Conservation Commission - 1083 (05/22/2025)

DETERMINATION OF NO REGULATED ACTIVITY OR, IN THE
ALTERNATIVE, REQUEST TO CONDUCT REGULATED
ACTIVITIES ASSOCIATED WITH PROPOSED PICKLEBALL
COURTS LOCATED AT 51 DANIELS AVENUE
MAY 1, 2025
Kate Ericson 
Katelyn Chapin AIA
kericson@learn.k12.ct.us 
kchapin@newmanarchitects.com
Executive Director 
Newman Architects
LEARN 
265 Church Street, 15" Floor
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
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 
Waterford Application Form
3 
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 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 |,
2025

TAB 1

SHIPMAN
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
Proposed Pickleball Courts; 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 that such the proposed activities qualify as a non-regulated activity under
Section 4.2 of the Commission’s regulations. In the alternative, if the Commission determines
regulated activities exist, LEARN requests approval to conduct regulated activities associated
with the development of two pickleball courts on behalf of the property owner, the Town of
Waterford.
As discussed in greater detail below, the proposed plan does not propose any direct
wetland activities nor regulated activities within the 100-foot upland review area. The plans
calls for LEARN to construct two pickleball courts for the Town of Waterford on a portion of the
land located at 51 Danials Avenue.' The propose pickleball courts will be located in the in the
northeast corner of what is currently 51 Daniels Avenue and will be owned and operated by the
Town for the use by residents.
The proposed courts will be located in an existing lawn area of the site that is outside of
but nearby the 100-foot upland review area and will not result in any adverse impact to the
wetland. There are no proposed direct wetland activities or activities in the 100-foot upland
' LEARN is going to purchase the balance of 51 Danials Avenue for a new school facility, the Town will retain the
portion of land that will house the proposed pickleball courts. The area of land retained by the Town will adjoin and
expand existing Town-owned open space abutting 51 Daniel Avenue.
Shipman 
& Goodwin LLP 
| 
Connecticut 
| 
New York 
| 
www.shipmangoodwin.com

May 1, 2025
Page 2
review area associated with the pickleball courts, except for a temporary disturbance at the edge
of the area for grading and seeding. In addition, to the lack of adverse impact, the proposed
courts are an outdoor recreational use that will not disturb or obstruct the natural character of the
wetlands and as such qualify as a non-regulated use under Section 4.2 of the Commission’s
regulations.
The Proposed Project
As noted above, the Town of Waterford has agreed to sell a portion of the former
Southwest School site located at $1 Daniels Avenue to LEARN? to construct a new school
facility. That school facility is the subject of a separate but simultaneously filed wetland
application pending before the Commission.’
The Town of Waterford is retaining a portion of the 51 Daniels Avenue site to add to and
supplement existing and adjacent Town-owned open space and to maintain other Town interests
such as the lease of the existing cell tower. LEARN will construct the two proposed pickleball
courts for the Town on the Town-retained land. 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).
The two proposed pickleball courts will be located outside of the 100-foot upland review
area. The location of the courts is shown on plan sheet CS101 (attached at Tab 5). As part of its
planning process LEARN did evaluate an alternative configuration with the pickleball courts laid
out to abut each other side-to-side (as is the more traditional layout) rather than end-to-end. On
the recommendation of its wetland expert, LEARN decided to arrange the court end-to-end
because that design avoided placing part of the courts in the upland review area.
The 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 7).
All-Points identified and evaluated three wetlands (all off-site except a small area to the
northeast) as shown on the wetlands inspection map attached at Tab 6. Wetland | 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
? 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.
> 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

May 1, 2025
Page 3
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 100-foot upland review area or 100-foot vernal pool envelop except for a temporary
disturbance for grading and seeding which will not adversely impact the wetland or vernal pool.
All of All-Points’ recommendations to enhance and protect the associated wetland and vernal
pool are accepted and/or incorporated into the application for the pickleball courts. All-Point
evaluation and report concludes that there will not be any adverse impact to the wetland or vernal
pool from the proposed activities and that the recommended plantings will enhance the wetland
and vernal pool functions.
Conclusion
Based on the above, LEARN respectfully requests that the Commission find that there are
no regulated activities associated with the proposed pickleball courts or that such courts qualify
as a non-regulated activity under Section 4.2 of the Commission’s regulations. 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 fee of $60 for the state fee; we did not include a local
fee because the fee schedule lists “no fee” for non-regulated activities. 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,
UMatthew Ranellé
Matthew Ranelli
Enclosures
Shipman 
& Goodwin LLP 
| 
Connecticut 
{ 
New York 
| 
www.shipmangoodwin.com

