National Park Service

U.S. Department of the Interior

Statue of Liberty National Monument and Ellis Island

E LLIS I SLAND

DEVELOPMENT

C ONCEPT P LAN

F INAL ENV IRONMENTAL IMPACT STATEMENT
UNITED STATES DEPARTMENT OF THE INTERIOR 

NATIONAL PARK SERVICE 

DEVELOPMENT CONCEPT PLAN 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

New York Harbor, States of New York and New Jersey 

Lead Agency: Department of the Interior, National Park Service, Northeast Region 

This Development Concept Plan / Final Environmental Impact Statement has been prepared by the National Park 

Service (NPS) to consider alternative adaptive reuses for the 30 remaining vacant and deteriorating buildings of 

Ellis Island and access to the island. 

This environmental impact statement evaluates three alternatives regarding the future of the vacant historic 

buildings of Ellis Island. “Alternative 1: No Action — Continuation of Existing Management Direction,” 

describes the conditions after only temporary stabilization of the buildings and the existing vehicular service 

bridge. The eventual result of no action is the complete or near-complete loss of these resources as the effects of 

temporary stabilization expire. This alternative provides a basis of comparison to judge the potential impacts of 

the two “action” alternatives. Both action alternatives would include a new service bridge to New Jersey for 

emergency and service vehicles; the no-action alternative would not. “Alternative 2: Ellis Island Partners — Day 

Use Only,” describes conditions that would result after the buildings are rehabilitated as a campus for multiple 

nonprofit / institutional uses complementing the historic themes of Ellis Island. “Alternative 3: Ellis Island 

Institute with Overnight Accommodations” (the preferred alternative), describes conditions if the buildings were 

rehabilitated as a conference/retreat center. The facilities would have overnight accommodations to host 

meetings, retreats, and workshops primarily focusing on issues such as immigration, world migration, public 

health, family history, historic preservation, and the environment. The preferred alternative would accomplish 

the goals and objectives set forth in the NPS 1982 Statue of Liberty National Monument General Management 

Plan and would offer the greatest potential for long-term economic viability. 

The Development Concept Plan / Draft Environmental Impact Statement was available for public comment for a 

period of 60 days in the summer of 2003. All substantive comments have been addressed in the “Consultation 

and Coordination” chapter of this Development Concept Plan / Final Environmental Impact Statement. 

Thirty days after the Notice of Availability of this Development Concept Plan / Final Environmental Impact 

Statement is printed in the Federal Register, the National Park Service will sign and publish its Record of 

Decision in the Federal Register. At this point the National Park Service will move forward with the Service’s 

Partnership Construction Process and other required reviews for a partnership development project. In 

accordance with the Partnership Construction Process, implementation of the selected alternative will be subject 

to the findings of additional market analysis and feasibility studies to confirm the economic and programmatic 

viability of the project. The Service has been working with Save Ellis Island, Inc. to have this organization be the 

non-profit partner for implementation of the selected alternative. 

Following the Record of Decision, NPS also will begin consultation, planning, and environmental analysis for 

design of the permanent service bridge. 
FINAL ENVIRONMENTAL IMPACT STATEMENT iii

EXECUTIVE SUMMARY 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

FOR THE STATUE OF LIBERTY NATIONAL MONUMENT 

AND ELLIS ISLAND DEVELOPMENT CONCEPT PLAN 

INTRODUCTION 

Ellis Island occupies a singularly unique place in 

America’s heritage. It was the primary United States 

immigration station from 1892 to 1954 when more 

than 12 million people passed through the 

immigration station complex—the greatest wave of 

migration in this country’s history. Today, 40% of 

Americans can trace their family history via Ellis 

Island. In 1965 President Lyndon Johnson added 

Ellis Island to the national park system as a part of 

the Statue of Liberty National Monument. This was 

done in recognition of its significance in American 

history, architecture, and culture. 

When Ellis Island closed in 1954, abandonment led 

to a period of severe decline. In 1990, following 

extensive rehabilitation, the Main Building was 

reopened to the public as the Ellis Island Immigration 

Museum, and subsequently, two adjacent buildings 

were rehabilitated as administrative offices. The 

many remaining structures in the historic 

immigration station complex, however, remain 

abandoned and threatened. 

NEED FOR THE ACTION 

In recent years, concern for the accelerating rate of 

deterioration helped to rally private, state, and federal 

support for a program of temporary stabilization for 

the island’s 375,000 square feet of vacant buildings 

and corridors. The need for the temporary 

stabilization program prompted the National Park 

Service (NPS) to identify a range of reuse 

alternatives that would lead to long-term 

rehabilitation and reuse of these buildings in order to 

expand visitor experiences and provide some level of 

economic sustainability. “Figure ES-1: Ellis Island 

Map Depicting All Structures” identifies the 

structures included in this Development Concept 

Plan / Final Environmental Impact Statement. 

This environmental impact statement analyzes the 

consequences of continuing to apply only temporary 

fixes for stabilization of the vacant buildings and 

service bridge for another 10 to 15 years (as 

prescribed under the no-action alternative) or 

implementing one of the two “action” alternatives 

that propose long-term rehabilitation and reuse. 

PURPOSE AND 

OBJECTIVES OF TAKING ACTION 

The overall purpose of the Development Concept 

Plan is to provide for the long-term rehabilitation, 

reuse, and protection of cultural and historic 

resources on Ellis Island. This statement relates 

directly to the objectives outlined in the 1982 Statue 

of Liberty National Monument General Management 

Plan. The NPS objectives are to 

protect the Island’s cultural and natural resources 

provide for the long-term rehabilitation and 

adaptive reuse of the island’s Beaux-Arts 

campus of integrated brick, stucco, and tile 

structures with connecting corridors of masonry 

and glass, within a designed landscape of lawn 

and mature trees 

provide uses that complement the island’s 

historic themes and related contemporary issues 

and that can be economically sustained 

provide enhanced opportunities for visitors to 

understand and experience Ellis Island’s history, 

including managed public access to most of the 

island’s cultural landscape 

provide a high level of security and safety for the 

visitors, staff, and resources of Ellis and Liberty 

Islands, and the ability to respond quickly in 

emergency situations 

provide thematically appropriate, safe, and 

economically viable access to and from the 

island in support of its adaptive reuse, 

emergency management, and security 

requirements. 
EXECUTIVE SUMMARY

iv STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

ISSUES 

The NPS interdisciplinary planning team identified 

numerous issues through public meetings and agency 

consultations. The following issues were raised 

through scoping: 

Loss of cultural resources if rehabilitation does 

not occur 

Delaying a permanent solution would increase 

costs in the long run 

If the no-action alternative is selected, mitigation 

for the loss of buildings should include 

documentation and interpretation 

The federal government should pay for the 

protection of these buildings 

Loss of bridge access would result in increased 

safety and security concerns 

The plan should not include large-scale 

demolition or new construction 

Jitney access for the public, retreat attendees, and 

lodging guests from Jersey City may raise 

security issues with respect to boarding 

The permanent bridge should allow pedestrian 

access 

The bridge, or parking for the ferry to Ellis 

Island, may affect natural and cultural resources 

of Liberty State Park 

The temporary (or permanent) bridge is not part 

of the cultural landscape and should be 

permanently removed (or should not be 

constructed) 

IMPACT TOPICS 

The following impact topics were analyzed in this 

environmental impact statement: 

Historic Architectural Resources 

Cultural Landscapes 

Archeological Resources 

Geologic Resources and Soils 

Marine Sediments 

Floodplains 

Vegetation / Threatened and Endangered Plants 

Fish 

Wildlife / Threatened and Endangered Wildlife 

Surface Water 

Groundwater 

Air Quality 

Noise 

Hazardous Materials 

Tourism 

Park Administration 

Access to Ellis Island 

Access to Ferry Terminals 

Parking 

Circulation 

Visitor Experience 

Ellis Island Infrastructure 

The following impact topics were considered but 

dismissed from further analysis because no impacts 

from the actions proposed in this environmental 

impact statement would occur: 

Museum Collections 

Wetlands 

Land Use 

Environmental Justice and Population 

ALTERNATIVES 

SELECTED FOR ANALYSIS 

The alternatives presented in this environmental 

impact statement were developed by the NPS staff of 

the Statue of Liberty National Monument and Ellis 

Island. The NPS Management Policies, the park’s 

mission statement and goals, relevant laws and 

regulations, and public input all helped to direct and 

shape the alternatives. 

Alternatives Selected for Analysis

FINAL ENVIRONMENTAL IMPACT STATEMENT vii

SUMMARY OF ALTERNATIVE 1: 

NO ACTION — CONTINUATION

OF EXISTING MANAGEMENT DIRECTION

Under this alternative, maintenance and operations by 

the National Park Service would continue. Current 

stabilization treatment of the abandoned and unused 

buildings would carry on until all buildings have 

been completed. Stabilization of the buildings on 

Island 2 has been completed and is almost complete 

for the buildings on Island 3. The park has been 

exploring options for stabilizing the Baggage and 

Dormitory Building and expects to begin that project 

in 2006. Stabilization measures would include 

temporary ventilated wood and Plexiglas window 

panels to subdue water infiltration and facilitate air 

movement; temporary asphalt shingle roofs on areas 

where the removed original clay tiles would 

eventually be replaced or repaired; repointing of 

existing brick and stone masonry that has failed to 

resist the weather; shoring of compromised or failing 

structural and exterior wall elements; the 

maintenance and temporary repair of gutters, leaders, 

and other water-control techniques; removal and 

control of invasive vegetation that has been damaging 

the structures; and abatement and removal of debris 

and hazardous materials inside the buildings. The 

stabilization procedures are only a temporary strategy 

to slow further deterioration. Depending upon the 

condition of a particular building, stabilization might 

provide a 10- to 15-year period of suspended or 

slowed decay. These ongoing stabilization efforts 

would also include several interventions in the 

corridor system and to the utilities infrastructure. No 

general public access would be allowed in these 

stabilized structures. 

The ongoing NPS efforts to go beyond basic 

stabilization of two of the buildings would also 

continue. The exterior of the Ferry Building already 

has been restored, and the planned interior 

rehabilitation would be completed. The exterior of 

the Hospital Outbuilding and Laundry already has 

been restored, and the plans for interior rehabilitation 

of this building would be implemented. Depending 

on funding/staffing, limited access may be allowed in 

these two buildings, as well as some additional 

exterior grounds 

Under this alternative, the park would continue to 

implement measures to provide a high level of 

security. The existing temporary construction bridge 

would continue to be used, subject to Federal 

Highway Administration inspection and permitting, 

until it could no longer be sustained. At that time, all 

access would be by ferry or barge. 

Ongoing or perpetual stabilization would not be 

regarded as a viable or sustainable option because all 

structures would eventually reach a point at which 

they could not reasonably be reclaimed. While not 

provided for within this no-action alternative, 

demolition and removal would become a logical and 

unfortunate future consequence. This would occur 

when temporary stabilization measures have run their 

course, and efforts to secure funding for 

rehabilitation have been unsuccessful. 

ELEMENTS COMMON

TO ALTERNATIVES 2 AND 3 

The economic feasibility of alternatives 2 and 3 is 

dependent upon the adaptive reuse of the 

30 buildings proposed for restoration. Reuse must 

also be complementary to the island’s historic themes 

and related contemporary issues. Both of these are 

consistent with the objectives identified above, which 

derive from the 1982 General Management Plan. 

The NPS intent to seek a private-sector partner(s) to 

assist in the rehabilitation and maintenance of these 

historic structures, which is an important feature of 

both alternatives, was also first adopted in its 1982 

General Management Plan. 

Both action alternatives would ensure the 

preservation of the defining characteristics of Ellis 

Island’s buildings and their environment while 

providing some flexibility for reasonable and 

economically viable adaptive reuse proposals. The 

overall campus environment of Ellis Island would be 

preserved and its character-defining features would 

be retained, including massing and scale, spatial 

organization and circulation, distinctive spaces and 

architectural features, fenestration, building 

materials, and vegetation patterns. 

There are a number of elements that are consistent 

across alternatives 2 and 3, as both these alternatives 

meet the NPS goals for Ellis Island. The common 

elements are 

Rehabilitation of all Ellis Island resources — 

Alternatives 2 and 3 propose rehabilitation efforts 

that are consistent with the guidelines of The 

Secretary of the Interior’s Standards for the 

Treatment of Historic Properties. 
EXECUTIVE SUMMARY

viii STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Continuation of ferry use — The action alternatives 

propose to continue the historic use of ferry boats by 

both day-use and overnight visitors. 

Equal access provisions — A program would be 

implemented to increase opportunities for lowincome people to visit the site. A variety of methods 

to subsidize ferry fares for these visitors would be put 

into place; this could include free rides for school 

groups in targeted areas, reduced-fare days, and 

special passes. 

Construction of a permanent bridge — A service 

bridge would be constructed in a location to be 

determined by subsequent permitting procedures. The 

bridge would be a key element in the park’s 

emergency management programs, including access 

for emergency vehicles and evacuations from Liberty 

and Ellis Islands. In addition, the bridge would be 

used for operations, construction activities, 

maintenance, and deliveries. Construction of the new 

bridge would occur with or without rehabilitation and 

reuse of Ellis Island’s historic structures. In the case 

of alternative 3, the service bridge would be available 

for pick up and drop off of conference center guests. 

Improvements to infrastructure — Proposals for 

utility infrastructure improvements would be 

provided by the National Park Service, or its 

designated partner, in support of rehabilitation and 

reuse of all remaining vacant and unrestored 

buildings. 

Operating budget increases — Implementation of 

either action alternative would require an increase in 

the park’s annual operating base. 

Additional funding — Annual operating subsidies 

from nonappropriated sources would be needed to 

sustain partnership programs and building 

maintenance. 

Enhanced security — Both action alternatives 

propose a continuation of increased permanent 

security measures to include screening all visitors, 

packages, and vehicles to Ellis Island. Also included 

is the continued implementation of emergency 

evacuation procedures. 

SUMMARY OF ALTERNATIVE 2: 

ELLIS ISLAND PARTNERS – DAY USE ONLY

The Ellis Island Partners concept would be managed 

primarily by the National Park Service and would 

create a campus of multiple nonprofit and 

institutional uses that complement the purposes, 

themes, and significance of Ellis Island. The 

nonprofit organizations and institutions that would 

make up the campus of partners would offer visitor 

programs and exhibits relating to themes such as 

immigrant contributions, worldwide immigration 

issues, ethnic diversity, tolerance, human rights, 

refugees, public health, family history, and other 

topics relating to the significance of Ellis Island. 

Office space for nonprofit organizations and 

institutions would be appropriate under this concept, 

but general commercial office space would not be 

permitted. 

This alternative proposes rehabilitation of Ellis 

Island’s historic buildings and landscape over a 10- 

to 15-year period solely through private fundraising 

and future federal appropriations. A combination of 

partnerships, cooperators, and traditional concession 

operations would provide visitor services, programs, 

and routine maintenance of buildings. The National 

Park Service would have management oversight of 

the entire island. All of the building exteriors would 

be restored and interiors completed to “core and 

shell” condition, which means that interior finishes 

would be provided by future tenants. Over time, and 

as funding permits, all of the unrestored buildings of 

Ellis Island would be rehabilitated and occupied by a 

potentially diverse mix of cultural, educational, and 

other nonprofit institutions. To provide a visual 

comparison for visitors, one or more selected interior 

spaces would be preserved or left in a stabilized 

“ruin-like” condition for future research and 

interpretation. There would be no overnight 

accommodations. 

Outdoor areas would be programmed for themed 

events and festivals. Some visitor services may be 

provided through one or more concession 

agreements. 
Elements Eliminated 

from Consideration

FINAL ENVIRONMENTAL IMPACT STATEMENT ix

SUMMARY OF ALTERNATIVE 3: 

ELLIS ISLAND INSTITUTE WITH 

OVERNIGHT ACCOMMODATIONS

(PREFERRED ALTERNATIVE) 

Alternative 3 was chosen as the preferred alternative 

because it would best accomplish the objectives and 

goals set forth in the General Management Plan that 

was prepared by the National Park Service in 1982. 

In particular, this alternative fulfills to the greatest 

extent of any of the alternatives, objective 3, which 

states that alternatives must be economically 

sustainable. 

An “Ellis Island Institute” would be the primary use 

under this alternative. The institute would be 

developed and managed by a nonprofit partner and 

would provide cultural, interpretive, and educational 

programs and activities. The institute would also 

include a policy research center and administrative 

and study spaces. An associated small conference 

facility and overnight accommodations would be 

developed, financed, and managed by a professional 

hospitality business partner working with the 

nonprofit partner. The facility would host meetings, 

retreats, and workshops that would primarily focus 

on such issues as immigration, world migration, 

public health, cultural and ethnic diversity, and 

family history. The basic difference between 

alternatives 2 and 3 would be alternative 3’s 

provision for a more fully integrated rehabilitation 

program and the use of conventional financing to 

rehabilitate buildings for overnight lodging and 

related facilities for conference participants. In 

addition, state-of-the-art telephone, conferencing, 

Internet communications, and other technological 

amenities would be provided. The island would 

provide a secure world-class venue for deliberation, 

research, and reflection that is minutes away from the 

major cultural, educational, and transportation 

facilities of New York and New Jersey. 

The National Park Service has been working with 

Save Ellis Island, Inc. to have this organization be the 

nonprofit partner for the implementation of the 

preferred alternative. Selection of the business 

partner would be approved by the National Park 

Service, with preference given to proposals that 

would meet the park’s goals and support the mission 

and operation of the nonprofit institute. 

The buildings would be rehabilitated and adaptively 

reused over a five- to seven-year period through a 

combination of private financing, philanthropic 

support, and government appropriations. A market 

analysis (see “Appendix C: Analysis of Relative 

Financial Feasibility and Economic Sustainability of 

EIS Alternatives”) suggests that Ellis Island includes 

many of the critical factors required for making such 

a retreat/conference facility successful, including 

association with large and resonant ideas, signature 

architecture, and uniqueness. 

In accordance with the NPS Partnership 

Construction Process, additional market analysis and 

feasibility studies would be completed to test and 

confirm the economic and programmatic viability of 

the project prior to NPS approval of the project, 

initiation of a capital fundraising campaign by the 

park’s nonprofit partner, and design of facilities. If 

the Partnership Construction Process results in a 

determination that the project as described is not 

feasible, NPS will further consider alternatives for 

management of Ellis Island taking into account the 

information gained from the process outlined above 

and other facts and circumstances then available. 

This further consideration of alternatives will be 

conducted in accordance with applicable 

requirements of the National Environmental Policy 

Act and the National Historic Preservation Act (as 

amended). 

Properly designed to the scale and historic context of 

Ellis Island, an “Ellis Island Institute” and retreat 

facility, in combination with one or more 

thematically related cultural institutions and visitor 

attractions, would restore an appropriate function and 

purpose to Ellis Island, thus ensuring its long-term 

rehabilitation and use. 

ELEMENTS ELIMINATED 

FROM CONSIDERATION 

During the course of developing the plan and three 

alternatives, several alternative elements were 

considered and subsequently eliminated from further 

consideration, including: 

intentional demolition of any structures 

construction of significant new structures 

reuses of buildings for dominant retail and/or 

commercial purposes 

pedestrian use of the service bridge 
EXECUTIVE SUMMARY

x STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

ENVIRONMENTAL CONSEQUENCES 

The potential impacts of each alternative are 

summarized below. 

CULTURAL RESOURCES 

HISTORIC ARCHITECTURAL RESOURCES

In contrast to alternatives 2 and 3, the no-action 

alternative does not provide for a plan of historic 

preservation of the significant cultural resources of 

Ellis Island. The proposed stabilization activities for 

the historic structures would only result in short-term 

benefits to the resources, and long-term preservation 

of cultural resources is not expected. There would be 

the possibility of eventual loss of many, if not all, of 

the Ellis Island properties that are listed on the 

National Register of Historic Places (National 

Register). Although it may not happen during the 15- 

to 20-year life of this plan, eventually, the loss of 

such significant cultural resources is expected to 

result in impairment of NPS resources. When 

compared to alternatives 2 and 3, the no-action 

alternative is decidedly negative in its overall effect 

on historic properties, with long-term major adverse 

impacts anticipated for the region and, possibly, for 

the nation. Conversely, the proposed rehabilitation 

and reuse of the structures on Ellis Island that are 

listed on the National Register, would ensure the 

preservation of National Register cultural resources. 

The ultimate effect of either action alternative—the 

avoidance of the loss of Ellis Island's historic 

structures to unchecked deterioration (the expected 

result of the no-action alternative)—is a major benefit 

compared to the no-action alternative. An additional 

adverse impact of the no-action alternative could 

result from the removal of the temporary service 

bridge connecting Ellis Island with the mainland. 

Historic properties on Ellis Island would be placed at 

higher risk of fire damage/loss due to longer response 

times and less efficient methods of firefighting, a 

potentially major adverse impact not expected under 

alternatives 2 and 3. 

CULTURAL LANDSCAPE

A similar loss of the integrity of the cultural 

landscape, as described for historic architectural 

resources, would occur under the no-action 

alternative. In contrast to alternatives 2 and 3, this 

alternative does not provide for a plan of historic 

preservation for the cultural landscape of Ellis Island, 

and the possibility of its eventual loss exists. When 

compared to alternatives 2 and 3, the no-action 

alternative is decidedly negative in its overall effect 

on the cultural landscape of Ellis Island, with major 

adverse impacts anticipated for the region and, 

possibly, for the nation. Of the three alternatives, the 

no-action alternative would result in the highest risk 

to the cultural landscape of Ellis Island. Due to the 

lack of a long-term preservation strategy under this 

alternative, the eventual loss of the cultural landscape 

is likely and would be expected to result in 

impairment of NPS resources. Cultural landscape 

rehabilitation efforts under either action alternative 

would provide major benefits by conserving the 

major features of the cultural landscape intact. 

Despite the postponement of the removal of the 

temporary service bridge, the no-action alternative 

would result in its eventual removal, a benefit for the 

cultural landscape of Ellis Island and surrounding 

areas. This positive effect would not be realized 

under alternative 2 or 3, as both propose a permanent 

bridge replacement. The bridge would perpetuate the 

diminished nature of the water space between the 

island and the mainland, negatively affecting Ellis 

Island and surrounding National Register properties 

(Statue of Liberty, CRRNJ Terminal). At the same 

time, the presence of a bridge (under alternative 2) 

would provide a higher degree of protection from fire 

damage/loss for Ellis Island's cultural resources. This 

is an unknown, but possibly major positive effect 

compared to the no-action alternative. 

TERRESTRIAL AND MARINE 

ARCHEOLOGICAL RESOURCES

The no-action alternative is not believed to have the 

potential to adversely affect archeological resources 

in a manner that would jeopardize their National 

Register characteristics. When compared to 

alternatives 2 and 3, in which ground-disturbing 

activities are likely, it is believed that the risk to 

archeological resources on Ellis Island would be 

minimized under the no-action alternative. Smallscale dredging in the ferry slip proposed under 

alternatives 2 and 3 has the potential to result in 

minor site-specific adverse impacts because of its 

potential to affect buried cultural deposits. No 

impairment of park archeological resources would 

occur under any alternative. 
Natural Resources

FINAL ENVIRONMENTAL IMPACT STATEMENT xi

NATURAL RESOURCES 

GEOLOGIC RESOURCES AND SOILS

All three alternatives anticipate the removal of the 

temporary service bridge and the sealing of the gap in 

the existing floodwall guarding Liberty State Park 

where the bridge landing now exists. Negligible 

impact on soils would occur from filling the seawall. 

In alternatives 2 and 3, additional negligible to minor 

impacts on soils would result from excavating for 

new underground utility connections, grading new 

access roads to the landings at Liberty State Park and 

Ellis Island, and from grading for construction 

staging areas. No impairment of park soils or geology 

would occur. 

MARINE SEDIMENTS

Localized negligible or minor temporary disturbance 

to marine sediments in the channel between Ellis 

Island and the state park would occur from removing 

pilings for the temporary service bridge under all 

three alternatives. Disturbance and increases in 

turbidity would continue under alternatives 2 and 3 

because in-channel work, including the installation of 

new pilings, would be required. No marine sediments 

are part of the park; therefore, no impairment of park 

marine sediments is possible, although impacts would 

also be no more than minor. 

FLOODPLAINS

Removing the temporary service bridge and sealing 

the floodwall could result in minor beneficial impacts 

from flood prevention under any of the alternatives. 

During extreme weather events, it is possible that the 

new permanent bridge proposed under alternatives 2 

and 3 could experience some flooding and reduced 

access. No impairment of park floodplains would 

occur under any alternative. 

VEGETATION

Under the no-action action alternative, it is expected 

that negligible to minor impacts on vegetation could 

occur from clearing for construction staging 

associated with stabilization efforts and removal of 

the temporary service bridge. Those impacts 

associated with bridge removal would also occur 

under the two action alternatives. Additional 

negligible to minor losses of open field vegetation 

would be likely from the creation of landing sites and 

access roads and from construction staging areas for 

building a permanent bridge and rehabilitating 

buildings on Ellis Island. 

No impacts on threatened or endangered vegetation 

are expected from the no-action alternative. 

However, minor to moderate localized impacts from 

the loss of two state protected plant species (Canada 

hawkweed and Ohio spiderwort) are possible from 

the planting of restored courtyards on Ellis Island 

under either alternative 2 or 3. These impacts could 

be eliminated or reduced to negligible through 

avoidance, replanting individuals, or improving offsite habitat. No impairment of park vegetation would 

occur. 

FISH

Removal of the temporary service bridge, under any 

alternative, could result in minor to moderate shortterm impacts on fish in the immediate area of 

construction from direct activity, increases in 

turbidity, and suspension of toxins. Additional 

moderate short-term impacts on fish in the channel 

between Ellis Island and the New Jersey shoreline, 

and a longer period of impact than under no action, 

could result from building the permanent bridge 

under alternatives 2 and 3. No impairment of park 

fisheries would occur. 

WILDLIFE

Minor impacts on unprotected wildlife are expected 

from construction to remove the temporary service 

bridge in all alternatives, particularly in Liberty State 

Park. The state protected Savannah sparrow could 

experience minor short-term effects, and other 

seasonal residents and migrants could experience 

negligible to minor impacts. Additional displacement 

through habitat removal and increased human activity 

from the construction and operation of bridge 

landings for the permanent bridge could result in 

additional long-term negligible to minor effects at 

both the state park and on Ellis Island under either 

action alternative. Savannah sparrows may 

experience short-term moderate effects, and other 

seasonal residents and migrants could experience 

minor impacts. Depending on the bridge alignment, 

Savannah sparrows may suffer long-term minor 

impacts resulting from loss of habitat and the 
EXECUTIVE SUMMARY

xii STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

additional presence of humans and traffic. 

Landscaping courtyards on Ellis Island under 

alternative 2 or 3 would remove habitat for some 

wildlife species, with possible long-term minor 

adverse impacts. Additional negligible to minor 

impacts from the continual presence of humans 

throughout the night could also occur to Ellis Island 

wildlife if alternative 3 were adopted. No impairment 

of park wildlife resources would occur. 

SURFACE WATER

Removal of the temporary service bridge could result 

in minor to major localized increases in turbidity in 

surface marine water during the construction period 

for all alternatives. Fuel leaks or petroleum releases 

from heavy equipment could result in negligible 

degradation of surface water near construction sites. 

Additional moderate impacts on surface water quality 

could result from construction of the permanent 

bridge, and minor impacts from construction of 

additional staging areas, roads, and rehabilitation 

could occur under alternatives 2 and 3. In the long 

term, impacts on surface water would be nonexistent 

or negligible. No impairment of park surface water 

would occur. 

GROUNDWATER

The no-action alternative would have no impact on 

groundwater. Alternatives 2 or 3 could result in 

negligible to major impacts on local groundwater 

supplies if construction of the permanent bridge 

requires excavation in an area where groundwater 

tables are high, which might then require extensive 

pumping. Dewatering or contamination of the aquifer 

from pumping are possible outcomes. Additional 

testing and National Environmental Policy Act

(NEPA) analysis would be required to determine 

features of the aquifer, mitigation, and whether 

impairment is possible. Such analysis is anticipated 

for site-specific analysis of the permanent bridge. 

AIR QUALITY

Compared to existing conditions, emissions from 

construction equipment and increased car traffic 

related to increased visitation under any alternative, 

would probably not be detectable any further than the 

immediate construction area. Emissions from these 

same sources would be about 5% higher under 

alternatives 2 and 3 compared to the no-action 

alternative. No impairment of park air quality would 

occur. 

NOISE

Long-term increases in noise are expected to be 

negligible; however, noise during construction may 

be severe on a short-term basis. Very loud noise 

impacts would continue at least twice as long under 

alternative 2 or 3 than under no action but would be 

temporary in any of the alternatives. No impairment 

of park wildlife or visitor experience would occur as 

a result of noise. 

HAZARDOUS MATERIALS

Resuspension of marine sediments during removal of 

the temporary service bridge pilings could result in 

negligible to minor increases in concentrations of 

toxic or carcinogenic chemicals in surface water 

under any of the alternatives. These same effects 

could also occur from installing pilings for the 

permanent bridge proposed in alternatives 2 and 3. 

The impact would decrease when the sediments 

resettle. Workers could also encounter soils 

contaminated with chromium and other dangerous 

toxins during construction of landings and access 

roads for the permanent bridge. If a mitigation plan is 

put into place and followed, impacts could be minor 

or moderate. Encapsulating contaminated fill 

following construction would eliminate the risk of 

exposure in the long term. Stabilization of buildings 

in the no-action alternative, and rehabilitation in 

alternatives 2 and 3, would risk exposure of workers 

to asbestos and lead-based paint. With the use of 

standard precautions, this risk would be negligible. 

No impairment of park resources from exposure to 

hazardous materials would occur. 

SOCIAL AND ECONOMIC RESOURCES 

Under the no-action alternative, tourism at Ellis 

Island would likely continue to increase by a 

negligible to minor amount each year over the life of 

the plan. Extended programming and activities 

offered under alternatives 2 and 3 would result in a 

minor benefit to tourism from increased visitorship to 

and around Ellis Island, as well as increased demand 

for lodging in the New Jersey / New York area. 

Removing the temporary service bridge could 
Summary Conclusions

FINAL ENVIRONMENTAL IMPACT STATEMENT xiii

increase emergency response times by up to 10 times, 

resulting in possible major impacts depending on the 

event and need for emergency services. Compared to 

this, building a permanent bridge would result in a 

benefit of unknown intensity, possibly major, to park 

administration in the ability to provide emergency 

assistance. The convenience the bridge would offer 

for non-emergency access is considered a minor 

benefit to park administration. No impairment of park 

resources would occur. 

TRANSPORTATION AND CIRCULATION 

Removal of the temporary service bridge under the 

no-action alternative could result in minor to 

moderate increases in ferry traffic and decreases in 

car and truck traffic to Ellis Island in the long term. 

Negligible to moderate short-term impacts on access 

for staff and delivery vehicles could result from 

bridge removal and reconstruction of a permanent 

bridge under alternatives 2 or 3. Compared to no 

action, the impact would be relatively beneficial 

because it would only be temporary. 

Negligible impacts on parking may occur at Liberty 

State Park from increased visitation under the noaction alternative. Minor impacts on parking in 

Liberty State Park would occur from increases in 

visitation expected from either action alternative. 

Undetectable to negligible impacts on levels of 

service at intersections in the area are attributable to 

increased visitation resulting from any of the 

alternatives. 

VISITOR EXPERIENCE 

Minor adverse impacts on visitor experience would 

continue to occur under the no-action alternative 

from a lack of access to the larger experience of Ellis 

Island’s historic structures and cultural landscape. 

Under alternative 3, the combination of significantly 

increased visitor access to the majority of Ellis 

Island, the expansion of interpretive offerings, and 

the provision of a conference facility with overnight 

lodging could result in a major benefit to the visitor 

experience at Ellis Island. With the exception of 

overnight lodging accommodations, similar benefits 

to visitor experience are expected under alternative 2. 

When compared to the no-action alternative, where 

both access and interpretive offerings would be 

limited, alternative 3 would provide a significantly 

more enhanced visitor experience. 

All three alternatives would result in minor impacts 

on visitor experience from construction noise and 

dust associated with bridge removal, construction of 

a permanent bridge in alternatives 2 and 3, and 

stabilization or rehabilitation of the buildings on Ellis 

Island. No impairment of park resources or values 

would occur. 

INFRASTRUCTURE 

The upgrading and improvement of utilities proposed 

under alternatives 2 and 3 are considered moderate 

benefits to the Ellis Island infrastructure and would 

complement the rehabilitation efforts of historic 

structures proposed for reuse under these alternatives. 

SUMMARY CONCLUSIONS 

Fifty years of neglect have taken a toll on Ellis 

Island’s abandoned buildings and landscape. Today, 

however, a window of opportunity exists—interim 

stabilization measures, combined with the 

determination of highly motivated nonprofit and 

governmental partners, have created the opportunity 

for what may be the last best chance to save these 

historic treasures. This plan honors the legacy of Ellis 

Island and sets the stage for the restoration and 

adaptive reuse of the entire historic immigration 

station complex. It builds upon earlier NPS efforts to 

identify a long-term feasible solution for preserving 

these historic structures and to ensure that comments 

expressed during previous public meetings and 

agency consultations are reflected in the plan. 

The plan calls for primary reuses based on sound 

business practices and response to the island’s 

historic themes. Visitors and retreat participants 

would have a greater understanding of Ellis Island’s 

history as an all-encompassing immigration operation 

that functioned like a city—welcoming, screening, 

and caring for millions of immigrants to this country. 

Buildings once used as dormitories and hospital 

wards for immigrants would be adaptively reused for 

interpretation, research, meetings, retreats, and 

conferences that would primarily focus on issues that 

might include public health, world migration, 

immigrant contributions, and ethnography and family 

history. More than a museum, Ellis Island would 

provide an ideal setting to explore related 

contemporary issues such as racial and ethnic 

tolerance, civic responsibility, and the American 

experience. 
EXECUTIVE SUMMARY

xiv STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

This plan is just a framework; it will not be achieved 

without broad support and participation of state and 

local governments, the preservation community, 

private sector, and concerned citizens. The 

institutions proposed in this plan would have to be 

conceived and supported by others—and it will be 

expensive. With constraints on public expenditure at 

all levels of government, implementation of the 

vision set forth in this plan will depend on multiple 

funding sources, including conventional financing 

and philanthropic support. To ensure economic and 

programmatic viability, the project’s proposals would 

be evaluated through market analysis and feasibility 

studies, and the project would be designed and 

phased accordingly. If these market analysis and 

feasibility studies results in a determination that the 

project as described is not feasible, NPS will further 

consider alternatives for management of Ellis Island 

taking into account the information gained from the 

process outlined above and other facts and 

circumstances then available. This further 

consideration of alternatives will be conducted in 

accordance with applicable requirements of the 

National Environmental Policy Act and the National 

Historic Preservation Act (as amended). 

Through continued due diligence, shared vision, and 

cooperative action, Ellis Island would again be put 

into the service of a nation. 
FINAL ENVIRONMENTAL IMPACT STATEMENT xv

CONTENTS 

PURPOSE OF AND NEED FOR THE ACTION 

INTRODUCTION ..................................................................................................................................................3 

BRIEF HISTORY OF ELLIS ISLAND ..........................................................................................................3 

Recent Administrative History .............................................................................................................6 

PURPOSE OF AND NEED FOR THE ACTION...........................................................................................7 

CONSTRAINTS..............................................................................................................................................8 

ISSUES AND IMPACT TOPICS.........................................................................................................................10 

ISSUES RAISED BY SCOPING..................................................................................................................10 

Loss of Cultural Resources.................................................................................................................10 

Costs of Postponing Permanent Treatment.........................................................................................10 

Mitigation for Loss .............................................................................................................................10 

Federal Government Responsibility for Rehabilitation ......................................................................10 

Loss of Service Bridge Access ...........................................................................................................10 

Loss of Historic Resources .................................................................................................................11 

Security Concerns...............................................................................................................................11 

Pedestrian Access ...............................................................................................................................11 

Protection of Liberty State Park’s Natural, Recreational, and Scenic Resources ...............................11 

Bridge as an Intrusion.........................................................................................................................11 

IMPACT TOPICS ANALYZED...................................................................................................................11 

Historic Architectural Resources ........................................................................................................11 

Cultural Landscape .............................................................................................................................11 

Archeological Resources ....................................................................................................................12 

Geologic Resources and Soils.............................................................................................................12 

Marine Sediments ...............................................................................................................................12 

Floodplains .........................................................................................................................................12 

Vegetation / Threatened or Endangered Plants...................................................................................12 

Fish .....................................................................................................................................................12 

Wildlife / Threatened or Endangered Wildlife ...................................................................................12 

Surface Water .....................................................................................................................................12 

Groundwater .......................................................................................................................................12 

Air Quality..........................................................................................................................................12 
CONTENTS

xvi STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Noise...................................................................................................................................................12 

Hazardous Materials ...........................................................................................................................13 

Tourism...............................................................................................................................................13 

Park Administration............................................................................................................................13 

Access to Ellis Island..........................................................................................................................13 

Access to Ferry Terminals ..................................................................................................................13 

Parking................................................................................................................................................13 

Circulation ..........................................................................................................................................13 

Visitor Experience ..............................................................................................................................13 

Ellis Island Infrastructure....................................................................................................................13 

IMPACT TOPICS DISMISSED ...................................................................................................................13 

Museum Collections ...........................................................................................................................13 

Wetlands .............................................................................................................................................13 

Land Use.............................................................................................................................................14 

Environmental Justice.........................................................................................................................14 

Population...........................................................................................................................................14 

RELATIONSHIP TO OTHER PLANS AND POLICIES....................................................................................15 

BACKGROUND...........................................................................................................................................15 

1982 General Management Plan.........................................................................................................15 

Updated General Management Plan ...................................................................................................15 

Internal Draft Environmental Impact Statement, Ellis Island Bridge and Access Alternatives, 

Statue of Liberty and Ellis Island, August 25, 1995 ....................................................................15 

Governors Island National Monument................................................................................................16 

National Parks of New York Harbor Initiative ...................................................................................16 

Restoration of the Ferry Building and the Hospital Outbuilding and Laundry...................................16 

Ferry Passenger Security Screening....................................................................................................17 

Stabilization Planning.........................................................................................................................17 

Utility Infrastructure Planning ............................................................................................................17 

Seawall Rehabilitation ........................................................................................................................17 

Liberty State Park Transportation Master Plan Update ......................................................................18
Contents 

FINAL ENVIRONMENTAL IMPACT STATEMENT xvii

ALTERNATIVES

INTRODUCTION ................................................................................................................................................21 

RANGE OF ALTERNATIVES ....................................................................................................................21 

Mitigation Measures and Development Constraints...........................................................................21 

Facility Design....................................................................................................................................21 

Resource Protection............................................................................................................................22 

IMPLEMENTATION PRIORITIES .............................................................................................................22 

ALTERNATIVE 1: NO ACTION — CONTINUATION OF EXISTING MANAGEMENT DIRECTION ......23 

GENERAL CONCEPT .................................................................................................................................23 

The Later Years ..................................................................................................................................23 

Visitor Experiences and Uses .............................................................................................................23 

Management and Operations ..............................................................................................................24 

Access.................................................................................................................................................24 

Costs ...................................................................................................................................................24 

Summary.............................................................................................................................................24 

ELEMENTS COMMON TO ALTERNATIVES 2 AND 3 .................................................................................29 

VISITOR EXPERIENCES AND USES........................................................................................................29 

Interpretation ......................................................................................................................................29 

Cultural/Educational...........................................................................................................................29 

Dining/Food Service...........................................................................................................................29 

MANAGEMENT AND OPERATIONS .......................................................................................................30 

Utility Infrastructure ...........................................................................................................................30 

Increased Security...............................................................................................................................30 

ACCESS........................................................................................................................................................30 

Service Bridge for Emergencies and Operations ................................................................................30

COSTS...........................................................................................................................................................31 

ALTERNATIVE 2: ELLIS ISLAND PARTNERS — DAY USE ONLY...........................................................32 

GENERAL CONCEPT .................................................................................................................................32 

Visitor Experiences and Uses .............................................................................................................32 

Management and Operations ..............................................................................................................32 

Access.................................................................................................................................................35 

Costs ...................................................................................................................................................35 
CONTENTS

xviii STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Summary.............................................................................................................................................35 

ALTERNATIVE 3: ELLIS ISLAND INSTITUTE WITH OVERNIGHT ACCOMMODATIONS 

(PREFERRED ALTERNATIVE)..............................................................................................................36 

GENERAL CONCEPT .................................................................................................................................36 

Visitor Experiences and Uses .............................................................................................................36 

Management and Operations ..............................................................................................................39 

Access.................................................................................................................................................39 

Costs ...................................................................................................................................................39 

Project Feasibility / Due Diligence.....................................................................................................40 

Summary.............................................................................................................................................41 

ALTERNATIVES ELIMINATED FROM FURTHER CONSIDERATION ...............................................41 

Substantial New Construction ............................................................................................................41 

Demolition..........................................................................................................................................42 

Dominant Retail or Commercial Office Uses.....................................................................................42 

Pedestrian Use of Service Bridge .......................................................................................................42

AFFECTED ENVIRONMENT 

INTRODUCTION ................................................................................................................................................57 

HISTORIC SIGNIFICANCE OF ELLIS ISLAND.......................................................................................57 

LAND USE ...................................................................................................................................................58 

On-Site Uses.......................................................................................................................................58 

Liberty State Park ...............................................................................................................................58 

Grand Jersey Medical Center..............................................................................................................58 

Jersey City ..........................................................................................................................................59 

POPULATION ..............................................................................................................................................59 

State of New Jersey ............................................................................................................................59 

Hudson County ...................................................................................................................................59 

Jersey City ..........................................................................................................................................59 

New York County...............................................................................................................................60 

ENVIRONMENTAL JUSTICE ....................................................................................................................60 

AFFECTED ENVIRONMENT............................................................................................................................61 

CULTURAL RESOURCES..........................................................................................................................61 

Regional Environment ........................................................................................................................61 
Contents 

FINAL ENVIRONMENTAL IMPACT STATEMENT xix

Environment within the Project Area .................................................................................................62 

Historic Architectural Resources ........................................................................................................63 

Defining Architectural Characteristics ...............................................................................................64 

CULTURAL LANDSCAPE .........................................................................................................................65 

Defining Characteristics .....................................................................................................................66 

ARCHEOLOGICAL RESOURCES .............................................................................................................67 

Terrestrial Archeological Resources...................................................................................................67 

Marine Archeological Resources........................................................................................................68 

MUSEUM RESOURCES..............................................................................................................................68 

NATURAL RESOURCES ...................................................................................................................................70 

GEOLOGIC RESOURCES AND SOILS .....................................................................................................70 

MARINE SEDIMENTS ................................................................................................................................70 

FLOODPLAINS............................................................................................................................................71 

VEGETATION..............................................................................................................................................71 

Threatened and Endangered Plant Species .........................................................................................72 

FISH ..............................................................................................................................................................72 

Threatened and Endangered Fish Species...........................................................................................72 

WILDLIFE ....................................................................................................................................................73 

New Jersey Threatened and Endangered Wildlife Species.................................................................73 

SURFACE WATER......................................................................................................................................74 

GROUNDWATER........................................................................................................................................75 

AIR QUALITY .............................................................................................................................................75 

Criteria Pollutants ...............................................................................................................................75 

NOISE ...........................................................................................................................................................76 

HAZARDOUS MATERIALS.......................................................................................................................76 

Historic Fill.........................................................................................................................................77 

Marine Sediments ...............................................................................................................................78 

Building Materials ..............................................................................................................................78 

Above-Ground Storage Tanks ............................................................................................................78 

SOCIAL AND ECONOMIC ENVIRONMENT..................................................................................................79 

TOURISM .....................................................................................................................................................79 

CONCESSIONS............................................................................................................................................79 
CONTENTS

xx STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

CURRENT VISITOR EXPERIENCE...........................................................................................................79 

PARK ADMINISTRATION.........................................................................................................................80 

TRANSPORTATION AND CIRCULATION .....................................................................................................82 

ACCESS TO ELLIS ISLAND ......................................................................................................................82 

Temporary Service Bridge Access......................................................................................................82 

Ferry Access .......................................................................................................................................82 

Battery Park Ferry Service..................................................................................................................82 

Liberty State Park Ferry Service.........................................................................................................82 

CIRCULATION AND ACCESS TO LIBERTY PARK TERMINAL .........................................................83 

Access from Highways .......................................................................................................................83 

Access from Adjacent Roadways .......................................................................................................83 

New Jersey Area Ferry and Light Rail Access ...................................................................................84 

PARKING FACILITIES ...............................................................................................................................84 

Ellis Island ..........................................................................................................................................84 

Liberty State Park ...............................................................................................................................84 

Nearby Parking Facilities....................................................................................................................84 

CIRCULATION ............................................................................................................................................85 

ELLIS ISLAND INFRASTRUCTURE................................................................................................................86 

STABILIZATION IMPROVEMENTS.........................................................................................................86 

UTILITIES ....................................................................................................................................................86 

PLUMBING SYSTEMS ...............................................................................................................................86 

Domestic Water ..................................................................................................................................86 

Fire Protection ....................................................................................................................................87 

Sewage Disposal.................................................................................................................................87 

Storm Sewers......................................................................................................................................87 

ELECTRIC AND FUEL SERVICE..............................................................................................................87 

Electrical Power..................................................................................................................................87 

Standby Electrical Power Generation .................................................................................................88 

Natural Gas.........................................................................................................................................88 

Fuel Oil...............................................................................................................................................88 

MECHANICAL SYSTEMS..........................................................................................................................88 

Central Chilled-Water Plant................................................................................................................88 

Central Heating Plant..........................................................................................................................88
Contents 

FINAL ENVIRONMENTAL IMPACT STATEMENT xxi

ENVIRONMENTAL CONSEQUENCES 

INTRODUCTION ................................................................................................................................................93 

OVERARCHING LAWS AND POLICIES..................................................................................................93 

CUMULATIVE IMPACTS...........................................................................................................................93 

METHODOLOGY FOR ANALYZING IMPACTS............................................................................................94

CULTURAL RESOURCES..........................................................................................................................94 

Historic Architectural Resources, Cultural Landscapes .........................................................................94 

Archeological Resources........................................................................................................................94 

NATURAL RESOURCES ............................................................................................................................95 

Geologic Resources, Soils, and Marine Sediments ................................................................................95 

Floodplains .............................................................................................................................................95 

Vegetation / Threatened and Endangered Plant Species.........................................................................95

Fish.........................................................................................................................................................96 

Wildlife / Threatened and Endangered Wildlife Species........................................................................96

Water Resources.....................................................................................................................................96 

Air Quality..............................................................................................................................................97 

Noise.......................................................................................................................................................97 

Hazardous Materials...............................................................................................................................98 

SOCIAL AND ECONOMIC ENVIRONMENT...........................................................................................98 

TRANSPORTATION AND CIRCULATION..............................................................................................99 

VISITOR EXPERIENCE ..............................................................................................................................99 

ELLIS ISLAND INFRASTRUCTURE.......................................................................................................100 

Site Utilities..........................................................................................................................................100 

REGULATIONS AND POLICIES ....................................................................................................................101 

CULTURAL RESOURCES........................................................................................................................101 

NATURAL RESOURCES ..........................................................................................................................102 

Geologic Resources, Soils, and Marine Sediments ..............................................................................102 

Floodplains ...........................................................................................................................................102 

Vegetation / Threatened and Endangered Plant Species.......................................................................102 

Fish.......................................................................................................................................................102 

Wildlife / Threatened and Endangered Wildlife Species......................................................................102 

Water Resources...................................................................................................................................103 

Air Quality............................................................................................................................................103 

Noise.....................................................................................................................................................103 

Hazardous Materials.............................................................................................................................103 

SOCIAL AND ECONOMIC ENVIRONMENT.........................................................................................104 
CONTENTS

xxii STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

TRANSPORTATION AND CIRCULATION............................................................................................104 

VISITOR EXPERIENCE ............................................................................................................................104 

ELLIS ISLAND INFRASTRUCTURE.......................................................................................................104 

IMPACTS OF ALTERNATIVE 1: NO ACTION — CONTINUATION OF EXISTING 

MANAGEMENT DIRECTION ..............................................................................................................105 

CULTURAL RESOURCES........................................................................................................................105 

Historic Architectural Resources..........................................................................................................105 

Cultural Landscape...............................................................................................................................105 

Archeological Resources......................................................................................................................107 

NATURAL RESOURCES ..........................................................................................................................107 

Geologic Resources and Soils ..............................................................................................................107 

Marine Sediments.................................................................................................................................108 

Floodplains ...........................................................................................................................................108 

Vegetation / Threatened and Endangered Plant Species.......................................................................108 

Fish.......................................................................................................................................................109 

Wildlife / Threatened and Endangered Wildlife Species......................................................................109 

Surface Water.......................................................................................................................................110 

Groundwater.........................................................................................................................................111 

Air Quality............................................................................................................................................111 

Noise.....................................................................................................................................................111 

Hazardous Materials.............................................................................................................................111 

SOCIAL AND ECONOMIC ENVIRONMENT.........................................................................................112 

Tourism ................................................................................................................................................112 

Park Administration..............................................................................................................................112 

TRANSPORTATION AND CIRCULATION............................................................................................113 

Access to Ellis Island............................................................................................................................113 

Access to Ferry Terminals....................................................................................................................113 

Parking .................................................................................................................................................113 

Circulation............................................................................................................................................113 

VISITOR EXPERIENCE ............................................................................................................................114 

ELLIS ISLAND INFRASTRUCTURE.......................................................................................................114 

SECTIONS REQUIRED UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT............................115 

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES...................................115 

LOSS IN LONG-TERM AVAILABILITY OR PRODUCTIVITY OF RESOURCES TO 

ACHIEVE SHORT-TERM GAIN .......................................................................................................115 

UNAVOIDABLE ADVERSE IMPACTS...................................................................................................115 

IMPACTS OF ALTERNATIVE 2: ELLIS ISLAND PARTNERS — DAY USE ONLY.................................116 
Contents 

FINAL ENVIRONMENTAL IMPACT STATEMENT xxiii

CULTURAL RESOURCES........................................................................................................................116 

Historic Architectural Resources..........................................................................................................116 

Cultural Landscape...............................................................................................................................116 

Archeological Resources......................................................................................................................118 

NATURAL RESOURCES ..........................................................................................................................119 

Geologic Resources and Soils ..............................................................................................................119 

Marine Sediments.................................................................................................................................120 

Floodplains ...........................................................................................................................................120 

Vegetation / Threatened and Endangered Plant Species.......................................................................120 

Fish.......................................................................................................................................................121 

Wildlife / Threatened and Endangered Wildlife Species......................................................................122 

Surface Water.......................................................................................................................................123 

Groundwater.........................................................................................................................................124 

Air Quality............................................................................................................................................124 

Noise.....................................................................................................................................................125 

Hazardous Materials.............................................................................................................................125 

SOCIAL AND ECONOMIC ENVIRONMENT.........................................................................................126 

Tourism ................................................................................................................................................126 

Park Administration..............................................................................................................................127 

TRANSPORTATION AND CIRCULATION............................................................................................127 

Access to Ellis Island............................................................................................................................127 

Access to Ferry Terminals....................................................................................................................128 

Parking .................................................................................................................................................128 

Circulation............................................................................................................................................128 

VISITOR EXPERIENCE ............................................................................................................................129 

ELLIS ISLAND INFRASTRUCTURE.......................................................................................................130 

SECTIONS REQUIRED UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT............................131 

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES...................................131 

LOSS IN LONG-TERM AVAILABILITY OR PRODUCTIVITY OF THE RESOURCES 

TO ACHIEVE SHORT-TERM GAIN.................................................................................................131 

UNAVOIDABLE ADVERSE IMPACTS...................................................................................................131 

IMPACTS OF ALTERNATIVE 3: ELLIS ISLAND INSTITUTE WITH OVERNIGHT 

ACCOMMODATIONS (PREFERRED ALTERNATIVE) ....................................................................132 

CULTURAL RESOURCES........................................................................................................................132 

Historic Architectural Resources..........................................................................................................132 

Cultural Landscapes .............................................................................................................................132 

Archeological Resources......................................................................................................................133 
CONTENTS

xxiv STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

NATURAL RESOURCES ..........................................................................................................................133 

Geologic Resources and Soils ..............................................................................................................133 

Marine Sediments.................................................................................................................................133 

Floodplains ...........................................................................................................................................134 

Vegetation / Threatened and Endangered Plant Species.......................................................................134 

Fish.......................................................................................................................................................134 

Wildlife / Threatened and Endangered Wildlife Species......................................................................135 

Surface Water.......................................................................................................................................135 

Groundwater.........................................................................................................................................136 

Air Quality............................................................................................................................................136 

Noise.....................................................................................................................................................136 

Hazardous Materials.............................................................................................................................136 

SOCIAL AND ECONOMIC ENVIRONMENT.........................................................................................137 

Tourism ................................................................................................................................................137 

Park Administration..............................................................................................................................137 

TRANSPORTATION AND CIRCULATION............................................................................................138 

Access to Ellis Island............................................................................................................................138 

Access to Ferry Terminals....................................................................................................................138 

Parking .................................................................................................................................................138 

Circulation............................................................................................................................................138 

VISITOR EXPERIENCE ............................................................................................................................139 

ELLIS ISLAND INFRASTRUCTURE.......................................................................................................139 

SECTIONS REQUIRED UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT............................140 

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES...................................140 

LOSS IN LONG-TERM AVAILABILITY OR PRODUCTIVITY OF THE RESOURCES 

TO ACHIEVE SHORT-TERM GAIN.................................................................................................140 

UNAVOIDABLE ADVERSE IMPACTS...................................................................................................140

CONSULTATION AND COORDINATION 

HISTORY OF PUBLIC INVOLVEMENT........................................................................................................143

SCOPING PROCESS AND PUBLIC MEETINGS....................................................................................143

Public Scoping Forums.....................................................................................................................143

Alternatives Analysis Workshop ......................................................................................................144

DISTRIBUTION OF THE DEVELOPMENT CONCEPT PLAN / DRAFT ENVIRONMENTAL 

IMPACT STATEMENT ......................................................................................................................145

PUBLIC NOTIFICATION..........................................................................................................................146
Contents 

FINAL ENVIRONMENTAL IMPACT STATEMENT xxv

AGENCIES AND ORGANIZATIONS PARTICIPATING DURING THE SCOPING PROCESS ..........146

MAILING LIST ..........................................................................................................................................146

Federal Agencies ..............................................................................................................................146

State of New Jersey ..........................................................................................................................147

State of New York ............................................................................................................................147

Elected Officials ...............................................................................................................................147

City and County Agencies ................................................................................................................147

LIST OF PREPARERS AND CONTRIBUTORS ......................................................................................148

National Park Service .......................................................................................................................148

Beyer Blinder Belle Architects & Planners LLP ..............................................................................149

Robert Silman Associates .................................................................................................................149

Dewberry-Goodkind, Inc..................................................................................................................149

Sedway Group ..................................................................................................................................150

COMMENTS ON THE DEVELOPMENT CONCEPT PLAN DRAFT ENVIRONMENTAL IMPACT 

STATEMENT AND NATIONAL PARK SERVICE RESPONSES TO COMMENTS.........................151

COMMENTS AND RESPONSES..............................................................................................................151

APPENDIXES 

Appendix A: Scoping Meetings Summary For The Development Concept Plan / Draft 

Environmental Impact Statement.............................................................................................................263 

Appendix B: Letters to State Historic Preservation Offices and the Advisory Council 

on Historic Preservation...........................................................................................................................268 

Appendix C: Draft Analysis of Relative Financial Feasibility and Economic Sustainability 

of EIS Alternatives...................................................................................................................................271 

Appendix D: Draft Programmatic Agreement....................................................................................................297 

Appendix E: List of Threatened and Endangered Species and Species of Concern ...........................................308

REFERENCES 

REFERENCES ...................................................................................................................................................347 
CONTENTS

xxvi STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

FIGURES 

ES-1: Ellis Island Map Depicting All Structures ...................................................................................................v 

1: Region and Vicinity Plan.................................................................................................................................4 

2: Alternative 1, No Action — the Early Years.................................................................................................25 

3: Alternative 1, No Action — the Later Years .................................................................................................27 

4: Alternative 2, Ellis Island Partners — Day Use Only....................................................................................33 

5: Alternative 3, Ellis Island Institute with Overnight Accommodations ..........................................................37

TABLES 

1: Features of the Alternatives...........................................................................................................................43 

2: Impact Summary Chart..................................................................................................................................48 

3: Purpose and Objectives of Taking Action and the Means by Which Each Alternative 

Meets Them...................................................................................................................................................53
Purpose of and 

Need for the Action
FINAL ENVIRONMENTAL IMPACT STATEMENT 3

INTRODUCTION 

The National Park Service (NPS) proposes in this 

Development Concept Plan / Final Environmental 

Impact Statement to adaptively reuse the 30 

remaining vacant and deteriorating buildings of Ellis 

Island. This document describes how buildings, 

utilities, and landscaping would be restored or 

rehabilitated under each alternative. The combination 

of these scenarios for the 30 buildings is referred to 

as a “development concept plan” or “site 

development plan.” 

This environmental impact statement also analyzes, 

in a more programmatic or broad-scale way, options 

for continuing to transport materials, supplies, and 

park staff and provide for emergency service to the 

island, which now takes place by way of a service 

bridge between Liberty State Park in New Jersey and 

Ellis Island. The bridge was originally intended as a 

temporary structure for transport of materials used 

during restoration of the Main Immigration Building. 

Alternative 1 (no action) contemplates bridge 

removal, with transport of materials, supplies, staff, 

and emergency personnel by ferry or barge. 

Alternatives 2 and 3 propose the replacement of the 

existing temporary bridge with a permanent service 

bridge. Because the analysis of access is 

programmatic in this environmental impact 

statement, the National Park Service anticipates a 

future additional environmental impact statement or 

environmental assessment to further analyze sitespecific impacts and gather public input on a 

permanent service bridge whether or not alternative 2 

or 3 is implemented. 

Over the past several years, concerned individuals, 

civic groups, and preservation organizations have 

brought national attention to the perilous condition of 

Ellis Island’s many long-vacant deteriorating 

buildings. There is wide consensus that, given federal 

budget constraints, the size of the annual construction 

budget for the entire national park system, and the 

backlog of funding needs throughout the system, 

these buildings will be lost unless appropriate and 

economically sustaining reuses for them can be 

implemented through a public/private partnership 

initiative. This Development Concept Plan / Final 

Environmental Impact Statement signals the NPS 

intent to seek the active participation of a nonprofit 

partner to take a lead role in the rehabilitation and 

revitalization of this campus of historically 

significant and architecturally distinctive buildings 

and to do so in a manner that is consistent with the 

goals and principles set forth in this document and 

the NPS 1982 Statute of Liberty National Monument 

General Management (NPS 1982).

BRIEF HISTORY OF ELLIS ISLAND 

Ellis Island, a small island in New York Harbor, is 

located in the upper bay just off the New Jersey 

coast, within the shadow of the Statue of Liberty (see 

“Figure 1: Region and Vicinity Plan”). Both it and 

the Statue of Liberty are managed by the National 

Park Service as part of the Statue of Liberty National 

Monument. The primary historic significance of Ellis 

Island is its use as an immigration station—from 

1892 to 1954, over 12 million immigrants entered the 

United States through the portal of Ellis Island. 

The Dutch purchased the 3-acre island from the 

Delaware Nation in 1630 to reward Michael Paaw 

(Paw) for shipping goods to the emerging colony. Its 

present name is derived from Samuel Ellis, who had 

come into possession of the island by 1785. From the 

time of the Dutch purchase through several centuries, 

Ellis Island has played many roles in American 

History. 

During 1794 serious threat of war with France and 

Great Britain forced the state of New York to secure 

Ellis Island as part of its harbor defense system to 

deter a naval attack, and earthworks were built on the 

island. In the years preceding the War of 1812, 

additional fortification was constructed, including 

Fort Wood on Bedloe’s Island, Castle William and 

Fort Jay on Governors Island, and the West Battery at 

the southern tip of Manhattan (now Castle Clinton 

National Monument). Shortly before the War of 

1812, a battery of 20 guns, a magazine, and a 

barracks were constructed on Ellis Island and named 

Fort Gibson. In 1861, as the Civil War began, Fort 

Gibson was dismantled, and a naval powder 

magazine was established in its place. 

