All the Opinion That's Fit to Print

Earlier this week, in the aftermath of the first meeting of the Conservation Advisory Council and the run-up to the Common Council's expected vote on Tuesday on the resolution that would declare the proposed sewer separation project a Type II action, members of the South Bay Task Force composed a letter to the editor, expecting it would be published in the Register-Star. When they submitted the letter to our hometown newspaper, the letter was rejected, and the writers were informed that "our policy is to run one letter a month from an individual and we ran one from you not that long ago."

Gossips has no such policy to limit discussion and communication about important issues. What follows is the letter that the Register-Star would not publish.

To the Editor:

The citizens of Hudson were deprived of a unique chance to slow down a runaway train last week when Common Council President Don Moore advised members of the Conservation Advisory Council (CAC), at their very first meeting, to "not take a position" on the $600,000 Storm Sewer Separation Plan.

Even though bringing clarity to the City's deliberations about the State Environmental Quality Review Act doesn't require anyone to take a position, Mr. Moore's message was clear--and discomfiting. He seemed to suggest that this huge project, which will ultimately send hundreds of millions of gallons of streetwater runoff directly into the North Bay, needs no environmental review.

The Common Council will take up the question again at its June 16 meeting, and it's not too late to avert an environmental tragedy. We hope the Council considers the following significant facts before the Tuesday vote on final approval for a project which will significantly impact a valuable waterfront resource for generations to come:

First, the City hastily submitted an application for a federal grant last June which it never shared with the public. In fact, the details were unknown to residents until after the grant was awarded in December.

Second, in submitting its grant request the City ignored a comprehensive 1984 study which proposed a stormwater management facility to handle the City's separated runoff. That proposal, found in the 1984 Combined Sewer Overflow Study, was specifically designed to mitigate the adverse environmental impacts of runoff into the North Bay.

In fact, in a petition presented to the Council two months ago, 416 citizens reminded the Common Council what the State had required the City to commit to as a condition of approval for the 1984 study:

1.  A completed hydrology study;

2.  Water monitoring to determine the North Bay's "assimilative capacity"; and

3.  "A more conclusive analysis relative to the effects [on] fishing, fish spawning and nursery [and] wildlife."

Though the expected design life of the 1984 plan was only twenty years, its environmental impact requirements, updated and modified in 2008, remain significant. Because the City failed these obligations, today nothing is known about the North Bay's flushing capacity or water quality, although its significance as a fish nursery and a National Audubon Important Bird Area is better appreciated.

Not only have none of the State's monitoring requirements been addressed, but the City's Long-Term Control Plan--the federally required comprehensive management plan for combined sewer systems--asserts, erroneously, that the City "does not contain any habitats for known or Endangered species" [sic].

Third, the effect of the City's failure to consider the environmental impacts of the proposed project means a giant step backwards in our decades-long waterfront cleanup efforts (and the possible derailing of the current plan's more laudable components). When completed, the new system will dump at least 240 million gallons of untreated streetwater runoff into the North Bay each year, threatening the habitat of the Shortnose Sturgeon (Federally Endangered) and the Least Bittern (NYS Threatened), as well as numerous other listed species of animals and plants. For comparison, the 2010 Deepwater Horizon disaster in the Gulf of Mexico spilled approximately 200 million gallons of oil into the Gulf.

Finally, by disregarding the express wishes of the Common Council at its April 21st meeting to seek expert guidance while completing the Environmental Assessment Form itself, Mr. Moore has unnecessarily delayed the project.

For reasons explained in our Register-Star Letter of May 29, Delaware Engineering had already failed to properly answer key questions in the EAF it had submitted to the Council in early May.

The Common Council still has time to do the right thing. The 11th hour rush to judgment is a manufactured crisis, especially in light of Mr. Moore's efforts to dissuade the CAC from providing any assistance, as if a properly conducted environmental review for an infrastructure project is not standard practice. It can still be done. And the City can then proceed to build a sewer separation plan that is appropriate for our growing and environmentally conscious City.

The letter was signed by the members of the South Bay Task Force: Jennifer Arenskjold, Patrick Doyle, Peter Meyer, Timothy O'Connor, and Christopher Reed.