January 19, 2005
Dear Great Lakes Collaborative Colleague,
New York Rivers United (NYRU) is an active member in the Great Lakes Collaborative, a critical effort to restore the Great Lakes Basin. Working together with our friends and colleagues at American Rivers, we believe there is another joint effort that will help in achieving our mutual goals and objectives: The Citizens’ Agenda for Rivers. Many of you are aware of the Agenda and have already given your support; for others this is an introduction and a request for your support.
The Citizens’ Agenda is a proactive policy plan for rivers developed by a steering committee of river and watershed leaders over the last year. It delivers a simple message to all decision-makers: Americans demand clean water and healthy rivers, and we will hold our leaders accountable for doing their part. We believe this message is applicable to the Great Lakes Basin now more than ever.
More than 300 organizations, representing more than 3.6 million Americans, have already endorsed the Citizens’ Agenda for Rivers (view the list of endorsers at www.healthyrivers.org/Endorsements.html). But we are still short of our goal of 1,000 organizational endorsements. We hope to reach this goal in time to deliver the Citizens’ Agenda to the new Congress in late January or early February.
The Citizens’ Agenda identifies three issues representing the most acute threats to the largest number of rivers: eroding water quality, insufficient water flows for river health, and the impacts of sprawl and development. It then calls on decision makers at the local, state and federal levels to take specific policy actions to address each of these threats, such as calling on Congress to pass the Clean Water Authority Restoration Act and states to adopt ecologically based instream flow standards. (Read the full set of policy prescriptions at www.healthyrivers.org/read.html). The Citizens’ Agenda will be updated periodically to reflect changing threats and priorities.
The goals of the Citizens’ Agenda for Rivers, and the solutions it proscribes, are particularly appropriate for those of us concerned about the health of water resources in the Great Lakes Basin. The Citizens’ Agenda also sends a message to Great Lakes decision makers that we are part of larger, nationwide movement that will not rest until we have secured clean water and healthy rivers in all of our communities.
Please go to www.healthyrivers.org today and endorse the Citizens’ Agenda for Rivers. For more detailed information, and to learn about other opportunities to participate in this effort, please contact me (contact info below) or Matt Sicchio at American Rivers (msicchio@americanrivers.org, 202-347-7550).
Sincerely,
Bruce Carpenter
Executive Director
New York Rivers United
T: 315-339-2097
bruce_carpenter@newyorkriversunited.org
Friday, January 28, 2005
Tuesday, January 18, 2005
Action Alert -- Sewage Blending
RIVERS AT RISK
ACTION ALERT!!!!!!!
Dear New York River Conservation Colleague:
New York Rivers United, a leader in river conservation in New York State, needs your help. We need to alert you to an imminent threat to rivers, streams and public health. We ask for your help in mobilizing the river activists across the State to ACTION.
The Issue: Sewage Dumping
Last fall, the Environmental Protection Agency (EPA) proposed a "sewage blending" policy. This is not a Congressional action. Instead, it is a change in regulation. But this change could more accurately be called a "sewage dumping" policy. This change would allow sewage treatment plants to bypass an important treatment phase when it rains and mix partially treated waste with fully treated waste and dump that mixture into our rivers and streams. This policy poses a serious threat to human health and the environment. For more information on the policy including fact sheets, visit
http://www.americanrivers.org/sewagedumping.html
WHAT YOU CAN DO TO STOP SEWAGE DUMPING
1. Email or fax a letter to EPA Administrator urging him NOT to finalize EPA's sewage dumping policy. (See sample letter below.) Spread the word to your colleagues, volunteers, and members and ask them to send a letter to Administrator. Fax copies of your letters to your Senators and Congressmen. Or call your Congressional offices asking them to tell EPA to stop this policy. Please email us a copy of your letters. We will use them on our visits to Congressional staff in Washington and help educate them.
2. Contact your local reporters. Writing letters to the editor and contacting local media is a way to inform others of this issue. If you request we can provide sample materials. (bruce_carpenter@newyorkriversunited.org; (315 339-2097).
Citizens' Agenda for Rivers
New York Rivers United is a steering committee member in this effort. The effort to organize Stopping sewage dumping is a key plank in the Citizens' Agenda for Rivers. If you haven't yet endorsed the Citizens' Agenda, please sign-on at www.healthyrivers.org
We will be in touch with updates about this policy in the coming weeks. With your help, the river movement will be heard. Our health our rivers will continue to be protected Thank you.
