Conservation Commission - 1072 (05/08/2025)

C-RS-0f
ZNyA 
WETLAND ASSESSMENT
\ ALL-POINTS
TECHNOLOGY CORPORATION 
iii)
LP
MAY 022025 
|
Planning & De
|__ Town of Waters
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

Wetland and Vernal Pool 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 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 pool breeding habitat due to their
shallow flooding and short-duration hydroperiod.
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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.
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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.
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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
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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.
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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 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
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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 Vernal 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 forested areas thereby eliminating a potential Migratory
Corridor to the west.
Migratory Corridors occur in areas that link vernal pools and Suitable Non-Breeding Habitat, which
consists of (both forested wetland and upland habitats). The principal Migratory Corridors associated
with Vernal Pool 1 are located to the south and east of the resource area linking adjacent and
somewhat continuous upland and wetland forested habitats. Although residential properties are
located 
proximate to these 
Migratory Corridors, 
there is significantly less landscape-level
anthropogenic changes when compared to the expansive school development, that still maintains a
relatively large forested habitat block to accommodate these Migratory Corridors. The proposed
redevelopment does not intercept this Migratory Corridor.
There is the potential for short term wetland impacts during construction due to the proximity of
wetland resources and proposed site work associated with grading and vegetation removal activities.
The potential for these short-term impacts is mitigated with the implementation and maintenance of
a comprehensive soil erosion and sediment control plan, as detailed on the separately attached project
site plans that were developed in accordance with 2024 Connecticut Guidelines For Soil Erosion and
Sediment Control. The installation of silt fence and employment of additional erosion control Best
Management Practices (“BMPs”) would function as an effective isolation barrier for possible migrating
herpetofauna from encountering construction. Additionally, a Wetland and Vernal Pool Protection Plan
will include contractor education and awareness signage of the nearby sensitive wetland resources,
including the vernal pool habitat and associated herpetofauna (i.e., wood frog, salamanders, turtles,
snakes, etc.) that could be encountered.
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Wetland and Vernal Pool Protection Plan
As a result of the proposed development’s location in the vicinity of wetlands and vernal pool, the
following protection plan is provided to avoid unintentional impact to wetland and vernal pool habitats
and associated herpetofauna during construction activities. Complete details of the recommended
wetland and vernal pool are enclosed with a summary provided below. Upon permit approval, this
protection plan will be incorporated into the construction drawings to ensure the Contractor is fully
aware of the project’s environmentally sensitive setting and the required protection measures.
A wetland scientist from APT experienced in compliance monitoring of construction activities will serve
as the Environmental Monitor for this project to ensure that the following BMPs are implemented
properly. The proposed wetland and vernal pool protection program consists of several components
including: periodic inspection and maintenance of erosion controls and isolation structures; education
of all contractors and sub-contractors prior to initiation of work on the site; protective measures;
wildlife sweeps to remove any wildlife from work areas; and reporting.
APT recommends establishing a wetland and vernal pool protection program consisting of contractor
awareness training prior to initiation of construction activities. The contractor training session would
stress the sensitive nature of the project, what species might be encountered and what to do if they
are present. In addition, the wetland protection program would include an initial inspection of the silt
fence erosion and sedimentation controls that will serve double duty as a restrictive barrier to possible
species dispersal into the construction site from the nearby wetland and vernal pool. Provided the
wetland protection program is properly implemented during construction, it is APT’s opinion that
potential short-term impacts to nearby wetland and vernal pool resources would not occur.
Mitigation
Since the proposed addition and renovation activities will not directly impact wetland resources and
are limited to activities within the existing developed/disturbed upland review area, no mitigation is
considered necessary. APT will perform contractor education training at a pre-construction meeting to
review the environmentally sensitive nature of the project area, where wetland and vernal pool
resources are located and the need to ensure protection of those resources during construction
through implementation and maintenance of the soil erosion and sediment control plan. APT will also
posting notice signs to highlight the environmentally sensitive nature of the subject property to
maintain diligence by the contractor throughout the construction project duration.
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Summary and Conclusion
The LEARN - Early Childhood School redevelopment project will not directly impact wetland or vernal
pool resources. In addition, activities proposed in the 100-foot URA will be limited to existing
developed and disturbed areas and only encompass a 
relatively small +1,000 SF area. A
comprehensive suite of erosion and sedimentation control measures in addition to a Wetland and
Vernal Pool Protection Plan will be implemented during construction to prevent direct and indirect
impacts to nearby wetland and vernal pool resources during construction.
Considering the proposed development activities avoid any direct wetland and vernal pool impact,
work is limited to the outer URA within an existing degraded and maintained area, and extensive
protection measures will be employed during construction activities, it is our professional opinion that
no likely adverse impact to wetland and vernal pool resources would result.
Based on the findings of this assessment, we respectfully request that the Town of Waterford
Conservation Commission serving as the Inland Wetlands Agency find this project and the various
conservation and mitigation measures are adequately protective of the interests contained in the Town
of Waterford Inland Wetlands and Watercourses Regulations and issue a wetland permit approving
the proposed regulated activity.
If you have any questions regarding the above-referenced information, please feel free to contact me
by telephone at (860) 552-2033 or at dgustafson@allpointstech.com.
Sincerely,
All-Points Technology Corporation, P.C.
Dan Ay at
Dean Gustafson
Professional Soil Scientist
Senior Wetland Scientist
Enclosures
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Wetland Inspection Report

