[CT Birds] Rail Comments

Kathy Van Der Aue kathyvda at gmail.com
Tue Feb 16 11:37:14 EST 2016

Well done, Patrick, very detailed and informative!  I sent a less detailed
letter in the name of COA.  I hope others have also sent letters to express
their opinions on this project as I believe public comment closes today.
Information can be found at NECFuture.com

Kathy Van Der Aue
Southport, Connecticut
Visit my Blog at http://naturaliststable.wordpress.com

On Tue, Feb 16, 2016 at 7:45 AM, Comins, Patrick via CTBirds <
ctbirds at lists.ctbirding.org> wrote:

> 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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