Bruce Carpenter, Executive director
New York Rivers United
PO box 1460, Market St.
Rome NY 13442-1460
Sample letter to Leavitt
Administrator Leavitt
Environmental Protection Agency
101A
Ariel Rios Building
Mail Zone 101A
1200 Pennsylvania Avenue NW
Washington, D.C. 20460
Email: leavitt.michael@epa.gov
Fax: 202-501-1450
Dear Administrator Leavitt,
Please protect human health and the environment by withdrawing the proposed sewage blending policy and take steps to ensure that wastewater treatment plants are adequately treating all sewage.
The proposed blending policy would allow wastewater treatment facilities to bypass biological treatment methods during periods of heavy rain and snowmelt and pour the partially treated water back into America’s rivers and streams. This policy will not solve the current problems caused by sewer overflows. Instead, it will just give treatment plants the permission to continue environmentally detrimental practices.
Blending treated and untreated water dilutes the pollution but fails to remove deadly disease producing pathogens from the water. Bypassing the biological treatment phase allows bacteria, viruses and parasites to slip back into our waterways and cause illnesses such as respiratory infections, hepatitis, and dysentery. The EPA has found that a discharge of inadequately treated sewage spreads disease in U.S. waterways. Experts estimate that there are 7.1 million mild-to-moderate cases and 560,000 moderate-to-severe cases of infectious waterborne disease in the United States annually.
Blending also poses a huge threat to the environment, particularly to the health of rivers and streams. Allowing inadequately treated sewage to flow into our nation’s waters would cause long-term environmental damage; kill fish, close beaches, and destroy shellfish beds.
I urge you to protect human health and the environment by withdrawing the proposed blending policy and take steps to ensure full treatment of wastewater at all times.
Thank you for your consideration.
ACTION ALERT!!!!!!!
Dear New York River Conservation Colleague:
New York Rivers United, a leader in river conservation in New York State, needs your help. We need to alert you to an imminent threat to rivers, streams and public health. We ask for your help in mobilizing the river activists across the State to ACTION.
The Issue: Sewage Dumping
Last fall, the Environmental Protection Agency (EPA) proposed a "sewage blending" policy. This is not a Congressional action. Instead, it is a change in regulation. But this change could more accurately be called a "sewage dumping" policy. This change would allow sewage treatment plants to bypass an important treatment phase when it rains and mix partially treated waste with fully treated waste and dump that mixture into our rivers and streams. This policy poses a serious threat to human health and the environment. For more information on the policy including fact sheets, visit
http://www.americanrivers.org/sewagedumping.html
WHAT YOU CAN DO TO STOP SEWAGE DUMPING
1. Email or fax a letter to EPA Administrator urging him NOT to finalize EPA's sewage dumping policy. (See sample letter below.) Spread the word to your colleagues, volunteers, and members and ask them to send a letter to Administrator. Fax copies of your letters to your Senators and Congressmen. Or call your Congressional offices asking them to tell EPA to stop this policy. Please email us a copy of your letters. We will use them on our visits to Congressional staff in Washington and help educate them.
2. Contact your local reporters. Writing letters to the editor and contacting local media is a way to inform others of this issue. If you request we can provide sample materials. (bruce_carpenter@newyorkriversunited.org; (315 339-2097).
Citizens' Agenda for Rivers
New York Rivers United is a steering committee member in this effort. The effort to organize Stopping sewage dumping is a key plank in the Citizens' Agenda for Rivers. If you haven't yet endorsed the Citizens' Agenda, please sign-on at www.healthyrivers.org
We will be in touch with updates about this policy in the coming weeks. With your help, the river movement will be heard. Our health our rivers will continue to be protected Thank you.
Bruce Carpenter, Executive director
New York Rivers United
PO box 1460, Market St.
Rome NY 13442-1460
Sample letter to Leavitt
Administrator Leavitt
Environmental Protection Agency
101A
Ariel Rios Building
Mail Zone 101A
1200 Pennsylvania Avenue NW
Washington, D.C. 20460
Email: leavitt.michael@epa.gov
Fax: 202-501-1450
Dear Administrator Leavitt,
Please protect human health and the environment by withdrawing the proposed sewage blending policy and take steps to ensure that wastewater treatment plants are adequately treating all sewage.
The proposed blending policy would allow wastewater treatment facilities to bypass biological treatment methods during periods of heavy rain and snowmelt and pour the partially treated water back into America’s rivers and streams. This policy will not solve the current problems caused by sewer overflows. Instead, it will just give treatment plants the permission to continue environmentally detrimental practices.
