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Town of Guilford seeks Corps permit to authorize work, previously placed fill for roadway repair in Guilford

Published May 23, 2017
CONCORD, Mass. – The town of Guilford Engineering Department is seeking a permit from the U.S. Army Corps of Engineers, New England District for work in waters of the U.S. in conjunction with the reconstruction of Tuttles Point Road in Guilford, Conn.

The town of Guilford seeks to authorize and retain previously placed fill material to elevate the centerline of the existing 18-foot-wide roadway for a length of 631 feet to elevation 7.3 NAVD88. The work completed by the town of Guilford included the use of a backhoe, excavator and bulldozer to discharge approximately 300 cubic yards of rock fill over a 5,695-square-foot (0.13 acre) area of tidal wetlands dominated by smooth cordgrass for construction of the raised road embankment at a slope of one to one.

In addition, two 40-foot-long, 15-inch diameter culverts, one of which was non-functional, were replaced with a single 36-inch culvert. The new culvert was placed at the same invert elevation (2.0 feet NAVD88) as the previously installed twin structure. This work also included the replacement of the two existing 10-foot-long by 5-foot-high headwalls in kind. The culvert conveys flows from a 4.6-acre tidal wetland area identified as Tuttles Point Marsh.

This work was undertaken in tidal waters and wetlands tributary to Long Island Sound from the intersection of Tuttles Point Road from Mulberry Road to White Top Lane, Mulberry Point in Guilford. The purpose of the completed work was to reduce the amount of road flooding, which will improve public safety and access for emergency vehicles during higher tidal events.

The purpose of the fill in wetlands and waters was to prevent flooding of the causeway for the Tuttles Point Road neighborhood of Faulkner Drive, Highland Street, Meriden Street, Spring Street, Sagamore Street, White Top Lane, and Rock Lane which only can be accessed via this roadway. The completed work will ensure that historical flooding during storm and astrological high tide events, historically five or six times a year, will minimize the frequency of the road being overtopped. During tidal cycles the capacity of the twin 15-inch culverts prevented tidal inflow from reaching the entire 4.6-acre marsh surface at high tide.

Under post-construction condition, the increased capacity in the volume of the 36-inch culvert will not result in a net increase in acreage of tidal wetland. However, it will allow greater salt-water intrusion into the existing 4.6-acre wetland and a faster time to drain freshwater intrusion which is necessary to combat establishment of invasive common reed. The post-constructed condition is expected to result in tidal wetland enhancement that will exceed two times the area of wetland alteration. Thus, compensatory mitigation is not being proposed by the applicant for permanent wetland fill.

This project has the potential to have an adverse effect on approximately 0.51 acre of Essential Fish Habitat (EFH) for various species and life stages. However, there is no Habitat Areas of Particular Concern designed at, or near, the site. The habitat at the proposed work location consists of an intertidal salt marsh embayment of approximately 4.6 acres dominated by saltmarsh cordgrass and common reed, surrounded by residential development. Tidal connectivity to the marsh is maintained by a tidal creek, conveyed under Tuttles Point Road. The work resulted in the direct fill and associated loss of 5,695 square feet of vegetated tidal wetland for construction of the elevated roadway revetment. The Corps has made a preliminary determination that site-specific impacts require expanded consultation for EFH. The Corps will submit an EFH assessment to National Marine Fisheries Service, who in tum will provide conservation recommendations. The Corps will coordinate with the applicant regarding implementation of these recommendations. The EFH consultation will be concluded prior to the final permit decision.

The public notice, with more specifics on the work proposed by the town of Guilford, can be viewed on the Corps website at The application for the federal permit was filed with the Corps in compliance with Section 10 of the Rivers and Harbors Act, which provides for federal regulation of any work in, or affecting navigable waters of the U.S.; and Section 404 of the Clean Water Act, which regulates the discharge or fill of material in U.S. waters, including wetlands.

Public comments on this work proposed by the town of Guilford (file # NAE-2016-00413) should be forwarded no later than June 22, 2017 to the U.S. Army Corps of Engineers, New England District, Regulatory Division (ATTN: Cori Rose), 696 Virginia Road, Concord, MA 01742-2751. Additional information is available from Permit Project Manager Cori Rose at 978-318-8306 or toll free 800-343-4789 or 800-362-4367 (if calling from within Massachusetts) or by email to:

Tim Dugan

Release no. 17-052