ML072640571

Comment of National Resource Education Foundation of New Jersey on Amergens CZMA Consistency Certification, Filed at the Nj Dept of Environmental Protection

ML072640571
Person / Time
Site:	Oyster Creek
Issue date:	03/22/2007
From:	Natural Resource Education Foundation of New Jersey
To:	Heyl A Office of Nuclear Reactor Regulation, State of NJ, Dept of Environmental Protection, Bureau of Coastal Mgmt
References
2130-07-20506, TAC MC7624
Download: ML072640571 (4)

Text

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• NATURAL RESOURC OF NI Mr. Andrew Heyl Land Use Regulation Program Bureau of Coastal Management New Jersey Department of Environmental Protection 501 East State Street Trenton, NJ 08625-0439 E EDUCATION FOUNDATION

,W JERSEY, INC.

7, \\Varctown, NJ 08758 March 222007-

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Dear Mr. leyl,

The Natural Resource Education Foundation of New Jersey, Inc. (NREF), a 501c3, not-for-profit corporation that currently leases the 190 + acre parcel of land known as the Lighthouse Center for Natural Resource Education, in Waretown owned by NJDEP-Division of Fish and Wildlife, is writing this letter in regard to the potential donation of land from Exelon Corporation to Lacey Township (Ocean County). Recently, representatives from Exelon Corporation presented their proposal (that they submitted to NJDEP) for this land donation, to our Board of Directors, and indicated to us the proposal that they have recently set-forth to the NJDEP. We would like to provide comment regarding this pending land donation, and respectfully request that NJDEP consider our ideas, suggestions, and recommendations herein.

It is our understanding that Exelon Corporation proposes to donate 200 acres of land formerly known as "Finninger Farm" and totaling 600+ acres of acquired property adjacent to Route 9 and the Oyster Creek. Power Plant and extending to Barnegat Bay.

The proposed land donation. constitutes the 220 easternmost acres of this parcel, and is dominated by wetlands habitat - both manmade and natural. The proposal suggests that the land be donated to Lacey Township for "public open space" andthat it be subsequently enhanced and developed to provide for the following amenities: 5+ miles of nature trails, parking lot. with an 80+ car capacity, restroom facilities, several ball fields, a boat ramp, and an interpretive/nature center. The estimated cost of improvements was reported as $3-4 million, with the land donation being of approximate equal value, bringing the total proposed donation to $6-8 millions dollars.

The NREF, after significant discussion at a recent meeting, offers the following comments and suggestions regarding this proposal:

The Finniner Farm & Open Space:

As the Trust for Public Land writes in The Century Plan (1995) The Finninger Farm (page 51) is a valuable parcel of land, containing diverse habitats. Of particular

significance are the "old fields which comprise this site's most interesting feature, as they provide habitat for a number of threatened, endangered, or declining birds known collectively as "grassland" species.. In fact, TPL further concludes that a management plan should be developed for maintaining these open field areas.

In all, 137 species of migrant, resident, and transient birds were observed on the site. The property holds intrinsic value as habitat for a large number of species (both terrestrial and aquatic).

The NREF supports this land being preserved as open space, and for making it as "accessible to the public" as reasonable and cost-effective. We (the NREF) are aware that a majority of the 220 acre parcel in consideration is proportionately described as "wetldnds" and, as such, would require a significant amount of permits and improvements prior to be truly "public accessible."

We oppose any degradation or development of wetlands.

In addition, we oppose the investment of building infrastructure funds (estimated at 50%

of the $3-4 million for site improvements) and the inherent expense in its operation of a nature center. The NREF would prefer the establishment of a special fund directing these corporate monies that would be better focused on existing educational, environmental and research programs. Exelon Corporation should apply these funds to the betterment of the surrounding environs through support of research that gathers the necessary scientific data to support.Best Management Practices, policies, and procedures, and through programs and projects that further both the educational opportunities and the public access to preserved open space throughout the Barnegat Bay watershed and the service areaof the Exelon facility.