Blending treated and untreated water dilutes the pollution but fails to remove deadly disease producing pathogens from the water. Bypassing the biological treatment phase allows bacteria, viruses and parasites to slip back into our waterways and cause illnesses such as respiratory infections, hepatitis, and dysentery. The EPA has found that a discharge of inadequately treated sewage spreads disease in U.S. waterways. Experts estimate that there are 7.1 million mild-to-moderate cases and 560,000 moderate-to-severe cases of infectious waterborne disease in the United States annually.
Blending also poses a huge threat to the environment, particularly to the health of rivers and streams. Allowing inadequately treated sewage to flow into our nation’s waters would cause long-term environmental damage; kill fish, close beaches, and destroy shellfish beds.
I urge you to protect human health and the environment by withdrawing the proposed blending policy and take steps to ensure full treatment of wastewater at all times.
Thank you for your consideration.
Friday, January 07, 2005
Hudson Action Opposed
January 06, 2005
Richard J. Polo, Jr.
Colonel, Corps of Engineers
District Engineer
New York District, CEN AN-PLE
26 Federal Plaza
New York, NY 10278-0090
RE: Draft Hudson River at Athens DEIS
Dear Ms. Hulkower:
New York Rivers United (NYRU) is a statewide river conservation organization. Our Mission is is to “conserve, protect and restore the rivers of New York State”. We have had great success on this endeavor and have expertise in identifying potential problems. The Hudson River is one of our State’s, our Nations greatest river resources.
We are writing to urge the U.S. Army Corps of Engineers to withdraw the proposal to remove 935,000 cubic yards of sediment to create a 300-foot wide, 6,000- foot long navigational channel to a depth of -24 feet Mean Low Water (MLW), in the vicinity of the Hudson City Light to the north dock at Union Street, Athens, New York.
It is clear based on the Draft Design Report & Draft Environmental Impact Statement that this project is neither economically nor environmentally justified.
Adequacy of Public Comment Period
Rivers are a public resource and have great importance to all. Every effort must be made to ensure the fullest public input. NYRU objects to the timing and adequacy of the Public Comment period for this project. It has been eight years since the Congressional action that precipitated this Study. It has been nearly three years since the Corps initiated a public outreach process for this project. Between then and now there has been no public information disseminated until the release of the DEIS and related documents in December 2004. And yet, the Public and interested Government Agencies are given a mere thirty days, spanning the year end holiday season, to review and comment on this significant, costly and complex proposal.
We specifically ask that:
∑ The Corps schedule a Public Hearing, and
∑ The Corps extend the Public Comment period for at least sixty days to allow all interested parties to properly review and comment.
The lack of sufficient time for Public Comment on this project is especially significant in view of the many serious economic, environmental and public policy questions raised by this proposal, as discussed below. NYRU is especially concerned with the environmental impacts of this project
Environmental Impacts
This project will result in a great number of significant environmental impacts. Significant and valuable fish and wildlife habitat exist in the waters adjacent to the Middle Ground Flats.
The most noteworthy project impact is to fish spawning habitat. As is stated in the Draft Design Report the project area is a “spawning area for several anadromous fish species including American shad (Alosa sapidissima), stripped bass (Morone saxatilis), herring (Alosa aestivalis), and the endangered shortnose sturgeon (Acipenser brevirostrum), as well as a variety of resident species.” (p. 5)
The DEIS points out that “Maintenance dredging of the Hudson navigation channel has also been considered a problem for the Hudson River shortnose sturgeon stock. In particular, hydraulic dredges can lethally harm sturgeon by entraining sturgeon in the dredge dragarms and impeller pumps.” (p. 21)
The U.S. Fish and Wildlife Service (USFWS) in its assessment of this proposal indicated, “The dredging has the potential to impact important spawning and nursery areas for the American shad, blueback herring, and alewife,” and that “There are also likely to be cumulative effects
associated with other proposed dredging projects in the vicinity of the project area considered.”
