From Kara Cressman 4/12/2012

To: NY State Department State Division of Coastal Resources,

I am writing in regard to the Department of State Division of Coastal Resources consistency review for United Water’s proposal for desalination for Rockland County (the “Haverstraw Supply Project”).

I am formally requesting that the Department of State extend the public comment period on this project until the New York State Department of Environmental Conservation’s SEQRA review is complete. This extension would ensure that the Department of State is given the benefit of full review of all the relevant materials that will be submitted by April 20, the close of the DEC public comment period. This request for extension of the DOS public comment period, in order to give this complex proposal the full public scrutiny that it requires, is in line with the recent resolution passed unanimously by the Rockland County Legislature asking for a longer public comment period for the SEQRA review of 90 days.

I am also writing to ask you to reject this proposal, which I believe is inconsistent with DOS criteria for approval.

The Rockland Water Coalition, a broad array of local citizen groups working together with major regional partners such as Riverkeeper, Scenic Hudson, and Clearwater, has come together in opposition to this proposal.

I join these groups in their concerns:

  • Impacts on the “Irreplaceable Habitat” of Haverstraw Bay, a critical spawning ground, nursery, feeding area and wintering habitat for fish and other wildlife, with impacts beyond the river on Atlantic fisheries;
  • Impacts on Haverstraw Marsh (federal wetlands), known as a recovering habitat for wildlife, including the Bald Eagle;
  • Substantial increase in greenhouse gas emissions due to energy intensive desalination;
  • Increased regional energy usage, counter to state’s goal of shutting down Indian Point;
  • Establishment of an irreversible precedent for this technology in NY State, in place of water supply policies and technologies with far lower environmental impacts;
  • Creation of a permanent impediment to the recovery of this formerly industrial area, which is working to restore itself as a river-based community in terms of its environment, recreation, and river-related economy;
  • Permanent alteration to the character of this community;
  • Inconsistency with Rockland County Comprehensive Plan, which calls for the protection of Haverstraw Bay and the establishment of the bay as an important estuary education center.

In addition, I would like to state my concerns regarding United Waters history and conduct within the Rockland community. I live in West Nyack which much of, lies within a well known flood plain. Hurricane Irene 2011 was a prime example of United Waters lack of true cooperation with the people they serve. Up to a week before the hurricane was to hit our area, they were asked repeatedly by concerned citizens and local officials from New York and New Jersey, to lower the swell at the Lake Deforest dam to release water. Which was at full capacity. While others up and down the east coast were preparing by releasing water from their damns. United Water claimed that they could not do this, going as far as to tell one citizen who called them, ” You shouldn’t have built a house in a flood plain.” This kind of callous remark concerns me deeply. Consequently this area was flooded very badly. When it comes to relying on United Water/Suez to safely and responsibly supply this area with “balanced” drinking water and to protect an estuary that has been designated ” Irreplaceable”. I don’t trust them. United Water stated at a meeting I attended that they chose the sight for the desalination plant precisely because it had already been “disturbed”. How then are they looking at the Haverstraw Bay, as if it were “irreplaceable”? I think not. I urge you to consider these things while determining your judgement of their proposal. United Water remains committed to being a business for profit, which really means infrastructure built by them and maintained by them, because that’s how they make their money! Based on United Waters conflict of interest, their track record in the community and the sensitivity of the Haverstraw Bay it seems clear that de-sal is risky for Rockland and the Haverstraw Bay!

Further more, the proposal appears to be in direct contradiction to DOS policy to protect, preserve and restore significant coastal fish and wildlife habitats so as to maintain their viability as habitats. Haverstraw Bay is the most highly valued “Irreplaceable” Significant Coastal Fish and Wildlife Habitat according to the Department of State own designation. If built, this desalination plant would jeopardize the recovery of several federally endangered species and species of concern, including the Atlantic sturgeon, shortnose sturgeon, and the American eel.

This proposal would take water management in the Hudson Valley in the wrong direction, locking in a highly energy intensive water technology at a time when New York State’s Executive Order 24 has mandated 80% reductions in greenhouse gas emissions by 2050 and 15% reductions in energy use by 2015.

The application by United Water fails to thoroughly examine sustainable water options. There are better choices that can strengthen our economy while protecting our environment, including an energetic program of water conservation and efficiency, storm water recapture to reduce flooding and enhance recharge of aquifers, water reuse, sustainable land-use planning, and an active program to preserve open space.

I ask the DOS to extend the public comment period for this proposal. I also suggest that that the application of United Water for the Haverstraw Water Supply Project appears to be inconsistent with Coastal Policies.

Kara Cressman
West Nyack, New York