Wetlands & Vernal Pools
Documented wetlands, vernal pools with endangered species, and an interconnected hydrologic network are directly threatened by the proposed facility.
Why This Matters
The proposed Fire Training Facility site sits within a sensitive ecological area containing mapped wetlands greater than 9,000 square feet, a confirmed vernal pool, and habitat for state-listed endangered species. The city’s own environmental consultant acknowledged the survey was incomplete — yet the project continues to advance.
These wetlands, vernal pools, and the endangered species they support are part of what makes this a residential neighborhood — they are the neighborhood’s character. On October 14, 2025, the ZBA denied the road application 5-0 on criteria 2 (traffic) and criteria 5 (neighborhood character), with the chairman stating the character would “change irreparably” (ZBA Hearing — Oct 14, 2025, 2:16:49). Permanently destroying pristine wetland habitat when a zero-impact underground alternative exists at the same cost is exactly the irreparable change the board rejected.
The destruction is unnecessary. Horizontal Directional Drilling (HDD) eliminates all wetland and buffer impacts — zero trees removed, zero wetland disruption — at $250 per foot, matching the city’s own trench cost (Henniker Directional Drilling quote, Nov 18, 2025). Even Commissioner Sarno recognized these resources need protection, making his Conservation Commission vote contingent on a vernal pool conservation easement — which Attorney Prolman admitted has not been drafted (CC Minutes, Feb 3, 2026).
Key Facts
Proximity to Sensitive Resources
- A confirmed vernal pool at the Teak Drive/Gosselin Road intersection — documented by the City’s own consultant
- The vernal pool exceeds 4 feet deep in the center, with semi-permanent hydrology supported by groundwater
- An abundance of fairy shrimp — a primary vernal pool indicator species — was found during the April 10, 2025 survey (Gove Environmental Services)
- Three classified wetland areas (A, B, and C) were formally delineated in the project area
- The proposed access road would cross directly through the narrow connection between Wetland A (vernal pool) and Wetland C
Endangered & Threatened Species
The NH Natural Heritage Bureau DataCheck (NHB25-0677, March 25, 2025) confirmed records of the following species near the project site:
| Species | Scientific Name | NH Status |
|---|---|---|
| Eastern Box Turtle | Terrapene carolina carolina | Endangered |
| Eastern Hognose Snake | Heterodon platirhinos | Endangered |
| Eastern Meadowlark | Sturnella magna | Threatened |
The city’s own consultant (Gove Environmental Services) acknowledged that the forested upland and wetland in the vicinity of the proposed access driveway “may provide suitable habitat” for both the Eastern Box Turtle and Eastern Hognose Snake.
At the October 14, 2025 ZBA hearing, the City’s environmental consultant Brendan Quigley stated: “The entire landfill property is shaded green, which is highest rank habitat in the region” — referring to grassland bird species in the NH Wildlife Action Plan. [ZBA Oct 14, 1:47:19]
Yet at the February 3, 2026 Conservation Commission meeting, the same consultant described the area of impact as “marginal habitat, with young white pine and other roadside species.” Same property. Same consultant. Different audience — different characterization.
Paula Johnson, the Ward 5 Alderman, provided 22 pages of endangered species regulation and identification documentation in November 2025, further confirming the regulatory significance of these species.
The Survey Was Incomplete
The city’s own wetland report admits the species survey could not be completed:
“The depth of the pool, exceeding 4 feet in the center, and the dense buttonbush edge made survey of the pool difficult. It is therefore likely that additional indicator species are present in this pool but were not recorded by the survey.” — Gove Environmental Services, Wetland Report, May 19, 2025
This admission was also cited by resident Podister at the October 14 ZBA hearing [1:15:43], quoting the applicant’s own survey: “The survey was difficult to complete and there are likely additional species present.”
