- The proposed activities involve site alterations which are reasonably likely to discharge storm water runoff pollutants from the roof areas to downstream wetlands and watercourses, potentially causing premature eutrophication.
- The filling of 15,000+ sq ft of wetlands is a significant activity and will likely lead to a loss in ecological wetlands functions.
- The proposed activity is a High Pollutant Load Site by the CT DEP 2004 Storm Water Quality Manual (Table 7-5, page 7-8) under several criteria. This generates higher pollutant loads from impervious surfaces.
- The proposed stormwater basins are dry detention basins which do not minimize water quality impacts as directed by the CT DEP 2004 Storm Water Quality Manual.
- The proposed stormwater basins do not have forebays as required by the CT DEP 2004 Storm Water Quality Manual, which would allow downstream nutrient loading to receiving waters and wetlands, including the Kissawaug Swamp.
- The filling of wetlands for the building and/or parking areas result in the destruction of wetlands which is the very definition of an adverse physical impact and Significant Activity requiring a public hearing under the Inland Wetlands &Watercourses Act and the consideration of feasible and prudent alternatives pursuant to Conn. Gen. Stat. § I W A §22a-41.
- The proposed wetlands mitigation will not serve to mitigate the filling and loss of functional wetlands and is not a feasible and prudent alternative
In addition to Attorney Keith Ainsworth, the MSTA hired the following experts to testify before the Conservation Commission:
- Steven Trinkhaus of Trinkhaus Engineering, LLC, a professional engineer and drainage expert
- Dr. Steven Danzer of Steven Danzer, Ph.D. and Associates LLC, a nationally certified Soil Scientist, Professional Wetlands Scientist and Certified Arborist
- Dennis Quinn of Quinn Ecological, LLC, a herpetologist and Adjunct Instructor at Naugatuck Valley Community College (unfortunately, because the MSTA was denied access to the Timex site, Dennis Quinn was unable to do any habitat evaluation of the existing site wetlands to check for the potential existence of threatened or endangered species, and so there was no report to produce)
Here
are the full reports from our expert witnesses, which fully confirm the
concerns we had when filing our intervenor petition back in January. As
a result of the MSTA’s efforts to expose the adverse environmental
impacts this project would cause, the Conservation Commission finally
voted on a finding of significant impact to wetlands at the Feb 28th
meeting and scheduled a public hearing for March 28 at 7pm. The
applicant is also required to provide feasible and prudent alternatives
to filling in wetlands. THANK YOU to all the donors who sponsored our
lawyer and expert witnesses: your support was critical for getting us to
this decision.
