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

Comment EI-26990

Received or sent (printed as 10/19/2020)

NY?NJ Baykeeper comments on the Draft Supplementary Environmental Assessment issued in September 2020 NY/NJ Baykeeper has been a leading non-profit conservation organization that has tackled clean water, land preservation and green-infrastructure issues in communities of the NY/NJ Harbor region for over 30 years. We have partnered on more than three dozen land preservation and natural restoration projects in the region, totally more than 3,000 acres. This includes adding land to Laurel Hill Hudson County Park, the nationally recognized natural restoration of Hudson County’s Lincoln Park West, funding land acquisitions to create Jersey City’s Hackensack Riverfront Park. As the NY/NJ Baykeeper I have the pleasure of serving as Co-chair of the NewarkDIG Coalition (Doing Infrastructure Green) and the Vice Chair of the Meadowlands Conservation Trust. Our staff attorney, Michele Langa, serves as Co-Chair of the Passaic River Citizens Advisory Group. So, we are aware that investments into urban open space preservation, natural restoration, green infrastructure, public trails for hiking and low impact transportation are large and increasing significantly regionally and throughout the country. Nowhere is that more important than crowded urban neighborhoods, and Hudson is among the most densely populated counties in the nation. Finding existing open space or areas that could be retrofitted for these purposes in cities is extremely challenging because of intense competing land uses. Planners, elected officials, even engineers regularly lament the limited opportunities to preserve more natural lands in cities However, with creativity and strong public support, Communities near and far are finding creative way to green their urban neighborhoods. Nearby it was done in Bloomfield with a 17-acre Lions Gate Green Infrastructure Park, in several natural restorations in the Meadowlands, in Trenton’s Capital Park, and at a re-envisioned and restored landfill Camden. The Embankment, may be the best opportunity anywhere to expand this concept and practice, as it is an existing marvelous, ready-made structure and linear park in the heart of Jersey City and Hudson County that can provide myriad public benefits The Embankment Coalition vision for the Harsimus Branch and its Embankment takes advantage of a rare opportunity to use unique existing elevated urban open space that preserves thriving upland forest and a wildlife corridor that runs from the Hudson River to the Hackensack. The Harsimus stem Embankment as environed by the citizen-led Embankment Coalition provides more recreational and enjoyment of nature for people, more habitat for wildlife, rainwater capture and floodwater reduction while having the foresight to reserve a portion of the corridor for future light rail and low-impact transportation needs. Furthermore, the Coalition and has strong positive relationship with Jersey City, the community at large, and an extensive network of local, state and regional organizations who support these objectives. NY/NJ Baykeeper has commented on this project for well over a decade and has witnessed the public good that should be derived from this golden opportunity to transform the Embankment and rail line into a greenway has been thwarted by legal technicalities based on false assumptions proffered by Conrail representatives. It has happening again in this faulty DSEA that fails to acknowledge the adverse impacts that would result from authorizing an unconditional abandonment and fails to consider both the environmental impacts and the alternatives to mitigate them. Therefore, it fails to serve as an alternative to an Environmental Alternative or an Environmental Impact Statement. We applaud and support the strong comments of Jersey City’s legal team who have detailed and called out the attempt to circumvent the public’s right (by way of Jersey City) of first refusal by trying to pass a well-known easily documented rail line as a rail spur. The City also details the adverse impacts that should have been captured and presented in the DSEA. Underhanded tactics such as these are what understandably breeds public cynicism and a loss of faith in government agencies. Thank you for your consideration. Sincerely, Greg Remaud Baykeeper and CEO NY/NJ Baykeeper

Submitted by: Greg Remaud · NY/NJ Baykeeper · HAZLET, 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-26990 · back to the docket sheet