From Margie Turrin

My training is in ecology and I spend a fair amount of my time working and doing education on and around the Hudson. I want to speak tonight to some of the ecological impacts of the proposed United Water desalination plant.

Haverstraw Bay is a unique reach of the Hudson River – here the river is wide its shallow, its slow moving and brackish. This combination of physical characteristics does not appear anywhere else on the Hudson River and provides just the right setting to be highly productive biologically. In fact this reach of the river is well known as the nursery for many anadromous fish – fish that rely on it to complete their lifecycle.

The most recent 2011 draft updated version of the Department of State Significant Coastal Fish and Wildlife Habitat ratings recognized the uniqueness of Haverstraw Bay, classifying it as irreplaceable, the highest rated ecosystem in the river (213 pts.).

It is of critical importance not only to the Hudson River but commercial and recreational fisheries throughout the Atlantic Coastal are dependent on it.

My point is we need to step back and look at the bigger picture…This is part of a much bigger system, and in order to really look at impacts we need to use this wider systems type of thinking. Science has shifted to a systems approach which means looking at relationships that are interconnected -– we need to see the whole system, its varied parts and each of their roles within the framework.

The Hudson itself is a system with Haverstraw Bay being a key nursery area within it, but it is only a part of an even larger system – that of the fisheries along the Atlantic Coast. Haverstraw Bay provides a unique and invaluable role in that bigger system.

Looking to the DEIS created for the proposed desalination project the document discusses assessed impacts–but all with a focus on the immediate area and in addition we are looking at the impact for just this facility – this is not the way to consider this project. Haverstraw Bay is not in isolation on the Hudson River, but positioned in an area that already has other impacts. In the area of the Bay there already exists Bowline to the South and Indian Point to the northeast – both are causing impacts, part of the larger human footprint. We need to look at things cumulatively – again looking at the system.

Beyond that on a good day this would be just one more hit – but we aren’t on a good day. This is a system that is already in trouble…

How do we know this? The DEC has been studying the fish in the river for a long time. In 2008 PISCES Conservation Ltd. released a report on the status of fish populations & the ecology of the Hudson. Before this report the data showed there were problems but the report really highlighted it. Of the 13 key Hudson species focused on in the study 10 were in decline. But its worse than that – the American shad that uses this Haverstraw Bay for a considerable portion of its nursery stage is no longer allowed to be fished because of the significant decline in numbers. This is one more piece of our Hudson Fisheries history that is now closed.

Two other herring in the study are also in serious decline in the river and because of this have been selected by the DEC for focus in citizen monitoring as they move in to spawn – Alewife, Blueback Herring. All three of the fish just mentioned are Herring – which is known to be very sensitive to impingement – their skins are easily damaged and so they have a low to negligible survival rate following impingement. Impingement is part of the assessed impact of the proposed plant, and this will be one more impact for them.

Of the 13 fish studied all but one are regularly found in the bay using it as part of their lifecycle – 5 use the bay as a substantial part of their nursery area – Striped Bass, American Shad, White Perch, Atlantic Tom Cod (another fish in serious decline in the river), and bay anchovy.

I am focusing on this to show how fragile our system is currently – we know that it is suffering serious impacts – yet on the one hand we close fisheries and on the other we consider large-scale projects in a known nursery section of the river where the stock is fragile and we know the project will have impacts on larvae and young of the year fish.

Not included in the PISCES report are several other species of concern – two that are currently endangered and use this area of the river extensively. Both the Atlantic and Shortnose sturgeon are found in the bay. Both have long lives, do not spawn annually and are later maturing than most fish making them especially susceptible to impacts. It can take decades to rebuild their stock once it becomes threatened. Atlantic actively use this area of the river as a nursery, the young can remain in the river for as long as 6 years before migrating out. I can validate that their existence in this part of the river as this past summer I held a juvenile sturgeon ~ 12 cm long in my palm – netted right at the top of the bay.

But besides my personal anecdote the DEC fisheries unit together with the US Fish and Wildlife and New England Interstate Water Pollution Control Commission published on this in 2007*. Over the 3 years of sampling included in the study they netted 562 juvenile Atlantic sturgeon – and 90 percent of them right here in Haverstraw Bay. They are found in all substrates in this part of the bay. They prefer soft/deep bottom material but some of their largest single net catches came from hard bottoms and shallow depths – in short they were netted in hard, soft, deep, and shallow water as they move throughout the bay. This is an endangered species and we are considering a project that will most certainly impact their nursery area.

(*reference: Juvenile Atlantic Sturgeon Habitat Use in Newburgh and Haverstraw Bays of the Hudson River: Implications for Population Monitoring 2007, Sweka et al. North American Journal of Fisheries Management 27:1058–1067, 2007)

Entrainment is a strong concern in this nursery stretch of the river. Entrainment means expected loss of fish eggs, larvae and young of year through pulling them into and through the proposed water system – in this type of system it will be an expected 100% mortality. The project proponent reduced the intake slot size to .5 mm, but there will still be impacts in this fragile nursery area. The DEIS notes that in fish biology there are expected egg and larvae loss numbers. Yes in nature there are expected losses – but the losses incurred in the proposed desal project would be on top of normal expected loss. There nothing in the natural cycle that would account for a desal plant – this is an added loss and must be considered this way, not as just incidental, and again in a nursery area of the river.

It is also of concern that the time of year where the DEIS notes the plant would have highest water withdrawal coincides with the period of highest fish egg and larval densities. This means they will have the largest impact on fish kill.

Salinity & toxicity discharge regime –
Circulation modeling has been done but no actual physical assessment has tested the model. Putting things into the river does not wash them away – the tidal nature of the river brings things back every ~ 6 hours, bringing things back & forth and holding them in an area. And Haverstraw Bay is a slow moving section of the river because of its width. In the summer months when the weather is drier (which coincides with the times noted for the largest withdrawal from the proposed plant) the river flushing times are much longer since there is not as much freshwater input from the upper reaches. This can allow plant discharges to linger and build in this slower moving section of the river. Models should be supported with actual testing deploying some ADCPs (acoustic doppler current profilers), especially with this being a sensitive region of the river. Depending on the salinity of the return water it will enter as a plume at the pipe end. The DEIS notes that the discharge could add up to 4-6 psu to the surrounding water. Again there has been no validation of the model on this and potential impacts.

I end my comments by noting that we have been shifting the paradigm away from turning to large corporations who offer as proposed ‘solutions’ large energy intensive plants; who attempt to solve our challenges, but in the end by using the same type of thinking that brought us to where we currently are, adds more problems in the future. Our new paradigm focuses towards partnerships between residents, who need to recognize their role in solving the problem, our elected representatives in government who need to guide the way in setting new structures for change, and our businesses/corporations who need to embrace the public as a partner in moving forward. This is the model the DEC Hudson River Estuary Action Plan has been presenting in their Action Plan, and yet it is not the model we see here.

Let me ask who owns this Hudson River water? Whose water is this? Is it in the public trust? We want to be careful we don’t cause its further decline while it is in our care.

Margie Turrin