Hydrologic Connectivity
The wetlands and water features at this site are not isolated — they form part of an interconnected system:
- Wetland A (vernal pool) drains west into Wetland B via a narrow connection
- Both drain into Wetland C, a forested red maple wetland with an intermittent stream
- Wetland C continues outside the project area to the west
- Any contamination introduced at the facility site can migrate through this connected network
- GIS mapping shows measured distances between water features (979 feet and 90 feet overlays documented)
The Wetland Report
On May 19, 2025, Gove Environmental Services completed a formal “Report on Wetlands — Proposed Firefighter Training Area” documenting:
- Wetland delineation performed January 6, 2024
- Vernal pool survey conducted April 10, 2025
- Three wetland areas (A, B, C) with full functional assessments
- NHB DataCheck confirming 3 state-listed species near the project
What the Report Found
- Wetland A: Principal function is wildlife habitat — supports vernal pool breeding, amphibians, and turtles
- Wetland C: Principal functions are wildlife habitat and water quality protection, enhanced by largely intact forested buffer
- Fairy shrimp in abundance — primary vernal pool indicator species
- Survey acknowledged as incomplete due to pool depth and dense vegetation
What the City Proposed as Mitigation
- Graded slopes seeded with native seed mix — that’s it
- No tree replacement plan (application checked “No”)
- “Relatively few opportunities for impact mitigation due to the limited scope and publicly funded nature of the project”
At the November 25 ZBA hearing, resident Howell characterized this mitigation as: “just plant some wild flower mix” [1:04:30].
Proposed Impact
The Conservation Commission application (June 17, 2025) details:
- Driveway: 917 feet long x 25 feet wide
- New impervious surface: ~23,000 square feet (in currently undeveloped woodland)
- Tree removal: Yes — total number listed as “TBD”
- Tree replacement: None
- Permanent wetland impact: Yes
- Permanent buffer impact: Yes
- Vernal pool buffer: 100 feet (not the standard 40 feet) — per Attorney Prolman [ZBA Nov 25, 1:39:23]
What’s at Risk
Vernal Pool Protection
Vernal pools are seasonally flooded depressions that provide critical breeding habitat for amphibians and invertebrates. Under New Hampshire law:
- Vernal pools may qualify for protection under RSA 482-A (Fill and Dredge in Wetlands)
- Vernal pools have a 100-foot buffer zone — not the standard 40-foot
- Any activity within the buffer zone requires review
- Destruction of vernal pool habitat can be irreversible
Water Quality
- PFAS contamination from fire training activities could enter the water system through soil infiltration
- Connected wetland systems would distribute contamination downstream
- Remediation of contaminated wetland systems is extremely difficult and costly
Conservation Commission Authority
The Nashua Conservation Commission is tasked with reviewing projects that impact wetlands and buffers. At the February 3, 2026 meeting:
- DPW presented “updated plans” for the water service connection
- The commission voted 6-0 to approve the conventional trenching plan with conditions (pollinator mix, native shrubs, 12,000 ft easement, limit cut impact)
- Commissioner Sarno’s vote was contingent on a conservation easement around the vernal pool — Attorney Prolman admitted it has not been drafted yet
- The commission described the area as “marginal habitat” — contradicting Quigley’s own “highest rank habitat” statement at the ZBA
- After the vote, the commission discussed re-visiting horizontal drilling
What Needs to Happen
- Complete species survey — the City’s own report says additional species are likely present but unrecorded
- Full hydrologic connectivity study mapping water flow from the site to all downstream features
- Comprehensive environmental assessment before any further construction
- Independent review of the wetland delineation report by qualified ecologists
- Consider the Ridge Road alternative — an upland site with no mapped wetlands
Photo Evidence
Official photos from the City’s Conservation Commission application are available on the Photo Evidence page.
Source Documents
- Gove Environmental Services, Wetland Report (May 19, 2025)
- Conservation Commission Wetlands Application (June 17, 2025)
- NH Natural Heritage Bureau DataCheck NHB25-0677 (March 25, 2025)
- GIS mapping showing wetland boundaries and measured distances
- Endangered species documentation (22 pages, provided by Ward 5 Alderman)
- ZBA Hearing transcripts (Oct 14, Nov 25, 2025)