Planning & Zoning Commission (linked)

79 Elm Street • Hartford, CT 06106-5127  
 
  www.ct.gov/deep 
         Affirmative Action/Equal Opportunity Employer 
 
 
 
 
September 27, 2022 
Bob Russo 
CLA Engineers, INC 
317 Main St 
Norwich, CT 06360 
brusso@claengineers.com 
NDDB DETERMINATION NUMBER: 202109516 
Project: Stone Ridge Business Park, 21 Gurley Road in Waterford, CT 
Expiration: September 27, 2024 
I have reviewed Natural Diversity Data Base (NDDB) maps and files regarding this project. According to our 
records, there are State-listed species (RCSA Sec. 26-306) documented nearby the proposed project area.   
 
 
 
We concur with your revised site plan and your protection measures (attached) to minimize impacts to these 
species. 
 
Natural Diversity Database information includes all information regarding critical biological resources available to us at the time of the 
request. This information is a compilation of data collected over the years by the Department of Energy and Environmental Protection’s 
Bureau of Natural Resources and cooperating units of DEEP, independent conservation groups, and the scientific community. This 
information is not necessarily the result of comprehensive or site-specific field investigations. Consultations with the NDDB should not be 
substituted for on-site surveys required for environmental assessments. Current research projects and new contributors continue to 
identify additional populations of species and locations of habitats of concern, as well as, enhance existing data. Such new information is 
incorporated in the NDDB as it becomes available. 
Please contact me if you have any questions (shannon.kearney@ct.gov). Thank you for consulting with the 
Natural Diversity Data Base and continuing to work with us to protect State-listed species. 
Sincerely, 
/s/ Shannon B. Kearney 
Wildlife Biologist 
Attachments: (1) Species Protection Plan  
Scientific Name 
Vertebrate Animal 
Opheodrys vernalis 
Thamnophis sauritus 
Terrapene carolina carolina 
Icteria virens 
Common Name 
 
Smooth green snake 
Eastern ribbon snake 
Eastern box turtle 
 
Yellow-breasted chat 
State Status 
 
SC 
SC 
SC 
 
E 
Toxostoma rufum 
Brown thrasher 
SC 

September 22, 2022
Ms. Karen Zyko
Environmental Analyst
CTDEEP
79 Elm Street
Hartford, CT 06106-5127
RE:
Project: Preliminary Assessment of Stone Ridge Business Park, 21     
Gurley Rd in Waterford, CT NDDB Preliminary Assessment No.: 
202109516
GSD 60
Dear Ms. Zyko
CLA has been engaged in re-design of the above referenced project in order to minimize the 
potential for impact to State Listed Species that were cited in your Preliminary Assessment letter 
of September 14, 2021. To review, that letter indicated that there were extant populations of the 
following species in the vicinity of the site:
That letter also indicated that “If you do not intend to do site surveys to determine the presence or 
absence of state-listed species, then you should presume species are present and let us know how
you will protect the state-listed species from being impacted by this project. You may submit these
best management practices or protection plans with your new request for an NDDB review” As site 
surveys have not been undertaken, this letter  documents the design  revisions, best management 
practices (BMPs) and protection plans that have been undertaken in order  to minimize the potential 
for impacts to the protected  species.  The design revisions are protective of potential habitat while 
Scientific Name
Common Name
Smooth green snake 
Eastern ribbon snake 
Eastern box turtle
Yellow-breasted chat 
Brown thrasher
State Status
Vertebrate Animal
Opheodrys vernalis
SC
Thamnophis sauritus
SC
Terrapene carolina carolina
SC
Icteria virens
E
Toxostoma rufum
SC
CLA Engineers, Inc.
Civil
  Structural
Survey   
317 MAIN STREET
NORWICH, CT 06360
(860) 886-1966
(860) 886-9165 FAX

