Author: Heather Fenyk

Fire and Ice

Essay and photos by Joe Mish

The last full month of autumn, disguised as winter, covers this deer with an early blanket of snow.

The dried carpet of sliver maple leaves covering the lawn, was raked into a large pile, over several days, to prepare for cremation. Without conscious intent, the burning of autumn leaves took on the appearance of a sacrificial pyre, offered to some mischievous god to gain favor for the coming winter’s hunt.

The light gray smoke that rose from the smoldering pile of dried leaves magically turned into orange flame, which slowly consumed the sacrifice. Flames reduced the leaves to glowing embers, filling the air with the gentle scent of smoky incense, and finally to a layer of light gray ash, dispersed by a gust of November breeze.

November’s arrival is enlivened by lingering color, and departs with bare tree tops in its wake. During this period of transition, dramatic change takes place as the earth turns its glance away from the sun, to make it appear the stationary sun is traveling across the sky. As a result, the sun appears lower in the sky, day length and sunlight decrease and the earth begins to cool.

Myth suggests the earth’s lapse in attention to the bright star that holds our universe together, was a slight, deserving of immersion into deep cold and growing darkness. When the earth turns back to face the sun in the spring, all is forgiven, as light and warmth are restored to usher in a celebration of new life and hope.

If November were to be folded in half, fluorescent orange, oak leaves, would be layered upon the cold white snow, set against a slate gray background with bare, thin black tree branches forming a skeletal support structure upon which the compressed image of the month rests.

When the bright colors fade, the orange glow of funereal leaf pyres die, and the earth is left in darkness, eyes turn toward the heavens to gaze upon the bright stars and planets glowing against a black velvet lined display case. Countless billions of stars dot the heavens, clusters of stars taking on a milky appearance. Each star holding a portion of the faded daylight lost in the approach of winter. The stars give hope that the light is not lost after all, and with appropriate supplication directed to the heavens, it will soon be returned.

Staring at the night sky over time, patterns emerge and dots of light are connected to form the outline of mythical beings and animals referenced against the human experience. It then becomes apparent, the figures move across the sky, and appear only at certain times of the year.

November has its signature night sky, featuring impressive planetary choreography, meteor showers and animated constellations recognized by the earliest human inhabitants.

Planets, undifferentiated from stars at first glance make a featured appearance. Mars, Jupiter, Saturn, and Uranus take the stage at different times, in association with constellations, sunrise and sunset.

November fifteenth is the full beaver moon. Each full moon bears many aliases associated with events in nature. That link creates a primitive calendar, allowing a level of predictability required to enhance survival. The constellation, castor, appeared as a beaver to the paleo mind, and is used by taxonomists to derive the scientific name, ‘castor canadensis’, for the beaver. The impact of the impact of the stars on human creativity is timeless.

Meteor showers and falling stars, seen in the heavenly lit November sky, demand explanation. Strip away science, and let your imagination run wild with unrestrained conjecture to create a mythology that satisfies your primitive mind.

Any image of quintessential November is subjective at best and its many moods offer a variety of choices.

The first snow is usually delivered before November hands the last vestige of autumn over to December. The first, freshly minted white flakes are welcome emissaries who announce the intention of winter to arrive soon after. When the sky turns gray, the temperature drops near freezing, and flurries are forecast, all eyes are compelled by some innate siren call, to catch sight of their first snowflake. The stunning beauty and intricacy of each snowflake, appears to be the work of an ethereal entity and suggests the existence of a higher power. In some way, each unique flake is the blueprint for the infinite diversity of life and the appearance and personality of individuals within a species.

I clearly recall sitting around a large conference table in a room with two walls of outside windows, when snow was forecast for late afternoon. I kept watching for the first flake, which would easily stand in contrast against the dark wooded landscape. The anticipation was high, though the meeting ended without the expected precipitation. Odd that this event is cemented in my memory, though it may be a case where the intensity of expectation is such that the sight of a single snowflake would allow my escape from sterile environment in which I sat, it would, in essence, amount to a jailbreak for my soul.

