connecticut ecosystems

Connecticut Ecosystems LLC

• Wetland Delineation • Wetland & Aquatic Evaluation • Mitigation

• Natural Resource Inventory • Permit Assistance • Expert Testimony

38 Westland Avenue • West Hartford, CT 06107

Phone (860) 561-8598 • Fax (860) 561-0223 • email [email protected]

July 9, 2021 Inland Wetlands Agency City of Norwalk 125 East Avenue P.O. Box 5125 Norwalk, CT 06856-5125 Re: 40 Fullin Road Third Party Review CE Job# 20-11 Dear agency members: At the request of the Inland Wetlands Agency (“IWA”) I have conducted a third-party review of the wetland-related aspects of the above-referenced permit application. As part of that effort I reviewed the following documents: 1. “The Cottages at Pepper Ridge” site plan review set prepared by D’Andrea Surveying & Engineering, P.C. (“D’Andrea”), revised date 5/24/21 2. “Landscape Plan” prepared by Environmental Land Solutions, LLC (“ELS”), dated 5/3/21 3. Drainage Summary Report prepared by D’Andrea, dated 5/3/21 4. Letter from ELS dated May 3, 2021 I inspected the 7.127 acre project site on June 24, 2021. Below are my comments on the application materials. 1. The site is characterized by a variety of disturbances: a large abandoned parking lot in a state of disrepair (Figure 1); discarded debris, and localized proliferations of invasive flora (e.g., Garlic Mustard, Porcelain Berry, Mugwort, etc.) (Photos 2 and 3). 2. The western wetland has been severely impacted by a profusion of Garlic Mustard in the understory (Photo 2). The eastern wetland supports far fewer invasive flora (Photo 4). 3. Runoff from the abandoned parking lot and the western wetland flows into a linear constructed swale, which drains off-site to the south, where it is flanked by a grass slope and parking lot (Figure 1). The swale contained a low flow of clear water on the inspection date. I did not review the off-site portion of this swale, but

Figure 1. Aerial Photograph 40 Fullin Road Norwalk, CT Connecticut Ecosystems LLC July 9, 2021

Western Wetland

Eastern Wetland

Swale Abandoned Parking Lot

40 Fullin Road Norwalk, CT 6/24/21 1. Narrow swale in western wetland at proposed road crossing 2. Large patch of invasive Garlic Mustard in western wetland 3. Profusion of invasive Porcelain Berry adjacent to western wetland 4. Eastern wetland, note dark water-stained soils

1 2

3 4






an aerial photograph (Figure 1) shows that at most it extends to Lois Street, several hundred feet to the southwest. 4. The site plan proposes to access the property from Fullin Road, which would require a crossing of a narrow portion of the western wetland (1,875 square feet of wetland disturbance). A 36 inch diameter concrete pipe is proposed to carry surface drainage below the road crossing. I request that the applicant prepare an analysis of Feasible and Prudent alternative designs for crossing the western wetland and swale. The three alternative designs that should be considered are the proposed 36 inch diameter concrete pipe, a bridge and an open bottom box culvert. The 1996 Amendments to the Inland Wetlands and Watercourses Act define the terms “feasible” and “prudent”. The former means “able to be constructed or implemented consistent with sound engineering principles.” The latter means “economically and otherwise reasonable in light of the social benefits to be derived from the proposed regulated activity provided cost may be considered in deciding what is prudent and further provided a mere showing of expense will not necessarily mean an alternative is imprudent.” The definition of the term “feasible” is straightforward, while the definition of “prudent” is more complex and nuanced, and involves a consideration of “social benefits” and cost. I interpret the term “social benefits” to mean “environmental benefits” in the context of a wetland permit application. I generally recommend a bridge or open box culvert design for road crossings of wetlands or watercourses that serve as a significant wildlife corridor, or where the passage of finfish or other aquatic wildlife is a function of the resource that will be crossed. I saw no evidence that the western wetland or narrow linear swale serve as a significant wildlife corridor, or support finfish or aquatic organisms such as amphibians. Surface flow in the swale is likely intermittent or seasonal, and the western wetland and swale are surrounded by an urbanized landscape, limiting the opportunities for long-distance wildlife movements (Figure 1). 5. In order to compensate for the proposed wetland impact, the creation of a 4,075 square foot wetland is proposed. This will be accomplished by removing a portion of the existing parking area, lowering the grade to match the elevation of the adjacent western wetland, final-grading with a clean, organic-enriched topsoil, and vegetating the area with plantings and a seed mix. I offer the following recommendations and observations regarding the mitigation plan:






