[CT Birds] Rail Comments

Comins, Patrick PCOMINS at audubon.org
Tue Feb 16 07:45:23 EST 2016

Below are the comments Audubon Connecticut submitted on the Draft EIS for the Northeast Corridor Rail Improvement Plan.   There is also an  attachment with a table of affected lands in the .pdf, which I could send to people if anyone is interested  (the formatting is a bit off in this text version):

February 15, 2016
Re: Comments on the Tier 1 Draft Environmental Impact Statement for the Northeast Corridor Future Plan
The Northeast Corridor Future Plan recommends several infrastructure proposals to update our mass transit system in the Northeast. Despite the potential reduction in carbon emissions, the uncertainties associated with Action Alternatives 2 and 3 present some significant negative impacts on wildlife, important habitats such as Audubon Important Bird Areas, wetlands, grasslands, and forest interior habitats. Audubon Connecticut therefore strongly recommends that Alternative 1, with proper design, and combined with an emphasis on completing the New Haven to Springfield commuter line, be selected as the preferred alternative. The negative impacts on important habitats for birds and other wildlife presented by Alternatives 2 and 3 are just too high of a price to pay for an as of yet undefined transportation dividend. And identifying Alternative 1 as a preferred scenario does not exclude the need for careful environmental review and the inevitable need for planning and design work that would avoid any environmental damage that presents a significant threat either on a temporary or permanent basis.

Our specific concerns at this time with the draft EIS and proposed alternatives include:  Major impacts to several Important Bird Areas including the Connecticut Audubon Society's Bafflin Sanctuary in Pomfret, the Audubon Center at Bent of the River in Southbury, the Quinnipiac River Tidal Marsh in New Haven, and Mansfield Hollow State Park in Mansfield. Even if some of these areas are proposed to be tunnels there will likely be significant disruption of surface habitats and public access during construction and operational phases of the project.  There are questions as to what grade would the tracks be going through the Bent of the River Audubon Center in Southbury, CT. The topography is such that while the intent is to have this be underground it may have to come to the surface through the Pomperaug Valley. This would be unacceptable and violate deed restrictions related to the donation of the Audubon Center at Bent of the River to Audubon.  The surface portion through Paugussett State Forest, Lake Lillinonah and George C. Waldo State Park would cause unacceptable negative impacts to an ecologically important area that is a critical wintering areas for Bald Eagles, as well as other raptor and numerous species of diving birds and waterfowl.  Alternative 1 would have significant impacts on the tidal marshes of the lower Connecticut River, including a significant migratory roost for Tree Swallows that supports a high percentage of the eastern North American population of Tree Swallows in fall migration and includes some of the most important nesting habitat in the world for Saltmarsh Sparrows, a species of global conservation concern.  The impacts to acreage of forest interior habitat that would be converted to edge, transitional or other non-interior classes is likely to be much larger than the footprint acreage directly affected. This impact is undefined in the draft EIS.  Alternatives 2 and 3 present an unacceptable fragmentation impact on important habitat for Cerulean Warblers at Natchaug State Forest.  Impacts to private, NGO and municipal open space, as well as impacts to state forests and wildlife management areas were not taken into account in the draft EIS.  No detailed shapefiles of the routes and what is tunnel were provided to the public. This would have allowed us to better assess the full scale of impacts to important habitat for birds and other wildlife.  Impacts to state-listed species and globally endangered, vulnerable, and near threatened species on the IUCN list were not taken into account in the draft EIS. This is particularly important for any potential negative impacts to Saltmarsh Sparrow, a species for which the Northeastern U.S. is a disproportionally important nesting area and a species that is already at high risk of extinction.  We also strongly suggest that consideration be given to reducing existing tidal restrictions created by the existing rail lines as coastal routes are upgraded.