The USFWS also stated, “Dredging would change the substrate profile from a relatively flat bottom to a sloped condition with corresponding changes in current speed and pattern, which may keep eggs and fry suspended in the water column a for a longer period of time, thus increasing their vulnerability to predators.” (p. 12)
Economically Unjustified
The Corps states in the Draft Design Report that: “The net effect of these changes has produced a finding that the project is not economically justified at either the -24 ft MLW or the -26 ft. MLW depths.” (p. 12). There are several other references in the Draft Design Report and the DEIS indicating that this $30 million project does not make economic sense. The expenditure of $20 million of federal monies is unacceptable particularly in light of the fact that one company “Peckham Industries, Inc., would be the primary beneficiary of the deepening.” (p. 5) In addition, there is currently no local sponsor willing to pick up the $10 million balance neither for the project nor for operation and maintenance costs.
The Corps is given Congressional authorization that allows the deepening of the channel to –24 feet MLW. The barges that use this channel need “draw up to -26 feet when fully loaded.” The fact that the proposed project does not meet shipping needs is additional reason to withdraw this project.
The Corps Colonel Richard J. Polo, Jr., District Engineer states in the Design Report that
“I have determined that there is no feasible project that meets the Principles and Guidelines of the Water Resources Council. However, based upon authorizing legislation that has directed Federal interest in water resources improvements, the design phase will proceed for the navigation improvements at the Hudson River, Athens project, with such modification thereof as in the discretion of the Commander, HOUSACE, as may be advisable.”
Dredge Spoil Disposal
The Corps proposal to dispose of 935,000 CY of material on Houghtaling Island (an existing USACE-owned dredged material placement site) raises serious environmental concerns as well.
Historically, channel maintenance dredging has resulted in the filling of wetlands along the Hudson River. “The loss of wetlands has resulted in a reduction in the quantity of habitat available for emergent wetland – and/or mudflat-dependent wildlife such as waterfowl, shorebirds, and semiaquatic mammals such as muskrats (Ondatra zibethica) and mink (Mustela vison). Nursery and forage habitat for fish has also been lost.” (p. 6)
The USFWS assessment clearly indicated that the there will be detrimental impacts to species of concern such as the cerulean warbler. The cerulean warbler is considered a species of concern by the USFWS and a species of special concern by the NYSDEC. The USFWS indicated, “The proposed expansion of the active disposal site will result in the loss of mature forested upland and possibly isolated wetland habitat as the area is cleared and graded. Numerous forest bird and wildlife species, including the cerulean warbler, will lose habitat.” (p. 14) They also state “clearing and continued use of the proposed dredge disposal area will result in the direct loss of cerulean warbler habitat…” (p.10)
Cultural Resources
This project also has the potential to significantly impact cultural resources. Of the “31 vessels” discovered, “nine are eligible” to be placed on the National Register of Historic Places and “all are recommend for additional work…” (p. 6)
In addition “historic ice houses” have been discovered on Houghtaling Island and all three are eligible for placement on the National Register of Historic Places.
Contaminated sediment
Based on the DEIS “nine sediment samples were collected along the proposed channel alignment” (p. 8) to determine if the sediment are contaminated. The DEIS reports that “No hazardous, toxic, or radioactive waste (HRTW) levels were found.” (p. 16) and that the contamination ranged from “marginally impacted” to “suitable” for construction of wetlands and upland disposal. The DEIS does not, however include any of the data, or the methodology used to gather and analyze the data. The data collected should be provided as part of the DEIS.
The USFWS report indicated “sediments at the Athens Ferry Slip (outside the project alignment) were found to have higher concentrations of PCBs (3,230ppb) than the area proposed for dredging.
We would support the USFWS recommendation, “that the Corps accurately delineate the contaminated areas prior to construction, make these area known to project contractors, and isolate these areas form the work area. …”the Corps model the potential lateral movement of contaminants as well as the movement of sediments that may become exposed during side-slope sloughing and make appropriate modification…to avoid resuspension of contaminants.”
Material should be analyzed prior to use for “capping purposes in advance of creating wetlands.”
Current impacts on water quality
Part of the justification for this project is that current barge scouring is negatively impacting water quality in the area. The significance of the current barge scour problem and its impact on water quality should be clearly understood and ameliorated regardless of whether or not this dredging project goes forward.
Controlling resuspension
The DEIS is lacking in its discussion on how resuspension would be controlled during the dredging operation. Suspended solids may reduce photosynthesis and reduce dissolved oxygen “and result in fish and benthic mortality.”
If the project proceeds, engineering measures such as silt curtains should be used to minimize the movement of suspended solids.
Turbidity monitoring should be conducted during the dredging operation and if water quality problems arise the operation should cease and the problem corrected. In addition the long-term cumulative impacts of operation and maintenance dredging have not been fully explored and are in need of further assessment.
