Comment EI-26986
Received or sent (printed as 10/18/2020)
Re: Draft Supplementary Environmental Assessment Issued in September 2020. I am a resident of Jersey City Heights. For several years I have been working to ensure that community voices are represented in the CSO Long Term Control Plans required by The New Jersey Department of Environmental Protection to comply with the federal Clean Water Act. Cities must adopt plans to address stormwater issues and combined sewer outflows (CSOs) that contaminate waterways. Like other cities in the state and nation, Jersey City has an antiquated system of combined storm water and wastewater sewers that allow pollutants like motor oil, trash, animal waste, and raw sewage to flow into basements, streets, and rivers when storm water exceeds the handling capacity of the system. The City and region will be spending billions of dollars to address this issue through increasing sewer capacity, retention facilities, and green infrastructure. Local taxpayers will be picking up most of the cost. The Harsimus Branch Embankment is an example of already existing green infrastructure that serves the community in stormwater control. The Embankment is a massive stone and earthen structure that runs through a flood plain. A forest has grown up on its top. The trees and other vegetation there break up heavy rain, and the structure’s fill absorbs it and slowly releases excess water into the City’s overburdened combined sewer system over a period of days or weeks. Multiple development proposals have been made by the developer to whom Conrail unlawfully sold Embankment property, and both Conrail and the developer applied for demolition permits. There is a strong likelihood that some development proposal will move forward in the event of an unconditioned abandonment. Yet the DSEA does not provide relevant information about this to the decision-makers, as required to do by NEPA. If the Embankment is demolished, the rainwater now soaked up by the Embankment would instead flow directly into the overburdened combined sewer system, with even more local flooding and combined sewer outflows (CSOs) requiring abatement. On top of that, any redevelopment of the open space will result in more impermeable lot coverage with even greater adverse stormwater effects on the community. A major sewer line adjacent and parallel to the Branch directs water along Sixth Street and its extension to the end of Thomas Gangemi Drive on the Hudson. The impact of Embankment demolition and the removal and transport of tons of earth and stone by heavy equipment on this system has not been analyzed nor even mentioned in the DSEA. The DSEA should recognize the adverse effects of demolition, quantify the stormwater or contaminants that would be released, describe the deleterious effects on human health and well-being, and calculate the cost to the taxpayer of addressing these issues. That the cost may be incalculable is no reason not to describe the reasonable and foreseeable impacts for decisionmakers. Sincerely, Moriah Kinberg
Submitted by: moriah kinberg · Jersey City, New Jersey
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-26986 · back to the docket sheet