Conservation Commission Meeting Agenda/Materials 109R and 131 Clark Lane Exhibit List (linked)

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183 Guinevere Ridge
Cheshire, CT 06410
(203) 271-1949
sigrun.gadwa@sbcglobal.net
January 26, 2023
Conservation Commission, Town of Waterford
15 Rope Ferry Road
Waterford, Connecticut 06385 - 2886
ATTN: Chairman Dimmock and Environmental Planner, Maureen Fitzgerald
RE: Application Review: App. # C22-15. 47-Unit Residential Subdivision, including affordable
units; 141 Clark Lane. Owners: L & M Archambault; Applicant Kingstown Properties, LLC
Carya Job No.: 23- WFD 3
Dear Commissioners:
Carya Ecological Services, LLC has conducted a preliminary review of the above-referenced
application by Kingston Properties, at the request of several property owners of abutting homes on
the east side of Clark Lane, including Arlene Sherman (119 Clark Lane).
1.0 INTRODUCTION
We have reviewed the following sources of information relevant to this application.
/. The most recent set of plans, dated 12-15-22, for this application, prepared by the firm of
Provost & Rovero, Inc., offering engineering, surveying, and land planning services. The 21-
sheet plan set is available for download on the Town of Waterford web site.
The Storm Drainage Report accompanying the plans, dated October 10, 2022
The wetland delineation report by soil scientist Joseph Theroux, dated 5-6-22.
The Wetland Functions and Values & Impact Analysis by J. Theroux, date 8-11-22.
Excerpts of the Technical literature on Stormceptor Pretreatment devices and on the
performance of biofiltration basins.
6. Performance Testing Results and design specification for biofiltration basins published by the
University of New Hampshire Stormwater Center (2009 and 2012, pp20 and 21 in both reports)
pdfs may be downloaded from https://www.unh.edu/unhse/pubs-specs-info .
7. Appendix A of the NY State DEC Stormwater Management Design Manual (Excerpts in
Attachment B).)';
MR WN
C-22-14
109R & 131 CLARK LANE
PUBLIC HEARING 01-26-23
Pertinent excerpts with references are in Attachment 2. EXHIBIT #17

AMES Sr SS | ee i
Jan 26, 2023
Page 2
8. Fenger Brook Watershed Management Study, New London and Waterford, 1996. Prepared for
Coastal Resources Management, Sea Grant Marine Advisory Program , New Haven, CT.
9. 2015 CTDEEP report on Fenger Brook (CT 2000-30-01) as and impaired portion of the
Southeast Shoreline Drainage Area (CT 2000).
10. CTDEEP Fisheries Data from 1993, 2001, and 2010.
Our goal was to evaluate the potential for significant adverse changes to this large, currently well-
buffered headwaters wetland system and to downstream regulated resources. These include Alewife
Cove, the easternmost cove on the Waterford Shoreline, sensitive to increased nutrient loading. ?
Fenger Brook has overall impairment per the 2015 CTDEEP Report on Connecticut’s water
resources, but there is no breakdown as to the relative levels of impairment in different segments. Are
hydrologic changes reasonably likely to result from the proposed residential project, increased water
in wetlands bordering the southern portion by the stormwater discharge, and drier conditions
bordering the narrow northern portion ? Will the stormwater management system, in particular the
bioretention basin function as intended, preventing increased nutrient loading to the Fenger Brook
riparian corridor and the sensitive downstream estuary, Alewife Cove? Significance of impacts is
closely tied to the sensitivity and quality of the downgradient wetland resources, under existing
conditions and functional status.
To make this evaluation, we supplemented the information provided by the applicant with additional
natural resource data on the headwaters portion of Fenger Brook, to the extent feasible. We have not
yet found recent data on the health and nutrient status of Alewife Cove, key information that should
have been provided by the applicant. On Saturday, January 21", 2023, we conducted a field survey
of the site perimeter and downgradient wetland resources, and tested specific conductivity and salinity
at several locations, including a station just upstream (north) of Route 1. Local residents were also
questioned. Desktop Sources of Natural Resources Data on the site vicinity and the Fenger Brook
Watershed included the CTECO website, and the NRCS/USDA web soil survey. The Carya office
library has assorted studies and manuals on wetland buffers, stormwater management, functions and
values assessment methodology, and potential wetland stressors. The 2020 NY Stormwater
Management Design Manual and the University of New Hamshire Stormwater Center Provide
guidance on Bioretention Basin Design and Pollutant-loading data.
2.0 EXISTING CONDITIONS
Carya water quality testing results, shown in Table | in Attachment A, showed that upper Fenger
Brook does not currently have elevated levels of nutrients or salt; specific conductivity was only 146
uS/cm and salinity was 0.1 ppt at the station is just upstream of Route 1;Upper. Readings within
? The 1996 Management Study of the Fenger Brook Watershed prepared by Seagrant may be found in Attachment 3.. It
emphasies the importance and vulnerability of Alewife Cove.
Carya Ecological Services, LLC, Cheshire Connecticut January 26, 2023

