Comment EI-17538
Received or sent (printed as 4/29/2009)
As president of the Harsimus Cove Association, the primary neighborhood organization representing residents of the National Historic District and other areas in Harsimus Cove, I strongly object to the inadequate Environmental Assessment (EA) issued by your Section of Environmental Analysis. The EA re-packages a Conrail story, and cannot be considered objective. Conrail's history of so-called City involvement in its illegal demolition activities is a case in point. It is common knowledge that the City was interested in protecting the safety of its citizens, who were threatened by Conrail's neglect of the structure and its bridges. In any event, any City actions to correct safety problems have no bearing on Conrail's abandonment action or inaction. Conrail continues to this day to not maintain its structures or the sidewalks along them. as property owners are obliged to do. We do not understand why the EA did not call for an Environmental Impact Statement (EIS). The 1998 Dresdner Robin report, which is only a preliminary environmental investigation, found antimony, arsenic, lead, and mercury and PAH levels in the soils of the Embankment that require the fill to be handled with appropriate engineering and institutional controls. We want further in-depth studies, and we want Conrail's partner to release results of soil samples it took at the site. Tons of contaminated soil cannot be removed and trucked through the streets of a major urban area without careful controls. The EA has not considered that the Embankment top has been providing habitat for migrating and local species of birds and butterflies in this otherwise built-out area. It says there is no evidence of threatened or endangered species - but then, no one has every studied the area to see if there are. There are certainly such species documented nearby - and bird and butterflies usually ignore No Trespassing" signs. The STB must not separate what it sees as the direct effect of abandonment (nothing) with what it sees as the indirect effects (demolition and reuse). The probable reuses of this site are heavily influenced by what happens at STB, and they must be further explored. The EA's bureaucratic evasion is not in the spirit of the National Environmental Protection Act (NEPA), under which federal agencies are to study direct and indirect effects, both immediate and cumulative, of their actions. I ask STB, on behalf of the thousands of residents in our neighborhood who will be affected by the outcome of this case, to authorize a full EIS. Eric Fleming Harsimus Cove Association, president"
Submitted by: Eric Fleming · Harsimus Cove Association
The Board publishes this comment in its environmental-comment table for this proceeding. It is quoted here as printed; nothing is inferred from it, and it states the commenter's own position in their own words, not this record's.
Permanent address docketyard.org/d/AB-167/sub/1189X/comment/EI-17538 · back to the docket sheet