Hercules Testimony Never Given at Roxbury Planning Board

Prepared Testimony for the Public Roxbury Planning Board

My prepared testimony for the public Roxbury Planning Board hearing on the Hartz Mountain application to build a warehouse on the Hercules property was never delivered. The application for the 54-acre warehouse was suddenly withdrawn, so no public meeting regarding the warehouse took place. Here is the testimony I didn't give.

My frustration with the planning board meetings is that all public comments after the testimony at the hearings could only relate to what witnesses and the planning board members presented. The public was allowed to ask questions or express concerns outside of that scope.

This restriction is understandable and necessary for the board's operation, but it remains very frustrating for the public. I was looking forward to an open public planning board meeting. I wrote my comments to highlight a small example of the larger need for a more scientific environmental study of habitats on the Hercules property. 

Comments by:

Brian T. Lynch, MSW
Mine Hill, N.J.
May 1, 2024

I am what the Raritan Headwaters Association (RHA) calls a citizen scientist, volunteering to monitor streams on behalf of the organization. This means I have received specialized training from them and am certified as a stream monitor by the New Jersey DEP. Since 2018, I have been monitoring a section of the Black River located about 150 yards from where it exits the Hercules-Kenvil property.

I believe the Environmental Impact Statement (EIS) prepared by Hertz Mountain Corporation as part of their General Site Permit does not meet the needs of this board. The EIS lacks sufficient site-specific details regarding the fauna and flora that will be affected. An adequate habitat inventory and assessment are missing. My statement tonight is intended to give just one example of why a detailed environmental evaluation matters at this site.

A temperature difference of 5 degrees Celsius, or 9 degrees Fahrenheit, in stream water may seem minor. However, it could spell the difference between survival and extinction for the American Brook Lamprey that inhabits the Black River between Hercules and Sunset Lake.

American Brook Lamprey are ancient freshwater fish that have survived every natural disaster over the past 360 million years. They are virtually unchanged from their earliest fossil records, dating back that far. No one knows precisely how long these “living fossils” have inhabited the Black River in Kenvil, but residents just downstream from Hercules have seen them for generations. 

This should be good news. The American Brook Lamprey are pollution intolerant. Their presence in the stream is the best proof that Ashland Chemical and Roxbury Township have that an array of toxic chemicals in the soil is staying put rather than migrating into the "Great Spring" in the southern wetlands. These fish are also intolerant of high turbidity, high salinity, man-made barriers such as dams, and water temperatures above 20 degrees Celsius, or 68 degrees Fahrenheit. For this reason, the U.S. EPA considers the Brook Lamprey an excellent biological indicator of water quality in our streams. If the waters flowing from the Great Spring on the Hercules property were tainted with toxins, turbid, salty, or too warm, the lamprey would not be present at the RHA monitoring site. Some barriers would prevent them from migrating to the monitoring site from below Sunset Lake. I monitor the stream where water exits Hercules. Each year, my volunteer colleagues and I collect samples for laboratory analysis of the macroinvertebrates living in the stream bed. This section of the stream is not well suited for the HDMI water quality index based on macroinvertebrates analysis because the stream flows over a smooth bed of glacial sand. There are no cobbles or riffles to add oxygen to the water. Because cold water holds more oxygen than warm water, the coolness of this water is critical for all aquatic life in this part of the stream. I also measure the stream's temperature, volume, and turbidity every year. On the warmest June monitoring day in 2022, after three-quarters of an inch of rain fell 18 hours prior, the water temperature was just at 20 degrees Celsius (68 degrees F). This is the upper limit beyond which the American Brook Lamprey cannot survive. Also, the water was only slightly turbid after that rainfall. This observation matters because, up until a few weeks ago, I had never seen an unusual amount of turbidity after a rainstorm at the monitoring site. High turbidity after a rain often signals that soil or sediments are entering the stream in large amounts. On April 13, 2024, I observed substantial turbidity after a significant rainstorm. I photographed the stream and then checked each accessible location where water enters the property. No significant inflow of turbid water was observed there. I photographed those sites as well. This suggests that the soil causing this excess turbidity might be coming from the bioremediation area where acres of soil have been excavated and exposed. If so, this raises the possibility of toxins in the soil migrating off-site. For the lamprey, increased turbidity and potential toxins entering the water pose t

 

Why Else should the Lamprey’s survival matter?

Among the many good reasons, these ancient survivors have one of the most robust immune systems on the planet. Scientists are convinced that lampreys hold genetic secrets that might someday unlock ways to enhance our immunity from diseases. There is an urgency among scientists to study these fish because their numbers are dwindling. They are already listed as an endangered species in several nearby states. In New Jersey, they will soon be listed as a “species of interest.” This will allow the DEP to study them more carefully and determine if they need protection.

My comments here highlight just one example of where the EIS falls short in assessing the potential environmental impacts of the proposed development on the aquatic habitat at Hercules. I ask this board to consider this information as you make your decision on the General Site Plan approval.

POST SCRIPT: Since I wrote this, the NJDEP Fish and Game took an interest in the lamprey in the Upper Black River, conducted a fish survey, and discovered that the stream is also home to first-of-the-year brook trout. The stream's categorization will be upgraded to C1-TP, which is the highest level of pro