Author Joe Mish has been running wild in New Jersey since childhood when he found ways to escape his mother’s watchful eyes. He continues to trek the swamps, rivers and thickets seeking to share, with the residents and visitors, all of the state’s natural beauty hidden within full view. To read more of his writing and view more of his gorgeous photographs visit Winter Bear Rising, his wordpress blog. Joe’s series “Nature on the Raritan, Hidden in Plain View” runs monthly as part of the LRWP “Voices of the Watershed” series. Writing and photos used with permission from the author.

Headgates Dam Removal Project

Somerset County has filed an application with the New Jersey Department of Environmental Protection for a minor diversion of Green Acres encumbered parkland in support of the proposed overall Headgates Dam Removal Project at Raritan River Mile 29.9, located in the Townships of Bridgewater and Hillsborough within Duke Island Park, Somerset County. The portion of the project that requires a diversion is the relocation of the existing Bridgewater Township 54-inch diameter sanitary sewer pipe. In order to meet the project need, it is necessary to divert a relatively small portion of the river and park property (subsurface), specifically 0.42 acres from encumbered parkland at Block 102, Lots 10 and 39 in the Township of Bridgewater and Block 48, Lot 10 in the Township of Hillsborough, Somerset County.

As compensation for the proposed diversion, Somerset County proposes to accept monetary compensation for the minor diversion which will be deposited into Somerset County’s Open Space Preservation Trust account to be utilized for future acquisition of land for recreation or conservation purposes. Pursuant to N.J.A.C. 7:36-26.6(c) a hearing to obtain public comment on this request will be held at: North Branch Park located at 355 Milltown Road, in Bridgewater Township, New Jersey on December 3rd at 6:00 PM.

Please see below a letter in support of this diversion, submitted to Somerset County by the Lower Raritan Watershed Partnership (LRWP).

November 17 / 2024

Thomas J. Boccino, PP, LLA / Supervising Planner – Preservation, Planning Division / Somerset County Department of Engineering and Planning / 20 Grove Street • P.O. Box 3000 / Somerville, NJ 08876-1262 / Boccino@co.somerset.nj.us

RE: Headgates Dam Removal Project

Dear Mr. Boccino —

The Lower Raritan Watershed Partnership (LRWP) is writing to express full support for the proposed minor diversion of Green Acres encumbered parkland to support the proposed overall Headgates Dam Removal Project at Raritan River Mile 29.9, located in the Townships of Bridgewater and Hillsborough within Duke Island Park, Somerset County. Our understanding is that the portion of the project that requires a diversion is the relocation of the existing Bridgewater Township 54-inch diameter sanitary sewer pipe.

The LRWP supports this diversion as an important step in meeting project needs, and furthermore understands that it is necessary to divert a relatively small portion of the river and park property (subsurface), specifically 0.42 acres from encumbered parkland at Block 102, Lots 10 and 39 in the Township of Bridgewater and Block 48, Lot 10 in the Township of Hillsborough, Somerset County. The LRWP believes that the overall project will significantly enhance habitat connectivity, improve water quality, and expand recreational opportunities for the Lower Raritan River and Watershed.

The LRWP 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. Specifically regarding the proposed interventions to replace and relocate of a section of the Bridgewater Township 54-inch sanitary sewer line, these activities will not only directly improve resources impacted by legacy contamination, but will benefit a broad spectrum of the Raritan River’s ecology and 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 the proposed restoration activities for the Headgates Dam Removal Project to advance multiple Lower Raritan Watershed stakeholder goals, namely expanding access to several thousand acres of non-tidal freshwater mid to upper reaches of the Raritan River’s major tributaries. More specifically, we expect that removal of Headgates Dam will 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.

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 LRWP feels that the proposed projects could help to reverse declining population trends, and anadromous fish returning to spawn each spring in the Raritan River.

Please do not hesitate to contact me if you have questions, or if you wish to discuss further.

Sincerely,

Heather Fenyk, Ph.D., AICP/PP

Board President, Lower Raritan Watershed Partnership

October 20 Green Brook litter trap litter tally

On Sunday October 20, LRWP Board Member Anton Getz, Litter Trap Coordinator Clare Levourne and a host of volunteers conducted a clean up at the Green Brook litter trap site, giving our new floodplain litter tally tool a trial run and documenting 3,279 pieces of trash(!!!). THANK YOU VOLUNTEERS!!