Town of Waterford, Conservation Conunmission
Jan 26, 2023
Page 3
interior wetlands were also very low. One station did have elevated salinity and conductivity readings
(4ppt and 549 uS/cm), in a small, west-flowing tributary to Fenger Brook, about 250 feet
downgradient (west) of the three-story apartment building just south of Clark Middle School.
However, without additional data on nutrient concentration, the reason for the elevated specific
conductivity is not known. (Low electrical conductivity means unimpaired water, but conductivity
can be elevated due to a variety of dissolved constituents.) Note that the 2015 CTDEEP report did
find impairment, but did not specify locations, likely south of Route! in the lower watershed.
If upper Fenger Brook were significantly impacted by leachate from the closed New London landfill
(west of the subject site) the conductivity reading just north of Route | would have been much higher.
Perhaps this expected nutrient source has diminished since 2015. Otherwise good water quality is not
surprising, in view of breadth of the protected forested open space in the headwaters of Fenger’s
Brook, about 2/3 mile wide near the subject site. Fortunately the watershed of this brook does not
include the dense residential development along the Thames River and to the west of Clark Lane, as
shown in Figures | and 2.
Mr. Theroux provided good information on the hydrologic characteristics and functions of the very
long swath of wetlands immediately adjacent to the project (about 1/3 mile). These wetlands are
primarily groundwater fed, with seasonal saturation and flooding of depressions. Multiple small
drainageways flow towards Fenger Brook. He rated wildlife habitat. production export via food chain,
and ground water discharge as important functions; water quality was rated very good, consistent
with Carya water testing data. However Flood storage function was incorrectly rated as low, not
taking into account the irregular ground topography and multiple small and large depressions , that
trap and infiltrate precipitation, preventing flooding and downstream channel enlargement. Tree
transpiration also prevents flooding. Roots take up and transpire large volumes of surface water,
aerating the soil, and creating pore space for infiltration. Mr. Theroux did not assess the functions
and values of the wetland system as a whole as called for by the Highway Methodology, and the other
extant wetlands assessment methodologies. His assessment should have taken the New London
portion into account; it has more embedded pools and high-value upland islands, including cliffs with
den-caves suitable for bobcat. This top wetland predator is well-documented at this site. Amphibians
and crayfish are important foods for bobcat. Wildlife habitat was rated as a principal wetland function,
but the report did not mention the numerous forest pools, some of which are expected to be productive
vernal pools or the significance of the wetlands’ high ecological integrity. The undeveloped land at
the headwaters of Fenger Brook , north of Route 1, is an almost three-square mile contiguous habitat
block, a half mile to two third miles across.
We viewed the wetland from the west (Clark Lane back yards); from the South (from the entry Road
to Clark Middle School) and from the West. Habitat to the west of the site includes over 100 acres
Carya Ecological Services, LLC, Cheshire Connecticut January 26, 2023

Tawa of Waterford, Conservation Commission
Jun 26, 2023
Page 4
of forested ridges, scenic rock outcrops, cliffs, and wetlands, which can easily be accessed from Clark
Woods Park Road and a network of hiking trails. Undeveloped municipally owned land includes the
central and southern portion of New London’s 95-acre Clark Woods Park, which includes portions of
the subject wetland system. Accordingly it does have significant human use values: recreational,
educational and aesthetic value. Trails and vernal pools straddle the unmarked town line.
We also characterized and sampled several water quality parameters in the large forested wetland
south of Clark Lane Middle School, which 15 similar to the wetlands located downgradient of the
proposed high density, linear development of manufactured rental homes.
Photos of Bates Woods Park
CONCLUSION
It is our professional opinion that the omissions and concerns discussed orally in my presentation
today, based on the sources listed above in the footnotes to the materials reviewed, should be
addressed by the applicant before a permit is issued,
Please get in touch with us if you have any questions on the above.
Respectfully submitted,
Su Ge
Carya Ecological Services, LLC, Cheshire Connecticut January 26, 2023

Figure {.; Permitted Stormwater Facilities in the Fenger Brook Watershed including MSs
(numbers correspond with permitted facilities listed in Table 5)
Legend
4& — Stormwater Permits
MS4 Area
Cc] Impaired Drainage Area(s)
(mpaired Waterbody(s)
Surface Water
Major Road
~ am Town Boundary
Waterford
Permits(s) within Fenger Brook Watershed with
Impairment to Habitat for Fish, Other Aquatic Life and Wildlife Created: CT DEEP, July 2012
Southeast Shoreline (CT2000) Summary
Page 11 of 16

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