Commentary: Understanding an “Engineered Stormwater Management Plan”

Freedom—August 19, 2026—Polluted runoff from rain and melting snow causes over 90% of water quality problems in our lakes and rivers.

That’s according to NH LAKES, which says the pollutants that degrade our lakes range from phosphorus and pesticides to bacteria and nutrients from septic systems.

Controlling runoff, or “stormwater” as it is often called, is especially important for commercial operations. They have a higher level of land density and use, and a higher level of impervious surfaces, including roads, rooftops and parking areas.

The higher the percentage of impervious surfaces, the greater the frequency, volume and flow rate of runoff. On a lake, unmanaged runoff can destabilize a shoreline and send pollutants into the water.

In January, Freedom’s Select Board required Wabanaki Campground to provide a stormwater management plan produced by a qualified engineer.

The stormwater plan is part of a multi-part enforcement action that the town took against Wabanaki manager Mark Salvati to address a broad set of development issues that were made public during Planning Board proceedings in 2024 and 2025.

As part of his agreement with the town, Mr. Salvati has paid $82,500 in fines. An additional $716,100 in fines remains outstanding and is dependent on his cooperation with the terms of the January agreement.

With an engineered stormwater management plan now required, what should the community expect? For one thing, experts agree that a plan needs to account for what actually exists on the property, not merely what was historically approved.

That is especially important in the case of Wabanaki because public records show the campground has changed substantially since DES approved a subdivision plan and issued a campground operating certificate in 2001.

Perhaps in recognition of that, the town paired its stormwater management plan requirement with an “existing conditions” plan requirement.

An existing conditions plan will allow town officials to determine the full extent to which the business is out of compliance with local regulations. That, in turn, will point to what changes are needed to address the property’s runoff issues.

Key to any analysis is the percentage of impervious surfaces on the property. As previously noted, the higher the percentage of impervious surfaces, the greater the frequency, volume and flow rate of runoff.

Wabanaki Campground’s impervious surfaces include buildings, roads, compacted campsites, parking areas and RVs. Additional impervious surfaces include dozens of decks and porches constructed without permits, according to town records.

During the 2024 and 2025 Planning Board proceedings, Wabanaki agent Horizons Engineering submitted so many conflicting versions of the property’s “current state” that the board voted to halt the proceedings. The application was then abandoned. A new current conditions plan will presumably rectify that.

Another key to the current analysis is answering the question “where will the runoff go”?

A drainage system with ditches and culverts was constructed in the 1960s as part of an aborted residential development. But pictures of the property’s runoff and shoreline erosion suggest that system is no longer functional.

An engineered whole-site drainage map based on a thorough in-person site inspection should show specifically how runoff will be handled at every existing and proposed discharge point on the property, and where the runoff will be directed.

For example, runoff from a parking area might be directed to a catch basin, be treated and then be funneled to an infiltration basin. Or runoff from a roadway might be directed to a culvert, then to a ditch and thereafter to the lake.

The treatment of runoff before it enters the lake will be a key issue that should be addressed in any plan that Wabanaki puts forward. In addition to abutting the lake, the campground is above a primary recharge area of the Ossipee Aquifer, the region’s drinking water supply.

The creation of an existing conditions plan and an engineered stormwater management plan, and how they interact, is a complex technical exercise—and one that is more intricate than this brief summary suggests.

Mr. Salvati has hired Bobrek Engineering of Danvers, MA, for the stormwater plan. Former Horizons Engineering surveyor Bryan Berlind is responsible for the current conditions plan. The Select Board has hired CMA Engineering of Portsmouth to conduct a third-party review of the documents.

The result of this process will ultimately form the basis of a Site Plan Application, which Wabanaki is required to prepare and submit to the Planning Board as part of the January agreement. Freedom Conservation Commission will scrutinize the plans, and the Planning Board has discretion to require its own third-party technical review.

To date, Wabanaki has submitted an existing conditions plan and two versions of what it calls a “Stormwater Report” and a separate “Proposed Drainage Plan.” CMA has reviewed the former and the first of the two versions of the latter.

The Select Board has declined to comment on the submissions or CMA’s reviews. It has asked the public to withhold comments on the materials until it determines whether Mr. Salvati has met the requirements it set forth in January.