In 1890 the federal government assumed full 

responsibility for the reception of immigrants at the 

Port of New York. On April 11, 1890, Congress 

decided to remove the naval powder magazine 

operation from Ellis Island and appropriated $75,000 

to enable the secretary of the treasury to improve 

Ellis Island for use as a federal immigration station. 
PURPOSE OF AND NEED FOR THE ACTION

4 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

N

N

FIGURE 1: REGION AND VICINITY PLAN

This Project 

This Project 

Region Plan (not to scale)

Vicinity Plan (not to scale)

356/20242 356 

STLI Nov 2005 
Introduction

FINAL ENVIRONMENTAL IMPACT STATEMENT 5

On January 1, 1892, the immigration station on Ellis 

Island was formally opened to process steerage 

passengers. (First and second cabin passengers were 

processed on board ship and disembarked directly in 

Manhattan.) At a cost of some $500,000, the new 

immigration station consisted of a large two-story 

processing building, separate hospital facilities, 

laundry, and utility plant, all constructed of wood. In 

addition, parts of Fort Gibson and naval magazines 

were converted for use as detainees’ dormitories and 

other station purposes. Landfill was used to enlarge 

the site to approximately double its original 3.3-acre 

size. The federal government continued landfilling, 

and the size of Ellis Island increased to 14 acres in 

1897. This portion of Ellis Island is known as the 

north side of Ellis Island or “Island 1.” 

On June 15, 1897, the island’s buildings were 

virtually destroyed by fire, and later that year, 

Congress authorized funds for new fireproof facilities 

at Ellis Island. A contract was awarded to the 

Broadway firm of Boring & Tilton to design the new 

brick and ironwork structures. This was the first 

important government building to be designed by 

private architects under competition mandated by the 

Tarnsey Act of 1875. Three years later, on 

December 17, 1900, the new Ellis Island immigration 

station was opened. At a cost of some $1.5 million, 

the new station complex featured an impressive 

French “Beaux-Arts” Renaissance-style brick 

structure laid in Flemish bond with limestone trim. 

By 1899 a second 3-acre “island,” or extension of 

Ellis to the southwest, was created from fill to house 

a new hospital complex. “Island 2” was separated 

from Island 1 by a ferry slip and was completed in 

1901. The placement of still more fill between 1903 

and 1906 created a 4.75-acre “Island 3” to the 

southwest of Island 2. It was separated by a ferry 

dock basin (later filled) and housed a contagious 

disease hospital complex opened for use in 1911. 

Filling the dock basin and adding another 

approximately 3 acres of fill to various parts of the 

island created the 27.5-acre Ellis Island of today. 

Islands 2 and 3 are referred to as the “south side” of 

Ellis Island, and as noted above, the northern 14 acres 

are known as the “north side.” 

When the United States entered World War I on 

April 6, 1917, the Ellis Island facilities were used to 

hold German merchant ship crews in custody while 

their ships remained anchored in New York Harbor. 

Numerous suspected enemy aliens throughout the 

nation were also rounded up and brought to Ellis 

Island for incarceration. Between 1918 and 1919, the 

U.S. Army and Navy took over the Main Building, 

the Baggage and Dormitory Building, and the 

Hospital Complex on Islands 2 and 3 for use as a way 

station and treatment of returning sick and wounded 

American servicemen. 

Following the war, the aging and neglected facilities 

at Ellis Island were reopened for immigrant 

inspection in 1920. Postwar immigration quickly 

revived with 560,971 immigrants passing through 

Ellis Island in 1921. The Immigration Act of 1924

had a significant impact on the operation of Ellis 

Island by placing an annual limit on the number of 

permitted immigrants. Under this law, regular 

immigration processing was transferred to the United 

States consulates abroad for processing before 

coming to the United States. Immigrants were sent to 

Ellis Island only when their papers were not in order, 

their status was questioned, or they required medical 

treatment. Accordingly, the buildings at Ellis Island 

slowly fell into disuse and disrepair. 

In the 1930s, in response to a growing sentiment for 

humanizing the conditions under which detainees 

were kept, some improvements were made. The 

Works Progress Administration (referred to as the 

“WPA”) funded further landfilling on Ellis Island, 

creating recreation grounds on the Manhattan side of 

the Main Building. Other new playgrounds and 

gardens were constructed and maintained through 

WPA labor, including the filled area between 

Islands 2 and 3. Between 1934 and 1935 the Baggage 

and Dormitory Building was remodeled to allow 

better segregation of the different classes of 

deportees. 

After World War II erupted in Europe in September 

1939, the U.S. Coast Guard occupied the 

Immigration Building, Ferry House, and ground floor 

of the Baggage and Dormitory Building to house and 

train recruits to patrol the region’s waters. In 1940 

the Immigration and Naturalization Service was 

transferred from the Department of Labor to the 

Department of Justice, symbolic of the fact that 

immigrants had come to be considered primarily as 

potential threats to our national security. After the 

United States entered the war in December 1941, 

Ellis Island was again used as a hospital for returning 

wounded servicemen. 

Following the decommissioning of the Coast Guard 

station in 1946, Ellis Island remained in use primarily 

as a detention center for aliens whose status was 

questioned. In 1951 the United States Public Health 

Service closed the Hospital Complex on the island. 

As a result of the Immigration and Naturalization Act 

of 1952 and a liberalized detention policy in 1954, 
PURPOSE OF AND NEED FOR THE ACTION

6 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

the number of detainees on Ellis Island dropped to 

less than 30. The Ellis Island facility, consisting of 

some 40 structures, was closed as an immigration 

station in 1954 and declared surplus federal property 

by the General Services Administration. 

Over the next decade, all of the structures remained 

vacant and in a state of deterioration. In 1965—in 

recognition of its importance to the country’s heritage 

and the need for its preservation—President Lyndon 

Johnson declared Ellis Island part of the Statue of 

Liberty National Monument. Between 1976 and 

1984, Ellis Island was opened to the public, but only 

on a limited basis. Because it was part of a national 

monument, the island’s control and maintenance 

became the responsibility of the National Park 

Service; however, no funds were appropriated for 

upkeep or rehabilitation. A few resource studies and 

planning activities were conducted during the 1970s, 

and limited funds were appropriated for emergency 

repairs in 1976. Over this period, the National Park 

Service was able to maintain only a minimal security 

presence on the island while the buildings continued 

to deteriorate. 

RECENT ADMINISTRATIVE HISTORY

The current trend toward rehabilitating the buildings 

on Ellis Island began with preparation for the 

centennial—the 100th anniversaries of the Statue of 

Liberty and Ellis Island—which started as early as 

1979. The National Park Service created a planning 

team to explore possible management, rehabilitation, 

and development alternatives for the Statue of 

Liberty. With the approaching centennial, national 

attention focused on the need for restoration of the 

Statue of Liberty. Ellis Island ultimately benefited 

from its proximity and thematic connection with the 

Statue, because the 1980 Analysis of Alternatives for 

the General Management Plan (NPS 1980) that was 

prepared by the planning team also included Ellis 

Island. 

In 1982 the National Park Service completed the 

Statute of Liberty National Monument General 

Management Plan (NPS 1982), which focused 

primarily on Ellis Island. The plan proposed that the 

Main Immigration Building would be rehabilitated to 

become the Immigration Museum. The adjacent 

Kitchen and Laundry Buildings would also be 

rehabilitated and used for administrative functions. 

These improvements were subsequently 

accomplished through a partnership between the 

National Park Service and the Statue of Liberty-Ellis 

Island Foundation, Inc. The Main Building was 

reopened to the public on September 10, 1990, as the 

Ellis Island Immigration Museum. Over 23 million 

people have visited the museum since it opened. In 

2004 the museum received over 1.5 million visitors. 

The 1982 General Management Plan also determined 

that a private development partner should be found to 

assist in rehabilitation and adaptive reuse of the 

Baggage and Dormitory Building and the entire 

Hospital Complex. In 1982 the Park Service issued a 

Request for Proposals as a means of gathering ideas 

for development and rehabilitation. A developer 

selected by the Park Service proposed that an 

international conference center be established on 

Ellis Island. After several years of negotiations, the 

secretary of the interior agreed to a plan that 

preserved most of the buildings on the island. In 1988 

an agreement to lease was signed by the secretary, 

and in 1992, the developer submitted more detailed 

plans. Reaction to these plans included major 

concerns raised by the preservation community and 

others regarding the proposed demolition of certain 

structures, construction of several new buildings, a 

lack of public programming, and the absence of 

public participation in the development planning 

process. The subsequent controversy, combined with 

a weakening economy, resulted in the developer’s 

eventual withdrawal from the lease agreement, and 

the project was cancelled. 

By the mid-1990s public attention again focused on 

the continued deterioration of the many unoccupied 

buildings of Ellis Island. The World Monuments 

Fund, the National Trust for Historic Preservation, 

the New York Landmarks Conservancy, and other 

preservation organizations focused national attention 

on the imperiled condition of the buildings. 

During this same period, the U.S. Supreme Court 

settled the long-standing jurisdictional dispute on 

Ellis Island between the states of New York and New 

Jersey. The court granted the state of New Jersey 

sovereignty over 22.5 of the island's 27.5 acres. 

Following the decision, the governor of New Jersey 

appointed an Advisory Committee on the 

Preservation and Reuse of Ellis Island. The 

deliberations and final report of that committee 

contributed significantly to the growing public 

awareness of the need for action. In response to one 

of the report’s recommendations, and to further focus 

attention on the issue, a new nonprofit organization 

called “Save Ellis Island Inc.” was established to 

raise funds to preserve the remaining buildings on 

Ellis Island. In 2001 the National Park Service signed 

a major fundraising agreement with Save Ellis Island 

Inc. 
Introduction

FINAL ENVIRONMENTAL IMPACT STATEMENT 7

Through the cooperative efforts of federal, New 

Jersey State, Save Ellis Island Inc., and private 

efforts, a program of building stabilization is now 

underway. When completed, this effort will stem 

further deterioration for a period of approximately 10 

to 15 years. At the time of this writing, stabilization 

has been completed on Island 2, and stabilization is 

almost completed for the buildings on Island 3. The 

park has been exploring options for stabilizing the 

Baggage and Dormitory Building on Island 1 and 

expects to begin that building’s stabilization in 2006. 

This new public-private partnership has also resulted 

in the restoration of the exteriors of two additional 

buildings: the Ferry Building and the Hospital 

Outbuilding and Laundry. Work on rehabilitation of 

the Ferry Building interior and associated corridor is 

expected to begin in mid-2006. Other important work 

now underway relates to planning and improvements 

to the utility infrastructure for the south side and 

rehabilitation of the Ellis Island seawall. 

Other recent activities at Ellis Island include those 

put in place after September 11, 2001. The National 

Park Service closed the Statue of Liberty National 

Monument and Ellis Island after September 11 to 

strengthen security elements of the park's operation 

and put key security measures into place. The park 

reopened to the public on December 20, 2001, and 

continues to consider the enhancement of security 

procedures in the park as a top priority. 

PURPOSE OF AND 

NEED FOR THE ACTION 

The same coalition of public and private interests that 

motivated the building stabilization program 

recognizes that stabilization is only a short-term 

tactic, and a long-term solution to securing the 

island’s future must still be identified. To be viable, a 

balanced approach must be found that is compatible 

with the objectives of historic preservation and 

acknowledges the economic realities that have stood 

in the way of previous efforts to adaptively reuse the 

buildings. 

A long-term solution must also be found to address 

the question of access to Ellis Island for emergency 

management and administrative operations. The 

public comes to Ellis Island by concession-managed 

ferries from Battery Park in Lower Manhattan and 

from Liberty State Park in Jersey City, New Jersey. 

Service and maintenance vehicles access Ellis Island 

via a temporary service bridge that was constructed 

in the 1980s to facilitate restoration of the Main 

Building. The bridge has existed long beyond its 

intended life span. A project to stabilize the bridge 

was completed in fall 2002 to enable continued use 

for park operations and emergencies; this work will 

extend the life of the bridge for about 10 years. 

Continued access by a service bridge is critical to the 

park’s emergency management operations as well as 

for efficient operations, construction activities, 

maintenance, and deliveries. 

The purpose of this proposed development concept 

plan is to provide for the long-term rehabilitation, 

reuse, and protection of cultural and historic 

resources on Ellis Island. This statement is consistent 

with the 1982 General Management Plan. In 

addition, several more specific objectives (listed 

below) for this proposed development concept plan 

were developed using the framework of the 1982 

General Management Plan to better reflect current 

conditions. The objectives were used by NPS staff to 

help determine the appropriate range of alternatives 

to analyze in this environmental impact statement. If 

an alternative did not meet the above-stated purpose 

and the objectives to a large degree, it was considered 

to be unreasonable (see the “Alternatives” chapter for 

more information). The NPS objectives are to 

protect the island’s cultural and natural resources 

provide for the long-term rehabilitation and 

adaptive reuse of the island’s Beaux-Arts 

campus of integrated brick, stucco, and tile 

structures with connecting corridors of masonry 

and glass, within a designed landscape of lawn 

and mature trees 

provide uses that complement the island’s 

historic themes and related contemporary issues 

and that can be economically sustained 

provide enhanced opportunities for visitors to 

understand and experience Ellis Island’s history, 

including managed public access to most of the 

island’s cultural landscape 

provide a high level of security and safety for the 

visitors, staff, and resources of Ellis and Liberty 

Islands, and the ability to respond quickly in 

emergency situations 

provide thematically appropriate, safe, and 

economically viable access to and from the 

island in support of its adaptive reuse, 

emergency management, and security 

requirements 
PURPOSE OF AND NEED FOR THE ACTION

8 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

The statement of purpose and these objectives will be 

incorporated in an updated general management plan 

for the Statue of Liberty National Monument and 

Ellis Island that was initiated in 2003. 

CONSTRAINTS 

The National Park Service is prohibited by a set of 

laws, regulations, and policies from taking certain 

actions. For example, the NPS Organic Act of 1916

prohibits the Park Service from taking or continuing 

actions that would impair any park resource or value, 

and particularly those resources or values for which 

the park was created. 

The National Environmental Policy Act requires 

federal agencies to consider all environmental 

impacts of a proposed action, including impacts on 

cultural resources. This Development Concept Plan / 

Final Environmental Impact Statement, with scoping 

and review of the draft version of the document by 

the interested and affected public, fulfills the 

requirements of the National Environmental 

Policy Act. 

Section 106 of the National Historic Preservation Act

requires federal agencies to take into account the 

effects of a proposed action on historic properties. 

This means that federal agencies must make a 

responsible effort to identify properties listed on or 

eligible for the National Register of Historic Places 

that may be affected by an action and to determine 

the impacts that an action may have on such 

properties. The information on cultural resources 

contained in this environmental impact statement is 

presented to help fulfill these requirements. 

Security — The National Park Service is constrained 

in its operation and management of the Statue of 

Liberty National Monument and Ellis Island by 

security concerns that have been brought into focus 

by the events of September 11, 2001. Symbols of 

American values are considered high-profile targets 

for future terrorist attacks, and in response to these 

possible threats, improvements to the security 

elements of park operations are being implemented 

with advice and consultation from security experts 

from the public and private sector. Nearly all aspects 

of NPS operations, as well as those of park 

concessioners, partners, and contractors, have been 

altered by an increased awareness of security issues. 

Access is of particular concern, although within the 

context of increased security, the National Park 

Service remains committed to maintaining public 

access to the Statue of Liberty National Monument 

and Ellis Island. Currently, access to the park is being 

intensely managed, and actions have been 

implemented to ensure a high level of security at all 

entry points to the park. Some measures, such as 

airport-type screening of all passengers before 

boarding ferries, are readily apparent to visitors, 

while others are not. In addition, for the purposes of 

this environmental impact statement, some 

management options that might have been feasible in 

the past are now considered to pose unacceptable 

security risks. For example, the introduction of a new 

location for general public entry, such as a pedestrian 

bridge to Ellis Island, was considered but deemed 

infeasible from a security point of view. 

The “Partnership Construction Process” is a new 

NPS process for managing, monitoring, and 

approving the partnership construction process 

developed in response to Congressional concern 

about fiscal accountability and sustainability in 

partnership projects. The National Park Service and 

its partner on this project will comply with the 

Partnership Construction Process and with NPS 

Director’s Order 21: Donations and Fundraising. 

In accordance with the Partnership Construction 

Process, implementation of the preferred alternative 

set forth in this plan would be subject to the findings 

and recommendations of a number of additional 

studies to determine the programmatic and economic 

feasibility of the project. In addition, this process 

includes Congressional review and approval of a 

project concept and fundraising proposal prior to any 

fundraising activities or design development. All 

partnership development projects over $500,000 are 

subject to approval by the NPS Development 

Advisory Board. If the Partnership Construction 

Process results in a determination that the project as 

described is not feasible, NPS will further consider 

alternatives for management of Ellis Island taking 

into account the information gained from the process 

outlined above and other facts and circumstances 

then available. This further consideration of 

alternatives will be conducted in accordance with 

applicable requirements of the National 

Environmental Policy Act and the National Historic 

Preservation Act (as amended). 

Permanent Service Bridge — Both of the proposed 

action alternatives (alternatives 2 and 3) analyzed in 

this environmental impact statement recognize the 

critical need for a permanent service bridge for Ellis 

Island’s emergency management operations, as well 

as for efficient operations, construction activities, 

maintenance, and deliveries to Ellis Island. 
Introduction

FINAL ENVIRONMENTAL IMPACT STATEMENT 9

Replacement of the temporary service bridge from 

New Jersey will be a federal responsibility regardless 

of the future disposition of the remaining buildings of 

Ellis Island. The design and location of the bridge 

will be determined through future planning in 

cooperation with the state of New Jersey, compliance 

with the National Environmental Policy Act and other 

required environmental reviews and permits, and 

review by the NPS Development Advisory Board. 
10 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

ISSUES AND IMPACT TOPICS

Issues are problems raised by the public and National 

Park Service or other agency staff that are thought to 

need resolution through the current planning process. 

In the case of this Development Concept Plan / Final 

Environmental Impact Statement, the public was 

involved through scoping. A summary of the specific 

scoping activities is available in the “Consultation 

and Coordination” chapter, which also contains 

comments received during the public review period 

for the Development Concept Plan / Draft 

Environmental Impact Statement and NPS responses 

to comments. Please see appendix A for a summary 

of the scoping meetings and appendix B for copies of 

the NPS letters to the New York and New Jersey 

State Historic Preservation Offices and the Advisory 

Council on Historic Preservation. 

The following section summarizes major planning 

issues and environmental impact topics that have 

come from the scoping activities. 

ISSUES RAISED BY SCOPING 

LOSS OF CULTURAL RESOURCES

Many members of the public, as well as the National 

Park Service (as explained above), are concerned that 

stabilization of the buildings on Ellis Island was only 

intended as a temporary solution, and the process of 

deterioration would continue as soon as stabilization 

work has been completed, resulting in the eventual 

loss of the buildings. This planning issue is a central 

component of the NPS need for action. 

COSTS OF POSTPONING

PERMANENT TREATMENT

Delaying a permanent solution to the deterioration of 

buildings on Ellis Island could increase costs. This is 

because the buildings would need to be stabilized in 

the interim, yet stabilization would not offset the 

ultimate cost of permanent rehabilitation. 

Stabilization only lasts 10 to 15 years; without a 

long-term solution, it would need to be repeated to 

prevent the loss of the historic resource. At the 

extreme, the “cost” of postponing treatment could be 

the eventual loss of the resources themselves. 

However, if a permanent treatment alternative is 

implemented sooner rather than later, interim 

stabilization costs, and the chances the buildings 

would be lost, would be minimized. 

MITIGATION FOR LOSS

If treatment beyond stabilization is not possible, the 

loss of the historic resources may be potentially 

mitigated by means of building documentation, 

interpretive programs, and displays. These are 

standard mitigation measures for the loss of cultural 

resources and would be used if the no-action 

alternative were adopted. 

FEDERAL GOVERNMENT

RESPONSIBILITY FOR REHABILITATION

Some commenters expressed the view that the federal 

government and Congress should be responsible for 

providing funding to protect these historic resources. 

Alternative 2 gives the federal government, through 

the National Park Service, a major role in funding the 

rehabilitation. Because overall costs are so high in 

relation to the entire annual NPS budget for 

construction, philanthropic donations would be used 

in this alternative as a supplemental source of funds. 

Both action alternatives include a federal role in 

funding the costs of providing utility infrastructure 

for the south side and increasing the park’s operating 

base. 

LOSS OF SERVICE BRIDGE ACCESS

The loss of the bridge would result in increased 

safety and security concerns due to lack of access for 

emergency equipment and personnel and the inability 

to transport visitors and employees off Ellis Island 

during natural disasters, fire, medical emergencies, or 

other circumstances requiring evacuation from Statue 

of Liberty National Monument and Ellis Island. The 

loss of the bridge and vehicular service access to Ellis 

Island prior to completion of the rehabilitation would 

substantially increase rehabilitation costs and 

adversely impact the overall feasibility of adaptive 

reuse of the island’s vacant buildings. These factors 

are analyzed for the no-action and action alternatives 

in this environmental impact statement. 
Issues and Impact Topics 

FINAL ENVIRONMENTAL IMPACT STATEMENT 11

LOSS OF HISTORIC RESOURCES

Some commenters indicated concern regarding 

demolition and new construction of buildings. The 

National Park Service determined that only smallscale dismantling would be considered part of the 

action alternatives because impacts on the cultural 

landscape from large-scale changes to the buildings 

would violate the purpose and objectives in the 1982 

General Management Plan. Rehabilitation work, 

including any necessary dismantling, would be 

approved only if determined to be in accordance with 

the Secretary of the Interior’s Standards for 

Rehabilitation. 

SECURITY CONCERNS

Security is an ongoing concern for this and other 

national parks regardless of the means by which 

visitors access them. Jitney or other authorized 

vehicular access for the public, retreat attendees, 

and/or lodging guests via the service bridge would all 

raise security concerns. These concerns are addressed 

in the action alternatives through measures such as 

limiting access, using gated entries, and/or expanding 

NPS screening. 

PEDESTRIAN ACCESS

Some commenters indicated their desire for a bridge 

allowing pedestrian access to Ellis Island, while 

others raised concerns that, if pedestrian access were 

allowed, Liberty State Park would function as a 

parking lot for the Statue of Liberty and Ellis Island. 

The need for pedestrian access may be driven by the 

desire to have more “affordable” access to the island. 

The cost of ferry service is perceived to prevent some 

low- and moderate-income people from visiting the 

island. However, a pedestrian bridge has been 

eliminated from detailed analysis in this 

environmental impact statement because of the 

increased security risk it could pose, particularly in 

the aftermath of the September 11, 2001, terrorist 

attacks. Mitigation measures to provide additional 

opportunities for low- and moderate-income visitors 

to experience the island would be put in place and are 

described in the action alternatives. These measures 

include subsidies of the cost of ferry trips and other 

programmatic solutions. 

PROTECTION OF LIBERTY 

STATE PARK’S NATURAL, 

RECREATIONAL, AND SCENIC RESOURCES

Some commenters expressed their hopes for the 

continued restoration and protection of Liberty State 

Park lands. They raised concerns that the park not be 

perceived simply as a parking lot for visitors 

traveling to the Statue of Liberty National Monument 

and Ellis Island. Others raised concerns about the 

present location of the service bridge landing in the 

state park. These concerns are analyzed in the action 

and no-action alternatives; mitigation measures 

would be further addressed in the subsequent design 

of a permanent bridge. 

BRIDGE AS AN INTRUSION

Some commenters indicated the temporary service 

bridge is an intrusion on the island’s cultural 

landscape and should be permanently removed. 

Alternative 1 (no action) includes the permanent 

removal of the bridge, and alternatives 2 and 3 

include analysis of this concern as an impact topic. 

IMPACT TOPICS ANALYZED 

The following section identifies topics carried 

forward as part of the impacts analysis. 

HISTORIC ARCHITECTURAL RESOURCES

The impacts on several features of the buildings on 

Ellis Island from the actions proposed in each 

alternative are analyzed. These include massing and 

scale, building materials, fenestration, corridor 

systems, stairwells, and interior spaces and features. 

CULTURAL LANDSCAPE

The cultural landscape of the island includes how the 

combination of buildings, landscaping, roads, or 

paths present themselves. This environmental impact 

statement analyzes spatial organization, or the 

“campus feel” of the immigration station; clustering 

of buildings and open spaces between buildings; the 

circulation, including covered corridors and historic 

walkways; and vegetation patterns and historic trees. 
PURPOSE OF AND NEED FOR THE ACTION

12 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

ARCHEOLOGICAL RESOURCES

Buried historic or prehistoric resources are present 

both on the island and underwater just off the coast of 

the island. Bridge removal, construction, or the 

rehabilitation of structures on Ellis Island could 

involve grading or excavating soils in which these 

resources may be present. 

GEOLOGIC RESOURCES AND SOILS

The alternatives include proposals to remove the 

existing bridge, build a permanent bridge, and/or 

grade staging areas and access roads. All of these 

could remove soils, although none are expected to 

affect bedrock. 

MARINE SEDIMENTS

Bridge removal and construction would involve work 

in the channel, which could disturb marine sediments. 

FLOODPLAINS

A section of Liberty State Park, where one side of the 

temporary service bridge connects, is vulnerable to 

flooding and protected by a floodwall. Removing the 

temporary bridge would require that a space in the 

wall be sealed and flood protection increased. 

VEGETATION / THREATENED 

OR ENDANGERED PLANTS

Vegetation would be removed to grade areas for 

bridge landings, staging areas, and access roads. In 

addition, two protected plant species that grow in 

courtyards on Ellis Island would be removed to 

restore landscaping to that more associated with the 

cultural value of the island. 

FISH

Work in the channel between Ellis Island and Liberty 

State Park would directly disturb and displace fish 

and would increase turbidity and mobilize marine 

sediments. The sediments contain known toxins, such 

as heavy metals and organics, which could keep fish 

away from the area or harm aquatic life during, and 

for a period of time following, construction of the 

bridge. 

WILDLIFE / THREATENED 

OR ENDANGERED WILDLIFE

Wildlife could be disturbed and displaced by 

construction noise and could be permanently affected 

by the removal of habitat or presence of traffic 

adjacent to habitat, particularly in Liberty State Park. 

The protected Savannah sparrow and other yearround resident birds may experience more adverse 

effects than would seasonal or migratory species. 

SURFACE WATER

As noted above, work in the channel to remove the 

existing bridge and build a new one would increase 

turbidity and disturb marine sediments, some of 

which may contain heavy metals or other toxins. 

GROUNDWATER

The bridge landing on the New Jersey side could 

require excavation in an area with high groundwater 

tables. There is also some small chance that pumping 

to dewater the groundwater table could result in 

contamination of the aquifer from seawater or from 

heavy metals or other toxins. 

AIR QUALITY

Increases in vehicles associated with construction or 

increased visitor use could result in increased 

emissions of pollutants associated with internal 

combustion or diesel engines, as well as dust from 

grading or construction sites. 

NOISE

Construction equipment could be quite loud and 

disturb visitors and wildlife. Construction workers 

would be less affected because they would wear ear 

protection. 
Issues and Impact Topics 

FINAL ENVIRONMENTAL IMPACT STATEMENT 13

HAZARDOUS MATERIALS

The fill material and marine sediments in the study 

area, and particularly in Liberty State Park and the 

channel between it and Ellis Island have, in some 

cases, been found to contain dangerous heavy metals 

and organics such as polychlorinated biphenyls 

(PCBs), dichlorodiphenyl trichloroethane (DDT), and 

polycyclic aromatic hydrocarbons (PAH). The 

building of bridge landings and roads or the removal 

of bridge pilings could result in the exposure of 

workers or visitors to these substances if precautions 

are not taken. 

TOURISM

Tourism could increase at a slightly faster pace if the 

buildings are restored than if they are not, resulting in 

increased revenues in New York City and local New 

Jersey communities. 

PARK ADMINISTRATION

Additional park staff would be required to help 

coordinate with partners, operate facilities, and 

manage visitors under either action alternative. It 

would take longer to provide emergency services if 

no bridge access were available. 

ACCESS TO ELLIS ISLAND

Although removing the bridge would not affect 

current public access, it would require the use of 

ferries to transport goods and services to administer 

the park and associated operations. 

ACCESS TO FERRY TERMINALS

Roads leading to the ferry terminals in New York and 

New Jersey may experience increases in traffic, some 

of which would not be associated with this project 

but would be cumulative from other sources. 

PARKING

As visitation to both Ellis Island and Liberty State 

Park increases, demand for parking spaces would 

also increase. Parking is already limited and, 

although additional parking has been proposed, it has 

not been funded. 

CIRCULATION

Arriving at either of the ferry terminals involves the 

use of public or private transportation. The use of 

private vehicles may contribute to ongoing 

cumulative impacts from congested roads and 

intersections. 

VISITOR EXPERIENCE

Restoring buildings or the cultural landscape on Ellis 

Island would increase access to portions of the Island 

and enhance the overall scope of the visitor 

experience. 

ELLIS ISLAND INFRASTRUCTURE

Some deficiencies in the electrical, plumbing, or 

other infrastructure on Ellis Island exist, particularly 

with regard to the buildings that would be restored 

under the action alternatives. They would be 

upgraded to accommodate reuse of the restored 

buildings if alternative 2 or 3 were selected. 

IMPACT TOPICS DISMISSED 

MUSEUM COLLECTIONS

No impacts on the current museum collections are 

expected from any of the alternatives. Some of the 

Ellis Island collection would need to be moved from 

their existing locations so that buildings, such as the 

Recreation Hall, could be rehabilitated (see the 

“Affected Environment” chapter for more 

information). 

WETLANDS

No wetlands occur in the project area, but they do 

exist in Liberty State Park between Freedom Way 

and Liberty Walk. No bridge landings, access roads, 

or other development in this area of the state park are 

proposed; therefore, no direct impacts on wetlands 

are expected. Silt fencing or other mitigation would 

be used to prevent runoff from entering wetlands 
PURPOSE OF AND NEED FOR THE ACTION

14 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

from construction sites if the wetlands are lower in 

elevation or would be affected by dust. 

LAND USE

Some very small-scale changes in land use may occur 

as a result of implementing the alternatives, but these 

changes are better analyzed in other sections. For 

example, bridge landings are analyzed in soils, 

vegetation, noise, and wildlife, and restoration of the 

buildings is discussed in the “Cultural Resources” 

and “Visitor Experience” sections of the 

“Environmental Consequences” chapter. Therefore, 

to avoid overlap, land use as its own section was 

eliminated. 

ENVIRONMENTAL JUSTICE

Executive Order 12898, “Federal Actions to Address 

Environmental Justice in Minority Populations and 

Low Income Populations,” requires all federal 

agencies to take appropriate and necessary steps to 

identify and address disproportionately high and 

adverse effects of federal projects on the health or 

environment of minority and low-income populations 

to the greatest extent practicable and permitted by 

law. After some preliminary analysis, no impacts on 

minority or low-income populations were apparent; 

thus, the impact topic was dropped. Additional 

information is presented in the introduction to the 

“Affected Environment” chapter. 

POPULATION

Census information and other statistics were 

collected for the local counties and region and for the 

states of New York and New Jersey. However, no 

impacts on the populations of any of these areas from 

the activities proposed in this Development Concept 

Plan / Final Environmental Impact Statement were 

discernable. Therefore, the impact topic was dropped 

from further analysis. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 15

RELATIONSHIP TO OTHER PLANS AND POLICIES

BACKGROUND 

This section describes the relevant features of other 

plans, policies, projects, and environmental impact 

documents that have led to or helped define the 

purpose, need, and alternatives in this Development 

Concept Plan / Final Environmental Impact 

Statement, or which have bearing on impacts 

evaluated in this document. 

1982 GENERAL MANAGEMENT PLAN 

In 1982 the Statue of Liberty National Monument

General Management Plan, which primarily 

focused on Ellis Island, recognized the need to 

rehabilitate the historically significant vacant 

buildings on Ellis Island in order to interpret the 

immigrant experience of arrival and screening in 

the United States during the years that Ellis Island 

served as an immigrant processing facility and 

hospital. Most of the buildings on the north side of 

Ellis Island were recommended for rehabilitation 

and use by the National Park Service for 

interpretation, visitor services, and administrative 

use. The balance of the buildings on the island, 

including all of the south-side buildings comprising 

the former hospital complex and associated 

buildings, were to be preserved on the exteriors, 

and the interior spaces adapted for use by either the 

National Park Service or a private organization 

under a lease agreement or concession contract. 

This Development Concept Plan / Final 

Environmental Impact Statement is consistent with 

the goals and intent of the 1982 General 

Management Plan. 

UPDATED GENERAL MANAGEMENT PLAN

Work has begun on a comprehensive revision and 

update to the 1982 General Management Plan, and 

a final plan is expected in 2007. The broad purpose 

of the updated general management plan will be to 

clearly describe specific resource conditions and 

visitor experiences to be achieved within the park, 

and to identify the kinds of management use and 

development that will be appropriate in achieving 

and maintaining those conditions. The plan will 

ensure that this basic foundation for decision 

making has been developed in consultation with the 

general public and interested stakeholders and 

adopted by the NPS leadership after adequate 

analysis of the economic and environmental costs 

and benefits of alternative courses of action. The 

updated general management plan will incorporate 

the decisions made in this development concept 

plan. 

INTERNAL DRAFT ENVIRONMENTAL IMPACT 

STATEMENT, ELLIS ISLAND BRIDGE AND 

ACCESS ALTERNATIVES, STATUE OF 

LIBERTY AND ELLIS ISLAND, 

AUGUST 25, 1995 

In 1992 Congress appropriated $15 million for 

construction of a permanent bridge linking Ellis 

Island and New Jersey’s Liberty State Park, located 

within Jersey City, New Jersey. In response to this, 

the National Park Service prepared an internal draft 

environmental impact statement (NPS 1995a) to 

consider various access alternatives that responded 

to the need articulated by Congress and others for 

affordable access to Ellis Island. At that time, the 

National Park Service outlined four objectives: 

(1) preserve Ellis Island and provide for the 

enjoyment of this resource; (2) preserve and protect 

the historic, cultural, and natural aspects of the 

environment; (3) support NPS operations and 

administration of the park; and (4) maximize the 

economic efficiency of the transportation system. 

The internal draft environmental impact statement 

fully evaluated these four alternatives: 

No-action alternative described the conditions 

that would exist after the removal of the 

current temporary service bridge 

No-build alternative described conditions 

similar to the no-action alternative, but 

included a provision for free ferry service from 

New Jersey on either one day each week or one 

day each month 

New bridge alternative (the preferred 

alternative) identified a location and design 

profile for a new bridge, which would be 

suitable for pedestrian access 
PURPOSE OF AND NEED FOR THE ACTION

16 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

A pedestrian tunnel alternative would provide a 

tunnel in the bedrock below the harbor. 

Public scoping meetings were held in July 1993, 

and additional meetings with public agencies were 

held during July and August 1993 to elicit issues 

and concerns. The draft environmental impact 

statement was completed on August 25, 1995, for 

internal NPS review prior to release for public 

review and comment. During this same period, 

however, Congress rescinded the appropriation for 

the bridge. Work and expenditures on the draft 

environmental impact statement were halted, the 

document was never released for public review, and 

the National Park Service did not prepare a final 

environment impact statement. To date, funds for 

the construction of a new bridge connecting Ellis 

Island and New Jersey have not been reinstated by 

Congress. 

GOVERNORS ISLAND NATIONAL MONUMENT 

The Governors Island National Monument was 

established by Presidential Proclamation on 

January 19, 2001. The monument includes two 

early 19th century fortifications (Castle Williams 

and Fort Jay), built as part of a system of defenses 

for New York Harbor. The monument consists of 

approximately 20 acres, sits within a National 

Historic Landmark District, and is part of a larger 

island totaling 172 acres. In a White House 

ceremony held on January 31, 2003, President Bush 

reaffirmed the establishment of the Governors 

Island National Monument and executed the 

transfer of the monument to the National Park 

Service and the rest of the island to the state and 

city of New York. The Governors Island 

Preservation and Education Corporation (the statecity redevelopment entity) and the National Park 

Service will develop a general management plan 

and collaborate on respective management and 

redevelopment plans, public access, programs, and 

activities for the island. It has been suggested that 

ferry service to the Statue of Liberty and Ellis 

Island might also include a stop at Governors Island 

so visitors can experience that national monument. 

In the past, Governors Island has also been 

identified as a potential location for a major 

conference center, with some elements similar to 

the ideas in alternative 3 of this environmental 

impact statement for Ellis Island. 

NATIONAL PARKS OF 

NEW YORK HARBOR INITIATIVE

The National Parks of New York Harbor is a new 

collaboration among several units of the national 

park system in the greater New York / New Jersey 

metropolitan area, with leadership and support 

provided by an executive director and a small staff 

in a special office established for that purpose. The 

executive director (or commissioner) works with an 

executive council of superintendents to coordinate 

joint efforts. The Statue of Liberty National 

Monument and Ellis Island are part of this 

collaboration. 

The mission of the National Parks of New York 

Harbor is to enhance the identity, visibility, and 

public support for the NPS units and to collaborate 

with others in the New York / New Jersey 

metropolitan area in the care and appropriate use of 

all historic, recreational, and natural resources and 

to promote the national park system. Among other 

functions, this new office will play an important 

role in promoting and coordinating the interpretive 

and educational programs of the various NPS sites 

and their partnerships, including the Statue of 

Liberty National Monument and Ellis Island. The 

initiative also includes the involvement of the 

newly created National Parks of New York Harbor 

Conservancy to increase awareness of, and raise 

funds for, the resources and programs of the 

National Parks of New York Harbor. 

RESTORATION OF THE 

FERRY BUILDING AND THE 

HOSPITAL OUTBUILDING AND LAUNDRY

The exterior restoration of the Ferry Building and 

the Hospital Outbuilding and Laundry were 

completed in 2002. This work was funded by two 

federal challenge grants through the Save 

America’s Treasures Program, with matching funds 

from New Jersey. Work included restoration of 

windows, masonry elements, terra cotta roof tiles, 

the copper and lead-clad tower, and replicating 

metal entry doors. Work in the Ferry Building also 

included new utilities, replacing existing steam, 

electric, and water service. As of the writing of this 

proposed development concept plan, a design for 

interior rehabilitation of the Ferry Building has 

been prepared, and construction is expected to 

begin in 2006. Funds for the interior work were 

provided through private donations to the National 

Trust for Historic Preservation's Save America's 
Relationship to Other Plans and Policies 

FINAL ENVIRONMENTAL IMPACT STATEMENT 17

Treasures Program and by the New Jersey fiscal 

year 2002 budget appropriation. 

FERRY PASSENGER SECURITY SCREENING 

Since September 11, 2001, the National Park 

Service has continued to evaluate its approach to 

security and emergency management for the park, 

including suitable locations for permanent airporttype screening facilities. In New York, the 

operation is temporarily housed in several 

connected tent structures located on the promenade 

adjacent to Castle Clinton National Monument. 

Through a memorandum of understanding with the 

New York City Department of Parks and 

Recreation, the National Park Service was granted 

permission to occupy the park to operate a 

screening facility for one year, renewable for two 

additional one-year periods. Preliminary 

evaluations and discussions with city agencies and 

other stakeholders have included consideration of 

historic Pier A, located at the northern end of the 

Battery as a potential location for visitor 

embarkation and security screening. Other locations 

are also being considered. In New Jersey, the 

passenger screening operation is currently being 

conducted in Liberty State Park. Permanent security 

screening facilities may require that the National 

Park Service obtain an interest in property. To date, 

no funding has been allocated for acquisition or 

improvements related to permanent security 

screening facilities. 

STABILIZATION PLANNING 

A plan for stabilization of all of the vacant and 

deteriorating buildings of Ellis Island was 

completed by the National Park Service in 1998. In 

1999 the Park Service began a stabilization 

campaign to secure all of the unrestored and vacant 

buildings on Ellis Island from further deterioration 

for a 10- to 15-year period. Work included removal 

of hazardous materials from some buildings, cutting 

back encroaching vegetation, temporary roof 

repairs, and sealing window and door openings. 

Work has proceeded in phases. Funding for this 

work has come from a variety of sources including 

the state of New Jersey, the park’s concession 

franchise fee program, and Congressional 

appropriations. Save Ellis Island Inc. has been 

instrumental in advocating for the stabilization 

program. At the time of this writing, stabilization 

has been completed for Island 2, and stabilization is 

almost completed for Island 3. The park has been 

exploring options for stabilization of the Baggage 

and Dormitory Building on Island 1 and expects to 

begin that building’s stabilization in 2006. 

UTILITY INFRASTRUCTURE PLANNING

In anticipation of the rehabilitation and reuse of the 

south-side buildings, the National Park Service has 

initiated a program of infrastructure planning and 

improvements to bring essential services to all of 

the buildings. Improvements call for extending 

domestic and fire protection water, storm and 

sanitary sewers, electric service and 

communications, and HVAC (heating, ventilation, 

and air conditioning) systems. The total estimate 

cost of this work is close to $10 million to 

$12 million. Work will proceed in phases as 

funding becomes available. To date, Congress has 

appropriated approximately $2 million to begin the 

first phase of this work that will extend utilities 

from the Ferry Building to the mid point of the 

corridor between Islands 2 and 3. At the time of this 

writing, this work is almost completed. The 

National Park Service expects to fund subsequent 

phases using set asides from the park’s 805 

concession fee program. 

SEAWALL REHABILITATION

The entire perimeter of Ellis Island is protected by a 

masonry seawall built of various construction 

techniques from the late 19th century to the mid1930s. Although several preservation efforts were 

undertaken in the 1980s along Island 1, today much 

of the seawall shows varying degrees of 

deterioration. Mortar joints have eroded, dislodging 

large granite blocks that have fallen into the harbor. 

In some areas, wooden piers and pilings are 

decaying and being attacked by marine borers, 

leading to erosion beneath and behind the seawall. 

Seawall settlement is most noted adjacent to the 

Ferry Building, along the east side of Island 2 and 

at the southwest corner of Island 3. The NPS Fiscal 

Year 2006 Line Item Construction Program 

includes funding for rehabilitation of approximately 

6,500 linear feet of seawall. 
PURPOSE OF AND NEED FOR THE ACTION

18 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

LIBERTY STATE PARK

TRANSPORTATION MASTER PLAN UPDATE

At the request of the Governor’s Advisory 

Committee on the Preservation and Use of Ellis 

Island, a Final Transportation Master Plan Update 

(Vollmer 2002) was issued in September 2002 for 

Liberty State Park. The goal of the updated plan 

was to develop recommendations that would aid in 

the reduction of vehicular impacts brought about by 

future development and projected levels of 

visitation. The plan is a framework that aims at 

promoting park goals, such as the preservation of 

open space and the decrease of overall park traffic 

in order to enhance park visitors’ experience. The 

plan update included a number of recommendations 

relating to the following: external access to the 

park, internal park circulation, parking facilities 

within the park, traffic flow, pedestrian use, and 

park gateways. The updated plan discusses the 

development of a managed access bridge as an 

alternate means of pedestrian travel to Ellis Island. 

The plan does suggest, however, that further 

consideration of the merits of this proposal should 

be taken up in an Ellis Island development concept 

plan / environmental impact statement. 
Alternatives 
FINAL ENVIRONMENTAL IMPACT STATEMENT 21

INTRODUCTION

RANGE OF ALTERNATIVES 

This Development Concept Plan / Final 

Environmental Impact Statement evaluates the noaction alternative and two action alternatives for the 

adaptive reuse of 30 vacant buildings on Ellis Island. 

The National Environmental Policy Act, NPS 

Management Policies (NPS 2001c), the goals 

presented in the NPS 1982 General Management 

Plan (NPS 1982) (which are refined in this 

development concept plan to reflect current 

conditions), and other relevant laws and regulations 

have all helped to direct and shape the action 

alternatives. The action alternatives also reflect input 

from workshop meetings of the interdisciplinary 

team, comments by public agencies, and suggestions 

from the general public received during the public 

scoping process for this environmental impact 

statement. “Table 1: Features of the Alternative,” 

which can be found at the end of this chapter, 

presents a comparison of the actions proposed under 

the following three alternatives: 

Alternative 1: No Action — Continuation of Existing 

Management Direction 

Alternative 2: Ellis Island Partners — Day Use only 

Alternative 3: Ellis Island Institute with Overnight 

Accommodations 

The National Environmental Policy Act requires 

analysis of “reasonable” alternatives, which are 

defined as “practical or feasible” from a technical and 

economic point of view, and those that are obvious or 

make sense. A financial feasibility and economic 

sustainability analysis, completed in 2000 (see 

appendix C), indicated that neither of the two action 

alternatives would be economically feasible in the 

traditional private development sense; however, they 

would be considered potentially feasible if, through a 

combination of project revenues and public and 

private-sector fundraising, they could generate 

sufficient capital funds for construction. The authors 

found that if approximately 30% of the cost of 

restoration could be generated from conventional 

financing, there would be a reasonably good chance 

of raising the balance from a combination of private 

and public sources. Reuse of the buildings by private 

“partners” was considered critical in making the 

restoration effort feasible and is an integral part of 

both action alternatives (alternatives 2 and 3). 

Part of the test of reasonableness is whether an 

alternative meets, either fully or to a large degree, the 

objectives presented earlier in the “Purpose of and 

Need for the Action” chapter and is within stated 

constraints. Each of the action alternatives is 

responsive to the objectives and within the 

constraints. 

In accordance with the NPS Partnership 

Construction Process (as described in the “Purpose 

of and Need for the Action” chapter), additional 

studies would be completed to test and confirm the 

programmatic and economic viability of the preferred 

alternative. This would occur prior to NPS approval 

of the project, initiation of a capital fundraising 

campaign by the park’s nonprofit partner, and design 

of facilities. If the preferred alternative is determined 

to be viable, the project would be implemented and 

the findings of these studies would be reflected in the 

project’s design and phasing. 

MITIGATION MEASURES 

AND DEVELOPMENT CONSTRAINTS

Mitigation measures and development constraints are 

specific actions that can be implemented to minimize, 

avoid, or eliminate negative impacts (see “Table 2: 

Impact Summary Chart” at the end of this chapter) on 

resources that would be affected by alternative 

actions. The National Park Service would fully 

comply with all applicable laws, regulations, and 

policies governing resource protection as described in 

the “Consultation and Coordination” chapter of this 

document. 

FACILITY DESIGN

Rehabilitation plans and designs would be consistent 

with the historic architectural themes of Ellis Island 

and the guidelines of The Secretary of the Interior’s 

Standards for the Treatment of Historic Properties 

(NPS 1995c).
ALTERNATIVES

22 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

RESOURCE PROTECTION

Natural Resources 

Areas near building rehabilitation activities would be 

revegetated with native or appropriate transplanted 

species to restore the historic landscaping appearance 

of the island. Rehabilitation efforts would comply 

with the various natural resource protection laws that 

are discussed in the “Environmental Consequences” 

chapter. 

Cultural Resources 

The quality of cultural resources would be preserved. 

Rehabilitation efforts would comply with the various 

cultural resource protection laws discussed in the 

“Environmental Consequences” chapter. Through 

consultation with project designers and the State 

Historic Preservation Offices of the states of New 

York and New Jersey, a plan would be developed to 

avoid or mitigate negative impacts on resources. 

IMPLEMENTATION PRIORITIES 

The purpose of the development concept planning 

effort is to determine the types of management 

actions that would be appropriate to enhance natural 

and cultural resource protection and visitor 

experience at Ellis Island. Market analysis and 

feasibility studies will test and confirm the economic 

viability of the preferred alternative. The findings of 

these studies and project financing will ultimately 

determine when most proposed actions could be 

implemented. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 23

ALTERNATIVE 1: NO ACTION — 

CONTINUATION OF EXISTING MANAGEMENT DIRECTION

GENERAL CONCEPT 

Under this alternative (see “Figure 2: Alternative 1, 

No Action — the Early Years”), current stabilization 

treatment of the abandoned and unused buildings 

would continue until all buildings have been 

completed. At the time of this writing, stabilization 

has been completed on Island 2 and is almost 

completed on Island 3. The park has been exploring 

options for stabilizing the Baggage and Dormitory 

Building on Island 1 and expects to begin that 

building’s stabilization in 2006. Stabilization 

measures would include temporary ventilated wood 

and Plexiglas window panels to subdue water 

infiltration and facilitate air movement; temporary 

asphalt shingle roofs on areas where the removed 

original clay tiles eventually would be replaced or 

repaired; repointing of existing brick and stone 

masonry that has failed to resist the weather; shoring 

of compromised or failing structural and exterior wall 

elements; the maintenance and temporary repair of 

gutters, leaders, and other water control techniques; 

removal and control of invasive vegetation that has 

been damaging the structures; and, subject to 

available funds, abatement and removal of debris and 

hazardous materials inside the buildings. The 

stabilization procedures are only a temporary strategy 

to slow further deterioration. Depending upon the 

condition of a particular building, stabilization might 

provide a 10- to 15-year period of suspended or 

slowed decay. 

The ongoing NPS efforts to go beyond basic 

stabilization of two of the buildings also would 

continue. The exterior of the Ferry Building has 

already been restored, and the planned interior 

rehabilitation would be completed. The exterior of 

the Hospital Outbuilding and Laundry has also been 

restored, and the plans for interior rehabilitation of 

this building would be undertaken. These ongoing 

efforts would also include several interventions in the 

corridor system and to a portion of the utilities 

infrastructure. 

The existing temporary service bridge would 

continue to be used, subject to Federal Highway 

Administration inspection and permitting, until it 

could no longer be sustained. 

Ongoing or perpetual stabilization would not be 

regarded as a viable or sustainable option because all 

structures would eventually reach a point at which 

they could not reasonably be reclaimed. While not 

provided for in this alternative, demolition and 

removal would become a logical and unfortunate 

future consequence. This would occur when 

temporary stabilization measures have run their 

course, and efforts to secure funding for 

rehabilitation have been unsuccessful. 

A decision to not install a permanent service bridge 

would lead to the eventual loss of the bridge and 

would have severe logistic and economic 

consequences for the operation, safety, and viability 

of island programs and facilities. The loss of the 

bridge would jeopardize emergency management and 

response options for the park. 

THE LATER YEARS

If efforts to secure funding for rehabilitation fail, 

ongoing or perpetual stabilization would not be a 

viable or sustainable option. Eventually, these 

structures would reach a point at which they could 

not reasonably be reclaimed, even by concerted 

efforts (see “Figure 3: Alternative 1, No Action — 

the Later Years”). Due to the differential decay in the 

structures (dependent upon such factors as specific 

location, age, and exposure), it would be difficult to 

predict precisely when a particular building might 

irretrievably deteriorate. The long-term implication 

of the no-action alternative is that once a building 

reaches this state of irretrievable disrepair, actions 

would have to be taken to prevent possible injury to 

visitors and staff. This could entail protective 

barriers, as well as demolition and removal of 

structures in the longer term. 

VISITOR EXPERIENCES AND USES

General public access to the stabilized buildings 

would not be permitted, but some opportunities 

would be provided for visitor experiences in the 

Ferry Building and the Hospital Outbuilding and 

Laundry if funding and staffing allowed and with 

assistance from park partners. These buildings would 

be used for interpretive purposes—interactive 

exhibits and programs would be developed to enable 

a better understanding of the history and use of Ellis 
ALTERNATIVES

24 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Island’s south side. Limited tours of some exterior 

grounds could also be provided for as long as they 

could be safely conducted; but again, only if funding 

and staffing were available, and park partners were 

able to assist. 

MANAGEMENT AND OPERATIONS

NPS maintenance and operations would continue as 

they are currently managed. The stabilized and 

restored buildings would be maintained as long as 

possible with continued assistance from park partners 

and as funding and staffing permitted. 

Increased Security 

The park would continue to implement measures to 

maintain a high level of security and to help protect 

visitors, employees, and park resources. Access to the 

park would continue to be intensely managed and a 

high level of security maintained at all entry points to 

the park. Airport-type screening for all passengers 

before boarding the visitor ferries to Ellis Island 

would continue to occur off site. All vehicles arriving 

via the temporary service bridge would continue to 

be subject to inspection. 

In the event of an emergency evacuation from 

Liberty or Ellis Islands, the temporary service bridge 

would be used as a primary evacuation route as long 

as it was serviceable. 

ACCESS

Visitors to Ellis Island would continue to arrive and 

depart, as they did historically, by boat to and from 

the main slip. All embarking visitors would continue 

to be screened for any items determined to be a 

security risk at facilities at Battery Park in Manhattan 

and Liberty State Park in New Jersey. 

Docking facilities for NPS staff and for the United 

States Park Police boats would be retained. No 

private marina uses would be allowed. 

The temporary service bridge underwent stabilization 

in the fall of 2002 to extend its service life for up to 

10 years. During this time the bridge will continue to 

provide access for park operations, construction 

activities, maintenance, and deliveries, as well as for 

emergency vehicles and evacuations. After this time, 

the temporary service bridge would reach its limit of 

sustainable service and would be removed. Access 

for operations, construction, maintenance, deliveries, 

and emergencies would be by boat or barge. 

COSTS

Over the next 10 to 15 years, financial costs 

associated with the no-action alternative would be 

related to completion of the stabilization program on 

the remaining buildings. In addition, some minimal 

staff and financial resources would be required to 

maintain the stabilized structures for approximately 

10 to 15 years, beyond which time, routine 

maintenance would no longer be feasible. Presently, 

approximately $1.5 million is available for 

stabilization of the Baggage and Dormitory Building. 

No specific operational funding has been provided to 

maintain the stabilization program. The park would 

continue to allocate project funding to the greatest 

extent practicable to provide staff and resources to 

maintain the stabilized structures. 

In the later years, as the useful life of the stabilization 

efforts expires, steps (such as erection of barriers or 

removal of failed or failing structures) may have to 

be taken to ensure staff and visitor safety. These 

actions, however, are not a part of this development 

concept plan, and the costs associated with them have 

not been estimated. 

The eventual removal of the temporary service 

bridge, when it is no longer safe or serviceable, is 

estimated to cost approximately $500,000. 

SUMMARY

The current management direction would result in 

rehabilitation of the Ferry Building and Hospital 

Outbuilding and Laundry and stabilization of the 

remaining buildings. The stabilization strategy was 

put into place as a temporary fix to slow further 

deterioration with the intent of being followed by 

long-term measures such as rehabilitation. A strategy 

of perpetual stabilization would not be viable over 

the long term and would mean that efforts to secure 

rehabilitation funding for the rest of the buildings had 

failed. Removal of the temporary service bridge 

would seriously compromise the park’s ability to 

respond to an emergency and would have severe 

economic and functional consequences for park 

operations as a whole. 


FINAL ENVIRONMENTAL IMPACT STATEMENT 29

ELEMENTS COMMON TO ALTERNATIVES 2 AND 3

The economic feasibility of alternatives 2 and 3 is 

dependent upon the adaptive reuse of the 

30 buildings proposed for rehabilitation. Reuse must 

also be complementary to the island’s historic themes 

and related contemporary issues. Both economic 

feasibility and reuse consistent with historic themes 

are components of an objective derived from the 

1982 General Management Plan and identified in the 

“Purpose of and Need for the Action” chapter. The 

NPS intent to seek a private-sector partner(s) to assist 

in the rehabilitation and maintenance of these historic 

structures, which is an important feature of both 

action alternatives, was also first adopted in the 1982 

General Management Plan. 

Both action alternatives would ensure the 

preservation of the defining characteristics of Ellis 

Island’s buildings and their environment while 

providing some flexibility for reasonable adaptive 

reuse proposals. The overall campus environment of 

Ellis Island would be preserved, and its characterdefining features would be retained, including 

massing and scale, spatial organization and 

circulation, distinctive spaces and architectural 

features, fenestration, building materials, and 

vegetation patterns. 

A number of other elements that are common to 

alternatives 2 and 3 are described below. 

VISITOR EXPERIENCES AND USES 

Although the action alternatives include descriptions 

of general rehabilitation treatment for each of the 

buildings, they do not identify a specific use. Instead, 

the following sections describe the types of reuses 

that the National Park Service believes would be 

appropriate at Ellis Island and the framework under 

alternatives 2 and 3 for making decisions on specific 

uses for individual structures. This approach reflects 

the NPS commitment to maximize flexibility to allow 

private-sector partners full opportunity to propose 

specific building reuse schemes and programs that 

would be appropriate and feasible in the context of an 

overall reuse plan. The range of opportunities for 

visitor experiences would largely depend upon 

building use and program offerings of the selected 

park partner(s). 

INTERPRETATION

The National Park Service has identified a variety of 

structures, landscapes, and spaces that are important 

to public understanding of the purpose and 

significance of Ellis Island. These elements would be 

preserved and interpreted to promote a broad 

understanding of their historic appearance and use. 

All exterior grounds, except where specifically 

identified for a more restricted use, would be 

included in this reuse category. In some buildings, 

selected interior spaces might be preserved or might 

be left in a stabilized “ruin-like” condition to provide 

a range of interactive experiences for visitors. Some 

areas would be open to the general public while 

others might be open only in association with one of 

the alternative reuse concepts. Management and 

interpretation would be by the National Park Service 

or other entities. 

CULTURAL/EDUCATIONAL

Within this category, a wide variety of uses would be 

appropriate in a combination of public and limited 

public space, depending on the specific nature of use, 

such as museum-type exhibits and presentations; 

theatrical events; festivals and celebrations (including 

use of outdoor spaces); research and learning centers 

for a range of for-profit and not-for-profit 

organizations; educational facilities for various 

school groups (elementary through high school); 

university-sponsored inquiry and study programs; 

genealogical research; or event spaces supporting 

cultural and educational purposes. 

DINING/FOOD SERVICE

Food service could be accommodated in various 

locations to supplement and diversify existing food 

services on the island (open to general public), and to 

exclusively support a rehabilitation concept use. A 

variety of dining and food service uses would be 

developed in support of the culinary and economic 

needs of diverse visitors. Dining and food service 

would be provided through a cooperative agreement, 

historic lease operation, and/or by NPS concession 

contract. 
ALTERNATIVES

30 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

MANAGEMENT AND OPERATIONS 

Under both action alternatives, certain structures and 

areas of the island would be set aside for current and 

future NPS operations, administration, maintenance, 

and storage. These structures and areas would be 

maintained by the National Park Service and would 

not be accessible to the general public. 

UTILITY INFRASTRUCTURE

Under alternatives 2 and 3, the National Park Service 

would provide utility infrastructure improvements to 

bring basic services to all of the rehabilitated 

buildings on Ellis Island through set asides from the 

park’s 80% concession fee program. This “federal 

share” of the rehabilitation would be used to leverage 

financial investment by the private sector and to 

demonstrate the type of financial commitment by the 

government that many philanthropic donors want to 

see as evidence of an effective partnership before 

giving support to a project. Directing and 

coordinating this work would enable the National 

Park Service to ensure that such systems are 

sufficiently flexible to serve future partner 

requirements, are environmentally sound, and are 

fully compatible with the existing or proposed 

systems of occupied structures on Island 1. 

Utility infrastructure work would include electricity, 

domestic water, sanitary and storm sewer, fire 

protection and suppression, communication/data 

systems, and centralized heating and cooling to, or to 

the immediate vicinity of, all buildings. Subsequent 

tie-in, interior distribution system(s), and metering 

configuration would vary according to the proposed 

use and partner/user needs. 

INCREASED SECURITY

Measures to provide a high level of security would be 

integral to both action alternatives. A long-term 

solution for access is critical to the park’s emergency 

management planning and operations. The security 

and emergency management implications of all 

proposals and decisions would be carefully evaluated. 

Access to the park would be stringently managed and 

a high level of security maintained at a limited 

number of entry points to the park. All visitors to 

Ellis Island by boat would continue to be screened 

prior to boarding for any items determined to be a 

security risk. Similarly, all vehicles arriving via the 

service bridge would continue to be subject to 

inspection. In the event of an emergency evacuation 

of Liberty and Ellis Islands, the service bridge to 

New Jersey would serve as a permanent, primary 

evacuation route under alternatives 2 and 3. 

ACCESS 

Both action alternatives would make continued use of 

waterborne transportation as the preferred means of 

transport for the general public. Traveling to Ellis 

Island by boat is a key component of the overall 

interpretive experience and would remain the primary 

means of visitor access. Day-use visitors to Ellis 

Island would continue to arrive and depart as they 

have historically, by boat to and from the main ferry 

slip. New uses provided for under the action 

alternatives might require dedicated ferry service that 

would tie up along the seawall adjacent to Island 2. 

To maintain adequate security, all embarking visitors 

would be screened at screening facilities at Battery 

Park in Manhattan and Liberty State Park in New 

Jersey. 

