November 16 2006
FROM: Kingston Greenways Association
PO Box 391
Kingston, New Jersey 08528
TO: New York District, U.S. Army Corps of Engineers
Regulatory Branch, ATTN: Route 92 FEIS
26 Federal Plaza, Room 1937
New York, New York 10278-0090
By e-mail to: Nan.Route92EIS@usace.army.mil
RE: Final Environmental Impact Statement for the Route 92 Project proposed by the New Jersey Turnpike Authority – Application number 1999-00240-J1
South Brunswick/Plainsboro Townships, Middlesex County, New Jersey
Dear Sir or Madam:
With this letter, Kingston Greenways Association, a New Jersey Non-Profit Corporation (KGA) is voicing its continued opposition to the construction of Rt. 92 and wishes to record the following comments on the Final Environmental Impact Statement (FEIS) concerning the proposal to build an extension of the Turnpike known as Route 92 from Exit 8A in Jamesburg to Route 1 in South Brunswick.
Kingston Greenways Association is a local open-space preservation organization whose members are dedicated to the preservation of natural habitat, parks, and farmland surrounding the 325-year old village of Kingston. The historic village of Kingston lies 1.5 miles due west of the proposed terminus of the new highway. Our primary mission is to preserve and protect the Greenbelt around the Village of Kingston.
We earlier expressed opinions on the previous draft EIS in a letter dated June 15 2004. We received responses to the points we raised and noted them. However a number of concerns still remain, even in the light of the recent FEIS. They are as follows. A fuller background to these concerns has been expounded in our previous letter and will not be repeated here.
(1) Traffic increase on Ridge and Heathcote Roads.
The FEIS indicates that construction of Route 92 will produce increased traffic on Ridge and Heathcote Roads. At p.m. peak hour, truck traffic is predicted to increase by 50% (to 66 trucks per hour). We do not believe that the impact of this on either the Cook Natural Area or the newly created Mapleton Preserve through which Ridge Road in Kingston passes is acceptable. Both the Cook Natural Area and the Mapleton Preserve form part of the Green Belt around Kingston, a region intended to provide relief, for both human and wild life, from the pervasive urbanism. The Greenbelt also has the purpose of maintaining the historic original ambience of the area. Adding to traffic through this area will certainly undercut these purposes.
In addition, the village center of Kingston through which Heathcote Road, a narrow residential road, passes will clearly be negatively impacted, as described in the FEIS.
One factor that we find extremely puzzling in Table 4-3a is how the cars on Laurel Avenue north of Church Street, listed as 1,129 cars per hour at peak in the A.M. with the no-build alternative could credibly be modeled to fall to 1042 cars per hour at peak with the Rt. 92 alternative. Similarly, we find it highly improbable that car traffic on Heathcote/Ridge could fall and not rise significantly.
With the proposed Route. 92 terminus at the intersection of Ridge Road and Route 1, we strongly believe that commuters to and from the area west of Kingston who now enter and exit the Turnpike at the New Brunswick exit will be induced to take Heathcote/Ridge to Route 92.
This is because for those municipalities to the west of us, the routing of 206 to 518E to 603 (passing by the historic Rockingham site) to Heathcote/Ridge to Route 92 provides the most "convenient" route to the Turnpike, especially for those who would be traveling South on that road. Likewise, Turnpike-bound commuters with ready access to Route 27 from the North and South of Kingston will likewise be induced to travel down Heathcote/Ridge.
As the traffic study in the FEIS completely fails to take into consideration any of the traffic traveling to/from the west of Kingston from areas such as Rocky Hill, Montgomery, Belle Meade and Hillsborough, we find it to be fatally flawed.
Why was the traffic model to the west of the proposed Route 92 terminus in Kingston limited to a distance of only 1.2 miles (the distance to Route 27), when it was extended significantly further distances in the direction of Plainsboro? We find this to be highly biased, and believe that it serves to underestimate the effect of traffic on our Village.
(2) Impact to the PA5 area.
