functions
Floodflow Alteration (Storage & Desynchronization) — This function considers the
effectiveness of the wetland in reducing flood damage by attenuation of floodwaters
for prolonged periods following precipitation events.
Groundwater Recharge/Discharge — This function considers the potential for a
wetland to serve as a groundwater recharge and/or discharge area. Recharge should
relate to the potential for the wetland to contribute water to an aquifer. Discharge
should relate to the potential for the wetland to serve as an area where groundwater
can be discharged to the surface.
Water Quality Functions
Sediment/Toxicant/Pathogen Retention — This function reduces or prevents
degradation of water quality. It relates to the effectiveness of the wetland as a trap
for sediments, toxicants, or pathogens.
Nutrient Removal/Retention/Transformation — This function relates to the
effectiveness of the wetland to prevent adverse effects of excess nutrients entering
aquifers or surface waters such as ponds, lakes, streams, rivers, or estuaries.
Sediment/Shoreline Stabilization — This function relates to the effectiveness of a
wetland to stabilize streambanks and shorelines against erosion.
Societal Values
Recreation (Consumptive and Non-Consumptive) — This value considers the
effectiveness of the wetland and associated watercourses to provide recreational
opportunities such as canoeing, boating, fishing, hunting, and other active or passive
recreational activities. Consumptive activities consume or diminish the plants, animals,
or other resources that are intrinsic to the wetland, whereas non-consumptive
activities do not.
Educational/Scientific Value — This value considers the effectiveness of the wetland
as a site for an “outdoor classroom” or as a location for scientific study or research.
Uniqueness/Heritage — This value relates to the effectiveness of the wetland or its
associated waterbodies to produce certain special values. Special values may include
such things as archaeological sites, unusual aesthetic quality, historical events, or
unique plants, animals, or geologic features.
4|Page
Visual Quality/Aesthetics ~ This value relates to the visual and aesthetic qualities of
the wetland.
Threatened or Endangered Species Habitat — This value relates to the effectiveness
of the wetland or associated waterbodies to support threatened, endangered or special
concern species.
The degree to which a wetland provides each of these functions is determined by one or more of the
following factors: landscape position, substrate, hydrology, vegetation, history of disturbance, and
size. Each wetland may provide one or more of the listed functions at Principal levels.
The determining factors that affect the level of function provided by a wetland can often be broken
into two categories. The effectiveness of a wetland to provide a specified function is generally
dependent on factors within the wetland whereas the opportunity to provide a function is often
influenced by the wetland’s position in the landscape and adjacent land uses. For example, a
depressed wetland with a restricted outlet may be considered highly effective in trapping sediment
due to the long residence time of runoff water passing through the system. If this wetland is located
in gently sloping woodland, however, there is no significant source of sediment in the runoff therefore
the wetland is considered to have a small opportunity of providing this function.
Biological Functions:
The ecological integrity of all three Wetlands have been compromised due to proximity to
developed areas, historic alteration of Wetland 2 and the relatively small size of Wetland 3.
From a comparative perspective, Wetland 1 has the highest ecological quality: however,
fragmented upland habitat buffering this wetland from the existing on-site development,
Daniels Avenue to the north and residential properties to the east has diminished some of the
wetland’s biological functions. As a result, wildlife utilization would largely be used by
generalists and species habituated to the high level of human activity that exists both on the
subject property and in the surrounding area. Wetland 1 maintains sufficient hydrology to
support vernal pool breeding habitat throughout the complex but does not maintain permanent
inundation to support finfish habitat. Although the ecological integrity of these wetlands has
been compromised, wildlife habitat function is supported within Wetland 1 at a Principal level
due in part to the vernal pool habitat but not at a significant capacity in Wetlands 2 and 3.
All three wetlands consist of a common vegetative class of palustrine forest cover type with
shrub and herbaceous understory. However, there is not a large diversity of wetland cover
types so there is a limited potential to produce food for several different types of wildlife that
require diverse or specific wetland habitats beyond the forest habitat that is present.
