Dear United States Coast Guard, a subordinate of the United States Department of Homeland Security,
Thank you for your service to the United States, particularly New York state, since The Revenue Cutter Service and the United States Life-Saving Service were merged to become the Coast Guard by 14 U.S.C. § 1 in 1915. Through wartime and in peace your work has proven invaluable to our safety and security and the sacrifices made by your members are an important aspect to the viability of the citizens of the country to this day.
However, at this time I cannot support your current endeavor which appears to serve a limited number of corporate interests over that of the greater good of the citizens of the states of New York and New Jersey. I strongly oppose the proposed Anchorage Grounds along the lower Hudson River, NY known as USCG-2016-0132.
Over the last several decades the US Federal Government through a number of different agencies, the States of New York and New Jersey, the counties of Bergen, Rockland, Putnam, Westchester, Orange, Sullivan, Ulster, Dutchess, Albany, Columbia, Greene, Rensselaer and the Bronx as well as the many riverside cities and towns, a large number of local, regional and national not-for-profits including Clearwater, NYNJTC, the Dyson, the National Audobaun Society and many, many others spent countless dollars over recent decades in clean up and restoration of the Hudson Valley.
Ecologically speaking, the work has taken portions of the Hudson River from Superfund status to where it is today in the early stages of recovery. It includes $460,000,000 and counting investment in General Electric cleanup, over $100,000,000 so far in Dow Chemicals clean up & at least $100,000,000 in Indian Point ongoing issues, as well as the undisclosed amounts spent on the General Motors and Allied Refining / Steam Refiners Sugar sites to name some of the larger projects outside of the regular restoration necessary to undo damage by industrial & corporate abuse including intentional dumping, accidental spills and general toxic runoff as well as municipal mismanagement of waste and runoff that routinely re-harms the river.
Allowing additional docking on the river reintroduces the potential for these burdens to the still recovering ecosystem again and chances spills and other accidents that would recontaminate the river undoing the vast money spent and years of work to restore the area.
Furthermore, since the majority of the barges are expected to be petroleum products one should apply the industry’s track record with safety, environmental impact and clean-up accountability to the regional expectations of such a project.
In the Hudson River region alone a few examples of industry negligence include: April 2016 Englewood Boat Basin spill; May 2016 the Germantown Boat Launch pipe leak; May 2015 Indian Point Energy Center’s Tomkins Cove fire related spill; as well as larger and more famous issues like the Kill Van Kull spill in 2012; Diamond Reef / New Hamburg in 2005; the Arthur Kill spill in 2003 and the 420,000-gallon 1977 spill at West Point. That’s not even discussing the environmental impact of disasters like the Exxon Valdese in Alaska, the 2014 Baton Rouge incident that closed 65 miles of the Mississippi River, the 2013 Vicksburg, Mississippi spill and so many more. In some cases as little as 30 gallons of crude was recovered from spills of over 30 thousand gallons. And, in all cases the overall cost of cleanup and restoration to the environment was shouldered heavily by the local citizens.
Within the current proposal there appears to be very little study of the environmental impact of what leaks, spills and other toxic runoff from these anchorages. Furthermore there doesn’t appear to be any accident mitigation plan for dealing with potential leaks and spills nor any type of clean up and recovery plan that would hold the docked vessel owner’s liable for the environmental impact costs. Although, even if these were available, it still likely wouldn’t be insurance enough against the likelihood of an environmental problem.
Cost aside, however, the Hudson River valley supports irreplaceable ecosystems. Each stretch of the river provides unique habitats—including 40 state-designated significant wildlife habitats—essential for fish, birds, animals and plants.