I should probably clarify a couple of side points that have come up.
If an owner has a seasonal dock, such as a pipe dock, and wants to replace it with a sturdier form of season dock in the same size and footprint, then they can absolutely can do so without a permit. The Department has no interest. Please take photos of the old dock before removing it so that if and when someone reports a new illegal pier the complaint can be closed out as quickly as possible.
If an owner wants to replace a seasonal dock with a permanent one then we are obligated to request the need because we are obligated to justify issuing a permit for what amounts to the private taking of public lands. Part of our charge is to keep as much of the public trust available to the full public for as much time as possible. This means consideration to winter use and safety as well as summer use. People tend to assume that we regulate permanent structures for some environmental reason because we are an environmental agency, but in truth it is predominantly about balancing the public trust vs private property rights. When I had stated that "the Department is not going to start accepting boater inability as justification for "beefier" docks", I was specifically speaking to those cases where the justification given for needing a permanent pier (ie piling or crib construction) was that it was needed to absorb impact when docking. This in and of itself is not an acceptable justification for a permanent pier at a private residence. When it comes to commercial and other public facilities there are other considerations that come into play such as the abilty to bear weight associated with loading or unloading passengers and supplies, the number of craft using the pier, torque on long piers, and similar issues. The fact is that inexperienced boaters have less impact on these docks since they will typically hit another boat first and that boat will serve the same fuction as a bumper.
All of these things aside, it would be really nice if whenever we have people say to us that their boating skills are not very good, we could provide them with information on where they might learn to be better boaters.
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