21 February, 2005

Jeff Blecharczyk
DES Wetlands Bureau
PO Box 95
Concord, NH 03302

Email: jblecharczyk@DES.state.nh.us

REF: REVISED DREDGE AND FILL APPLICATION FOR PROPOSED WAL-MART STORE, WEST MAIN ST., HILLSBORO, NH MAP 11F LOTS 20 AND 441

The Contoocook North Branch River Local Advisory Committee, (CNBRLAC), has serious concern about the wetlands dredge and fill permit application of Wal-mart proposed for the town of Hillsboro. Since this is a major project within this protected river’s watershed, we should have received a copy of the application. (We did not receive a copy until Monday and only when we copied it at our own expense from the one copy in the town of Hillsboro.) This project involves the filling of + 0.86 acres of wetland within the Shedd and Beards Brook sub-basin of the Contoocook River drainage basin, a protected river.

    1. PERCENTAGE OF SITE TO BE COVERED WITH IMPERVIOUS SURFACE

No where in the plans does it state the percentage of the site which will be covered by impervious surface.(This is normally put on several of the plans of the site). The rationale for the legal limit of 30% of the lot covered with a building, is due to the problems with the amount of impervious surface. The application states that the building will cover 23% of the lot. However, with the numerous roadways and parking lots, it will actually cover over 70% of the site.

In the recently published USGS Water Quality in the New England Coastal Basins, their major finding was:

"Degradation of stream ecosystems appear to occur early in the process of watershed urbanization. Populations of macroinvertebrate species, such as mayflies, stoneflies, and caddisflies, which are sensitive to urban contaminants are reduced where as little as 3 percent of the land cover in the watershed is urban and population density is less than 300 people per square mile. Stream ecosystems are fully degraded where urban areas cover about 20 percent of the watershed. " ( p. 1 Publication 1226)

Covering over 70% of this large site on top of Penstock Hill, in addition to the already existing pavements (of Sylvania, Shaw’s, Cricentis, Carpenter Ford, and other businesses) all in the same area around the confluence of Beard Brook and North Branch of Contoocook River can result in serious degradation of the river. Concord representatives on our LAC expressed concern, as their town depends on the Contoocook River for their municipal water supply.

    1. INCOMPLETE TREATMENT OF A MANMADE WETLAND TO REMOVE TOXIC CHEMICALS FROM THE STORMWATER RUNOFF

According to the plan, all the storm drainage will be routed from throughout the site to the newly created wetlands on the Northwest corner of the property. Wetlands are capable of removing sediments, phosphates, and some oil from the runoff. However, wetlands are not capable of removing either chloride (from the de-icing of the parking lot), nor can they remove any materials which are dissolved in the water, such as benzene, toluene, and MBTE). According to the USGS Water Quality Trends in New England Rivers, published in 2003, "Annual chloride concentrations in the Merrimack River increased its mean-annual chloride concentration 760%, from 2.9mg/L to 24.9mg/L. The upward chloride trends are likely the result of road salt application for de-icing purposes." p. 13

Chloride will kill the vegetation, which will cause further limitation to the wetlands ability to filter the water. Also, wetlands ability to filter the stormwater runoff only occurs during the growing season, causing no filtration during the winter months.  

    1. IMPACT ON BEARD BROOK A FEDERALLY STOCKED SALMON STREAM AND DRAINAGE INTO A PROTECTED RIVER

According to the Wal-mart plan, the runoff will leave the property through two culverts under the bypass into the wetlands and Shedd Brook near the confluence of Beard Brook. . Normally, if you change the drainage of an area, a federal alteration of terrain permit is required, especially when it will drain into a federally funded (US fish and Wildlife) salmon restoration brook, (Beards Brook) Also the wetlands on the other side of the bypass is one of the major aquifers for the town. In these days when drinking water supply is in great demand and a valuable asset, we think that the town might want to limit degradation of their aquifers so they can be used as future water supply for either the town or be sold to other towns.

    1. POND ON PROPERTY IS NOT A NEWLY MANMADE POND

The application states that the pond on the south eastern corner and the wetlands on northern side of the property is manmade, created when the fill from the bypass was placed there. However, that pond has been in existence for a much longer time. According to the 1957 USGS Topographical map of 1957, that area was wetlands back then. According to the Dec. 1953 Hillsborough County Soil Map, (before old Route9 was relocated slightly to the north) that area is composed of Whitman stony loam, (poorly drained soils). See copies of maps attached).

Representatives of the fourteen towns that serve on this state appointed local advisory committee encourage you to look at this type of development carefully in light of the above issues.

Signed and submitted on behalf of CNBRLAC

Rodman Zwirner,

Chair