Monday, April 27, 2009


RE: The Gowanus Canal Superfund Nomination

April 21, 2009

Dear Mr. Munhall,

RE: HQ SSUND 2009-0063



Our names are Lucy DeCarlo, Rita Miller and Triada Samaras. Two of us are third generation Carroll Gardens residents, one is a “newcomer” at only fifteen years. Each of us are property owners. We are all founding members of a grass roots community organization called, CORD (the Carroll Gardens Coalition for Respectful Development). Our organization believes in exactly that…development that is respectful of the environment, context and character of our neighborhood, which is why our group has worked and continues to work very closely with other community organizations as well as the New York City Department of City Planning on the rezoning and preservation of Carroll Gardens.

We would like to begin by thanking you and the EPA for the generously long comment period. Accepting comments until June 6th , allows the residents to compose their thoughts and fully express their feelings toward the nomination of the Canal for Superfund status.

We think that the DEC request to nominate the Gowanus Canal as a Superfund site is the best thing that has ever happened to our neighborhood.

The canal, a cross contaminated aberration displaying the result of the many decades of abuse by pollutants and polluters alike, antiquated, inadequate New York City run infrastructure as well as a great deal of neglect, has presented and continues to present itself as nothing short of a major public health hazard. It is an absolutely appalling, environmental disgrace. It is an open sewer here, in the United States of America, in one of the greatest cities in the world, in this, the 21st Century. How shameful!

For a very long time, we have been told by both elected and civic leaders that the only way to get the canal clean, was to develop it for residential housing----that would be the catalyst in moving the canal toward somewhat, cleanliness. But, there was never any explanation of which mechanism would be put into place exactly to make this happen.

Placement upon the National Priorities List, appears to be the best, indeed, the only mechanism by which the required thorough, comprehensive remediation can be achieved. The word, comprehensive, is by far the most important aspect of what superfund status offers us, as a community.

There has been a great deal of press about one development project in particular and the fact that this developer, has expressed their reluctance to continue with the project if the canal is indeed placed upon the NPL. They have publicly stated that they feel that their project would be stigmatized and therefore unmarketable if the superfund label were placed on the Gowanus Canal.

Simply labeling the Gowanus a superfund site is not going to make anyone view the canal any differently. Any sighted, living creature only has to take a brief glimpse at the canal, even on its best day, to see that there is something terribly wrong with it.

There has also been posturing in the press by some, claiming that those who are for the canal being placed on the NPL are really just against the above mentioned Toll Brothers project and other proposed projects, like, Public Place. They prefer to spin a tall tale by claiming that those who are pro-superfund site status are really anti development factions in disguise, who only want the canal placed upon the NPL to stop all development for their own nefarious reasons.

This is utter nonsense. We are for the superfund designation. We are not anti-any development but, we are against placing densely populated developments on quasi-remediated sites. We believe that comprehensive cleanup should come before any development. We want the canal cleaned, period.

We believe that everyone deserves to live in a healthy, life supporting environment. Clean water is an integral part of that. If the US Government has the means, the inclination and the opportunity to get this job done right-----then, so be it. Should the Toll Brothers, or any other perspective developer, feel that a clean, healthy environment is NOT in the best interests of the community, or, is not necessary for the present and/or future residents, then perhaps they are not really such great new potential neighbors and losing them would not be such a disaster after all.

In regard to Public Place, the chief concern, as indicated by individual CORD members in written statements to NYC’s HPD, during their recent comment period, has always been the following:

An extended period of time in which to measure the success of the land remediation prior to construction is vital. This was not part of the presented plan, even though the DEC admitted that this particular brownfield site was totally unique from any other brownfield site because of its proximity and symbiotic, cross contaminating relationship with the equally, albeit differently, polluted canal.

The EPA’s involvement in this process gives us a much more secure feeling that the upland remediation will now not only be done properly, but, will be vigilantly monitored to insure its success. Since the EPA will be monitoring how effective and successful that upland remediation is by monitoring the cessation (hopefully), of the upland’s contamination of the canal, and vice versa, We feel that everyone working, living or playing upon or near that site can have a much more reasonable expectation of life without risk of health problems due to however well intentioned, what comes down to a partial, piecemeal and therefore, inadequate cleansing of the area.

The fact that the New York State Department of Environmental Conservation initiated the request in the first place speaks volumes. If the State felt that they could effectively do the job alone, or even in conjunction with the City, they would not have felt the need to request that the site be granted Superfund status.

It makes perfect sense to us that a Federal agency be responsible for this project. It is of a nature, size and scope that cries out to and for the US government and its considerable resources.

We were delighted to hear Mr. Walter Mugdan express the readiness and willingness of the EPA to work hand in hand with the state and city of New York on this project, in spite of the fact that Mayor Bloomberg’s spokesman was expressing disapproval and disbelief in the EPA and the Superfund program. This willingness to collaborate on the part of the EPA, in the spirit of getting the best job possible done, further bolsters our confidence that this is the way to proceed.

We are not concerned about the length of time this process will take. It is too important to rush. We are not at all concerned about our property values. The ultimate goal here is a clean, healthy canal and waterfront area. Once accomplished, all in proximity are lifted in value and more importantly, by the healthier environment. Achieving resolution of the canal’s pollution and executing measures to address and improve the inadequate infrastructure whether that be by the implementation of retention basins, treatment stations, separation of sewers from CSO’s, a combination of these, or some other method, is the priority. In our opinion, all else is secondary.

We absolutely and enthusiastically support the nomination of the Gowanus Canal to the National Priorities List and its designation as a Superfund site.

Let us finally move forward and reclaim this unique waterway and surrounding area. Let’s proceed to respectfully develop it to its full potential, and leave something truly valuable to our children, our grandchildren and for all generations to come.

Thank you.


Lucy DeCarlo 13 Second Street

Rita Miller

Triada Samaras


Brooklyn, NY 11231

You may submit your comments on-line to:
or via email at:
For questions contact Dennis Munhall 2 NPL Co-Ordinator at:
Tel. 212-637-4343


With the "Protect Our Homes" petition, CORD was formed in May, 2007. This petition arose as an overwhelmingly negative response to the coming of the over-sized 360 Smith Street Development at the corner of Smith Street and Second Place (Aka Oliver House; aka 131 Second Place). This petition, which had well over three thousand signatures, led to a new zoning text amendment in summer of 2008.

To: Our Elected Officials, Community Leaders, The MTA:
(MAY, 2007)

We the undersigned Carroll Gardens homeowners and residents, are appalled by the "as of right" ruling which allows owners and developers to erect buildings in our neighborhood with no regard to the impact they will present to our quality of life and the value of our homes........