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Miller Farms Application

2/20/1997

Southington Conservation Commission
75 Main Street
Southington, CT 06489
Re: "Miller Farms" application by LePage Homes, Inc.

Dear Commissioners:

I am writing on behalf of the Quinnipiac River Watershed Association (QRWA) and at the request of the intervenors with regard to the above referenced application to your commission. My comments are based upon a review of the plans and the Wetland Evaluation, the Impact Assessment prepared by Environmental Planning Services, a site walk around the pond on the adjoining DiBacco Property, conducted on Thursday, February 6, 1997, and an interview with Mr. and Mrs. DiBacco. We are concerned that several aspects of the proposed plan are not consistent with protection of wetland functions both in the immediate vicinity of the proposed project (Wetlands #1 and #2), and lower in the sub-basin watershed. Drainage from the site reaches LaCourse Pond, Panthorne Pond, Judd Brook, the Ten mile River, the Quinnipiac River, and eventually Long Island Sound. We are not opposed per se to a subdivision at this site, provided it includes a superior stormwater treatment design and carefully framed provisions for future pond-watershed management. However, we believe the plan before the commission could be significantly improved.

First , we maintain that this application is significant and warrants a public hearing, in view of the size of the proposed subdivision, the exceptional existing water quality in LaCourse pond (currently an oligotrophic pond, supporting freshwater mussels), and the well-established cost to adjoining property owners, and often the tax-payer as well, of dealing with eutrophic ponds, exemplified by the problems at Spring Lake in Eastern Southington. The fishing Pond in Panthorne Park is an important recreational resource for Southington children, and its current health depends upon good water quality coming from upstream. LaCourse Pond, which although privately owned, is often made available to members of the public by the DeBaccos for fishing, upon request, supports large mouth bass, yellow perch, calico bass, pickerel, and blue gill, blue gill, and bullhead. Characteristic fish scale piles on the east shore of the pond substantiate reports of fishing in the pond by river otter. An additional unique downstream aquatic resource, at the junction of Judd Brook and the Ten mile River, is a thriving population of a very rare, pollution-intolerant freshwater mussel, Lampsilis radiata, discovered last summer. It is one of only three self-sustaining populations of this species in Connecticut according to Southern New England Freshwater mussel expert, Douglas Smith, at the University of Massachusetts. Biologist Julie Victoria at the DEP Natural Resources Center can provide more information on this species. Finally, downstream along Judd Brook is a high quality permanently inundated floodplain swamp preserve, owned by the Cheshire Land Trust; this is a scientific research site, #C1, of the South Central Regional water Authority, the "control" site for the long term biological monitoring program, as required by CT DEP Diversion Permit DIV-86-07 for assessing impacts of water supply pumping. Several pages of the 8/32/94 monitoring report are submitted for the record. Because soils at the site are very sandy, nutrients from fertilizers and pesticides, dissolved in groundwater, pass through the soil readily. The QRWA believes this application warrants very careful review, with input by the public and technical advice available from Chuck Lee in the DEP Lakes Section. We believe the applicant's proposed water quality renovation measures could be significantly improved.

Conservation restrictions The potential impacts on the pond and on wetlands of fertilizers and pesticides in runoff and in ground water seepage from landscaped areas around houses was not addressed at all in the report by Environmental Planning Services, Inc. It was unclear from the plans I reviewed this morning, whether the application provides for conservation "buffer" restrictions requiring maintenance of natural vegetation and soils between wetlands and landscaped areas. Because of the sandy soil textures at the site, filtering of pollutants by soils requires wider, naturally vegetated buffers (at least 75 ft) than would be the case in fine-textured soils. Fortunately the presence of a very attractive natural ground-cover of Princess Pine upslope of most wetland boundaries would make this option very aesthetically appealing to most home-owners. It will be important to educate homeowners about the key role of natural buffer vegetation in protecting pond water quality, which is important for their property values. The QRWA strongly encourages including conservation restriction language in deeds, and marking their locations on the ground with permanent monuments, to ensure that they are respected in perpetuity, and also the formation of a homeowners' association to deal with lake management issues.

Hydrologic impacts on wetlands by detention basins & water quality renovation alternatives

The applicant's consulting biologist failed entirely to address the effects of significant water level changes on the vegetation, soil organisms, amphibians and other forms of life in wetlands # 1 and #2. Increased water levels dramatically alter the ecology of any wetland system, either killing or weakening vegetation and making plants vulnerable to attack by pathogenic organisms such as fungi in the Armillaria genus. Most other less obvious forms of life in a wetland are also significantly impacted by hydrologic changes. The report includes no discussions of expected water level changes and their durations. The duration of retention in water quality basins is also not discussed, a major omission because adequate time for settling out of pollutants is a key ingredient of the design of any detention basin.The commission can not have any assurance that these basins will function as hoped unless retention duration of a minimum of 24 hours can be documented by engineering calculations, as recommended by Milone & McBroom (1991). Larger extended detention basins could include both shallow marsh and flood storage areas, as shown in the attached sheets, reducing hydrologic impacts on wetlands. As another alternative (sketch attached) in view of the very sandy soils at the site, with excellent infiltration potential, we recommend that the applicant consider constructing infiltration basins with a forebay for convenient sediment removal. Infiltration would help maintain flow in the springs which supply a steady water supply to this pond, which I was informed has a very constant water level even during droughts.

We are particularly concerned about the discharge of insufficiently filtered stormwater into LaCourse Pond. We do not believe that the measures proposed by the applicant to protect water quality are appropriate to the site, especially in view of the uniqueness and high recreational value of downstream wetlands, which you are required by stature to take into account.

Respectfully submitted

Sigrun Gadwa
QRWA Executive Director


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