1 Michael W. Klemens, LLC Ecological Land Use Planning POB
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Michael W. Klemens, LLC Ecological Land Use Planning POB 432/105 Main Street Falls Village, CT 06031 January 14, 2021 Chairman Hannon and Members of the Farmington Inland Wetlands Commission 1 Monteith Drive Farmington CT 06032 In Re: Proposed residential development 402 Farmington Ave and Quarry Road Dear Mr. Hannon and Members of the IWWA: I have reviewed various documents submitted into the record regarding the above captioned proposed development. My review focuses primarily on the Wetland Delineation and Impact Assessment prepared by Milone and MacBroom (MMI #3571-09) which I believe is in large part the work product of Megan B. Raymond. You already received some verbal testimony from me at your meeting of January 7th 2021 which I will expand upon in this letter. Ms. Raymond’s assessment is focused on the two vernal pools that lie within the Tennessee Gas Pipeline easement in the vicinity of the proposed development. But in my professional opinion, that should not be the endpoint of this assessment, but the beginning. These vernal pools are but stepping stones in a mosaic of interconnected wetland habitats that pool along the base of Talcott Mountain. Such wetland formations occur along the base of these diabase ridges because the hard igneous rock forms a dam. These wetlands flow along the base of the ridge, until there is a gap through which they flow. The wetlands on this site have direct connections north and south along the base of the ridge, but also ecological connections that ecologically join these wetlands with other perched wetlands on the higher elevations upon the trap rock ridge. In my forthcoming book (Klemens et al. 2021 in press: Conservation of Amphibians and Reptiles of Connecticut) there is an illustration of the annual movements of the spotted turtle (Clemmys guttata) from wetlands not unlike those that occur north and south of the subject property. An earlier version of that illustration can be viewed in Klemens, Shansky, and Gruner (2006). The annual cycle of such landscape species encompasses wetlands at the base of the ridge and move then move upward to perched vernal pools on the ridge, and back to hibernate in the base of ridge wetland complex. Spotted turtles, a State-listed species have been found in other nearby sites along the base of Talcott Mountain within this wetland system. Additional species that are mapped in the aforementioned book are ribbon snakes (Thamnophis sauritus) a wetland dependent State-listed species that has been found (as per geo-referenced data) on 1 the subject property in 2017. Eastern box turtles (Terrapene carolina) a facultative vernal pool species have been found at several numerous nearby sites. Other species that have been documented at and immediately adjacent to the site are spotted salamanders (Ambystoma maculatum), marbled salamanders (Ambystoma opacum), and potentially blue-spotted salamanders (Ambystyoma laterale). Both the eastern box turtle and the blue spotted salamander are State-listed species. There is a well- established pattern in the Central Connecticut Lowland, where Jefferson salamanders (Ambystoma jeffersonianum) occur in vernal pools on the ridge top (as they do at multiple sites on Talcott Mountain) and blue spotted salamanders occur in the swamps at the base of the ridge. There is some genetic exchange between those two species of salamanders across the elevation gradient from the top of the ridge to the swamps below (see Bogart and Klemens, 1997, 2008). The previously documented richness of the wetland-dependent amphibians and reptiles that have been recorded from this swamp system, and the paucity of data in the report, calls into question the amount of survey effort, the times of year, number of person hours, and methods of survey. For example, were minnow traps used in the vernal pools to determine the presence of pool breeding salamanders? How many times in the springtime breeding season were egg masses counted? Wood frog egg masses are deposited several weeks to a month earlier than spotted salamander masses. The current pattern of early springtime weather (mid-February) followed by several weeks of freezing weather, and then a secondary period of warmth in mid-late March has resulted in very protracted breeding seasons. At a long-term study site, in a series of pools located in a swamp system at the base of a trap rock ridge (Hatchett Hill) in nearby East Granby, we have had to modify our sampling (egg mass counts) to adjust to what is now a bimodal 6-8 week breeding season, that historically was compressed into a unimodal pattern of 3-4 weeks. This is a direct result of weather patterns associated with climate change. Given these variables and the paucity of information, more detail is needed as to the sampling regimens that have yielded such little biological data. Another question to be addressed is whether live turtle traps were employed in the vernal pool to assess the use of these wetlands by spotted turtles? Turning to the two vernal pools, apart