911 Day of Service, LRWP, SEWA International & Americorps

On September 14, in honor of 911, the LRWP supported @sewainternationalcentraljersey in their 911 Day of Service event. Focusing on activities for the SEWA high school youth, the LRWP hosted an open house at the Boat Shop with stations for rain barrel building & painting, boat building, and talks about stormwater management and stewardship. After our service “on land,” we then took everyone to Donaldson Park for a chance to get in canoes and kayaks to do water quality monitoring and a mini-cleanup by water. For many of the youth it was their first time paddling and their first time on the Raritan River.

Of course events like these can only be realized through great community effort. Gratitude to our amazing boat build team of Derek Hartwick, Nick Schmidt and Brian Smith, and our Water Quality Monitoring Coordinator Jocelyn Palomino. We are so grateful to the board members working behind the scenes to make this a successful event: Dini Checko, Missy Holzer, Amy Braunstein, David Tulloch, Alex Zakrewsky and Heather Fenyk. Huge thanks also to Rutgers Cooperative Extension Water Resources Chris Obropta for teaching us all about good stormwater management, to Raritan Riverkeeper Bill Schultz & Lorraine for keeping us safe on the water, to Highland Park Mayor Elsie Foster Dublin and HP Borough Council President Matt Hersh for reminding us of the impact of environmental stewardship at the local level, and to the Americorps volunteers everyone else who pitched in to support this special day of service and stewardship!!

NPS Thomas A. Edison Park decision update

Many of you followed the LRWP’s organizing against conversion of Thomas A. Edison Park from free public land to fee-based access. Just a note to share that the National Park Service concluded its review of Middlesex county’s proposed changes to Thomas Edison Park, and has adopted the environmental assessment prepared by Middlesex County contingent upon Middlesex County making changes to ensure the park remains available for public recreational use and that funds raised from new facilities are invested back into the park.

NJ PACT REAL Rules

As the driest calendar month on record stretches into November, as new terms like “flash drought” and “red flag warnings” enter our lexicon, and as wildfires emerge in unusual places, the LRWP urges the New Jersey Department of Environmental Protection (NJDEP) to protect our most vulnerable communities by adopting the NJPACT REAL rules. The adoption and implementation of these rules, short for “Protecting Against Climate Threats: Resilient Environments and Landscapes,” is especially and crucially important for heavily populated regions and Environmental Justice communities — like many Lower Raritan Watershed municipalities — located in proximity to Superfund toxic waste sites.

2019 US Government Accountability Office Report 20-73 identifies a total of 945 Superfund sites in the United States at special risk of disaster associated with wildfire, storm surge, flooding, and sea level rise. An incredible 24 of these sites (4% of the nation’s total at-risk Superfund sites) are within our 352-square mile Lower Raritan Watershed. Lower Raritan residents cannot escape these pollutant hazards: they are proximate to where we live and work. Without additional state-implemented resilient measures, wildfires and floods have the potential to bring toxins from these sites directly into our homes. More info on the GAO report, and a list of these sites, is on the LRWP website.

The NJDEP NJPACT REAL initiative is part of a broader commitment to safeguard New Jersey’s ecosystems, communities, and infrastructure in the face of climate threats, including sea-level rise, extreme storms, flooding, and heatwaves. The Watershed Institute has organized a petition to send to NJDEP in support of adopting the NJPACT REAL rules. The LRWP encourages you to join us in adding your name to the petition to show your commitment to a safer, more sustainable New Jersey.

More on the specifics of NJPACT REAL, its objectives, and the potential impacts on New Jersey’s communities, businesses, and natural environments, below:

Background of NJPACT REAL

New Jersey is particularly vulnerable to the effects of climate change due to its extensive coastline, urban density, and critical infrastructure in low-lying areas. In response, NJDEP launched the Protecting Against Climate Threats (NJPACT) program, with the REAL rules addressing land use, environmental resource management, and flood risk.

