LRWP response to Draft RP/EA for American Cyanamid Co. Superfund Site

The LRWP has submitted the following letter in response to NOAA’s Invitation to Public Comment on their “Restoration Plan/ Environmental Assessment Draft (RP/EA) for the American Cyanamid Co. Superfund Site, Bridgewater Township, Somerset County, New Jersey”:

May 23, 2016

Carl Alderson
NOAA Restoration Center – Sandy Hook Office
JJ Howard National Marine Fisheries Science Center
74 Magruder Rd, Highlands, NJ 07732

RE: American Cyanamid Draft RP/EA

Dear Mr. Alderson –

The Lower Raritan Watershed Partnership has reviewed NOAA’s proposed Restoration Plan/ Environmental Assessment (RP/EA) for the American Cyanamid Co. Superfund Site, Bridgewater Township, Somerset County, New Jersey and fully supports the proposal for primary and compensatory restoration activities.

The LRWP is New Jersey’s newest watershed association, formed in 2014 to address legacy contamination and current pollution in the Raritan River and the Lower Raritan Watershed. Our mission is to conserve, enhance and restore the natural resources of the New Jersey Watershed Management Area 9, the Lower Raritan Watershed. We believe that not only will removal of the Weston Mill Dam on the Millstone River directly improve resources impacted by legacy contamination, it is our understanding that the proposed project will benefit a broad spectrum of the Raritan River’s ecology and will likewise enable other environmental and human use benefits. Significant ecological, environmental and human use benefits have in fact already been realized following recent removal of a series of dams (Robert Street, Nevius Street and Calco) on the lower portion of the Raritan River between the towns of Bridgewater and Bound Brook. Likewise, we expect that design of technical fish passage at the Island Farm Weir (located on the Raritan River) will advance multiple Lower Raritan Watershed stakeholder goals.

The LRWP is also aware that the removal of the Weston Mill Dam on the Millstone River, as well as future modifications at the Island Farm Weir to include a technical fish passage at the Island Farm Weir on the Raritan River, will expand access to several thousand acres of non-tidal freshwater mid to upper reaches of the Raritan River’s major tributaries. Removal of Weston Mill Dam and the construction of a technical fish passage at Island Farm Weir will significantly enhance maturation and rearing habitat for striped bass, American shad, American eel, blueback herring, and alewife, and should significantly increase the abundance of anadromous and catadromous species, which will improve the ecological health of the Raritan River.

The LRWP’s only concerns with NOAA’s proposal are short term sediment transport impacts following dam removal. However, we are confident that NOAA’s plan to reduce potential environmental consequences is sound and further expect that the proposed projects will provide long term restorative benefits to water chemistry, specifically decreased water temperatures in formerly impounded sections, and increased dissolved oxygen concentrations. These changes will benefit riverine biota from the most basic food chain level up to the top predators for many years to come.

Enhancing fish populations in the Raritan River system is important for fresh and marine ecosystems. It is especially appropriate as the National Marine Fisheries Service (NMFS) lists the estuarine portion of the Raritan River as an important migratory pathway for anadromous alewife and blueback herring, species which NOAA lists as of special concern. The Lower Raritan Watershed Partnership feels that the proposed projects could help to reverse declining population trends, and anadromous fish returning to spawn each spring in the Raritan River provide an attraction to the general public in the Raritan River Basin. The removal of the Weston Mill Dam on the Millstone River and feasibility analysis and design of technical fish passage at the Island Farm Weir are important to the LRWP and we fully support the proposed projects.

Sincerely,

Heather Fenyk, Ph.D., AICP/PP
President, Lower Raritan Watershed Partnership
www.lowerraritanwatershed.org

The National Oceanic and Atmospheric Administration, the Department of Interior, and the State of New Jersey invite public comment on a proposed plan.
The Draft RP/EA is available at the following website:

http://darrp.noaa.gov/hazardous-waste/american-cyanamid

The public comment period on this plan ends June 10, 2016.

To request further information or an additional hard copy of this document or to submit your comments, please contact Carl Alderson at (732)371-0848, NOAA Restoration Center – Sandy Hook Office, JJ Howard National Marine Fisheries Science Center, 74 Magruder Rd, Highlands, NJ 07732 or by email at Carl.Alderson@noaa.gov. Please put “American Cyanamid Draft RP/EA” in the subject line.

2 Comments On “LRWP response to Draft RP/EA for American Cyanamid Co. Superfund Site”

  1. Why not propose to remove the Island Farm weir too? It’s not natural and it was put into our waterway before we had serious flooding problems in Manville. I’m hopeful there’s new technology to allow the water company to source its daily water needs without artificially raising both rivers by over one foot. Why debate its effects? Just remove it and look for an alternative solution. Thank you.

    Reply

    • Thanks, Richard, for your reasoned comment. You are right, from an ecological standpoint it makes abundant sense for NOAA to develop a study on the impacts of Island Farm Weir removal. The proposed fish ladder feasibility analysis should not be the only option presented. Please consider submitting a letter to NOAA with that suggestion – the deadline for comments is June 10.

      Reply

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