Public Comments and Advocacy Letters


February 17: We informed top officials at the MTA, DEC, and City DOT of the shoreline collapse at 29th street bulkhead. We requested that they; address the urgent unsafe condition of the bulkhead and adjacent roadway (just about 3 feet away from the collapse/open water), rebuild a shoreline that incorporates public access to the water and native habitat restoration through living shorelines in the redesign, and remove the abandoned barges at shoreline.

February 1: We submitted written testimony regarding the Transportation, Economic Development, and Environmental Conservation Part Y “Clarifying the State’s Ban on Single-Use Plastic Bags” budget proposal advocating for the definition of “reusable bags” to not be expanded to include virgin petroleum/plastics industry waste products.


December 17: In our comments regarding Equity Works Former MGP site (manufactured gas plant), we expressed strong concern with remediation methods used in the cleanups of former MGP sites in general, namely the practice of in-situ stabilization, which attempts to trap existing contamination in the ground by mixing a viagra uit india low strength concrete with the contaminated soil. We also included a list of questions specific to this site, and recommendations for both the site and the remediation process in general (eg: best timing for levitra that the DEC invest in studying bioremediation techniques for future remediation projects).

November 21: We support the designation of the Meeker Avenue Plume site as a Superfund, and its addition to the National Priorities List.


December 16: We worked with Riverkeeper on a joint-comment letter against the issuance of Air State Facility permits to National Grid. These permits would enable National Grid to build new 2 Compressed Natural Gas injection heaters and 2 new Liquid Natural Gas vaporizers. We know that increased energy demands do not need to be met by extractive industries, and do not support building new extractive-energy infrastructure.

November 11: We wrote Queens Borough Transportation Commissioner Nicole Garcia opposing the Vernon. Blvd Bulkhead Restoration plan.

April 20: We wrote Hon. Michelle L. Phillips, Acting Secretary to the Commission NYS Public Service Commission, RE: Case 19-G-0309 – KeySpan Gas East Corp. d/b/a National Grid to oppose rate payers paying for Superfund cleanup expenses and infrastructure improvements. National Grid is one of the Potentially Responsible Parties (PRP) identified by EPA as part of the Newtown Creek remediation, and as such they should be paying to clean up the damage they’ve done to the Creek. In this case they’re attempting to raise funds for these expenses from rate payers through a “delivery rate” or “revenue” increase. Secretary Phillips granted Mark, has you ordered this medicine? Do you satisfied cialis daily dosage pharmacy. We would strongly recommend you to consult your doctor before taking a medication. an extension to National Grid, until April 15, 2022. All legal documents for the case are available here, along with a fact sheet here.

April 9: We expressed our frustration with the Vernon Blvd Bulkhead Restoration plan proposed to Queens Community Board 2 by the city for its disregard of existing community-led design and visioning plans for the site. These plans focus on creating public access to the water on this city-owned shoreline, and center green infrastructure through increased (native) planted areas to achieve similar storm water management goals through alternative means. We oppose any plan for the site that fails to generate these public viagra online benefits.

January 13: We do not believe that water quality standards for Newtown Creek are adequate, and definitely don’t support their weakening. We told DEC this, and to advocated for improved and increased engagement with the impacted communities as many were left out of (and uninformed of) this proposed reduction in water quality standards.


December 2: We expressed our concern that Citywide & East River/Open Waters LTCP (which touches every borough of New York City) will not appropriately address the billions of gallons of CSO which are discharged every year, and submitted these comments on the DEP’s Retained Alternatives Summary for the Citywide/Open Waters CSO Long Term Control Plan to Commissioner Sapienza. (According to this plan, the volume of CSO discharged to certain East River areas is set to increase with the existing approvals of other approved LTCPs, namely Newtown Creek and Bronx River! City-wide levels of CSO need to be drastically reduced in order to achieve a harbor where all residents can safely interact with their local waterway.)

July 31: Willis delivered comments on the 2019 National Grid Rate Case at CUNY School of Law in strong opposition to National Grid’s proposal to offload 100% of their Superfund costs onto their customers viagra professional pfizer through rate increases. As a responsible party in the Superfund they are required to pay to remediate the historic pollution they left behind. Making their customers who live with these toxins is unacceptable. We also demanded that they finish the Renewable Natural Gas Project at the Newtown Creek Wastewater Treatment Plant, and that there be more financial transparency for this project.

