Canal Commission Memo
MEMOTo: Anthony B. Sabidussi, Section Chief
NJ DOT, Bureau of Environmental Services
C: Jon Carnegie, Senior Project Manager
The Transportation Policy Institute, Rutgers UniversityFrom: James C. Amon, Executive Director
Subject: Cultural Resources Effects Document
Penns Neck Area EIS
Date: 9 January 2003
I am writing to express my strongest objection to an aspect of the Penns Neck Area Cultural Resources Effects Document.
On page 22 of that document there is a discussion of noise impact on the Delaware and Raritan Canal, a National Register of Historic Sites property. It reports that the NJDOT did a noise effect study on the D&R Canal. I had heard that such a study had been done and have requested a copy of it without success. At the very least it must be reported the conditions under which this study was done. What locations exactly, what time of day, what time of the year, and other details of the conditions are all relevant to my ability to accept as valid that this test produced information that is appropriate.
More important, however, I am in complete disagreement with the statement that "Because the canal does not meet the criteria for a location where serenity and quiet are of extraordinary significance, noise effects were based on the NAC standards for a recreation facility . . . " This is not a playground or an active sport area like a ball field. I refer you to the MASTER PLAN for the Delaware and Raritan Canal State Park (D&R Canal Commission, 1989) which states as a principle guiding all activity related to the Canal Park that "The Canal Park must retain a degree of serenity and separation from the man-made world." This principle, which was adopted by the Canal Commission after following all appropriate legal procedures for the adoption of a Master Plan, is part of the basis for the Canal Commission's regulatory program and more specifically is partial basis for N.J.A.C. 7:45-8.2(b) 4 which stipulates that roads proposed for construction near the Canal Park will not be approved unless the applicant can demonstrate that "The increased traffic will not have a noise impact on the Park."
An "Objective" adopted by the Canal Commission to articulate the above-cited "Principle" states that "Vehicular intrusion, either from roads that enter the Canal Park or from those that run parallel to it, should be avoided." (p.32, MASTER PLAN)
The assumption that noise intrusion is not a significant issue for the Canal Park appears
to have been made solely to satisfy the needs of this project and is not based upon any
analysis of this invaluable cultural resource or an understanding of the planning work that has been accomplished for it. It must be reversed.Once this improper assumption is reversed it will then be necessary to go to pages 14 and 15 of the Cultural Resources Effects Document and correct the text that describes the adverse impacts that would result from Alternatives B and B1. That discussion must be expanded to note that those two alternatives would produce an adverse impact on the Delaware and Raritan Canal because of the intrusive noise impact that would result if either of them were built.
I have not completed my review of this entire document so I may have other comments, but I believe that this issue of such importance that I want to send it to you immediately.
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