i
ALL-POINTS
TECHNOLOGY CORPORATION 
WETLAND INSPECTION
October 18, 2024 
APT Project No.: CT3611350
Prepared For: 
Langan Engineering and Environmental Services
Long Wharf Maritime Center
555 Long Wharf Drive, New Haven, CT 06511
Site Address: 
51 Daniels Avenue, Waterford, Connecticut
Date of Investigation: 
9/25/2024
Field Conditions: 
Weather: cloudy, mid 60's
Soil Moisture: dry to moist
Wetland/Watercourse Delineation Methodology1:
&Connecticut Inland Wetlands and Watercourses
Connecticut Tidal Wetlands
OU.S. Army Corps of Engineers
Municipal Upland Review Area: Wetlands: 100 feet 
Watercourses: 100 feet
The wetlands inspection was performed by2:
Matthew Gustafson, Registered Soil Scientist
Enclosures: Wetland Delineation Field Forms & Wetland Inspection Map
This report is provided as a brief summary of findings from APT's wetland investigation of the referenced Study Area
that consists of proposed development activities and areas generally within 200 feet. If applicable, APT is available
to provide a more comprehensive wetland impact analysis upon receipt of site plans depicting the proposed
development activities and surveyed location of identified wetland and watercourse resources.
| Wetlands and watercourses were delineated in accordance with applicable local, state and federal statutes, regulations and guidance.
2 All established wetlands boundary lines are subject to change until officially adopted by local, state, or federal regulatory agencies.
3 APT has relied upon the accuracy of information provided by Langan Engineering and Environmental Services regarding the location and limits
of the Study Area for the purposes of identifying wetlands and watercourses.
ALL-POINTS TECHNOLOGY CORPORATION, P.C.
567 VAUXHALL STREET EXTENSION « SUITE 311 
» WATERFORD, CT 06385 + PHONE 860-663-1697

Attachments
> 
Wetland Delineation Field Forms
> 
Wetland Inspection Map

Wetland Delineation Field Form
Wetland I.D.:
Wetland 1
Flag #’s:
WF 1-01 to 1-22
Flag Location Method:
Site Sketch
GPS (sub-meter) located
WETLAND HYDROLOGY:
NONTIDAL
Intermittently Flooded 0
Artificially Flooded O
Permanently Flooded 0
Semipermanently Flooded O
Seasonally Flooded &
Temporarily Flooded 0
Permanently Saturated 0
Seasonally Saturated/seepage
Seasonally Saturated/perched 0
Comments: Wetland 1 consist
a distinct slope break to the abutting upland forest.
of a seasonally flooded interior with bordering saturated edges following
TIDAL O
Subtidal 0
Regularly Flooded 0
Irregularly Flooded 0
Irregularly Flooded 0
Comments: None
WETLAND TYPE:
SYSTEM:
Estuarine O 
Riverine 0 
Palustrine
Lacustrine 0 
Marine O
Comments: None
CLASS:
Emergent 0)
Scrub-shrub 0
Forested
Open Water 0
Disturbed 0
Wet Meadow 0
swamp white oak
Comments: Closed canopy hardwood forest consisting of red maple and black gum with co-dominant
WATERCOURSE TYPE:
Perennial 0
Intermittent 0
| Tidal
Watercourse Name: None
Comments: None
Page | of 2