Therefore, these wetlands were assessed as supporting the production export (nutrient)
function at a Secondary level based on the fruit bearing shrubs observed in the three resource
areas,
Hydrologic Functions:
Wetlands 1, 2 and 3 do not border on a perennial watercourse with an active floodplain, and
floodflow alteration is only supported at a Secondary level within Wetland 1 due to the
potential for this system to support flood storage from stormwater runoff since it essentially
functions as a confined basin. This function is not supported within Wetlands 2 or 3 due to the
small size of these features.
All three wetlands receive groundwater discharges from hillside seepage providing the
potential for both water discharge and recharge to the local groundwater. Wetland 1 was
S|Page
assessed as supporting the groundwater discharge/recharge function at a Principal level due
to its larger size while Wetlands 2 and 3 support this function at a Secondary level due to their
relatively small size.
Water Quality:
The developed surrounding environment provides an opportunity for all three wetlands to
support sediment/toxicant/pathogen retention and nutrient removal/retention/transformation
functions. Wetland 1 receives stormwater from the subject property through sheet flow. Based
on the resource size and location of Wetland 1 there is a potential to support these water
quality functions in a Secondary level. Due to the relatively small sizes of Wetlands 2 and 3
there is limited potential to support this function in any significant capacity.
None of the wetlands have the potential for sediment/shoreline stabilization since they do not
border on a perennial stream or open water body that would generate high flow velocities
during storm events or from wave action.
Societal Values:
Wetland 1, consisting of a forested wetland type that supports vernal pool habitat is easily
accessible by the public, and is associated with a school, supports an opportunity for various
societal values. However, due to a lack of hunting or fishing opportunities, this wetland
supports recreation value at a Secondary level. This wetland supports educational/scientific
value at a Principal level due to the ease of access, proximity to a unique wetland habitat with
breeding by vernal pool species, and future use of the property as a public school. In addition,
this wetland supports visual/aesthetics value at a Secondary level due to the proximity of
development and obstructive intervening vegetation from any publicly viewable areas. The
uniqueness/heritage value of this wetland is diminished by the lack of: archaeological sites;
unusual aesthetic quality; historical events; or unique plants, animals, or geologic features. As
such, Wetland 1 does not support the uniqueness/heritage value at a Principle or Secondary
level. Due to their small size and lack of unique characteristics, Wetlands 2 and 3 do not
support any of these functions and values in a significant capacity.
Urban wetland quality values are supported by Wetland 1 at a Secondary level, since this
wetland is generally surrounded by development but does support some habitat for wildlife
particularly for vernal pool species, Wetlands 2 and 3 do not support this value in a significant
capacity due to their small size and lack of diverse habitat.
Threatened or Endangered Species Habitat:
No State-listed Threatened, Endangered or Special Concern species are known to utilize the
subject property, or its wetlands based on available mapping (December 2024) from the
Connecticut Department of Energy & Environmental Protection (“DEEP”) Natural Diversity Data
Base (“NDDB”). The nearest NDDB buffer area is located +0.18 mile to the northeast in nearby
Millstone Brook riparian corridor. As such, consultation with DEEP NDDB is not required for
this project. Due to the relatively small forest patch size, limited size of these wetland
resources through development on the subject property and abutting properties, the potential
wildlife habitat value for rare species would be limited and is not considered to be supported
at either a Principle or Secondary level.
6|Page
P 1 Activiti
The following section summarizes development activities. The WCC regulates activities in wetland and
watercourses and upland areas within 100 feet of wetlands and watercourses, known as an upland
review area (“URA”) that are likely to impact wetlands and watercourses and not otherwise deemed
as-of-right or non-regulated activities.
The proposed redevelopment will avoid direct wetland impacts. As previously discussed, Wetland 1 is
located mainly off the subject property with the vernal pool habitat located off site and Wetlands 2
and 3 are entirely located off the property. However, due to the proximity of all wetlands to the subject
property, the 100-foot URA encroaches on to the property. The proposed redevelopment will avoid
encroachment into most of the URA with one exception. A small +200 SF portion of the proposed
perimeter sidewalk that will surround the entire LEARN school will just encroach into the URA of
Wetland 2 with associated grading and limit of disturbance encompassing an additional +800 SF of
the URA; total activity in the URA is +1,000 SF. This relatively small area of regulated activity in the
URA is currently comprised of maintained lawn associated with the nearby athletic field. In addition,
a gravel access road that provides access to the telecommunications facility (approved by this
Commission in 2012) is located between the proposed sidewalk and Wetland 2. Additionally, the
redevelopment project avoids any encroachment into areas within 100 feet of the vernal pool in
Wetland 1. As a result, the proposed redevelopment will not impact the vernal pool habitat or intercept
migratory corridors or forested habitat used by the identified vernal pool species.
