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Subway Cars for Artificial Reefs
(from Jersey Coast Anglers Association January 2001 Newsletter)
It seems that the NJ Division of Fish
and Wildlife, the NY Transit Authority and other agencies are planning to deploy 1200
obsolete NY City subway cars on ocean reef sites along NJ and NY. JCAA has always been a strong supporter of the
artificial reef program. The stocks of cod,
whiting, and scup are severely depleted. In
addition, the regulations on summer flounder, tautog and bluefin tuna certainly limit our
catch. More recreational boaters have come to
rely on the species that inhabit the reefs and wrecks to provide food for the table. The creation of additional artificial reefs
continues to be important to the billion dollar recreational industry. A recent critical article in the Asbury Park Press
and a letter authored by Clean Ocean Action and the American Littoral Society threaten the
completion of this project.
JCAA has always been involved with and supported the creation of artificial reefs. Many of our member clubs are members and
supporters of the artificial reef program. They
run tournaments and raffles to support this program.
Every recreational fisherman contributes to this program through the excise
tax on recreational tackle through the Wallop Breaux Fund.
In a spectacular breakdown of communication, JCAA was never invited to the hearings
on this project or informed about the proposal. The
NJ Division of Fish and Wildlife should know better.
To further compound the problem, Clean Ocean Action and the American Littoral
Society wrote a letter questioning this proposal without discussing their action with
JCAA. I have included their original letter
below along with Cindy's response to JCAA. I
have also included my original email response to the Asbury Park article.
I will speak with the NJ Division of Fish and Game further to make sure they know how disappointed we are to have been left out of the decision-making process. I have already received a letter from Derry Bennett in response to my email and have spoken directly with Cindy Zipf. They are both aware of our dismay attheir lack of communication prior to the release of their letter and have apologized for their oversight. We have agreed to discuss this further and attempt to resolve our differences in this matter. Whether we agree or not, we need to communicate better around these issues. We do need to develop clear criteria for the materials used for artificial reefs and plan a workshop to develop the criteria.
We need to support this present project. NY Transit has committed to cleaning and
paying for the placement of these subway cars. We have been assured they will meet
stringent standards and not cause any pollution of the ocean. In their letter, Clean
Ocean Action and the American Littoral Society suggest recycling these cars.Many of the
recycling projects for this type of material do not require the same level of cleanliness
guaranteed under the artificial reef program and the recycling itself can contaminate the
air. On the same day the article appeared in the Asbury Park Press I was at a meeting of
the Governor's Task Force to Reduce Mercury Contamination in Fish. We discussed the
problems inherent in metal recycling incinerators in New Jersey. These incinerators are
releasing pollutants that include mercury into the atmosphere that eventually wind up in
the water.
Do you support
expanded artificial reefs? Do you think it is a good idea to use these subway cars to
provide additional reefs? If your answer is yes, you must write to David N. Ross, Chief
Operations Officer, Material Division, NY City Transit, 130 Livingston Street, Brooklyn,
NY 11201 to express your support for this project.
JCAA & NJSFSC LETTER
Jersey Coast anglers Association
Working For the Saltwater Resource and Marine Anglers
New Jersey Federation Of
Sportsmen’s Clubs
Working For The 150,000 Sportspersons Of New Jersey
Sunday, December 17, 2000
Clean Ocean Action &American
Littoral Society
Subject Artificial Reef Program
Dear Cindy and Derry,
I received many calls
in the last couple of days concerning your comments on subway cars. I was asked if Clean
Ocean Action and the American Littoral Society discussed their position with me, JCAA or
New Jersey State Federation of Sportsmen Clubs (NJSFSC). I was asked if Derry or Cindy had
given me a call on this issue. I had to say no and that upset a lot of my board members
and member clubs. I told them that Cindy and I had actually talked in the beginning of the
week and this was never mentioned. Remember I invited Cindy to come to the JCAA Meeting
because Congressman Pallone was going to be there. I asked Cindy if there was anything
new. The subway cars issue was not mentioned. I would have gladly responded to concerns
you have about this program. I could have discussed these issues with our members at the
JCAA meeting on Tuesday evening.
The Artificial Reef
Program is very important to JCAA, NJSFSC and many of our member clubs. Many of our member
clubs make donations and are members of the program. This program has replaced habitat and
structure destroyed by the constant dragging of the ocean bottom by commercial fishing. It has also created structure where there has been
none before and has increased fish populations. All
you have to do is go out on the water and you will see the opportunities that artificial
reefs have provided to the recreational angler. Thousands
of anglers are bringing home food for the table and enjoying this recreational activity
because of artificial reefs. It has also
increased the diving experience of many of our members by creating new opportunities and
taking some of the pressure of the wrecks. In
addition, tremendous economic value to the recreational fishing industry has been created.
If you were going to do a release opposing this, we deserved a phone call. That is the way partnerships work. If the JCAA and NJSFSC were going to come out with a press release that would impact the positions of Clean Ocean Action and the American Littoral Society, we would have given you a phone call and let you know what to expect. We would not have blindsided you. We would have given your organizations the opportunity to discuss this position with us before we made a decision. Again that is common courtesy among groups that work together as partners. We are used to some groups doing this. But we though we had a close relationship with Clean Ocean Action and the American Littoral Society and we expect more.
It is not so much that
Clean Ocean Action and the American Littoral Society came out against this project but you
did it without discussing this with us. When things like this happen this puts serious
strains on relationships and can change them.
Sincerely,
Thomas P. Fote
Legislative Chairman JCAA & NJSFSC
ALS & COA
Letter to NY City Transit
November 20, 2000
David N. Ross
Chief Operations Officer
Material Division NY City Transit
130 Livingston Street
Brooklyn, NY 11021
Dear David,
Thank you for the invitation to comment on the proposal to place 1300 subway cars in the ocean to create "artificial reef material."We also want to thank you for the packet of information from the meeting November 2, 2000. Please note that the packet includes a list of Meeting Attendees; as you are aware, neither of us were able to make the meeting and your list should be amended to reflect that fact.
Since you asked, we wanted to provide you with our thoughts about the proposed project of dumping 1300 obsolete subway cars into the ocean as "artificial reef material." Reef material is intended to mimic natural marine reefs and wrecks.The natural rocky reefs off the Jersey Shore are geologic systems lasting for eons and iron shipwrecks remain for hundreds of years.
One of the critical questions is how long should artificial reef material last to mimic natural reef materials and establish and support biological diversity and communities?One example is the Army Corps of Engineers determined that a reef in Delaware Bay should last a minimum of 30 years but clearly even 30 years doesn't begin to mimic the natural systems.
It has been estimated that subway cars may last 10 - 15 years. The subway cars have not been proven to provide long-term, sustained environment for biological ecological systems. In less than 20 years or so, the subway cars will leave basically corroding detritus or more litter in the marine environment.
The benefits of the disposal of these materials as reef material are not convincing. It is our view that this disposal plan boarders more on an ocean dumping activity and not the creation of habitat to sustain a marine biological community. This proposal may start a pattern of conveniently dumping anything that is inconvenient to recycle or manage upland.
Natural resources contained in these subway cars should be recycled even if it costs more in the short term. Dumping these materials at sea will destroy their availability in a world with even dwindling natural resources, including metals. Over the long haul, it is better to conserve and reserve these materials for future use.
A genuine biologically defensible standard should be established for materials creating artificial reefs that mimic natural systems and prove to provide sustainable biological ecosystems of importance to the ocean.
Sincerely,
D.W. Bennett
Executive Director American Littoral Society
Cindy Zipf
Executive Director Clean Ocean Action