No public or private marina uses would be permitted. 

Docking facilities for the NPS staff and United States 

Park Police boats would be retained. 

To increase opportunities for low-income people to 

visit the site, a variety of programs to subsidize ferry 

fares for these visitors would be put into place. These 

might include free rides for school groups in targeted 

areas, reduced fare days, and special passes. 

SERVICE BRIDGE

FOR EMERGENCIES AND OPERATIONS 

Under alternatives 2 and 3, the current temporary 

service bridge linking Ellis Island and New Jersey 

would be replaced with a permanent bridge and 

security screening facility. Construction of a new 

bridge would occur with or without rehabilitation and 

reuse of Ellis Island’s remaining historic buildings. 

The design and location would be determined by 

subsequent environmental planning under the 

National Environmental Policy Act, and permitting 

procedures managed by the U.S. Army Corps of 

Engineers, in consultation with the U.S. Coast Guard; 

New Jersey Department of Environmental Protection; 

Jersey City and Liberty State Park, New Jersey; New 

York and New Jersey State Historic Preservation 

Offices; and other interested parties. The final 

alignment and design of a permanent service bridge 

and security screening structure would seek to 
Elements Common to Alternatives 2 and 3 

FINAL ENVIRONMENTAL IMPACT STATEMENT 31

mitigate environmental, visual, and traffic impacts on 

Ellis Island and on Liberty State Park and would 

consider additional factors such as cost and 

maintenance issues. The permanent service bridge 

would be a key element in the park’s emergency 

management program, including access for 

emergency vehicles and personnel, and for 

evacuations from Liberty and Ellis Islands. In 

addition, the service bridge would be used for 

operations, construction activities, maintenance, and 

deliveries. 

As with all other entry points to the park, access 

would be rigorously managed and a high level of 

security maintained at the service bridge where 

access would be strictly limited. General vehicular 

and pedestrian access across the service bridge would 

not be permitted because, as noted above, an 

additional entry point for the general public would 

not be prudent given the constraints imposed by 

increased security. 

COSTS 

Providing basic utilities infrastructure to all of the 

rehabilitated buildings under either alternative 2 or 3, 

is estimated to cost in the range of $10 million to 

$12 million. To date, $2 million has been spent to 

improve or provide utilities to buildings that have 

already been stabilized (under the no-action 

alternative). Removing the temporary bridge is 

estimated to cost $500,000, and replacing it with a 

permanent bridge would cost approximately 

$25 million. More precise costs of bridge removal 

and replacement would be developed as part of future 

environmental impact analysis. Funding for 

construction of a new bridge would be sought 

through Federal Highway Administration programs.
32 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

ALTERNATIVE 2: ELLIS ISLAND PARTNERS — DAY USE ONLY

GENERAL CONCEPT 

The Ellis Island Partners concept would create a 

campus of nonprofit and institutional uses that 

complement the purposes, themes, and significance 

of Ellis Island (see “Figure 4: Alternative 2, Ellis 

Island Partners — Day Use Only”). The nonprofit 

organizations and institutions that would make up the 

campus of partners would offer visitor programs and 

exhibits relating to themes such as immigrant 

contributions, worldwide immigration issues, ethnic 

diversity, tolerance, human rights, refugees, public 

health, family history, and other topics relating to the 

significance of Ellis Island. Office space for 

nonprofit organizations and institutions would be 

appropriate under this concept, but general 

commercial office space would not be permitted. 

This alternative proposes rehabilitation of Ellis 

Island’s historic buildings and landscape over a 

period of 10 to 15 years, funded solely through 

private fundraising and future federal appropriations. 

A combination of partnerships, cooperators, and 

traditional concession operations would provide 

visitor services, programs, and routine maintenance 

of buildings. The National Park Service would have 

management oversight of the entire island. All of the 

building exteriors would be restored and interiors 

completed to “core and shell” condition, which 

means that interior finishes would be provided by 

future tenants. Over time and as funding permits, all 

of the buildings on Ellis Island that have not been 

restored would be rehabilitated and occupied by a 

potentially diverse mix of cultural, educational, and 

other nonprofit institutions. To provide a visual 

comparison for visitors, one or more selected interior 

spaces would be preserved or left in a stabilized 

“ruin-like” condition for future research and 

interpretation. There would be no overnight 

accommodations. 

Outdoor areas would be programmed for themed 

events and festivals. Some visitor services might be 

provided through one or more concession 

agreements. 

VISITOR EXPERIENCES AND USES

Under this alternative, the buildings would be 

adaptively reused, primarily for interpretive uses and 

cultural/educational uses. Food services would also 

be provided, and some of the buildings would be 

reused as offices or administrative spaces for 

nonprofit organizations. The specific mix and 

distribution of uses would be determined through 

memoranda of agreement or lease or cooperative 

agreements between the nonprofit organizations and 

the National Park Service. 

Visitors to Ellis Island would have a wide range of 

opportunities to experience the buildings and spaces 

on the south side of Ellis Island and in the Baggage 

and Dormitory Building. The majority of programs 

and exhibits offered by numerous organizations 

would be open to the general public. There would be 

times, activities, and places that would likely be 

limited to users of the Ellis Island Partners; however, 

this would likely be a relatively small percentage of 

the overall space on the island. The majority of the 

office and administrative areas would not be open to 

the general public. 

Any overnight accommodations that might be 

associated with the Ellis Island Partners would be 

located off-island in New Jersey, Manhattan, or 

elsewhere. 

MANAGEMENT AND OPERATIONS

The National Park Service would undertake the 

rehabilitation work directly or through multiple 

fundraising partners. Buildings would be 

rehabilitated so as to be generally suitable for the 

range of day uses described above (refer to the 

section “Elements Common to Alternatives 2 and 3” 

that was presented earlier in this chapter). 

Rehabilitation would proceed in phases based upon 

the availability of funds and the space needs of 

partners. Priority would be placed on the 

rehabilitation and reuse of the buildings on Island 2 

to extend the rehabilitation work that was recently 

done to the Ferry Building and Hospital Outbuilding 

and Laundry. This would initially secure the 

architectural context of the ferry slip and the view 

from the Immigration Museum. 

Under the Ellis Island Partners concept, the National 

Park Service would assume the primary role in the 

management, maintenance, and upkeep of the 

buildings. A substantial increase in the park’s 

operating base would be required, although many 

functions would be accomplished through 

outsourcing and fees for services. 

Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 35

The National Park Service would enter into leases 

with multiple not-for-profit cultural/educational 

institutions and organizations to fit out and occupy 

buildings for specific purposes. The lease agreements 

would specify occupancy fees and rates for the 

various services that would be provided. 

ACCESS

Under this alternative, a new permanent service 

bridge would be a key element in the park’s 

emergency management program, including access 

for emergency vehicles and personnel, and for 

evacuations from Liberty and Ellis Islands. In 

addition, the service bridge would be used for NPS 

and Ellis Island Partner operations, construction 

activities, maintenance, and deliveries. The general 

public visiting the Ellis Island Partners facilities 

would travel to the island via ferry, as would visitors 

to the Immigration Museum. 

COSTS

As part of this plan, capital development costs (shell, 

core, exterior construction, and interior finishing 

costs), infrastructure, and net operating income for 

the Ellis Island Partners were estimated. Although 

not based on a specific development program, an 

economic analysis (see appendix C) was done to help 

understand the relative potential financial feasibility 

and sustainability of the alternatives. According to 

the financial analysis, capital development costs for 

this concept would be about $156 million. Funding 

for these costs would need to come entirely from 

governmental and philanthropic sources. Due to the 

uncertainties of occupancy and revenue, conventional 

financing would not be considered a viable option. A 

major fundraising campaign(s) would be undertaken 

to raise this money. 

Individual elements of the Ellis Island Partners’ 

cultural/educational/interpretive programs and 

activities would be capable of generating some 

revenue. However, the predominant experience for 

this kind of activity in the United States indicates that 

breaking even would be considered a financial 

success. Therefore, government appropriations would 

be required to sustain operations and provide 

adequate upkeep of the buildings. The National Park 

Service estimates it would require a park operating 

base increase of about $1.5 million annually to fund 

maintenance and other services and provide an 

additional 11 personnel needed to manage 

buildings and programs. Considerable philanthropic 

contributions would also be needed.

SUMMARY

Although the concept of a campus of nonprofit 

partners has many compelling elements, it is not the 

preferred alternative. Programs and activities of the 

various partners may not provide a clear and 

compelling public image for the island, and the 

organizations could find themselves competing with 

one another for limited private funding resources. 

The NPS role as landlord and facility manager could 

result in a far larger and more complex federal 

operation requiring additional staff, funding, and 

contracting. Due to a reliance on governmental 

appropriations and philanthropic contributions for 

capital improvements, it is anticipated that 

development of the Ellis Island Partners’ concept 

would take as long as 10 to 15 years to complete, or 

perhaps longer. These concerns, combined with the 

continuing need for substantial operating subsidies 

from governmental and philanthropic sources, make 

this alternative relatively less desirable as a long-term 

sustainable solution. 
36 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

ALTERNATIVE 3: ELLIS ISLAND INSTITUTE WITH 

OVERNIGHT ACCOMMODATIONS (PREFERRED ALTERNATIVE)

GENERAL CONCEPT 

Alternative 3 was chosen as the preferred 

alternative because it would best accomplish the 

objectives and goals derived from the 1982 General 

Management Plan (see “Table 3: Purpose and 

Objectives of Taking Action and the Means by 

Which Each Alternative Meets Them” at the end of 

this chapter). In particular, objective 3, which states 

alternatives must be economically sustainable, 

would be fulfilled to the greatest extent of any of 

the alternatives. 

The primary use would be an “Ellis Island 

Institute,” developed and managed by a nonprofit 

partner that would include cultural, interpretive, 

and educational programs and activities with a 

policy research center and administrative and study 

spaces (see “Figure 5: Alternative 3, Ellis Island 

Institute with Overnight Accommodations”). An 

associated small conference facility and overnight 

accommodations would be developed, financed, 

and managed by a professional hospitality business 

partner working with the nonprofit partner. The 

facility would host meetings, retreats, and 

workshops, focusing primarily on issues such as 

immigration, world migration, public health, 

cultural and ethnic diversity, and family history. 

The basic difference between alternatives 2 and 3 is 

alternative 3’s provision for a more fully integrated 

rehabilitation program and the use of conventional 

financing to rehabilitate buildings for overnight 

lodging and related facilities for conference 

participants. In addition, state-of-the-art telephone, 

conferencing, Internet communications, and other 

technological amenities would be provided. The 

island would provide a secure world-class venue for 

deliberation, research, and reflection that is minutes 

away from the major cultural, educational, and 

transportation facilities of New York and New 

Jersey. 

The National Park Service has been working with 

Save Ellis Island, Inc. to be the nonprofit partner 

for the preferred alternative. The business partner 

would be approved by the National Park Service 

with preference given to proposals that meet the 

park’s goals and that support the mission and 

operation of the nonprofit institute. 

The buildings would be rehabilitated and adaptively 

reused over a five- to seven-year period through a 

combination of private financing, philanthropic 

support, and government appropriations. A market 

analysis (see “Appendix C: Analysis of Relative 

Financial Feasibility and Economic Sustainability 

of EIS Alternatives”) suggests that Ellis Island 

includes many of the critical factors required for 

making such a retreat/conference facility 

successful, including association with large and 

resonant ideas, signature architecture, and 

uniqueness. Properly designed to the scale and 

historic context of Ellis Island, an “Ellis Island 

Institute” and retreat facility, in combination with 

one or more thematically related cultural 

institutions and visitor attractions, would restore an 

appropriate function and purpose to Ellis Island, 

thus ensuring its long-term rehabilitation and use. 

In accordance with the NPS Partnership 

Construction Process, additional market analysis 

and feasibility studies would be completed to test 

and confirm the economic and programmatic 

viability of the preferred alternative prior to NPS 

approval of the project, initiation of a capital 

fundraising campaign by the park’s nonprofit 

partner, and design of facilities. If it is determined 

to be viable, the project would be implemented, and 

the findings of the studies would be reflected in the 

project’s design and phasing. If the Partnership 

Construction Process results in a determination that 

the project as described is not feasible, NPS will 

further consider alternatives for management of 

Ellis Island taking into account the information 

gained from the process outlined above and other 

facts and circumstances then available. This further 

consideration of alternatives will be conducted in 

accordance with applicable requirements of the 

National Environmental Policy Act and the 

National Historic Preservation Act (as amended). 

VISITOR EXPERIENCES AND USES

Under this alternative, the buildings would be 

adaptively reused for the same functions described 

for alternative 2, including interpretation, 

cultural/educational purposes, and dining/food 

service. In addition, a maximum of 250 overnight 

guest rooms would be permitted in conjunction 

Alternative 3: Ellis Island Institute with Overnight Accommodations (Preferred Alternative) 

FINAL ENVIRONMENTAL IMPACT STATEMENT 39

with the conference facility. Lodging and dining 

could take a number of forms, and depending upon 

the design of the overall facility, be accommodated 

in various buildings. Regardless, conference 

facility buildings would be finished out to highquality standards. Rehabilitation to accommodate 

lodging and dining would recognize the limitations 

inherent in the existing floor plans, building 

configurations, existing window locations, and 

other character-defining features and spatial 

relationships. Support spaces normally associated 

with lodging (such as housekeeping, laundry, and 

maintenance) would be accommodated in a 

manner sensitive to the historic character of Ellis 

Island or be accommodated off-island. 

It is anticipated that the institute and conference 

facility would accommodate about 300 people. 

The character and size of the conference center 

would be similar to academic and institutional 

retreat centers of a comparable size. Examples of 

potential uses would include academic and 

scholarly retreats, forums, “think-tank” policy 

meetings, specialized training programs, and 

family reunions. 

Visitors to Ellis Island would be provided with a 

range of opportunities similar to those in 

alternative 2, including buildings and spaces on the 

south side of Ellis Island and in the Baggage and 

Dormitory Building. The nature and extent of these 

opportunities would depend on the specific reuse 

scenario selected. The extent and quality of the 

experiences offered to the general public are 

considered important factors in the evaluation of 

reuse proposals. 

All or portions of buildings included in the 

institute and conference facility would, at times, be 

limited to retreat participants or other users of the 

institute. Institute and conference facility attendees 

would have an opportunity for the exceptional 

experience of spending the night on Ellis Island. 

MANAGEMENT AND OPERATIONS

Historic structures and landscapes on Ellis Island 

would be rehabilitated for adaptive reuse through a 

combination of private financing, philanthropic 

support, and government funding. The institute 

would establish and manage interpretive, research, 

and educational programs. The business partner 

would manage the various hospitality elements of 

the conference facility. An agreement between the 

National Park Service, the institute, and the 

conference facility partner would define business 

relationships, responsibilities, and protocols. This 

would include marketing and “branding” of the 

facilities, programming and management 

responsibilities, scheduling procedures, and 

preferential arrangements, such as minimum 

annual allocation of facilities for the exclusive use 

of the institute, cost sharing, guidelines for 

appropriate use(s) of the facilities by others, and so 

forth. The institute and the conference facility, 

while legally and financially separate, would be 

seen and would function as a seamless entity. 

The National Park Service would provide policy 

guidance and oversight for the institute but would 

not be actively involved in management or 

operations. A small increase in the park’s 

operating base would be required. 

ACCESS

The permanent service bridge would be a key 

element in the park’s emergency management 

program, including access for emergency vehicles 

and personnel and for evacuations from Liberty 

and Ellis Islands. In addition, the service bridge 

would be used for deliveries; to support the 

operations of the park, institute, and conference 

facility; and for maintenance. Under this 

alternative, however, managed access via the 

service bridge would be provided to accommodate 

“drop-off” and “pick-up” service for attendees of 

functions sponsored by the institute and conference 

facility. 

COSTS

As part of this development concept plan, capital 

development costs (shell, core, exterior 

construction, and interior finishing costs), 

infrastructure, and net operating income for the 

Ellis Island Institute were estimated. Although not 

based on a specific development program, an 

economic analysis was completed to help 

understand the relative potential financial 

feasibility and sustainability of the alternatives. 

According to the financial analysis, capital 

development costs for the retreat/conference 

component of the institute are estimated at 

$103 million and would generate an estimated 

income of $4.8 million per year. This annual 

revenue would leverage a private investment of 
ALTERNATIVES

40 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

about $48 million, a significant portion of the 

overall development costs. An updated financial 

analysis would be completed prior to NPS 

approval of the project, initiation of a capital 

fundraising campaign by the park’s nonprofit 

partner, and design of facilities. It is assumed that 

the developer of the conference facility would be 

able to obtain conventional financing for a portion 

of the conference facility development costs and 

make use of investment tax incentives under the 

National Historic Preservation Act of 1966 (16 

U.S.C. 16,470a-1(a)(170 ed.), as amended. Given 

the high cost of rehabilitating the buildings at Ellis 

Island, and the limits being placed on their uses, 

the retreat component might not generate sufficient 

revenue to cover its operating costs and the high 

level of debt that would be incurred for capital 

development. Thus, the facility might not be 

economically feasible in the conventional profitmaking sense of the word, and some sort of gap 

assistance might be needed. Such assistance would 

be sought through private fundraising. Prior to 

NPS approval of the project, the overall economic 

viability of the preferred alternative and the 

amount of gap assistance needed would be 

identified through additional market analysis and 

financial feasibility studies. Capital development 

costs for the cultural/educational/interpretive 

components of the institute would be estimated at 

$45 million. Funding for these elements would be 

expected to come primarily through philanthropic 

contributions raised during a fundraising 

campaign(s) by the nonprofit partner. In addition, 

the National Park Service would seek special 

legislation to enable the nonprofit to qualify for the 

preservation tax credit. It is anticipated that the 

cultural/educational /interpretive components of 

the institute would, by being well programmed and 

marketed, be capable of generating some revenue. 

However, as noted in alternative 2, this kind of 

venture is considered a success if it is able to 

simply break even on its operating costs. 

Nevertheless, the fundraising campaign(s) would 

seek contributions to set up an endowment that 

could function as an operating subsidy for the 

institute. 

A small increase to the park’s operating base 

would be required for administration and 

coordination with the institute. It is estimated that 

an increase of $466,000 for four staff would be 

sufficient for these activities. 

PROJECT FEASIBILITY / DUE DILIGENCE

In accordance with the Partnership Construction 

Process, this project would be subject to 

Congressional review and approval of the project 

concept and fundraising proposal prior to any 

fundraising activities or design development. The 

project would also be reviewed by the NPS 

Development Advisory Board. 

As part of the due diligence required by the 

Partnership Construction Process, implementation 

of this project would be subject to the findings and 

recommendations of a number of additional studies 

to be undertaken by the park’s partner, Save Ellis 

Island, Inc., and the National Park Service. These 

studies would provide additional information to 

determine the programmatic and economic 

feasibility of creating the Ellis Island Institute and 

Conference Center. Initially, some of the studies 

may be done on a limited basis, then updated in 

greater detail after certain milestones have been 

reached. As part of its review and evaluation of 

these studies, the National Park Service may seek 

an independent peer review of the assumptions, 

conclusions, and recommendations. 

Additional studies would include the following: 

Architectural Master Plan — architectural 

study based upon the recommendations of this 

Development Concept Plan / Final 

Environmental Impact Statement to identify 

options for layout and building use for the 

Ellis Island Institute and Conference Center, 

including a Class C Cost Estimate. 

Market Study — updated market analysis to 

provide current market information relative to 

the demand for the conference facility and 

relationship with other conference facilities, 

including proposals for future development of 

Governors Island. 

Institute Strategic Plan — including a market 

analysis for the public programming elements 

of the institute. 

Financial Feasibility — financial feasibility 

analysis, including a proforma analysis for the 

conference facility. 

Fundraising Feasibility — updates an earlier 

(2004) study to evaluate private-sector interest 

and potential financial support for general 
Alternative 3: Ellis Island Institute with Overnight Accommodations (Preferred Alternative) 

FINAL ENVIRONMENTAL IMPACT STATEMENT 41

capital expenditures for rehabilitation and 

program development and implementation, as 

well as an endowment. 

The National Park Service and its partner would 

use the findings of the above studies to define a 

preliminary program for the project, including 

overall cost estimates, anticipated developer 

financing projections, and projected operating 

costs and revenues. The preliminary program 

would be evaluated relative to 

feasibility and appropriateness 

financial feasibility 

benefit to the general public 

risk to the government 

impact on park management and operations 

The preliminary program would be used in 

negotiating terms with prospective business 

partners. The agreed-upon plans and financials of 

the selected business partner would be used by the 

National Park Service and Save Ellis Island, Inc. to 

refine the fundraising needs of the project within a 

fundraising proposal. If the Partnership 

Construction Process results in a determination 

that the project as described is not feasible, NPS 

will further consider alternatives for management 

of Ellis Island taking into account the information 

gained from the process outlined above and other 

facts and circumstances then available. This 

further consideration of alternatives will be 

conducted in accordance with applicable 

requirements of the National Environmental Policy 

Act and the National Historic Preservation Act (as 

amended). 

SUMMARY

The ability to use a combination of funding 

sources, including conventional debt financing to 

put together a comprehensive development 

package that achieves park goals and that can 

accomplished in five to seven years, provides a 

compelling reason to select the “Ellis Island 

Institute” concept as the preferred reuse 

alternative. In accordance with the NPS 

Partnership Construction Process, additional 

market analysis and feasibility studies would be 

completed to test and confirm the economic and 

programmatic viability of the preferred alternative 

prior to NPS approval of the project, initiation of a 

capital fundraising campaign by the park’s 

nonprofit partner, and design of facilities. If it is 

determined to be viable, the project would be 

implemented, and the findings of these studies 

would be reflected in the project’s design and 

phasing. 

The institute would provide a new international 

forum to present and discuss historic and 

contemporary issues associated with world 

migration and public health. The institute’s 

purpose and mission would have the potential to 

resonate with individual and corporate donors, as 

well as foundations. Few locations in the United 

States have as much name recognition and unique 

meaning as Ellis Island. Its name is recognized by 

most Americans, as well as people around the 

world. 

ALTERNATIVES ELIMINATED 

FROM FURTHER CONSIDERATION 

As noted above, all possible reasonable 

alternatives were screened for technical, logistic, 

and economic feasibility, as well as for their ability 

to achieve stated objectives for this plan. They also 

needed to be within the stated constraints, 

including consistency with NPS Management 

Policies, The Secretary of the Interior’s Standards 

for the Treatment of Historic Properties (NPS 

1995c), the goals and objectives contained in the 

1982 General Management Plan and refined in 

this development concept plan, and the cultural 

resources and historic themes of Ellis Island. Only 

those able to pass all tests were included for 

environmental analysis. 

Some of those considered but rejected because 

they were not reasonable include the following: 

SUBSTANTIAL NEW CONSTRUCTION

The Secretary of the Interior’s Standards for 

Treatment of Historic Properties (NPS 1995c) and 

the accompanying guidelines allow for a 

contemporary use through alterations and 

additions, but such alterations and additions, to be 

in accord with the standards, should not radically 

change, obscure, or destroy character-defining 

features and spatial relationships. Substantial new 

construction was eliminated from further 
ALTERNATIVES

42 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

consideration because the addition of new 

buildings would radically change the campus 

setting of the buildings that has continued to 

characterize the site over time despite numerous 

phases of development and subsequent decline. 

DEMOLITION

The inter-connected buildings and corridors of 

Ellis Island, including their organization, massing, 

scale, and architectural detailing, are also 

character-defining features. Historically, each 

structure served a specific function that related to 

the operation of the whole. While the functions 

would change with adaptive reuse, and minor 

alterations would be possible as long as they are 

consistent with the guidelines of The Secretary of 

the Interior’s Standards for the Treatment of 

Historic Properties, demolition of structures was 

eliminated from further consideration because the 

loss of any structure or structures would 

compromise the integrity of the entire campus. 

DOMINANT RETAIL OR 

COMMERCIAL OFFICE USES

This plan provides for the rehabilitation and 

adaptive reuse of Ellis Island’s vacant buildings 

for purposes that support, enrich, or complement 

the historic themes and related contemporary 

issues associated with Ellis Island’s rich legacy. 

The plan identifies the types of uses that would be 

appropriate for inclusion in an adaptive reuse 

development. Commercial office space and 

dominant retail uses were not given further 

consideration because these uses would be 

inconsistent with park purposes and significance 

and, thus, inappropriate for inclusion in a reuse 

scenario for Ellis Island.

PEDESTRIAN USE OF SERVICE BRIDGE

Since the events of September 11, 2001, enhancing 

security at the Statue of Liberty National 

Monument and Ellis Island has been a priority for 

the park. Improvements to the security elements of 

park operations are being implemented with advice 

and consultation from security experts from both 

the public and private sectors. The security 

implications of all actions are being carefully 

considered. Strict management of entry points is a 

fundamental tenet of the overall security strategy. 

Use of the service bridge for pedestrian access to 

Ellis Island was eliminated from further 

consideration because introducing a new location 

for general public entry would be inconsistent with 

the requirements of increased security. From a 

security point of view, increasing the number of 

entry points to the park would pose an 

unacceptable risk. This same reasoning applies to 

creating an underground tunnel connecting the 

mainland with Ellis Island. 
FINAL 

ENVIRONMENTAL IMPACT STATEMENT 43

TABLE 1: FEATURES OF THE ALTERNATIVES

Plan Elements 

Alternative 1: Continuation of Existing 

Management Direction 

(No Action) 

Alternative 2: Ellis Island Partners — 

Day Use Only 

Alternative 3: Ellis I

Overnight Acc

(Preferred A

Building Stabilization / Rehabilitation  Currently scheduled stabilization of unused 

buildings would continue. 

Preservation of the defining characteristics of all buildings, while allowing some flexibility for reasonable adaptive reuse proposals. 

Same as alternative 2. 

 Stabilization measures include temporary 

ventilated wood and Plexiglas window panels to subdue water infiltration and facilitate air movement. 

Treatment of all buildings would be based on The Secretary of the Interior’s Standards for Rehabilitation. 

Same as alternative 2. 

 Placement of temporary asphalt shingle roofs 

where original clay tiles were removed; some repair of damaged clay tiles. 

Overall campus environment of Ellis Island would be preserved and its character-defining features would be retained, including massing and scale, spatial organization and circulation, distinctive spaces and architectural features, fenestration, building materials, and vegetation patterns. 

Same as alternative 2. 

 Repointing of existing brick and stone masonry. Rehabilitation would proceed in phases over a 

period of 10 to 15+ years as funds are available. 

This alternative would preto rehabilitation at the staaccomplished in a 5- to 7

 Shoring of compromised or failing structural and 

exterior wall elements. Maintenance and temporary repair of gutters, leaders, and other water-control techniques. Removal of invasive vegetation that have caused structural damage. Abatement and removal of debris and hazardous materials inside the buildings. Continue with plans to rehabilitate the interiors of the Ferry Building and the Hospital Outbuilding and Laundry (exterior restorations have been completed). Potential stabilization of the Baggage and Dormitory Building on Island 1. 
44 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND Plan Elements Alternative 1: Continuation of Existing Management Direction (No Action) Alternative 2: Ellis Island Partners — Day Use Only Alternative 3: Ellis I

Overnight Acc

(Preferred A

Visitor Experiences and Uses General public access to stabilized buildings not permitted. Contingent on funding and staffing, some visitor access to the Ferry Building and Hospital Outbuilding and Laundry for interpretive uses. Contingent on funding and staffing, some limited tours of exterior grounds. The Ellis Island Partners concept would create a campus of nonprofit and institutional uses that complement the purposes, themes, and significance of Ellis Island. Office and meeting room space for nonprofit organizations and institutions would be available; general commercial office space would not be permitted. Primary use would be the 

that would include a smafacility with state-of-the-ainfrastructure, overnight lresearch center, and admspaces. Capacity of the institute awould be approximately 3

Lodging Lodging No overnight accommodations on the island. A maximum of 250 overn

be permitted in conjunctiofacility; spaces required fpurposes (i.e., housekee

Interpretation Interpretation A variety of structures, landscapes, and spaces would be preserved and interpreted to promote a broad understanding of their historic appearance and use. Same as alternative 2. Exterior grounds (except where indicated) would be included for interpretive uses. Same as alternative 2. Some interior space would be left in a ‘”ruin-like” or preserved condition to provide a range of interactive experiences. Same as alternative 2. There would be a wide range of opportunities for visitor experiences. The majority of programs and exhibits would be open to the general public. A small percentage of areas, times, and activities would be limited to Ellis Island Partners. Office and administrative areas would not be open to the general public. Management of visitor programs and interpretation would be primarily by NPS staff with some outsourcing. There would be a range o

experiences but nature aon the specific reuse scethe institute and conferenbe limited to retreat particusers. Retreat participantspending the night at Ellis Management of visitor printerpretation would be pIsland Institute with oversby the National Park Serv
FINAL 

ENVIRONMENTAL IMPACT STATEMENT 45

Plan Elements 

Alternative 1: Continuation of Existing 

Management Direction 

(No Action) 

Alternative 2: Ellis Island Partners — 

Day Use Only 

Alternative 3: Ellis I

Overnight Acc

(Preferred A

Cultural/Education Cultural/Education 

 A wide variety of uses would be appropriate in a 

combination of public and limited public-use spaces. 

Same as alternative 2. 

 Uses could include museum-type exhibits and 

presentations, theatrical events, festivals and celebrations, research and learning centers, educational and cultural purposes, study programs, genealogical research. 

Same as alternative 2. 

Dining/Food Service Dining/Food Service 

 General public food service available in various 

locations. Food service to support specific concept uses. Dining and food service provided through a cooperative agreement, historic lease operation, or NPS concession contract. 

Same as alternative 2. Food service to support sand overnight guests. Same as alternative 2. 

Management/Operations/Security  No change in NPS management of maintenance 

and operations. 

Certain structures and areas would be set aside for NPS operations, administration, maintenance, and storage. These structures/areas would be maintained by the National Park Service and would not be accessible to the general public. 

Same as alternative 2. 

 Stabilized and restored buildings would be 

maintained as long as funding is available. 

The National Park Service would have overall facility management responsibility. 

The retreat / conference fassume most facility manresponsibilities. 

 Enhanced program to provide greater levels of 

security. 

 Use of the temporary service bridge for 

emergency access and evacuation for as long as it is serviceable. 

Utility infrastructure improvements would be provided by the National Park Service through set asides from the park’s 80% concession fee program. 

Same as alternative 2. 

 High level of security at all entry points. All 

embarking visitors would be screened at the screening facilities at Battery Park and Liberty State Park. Entry at temporary service bridge would be strictly managed, and all vehicles would be inspected. 

Program to provide high levels of security, including emergency and evacuation procedures. 

Same as alternative 2. 
46 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND Plan Elements Alternative 1: Continuation of Existing Management Direction (No Action) Alternative 2: Ellis Island Partners — Day Use Only Alternative 3: Ellis I

Overnight Acc

(Preferred A

Permanent use of service bridge for emergency access and evacuations. Same as alternative 2. High level of security at limited number of entry points. All embarking visitors would be screened at the screening facilities at Battery Park and Liberty State Park. Entry at service bridge would be strictly managed, and all vehicles would be inspected. Same as alternative 2. Access Primary method of visitor access to the island would continue to be by ferry. Same as alternative 1. Same as alternative 1. All embarking visitors would be screened at the screening facilities at Battery Park and Liberty State Park. Same as alternative 1. Same as alternative 1. No public or private marina uses would be permitted. Same as alternative 1. Same as alternative 1. Docking facilities for NPS staff and U.S. Park Police boats would be retained. Same as alternative 1. Same as alternative 1. A variety of programs to subsidize ferry fares for low-income visitors, free rides for school groups, reduced fare days, special passes would be implemented. Same as alternative 2. Recent stabilization of the temporary service bridge would extend service life another 10 years; bridge would be removed when it reached its limit of sustainable service. After bridge removal, access for all uses (visitor, operations, construction, maintenance, deliveries, and emergencies) would only be by boat or barge. A permanent service bridge and security facility would be constructed with or without rehabilitation and reuse of Ellis Island’s remaining historic buildings. The location would be determined by subsequent permitting procedures. Same as alternative 2. General vehicular and pedestrian access across the service bridge would not be permitted. Same as alternative 2. Managed access would b

authorized vehicles for drconference/retreat attend
FINAL 

ENVIRONMENTAL IMPACT STATEMENT 47

Plan Elements 

Alternative 1: Continuation of Existing 

Management Direction 

(No Action) 

Alternative 2: Ellis Island Partners — 

Day Use Only 

Alternative 3: Ellis I

Overnight Acc

(Preferred A

Costs/Funding  Park would use existing staff and funding as 

much as possible to maintain the stabilized buildings. Current stabilization—$1.5 million for the Baggage and Dormitory Building. 

Funding for rehabilitation and maintenance of all existing buildings would come from a combination of philanthropic contributions and future government appropriations, with relatively shortterm lease agreements; conventional financing by partners would not be considered a viable option. Estimated costs for the Ellis Island Partners concept would be $156 million. Ellis Island Partners’ cultural, educational, and interpretive programs would generate some level of revenue. 

Private-sector financial arehabilitation and maintebuildings. Conference/retreat facility approximately $103 milliowould obtain conventionaof costs and some fundininvestment tax incentives National Historic Preserv

 Some buildings would be 

adaptively reused througprivate financing, philanthgovernment appropriationcultural/educational/interpthe institute estimated to 

 Removal of temporary bridge—$500,000. Removal of temporary bridge—$500,000. 

Replacement bridge—approximately $25 million. 

Same as alternative 2. 

 Funding for construction of the new permanent 

bridge would be sought through Federal Highway Administration programs. 

 Utilities infrastructure to rehabilitated buildings 

estimated at $10 million to $12 million. 

Same as alternative 2. 

 Increase of park operating budget of $1.5 million 

for 11 additional personnel and other services. 

Increase of park operatin4 additional personnel an
48 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

TABLE 2: IMPACT 

SUMMARY 

CHART

Impact Topic 

Alternative 1: Continuation of Existing 

Management Direction 

(No Action) 

Alternative 2: Ellis Island Partners — 

Day Use Only 

Alternative 3

With Overn

(Prefe

Cultural Resources Historic Architectural Resources 

Stabilization of remaining Ellis Island structures provides a localized, minor benefit. Rehabilitation of the interiors of the Ferry Building and Hospital Outbuilding and Laundry provides a moderate, site-specific benefit. Bridge removal results in potential major adverse impact to historic structures due to increased risk of fire damage/loss. 

Historic structure rehabilitation efforts under alternative 2 would provide moderate benefits to cultural resources. 

Same as alter

 The eventual loss of many, if not all, of the eligible 

properties on Ellis Island and impairment of NPS historic architectural resources. 

No impairment of park resources. Same as alter

Cultural Landscape Due to the lack of a long-term preservation strategy 

under this alternative, the eventual loss of the cultural landscape is likely and could result in impairment of NPS resources. 

The rehabilitation and reuse of the cultural landscape proposed under alternative 2 would result in a moderate, site-specific benefit to cultural resources on Ellis Island compared to no action. 

Same as alter

 Major benefit to the original cultural landscape from 

the removal of the temporary service bridge, with no bridge replacement. 

The construction of a new bridge could have long-term, moderate adverse impacts to the cultural landscape of Ellis Island and several surrounding National Register properties. Construction of a permanent bridge would offer an unknown benefit to the cultural resources of Ellis Island by providing a high level of protection from fire damage/loss. 

Same as alterSame as alter

Archeological Resources It is believed that the no-action alternative does not 

have the potential to adversely affect archeological resources in a manner that would jeopardize their National Register characteristics. 

Small-scale dredging activities proposed under alternative 2 could potentially result in minor, site-specific adverse impacts in its potential to affect cultural deposits. 

Same as alter

Geologic Resources, Soils, and Marine Sediments Geology and Soils Negligible impact to soils could occur from filling 

the seawall after removing the temporary service bridge. 

Negligible to minor impact to soils could occur from filling the seawall after removing the temporary service bridge. Additional negligible to minor impacts from excavating for new underground utility connections, grading new access roads to the permanent bridge landings, 

Same as alter
FINAL 

ENVIRONMENTAL IMPACT STATEMENT 49

Impact Topic 

Alternative 1: Continuation of Existing 

Management Direction 

(No Action) 

Alternative 2: Ellis Island Partners — 

Day Use Only 

Alternative 3

With Overn

(Prefe

and grading for construction staging areas. 

Marine Sediments Localized negligible or minor temporary 

disturbance to marine sediments in the channel between Ellis Island and the state park could occur from removing pilings for the temporary service bridge under all three alternatives. 

Localized negligible or minor temporary disturbance to marine sediments in the channel between Ellis Island and the state park could occur from removing pilings for the temporary bridge and completing construction of a new bridge. Impacts could extend for at least twice as long compared to the no-action alternative. 

Same as alter

Floodplains Flood risk Removing the temporary service bridge and 

sealing the floodwall could result in minor beneficial impacts from flood prevention. 

Removing the temporary service bridge and sealing the floodwall could result in minor beneficial impacts from flood prevention. 

Same as alter

Access No long-term impact from flooding. During extreme weather events, bridge could be 

somewhat flooded and restrict vehicular access. 

Same as alter

Vegetation, Fish, and Wildlife Vegetation Negligible to minor temporary impacts from 

clearing construction area to remove temporary service bridge. 

Additional negligible to minor temporary impacts from activities to construct permanent bridge, as well as long-term loss to build new bridge features such as access roads and landings. 

Same as alter

Protected plant species No impacts expected. Minor to moderate impacts to two species listed 

by New Jersey as species of special concern from replanting courtyards on Ellis Island. 

Same as alter

Fish Minor to moderate short-term impacts from 

increased mobility of sediments and potential toxins during temporary service bridge removal. 

Compared to no action, additional moderate impacts from increased suspension of sediments and increased turbidity and concentrations of toxins from bridge construction. 

Same as alter

Wildlife—construction Short-term minor impacts through disturbance and 

possible displacement from construction activity. 

Same as alternative 1, except the duration of activity and resulting impacts could be at least double, resulting in minor to moderate impacts. 

Same as alter

Wildlife—long term No long-term impacts are anticipated. Habitat would be removed to create such bridge 

features as access roads and landings. In addition, car and truck traffic using the bridge could permanently disturb or displace wildlife near the landings. Planting courtyards could remove existing bird and other wildlife habitat. All of the above would result in minor impacts to wildlife. 

Same as alternegligible to mfrom the nighthumans and li
50 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND Impact Topic Alternative 1: Continuation of Existing Management Direction (No Action) Alternative 2: Ellis Island Partners — Day Use Only Alternative 3

With Overn

(Prefe

Protected wildlife—short term Short-term disturbance and possible displacement from construction activity with minor effects possible to Savannah sparrow and seasonal resident bird species. Same as alternative 1, except the duration of activity and resulting impacts could be at least double. Minor to moderate impacts to Savannah sparrows, and minor impacts to other seasonal protected bird species. Same as alterProtected wildlife—long term No long-term impacts are anticipated. Possible minor impacts from the removal of Savannah sparrow habitat near the bridge landing or the presence of truck traffic along the bridge. Same as alterWater Resources Surface Water An unknown degree of increase in turbidity and suspension of toxins currently in marine sediments could result from removing bridge pilings. Impacts could range from minor to major for the construction period. Additional negligible impacts from surface disturbance, fuel leaks, etc. during construction are possible. No long-term impacts are anticipated. Same as alternative 1 for bridge removal activities. Additional likely moderate short-term impacts could result from the same activities associated with the construction of a permanent bridge. No long-term impacts are anticipated. Same as alterGroundwater No impacts to groundwater are expected. Unknown negligible to major impacts to groundwater aquifers from dewatering or contamination are possible, but not likely, if bridge landing locations require extensive groundwater pumping. Same as alterAir Quality and Noise Air Quality Temporary emissions associated with construction vehicles would only be detectable in the immediate area. No detectable area-wide changes in air quality would result from construction or increased visitor use. Same as no action, except emissions are expected to increase by about 5% over no action. Negligible to minor impacts. Same as alterNoise Very loud noise (some over 100 decibels) would occur for short periods of time, with resulting short- term severe impacts to wildlife and visitors. The same very loud noise (over 100 decibels) could continue for at least twice as long as no action to build a permanent bridge and complete rehabilitation of historic structures. Same as alter
FINAL 

ENVIRONMENTAL IMPACT STATEMENT 51

Impact Topic 

Alternative 1: Continuation of Existing 

Management Direction 

(No Action) 

Alternative 2: Ellis Island Partners — 

Day Use Only 

Alternative 3

With Overn

(Prefe

Hazardous Materials Marine Sediments The resuspension of marine sediments could result 

in unknown, but likely no more than minor impacts from increased concentrations of heavy metals and other contaminants. The impacts would be temporary. 

Resuspension of marine sediments and associated toxins related to bridge removal and new bridge construction could continue for at least twice as long as under the no-action alternative. 

Same as alter

Soils No impact from disturbing soils is expected. Minor to moderate impacts to workers who could 

be exposed to heavy metals and other contaminants in soils during grading or excavating for permanent bridge landings or access roads. Long-term impacts negligible or nonexistent because of clean-fill cap. 

Same as alter

Structure Rehabilitation Negligible risk to workers removing asbestos and 

lead-based paint during stabilization because of standard mitigation. 

Negligible risk to workers removing asbestos and lead-based paint during rehabilitation because of standard mitigation. 

Same as alter

Social and Economic Environment Tourism Tourism would increase by a negligible to minor 

amount each year over the life of the plan. 

Extended programming would provide an additional minor benefit to tourism, which is expected to increase at a slightly higher rate than under no action. 

Same as alter

Park Administration—Emergency Response 

Emergency response times without bridge access are expected to increase by up to 10 fold, with resulting possible major impacts to the park’s ability to provide fire, ambulance, or police protection. 

No impacts to existing conditions would occur; however, compared to no action, a permanent bridge could provide up to major relative benefits in the park’s ability to provide fire, ambulance, or police protection. 

Same as alter

Transportation and Circulation Access to Ellis Island Minor to moderate increases in ferry traffic and 

decreases in car and truck traffic to Ellis Island could result in the long term from bridge removal. 

No impacts relative to existing conditions would occur; however, compared to no action, minor to moderate relative decreases in ferry traffic and increases in car and truck traffic from New Jersey to the island would occur. 

Same as alter

Parking Negligible impacts to parking may occur at Liberty 

State Park from increased visitation under the noaction alternative. 

Negligible to minor impacts to parking in Liberty State Park could occur from increases in visitation expected from either action alternative. 

Same as altercloser to minoadditional requovernight gue

Circulation Undetectable to negligible impacts to levels of 

service at intersections in the area are attributable 

to increased visitation resulting from any of the alternatives. 

Same as alternative 1. Same as alter
52 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND Impact Topic Alternative 1: Continuation of Existing Management Direction (No Action) Alternative 2: Ellis Island Partners — Day Use Only Alternative 3

With Overn

(Prefe

Visitor Experience Long Term Minor adverse impacts to the visitor experience could continue to occur from a lack of access to the larger experience of Ellis Island’s historic structure and cultural landscape. The combination of significantly increased visitor access to the majority of Ellis Island and the expansion of interpretive offerings could result in a major benefit to the visitor experience at Ellis Island. Additional visi

would derive fconference anoption of overaccommodatiowould be simi

Short Term Negligible to minor impacts to the visitor experience from construction noise and dust associated with bridge removal and stabilization of buildings on Ellis Island. Similar impacts as no action, but the period of time visitors would be subjected to construction noise and dust, and its effect on the visitor experience, would be at least twice as long. Same as alterSite Infrastructure Utilities Existing utilities would remain as they are now. Moderate benefits to the site from completing electrical and water utilities would take place. Same as alter
FINAL ENVIRONMENTAL IMPACT STATEMENT 53

TABLE 3: PURPOSE AND 

OBJECTIVES OF 

TAKING 

ACTION AND THE 

MEANS BY 

WHICH 

EACH 

ALTERNATIVE 

MEETS 

THEM 

Purpose and Objectives 

Alternative 1: Continuation of Existing 

Management Direction 

(No Action) 

Alternative 2: Ellis Island Partners — 

Day Use Only 

Alternative 

With Overn

(Prefe

Provide for the long-term rehabilitation, reuse, and protection of cultural and historic resources on Ellis Island. 

The interiors of the Ferry Building and the Hospital Outbuilding and Laundry will continue to be rehabilitated; the remaining 28 buildings will be stabilized, but will eventually deteriorate. The long-term purpose and objective would not be met. 

All historic buildings will be rehabilitated and reused through a phased program that relies exclusively upon philanthropic contributions and government appropriations. Dependent upon donations and public appropriations, the rehabilitation work may take 10 to 15 years or more to complete. 

All of the builditimely and cooand adaptively of a public/privImprovements five to seven y

Protect the island’s cultural and natural resources 

Natural resources would continue to exist as they are currently, and would be protected in compliance with NPS Management Policies and other relevant 

statutes. 

Same as alternative 1. Same as altern

Provide for the long-term rehabilitation and adaptive reuse of the island’s Beaux Arts campus of integrated brick, stucco, and tile structures, with connecting corridors of masonry and glass, within a designed landscape of lawn and mature trees. 

This objective would not be met. Individual buildings would eventually be lost when stabilization efforts can no longer preserve the building for any adaptive reuse. 

Over an extended period of time, the entire campus of buildings would be rehabilitated by the National Park Service with the possible assistance of one or more nonprofit partners consistent with TheSecretary of the Interior’s Standards for the Treatment of Historic Properties. 

The park would partner, Save Ethe Ellis Island small conferenfinanced, devehospitality busiprogrammatic appendix D) amNew Jersey StOffices, the AdPreservation, aService would review and appwork. 

Provide uses that complement the island’s historic themes and related contemporary issues and that can be economically sustained. 

This objective would not be met. The stabilized buildings would accommodate no uses and would eventually be lost altogether. 

The nonprofit organizations would offer programs and exhibits that relate to the park’s historic themes and related contemporary issues. Organizations would offer interpretive and educational programming on the island. Tenants would fund fit-out costs of space and would make lease payments to the park to help defray the overall cost of maintaining the buildings and landscape. 

The Ellis Island programs, worrange of immigissues related themes of Ellis partner would ufinancing and tincentive progrcosts. Revenue center would band operating 
54 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND Purpose and Objectives Alternative 1: Continuation of Existing Management Direction (No Action) Alternative 2: Ellis Island Partners — Day Use Only Alternative 

With Overn

(Prefe

Significant operating subsidies would be needed from governmental and private philanthropic sources to offset annual operating deficits. Some gap ass

subsidize annu

Provide enhanced opportunities for visitors to understand and experience Ellis Island’s history including managed public access to most of the island’s cultural landscape. This objective would not be met. The visiting public would be restricted from any access to the south side of Ellis Island. Visitors would have general access to the majority of the grounds and many of the common areas within the rehabilitated buildings. Visitors would 

majority of the less access to public spaces wbuildings. Provide a high level of security and safety for the visitors, staff, and resources of Ellis and Liberty Islands, and the ability to respond quickly in emergency situations. A high level of security would be provided, although the eventual loss of the temporary service bridge, when it can no longer be maintained, will have a severe impact on the NPS’s ability to provide for the safety and security of resources and visitors in emergency situations. A high level of security would be provided. Visitors to Ellis Island by ferry would be screened before boarding in Manhattan and New Jersey. All vehicles utilizing the service bridge would be thoroughly screened before crossing. The service bridge would significantly improve emergency response time and evacuation. A high level of provided. Visito

would be screeManhattan and utilizing the sescreened. The a critical role in response and e

Provide thematically appropriate, safe, and economically viable access to and from the island in support of its adaptive reuse and security requirements. This objective will no longer be met when the temporary service bridge can no longer be maintained and must be removed. All transportation to and from the island would be by boat or barge. Service, maintenance, and emergency response operations will be compromised and more costly following the loss of the service bridge. Most visitors to Ellis Island would continue to arrive by ferry as immigrants did historically. The permanent service bridge will facilitate the rehabilitation and maintenance of the island’s historic structures by providing an economically feasible means of access for construction, operations, and management activities. Most visitors to 

and the Ellis Iscontinue to arrservice bridge economic feasinstitute/retreat operating/maninstitute/retreat dropped off or authorized and utilizing the se
Affected

Environment 
FINAL ENVIRONMENTAL IMPACT STATEMENT 57

INTRODUCTION 

This chapter provides a general description of the 

environment of Ellis Island and the surrounding study 

area. It is divided into two sections: this introduction 

section, which identifies important or interesting 

information about the park or study area; and the 

“Affected Environment” section, which describes the 

resources that could experience effects from one or 

more of the actions in the alternatives. The “Affected 

Environment” section describes the cultural, natural, 

socioeconomic, and logistic (such as traffic and 

infrastructure) elements of the environment. An 

impact analysis corresponding to each of the topics in 

this section is provided in the “Environmental 

Consequences” chapter that follows. 

Additional information about the park is available by 

reading the Statue of Liberty National Monument

General Management Plan prepared by the National 

Park Service in 1982. Although the General 

Management Plan was prepared 20 years ago, its 

stated goals are relevant today. For example, the 

General Management Plan identified the need for 

$50 million to restore the northern half of Ellis Island 

as an immigration museum and suggested the 

possibility of leasing the south side of the island to 

the private sector. That same year, the Secretary of 

the Interior established the Statue of Liberty-Ellis 

Island Centennial Commission, and the Statue of 

Liberty-Ellis Island Foundation was set up as the 

fundraising arm. In October 1976, Ellis Island was 

placed on the National Register of Historic Places 

(National Register). 

In 1986 a temporary service bridge was constructed 

from Liberty Park, on the New Jersey mainland, to 

Ellis Island to aid in the construction of the museum 

and visitor center. The bridge was permitted and 

constructed as a temporary structure planned for 

removal after its construction-related purpose was 

fulfilled. The bridge remains in operation today and 

was stabilized in 2002. While all alternatives include 

removal of this bridge, alternatives 2 and 3 

contemplate construction of a permanent service 

bridge in its place. 

In 1990 restoration of the Main Building, the largest 

historic restoration project in United States history 

was completed. The restored Main Building reopened 

as the Ellis Island Immigration Museum to celebrate 

the American immigrant experience. Over 20 million 

people have visited the museum since it opened. In 

the year 2000, the number of visitors to the museum 

reached nearly 2 million. Visitor numbers dropped to 

1.5 million people in 2002 following the attacks of 

September 11, 2001, but are expected to rise steadily 

in the coming years. In 1996 the entire south side of 

Ellis Island was named one of the world’s “most 

endangered sites” by the World Monuments Fund. 

The following year, the National Trust for Historic 

Preservation listed the abandoned buildings of Ellis 

Island as one of the nation's “most endangered 

historic places.” 

In 1998 a long-standing jurisdictional dispute was 

finally settled by the U.S. Supreme Court when it 

granted the State of New Jersey sovereignty over 

22.5 of the island’s 27.5 acres. Following the 

decision, New Jersey Governor Christie Whitman 

appointed an Advisory Committee on the 

Preservation and Reuse of Ellis Island. The 

deliberations and final report of that committee 

contributed significantly to the growing public 

awareness of the need for action. To further focus 

attention on the issue, a new nonprofit organization 

called Save Ellis Island Inc. was established to raise 

funds to preserve the remaining buildings on Ellis 

Island. In 2001 the National Park Service signed a 

major fundraising agreement with Save Ellis Island 

Inc. 

In 1999 Congress appropriated initial funding for the 

temporary stabilization of the south-side buildings— 

work that continues today. Also in 1999, the Save 

America’s Treasures program awarded Ellis Island 

funds to begin restoration of the Ferry Building, with 

additional matching funds being secured in 2000 by 

the New Jersey Governor’s Advisory Committee. A 

second Save America’s Treasures grant was awarded 

later in 2000 for restoration of the Hospital Laundry 

and Outbuilding. 

HISTORIC 

SIGNIFICANCE OF ELLIS ISLAND 

Ellis Island, located off the New Jersey shoreline in 

Upper New York Bay and within sight of the Statue 

of Liberty, is significant in its role as the principal 

federal immigration station in the United States 

between 1892 and 1954. Today Ellis Island has 

become a symbol of American immigration, the 

history of diversity in America, and the reasons 
AFFECTED ENVIRONMENT

58 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

people still seek refuge in the United States. Before it 

was destroyed by fire in 1897, approximately 

1.5 million immigrants were processed on Ellis 

Island at the first federal depot for the Port of New 

York. A new inspection station was built and opened 

on the island in 1900 with the completion of the 

massive Main Building. During the first half of the 

20th century, the small original island (approximately 

3 acres) was enlarged to encompass three connected 

islands covering 27.5 acres on which were built some 

41 structures, including a general hospital and 

contagious disease hospital complexes. These 

facilities provided for the administration of federal 

immigration laws in the processing of incoming 

immigrants. It is estimated that some 12 million 

immigrants entered the United States through Ellis 

Island. 

The physical aspect of Ellis Island embodies the 

American ideals of freedom, democracy, and an open 

society. Major characteristics that contribute to Ellis 

Island’s symbolic presence are its siting in New York 

Harbor on a large, clearly artificial island that can be 

seen from many vantage points around the harbor; its 

dramatic profile rising from a flat land mass; the 

circulation system within the property; the views of 

New York and New Jersey from the island; and the 

building complex itself, the details (profiles, plans, 

materials, workmanship, doors, windows, cornices, 

roofing, and ornament) of which contribute to the 

overall characteristics of Ellis Island. 

The physical and social history of Ellis Island also 

reflects important transitions in American attitudes 

toward immigration. Between 1900 and 1914, 

immigration was at its highest level for the 20th 

century, reaching its peak in 1907 when more than 

one million aliens passed through Ellis Island. After a 

sharp decline in immigration during World War I, a 

period that saw the island used primarily as a military 

hospital and detention and deportation center for 

suspected enemy aliens, the flow of aliens quickly 

revived. However, immigration was altered 

dramatically with the passage of immigration 

restriction laws in the early 1920s. These statutes, 

which placed a ceiling on annual immigration and 

established quotas for foreign nations, also provided 

for the primary inspection of immigrants in American 

consulates in the immigrant’s country of origin. 

Thereafter, only those immigrants whose status in 

this country was questioned, whose papers were not 

in order, or who required medical treatment were sent 

to Ellis Island. The facilities were increasingly used 

for the assembly, detention, and deportation of aliens 

who had violated the terms of their admittance. Thus, 

while the early history of the Ellis Island immigration 

station reflected America’s liberal “open door” 

attitudes toward immigration, the later history of the 

island was shaped by the new national policies that 

succeeded in narrowing the open door to America. 

LAND USE 

ON-SITE USES

Ellis Island is completely owned and operated by the 

National Park Service and is part of the Statue of 

Liberty National Monument. Public access is 

currently limited to the Main Building (Ellis Island 

Immigration Museum) and surrounding grounds. 

Park administration buildings are located 

immediately west of the Immigration Museum. 

Currently, buildings on the south side of Ellis Island 

are undergoing stabilization work to stem further 

decay of resources. 

LIBERTY STATE PARK 

Opposite the Statue of Liberty and Ellis Island, 

Liberty State Park encompasses approximately 

800 acres. Over 2 million persons visit Liberty State 

Park annually, making it the most popular of all state 

parks in New Jersey. Besides natural amenities, such 

as wetland habitats, the park offers an interpretive 

center, playground facilities, the historic Central 

Railroad of New Jersey Terminal, and the Liberty 

Science Center. Approximately $90 million has been 

expended in the first stages of the park’s 

development. The initial phase of a 400-slip boat 

marina at the northern end of the park has been 

completed. The Liberty Science Center, a 

200,000 square foot, $50 million science museum 

located in Liberty State Park, is a marquee attraction 

that opened in 1992. In 2000 additional improved 

open space was provided (Millennium Park), and 

Liberty House Restaurant opened in 2002. 

GRAND JERSEY MEDICAL CENTER

Immediately adjacent to the entrance to Liberty State 

Park on Jersey Avenue, construction is underway on 

the Grand Jersey Medical Center, a $180 million, 

325-bed medical facility. This project, scheduled for 

completion in 2004, is a partnership of the Jersey 

City Medical Center, the New Jersey Economic 

Development Authority, and the City of Jersey City. 
Introduction

FINAL ENVIRONMENTAL IMPACT STATEMENT 59

JERSEY CITY

Jersey City’s historic industrial waterfront has been 

replaced with residential and office development — 

particularly in the financial services sector. Demand 

for office space is very strong: as of the fourth 

quarter of 2002, vacancy of Class A office space was 

less than 5%. In the period between 1990 and 2002, 

over 15 million square feet of office space and nearly 

80,000 new residential units were developed. Four 

hotels providing nearly 950 rooms have been 

completed or are under construction. The former 

location of the Colgate Palmolive Company has been 

transformed into 6 million square feet of office space 

and 800 residential units. The Goldman Sachs office 

tower under construction now will be the tallest 

building in New Jersey and mirror the office towers 

of lower Manhattan. In addition to development at 

the Exchange Place District, Colgate Redevelopment 

Area, and the Tidewater Redevelopment Area, other 

ongoing residential projects will add over 450 new 

residential units at Fultons Landing, Pier House, and 

Hudson Point. 

POPULATION 

STATE OF NEW JERSEY

According to 2000 Census data, New Jersey has a 

population of 8,414,350, an increase of slightly more 

than 9% over the last decade. According to census 

figures, nearly 73% of that population is classified as 

white (a 6% decrease since 1990), nearly 14% as 

Black/African American (similar to 1990), and 

approximately 13% as Hispanic or Latino (a 4% 

increase since 1990). Since 1990 the minority 

population has increased from approximately 21% to 

more than 27% of the total population. 

Owner-occupied housing constitutes 65% of the New 

Jersey housing market, with a median house value of 

$162,300. Renter-occupied housing composes the 

remaining 35% of the housing market with a median 

monthly rent of $521. The average per capita income 

for 1989 was $18,714. Earnings of 7.6% of the state's 

population fall below the poverty level. 

HUDSON COUNTY

According to 2000 Census data, Hudson County has 

a population of 608,975, an approximate 9% increase 

over 1990. The majority (55%) of that population is 

classified as white (approximately 13% decrease 

since 1990), 13% as Black/African American (a 1% 

increase since 1990), and nearly 40% as Hispanic or 

Latino (an increase of about 7% since 1990). Since 

1990 the minority population has increased from 

approximately 48% to more than 53% of the total 

population 

Owner-occupied housing constitutes 31% of the 

Hudson County housing market with a median house 

value of $157,000, roughly 3% lower than the state of 

New Jersey median value of $162,300. Renteroccupied housing composes the remaining 69% of 

the housing market with a median monthly rent of 

$465, nearly 11% lower than the state of New Jersey 

median of $521. 

The average per capita income in Hudson County for 

1989 was $14,480, 23% below the state average. 

Earnings of approximately 15% of the county's 

population fall below the poverty level, nearly twice 

the state figure for wage earners living below the 

poverty level. 

JERSEY CITY

Jersey City has a population of 240,055, a 5% 

increase since 1990. Thirty-four percent of that 

population is classified as white (a 14% decrease 

since 1990), 28% as Black/African American (a 

decrease of more than 1%), 28% as Hispanic or 

Latino (a 4% increase since 1990), and the remaining 

10% as other ethnic origin. Census Tract 47 

encompasses the westernmost portions of Jersey City, 

including Liberty State Park. This tract extends 

beyond the study area and comprises less than 1% of 

the total Jersey City population. 

Owner-occupied housing constitutes 28% of the 

Jersey City housing market with a median value of 

$127,700, 21% lower than the state median value of 

$162,300 (1989 Census data). Renter-occupied 

housing composes the remaining 72% of the housing 

market with a median monthly rent of $464, nearly 

11% lower than the state median rent of $521. 

The average per capita income in Jersey City for 

1989 was $13,060, 30% below the state average and 

10% below the county average. Earnings of 

approximately 19% of the Jersey City population fall 

below the poverty level, more than twice the state 

percentage and 30% more than the county 

percentage. 
AFFECTED ENVIRONMENT

60 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

NEW YORK COUNTY

According to 2000 Census data, a portion of Ellis 

Island is in New York State as part of New York 

County. The census data for this area is Census 

Tract 1 Block 1. In the 1990 Census data there were 

six people living in this portion of New York County, 

primarily park service employees on Liberty Island. 

Several NPS staff remain housed here. 

