Comment EI-17679
Received or sent (printed as 5/7/2009)
As coordinator of the Embankment Preservation Coalition, I would like to point out that our organization has joined with the City and Rails to Trails in environmental comment filings that provide compelling legal arguments. This comment is intended only as a personal comment. It is anecdotal which I believe is at least as appropriate as Conrail’s anecdotal history of events, which has been accepted by the woefully inadequate Environmental Assessment. When I moved to Jersey City in 1978, my neighborhood was downtrodden. Many buildings were burned out or boarded up. The Harsimus Branch was still operating then, and continued to do so for more than a decade. The Branch and its elevated stone Embankment contributed to the blight of the area – not so much because of its function (after all, residences and freight had happily co-existed for many decades) but because of the railroad’s lack of maintenance. Dark trestles covered 100 feet at each intersecting avenue. Pigeons roosted under them, and lighting was nonexistent or broken. Sidewalk was missing along the 400-foot lengths of most Embankment blocks. Because uncared for, the site attracted garbage and graffiti. The City had to deal with safety issues caused by the private owner. It finally turned its attention to the Embankment, with an eye to alleviating blight along Sixth Street. By 1998, however, the area had already undergone change. Many individuals and small investors had seen beneath the grit and grime and started to reclaim these buildings one by one. City Administration perception of the area’s needs lagged a bit behind that of the individuals who had engaged in this reclamation. When the City undertook a redevelopment study, residents came together to study the site and after much consideration of its history, function, and aesthetic and environmental contributions, decided the Embankment should be retained and reused. The Embankment Preservation Coalition was formed, and proceeded to take the steps necessary to insure the site received the recognition it deserved. It was listed on the State Register in 1999 and declared eligible for the National Register in 2000. In 2003 the City of Jersey City recognized it as a Municipal Landmark. (It has since received additional recognitions: NY/NJ Harbor Estuary Priority Habitat Acquisition Site; Preservation NJ’s 10 Most Endangered Historic Sites; priority acquisition in Hudson County Master Plan; recommended segment of the East Coast Greenway; suitability for light rail and light freight in our City’s Master Plan.) All of the public uses envisioned for the Embankment are beneficial for our environment and compatible with with each other and with historic use. To the contrary, the private use proposed would degrade the environment, erase our history, and fragment and develop an assembled transportation corridor. When we first approached Conrail and the City about acquiring the property for reuse as historic site, open space, and trail, we were puzzled by Conrail’s seeming unwillingness to negotiate acquisition. Even more confounding, after we researched the status of the rail line, was Conrail’s failure (and later, the failure of the potential buyer) to acknowledge the rail line needed to be abandoned. Conrail’s failure to maintain its property had caused much harm to the community over the decades, making it especially difficult to understand why they would not try to give the community what it wanted, especially if the community was able to raise the money that Conrail was asking for the property. We indeed had helped the City raise $3.2 million and lined up additional contributors around the time Conrail sold the property for private development--for under $3 million. We took heart from our research, however, that the abandonment permit process would provide historic and environmental protections for the site. We were gratified that the STB agreed with our petiton and found that the Harsimus Branch had not been properly abandoned. We are now alarmed, however, that the inadequate Environmental Assessment may be signalling a failure of the agency to follow through logically on its abandonment finding. We go back to the provisions of NEPA and NHPA that encouraged us to pursue our preservation effort, and ask the STB to administer them in the spirit they were intended. NEPA states its purpose “To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation...” Our organization and thousands of individuals who have contributed to our efforts over eleven years have worked in the spirit of NEPA, even if not everyone knows what NEPA is. We are dependent on your administering NEPA in the spirit in which it was intended. Please authorize a full Environmental Impact Statement. Please keep the public trust.
Submitted by: Maureen Crowley · Embankment Preservation Coalition · 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-17679 · back to the docket sheet