Thank you very mush for the opportunity to comment and we look forward to a response from our action. Should you wish to contact me, I can be reached at (315) 339-20097 or via e-mail mailto:bruce_carpenter@newyorkriversunited.org:
Sincerely,
Bruce Carpenter, Executive Director
Copy: Congressman John Sweeney
NYSDEC Commissioner Erin Crotty
Ms. Bonnie Hulkower, U.S. Army Corps of Engineers
Andrew Fahlund, American Rivers
Richard Roos-Collins, ESQ
Richard J. Polo, Jr.
Colonel, Corps of Engineers
District Engineer
New York District, CEN AN-PLE
26 Federal Plaza
New York, NY 10278-0090
RE: Draft Hudson River at Athens DEIS
Dear Ms. Hulkower:
New York Rivers United (NYRU) is a statewide river conservation organization. Our Mission is is to “conserve, protect and restore the rivers of New York State”. We have had great success on this endeavor and have expertise in identifying potential problems. The Hudson River is one of our State’s, our Nations greatest river resources.
We are writing to urge the U.S. Army Corps of Engineers to withdraw the proposal to remove 935,000 cubic yards of sediment to create a 300-foot wide, 6,000- foot long navigational channel to a depth of -24 feet Mean Low Water (MLW), in the vicinity of the Hudson City Light to the north dock at Union Street, Athens, New York.
It is clear based on the Draft Design Report & Draft Environmental Impact Statement that this project is neither economically nor environmentally justified.
Adequacy of Public Comment Period
Rivers are a public resource and have great importance to all. Every effort must be made to ensure the fullest public input. NYRU objects to the timing and adequacy of the Public Comment period for this project. It has been eight years since the Congressional action that precipitated this Study. It has been nearly three years since the Corps initiated a public outreach process for this project. Between then and now there has been no public information disseminated until the release of the DEIS and related documents in December 2004. And yet, the Public and interested Government Agencies are given a mere thirty days, spanning the year end holiday season, to review and comment on this significant, costly and complex proposal.
We specifically ask that:
∑ The Corps schedule a Public Hearing, and
∑ The Corps extend the Public Comment period for at least sixty days to allow all interested parties to properly review and comment.
The lack of sufficient time for Public Comment on this project is especially significant in view of the many serious economic, environmental and public policy questions raised by this proposal, as discussed below. NYRU is especially concerned with the environmental impacts of this project
Environmental Impacts
This project will result in a great number of significant environmental impacts. Significant and valuable fish and wildlife habitat exist in the waters adjacent to the Middle Ground Flats.
The most noteworthy project impact is to fish spawning habitat. As is stated in the Draft Design Report the project area is a “spawning area for several anadromous fish species including American shad (Alosa sapidissima), stripped bass (Morone saxatilis), herring (Alosa aestivalis), and the endangered shortnose sturgeon (Acipenser brevirostrum), as well as a variety of resident species.” (p. 5)
The DEIS points out that “Maintenance dredging of the Hudson navigation channel has also been considered a problem for the Hudson River shortnose sturgeon stock. In particular, hydraulic dredges can lethally harm sturgeon by entraining sturgeon in the dredge dragarms and impeller pumps.” (p. 21)
The U.S. Fish and Wildlife Service (USFWS) in its assessment of this proposal indicated, “The dredging has the potential to impact important spawning and nursery areas for the American shad, blueback herring, and alewife,” and that “There are also likely to be cumulative effects
associated with other proposed dredging projects in the vicinity of the project area considered.”
The USFWS also stated, “Dredging would change the substrate profile from a relatively flat bottom to a sloped condition with corresponding changes in current speed and pattern, which may keep eggs and fry suspended in the water column a for a longer period of time, thus increasing their vulnerability to predators.” (p. 12)
Economically Unjustified
The Corps states in the Draft Design Report that: “The net effect of these changes has produced a finding that the project is not economically justified at either the -24 ft MLW or the -26 ft. MLW depths.” (p. 12). There are several other references in the Draft Design Report and the DEIS indicating that this $30 million project does not make economic sense. The expenditure of $20 million of federal monies is unacceptable particularly in light of the fact that one company “Peckham Industries, Inc., would be the primary beneficiary of the deepening.” (p. 5) In addition, there is currently no local sponsor willing to pick up the $10 million balance neither for the project nor for operation and maintenance costs.
