CANDLEWOOD VALLEY CHAPTER TROUT UNLIMITED P.O Box 3795, Danbury, CT 06810 TO: Newtown Inland Wetlands Commission May 12, 2015 FROM: Candlewood Valley Trout Unlimited RE: Application IW# 08-43 The Riverwalk at Sandy Hook Village The Candlewood Valley Chapter of Trout Unlimited (CVTU) offers the following comments to the Inland Wetlands Commission for consideration during its deliberations on the subject application. Trout Unlimited is the nation’s largest grass roots coldwater conservation group with nearly 200,000 members. Over 50 members of the Chapter live in Newtown. Below are several concerns and requests that our organization would like the Commission to address while considering this application. Our concern is with the Pootatuck River and project impacts on the river. The River just upstream from the project the site is a Class I Wild Trout Management area sustaining a population of naturally reproducing trout, one of only 9 such waters in Connecticut. The River immediately adjacent to the development is managed as a stocked area and is used by many residents of Newtown as a recreational source. The Pootatuck is a rare resource which needs to have the highest levels of protection. We thank the Inland Wetlands Commission for holding hearing open so the public could have an opportunity to review the file and comment. Representatives from CVTU have had the opportunity to review information contained in the file as of May 12 and to walk the site with the Developer. We appreciate the cooperation of the Commission and the Developer in order to do so. We offer the following comments on the project: 1. A zone of separation between the project and the river is important as the riparian buffer provides an opportunity for runoff to be treated naturally and to cool during critical summer periods as well as providing many other benefits. The Iroquois pipeline right of way and the FEMA flood zone for the river result in a significant separation between the project and the river over much of the site. Therefore, much of the project has an reasonable zone of separation from the river. We note that it would have been most helpful to have the river prominently displayed on project maps showing the size of the riparian buffer. The developer indicated during the site walk that the intention is to leave the current riparian buffer in place. We commend this intent and suggest leaving the current riparian buffer in place be incorporated as a condition into project approvals. 2. The CVTU area of biggest concern is the northern end of the complex containing the 2, three bedroom town houses without garages (Building 7). We note that the area north and east of drainage areas B, C, D, and E on the drainage area map has no stormwater management. While some of this area is current tributary channel and wetlands, Building 7 and the area containing the building parking and the entrance drive will drain directly to the unnamed tributary stream with no retention or other management of stormwater. Any spills or materials from this area will go directly to the stream and hence, to the Pootatuck, with no opportunity for treatment or 3. 4. 5. 6. management. CVTU would request that runoff from this area, and particularly the parking spaces and road in the vicinity of Building 7 be managed, perhaps by a rain garden to the west of Building 7 and water from the road between drainage area E and the stream routed to a rain garden west of the stream. We appreciate the applicant’s plans to capture and infiltrate up to the first 2” of rainfall. We do have questions around this design as follows: The current application file does not contain information on the design of the infiltration galleries or rain gardens. It is not clear how quickly these will drain and the time period of the rain which will be treated. That is, for example, if there are 2 days with 2” of rain each, will both be treated or will the second day’s rain overflow the treatment system and be released. We request that the Commission request the Applicant clarify these matters. We note in the JMM report that a maintenance plan will be required to continue to keep the system in operation over many years. We encourage the Commission to require inspections and maintenance at defined times with reporting of results to the Town enforcement staff so that the system will remain effective for the long term. The current box culvert design has a drop at the exit which will be prohibitive to fish and wildlife transit through the culvert. We suggest the Commission request that this drop under the culvert be eliminated. We had questions on calculation of impervious area. It appears that calculations are based on changes to the original application rather than the undeveloped site. While this may be consistent with a permit modification, we would suggest that the Commission compare the predevelopment impervious area and runoff from same to the post development runoff areas for preservation of the watercourse. We also note as mentioned above, that a portion of the area north and east of drainage areas B, C, D, and E is not included in the drainage calculations and has impervious area resulting from the project. The south end of the Building 1 parking and the southwest corner of Building 4 both show trash recycle bins. We suggest the runoff from these bins be routed to the appropriate stormwater treatment systems. CVTU welcomes the opportunity to work with the Commission and could provide references on impacts of impervious surfaces or heated temperature impacts upon request. For additional information or questions please contact Chapter President, Steve Zakur at 203-994-0627 or Conservation Chairman, Joe Hovious at 203-270-1960.