(These comments were submitted to the state environmental conservation department during its public comment period on the latest Putnam Trail design by the group, Save the Putnam Trail.)
We encourage the DEC to reject the permit application for the project based on four critical deficiencies in the permit application: Ignored seasonal wetlands, inadequate stormwater design, an outdated and inappropriate environmental assessment done for a different design five years ago, and a lack of alternative design considerations.
The Putnam Trail not only runs through the buffer area of the wetland, but it is also the site of vernal pools, which are important remnants of the riparian ecosystem of the valley of Tibbetts Brook, once a much wider river known as Mosholu.
We are alarmed that you are currently reviewing the application with mapping that ignores seasonal wetlands, and does not recognize the riparian zone wetlands as one system, but rather presents an uninformed view of the areas as disjointed wetland segments.
We feel that it is imperative to treat Tibbetts Wetland with sensitivity and reject pavement in its buffer zone, for its properties to spread stormwater, sedimentation and heat most efficiently. Tibbetts is one of the last surviving freshwater wetlands in the city, and many ecosystems found in Van Cortlandt Park are able to sustain themselves only because of their wetland.
According to the Audubon Society, the Van Cortlandt marsh is home to a greater number of breeding species than is the entire Central Park.
Tibbetts Wetland is a special area in the topography of Van Cortlandt Park, situated within the lowest valley of the park. The natural drainage gradient throughout the park is southwesterly, with the exception of the Henry Hudson Parkway, which drains directly into the wetland buffer area from both the easterly and westerly directions via the specially designed drainage lagoons.
According to research done by Friends of Van Cortlandt Park, groundwater displayed by the Croton filtration plant in the northeast of the park also drains to Tibbetts Wetland, and brings with it sediment and pollution from Mosholu Parkway into the lake. The golf courses, built on dried marshland that one comprised the Mosholu valley, also drain into the area that is currently the Putnam Trail.
In short, the wetland area that includes the Putnam Trail is a valley whose watershed sources mentioned above — parkland, highway, filtration plant and association infrastructure, development outside the park — are stressors for the wetland, and together with other factors, lead to a condition known as urban stream syndrome.
DEC Commissioner’s Policy CP-49 requires climate change considerations in permitting, and this application is not in compliance. No watershed analysis was done, and no climate change anticipation was built into the design — design storms above the three-year storm were not considered. Even more alarmingly, no water monitoring to establish a baseline water quality was done prior to the design.
Lastly, the design should have analyzed flash flooding risks.
Due to all of the above concerns, we feel that the negative declaration made in the application is in error.
We urge the DEC to base its decision in this matter on environmental foresight and its direct duties, rather than appeasing the higher political will that covets a uniformly paved greenway at any cost.
The author is a member of Save the Putnam Trail.