Wetland Delineation Field Form (Cont.)
SPECIAL AQUATIC HABITAT:
Vernal Pool Yes O No C) Potential 
[ Other O
Vernal Pool Habitat Type: ‘Cryptic’
Comments: A large depressional area was identified void of vegetation containing buttressed roots and
moss trim lines indicating inundation is present during month of elevated water levels. This
depressional area did not contain any flooding at the time of inspection. An adult wood frog was
observed within the depressional limits. It is recommended a formal vernal pool investigation be
performed during the spring breeding season to determine the presence of obligate vernal pool
breeding.
SOILS:
Are field identified soils consistent with NRCS mapped soils? 
Yes 
Noo
DOMINANT PLANTS:
Red Maple (Acer rubrum) 
Black Gum (Nyssa sylvatica)
Swamp White Oak (Quercus bicolor) 
Sweet Pepperbush (Clethera alnifolia)
Highbush Blueberry (Vaccinium corymbosum) 
Multiflora Rose* (Rosa multiflora)
Sensitive Fern (Onoclea sensibilis) 
Cinnamon Fern (Osmunda cinnamomea)
Poison Ivy (Toxicodendron radicans) 
Greenbrier (Smilax rotundifolia)
* denotes Connecticut Invasive Species Council invasive plant species
GENERAL COMMENTS:
All-Points Technology Corp., P.C. (“APT”) investigated property at 51 Daniels Avenue in Waterford,
Connecticut (“Site”). The +20-acre town-owned parcel is developed with the former Waterford Dual
Language & Arts Magnet Middle School, which is currently vacant, and wireless telecommunications
facility located in the southeast corner of the Site. The vacant school building and associated
infrastructure occupies the northern and central portion of the Site along with open fields that extend
to the western and southern portions of the property. Successional forest and scrub/shrub habitats
are present along the Site’s eastern and western boundaries. APT soil scientists identified and
delineated three (3) wetland systems that are primarily located on adjacent parcels with some
encroachment into the Site.
Wetland 1 is located in the northeastern portion of the Site, 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
Site. A large depressional area 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, which appears
to be entirely located on the adjacent property, has the potential to support breeding habitat for vernal
pool indicator species.
Page 2 of 
2

Wetland Delineation Field Form
Wetland I.D.:
Wetland 2
Flag #’s: 
WF 2-01 to 2-14
Flag Location Method:
Site Sketch
| GPS (sub-meter) located
WETLAND HYDROLOGY:
NONTIDAL &
Intermittently Flooded 0
Artificially Flooded O
Permanently Flooded 0
Semipermanently Flooded O
Seasonally Flooded X
Temporarily Flooded O
Permanently Saturated 0
Seasonally Saturated/seepage X)
Seasonally Saturated/perched
Comments: Wetland 2 consists of a seasonally saturated complex with interior seasonal flooding
containing two depressional areas.
TIDAL O
Subtidal 0
Regularly Flooded O
Irregularly Flooded O
Irregularly Flooded O
Comments: None
WETLAND TYPE:
SYSTEM:
Estuarine 0 
Riverine 0 
Palustrine
Lacustrine O 
Marine 0
Comments: None
CLASS:
Emergent 0
Scrub-shrub 1
Forested
Open Water 0
Disturbed 0
Wet Meadow 0
Comments: Forested complex dominated by red maple with co-dominant black gum.
WATERCOURSE TYPE:
Perennial 0
[ Intermittent O
| Tidal 0
Watercourse Name: None
Comments: None
Page 1 of 
2