ENVIRONMENTAL JUSTICE 

Executive Order (EO) 12898, “Federal Actions to 

Address Environmental Justice in Minority 

Populations and Low Income Populations,” requires 

all federal agencies to take appropriate and necessary 

steps to identify and address disproportionately high 

and adverse effects of federal projects on the health 

or environment of minority and low-income 

populations to the greatest extent practicable and 

permitted by law. The goal of EO 12898 is to require 

each federal agency to “. . . identify and address 

disproportionately high and adverse human health or 

environmental effects of its programs, policies, and 

activities on minority populations and low-income 

populations” (section 1-101, EO 12898, 1994). 

The purpose of the environmental justice review is to 

determine if a disproportionate share of the proposed 

project’s socioeconomic impacts that may be 

considered significantly adverse are borne by lowincome and minority communities. 

The environmental justice evaluation of the 

demographic and economic census data indicates that 

minority residents dominate the surrounding urban 

area. The poverty level for the surrounding area is 

above the Hudson County level and well above the 

percentage for New Jersey. 

According to the 2000 Census data, 56% of the 

population of Jersey City is comprised of 

Black/African American and Hispanic or Latino 

minorities, consistent with the 53% minority 

population in Hudson County, but much higher than 

the New Jersey State minority population level of 

27%. Between 1990 and 2000, the minority 

population has increased by approximately 5% at the 

city, county, and state levels. 

According to 1989 economic data, the percentage of 

residents with earnings below the poverty level in 

Jersey City was 19%. Fifteen percent of the Hudson 

County population was classified below the poverty 

level while only 7.6% of the state population was 

classified below the poverty level. 

As indicated earlier in the “Purpose of and Need for 

the Action” chapter, none of the activities anticipated 

in any of the alternatives would have disproportionate 

effects on disadvantaged communities. Although this 

supporting information is presented for public 

review, analysis of the impacts of each alternative 

indicated none would occur specifically on 

economically disadvantaged or minority 

communities, and so it was dropped from the affected 

environment and impacts analysis discussions. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 61

AFFECTED ENVIRONMENT 

CULTURAL RESOURCES 

REGIONAL ENVIRONMENT

The Upper New York Harbor region surrounding 

Ellis Island is rich in historical and cultural resources, 

several of which exist within the study area. A 

number of properties on or eligible for the National 

Register of Historic Places (National Register) exist 

in the region and are described below to give some 

context for the importance of Ellis Island. A few 

properties in Lower Manhattan are designated 

National Historic Landmarks. This area has been 

selectively surveyed and studied to identify some of 

the properties eligible for the National Register of 

Historic Places. Selected National Register properties 

that exist within the region are listed below. 

Statue of Liberty 

National Monument, Liberty Island 

Liberty Island is historically significant because it is 

the home of the Statue of Liberty. The statue is so 

monumental that its significance is established by its 

architecture, engineering, and artistic 

accomplishments as sculpture. The island is also the 

site of Fort Wood, a part of the 19th century harbor 

defense system. The Statue of Liberty was 

constructed between 1875 and 1884, and it was 

dedicated in 1886. It was conceived and designed by 

the French sculptor Frederic Auguste Bartholi, with 

engineering of its iron skeleton by Gustave Eiffel. 

The copper statue stands 152 feet above an 89-foot 

pedestal, making it easily visible in the harbor. It 

rises from the center of Fort Wood in a massive 

granite base designed by the prominent architect 

Richard Morris Hunt. The statue underwent major 

renovations in the 1980s, leading to its rededication 

in 1986—its centennial year. 

France presented the statue to the United States in 

celebration of the two countries’ friendship; however, 

it soon became the symbol of freedom and 

opportunity for immigrants to America. Taken 

together, the Statue of Liberty and Ellis Island are 

powerful visual representations of the American 

philosophy of liberty and democracy, as well as a 

collective symbol for the welcoming of immigrants at 

the turn of the 20th century. 

Central Railroad of New Jersey Terminal 

The CRRNJ Terminal is historically important 

because it is one of the last two major railroad 

terminals in Hudson County, the home of the coastal 

terminals in the later 19th and early 20th centuries. 

The eminent Boston architectural firm of Peabody 

and Sterns designed the terminal, which is located in 

the region of Jersey City once known as 

Communipaw Cove. Completed in 1889, it was the 

largest railroad terminal undertaken at the time and is 

now part of Liberty State Park. The architecturally 

significant Chateauesque-style structure included 

ferry and railroad terminals with four ferry slips 

leading to the train shed, a significant engineering 

achievement for its time. Although the tracks 

themselves have been removed, the building still 

stands as an important representation of the great 

railroad network in Jersey City. 

Morris Canal 

The Morris Canal Jersey City extension, located just 

north of the CRRNJ Terminal, retains its National 

Register significance as the third of the great Hudson 

River canals, constructed between 1825 and 1831 

after the Erie and the Delaware and Hudson. The 

Morris Canal originally linked the Passaic River at 

Newark with the Delaware River at Philipsburg, and 

was extended in 1836 to connect to the Hudson River 

at Jersey City. Railroads soon supplanted the need for 

canal-based transportation, but sections of the system 

still exist. The end of the canal extension contains 

little cultural or historical association with Ellis 

Island, but is located in close proximity to it. 

Castle Clinton National Monument 

Castle Clinton National Monument is significant for 

its role in the chain of forts built for the defense of 

the harbor in the early 19th century and for its use as 

a major immigration station in the latter 19th century. 

The circular sandstone fort was constructed between 

1808 and 1811 on an islet just off Manhattan’s 

southern tip, eventually becoming fully integrated 

through landfilling. It was designed by Lt. Col. 

Jonathan Williams—architect of Castle Williams and 

Fort Gibson—with assistance from John McComb, 

Jr., one of the architects of New York's City Hall and 

Hamilton Grange National Monument. In 1824 

Castle Clinton was converted into Castle Garden, a 
AFFECTED ENVIRONMENT

62 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

theatre. It was then used as an immigration station 

from 1855 to 1890 and was closed just before Ellis 

Island opened for similar purposes in 1892. From 

1894 to 1941 Castle Clinton was used as the New 

York Aquarium. It was designated a National 

Monument in 1946 and is administered by the 

National Park Service. Castle Clinton houses the 

ticketing facility for visitors to Ellis Island and the 

Statue of Liberty. 

Governors Island 

The eastern one-third of Governors Island is a 

National Historic Landmark. From the time of the 

American Revolution, Governors Island had been a 

major component of the coastal fortification system 

for the nation’s largest harbor. The fortifications 

within the historic district are Fort Jay, a square fourbastioned fort, and Castle Williams, a circular 

casemated work. They date from before the War of 

1812. Together with Castle Clinton, Fort Gibson (on 

Ellis Island) and Fort Wood (on Liberty Island) 

provided a formidable defense of the harbor. Fort Jay 

and Castle William now comprise the Governors 

Island National Monument. The northern part of Ellis 

Island can be seen from the northern shore of 

Governors Island, from approximately Castle 

Williams to the ferry terminal dock. The massive 

circular sandstone Castle Williams can be seen from 

Ellis Island. It was erected between 1807 and 1811, 

and designed by Lieutenant Colonel Jonathan 

Williams. 

City Pier A 

City Pier A is located at the northern end of Battery 

Park and was built between 1884 and 1886. It is the 

oldest pier on the waterfront of Manhattan, with the 

only pier shed from the 19th century. A clock tower 

built in 1919 is a memorial to American servicemen 

killed in World War I. 

Whitehall Building 

This building was designed by Henry Hardenbergh 

and built between 1902 and 1904. The office building 

was very profitable, and its owners enlarged it 

between 1908 and 1910, with plans by Clinton and 

Russell. It is characterized by its large size, color 

scheme, and terracotta ornamentation on top. 

International Mercantile 

Marine Company Building 

This building was constructed between 1882 and 

1887 as the red brick Washington Building. After it 

was acquired by the International Mercantile Marine 

Company in 1919, it was given a new façade and 

interiors. The company was the world’s largest 

steamship company. 

United States Custom House 

Listed as a National Historic Landmark, the Custom 

House was constructed between 1900 and 1907. It is 

an outstanding example of Beaux-Arts elements in a 

government building and one of noted architect Cass 

Gilbert’s finest designs. It includes sculpture by 

Daniel Chester French and murals by Reginald 

Marsh. 

Bowling Green Park and Historic Fence 

This 18th century park was enclosed by an iron 

fence. Both the park and fence are among the few 

surviving landscape features of Colonial New York. 

Bowling Green Station Control House 

Built between 1904 and 1905, this entrance has 

always served the Bowling Green subway station. It 

was constructed by the Interborough Rapid Transit 

Company, which built New York’s first subway 

lines. 

Watson House 

Built for James Watson (1793, extension 1806), this 

house is a survivor from the days when State Street 

was a prestigious residential neighborhood. Its design 

is attributed to John McComb. It was also the home 

of Elizabeth Ann Seton, who was the founder of the 

Sisters of Charity and first American-born Roman 

Catholic saint. 

ENVIRONMENT WITHIN THE PROJECT AREA

The site of Ellis Island involves a cultural history 

ranging from prehistoric times (approximately 

3,000 years ago) to the present. The most complete 

record of human use dates from the last 400 years to 

present. The site currently exists as a complex of 
Affected Environment

FINAL ENVIRONMENTAL IMPACT STATEMENT 63

approximately 41 structures (34 of which are 

buildings) mostly of brick, stone, and stucco 

construction as shown in the NPS List of Classified 

Structures (NPS 1995b). Structures range from one to 

three stories in height and are specifically associated 

with the Ellis Island “immigration period” (1892–

1954), which is defined as the “period of 

significance.” For this time period, the site has been 

determined eligible under two criteria (A and C) for 

the National Register of Historic Places (NPS 1976). 

The specific elements that contribute to significance 

under each criterion are described below: 

Criterion A — Buildings or landscapes can be found 

significant for their association with events related to 

broad patterns of United States history. This criterion 

is reflected in Ellis Island's influence on events that 

have significantly contributed to the history of the 

United States. Unique to Ellis Island, these events are 

characterized by the great wave of immigration 

during the early 20th century that helped shape the 

United States socially, economically, and politically. 

In addition, prior to the immigration station, the 

island played a significant role as part of the harbor 

defense system of the late 18th and early 19th 

centuries. 

Criterion C — An historic structure or complex can 

be significant because it embodies distinctive 

characteristics of a particular construction technique. 

This criterion is represented in the collection of 

Beaux Arts-style buildings on Ellis Island. The Main 

Building is one of the several dozen great Beaux Arts 

public monuments in the country. The major 

characteristics of the Ellis Island buildings are largely 

intact and possess integrity of location, design, 

materials, and workmanship, as well as feeling and 

association with the immigration period. 

Between 1892 and 1954, major changes occurred as 

the size of the island was increased and additional 

buildings were constructed. The island’s built 

environment and cultural landscape, although 

deteriorated, remain largely intact, as does the overall 

setting of the island in the harbor. Information on the 

specific cultural resource elements of Ellis Island is 

presented below. 

HISTORIC ARCHITECTURAL RESOURCES

The site exists today as a complex of approximately 

41 structures dating to the “immigration period” 

(1892–1954). Between 1897 and 1901, the original 

Beaux Arts-style structures were planned and built, 

including the Main Building, the Kitchen and 

Laundry Building, and the Powerhouse on Island 1, 

and the Hospital Outbuilding and Laundry on 

Island 2. A simple ferry building was built during this 

period but was replaced between 1934 and 1936 with 

the current Art Deco structure. 

For the most part, the existing historic building 

complex was built between 1900 and 1937 as the 

United States Immigration Station and encompasses 

the Beaux Arts and Moderne styles of architecture. 

The Main Building and Hospital Complex resolutely 

communicate authority, solidity, and grandeur, the 

dominant architectural language of Ellis Island. 

In particular, the Hospital Complex, operated by the 

United States Public Health Service on Islands 2 

and 3, is noteworthy in that it is one of the largest 

hospital complexes to be built in a single campaign in 

the United States during the first decades of the 20th 

century. Its notable architectural design further 

contributes to its significance. 

In the early years of Ellis Island's use as a United 

States immigration station, before the passing of acts 

restricting immigration, the Immigration Service had 

little means of controlling either the quantity or 

physical well-being of the waves of immigrants. A 

number of immigrants arrived with communicable 

diseases such as chicken pox, measles, diphtheria, 

tuberculosis, mumps, and ringworm. The various 

hospital buildings were designed to meet this 

challenge. The hospital's design included a series of 

freestanding, standardized pavilions that were 

connected to each other, to the medical facilities, and 

to the rest of the buildings on Island 1 by a system of 

weatherproof galleries. This design, with its 

decentralized pavilions, is significant because it 

represents a particular theory of contagion controlby-isolation carried to its highest point before the 

appearance of the modern pharmacopoeia of 

antibiotics. (Beyer et al. 1988). Thus, regarding both 

historic and artistic significance, the Ellis Island 

Hospital Complex is an important monument. Size 

alone makes it compelling and the design, in the 

unity and coherence of its Georgian Revival idiom, 

makes it reminiscent of Jefferson’s campus design for 

the University of Virginia. All of the buildings within 

the Hospital Complex are integral to one another, so 

much so that the removal of one structure would 

prove detrimental to the whole. 
AFFECTED ENVIRONMENT

64 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

Taken as a representative whole, the buildings of 

Ellis Island were many immigrants’ introduction to 

the architecture of the United States and likely 

shaped their first impressions of the country. The 

preservation of those individual design elements that 

collectively contribute to the integrity of the 

architectural resource are therefore part of both action 

alternatives. 

DEFINING

ARCHITECTURAL CHARACTERISTICS 

A Historic Structure Report (Unrau 1981) for Ellis 

Island was prepared in 1981. Subsequently, in 1984 

the historical component was completed for a 

Historic Resource Study (Unrau 1984) of Ellis Island. 

The defining architectural character of Ellis Island is 

well documented. 

Massing and Scale 

The architecture of the buildings on Ellis Island 

follows a progression from the imposing to the 

welcoming. From the Main Building to the farthest 

Isolation Ward, the scale of each structure is 

reflective of its function and purpose. Individual 

buildings appear to advance from and recede into 

their environment. Some structures, such as the Ferry 

Building, Psychopathic Ward, and Main Hospital, 

dominate the surroundings. Others, such as the 

Isolation Wards and Staff House, are more 

submissive. This oscillation between the grand and 

the modest helps to shape the overall feeling of the 

island and to maintain the symbolic and historic 

importance of each structure. 

Materials 

Dominant construction materials—limestone and 

brick, terra cotta and stucco, clay tile and copper—

were apparently chosen not only for their inherent 

durability, but also for their connotations of 

permanence and beauty (Beyer et al. 1988). Several 

materials, such as brick and limestone, are used in 

combinations to render pleasing and, sometimes, 

startling contrasts. Undulating red clay roofs feature 

massive copper gutters and detailing. Bulls-eye 

windows framed by red brick punctuate walls of 

earthy, pebbledash stucco. Although later structures, 

such as the Ferry Building and the Recreation Hall, 

lack exuberant ornamentation reflecting a later design 

vernacular, the use of common materials such as 

brick and limestone firmly relate these structures to 

the whole (Beyer et al. 1988). 

Fenestration 

Aside from the functional requirements of light and 

ventilation—of topical concern for any medical 

facility—the windows of Ellis Island were, in fact, 

the only view many immigrants had of the new 

world, especially if they were confined to isolation 

wards for long periods of time. Architecturally, the 

windows at Ellis Island contain a fair amount of 

ornamentation (such as keystones, terra cotta, and 

limestone trim and quoins) that contributes to the 

complete visual impact of the complex. 

Corridor System 

Most of the buildings on Ellis Island are 

interconnected by means of a covered corridor 

system. This system was an obvious circulation 

choice considering the harsh winter conditions of a 

relatively small, flat island in the New York Harbor, 

where patients, doctors, nurses, and staff needed 

access to all parts of the island year-round. 

Architecturally, the corridor, with its brick base, 

arched windows, and clay tile roof, provides a steady, 

unassuming theme through which the individual 

buildings harmonize with each other. The earliest and 

latest structures are united, literally and figuratively. 

Stairwells and Associated Light Monitors 

The basic floor plans of the south-side buildings have 

not been modified substantially since their original 

construction. One of the more distinguishing features 

of these plans is the location and configuration of the 

stairwells and monitors, particularly in the main 

hospital complex on Island 2. Aside from their role of 

providing strategically placed vertical circulation and 

egress, the stairwells also serve to reinforce the 

architectural language of the buildings, stepped back 

slightly in elevation and articulated at the roofs by 

means of octagonal light monitors. Each of these 

subtle gestures is meant to telegraph an interior 

function to an exterior expression of massing and 

detail (Beyer et al. 1988). 

Interior Spaces and Features 

Some hospital interior spaces and features present a 

vivid record of the specific uses for which they were 
Affected Environment

FINAL ENVIRONMENTAL IMPACT STATEMENT 65

designed. Planned and constructed as a fully selfsustaining entity, the hospital’s layout and facilities 

responded to the latest medical theories regarding the 

nature and treatment of contagious diseases. Future 

rehabilitation and reuse of the hospital buildings 

should preserve the historic character of those interior 

spaces that are particularly evocative and/or 

significant to the understanding of how the hospital 

functioned. Examples of such relevant interior spaces 

include the Laundry Press (Laundry Building, 

1st Floor); the Operating Room in the hospital 

extension, 3rd floor; the Autopsy Theatre/Morgue 

and Boiler Room, both located in the Powerhouse 2 

building. 

CULTURAL LANDSCAPE 

Ellis Island’s cultural landscape has been extensively 

altered from its earliest history as a Native American 

seasonal hunting and fishing ground to its current 

incarnation as the Ellis Island Immigration Museum 

and historic site. The earliest changes came with the 

implementation of commercial, domestic, and 

military land uses by 17th and 18th century colonists 

and the accompanying addition of buildings, 

fortifications, and associated small-scale features. 

Construction of the first immigration station between 

1890 and 1897 shifted the island’s primary land use 

to immigration and changed its special organization 

by creating a campus-like setting of facilities that 

remained consistent throughout subsequent phases of 

island development. Completion of the second 

immigration station in 1897 and the addition of 

landfill to create Islands 2 and 3 altered many 

landscape characteristics, including spatial 

organization, circulation, topography, and vegetation. 

The new buildings were once again clustered in a 

campus arrangement, but this time they were set back 

from the water’s edge, creating more open space and 

emphasizing the facility’s importance. For many 

immigrants during the first decades of the 20th 

century, the island’s landscape was their initial 

introduction to America. Recognizing this, 

Commissioner William Williams implemented 

changes to enhance the station’s status as the 

country’s premier immigration station, including 

creating a more formalized landscape with defined 

walkways, expansive lawns, and ornamental 

plantings. This period was likely the most significant 

and eventful in the frequency and significance of 

landscape change. 

During World War I, the landscape remained 

relatively unaltered. It showed evidence of neglect 

when the island reopened for immigration after the 

war, but post-war priorities centered on reestablishing 

immigration operations and maintaining deteriorating 

buildings, leaving limited resources available for the 

ornamental landscape. However, throughout the 

ensuing decades landscape improvements did occur. 

Landfill projects during the 1920s and 1930s 

increased the island’s size to 27.5 acres, while 

development and partial implementation of a 

comprehensive planting plan in the 1930s and 1940s 

provided a sense of overall order and continuity in 

the landscape. The present circulation patterns, open 

spaces, and rows of small trees on the leeward side of 

the island were established during this period. 

Changes in the immigration patterns and island 

operations directly influenced how the cultural 

landscape evolved and was maintained throughout 

the late 1940s and early 1950s. The shift from 

immigration processing to detention led to the 

creation of more fenced outdoor spaces for detainee 

and employee recreation and less emphasis on 

maintaining a highly manicured formal landscape. 

Soon after the island was abandoned in 1954, 

vegetation became overgrown and obscured the 

designed landscape, although some features like the 

circulation system of walkways remained relatively 

unchanged. Interest in island preservation led to 

subsequent construction projects in the 1970s and 

1980s that modified portions of the landscape on 

Island 1 for new uses. In the 1990s, NPS planners 

began to recognize the importance of the cultural 

landscape in the overall island rehabilitation. 

Planning efforts began to comprehensively address 

the island’s cultural landscape, including work to 

preserve and stabilize the landscape and structures on 

Islands 2 and 3. 

Currently, the island’s cultural landscape includes 

remnants of the development that occurred in the 

1940s, along with a layer of contemporary additions. 

Much of the remaining landscape, particularly on 

Islands 2 and 3, remains in poor condition. The 

historic character of the landscape is discerned 

through examination of the island’s primary 

landscape characteristics. 

Thirty-four historic buildings are included within the 

Ellis Island’s List of Classified Structures (NPS 

1995b), which also includes additional structures 

such as corridors, a flagpole, water tower, walkways, 

ferry slip, and seawall. These buildings and other 
AFFECTED ENVIRONMENT

66 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

structures are in varying states of rehabilitation, 

stabilization, or abandonment. Several nonhistoric 

structures, such as the reconstructed water tower, 

NPS guardhouse, concession kiosk, and maintenance 

building, also exist on the island. Vegetation dating 

to the 1940s remains dominant on the island, 

including London planetree (Platanus acerifolia) 

which lines the ferry basin, and various other trees 

and shrubs planted along the walks and between 

buildings on Islands 2 and 3. Open lawns are also 

present on all three islands, generally following the 

historic layout, with slight modifications on Island 1 

for the addition of the contemporary entry portico 

and Wall of Honor. Modern additions include 

flowerbeds and newly planted trees on Island 1, and 

volunteer trees and shrubs at various locations on all 

three islands. 

Both on-site and off-site views have changed. On-site 

views have recently improved with the removal of 

overgrown vegetation and the continuing 

rehabilitation of the island's facilities. Off-site views 

are more varied with the growth of the urban 

environment. They are dominated by the lower 

Manhattan skyline (now absent the World Trade 

Towers) to the northeast, the Statue of Liberty to the 

south, and Liberty State Park to the northwest. 

Extant small-scale features include a combination of 

historic items, including iron cleats along the ferry 

slip, water hydrants, manhole covers, the main 

flagstaff, remnants of light poles, fencing, a bird bath, 

flagpole foundation, a cinder rubble wall, and a trash 

can, and contemporary features such as new lighting, 

benches, trash cans, fencing railings, and NPS 

signage. 

DEFINING CHARACTERISTICS

Of the landscape characteristics identified for Ellis 

Island, three categories stand out as the most 

significant for preservation of the cultural landscape: 

spatial organization, circulation, and vegetation (NPS 

2001b; NPS 2002). Additionally, preservation of 

some of the island’s small-scale features would also 

assist in maintaining the cultural landscape’s integrity 

to a lesser extent. 

Spatial Organization 

Of primary concern is the island’s spatial 

organization. Throughout its history, the campus feel 

of the immigration station has been preserved despite 

numerous phases of development and subsequent 

decline. The clustering of buildings around the ferry 

basin and the preservation of open spaces between 

buildings has allowed this campus feel to be 

maintained. The campus setting is further reinforced 

by open lawn areas, small courtyards between 

buildings, linear tree plantings, and the geometric 

pattern of the walkways. Land use has changed from 

immigration and detention to commemoration, 

interpretation, and preservation, resulting in 

numerous landscape additions like the Wall of 

Honor, concession areas, crowd-control features, and 

signage. The topography remains relatively flat and 

level, much as it has been throughout the island’s 

history. 

Circulation 

Closely related to the spatial organization is the 

island’s internal circulation system, which includes 

covered corridors and elements of the historic 

walkway system with contemporary improvements 

and upgrades, especially around the rehabilitated 

Main Immigration Building on Island 1. The 

geometric layout of the sidewalks and corridors on all 

three islands has been a major feature of the 

landscape since the 1940s. This pattern of 

development also contributes to the island’s spatial 

organization by providing connections between 

individual buildings and open spaces. Circulation to 

and from the island is provided by boat, as it was 

historically, and for limited purposes, by vehicle with 

the addition of the nonhistoric temporary service 

bridge to New Jersey. 

Vegetation 

Vegetation patterns, as well as individual historic 

trees, are also an important contribution to the 

integrity of the cultural landscape. The linear 

plantings of trees along the ferry basin and sidewalks, 

the historic pattern of trees and shrubs on Islands 2 

and 3, and the established lawns on all three islands 

have been defining elements of the cultural landscape 

since the historic period. Mature historic trees, 

including the London planetree (Platanus acerifloia) 

on Island 1 and other identified historic species on 

Islands 2 and 3, are significant contributors to the 

island’s historic character. 
Affected Environment

FINAL ENVIRONMENTAL IMPACT STATEMENT 67

ARCHEOLOGICAL RESOURCES 

TERRESTRIAL ARCHEOLOGICAL RESOURCES

Ellis Island contains prehistoric and historic 

archeological resources. These resources range in age 

from at least the pre-European hunting and gathering 

Woodland period (approximately 3,000 to 400 years 

ago) to the closing of the second immigration station 

in 1954. Many of these resources have been 

documented over the past 20 years through planned 

research and unplanned discoveries. Most of these 

archeological resources are unique and can illuminate 

information about prehistory and history not 

available through other sources or disciplines. 

Prehistoric hunters and gatherers exploited the rich 

estuarine environment offered by the mixing of the 

Hudson River and the Atlantic Ocean. This 

environment provided resources including an 

abundance of plant species, large and small 

mammals, local and migrating birds, finfish, and 

diverse shellfish. Ellis Island, like its neighbor 

Liberty Island, was known as one of the “Oyster 

Islands” in the harbor because of the large number of 

Eastern oysters that could easily be gathered in the 

waters surrounding the island. A large Middle/Late 

Woodland-period shell midden was excavated on 

Liberty Island a few years ago. 

European settlers also gathered oysters from waters 

around Ellis Island, and the locale was noted for shad 

fishing. By the 18th century, a tavern may have been 

located on the island. Beginning in 1765, Ellis Island 

was used for the execution of people convicted of 

piracy. While artifacts or features associated with this 

period of the island’s history may be found, their 

existence is far from certain, and they will probably 

be accidentally discovered. Most of the deposits, 

artifacts, and features from either prehistoric or early 

historic times will likely be deeply buried by the 

large fill deposits used to level and expand the island. 

As noted in the section “Brief History of Ellis Island” 

and elsewhere in this document, the island was an 

important piece of the defense of New York Harbor, 

and chances are good that remnants exist of 

fortifications dating back as early as 1794, from Fort 

Gibson and from later use as a naval munitions 

storage area. 

Beginning in the 1890s, Ellis Island grew through 

land filling. What began as a small island of 

approximately 3 acres expanded to its present size of 

27.5 acres by the time the immigration function of 

the island was discontinued. The present 

configuration developed as a result of several 

different expansion episodes rather than a single 

design. The northern and western edges of Island 1 

(i.e., the northern part of Ellis Island) consist of land 

created in the 1920s and 1930s. Fill material used to 

create this land does not have much archeological 

value. Discrete soil deposits within the fill, however, 

and the bulkheads constructed to retain it, may have 

some further research value. When the land was 

created, wharfs or docks may have been buried 

beneath the fill. Any remains of such structures, or 

other features, may also have archeological value. 

Several archeological projects conducted on the 

island through the last 25 years have documented 

archeological resources from several of the periods 

mentioned. The most important and extensive 

research projects are those conducted by John 

Pousson in the 1980s and by Hunter Research, Inc., 

in the 1990s. 

John F. Pousson prepared an “Archeological 

Overview and Assessment of Archeological 

Resources on Ellis Island of Statue of Liberty 

National Monument, New York” (Pousson 1986). In 

the assessment, Pousson discusses the prehistory and 

history of the island in great detail and presents 

numerous maps and historical documents noting the 

known resources. A systematic archeological survey 

of the resources was also conducted over the island, 

and the results were reported in the assessment. This 

survey provided coverage for most of the island, and 

it documented many deposits connected with the first 

and second immigration stations. Pousson’s report 

also notes the presence of a shell midden, human 

skeletal remains, and a few fragments of prehistoric 

pottery in the Main Building basement (Pousson 

1986). Pousson’s conclusions are summarized as 

follows: 

Evidence of prehistoric use of Ellis Island 

may be expected on remnants of the 

island’s original surface (i.e., on portions 

of Island 1). 

Historic use (including commercial and 

military use) may be represented by 

deposits found (a) beneath and north of 

the Main Building and (b) beneath, north, 

and northeast of the Kitchen and Laundry 

Building. The area between the Main 

Building, the Kitchen and Laundry 
AFFECTED ENVIRONMENT

68 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

Building, and the Baggage and Dormitory 

Building, therefore, has the potential for 

containing historic archeological remains. 

Development of the first immigration 

station and its destruction by fire in 1897 

are likely to be reflected in “abundant and 

significant archeological resources” on 

Island 1. 

“The remarkably well documented 

development of the second immigration 

station also resulted in archeological 

resources, but the structural preservation 

of nearly the entire station and the 

operational routines for immigrant activity 

and debris disposal seriously limit the 

quantity and significance of these 

resources.” Artifacts associated with 

immigration and related activities do, 

however, “possess a significance which 

surpasses the archeological potential of 

their context. This significance derives 

from the artifacts’ direct association with 

a nationally renowned historic site, and 

their potential for enhancing the public’s 

appreciation of that site through their 

interpretation and display.” 

One of the major drawbacks of the investigations 

reported in the ”Archeological Overview and 

Assessment,” however, was that the testing examined 

deposits only 1 to 1.5 feet below the 1986 grade, 

which limited the ability of the testing program to 

document deeply buried deposits or features. 

Moreover, the work did not focus on utility 

infrastructure, which can be interpreted and evaluated 

as industrial archeological resources that reflect 

engineering and technology from 1892 to 1954. 

Hunter Research, Inc., conducted extensive 

excavations on Ellis Island in the early 1990s in 

anticipation of the construction of the Wall of Honor 

(Hunter 1993). This research project uncovered 

portions of military works (such as foundations of the 

parapet and barracks dating from 1794, 1807–1812 

[Fort Gibson], and later) and the first immigration 

station (i.e., Disinfecting House and the Kitchen and 

Restaurant, 1890–1897). Part of Fort Gibson was 

incorporated into an interpretive design and is now 

on public display. These excavations provided 

detailed evidence of the existence of archeological 

remains connected with use of the island during the 

19th century. 

MARINE ARCHEOLOGICAL RESOURCES

As an island, Ellis Island has both documented and 

potential archeological resources lying underwater. 

Foremost among these are the remains of the sunken 

ferry Ellis Island. This ferry entered service as a 

passenger and staff boat for Ellis Island in 1904 and 

ran almost continuously until 1954. When the island 

was transferred to the National Park Service, the ferry 

was also included. In 1968 the ferry sank at the dock 

within the ferry slip in its present position. Efforts to 

raise the ferry in 1987 and 1988 by the U.S. Navy 

were unsuccessful and the wreck remains in the ferry 

slip where portions of it are visible at low tide. In 

July 2002 the NPS Submerged Cultural Resources 

Unit spent more than a month documenting the 

remains of the ferry and assessing its rate of decay. 

In April 2002 a remote sensing survey in the ferry 

slip and around the island produced numerous 

magnetic anomalies indicative of cultural resources. 

While many, if not most, of these anomalies are 

likely modern debris such as pipes and building 

materials, some may represent the historical use of 

Ellis Island. 

MUSEUM RESOURCES

The Statue of Liberty and Ellis Island museum 

collections consist of approximately 35,000 objects, 

as well as archival and archeological collections. 

These collections are used to document and interpret 

the following themes: 

The history of the Statue of Liberty, its 

design, construction, restoration, and 

fundraising activities 

The Statue of Liberty as an evolving 

symbol of liberty and freedom 

The history and development of Ellis 

Island as a major immigration station and 

hospital complex, 1892 to 1954 

Other uses of Ellis Island, including a 

detention center for enemy aliens, hospital 

for American soldiers, and Coast Guard 

training center 

Prehistory, early European contact period, 

and 19th century military history of 

Bedloe's and Ellis Islands. 
Affected Environment

FINAL ENVIRONMENTAL IMPACT STATEMENT 69

Part of the museum collection is presently stored in 

the Recreation Hall (List of Classified Structures

# 22666, NPS 1995b). The objects include furniture 

left on Ellis Island after it closed in 1954, pieces of 

the original copper towers on the Main Building, 

original armature bars from the Statue of Liberty, 

molds used to create the 1986 Statue of Liberty torch, 

and assorted building fragments from Ellis Island 

buildings. 

The Recreation Hall was designed as a theatre for 

immigrants and staff and retains many of its original 

features. A large open shelving system stands in the 

center of the auditorium, providing 6,500 square feet 

of museum storage. The stage and several smaller 

adjacent rooms also contain museum objects. 

The museum collection stored in the Recreation Hall 

would need to be moved to another location before 

that building could be rehabilitated for future use. 

The park's Collection Storage Plan and Collection 

Management Plan are being updated in 2003, and 

these plans will provide further guidance in 

identifying and developing a new museum storage 

area for these collections. The park is interested in 

rehabilitating the Immigration Building (List of 

Classified Structures # 22660, NPS 1995b), also 

known as the New Immigration Building, for use as 

museum storage where current collections could be 

moved. However, the museum collection would not 

be moved out of the Recreation Hall until 

rehabilitation of the New Immigration Building is 

complete and meets NPS collection storage 

standards. 
70 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

NATURAL RESOURCES

GEOLOGIC RESOURCES AND SOILS 

In 1908 the bedrock beneath Ellis Island was first 

identified as Hudson Schist. Borings conducted in 

1984 for the construction of the existing temporary 

bridge confirmed the presence of mica schist 

bedrock. The schist is also mapped beneath Liberty 

Island and westward to approximately the inshore 

end of the Morris Canal Basin (MRCE 1993). 

Geologic maps indicate that the bedrock is overlain 

by soils of glacial origin. The glacial soils comprise 

heterogeneous mixtures of sand, gravel, silt, and clay 

with cobbles and boulders. Overlying the till on the 

river bottom and near shore are recent river 

sediments composed of organic silts. 

Soils on Ellis Island, like most of eastern Jersey City, 

are filled land over nearly level, very poorly drained, 

very deep mineral and organic soils on tidal flats. 

Both the island and Liberty State Park overlie part of 

a broad, shallow tidal flat that stretched from Paulus 

Hook to Constable Hook in the city of Bayonne, and 

extended a mile eastward from the shoreline to the 

Hudson River Channel. By the end of the 

19th century, it and neighboring land had been filled 

in using garbage from New York City, dredge spoils 

from New York Harbor, and fill materials from local 

industrial facilities. By 1872 a large promontory had 

been built just south of Paulus Hook. The Central 

Railroad of New Jersey laid track at the end of the 

promontory and constructed the existing CRRNJ 

Terminal. As demand for rail space increased, the 

railroads extended the shorelines to the east from the 

Jersey City waterfront by dumping debris and fill into 

the river and New York Bay. The fill material varies 

from 10 to 30 feet thick. The rail lines and piers were 

later removed for redevelopment into Liberty State 

Park. 

The original size of Ellis Island, prior to its use as an 

immigration station, was approximately 3 acres (U.S. 

Supreme Court 1998). By the January 1892 opening 

of Ellis Island as an immigration station, the United 

States had added fill to the shoreline of the island to 

form a landmass of approximately 6 acres. With 

continued landfilling by the United States 

government, Ellis Island consisted of 14 acres of land 

by 1897. This portion of Ellis Island is now known as 

the north side or Island 1. By 1899 Island 2 

(approximately 3 acres) was created to the southwest 

of the original island. This section of the island 

contains the Main Hospital Building, Administration 

Building, the Psychopathic Ward, the Hospital 

Outbuilding and Laundry, and the New Hospital 

Extension. The current ferry basin is located between 

Island 2 and the Island 1. Between 1903 and 1906, 

Island 3, with a landmass of approximately 

4.75 acres, was constructed to the southwest of 

Island 2. A dock basin separated Islands 2 and 3. All 

three islands were connected along the northwestern 

side of Ellis Island by a covered gangway, supported 

by piles. During the 1920s the dock basin was filled, 

adding approximately 4 acres of land to the island. 

Islands 2 and 3 were then known as the South Island 

(now called south side). Finally, between 1933 and 

1934, approximately 3 acres of fill were added to the 

north side of the original island and along the 

northwest side of the original island and the south 

side. A recent report (MRCE 1993) indicated that fill 

material on the northeast portion of Ellis Island, near 

the existing temporary service bridge, is 

approximately 14 feet thick. 

Tests conducted by the New Jersey Department of 

Environmental Protection (NJDEP), in connection 

with the redevelopment of Liberty State Park, 

indicate that chemical compounds are present in the 

fill (see the “Hazardous Materials” section for more 

information). Although the New Jersey Department 

of Environmental Protection attempted to assess the 

risk posed by the freight yards in 1990, a lack of 

sufficient quantified data prevented it, and the 

department indicated a more thorough investigation 

was required. No decision has been made concerning 

the risk posed by soil contamination and how it might 

affect future development in Liberty State Park. 

Areas that are within 100 feet of the centerline of 

Liberty Walk at the state park consist of clean fill that 

was brought in during the 1990s for the construction 

of the promenade. 

MARINE SEDIMENTS 

The marine sediments in the project area consist of 

the sub-bottom portion of New York Harbor located 

between the western edge of Ellis Island and Liberty 

State Park. This area includes the touchdown point or 

landing for the temporary service bridge. The portion 

of the harbor west of Ellis Island currently ranges in 
Natural Resources

FINAL ENVIRONMENTAL IMPACT STATEMENT 71

depth from approximately 14 to 23 feet, with the 

deeper section located towards the middle of the 

channel. 

Sub-bottom stratigraphy in the project vicinity 

generally consists of a layer of organic silt overlying 

glacial and/or lacustrine deposits of sand, silt, and/or 

clay. These deposits, in turn, lie on bedrock. In some 

restricted locations, possibly late-Pleistocene or early 

Holocene-aged peat deposits are located on top of the 

glacial deposits or immediately on top of the bedrock, 

with no glacial deposit present. 

Studies of the channel between Ellis Island and 

Liberty State Park show that bottom sediments are 

high in oxygen-depleting organic material and 

various pollutants. Although information on the 

chemical and physical characteristics of sediments in 

the channel is not available, sediment contamination 

similar to that taken from other areas of New York 

Harbor is expected here as well (see the “Hazardous 

Materials” section for more information). 

FLOODPLAINS 

All of Ellis Island is in the 100-year floodplain as 

designated by the Federal Emergency Management 

Agency (FEMA). The 100-year flood occurs at an 

elevation of 3.1 feet (National Geodetic Vertical 

Datum of 1929). Flood elevations for the 10-, 50-, 

and 500-year storm events as depicted on the FEMA 

map are 7.4 feet, 9.4 feet, and 11 feet, respectively. 

The FEMA map also shows the points where the 

temporary service bridge connecting Liberty State 

Park and Ellis Island are below the elevation of the 

100-year flood event. However, both Ellis Island and 

Liberty State Park are protected from flooding by 

seawalls. The seawall protecting Liberty State Park 

(which includes protective berms) and Liberty Walk 

was constructed at an elevation of 11.7 feet above the 

500-year flood level. Although this seawall protects 

most of the lower-lying areas of Liberty State Park, 

water from even a 100-year flood event could 

penetrate the seawall at the point where the bridge is 

cut into it. During the restoration of Island 1 and the 

development of Liberty State Park during the 1980s, 

the National Park Service and the New Jersey 

Department of Environmental Protection entered into 

an agreement in which the National Park Service 

allocated funds to the New Jersey Department of 

Environmental Protection for maintenance of the 

seawall. 

Ellis Island and portions of Liberty State Park are not 

protected from high waves and both are vulnerable to 

wave action from long fetches within the harbor. 

VEGETATION 

Ellis Island has undergone numerous changes 

throughout its history. The original island was a 3-

acre island with a tavern for fisherman. As described 

earlier in this document, it was later enlarged to its 

present size of 27.5 acres by landfill, and the 

landscape was extensively altered through the 

planting of trees and lawn areas and the addition of 

buildings, courtyards, and paths. As a result of these 

activities, few natural areas remain. 

The northern portion of the island, largely outside the 

study area, is currently open to the public and 

includes the Ellis Island Immigration Museum and 

other tourist attractions. Vegetation continues to 

consist of landscaped lawns and gardens. 

The southern portion of the island is covered with a 

number of buildings that have been vacant for 

approximately 50 years. Courtyards overgrown with 

weedy, invasive species and tree-lined walkways 

separate each set of buildings. The dominant tree 

species within the southern portion of the island is the 

Eastern Sycamore (Platanus occidentalis). While 

some of the weedy species have escaped from 

cultivation in the former gardens, others appear to 

have been wind borne or otherwise more “naturally” 

invaded. Of the over 250 plant species identified on 

Ellis Island, at least one-half are not native to the 

region. The most represented families of plant 

species observed during a site reconnaissance of Ellis 

Island in August 2001 (NPS 2001b) were Asteraceae, 

a highly diversified family of herbs, and Poaceae, 

primarily herbs. 

Like Ellis Island, Liberty State Park has also 

undergone numerous changes that have affected 

vegetation. The site contained abandoned industrial 

buildings, unused railroad tracks, and dumpsites 

when it was proposed as a state park. Clearing these 

structures also necessarily resulted in the clearing of 

much of the vegetation of the 1,156-acre park. Today, 

this open space is a mosaic of early and successional 

old-field plant communities, wooded thickets, 

emergent wetlands, and landscaped gardens. 

Vegetative communities in the state park include a 

variety of species. In 1993 a plant survey conducted 
AFFECTED ENVIRONMENT

72 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

by the New Jersey Department of Environmental 

Protection recorded over 150 plant species (NJDEP 

1993). 

Open fields in the park are dominated by species of 

wormwood, goldenrod, and boneset. Wooded 

thickets include pioneering hardwood species such as 

trembling aspen, eastern cottonwood, tree-of-heaven, 

and species of sumac. Approximately one-third of 

Liberty State Park has been landscaped as lawn, 

picnic areas, and parking areas. The lawn areas have 

been planted with a variety of grass species, 

including orchard grass, weeping love grass, fescue, 

bluegrass, and crab grass. 

THREATENED AND 

ENDANGERED PLANT SPECIES

No recorded sightings of federally threatened or 

endangered plant species have occurred on Ellis 

Island or in Liberty State Park, although three state 

protected species have been found. The Canada 

hawkweed (Hieracium kalmii) is listed as endangered 

from New Jersey’s official Endangered Plant Species 

List. The Canada hawkweed is typically found in a 

variety of habitats including woods, beaches, and 

fields, but especially in sandy soils. This perennial is 

located from Newfoundland to New Jersey and west 

to Illinois and British Columbia, and has been located 

on Ellis Island. 

The New Jersey Department of Environmental 

Protection Natural Heritage Program classifies 

species as critically imperiled (S1), imperiled (S2), or 

rare (S3). The Ohio spiderwort (Tradescantia 

ohiensis) is classified by the program as an imperiled 

species (S2) in the state of New Jersey and has been 

located on Ellis Island (Canada hawkweed is listed as 

S1). This plant is typically found in meadows and 

thickets from Massachusetts to Minnesota, and south 

to Florida and Texas. 

A 1990 vegetation inventory (Anderson 1990) found 

Torrey’s Rush (Juncus torreyi), a species of special 

concern ranked critically imperiled (S1) in New 

Jersey in Liberty State Park. No rare (S3) species or 

any rare natural communities listed in the Natural 

Heritage Program database for Hudson County have 

been identified on Ellis Island or in Liberty State 

Park. Between 1995 and 1997, two vascular plant 

inventories were performed on Ellis Island. No 

federal threatened or endangered plants were sited. 

Hieracium kalmii and Tradescantia ohiensis were 

observed and documented. 

FISH 

Ellis Island is part of a regionally significant fish 

habitat complex (which includes the Upper New 

York Harbor of the Hudson River) with more than 

100 species of finfish. Large concentrations of 

marine and estuarine species pass near the island as 

they migrate between the Atlantic Ocean and the 

Hudson-Raritan Estuary. In addition to these 

migratory species, the bay in the vicinity of Ellis 

Island supports seasonal and year-round populations 

of fish. Various surveys have been performed in the 

vicinity of Ellis Island (Texas Instruments 1976; 

NJDEP 1984). The surveys indicate dominant species 

such as striped bass, bay anchovy, blueback herring, 

American eel, and Atlantic silversides. The deeperwater areas directly west of Ellis Island, between 

Liberty State Park and Ellis Island, are important 

wintering habitats for striped bass and blueback 

herring. The near-shore waters of Liberty State Park, 

wetlands, and mudflats provide important nursery 

habitat for many species including the Atlantic 

tomcod, striped killifish, and mummichog. 

THREATENED AND 

ENDANGERED FISH SPECIES

One protected species that occupies both brackish 

and fresh water in the harbor and Hudson River is the 

federal and state endangered shortnose sturgeon 

(Acipenser brevirostrum). The shortnose sturgeon 

spends the majority of its adult life in the less saline 

portions of the Hudson River where it occupies deep 

channels with strong currents. Spawning occurs in 

the upper reaches of the bay, and after spawning, the 

adult sturgeon move downstream. Nursery areas for 

juvenile and larval sturgeon in the Hudson River 

extend from Haverstraw Bay to Coeymans. 

The Hudson River-Upper New York Bay is also an 

important habitat for several anadromous (those that 

travel into freshwater to spawn) fish of special 

concern, including the Atlantic or Gulf sturgeon 

(Acipenser oxyrinchus), Atlantic tomcod 

(Microgadus tomcod), hickory shad (Alosa 

mediocris), and rainbow smelt (Osmerus mordax). 

The hickory shad and the Atlantic tomcod are 

classified by the New Jersey Natural Heritage 

Program as a state species of special concern and 
Natural Resources

FINAL ENVIRONMENTAL IMPACT STATEMENT 73

ranked as a rare species (S3) in New Jersey. The 

rainbow smelt is also classified as a species of special 

concern, ranked as “believed to be in peril but the 

degree of rarity uncertain” (SU) in the state of New 

Jersey. The Atlantic sturgeon is a federally listed 

threatened species. The majority of anadromous fish 

in the Hudson River estuary, including Atlantic 

sturgeon and hickory shad, spawn in spring. Two 

anadromous species, Atlantic tomcod and rainbow 

smelt, enter the estuary during the fall and remain 

until their respective spawns (early winter for tomcod 

and early spring for smelt). 

WILDLIFE 

With minimal natural areas, few species of reptiles or 

mammals have been documented on Ellis Island. 

Those that have been identified were typically 

located in the southern portion of the island where 

overgrown courtyards provide some cover and food. 

The most common mammals are mice and rats. Other 

mammals observed include muskrats, an Eastern gray 

squirrel, and a single Virginia opossum, which may 

have been extirpated. The only reptile observed 

recently by park officials was a garter snake. 

A few species of amphibians, reptiles, and mammals, 

primarily those species readily adapted to urban 

environments or able to survive in smaller wetlands, 

have been documented in Liberty State Park. Open 

fields and thickets provide habitat for eastern 

cottontail rabbits, opossum, meadow vole, and 

Norway rat. Species inhabiting the wetland habitats 

include muskrat, snapping turtle, and painted turtle. 

The common garter snake and Fowlers’ toad have 

also been observed. 

Due to a lack of habitat, there are also few bird 

species actually on the island. The bulk of bird 

diversity on the island is located in the habitat 

provided by overgrown courtyards, which provide 

limited shelter and food. A recent field survey found 

species typical of urban areas, including song 

sparrow, rock dove, American crow, European 

starling, and barn swallow. Waterfowl observed 

include ring-billed gull, laughing gull, Canada goose, 

mallard, and double-crested cormorant. These species 

are common bird species located along the shorelines 

of New York and New Jersey. A pair of night herons 

has been observed inhabiting the trees in the vicinity 

of the Hospital Outbuilding and Laundry on the south 

side. At least one barn owl observed by park officials 

is now nesting in the attic of one of the hospital 

buildings. 

While few bird species are able to live on Ellis 

Island, many more migratory and seasonal resident 

species use the open spaces and relatively diverse 

habitat in Liberty State Park. Surveys conducted 

since the mid-1970s (Texas Instruments 1976; 

(NJDEP 1994) recorded a total of 240 bird species in 

the state park and surrounding areas, 18 of which are 

under federal or state protection as threatened, 

endangered, or other special status (see below). The 

state park’s shoreline attracts herons, egrets, and 

several types of waterfowl. The park is an important 

concentration area for wintering waterfowl such as 

brant, American black duck, canvasback, greater 

scaup, and Canada goose. Several species of raptors 

use the park during the spring and fall migrations and 

as seasonal residents. 

NEW JERSEY THREATENED 

AND ENDANGERED WILDLIFE SPECIES

No sightings of federal or state protected birds have 

been recorded at Ellis Island. Of the 18 known to live 

or migrate through Liberty State Park, four species 

are year-round or seasonal residents. None are listed 

under the federal Endangered Species Act, but all are 

on the state list (see appendix E) of endangered and 

threatened wildlife maintained by the New Jersey 

Division of Fish and Wildlife. They include one yearround resident, the threatened Savannah sparrow 

(Passerculus sandwichensis), and seasonal residents 

northern harrier (Circus cyaneus), peregrine falcon 

(Falco peregrinus) and short-eared owl (Asio 

flammeus). The latter three species are listed as 

endangered on the New Jersey state list. Northern 

harriers and long-eared owls winter in the park. 

Peregrine falcons are observed regularly hunting 

along the shoreline. The following information about 

each is taken from the New Jersey Division of Fish 

and Wildlife website at 

http://www.njfishandwildlife.com/. 

The Savannah sparrow occupies open habitats and 

nests in fields, grasslands, and meadows, as well as 

salt marsh edges and coastal grasslands, if they are 

available. Historically, the clearing of forests for 

farmland and filling of coastal marshes provided 

habitat for breeding sparrows in New Jersey. With 

the decline in traditional agriculture, breeding 

populations of sparrows have also fallen. Christmas 

bird counts and other information indicate a 
AFFECTED ENVIRONMENT

74 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

significant decrease in wintering Savannah sparrows 

in the state since the late 1950s. 

The northern harrier hawk inhabits open country such 

as tidal marshes, fallow fields, grasslands, meadows, 

and agricultural areas. This species forages over these 

same areas that contain low vegetation. Communal 

winter roosts of harriers are located on the ground 

within drier portions of marshes or in grasslands. 

Declines of breeding harriers in New Jersey have 

been related to the loss of habitat, shooting (earlier in 

the 20th century), and reproductive failures resulting 

from organic pesticides. Wintering populations of 

harriers in New Jersey are considered stable, but 

breeding populations are endangered. 

Peregrine falcons, recently (1999) de-listed on the 

federal threatened and endangered species list, favor 

open areas for foraging and often hunt over marshes, 

beaches, or open water. Peregrine falcons historically 

bred in New Jersey on cliffs along the Hudson River 

(Palisades) and along the Delaware River. 

Persecution, nest disturbances, and particularly the 

introduction of DDT (dichlordiphenyl trichloroethane) eliminated the species from much of its 

former range. An aggressive program of building 

artificial nest sites and raising and releasing birds has 

helped in de-listing the species. In New Jersey, the 

peregrine population remains stable at about 15 pairs. 

Despite elevated PCB (polychlorinated biphenyls) 

levels in peregrine eggs, pairs are exhibiting good 

productivity. 

The short-eared owl inhabits coastal tidal and 

brackish marshes, inland fields, pastures, and 

grasslands in New Jersey. Owls forage on drier 

portions of coastal habitat, similar to northern 

harriers. This species is sensitive to human activity 

and requires large tracts of undisturbed open areas, 

particularly for breeding (they do not breed in the 

study area). Wintering short-eared owls may 

concentrate at landfills where rodents are abundant, 

and winter roosts are sometimes in conifers also 

occupied by long-eared owls. Habitat loss, shooting, 

and egg collecting are considered reasons for its 

decline. 

SURFACE WATER 

Ellis Island lies near the west bank of the mouth of 

the Hudson River. The source of the Hudson River is 

the Adirondack Mountains from which the river 

flows southward to the Atlantic Ocean. Near Troy, 

New York, approximately 140 miles north of Ellis 

Island, the river becomes tidal. 

Due to sea level changes associated with the end of the 

Wisconsin glaciations, New York Harbor has 

undergone tremendous environmental changes over 

the last 12,000 years (Pirnie 1994). Approximately 

12,000 years ago, the project area was part of a marshy 

plain overlooking a narrower Hudson River. Over the 

next approximately 8,000 years, the marshy plain 

changed first to a coniferous forest and, subsequently, 

a deciduous one. Small areas of marshland may have 

continued to exist in these forests in localized lowerlying locations. For the past 4,000 years, a continual 

rise of sea level slowly inundated the study area, which 

became a shallow part of Upper New York Bay (Pirnie 

1994). 

During the 17th century the project area was part of a 

large cove or bay (now filled in as Liberty State Park) 

called Communipaw Cove or Oyster Bay. The latter 

name was in reference to the large numbers of shellfish 

that formerly resided along the bottom of the bay. 

Now, New York Harbor is a network of tidal 

waterways located between southeastern New York 

and northern New Jersey. The harbor meets the 

Atlantic Ocean at the eastern end of the Long Island 

Sound and at the mouth of the Lower New York Bay 

at Sandy Hook. Waters surrounding Ellis Island are 

relatively shallow in comparison with the main 

channel of the Hudson River. The water depths near 

the existing temporary service bridge range from 10 

to 20 feet below mean sea level. 

Dredging within the project vicinity apparently 

occurred during the mid-to-late 19th century and early 

20th century. The dredging was conducted in order to 

create and maintain approach channels with 

appropriate depth of water to the piers that formerly 

extended from the shoreline of Liberty State Park. 

Prior to dredging, the depth of the channel between 

Ellis Island and the mainland was shallow enough for 

wading. Generally, the dredging deepened this portion 

of New York Harbor to depths of 15 to 27 feet. 

The waters surrounding Ellis Island are under the 

jurisdiction of the Interstate Sanitation Commission. 

Both New York and New Jersey have classified the 

surface water for differing uses: New York State 

Department of Environmental Conservation as Class 

1 saline, suitable for secondary contact recreation, 

fishing, fish propagation and survival; and New 

Jersey as Class SE2 saline estuarine waters, 
Natural Resources

FINAL ENVIRONMENTAL IMPACT STATEMENT 75

designated for maintenance, migration, and 

propagation of natural and established biota, 

migration of diadromous fish between fresh and salt 

water, maintenance of wildlife, secondary contact 

recreation, and any other reasonable uses. In 1992 

surface water met applicable ambient water quality 

standards for dissolved oxygen, chlorine, coliform, 

and metal concentrations at harbor survey stations 

monitored by the New York City Department of 

Environmental Protection. Tetrachloroethylene 

exceeded New York and New Jersey standards 

during the 1992 survey. 

An earlier study in the vicinity of the Liberty State 

Park Northern Marina indicated the presence of 

pesticides and metals in the surface waters 

throughout of the Morris Canal Basin. The study 

concluded that water quality near Ellis Island may be 

similarly contaminated (NJDEP 1990). 

GROUNDWATER 

Depth to groundwater in Liberty State Park is 

approximately 4 feet below grade and is expected to 

be similar for Ellis Island. Liberty State Park 

groundwater is designated as Class II-A by the New 

Jersey Department of Environmental Protection. 

Groundwater investigations in Liberty State Park 

have revealed the presence of metals, semi-volatile 

organic compounds, and total petroleum 

hydrocarbons in excess of the NJDEP Groundwater 

Quality Standards. No specific groundwater 

investigation has been conducted for Ellis Island. 

AIR QUALITY 

Either action alternative could result in increased 

visitor use at Ellis Island in the long term, as well as 

temporary construction impacts associated with 

rehabilitating buildings and replacing the temporary 

service bridge with a permanent one. Increases in 

visitor use would also increase the concentrations of 

vehicle-related pollutants, possibly including those 

from additional ferry use. In particular, cars looking 

for parking to take the ferry would increase. Besides 

emissions from construction equipment, construction 

itself could increase dust (total suspended 

particulates). Therefore, these types of emissions are 

described here and in the impacts analysis in the 

“Environmental Consequences” chapter. 

The levels of pollutants in lower Manhattan were not 

examined, because NPS visitor use information 

indicates that the portion of visitors to the ferry are 

probably not significant enough to impact air quality 

levels compared with the total number of 

automobiles, buses, trucks, and other stationary 

sources in the lower Manhattan area. 

CRITERIA POLLUTANTS

The U.S. Environmental Protection Agency (EPA) 

regulates six criteria pollutants that could cause 

adverse health effects by setting emission standards 

(national ambient air quality standards [NAAQS]). 

The six regulated pollutants under this program are: 

sulfur dioxide (SO2), particulate matter with a 

diameter less than or equal to 10 microns (PM10), 

ozone (O3), nitrogen dioxide (NO2), lead (Pb), and 

carbon dioxide (CO). The national ambient air 

quality standards are typically established for a 

variety of averaging times, ranging from one hour to 

one year. The state of New Jersey has also 

established ambient air quality standards (AAQS) 

that include six criteria pollutants and total suspended 

particulates. 

Although all six criteria pollutants are of importance, 

CO, nitrogen oxides (NOx), and hydrocarbons (HC) 

are given particular scrutiny because HC and NOx

can react with sunlight to form ozone and 

photochemical smog. The formation of smog in the 

New York / New Jersey metropolitan area is a 

regional problem and is the result of significant and 

widespread emissions of ozone precursors, such as 

HC and NOx, which emanate from mobile sources, 

and from stationary sources outside the area that are 

transported into the region. 

NJDEP monitoring of CO levels at two nearby 

stations (Kennedy Boulevard station and at the North 

Bergen monitoring station) between 1996 and 2001 

showed no exceedances of the 1-hour or 8-hour CO 

standards during the last six years. A monitoring 

station at Veterans Park indicated that levels of NO2

and SO2 are well below national and state standards. 

The Newark Avenue station in Jersey City reported 

PM10 well below national standards. Total suspended 

particulates were also below the New Jersey primary 

standard for annual average concentrations and below 

both the primary and secondary standards for 24-hour 

concentrations between 1989 and 1993. 
AFFECTED ENVIRONMENT

76 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

NOISE 

Quantitative information on the effects of airborne 

noise on people is well documented. Noise may 

interfere with human activities such as sleep, speech, 

communication, and tasks requiring concentration or 

coordination. It may also cause annoyance, hearing 

damage, and other physiological problems. Several 

factors affect sound as the human ear perceives it. 

These include the actual level of sound (or noise), the 

frequencies involved, the period of exposure to the 

noise, and changes or fluctuations in the noise levels 

during exposure. Levels of noise are measured to 

correspond to human hearing in the unit known as the 

A-weighted decibel, or dBA. 

Because the sound pressure level unit of dBA 

describes a noise level at a moment in time, and 

because very few noises are constant, the equivalent 

sound level is used to describe the fluctuating noise 

heard over a specific period, as if it had been a steady, 

unchanging sound. For this condition, a descriptor 

called Leq can be computed. Leq is the constant sound 

level that, in a given situation and period (e.g., 1 hour, 

denoted by Leq(1) or 24 hours, denoted as Leq(24)), 

conveys the same sound energy as the actual time–

varying sound. Statistical sound-level descriptors such 

as L1, L10, L50, L90, and Lx are sometimes used to 

indicate noise levels that are exceeded 1, 10, 50, 90 

and x percent of the time, respectively. The L10

descriptor is particularly appropriate for traffic noise 

because of its fluctuating nature. 

Monitoring of noise levels on Ellis Island and Liberty 

State Park was conducted in July 1994 as part of the 

1995 draft environmental impact statement (NPS 

1995a). For that study, dates were selected to 

represent typical conditions experienced during 

weekend day and weekday traffic and visitor use. 

Three stations on Ellis Island and two in Liberty State 

Park were selected. 

Discrete noise sources on the island included 

helicopters and planes flying overhead, horns from 

ferries arriving at and departing from the island, NPS 

work boats, movement of construction vehicles, and 

all-terrain vehicles used by NPS staff. The majority 

of these activities (except for construction) continue 

to take place on Ellis Island. 

The same types of noise were heard in Liberty State 

Park, including helicopters and planes flying 

overhead, private automobiles, and buses traveling 

along park roads, lawnmowers, pavement repair 

equipment on the sidewalk/bicycle path, and 

construction trucks. Since the time of monitoring, the 

Liberty Walk construction project has been 

completed, eliminating the construction noise. All 

other monitored activities continue at the park. 

The daily average Leq values measured during the 

monitoring program ranged form 52.3 dBA at Liberty 

State Park 1 monitoring station (LSP1) to 60.3 dBA 

on the western side of Ellis Island. Average L10

values ranged during the day from 53.4 dBA at LSP1 

to 65.9 dBA on the northwest corner of the island. 