TAB 2

TOWN OF WATERFORD
Application for Inland Wetland / Watercourse Permit
Tyne of Application: 
Agency 
Use:
Permitted Use, Section 4.1 
VA 
Date Received:
Unregulated Activities, Section 4.2 
Received By:
Regulated Activities, Section 6 
Fee: 
Application Number:
KcoA pplicant: 
LEARN Regional Education Service Center 
Phone: 
860 434 4800 x1345
Address; 
44 Hatchetts Hill Road, Old Lyme 
State: 
CT 
Zip: 
06371
Fax: 
E-Mi 
kericson@learn.k12.ct.us
2. Owner/Co-applicant:_Town of Waterford 
Phone:
Address: 
15 Rope Ferry Road, Waterford 
State, 
CT 
Zip: 
06385
Fax: 
E-Mail:
3. Agent: _ Shipman & Goodwin LLP Attn: Matt Ranelli 
Phone; 
860 2515748
Address: 
One Constitution Plaza, Hartford CT 
State; CT 
Zip: 06103-1919
Fax: 
E-Mail: 
_mranelli@goodwin.com
4. Property Address: 
_51 Daniels Avenue
$. Abutting Property Owners —- Complete Attached Form
6. Activity to be Reviewed and / or Licensed (attach sheet if necessary):
No direct wetland activities or distubance. 
Two pickleball courts are located outside the upland review area and are
not regulated activiteis becuase (1) they will not adversely impact the wetlands and (2) they are a non-regulated use.
7. Description of Proposed Activity (attach sheet if necessary):
Construction activites related to two new pickleball courts on Town property and located outside the upland review
area. They satisfy the requirments for non-regulated uses in section 4.2 and will not adversely impact the wetland
8. Purpose of Activity (attach sheet if necessary): _ Recreational use - public pickle ball courts
9a. Acreage of Property: Appox. 4.0 acres 
9b. Acreage of Wetlands: 
No on-site wetlands
10. Acreage of Wetlands Altered: 0
11. Wetland Mitigation Proposed: 
Yes. See attached reports regarding soil and erosion control measures and wetiands
12, Section 7 and sections 8.1 & 8.2 of the Town of Waterford “Intand Wetlands and Watercourse Regulajjons”
have been complied with: (Review attached check list) 
Yes: v 
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 in 
all supporting documents according to the best of his / her knowledge, information and belief.
Me 
Date: 
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51 Daniel Ave Adjacent
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 tegal boundary definition, regulatory
interpretation, or parcel-level analyses.

TAB 3

Connecticut Department of
OB COURS 
09 8) 2 SSS 
Oe
ENERGY & 
For DEEP 
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, 3 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 II: To Be Completed By The Inland Wetlands Agency Or The Applicant
TOWN IN WHICH THE ACTIVITY IS OCCURRING (print name): _ Town of Waterford
does this project cross municipal boundaries (check one)? 
~—-yes [] 
no
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: 
4104
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 7a] 
description:
Public recreation pickleball courts with no wetland activiites or disturbance
ACTIVITY PURPOSE CODE (see instructions - one code only): 
[=
10. 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
DATE RECEIVED: 
PART Ill: To Be Completed By The DEEP 
DATE RETURNED TO DEEP:
FORM COMPLETED: YES 
NO 
FORM CORRECTED 
/ COMPLETED: YES NO
rev. 1/2024 pdt

TAB 4

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TAB 6

Wetlands]
Wetland Inspection Map
51 Daniels Avenue
Waterford, Connecticut
‘Approximate Parcel Boundary
LANGAN
—— 100 upland Review Aroa
— boineated Welland Boundary
© Aoproximate wetand area
Mao Hoos,
Tees Ntep Source: 2019 CT Aerial Imagery (CTECO)
‘Map Seale 1lach 
= 200 fel
‘Map Date: September 2024

TAB 7

ALL-POINTS
TECHNOLOGY CORPORATION 
WETLAND ASSESSMENT
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: 
— Waterford Pickleball Courts and Parking
51 Daniels Avenue, Waterford, Connecticut
APT Job No: CT3611350
Dear Ms. Gagnon,
All-Points Technology Corporation, P.C. (‘APT’) understands that the Town of Waterford is acquiring
+£3.96 acres of a +19.32-acre parcel at 51 Daniels Avenue in Waterford, Connecticut to be utilized for
two pickleball courts, eight (8) associated parking space and a concrete sidewalk to provide pedestrian
access to the proposed courts (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”). This document provides an
assessment of one (1) wetland and embedded vernal pool located proximate to the Project, which
includes a description of the functions and values of the wetland 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 +3.96-acre area comprised primarily of maintained lawn immediately
east of existing bituminous paved parking and access associated with the vacant school. The eastern
edge of the Project area just encroaches into an upland forest that buffers the nearby wetland. A
single wetland complex, Wetland 1, and imbedded vernal pool, Vernal Pool 1, are mainly off the
eastern property boundary with the majority of the resource located site on abutting parcels. The
proposed Project’s development activities will avoid any direct impact to this resource area.
Wetland Resources
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 immediately 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
ALL-POINTS TECHNOLOGY CORPORATION, P.C.
567 VAUXHALL STREET EXTENSION « SUITE 311 - WATERFORD, CT 06385 - PHONE 860-663-1697

