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Letter to the NJDEP Project team on Rebuild By Design – Hudson River,
from Responsible Development Alliance Hoboken & Hoboken Quality of Life Coalition
re: Draft Environmental Impact Statement (DEIS)  

​Thoughts on Preferred Alternative 3
 
Many thanks are due to Assistant Commissioner David Rosenblatt, Program Manager Dennis Reinknecht, Mayors Fulop, Turner and Zimmer, the Citizens Advisory Group, consulting resources from Dewberry, Stevens Tech experts, varied Federal agencies, and many citizens and others for the comprehensive review of the intense flood issues related to the lower-lying sections of Hoboken, Jersey City and Weehawken.  The effort has been comprehensive and illuminating. 
 

After the approval of a $230 million U.S. HUD Community Development Grant, the New Jersey State Department of Environmental Protection (DEP) was designated to design and implement a program intended to address flooding from major storm surges, high tides and heavy rainfall events. Five potential design concepts, subsequently culled to three alternatives, were proposed to advance the project.  Ultimately Alternative 3 was selected by the NJDEP as the proposed “Preferred Alternative.” Throughout the process, DEP sought public, local government and key stakeholder input at numerous public meetings, forums, drop-in and Q and A sessions, and welcomed public input at any time during the planning process. Alternative 3 properly gained wide preference, as it provides numerous advantages to the other proposed designs including the lowest initial and maintenance cost, the best benefit/cost ratio and fewer potential utility crossings and better scale of potential relocations.

Unfortunately, despite the herculean efforts taken to involve key stakeholders, NJ Transit and LCOR, the respective owner and developer of a significant piece of land affected by Alternative 3, have not articulated their opinion, expressed a preference or assisted the DEP in resolving the important decision of whether “Option 1” or “Option 2” under Alternative 3 should be implemented.   The land in question consists of the majority of the Hoboken Terminal and Rail Yards Redevelopment Zone (Zone) for which there is an approved plan. Due to the potential for increased costs and implementation delays we respectfully ask the DEP to seek NJTransit and LCOR commitment to a preference between the two Options that are imbedded in Alternative 3 and that the DEP identify whether Option1 or 2 under Alternative 3 has been selected under their Preferred Alternative.


Several representatives of the building trades have articulated their support of Option 1 and we posit that Option 1 would protect not only the extant structures of Hoboken, but also the ability to develop this Zone. Additionally, the DEP Draft Environmental Impact Statement (DEIS) Table 6.1, shows that the Option 1 costs, which may be borne directly by the citizens of the affected municipalities (and are well beyond the proceeds of the HUD Grant are significantly less than those under Option 2:

Option Selected                              Option 1                   Option 2
Total Resist Cost ($ millions)      $ 224.5-249.9          $ 238.1-268.5
Annual Maintenance ($ millions)   $ 1.4 – 2.3               $ 1.5 – 2.4

Likewise, DEIS Table ES.1, Engineering and Construction Costs, projects the estimated Delay, Storage and Discharge costs of the project as between $126.4 and $148 million with the difference presumably being between Options 1 and 2 although the DEIS does not definitely state so.
 
Stakeholders throughout Hoboken have, over the two years of the Rebuild By Design process, stated their preferences and considered the potential impact of one plan versus another with regards to their neighborhoods, properties and anticipated costs.  Obviously, there is a crucial timetable to appropriate decision-making and we posit that inherent in that timeline is a determination of whether Option 1 or Option 2 will be part of the Preferred Alternative. We hope that the DEP agrees with this assessment, procures the input of NJTransit and LCOR, and makes this most important decision so that all stakeholders can assess the potential impact of the DEIS.


Thank you for the opportunity to participate in this planning process that will affect our community for decades to come. 
Sincerely,
Responsible Development Alliance of Hoboken
Hoboken Quality of Life Coalition
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