HomeMy WebLinkAbout24IWC11-375 Maple Ave-SS Review Comments 1 1-7-2025
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____________________________________________________________________
Ian Cole, LLC
Professional Registered Soil Scientist / Professional Wetland Scientist
PO BOX 619
Middletown, CT 06457
Itcole@gmail.com
860-514-5642
January 7, 2025
Ms. Stacy Radford
Zoning & Wetland Officer
Department of Land Use & Development
Town of Montville
310 Norwich-New London Turnpike
Uncasville, CT 06382
Re: 24IWC11 – 349 Maple Ave. LLC
375 Maple Ave. and Route 163
Montville, CT
Site Improvement Plan and Stormwater Management Report Review
Dear Ms. Radford and Commission Members:
On behalf of the Town of Montville, I coordinated review efforts with Boundaries LLC
for the above referenced wetland application. I completed a site visit and reviewed the
subject site plans and wetland application to construct a new trailer storage facility by the
Rand-Whitney Company at 375 Maple Avenue. I offer the following comments for the
Town of Montville Inland Wetland Commission consideration relative to assessing the
significance of impacts to the regulated areas.
The following documents were reviewed:
• Inland Wetlands Application.
• Project Cover Letter.
• Stormwater Management Plan.
• Wetland Delineation Report.
• Site Improvement Plan, 375 Maple Avenue/Route 163, Town of Montville,
Connecticut 06382, Prepared for 349 Maple Ave. LLC, 410 Maple Avenue,
Montville, Connecticut 06382, December 16, 2024.
• Town of Montville Inland Wetlands and Watercourse Regulations (October 19,
2017)
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The following comments or questions are based on a site visit completed on January 3,
2025, discussions with Boundaries, LLC and the above documents:
1. I have reviewed the wetland boundary as identified and flagged by Mr. Robert
Russo and Mr. Jospeh Theroux and I am in general agreement with the regulated
boundaries as depicted on the subject site plans. Although the wetland boundary
is readily identifiable to most professionals, for the Commission’s benefit and for
construction purposes, it is suggested before the start of construction that the
Project’s surveyors stake out the limits of disturbance and re-flag the wetland
boundary with new markers, so the wetlands are clearly marked in the field , as
many of the flags were missing or degraded making them difficult to recover at
the time of my field visit on 1-3-2025.
2. Consideration should be given to additional native shrub plantings between
Stormwater Basin #1 and the edge of Rockland Pond. As depicted on the site
plans the area would be essentially cleared of vegetation to the ponds edge and
replanted with New England Roadside Seed Mix. There is an opportunity to
soften the ecotone between the development’s edge and the pond which should be
evaluated by the applicant.
3. Because the site was previously utilized to stockpile miscellaneous landscaping
material including woody debris and other earthy materials, consideration should
be given to including an invasive species monitoring plan to ensure no invasive
species are propagated along the wetland boundary where they currently do not
exist. Notable patches of Knotweed and mugwort were observed intermittently
throughout the property and the activity of converting the woods to meadow
habitat has the potential to propagate sun-loving invasive plant species as the tree
canopy will be removed and replaced with low-growing vegetation.
4. It is my understanding the Project has formally requested a Jurisdictional
Determination (JD) from the United States Army Corps of Engineers (USACE). It
has been my experience that the JD process can take upwards of 1 year or more to
receive a formal ruling from the USACE. In the interim the Commission should
request the Applicant, or their representatives to provide a professional opinion as
to the applicability of additional State and/or Federal Jurisdiction over the
proposed 9,496 SF of fill to the intermittent watercourse that extends from the 30”
Sharp Hill drainage pipe outlet. It is my professional opinion that the subject
drainage feature may not be regulated by the USACE, due to its site setting,
isolation, ephemeral nature, and origin of creation. For the Commissions
understanding and context the subject watercourse has very little stream and bank
development and is very shallow in nature. Furthermore, I would expect given
the nature of the watercourse, the subject drainageway is likely biologically inert
and does not provide any substantial stream habitat due to lack of persistent flow,
lack of wetland vegetation, and overall site disturbances.
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5. I concur with the additional erosion and sediment controls recommended by
Boundaries which include incorporating a double row of sediment barrier where
construction activity is located within 50-feet of the limit of inland wetlands per
the DEEP Construction General Permit.
6. It is my professional opinion based on a review of the proposed activities and the
Town of Montville’s definition of a “Significant Activity” that the relocation of
the Sharp Hill Drainage which will require filling 9,496 SF of a man-made
intermittent watercourse is a significant activity, as the proposal is significantly
changing the dynamics of the watercourse, albeit one that is man-made. The
project is proposing industry standard water quality treatment which can be
enhanced based on the additional recommendations of Boundaries LLC and the
suggestions provided in this letter report. These additions should be considered to
help mitigate a major effect or negative impact to the overall wetland resources
and environment.
In closing while the proposed activity is significant in the fact it will be relocating a
man-made watercourse and will result in the permanent filling of a watercourse it likely
will not have a major effect or negative impact due to the nature of the subject feature
and the inclusion of design features which will replace and/or has the opportunity to
enhance the existing functions of the watercourse slated to be relocated . In my
professional opinion, if the subject application includes the additional recommendations
the regulated activities:
1. Should not result in an adverse impact to Rockland Pond or Oxoboxo Brook;
2. Are consistent with and satisfy the statutory factors for consideration provided by
Section 22a-41 of the Connecticut General Statutes; and
3. Are consistent with and satisfy the criteria for consideration provided by the
Town of Montville’s Inland Wetlands and Watercourses Regulations.
If you have any questions or comments, please do not hesitate to contact me at
itcole@gmail.com or (860) 514-5642.
Sincerely,
Ian T. Cole
Professional Registered Soil Scientist
Professional Wetland Scientist #2006
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WETLAND REVIEW SITE PHOTOS
IAN COLE, LLC
JANUARY 3, 2025
RAND-WHITNEY RECYCLING, LLC – NEW
TRAILER STORAGE AREA
375 MAPLE AVENUE
MONTVILLE
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Photo 1: Sharp Hill Drainage Area
Photo 2: Sharp Hill drainage discharge point. Note sediment buildup.
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Photo 3: General channel conditions of the Sharp Hill drainage as it migrates east towards
Oxoboxo Brook. Note lack of stream development and lack of wetland vegetation.
Photo 4: General conditions along Oxobox Brook
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Photo 5: Rockland Pond
Photo 6: General upland conditions slated to host the trailer storage area
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Photo 7: Wooded area that will be converted to parking / stormwater quality basins. Note
small patch of Knotweed in foreground of photo.