The NJPACT REAL rules aim to:

  1. Integrate climate resilience into land use planning.
  2. Update and enhance flood protection standards.
  3. Encourage sustainable growth while protecting natural resources.
  4. Build upon New Jersey’s Coastal Management Program to address sea-level rise and other coastal challenges.

By addressing both urban and natural landscapes, NJPACT REAL provides a comprehensive approach to creating climate-resilient communities. The rules were informed by extensive scientific research, including data from New Jersey’s Climate Change Resilience Strategy, which outlines statewide climate adaptation and resilience goals.

Key Components of NJPACT REAL Rules

1. Enhanced Flood Protection Standards

One of the primary focuses of NJPACT REAL is flood protection. Recognizing the increased frequency and intensity of rainfall, the REAL rules set stricter standards for floodplain development. These standards account for both current and projected flood risks, addressing scenarios in which intense storms could cause extensive flooding.

Key changes include:

  • Flood elevation standards: The NJPACT REAL rules require new development to account for higher base flood elevations, meaning that buildings must be constructed to withstand projected flood levels based on future climate models.
  • Flood-resistant building requirements: REAL mandates specific design criteria for new structures in flood-prone areas to mitigate damage.
  • Stormwater management upgrades: Enhanced stormwater regulations are aimed at reducing runoff, preventing erosion, and improving water quality, benefiting both the environment and the community.

2. Protecting Inland Wetlands

Wetlands provide crucial protection against storms, flooding, and erosion by acting as natural buffers. The NJPACT REAL rules emphasize the preservation and restoration of these landscapes, particularly in coastal regions that are susceptible to rising sea levels and erosion.

The rules encourage:

  • Wetland conservation: By limiting development in wetland areas, REAL seeks to preserve these ecosystems’ natural resilience.
  • Restoration of degraded wetlands: REAL promotes initiatives to restore wetland areas impacted by past development, providing a buffer against coastal flooding and erosion.
  • Adaptive planning for saltwater intrusion: As sea levels rise, saltwater intrudes into freshwater areas, disrupting ecosystems and agriculture. NJPACT REAL includes guidelines for adaptive land use in regions threatened by saltwater intrusion.

3. Sustainable Land Use Planning

NJPACT REAL encourages sustainable land use by promoting green infrastructure and preserving open spaces. These practices not only reduce flood risks but also support biodiversity, improve air quality, and provide recreational opportunities for communities.

Specific goals include:

  • Green infrastructure: NJPACT REAL supports green roofs, permeable pavements, and rain gardens that manage stormwater sustainably, reducing flood risks.
  • Preservation of open spaces: REAL sets guidelines to discourage development in critical areas like floodplains and wetlands.
  • Zoning updates: REAL includes recommendations for local governments to adopt stormwater management master plans and land-use policies that account for future climate conditions, such as flood risks.

4. Adapting to Sea-Level Rise

New Jersey’s 1,800 miles of tidal shoreline make it highly vulnerable to sea-level rise. NJPACT REAL focuses on ensuring that coastal communities can adapt to the rising tides.

Key measures include:

  • Coastal building standards: Enhanced design standards for coastal buildings help reduce the impact of tidal and storm surges.
  • Encouraging natural buffers: REAL promotes the use of sand dunes, marshes, and other natural barriers to absorb the impact of storm surges.

5. Climate-Informed Decision-Making

The REAL rules emphasize data-driven decision-making, using the latest climate science and models to guide regulations. NJPACT REAL requires public and private projects to use updated climate data and projections, ensuring that investments in infrastructure and development account for anticipated climate changes.

Implications for New Jersey’s Residents and Businesses

For residents, NJPACT REAL means a safer and more resilient New Jersey. Homes built under the new standards will be better protected against floods, while green spaces and restored wetlands provide natural beauty and recreational areas that enhance quality of life. However, there may be costs associated with retrofitting older buildings or adhering to the new construction standards, which NJDEP is addressing through financial and technical assistance.

