October 27, 2014

Lauren Farrell
MassDEP Waterways Regulation Program
One Winter Street, 5th Floor
Boston, MA 02108

Re: Small Dock and Pier General License – September 2014 preliminary draft
Dear Ms. Farrell,

The Connecticut River Watershed Council (CRC) is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed. We reviewed and provided comments on the 2012 potential eligibility criteria and design standards for small docks and piers. In this letter, we submit brief comments on the draft general license for small docks and piers.

We see that the dock size eligibility for navigable rivers has been reduced from 600 square feet (in 2012) to 300 square feet, and we support that change. We also support the change of maximum width from 5 (in the 2013 draft) feet to 4 feet.

The 2012 draft listed some of the construction standards, like prohibiting the use of chromate copper arsenate treated wood. What happened to construction standards? They seemed like a good idea, and in fact we recommended that Styrofoam be eliminated because of their tendency to break up and become a water quality problem (floatables).

Thank you for the opportunity to comment. If you would like to contact me, I can be reached at 413-772-2020 x. 205 or adonlon@ctriver.org.
Andrea Donlon
River Steward