• The “Wetland Creation Plan” (Sheet LP.2) shows the mitigation area in a cross section view. This is helpful, since it illustrates the proposed grades in the mitigation area in the context of the existing western wetland and the adjacent proposed development. For greater clarity, I recommend that the applicant prepare a plan view of the mitigation area, with existing and proposed grades. This will illustrate the shape of the mitigation area as well as the proposed grading throughout this area. It will also better guide the installation of the mitigation area by a contractor. • A qualified wetland professional should supervise the installation of the mitigation area (earthwork and plantings). • An as-built plan should be prepared following the construction of the mitigation area. • Two perforated PVC standpipes should be installed in the mitigation area to allow for the measurement of groundwater levels during the monitoring inspections. • Several plots should be established to monitor vegetation patterns and changes over time in the mitigation area. Percent areal coverage of dominant species should be estimated in the plots during each monitoring inspection. • Photographs should be taken at fixed locations during each monitoring inspection. • Any woody plantings that die during the monitoring period should be replaced with the same or similar species. • Item 2 of the “Wetland Creation Management Notes” on Sheet LP.2 states that the seeded areas of the mitigation site will be mowed (weed whacked) monthly during the first growing season after seeding to control weed plants. Will this impact the establishment of desirable native flora? • One of the most important factors in the establishment of a mitigation wetland community via seeding is the maintenance of a suitable soil moisture level through supplementary irrigation when necessary. Who will be responsible for determining when watering of the mitigation area is required? 6. The Landscape Plan (Sheet LP.1) shows areas where the invasive Burning Bush will be removed by hand from the eastern wetland. I also observed Multiflora Rose and Privet in this wetland. All of these invasive should be removed, and replaced in kind with appropriate wetland shrubs. 7. The site plan proposes a hydrodynamic separator stormwater treatment system to renovate the runoff generated by the site. What is the removal efficiency of this treatment system with respect to common pollutants in storm water runoff (e.g., sediments, oil and grease, heavy metals, etc.)? 8. The “Drainage Summary Report” states that the proposed drainage system will infiltrate the Groundwater Recharge Volume. However, it further states that on-site deep test pits or soil borings will be performed in the near future to determine the suitability of the soils for groundwater recharge. Has this testing been completed yet? This information






is critical to understanding whether the proposed groundwater infiltration system will work properly. Please do not hesitate to contact me if you have any questions regarding this correspondence. Very truly yours, Connecticut Ecosystems LLC

Edward M. Pawlak Registered Soil Scientist Certified Professional Wetland Scientist

Professional Resume Edward M. Pawlak

38 Westland Avenue

West Hartford, CT 06107 (860) 561-8598

---------------------------------------------------------------------------------------------- EDUCATION New England Regional Soil Science Certificate Program,

University of Massachusetts at Amherst, 1998 M.S., Silviculture, SUNY College of Environmental Science

& Forestry, Syracuse, NY, 1983. B.A., Biology & Secondary Education, State University College at Oswego, Oswego, NY, 1977.

EXPERIENCE 1995-present Connecticut Ecosystems LLC

38 Westland Avenue West Hartford, CT 06107 Owner of environmental consulting company.

Provides professional wetland and aquatic consulting services to private and municipal clients. Professional services include: Inland and coastal, State and Federal wetland boundary delineations Wildlife and vegetative inventories Environmental reports Permit assistance Wetland mitigation Aquatic studies Expert testimony

1989-1995 Soil Science & Environmental Services, Inc.

545 Highland Avenue Cheshire, CT 06410 Senior Wetland Scientist - Managed nearly one hundred projects for private and municipal clients.

1984-1989 Bristol-Myers Company Syracuse, NY & Wallingford, CT Statistical Programmer - Prepared analysis tables and graphics for statistical and medical staff in support of New Drug Applications.

Professional Resume Page 2 Edward M. Pawlak --------------------------------------------------------------------------------------------------- Supervisor of Statistical Programmers - Supervised

Statistical Programmers in the Oncology Therapeutic Area. 1979-1981 Paul V. Moore High School

Central Square, NY

Science Teacher - Taught Regents Biology and non-Regents Chemistry lecture and laboratory classes.

1977-1979 Franklin Junior High School

Reisterstown, MD

Science Teacher - Taught seventh and ninth grade General Science.