For businesses, particularly those in construction, real estate, and land development, NJPACT REAL introduces new requirements to mitigate environmental impacts. These standards may require adjustments to building practices, but they also create opportunities for innovation in sustainable construction and green infrastructure. Furthermore, companies specializing in environmental restoration and engineering will find increased demand for services related to flood protection and wetland restoration.

Challenges and Future Directions

While NJPACT REAL is a significant step forward, implementing these standards will require collaboration among government agencies, municipalities, businesses, and residents. Some communities may face challenges adapting to the new rules, particularly in areas where older infrastructure is prevalent.

Conclusion

The NJPACT REAL rules demonstrate New Jersey’s commitment to climate resilience, offering a proactive framework to address current and future climate risks. By enhancing flood protections, conserving wetlands, promoting sustainable land use, and incorporating climate science into decision-making, NJDEP is equipping New Jersey for a more resilient future. The REAL rules represent an essential step in building communities that can withstand the impacts of climate change while preserving the natural landscapes that make New Jersey unique.

Using Rivers as a Contextual Bridge to Connect K-8 Students to Their Communities

By LRWP Board Members Missy Holzer and Heather Fenyk

For K-12 students, there is only one New Jersey Student Learning Standard (NJSLS) on rivers: “Use maps to identify physical features (e.g., continents, oceans, rivers, lakes, mountains).” On Monday October 20, Lower Raritan Watershed Partnership Board Members Missy Holzer and Heather Fenyk joined K-12 educators attending the New Jersey Council for the Social Studies annual conference to lead what we hope was the first of many workshops to support educators and students in using maps and rivers to learn about, and connect to, their communities. We now invite K-12 educators from all disciplines to explore curricular materials we shared at our NJCSS2024 session, titled “Using Rivers as a Contextual Bridge to Connect K-8 Students to Their Communities: A First Nations Perspective.” A curriculum guide and all workshop materials, including the powerpoint, bibliography, and detailed teacher and student case study guides, are available at: https://tinyurl.com/LRWP24NJCSS.

This LRWP workshop for social studies teachers emerged from our own place-based, problem-based teaching orientation, and built specifically on our Spring 2024 volunteer eel monitoring program. We centered the lesson around a special case study: “The Mystery of the Missing American Glass Eels,” and also worked to support educator comfort with using maps, particularly topographic maps, as tools for student understanding of change to their local landscape over time. Our aim, as always, is to help educators use local waterways to connect students to their backyards, while developing our next generation of local stewards.

While it may seem unusual for an environmental non-profit to engage with K-12 social studies educators, the LRWP sees great potential to connect with multiple disciplines, including social studies, science, math and art. From the past to the present, and into the future, New Jersey’s waterways were and are vital to our existence. Besides being a continual source of water, our rivers, streams, and canals have implicitly and explicitly shaped our presence in the state. Drinking water, food, transportation (people and goods), industry, energy, and recreation are a few of the services our waterways have contributed to life in New Jersey.

Viewing our waterways from a watershed perspective that includes all the tributaries, rivers, and wetlands within a drainage area, connects communities to each other as much as they connect the flow of water from the headwaters of a river to the sea. Our Lower Raritan Watershed, its lands, streams, and the Raritan River, offer a host of case-based, problem-based, and place-based approaches to formal and informal investigation of these connections from the past, present, and future. The LRWP invites formal and informal educators to connect with us to discuss opportunities to partner for classroom or field based approaches to learning and inquiry.

Sept 14 – SEWA USA & LRWP Open House!

In partnership with SEWA USA – Central New Jersey Chapter, the LRWP is pleased to co-host a special Boat Shop Open House on Saturday September 14, 2-5pm at our 101 Raritan Avenue Boat Shop in Highland Park.

We welcome you to join us for refreshments, boat build demos, rain barrel painting, a special presentation by Rutgers Professor Chris Obropta, a clean-up at Donaldson Park, and a change to get out on the Raritan River for a paddle!

Please note that parking will be tight: if you drive, you will want to find parking on the side streets.

Headed for a Fall

Essay and photos by Joe Mish

The green mittens are going fast, we expect a shipment of red mittens to arrive shortly, well before cold weather sets in. Sassafras trees have three variations of leaf shape, one reminiscent of a mitten. When the red mittens are on display, Autumn has arrived.