  
the BMPs and protection plans will minimize the potential for disturbance during construction.   
Habitat descriptions from CTDEEP publications are excerpted for each species to provide context 
for the design revisions, BMPs and protection plans. CLA performed on-site review to determine 
which portions of the site are likely to be used by the various protected species.  
Smooth green snake 
“Smooth greensnakes favor moist, open habitats, such as old fields, meadows, pastures, fens, 
coastal grasslands, and edges of wetlands. Occasionally, this snake may inhabit sparsely forested 
areas with scattered shrubs and trees, such as mountaintop balds. Rural, undisturbed locations 
appear to be preferred, but smooth greensnakes have been found in urban and suburban areas as 
well. Greensnakes can be found basking on rocks, logs, or other debris. Sometimes, this snake may 
be absent from seemingly suitable habitat” (1) (2) 
Based on CLA’s field review of the site, the most likely smooth green snake habitat is the early 
successional old field habitat indicated on Figure 1.  Note that this area also includes wetland 
edge. 
Eastern (common) ribbon snake 
“The ribbonsnake seldom ventures from shallow aquatic habitats, and favors open, 
grassy, or shrubby areas bordering ponds, streams, and wooded swamps. It may also be 
found in wet woodlands. Winter dens are underground, usually at higher in elevations 
and sometimes near trap rock systems. 
This snake feeds on a variety of aquatic creatures, mainly amphibians such as frogs, 
toads, salamanders, and tadpoles. It also will consume small fish and some invertebrates. 
In turn, this snake is preyed upon by birds, mammals, fish, and large amphibians.” 
Based on CLA’s field review of the site, the most likely eastern ribbon snake habitat is shown 
on Figure 2. These areas include shallow aquatic habitat and their bordering grassy and shrubby 
areas. 
Eastern box turtle 
In Connecticut, this terrestrial turtle inhabits a variety of habitats, including woodlands, field edges, 
thickets, marshes, bogs, and stream banks. Typically, however, box turtles are found in well-
drained forest bottomlands and open deciduous forests. They will use wetland areas at various 
times during the season. During the hottest part of a summer day, they will wander to find springs 
and seepages where they can burrow into the moist soil. Activity is restricted to mornings and 
evenings during summer, with little to no nighttime activity, except for egg-laying females. Box 
turtles have a limited home range where they spend their entire life, ranging from 0.5 to 10 acres 
(usually less than 2 acres) 
Based on CLA’s field review of the site, the most likely eastern box turtle habitat is the 
combination of small stream/wetland/early successional field shown on Figure 3. This areas 
includes field edges, thickets, wetlands and areas of sandy soil suitable for egg laying. 

  
 
 
Yellow breasted chat 
Habitat: According to the CTDEEP website, Yellow breasted chat use woodland edges; dense 
thickets, especially of briers and brambles; shrubby old fields, stream thickets and swamp margins 
(5). Per the Connecticut Breeding Bird Atlas, their habitat is shrubby land and dense second growth 
thickets (7). They are commonly found in dense tangles of blackberry, poison ivy and honeysuckle 
in Virginia. Chat territory near Haley Farm State Park, Groton, was dominated by Asiatic 
bittersweet, arrow-wood and multiflora rose (7).  
Based on CLA’s field review of the site, the most likely yellow breasted chat habitat is shown 
on Figure 4.  Note that is area includes dense thickets, woodland edge, a shrubby old field, 
stream thickets and swamp margins.  
Brown thrasher 
In Connecticut, brown thrashers are most often found in heavy thickets and vine tangles 
where they feed and nest. They do most of their foraging on the ground, frequently under 
the cover of shrubs and vines (6).  Per the Connecticut Breeding Bird Atlas, brown 
thrashers nest in thickets, brushy hillsides and woodland edges (7).  
Based on CLA’s field review of the site, the most likely brown thrasher habitat is shown on 
Figure 4.  Note that is area includes dense thickets, vine tangles, a shrubby old field, stream 
thickets and woodland edges.  
Site redesign and protective measures 
Based on CTDEEP’s PA and feedback from Town of Waterford staff, CLA re-designed the 
site, eliminating two of the proposed buildings.  Please refer to attached Figures 5 and 6 for a 
comparison of the two.  The elimination of the two buildings leaves additional potential habitat 
for both avian species and eastern ribbon snake.   
As shown on Figure 6, a significant portion of the site (12.4 acres out of 22) will be left intact 
with the existing vegetative cover undisturbed. After construction, 5.0  acres of the disturbed 
area will be re-planted, leaving a developed area of 4.6 acres.  The plans now specifically call 
for no disturbance of vegetation within a minimum of 50 feet of all inland wetlands. This overall 
minimization of the building footprint and maintenance of native vegetation also serves to 
protect habitat for each of the identified species.   
Several best management practices were also added to the plans to minimize the potential for 
impacts to protected species during construction. The text as excerpted from the plans is 
provided below. 
 

  
PROTECTED SPECIES PROVISIONS 
 
EASTERN BOX TURTLE (TERRAPENE CAROLINA CAROLINA), SMOOTH GREEN 
SNAKE (OPHEODRYS VERNALIS) AND EASTERN RIBBON SNAKE 
(THAMNOPHIS SAURITUS), ALL STATE LISTED SPECIES OF SPECIAL CONCERN, 
HAVE BEEN FOUND IN THE VICINITY OF THE PROPERTY. BOX TURTLES ARE 
TERRESTRIAL SPECIES THAT ARE FACULTATIVE USERS OF WETLANDS AND LAY 
EGGS IN SPRING TIME IN SANDY AND GRAVELLY SUBSTRATES.  SMOOTH 
GREENSNAKES FAVOR MOIST, OPEN HABITATS, SUCH AS OLD FIELDS, MEADOWS, 
PASTURES, FENS, COASTAL GRASSLANDS, AND EDGES OF WETLANDS. THE 
EASTERN RIBBON SNAKE USES SHALLOW AQUATIC HABITATS, AND FAVORS 
OPEN, GRASSY, OR SHRUBBY AREAS BORDERING PONDS, STREAMS, AND 
WOODED SWAMPS. (https://portal.ct.gov/DEEP/Wildlife/) 
 