Wetland 1 was identified on the subject property located along the eastern property boundary with
the majority of the resource located off-property. Imbedded within this system breeding of vernal poot
species was also confirmed during a follow-up investigation performed on April 12, 2025. This area
was surveyed based on the limits of inundation observed during the spring inspection. A detailed
description of wetland and vernal pool resources identified is provided below.
Wetland Description
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.
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 near the Project
area. 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 are dominated by the Udorthents-Urban land complex within existing
developed associated with the vacant school and Charlton-Chatfield complex in the undeveloped
areas. 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:
Chariton-Chatfield Complex (73) consists of very deep, well drained soils formed in loamy
melt-out till. They are moderately deep to bedrock. They are nearly level to very steep soils
on moraines, hills, and ridges.
Udorthents-Urban Land Complex (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.
2|Page

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.
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.
By Page

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.
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.
A summary description of functions and values is provided below.
Biological Functions:
The ecological integrity of Wetland 1 has been compromised due to proximity to developed
areas indicative of the bordering invasive species. Fragmented upland habitat buffering this
wetland has occurred with the existing school development to the west, Daniels Avenue to the
north and residential properties to the east. 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. This wetland 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 has
been compromised, wildlife habitat function is supported within Wetland 1 at a Principal level
due largely to confirmed breeding by two obligate vernal pool species.
4|Page

The wetland consists 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, this
wetland is assessed as supporting the production export (nutrient) function at a Secondary
level based on the fruit bearing shrubs observed in the resource.
Hydrologic Functions:
Wetland 1 does not border a perennial watercourse with an active floodplain, 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 wetland receives groundwater discharges from hillside seepage providing
the potential for both water discharge and recharge to the local groundwater. Due to this
factor, the wetland was assessed as supporting the groundwater discharge/recharge function
at a Principal level.
Water Quality:
The developed surrounding environment provides an opportunity for this wetland to provide
sediment/toxicant/pathogen 
retention 
and 
nutrient 
—removal/retention/transformation
functions. This wetland currently receives some stormwater flow from the subject property
and adjacent school development through sheet flow, Based on the resource size and location
of Wetland 1 there is a potential to support these water quality functions but the size limits
the function 
to 
a 
Secondary 
level. 
Wetland 
1 
does 
not 
have the potential 
for
sediment/shoreline stabilization since it does not border on a perennial stream or open water
body that would generate high flow velocities during storm events or 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.
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.
5|Page

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 the wetland resource,
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.
Proposed Activities
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 development will avoid direct impacts to Wetland 1 and Vernal Pool 1. However, the
proposed Project will require temporary disturbances in the URA such as limited vegetation clearing,
grubbing, and grading to accommodate the pickleball courts and parking area. Such activities will
result in £3,870 SF of work within the 100-foot URA with the closest activity +63 feet from the nearest
wetland area. Please note that proposed activities in the URA do not include any impervious surfaces
or stormwater management features and are limited mainly to minor grading activities. Those areas
will be restored with native trees, shrubs and herbaceous plants and grasses as discussed in detail in
the mitigation section of this report. In addition, minimal disturbance would result within 100 feet of
the vernal pool edge, also known as the vernal pool envelope (“VPE”). Although there is a slight
encroachment into the VPE, the development would not impact primary migratory corridors of two
identified vernal pool species; this topic is discussed in greater detail in the subsequent section.
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 pickleball court development will avoid any direct impact to wetland or
vernal pool resources. Areas of proposed activity within the 100-foot URA to Wetland 1 consist of
vegetation clearing, grubbing and regrading needed for the installation of eight (8) parking spaces,
two pickleball courts, and a concrete sidewalk. The parking area, sidewalk, and courts, both impervious
surfaces, are located outside of the 100-foot URA. 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
and wildlife habitat. While portions of the upland edge forest will be removed to accommodate for the
development, the majority of the development area consists of maintained lawn which experiences
routine disturbance and maintenance, such functions are not being supported in a significant capacity.
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Construction and operation of the courts would not result in direct physical impact to Vernal Pool 1;
however, minor grading will just encroach within 100 feet of the vernal pool edge, also known as the
vernal pool envelope (“VPE”). 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/
Pool Best Management Practices (“BMPs”) also establish the concept of “directional corridors”
(identified herein as “Migratory Corridors"). Identification