August foliage provides the canvas upon which September begins to smudge and splash bright colors across the landscape. These scattered traces of color are the threads from which the blanket of full fall brilliance is woven.

As the earth squints at the sun, the decreasing daylength triggers a seasonal response, marked by visual changes in leaf color. The bold statement of color, expanding daily, by the hand of an unseen artist, fires the imagination of the human mind to dwell in a borderless realm of magic and possibility.

In the time before science, the wonders of the natural world were rationalized by myth, to satisfy the overpowering human curiosity, which demanded explanation. In a way, the periodic appearance of leaf color was a teaching aid to foster human survival by articulating the most critical elements of adaptation, creativity, and imagination.

The world that surrounds us is the catalyst for all we create, innovation is the product of imagination. Inspiration may be found in the least probable places, where the path of a fallen leaf on the driveway, leads directly to the starlit heavens and their impact on the earth and all living things.

I enjoy taking a paleo perspective to view nature and try to share the experience and emotion of my kindred paleo counterparts. Standing in their moccasins, I would come to realize a repetitive pattern exists which provides predictability, a key to survival and a reference point upon which to stack temporary facts. The appearance of color precedes the arrival of cold weather, a reminder to be prepared for snow and cold. See the colors of the sunset and rise, appear on the leaves. The overflowing colors are spattered across the landscape as the sun crashes into or escapes from the earth, to allow the colors of the sky to be held in your hand.

Summer has a home in September, so the transition to autumn is quite subtle, though hints of color stand out like small islands in the sea of green. While some specific trees and shrubs turn off the green, early in September, random species will always showcase a wink of color.

Black walnut trees are the first to turn yellow and shed leaves. They appear abandoned and leafless, while nearby trees are still veiled in green. The ground beneath the trees covered in a thick layer of yellow leaves, and laden with walnuts encased in thick green husks appear as if set on a yellow tablecloth for distribution and consumption by the local gray squirrels.

Staghorn sumac surrenders its green but retains its gold and red leaflets as adornments to compliment its dark brown hairy seed clusters. Many are already marked by white-tail deer bucks, scraping the velvet from their antlers.

Sassafras trees appear adorned in yellow or red, some leaves, in the shape of colorful mittens, as if displayed on a rack for sale.

American sycamore leaves are light green and edged with a golden brown as they begin to change in late summer. Their height and crown easily seen, especially when growing in groves along a watercourse is an obvious sign of changing seasons.

Native dogwood trees in late summer are adorned with faded reddish-purple leaves and bright red gleaming berries, which stand in contrast to each other and make this small understory tree, a fall treat to behold.

Black gum trees, found along the upper South Branch, are first in flight in their beech, birch, maple neighborhood association, as their obovate leaves, egg shaped with the broad end toward the tip, turn a rich salmon color and actually look like old fashioned Christmas lights.

Still, it is the random splash of color that catches the eye long before the great parade of fall color arrives. A single leaf of pumpkin orange appears among the dark green crown of an oak tree, as if signaling for rescue, afloat on an expanse of green ocean, five thousand feet below a search plane.

Unable to keep a secret, or simply out of step with the fall choreography, these colorful precursors are the sparks that light the autumn fire.

Author Joe Mish has been running wild in New Jersey since childhood when he found ways to escape his mother’s watchful eyes. He continues to trek the swamps, rivers and thickets seeking to share, with the residents and visitors, all of the state’s natural beauty hidden within full view. To read more of his writing and view more of his gorgeous photographs visit Winter Bear Rising, his wordpress blog. Joe’s series “Nature on the Raritan, Hidden in Plain View” runs monthly as part of the LRWP “Voices of the Watershed” series. Writing and photos used with permission from the author.

LRWP Opposes conversion of Thomas A. Edison Park from free public land to fee-based access

The LRWP is opposed to conversion of Thomas A. Edison Park from free public land to fee-based access, and has serious concerns regarding the environmental impact of the proposed project (see our comments below). We encourage watershed residents to review and comment on the Environmental Assessment submitted by Middlesex County to the National Park Service regarding the County’s plan to turn Thomas A. Edison Park into a Destination Athletic Complex with 14 artificial turf fields. You will find the Environmental Assessment and details to provide comment here. The comment period ends on September 3, 2024.