PROFESSIONAL Certifications AFFILIATIONS Professional Wetland Scientist, Society of Wetland

Scientists

Memberships Society of Soil Scientists of Southern New England (SSSSNE) Connecticut Association of Wetland Scientists Hartford Audubon Society Connecticut Botanical Society Society of Wetland Scientists

PAPERS & Pawlak, E. 2013. Vernal Pool Monitoring. CACIWC PRESENTATIONS Annual Meeting November 2013. Pawlak, E. 2012. Benefits of Monitoring Wetland Mitigation Projects: A Case Study. CAWS Annual Meeting, March 2012. Pawlak, E. 2010. The Use of GPS Technology in Rare Species Surveys. CACIWC Annual Meeting, November 2010. Pawlak, E. 1999. Town of Haddam Vernal Pool Study. Vernal Pool Workshop, Wesleyan University, May 1999. Pawlak, E. 1999. Criteria for Vernal Pool Identification and Inventory. NY State Wetlands Forum, Inc. Fifth Annual

Meeting, Syracuse, NY. Pawlak, E. 1998. Town of Columbia Wetland Study. CAWS First Annual Meeting, “Selecting a Wetlands

Evaluation Method”, Cromwell, CT.

Professional Resume Page 3 Edward M. Pawlak --------------------------------------------------------------------------------------------------- Pawlak, E. 1997. Town of Haddam Vernal Pool Study.

Vernal Pool Workshop, Wesleyan University, November 1997.

Pawlak, E. 1997. Haddam, CT Town-Wide Vernal Pool Study. Poster Session at CACIWC Annual Meeting, November 1997.

Pawlak, E. 1996. Haddam, CT Town-Wide Vernal Pool Study. Poster Session at CACIWC Annual Meeting, November 1996. Pawlak, E. and G. T Logan. 1995. Draft Cromwell Wetland Buffer Designation Methodology. SWS Annual Meeting, Cambridge, MA, May 1995. Pawlak, E. and G. T. Logan. 1994. Draft Cromwell Wetland Buffer Designation Methodology. Poster Session of the "Wetland Buffer Conference" sponsored by SSSSNE, Stockbridge, MA, November 1994.

WORKSHOPS & Vernal Pool Mapping Workshop. April 2014. CONFERENCES Wildlife Tracking Workshop. CAWS, September 2013. Invasive Species Workshop. CAWS, Summer 2013. Red Soil Workshop. SSSSNE. Wallingford, CT. Summer,

2013. Instructor, DEP Municipal Inland Wetland Commissioners Training Program (Vernal Pools). October 2007, 2013. Member of DEP Vernal Pool Model Regulations Committee. September-October 1999. Hydric Soils Workshop. SSSSNE. Brooklyn, CT. July 1999.

Floodplain Wetlands Workshop. AMWS. Amherst, MA. July 1999.

Winter Botany. AMWS. Boylston, MA. January 1999 Vernal Pool Policy Workshop. Yale University. May 1988 Vernal Pool Field Trip Leader. DEP Vernal Pool

Workshop. April 1998 Vernal Pools. Wesleyan University. November 1997 & January 1998

Vernal Pool Ecology. Tufts University. Spring 1997 Tidal Wetland Botany. IWEER. Fall 1996 Systematics Workshop: Carex Section Ovales. UConn,

Summer 1996 Identification of Grasses, Sedges & Rushes. IWEER.

Summer 1996

Professional Resume Page 4 Edward M. Pawlak --------------------------------------------------------------------------------------------------- Systematics Workshop: Scirpus. UConn, Summer 1995 Wetland Buffer Conference, SSSSNE, Stockbridge, MA,

Fall 1994 17th Annual Conference of the New England Association of Environmental Biologists, Spring 1993

CONTINUING Wetlands Assessment & Field Techniques. UMass at EDUCATION Amherst, Spring 2011 Field Ornithology - SCSU, Spring 1998 Soil Physics - UMass at Amherst, Fall 1997 Wetland Delineation - UMass at Amherst, Summer 1997 Soil Formation & Classification - UMass at Amherst,

Spring 1997 Soil Morphology & Mapping - UMass at Amherst, Spring

1996 Hydric Soils - UMass at Amherst, Fall 1994

Aquatic Insect Ecology & Systematics - SCSU, Spring 1993 Aquatic Entomology - SCSU, Fall 1992 Limnology - CCSU, Fall 1991 Herpetology - SCSU, Spring 1990

MUNICIPAL Connecticut Ecosystems LLC has identified potential vernal PROJECTS pools in 20 towns in Connecticut by remote sensing: Avon Barkhamstead Bolton Canton Colebrook East Granby East Haddam Farmington Granby Guilford Haddam Hartland Lyme New Hartford Salem Simsbury Somers Suffield Vernon

Professional Resume Page 5 Edward M. Pawlak --------------------------------------------------------------------------------------------------- Westbrook

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