The highest Leq and L10 values recorded on Ellis 

Island were 84.7 dBA and 86 dBA, respectively. The 

higher intermittent values were attributed to the 

construction equipment operating near these 

locations. The lowest noise levels occurred in Liberty 

State Park at a relatively isolated setting near the 

Interpretive Center building. The maximum noise 

level recorded was at 102.8 dBA, which occurred on 

Ellis Island and was related to the movement of 

construction equipment. 

Average Leq and L10 values recorded during the noise 

monitoring program at Ellis Island and Liberty State 

Park were below federal highways criteria, although 

the highest Leq and L10 values were above them. 

However, these values are attributed to construction 

equipment and are considered a temporary, localized 

increase. 

HAZARDOUS MATERIALS 

As part of this environmental impact statement, 

existing data were reviewed to assess the potential 

sources and extent of contamination by hazardous 

materials resulting from the activities described in 

each alternative. A site reconnaissance of Ellis Island 

was conducted on August 2, 2001, to supplement the 

existing data and to observe the condition of the 

30 buildings on Ellis Island that are the subject of this 

environmental impact statement. 

Potential sources of hazardous materials include 

landfill material that was used to construct the 

majority of the 27.5 acres of landmass of Ellis Island, 

landfill material that was deposited along the west 

shoreline of what is now Liberty State Park, the 

marine sediments in the Upper New York Bay, the 

water quality of the Upper New York Bay itself, the 

above-ground fuel-oil storage tanks on Ellis Island, 

suspected asbestos-containing materials, and lead-
Natural Resources

FINAL ENVIRONMENTAL IMPACT STATEMENT 77

based paint associated with various portions of the 

proposed project area. 

HISTORIC FILL

The source of the fill on Ellis Island is unknown as 

are the chemical characteristics of the island’s fill 

material. It is likely similar to other “historic fill” 

used during this same time period in urban areas of 

New York and New Jersey in the late 1800s to the 

early 1900s. Tests of this material have found it 

typically contains concentrations of heavy metals, 

semi-volatile organic compounds, and petroleum 

hydrocarbons that may exceed the NJDEP residential 

or non-residential direct contact soil cleanup criteria. 

The eastern shoreline of Jersey City that is now 

Liberty State Park was created by landfill activities, 

the majority of which were conducted from the 1860s 

through the late 1920s. The fill material is 10- to 

30-feet thick and consists of garbage from New York 

City, dredge spoils from New York Harbor, and fill 

from local industrial facilities. According to historic 

maps (Sanborn® Fire Insurance), the former uses of 

the northern and central portions of Liberty State 

Park include a railroad terminal of the Central 

Railroad of New Jersey and a freight yard of the 

Lehigh Valley Terminal Railroad Company. 

Numerous piers operated by coal freighting 

companies extended into the Upper New York Bay. 

Demolition of the railyards and piers preceded the 

opening of Liberty State Park to the public in the 

1980s. Surveys conducted of the railroad freight yard, 

CRRNJ Terminal parking area, and the south lawn 

area (Pirnie 1994) indicate metals, semi-volatile 

organic compounds, and petroleum hydrocarbon 

contamination in the fill material, with concentrations 

of contaminants in some areas exceeding the NJDEP 

residential or non-residential direct contact soil 

cleanup criteria. 

The freight-yard area consists of approximately 

350 acres and was the subject of a 1990 contaminant 

investigation by the New Jersey Department of 

Environmental Protection. A total of 57 soil samples 

were collected at depths up to 0.5 foot from 

28 locations within the freight yard. The samples 

were analyzed for a full slate of contaminants, 

including organics, pesticides, polychlorinated 

biphenyls (PCB), and metals. A few volatile organic 

compounds were detectable at levels up to 0.012 

parts per million (ppm) (less than the current NJDEP 

residential or non-residential direct contact soil 

cleanup criteria). These include acetone, methylene 

chloride, 2-butanone, chloroform, ethylbenzene, 

trichloroethene, and toluene. Semi-volatile organic 

compounds (including several polycyclic aromatic 

hydrocarbon [PAH] compounds), pesticides 

(including dieldrin, DDE, and DDT), PCBs, and 

many metals (including arsenic, cadmium, 

chromium, mercury, and lead) were also detected, 

many at concentrations that exceeded the NJDEP 

action levels in effect at the time. The NJDEP Site 

Remediation Program’s (SRP) 1999 Site Status 

Report (NJDEP 1999b) states that the metals, 

pesticides, semi-volatile organic compounds, and 

total petroleum hydrocarbon contaminants have been 

found in one or more of the following media at the 

site: groundwater, surface water, soil, or sediments. 

The SRP’s Site Status Report noted that at the time 

the park decides to develop the freight-yard area (see 

alternatives 2 and 3), a minimum of 1 foot of clean 

fill material and/or asphalt would be placed as a 

cover over the contaminated fill material, in 

accordance with NJDEP remediation requirements 

for historic fill sites. The clean fill-cap method of 

encapsulating the historic fill has been utilized at 

other locations within Liberty State Park (Liberty 

Science Center, CRRNJ Terminal parking lot, 

Liberty Walk, and the Northern Marina) to eliminate 

the exposure pathways of inhalation and direct 

contact with the contaminated historic fill. Chromate 

waste fill material has been identified by the New 

Jersey Department of Environmental Protection in 

the area of the Caven Point Pier and the sewer line 

area of the freight yard. The NJDEP SRP 1999 Site 

Status Report (NJDEP 1999b) indicates that 

additional investigation is necessary to characterize 

the extent of chromate contamination in these areas. 

Another site in Hudson County adjacent to the park is 

also a potential source of contamination. Chromium 

has been found in fill material at this site (Chromate 

site 15) and at many others in Hudson County. Most 

of these areas were either the locations of former 

chromate ore processing plants or where ore was 

used as fill material. They have been found to contain 

both hexavalent and trivalent forms of chromium; 

hexavalent is considered most dangerous to humans 

as inhalation of dust particles is associated with a 

higher incidence of cancer. Chromate site 15 is 

reportedly not accessible to the public, and according 

to the NJDEP SRP Chrome Update 28 Report 

(NJDEP 1999a) has undergone a Preliminary Site 

Characterization where soil, groundwater, surface 

water, and sediment sampling have been conducted. 

The results of the site characterization sampling were 
AFFECTED ENVIRONMENT

78 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

not available at the time of publication of this Final 

Environmental Impact Statement. 

MARINE SEDIMENTS

Marine sediments in the area of the existing 

temporary service bridge consist of organic silt (5- to 

20-feet thick) over a layer of till or sand (0 to 25-feet 

thick), with bedrock consisting of mica schist. 

Studies of the bottom sediments in the channel 

between Ellis Island and Liberty State Park indicate 

they are high in oxygen-depleting organic material. 

However, further information on the chemical 

characteristics of this material is not available. For 

the purposes of analysis, this environmental impact 

statement assumes sediments in the entire vicinity of 

the project area are physically similar to those below 

the temporary service bridge, and that they also are 

high in organics. 

Additional pollutants are likely part of the marine 

sediments in the study area. The National Oceanic 

and Atmospheric Administration National Status and 

Trends Program collected data that indicates 

sediment contamination is found throughout the 

Upper New York Bay. The study shows the New 

York Harbor area ranks among the 20 worst estuaries 

in the nation with respect to high concentrations of 

organic and inorganic pollutants. 

A 1988 sampling effort in the sediment of Morris 

Canal Basin north of the tide-water basin area of the 

park (NJDEP 1988) found elevated levels of 

polycyclic aromatic hydrocarbons (PAH) and total 

petroleum hydrocarbons (TPH). However, the report 

concluded the contamination may result from the 

Northern Marina site, and may not be indicative of 

the conditions in the rest of the study area. 

BUILDING MATERIALS

Asbestos and lead have been found in the materials of 

several buildings on Ellis Island. Stabilization of the 

buildings, including removal or abatement of 

asbestos-containing materials and the scraping and 

removal of deteriorated lead-based paint, is ongoing 

and subject to available funding. Currently, 

contractors have stabilized 6 of the 30 existing 

buildings on the south side and Island 1. In addition 

to the removal of hazardous materials, stabilization 

includes removing exterior overgrown vegetation, 

weatherproofing (e.g., roof, window, and brick 

repairs as necessary), general cleanup, and removal 

of debris from inside the buildings. 

Investigations to date have found asbestos is 

primarily a component of linoleum and floor tile in 

the Main Hospital Building, Administration Building, 

New Hospital Extension, and the connecting 

corridors between these buildings. Asbestos survey 

and sampling were conducted during the hazmat 

removal phase of the stabilization of Island 2, 

including the attic and connecting structure spaces. 

Before reuse takes place, such a survey would be 

completed, and any required asbestos-removal 

activities would be conducted as part of building 

stabilization. Minor amounts of asbestos-containing 

material, not observed or removed during the 

stabilization of the buildings, may be encountered 

during the final renovation of the buildings as part of 

the island’s south-side adaptive reuse construction 

project. 

The 30 buildings that are the subject of this analysis 

were constructed prior to the implementation of 

federal regulations that, today, severely restrict the 

use of lead in residential and commercial paints. 

Paint observed on the interiors of all the buildings is 

suspected of containing lead. In addition to scraping 

paint, stabilization includes cleanup, removal, and 

proper disposal of the lead-based paint debris. Even 

this effort does not completely abate or encapsulate 

the lead-based paint within the buildings, and some 

remnant of lead-based paint would likely be 

encountered throughout the buildings during final 

renovation work associated with the reuse of the 

south side. 

ABOVE-GROUND STORAGE TANKS

Three above-ground tanks store #2 marine grade 

diesel fuels for NPS boats, emergency generators, 

construction contractors working on stabilizing 

buildings on Islands 2 and 3, and for heating. There 

are currently no underground storage tanks on Ellis 

Island. The 10,000-gallon double-walled, aboveground marine fuel tanks are located on the northeast 

corner of the island, near the service dock. In 1986 

these three above-ground tanks replaced the three old 

underground tanks. A 1,000-gallon double-walled, 

above-ground gasoline fuel tank also serves the 

stabilization effort in the contractor staging area on 

the west side of the island. To date, there have been 

no spills or other problems with the operation of the 

above-ground storage tanks. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 79

SOCIAL AND ECONOMIC ENVIRONMENT 

TOURISM 

Ellis and Liberty Islands are only two of many 

world-renowned destinations in the New York / 

New Jersey metropolitan area, famous for virtually 

unlimited opportunities for recreation and 

entertainment. The city contains almost 

18,000 restaurants and, according to the New York 

City Convention and Visitors Bureau, provides 

overnight lodging for more than 17 million 

overnight visitors to the city annually. Over 

37 million people visited New York City in 2000, 

accounting for almost $25 billion in economic 

impact. The tourism industry plays a large role in 

the local and regional economy, supporting 

approximately 300,000 jobs and generating 

$3.2 billion in wages and approximately $3 billion 

in tax revenues in 2000. New York City alone 

received nearly $1 billion in tax revenues as a result 

of the tourism industry. 

Economically, tourism is no less important to New 

Jersey. In 2001 over $30 billion was spent in New 

Jersey on travel and tourism. In 2000 tourism 

accounted for over 700,000 jobs, approximately 

$16.6 billion in wages, and $5.5 billion in tax 

revenues. 

In 2001 the tourism industry experienced a 

downturn primarily due to economic conditions that 

occurred throughout the country and region and the 

events of September 11, 2001. As a result, the 

number of visitors decreased to approximately 

32 million in 2001; similar projections were made 

for 2002. However, industry experts predict the 

downturn to be temporary and cyclical. 

The recent regional and national trends in tourism 

have been mirrored in visitor attendance at the 

Statue of Liberty National Monument and Ellis 

Island. In 2000, 4.4 million ferry tickets were sold 

and approximately 1.9 million persons visited Ellis 

Island. Following the terrorist attack in September 

2001, the park was closed for 3 months. In 2002, 

3.2 million ferry tickets were sold and 

approximately 1.4 million persons visited Ellis 

Island. The park expects visitation to grow 

approximately 2.5% annually from the 2002 level. 

CONCESSIONS 

Commercial activities at the Statue of Liberty National 

Monument and Ellis Island are administered by 

concession contracts. Services provided include visitor 

ferry transportation to and from both New York and 

New Jersey. Gift and refreshment services are available 

on the boats. Presently, the contract is with Circle-Line 

Statue of Liberty Ferry, Inc. This contract requires a 

15% fee payable to the U.S. Treasury on gross receipts 

of ticket sales and 10% on the gross revenues generated 

from other authorized services. In addition to the 

above, the concessioner pays a flat rental fee for space 

provided at Castle Clinton National Monument of 

$3,300 per year. The concessioner also has contracts 

with both New York City and New Jersey for the 

activities conducted at each jurisdiction. New York 

fees are 7.25% of the ticket sales. New Jersey collects a 

7% fee on the gross receipts. 

Concession services provided at Ellis Island include 

food, a souvenir shop, audio tour, and day and afterhours catering. The current concessioner for these 

services is Aramark Sports and Entertainment, Inc. 

Concession supplies transported over the temporary 

service bridge are delivered to Ellis Island at a 

substantial savings to Aramark relative to the costs of 

ferry transport. 

The concessions at both Liberty and Ellis Islands 

generated about $29 million in sales during FY 2002, 

with visitation of just over 2.1 million. A fee obligation 

to the U.S. Treasury generated by concession activities 

at both sites was over $4.6 million. 

Fares from ferry taxes, sales taxes, fees, hotel 

occupancy, and city income taxes generate about 

$10.7 million in revenue for the city of New York, 

$10.9 million for the state of New York, and $2 million 

for the state of New Jersey. Using U.S. Department of 

Commerce employment multipliers, the total increase 

in direct and indirect sales from visitor- and 

concession-related expenditures is responsible for 

about 1,015 jobs in New Jersey and 5,270 jobs in 

New York. 

CURRENT VISITOR EXPERIENCE 

All visitors access Ellis Island by concession-operated 

ferries from either Battery Park in lower Manhattan or 
AFFECTED ENVIRONMENT

80 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

the Central Railroad of New Jersey Terminal in 

Liberty State Park, New Jersey. Since 

September 11, 2001, all visitors are screened before 

they board the ferries. From Manhattan, ferries 

travel first to Liberty Island, where visitors can 

disembark. At Liberty Island, visitors can take part 

in ranger tours and programs, view the interpretive 

waysides, and enjoy the spectacular views of the 

Statue of Liberty, New York harbor, and the 

skyline. Ranger tours inside the monument are 

available with a time pass obtained in advance of 

arrival on the Island. Passes can be reserved on-line 

at www.statuereservations.com or by calling 1-866-

STATUE4. A limited number of walk up passes are 

available on a first come first serve basis each day 

at the ferry ticket offices. Ferries depart 

approximately every 30 minutes from Liberty 

Island for Ellis Island. Ferries leaving from Liberty 

State Park travel in the reverse direction, going to 

Ellis Island first and then to Liberty Island. 

All visitors to Ellis Island arrive at the historic ferry 

slip and are directed to the Main Building that now 

houses the Ellis Island Immigration Museum. Here, 

on three floors of the building, visitors can view 

extensive permanent and temporary exhibits 

pertaining to immigration and related themes. 

Visitors may participate in ranger tours or 

experience the museum at their own pace. For a fee, 

visitors may also rent a portable audio player that 

provides supplemental interpretive information. An 

introductory film is presented several times an hour 

and at times, historical dramas are presented in a 

small theatre. Visitors spend an average of 2 to 

3 hours on Ellis Island. 

The American Family Immigration History Center, 

developed and operated by the Statue of LibertyEllis Island Foundation, is located in a portion of 

the ground floor of the Main Building. For a fee, 

visitors can conduct immigrant research using a 

computer database of ship manifests and print out 

their search results. 

Visitor services on Ellis Island include a 

concession-operated café and gift shop. Weather 

permitting, visitors can stroll around a portion of 

the grounds adjacent to the Main Building with 

views of the harbor, the Statue of Liberty, and the 

Manhattan skyline. 

PARK ADMINISTRATION 

The National Park Service operates the Statue of 

Liberty National Monument (which includes Liberty 

and Ellis Islands) 364 days a year. Ellis Island is open 

from 9:30 A.M. to 5:15 P.M. for visitors, with extended 

open hours during the summer and when space is 

provided for special events. Hours vary seasonally and 

according to weather. Visitors currently arrive by 

ferries both for normal visitation and for special events. 

The National Park Service maintains offices in the 

Kitchen and Laundry Building on the north side of 

Ellis Island for the administration and operation of the 

Statue of Liberty National Monument. Approximately 

250 to 300 park staff and contract employees work on 

Liberty and Ellis Islands, depending upon the time 

of year. 

The existing temporary service bridge facilitates access 

to Ellis Island by NPS and concession staff, 

maintenance contractors, emergency personnel, and 

suppliers. Park operations also require periodic 

building maintenance, delivery of supplies, and 

removal of wastes for which the service bridge 

provides access. The temporary service bridge also 

provides rapid access and egress for emergency 

vehicles in case of a medical, fire, hazardous waste, or 

law enforcement emergency. 

The Jersey City Fire Department provides fire 

protection and medical emergency response to Ellis 

Island and Liberty State Park. The Fire Department 

employs approximately 480 full-time personnel, all of 

which are first-respondent trained. Some have received 

Emergency Medical Technician (EMT) certification. 

The Fire Department has five fire companies (10, SQ4, 

22, 8, and 9, in respective order) that would respond in 

case of an incident at Ellis Island or Liberty State Park. 

Tower Ladders 4 and 6 would also be utilized if 

needed. 

The Jersey City Fire Department also responds to calls 

for assistance and medical emergencies on Ellis Island 

via Liberty State Park and the temporary service 

bridge. The existing response time is approximately 3 

to 4 minutes. There have been four incidents requiring 

emergency fire department assistance in the last three 

years: one in 2000, two in 2001, and one in 2002. The 

incident in 2002 was reported to be a structure fire that 

may have been due to a lack of maintenance in a 

building; fire response teams were on the scene for 

approximately one hour. 
Social and Economic Environment

FINAL ENVIRONMENTAL IMPACT STATEMENT 81

The Jersey City Emergency Squad consists of three 

two-person trucks that rove throughout the city. 

According to the Jersey City Police Department, 

response time to Ellis Island ranges from 

90 seconds to 4 minutes, depending upon the 

location of the truck at time of dispatch, time of 

day, day of the week, and traffic conditions. 

Depending on the nature of the call for service, 

ambulances may also be dispatched at the same 

time. Ambulance units from Jersey City and 

Bayonne have a response time of less than four 

minutes. 

Currently, trained Emergency Medical Technicians on 

the NPS staff handle medical emergencies; victims are 

normally transported to a fully equipped first-aid 

facility for treatment and to await an ambulance. By 

comparison, medical emergencies on Liberty Island 

require individuals to be transported by ferry to either 

New Jersey or New York City, where an ambulance 

provides transport to a local hospital. A NPS ranger 

accompanies the person on the trip from Liberty Island 

to the mainland. In extreme medical emergencies, a 

helicopter equipped for medical evacuations transports 

individuals off the island. 
82 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

TRANSPORTATION AND CIRCULATION

ACCESS TO ELLIS ISLAND 

TEMPORARY SERVICE BRIDGE ACCESS

The existing service bridge was originally built in 

1986 as a temporary structure to provide access 

during construction of the existing museum and 

visitor center on Ellis Island. The bridge originates in 

the Green Park area of Liberty State Park, directly 

across the narrow waterway from Ellis Island. Users 

of this bridge are restricted to construction, delivery 

and emergency vehicles, and authorized park vehicles 

associated with the administration and maintenance 

services on the island. At no time are pedestrians 

permitted on the bridge. A security guard house is 

located at the entrance to the bridge on the New 

Jersey mainland. The bridge has outlived its intended 

life span and was stabilized in 2002 in order to 

provide safe short-term service. 

FERRY ACCESS

Ferries are the only mode of transportation for the 

general public to access Ellis Island. Circle Line 

operates six ferries between terminals in New York 

City and New Jersey and Liberty and Ellis Islands. 

The capacity of each ferry ranges from 450 to 

1,035 passengers, with a median capacity of about 

800. Ferries currently depart in New Jersey from the 

CRRNJ Terminal located in Liberty State Park, and 

in New York from a slip in Battery Park at the 

southern tip of Manhattan. Scheduled tours and other 

group outings depart from other Circle Line ferry 

terminals in Manhattan. Ferry service is provided 

seven days a week, year-round, from both the New 

York and New Jersey locations. 

Ferry service is historically significant to the New 

York Harbor area and also permits control of the 

number of visitors to Ellis Island. Although there is 

no charge to visit either the Statue of Liberty or Ellis 

Island, there is a fee for the ferry service. Currently, 

the fee is $4 for children and $10 for adults for a 

round-trip ticket that includes both the Statue of 

Liberty and Ellis Island. 

The ferry service is partly governed by supply and 

demand. If the forecast increases in visitor traffic 

associated with the action alternatives (alternatives 2 

and 3) prove accurate, ferry service operators might 

be expected to increase the frequency of trips to Ellis 

Island and the Statute of Liberty. However, there is a 

limit to the number of boats that can be serviced at 

Ellis Island based upon the available number of ferry 

slips (docks) and the need for security. Current 

operations use two slips only. The future ferry route 

may be revised to encourage more visitors to Ellis 

Island. 

BATTERY PARK FERRY SERVICE

The New York access to Ellis Island is from the 

Castle Clinton National Monument in Battery Park at 

the southern tip of Manhattan. Prior to September 11, 

2001, about 3.5 million passengers per year used this 

location to access Ellis and Liberty Islands (NPS 

1995a). In 2002, about 2.2 million embarked from 

Battery Park. The Battery Park location has been in 

operation far longer than the Liberty State Park 

location. 

The two methods available to the public for accessing 

the ferry service at Battery Park include private 

vehicles (cars, taxis, or school buses) and mass 

transportation in the form of New York City subway 

and city buses. Parking in and around Battery Park 

for private vehicles is limited. 

Battery Park is readily accessible by public transit. 

After being temporarily suspended following 

September 11, 2001, bus and subway service has 

been restored. Currently, the M1, M6, and M15 bus 

lines all stop at Battery Park. The Bowling Green 

station on the 4 and 5 subway lines is located next to 

Battery Park. In addition, the N and R subway lines 

stop at the Whitehall Street station, and the 1 and 

9 subway lines stop at the South Ferry station at the 

southern end of Battery Park. An NPS survey of ferry 

passengers indicates a large proportion of travelers 

from the Battery Park terminal access the terminal by 

way of public transportation (42%) or charter bus 

(16%). 

LIBERTY STATE PARK FERRY SERVICE

The New Jersey ferry access point within Liberty 

State Park has been changed several times due to 

construction and modifications within the park. 

Currently, boarding takes place at the North 
Transportation and Circulation 

FINAL ENVIRONMENTAL IMPACT STATEMENT 83

Overlook, adjacent to the CRRNJ Terminal, and at 

the northern end of the park. In 2000, approximately 

842,000 visitors departed from Liberty State Park for 

the Statue of Liberty and Ellis Island. Following 

September 11, 2001, this decreased, and in 2002, 

approximately 500,000 visitors embarked from the 

state park terminal. Future plans for Liberty State 

Park include renovation of one of the existing historic 

ferry slips at the tip of the North Overlook. The use 

of the renovated slip would have historic 

significance, but would probably not change the 

efficiency of the ferry service. 

There are two possible ways to access Liberty State 

Park. Unlike New York, the majority of passengers 

(85%) on the New Jersey ferry arrive at the landing 

in personal automobiles. Mass transit is available to 

the terminal via Hudson-Bergen Light Rail, which 

connects Newport Mall and PATH (Port Authority 

Trans Hudson rail link) in Jersey City to Bayonne 

and Newark. This service is intended to provide a rail 

system along the New Jersey waterfront in the Jersey 

City area, and to connect the waterfront to points in 

New York City. The Liberty State Park light rail 

station is immediately outside Liberty State Park at 

the street intersection of Johnston Avenue and 

Monitor Street in Jersey City, adjacent to the New 

Jersey Turnpike. A park-operated jitney service 

makes stops at both the light rail station and the ferry 

terminal. 

CIRCULATION AND ACCESS 

TO LIBERTY PARK TERMINAL 

Because so many private vehicles are used to access 

the terminal at Liberty State Park, the potential for 

impacts to approaching traffic exists as a result of 

NPS proposals. In addition, air quality could be 

negatively impacted from increased visitor use and/or 

construction of a permanent bridge. Analyses of 

existing traffic conditions and future predicted 

conditions for each action alternative at major 

intersections and access points were conducted for 

this environmental impact statement. 

ACCESS FROM HIGHWAYS

Currently, major vehicular access to Liberty State 

Park is via exits 14B and 14C from the New Jersey 

Turnpike. There are no other highways that provide 

direct access to Liberty State Park. The current New 

Jersey Turnpike signage to Liberty State Park directs 

drivers to use exit 14B, though exit 14C is actually 

closer to Liberty Science Center. Vehicles using exit 

14B are directed through the Industrial Park to reach 

Liberty State Park. The New Jersey Turnpike is 

planning to re-sign exits to provide for more direct 

access by directing park visitors to exit 14C if they 

are headed east on the Turnpike. Exit 14B would still 

be used to access the park for westbound drivers. 

ACCESS FROM ADJACENT ROADWAYS

Several roads exist in Liberty State Park. From a 

counterclockwise direction from the ferry service 

dock at the North Overlook and CRRNJ Terminal, 

the loop roadways are described below. 

Audrey Zapp Drive — located on the northerly side 

of the park, running from the ferry dock, CRRNJ 

Terminal, and North Overlook west to Phillip Drive. 

Audrey Zapp Drive continues west under the New 

Jersey Turnpike and out of the park, changing to 

Johnston Avenue. 

Phillip Drive — runs south from Audrey Zapp Drive 

along the westerly perimeter of the park, passing the 

Liberty Science Center at Communipaw Avenue. 

Phillip Drive ends at Burma Road in the adjacent 

industrial park that occupies the southwest corner of 

the peninsula on which Liberty State Park is located. 

Burma Road — continues south through the 

industrial park to a traffic circle at the southwest 

corner of the industrial park. At the traffic circle, 

Burma Road meets Morris Pesin Drive and Bayview 

Avenue. 

Morris Pesin Drive — a continuation of Bayview 

Avenue from the west. Morris Pesin Drive proceeds 

east through the industrial park and into Liberty State 

Park, terminating at Freedom Way at the Visitor 

Center entrance to Liberty Walk and South Overlook. 

Freedom Way — continues north from Morris Pesin 

Drive to terminate at Audrey Zapp Drive 

immediately west of the CRRNJ Terminal. Liberty 

Walk, which parallels Freedom Way, is a pedestrian 

walkway along the waterfront between the Visitor 

Center at South Overlook and the ferry dock at North 

Overlook. 

Current roadway configuration and signage direct 

Liberty State Park visitors from the New Jersey 

Turnpike exit 14B onto Bayview Avenue. At the 
AFFECTED ENVIRONMENT

84 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

traffic circle in the industrial park, visitors can either 

turn east onto Morris Pesin Drive to reach the visitor 

center, or north onto Burma Road to reach Liberty 

Science Center. 

NEW JERSEY AREA FERRY 

AND LIGHT RAIL ACCESS

Ferry service connects the Exchange Place, Hudson 

Exchange, and Liberty Harbor North areas to lower 

Manhattan, and also connects Hudson Exchange to 

38th Street in Manhattan. In April 1999 the HudsonBergen Light Rail Transit System (HBLRTS) began 

operation from 34th Street in Bayonne to Exchange 

Place, providing access to Exchange Place area 

businesses, Colgate ferry, and the PATH from two 

park-and-ride lots and 11 stations in Bayonne and 

Jersey City. Recently, the HBLRTS has extended its 

operation to Harborside, Newport, and Hoboken. 

When completed, the HBLRTS will be a 20.5-mile 

system that will run along the Hudson County 

waterfront from Bayonne to Ridgefield in Bergen 

County, New Jersey. 

PARKING FACILITIES 

ELLIS ISLAND

Parking on Ellis Island is currently limited to 

employees, contractors, suppliers, and other essential 

personnel. Currently, parking exists for 40 to 50 NPS 

employees on the west side of the island behind the 

Bakery and Carpentry Building. Temporary, informal 

parking areas have existed with the construction of 

the temporary service bridge that was built in 1986 

for the rehabilitation of the Ellis Island Immigration 

Museum and other buildings on Island 1. Additional 

small parking areas have also been created on the 

island for stabilization contractors, delivery trucks, 

and other visitors. 

LIBERTY STATE PARK

Liberty State Park provides several scattered parking 

areas for private cars and buses. Lot 6 functions as 

the primary parking area for visitors to Ellis and 

Liberty Islands, accommodating 900 cars and 

50 buses. This lot reaches capacity on busy days but 

is typically no more than one-half full during the 

week, even in the summer. A fee of $5 to park more 

than 2 hours is collected. The park intends to add 

25 bus spaces to Lot 6. 

Other lots adjacent to the park’s Visitor and 

Interpretive Centers can accommodate several 

hundred additional vehicles some distance from the 

terminal and ferry slip. Vehicles using these lots most 

often belong to visitors who are picnicking or using 

Liberty Walk, the Visitor Center, or the Interpretive 

Center. Recent spot checks indicate most of these lots 

are no more than one-half full during the week. Two 

additional lots serve the Liberty Science Center. 

Overall, parking facilities at Liberty State Park are 

sufficient for most weekdays, but insufficient for 

heavy normal days and special-event situations. On 

sunny weekend days, the parking areas can reach 

their capacities, and access restrictions must be 

enforced. This is exacerbated by a steady increase in 

visitorship to the park, from approximately 

1.6 million visitors in 1990 to approximately 

4.5 million in 2001. Liberty Science Center currently 

experiences over 700,000 visitors with a projected 

1.1 million visitors by 2005. As such, available 

parking is a growing concern. 

The Liberty State Park Transportation Master Plan 

Update completed in 2002 (Vollmer 2002) 

recommends the completion of an expanded central 

parking facility at the Liberty Science Center. There 

are no other plans for expanding parking facilities 

within the park. Without additional available parking, 

there is concern that the anticipated increases in 

visitors to Liberty State Park and Ellis Island would 

routinely overwhelm the parking facilities during the 

primary season. 

NEARBY PARKING FACILITIES

Two public parking lots exist outside Liberty State 

Park. The park operates a jitney between the light rail 

station and several transit stations in Liberty State 

Park. A lot for the rail station near the Liberty 

Science Center accommodates approximately 

1,200 vehicles, with the possibility of increasing the 

lot to 5,000 cars. Visitors to the park could utilize 

both this lot and the jitney to access the ferries to 

Ellis Island, although the jitney stop currently is 

intended to serve as a connection between the train 

and the park, rather than for visitors arriving in 

personal vehicles. The lot is operated by the New 

Jersey Transit Authority for light rail passengers 

only, but does allow the park to use it for overflow 
Transportation and Circulation 

FINAL ENVIRONMENTAL IMPACT STATEMENT 85

parking during peak usage days (primarily summer 

weekends) and for special events. Although the 

Jersey City Planning Board has approved the largercapacity lot, expansion would require a parking 

structure, and no plans are currently being 

considered. 

The West Side Avenue Park and Ride lot is located in 

Jersey City. This lot is not in the vicinity of the park, 

and no regular transit service exists between it and 

the park. In addition, signs directing visitors to the 

park are poor. Jersey City is considering a wayfinding program to direct visitors to the park and to 

the West Side Avenue park-and-ride lot. 

CIRCULATION 

The Hudson County Extension of the New Jersey 

Turnpike is the primary access route to Liberty State 

Park. Impending connection of the Hudson Bergen 

Light Rail to Hoboken Terminal will offer visitors 

the ability to reach Liberty State Park by mass transit. 

Due to the long distances between attractions within 

the park and the limited access from areas north and 

west of the park, there is relatively little pedestrian 

circulation within the park. 

Visitors are encouraged to take advantage of a park 

shuttle to travel within the park on a 40-minute loop. 

Recent residential, commercial, and office 

development in downtown Jersey City will likely 

create an expanded base of potential visitors who 

would access the park on foot. 

The effective operation of an urban street network is 

largely dependent on the way that roadway 

intersections accommodate traffic. In particular, the 

level of service (LOS) at signalized and unsignalized 

intersections controls the level of service of the entire 

roadway network. 

A 1994 traffic study (NPS 1995a) indicated that the 

intersection of Audrey Zapp Drive and Phillip Drive 

was operating at capacity—LOS E—during afternoon 

hours. Given the normal increase in capacity 

observed at area intersections, this intersection may 

now be operating at an unacceptable level of service 

(LOS F). LOS F is defined as having average vehicle 

delays of over 60 seconds at unsignalized 

intersections. LOS F intersections will operate in an 

unpredictable manner, with the possibility for 

extensive delays and gridlock. All other intersections 

within Liberty State Park and in the adjacent 

industrial park were found to operate at acceptable 

levels of service. 

The off-site intersections through which park visitors 

access the park were found to operate at unacceptable 

levels of service during the afternoon and evening. 

There are two intersections between New Jersey 

Turnpike exit 14B and the traffic circle in the 

industrial park: Morris Pesin Drive / Bayview 

Avenue at Caven Point Road and Bayview Avenue at 

the New Jersey Turnpike exit. Both of these 

intersections were found to operate at or above 

capacity (LOS E or LOS F) in 1994. Since the 

number of visitors to the park area has increased, it is 

likely that vehicle traffic and congestion has also 

increased to a predominately LOS F situation at these 

intersections. 

The 2002 Liberty State Park Transportation Master 

Plan Update (Vollmer 2002) includes a number of 

proposed projects within the park to promote better 

vehicular circulation; these include 

installing a traffic light at Audrey Zapp 

Drive and Phillip Street 

realigning Phillip Street and Burma Road 

eliminating the Burma Road Traffic Circle 

improving the turning radii at the corner 

of Morris Pesin Drive and Freedom Way 

prohibiting trucks from making left turns 

onto Phillip Street from Jersey City 

Boulevard
86 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

ELLIS ISLAND INFRASTRUCTURE

STABILIZATION IMPROVEMENTS 

Phase I and II stabilization improvements have been 

completed on Island 2. The stabilized buildings 

include the Hospital Building, Hospital 

Administration Building, New Hospital Extension, 

Psychopathic Ward, and portions of the connecting 

corridors. The Ferry Building and Hospital 

Outbuilding and Laundry were also included in this 

effort and have now undergone extensive exterior 

restoration. 

The intent of the pending Phase III stabilization will 

be to stabilize the balance of the buildings and 

structures on Islands 2 and 3, as well as the Baggage 

and Dormitory Building on Island 1. The Phase III 

stabilization work will proceed and be coordinated 

with Phase I of the upgrades to the south-side master 

utilities and infrastructure improvements. 

The objective of the stabilization improvements is to 

reduce the rate of deterioration to the buildings and 

structures for a period of 10 to 15 years, by securing 

the building envelopes from the elements. Upon 

completion of the stabilization improvements, the 

buildings and structures will require continued 

maintenance and housekeeping programs in order to 

achieve the maximum benefit for the longest period 

of time. 

UTILITIES 

Ellis Island receives utility service from the various 

New Jersey utilities. Many of the utility support 

systems were upgraded as part of the major 

renovations completed in 1990 for the opening of the 

Immigration Museum and in anticipation of future 

redevelopment of the south side. 

PLUMBING SYSTEMS 

DOMESTIC WATER

Domestic water is supplied through a 12-inchdiameter ductile iron pipe fed from a 12-inch city 

water main, located in Liberty State Park, New 

Jersey, where the utility company meter pit is 

located. The water main crosses under the Hudson 

River and enters the island through the Main 

Powerhouse Building. The water service has been 

designed to provide water service and fire protection 

for the entire island. 

After entering the Powerhouse Building, a 4-inch 

branch line provides temporary domestic water to 

Islands 2 and 3, while the 12-inch main feeds two 

25-hp (horsepower), 1,000-rpm (revolutions per 

minute), 75-foot head tank fill pumps, which then 

feed a 300,000-gallon elevated water storage tank. 

The elevated tank feeds a 10-inch undergroundpressurized loop around Island 1. The underground 

loop currently supplies the fire hydrants and feeds 

domestic water services and fire protection/sprinkler 

systems in the Powerhouse, Bakery and Carpentry, 

Kitchen and Laundry, and Main Buildings. The water 

supply has a capped 10-inch underground tap for 

future extension of the water supply lines to Islands 2 

and 3. 

According to the Draft Ellis Island Utility System 

Existing Conditions Report by H.F. Lenz Company 

(H.F. Lenz Company 2001), the domestic water 

piping and valves appear to be in good condition, 

with no leaks or deterioration of pipe joints visible. 

The available water pressure was sufficient for the 

plumbing fixtures or equipment it served. Static 

pressure in the Main Building measured 36 psi 

(pounds per square inch) in the basement and 30 psi 

at the second floor. 

The primary purpose of the 300,000-gallon water 

storage tank is to provide domestic water and fire 

protection water reserve capacity. Additionally, the 

tank minimizes dependency on the Jersey City Water 

Authority for water pressure and flow during shortterm interruptions in service. 

Islands 2 and 3 currently have no domestic water 

supply connections to existing buildings or structures. 

The existing domestic water lines that at one time 

were active have been abandoned in place and are 

believed to be inadequate for reuse because of 

deteriorated condition (H.F. Lenz Company 2001). 

Several sections of the piping would require testing 

to confirm this assumption. A secondary 8-inch water 

main from Jersey City was provided to Islands 2 

and 3 as part of the 1988 renovations on Island 1. 

According to the Ellis Island Site Utilities Technical 

Feasibility Study (Syska and Hennessy, Inc. 1984), a 

leak had occurred near the New Jersey bulkhead. The 
Ellis Island Infrastructure 

FINAL ENVIRONMENTAL IMPACT STATEMENT 87

study recommended that the line be repaired and used 

during construction and then interconnected to the 

new water distribution loop to serve as a reserve in 

the event of a rupture in the new line. 

FIRE PROTECTION

Water service for fire protection is provided from the 

10-inch water service loop that encircles Island 1. 

Currently, electric fire pumps located in the basement 

of the Bakery and Carpentry Building and in the 

Main Building are used to provide pressure to operate 

sprinkler systems in these buildings and in the 

Kitchen and Laundry Building. A fire pump test 

header for the Main Building is located at the harbor, 

while the test header for the Bakery and Carpentry 

Building is located along the south wall of the 

structure. 

New fire hydrants were installed around Island 1 as 

part of the 1980s renovation project. Inspection of 

existing fire hydrants on Islands 2 and 3 revealed that 

the condition was very poor due to inactivity and 

could not be operated because of rusted or corroded 

valves and parts. Reportedly, previous attempts by 

NPS staff to reuse existing piping and equipment 

have been unsuccessful, which suggests that all 

underground piping on the south side may need to be 

replaced. 

SEWAGE DISPOSAL

Existing duplex sewage disposal pumps, located 

adjacent to the Powerhouse at the north end of 

Island 1, consist of a 480-gpm (gallons per minute), 

duplex lift station that discharges all waste from 

Island 1 to the Jersey City Sewage Authority System 

through an 8-inch ductile iron force main. The pumps 

were installed in conjunction with the 1988 

renovations on Island 1. The pumps currently serve 

only the renovated buildings but were sized with 

future building renovations in mind. 

The existing domestic water and sanitary sewage 

loads are based on north-side figures and produce 

120,000 gallons per day; south side produces 

150,000 gallons per day. The combined flow of 

270,000 gallons per day is sufficient for a population 

of 1,000 day-night users. The north side’s daily 

demand of 120,000 gallons equates to a flow rate of 

211 gpm, leaving a reserve pumping capacity for the 

south side of 269 gpm. 

STORM SEWERS

The existing storm sewer system on Ellis Island 

consists of two distinct, separate systems: one serves 

Island 1 and another serves Islands 2 and 3. The 

system on Island 1 includes yard inlets, catch basins, 

area drains, roof drains, pipes, and rainwater 

conductors that deposit stormwater into the Hudson 

River (New York Harbor). Also included in this 

system are some drainage structures (inlets) from an 

earlier period. The newer parts of this system were 

installed with restoration work undertaken to develop 

the visitor and administrative areas. 

The sewer system on Islands 2 and 3 consists of a 

combination storm and sanitary sewer system. 

Stormwater is piped away from the buildings through 

sewer pipes that collect both stormwater and sanitary 

sewage. The combined flow is deposited into the 

Hudson River. The system on Island 2 also includes 

cisterns. Many older municipalities in the region have 

similar combined sewer systems. 

ELECTRIC AND FUEL SERVICE 

ELECTRICAL POWER

Ellis Island is currently supplied with 13.2 kV 

(kilovolt) power from a Public Service Electric & 

Gas (PSE&G) substation located in Liberty State 

Park in New Jersey. The 13.2 kV cables run beneath 

New York Harbor, encased in PVC conduit to the 

Powerhouse. A double-ended switchgear unit is 

located in the Powerhouse, which in turn distributes 

13.2 kV power to transformers in the Powerhouse 

and Main Buildings. From there, power is distributed 

at lower voltage levels to the remaining buildings and 

equipment on Ellis Island. These voltage levels are 

usually 480/277 volts or 208/120 volts, 3-phase. 

The power system appears to have been designed to 

serve all of Ellis Island. The main distribution 

equipment is located in the Powerhouse and currently 

is connected at full power to two other buildings. The 

secondary power distribution system to the existing 

buildings on Islands 2 and 3 has not been operated 

because of its poor condition. Temporary service to 

the buildings for ongoing stabilization work is 

currently provided through temporary feeders. The 

13.2 kV switchgear, located in the Powerhouse, is 

equipped with spare breakers designated for feeder 

extensions to all parts of the island. 
AFFECTED ENVIRONMENT

88 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

STANDBY ELECTRICAL POWER GENERATION

A single 750 kW (kilowatt) diesel generator is 

located in the Powerhouse and serves the life safety 

loads in the Main, Powerhouse, and Kitchen and 

Laundry Buildings. This generator also serves the fire 

pumps that are located in the Main Building and in 

the Bakery and Carpentry Building. The generator is 

not adequately sized to provide standby power for the 

entire island. 

NATURAL GAS

Natural gas service to Ellis Island is provided by 

Public Service Electric & Gas. An existing 8-inchdiameter service line was installed by Public Service 

Electric & Gas for the rehabilitation and restoration 

of Island 1. The service enters the Powerhouse 

Building, where it primarily serves three highpressure steam boilers. The boilers were designed to 

provide heating, domestic hot water generation, and 

humidification loads for the entire island. 

FUEL OIL

No. 2 fuel oil is stored on Ellis Island to serve the 

fueling station for NPS boats, to provide fuel for the 

diesel-driven electric generator, and as a back-up fuel 

for the steam boilers. The oil is stored in three 

10,000-gallon aboveground, concrete-vaulted tanks 

located in the northwest corner of Island 1. Oil is 

pumped through a quadraplex fuel oil pump station to 

a day tank, where it serves the boilers and generator. 

In addition to the quadraplex pumps, a simplex fuel 

oil pump located in its own building serves the 

fueling station. 

MECHANICAL SYSTEMS 

CENTRAL CHILLED-WATER PLANT

A central chilled-water plant was installed within the 

Powerhouse Building on Island 1 as part of the 1980s 

renovation project to serve the island’s present needs, 

as well as the proposed future needs. The central 

chilled-water plant consists of three electric-driven 

hermetic chillers; three induced-draft, cross-flow 

cooling towers; three chilled-water distribution 

pumps; three condenser water pumps; and one plateand-frame heat exchanger. 

Two of the existing chillers have a nominal capacity 

of 500 tons and were manufactured in 1985. The 

third chiller has a capacity of 700 tons and was 

manufactured in 1995. Currently, only one of the 

three chillers is required to be operating at any given 

time to serve the existing cooling demands, resulting 

in a relatively low number of operating hours for 

each machine. The chillers are in good condition and 

have a life expectancy of at least 10 more years 

(through 2011) with current demand and operation 

patterns. Refrigerant HCFC-123, to be phased out in 

year 2030, is utilized in all three machines. An 

ASHRAE-15 compliant ventilation system has been 

installed within the chilled-water plant; however, the 

existing refrigerant monitoring system is not 

operational. 

Two cooling towers with a nominal capacity of 

500 tons were installed in 1985 to serve the two 

original chillers. A third cooling tower with a 

nominal capacity of 700 tons was installed in 1995 to 

serve the third chiller. Each cooling tower is provided 

with a submersible-type distribution pump. The 

original cooling towers and their associated pumps 

are in relatively poor condition and would need to be 

replaced in the near future, assuming existing 

demand remains at current levels. The condenser 

water system is provided with a chemical water 

treatment system. 

Three chilled-water pumps are designed to match the 

required flow rate through each associated chiller. 

The pumps are connected in a parallel piping 

configuration allowing for each pump to operate at 

full flow. A single chiller and associated pump can 

satisfy the cooling demand for the existing renovated 

structures on Island 1. 

A plate-and-frame heat exchanger has been installed 

within the Powerhouse 1 Building as part of the 

1980s renovation project to generate chilled water in 

the winter months without the use of the chillers. The 

heat exchanger can produce nominally 500 tons of 

cooling with one of the 500-ton cooling towers. 

CENTRAL HEATING PLANT

In addition to the construction of a new chilled-water 

plant in Powerhouse 1, the 1980s renovation project 

included a new high-pressure steam boiler plant and 

distribution system. The estimated heating and 

domestic water heating requirements for the entire 

island were approximately 1,212-boiler hp or 
Ellis Island Infrastructure 

FINAL ENVIRONMENTAL IMPACT STATEMENT 89

40,573 million Btu/hr (British thermal units per 

hour). 

There are three dual-fuel (gas and No. 2 fuel oil) 

high-pressure steam boilers, with a total capacity of 

1,200-boiler hp, to meet the heating and hot water 

needs of the entire island. 

As with the chilled-water needs, all existing demand 

for heating comes from Island 1. High-pressure steam 

piping and pressure-reducing valves provide lowpressure steam for domestic hot water, heating, and 

humidification needs in the renovated buildings on 

Island 1. Low-pressure condensate receiver/pumps 

located in each building pump condensate back to the 

surge tank in Powerhouse 1 to feed the boilers. 

The overall condition of the boiler plant is good to 

fair. The boiler plant was constructed to allow for a 

fourth boiler at 500-boiler hp in order to provide 

additional capacity and/or redundancy to the system 

if it is expanded. 
Environmental 

Consequences
FINAL ENVIRONMENTAL IMPACT STATEMENT 93

INTRODUCTION 

This environmental consequences chapter analyzes 

both beneficial and adverse impacts that could result 

from implementing the three alternatives. In addition, 

it includes a summary of laws and policies relevant to 

each impact topic, methods used to analyze impacts, 

and definitions of impact “thresholds” (e.g., 

negligible, minor, moderate, and major). As required 

by the national regulations implementing the 

National Environmental Policy Act (NEPA), a 

summary of the impacts is provided in table 2, which 

can be found in the “Alternatives” chapter. 

As noted in the “Purpose of and Need for the Action” 

chapter, this environmental impact statement includes 

more specific information for the rehabilitation of 

buildings on Ellis Island than it does for a permanent 

bridge. This is because an additional environmental 

analysis would be completed to compare alternative 

bridge designs and the impacts of construction and 

operation. Additional environmental analysis would 

also include obtaining all necessary permits and 

approvals from state and federal regulatory agencies. 

OVERARCHING LAWS AND POLICIES 

Two overarching environmental protection laws and 

policies guide the National Park Service: the National 

Environmental Policy Act of 1969 and its 

implementing regulations and the NPS Organic Act 

of 1916. 

The National Environmental Policy Act is 

implemented through regulations of the Council on 

Environmental Quality (CEQ) (40 CFR 1500–8). The 

National Park Service has in turn adopted procedures 

to comply with the National Environmental Policy 

Act and CEQ regulations, as found in Director’s 

Order 12: Conservation Planning, Environmental 

Impact Analysis, and Decision Making (NPS 2001a) 

and its accompanying handbook. 

The National Park Service is prohibited by the NPS

Organic Act from impairing park resources and 

values. NPS Management Policies (NPS 2001c,

Section 1.4.5) state “an impairment . . . is an impact 

that, in the professional judgment of the responsible 

NPS manager, would harm the integrity of park 

resources or values, including the opportunities that 

otherwise would be present for the enjoyment of 

those resources or values.” 

In keeping with the requirements of both Director’s 

Order 12 and NPS Management Policies, this 

environmental impact statement includes an 

assessment of whether impairment of park resources 

or values might occur. The NPS Management 

Policies help park units identify whether impairment 

is possible by providing the following guidance: 

An impact would be more likely to constitute an 

impairment to the extent that it affects a resource 

or value whose conservation is necessary to 

fulfill specific purposes identified in the 

establishing legislation or proclamation of the 

park, is the key to the natural or cultural integrity 

of the park or to opportunities for enjoyment of 

the park, or is identified as a goal in the park’s 

general management plan or other relevant NPS 

planning documents. 

An impact would be less likely to constitute 

impairment to the extent that it is an unavoidable 

result, which cannot be reasonably further 

mitigated, of an action necessary to preserve or 

restore the integrity of park resources or values. 

CUMULATIVE IMPACTS 

Cumulative impacts are a part of every NPS 

environmental analysis. They help the reader and 

decision maker understand something about the 

“total” or “combined” impacts of actions on a 

resource that may also be affected by the actions in 

one of the alternatives. The analysis includes actions 

taken in the past, present, or reasonably foreseeable 

future, and is without regard to land ownership. 

Therefore, actions on private or adjacent state or 

federal land that contribute to impacts on resources in 

the study area can be included. 
94 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

METHODOLOGY FOR ANALYZING IMPACTS

This section provides a description of the 

methodology and thresholds used in the impact 

analysis. 

CULTURAL RESOURCES 

A review of relevant resource materials regarding 

cultural resources on Ellis Island and in the project 

area was completed to identify and evaluate potential 

impacts to historic properties. The most recent 

cultural resource studies conducted within the 

proposal area include Pousson (1986), Hunter 

Research (1993), and NPS Olmsted Center for 

Landscape Preservation, Cultural Landscape Report 

for Ellis Island (2002). In addition, a review of 

documents related to several cultural resource studies 

conducted in the general area within the past 25 years 

contributes to the information provided in the 

“Affected Environment” chapter of this document.

The National Park Service characterizes cultural 

resources by the following categories: historic 

architectural resources, cultural landscapes, 

archeological resources, museum objects, and 

ethnographic resources. The potential impacts and 

mitigation measures for all alternatives are addressed 

below by cultural resource type. The analysis of 

impacts to cultural resources presented in this Final 

Environmental Impact Statement assumes the 

National Park Service's adherence to The Secretary of 

the Interior's Standards for the Treatment of Historic 

Properties (see “Regulations and Policies” section in 

this chapter for more information on these standards). 

For the purposes of this document, the level of 

impacts on cultural resources was determined using 

the following criteria: 

HISTORIC ARCHITECTURAL 

RESOURCES, CULTURAL LANDSCAPES

Negligible — impact(s) at the lowest levels of 

detection (barely perceptible or measurable). 

Minor Adverse — impact does not affect the 

character-defining features of a National Register 

eligible or listed structure or cultural landscape. 

Minor Beneficial — stabilization/preservation of 

character-defining features to maintain existing 

integrity of a structure or cultural landscape in 

accordance with The Secretary of the Interior's 

Standards for the Treatment of Historic Properties

and The Secretary of the Interior's Standards for the 

Treatment of Historic Properties with Guidelines for 

the Treatment of Cultural Landscapes (Secretary of 

the Interior's Standards).

Moderate Adverse — impact alters a characterdefining feature(s) of the structure or cultural 

landscape but does not diminish the National Register 

integrity of the resource. Moderate Beneficial — 

rehabilitation of a structure or cultural landscape in 

accordance with the Secretary of the Interior's 

Standards to make possible a compatible use of the 

resource, while preserving its character-defining 

features. 

Major Adverse — impact alters a character-defining 

features(s) of the structure or cultural landscape, 

diminishing its integrity to the extent that it is no 

longer eligible for the National Register. Major 

Beneficial — restoration in accordance with the 

Secretary of the Interior's Standards to accurately 

depict the form, features, and character of a structure 

or cultural landscape as it appeared during its period 

of significance. 

Impairment — A major, adverse impact to a resource 

or value whose conservation is (1) necessary to fulfill 

specific purposes identified in the establishing 

legislation or proclamation of Ellis Island as a 

National Monument; (2) key to the natural or cultural 

integrity of the park; or (3) identified as a goal in the 

park's general management plan or other relevant 

NPS planning documents. 

ARCHEOLOGICAL RESOURCES

Negligible — impact(s) is at the lowest levels of 

detection (barely perceptible or measurable). 

Minor Adverse — impact affects an archeological site 

with the potential to yield important information 

related to local prehistory/history. Disturbance is 

confined to a small area with little, if any, potential 

for loss of important information. Minor Beneficial 

— preservation of a site in its natural state. 
Methodology for Analyzing Impacts

FINAL ENVIRONMENTAL IMPACT STATEMENT 95

Moderate Adverse — impact affects an archeological 

site with the potential to yield important information 

related to state prehistory/history. Disturbance would 

not result in a substantial loss of important 

information. Moderate Beneficial — stabilization of 

the site. 

Major Adverse — impact affects an archeological site 

with the potential to yield important information 

related to national prehistory/history. Disturbance is 

substantial, resulting in the loss of most or all of the 

site's potential to yield important data. Major

Beneficial — active intervention to preserve the site. 

Impairment — same as under “Historic Architectural 

Resources, Cultural Landscapes.” 

NATURAL RESOURCES 

GEOLOGIC RESOURCES, 

SOILS, AND MARINE SEDIMENTS

Information from the U.S. Forest Service, National 

Oceanic and Atmospheric Administration, and 

historic literature were consulted to identify existing 

and historical conditions. The following definitions 

were used to assess impacts: 

Negligible — The impact is slight but detectable 

locally or in the short-term, or is at the lower levels 

of detection in the long-term or regionally. 

Minor — The impact is readily apparent locally or in 

the short-term, or slight but detectable in the longterm or regionally. 

Moderate — The impact is severe locally or in the 

short-term, or readily apparent regionally or in the 

long-term. 

Major — The impact is severe regionally or in the 

long-term. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 

FLOODPLAINS

Floodplain maps and information in an earlier 

environmental impact statement (NPS 1995a) were 

used to assess the 100- and 500-year floodplains for 

the project area. The following definitions of impacts 

were used in evaluating effects on flooding. 

Negligible — No detectable change in the risk of 

flooding would occur. 

Minor — Slight, but detectable changes in the risk of 

flooding or extent of damage it would cause would 

occur. 

Moderate — Readily detectable changes in the risk of 

flooding or extent of damage it would cause would 

occur. 

Major — Very large increases in the risk of flooding 

or extent of damage it would cause would occur. 

Impairment — The risk and frequency of large-scale 

flooding would irreparably damage park resources or 

values. 

VEGETATION / THREATENED 

AND ENDANGERED PLANT SPECIES

The standards developed by the New Jersey 

Department of Environmental Protection were used 

to assess the status of vegetative communities at 

Liberty State Park and on Ellis Island and to 

document potential impacts from each of the 

alternatives. The following definitions of impacts 

were used in evaluating effects on vegetation: 

Negligible — The impact is slight but detectable 

locally or in the short-term, or is at the lower levels 

of detection in the long-term or regionally. No 

protected species are affected. 

Minor — The impact is readily apparent locally or in 

the short-term, or slight but detectable in the longterm or regionally. No habitat critical for protected 

species is affected or other habitat is available 

nearby. 

Moderate — The impact is severe locally or in the 

short-term, or readily apparent regionally or in the 

long-term. Local loss of protected species may occur, 

but regional populations are not affected in a readily 

detectable way. 
ENVIRONMENTAL CONSEQUENCES

96 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

Major — The impact is severe regionally or in the 

long-term. The loss of local protected species affects 

regional populations in a readily detectable way. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 

FISH

The literature was consulted to determine which 

species of fish would be present in the vicinity of the 

island. The same criteria and methodology as those 

described below for wildlife were used to determine 

impacts to fish. 

WILDLIFE / THREATENED 

AND ENDANGERED WILDLIFE SPECIES

Casual and more systematic wildlife surveys in 

Liberty State Park and on Ellis Island were used to 

determine the presence or absence of particular 

species. Special zones, such as the Natural Area in 

Liberty State Park, were considered in each 

alternative to document possible far-reaching wildlife 

effects within the park. Informal consultation with 

both the U.S. Fish and Wildlife Service and the New 

Jersey Department of Environmental Protection were 

held to help determine the presence or absence of 

federal (threatened, endangered, candidate, or 

proposed) and state (threatened or endangered) 

protected animal species. 

The following definitions were used to assess impacts 

to wildlife: 

Negligible — The impact to nonprotected wildlife is 

slight but detectable locally or in the short-term, or is 

at the lower levels of detection in the long-term or 

regionally. No protected species are affected. 

Minor — The impact to nonprotected wildlife is 

readily apparent locally or in the short-term, or slight 

but detectable in the long-term or regionally. No 

habitat critical for protected species is affected or 

other habitat is available nearby. Only nonbreeding 

animals of concern are present, or proposed 

mitigation to breeding animals will fully offset 

impacts to these individuals. 

Moderate — The impact to nonprotected wildlife is 

severe locally or in the short-term, or readily apparent 

regionally or in the long-term. Local loss of protected 

species may occur, but regional populations are not 

affected in a readily detectable way. Actions may 

interfere with activities necessary for survival or 

breeding on an occasional or short-term basis, but are 

not expected to threaten the continued existence of 

the species in the park. 

Major — The impact to nonprotected wildlife is 

severe regionally or in the long-term. The loss of 

local protected species affects regional populations in 

a readily detectable way. Mortality or other effects 

are expected on a regular basis and could threaten 

continued survival of the species in the park. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 

WATER RESOURCES

The Clean Water Act and supporting criteria and 

standards (promulgated by the Environmental 

Protection Agency) and criteria applicable to surface 

water and groundwater quality (as established by the 

New Jersey Department of Environmental Protection 

and New York State Department of Environmental 

Conservation standards for class I and SE2 waters) 

were used to assess waters surrounding Ellis Island. 

The following impact thresholds were established to 

describe the relative changes in water quality 

(overall, localized, short-term, long-term, cumulative, 

adverse, and beneficial) under the two action 

alternatives when compared with the baseline 

conditions of the no-action alternative for Ellis 

Island. 

Negligible — The impact is slight but detectable 

locally or in the short-term, or is at the lower levels 

of detection in the long-term or regionally. 

Minor — The impact is readily apparent locally or in 

the short-term, or slight but detectable in the longterm or regionally. 

Moderate — The impact may exceed standards in the 

short-term, or is readily apparent, but does not exceed 

standards, regionally or in the long-term. 
Methodology for Analyzing Impacts

FINAL ENVIRONMENTAL IMPACT STATEMENT 97

Major — The project will result in impacts that 

exceed New York and New Jersey standards for 

water quality in the long-term or permanently. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 

AIR QUALITY

The pollutants of concern for this Final 

Environmental Impact Statement are those associated 

with vehicle emissions, and include carbon monoxide 

(CO), and the constituents of “smog” or ozone, 

hydrocarbons and oxides of nitrogen. Because it is 

most likely to change, carbon monoxide was 

particularly called out in this analysis. 

Four stations were selected for this project to 

represent existing (i.e., background) ambient air 

quality. Those stations were located at Kennedy 

Boulevard in Jersey City, Newark Avenue in Jersey 

City, Veterans Park in Bayonne, and Tonnelle 

Avenue in North Bergen. Year 2001 data are the 

latest available data for these monitoring stations. 

The New Jersey Department of Environmental 

Protection records CO levels at the Kennedy 

Boulevard and North Bergen monitoring stations. 

The Kennedy Boulevard station has a record 

extending back many years. For this Final 

Environmental Impact Statement, CO levels were 

analyzed for the period between 1996 and 2001. 

The model added CO emissions related to localized 

traffic increases and delays at intersections, projectrelated impacts from construction vehicles, and 

conservative CO background levels, and the resulting 

total impact was compared to the 1-hour and 8-hour 

CO ambient air quality standards of 35 mg/kg 

(milligrams/kilograms) and 9 mg/kg (35 parts per 

million [ppm] and 9 ppm, respectively), in order to 

assess the compliance of the intersections with the 

standards. Results from an earlier, unpublished study 

(NPS 1995a) were then compared with baseline 

conditions in 2001 and the proposed alternatives. A 

qualitative analysis was then conducted to determine 

potential impacts to air quality. 