May 10: We wrote the NYSDEC with our concerns that the proposed cleanup of ExxonMobil OU-3* will not result in a cleaner (or usable) waterway. All upland sites, like OU-3, need to be properly remediated to prevent future recontamination of the Creek. The proposed methods (capping the contaminants at the bottom of the Creek, and storing/cleaning contaminated water in temporary recovery wells) will likely result in PCB migration to the Creek when groundwater begins flowing in its natural direction (towards the Creek) again as recovery wells are taken off-line. We also requested a full PCB removal in conjunction with bulkhead replacements in the area.


August 6: The DEC proposed removing Newtown Creek from List of Impaired Waters. We wrote in opposition as Newtown Creek is severely impaired, naming the following 4 key reasons why in the letter: (1) work to begin designing CSO alternatives must begin now, not sometime in the next 24 years, (2) floating trash is pervasive across the Creek, posing both health risks to wildlife and a major deterrence for recreational purposes, (3) dissolved oxygen levels are uninhabitably low, we need a drastic reduction to CSO volumes and improved natural function of the Creek to improve it, and (4) CSO leads to large amounts of sewage related bacteria within the water body, that pose a direct threat to human and environmental health.

May 2: We wrote to permitting authorities and representatives from the Division of Marine Resources at NYSDEP, requesting that they allow oyster garden permits in contaminated/Superfund waterways for their environmental and public educational benefits. We inform them of the great population of wild oysters that have returned to the mouth of the Creek. We believe that the value of adding oysters to our waterways should not be overshadowed by the potential for human contamination, especially when appropriate education and signage covering the risks of consuming contaminated fish and shellfish is and can be made more accessible.


October 23: We sent additional LTCP feedback to DEP Commissioner Sapienda, ccing DEC Commissioner Seggos. We questioned the utility of a CSO plan that will only address 62.5% of (current) discharge from the 3 largest outfalls on Newtown Creek, and will complete the insufficient remediation over 25 years. We do not believe that a redirection of the Dutch Kills CSO into neighboring waterways counts as an elimination of the CSO or issues related to CSOs. Finally, we argued for the inclusion of GI solutions to many water quality issues.

September 3: We submitted Comments on Former Pratt Oil Works , DEC Site #S241115 Operable Units 01, 02 to the NYSDEC’s Division of Environmental Remediation documenting numerous instances of petroleum discharge into open water and seeping through shorelines. We urged the DEC to enforce penalties to fund intertidal habitat restoration and support impacted wildlife through a living shoreline and/or ecologically inclusive bulkheads. We firmly believe that any release of NAPL or hazardous substances into local waterways is not acceptable.

May 31: We submitted our feedback on the Long-Term Control Plan (LTCP) to DEP Commissioner Sapienza. We request 100% CSO recapture from the largest 3 outfalls on the Creek: NCQ-077 (Maspeth Creek), NCB-083 (East Branch) and NBC-015 (English Kills), storage tanks to hold the recapture, an expansion of green infrastructure, an expansion of soft shorelines, oppose increased aeration and the proposed potential use of chlorination, and oppose the LTCP’s method of finding solutions to meet individual issues’ (ie: fecal coliform and dissolved oxygen levels) acceptable standards (ie: through aeration and chlorination) in favor of complete and comprehensive remediation of the root cause of multiple issues (ie: investing in directly reducing CSO outflow).


February 13: We did not believe that human health was being prioritized by the proposed remediation actions for (Newtown Creek Superfund Site) Operable Unit One (OU-1) and adjacent sites of the Greenpoint Petroleum Remediation Project.


June 9: We wrote in opposition to aeration as a strategy for long-term water quality control, requesting that the NC-3 aeration project for East Branch project at least be delayed until the forthcoming Newtown Creek Long Term Control Plan be released.

February 11: Instead of expanding aeration into the Dutch Kills tributary, we wrote DEC and DEP to request that the issue of low dissolved oxygen levels be addressed through ecologically-supportive, “green” methods.