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ATLANTIC HIGHLANDS HERALD |
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Dear Reviewing Authorities, My concerns for the threatened and endangered species at Sandy Hook are numerous and voluminous. It is hereby requested that the following comments/ statements be included in all reviews, findings and duly recorded in official documents for the (Endangered Species management Plan " for Sandy hook, NJ. * The public was made aware of the initial "open house" for the aforementioned plan was via a press release issued from Superintendent Wells's office. The notice was insufficient in that it did not sufficiently disclose where information could be found on the 1992 "Plan" that needed to be to be revised to reflect current issues at Sandy Hook. * The Press Release stated that, " If you are unable to attend and would still like to share your ideas you can contact us via mail or email. Please send your comments to the Superintendent at the address below, or online at http://parkplanning.nps.gov no later than July 30, 2006," provides a link to the NPS website. As described in my attached letter to the Atlantic Highlands Herald. The quoted link does not provide any area for comment. Repeated searches performed on the referred to link resulted in no information on the Endangered Species Management Plan does not appear and/or the "open house." * Apparently, certain "interested parties" were mailed notices of the "public" meeting and comment period to their individual addresses. Since 2002, I have repeatedly submitted comments, statements and petitions to the NPS and Superintendent Wells' office regarding proposals, plans for Sandy Hook. Contained within these submissions I specifically asked to be included in notices, mailings and to be considered as a declared "interested party." I am personally aware of and have submitted letters/statements from others that also declared their interested party status. Most of these commenters were not mailed notices. I am aware of only one commentor that was actually mailed a notice to their address. The insufficient notification is unacceptable and certainly not representative of good faith and in the best interest of the public for a meeting held to seek public comment/participation. * It was determined by/concluded in the 2003 NPS Environmental Assessment that an additional and far reaching Environmental Impact Statement was not required. The EA was the topic of "public meetings" and a comment period was provided as well. Clearly, the Endangered Species Management Plan is a supplemental document that is trying to make up for the insufficiencies and omissions of the 2003 EA and to bring the EA into minimal compliance with NEPA mandates. Obviously, the "plan' now being undertaken not only clouds the conclusions of the 2003 EA but as well indicates that the conclusions were premature at best. * The 2003 EA cover page that appears online now states that it was revised in 2005. The 2005 revisions are not depicted, defined nor described. The public and "interested parties" are due explanations and another meeting for full disclosure to comment on the 2005 revisions. * A true and credible EA for the Endangered Species Management Plan must be in depth and not cursory. Soil borings, sand analysis, quality and quantity of runoff determinations from the pending commercial development at the north end of the Hook and the cumulative effects thereof should be factored in to any study and /or review of habitat, breeding, feeding and migratory data/conditions for the barrier island's many diversified species. "Oil and chemical spills in the bays and surrounding areas are still common; major spills in the Arthur Kill occurred in the early 1990s. Nutrients, organic matter, and suspended solids continue to enter the watershed from sewage treatment plants and other point and nonpoint sources." " Accidental releases of oil and other hazardous materials are a major threat in this area. Spills can occur during each mode of transportation and during product transfer. Severity of spill impacts is affected by numerous factors, such as type of oil product, behavior of the product on water, volume of the spill, weather conditions, time of year, and habitats impacted. Biological resources at risk include all stages of benthic organisms, the eggs, larvae, and juvenile stages of fish and shellfish, waterfowl, seabirds, shorebirds, beach strand plants, colonial waterbirds, marine mammals, and sea turtles. Nonpoint sources, less easily recognized, contribute up to half of all the oil-related pollution, and result from municipal and urban wastes, urban runoff, atmospheric deposition of incomplete combustion products from autos and trucks, unrecovered spent motor oils, leaks from offshore operations, and burned and unburned fuels and lubrication products from boating. This chronic low-level pollution has devastating and widely differing effects on fish, invertebrates, and algae, with the early life stages being most vulnerable." (SIGNIFICANT HABITATS AND HABITAT COMPLEXES OF THE NEW YORK BIGHT WATERSHED Raritan Bay - Sandy Hook Bay Complex). Oil Spills and Other Contaminants - Oil spills pose a threat to piping plovers throughout their life cycle. Oiled plovers have been reported from Breezy Point, New York; Sandy Hook and Mantoloking, New Jersey; Trustom Pond, Rhode Island; Horseneck Beach, Massachusetts; and Matagorda Island National Wildlife Refuge, Texas (USFWS files). Fourteen abandoned plover eggs from five New Jersey sites were analyzed for presence of organochlorine and heavy metal burdens in 1990 (USFWS 1991a). Although DDE, PCB's, and chlordane metabolites were detected in all samples, levels did not appear to threaten reproduction. Mercury concentrations ranged from 0.077 to 1.07 ppm wet weight; with the exception of 1.07 ppm wet weight mercury in eggs from Brick Township, New Jersey, mercury residues in that study appeared below those thought causative of avian reproductive anomalies. The NPS plan for private-for-profit commercial and office uses pending for the north end of the Hook will exacerbate the above referenced conditions associated with urban sprawl. * The uses for the "redevelopment" of the structures at the Fort Hancock have not been individually identified. This is problematic when attempting to judge the cumulative impacts from the proposed development ( particulary from infrastructure and traffic runoff). Yet, any research and conclusions must consider the maximum and not minimal effects to the ecological necessities for the survival of flora and fauna. The public that frequents Sandy Hook are the first hand witnesses to and the best objective parties to contribute to any analysis of the environment and it's inhabitants at the Hook. Their participation is critical to any/all definitive conclusions reached by an EA for the Management Plan for Endangered Species. In light of the insufficient notice, the misleading link to the NPS website that is absent of any material on the "plan" and "public meeting, an extension for the comment period is appropriate. Common sense and the fairness doctrine dictates that another public meeting that presents and provides access to the material that the public is asked to comment on is requisite. Please find included as attachments to this email, articles and emails that I respectfully request to be included in the official record and comment period for the Sandy Hook "Endangered Management Plan." Once again, I remind the reviewing authorities and their retained contractors that I am a declared interested party. As such please forward all notices of meetings, comment periods and any/all plans that the public is "permitted" to participate in. Respectfully, Carole Balmer  |
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