The following definitions were used in assessing 

impacts to air quality: 

Negligible — The impact is slight but detectable 

locally or in the short-term, or is at the lower levels 

of detection in the long-term or regionally. 

Minor — The impact is readily apparent locally or in 

the short-term, or slight but detectable in the longterm or regionally. 

Moderate — The impact may exceed standards in the 

short-term, or is readily apparent, but does not exceed 

standards, regionally or in the long-term. 

Major — The project will result in impacts that 

exceed air quality standards in the long-term or 

permanently. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 

NOISE

Because the sound pressure level unit of dBA 

(A-weighted decibel) describes a noise level at just 

one moment and very few noises are constant, the 

equivalent sound level, Leq is used to describe the 

fluctuating noise heard over a specific period, as if it 

had been a steady, unchanging sound. Leq is the 

constant sound level that, in a given situation and 

period (e.g., 1 hour, denoted by Leq(1), or 24 hours, 

denoted as Leq(24)), conveys the same sound energy as 

the actual time–varying sound. Statistical sound level 

descriptors such as L1, L10, L50, L90, and Lx are 

sometimes used to indicate noise levels that are 

exceeded 1, 10, 50, 90, and x percent of the time, 

respectively. The L10 descriptor is particularly 

appropriate for traffic noise because of its fluctuating 

nature. 

Noise Monitoring Stations 

An ambient or background noise monitoring program 

was conducted in 1994 to measure existing noise 

levels within the project area. Noise levels on Ellis 

Island and Liberty State Park were measured and 

recorded on two dates in July 1994. Three stations 

were selected on Ellis Island and two in Liberty State 

Park. The dates coincided with the traffic counting 

program in 1994 to represent typical conditions 

experienced during weekend day and weekday. 
ENVIRONMENTAL CONSEQUENCES

98 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

Noise monitoring stations were located on the 

western side of Ellis Island, the northwest corner of 

Ellis Island and the northern section of Ellis Island. 

The Liberty State Park locations were near the 

landing site of the existing temporary service bridge 

and at the CRRNJ parking lot. 

The noise meters at monitoring stations were 

programmed to measure random background noise 

and the following: 

Leq — equivalent sound level 

Max (L) — maximum sound level 

Min (L) — minimum sound level 

L10 — noise level that is exceeded 10% of the 

time 

L90 — noise level that is exceeded 90% of the 

time 

Impacts were assessed using the following criteria: 

Negligible — Noise increases over background by no 

more than 3 decibels in the short-term, and does not 

increase by detectable amounts in the long-term. 

Minor — Noise increases between 3 to 9 decibels in 

the short-term, and by no more than 3 decibels in the 

long-term. 

Moderate — Noise increases between 10 to 

15 decibels in the short-term (unmitigated), and by no 

more than 10 decibels in the long-term. 

Major — Noise increases by more than 15 decibels in 

the short-term and 10 decibels in the long-term. 

Impairment — Noise is so persistent or loud that 

visitor experience, wildlife, or other park resources or 

values are lost throughout the park for a long period 

of time or permanently. 

HAZARDOUS MATERIALS

Historic literature and the results of surveys for toxic 

substances were used to determine the presence and 

concentrations of hazardous materials in buildings, 

soils, and marine fill. 

Impacts were assessed using the following criteria: 

Negligible — No standards are violated or thresholds 

crossed in the short- or long-term; workers and 

visitors are fully protected from direct contact with 

contaminated substances; changes in water quality 

are at the limits of detection, even locally. 

Minor — No standards are violated or thresholds 

crossed in the short- or long-term; workers and 

visitors are fully protected from direct contact with 

contaminated substances; changes in water quality 

are slight, but detectable in the short-term or locally, 

or at the limits of detection in the long-term or 

regionally. 

Moderate — No standards are violated or thresholds 

crossed in the long-term, but short-term exceedances 

may occur; workers and visitors are usually fully 

protected from direct contact with contaminated 

substances, but occasional contact may occur; 

changes in water quality are readily detectable in the 

short-term or locally, or slight, but detectable in the 

long-term or regionally. 

Major — Standards may be violated or thresholds 

crossed on a sustained basis; workers and visitors 

make regular contact with contaminated substances; 

changes in water quality are readily detectable and 

severe in the short- or long-term, both locally and 

regionally. 

Impairment — Standards and thresholds are 

repeatedly violated and clean up cannot repair this; 

workers and visitors are unsafe from contact with 

contaminated substances when at the park; changes in 

water quality are severe and permanent. 

SOCIAL AND 

ECONOMIC ENVIRONMENT 

Tourism data were derived from the New York City 

Convention and Visitors Bureau. Historical visitor 

data, visitor projections, employment data and 

projections, and park administration information 

were obtained from NPS staff and documents. Land 

use information was based upon field visits during 

2001 and from secondary information. U.S. Census 

Data were used for analysis of regional population 

and economic data. An environmental justice review 

was conducted to determine if a disproportionate 

share of the proposed project’s socioeconomic 

impacts that could be considered significantly 

adverse are borne by low-income and minority 

communities. The review consisted of the 
Methodology for Analyzing Impacts

FINAL ENVIRONMENTAL IMPACT STATEMENT 99

identification of disadvantaged (low-income and/or 

minority) populations and the determination of 

whether any disadvantaged populations would be 

disproportionately impacted by the proposed project. 

As noted in the “Purpose of and Need for the Action” 

chapter, no disadvantaged populations would be 

disproportionately affected by any of the alternatives; 

therefore, this topic was dropped from further 

analysis. The following definitions were used to 

assess impact to tourism and park administration: 

Negligible — The impact is slight but detectable 

locally or in the short-term, or is at the lower levels 

of detection in the long-term or regionally. 

Minor — The impact is readily apparent locally or in 

the short-term, or slight but detectable in the longterm or regionally. 

Moderate — The impact is severe locally or in the 

short-term, or readily apparent regionally or in the 

long-term. 

Major — The impact is severe regionally or in the 

long-term. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 

TRANSPORTATION AND CIRCULATION 

Existing “level of service” data were compared to 

projections of anticipated future volumes for 

evaluation of traffic and transportation impacts on 

local roadways and parking facilities. 

The following definitions were used to assess the 

degree of impact: 

Negligible — Access to Ellis Island for visitors and 

staff remains uninterrupted, or experiences shortterm, barely detectable changes, and/or no long-term 

changes. Changes in demand for parking as a result 

of this project are at the lower limits of detection, 

usually a 1% increase or less. Level of service stays 

within its existing category, and changes are barely 

detectable. 

Minor — Access to Ellis Island for visitors and staff 

experiences slight but detectable changes in the shortterm, and/or barely detectable in the long-term. 

Changes in demand for parking as a result of this 

project are slight, but detectable, usually a 1%–9% 

change. Level of service stays within its existing 

category, and changes within the category are slight 

but detectable. 

Moderate — Access to Ellis Island for visitors and 

staff experiences readily detectable changes in the 

short-term, and/or slight, but detectable changes in 

the long-term. Changes in demand for parking as a 

result of this project are readily detectable, usually a 

10%–15% change. Level of service changes one 

category 

Major — Access to Ellis Island for visitors and staff 

experiences large-scale changes in the short-term, 

and/or readily detectable changes in the long-term. 

Changes in demand for parking as a result of this 

project are severe, and decrease by more than 15%. 

Level of service moves from under capacity to at or 

over capacity. 

Impairment — Because no intersections exist on Ellis 

Island, impairment of park resources is not possible 

under this impact topic. 

VISITOR EXPERIENCE 

The following definitions were used to assess degree 

of impact: 

Negligible — The impact is slight but detectable 

locally or in the short-term, or is at the lower levels 

of detection in the long-term or regionally. 

Minor — The impact is readily apparent locally or in 

the short-term, or slight but detectable in the longterm or regionally. 

Moderate — The impact is severe or exceptionally 

beneficial locally or in the short-term, or readily 

apparent regionally or in the long-term. 

Major — The impact is severe or exceptionally 

beneficial regionally or in the long-term. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 
ENVIRONMENTAL CONSEQUENCES

100 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

ELLIS ISLAND INFRASTRUCTURE 

SITE UTILITIES

The general standards by which utility size and 

service are evaluated in the United States are 

established by Building Officials Code 

Administrators (BOCA), International. Local 

authorities typically refer to BOCA for enforcement 

of building and construction codes. The following 

threshold definitions were used in this analysis: 

Negligible — The impact is at the lower limits of 

detection. 

Minor — The impact is slight but detectable. 

Moderate — The impact is readily apparent. 

Major — The impact is severe or highly beneficial. 

Impairment — The impact is so sustained and severe 

that the integrity of the resource will be lost 

parkwide, and the resource is either important to park 

purposes or is one whose protection has been spelled 

out as a reason for creating the park. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 101

REGULATIONS AND POLICIES

This section provides a description of the laws, 

regulations, and policies related to each impact topic. 

CULTURAL RESOURCES 

The National Park Service is charged with protection 

and management of cultural resources in its custody. 

This is furthered through the implementation of NPS 

Director’s Order 28: Cultural Resources 

Management Guidelines (NPS 1998), the 2001 NPS 

Management Policies, and the 1995 Servicewide 

Programmatic Agreement with the Advisory Council 

on Historic Preservation and the National Conference 

of State Historic Preservation Officers. The park also 

has a draft programmatic agreement (see appendix D) 

in progress with the New Jersey and New York State 

Historic Preservation Officers and the Advisory 

Council on Historic Preservation, specifically for work 

on Ellis Island structures and landscapes. These 

documents require NPS managers to avoid adversely 

impacting park resources and values, or to minimize 

impacts to the greatest degree practicable. 

Numerous laws also regulate the management of 

cultural resources on public lands, including the 

following: 

Antiquities Act of 1906 — authorized the president to 

establish historic landmarks and structures as 

monuments owned or controlled by the U.S. 

government and to institute a fine for unauthorized 

collection of their artifacts. 

The Secretary of the Interior’s Standards for the 

Treatment of Historic Properties — define the degree 

to which historic properties can be changed and 

retain their integrity. The standards and the 

accompanying guidelines allow for a contemporary 

use through alterations and additions if properties are 

rehabilitated, but such alterations and additions to be 

in accord with the standards should not radically 

change, obscure, or destroy character-defining 

features and spatial relationships of buildings or a 

cultural landscape. 

National Historic Preservation Act of 1966 — this 

act, as amended, and the regulations of the Advisory 

Council on Historic Preservation (36 CFR 800), 

typically represent the principal pieces of 

management legislation for cultural resources 

associated with NPS projects. Section 106 of the 

National Historic Preservation Act requires all 

federal agencies to consider the effects of their 

actions on cultural resources determined eligible for 

inclusion in the National Register of Historic Places 

(National Register), and take actions to minimize 

harm to them. An action is considered to have an 

effect if it alters a National Register-eligible 

resource's significant characteristics such as location, 

setting, or use. An adverse effect is one that 

diminishes the integrity of a resource, thereby 

jeopardizing its National Register eligibility/status 

(e.g., alteration of setting, physical damage/ 

destruction, neglect, sale, or lease without adequate 

protective restrictions). Section 110 of the act further 

requires federal land managers to establish programs 

in consultation with the state historic preservation 

office to identify, evaluate, and nominate properties 

to the National Register. This act applies to all 

federal undertakings or projects requiring federal 

funds or permits. 

National Parks and Recreation Act of 1978 (The 

Redwoods Act) — requires that general management 

plans be developed for each unit in the national park 

system, and that the plans include, among other 

things, measures for preserving the area’s resources 

and an indication of the types and intensities of 

development associated with public use of a given 

unit. 

Archeological Resources Protection Act of 1979 — 

further codifies the federal government’s efforts to 

protect and preserve archeological resources on 

public lands by stiffening criminal penalties, as well 

as instituting civil penalties, for the unauthorized 

collection of artifacts. Additionally, it establishes a 

permit system for the excavation and removal of 

artifacts from public lands, including their final 

disposition, as well as confidentiality provisions for 

sensitive site location information where the release 

of such information may endanger the resource. 

Native American Graves Protection and Repatriation 

Act of 1990 — sets forth procedures for determining 

the final disposition of any human remains, funerary 

objects, or objects of cultural patrimony that are 

discovered on public lands or during the course of a 

federal undertaking. 
ENVIRONMENTAL CONSEQUENCES

102 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

Curation of Federally Owned and Administered 

Archeological Collections — establishes guidelines 

and procedures for the proper curation and 

management of archeological collections owned or 

administered by federal agencies (36 CFR part 79). 

NATURAL RESOURCES 

GEOLOGIC RESOURCES, 

SOILS, AND MARINE SEDIMENTS

NPS Management Policies require that each park unit 

“will actively seek to understand and preserve soil 

resources of parks and to prevent, to the extent 

possible, the unnatural erosion, physical removal, or 

contamination of the soil, or its contamination of 

other resources.” 

FLOODPLAINS

NPS Management Policies (NPS 2001c), 

section 4.6.4, address management of and in 

floodplains. Parks are instructed to (1) manage for the 

preservation of floodplain values; (2) minimize 

potentially hazardous conditions associated with 

flooding; and (3) comply with the NPS Organic Act

and all other federal laws or executive orders related 

to the management of activities in flood-prone areas. 

In particular, parks are told to avoid direct and 

indirect support of development in floodplains if the 

development could adversely affect the functions of 

the floodplain or its natural resources, or increase 

flood risks. Executive Order 11988 requires parks to 

evaluate alternatives that would lessen or eliminate 

adverse effects of their actions on floodplains, and 

prepare a “statement of findings” presenting options 

for doing so. No adverse effects to floodplains are 

expected from any alternative in this environmental 

impact statement. 

VEGETATION / THREATENED 

AND ENDANGERED PLANT SPECIES

Biological resource management in the National Park 

Service has its roots in its founding legislation, the 

Organic Act of 1916, which directs parks to 

“conserve the scenery and the natural and historic 

objects and the wildlife therein to leave them 

unimpaired for the enjoyment of future generations.” 

These general powers were broadened by the 

Redwood National Park Act of 1978, in which 

Congress gave further direction that parks should not 

be managed in any way that might reduce values or 

purposes for which they have been established. 

Generally, NPS Management Policies state the parks 

“will maintain as parts of the natural ecosystems of 

parks all native plants and animals” (section 4.4.1). 

Parks are called upon to minimize human impacts on 

native plants and plant communities, and when 

actions require removal of native plants, to ensure 

that such removals will not cause unacceptable 

impacts to native resources, natural processes, or 

other park resources (section 4.4.2.1). 

NPS Management Policies also direct the National 

Park Service to inventory, monitor, and manage state 

and locally listed (e.g., protected under state acts 

similar to the federal Endangered Species Act) 

species and other native species that are of special 

management concern to the parks to maintain their 

natural distribution and abundance. Although the 

National Park Service must follow the mandates of 

the federal Endangered Species Act, no federally 

listed, candidate, or proposed species exist in the 

study area. 

FISH

The NPS Organic Act of 1916 directs parks to 

“conserve the scenery and the natural and historic 

objects and the wildlife therein to leave them 

unimpaired for the enjoyment of future generations.” 

These general powers were broadened by the 

Redwood National Park Act of 1978, in which 

Congress gave further direction that parks should not 

be managed in any way that might reduce values or 

purposes for which they have been established. In 

this context, biological resource management is 

designed to preserve or restore the natural behavior, 

genetic variability and diversity, and ecological 

integrity of fish populations. 

WILDLIFE / THREATENED 

AND ENDANGERED WILDLIFE SPECIES

As noted in the “Vegetation” and “Fish” sections, 

biological resource management in the National Park 

Service has its roots in the Organic Act of 1916, 

which directs parks to “conserve the scenery and the 

natural and historic objects and the wildlife therein to 

leave them unimpaired for the enjoyment of future 

generations.” This means parks cannot be managed in 
Regulations and Policies 

FINAL ENVIRONMENTAL IMPACT STATEMENT 103

any way that reduces values or purposes for which 

they have been established. In this context, biological 

resource management is designed to preserve or 

restore the natural behavior, genetic variability and 

diversity, and ecological integrity of wildlife 

populations. Parks are also directed to protect and 

perpetuate native wildlife as part of the park’s natural 

ecosystem. Natural processes are relied on to control 

populations of native species to the greatest extent 

possible. 

NPS Management Policies also direct the National 

Park Service to inventory, monitor, and manage state 

and locally listed (e.g., protected under state acts 

similar to the federal Endangered Species Act) 

species and other native species that are of special 

management concern to the parks to maintain their 

natural distribution and abundance. Although the 

National Park Service must follow the mandates of 

the federal Endangered Species Act, no federally 

listed, candidate, or proposed species exist in the 

study area. 

WATER RESOURCES

NPS Management Policies (2001c, section 4.6) have 

water protection policies. In section 4.6.3, the 

policies state “The Service will determine the quality 

of park surface and groundwater resources and avoid, 

wherever possible, the pollution of park waters by 

human activities occurring within and outside of 

parks.” 

A primary means for protecting water quality is the 

Clean Water Act that provides for the establishment, 

implementation, and enforcement of water quality 

standards. Generally, the federal government has 

delegated the development of standards to the 

individual states subject to EPA approval. In 

addition, the New Jersey Department of Environment 

Protection and New York State Department of 

Environmental Conservation have standards for 

different classes of surface water. 

AIR QUALITY

The Environmental Protection Agency has set air 

quality standards for six principal “criteria” 

pollutants, including carbon monoxide, ozone, and 

two types of particulates (those smaller than 

10 microns and those smaller than 2.5 microns). 

NPS management of air quality is primarily to 

monitor and mitigate impacts to visibility in larger 

parks considered to be class I areas by the Clean Air 

Act. Beyond this, parks are instructed to comply with 

all federal and state air quality standards. 

NOISE

The Federal Highway Administration (FHWA) 

guidelines for noise abatement criteria are widely 

used for the discussion and evaluation of noise levels. 

The guidelines provide different standards based on 

land use. In general, when noise levels from a project 

approach or exceed the noise abatement criteria or 

when they exceed existing noise levels by more than 

10 decibels (dBA), abatement measures would be 

considered. 

The New Jersey Department of Transportation 

(NJDOT) uses FHWA-derived standards in noise 

control and abatement for highway projects. If noise 

levels from a particular project are within 3 dBA of 

the FHWA standards, or if the increase is 10 dBA or 

more, then noise abatement may be required. Noise 

abatement is not automatically required if one of 

these conditions is met. The need for abatement is 

determined on a case-by-case basis. For noise 

abatement measures, the goal of noise reduction is 

10 dBA. 

NPS Management Policies (2001c) also require parks 

to “preserve, to the greatest extent possible, the 

natural soundscapes.” These are soundscapes that 

exist in the absence of human-caused sound. 

HAZARDOUS MATERIALS

NPS Management Policies address hazardous 

materials in the biological, soils, and water quality 

management sections, but also add that the National 

Park Service will strive to prevent the release of 

human-generated chemicals that can block the 

release, deposition, or perception of natural 

chemicals. 

Standards for exposure to lead-based paint and 

asbestos, for contact with contaminated soil or 

groundwater, and for surface or groundwater 

pollution are promulgated by the Occupational, 

Safety, and Health Administration; Environmental 

Protection Agency; and state environmental 

protection agencies. 
ENVIRONMENTAL CONSEQUENCES

104 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

SOCIAL AND 

ECONOMIC ENVIRONMENT 

The only policy guidance outside of that contained in 

regulations for the National Environmental Policy 

Act for socioeconomics is supplied by a 1994 

executive order (EO 12898) requiring all federal 

agencies to analyze and consider impacts of actions 

on minority and low-income populations and 

communities to make sure they are not adversely and 

disproportionately affected. 

TRANSPORTATION AND CIRCULATION 

Policies concerning transportation systems exist in 

the NPS Management Policies; however, they 

primarily pertain to the building of new roads. The 

National Park Service does encourage visitors to use 

a mix of public transportation, including buses, 

trains, and ferries. 

VISITOR EXPERIENCE 

The NPS Management Policies and Organic Act

indicate that enjoyment of park resources and values 

by the people of the United States is “part of the 

fundamental purpose of all parks” (section 8.2). The 

National Park Service is committed to “providing 

appropriate, high quality opportunities for visitors to 

enjoy the parks,” and promises to maintain within 

parks “an atmosphere that is open, inviting, and 

accessible to every segment of American society.” 

This section also identifies constraints on the kind of 

uses parks can allow. 

ELLIS ISLAND INFRASTRUCTURE 

The general standards by which utility size and 

service are evaluated in the United States are 

established by Building Officials Code 

Administrators (BOCA), International. Local 

authorities typically refer to BOCA for enforcement 

of building and construction codes. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 105

IMPACTS OF ALTERNATIVE 1: NO ACTION — 

CONTINUATION OF EXISTING MANAGEMENT DIRECTION

CULTURAL RESOURCES 

HISTORIC ARCHITECTURAL RESOURCES

With the exception of the potential for enhanced 

protection for archeological resources and the 

restoration of the historic setting of the island (bridge 

removal), the no-action alternative meets none of the 

cultural resource-related NPS objectives stated in the 

“Purpose of and Need for the Action” chapter for the 

future of Ellis Island. Of particular concern is the 

lack of long-term protection of historic structures that 

are listed on the National Register of Historic Places. 

Under this no-action alternative, improvements to 

historic structures would be limited to ongoing 

stabilization of Ellis Island structures over the next 

10 to 15 years, as well as the interior rehabilitation of 

the Ferry Building and the Hospital Outbuilding and 

Laundry. The exteriors of these buildings were 

previously restored. All stabilization and 

rehabilitation activities are being conducted 

according to The Secretary of the Interior's Standards 

for the Treatment of Historic Properties. 

The Ellis Island stabilization program is of limited 

historic preservation value, delaying for 15 to 

20 years, at best, the eventual point at which 

significant deterioration of historic structures would 

become apparent. It is not regarded as a viable or 

sustainable option for the National Park Service 

because, eventually, all structures on the island would 

reach a point of deterioration, which would preclude 

any further maintenance or restoration. As structures 

on Ellis Island reach a state of irreversible 

deterioration and are deemed unsafe, actions would 

be necessary to prevent injury to visitors and staff. 

Consideration would necessarily be given to 

demolition; however, demolition/removal activities 

are not included under the no-action alternative and 

would be addressed at a later time, should they be 

necessary. 

Stabilization activities are considered a short-term, 

localized, minor benefit to the cultural resources of 

Ellis Island. These benefits, however, are of limited 

usefulness in the long-term preservation of the 

National Register resources of Ellis Island. When 

compared with alternatives 2 and 3, which propose 

rehabilitation of all historic structures, the no-action 

alternative poses a significantly higher degree of risk 

to cultural resources on Ellis Island. 

The rehabilitation of the interiors of the Ferry 

Building and Hospital Outbuilding and Laundry is 

considered a moderate, site-specific benefit for the 

cultural resources of Ellis Island. However, when 

compared to rehabilitation of all historic structures 

under alternatives 2 and 3, the benefit provided under 

the no-action alternative is significantly less. 

Cumulative Impacts. Beyond the natural forces of 

time and weather, no additional impacts to the 

buildings on Ellis Island would occur. 

Conclusions. Rehabilitation of the interiors of the 

Ferry Building and Hospital Outbuilding and 

Laundry provides a moderate, site-specific benefit. 

However, in general, this alternative does not provide 

for a plan of historic preservation of the significant 

cultural resources of Ellis Island. Stabilization 

activities of historic structures proposed would result 

in only short-term benefits to the resources, and longterm preservation of cultural resources is not 

expected. The eventual loss of many, if not all, of the 

eligible properties on Ellis Island is possible. The 

predicted loss of such significant cultural resources is 

expected to result in impairment of NPS resources. 

When compared to the positive preservation benefits 

offered under alternatives 2 and 3, the no-action 

alternative is decidedly negative in its overall effect 

on historic properties, with long-term, major adverse 

impacts anticipated for the region and, possibly, for 

the nation. 

CULTURAL LANDSCAPE

Defining characteristics of the cultural landscape of 

Ellis Island have been identified as spatial 

organization, circulation, vegetation, and, to a lesser 

degree, small-scale features (see the “Affected 

Environment” chapter). Under the no-action 

alternative, maintenance of the Ellis Island landscape 

would not continue at the level required to maintain 

its historic integrity. 

For the immediate future, the spatial organization of 

the landscape (structures' relationships to one 

another) would remain essentially unaffected by the 
ENVIRONMENTAL CONSEQUENCES

106 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

no-action alternative. However, a lack of 

maintenance of the defined and characteristic spaces 

between historic structures would undoubtedly 

contribute to a loss of the campus setting. Delineation 

of open spaces would become less distinct with the 

overgrowth of invasive vegetation. In later years, the 

effects of the lack of maintenance of historic 

structures would also become apparent. The potential 

need to remove deteriorating structures would 

jeopardize the general spatial organization of the 

cultural landscape of Ellis Island. 

This alternative's lack of long-term maintenance and 

preservation strategies for circulation routes 

(sidewalks and covered corridors) on Ellis Island 

would result in the general deterioration of the 

enclosed corridor system and the existing pattern of 

sidewalks surrounding the recreation yard between 

Islands 2 and 3. Distinct vegetation patterns, as well 

as individual historic trees, currently contribute to the 

integrity of the cultural landscape of Ellis Island. 

Over time, the no-action alternative would likely 

result in significant detrimental effects to the 

characteristic vegetation due to a lack of 

maintenance. 

Many extant small-scale features, which currently 

exist within the landscape of Ellis Island, are in poor 

condition and in need of preservation. Under the noaction alternative, these features would continue to 

deteriorate, eventually beyond the point where 

reasonable preservation is practical. If extant features 

cannot be preserved in place, preservation of a 

particular item style or type, such as a historic light 

post, may be achieved by placing the item in 

curatorial storage. The loss of the integrity of the 

cultural landscape of Ellis Island due to neglect / lack 

of maintenance expected under the no-action 

alternative has the potential to result in a long-term, 

major, adverse impact to a National Register 

resource. The effect would be regional, if not 

national, in scope. The no-action alternative poses a 

higher degree of risk to the cultural landscape of Ellis 

Island than do alternatives 2 and 3, which propose 

landscape rehabilitation. 

The no-action alternative would also result in the 

short-term stabilization and eventual removal of the 

nonhistoric temporary service bridge. Stabilization 

actions would extend the bridge's service life 

approximately 10 years and, consequently, result in 

the postponement of restoration of the historic setting 

and views to and from Ellis Island. This nonhistoric 

feature, a situation that would continue with the delay 

of bridge removal, currently mars views from certain 

aspects of Ellis Island. A significant National 

Register characteristic of Ellis Island is its isolated 

historic setting, a primary reason for its selection as a 

site for an immigration station. Postponing the 

restoration of its original historic setting hinders the 

public's understanding of the island's isolated 

geographic position during the period of its greatest 

use (immigration period). Extension of the service 

life of the temporary bridge is considered a moderate, 

adverse impact to the cultural landscape of Ellis 

Island, albeit a temporary one. The impact is 

considered local to regional (harbor-wide) in nature. 

The eventual bridge removal proposed under the noaction alternative would result in a variety of positive 

effects on the cultural landscape of Ellis Island. 

Restoring the historic setting would promote greater 

understanding of the significant characteristics of 

Ellis Island, including its unique position in U.S. 

history, its association with the immigration period, 

and elements of the landscape design, all of which 

are impacted by the existing bridge. Removal of the 

temporary service bridge would also allow the 

restoration of the 1930s seawall and the existing 

roadway and parking areas on Ellis Island to an 

earlier, more sympathetic appearance when no 

vehicles existed on the island. 

Views of Ellis Island would also benefit from the 

removal of the nonhistoric bridge's visual obstruction 

by restoring the original historic setting of the island 

and the region (harbor area) (e.g., restoration of 

“waterspace” between Ellis Island and the mainland, 

reinforcing the sense of an island). Currently, visitors 

on Ellis Island cannot see the existing service bridge, 

as visitor space now exists on the east side of the 

island with the view toward the west blocked by 

existing historic buildings. However, views of Ellis 

Island from Liberty State Park and the CRRNJ 

Terminal would be enhanced by the restoration of the 

historic setting. 

The restoration of the historic setting of Ellis Island 

as a result of the proposed bridge removal is 

considered a major, long-term benefit to the cultural 

landscape of Ellis Island. The benefits are believed to 

be regional in scope due to the concomitant positive 

effects of the bridge's removal on nearby National 

Register properties located within Ellis Island's 

viewshed. The positive effect on the cultural 

landscape of Ellis Island as a result of eventual 

removal of the bridge is significantly greater under 

the no-action alternative than under alternatives 2 
Impacts of Alternative 1: No Action — Continuation of Existing Management Direction 

FINAL ENVIRONMENTAL IMPACT STATEMENT 107

and 3, which propose construction of a new 

permanent bridge. 

Removal of the bridge would also have the potential 

to negatively affect the cultural resources of Ellis 

Island as a result of increased fire response time. Ellis 

Island would be reliant on New York City fireboats 

based in Brooklyn. Best response times would be 

between 20 to 30 minutes but could be longer, 

depending on the location of the boat at the time of 

the emergency call. In addition, fireboats are likely to 

be less effective in combating a fire than land-based 

engine companies because their water cannons may 

not be able to reach fires in structures on all parts of 

the island. In addition, salt water used by the 

fireboats would have a more detrimental effect on 

historic structures than would fresh water used by 

land-based engines. The less efficient fire-fighting 

methods expected by the eventual removal of the 

bridge proposed under the no-action alternative have 

the potential to result in adverse impacts of unknown 

intensity to cultural resources on Ellis Island. 

Alternatives 2 and 3 provide a significantly lower 

risk of loss of historic resources by fire due to the 

bridge replacement proposals included in both. 

Cumulative Impacts. Time and the lack of an 

adequate long-term preservation plan for the cultural 

landscape of Ellis Island have had a combined impact 

on many of the features that make up the cultural 

landscape. The cumulative loss of National Register 

properties on Ellis Island over time under the noaction alternative is considered a major, long-term, 

adverse impact to cultural resources, with regional to 

national implications. 

Conclusions. The postponement of the removal of 

the temporary service bridge is considered a 

temporary, moderate, adverse impact. However, the 

no-action alternative would result in its eventual 

removal, a major benefit for the cultural landscape of 

Ellis Island and surrounding areas. This positive 

effect is not realized under alternatives 2 or 3, as both 

propose a permanent bridge replacement. 

Associated with eventual bridge removal, historic 

properties on Ellis Island would be placed at higher 

risk of fire damage/loss due to longer response times 

and less efficient methods of fire-fighting, a 

potentially major adverse impact not expected under 

alternatives 2 and 3. 

In contrast to alternatives 2 and 3, this alternative 

does not provide for a plan of historic preservation 

for the cultural landscape of Ellis Island, and the 

possibility of its eventual loss exists. When compared 

to alternatives 2 and 3, the no-action alternative is 

decidedly negative in its overall affect on the cultural 

landscape of Ellis Island, with major adverse impacts 

anticipated for the region and, possibly, for the 

nation. 

Of the three alternatives, the no-action alternative 

would result in the highest risk to the cultural 

landscape of Ellis Island. Due to the lack of a longterm preservation strategy under this alternative, the 

eventual loss of the cultural landscape is likely and 

would be expected to result in impairment of NPS 

resources. 

ARCHEOLOGICAL RESOURCES

Under this no-action alternative, no impacts to either 

terrestrial or marine archeological resources are 

anticipated. 

Cumulative Impacts. No cumulative impacts to 

archeological resources have been identified under 

the no-action alternative. 

Conclusions. The no-action alternative does not have 

the potential to adversely affect archeological 

resources in a manner that would jeopardize their 

National Register characteristics. When compared to 

alternatives 2 and 3, under which ground-disturbing 

activities are likely, the risk to archeological 

resources on Ellis Island is minimal under the noaction alternative. No impairment of park 

archeological resources would occur. 

NATURAL RESOURCES 

GEOLOGIC RESOURCES AND SOILS

New soil would be required to fill in where the 

existing bridge touches down on both Ellis Island and 

in Liberty State Park and to fill in the break in the 

seawall where the bridge intersects it. The impacts to 

soils from these activities would be negligible. 

The stabilization of the buildings on the south side 

(Islands 2 and 3) is anticipated to have no impact 

upon the project area’s geologic formations or 

existing soils. 
ENVIRONMENTAL CONSEQUENCES

108 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

Cumulative Impacts. As described in the “Affected 

Environment” chapter, dredge spoils and other 

materials have been used as fill to create soils in the 

area on which to build. Soils have also been graded, 

excavated, and removed throughout the region to 

accommodate building. Especially compared to these 

actions, the impact of soil placement required under 

the no-action alternative is not detectable. 

Conclusions. Negligible impacts to soils would result 

from filling the seawall following bridge removal. No 

impairment of park soils or geology would occur. 

MARINE SEDIMENTS

The existing temporary service bridge rests on piles 

driven into marine sediments. The removal of these 

piles would leave holes in the sediment in the channel 

between the island and the state park and cause the 

suspension of bottom sediments into the water 

column. In time, sediments would settle, and over 

several years, the holes left by the pilings would be 

filled with marine sediments. A silt curtain 

surrounding the area where bridge removal would 

take place could minimize increases in turbidity 

associated with suspending sediments. The degree of 

impact to sediments is likely to be negligible or 

minor and localized. 

Cumulative Impacts. Marine sediments have been 

dredged and used as fill in several locations 

throughout the region, as described in the “Affected 

Environment” chapter. 

Conclusions. Localized negligible or minor 

temporary impact to marine sediments in the channel 

between Ellis Island and the state park would occur 

from removing pilings. No marine sediments are part 

of the park; therefore, no impairment of park marine 

sediments is possible. 

FLOODPLAINS

All of Liberty State Park is low lying and subject to 

flooding, although some would only experience 

minimal inundation should a flood event occur. A 

3.6-foot-high seawall (upon which Liberty Walk 

rests) protects most of the park, except where the 

temporary bridge is cut into the seawall at ground 

level. Here, water from a 100-year or 500-year flood 

event could penetrate the seawall and inundate lowerlying parts of the state park immediately to the 

northwest. 

Dismantling the existing temporary service bridge 

and completing the seawall following removal of the 

landing would reduce the potential for flooding of 

susceptible areas of Liberty State Park behind Liberty 

Walk during flood conditions, a minor positive 

impact. 

Cumulative Impacts. Liberty State Park is also 

vulnerable to wave action from long fetches within 

the harbor. Removing the bridge touchdown point 

and sealing the seawall could offer additional 

protection from this type of flooding. 

Conclusions. Removing the temporary service bridge 

and sealing the seawall could result in minor 

beneficial impacts from flood prevention. No impacts 

to or impairment of park floodplains would occur. 

VEGETATION / THREATENED 

AND ENDANGERED PLANT SPECIES

Vegetation in the courtyards on the south side 

(Islands 2 and 3) would continue to grow 

undisturbed, although construction staging and other 

small-scale clearing or occupation of Ellis Island 

resulting from the ongoing stabilization efforts may 

result in the temporary removal of some weedy 

vegetation. This is likely only a short-term, negligible 

impact to vegetation on the island. Invasive plant 

species would continue to invade and dominate much 

of these small, untamed areas. 

Two of the three New Jersey state protected plant 

species (Canada hawkweed and the Ohio spiderwort) 

found on Ellis Island grow in open areas and 

unmaintained courtyards. However, the no-action 

alternative is unlikely to have any effect on 

individuals of these species. 

Removal of the temporary service bridge would 

require clearing vegetation for construction staging 

areas where materials and equipment could be stored. 

These areas would be reseeded or replanted with 

native vegetation or allowed to regrow naturally. 

Impacts to vegetation would be negligible or minor. 

Cumulative Impacts. Vegetation in the region has 

been significantly altered to allow for urban and 

suburban growth over the past century and more. 

Changes over the years to the original Ellis Island 
Impacts of Alternative 1: No Action — Continuation of Existing Management Direction 

FINAL ENVIRONMENTAL IMPACT STATEMENT 109

have likely resulted in the near or complete 

elimination of that 3-acre site of native vegetation. 

However, some of the native vegetation in the study 

area has been restored with the ongoing restoration of 

the nearly 1,200-acre Liberty State Park, which 

includes wetlands, early and successional old-field 

plant communities and wooded thickets. 

Conclusions. Negligible to minor impacts to 

vegetation from clearing for construction staging 

associated with stabilization efforts and removal of 

the temporary bridge are likely. No impacts to 

threatened or endangered vegetation are expected, 

and no impairment to park vegetation would take 

place. 

FISH

The use and importance of the aquatic habitat 

between Liberty State Park and Ellis Island as a 

nursery area varies by season, with the number and 

diversity of species highest in June through 

November (NPS 1995a). Juvenile striped bass are 

found in the shallows of the harbor in winter and 

early spring. 

Construction may require work in the channel to 

remove existing pilings and other materials, and may 

cause increases in erosion and suspension of marine 

sediments. This in turn would increase turbidity, as 

well as concentrations of some toxins such as organic 

pesticides and heavy metals. Aquatic invertebrates, 

fish, and wildlife that feed on marine organisms 

could experience an increased uptake of these toxins 

if they remain in the area during construction. It is 

possible that the presence of either organics or heavy 

metals could be biomagnified in the food chain, as 

both are stored rather than eliminated when exposure 

takes place. The degree to which this phenomenon 

would take place is unknown, but would not likely be 

more than negligible or minor (e.g., slight, but 

detectable in the long-term). 

If construction activities are timed to avoid periods 

when diversity is high or the channel is used as a 

nursery, direct impacts to adults or juveniles could be 

reduced. However, if this is not possible, impacts to 

striped bass and other fish, including anadromous 

species, using the channel between the park and Ellis 

Island could be severe for the period of time during 

removal of the temporary service bridge. Because 

this is a short-term, localized impact, the effect to 

fisheries overall from construction would be short 

term and moderate. Eventually, bottom habitat may 

also be restored, and long-term impacts are not likely 

to be more than negligible. 

Cumulative Impacts. Fish species in the harbor are 

subject to a number of other stressors, including 

pollutants, fishing, dredging, and natural forces such 

as predation and weather and current related impacts. 

Nursery habitat, which is usually shallow water with 

emergent vegetation, is also the same areas 

historically filled to extend land surfaces. The 

combination of these impacts has had negligible or 

minor impacts on some species and more severe 

impacts on others. 

Conclusions. Removal of the temporary service 

bridge could result in minor to moderate short-term 

impacts to fish in the immediate area of construction 

from direct activity, as well as increases in turbidity 

and the suspension of toxins. No impairment of park 

fisheries resources would occur. 

WILDLIFE / THREATENED 

AND ENDANGERED WILDLIFE SPECIES

Short-term disturbance or displacement of wildlife 

related to noise and the presence of humans and 

equipment would occur on both Ellis Island and at 

Liberty State Park. Ellis Island provides minimal 

habitat for terrestrial wildlife. There are very few 

natural areas to provide shelter and food. Even so, 

during construction activities associated with removal 

of the temporary service bridge and stabilization of 

buildings on Ellis Island, birds and other wildlife 

could be disturbed and displaced. Because these 

impacts are temporary, the effect would be negligible 

or minor overall. 

Birds using the shore environment of the state park or 

the near-shore marine environment would be unlikely 

to remain in the area during removal of the temporary 

bridge. Depending on the species in the area, the 

displacement could be temporary or long-term, as 

some individuals and some species are more 

susceptible to noise and the presence of humans than 

others. At noise levels associated with the removal of 

bridge piles (76 to 101 decibels at a distance of 

between 50 and 800 feet), wildlife would not be able 

to habituate. At levels of 30 to 70 decibels, most 

species of wildlife would continue to avoid the noise 

or suffer secondary effects such as impacts to their 

ability to communicate (Bowles 1995). 
ENVIRONMENTAL CONSEQUENCES

110 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

The protected species most likely to be adversely 

affected by bridge removal is the state threatened 

Savannah sparrow, as it is a year-round resident of 

the state park. This species nests in open fields and 

thickets in the project area very near to where 

construction is likely to take place. Because the 

impact would be temporary, the effect on Savannah 

sparrows would be no more than a minor one. 

Other seasonal residents in the state park include the 

northern harrier, peregrine falcon, great blue heron, 

short-eared owl, and long-eared owl. The northern 

harrier hawk, a New Jersey state endangered 

(breeding population) species, utilizes undisturbed 

fields and shoreline for feeding in both summer and 

winter. Long-eared and short-eared owls are also 

winter residents of the park, and peregrine falcons are 

summer residents. If construction occurs during the 

time they are present in the park, these species could 

suffer negligible or minor impacts. 

Several bird species also migrate through Liberty 

State Park in the spring or fall, including several 

which are state listed (see the “Affected 

Environment” chapter). It is likely that fewer 

individuals of these species would use the park 

during the construction period as a migratory stop. 

However, because these species utilize a very large 

area, usually covering several hundred or thousand 

miles, the loss of habitat during the construction 

period at Liberty State Park is likely to be no more 

than a negligible or minor impact. 

Cumulative Impacts. Development and alteration of 

natural areas in the vicinity over the past century (and 

more) have eliminated habitat for bird species and 

other wildlife native to the region. In addition, the 

presence of human activity and noise has displaced 

sensitive individuals of many species. Liberty State 

Park is one of very few natural areas where wildlife 

can exist. Improvements to the park would increase 

the amount of open space available to birds and other 

wildlife, and could offset to some small degree the 

impact of noise and human activities associated with 

bridge removal. 

Conclusions. Minor impacts to nonprotected wildlife 

from construction are expected, particularly in 

Liberty State Park. Some protected species could be 

affected, Savannah sparrows could experience minor 

effects in the short-term, and other seasonal residents 

and migrants could experience negligible impacts. No 

impairment of park wildlife resources would occur. 

SURFACE WATER

Removal of footings, pilings, and abutments at the 

ends of the temporary bridge between Liberty State 

Park and Ellis Island could result in temporary, 

localized increases in turbidity in the surface water in 

the immediate vicinity. Turbidity could increase 

substantially for the construction period, but would 

return to current levels relatively quickly following 

the cessation of bridge removal activities. Some 

additional slight increases in turbidity may result 

from stabilization of the buildings, as construction 

may eliminate vegetation and leave soils vulnerable 

to erosion. 

Heavy equipment used to remove the bridge, or in 

stabilization of the buildings on Ellis Island, could 

leak oil or fuels, resulting in small releases into the 

channel or immediate marine environment. Standard 

best management practices, such as berms, could 

reduce these impacts to negligible (e.g., 

nondetectable) levels. Because the bridge would no 

longer be available, there would be an increase in the 

number of boat trips to transport personnel, goods, 

and services for the National Park Service and its 

concessioners. Incidental releases of petroleum 

products and resulting negligible degradation of 

surface water might also occur from these boats. For 

the most part, these releases would be diluted 

sufficiently with harbor water that they would not be 

detectable. 

The removal of pilings in the marine environment 

could result in the release of trace metals or other 

pollutants bound to bottom sediments (see the 

“Hazardous Materials” section below for more 

information). 

Cumulative Impacts. Tourism is expected to 

increase under the no-action alternative by about 

1.4% per year. These visitors would access Ellis 

Island by ferry, with slight increases in the release of 

petroleum products into the water column. 

Conclusions. Removal of the temporary service 

bridge could result in minor to major localized 

increases in turbidity in surface marine water. Fuel 

leaks or petroleum releases from heavy equipment 

and ferries could result in negligible degradation of 

surface water near construction sites or along ferry 

routes. No impairment of park surface water would 

occur. 
Impacts of Alternative 1: No Action — Continuation of Existing Management Direction 

FINAL ENVIRONMENTAL IMPACT STATEMENT 111

GROUNDWATER

The no-action alternative would have no impact upon 

groundwater; therefore, no impairment would occur. 

AIR QUALITY

A 1995 analysis (NPS 1995a) indicated the expected 

increases in emissions resulting from a combination 

of increased visitation, construction traffic to remove 

the temporary bridge, and decreases resulting from 

the removal of the bridge under an alternative similar 

to no-action would result in total combined one-hour 

maximum carbon monoxide emission of 7.7 mg/kg 

(7.7 parts per million, or ppm), and an 8-hour 

maximum of 5.4 ppm. These are both well under the 

federal standards of 35 ppm (1-hour) and 9 ppm (8-

hour). By comparison, emissions at more urban 

nearby sites (Kennedy Blvd. in Jersey City) ranged 

from 5.6 to 7.3 ppm as the 8-hour maximum and 7.4 

to 11.6 ppm as the 1-hour maximum emissions in the 

years between 1989 and 1993. Changes in air quality 

related to the project would not be detectable given 

this range of existing conditions, or would only be 

detectable in the immediate area of construction. 

Currently, about 50 NPS personnel and 40 

concessioner staff use the temporary bridge to 

commute to work on Ellis Island. The bridge also 

provides access for over 800 trips each year for the 

delivery of supplies and removal of wastes from the 

island, as well as for construction contractors and 

maintenance work. Removal of the bridge would 

eliminate car and truck traffic on the bridge itself, but 

would increase the number of ferries. A 1995 

analysis (1995a) indicated the number of vehicles 

would decrease by 3,400 per year. The increase in 

ferry or barge trips needed to supply goods for the 

park concessioner would be about 200 trips per year. 

In addition, delivery of supplies for normal NPS 

operation of the island would require about 100 trips 

per year. Compared to the current 1,800 ferry trips 

per year bringing supplies to Ellis Island (NPS 

1995a), this is an 11% increase. Despite this 

moderate increase in ferry traffic, air quality in the 

vicinity of Ellis Island and Liberty State Park would 

likely experience a minor relative benefit from the 

elimination of bridge traffic, especially if a portion of 

the traffic is from trucks or heavy duty vehicles. 

Cumulative Impacts. Visitation is expected to 

increase on Ellis Island by about 1.4% per year. Since 

85% of visitors from New Jersey access the ferry 

terminal via private cars, parking and congestion at 

intersections, with resulting increases in pollutants, 

are likely. These cumulative impacts are added into 

the emission totals above. 

Conclusions. Compared to existing conditions, 

emissions related to this project would probably not 

be detectable any further than the immediate 

construction area. A minor benefit to air quality from 

the reduction in truck traffic is possible. No 

impairment of air quality would occur. 

NOISE

As noted above under “Wildlife,” noise levels during 

bridge removal could be as high as 100 decibels for 

short periods of time for workers or visitors close 

(within 50 feet) to heavy equipment. Construction 

barriers would be used to reduce noise levels so they 

remain below 90 dBA. However, this is still an 

increase of up to 75% over current noise conditions 

and a potentially severe, short-term effect, with 

impacts comparable to a chain saw at 3 feet or a 

railroad horn at 100 feet. These noise levels may 

exceed FHWA and Hudson County noise standards at 

certain times of day and on certain days. While 

workers would likely be protected from the effects of 

noise, visitors may not. However, it is unlikely that 

visitors would be exposed to such loud noise for 

more than a few minutes, perhaps as they board the 

ferry or walk along the shore of Liberty State Park. It 

is only through extended exposure to noise levels 

above 80–85 dBA that noise-induced hearing loss 

results. 

Cumulative Impacts. Noise levels from increased 

traffic and growth in the region, as well as increases 

in visitors to the state park and to the ferry terminal 

are expected to minimally increase noise levels in the 

area as well by 0.4 to 0.6 decibel (NPS 1995a). This 

is less than a 1% increase and a negligible impact. 

Conclusions. Long-term increases in noise are 

expected to be negligible; however, noise during 

construction may be severe on a short-term basis. No 

impairment of the park wildlife or visitor experience 

would occur as a result of noise. 

HAZARDOUS MATERIALS

The continuation of the current stabilization activities 

presents the potential for exposure to lead-based paint 
ENVIRONMENTAL CONSEQUENCES

112 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

and asbestos-containing materials in the existing 

buildings on Ellis Island. Workers would be required 

to take standard precautions when working in these 

areas to properly protect themselves and to contain 

and dispose of these materials so as to prevent 

airborne exposure to these materials. Impacts are, 

therefore, expected to be negligible. Because ongoing 

work only targets stabilization of the existing 

structures, paint that is not flaking would not be 

removed; therefore, this could present a future risk of 

exposure to lead-based paint. Because paint is not 

flaking, the risk to public or staff exposure is 

negligible. 

Bridge removal may dredge contaminated marine 

sediments and result in their suspension in the water 

column. The resuspension of this material could 

mean trace metals, polychlorinated biphenyls (PCBs), 

or polycyclic aromatic hydrocarbons (PAH), which 

can be carcinogenic, are present for some period of 

time in surface water. The primary impact from 

resuspension is likely to be to aquatic life (see the 

discussions above under “Fish”). However, they will 

likely settle to the bottom again in a short period of 

time and would not present a significant 

concentration when they are in the water column. 

Contaminated soils at Liberty State Park would not 

likely be disturbed by bridge removal. This is 

because soils in the vicinity of the bridge landings 

have been treated with the clean fill-cap method of 

encapsulating the historic fill with at least one foot of 

clean sand or soil. No exposure from this source is 

expected under no action. 

Cumulative Impacts. As described in the “Affected 

Environment” chapter, soils in parts of Liberty State 

Park, in particular the railroad freight yard, have been 

found to contain several contaminants, including 

organics, pesticides, and metals. Chromium has also 

been found in fill materials at sites near the state 

park. 

Conclusions. Resuspension of marine sediments 

during pile removal could result in negligible to 

minor increases in concentrations of toxic or 

carcinogenic chemicals in surface water. The impact 

would decrease when the sediments resettle. Possible 

impacts to workers from asbestos during removal 

would be reduced to negligible by following standard 

procedures. No impairment of park resources from 

exposure to hazardous materials would occur. 

SOCIAL AND 

ECONOMIC ENVIRONMENT 

TOURISM

Under this alternative, it is anticipated that the 

number of people visiting Ellis Island could reach 

2.396 million by 2005, even without the proposed 

additional Ellis Island attractions in alternatives 2 and 

3. Visitors would be attracted to the island by the 

same attractions and amenities as currently provided. 

The no-action alternative would have neither a 

beneficial nor adverse impact on Ellis Island tourism. 

PARK ADMINISTRATION

Under the no-action alternative, no additional 

employees would be required for administration and 

coordination of the south-side activities. 

No immediate changes to the administration of 

emergency services would occur under this 

alternative. However, after the temporary service 

bridge is removed, emergency services would be 

affected. In the absence of a bridge, Emergency 

Medical Technicians (EMT) would treat medical 

emergencies on site and then transport patients via 

the first available ferry to either New Jersey or New 

York, adding an additional 30 minutes to the current 

response time. 

Similarly, police and fire would have a significantly 

longer response time. Ellis Island would have to rely 

on New York City's fire boats based in Brooklyn. 

Response time from Brooklyn is approximately 20 to 

30 minutes, but it could be longer depending on the 

location of the fire boat when the emergency call is 

placed. When compared to the current response time 

of 3 to 4 minutes, the bridge removal proposed under 

the no-action alternative would result in significantly 

increased fire response times and, consequently, a 

higher risk to visitors, staff, and cultural resources. 

Under the no-action alternative, the impact on park 

administration regarding the provision of emergency 

services is considered adverse, and could be major in 

intensity depending on the event and need for such 

services. 
Impacts of Alternative 1: No Action — Continuation of Existing Management Direction 

FINAL ENVIRONMENTAL IMPACT STATEMENT 113

Cumulative Impacts. Tourism is anticipated to 

increase by 1.4% per year annually. This increase is 

not related to this project, but simply the anticipated 

increase in park visitorship regardless of 

improvements or the lack of them. 

Conclusions. Tourism at Ellis Island would likely 

continue to increase by a negligible to minor amount 

each year over the life of the plan. 

Park administration would experience a potentially 

major adverse impact in its ability to provide 

emergency services quickly once the temporary 

bridge is removed. No impairment of park resources 

would occur. 

TRANSPORTATION AND CIRCULATION 

ACCESS TO ELLIS ISLAND

Trucks and cars would be able to use the temporary 

service bridge for approximately 10 years if the noaction alternative were chosen in the NPS record of 

decision on this environmental impact statement. 

After this, Ellis Island would only be accessible by 

boat or barge. As noted above under “Air Quality,” 

the increase in ferry or barge trips needed to supply 

goods for the park concessioner would be about 

200 trips per year. In addition, delivery of supplies 

for normal NPS operation of the island would require 

about 100 trips per year. Compared to the current 

1,800 ferry trips per year bringing supplies to Ellis 

Island (NPS 1995a), this is an 11% increase and a 

minor to moderate impact. 

Removal of the existing bridge would open up the 

entire width of the channel between the island and the 

New Jersey shoreline to small marine craft. Because 

this is not an area used frequently by marine vessels, 

the impact of opening it up to increased use would be 

a negligible or minor one. 

The number of vehicles entering the state park to 

deliver goods and services to the island by way of the 

existing service bridge would decrease by about 

3,400 vehicles per year when the bridge is removed. 

However, some traffic from NPS staff traveling to the 

island, or from the delivery of goods to the ferry 

terminal for use on the island, is likely to continue. 

ACCESS TO FERRY TERMINALS

Access to Liberty State Park ferry terminal is not 

expected to change, although traffic on roads leading 

to the terminal or competing for parking may 

increase. 

PARKING

Visitation would continue to increase by 

approximately 1.4% annually. Assuming 85% of the 

visitors to the New Jersey ferry terminal continue to 

drive, an addition of approximately 40 cars may 

require parking in the vicinity of Liberty State Park 

by 2005. A 1995 analysis (NPS 1995a) indicated 

these cars could be accommodated by existing lots in 

the state park or nearby, and that only a negligible 

impact to parking would occur. 

CIRCULATION

Despite decreases in visitation related to the events of 

September 11, 2001, long-term trends indicate the 

number of people visiting Ellis Island and Liberty 

State Park would continue to increase by about 1%-

2% per year. Since 85% of visitors access the ferry 

terminal from New Jersey by private vehicle, it is 

likely that the number of vehicles attributable to 

visitation would also increase. 

Several intersections identified in the “Affected 

Environment” chapter (Audrey Zapp Drive and 

Phillip Drive in Liberty State Park, and Morris Pesin 

Drive / Bayview Avenue at Caven Point Road, and 

Bayview Avenue at the New Jersey Turnpike exit 

outside the state park) already have a level of service 

at or above capacity. Level of service at these 

intersections would likely continue to deteriorate 

with the increases in visitors. 

Cumulative Impacts. Area-wide growth and other 

projects in the study area are expected to also add 

traffic. 

Conclusions. In the long-term, minor to moderate 

increases in ferry traffic and decreases in car and 

truck traffic to Ellis Island could result under the noaction alternative. Negligible impacts to parking may 

occur at Liberty State Park. Increases in visitation to 

both Liberty State Park and Ellis Island could add to 

deterioration in traffic conditions at some 

intersections. No impairment of park resources or 
ENVIRONMENTAL CONSEQUENCES

114 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

values resulting from these increases in traffic would 

occur as a result of this alternative. 

VISITOR EXPERIENCE 

Under the no-action alternative, visitor access to Ellis 

Island would continue via ferryboat. Boats would 

continue to dock along the south side of the Main 

Building where visitors directly enter the Main 

Building, much as early immigrants did. Many 

visitors have stated that the ferry ride and associated 

views of the harbor were an important and 

memorable part of their visit to Ellis Island (see the 

“Affected Environment” chapter). 

Under this alternative, visitor flow and use patterns 

would remain substantially the same, with visitation 

focused on a number of existing interpretive displays 

and exhibits offered in the Immigration Museum. As 

a result of the limited public access to the majority of 

the historic structures on Ellis Island, the historic 

scene would remain diminished and demand abstract 

interpretation. The south side of the island would be 

experienced essentially through photographs and 

models in exhibits on the north side. Even during the 

period of stabilization, the buildings would be offlimits, and spatial relationships would not be 

experienced directly. It is possible that some 

interpretive exhibits and programs may be provided 

for visitors in the Ferry Building and the Hospital 

Outbuilding and Laundry. As long as it is deemed 

safe, limited tours of some of the exterior grounds 

may be provided to visitors. 

The possibility of improving access to other 

structures/areas on Ellis Island (Ferry Building and 

Hospital Outbuilding and Laundry) is considered a 

minor benefit to the visitor experience on Ellis Island. 

However, in more general terms, the continuing lack 

of access to the larger experience of Ellis Island's 

historic structures and landscape is considered a 

minor adverse impact to the visitor experience under 

the no-action alternative. When compared to the 

enhanced visitor access proposed under alternatives 2 

and 3, the no-action alternative would provide 

significantly fewer visitor opportunities and 

experiences. However, compared to existing 

conditions, some small benefit from rehabilitating the 

Ferry Building and Hospital Outbuilding and 

Laundry. Construction noise and dust associated with 

bridge removal and stabilization of buildings on Ellis 

Island would result in negligible to minor impacts to 

the visitor experience. 

Cumulative Impacts. The visitor experience at Ellis 

Island is not expected to vary significantly from what 

exists today under this alternative. Consequently, no 

cumulative impacts to visitor experience are expected 

under the no-action alternative. 

Conclusions. The no-action alternative would 

perpetuate significantly restricted public access to the 

majority of Ellis Island, which is considered a minor 

adverse impact to the visitor experience. In 

comparison to alternatives 2 and 3, under which most 

of Ellis Island would be opened to the public, the 

visitor experience under the no-action alternative is 

notably restricted and diminished.

ELLIS ISLAND INFRASTRUCTURE 

Under the no-action alternative, the existing utility 

services and systems would be adequate to maintain 

the existing active facilities. This alternative would 

have neither a beneficial nor adverse impact on 

utilities located on or around Ellis Island. Without 

action, the following deficiencies would continue to 

exist. First, Ellis Island’s stormwater system releases 

untreated stormwater into the Hudson River without 

the benefit of any detention basins or treatment. 

Second, existing fire hydrants on the south side and 

related underground piping require replacement. 

Third, it appears that the central chilled-water plant’s 

refrigerant monitoring system was not operational at 

the time of the site visit. Fourth, the original cooling 

towers and associated pumps, while operational, are 

in poor condition and would require upgrades in the 

near future, especially if demand increases on Ellis 

Island. In addition, regular, ongoing maintenance of 

these systems will be required. 

Cumulative Impacts. The existing utilities on Ellis 

Island are expected to function much as they do today 

under this alternative. No cumulative impacts to 

utilities are expected under the no-action alternative. 

Conclusions. Deficiencies in the utilities would 

continue to exist. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 115

SECTIONS REQUIRED UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

The National Environmental Policy Act requires 

agencies to consider irretrievable (short-term or 

reversible) and irreversible (long-term or 

permanent) commitments of resources from 

proposed actions. The stabilization of buildings and 

the temporary bridge under this alternative would 

be a short-term commitment of time and money 

over a period of a few years; no other commitment 

of resources would take place. Eventually, this lack 

of commitment of resources would mean the 

ultimate loss of many of the historic buildings on 

Ellis Island and the integrity of the cultural 

landscape (see the “Unavoidable Adverse Impacts” 

discussion below). 

LOSS IN LONG-TERM AVAILABILITY 

OR PRODUCTIVITY OF RESOURCES 

TO ACHIEVE SHORT-TERM GAIN 

This section is meant to address agency decisions 

that are made for short-term benefits at the cost of 

long-term gains or productivity. Although there are 

no actions that fall specifically into this category, 

the no-action alternative would include short-term 

stabilization of both the temporary bridge and some 

of the historic structures. Neither effort is expected 

to last much beyond 10 years. It is believed that 

stabilization will not be repeated, as it is ongoing 

now to stem emergency deterioration and to allow 

for proper long-term planning. 

UNAVOIDABLE ADVERSE IMPACTS 

Stabilization activities of historic structures proposed 

would result in only short-term benefits to the 

resources, and long-term preservation of cultural 

resources is not expected. The eventual loss of many, if 

not all, of the eligible properties on Ellis Island is 

possible. Although it may not happen in the 15- to 

20-year life of this plan, eventually the loss of such 

significant cultural resources is expected to result in 

impairment of NPS resources. The same is true for the 

cultural landscape. 

Associated with eventual bridge removal, historic 

properties on Ellis Island would be placed at higher 

risk of fire damage/loss due to longer response times 

and less efficient methods of fire-fighting, a potentially 

major adverse impact not expected under alternatives 2 

and 3. 

