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How (and why) to make a public comment on the Gowanus NRDA

If you’ve been subscribed to our email list or keeping an eye on our Instagram account you’ve probably seen us post and share about the Superfund-related environmental restoration efforts on the canal — usually referred to as the NRDA.

Perhaps you’ve attended one of our learning sessions, or maybe you’ve just been curious about it. Well, we’re here to help!  The Dredgers want to make sure you know what’s happening and how you can get involved. Celeste LeCompte and Lilian Ruiz have put together a great overview of the whole process, including some guidance on how to make your public comments. 

What's the NRDA? Why Should I Care?

The Natural Resource Damages Assessment (NRDA) is the first part of a long-term environmental restoration effort that involves multiple government agencies, the entities held responsible for the pollution and its cleanup, and people like us — the community! 

The first step is a beefy, 50+ page document — the “Draft Plan” — for how environmental harm to the Gowanus Canal will be determined. 

This Plan will shape restoration efforts, both through identifying what local wildlife, habitat, and human activities have been harmed and by calculating the financial value of those harms. That dollar amount will be used to set the budget for restoration projects that could have a direct impact on (and benefit to!) our community. The process is overseen by a group of government agencies, known collectively as “the trustees.”

You can submit comments on the Draft Plan through June 14. 

The Dredgers have been reviewing the plan, and we’ve identified some issues that we hope to see addressed. We’ll post a longer update later, but for now, we are focused on three primary issues related to our mission and past work:

  • The current plan only intends to assess the impact of pollution on water in the canal, sediment on the bottom, and wildlife living in the canal. This leaves out a lot of parts of the canal that we care about, including the intertidal zone, and impacts to our local groundwater and air quality.
  • Human and recreational uses of the canal are extremely important and deserve a more robust analysis. The long-term pollution of the Gowanus Canal and the more recent changes in water access and bulkheads due to the remediation process have both limited recreational and fishing use of the canal.
  • Our research on the Atlantic Ribbed Mussel populations in the canal, our Birding by Canoe tours, our Science Saturday Drone Explorations, and our regular voyages on the canal have all shown us that there are a much wider range of creatures that have been impacted by the pollution than the plan currently accounts for.


We’ll be making comments focused on these issues and will specifically highlight evidence from our past experience on the canal. You can help, too, by sharing your perspective on these issues with the Trustees. Below, we have our guide on how to write an effective comment. A few questions to consider as you think about what to say:

  • What wildlife and species have you seen in your explorations of the canal?
  • How and why have you enjoyed boating or fishing on the canal? What has prevented you from boating here more?
  • What would a greener, more accessible canal mean for you? 


Postcards to help you write your comments can be found at upcoming local events, including all Dredgers events. (You can view the postcards here and print your own, if you like!) 

Celeste and Lillian are also available to attend your event or talk to your organization, if you’d like to help us spread the word. Reach out to celeste@revolutionarygrammar.com

A Guide for Writing Comments

This guide is meant to help individuals prepare comments to the Gowanus Canal Natural Resource Damages Assessment draft plan. Comments are due to the Trustees on June 14.

 

Component to include

Examples

Introduction
State who you are and your connection to the Gowanus Canal. Use “I am” statements, and/or the “Appreciation” section of our activity.

  • I am a long-time Gowanus resident and take frequent walks along the canal, which has been one of the few natural areas near my home. 


  • I moved to Carroll Gardens in 2019 to be closer to the canal, where I have been an active member of the Gowanus Dredgers Canoe Club and regularly canoe on the Gowanus. 

Your Experience
Describe your experiences with the Canal – positive and negative – and their impact on local enjoyment of the Canal and the immediately surrounding area. Use details that help show that your problem/solution are grounded in local knowledge.

  • On my walks, I have become an avid birder, spotting green herons, osprey, buffleheads, and many other species fishing, nesting, and swimming in the canal. 


  • I used to see ribbed mussels, raccoons, crabs, and herons on the wooden bulkheads that lined the canal. During remediation, I have seen many of the old wooden bulkheads removed and replaced with large steel sheet piles. 

Problem
Clearly describe something that concerns you about the plan or the state of the canal, focusing on the habitat, wildlife, or public uses like boating and fishing. What impact does this have on you and your community?

  • I am concerned that the proposed NRDA plan will not fully capture the abundance of wildlife using the canal.

  • The remediation work has caused a significant loss of habitat in the canal, and the proposed NRDA plan does not address this loss. The current plan is limited to assessments in the aquatic habitat, rather than recognizing the Canal’s past (and potential future) as an intertidal habitat. 

Solution

Simply and concisely describe what action or solution could address the problem you see and why it works. Reference other relevant projects or examples that support your idea.

  • Many community groups have collected additional information about species in the canal, through bioblitzes and regular monitoring activities. Many online birding communities and citizen science apps like iNaturalist capture a wide range of additional, abundant species that should inform the assessment, too.


  • Studying the shoreline and intertidal zone of the canal will provide important information about the wildlife, habitat and uses of the canal that is important for our community.

Make the Ask

What action do you want taken on your behalf? What do you want to see changed or considered? End with a thank you for reading your comment.


  • Please revise the NRDA to include a fuller assessment of wildlife that has been regularly seen in the canal, using information that has already been collected by community groups and citizen scientists, and expand outreach to local environmental groups.

  • The NRDA plan’s scope must be expanded to include both aquatic and intertidal habitats, in order to fully reflect the significant impacts that the pollution and the remediation activity have had on our local ecology.

You may submit your written comments on the Draft Assessment Plan or questions related to the Gowanus Canal NRDA by either email — nrd@dec.ny.gov — or post:

 

New York State Department of Environmental Conservation
Natural Resource Damages (NRD) Section
c/o Alicia Pasos
625 Broadway, 14th Floor
Albany, NY 12233

 

Comments must be emailed or postmarked by June 14, 2024.

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