[CT Birds] Comments of Audubon Connecticut on the Silver Sands State Park Improvement Plans

Comins, Patrick PCOMINS at audubon.org
Thu Oct 8 15:47:36 EDT 2015

Below are the comments that Audubon Connecticut submitted regarding the proposed improvements to Silver Sands State Park:

Comments of Audubon Connecticut Re. Proposed improvements to Silver Sands State Park

September 24, 2015

Thank you very much for the opportunity to comment on the plans for improvements at Silver Sands State Park. Audubon Connecticut is the state program of the National Audubon Society representing six local Chapters and over 10,000 members across the state. Our mission is to conserve and restore natural ecosystems, focusing on birds, other wildlife, and their habitats for the benefit of humanity and the earth's biological diversity.

The Important Bird Areas Program is a global effort, initiated by BirdLife International and implemented by the National Audubon Society in the United States, to identify habitats that are critical to birds of conservation concern for breeding, migration, and in winter. Silver Sands State Park, along with the Charles Island Natural Area Preserve and adjacent Walnut Beach, is identified by Audubon as one of 54 Important Bird Areas in Connecticut. Charles Island supports one of the three largest heron and egret nesting colonies in the state and the Park provides critical foraging grounds for these state-listed wading birds. Additionally, the Park's coastal location and extensive marshes, grasslands, and shrub/scrub habitats make the area important to a wide variety of birds in the migration, winter and nesting seasons. It represents one of the largest remaining extents of coastal shrub/scrub habitat in the state and is a key nesting area for Brown Thrashers, a species of special concern in Connecticut. The Park also receives extensive usage by raptors in the winter and migration periods, including the state threatened Short-eared Owl and American Kestrel and the state endangered Long-eared Owl and Northern Harrier. The beach area represents historic and potential nesting habitat for the federally threatened Piping Plover and the offshore waters support a great variety and abundance of waterfowl in the non-nesting season.

In addition to the importance of the park for birds, this array of high quality habitats make it an important destination for birding and other wildlife associated recreational activities. A key area for these activities is the overflow parking area; known in the birding community as the "Sparrow Lanes". These areas are so productive that the Connecticut Ornithological Association often holds their annual sparrow identification workshop at the Park.

We fully understand that state parks must serve the needs of a wide variety of park users, but the value of the Park for bird-associated recreation and for migratory stopover habitat is a resource of statewide importance. Audubon strongly requests that the areas around the "Sparrow Lanes" continue to be managed in a manner that supports migrating and wintering sparrows and other landbirds. The juxtaposition of many habitats, from gravelly bare soil, to weedy turf, to low weeds and wildflowers, to shrubs and small trees in the dividers between the parking lanes provides optimal vertical structural diversity that supports large numbers and a great variety of birds in migration.

The loss of this habitat in the heavily developed landscape of coastal New Haven County will not only put additional stresses on migrating birds, but also sharply reduce the opportunities for bird-associated recreation in the state. The replacement of the existing substrate with reinforced turf may or may not adversely impact the functionality of this site, but the clearing of the dividing lanes and loss of vegetative structure will surely reduce or eliminate the value of this site as critical stopover habitat. If the parking improvements to this area are shown to be necessary, we recommend working through the Important Bird Areas Advisory Committee to explore alternative plans that retain some of the current habitat values of this area and mitigate the loss of habitats through habitat improvements in proximal areas of the park. For example, no mowing of the overflow lot after August would allow grasses to mature later in the season and go to seed in time to provide food for migrating sparrows.

In addition to these primary concerns, we also suggest that the proposed route of the new boardwalk be fully examined. Field inventory efforts to gauge impacts to state-listed plants and animals and those listed as being of "greatest conservation need" (GCN) in Connecticut's State Wildlife Action Plan, that may occur in the tidal marsh area where construction is proposed, should be completed. Potential impacts to forage species that are important to state listed and GCN species should be included within these studies. The route of the proposed boardwalk should be selected to minimize fragmentation of the marsh habitats and avoid sensitive natural resources. Mitigation for the construction of the new boardwalk should take into account a disturbance buffer around the boardwalk and any fragmentation effects of the boardwalk to the marsh; not just the footprint of the boardwalk itself.

We also have concerns that increased visitation at the park could have negative impacts to the Piping Plovers that have attempted to nest in the west end of the park, historical plover nesting areas in the eastern end of the park, and to the critical heron and egret rookeries on Charles Island. The Department needs to ensure adequate staffing levels or other measures to monitor and minimize the negative effects of human usage on sensitive nesting areas.

We also have concerns about the precedent created by approving a project based an Environmental Impact Evaluation (EIE) that was created in 1993 and is currently more than 20 years old. The field observations for that EIE appear to be inadequate having only been conducted in the October-November timeframe, which would not capture usage of the impacted areas of the park in the nesting season or much of spring or fall migration. Finally, we request that park improvement plans, such as these, be reviewed by the DEEP Wildlife Division staff to determine effects on Greatest Conservation Needs species early in the planning process and that any concerns raised by the Wildlife staff are taken into account in planning and/or mitigation proposed as part of the project.

Thank you again for the opportunity to comment on this important issue.


Corrie Folsom-O'Keefe, Important Bird Areas Program Coordinator


Patrick M. Comins
Director of Bird Conservation
President, Friends of the Silvio O. Conte National Fish and Wildlife Refuge

Audubon Connecticut
185 East Flat Hill Road
Southbury, CT 06488

Phone: (203)405-9115
Fax: (203)264-6332

pcomins at audubon.org<mailto:pcomins at audubon.org>
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