Small losses of soil are expected from grading for 

construction, and disturbance to marine sediments and 

associated increases in turbidity and impacts on aquatic 

life are expected during removal of the temporary 

service bridge. The sediments may temporarily suspend 

heavy metals, organics, or other toxins. Long-term 

increases in noise are expected to be negligible; 

however, noise during construction may be severe on a 

short-term basis and have adverse effects on visitors 

and wildlife. Removing the temporary bridge could 

increase emergency response by an order of magnitude, 

with possible major adverse impacts on the ability of 

the NPS staff to maintain safety. Minor adverse 

impacts to the visitor experience could result from the 

lack of access to the larger experience of the island’s 

historic structures and cultural landscapes, as well as 

from noise and dust associated with bridge removal 

and building stabilization activities. 
116 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

IMPACTS OF ALTERNATIVE 2: ELLIS ISLAND PARTNERS — DAY USE ONLY

CULTURAL RESOURCES 

HISTORIC ARCHITECTURAL RESOURCES

Under alternative 2, long-term preservation of all or 

most of the currently vacant historic structures on 

Ellis Island would occur through adaptive reuse for 

purposes complementary to the island's historic 

themes and related issues. Exterior treatments of 

historic structures would be conducted in accordance 

with The Secretary of the Interior's Standards for 

Rehabilitation. The general campus environment of 

Ellis Island would be preserved and its characterdefining features retained. Rehabilitation actions for 

Ellis Island's historic structures would focus on 

supporting new uses of the structures proposed under 

this alternative. 

Adaptive reuse would preserve the historic structures 

of Ellis Island as witness to one of the largest 

migrations in human history. Many of the cultural 

resources linked to Ellis Island would benefit from 

preserving the view among sites such as Castle 

Clinton, U.S. Custom House, Governors Island, 

Liberty State Park Interpretive Center, and the 

immigrant destinations themselves (CRRNJ Terminal 

and Lower Manhattan). 

Historic structures would undergo a variety of 

rehabilitation methods under alternative 2. For 

instance, some walls would be eliminated and 

restructured as small chambers in the former hospital 

buildings, and wards would be opened up. Large 

dormitory spaces in the former Baggage and 

Dormitory Building may be subdivided, and ceilings 

and soffits may be lowered. Traditional materials 

may be used, but many new materials, fixtures, and 

features could replace deteriorated and obsolete 

materials. Distinctive spaces and elements would be 

retained and incorporated into the mix. Interpretive 

materials and access would be afforded where today 

there are none. 

Proposed uses would undergo review for 

compatibility with scale and other distinctive 

characteristics of the property. This review would be 

aided by the Historic Structure Reports (Unrau 1981; 

Beyer et al. 1988) and this environmental impact 

statement. An updated inventory of resources would 

be compiled for the evaluation of impacts of 

proposals on specific historic structure. 

As proposed under this alternative, historic structure 

rehabilitation is considered a moderate long-term 

benefit, with regional and possibly national, 

implications. 

Cumulative Impacts. Rehabilitation of all Ellis 

Island structures listed on the National Register of 

Historic Places is proposed under alternative 2, 

ultimately providing for their preservation. These 

multi-year actions offer significant positive 

cumulative benefits to the historic structures of Ellis 

Island. 

Conclusions. The proposed rehabilitation and reuse 

of the National Register structures on Ellis Island 

would ensure the preservation of National Register 

cultural resource. The ultimate effect of alternative 2, 

the avoidance of the loss of Ellis Island's historic 

structures to unchecked deterioration (which is the 

expected result under the no-action alternative), 

would be a moderate, decidedly positive, long-term 

benefit to cultural resources. This positive effect 

would also be realized under alternative 3. 

CULTURAL LANDSCAPE

The National Park Service has identified the 

landscape of Ellis Island as important to the public's 

understanding of the purpose and significance of Ellis 

Island. Under alternative 2, the cultural landscape 

would be rehabilitated and interpreted to promote a 

broad understanding of its historic appearance and 

use. All exterior grounds would be included in these 

efforts. Important cultural landscape characteristics 

of Ellis Island have been identified as spatial 

organization, circulation, vegetation, and, to a lesser 

degree, small-scale features (see the “Affected 

Environment” chapter). 

Regarding spatial organization, alternative 2 would 

result in the preservation of existing open spaces on 

the island, such as individual courtyards between 

buildings, former recreation areas behind the new 

Immigration Building, former recreation areas around 

the Powerhouse on Island 1, and the expansive 

recreation yard between Islands 2 and 3. New 

buildings or the removal of existing historic 

structures, either of which could negatively affect the 

spatial organization of Ellis Island, are not proposed 

under this alternative. Installation or rehabilitation of 
Impacts of Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 117

above-ground utilities on Ellis Island has the 

potential to visually impact the cultural landscape. To 

ensure historic compatibility, consideration would be 

given to the design and location of such utilities to 

avoid negative visual impacts to the spatial 

organization of the historic landscape. 

Future development would not significantly alter the 

circulation system’s character or features. Care would 

be taken to preserve historic sidewalks and corridors 

in place if possible. Any new circulation features 

would be designed to complement the established 

geometric layout and would not encroach on the 

island’s remaining open space. It is especially 

important to maintain the existing pattern of 

sidewalks surrounding the recreation yard between 

Islands 2 and 3, because these walks have remained 

relatively unaltered since their initial installation. 

Established planting and vegetation patterns would 

be preserved and/or rehabilitated. Mature historic 

trees, including the Platanus acerifloia on Island 1, 

and other identified historic species on Islands 2 

and 3, are significant contributors to the island’s 

historic character. Consequently, steps would be 

taken during proposed development to protect and 

preserve these specimens. Replacement trees and 

shrubs would be of the same species to maintain 

consistency with the island’s historic planting palette. 

New species would not be introduced. 

To the greatest extent possible, extant small-scale 

features would be preserved. However, many of these 

features are in poor condition and preservation of 

individual items may not be feasible. If extant 

features cannot be preserved in place, preservation of 

a particular item style or type, such as a historic light 

post, may be achieved by placing the item in 

curatorial storage and installing a replacement feature 

in the landscape. To maintain cultural integrity, 

replacement features would be compatible, yet 

distinguishable, from historic features in style and 

scale. 

The rehabilitation and reuse of the cultural landscape 

proposed under alternative 2 would result in a 

moderate, site-specific benefit to cultural resources 

on Ellis Island. When compared to the no-action 

alternative, under which the cultural landscape would 

be significantly compromised over time, alternative 2 

is notably beneficial in its effects. 

Alternative 2 also proposes that the current temporary 

bridge linking Ellis Island and New Jersey be 

replaced with a permanent structure and security 

facility. Environmental review of design and location 

of the proposed bridge is not included in this 

environmental impact statement, but it is planned for 

the future. Final alignment and design would seek to 

mitigate environmental, visual, and traffic impacts on 

Ellis Island and at Liberty State Park. 

The proposed new permanent bridge would be used 

for operations, construction activities, maintenance, 

and deliveries, as well as for emergency vehicles and 

evacuation, much as is the case today. General 

vehicular and pedestrian access would not be 

permitted. The presence of a bridge could potentially 

bring pressure from special interests to allow 

expanded use of the bridge, such as for park staff, 

concession staff, and after-hours use. This could 

result in the need for additional parking on Ellis 

Island. The historic landscape of the landing site on 

Ellis Island would not be restored but would be 

rehabilitated to as compatible a manner as possible. 

Any new bridge alignment would require some 

disturbance of the 1930s seawall at the touchdown 

point on Ellis Island. 

Construction of a new bridge would perpetuate the 

existing link (temporary service bridge) between Ellis 

Island and New Jersey, affecting its state of isolation 

that was a key factor in the selection of the island 

first as the site of Fort Gibson and, later, as the Ellis 

Island Immigration Station. Views from the historic 

structures and the designed landscape on the island 

would continue to be obstructed by a bridge, 

reinforcing an artificial, nonhistoric link between the 

island and Liberty State Park. The views of Liberty 

State Park, Liberty Walk, and the CRRNJ Terminal 

from the west side of Ellis Island would continue to 

be interrupted, as would the sense of the island in 

views toward Ellis Island from the historic structures 

along the New York / New Jersey harbor region. A 

permanent bridge would maintain the nonhistoric 

visual intrusion for both the Statue of Liberty and the 

CRRNJ Terminal, which are the nearest National 

Register properties to Ellis Island and the proposed 

bridge. The historic uninterrupted views of the 

waterspace between Ellis Island and the mainland 

from these two properties would continue to be 

compromised. 

The construction of a new bridge proposed under 

alternative 2 is believed to have long-term, moderate 

adverse impacts to the cultural resources of Ellis 

Island and several surrounding National Register 

properties. The impacts are believed to be regional 
ENVIRONMENTAL CONSEQUENCES

118 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

(harbor-wide) in nature. While no measures could 

fully mitigate the adverse effects of a new bridge, a 

structure located along the shortest alignment, with a 

narrow width, low profile, and constructed of 

materials that blend with the landscape, would 

minimize the visual impact. The potential for adverse 

effects to cultural resources related to new bridge 

construction is significantly greater under 

alternative 2 when compared to the no-action 

alternative (eventual removal of the temporary bridge 

/ restoration of historic setting). 

From a positive perspective, construction of a 

permanent bridge would allow for the continued 

rapid vehicular access to the island by emergency 

vehicles, resulting in a potential benefit to the cultural 

resources of Ellis Island. Response time of the Jersey 

City Fire Department via the temporary bridge is 

currently 3 to 4 minutes, versus a minimum of 20 to 

30 minutes expected under no action. Land-based 

engines are typically more effective in fire fighting 

because they are able to reach all structures on the 

island, something fire boats cannot always 

accomplish. The continuation of efficient firefighting methods expected with the presence of a 

bridge (proposed under alternative 2), would result in 

a benefit of unknown intensity to the cultural 

resources of Ellis Island, a marked advantage over 

the no-action alternative. 

Cumulative Impacts. The rehabilitation of Ellis 

Island's cultural landscape proposed under alternative 

2 would ultimately ensure its historic preservation. 

This multi-year effort offers significant positive 

cumulative benefits to the cultural landscape of Ellis 

Island which, without such actions, would most likely 

deteriorate to the point of possible impairment. 

Conclusions. Cultural landscape rehabilitation efforts 

under alternative 2 would provide moderate, sitespecific benefits to cultural resources, as is the case 

under alternative 3. Comparatively, the no-action 

alternative proposes no such actions, posing much 

higher risks to the cultural resources of Ellis Island. 

The bridge proposed under alternative 2 would 

perpetuate the diminished nature of the waterspace 

between the island and the mainland, creating longterm moderate adverse impacts to Ellis Island and 

surrounding National Register properties (Statue of 

Liberty, CRRNJ Terminal). A similar loss of historic 

setting/context for Ellis Island is also expected under 

alternative 3, though not under the no-action 

alternative, which proposes bridge removal. At the 

same time, the presence of a bridge under 

alternative 2 would result in a benefit to the cultural 

resources of Ellis Island due to the high degree of 

protection from fire damage/loss. This is a positive 

effect also provided for under alternative 3, but not 

under the no-action alternative. 

ARCHEOLOGICAL RESOURCES

Alternatives 2 and 3 include proposals for the 

National Park Service to provide utility infrastructure 

improvements that would bring basic services to all 

unrestored buildings on Ellis Island. Utility 

improvements would include electricity, domestic 

water, sanitary and storm sewer, fire 

protection/suppression, communication/data systems, 

and centralized heating and cooling to all of the 

buildings. Many of these improvements have the 

potential to impact buried terrestrial archeological 

resources through earth disturbance/trenching 

activities. Most utility improvements will follow 

existing lines. 

Terrestrial Archeological Resources 

Archeological remains on Ellis Island have been 

documented by several researchers over the last 

20 years. It is believed that prehistoric use of the area 

spans from approximately 3,000 to 400 years ago. 

Detailed information about the prehistoric and 

historic use of the island is presented in the “Affected 

Environment” chapter. 

Archeological remains connected with the prehistory 

or history of the island could be encountered during 

excavations proposed on the north side of Ellis 

Island, done either for rehabilitation of some of the 

buildings or in support of the renovation of the south 

side. Although the entire south side of Ellis Island is 

constructed of landfill, the potential for the presence 

of archeological remains cannot be discounted in this 

area. The fill used to enlarge the island is not 

believed to be of archeological value, having been 

derived from deposits disconnected with the island. 

However, several features and deposits connected 

with the operation of the second immigration station 

may remain buried. For example, while conducting 

stabilization measures in 2000, work crews 

discovered broken concrete sidewalk slabs that 

revealed the presence of the island’s storm drainage 

system and several water collection features. It is 

possible that such features, as well as others related 

to the operation of the second immigration station on 

Ellis, may be encountered during the development of 
Impacts of Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 119

the buildings on the south side of the island. 

Prehistoric archeological sites connected with lower 

water levels that occurred several thousand years ago 

may also be buried below the fill deposits used to 

expand the island. 

While the known archeological sites on Ellis Island 

are mapped and documented, there remains the 

possibility of encountering undiscovered resources 

during utility-related excavation activities proposed 

under alternatives 2 and 3, which have the potential 

for impacting archeological resources more than 

alternative 1 (no action). Ground-disturbing 

construction activities, however, will be assessed on a 

case-by-case basis following established section 106 

procedures, as defined in the National Historic 

Preservation Act. By following section 106 

procedures and conducting the necessary research 

and consultation, impact to the archeological 

resources should be minimal. 

Marine Archeological Resources 

A number of marine archeological resources have 

been documented within the waters surrounding Ellis 

Island (see the “Affected Environment” chapter). One 

of the most notable is the Ellis Island ferry (1904) 

that sunk in the Ellis Island ferry slip in 1968 and 

where it remains today. In addition, remote sensing 

activities around the island have revealed numerous 

magnetic anomalies, some of which could be cultural 

resources. Increased boat traffic for the south side 

and/or additional dredging in the ferry slip could 

possibly affect the remains of the sunken ferry. In 

addition, placing piles for a permanent bridge might 

affect marine archeological resources, although 

placing them in such a way as to avoid magnetic 

anomalies that may be discovered during surveys 

would prevent impacts from becoming more than 

minor. 

Cumulative Impacts. Alternative 2 is not expected 

to result in cumulative impacts to archeological 

resources in or associated with Ellis Island. 

Conclusions. Utility-related excavation activities 

have the potential for minor impacts to terrestrial 

archeological resources. Dredging and placing bridge 

piles proposed under alternative 2 have the potential 

to result in minor, site-specific adverse impacts on 

marine archeological resources. Similar adverse 

impacts are possible under alternative 3. No 

impairment of park resources would occur. 

NATURAL RESOURCES 

GEOLOGIC RESOURCES AND SOILS

New soil would be required to fill in where the 

existing bridge touches down on both Ellis Island and 

in Liberty State Park, and to fill in the break in the 

seawall at the point where it intersects with the 

bridge. As with no action, the impact to soils from 

this activity would be negligible. 

Soil would be removed to grade access roads and 

facilities associated with the new bridge. Depending 

on the bridge alignment, and the ability to use the 

existing dirt road, the impact would be negligible to 

minor. 

Creating staging areas and operating machinery 

during construction of the bridge and rehabilitation of 

the buildings on the south side could increase soil 

loss through erosion at both Ellis Island and Liberty 

State Park. To mitigate construction-related impacts, 

best management practices, including soil erosion 

control measures (such as sediment fences, berms, 

and hay bales) would be employed. If these 

mechanisms are effective, soil loss would be 

negligible; without them, they could be minor in the 

short-term. Re-seeding the areas following the 

completion of construction would reduce the impact 

in the long-term to undetectable or negligible levels. 

Additional soils may be disturbed during installation 

of new underground utility connections for the 

renovated buildings on the south side. Following 

excavation, exposed soil would be covered with 

uncontaminated soil and vegetation or a hardened 

surface such as pavement. In the long-term, impacts 

would be negligible. 

Cumulative Impacts. No additional cumulative 

impacts beyond those described under the no-action 

alternative are anticipated. 

Conclusions. Negligible to minor impacts to soils 

would result from filling the seawall after removing 

the temporary bridge, excavating for new 

underground utility connections, grading a new 

access road to the landing at Liberty State Park, and 

from grading for construction staging areas. No 

impairment of park soils or geology would occur. 
ENVIRONMENTAL CONSEQUENCES

120 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

MARINE SEDIMENTS

The existing temporary service bridge rests on piles 

driven into marine sediments. The removal of these 

piles would leave holes in the sediment in the channel 

between the island and the state park and cause the 

suspension of bottom sediments into the water 

column. In time, sediments would settle, and over 

several years, the holes left by the pilings would be 

filled with marine sediments. New pilings for a 

permanent bridge would probably be driven into 

different locations, depending on alignment. This 

would disturb additional marine sediments compared 

to no-action. To mitigate impacts, piles for the new 

bridge would be placed by pre-drilling, and pile caps 

would be installed above the sediments and mean 

low-water mark. Both measures are expected to 

reduce sediment disturbance. 

A silt curtain surrounding the area where removal of 

the temporary bridge, and later where construction of 

the permanent bridge would take place, could 

minimize increases in turbidity associated with 

suspended sediments. The degree of impact to 

sediments is likely to be negligible or minor and 

localized, but more severe than no action. 

Cumulative Impacts. No additional impacts to 

marine sediments beyond those described under the 

no-action alternative are anticipated. 

Conclusions. Localized negligible or minor 

temporary impacts (which would be greater than 

under no action) to marine sediments in the channel 

between Ellis Island and the state park would occur 

from removing pilings for the temporary bridge and 

installing new pilings for the permanent bridge. 

Mitigation, such as silt curtains, would reduce 

impacts to marine sediments. No marine sediments 

are part of the park; therefore, no impairment of park 

marine sediments is possible. 

FLOODPLAINS

All of Liberty State Park is low lying and subject to 

flooding, although some would only experience 

minimal inundation should a flood even occur. A 

3.6-foot-high seawall (upon which Liberty Walk 

rests) protects most of the park, except where the 

temporary bridge is cut into the seawall at ground 

level. At this location, water from a 100-year or 

500-year flood event could penetrate the seawall and 

inundate lower-lying parts of the state park 

immediately to the northwest. As with no action, 

dismantling the existing temporary bridge and sealing 

the floodwall is planned, and such actions would 

eliminate the existing likelihood of damage during an 

extreme weather event and could have a minor 

benefit on the impact of flooding. 

The replacement bridge would touch down on Ellis 

Island and Liberty State Park within the 100-year 

flood level, which is at about 3 feet above mean sea 

level. Depending on design, the bridge itself would 

likely be above both the 100- and 500-year 

floodplains. It is possible that the entry point for 

vehicles onto the bridge would experience some 

flooding during an extreme flood event. Since these 

would occur infrequently, the impact of flooding 

would be negligible or minor. 

Cumulative Impacts. No additional cumulative 

impacts beyond those under the no-action alternative 

are expected. 

Conclusions. As under no action, removing the 

temporary bridge and sealing the seawall could result 

in minor beneficial impacts from flood prevention. 

Building a permanent bridge could mean negligible 

impacts to access during extreme flood events. No 

impairment of park floodplains would occur. 

VEGETATION / THREATENED

AND ENDANGERED PLANT SPECIES

A small area would be required for landings at 

Liberty State Park and on Ellis Island for a permanent 

bridge, resulting in the loss of about 0.1 acre of 

vegetation. In addition, access roads to and from the 

bridge could be required, resulting in additional 

permanent loss of vegetation. If the existing dirt 

access road is usable, and only a small spur to the 

state park landing is needed, this loss would be of a 

negligible amount of vegetation. If an entirely new 

road is required, the impact could be minor. 

Removing the temporary service bridge and installing 

the permanent bridge could result in the temporary 

clearing of staging and construction areas on both 

Ellis Island and in Liberty State Park. The impacts to 

vegetation in both places are anticipated to be 

temporary and would be mitigated through 

appropriate replanting and reseeding of impacted 

areas. Because of this, and because impacts are likely 

to take place in open field communities that do not 

have unique habitat or other value, impacts to 
Impacts of Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 121

vegetation from construction activities would be 

negligible or minor. 

Landscaping the courtyards and other areas on the 

south side and maintaining these gardens would help 

control invasive species, but would also result in the 

removal or relocation of some individuals of either 

the Canada hawkweed or Ohio spiderwort, New 

Jersey State protected plant species. 

The Canada hawkweed is typically found in a variety 

of habitats including woods, beaches, and fields, 

especially in sandy soils from Newfoundland to New 

Jersey and west to Illinois and British Columbia. The 

Ohio spiderwort is typically found in meadows and 

thickets from Massachusetts to Minnesota, and south 

to Florida and Texas. Both grow in the abandoned 

courtyards on Ellis Island. Many or all of these 

courtyards would be changed in some way as a result 

of this alternative—either they would be repaired or 

they would be planted with ornamentals to reflect the 

cultural landscape at the time the island was used to 

receive and process immigrants. These actions would 

eliminate many of the individual plants or patches of 

plants growing now. It is possible that the park would 

replant individuals to locations where changes would 

not take place, or improve growing conditions for 

hawkweed or spiderwort in an off-island location as 

mitigation. If so, impacts would be offset, and either 

no or negligible adverse impacts to these two species 

would result. If the park is unable to mitigate the 

impact, the loss of these individuals or patches on 

Ellis Island would be more serious, and could range 

from locally minor to moderate. Because the area of 

the courtyards slated for planting is approximately 

3 acres, and these plant species grow over several 

states, the impact would not be a major one, and no 

impairment of park resources is expected. 

Cumulative Impacts. No additional cumulative 

impacts beyond those described under the no-action 

alternative are expected. 

Conclusions. Negligible to minor losses of open field 

vegetation would be likely from the creation of 

landing sites and access roads and from construction 

staging areas for removing the temporary bridge, 

building a permanent bridge, and rehabilitating 

buildings on Ellis Island. Minor to moderate 

localized impacts from the loss of two state protected 

plant species, Canada hawkweed and Ohio 

spiderwort, are possible from the planting of restored 

courtyards on Ellis Island. These impacts could be 

eliminated or reduced to negligible through 

avoidance or by replanting individuals or improving 

off-site habitat. 

FISH

Removing the temporary bridge and installing a 

permanent bridge are likely to have short-term minor 

to moderate localized direct impacts on fish and fish 

habitat in the channel between Ellis Island and New 

Jersey. Some in-water activities would be required, 

including removal and replacement of the existing 

bridge superstructure, piles, and pile caps. The work 

would likely be completed by pulling the piles, or 

cutting them at the mud line, with the assistance of a 

barge-mounted crane. These activities would displace 

fish in the channel and alter channel bottom habitat. 

Construction would require work in the channel to 

remove existing pilings and other materials. This, in 

turn, would increase turbidity, as well as 

concentrations of some toxins such as organic 

pesticides and heavy metals. Aquatic invertebrates, 

fish, and wildlife that feed on marine organisms 

could experience an increased uptake of these toxins 

if they remain in the area during construction. It is 

possible that the presence of either organics or heavy 

metals could be biomagnified in the food chain, as 

both are stored rather than eliminated when exposure 

takes place. The degree to which this phenomenon 

would take place is unknown, but it would not likely 

be more than negligible or minor (e.g., slight, but 

detectable in the long-term). 

Additional turbidity resulting from soil erosion 

during construction on either Ellis Island or in 

Liberty State Park would be controlled through the 

use of mitigation measures such as silt fences and hay 

bales. Silt curtains would be used within the bay to 

contain suspended marine sediments in a defined 

area. 

The use and importance of the aquatic habitat 

between Liberty State Park and Ellis Island as a 

nursery area varies by season, with the number and 

diversity of species highest in June through 

November (NPS 1995a). Juvenile striped bass are 

found in the shallows of the harbor in winter and 

early spring. If construction activities are timed to 

avoid these periods, direct impacts to adults or 

juveniles could be reduced. However, if this is not 

possible, impacts to striped bass and other fish, 

including anadromous species, using the channel 

between the park and Ellis Island could be severe for 

the period of time during temporary bridge removal 
ENVIRONMENTAL CONSEQUENCES

122 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

and the building of a permanent bridge. Because this 

is a short-term, localized impact, the effect to 

fisheries, overall, would be moderate. Compared to 

the no-action alternative, the period of increased 

activity in the channel and increased turbidity would 

be longer. The degree of impact would likely 

decrease as sediments settle and turbidity decreases 

following the completion of all construction 

activities. Eventually, bottom habitat may also be 

restored, and long-term impacts are not likely to be 

more than negligible. 

A 1995 study (NPS 1995a) indicated the endangered 

shortnose sturgeon in the Hudson River and estuary 

of New York Harbor is not likely to be affected by 

bridge removal or construction, as its habitat is 

upstream of the project area. In addition, the channel 

between Ellis Island and New Jersey is too shallow to 

represent future habitat for this species. 

Cumulative Impacts. No additional cumulative 

impacts beyond those under the no-action alternative 

are expected. 

Conclusions. Removal of the temporary bridge and 

construction of a permanent one could result in 

moderate short-term impacts to fish in the channel 

between Ellis Island and the New Jersey shoreline, 

with a longer period of impact than under no action. 

No impairment of park fisheries resources would 

occur. 

WILDLIFE / THREATENED 

AND ENDANGERED WILDLIFE SPECIES

Short-term disturbance or displacement of wildlife 

related to noise and the presence of humans and 

equipment would occur on both Ellis Island and at 

Liberty State Park. Birds using the shore environment 

of the state park or the nearshore marine environment 

would also be unlikely to remain in the area during 

the 2- to 3-year construction period. Depending on 

the species in the area, the displacement could be 

temporary or long-term, as some individuals and 

some species are more susceptible to noise and the 

presence of humans than others. At noise levels 

associated with the removal or replacement of bridge 

piles (76 to 101 decibels at a distance of between 50 

and 800 feet), wildlife would not be able to habituate, 

which would be a moderate impact. At levels of 30 to 

70 decibels, most species of wildlife would continue 

to avoid the noise or suffer impacts to their ability to 

communicate and other secondary effects, a minor 

impact (Bowles 1995). 

Short- or long-term post-construction impacts to 

wildlife are also possible, as habitat may be removed 

to create access roads and bridge landings on both 

Ellis Island and in Liberty State Park. The presence 

of car and truck traffic could also cause some 

individuals to permanently abandon the adjacent 

habitat, although some individuals may habituate and 

remain or re-occupy the area. The long-term impact 

to unlisted wildlife species is expected to be 

negligible or minor. 

The protected species most likely to be adversely 

affected by bridge removal and reconstruction is the 

state threatened Savannah sparrow, a year-round 

resident of the state park. This species nests in open 

fields and thickets in the project area very near to 

where construction is likely to take place. Long-term 

impacts to the Savannah sparrow are also possible, as 

relocating the bridge landing could remove sparrow 

habitat, or permanently locate an area of higher than 

existing car traffic adjacent to it. Because breeding 

habitat could be affected, the impact to this species 

could range from minor to moderate, depending on 

the location of the access road, construction site, and 

bridge landing. 

Seasonal residents in the state park include the 

northern harrier, peregrine falcon, great blue heron, 

short-eared owl, and long-eared owl. The northern 

harrier hawk, a state endangered (breeding 

population) species, utilizes undisturbed fields and 

shoreline for feeding in both summer and winter. 

Long-eared and short-eared owls are also winter 

residents of the park, and peregrine falcons are 

summer residents. Increased traffic, noise, and human 

presence are likely to discourage all of these species 

from using the area in and adjacent to the work zone. 

If construction occurs during the time they are 

present in the park, these species could suffer minor 

impacts. 

Several bird species also migrate through Liberty 

State Park in the spring or fall, including several 

which are state listed (see the “Affected 

Environment” chapter). It is likely that fewer 

individuals of these species would use the park 

during the construction period as a migratory stop. 

However, because these species utilize a very large 

area, usually covering several hundred or thousand 

miles, the loss of habitat during the construction 
Impacts of Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 123

period at Liberty State Park is likely to be no more 

than a minor impact. 

Ellis Island provides minimal habitat for terrestrial 

wildlife. There are very few natural areas to provide 

shelter and food. Even so, during construction 

activities on Ellis Island associated with bridge 

removal, bridge reconstruction, and rehabilitation of 

buildings on the island, birds and other wildlife 

would be disturbed and displaced. Because these 

impacts are temporary, the effect would be minor to 

moderate overall. 

Long-term impacts are anticipated due to landscaping 

of courtyards on the south side. Currently, passerine 

bird species use these open fields for nesting. This 

habitat would be removed and revegetated with 

ornamentals to approximate the cultural landscape 

when immigration to Ellis Island was taking place. 

The ornamentals could be attractive to other wildlife, 

although it is unknown if this would be the case. The 

increased visitation to buildings on the south side 

could also disturb and possibly displace wildlife in 

the area, although birds or other wildlife that are not 

sensitive to humans or that thrive in humandominated environments could become established. 

In the long-term, effects on existing wildlife would 

be minor (e.g., readily apparent, but localized). 

As noted in the “Affected Environment” chapter, 

habitat apparently does not exist on Ellis Island for 

any of the 18 species of protected wildlife in Liberty 

State Park, as inventories have not found them. 

Therefore, no impacts to any listed or otherwise 

protected species on Ellis Island is anticipated. 

Cumulative Impacts. No additional cumulative 

impacts beyond those in no-action are expected. 

Conclusions. Minor to moderate impacts to 

nonprotected wildlife from construction are expected, 

particularly in Liberty State Park. Displacement 

through habitat removal and increased human activity 

could also result in negligible to minor long-term 

effects at both the state park and on Ellis Island. 

Some protected species could be affected. Savannah 

sparrows may experience moderate effects in the 

short-term, and other seasonal residents and migrants 

could experience minor impacts. Depending on the 

bridge alignment, Savannah sparrows may suffer 

minor long-term impacts resulting from loss of 

habitat and the additional presence of humans and 

traffic. Landscaping courtyards on Ellis Island would 

remove habitat for some wildlife species with 

possible long-term minor adverse impacts. No 

impairment of park wildlife resources would occur. 

SURFACE WATER

The same impacts to surface water as described under 

the no-action alternative would occur under 

alternative 2 from the removal of the temporary 

bridge. These include temporary, localized increases 

in turbidity in the surface water in the immediate 

vicinity, possible spills or leaks from heavy 

equipment, and the release of trace metals of other 

contaminants from bottom sediments. Because a 

permanent bridge would then be built, no additional 

fuel leaks from barges or ferry trips required to 

substitute for truck or car delivery of goods and 

services would take place. 

However, installation of pilings for the permanent 

bridge, as well as the bridge itself, is likely to result 

in increases in turbidity, contaminants, and petroleum 

products into the channel between the island and state 

park. Cofferdams of steel sheet pile or a similar 

substance are likely to be required to dewater areas 

sufficiently to install pier footings. Dewatering or 

dredging within the areas confined by the cofferdams 

would spread turbid and, possibly, contaminated 

water to the channel, increasing concentrations in that 

environment. Water within the confines of the 

cofferdam could be quite turbid or contain high levels 

of hazardous organics or metals dredged from marine 

sediments. The impact to surface water could range 

from minor to moderate during construction. 

Some additional erosion and resulting turbidity 

beyond that described under no action would also 

result from construction and use of a new access road 

and from rehabilitation of buildings on the south side. 

Employing the same mitigation measures (such as silt 

curtains or hay bales) described in the “Marine 

Sediments” section under no action could minimize 

this impact to surface water. With mitigation, the 

impact would likely be negligible. In the long-term, 

these and all graded areas that would not be used 

permanently could be revegetated or surfaced to slow 

or eliminate erosion. 

As with no action, turbidity and concentrations of 

pollutants would decrease after construction of the 

permanent bridge is complete. 

Cumulative Impacts. No additional cumulative 

impacts beyond those under the no-action alternative 
ENVIRONMENTAL CONSEQUENCES

124 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

are expected, and because bridge access remains, no 

additional pollution from increases in ferry traffic is 

anticipated. 

Conclusions. As in no action, removal of the 

temporary bridge could result in minor to major 

increases in turbidity, and petroleum releases from 

heavy equipment could result in negligible 

degradation of surface water near construction sites. 

Additional moderate impacts to surface water quality 

could result from construction of the permanent 

bridge, and minor impacts from construction of 

additional staging areas, roads, and rehabilitation 

could occur under alternative 2. In the long-term, 

impacts to surface water would be nonexistent or 

negligible. No impairment of park surface water 

would occur. 

GROUNDWATER

Depending on the final design of a permanent bridge 

and ultimate rehabilitation of courtyards, sidewalks, 

and other areas impervious to surface water 

infiltration, some negligible decrease in groundwater 

is a possible outcome under this alternative. 

It is unlikely that groundwater would be encountered 

in the construction of the new bridge. However, if it 

is, it would be pumped into the channel between Ellis 

Island and Liberty State Park. A reduction in the 

level of groundwater beneath Liberty State Park 

could draw contaminated groundwater or even salt or 

brackish water toward the area where drawdown is 

taking place. If large quantities of groundwater 

require pumping, the aquifer could ultimately be 

contaminated, although this is not expected to 

happen. Additional testing to determine groundwater 

elevations and aquifer conditions may be required to 

avoid such impacts and would likely be conducted 

should excess pumping be required. If future design 

work indicates groundwater would be a problem, 

site-specific analysis under the National 

Environmental Policy Act (NEPA) would be 

required. 

If disposal of groundwater into the channel is 

required and the groundwater is contaminated, 

federal statutes would require it be treated, and a 

permit under the National Pollution Discharge 

Elimination System program would be needed. 

Cumulative Impacts. Groundwater is often used for 

drinking water and may be pumped now, or may 

have been pumped in the past, to supply municipal 

needs in the region. 

Conclusions. Negligible to major impacts to local 

groundwater supplies are possible if bridge 

construction requires excavation in an area where 

groundwater tables are high, and extensive pumping 

may be needed. Additional testing and NEPA 

analysis would be required to determine features of 

the aquifer, mitigation, and level of impairment. 

AIR QUALITY

An earlier analysis (NPS 1995a) indicated that 

increases in emissions could result from a 

combination of factors such as increased visitation, 

construction traffic to remove the temporary bridge, 

and construction of the permanent bridge. Decreases 

in emissions could occur from the removal of the 

bridge under an alternative similar to alternative 2. 

The result would be a total combined 1-hour 

maximum carbon monoxide emission of 8.1 ppm and 

an 8-hour maximum of 5.7 ppm. These levels are 

both well under the federal standards of 35 ppm 

(1-hour) and 9 ppm (8-hour). By comparison, 

emissions at the more urban sites nearby (Kennedy 

Blvd. in Jersey City) ranged from 5.6 ppm to 7.3 ppm 

as the 8-hour maximum and 7.4 ppm to 11.6 ppm as 

the 1-hour maximum emissions between the years 

1989 and 1993. Compared to no action, this is a 5% 

increase and a negligible to minor impact. 

Cumulative Impacts. Visitation is expected to 

increase on Ellis Island by about 1.4% per year. Since 

85% of visitors from New Jersey access the ferry 

terminal via private cars, parking and congestion at 

intersections, with resulting increases in pollutants, is 

likely. These cumulative impacts are added into the 

emission totals above. 

Conclusions. Compared to the no-action alternative, 

emissions would be about 5% higher, resulting in a 

relative negligible to minor impact. Emissions related 

to alternative 2 would probably not be detectable 

beyond the immediate construction area. 
Impacts of Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 125

NOISE

Under this alternative (as with no action), visitors and 

workers close (within 50 feet) to heavy equipment 

could be exposed to noise levels during bridge 

removal activities as high as 100 decibels for short 

periods of time. Construction barriers would be used 

to reduce noise levels so they remain below 90 dBA. 

However, this is still an increase of up to 75% over 

current noise conditions, and a potentially severe, but 

short-term effect. Noise levels could be comparable 

to a chain saw at 3 feet or a railroad horn at 100 feet. 

Impacts would be similar for the construction of the 

permanent bridge, but would extend for at least twice 

as long as under no action. Visitors along Liberty 

Walk and other outdoor areas on Ellis Island would 

be most affected by noise increases during bridge 

construction. 

Additional noise from rehabitation of buildings on 

the south side would occur. Given that noise levels 

are currently quite low, even this addition of 

construction noise could have major short-term 

impacts. 

Cumulative Impacts. Noise levels from increased 

traffic and growth in the region, as well as increases 

in visitors to the state park and to the ferry terminal 

are expected to minimally increase noise levels in the 

area by 0.4 to 0.6 decibel (NPS 1995a). This is less 

than a 1% increase and a negligible impact. 

Conclusions. Long-term increases in noise are 

expected to be negligible; however, noise during 

construction may be severe on a short-term basis. 

These impacts would continue at least twice as long 

under alternative 2 as under no action. No 

impairment of the park wildlife or visitor experience 

would occur as a result of noise. 

HAZARDOUS MATERIALS

As under the no-action alternative, removal of the 

existing temporary bridge would involve soil 

disturbance at the ends of the bridge on both Ellis 

Island and Liberty State Park. Because clean fill had 

been used to backfill the existing temporary bridge 

touchdown areas when the bridge was constructed, 

no exposure from contaminated soils is expected. 

On Ellis Island and at Liberty State Park, installation 

of a new bridge would require excavation activities to 

build new landings and access roads. A small parking 

area on either or both sides may also be needed. New 

underground utilities and/or potable (drinking) water 

lines to the rehabilitated buildings on the south side 

may also be needed. Although subsurface disturbance 

would be limited to the upper 3 feet of soil for the 

roads, the potential exists for exposure to organic 

compounds and heavy metals as described in the 

“Affected Environment” chapter. 

Based on a risk assessment performed for the Science 

Technology Center, the New Jersey Department of 

Environmental Protection determined that, although 

the total human exposure risk of developing cancer 

from contact with soils containing contaminants 

similar to those in the fill at Liberty State Park and 

Ellis Island is above the optimum level, the risk to 

workers is within the EPA acceptable range (NPS 

1995a). Risk is primarily from exposure to heavy 

metals, such as chromium. Because this 

environmental impact statement is programmatic for 

the building of the permanent bridge, future NEPA 

documents would need to include specific mitigation 

measures to protect workers and visitors from the 

health effects of these contaminants. Worker and 

visitor health and safety plans to mitigate impacts 

prior to construction are required by the New Jersey 

Division of Parks and Forestry. Examples of 

mitigation measures required by the state’s existing 

plan for smaller-scale construction include protective 

equipment such as face masks, synthetic gloves, 

tyvek coveralls, and disposable booties. 

Additional mitigation measures could include 

subsurface investigations prior to construction in all 

areas of proposed disturbance to characterize 

potential contaminants, containment of the material 

in a separate area prior to disposal to prevent surface 

water contamination, protection of workers 

potentially exposed via skin contact or respiratory 

contact to contaminants through the use of personal 

protective equipment in accordance with the New 

Jersey Division of Parks and Forestry procedures, 

and best management practices, including covering 

exposed soils during construction. With these 

measures in place, impacts to workers would be 

minor to moderate. Visitors would likely be kept 

away from the site during construction. 

Following the completion of construction, the clean 

fill cap method of encapsulating contaminated fill 

would likely be used to eliminate exposure. One foot 

of clean fill is placed on top of exposed contaminated 

material; this can be further sealed with pavement. 

The clean fill cap method has been used successfully 
ENVIRONMENTAL CONSEQUENCES

126 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

in other areas of Liberty State Park, and if properly 

applied, would eliminate the risk to visitors or staff of 

long-term exposure to contaminants. 

Removal of the temporary bridge and construction of 

a new bridge would also disturb marine sediments 

and could result in increased suspension of organics 

and metals contained in those sediments. These 

potential contaminants include heavy metals, 

polychlorinated biphenyls (PCB), polycyclic 

aromatic hydrocarbons (PAH), and other volatile and 

semi-volatile organics documented in the sediments 

of New York Harbor and the nearby Morris Canal 

Basin. Impacts would be somewhat mitigated by the 

measures identified above in the “Marine Sediments” 

section, including the use of pre-drilled piles, silt 

curtains, and cofferdams to limit the time needed to 

install piles and contain contaminated surface water. 

Impacts to surface water from the suspension of 

hazardous materials would be minor to moderate 

during construction and fall to negligible over the 

long-term. 

It is unlikely that groundwater would be encountered 

by construction of the new bridge; however, if it is, 

groundwater could be contaminated and require 

proper treatment and approval prior to discharge. 

Because treatment is required, impacts would be 

negligible. 

Vacant and stabilized buildings would be 

rehabilitated to be generally suitable for a range of 

day uses, including administrative and operational 

support, historic interpretation, and cultural and 

educational uses. Asbestos abatement and removal of 

lead-based paint to the extent required to make the 

buildings safe would be required. Workers 

conducting the removal would be well trained and 

would take all necessary precautions to protect 

themselves and to properly contain and dispose of 

these materials so as to prevent airborne exposure. 

Impacts would, therefore, be negligible. 

Cumulative Impacts. No cumulative effects beyond 

those described under the no-action alternative are 

anticipated. 

Conclusions. Workers could encounter contaminated 

soils in constructing landings and access roads for the 

permanent bridge. If a mitigation plan is put into 

place and followed, impacts would be no more than 

moderate. Encapsulating contaminated fill following 

construction would eliminate the risk of exposure in 

the long-term. Construction activities could also 

suspend organics and heavy metals in marine 

sediments, resulting in minor to moderate impacts to 

surface water from contamination. These would fall 

to negligible shortly after construction is complete. 

Asbestos and lead-paint removal would eliminate risk 

of exposure to visitors, and with the use of standard 

precautions, pose a negligible risk to workers. No 

impairment of park resources would occur. 

SOCIAL AND 

ECONOMIC ENVIRONMENT

TOURISM

Under alternative 2, 2.526 million visitors are 

projected to visit Ellis Island in the year 2005, an 

increase of 5.4% over the projected 2.396 million 

visitors without the proposed additional Ellis Island 

attractions. Without significantly increasing the 

number of visitors, this alternative seeks to increase 

the number and type of attractions and activities on 

the island to attract visitors who otherwise would not 

visit Ellis Island. A primary goal of the reuse of the 

existing buildings is to preserve and enhance the 

island’s cultural history and resources while 

strengthening Ellis Island’s economic selfsustainability through increased revenue. 

Under alternative 2, a variety of uses would be 

allowed as part of building rehabilitation. These uses 

include museum-type exhibits and presentations; 

theatrical events; festivals and celebrations (which 

would allow use of outdoor spaces); research and 

learning centers for a range of for-profit and not-forprofit organizations; educational facilities for various 

school groups (elementary through high school); 

university-sponsored inquiry and study programs; 

genealogical research; and administrative, meeting, 

or event spaces supporting cultural and educational 

purposes. Spaces within this category would be a 

combination of public and limited-public, depending 

on the specific nature of use. 

Although the additional exhibits and activities 

proposed under this alternative may not, in and of 

themselves, attract more visitors to Ellis Island, the 

combination of the Statue of Liberty, Ellis Island 

Immigration Museum, and the additional exhibits 

may provide a critical mass of attractions to entice 

visitors to lodge nearby in order to complete the 

entire tour of exhibits at the Statue of Liberty 

National Monument. Under these alternatives, the 

multi-day conferences and special events are 
Impacts of Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 127

anticipated to result in more off-site lodging nights in 

the region. 

Extended programming and activities offered under 

alternative 2 would result in a minor benefit to 

tourism in increased visitorship to and around Ellis 

Island, as well as increased demand for lodging in the 

New Jersey / New York area. 

PARK ADMINISTRATION

Under alternative 2, it is anticipated that 21 additional 

NPS employees would be required for administration 

and coordination of south-side activities, programs, 

security, and other services. Vendors or service 

operators, similar to arrangements currently in place 

with Circle Line and food vendors, would likely have 

to hire additional employees. 

The construction of the permanent bridge proposed 

under alternative 2 would allow continued vehicular 

access for emergency service personnel (fire, police, 

ambulance) to Ellis Island, as well as an expeditious 

pedestrian evacuation route should the need arise. 

Medical emergencies would be evacuated swiftly to 

the mainland without the dependence on ferries. 

Under the no-action alternative, following bridge 

removal, transport of medical emergencies could take 

more than 30 minutes. Response times for fire and 

police would continue at the current 3 to 4 minutes, 

versus the minimum 30-minute response time 

predicted after the removal of the bridge under the 

no-action alternative. The bridge would ensure 

continued rapid evacuation of Ellis Island in 

emergency situations, a concern that has been 

heightened since the events of September 11, 2001. 

Other operations of the National Park Service that 

now benefit from the bridge include deliveries of 

materials, supplies, parcels, and access for park and 

concession personnel. These conveniences would be 

terminated with the loss of the bridge. When 

compared to lengthy emergency response times and 

lack of a pedestrian evacuation route predicted under 

the no-action alternative, alternative 2 provides a 

benefit of unknown intensity, possibly major, to park 

administration. The convenience the bridge offers 

regarding non-emergency access is considered a 

minor benefit to park administration. 

Cumulative Impacts. Under alternative 2, tourism 

could experience a positive cumulative benefit with 

the potential increased demand for lodging in areas 

surround Ellis Island as a result of the expanded 

cultural programming and activities proposed under 

this alternative. Comparatively, the no-action 

alternative is not anticipated to result in similar 

benefits to tourism. 

Conclusions. Extended programming and activities 

offered under alternative 2 would result in a minor 

benefit to tourism in increased visitorship to and 

around Ellis Island, as well as increased demand for 

lodging in the New Jersey / New York area. When 

compared to lengthy emergency response times and 

lack of a pedestrian evacuation route predicted under 

the no-action alternative, alternative 2 provides a 

benefit of unknown intensity, possibly major, to park 

administration. The convenience the bridge offers 

regarding non-emergency access is considered a 

minor benefit to park administration. No impairment 

of park resources would occur. 

TRANSPORTATION AND CIRCULATION 

ACCESS TO ELLIS ISLAND

Under this alternative, the existing temporary service 

bridge would be replaced with a new limited-access 

bridge at a location to be determined. As is the case 

with the temporary bridge, authorized users of the 

permanent bridge would only include construction 

vehicles, emergency vehicles, delivery vehicles, 

official vehicles, and others requiring access to the 

facilities. A security guard house would be 

permanently located at the mainland side of the 

bridge and would be secured during nondelivery or 

visitation hours. Members of the general public 

would continue to arrive by ferry service. All 

delivery services would continue to use the bridge. 

Because access to Ellis Island is from Liberty State 

Park, deliveries may have to be restricted to business 

hours. Given the need to maintain island security, a 

permit process for delivery of goods that support the 

proposed functions would have to be established. 

The level of impacts to Ellis Island access during 

removal of the temporary bridge depends on the 

sequencing of construction. If a new bridge is built 

before the temporary bridge is removed, no more 

than negligible impacts related to the presence of 

construction vehicles and staging areas are expected. 

However, if the temporary bridge is removed first, 

moderate impacts for the length of the construction 

period are possible. Compared to no action, these 

impacts would be beneficial. 
ENVIRONMENTAL CONSEQUENCES

128 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

ACCESS TO FERRY TERMINALS

Ellis Island visitors who may wish to stay overnight 

would likely lodge at hotels in Jersey City, other 

nearby local New Jersey locations, or in New York 

City. As described in the “Affected Environment” 

chapter, most of these locations are well served by 

public transportation or private services, including 

the Bergen-Hudson Light Rail, New Jersey Transit 

buses, taxi, shuttle buses from some of the local 

hotels, and ferry service from several locations 

adjacent to the Hudson River. Guests to Ellis Island 

from New York City are anticipated to utilize the 

city’s extensive mass transit system and taxi service 

to get to any of the ferry terminals serving Ellis 

Island. Some visitors would continue to arrive at the 

ferry terminal by private vehicle. 

PARKING

This alternative includes special-event uses of 

buildings and spaces on Ellis Island for as many as 

500 visitors. If the New Jersey Transit Authority 

continues to allow the use of its light rail parking lot 

for overflow parking at Liberty State Park, parking 

for these events can be accommodated. Also, given 

current trends, most of the visitors arriving from New 

York would use mass transit options available to 

them. 

Because about 85% of New Jersey visitors and a 

small portion of New York visitors use private cars to 

access the ferry terminals, an increase in visitor 

growth by about 5% could result in as many as 50 

new cars attempting to find parking at Liberty State 

Park (assuming 21% of the increase occurs at the 

New Jersey terminal, 85% still drive cars, and 1.5 

passengers per car). Given current and future 

projected conditions in some of the lots at the state 

park, and in particular lot 6, the addition of 50 cars 

over the existing 900 spots in the lot would result in 

minor impacts. It is unlikely that additional cars 

could be accommodated on busy summer days, and 

they may need to be directed to more distant lots in 

the state park or use lots outside the park. Visitors 

may have to rely on buses. As noted in the “Affected 

Environment” chapter, no regular transit service 

exists between the West Side Avenue park-and-ride 

lot in Jersey City and the ferry terminal inside Liberty 

State Park. If the New Jersey Transit Authority 

continues to allow the use of its light rail parking lot 

for overflow parking on crowded days, no impact to 

existing parking facilities in the study area is 

expected. 

CIRCULATION

Under this alternative, it is assumed that a 5.4% 

increase in visitation beyond the figures under the 

no-action alternative would occur following 

rehabilitation of the south-side buildings. Since 85% 

of visitors access the ferry from New Jersey by 

private vehicle, it is likely that the number of vehicles 

attributable to visitation would also increase. 

Several intersections identified in the “Affected 

Environment” chapter (Audrey Zapp Drive and 

Phillip Drive in Liberty State Park; Morris Pesin 

Drive / Bayview Avenue at Caven Point Road; and 

Bayview Avenue at the New Jersey Turnpike exit 

outside the state park) are already at level of service 

at or above capacity. Level of service at these 

intersections would likely continue to deteriorate 

with the increases in visitors. However, an earlier 

analysis of impacts that expected a 10% increase in 

visitors to Ellis Island (NPS 1995a) indicated no 

changes in level of service would result directly from 

this increase. Rather, deterioration of conditions at all 

intersections in the study area would continue 

because of growth in the area and increased visitors 

to Liberty State Park. Therefore, impacts to 

circulation from alternative 2 would be greater than 

under no action, but would also be either 

undetectable or negligible. 

Cumulative Impacts. Area-wide growth and/or 

increased visitation to Liberty State Park would 

increase the use of existing public transportation and 

continue to add traffic at intersections already at 

capacity. It could also be harder to find parking spots 

inside Liberty State Park, as well as in the Battery 

Park area where the existing ferry terminals to Ellis 

Island are located. 

Conclusions. Negligible to moderate short-term 

impacts to access for staff and delivery vehicles 

could result from bridge removal and reconstruction. 

Compared to no action, the impact would be 

relatively beneficial because it would only be 

temporary. Minor impacts to parking in Liberty State 

Park could occur from increases in visitation 

expected from this alternative compared to no action. 

Undetectable to negligible impacts to levels of 

service at intersections in the area are attributable to 
Impacts of Alternative 2: Ellis Island Partners — Day Use Only 

FINAL ENVIRONMENTAL IMPACT STATEMENT 129

increased visitation that could occur under 

alternative 2. 

VISITOR EXPERIENCE

Construction activities associated with the removal of 

the temporary bridge, installation of the permanent 

bridge, and rehabitation of buildings on the south side 

could have a temporary impact on the visitor 

experience at Ellis Island through increases in noise 

and a scene inconsistent with the cultural landscape. 

However, this impact would be short lived and 

outweighed by the permanent improvements this 

alternative would provide to the visitor experience. 

Since September 11, 2001, tourism and visitation to 

the region have been critically reexamined. 

Particularly for Lower Manhattan, linkages are being 

reestablished within the nation’s gateway. The 

enhancements of adaptive reuse and day use for Ellis 

Island proposed under alternative 2 come at a critical 

time in the planning and consideration of new 

initiatives for visitation. 

Alternative 2 would create a campus of nonprofit and 

institutional day uses that complement the purposes, 

themes, and significance of Ellis Island. Visitor 

programs and exhibits relating to immigration, ethnic 

diversity, refugees, public health, and other topics 

relating to the island significance would be offered 

(see the “Alternatives” chapter for more detail). Most 

programs/exhibits would be open to all. A variety of 

dining and food service uses would be developed in 

support of the culinary and economic needs of 

diverse visitors. No overnight lodging would be 

provided on Ellis Island. 

Access to Ellis Island for the public would continue 

to be provided via existing ferry service. Boats would 

continue to dock along the south side of the Main 

Building where visitors directly enter the Main 

Building, much as early immigrants did. Many 

visitors have stated that the ferry ride and associated 

views of the harbor were important and memorable 

parts of their visit to Ellis Island (see the “Affected 

Environment” chapter). 

Visitor flow and use patterns would be significantly 

expanded when compared to the no-action 

alternative. Access would be permitted to most 

structures and exterior spaces of the island, with the 

exception of those included in a more restricted use 

area (park administration facilities). Such increased 

access would improve the visitor experience by 

enhancing the understanding of the history, 

architecture, and landscape of Ellis Island. 

Proposed activities under alternative 2 would 

increase visitor options and experiences and, 

therefore, the number of visitors to Ellis Island. The 

greater number of new visitors to Ellis Island would 

be for planned outdoor events. Due to the island site 

and transportation controls, these numbers would be 

restricted to a reasonable capacity. Availability of 

bridge access provided under this alternative could 

become an important factor in the quick evacuation 

of large numbers of visitors in an emergency. 

Additional interpretive and museum space proposed 

under alternative 2 would add only slightly to the 

duration of visitation of those coming to the Main 

Building. Visitation to new venues, while adding to 

the total number, would be limited by the relative 

small building area available, as well as by 

considerations for sustainability in the cost basis for 

rehabilitation. 

The combination of significantly increased visitor 

access to the majority of Ellis Island and the 

expansion of interpretive offerings under 

alternative 2 would result in a major benefit to the 

visitor experience at Ellis Island, an effect similar to 

that of alternative 3. When compared to the no-action 

alternative, where both access and interpretive 

offerings are limited, alternative 2 would provide a 

significantly more enhanced visitor experience. 

Cumulative Impacts. The multi-year efforts of 

historic structure / landscape rehabilitation would 

provide cumulative benefits to visitor experience 

through the ever increasing (at least for the first 10 to 

20 years) access to areas of Ellis Island from which 

the public is currently restricted. As restored 

structures and landscapes are opened to visitors, so 

too are associated interpretive exhibits and displays 

that will increase visitor options and experiences over 

time. Similar cumulative benefits are expected under 

alternative 3; comparatively, the no-action alternative 

would offer no such benefits. 

Conclusions. This alternative would result in minor 

adverse impacts to the visitor experience during 

construction, but would provide a significantly more 

enhanced and a major long-term benefit to the visitor 

experience at Ellis Island compared to the no-action 

alternative. No impairment of park resources or 

values would occur. 
ENVIRONMENTAL CONSEQUENCES

130 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

ELLIS ISLAND INFRASTRUCTURE 

The main utility connections provided to Ellis Island 

as part of the prior renovations are adequate to 

service all of the buildings on Ellis Island under 

alternative 2. As such, the need to install new 

submarine utilities beneath the Hudson River is not 

anticipated. 

However, while generally adequate, several 

infrastructure components could benefit from 

upgrades or improvements because (1) Ellis Island’s 

stormwater system releases untreated stormwater into 

the Hudson River without the benefit of any 

detention basins or treatment; (2) existing fire 

hydrants on the south side and related underground 

piping require replacement, including appropriate 

positive backflow prevention devices to protect the 

water supply system; (3) the central chilled-water 

plant’s refrigerant monitoring system is not 

operational or consistently operational; and (4) the 

original cooling towers and associated pumps, while 

operational, are in poor condition and would require 

upgrades in the near future, especially if demand 

increases on Ellis Island. In addition, regular, 

ongoing maintenance of these systems would be 

required. 

The installation of new underground and aboveground utilities on the south side to service the 

buildings proposed for renovation would disturb soils 

on Ellis Island. Upgrades may be required within the 

Powerhouse for proper distribution of utilities. 

Additional provisions for emergency power would be 

required. Above-ground utility structures would be 

designed and installed so as to minimally impair the 

island. 

The upgrading and improvement of utilities proposed 

under alternative 2 are considered moderate benefits 

to the Ellis Island infrastructure and would 

complement the rehabilitation efforts of historic 

structures proposed for reuse under these alternatives. 

Cumulative Impacts. Under alternative 2, existing 

utilities would be upgraded and improved to facilitate 

the rehabilitation of historic structures on Ellis Island. 

These actions are expected to result in cumulative 

benefits to the utility infrastructure of the island, 

which is also true under alternative 3. The no-action 

alternative would offer no such benefits. 

Conclusions. The upgrading and improvement of 

utilities proposed under alternative 2 are considered 

moderate benefits to the Ellis Island infrastructure 

and would complement the rehabilitation efforts of 

historic structures proposed for reuse under these 

alternatives. 
FINAL ENVIRONMENTAL IMPACT STATEMENT 131

SECTIONS REQUIRED UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

The National Environmental Policy Act requires 

agencies to consider irretrievable (short-term or 

reversible) and irreversible (long-term or permanent) 

commitments of resources from proposed actions. 

Under this alternative, the National Park Service 

would make an irreversible commitment of staff, 

money, and time to rehabilitate the deteriorating 

30 buildings that contribute to the overall cultural 

landscape of the island. The expected cost of 

rehabilitation is over $150 million; this does not 

include annual operating and maintenance costs. In 

return, the nation would experience major benefits 

from restoring the integrity of these very significant 

structures and the Ellis Island cultural landscape. 

LOSS IN LONG-TERM AVAILABILITY 

OR PRODUCTIVITY OF THE 

RESOURCES TO ACHIEVE SHORTTERM GAIN 

No losses in long-term availability or productivity of 

resources would be realized to achieve a short-term 

gain under alternative 2. In fact, the focus of this 

alternative is long-term gain or productivity of the 

site. 

UNAVOIDABLE ADVERSE IMPACTS 

Small losses of soil are expected from grading for 

construction. Disturbance to marine sediments and 

associated increases in turbidity and impacts on 

aquatic life are expected during removal of the 

temporary bridge and construction of a new 

permanent bridge. The sediments may temporarily 

suspend heavy metals, organics, or other toxins. The 

concentrations of these chemicals may be quite high 

in areas contained by cofferdams. Replanting the 

courtyards associated with buildings that are slated 

for rehabilitation could adversely effect or eliminate 

patches of two state protected plant species. Longterm increases in noise are expected to be negligible; 

however, noise during construction may be severe on 

a short-term basis and have adverse effects on 

visitors and wildlife. The Savannah sparrow, a state 

protected species and year-round resident of Liberty 

State Park, could experience additional minor longterm effects from removing habitat and the presence 

of traffic accessing a landing site in Liberty State 

Park. Groundwater dewatering or contamination is a 

possible outcome if building a landing requires 

pumping of an aquifer to reduce the water table. In 

addition to the mobilization of toxins in marine 

sediments, locating a bridge landing in Liberty State 

Park could involve digging in soils contaminated 

with chromium and other dangerous toxins. A 

mitigation plan could reduce impacts to workers and 

visitors from this activity. Minor impacts to parking 

availability at Liberty State Park are expected from 

increases in visitation. 
132 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

IMPACTS OF ALTERNATIVE 3: ELLIS ISLAND INSTITUTE 

WITH OVERNIGHT ACCOMMODATIONS (PREFERRED ALTERNATIVE)

CULTURAL RESOURCES 

HISTORIC ARCHITECTURAL RESOURCES

Similar to alternative 2, alternative 3 would provide 

for the long-term preservation of all or most of the 

currently vacant historic structures on Ellis Island 

through adaptive reuse for purposes complementary 

to the island's historic themes and related issues. 

The general campus environment of Ellis Island 

would be preserved, and its character-defining 

features retained (refer to alternative 2 for more 

detail on the rehabilitation of historic structures). 

As proposed under this alternative, historic 

structure rehabilitation is considered a moderate, 

long-term benefit, with regional and, possibly, 

national implications. 

Cumulative Impacts. Rehabilitation of all 

National Register structures on Ellis Island is 

proposed under alternative 3, ultimately providing 

for their preservation. These multi-year actions 

offer significant positive cumulative benefits to the 

historic structures of Ellis Island. 

Conclusions. The proposed rehabilitation and reuse 

of the National Register structures on Ellis Island 

would ensure the preservation of National Register 

cultural resources. The ultimate effect of alternative 

3, the avoidance of the loss of Ellis Island's historic 

structures due to unchecked deterioration (the 

expected result of the no-action alternative), is 

decidedly positive. This positive effect is similar 

under alternative 2. 

CULTURAL LANDSCAPES

Similar to alternative 2, alternative 3 proposes the 

rehabilitation and interpretation of the cultural 

landscape to promote a broad understanding of its 

historic appearance and use (see the “Affected 

Environment” chapter; also see alternative 2 for 

additional detail on impacts to the cultural 

landscape). 