The devil is generally in the details with these massive projects and the details on specific impacts to habitats of importance to birds and other wildlife and on open space other than state or federal lands are very difficult to assess from the maps and text that are provided. This is a huge plan with major implications for Connecticut’s habitats, open space, development patterns and our transportation network in the state. This project will impact tens of thousands of acres of habitat in Connecticut, in many cases converting critical and pristine habitat into rail infrastructure, with additional major fragmentation efforts on habitat in the state. The DEIS needs to do a better job of outlining resources such as NGO and municipal open space, open space owned by land trusts and other non-governmental organizations and private lands that may be protected under easement. In 1997, the Connecticut General Assembly set a goal of preserving 21% of the land area (673,210 acres) of Connecticut for open space for public recreation and natural resource conservation and preservation. As of September 2014, the State, working with land trusts and other partners, has protected a total of 496,191 acres, or close to 15% of Connecticut's land area (The Connecticut Comprehensive Open Space Plan, The “Green Plan”, 2014-2019). Connecticut is 73% of the way toward achieving this open space preservation goal. While the DEIS does take into account the impacts of proposed rails on federal, state, and county parks and forests, it does not consider the 239,791 acres of protected municipal, not for profit, and water company lands in CT. See the chart at the end of this document for a list of open space lands that will be impacted by proposed routes. Both Alternatives 2 and 3, will likely result in a setback to Connecticut’s land conservation goal as previously protected open space is converted and adjacent areas disrupted.

It is disturbing and unfortunate that the DEIS does not take into account state listed species or make use of the State’s Natural Diversity Database. Nor does the plan consider the potential impacts on species identified as globally at risk by the International Union for the Conservation of Nature (IUCN). For example, expanses of woodlands in the Northeast corner of Connecticut, an area known to be important to Cerulean Warbler (a Species of Special Concern in Connecticut and identified as globally vulnerable by the IUCN) would be impacted by the constructions of a rail line from Hartford to Storrs to Providence.
Also, beyond the number of acres that will be converted in Connecticut in Alternatives 1-3, the impact on adjacent forested lands may be underestimated. There are large areas of interior forest, identified by the Center for Land Use Education and Research at UCONN, around Natchaug State Forest and Nathan Hale State Park. The proposed rail line from Hartford to Storrs to Providence in Alternatives 2 and 3 would cut through some of these areas. Not only would sections of the forest be lost, but the adjacent woodlands would be more susceptible to edge affects, such as increased predation and cowbird parasitism. Also, high speed rail line along the I-84 corridor in western Connecticut with stops in Danbury and Waterbury (Alternative 3) is likely to increase urban sprawl and development in Connecticut Northwest corner, part of the USDA Forest Service PA-NY-NJ-CT Highlands.

Additionally, since there is a mix of at-grade and tunnel proposals included in the options, it would be good to have more details on things like the depth and methodology for drilling and the size and frequency of tunnel ventilation shafts to better assess impacts to sensitive surface resources. Audubon Connecticut strongly opposes transit of the proposed rail corridor through the Audubon Center at Bent of the River Property. Construction effects, possible ventilation infrastructure, security provisions and unforeseen impacts from construction and observation would potentially have serious negative impacts to the habitat, aesthetics and public access to this Audubon Center, which is a recognized Important Bird Area and one of the most popular destinations for birding and nature observation in the state. The Bent of the River was bequeathed to Audubon in 1993 by the estate of Althea Ward Clark and has strict conservation easements on the property. Any disturbance to the habitats of the Bent of the River from the proposed rail corridor would be in violation of those easement restrictions. While the impacts of Alternative 1 on the state’s bird populations are limited, we do want to bring to your attention the presence of a significant Tree Swallow roost on the Lower Connecticut River. Each fall hundreds of thousands of Tree Swallow use this roost each night from early September through mid-October. The roost is located on Goose Island, just north of where the I-95 crosses the Connecticut River and approximately a mile north of the proposed new bridge over the Connecticut River in Alternative 1. It would be a great tragedy to disrupt a natural event noted by Roger Tory Peterson of the Peterson Field Guides as the most incredible avian display he ever beheld. Additionally, the tidal wetlands of the lower Connecticut River have been identified as Wetlands of International Significance under the RAMSAR Convention and provide critical and irreplaceable nesting habitat for Saltmarsh Sparrows, a species classified as globally “Vulnerable” to extinction on the IUCN Red List. The possible tunnel under Long Island Sound has its own issues, depending on tunnel construction methodology and much more detail must be provided to assess these impacts, particularly as the route appears to cross some unique and very important and productive hard substrate bottomlands of the Sound. Thank you for the opportunity to comment on this important matter and please see the attached table below of open space/protected lands that are impacted by the proposed rail corridors.

Stewart J. Hudson
Executive Director
(Contact): Genese Leach, Policy Manager, Phone: 301-704-5235, Email: gleach at audubon.org

Patrick M. Comins, Director of Bird Conservation, Audubon Connecticut
Phone: (203)405-9115

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