from my questioning the comprehensiveness of the data, as I mentioned at your January 7th hearing, the customary procedure in evaluating landscape conditions pre- and post-development using Calhoun and Klemens (2002) is to create a visual presentation showing the pools, the 100-foot ring around the pools known as the vernal pool envelope, and the critical terrestrial habitat that reaches from the edge of the envelope to 750 feet. Although Ms. Raymond gave some calculations verbally it would be helpful for all involved in reviewing this application see a visual depiction of these zones, and the amount of land lost to development expressed in both square feet or acres, pre- and post-development, and those amounts expressed in percentages. There are numerous examples of how this is calculated and visually represented, including projects that the applicant’s environmental engineers and consultants have been involved with (e.g., Wheelers Farm Road 8-30g project in Milford). Finally, it should be noted that this location is mapped as a critical area for the connection of biodiversity to the north and south, colloquially referred to as a wildlife corridor (see Gruner, Klemens. and Persons 2006:34-36). This development as placed directly cleaves this wildlife corridor. Habitat 2 fragmentation such as is proposed is one of the primary threats to habitat degradation and local extinction (extirpation) of populations of sensitive species (see Johnson and Klemens, 2005). The placement of stormwater basins shown on the plans are also problematic. They could serve to trap wildlife moving through the corridor and serve as decoy vernal pool that could result in a population sink for the two vernal pools. In my professional opinion, based on the information provided by the Applicant, limited as it is, coupled with my in-depth knowledge of the area, there is a high likelihood of serious and irreversible impacts to wetlands and wetland-dependent species from the proposed development. These adverse impacts include further degradation of the two vernal pools and the severing of the inter-conservation area connection linking primary conservation areas to the northeast and southwest through the wetlands mosaic previously described. These wetlands, including the subject property, have documented occurrences of ecologically important, declining, and State-listed species. There is more than a mere theoretical possibility of specific harm to the public’s substantial interests in protecting these natural resources. The adverse impacts are highly probable, not merely possible. In my professional opinion, there are numerous uses and development scenarios for this site that would be more feasible and prudent than what is proposed in this application. Without the data and analysis that I have described as essential, I am at a loss to be specific, other than to suggest that a less intensive development, one that disturbs less of the landscape, and is located largely in the northeastern portion of 9249 Farmington Avenue, more distant from the vernal pools and wildlife corridor, could be made to work to make reasonable, economic use of the property. For now, my recommendation is that the application for Regulated Activity Outside Wetlands or Watercourse (Upland Review Area) Activity for the proposed driveway, parking lot, garage building, associated grading/clearing (include all proposed regulated activities), and stormwater management basins for this intensive use be rejected in favor of maintaining the existing low density residential zoning and Business Restricted zoning and the feasible and prudent alternatives are fully considered. Sincerely, Michael W. Klemens, PhD 3 Attachments: CV Calhoun and Klemens (2002) Gruner, Klemens, and Persons (2006) Literature Cited: Bogart, J. P. and M. W. Klemens. 1997. Hybrids and genetic interactions of mole salamanders (Ambystoma jeffersonianum and A. laterale) (Amphibia: Caudata) in New York and New England. American Museum Novitates 3218, pp. 78., 8 figs., 16 tabs. Bogart, J. P. and M. W. Klemens. 2008. Additional distributional records of Ambystoma laterale, A. jeffersonianum (Amphibia: Caudata) and Their Unisexual Kleptogens in Northeastern North America. American Museum of Natural History Novitates: 3627: 58 pp., 8 figures, 7 tables. Calhoun, A. J. K. and M. W. Klemens. 2002. Best Development Practices (BDPs) for Conserving Pool-breeding Amphibians in Residential and Commercial Developments. MCA Technical Paper No. 5, Metropolitan Conservation Alliance, Wildlife Conservation Society, Bronx, NY. Gruner, H. J., M. W. Klemens, and A. Persons. 2006. Farmington Valley Biodiversity Strategy. MCA Technical Paper No. 11, Metropolitan Conservation Alliance, Wildlife Conservation Society, Bronx, NY. Johnson, E. and M. W. Klemens (eds). 2005. Nature in Fragments: The Legacy of Sprawl. Columbia University Press, NY 382 pp. Klemens, M. W., M. Shansky, and H. J. Gruner. 2006. From Planning to Action: Biodiversity Conservation in Connecticut Towns. MCA Technical Paper No. 10, Metropolitan Conservation Alliance, Wildlife Conservation Society, Bronx, NY.