The project has been designed to avoid direct stormwater discharges to wetland resource areas while
maintaining existing drainage patterns and hydrology inputs to the wetland areas to the maximum
extent practicable. The proposed stormwater management system incorporates a variety of
stormwater quality measures including catch basins with sumps, ADS Stormtech Isolator Rows,
hydrodynamic separators, and belowground and aboveground infiltration basins. These treatment
measures will properly control peak runoff rates, retain all of the project’s post-development retention
volume, and provide proper renovation of the water quality volume, resulting in a significant
improvement over the current stormwater management system to the benefit of the receiving
wetlands. The proposed stormwater management system substantially achieves the stormwater
volume, rate, and average annual pollutant load reduction requirements as per the recommendations
of the 2024 Connecticut Stormwater Quality Manual.
Wetland and Vernal Pool Impact Analysis
The fundamental concept of wetland and vernal pool impact analysis is based on the precept that
wetland and vernal pool impacts should first be avoided where possible. Secondly, if practicable
alternatives do not exist to avoid wetland impacts, then impacts should be minimized. Thirdly,
mitigation should be considered for unavoidable wetland impacts, with consideration given to the loss
of wetland functions and values that are important to the local region.
As previously discussed, the LEARN - Early Childhood School redevelopment will avoid any direct
impact to wetlands or vernal pool resources.
Areas of proposed activity within Wetland 2’s 100-foot URA, which total +1,000 SF, are proposed to
occur within an existing maintained open field associated with the nearby athletic field that is routinely
mowed. Impacted and degraded areas currently exist in closer proximity to Wetland 2 associated with
the telecommunications facility and gravel access drive. Upland review areas can serve a number of
important functions that support wetlands and watercourses including water quality protection
(erosion control and sediment, nutrient, biological and toxics removal), hydrologic event modification
7|Page
and wildlife habitat. However, considering the existing developed and disturbed nature of this
particular upland review area, such functions are not being supported in a significant capacity.
Construction and operation of the school would not result in direct physical impact to Vernal Pool 1 or
impact within 100 feet of the vernal pool edge. It is widely documented that vernal pool dependent
amphibians are not solely reliant upon the actual vernal pool, which is limited to use for breeding and
egg/larval development, and require surrounding upland forest habitat for most of their adult lives.
Intact forest represents the highest value, or optimal, habitat within the VPE and adjacent areas to
support breeding opportunities for the various obligate vernal pool indicator species that rely on
forested habitat (e.g., wood frog and spotted salamander). The US Army Corps of Engineers New
England District's Verna/ Poo! Best Management Practices (“BMPs”) also establish the concept of
“directional corridors” (identified herein as “Migratory Corridors"). Identification of Migratory Corridors
allow a project to evaluate potential impacts to optimal pool-breeding amphibian habitat that focuses
on conserving the most essential habitats which link breeding pools, forested wetlands, and forested
uplands. These interrelated habitats form essential migratory corridors at a landscape scale level. The
location of Migratory Corridors is established through an evaluation of both wetland and terrestrial
habitat structure qualities (e.g., vegetative cover types, width of vegetated buffer, soil surface
moisture, thickness of duff layer, abundance of cover objects, etc.) that determines the locations of
“Suitable Non-Breeding Habitat” and “Non-Habitat” in proximity to the vernal pool. Non-habitat areas
such as developed areas, maintained lawn, and large expanses of impervious surface do not support
Migratory Corridors due to the lack of sufficient vegetative conditions which are often associated with
higher levels of predation and high level of human activity that can result in direct mortality. For the
subject property which is dominated by the existing school development and includes the school
building, relatively large areas of paved parking and access, and regularly maintained athletic fields
and lawn, represents a large area of Non-Habitat located west of Vernal Pool 1. This large area of
Non-Habitat provides no vegetative cover for migratory wood frogs or salamanders, which would
expose these amphibians to desiccation and high levels of predation. This existing development
separates the vernal pool habitat from other foreste