Wetland Delineation Field Form (Cont.)
SPECIAL AQUATIC HABITAT:
Vernal Pool Yes O No C) Potential 
| Other O
Vernal Pool Habitat Type: 'Cryptic'
Comments: Two potential vernal pools were identified within seasonally flooded areas in the northern
and southern limits of the complex. It is recommended that a formal vernal pool investigation be
performed during the spring breeding season to determine the presence of obligate vernal pool
breeding.
SOILS:
Are field identified soils consistent with NRCS mapped soils? 
| 
Yes 
NoO 
|
DOMINANT PLANTS:
Red Maple (Acer rubrum) 
Highbush Blueberry (Vaccinium corymbosum)
Multiflora Rose* (Rosa multiflora) 
Sweet Pepperbush (Clethera alnifolia)
Greenbrier (Smilax rotundifolia) 
Royal Fern (Osmunda regalis)
Sensitive Fern (Onoclea sensibilis) 
Cinnamon Fern (Osmunda cinnamomea)
Poison Ivy (Toxicodendron radicans) 
Black Gum (Nyssa sylvatica)
* denotes Connecticut Invasive Species Council invasive plant species
GENERAL COMMENTS:
Wetland 2 is located off the southeast corner of the Site on the adjacent property. Similar to Wetland
1, saturated edges border interior seasonally flooded areas. Potential vernal pool habitat was identified
within the northern and southern extents of the system. 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 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.
Page 2 of 2

Wetland Delineation Field Form
Wetland I.D.: 
Wetland 3
Flag #’s: 
WF 3-01 to 3-05
Flag Location Method: | Site Sketch 
GPS (sub-meter) located
WETLAND HYDROLOGY:
NONTIDAL &
Intermittently Flooded 0 
Artificially Flooded O 
Permanently Flooded 0
Semipermanently Flooded C1 | Seasonally Flooded 0 
Temporarily Flooded 0
Permanently Saturated 0 
Seasonally Saturated/seepage 
Seasonally Saturated/perched 0
Comments: Wetland 3 consists of a seasonally saturated depressional area at the base of a hillslope.
TIDAL O
Subtidal O 
Regularly Flooded 0 
Irregularly Flooded 0
Irregularly Flooded 0
Comments: None
WETLAND TYPE:
SYSTEM:
Estuarine 0 
Riverine 0 
Palustrine
Lacustrine 0 
Marine O
Comments: None
CLASS:
Emergent 0 
Scrub-shrub 1] 
Forested
Open Water 0 
Disturbed 0 
Wet Meadow 0
Comments: Wetland 3 is characterized by a closed canopy hardwood forest dominated by red maple.
WATERCOURSE TYPE:
Perennial C1 
| Intermittent 0 
| Tidal O
Watercourse Name: None
Comments: None
Page 1 of 2

Wetland Delineation Field Form (Cont.)
SPECIAL AQUATIC HABITAT:
Vernal Pool Yes O No & Potential O 
| Other
Vernal Pool Habitat Type: None
Comments: None
SOILS:
Are field identified soils consistent with NRCS mapped soils? 
Yes 
No O
DOMINANT PLANTS:
Red Maple (Acer rubrum) 
Spicebush (Lindera benzoin)
Multiflora Rose* (Rosa multiflora) 
Highbush Blueberry (Vaccinium corymbosum)
Poison Ivy (Toxicodendron radicans)
* denotes Connecticut Invasive Species Council invasive plant species
GENERAL COMMENTS:
Wetland 3 is located off the southwest corner of the Site 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 are unlikely support vernal pool breeding habitat due to their apparent shallow
flooding and anticipate short-duration hydroperiod.
Page 2 of 2

Legend
O sie 
Approximate Parcel Boundary
@ 
Wetland Flag
— 100° Upland Review Area
— elineated Welland Boundary
() Approximate Wetland Area
: 2019 CT Aerial Imagery (CTECO)
1 
inch = 200 feet
‘Map Date: Septombor 2024
Wetland Inspection Map
51 Daniels Avenue
Waterford, Connecticut
LANGAN
i, ov POINTS.
FECHINOLOGY CORFORATION

