Krista Romero
DEEP Land & Water Resources Division,
79 Elm Street, Hartford, CT 06106-5127

Re: Notice of Tentative Determination to Approve Structures, Dredging & Fill and Tidal Wetlands and 401 Water Quality Certificate And Intent to Waive Public Hearing

Dear Krista Romero,

On behalf of the Connecticut River Conservancy (CRC), I am submitting comments on application #201905232-SDFTWQ for the replacement and installation of new floating docks and new maintenance and dredging at 333 Ferry Road in Old Saybrook. CRC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed. As the project is located in the Connecticut River, it is of interest to CRC.

The proposed project calls for the replacement of existing floating docks, installation of new floating docks, as well as maintenance and expanded dredging.

Dock Replacement
The Licensee, the Connecticut Department of Energy and Environmental Protection (CT DEEP) Engineering & Field Support Services Division, proposes to replace existing 2,280 square feet of floating concrete dock and 12 timber piles that anchor the system. New dock structures will include 744 square feet of dock and five restraint piles. The permit application states that, at some point, storm damage resulted in the partial loss of floating docks, which were not replaced.

We are concerned that by replacing the docks with the same materials, the docks with be exposed to the same storm damage and break off once again. Many floating concrete docks are composed of large blocks of expanded polystyrene (EPS) coated in a shell of concrete with mesh and rebar support. When EPS from docks breaks off due to storm damage, fish and wildlife ingest the particles and it leaches chemicals such as benzene, styrene and ethylene into the water. We recommend that the Licensee replace existing docks with docks that contain no EPS at all, such as reused 55 gallon barrels or high density polyethylene cubes.

Dredging and Phragmites australis removal
We appreciate that the CT DEEP will hand-remove Phragmites australis and ask that in removing the phragmites, care is taken to ensure the bank will be stabilized once the plant is gone.

The CT DEEP is proposing to expand the existing dredge footprint to 22,321 square feet using a barge mounted crane with clamshell bucket to dredge the proposed dredge areas. We are interested to know the justification for a minimum of a 10-15 foot setback from any wetlands during this process, instead of a larger setback to protect the wetland. Dredging and maintenance comes at an environmental cost to the river; it can disturb or kill benthic species and communities, while increasing suspended sediments. CT DEEP should only dredge the areas absolutely necessary for safe navigation.

Thank you for the opportunity to comment on this project. I can be reached at 806-704-0057 or

Kelsey Wentling
River Steward