The NREF's mission is to promote environmental leadership through education, research, interpretation and communication. The NREF offers the following specific suggestions for potential alternative use of the additional investment that Exelon is willing to make:

(i.e. the $3+ million for the construction and operation of a nature/interpretive center and various site improvements proposed for Finninger Farm):

Endangered Species Study and Investigations:

Sea turtles are a primary concern in relation to the mortality of allowable species attributed to nuclear generating stations. This has applicability throughout the. coastal/estuarine areas of the United States where Exelon owns and operates/manages properties. The NREF has a special interest in this area since Drexel University, a renowned leader in this field, is one of NREF's partners. Perhaps Exelon could fund research and data collection that would support and enhance their corporate stewardship of the environs that their operations impact. The current lack of sufficient data to support the continued operations of these lands in coastal areas seems reason enough to support this research.

In addition, it is often that the properties adjacent to their operational facilities are also populated with regionally significant endangered species since these

areas are often made up of a variety of coastal habitats and are undeveloped.

In fact, NJDEP has a program through their Endangered and Nongame Species Program (The Landscape Project, as one example) that seeks to determine and document the "species significance" of each parcel of land in New Jersey. The 600+ acres of land currently owned by Exelon and currently "open space" may indeed have a significant value as wildlife habitat, and perhaps should be valued solely on that merit if determined and documented.

Existing Education and Interpretive Programs:

Again, in accordance with NREF's mission, to "educate and provide hands-on environmental educational experiences" we find a plethora of available and EXISTING programs already in-place for area residents and school groups.

First, and foremost, are the varied and well-designed programs of the NREF through Experience Barnegat Bay at the Lighthouse Center for Natural Resource Education (NREF). With six distinct habitats, complete with outdoor classrooms/I earning stations, interpretive signage, pilot-tested curricula, and significant resources available, the NREF sees little value to duplicating these efforts. The NREF struggles with sufficient funding sources for staff and operations. Perhaps these funds would be better spent supporting existing, local initiatives.

In addition, the Oyster Creek Generating Station property is surrounded by facilities owned by Ocean County and operated by the exemplary staff of Ocean County Parks and Recreation Department. These include: Wells Mills County Park, Eno's County Park, and the soon -to-open (2008) Jake's Branch County Park. These properties offer passive recreation, public access, amenities such as fields, play grounds and restroom facilities, as well as high quality interpretive programs.

NJDEP vs. NJDEP Finally, it would be amiss not to point out that the Lighthouse Center for Natural Resource Education (as well as: Double Trouble State Park, Island.

Beach State Park. Sedge Island Natural Resource Education facility, Barnegat Light State Park, a number of Wildlife Management Areas, Green Acres properties, etc.) are within a very close (less than 5 radial miles) proximity to the property in question, that NJDEP should consider investing in their existing properties. A program similar to the "Barnegat Bay Environmental Grant Fund" which currently offers grants to various local 501 c3/non-profit corporations on an annual basis for specific educational projects is administered by the Trust for Public Land (TPL) on behalf of NJDEP for fines/retribution from Cieba Geigy Corporation. Perhaps a similar fund could be set-up by Exelon on behalf of research and education projects within their customer/use area.

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The NREF is pleased to offer these comments for consideration regarding the pending donation of land to Lacey Township from Exelon Corporation. The NREF sincerely hopes that NJDEP considers these alternative suggestions to this project and offers Exelon the opportunity to modify their proposal and future plan(s) for the properly in question. A fund designated and administered for the sole purpose of supporting, education and research could operate in virtual perpetuity utiliziI.ng only the interest income generated from sound investment. We appreciate your time in reading our correspondence and remain available for additional information and input if appropriate and requested.

Sincerely Submitted, The NREF Board of Directors CC. Mr. James Laird, Public Relations Manager, Exelon Mr. Timothy Rausch, Oyster Creek, Site Vice President Mr. David Chanda, Director, NJDEP Division of Fish and Wildlife Mr. lose Fernandez, Director, NJDEP Division of Parks and Forestry Mr. Michael Mangurn, Director, Ocean County Parks and Recreation