1. 
THE THREE SPECIES ARE ARE PROTECTED BY LAW. NO TURTLES OR 
SNAKES SHALL BE REMOVED FROM THE SITE.  
2. 
NON DISTURBANCES AREAS (MINIMUM 50 FOOT WIDE WETLAND 
BUFFERS) HAVE BEEN INDICATED ON THE PLANS. THESE AREAS SHALL 
BE LEFT UNDISTURBED.  
3. 
CONSTRUCTION CONSIDERATIONS 
 
A. ALL CONSTRUCTION PERSONNEL SHALL BE APPRISED OF THE SPECIES 
DESCRIPTION, POSSIBLE PRESENCE OF THE TURTLES AND SNAKES, AND 
PROCEDURES TO FOLLOW IF THEY ARE FOUND AT THE SITE.  
B. NOVEMBER 1 - MARCH 31 (DORMANT SEASON): UPLAND LAND 
DISTURBANCE AS OUTLINED ON THE PLANS MAY BE PERFORMED 
WITHOUT RISK TO THE TURTLES AND SNAKES.  
C. APRIL 1 - OCTOBER 31: EXCLUSIONARY PRACTICES SHALL BE UTILIZED TO 
PREVENT TURTLE AND SNAKE ACCESS INTO CONSTRUCTION AREAS. 
 
D. SILT FENCE SHALL BE INSTALLED ALONG THE LIMITS OF DISTURBANCE 
AS SHOWN ON THE PLANS AND IN ACCORDANCE WITH THE 
CONSTRUCTION DETAILS.  
 
E. SILT FENCE SHALL BE INSPECTED Bl-WEEKLY AND AFTER MAJOR 
WEATHER EVENTS TO SECURE GAPS OR OPENINGS AT GROUND LEVEL 
THAT MAY LET TURTLES AND SNAKES PASS THROUGH.  
 
F. PRIOR TO DISTURBANCE FOR THE LOT DEVELOPMENT THE PROPOSED 
WORK AREA SHALL BE SEARCHED FOR TURTLES AND SNAKES. ALL 
TURTLES AND SNAKES  OCCURRING WITHIN THE WORK AREA SHALL BE 
RELOCATED TO SUITABLE HABITAT OUTSIDE OF THE DISTURBANCE AREA 
UNDER SUPERVISION BY A PROFESSIONAL FAMILIAR WITH THE HABITAT 
REQUIREMENTS ANO BEHAVIOR OF THE SPECIES. 
 
G. THE CONTRACTOR SHALL SEARCH THE WORK AREA FOR TURTLES AND 
SNAKES EACH MORNING PRIOR TO STARTING ANY WORK.  
 

H. ANY TURTLES AND SNAKES ENCOUNTERED IN THE IMMEDIATE WORK 
AREA SHALL BE CAREFULLY MOVED TO AN ADJACENT AREA OUTSIDE OF 
THE EXCLUDED AREA. FENCING SHALL BE INSPECTED TO IDENTIFY AND 
REPAIR THE ACCESS POINT.
I.
SILT FENCE SHALL BE REMOVED IMMEDIATELY AFTER THE SITE IS 
STABILIZED.
Summary
CLA notes that it is not possible to develop this site without some loss of potential habitat. 
However, given that large percentage of the land and existing cover to be maintained, this
development strikes a good balance that will not jeopardize the listed species.  
Sincerely,
Robert C. Russo
CSS
Biologist
Soil Scientist
References
(1) Klemens, Michael W. Amphibians and Reptiles of Connecticut and Adjacent 
Regions (State Geological and Natural History Survey of Connecticut - Bulletin 
No. 112) 
(2) https://portal.ct.gov/DEEP/Wildlife/Fact-Sheets/Smooth-Greensnake
(3) https://portal.ct.gov/DEEP/Wildlife/Fact-Sheets/Common-Ribbonsnake
(4) https://portal.ct.gov/DEEP/Wildlife/Fact-Sheets/Eastern-Box-Turtle
(5) https://portal.ct.gov/DEEP/Wildlife/Fact-Sheets/Yellow-breasted-Chat
(6) Connecticut Wildlife, Volume 35, Number 4 July/August 2015 pp. 12-13 CTDEEP
Sincerely,
Robert C Russo

  
 
(7) Bevier, Louis K. The Atlas of Breeding birds of Connecticut CTEP Bulletin 113 
 

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