An open letter to the United States Coast Guard and opposing the proposed Anchorage Grounds along the lower Hudson River, NY USCG-2016-0132

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.

The estuary contains more than 200 species of fish, over 500 species of birds and almost 1,000 species of other animals including reptiles and mammals. Many are considered threatened and a number are listed as endangered species.

The flora both within the river itself as well as the plants and trees along the shoreline represent over 1,000 species as well, some of which are also considered threatened.

New anchorage grounds and additional shipping traffic, even outside of the impact of an environmental disaster, will impact many of these species and their habitats. The building of the anchorages alone threatens damage to the riverbed not to mention the potential problems of ongoing usage and maintenance of the dock-sites can do to these delicate ecosystems. Additional traffic by these vessels chances introducing additional invasive species to the region undoing the delicate balance that was recently restored.

Again, there seems to be little dedicated in the proposal to understanding what the environmental impact would be on the ecosystems themselves and how to both protect these during construction and usage as well as offset the likely damages to the environment with other environmentally supportive projects.

Furthermore, the region includes 19 State Parks and Forests as well as over 50 county and town parks that are designated in some way to help protect the environment including Bear Mountain, Palisades Insterstate, Tallman Mounain-Piermong Marsh, Storm King Park, the Hudson Highlands, Mills Memorial, Tivoli Bays and others. These parks, and the entirety of the park system through these fourteen counties, furthermore provide a quality of life to the local residents and a tourist attraction that inspires visitors from around the world.

The financial cost of maintaining the parks falls on the local, State and Federal Government along with charity support by not-for-profits and, in some cases, dedicated park fees. The impact of the anchorages on these parks also doesn’t appear to be covered as it relates to either the ongoing use of the anchorages or the possible impact of an anchorage related disaster in either financial or environmental concerns.

Along these lines, anchorage grounds along the waterfront will devalue property values and harm residential well beings, reduce tourism and hurt local businesses that depend on the vistas as part of their pitch, and devalue the historic nature of the region.

Many of the River Towns have invested heavily in building up their waterfront communities. With the assistance of local residents, not-for-profits, county governments, the State of New York and the Federal Government spent trillions of dollars over the last few decades to support the growth of small businesses, residential areas, parkland and recreational spaces and the restoration of historic places along the Hudson River.

For example, $10 million has already been spent in developing on the Hudson River Walk through Westchester County and that doesn’t include the investment of the businesses and residences that abut the park and contribute to its appeal. In 2009 $38.8 million was used for the Walkway over the Hudson, the several million spent by Rockland County on it’s waterfront parks which helped spur local business and residential growth.

Furthermore, the millions of dollars and hours spent to preserve and promote the history, including the creation of the Hudson River Historic District would be lost as well. The pristine vistas that are captured by the ongoing work at Washington Irving’s House, the Lyndhurst, Kykut, Clermont Manor, Montgomery Place, Vanderbilt Hall and even West Point along the river’s edge would be lost to an industrial waterscape.

Because of these beautification projects many of these towns and the region as a whole has gone through a renaissance of sorts. The decisions that occur regarding the river will now impact millions of residents and thousands of businesses that have chosen this region to live and work specifically because of it’s natural beauty, history and current lifestyle.

In all these cases the aesthetics of the region would be compromised by the anchorages and the associated increase in traffic. The negative impact is not just on the vista like views, but in the smells and sounds associated as well as the visual aspects of what would happen to the region in the case of even a minor accident on the river as a result of the anchorages. The presence of these anchorages alone would devalue the investments spent on those projects and their adjoining towns. And, it’s not just the money already spent on these infrastructure projects including the riverwalks, waterfront parks, rail trails and more, it’s the money that will be lost by their being spoiled and how it will effect all of the river towns and cascade deeper into the counties and eroding the very nature of the Palisades, the lower Catskills and even into New York City and North Jersey as destinations not only for locals but for national and international tourists who specifically seek out the historic and picturesque nature of the region.

Again, in assessing the impact of the project there appears to be next-to-n documentation discussing the outcomes on local and regional economies as it relates to either the $4.7 billion regional tourism economy or the impact it will inevitably have on the viability of the local and regional resident’s quality of life and the nearly $6 billion dollar local economy that is supported by the diversity of the region’s residents.

Furthermore, there are a number industries that are linked directly to the Hudson River itself that would be impacted beyond tourism and local residential support including commercial fishing that will be competing for access to the river and likely negatively impacted by the presence of the anchorages and additional traffic.

The Hudson River is also the source of drinking water to more than 100,000 residents of the Mid Hudson Valley, including people living in Poughkeepsie, Highland, Port Ewen, Hyde Park and Rhinebeck. It’s also part of a larger aquatic ecosystem that also provides water directly or indirectly connected to the river for a large number of river side communities and to New York City.

There is no possible financial benefit that parking the barges could provide that would offset the money spent to this point to make the region viable. The money already spent in the region to create the current economic output it has serving the citizens and residents that support the region far outweighs whatever benefit that would primary come to non-local boat & barge operators so there’s absolutely no financial possibility that this is better for the region that retaining the current boat traffic liabilities on the river.

Furthermore, even with the additional local, State and Federal revenues this endeavor might produce, those profits would quickly be lost at the first ecological disaster to occur with the increased barge traffic since it’s more likely than not the local, State and Federal government would be responsible for the cleanup moreso than the negligent corporation that produced the disaster in the first place. It is impossible for the economic revenues to be more than what the cost of just the environmental clean up.

Beyond the economic and environmental impacts there’s also a major safety concern for the anchorages and the additional traffic they will support.

There are a litany of examples on the Hudson River alone of barges running around, into other watercraft, into river structures like bridges and even into the moorings themselves which create the possibility of not only an environmental disaster but a human one as well. It is indisputable that given the current conditions increasing the traffic simply increases the statistical probability that accidents will happen.

Furthermore, due to the nature of both the cargo and the region increased presence of these vessels, particularly unmanned and unguarded while mored, would make the region a richer target for both domestic and international terrorism

Both navigation accidents and terrorism have the potential to compromise the likes of major river crossings like George Washington Bridge, Tappan Zee Bridge, Bear Mountain Bridge, Newberg-Beacon Bridge, Mid-Hudson Bridge, Kingsland-Reincliff and shoreline infrastructure such as the Metro North rail lines, the CSX rail line, US-9/9W as well as other sensitive locations such as Indian Point, NYCR Power, the Westchester Rail Yards, West Point and even corporate interests like Kawasaki, the Sugar Refinery and even Bard College that are essentially directly on the river.

Time and money would be better spent improving on-river safety, security and upgrading the existing navigational limitations on the river rather than adding new potentially harmful situations to the river. Don’t be short sighted and turn the Hudson River into an industrial parking lot for a few quick dollars and waste the time, effort and energy that everyone has already spent reviving and revitalizing the river from the last industrial revolution it barely survived.