The FEIS has stated that in "crossing the Devil's Brook corridor, proposed Route 92 would cross one of the largest unbroken pieces of undeveloped land in Middlesex County" and that "it is also true that the Devil's Brook corridor is environmentally sensitive." Despite this acknowledgement, the recommendation is to construct two bridges totaling over 1,000 feet, to maintain the hydraulic integrity of the area. The Devil's Brook area is designated in the New Jersey State Development and Redevelopment Plan as PA5, the status New Jersey applies to its most environmentally sensitive areas. A PA5 category is meant to have the greatest degree of protection from development. We maintain that building these two large bridges would not provide this protection. This 1600-acre site is the second largest PA5 area in Middlesex County and comprises fully one-third of all its PA5 land.
(3) Stormwater Regulations conformity
The recent NJ Stormwater regulations now mandate special stormwater recharge requirements in new construction, and the FEIS does address this issue. However, the FEIS has failed to consider the impervious cover aspect. The proposed Route 92 would add at least 147 acres of impervious surface, a large enough area to be of significant concern. It should be noted that an alternative examined by the FEIS, the widening of Route 1, would result in a much lower increase of impervious surface. Construction of the road would represent a real setback to the efforts to limit impervious surface in the South Brunswick area; in effect, it would negate the advantage of previous acquisition of about 140 acres of open space.
The KGA maintains that the extra impervious surface introduced by Route 92 would be undesirably high, that this negative impact has not been adequately dealt with in the FEIS, and that an alternative to Route 92 should be chosen.
(4) Wetland replacement
The KGA believes that response to wetland mitigation is inadequate. Although mitigation is addressed in the appendix, the poor rate of success in wetland mitigation is not. Numerous studies show how difficult wetland creation is and that created wetlands lack the ecological diversity and habitat value of natural wetlands. Bradley Campbell, the former Commissioner of the NJ Department of Environmental Protection, stated that wetlands mitigation is "always a last resort" and has been a "dismal" failure in the past. Nor does the FEIS explain whether the estimated cost of wetland mitigation was included in the original estimated $400 million for the roadway.
(5) Species of Concern
As the FEIS notes, there is a large area of the wetlands and woodland near Heathcote Brook at the intersection of Route 1 and Ridge Road that was not included in the field surveys for federal and state threatened and endangered species. As we noted in our earlier comments, we have recorded sightings of 4 Species of Concern [namely Savannah sparrows, Osprey, Bald Eagle and Coopers hawk] in at least one of our Kingston counts between the year 2000 and now. The wetlands and woodlands mentioned above are connected to the Cook Preserve, Heathcote Park, Mapleton Preserve/Land and the D&R Canal State Park, forming a wildlife corridor. Thus, we discount the FEIS response that "given the long history of US Route 1 as a major travel route and the fragmentation of habitat caused by the extensive development along the corridor, the potential for suitable habitat for threatened and endangered species must be considered low." The presence of these birds in our "counts" indicates that this area has some potential to serve as habitat. Why was this area not included in field surveys for federal and state threatened and endangered species?
(6) Round-table discussions
The FEIS rejects the option of round table discussions on the basis that all reasonable alternatives to Route 92 have been identified. This may be so; but it is the selection between these alternatives that still in the opinion of the KGA dictates the need for round table discussion. It is our belief that the Route 1 widening alternative in combination with the modifications to Route 522 already initiated by South Brunswick Township is the preferable one; this should be made one of the topics of such discussion. Why was such a combination not considered in the FEIS?
(7) Light Pollution
The issue of light pollution has been avoided in the FEIS by claiming that no lighting has been designed. This is not an acceptable statement; at the least, the impact of certain kinds of available lighting could be estimated. In particular, in the area of interest of the KGA, the intersection with Route 1 will be elevated and if lights are used comparable to those on the Forrestal intersection, it is possible that the east part of Kingston village and its environs will be subjected to considerable night-time glare.
In summary, the above seven items either include descriptions in the FEIS of negative impacts or contain arguments that the FEIS has underrated negative impacts. We contend that the combination of these factors indicates that the construction of Route 92 is not in the best interests of the community at large and certainly not in the interest of the KGA. We cannot agree that the conclusion of the FEIS, (as displayed in Table ES-1 of the Executive Summary) that the construction of Route 92 is the best of the proposed alternatives from the environmental point of view.
Kingston Greenways Association