HomeMy WebLinkAbout22IWC11 SS Comments (5-19-2022)
May 19, 2022 Ms. Tiffany Williams Wetlands Enforcement Officer
310 Norwich-New London Tpk.
Uncasville, CT 06382
RE: 0 Ridge Hill Rd Wetland Crossing application CLA-7064N
Dear Tiffany: We have examined the site subsurface sewage and wetland crossing plans and application form submitted for Lawrence Darling, 0 Ridge Hill Rd to determine if the
proposal constitutes a significant activity as defined by the Montville Inland Wetland
Regulations. The pertinent sections of the regulations are as follows:
“8dd."Significant Impact" means any activity, including, but not limited to, the following activities which may have a major effect:
1. Any activity involving deposition or removal of material which will or may have a
substantial effect on the wetland or watercourse or on wetlands or watercourses outside
the area for which the activity is proposed.
2. Any activity which substantially changes the natural channel or may inhibit the
natural dynamics of a watercourse system.
3. Any activity which substantially diminishes the natural capacity of an inland wetland or watercourse to aquatic, plant or animal life and habitats,prevent flooding,supply water, assimilate waste, facilitate drainage, provide recreation or open space or other
functions.
4. Any activity whichis likely to cause or has the potential tocausea substantial turbidity, siltation or sedimentation in a wetland or watercourse.
5. Any activity which causessubstantial diminution of flow of a natural watercourse or
groundwater levels of thewetland or watercourse. 6. Any activity whichis likely to cause or has the potentia lto cause pollution of a wetland or watercourse.
CLA Engineers, Inc.
Civil Structural Survey
317 MAIN STREET NORWICH, CT 06360 (860) 886-1966 (860) 886-9165 FAX
7. Any activity which destroys unique wetland or watercourse areas or such areas having
demonstrable scientific or education value.”
The application form indicates that 2740 s.f. of inland wetland will be filled resulting in its permanent loss. CLA also notes that the aerial photography on the town’s GIS shows the thread of an intermittent watercourse present at the proposed crossing location.
Based on this information CLA believes that the proposed activity triggers sections 1, 2, and 4 under the definition of significant impact. Rationale for each of these is described below. 1. The proposed activity involves deposition of fill in the wetland that will
permanently eliminate wetland habitat and fragment that wetland. Elimination of
wetland and fragmentation of habitat are substantial effects. 2. The proposed activity will eliminate a natural channel and alter the natural dynamics by substituting pipe flow for natural flow. This is a substantial change. 3. The proposed activity involves excavation of wetland soil and surrounding upland
soil and has the potential to cause turbidity, siltation or sedimentation in the down gradient wetland and watercourse. In conclusion, CLA believes that the proposal constitutes a significant activity and requires a public hearing.
Very truly yours,
Robert C. Russo CSS