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AB 167 (Sub-No. 1189X) · CONSOLIDATED RAIL CORPORATION--ABANDONMENT EXEMPTION--IN HUDSON COUNTY, N.J.

Comment EI-17551

Received or sent (printed as 4/30/2009)

To Whom It May Concern: As a resident of Jersey City, and a professional involved in the Land Use Development field it is somewhat appalling to see the lack of in depth information provided in the Environmental Assessment (EA) performed for the abandonment of the Harsimus Branch Embankment. I understand per the regulations at 49 CFR 1105 that a full Environmental Impact Statement (EIS) may not legally be required, however this does not subvert the fact that the EA performed for the site is wholly inadequate. The argument that the demolition of the embankment is not part of the abandonment progress, and as such not subject to the review requirements is shameful. The Embankment was constructed by Conrail and as such is Conrail’s property. The effects of the demolition of the structures need to be included in this assessment to fully understand the implications involved in the abandonment process. The demolition is a secondary or cumulative impact of this process and is not addressed in the least in this report, issues which are required to be addressed per the regulations. I expect to see a revised EA or an EIS which covers these impacts which should include but not be limited to discussion regarding the following topics: The project is located within an extremely busy downtown area which a high degree of pedestrian, bicycle, and vehicular traffic. The demolition of the structure will require a large amount of construction equipment with continual entry and egress from the properties. As such, a detailed traffic analysis/assessment needs to be performed to characterize the degree of impact to the area and assess if these impacts preclude the construction of the project or require mitigation. The structures currently provide pervious surface which provides stormwater infiltration. If demolished the structures will no longer provide such infiltration and may have flooding impacts upon neighboring properties. An assessment should be performed to characterize these impacts and assure proper mitigation and compensation is made. It may also be necessary to assess the project with regard to the New Jersey Departement of Environemental Protection’s Stormwater Management Rules at N.J.A.C. 7:8, as well as the Flood Hazard Area Control Act Rules at N.J.A.C. 7:13. Thank you for your attention to these matters and the many others raised by concerned citizens and organizations. I hope the public has made you consider the imprint of your actions upon the community and cumulative effects which will result.

Submitted by: Kate Landman · Jersey City, NJ

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-17551 · back to the docket sheet