TO: Diane Keith, NER Program Manager / National Park Service / Federal Lands to Parks / c/o 54 Portsmouth St. / Concord, NH 03301

RE: Thomas A. Edison Park Environmental Assessment

On behalf of the Lower Raritan Watershed Partnership (LRWP), I am writing to express objection to Middlesex County’s proposed change of the purpose and use of acreage within Thomas A. Edison Park in Edison Township. The LRWP has reviewed the Environmental Assessment for this project, and remains concerned by the plans to: 1) convert significant contiguous woodland acreage to active park facilities, which will have the effect of further compromising habitat connectivity for wetlands species in a fringe ecosystem area; and 2) replace current woodland and natural grass acreage with artificial/synthetic turf, which will have the effect of eliminating important ecosystem services of filtering stormwater runoff and moderating temperatures provided by these landscapes. Clearly both woodland conversion and installation of synthetic turf will also have the result of exacerbating climate change and pollutant flows in the watershed.

Below we provide more detail on our concerns related to this project:

Failure to account for flood risk

Current flood models suggest that significant portions of the area of concern will be under water in the future. Development of these lands, especially using synthetic turf, will significantly compromise passive floodwater containment in an already flood-prone area of the Lower Raritan Watershed.

Synthetic Turf Sheds Microplastics, PFAS, and Other Chemicals

Like all plastic materials, synthetic turf doesn’t last forever—instead, it breaks up and sheds massive amounts of tiny plastic particles into the environment and our bodies. A 2018 report by the European Commission showed that athletic fields composed of synthetic turf shed an annual average of 18,000-70,000 tons of microplastics each year into surrounding air, soils, and waters. This includes huge quantities of crumb rubber, which leaches toxic lead, PFAS, phthalates, and other dangerous chemicals. People and other animals who walk and play on synthetic turf absorb plastic particles and their toxins through the skin, inhalation, and ingestion.

Synthetic Turf Wastes and Contaminates Water

Synthetic turf still requires regular watering, especially on hot days where it can heat up to 40-70 times hotter than the surrounding air—getting even hotter than asphalt. This is because unlike real organic, cooling, and oxygenating grass, synthetic turf is heat absorbent. The temperatures of plastic grass can get so hot it has been known to cause contact injuries called “turf burn.” Heated synthetic turf has also been found to release toxic gases, including carcinogenic benzene and formaldehyde. In addition, materials experts report major drainage issues linked to plastic grass. These issues worsen droughts by preventing groundwater—which many people depend on for drinking—from naturally recharging. When rain falls onto synthetic turf, research shows it absorbs chemicals and runs off—typically entering stormwater systems that drain to large water bodies, in this case the proximate Raritan River and the NY/NJ Harbor Estuary. Also of concern is the increased temperature of the stormwater runoff as it flows into the Raritan.

Increase in Impervious Cover

The conversion of forested habitat to plastic turf and parking lots will increase impervious cover, compromising any attempts to meet federal MS4 requirements let alone advance stormwater management best practices. As we face increasing risks and uncertainties of climate change we should, as a basic practice, never convert parkland to parking lots or synthetic surfaces.

Exacerbates Inequities of Access to Recreational Spaces

The Federal Government deeded Thomas Edison Park to Middlesex County to be used as a free park in perpetuity. Conversion of these free public lands to fee-based access violates the original intent of the deed, and the public interest. Furthermore, the County proposal is for expansion of park amenities in an already well-resourced portion of Middlesex County. The County clearly has not taken transportation equity or other equity concerns into consideration with respect to improving equitable recreational access to County system parks for low socio-economic status communities and for communities with limited access to transportation to park networks.

The LRWP respectfully requests that the National Park Service deny approval to Middlesex County for the proposed changes to Thomas Edison Park.

Sincerely,

Heather Fenyk, Ph.D., AICP/PP / Board President

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