The Corps is given Congressional authorization that allows the deepening of the channel to –24 feet MLW. The barges that use this channel need “draw up to -26 feet when fully loaded.” The fact that the proposed project does not meet shipping needs is additional reason to withdraw this project.
The Corps Colonel Richard J. Polo, Jr., District Engineer states in the Design Report that
“I have determined that there is no feasible project that meets the Principles and Guidelines of the Water Resources Council. However, based upon authorizing legislation that has directed Federal interest in water resources improvements, the design phase will proceed for the navigation improvements at the Hudson River, Athens project, with such modification thereof as in the discretion of the Commander, HOUSACE, as may be advisable.”
Dredge Spoil Disposal
The Corps proposal to dispose of 935,000 CY of material on Houghtaling Island (an existing USACE-owned dredged material placement site) raises serious environmental concerns as well.
Historically, channel maintenance dredging has resulted in the filling of wetlands along the Hudson River. “The loss of wetlands has resulted in a reduction in the quantity of habitat available for emergent wetland – and/or mudflat-dependent wildlife such as waterfowl, shorebirds, and semiaquatic mammals such as muskrats (Ondatra zibethica) and mink (Mustela vison). Nursery and forage habitat for fish has also been lost.” (p. 6)
The USFWS assessment clearly indicated that the there will be detrimental impacts to species of concern such as the cerulean warbler. The cerulean warbler is considered a species of concern by the USFWS and a species of special concern by the NYSDEC. The USFWS indicated, “The proposed expansion of the active disposal site will result in the loss of mature forested upland and possibly isolated wetland habitat as the area is cleared and graded. Numerous forest bird and wildlife species, including the cerulean warbler, will lose habitat.” (p. 14) They also state “clearing and continued use of the proposed dredge disposal area will result in the direct loss of cerulean warbler habitat…” (p.10)
Cultural Resources
This project also has the potential to significantly impact cultural resources. Of the “31 vessels” discovered, “nine are eligible” to be placed on the National Register of Historic Places and “all are recommend for additional work…” (p. 6)
In addition “historic ice houses” have been discovered on Houghtaling Island and all three are eligible for placement on the National Register of Historic Places.
Contaminated sediment
Based on the DEIS “nine sediment samples were collected along the proposed channel alignment” (p. 8) to determine if the sediment are contaminated. The DEIS reports that “No hazardous, toxic, or radioactive waste (HRTW) levels were found.” (p. 16) and that the contamination ranged from “marginally impacted” to “suitable” for construction of wetlands and upland disposal. The DEIS does not, however include any of the data, or the methodology used to gather and analyze the data. The data collected should be provided as part of the DEIS.
The USFWS report indicated “sediments at the Athens Ferry Slip (outside the project alignment) were found to have higher concentrations of PCBs (3,230ppb) than the area proposed for dredging.
We would support the USFWS recommendation, “that the Corps accurately delineate the contaminated areas prior to construction, make these area known to project contractors, and isolate these areas form the work area. …”the Corps model the potential lateral movement of contaminants as well as the movement of sediments that may become exposed during side-slope sloughing and make appropriate modification…to avoid resuspension of contaminants.”
Material should be analyzed prior to use for “capping purposes in advance of creating wetlands.”
Current impacts on water quality
Part of the justification for this project is that current barge scouring is negatively impacting water quality in the area. The significance of the current barge scour problem and its impact on water quality should be clearly understood and ameliorated regardless of whether or not this dredging project goes forward.
Controlling resuspension
The DEIS is lacking in its discussion on how resuspension would be controlled during the dredging operation. Suspended solids may reduce photosynthesis and reduce dissolved oxygen “and result in fish and benthic mortality.”
If the project proceeds, engineering measures such as silt curtains should be used to minimize the movement of suspended solids.
Turbidity monitoring should be conducted during the dredging operation and if water quality problems arise the operation should cease and the problem corrected. In addition the long-term cumulative impacts of operation and maintenance dredging have not been fully explored and are in need of further assessment.
Thank you very mush for the opportunity to comment and we look forward to a response from our action. Should you wish to contact me, I can be reached at (315) 339-20097 or via e-mail mailto:bruce_carpenter@newyorkriversunited.org:
Sincerely,
Bruce Carpenter, Executive Director
Copy: Congressman John Sweeney
NYSDEC Commissioner Erin Crotty
Ms. Bonnie Hulkower, U.S. Army Corps of Engineers
Andrew Fahlund, American Rivers
Richard Roos-Collins, ESQ
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