Riverkeeper position on the proposed Fjord Trail
January 14, 2025
Mike Dulong
Legal Program Director
In response to the release of the 60% design plan for the proposed Fjord Trail, Riverkeeper has given an abridged version of the following testimony capturing our high level view of the current plans. Our team is reviewing the full proposal in detail and will publish our complete comments on the Draft Generic Environmental Impact Statement (DGEIS) in the coming weeks. The comment period of the 60% design plan is open until March 4 and members of the public can submit their own comments to the NY Department of Parks by following this link.
As a member of the Fjord Trail steering committee, Riverkeeper has seen earlier drafts of designs for sections of the park and provided feedback to the Fjord Trail team at various points throughout the process. Some of our feedback has been incorporated into the current plan and some has not. These periodic updates from the Fjord Trail staff have been the extent of our involvement.
Public Testimony delivered on 1/14/25
Riverkeeper supports the goals of the Hudson Highlands Fjord Trail to facilitate human interaction with nature and with the Hudson River and to increase public safety along the Route 9D corridor. Leisure and recreation on waterfronts and immersion in nature have a positive impact on human health and emotional well-being. Therefore, we acknowledge the vision of the Fjord Trail and its potential to improve public safety, facilitate education and stewardship of the Hudson River, and provide a recreational asset for the region.
However, we have concerns about the project’s impacts on the Hudson River and its wildlife, wetlands, and habitats. Many of these impacts are avoidable depending on the route alternative that is ultimately selected.
1. New fill and pilings and shading would be harmful to the Hudson River and should be avoided.
Under the current plan, “[a]bout one mile of the proposed Fjord Trail South’s two-mile extent would be elevated over the Hudson River shoreline, with piles installed within the water. This includes an approximately one-half mile section southward from Breakneck Ridge and the half-mile section between Little Stony Point and Dockside Park” in Cold Spring. In total, the Fjord Trail South would entail development of 5.8 acres within undeveloped or overwater areas, and an estimated 23,000 square feet (0.53 acres) of the elevated trail sections covering over the Hudson River. “A total of 149 piles would be installed and approximately 1,920 cubic yards of fill would be placed within the Hudson River along this portion of the trail”
The addition of supporting pillars would limit the flow or movement of water and tidal variation in areas already impacted by Metro-North. These pile-supported structures would disturb the riverbed and shade in-water ecosystems along a significant portion of the Hudson’s eastern bank. The affected shoreline is largely engineered rip-rap (large stones used as a breakwater to prevent erosion), which allows for some intertidal and shallow subtidal habitats, providing refuge from waves and predators for a variety of invertebrates and small fishes. The existing rip-rapped shoreline from Cold Spring to Beacon dates back more than a century and, in that time, mature ecosystems have been established. While these habitats are imperfect, disturbing them would harm the river anew.
Riverkeeper is especially concerned that the DGEIS dismisses the impact on endangered shortnose and Atlantic sturgeon species, which would be impacted by construction and the shading caused by the walkway over the Hudson. The project proponent writes that the shoreline in the area is “not within [sturgeon’s] preferred habitat.” This is not accurate as the entire river in the area is a route for sturgeon migration. As the DGEIS correctly notes, the “Hudson Highlands” from Denning’s Point in Beacon south to Stony Point in Cold Spring is a Significant Coastal Fish and Wildlife Habitat (SCFWH) for sturgeon. The State Department of Environmental Conservation describes it as “a critical habitat for most estuarine-dependent fisheries originating from the Hudson River. This area contributes directly to the production of in-river and ocean populations of food, game, and forage fish species.” Constitution Marsh, the Fjord Trail’s southern terminus just south of Cold Spring village, is also classified as Significant Coastal Fish and Wildlife Habitat, and the Hudson River along the Southern Portion of the Fjord Trail provides Essential Fish Habitat for 11 species. In addition to potential immediate impacts on the sturgeon from 18 months of construction and permanent shading and hydrological impacts on the shoreline, the impacts on the established ecosystem and other species will also have indirect impacts on sturgeon. To wholly avoid these impacts, Riverkeeper requests that the Fjord Trail avoid in-water and overwater structures.
2. Protecting and preserving existing wetlands must be a priority.
There are two main trail options for the Fjord Trail North. Option 1 would result in boardwalk crossings over freshwater wetlands south of Fishkill Creek near its confluence with the Hudson River. These are particularly important wildlife areas, especially as they provide habitat for threatened and endangered species, such as the eastern box turtle, spotted turtle, eastern hognose snake, pied-billed grebe, and others. The DGEIS should especially consider the potential presence and impact upon the Atlantic Coast leopard frog, which the state Department of Environmental Conservation recently proposed to be listed as endangered. These critical environmental areas should be avoided. Option 2 leaves freshwater wetlands largely intact, though we acknowledge that Option 2 would result in impacts from steep slopes and stormwater runoff that warrant further scrutiny.
Additionally, we question whether the existing abutments for the walkway over Fishkill Creek could be utilized, as that would avoid additional disturbance, as opposed to the bridge needing to be entirely reconstructed.
3. Impervious surfaces should be avoided entirely.
The Fjord Trail would result in a significant increase in roughly 22.5 acres of impervious and semi-pervious surfaces. Nearly all of the impervious surfaces would be developed for Fjord Trail North, including “five acres of impervious area for parking and trail entry at the Notch, approximately 2.5 acres of impervious area for parking at the new Wade’s Hill Lot, approximately one acre of impervious surface for the proposed maintenance facility along Dennings Avenue in Beacon, and approximately 3.5 acres of impervious areas within Trail Banks to provide Accessibility,” as well as 8-9 acres of crushed stone pathway. Fjord Trail South as proposed would require .75 acres of impervious surfaces for the Washburn Lot expansion and .75 acres of crushed stone path. (Note that the figures for the southern portion do not seem to include the new overwater portions of the path.)
These newly paved parking areas would increase the introduction of contaminants into the river and local wetlands carried by stormwater. Excessive turbidity and nutrients could further exacerbate oxygen demand in the aquatic system. We appreciate that a Stormwater Pollution Prevention Plan and Erosion and Sediment Control Plans will be required, but we have yet to see any details of those plans.
Instead, we urge that the Fjord Trail be constructed with minimal or no new impervious surfaces. Pavement should be avoided where possible including in parking lots where gravel, interlocking pavers, or other pervious materials could be used as an alternative. In the case of the Washburn Lot, the surrounding area is potential habitat for the threatened eastern fence lizard, so an expansion of parking in that area should be avoided.
Riverkeeper protects and restores the Hudson River, and safeguards drinking water supplies through community partnerships, science, and law. Our core programs improve water quality, restore habitat for an abundance of life, and address the impact of climate change on our waterways. Founded in 1966 as the Hudson River Fishermen’s Association, Riverkeeper became the model for more than 320 Waterkeeper organizations around the world and helped establish globally-recognized standards for waterway and watershed protection. We continue to work toward the goal of a swimmable, fishable, and drinkable Hudson River for all. Learn more, get updates, and support our work by visiting riverkeeper.org
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