For Attention of Lake Residence: If you value having a seawall
We at LMLPA need to bring an issue to your attention. There is a proposed rule that will be coming out in the Federal Register any day now that includes a new Living Shorelines General Permit. pertinent It is very likely that the Corps of Engineers may include in Alabama Power’s new PGPs (yet to be issued to APCO) a requirement that anyone wanting to perform bank stabilization to prevent continued erosion may be required to have their contractor construct a Living Shoreline to prevent such erosion unless the Contractor can demonstrate (how this works is not spelled out in existing or proposed regulations) that this method will not adequately protect the bank. Unfortunately, the Alabama state legislature has voted to endorse the new “living shoreline” proposition which would in effect prevent construction of traditional seawalls. To stop this effort from being adopted by the U.S. Army Corps of Engineers (USACE), we need everyone to take action now! We only have a few weeks left to protest.
If you value having a seawall versus being forced in the future to install a “living shoreline” which could attract snakes and mosquitoes and be expensive and difficult to maintain, please take the following actions immediately:
- Create a new email addressed to U.S. Army Corp of Engineers <NWP2017@usace.army.mil>
- In the Subject line of the new email, put Docket # COE-2015-0017 protesting adoption of Living Shorelines
- Copy all of the text below the dotted line and paste it into the body of the email. Feel free to edit the text and add your own comments to make it more personal.
- Sign your name at the bottom under “Respectfully submitted”
You may also wish to mail a printed copy of the text to
U.S. Army Corps of Engineers, Attn: CECW-CO-R, 441 G Street NW, Washington, DC 20314-1000
Ms. Shannon Johnson, USACE Regulatory Division, Birmingham Field Office, 218 Summit Parkway, Suite 222, Homewood, Al. 35205
Also, email the contents of the document to our Alabama Senators.
Jeff Sessions <https://www.sessions.senate.gov/public/index.cfm/contact-jeff>
Richard Shelby <https://www.shelby.senate.gov/public/index.cfm/emailsenatorshelby>
COPY ALL TEXT BELOW THIS LINE AND PASTE INTO A NEW EMAIL
OR PRINT THE WORD DOC VERSION ATTACHED AT THE BOTTOM AND MAIL A HARD COPY
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To U.S. Army Corps of Engineers
RE: Docket COE-2015-2017 concerning proposed NWP B Living Shorelines Permit
We as residents on the shores of an Alabama Power Company hydro-electric lake strongly oppose the adoption of the Living Shorelines Permit for man-made reservoirs for the following reasons.
- Living Shorelines may make some sense for specific coastal areas where wave action is mild and estuarine areas as was originally intended, but not for man-made lakes where there is substantial higher energy wave action that causes constant significant erosion.
- Waves from boats, wind and storms can result in almost continuous low, moderate and high energy impacts to reservoir shorelines, thereby requiring proven substantial structures such as rip rap and seawalls.
- Living Shoreline construction techniques have not been proven and may not even be effective in reservoirs with routine drawdowns.
- Man-made lakes that were created for hydro-electric power and for human recreation do not have a natural shoreline. The shoreline was man-made from the beginning. Therefore it is unrealistic to now require Living Shorelines. We homeowners on these lakes have invested significant money in our lake property and wish to continue to protect our shorelines from erosion while providing a safe area for our children to swim and play without fear of snakes or a mosquito breeding ground that could be the unintended result of a Living Shoreline.
- Living shorelines are likely to fail quickly along shorelines with moderate to steep banks
- The installation of coir logs (coconut fiber logs) would require in most cases roughening and contouring the shoreline banks which would result in increased water turbidity (eg. Muddy water) and sediment getting into the shallow areas (possible wetlands) that are routinely used by bream, small fishes and many other aquatic species such as mussels and snails.
- There is a high potential for continued shoreline erosion due to roughening of the banks as well as the possibility of coir logs floating away into the lake
- Rip rap and seawalls have served lakeshore owners well for decades by preventing continued erosion of the shoreline and loss of property
- It has not been established what information is needed for a construction contractor to demonstrate to the USACE’s satisfaction that a Living Shoreline will not adequately protect shoreline erosion thereby allowing rip rap or a seawall as protection to an eroding shoreline bank.