Wetland and Vernal Pool
Protection Program

ENVIRONMENTAL NOTES - RESOURCES PROTECTION PROGRAM
WETLAND AND VERNAL POOL PROTECTION MEASURES
As a result of the project's location in the vicinity of sensitive habitats including wetland resources
and vernal pool habitat, the following Protection Program shall be implemented by the Contractor to
avoid unintentional impacts to proximate wetland and vernal pool resources during construction
activities. Details of protection measures to be implemented in association with construction and
maintenance of the facility are provided below.
It is of the utmost importance that the Contractor complies with the requirement for the installation
of protective measures and the education of its employees and subcontractors performing work
on the project site. The protection measures shall be implemented and maintained throughout the
duration of construction activities until permanent stabilization of site soils has occurred.
All-Points Technology Corporation, P.C. (“APT”) will serve as the Environmental Monitor for this
project to ensure that these protection measures are implemented properly and will provide an
education session on the project's proximity to sensitive wetlands prior to the start of construction
activities. The Contractor shall contact Dean Gustafson, Senior Wetland Scientist at APT, at least
5 business days prior to the pre-construction meeting. Mr. Gustafson can be reached by phone
at (860) 552-2033 or via email at dgustafson@allpointstech.com.
This resources protection program consists of several components including: education of all
contractors and sub-contractors prior to initiation of work on the site; installation of erosion controls;
petroleum materials storage and spill prevention; protective measures; wetland and vernal pool
protection measures; herbicide, pesticide, and salt restrictions; and reporting.
1. 
Contractor Education:
a. 
Prior to work on site, the Contractor shall attend an educational session at the pre-
construction meeting with APT. This orientation and educational session will consist
of an introductory meeting with APT to emphasize the environmentally sensitive
nature of the project, the various wetland and vernal pool resources, and the
requirement to diligently follow the Protective Measures as described in sections
below. Workers will also be provided information regarding the identification of
turtles, snakes, and common herpetofauna that could be encountered. The meeting
will further emphasize the non-aggressive nature of these species, the absence of
need to destroy such animals and the need to follow Protective Measures as
described in following sections.
b. The Town of Waterford Environmental Planner will be notified a minimum of 72
hours in advance of the pre-construction meeting with an invitation to attend.
c. 
The Contractor will designate a member of its crew as the Project Monitor to be
responsible for the periodic “sweeps” for turtles and other herpetofauna within the
construction zone each morning and for any ground disturbance work. This
individual will receive more intense training from APT on the identification and
protection of herpetofauna in order to perform sweeps. Any herpetofauna

discovered would be translocated outside the work zone in the general direction
the animal was oriented.
d. The Contractor’s Project Monitor will be provided with cell phone and email contacts
for APT personnel. Educational poster materials will be provided by APT and
displayed on the job site to maintain worker awareness as the project progresses.
e. APT will also post Caution Signs throughout the project site for the duration of the
construction project providing notice of the environmentally sensitive nature of the
work area, the potential for encountering various amphibians and reptiles and
precautions to be taken to avoid injury to or mortality of these animals.
f. 
If any rare species are encountered, the Contractor shall immediately cease all
work, avoid any disturbance to the species, and contact APT.
2. 
Erosion and Sedimentation Controls/Isolation Barriers
a. 
Plastic netting used in a variety of erosion control products (i.e., erosion control
blankets, fiber rolls [wattles], reinforced silt fence) has been found to entangle
wildlife, including reptiles, amphibians, birds and small mammals. No permanent
erosion control products or reinforced silt fence will be used on the project.
Temporary erosion control products that will be exposed at the ground surface and
represent a potential for wildlife entanglement will use either erosion control
blankets and fiber rolls composed of processed fibers mechanically bound together
to form a continuous matrix (netless) or netting composed of planar woven natural
biodegradable fiber to avoid/minimize wildlife entanglement.
b. 
Exclusionary fencing shall be at least 20 inches tall and must be secured to and
remain in contact with the ground and be regularly maintained by the contractor (at
least bi-weekly and after major weather events) to secure any gaps or openings at
ground level that may let animal pass through.
c. 
The extent of the erosion controls will be as shown on the site plans. The Contractor
shall have additional sedimentation and erosion controls stockpiled on site should
field or construction conditions warrant extending devices. In addition to the
Contractor making these determinations, requests for additional controls will also
be at the discretion of the Environmental Monitor.
d. 
Installation of sedimentation and erosion controls, required for erosion control
compliance and creation of a barrier to possible migrating/dispersing turtles, shall
be performed by the