Hudson River Park Project letter

JERSEY COAST ANGLERS ASSOCIATION / NEW JERSEY FEDERATION OF SPORTSMEN’S CLUBS

Honorable Joseph W. Westphal
Assistant Secretary of the Army for Civil Works
The Pentagon, Room 108
Washington, D.C. 20310-0108

Dear Assistant Secretary Westphal:

The JCAA and NJSFSC with its 150,000 members are writing to you today about a major threat to the marine fish of the Atlantic coast, to the recreation of literally millions of anglers, and the thousands of businesses that are dependent upon a healthy fishery resource along this coast alone. We believe that the proposed Hudson River Park Project could have a severe effect on the wellbeing of the lower Hudson River. This estuary, and the Hudson River Park project area in particular, is a primary nursery area (as well as a spawning area, feeding area and migratory pathway) for a majority of the coastal marine fish species that migrate along the U.S. East Coast. It is important to striped bass, winter flounder, summer flounder (fluke), bluefish, weakfish, black sea bass, sand tiger shark, sandbar shark, shortnose sturgeon, Atlantic sturgeon, menhaden, American eel, American shad, and alewife.

It is known that 25 percent of the Atlantic coast population of striped bass is produced by the Hudson River, and the interpier area of this proposed "Park" project is the most important over-wintering area for them in the lower Hudson estuary. The National Marine Fisheries Service concluded that this specific interpier area was "essential" to this stock's survival, which was the reason the "Westway" project was terminated in the mid-1980s. The Hudson River Park Project will affect a much larger portion of the same interpier area as would the Westway project. Recently, the lower Hudson River has been designated "essential fish habitat" for 15 species managed by the federal government.

The project area extends 5 miles along the west side of lower Manhattan and out to the pierhead line (about 1,000 ft) and covers 550 acres. Pollution and shading from the re-construction of over a dozen very large piers and placing an unspecified but potentially large number of "floating structures" between the 39 existing piers could have significant adverse effects on this important habitat. Accordingly, the proposed Hudson River Park Project may involve the potential loss of much of 490 acres of "essential fish habitat" affecting many Atlantic coast species.

We believe that all adverse effects of the full project must be thoroughly evaluated and all reasonable alternatives that might result in less damaging environmental effects must be considered before such a large and potentially damaging project is given federal approval. Therefore, we request that a federal Environmental Impact Statement be prepared for this project before any federal permits are issued.

Thomas P. Fote