CT Department of Energy and Environmental Protection
Land and Water Resources Division
79 Elm Street
Hartford, CT 06106-5127
February 24, 2020
Comment on Camp Claire Application No. 201815641-SDFTWQ
Dear Susan Jacobson,
On behalf of the Connecticut River Conservancy (CRC), I am submitting comments on application #201815641-SDFTWQ for the replacement and installation of a new floating and fixed pier system, and shoreline stabilization at Camp Claire, 15 Oakland Ave. in Lyme. 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 Hamburg Cove along the Connecticut River, it is of interest to CRC.
The proposed project calls for the installation of a dock and stairway for recreational access, gravel and stone fill, replacing a seawall and stabilizing sections of shoreline by grading and planting for flood and erosion control. This project will enhance enjoyment of the Connecticut River through safe access to the water, which is integral to CRC’s mission.
This project includes several activities that require hardening the shoreline, such as rebuilding sea walls and elevating the peninsula with gravel. We urge the Licensee, Docko Inc., to reduce these types of hard infrastructure in favor of natural alternatives, such as those used to construct living shorelines. Living shorelines improve water quality and habitat, and can act as a natural barrier to water level fluctuation. The Connecticut Department of Energy and Environmental Protection (CT DEEP) should encourage natural and living alternatives in future permitting processes.
The Licensee, Docko Inc, proposes to remove and replace the derelict floating dock with a new floating and fixed pier system. Keith Nielson, the contact for Docko Inc., explained that the floating components of the dock will be polyethylene tubs encapsulating expanded polystyrene (EPS) foam. While we advocate for alternatives to EPS floatation, we appreciate that the EPS foam will be contained within sturdy tubs to prevent the foam from entering the waterway.
Raising the Elevation of the Peninsula
Due to high waters overwhelming sections of the peninsula, Docko Inc. proposes to add gravel and crushed stone over 2,500 square feet of the peninsula in order to raise the height of the peninsula to a maximum height of 5.5’. We are concerned about raising the peninsula for two reasons:
- Raising the peninsula would eliminate intertidal areas that might provide habitat for plant and animal species that prefer wetter sites. In the context of climate change and rising waters, we can understand concerns of flooding; however, we ask that Camp Claire and Docko Inc. reconsider raising the peninsula and if it is absolutely necessary for the function of the camp.
- If the peninsula is raised, while existing vegetation will remain in place, there are no plans in place to introduce additional vegetation. The introduction of additional gravel and stone has the potential to impede natural growth and the establishment of a riparian zone along the peninsula, as well as reduce the amount of habitat for wildlife. The addition of gravel and rock will decrease the permeability of the area and lead to increases in runoff, which contributes detritus, nutrients and pollutants into the river. While the gravel may be necessary due to the high volume of foot traffic during the summer months, we urge Docko Inc. to plant native vegetation that can provide habitat, promote groundwater recharge and natural growth in the riparian zone. We recommend that the peninsula have designated walking areas composed of gravel, while promoting the growth of native plant species in ‘no-walk’ areas.
Wall Replacement and Bank Stabilization
Similarly, the proposal to replace 35’ of existing stones and walls with new stones and 30 cubic yards of stone and gravel backfill should include plans to introduce vegetation in the establish a living shoreline, which would promote the health of both aquatic and terrestrial species while reducing erosion. Instead of rebuilding the seawall, we ask that Docko integrate logs, woody debris and native plantings, which will reduce erosion and runoff while providing habitat, and reinforce the shoreline.
Docko Inc. proposes to stabilize the shoreline adjacent to the stone building and on the east side of the peninsula using large boulders at the toe of the eroding bank and supplementing the bank with coil logs and plantings of native wetland species. We appreciate this use of natural materials and native plants to stabilize the shore and prevent further erosion.
Keith Nielson indicated that Docko Inc. hopes the project will start in early March and be completed by mid-May to early June. Because there is a known infestation of invasive water chestnut and likely invasive hydrilla as well, we encourage CT DEEP to process this application so the project may run according to schedule. Increased construction activity in late May and early June could lead to the proliferation and spread of invasive species, which become active during the early summer months.
Thank you for the opportunity to comment on this project. I can be reached at 806-704-0057 or firstname.lastname@example.org.
27 Washington Street
Middletown, CT 06457