The rehabilitation and reuse of the cultural 

landscape proposed under alternative 3 would result 

in a moderate, site-specific benefit to cultural 

resources on Ellis Island, similar to benefits 

provided under alternative 2. When compared to the 

no-action alternative under which the cultural 

landscape would be significantly compromised over 

time, alternative 3 is notably beneficial in its effects. 

As under alternative 2, alternative 3 proposes that the 

current temporary bridge linking Ellis Island and New 

Jersey be replaced with a permanent bridge and 

security facility. Construction of a new bridge would 

perpetuate the existing link (temporary service bridge) 

between Ellis Island and New Jersey, affecting its state 

of isolation as well as some historic views to and from 

the island. The construction of a new bridge proposed 

under alternative 3 is believed to have long-term, 

moderate adverse impacts to the cultural resources of 

Ellis Island and several surrounding National Register 

properties. The impacts are believed to be regional 

(harbor-wide) in nature (refer to alternative 2 for more 

detail on the proposed bridge and its impacts on the 

cultural landscape). In comparison, the no-action 

alternative would enhance the cultural landscape of 

Ellis Island by the removal of the existing bridge. 

From a positive perspective, construction of a 

permanent bridge would allow for the continued rapid 

vehicular access to the island by emergency vehicles, 

resulting in a potential benefit to the cultural resources 

of Ellis Island (see alternative 2 for more detail). The 

maintenance of efficient fire-fighting methods expected 

with the presence of a bridge proposed under 

alternative 3 would result in a benefit of unknown 

intensity to the cultural resources of Ellis Island, a 

marked advantage over the no-action alternative. 

Similar benefits are provided under alternative 2. 

Cumulative Impacts. The rehabilitation of Ellis 

Island's cultural landscape proposed under alternative 3 

would ultimately ensure its historic preservation. This 

multi-year effort offers significant positive cumulative 

benefits to the cultural landscape of Ellis Island which, 

without such actions, would most likely deteriorate to 

the point of possible impairment (see the no-action 

alternative). 

Conclusions. Rehabilitation efforts under alternative 3 

would provide moderate, site-specific benefits to the 

cultural resources, as is the case under alternative 2. 

Comparatively, the no-action alternative proposes no 

such actions, posing much higher risks to the cultural 

resources of Ellis Island. The bridge proposed under 
Impacts of Alternative 3: Ellis Island Institute with Overnight Accommodations (Preferred Alternative) 

FINAL ENVIRONMENTAL IMPACT STATEMENT 133

alternative 3 would perpetuate the diminished 

nature of the waterspace between the island and the 

mainland, creating long-term moderate adverse 

impacts to Ellis Island and surrounding National 

Register properties (Statue of Liberty, CRRNJ 

Terminal). A similar loss of historic setting / 

context for Ellis Island is expected under alternative 

2, though not under the no-action alternative, which 

proposes bridge removal. At the same time, the 

presence of a bridge under alternative 2 would 

result in a benefit to the cultural resources of Ellis 

Island due to the high degree of protection from fire 

damage/loss. This is a decidedly positive effect also 

provided for under alternative 3, but not under the 

no-action alternative. 

ARCHEOLOGICAL RESOURCES

As is the case under alternative 2, utility 

infrastructure improvements proposed in 

alternative 3 have the potential to impact buried 

terrestrial archeological resources through earth 

disturbance / trenching activities (see alternative 2 

for detail on impacts to archeological resources 

associated with utility improvements). 

Terrestrial Archeological Resources 

Alternatives 2 and 3 have the potential to impact 

archeological resources more than alternative 1 (no 

action). Ground-disturbing construction activities, 

however, will be assessed on a case-by-case basis 

following established section 106 procedures as 

defined in the National Historic Preservation Act. 

By following section 106 procedures and 

conducting the necessary research and consultation, 

the impact to the archeological resources should be 

minimal. 

Marine Archeological Resources 

Increased dredging in the vicinity of the ferry slip 

under alternative 3 has the potential to impact 

marine archeological resources, as does placing 

pilings for the permanent bridge. However, by 

using existing information and following section 

106 guidelines, the impact to marine archeological 

resources should be no more than minor. 

Cumulative Impacts. Alternative 3 is not expected 

to result in cumulative impacts to archeological 

resources in or associated with Ellis Island. 

Conclusions. Utility infrastructure improvements may 

have minor impacts on terrestrial resources. Bridgerelated excavation and maintenance dredging activities 

proposed under alternative 3 have the potential for no 

more than minor impacts to marine archeological 

resources. Similar adverse impacts are possible under 

alternative 2. No impairment of park resources would 

occur. 

NATURAL RESOURCES 

GEOLOGIC RESOURCES AND SOILS

No impacts (beyond those described in alternative 2) to 

geology or soils are anticipated under alternative 3. 

These include grading soils to create access roads and 

construction staging areas and to install underground 

utilities. Digging may uncover contaminated fill, and 

this is analyzed in the “Hazardous Materials” section. 

Cumulative Impacts. No additional cumulative 

impacts beyond those described under the no-action 

alternative are anticipated. 

Conclusions. Negligible to minor impacts to soils 

would result when filling the seawall after removing 

the temporary bridge, excavating for new underground 

utility connections, grading a new access road to the 

landing at Liberty State Park, and from grading for 

construction staging areas. No impairment of park 

geology or soils would occur. 

MARINE SEDIMENTS

Impacts to marine sediments under this alternative 

would be the same as those described under 

alternative 2. These include holes in the channel 

sediments from removing pilings for the existing 

bridge and the disturbance and displacement of 

sediments to drive new piles. 

Cumulative Impacts. No additional impacts to marine 

sediments beyond those described under the no-action 

alternative are anticipated. 

Conclusions. Localized negligible or minor temporary 

impacts (slightly greater than under no action) to 

marine sediments in the channel between Ellis Island 

and the state park would occur during removal of 

temporary bridge pilings and installation of new pilings 

for the permanent bridge. Mitigation would likely 

reduce impacts to marine sediments, comparable to the 
ENVIRONMENTAL CONSEQUENCES

134 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

no-action alternative. No marine sediments are part 

of the park; therefore, no impairment of park 

marine sediments is possible. 

FLOODPLAINS

No differences between alternatives 2 and 3 are 

anticipated for flood risk. As described under 

impacts of alternative 2, dismantling the existing 

temporary bridge and sealing the floodwall would 

eliminate the existing likelihood of damage during 

an extreme weather event and would have a minor 

benefit on the impact of flooding. 

The replacement bridge would touch down at points 

in the floodplain on both Ellis Island and Liberty 

State Park; therefore, these landings could 

experience some flooding during extreme flood 

event. 

Cumulative Impacts. No additional cumulative 

impacts beyond those described under the no-action 

alternative are anticipated under alternative 3. 

Conclusions. As with no action, removing the 

temporary bridge and sealing the seawall could 

result in minor beneficial impacts from flood 

prevention. Building a permanent bridge may mean 

negligible impacts to access during extreme flood 

events. No impairment of park floodplains would 

occur. 

VEGETATION / THREATENED 

AND ENDANGERED PLANT SPECIES

No changes to impacts on vegetation from those 

described under alternative 2 are anticipated. These 

include the permanent loss of a small area of 

vegetated land to build bridge landings and access 

roads at Liberty State Park and on Ellis Island, and 

the temporary clearing of vegetation for 

construction staging areas. These areas would be 

replanted following construction, and impacts 

would be negligible or minor as a result. 

Landscaping the courtyards and other areas on the 

south side and the maintenance of these gardens 

would help control invasive species, but would also 

result in the removal or relocation of some 

individuals of either the Canada hawkweed or Ohio 

spiderwort, New Jersey state protected plant 

species. If the park can mitigate impacts to these 

protected species by replanting individuals to locations 

where changes will not take place, or improve growing 

conditions for hawkweed or spiderwort in an off-island 

location, impacts could fall to negligible. If not, 

impacts would be locally minor to moderate. Because 

the area of the courtyards slated for planting is only 

approximately 3 acres, and these plant species grow 

over several states, the impact would not be a major 

one, and no impairment of park resources is expected. 

Cumulative Impacts. No cumulative impacts beyond 

those identified under the no-action alternative would 

occur under alternative 3. 

Conclusions. Negligible to minor losses of open field 

vegetation are likely from the creation of landing sites 

and from constructing staging areas for removing the 

temporary bridge, building a permanent bridge, and 

rehabilitating buildings on Ellis Island. Minor to 

moderate localized impacts from the loss of two state 

protected plant species (Canada hawkweed and Ohio 

spiderwort) are possible from the planting of restored 

courtyards on Ellis Island. These impacts could be 

eliminated or reduced to negligible through avoidance, 

replanting individuals, or improving off-site habitat. 

FISH

No impacts (beyond those identified under 

alternative 2) to fish species are expected. These 

include direct impacts to fish and fish habitat from 

removal and replacement of the existing bridge 

superstructure, piles, and pile caps, as well as 

associated increases in turbidity and suspension of 

pollutants now in marine bottom sediments. The 

impacts of construction to fish could range to 

moderate, but would fall to negligible after 

construction is complete. Construction-related impacts 

would continue in the moderate range for a longer 

period of time than under no action. 

Cumulative Impacts. No additional cumulative 

impacts beyond those described under the no-action 

alternative are expected. 

Conclusions. Removal of the temporary service bridge 

and construction of a permanent one could result in 

moderate short-term impacts to fish in the channel 

between Ellis Island and the New Jersey shoreline, 

with a longer period of impact than under no action. No 

impairment of park fisheries resources would occur. 
Impacts of Alternative 3: Ellis Island Institute with Overnight Accommodations (Preferred Alternative) 

FINAL ENVIRONMENTAL IMPACT STATEMENT 135

WILDLIFE / THREATENED 

AND ENDANGERED WILDLIFE SPECIES

Wildlife impacts under alternative 3 would be 

similar to those described for alternative 2. These 

noise-related effects include short-term disturbance 

or displacement of wildlife. The presence of 

humans and equipment during construction (on 

both Ellis Island and at Liberty State Park) could 

also affect wildlife. Short- or long-term postconstruction impacts to wildlife from the removal 

of habitat or proximity of car and truck traffic may 

also occur. 

The protected species most likely to be adversely 

affected by bridge removal and reconstruction is the 

state threatened Savannah sparrow, a year-round 

resident of the state park. This species nests in open 

fields and thickets in the project area very near to 

where construction is likely to take place. Longterm impacts to the Savannah sparrow are also 

possible, because relocating the bridge landing 

could remove sparrow habitat or could force some 

sparrows to permanently relocate to an adjacent 

area that might be subject to greater vehicular 

traffic. 

Other seasonal residents in the state park would be 

disturbed or displaced during construction if it 

occurs during the season that wildlife normally 

occupy habitat in the park: the winter for longeared and short-eared owls and the northern harrier; 

the summer for peregrine falcons and northern 

harrier. Several bird species also migrate through 

Liberty State Park in the spring or fall, including 

several that are state listed (see the “Affected 

Environment” chapter). Construction may also 

mean fewer individuals of these species would use 

the park in a given year. 

Long-term impacts to some bird species using open 

fields in courtyards are anticipated due to 

landscaping of these courtyards. The increased 

visitation to buildings on the south side would also 

disturb, and possibly displace, wildlife in the area. 

Alternative 3 is also likely to have additional 

adverse impacts on wildlife on Ellis Island because 

visitors would be allowed to spend the night. This 

would disturb night-feeding animals, such as owls, 

and could also cause some species to abandon 

habitat in the area because of the continual human 

presence, night lighting, and other unnatural 

conditions. Because this impact is limited to Ellis 

Island, where wildlife habitat is currently sparse, the 

impact is likely to be negligible or minor. 

Cumulative Impacts. No additional cumulative 

impacts beyond those identified for the no-action 

alternative are anticipated. 

Conclusions. Minor to moderate impacts to 

nonprotected wildlife from construction are expected, 

particularly in Liberty State Park. Displacement 

through habitat removal and increased human activity 

may also result in negligible to minor long-term effects 

at both the state park and on Ellis Island. Additional 

negligible to minor impacts from the continual 

presence of humans throughout the night may also 

occur to Ellis Island wildlife. Some protected species 

would be affected; Savannah sparrows may experience 

moderate effects in the short-term, and other seasonal 

residents and migrants could experience minor impacts. 

Depending on the bridge alignment, Savannah 

sparrows may suffer minor long-term impacts resulting 

from loss of habitat and the additional presence of 

humans and traffic. Landscaping courtyards on Ellis 

Island could remove habitat for some wildlife species 

with possible long-term minor adverse impacts. No 

impairment of park wildlife resources would occur. 

SURFACE WATER

No changes to surface water, other than those described 

under alternative 2, are expected. These include 

temporary, localized increases in turbidity in the 

surface water in the immediate vicinity, possible spills 

or leaks from heavy equipment, and the release of trace 

metals or other contaminants from bottom sediments 

during removal of the temporary bridge and 

construction of the new bridge. The use of cofferdams 

to install new pilings could increase turbidity and 

suspended pollutants inside the confines of the dam, 

but result in decreases in concentrations outside it. 

Erosion from construction sites and the new access 

road would be effectively mitigated with the use of best 

management practices. 

Cumulative Impacts. No cumulative impacts beyond 

those described under the no-action alternative are 

anticipated. 

Conclusions. As with no action, removal of the 

temporary bridge could result in minor to moderate 

increases in turbidity, and petroleum releases from 

heavy equipment could result in negligible degradation 

of surface water near construction sites. Additional 
ENVIRONMENTAL CONSEQUENCES

136 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

moderate impacts to surface water quality would 

result from construction of the permanent bridge, 

and minor impacts from construction of additional 

staging areas, roads, and rehabilitation could occur 

under alternative 2. In the long-term, impacts to 

surface water would be nonexistent or negligible. 

No impairment of park surface water would occur. 

GROUNDWATER

No impacts (beyond those described under 

alternative 2) to groundwater are expected for this 

alternative. These include possible high water 

tables encountered during construction and the need 

to pump groundwater. There is some small chance 

that the groundwater could be contaminated, or that 

pumping could bring contaminated groundwater 

into contact with a clean aquifer. Additional testing 

to determine groundwater elevations and aquifer 

conditions may be required to avoid such impacts, 

and would likely be conducted should excess 

pumping be required. If future design work 

indicates groundwater would be a problem, sitespecific analysis under the National Environmental 

Policy Act would be required. 

If disposal of groundwater into the channel is 

necessary, and the groundwater is contaminated, 

federal statutes would require it be treated, and a 

permit under the National Pollution Discharge 

Elimination System program would be needed. 

Cumulative Impacts. No additional cumulative 

impacts beyond those described under alternative 2 

would occur. 

Conclusions. Negligible to major impacts to local 

groundwater supplies are possible if bridge 

construction requires excavation in an area where 

groundwater tables are high, and extensive 

pumping may be needed. Additional testing and 

NEPA analysis would be required to determine 

features of the aquifer, mitigation, and level of 

impairment. 

AIR QUALITY

Impacts to air quality from actions under 

alternative 3 would not be different than those 

under alternative 2. These include an approximately 

5% increase in emissions, compared to no action, 

from bridge-related construction and increased 

visitation by car to the New Jersey ferry terminal in 

Liberty State Park. Compared to existing conditions, 

this increase would be undetectable in the study area 

except in the immediate area of the construction site. 

Cumulative Impacts. No cumulative impacts (beyond 

those described for the no-action alternative) are 

expected. 

Conclusions. Emissions would be about 5% higher 

than under the no-action alternative, and a relative 

negligible to minor impact compared to no action. 

Compared to existing conditions, emissions related to 

this alternative would probably not be detectable any 

further than the immediate construction area. 

NOISE

Impacts would be the same as under alternative 2, 

where visitors and workers close (within 50 feet) to 

heavy equipment could be exposed to noise levels as 

high as 100 decibels for short periods of time. The 

period of construction would be at least twice as long 

as under the no-action alternative. 

Additional noise from rehabilitation of buildings on the 

south side would occur. Given that noise levels are 

currently quite low, even this additional construction 

noise could have major short-term impacts. 

Cumulative Impacts. No cumulative impacts (beyond 

those described for the no-action alternative) are 

expected. 

Conclusions. Long-term increases in noise are 

expected to be negligible; however, noise during 

construction may be severe on a short-term basis. 

These impacts would continue at least twice as long 

under alternative 2 as under no action. No impairment 

of park wildlife or visitor experience would occur as a 

result of noise. 

HAZARDOUS MATERIALS

Impacts from exposure to hazardous materials would 

be the same as those described under alternative 2. 

These include excavation activities on both Ellis Island 

and in Liberty State Park to build new landings, access 

roads, and parking areas and to install underground 

utilities and/or potable (drinking) water lines to the 

rehabilitated buildings on the south side. Although 

subsurface disturbance for the roads would be limited 
Impacts of Alternative 3: Ellis Island Institute with Overnight Accommodations (Preferred Alternative) 

FINAL ENVIRONMENTAL IMPACT STATEMENT 137

to the upper 3 feet of soil, the potential exists for 

exposure to organic compounds and heavy metals, 

as described in the “Affected Environment” 

chapter. 

Because this environmental impact statement 

analysis is programmatic for the building of the 

permanent bridge, future site-specific NEPA 

analysis would need to develop specific mitigation 

measures to protect workers and visitors from the 

health effects of these contaminants. In addition to 

protective clothing, mitigation could include 

subsurface investigations prior to construction in all 

areas of proposed disturbance to characterize 

potential contaminants; containment of the material 

in a separate area prior to disposal to prevent 

surface water contamination; protection of workers 

potentially exposed via skin contact or respiratory 

contact to contaminants through the use of personal 

protective equipment, in accordance with New 

Jersey Division of Parks and Forestry procedures; 

and best management practices, including covering 

exposed soils during construction. With these 

measures in place, impacts to workers would be 

minor to moderate. Visitors would likely be kept 

away from the site during construction. 

Following the completion of construction, the clean 

fill cap method of encapsulating contaminated fill 

would likely be used to eliminate exposure. 

Removal of the temporary bridge and construction 

of a new bridge would also disturb marine 

sediments and result in increased suspension of 

organics and metals contained in those sediments. 

Vacant and stabilized buildings would be 

rehabilitated to be generally suitable for a range of 

day uses. To get to that point, asbestos abatement 

and removal of lead-based paint would occur to the 

extent required to make the buildings safe. Workers 

conducting the removal would be well trained and 

would take all necessary precautions to protect 

themselves and to properly contain and dispose of 

these materials so as to prevent airborne exposure 

to these materials. Impacts would, therefore, be 

negligible. 

Cumulative Impacts. No cumulative effects 

beyond those described under the no-action 

alternative are anticipated. 

Conclusions. Workers could likely encounter 

contaminated soils during construction of landings 

and access roads for the permanent bridge. If a 

mitigation plan is put into place and followed, impacts 

would be moderate. Encapsulating contaminated fill 

following construction could eliminate the risk of 

exposure in the long-term. Construction activities could 

also suspend organics and heavy metals in marine 

sediments, resulting in minor to moderate impacts to 

surface water from contamination. These would fall to 

negligible shortly after construction is complete. 

Asbestos and lead-paint removal would eliminate risk 

of exposure to visitors, and with the use of standard 

precautions, would pose a negligible risk to workers. 

No impairment of park resources would occur. 

SOCIAL AND 

ECONOMIC ENVIRONMENT 

TOURISM

Without significantly increasing the number of visitors, 

alternative 3 would increase the number and type of 

attractions and activities on the island to attract visitors 

who otherwise might not visit Ellis Island. As 

discussed under alternative 2, the reuse of the existing 

buildings is designed to preserve and enhance the 

island’s cultural history and resources while 

strengthening Ellis Island’s economic selfsustainability through increased revenue. Alternative 3 

would provide for a variety of uses of rehabilitated 

structures (see alternative 2 for additional detail on 

impacts to tourism). The additional opportunities 

proposed under alternative 3 would likely provide a 

critical mass of visitor attractions to encourage an 

increase in nearby overnight stays. 

Extended programming and activities offered under 

alternative 3 would result in a minor benefit to tourism 

in increased visitorship to and around Ellis Island, as 

well as increased demand for lodging in the New 

Jersey / New York area. Alternative 2 would provide 

similar benefits, while the no-action alternative predicts 

a smaller increase in visitorship to the island with no 

concomitant increase in lodging demand. 

PARK ADMINISTRATION

Under alternative 3, it is anticipated that additional 

National Park Service and vendor employees would be 

required for administration and coordination of the 

south side activities. As under alternative 2, the 

construction of the permanent bridge would allow 

continued vehicular access for emergency service 

personnel (fire, police, ambulance) to Ellis Island, as 
ENVIRONMENTAL CONSEQUENCES

138 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND 

well as an expeditious pedestrian evacuation route 

should the need arise (see alternative 2 for 

additional detail on impacts to park administration). 

When compared to lengthy emergency response 

times and lack of a pedestrian evacuation route 

predicted under the no-action alternative, 

alternative 3 provides a benefit of unknown 

intensity, possibly major, to park administration, 

similar to that under alternative 2. The convenience 

the bridge offers regarding nonemergency access is 

considered a minor benefit to park administration, 

one that would not be available under the no-action 

alternative. 

Cumulative Impacts. Under alternative 3, tourism 

could experience a positive cumulative benefit, 

with a potential increased demand for lodging in 

areas surrounding Ellis Island as a result of the 

expanded cultural programming and activities 

proposed under this alternative. 

Conclusions. Extended programming and 

activities, including conference and retreat facilities 

offered under alternative 3, could result in a minor 

benefit to tourism in increased visitorship to and 

around Ellis Island, as well as increased demand for 

lodging in the New Jersey / New York area. When 

compared to lengthy emergency response times and 

lack of a pedestrian evacuation route predicted 

under the no-action alternative, alternative 3 

provides a benefit of unknown intensity, possibly 

major, to park administration. The convenience the 

bridge offers for nonemergency access is 

considered a minor benefit to park administration. 

No impairment of park resources would occur. 

TRANSPORTATION 

AND CIRCULATION 

ACCESS TO ELLIS ISLAND

The level of impacts to Ellis Island access during 

removal of the temporary service bridge would be 

the same as under alternative 2, and would depend 

on the sequencing of removing the temporary 

bridge and building a permanent one. If a new 

bridge is built before the temporary bridge is 

removed, no more than negligible impacts related 

to the presence of construction vehicles and staging 

areas are expected. However, if the temporary 

bridge is removed first, moderate impacts for the 

length of the construction period are possible. 

Compared to no action, these impacts would be 

beneficial. 

ACCESS TO FERRY TERMINALS

No impacts to public transportation to access ferry 

terminals is expected. 

PARKING

Impacts to parking would be similar to alternative 2, 

although 250 guests would be able to stay overnight at 

Ellis Island. Assuming these are not visitors who would 

also participate in special day events, and so are 

additive in their impacts, an additional approximately 

20 cars could require parking in Liberty State Park. 

Given current and future projected conditions in some 

of the lots at the state park, and in particular lot 6, the 

addition of 70 cars (or a 7.8% increase over the 

existing 900 spots in the lot) would result in minor 

impacts. It is unlikely the additional cars could be 

accommodated on busy summer days, and the cars may 

need to be directed to more distant lots in the state park 

or use lots outside the park. Visitors may have to rely 

on buses. As noted in the “Affected Environment” 

chapter, no regular transit service currently exists 

between the West Side Avenue park-and-ride lot in 

Jersey City and the ferry terminal inside Liberty State 

Park. If the New Jersey Transit Authority continues to 

allow the use of its light rail parking lot for overflow 

parking on crowded days, no impact to existing parking 

facilities in the study area is expected. 

CIRCULATION

Impacts to circulation from this alternative are 

expected to be indistinguishable from those in 

alternative 2. Although some increase in traffic 

attributable to increased visitors driving to ferry 

terminals is likely, compared to existing conditions or 

no action, the changes would barely be detectable. 

Cumulative Impacts. No cumulative impacts beyond 

those described under the no-action alternative are 

anticipated. 

Conclusions. Negligible to moderate short-term 

impacts to access for staff and delivery vehicles could 

result from bridge removal and reconstruction. 

Compared to no action, the impact would be relatively 

beneficial because it would only be temporary. Minor 

impacts to parking in Liberty State Park could occur 
Impacts of Alternative 3: Ellis Island Institute with Overnight Accommodations (Preferred Alternative) 

FINAL ENVIRONMENTAL IMPACT STATEMENT 139

from increases in visitation expected from this 

alternative compared to no action. These impacts 

would be slightly worse than under alternative 2. 

Undetectable to negligible impacts to levels of 

service at intersections in the area are attributable to 

increased visitation resulting from alternative 3. No 

impairment of park resources would occur. 

VISITOR EXPERIENCE

Alternative 3 proposes many of the same types of 

enhanced interpretive / cultural / educational visitor 

options as does alternative 2. Under all alternatives, 

access to Ellis Island for the public would continue 

to be provided via existing ferry service (see 

alternative 2 for more detail on uses proposed under 

both alternatives 2 and 3). 

Unique to alternative 3 are a proposed small retreat 

/ conference facility with overnight lodging, a 

policy research center, and administrative and study 

spaces. Ellis Island would provide an exceptional 

setting for meetings, workshops, and symposia on a 

wide range of national and international issues. 

These topics might include the history and meaning 

of Ellis Island as a gateway to the United States and 

as an important location in the history of public 

health. Potential activities could include academic 

retreats, "think-tank" policy meetings, training 

programs, and family reunions. The anticipated 

meeting size for the retreat would range up to 300 

persons. 

In conjunction with the conference facility, 

alternative 3 proposes the provision of a maximum 

of 250 overnight guestrooms on Ellis Island. 

Lodging and dining could take a number of forms, 

depending on the overall facility design. The 

visitor's overnight experience would not only evoke 

the immigrants' experience but would also provide 

a contemporary experience in affirmation of their 

legacy. Nighttime experiences would be pleasant, 

with city and harbor views dominating. No other 

land site provides such proximate and dramatic 

perspectives of the Statue of Liberty. 

As with alternative 2, visitor flow and use patterns 

would be expanded under this alternative, with 

significantly increased access to the structures, 

landscapes, and spaces of Ellis Island (see 

alternative 2 for detail). This increased access is 

considered a significant benefit over the limited 

access expected under the no-action alternative. 

Cumulative Impacts. The multi-year efforts of 

historic structure / landscape rehabilitation would 

provide cumulative benefits to visitor experience 

through the ever-increasing (at least for the first 10 to 

20 years) access to areas of Ellis Island from which the 

public is currently restricted. As restored structures and 

landscapes are opened to visitors, so too are associated 

interpretive exhibits and displays that will increase 

visitor options and experiences over time. Similar 

cumulative benefits are expected under alternative 2; 

comparatively, the no-action alternative would offer no 

such benefits. 

Conclusions. The combination of significantly 

increased visitor access to the majority of Ellis Island, 

the expansion of interpretive offerings, and the 

provision of a conference facility with overnight 

lodging under alternative 3 would result in a major 

benefit to the visitor experience at Ellis Island. With 

the exception of overnight lodging accommodations, 

similar benefits to visitor experience are expected 

under alternative 2. When compared to the no-action 

alternative, where both access and interpretive 

offerings are limited, alternative 3 would provide a 

significantly more enhanced visitor experience. 

ELLIS ISLAND INFRASTRUCTURE

The main utility connections provided to Ellis Island as 

part of the prior renovations are adequate to service all 

of the buildings on Ellis Island under alternative 3. As 

such, the need to install new submarine utilities 

beneath the Hudson River is not anticipated (refer to 

alternative 2 for more detail on impacts related to 

utility improvements). 

The upgrading and improvement of utilities proposed 

under alternative 3 are considered moderate benefits to 

the Ellis Island infrastructure and would complement 

the rehabilitation efforts of historic structures proposed 

for reuse under these alternatives. Alternative 2 would 

result in similar benefits. 

Cumulative Impacts. Under alternative 3, existing 

utilities would be upgraded and improved to facilitate 

the rehabilitation of historic structures on Ellis Island. 

These actions are expected to result in cumulative 

benefits to the utility infrastructure of the island. 

Conclusions. The upgrading and improvement of 

utilities proposed under alternative 3 are considered 

moderate benefits to the Ellis Island infrastructure and 

would complement the rehabilitation efforts of historic 

structures proposed for reuse under these alternatives. 
140 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

SECTIONS REQUIRED UNDER THE NATIONAL ENVIRONMENTAL POLICY ACT

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

The National Environmental Policy Act requires 

agencies to consider irretrievable (short-term or 

reversible) and irreversible (long-term or 

permanent) commitments of resources from 

proposed actions. In this alternative, the National 

Park Service would make an irreversible 

commitment of staff, money, and time to 

rehabilitate the deteriorating 30 buildings that 

contribute to the overall cultural landscape of the 

island. The expected cost of rehabilitating 

structures not associated with the institute or 

conference facility is over $50 million, and the 

conference facility itself would require an estimated 

$100 million in private investments; this does not 

include annual operating and maintenance costs. In 

return, the nation would experience major benefits 

from restoring the integrity of these very significant 

structures and the Ellis Island cultural landscape, 

including the chance to study, research, and relax 

overnight at this significant landmark. 

LOSS IN LONG-TERM AVAILABILITY 

OR PRODUCTIVITY OF THE 

RESOURCES TO ACHIEVE SHORTTERM GAIN 

No losses in long-term availability or productivity 

of resources would be realized to achieve a shortterm gain under alternative 3. In fact, the focus of 

this alternative is long-term gain or productivity of 

the site. 

UNAVOIDABLE ADVERSE IMPACTS 

Small losses of soil are expected from grading for 

construction. Disturbance to marine sediments and 

associated increases in turbidity and impacts on 

aquatic life are expected during removal of the 

temporary service bridge and construction of a new 

permanent bridge. The sediments may temporarily 

suspend heavy metals, organics, or other toxins. 

The concentrations of these chemicals may be quite 

high in areas contained by cofferdams. Replanting 

the courtyards associated with buildings that are 

slated for rehabilitation could adversely effect or 

eliminate patches of two state protected plant 

species. Long-term increases in noise are expected 

to be negligible; however, noise during construction 

may be severe on a short-term basis and have 

adverse effects on visitors and wildlife. The 

Savannah sparrow, a state protected species and 

year-round resident of Liberty State Park, could 

experience additional minor long-term effects from 

removing habitat and the presence of traffic 

accessing a landing site in Liberty State Park. 

Wildlife may experience additional adverse impacts 

from the presence of humans and lighting 24 hours 

a day on the island. Groundwater dewatering or 

contamination is a possible outcome if building a 

landing requires pumping of an aquifer to reduce 

the water table. In addition to the mobilization of 

toxins in marine sediments, locating a bridge 

landing in Liberty State Park could involve digging 

in soils contaminated with chromium and other 

dangerous toxins. A mitigation plan could reduce 

impacts to workers and visitors from this activity. 

Minor impacts to parking availability at Liberty 

State Park are expected from increases in visitation. 
Consultation 

and Coordination
FINAL ENVIRONMENTAL IMPACT STATEMENT 143 

HISTORY OF PUBLIC INVOLVEMENT

SCOPING PROCESS 

AND PUBLIC MEETINGS 

The National Park Service retained an independent 

consultant to assist the agency in preparing this 

Development Concept Plan / Environmental Impact 

Statement. Background data were collected, 

applicable agencies were contacted, issues and 

regulatory requirements were identified, and 

alternatives were screened by the consultant and NPS 

staff specialists. Together, these staff formed an 

interdisciplinary team. The team relied upon much of 

the information contained in the 1995 Statue of 

Liberty and Ellis Island–Ellis Island Bridge and 

Access Alternatives Draft Environmental Impact 

Statement (unreleased) by Goodkind & O’Dea, Inc. 

(NPS 1995a). Since the preparation of that draft 

environmental impact statement, the events of 

September 11, 2001, occurred, solidifying the need 

for a permanent, controlled vehicular access bridge to 

Ellis Island. 

In 1999 a consultant was retained to prepare the 

Market and Financial Feasibility Analysis of the 

Preservation and Reuse of Ellis Island’s South Side 

and Baggage and Dormitory Buildings (see 

“Appendix C: Analysis of Relative Financial 

Feasibility and Economic Sustainability of EIS 

Alternatives”). Information workshops to discuss this 

project with a variety of stakeholders were held in 

1999 and 2000. 

PUBLIC SCOPING FORUMS

The National Park Service hosted three public 

meetings to discuss the preservation and reuse of the 

south-side buildings. These public scoping forums 

were held in December 2000 in Trenton, Manhattan, 

and on Ellis Island. In addition, the National Park 

Service hosted an Ellis Island Development Concept 

Plan / Environmental Impact Statement Alternatives 

Analysis Workshop on February 28, 2002, at NPS 

offices in New York City. The organizations in 

attendance at the workshop included the National 

Park Service and New York and New Jersey State 

Historic Preservation Office representatives. 

The following entities publicly expressed support for 

the preservation and reuse of Ellis Island during the 

December 2000 scoping sessions: New Jersey 

General Assembly, City of Jersey City, Liberty 

Science Center, New Jersey State Historic 

Preservation Officer, Governor’s Advisory 

Committee on the Preservation and Use of Ellis 

Island, Preservation New Jersey, New York 

Landmarks Conservancy, Liberty State Park 

Development Corporation, and the New Jersey 

Department of Health. 

The issues and concerns arising from the public 

scoping forums are summarized below. Additional 

information is available in appendix A. 

New Jersey General Assembly — The assembly 

issued a resolution urging the National Park Service 

to include a permanent pedestrian or public access 

bridge between Liberty State Park and Ellis Island in 

the restoration plans. Both action alternatives include 

a bridge, but not for pedestrian or general public 

access. 

Jersey City Director of Economic Development — 

The director issued a statement encouraging a 

thorough study that addresses access issues and 

provides a market and financial sustainability 

analysis. As noted above, a market and financial 

feasibility analysis (appendix C) of reuse options was 

performed prior to preparation of this environmental 

impact statement. 

Liberty Science Center — The president and chief 

operating officer of the center presented written 

comments in support of the reuse of structures on 

Ellis Island. Ellis Island’s role as completing a major 

cultural attraction with the Statue of Liberty, Liberty 

State Park, and Liberty Science Center was stressed. 

Flooding, and particularly threats of tidal surge, were 

identified for consideration in the planning process. 

New Jersey State Historic Preservation Officer — 

The state historic preservation officer presented 

comments on behalf of the governor and the 

Advisory Committee on the Preservation and Use of 

Ellis Island in support of reuse. Topics of concern 

included preservation and stabilization, honoring 

history, affordable access, economic selfsustainability, rehabilitation rather than restoration, 

recognition of public health, and use as an 

international or regional history conference center. 

These concerns are addressed in the range of 

alternatives. 
CONSULTATION AND COORDINATION

144 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Preservation New Jersey — A member of this 

organization presented testimony in support of the 

stabilization efforts for protection of the resources on 

Ellis Island. 

New York Landmarks Conservancy — A member of 

the conservancy presented a statement supporting the 

stabilization efforts. Topics of concern included 

historic preservation with no demolition and minimal 

new construction, economic feasibility, excellence in 

design, transportation study, and accurate cost 

estimates. 

Liberty State Park Development Corporation — A 

representative from the corporation voiced support 

for the Governor’s Advisory Committee. Comments 

focused on transportation (access/parking/transit) and 

bridge issues. A suggestion was made to link the 

development and history of the CRRNJ Terminal and 

Liberty State Park with Ellis Island. 

New Jersey Department of Health — The department 

presented comments regarding the unique role of 

Ellis Island in the history of public health and 

suggested that reuse plans consider the development 

of a Public Health Learning Center that would 

provide a national venue on the history of health care. 

Other general public comments suggested that a 

Center for Immigrant Contributions be developed on 

Ellis Island. The need for inclusion of Section 106 

and Section 4(f) in the environmental impact 

statement was raised. Commenters indicated that the 

institutional architecture of south-side buildings 

should be restored to preserve the immigrant history 

without over-emphasizing the “darker side.” The 

National Park Service is documenting the progress of 

stabilization efforts and chronicling an oral history. 

Commenters noted that the issuance of a Request for 

Proposals (RFP) for the rehabilitation of Ellis Island 

should ensure that interested parties embrace 

preservation qualities. Using the RFP process, the 

National Park Service would solicit a development 

partner to finance, develop, and manage a small 

conference facility with overnight accommodations. 

In selecting a development partner, National Park 

Service would give preference to the smallest (as in 

the number of overnight rooms), most economically 

feasible proposal that meets the park’s goals, and that 

best supports the mission and operation of the nonprofit institute. 

ALTERNATIVES ANALYSIS WORKSHOP

As noted above, on February 28, 2002, the National 

Park Service held an internal alternatives analysis 

workshop that provided a venue for interested 

individuals, agencies, businesses, and organizations 

to learn about the proposed alternatives, offer ideas 

and suggestions, and voice concerns about various 

aspects of the proposed alternatives. Concerns 

surrounding each alternative are summarized below. 

Alternative 1 

No action — There is concern that under this 

alternative stabilization would only last for 10 to 

15 years, and no annual maintenance funds would be 

allocated. Therefore, the process of deterioration 

would continue as soon as stabilization work was 

completed. By definition, the stabilization only slows 

the deterioration process. Perpetual stabilization is 

not an option. In time, resources would be 

permanently lost. 

Loss of resources — The irreversible loss of 

resources is of primary concern. Economically, no 

funding is available for another round of 

stabilization. The controlled removal of asbestos and 

lead would be required as buildings deteriorate or are 

left unabated. Re-stabilization would ultimately 

increase the cost of any other action or alternative 

that would be undertaken in the next 10 to 15 years 

due to the delay in permanently addressing historic 

resources. Operating costs to maintain the buildings 

also increase the overall cost. After 10 to 15 years the 

investment for stabilization would be lost along with 

the historic resources. Although no funds would be 

needed to maintain a vacant island, environmental 

and safety hazards, such as fire, may result. 

Therefore, removal of the buildings must be 

considered. Deterioration of the Baggage and 

Dormitory Building is a safety risk and a visual 

detriment to visitor experience due to its prominent 

location near the renovated buildings. 

The loss of the historic resources may be potentially 

mitigated by means of building documentation, 

interpretive programs, and displays. If the proposed 

building uses are deemed undesirable or disrespectful 

to the Ellis Island history, deterioration of the 

resources may be the preference of some individuals. 

With respect to archeological concerns, there would 

be no disturbance to potentially significant historical 

resources below the surface. 
History of Public Involvement

FINAL ENVIRONMENTAL IMPACT STATEMENT 145 

The loss of the bridge would result in increased 

safety and security concerns due to the inability to 

transport visitors and employees off Ellis Island 

during natural disasters, medical emergencies, or 

other circumstances requiring evacuation. 

Alternative 2 

Loss of historic resources — Although stabilization, 

rehabilitation, and reuse actions are preferred, minor 

demolition and new construction could be viable 

options as part of renovation efforts. Although 

historic archeological resources could be damaged, 

the reuse should result in overall positive effects with 

little or no adverse effects. Potential adverse effects 

on landscape could occur during rehabilitation. 

Sunken ferry — Disposition of the sunken ferry in the 

slip remains unresolved. Recent underwater 

documentation of the structure has determined that it 

is substantially deteriorated and raising it is not 

feasible or appropriate. The mostly submerged sides 

of the ferry will likely collapse outward in a more 

prone position upon the bottom as the remaining 

cross-timbers deteriorate further. For the time being, 

the ferry remains an impediment to boat access at the 

western end of the ferry slip and precludes water 

access to the Ferry Building. 

Visitor access - The number of ferry trips would not 

increase dramatically. Pedestrian use of a new service 

bridge was dismissed because of security concerns 

that dictate limiting the number of access points to 

the island, undesirable visitor experience due to lack 

of historical perspective and interpretive 

opportunities, and the lack of parking available at 

Liberty State Park. Mitigation of environmental 

justice and free access issues may be addressed with 

“free visitation days” or “free access times” during 

regular visiting hours. 

Alternative 3 

The issues and concerns raised with respect to 

alternative 2 are also applicable to alternative 3. The 

only additional concern related to alternative 3 is the 

access to certain areas of Ellis Island outside of the 

normal visitor hours, because of the overnight 

accommodations. 

Access to Ellis Island has been a controversial issue 

for over a decade. On one side of the access issue, 

Jersey City and many other local jurisdictions in New 

Jersey have called for pedestrian access from Liberty 

State Park. The need for pedestrian access is driven 

by the desire to have “affordable” access to the 

island. The cost of ferry service prevents some lowand moderate-income people from visiting the island. 

Other access-related issues include the frequency of 

ferry service and the large number of visitors who 

want to come to the island. On the other side of the 

access issue is the preservation community that sees 

the bridge as an intrusion on the park’s historic scene 

and is calling for its removal. This perspective 

considers continued arrival by ferry as the only 

appropriate means of visitor access to Ellis Island. 

The events of September 11, 2001, have further 

complicated the access issue by highlighting the need 

for secure access to and from Ellis Island and the 

importance of a direct-access route for emergency 

response and evacuation. 

Concern was expressed regarding the need for review 

and approval of the rehabilitation work to be 

undertaken by the private development partner, and 

specifically the role of the State Historic Preservation 

Offices in this process. It was suggested that this 

Development Concept Plan / Environmental Impact 

Statement include a specific programmatic agreement 

between the National Park Service and the New York 

and New Jersey State Historic Preservation Officers 

setting out, in detail, their consultation and approval 

role throughout the rehabilitation process. A draft 

programmatic agreement is contained in appendix D. 

Environmentally sustainable materials should be 

considered in new bridge design. 

DISTRIBUTION OF THE 

DEVELOPMENT CONCEPT PLAN / 

DRAFT ENVIRONMENTAL 

IMPACT STATEMENT 

The release of the Development Concept Plan / Draft 

Environmental Impact Statement in June 2003, and 

publication of the Notice of Availability in the 

Federal Register on June 25, 2003 began a 60-day 

review period on the draft document. During that 

review period, the National Park Service held two 

public meetings to provide agencies and the public an 

additional opportunity to comment on the draft 

document. 

The first public meeting was held on July 24, 2003, at 

Federal Hall in Manhattan and was attended by 

14 people. The second meeting was held on July 28, 
CONSULTATION AND COORDINATION

146 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

2003, at Jersey City University in Jersey City, New 

Jersey; it was attended by 38 people. 

During the public comment period on the draft 

document, comments were received in the form of 

letters, cards, and emails. Written and verbal 

comments were submitted at the public meetings. 

PUBLIC NOTIFICATION 

To announce the scoping process and the public 

comment period for the Development Concept Plan / 

Draft Environmental Impact Statement, the National 

Park Service followed its policies and procedures for 

public notification concerning this planning effort. 

The National Park Service and the Environmental 

Protection Agency published a Notice of Intent in the 

Federal Register to prepare the environmental impact 

statement and then a Notice of Availability when the 

draft document was released for public review in 

May 2003. Additionally, letters were sent to the New 

York and New Jersey State Historic Preservation 

Officers, as well as the Advisory Council on Historic 

Preservation. Press releases or articles were published 

in local and regional newspapers. These publications 

include The New York Times, Newark Star Ledger, 

and the Jersey Journal. The executive summaries for 

the Development Concept Plan / Draft and Final 

Environmental Impact Statements have been posted 

on the park’s website (http://www.nps.gov/stli), and 

the draft and final documents are available in their 

entirety on the NPS planning website 

(http://www.planning.nps.gov). The National Park 

Service will brief area elected officials and 

stakeholders upon request to the superintendent. 

AGENCIES AND 

ORGANIZATIONS PARTICIPATING 

DURING THE SCOPING PROCESS 

Advisory Council on Historic Preservation 

Advocates for New Jersey History 

Aramark, Inc. 

Battery Park City Broadsheet 

Circle Line Statue of Liberty-Ellis Island Ferry, Inc. 

Guides Association of New York 

Jersey City Office of Economic Development 

Liberty Science Center 

Liberty Sate Park 

Liberty State Park Development Corporation 

New Jersey Department of Environmental ProtectionNatural Heritage Program 

New York Landmarks Conservancy 

Preservation New Jersey 

Save Ellis Island Inc. 

U.S. Department of the Interior, Fish and Wildlife 

Service 

MAILING LIST 

Federal, state, and local government agencies; 

organizations; and special interest groups were 

notified by mail of the availability of the 

Development Concept Plan / Draft Environmental 

Impact Statement and, again, for this Final 

Environmental Impact Statement. During the course 

of agency consultations and numerous public 

meetings, the National Park Service tracked all 

contacts and also included individuals who requested 

they be on the mailing list, or requested a copy of the 

Development Concept Plan / Draft and Final 

Environmental Impact Statements. As noted earlier, 

the executive summaries for the Development 

Concept Plan / Draft and Final Environmental 

Impact Statements have been posted on the park’s 

website (http://www.nps.gov/stli), and the draft and 

final documents are available in their entirety on the 

NPS planning website 

(http://www.planning.nps.gov). 

FEDERAL AGENCIES

Advisory Council on Historic Preservation 

National Marine Fisheries Service 

National Trust for Historic Preservation 

U.S. Army Corps of Engineers, New York District 

U.S. Coast Guard 

U.S. Environmental Protection Agency 

U.S. Department of the Interior, Fish and Wildlife 

Service 

U.S. Department of Transportation, Federal Highway 

Administration 
History of Public Involvement

FINAL ENVIRONMENTAL IMPACT STATEMENT 147 

STATE OF NEW JERSEY

New Jersey Department of Commerce and Economic 

Development 

New Jersey Department of Environmental Protection 

 Division of Parks and Forestry 

 Historic Preservation Office 

 Land Use Regulation Program 

 Natural Heritage Program 

 Office of Coastal Planning and Program 

Coordination 

New Jersey Department of Parks and Recreation 

New Jersey Department of Transportation 

New Jersey Economic Development Authority 

New Jersey Transit 

STATE OF NEW YORK

Department of Economic Development 

Department of Environmental Conservation 

Department of Parks and Recreation 

Department of State 

Division of Tourism 

Department of Transportation 

Historic Preservation Office 

ELECTED OFFICIALS

Governor James McGreevy 

Governor George Pataki 

Senator John Corzine 

Senator Frank Lautenberg 

New York City Mayor Michael Bloomberg 

Jersey City Mayor Glenn Cunningham 

CITY AND COUNTY AGENCIES

Battery Park City Authority 

City of Jersey City 

Hudson County 

Hudson County Department of Engineering and 

Planning 

Jersey City Economic Development Commission 

Jersey City Traffic Department 

Manhattan Borough President’s Office 

New York City Convention and Visitor’s Bureau 

New York City Department of Consumer Affairs 

New York City Department of Environmental 

Protection 

New York City Department of Parks and Recreation 

New York City Department of Planning 

New York City Department of Transportation 

New York City Department of Transportation, 

Region 11 

Port Authority of New York and New Jersey 

Organizations and Special Interest Groups 

Advocates for New Jersey History 

American Institute of Architects 

 Historic Building Committee 

 New Jersey Preservation of Historic Resources 

Committee 

American Institute of Architects, New Jersey Chapter 

Coalition for Liberty State Park 

Community Board #1 of New York City 

Committee for the New York Bight 

Council on the Environment of New York 

Environmental Action Coalition 

Environmental Defense Fund 

Friends of Liberty State Park 

Guides Association of New York City 

Guides Association of New York State 

Hudson County Chamber of Commerce 

Hudson County Cultural Affairs 

Hudson County Planning and Economic 

Development 

Hudson River Waterfront Conservancy 

Jersey City Historical Society 
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148 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

League of Women Voters for New York City 

Liberty Park Guardian Association 

Liberty Science Center 

Liberty State Park Commission 

Liberty State Park Development Corporation 

Lower Manhattan Cultural Council 

Maritime Association 

Meadowlands Regional Chamber of Commerce 

New Jersey Chamber of Commerce 

New Jersey Historical Society 

New Jersey Landmarks Conservancy 

New Jersey League of Historic Societies 

New Jersey Municipal Arts Society 

New York City Audubon Society 

New York City Chamber of Commerce 

New York City Downtown Alliance 

New York City Economic Development Corporation 

New York City Landmarks Preservation Commission 

New York City Office of Economic Development 

New York Historical Society 

New York Landmarks Conservancy 

New York League of Conservation Voters 

New York Municipal Arts Society 

Parks Council 

Preservation New Jersey 

Regional Plan Association 

Save Ellis Island Inc. 

Sierra Club (New York and New Jersey chapters) 

Statue of Liberty/Ellis Island Foundation 

LIST OF PREPARERS 

AND CONTRIBUTORS 

NATIONAL PARK SERVICE

Diane Dayson, advisor on park management and 

operations during planning 

BA, American History & Early Secondary 

Education, State University of New York at 

Cortland 

MA, Public Administration, New York 

University's Wagner School of Public Service 

28 years of experience in NPS park operations 

and administration 

Cynthia Garrett, advisor on park planning, operations 

and management, contributing author and editor 

BA, Art & Architectural History, Columbia 

University’s Barnard College 

MA, Urban & Regional Planning, George 

Washington University’s School of Government 

& Business Administration 

25 years experience in federal public planning 

and administration 

Robert McIntosh, northeast regional principal advisor 

on park planning and compliance 

BA, Biology, Springfield College 

MS, Forest Management, University of 

Massachusetts at Amherst 

35 years of park management, planning, and 

compliance experience 

Tom Dyer, project manager for the Development 

Concept Plan / Environmental Impact Statement, 

contributing author and editor 

BS, Landscape Architecture, Pennsylvania State 

University 

MA, Landscape Architecture, Harvard 

University’s Graduate School of Design 

25 years state and federal experience in planning 

design and development 

Diana Pardue, Park advisor on cultural resources and 

museum collection, contributing author, draft 

programmatic agreement 

BA, History, University of Kentucky 

26 years federal experience with curatorial 

resources 

William A. Griswold, northeast regional advisor on 

archeology resources, contributing author 
History of Public Involvement

FINAL ENVIRONMENTAL IMPACT STATEMENT 149 

BA, Archeology, Southwest Missouri University 

AM, Archeology, Harvard University 

Ph.D., Archeology, Harvard University 

12 years experience in historical archeology (10 

years with the National Park Service) 

John Maounis, northeast regional advisor on cultural 

resource management and compliance 

BA, English Literature, University of California 

MA, Library and Archival Studies, University of 

California 

26 years experience with museum, curatorial, 

and cultural resource stewardship 

David Uschold, advisor on cultural landscape 

preservation, contributing author 

BA, Landscape Architecture, State University of 

New York’s College of Environmental Science 

and Forestry 

Associate in Architecture, State University of 

New York 

MA, Landscape Architecture and Historic 

Preservation, State University of New York 

9 years experience with the NPS Olmstead 

Center for Landscape Preservation 

Paul Weinbaum, northeast regional advisor on 

section 106 compliance, contributing author, draft 

programmatic agreement 

BA, History, City College of New York 

Ph.D., History, University of Rochester 

22 years as NPS historian, plus 8 years 

experience as historic site curator 

BEYER BLINDER BELLE 

ARCHITECTS & PLANNERS LLP 

Timothy Macy, project manager, contributing author, 

management of consultant team 

BS, English and Environmental Design 

MA, American Literature 

BARCH, Architecture 

Years of Experience: 8 

James W. Rhodes, advisor on architectural 

preservation 

BARCH, Architecture 

Years of Experience: 36 

ROBERT SILMAN ASSOCIATES

John Matteo, contributing author; structural systems 

analysis 

BS, Civil Engineering 

BA, Art and Architectural History 

MS, Structural Engineering 

Years of Experience: 10 

DEWBERRY-GOODKIND, INC.

Ileana Ivanciu, task manager for hazardous waste, 

socioeconomics, traffic, M/E/P, natural resources 

BS, Geology and Geophysics 

MS, Geology and Geophysics 

Years of Experience: 22 

Anthony Lee, deputy task manager, socioeconomics 

MRP, Land Use and Environmental Planning 

BS, Urban and Regional Studies 

Years of Experience: 14 

Stanley Mast, QA/QC socioeconomics, traffic, 

M/E/P, natural resources 

BS, Civil Engineering 

MS, Civil Engineering 

Years of Experience: 50
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150 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

SEDWAY GROUP

Terry Margerum, director, economic financial 

viability study 

BS, Economics 

MBA 

Years of Experience: 25 

Kurt Fuchs, financial / economic feasibility 

BA, Economics 

Years of Experience: 13 

Naomi Porat, co-director, economic financial 

viability study 

MBA, Masters of Business Administration 

MRCP, Masters in City and Regional Planning 

BA, Community and Social Development 

Years of Experience: 17 
FINAL ENVIRONMENTAL IMPACT STATEMENT 151 

COMMENTS ON THE DEVELOPMENT CONCEPT PLAN 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

AND 

NATIONAL PARK SERVICE RESPONSES TO COMMENTS 

COMMENTS AND RESPONSES 

As noted earlier in this chapter, during the public comment period on the Development Concept Plan / Draft 

Environmental Impact Statement, comments were received in the form of letters, cards, and emails. Written and 

verbal comments were submitted at the two public meetings. 

Each page of each comment letter, card, or email, or transcript of verbal testimony has been reprinted in this 

section. Substantive comments, which are those questioning or commenting on a point of fact (rather than stating 

an opinion in favor of or against the project), have been responded to by the National Park Service on the facing 

page. If verbal testimony duplicates written comments (some commenters read their letter into the record at one 

of the public hearings), responses were made to the written comments only. 
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152 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 1
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 153 

Response to Comment Letter No. 1 

U.S. Environmental Protection Agency 

1a The National Park Service (NPS) intends to prepare a future National Environmental Policy Act (NEPA) 

document to analyze options for the placement of a permanent service bridge. The impacts from the 

bridge construction and landings would be presented in much greater depth than they are in this 

Development Concept Plan / Environmental Impact Statement because this Development Concept Plan / 

Environmental Impact Statement serves as a site-specific discussion of impacts from the rehabilitation of 

the buildings on Ellis Island for use as a conference and retreat center as summarized in your letter. The 

NPS will of course, ask the U.S. Environmental Protection Agency to review any draft environmental 

impact statement (EIS) prepared in conjunction with new service bridge construction. 
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154 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 1 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 155 

Response to Comment Letter No. 1 (continued) 

U.S. Environmental Protection Agency (continued) 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

156 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 2
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 157 

Response to Comment Letter No. 2

New York State Office of Parks, Recreation and Historic Preservation 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

158 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 2 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 159 

Response to Comment Letter No. 2 (continued)

New York State Office of Parks, Recreation and Historic Preservation (continued) 

2a The general public visiting Ellis Island would arrive exclusively by ferry, and the NPS would encourage 

institute and retreat participants to also arrive and depart Ellis Island by ferry as much as possible. 

However, managed access via the service bridge would be provided to accommodate “drop-off” and 

“pick-up” service for attendees of scheduled functions sponsored by the institute and conference facility. 

The institute attendees would have substantially different access requirements than the general public in 

terms of frequency, ease, hours of operation, and duration. Such service would be scheduled and timed to 

accommodate particular functions occurring at the institute. 
CONSULTATION AND COORDINATION

160 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 3
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 161 

Response to Comment Letter No. 3

New Jersey Department of Environmental Protection 

3a Many factors combine to make restoring and rehabilitating the remaining unrestored structures on Ellis 

Island very costly; those factors include the advanced state of deterioration of many of the buildings; the 

NPS requirement for no significant demolition; the NPS requirement that all work comply with The 

Secretary of the Interior’s Standards for the Treatment of Historic Properties; the NPS requirement to not 

allow commercial office or retail uses; and the site’s remote island location in the New York Harbor. For 

these reasons, the NPS agrees that the restoration, rehabilitation, and operation of Ellis Island require a 

strategy that allows for multiple sources of funding including public funds, private investment, and 

conventional financing, in addition to philanthropic donations. The NPS believes that “Alternative 3: Ellis 

Island Institute with Overnight Accommodations (Preferred Alternative)” best enables accomplishment of 

this objective. 
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162 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 3 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 163 

Response to Comment Letter No. 3 (continued)

New Jersey Department of Environmental Protection (continued) 

3b The NPS will continue to work closely with Liberty State Park on several issues, including traffic and 

parking. Please see responses (number 14) to Friends of Liberty State Park below for more information. 

3c The NPS has initiated a comprehensive examination of transportation issues through a number of separate 

but coordinated planning efforts. Recently, revisions to the General Management Plans (GMP) have been 

simultaneously initiated for both the Statue of Liberty National Monument and Ellis Island and Governors 

Island National Monument. Transportation for visitors, staff, and operations will be examined, and 

opportunities for greater efficiency and enhanced visitor access will be explored. Landside security 

requirements will also be considered. On a larger scale, the NPS recently completed a comprehensive 

study that looked at opportunities to extend and enhance ferry access to NPS sites throughout the New 

York Harbor area. Recognizing the need to ensure access to its island sites, the NPS is currently studying 

various means of providing affordable ferry access for disadvantaged groups and individuals. 

3d As noted in the Draft Development Concept Plan / Environmental Impact Statement, the NPS intends to 

begin planning and compliance efforts for locating and mitigating the impacts of a permanent bridge in 

the near future. Many of the issues you raise, such as visitor use patterns, safety, and security would be 

part of this analysis. As noted above, the NPS will continue to work with Liberty State Park on all issues 

of mutual concern. 
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164 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 3 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 165 

Response to Comment Letter No. 3 (continued)

New Jersey Department of Environmental Protection (continued)

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

166 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 4
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 167 

Response to Comment Letter No. 4

New Jersey Department of Environmental Protection, 

Office of Permit Coordination and Environmental Review 

4a The NPS will include provisions in any Request for Proposals and in the agreement with a selected 

contractor to ensure that all areas that are appropriately left and/or managed as a “ruin–like” condition are 

clearly noted, including how such areas are to be managed and maintained. Similar provisions would be 

included in any lease or other agreement with future site tenants. 
CONSULTATION AND COORDINATION

168 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 4 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 169 

Response to Comment Letter No. 4 (continued)

New Jersey Department of Environmental Protection, 

Office of Permit Coordination and Environmental Review (continued) 

4b The preferred alternative (alternative 3) plan for Ellis Island would ensure public access for day-use 

visitors to all of the exterior grounds and to all interior spaces that have special interpretive significance. 

Because many of the south-side buildings were constructed as identical spaces serving identical functions 

(such as the isolation wards), general public access to all areas would not be required in order to interpret 

the architecture and history of the place. General access by day-use visitors may at times be restricted in 

certain areas of the retreat center where visitor presence would interfere with its intended function or 

operation, while most common areas, restaurants, and other amenities would be accessible to the general 

public. 

4c The Development Concept Plan / Environmental Impact Statement analyzes activities to the extent they 

have an environmental impact. After the National Park Service selects the alternative that it will 

implement as the Development Concept Plan, details that have no environmental impact will be fleshed 

out; such details include signage, which partner would occupy which building, and how landscaping 

described in the Development Concept Plan / Environmental Impact Statement would be carried out. NPS 

will maintain final authority on all proposed restoration and rehabilitation work to be performed by others. 

Design and treatment standards would be negotiated in advance of work being performed.

4d The NPS will be happy to include the New Jersey Division Fish and Wildlife, as appropriate, in plans for 

park educational and interpretive activities. 

4e Impacts to the Savannah sparrow are primarily related to substitution of the temporary service bridge with 

a permanent one and resulting construction noise (see page 122 of the Draft Development Concept Plan / 

Environmental Impact Statement). This kind of impact would not be helped by planting to improve habitat 

and would also be short term. However, if planning and environmental analysis associated with 

permanent bridge construction shows that the landing proposed under the preferred alternative is in 

Liberty State Park and in Savannah sparrow habitat, the NPS would like to work with the New Jersey 

Division of Fish and Wildlife to devise mitigation measures such as the plantings you recommend. 
CONSULTATION AND COORDINATION

170 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 4 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 171 

Response to Comment Letter No. 4 (continued)

New Jersey Department of Environmental Protection, 

Office of Permit Coordination and Environmental Review (continued) 

4f Thank you for the information on timing restrictions and planting recommendations. The NPS will 

incorporate these as part of our planning and compliance for the permanent bridge. 

4g Recreational fishing was not addressed because it is not permitted at Ellis Island. The purpose of the park, 

as established by presidential proclamation and as further described in the park’s mission and 

management policies, is primarily related to cultural resource protection and interpretation of the 

historical significance of Ellis Island. Recreational fishing off of Ellis Island’s seawall would be 

inconsistent with these purposes.

4h Comment noted. 

4i The NPS agrees with your assessment of the no-action alternative. This alternative is a required 

component of any environmental impact statement and is analyzed to provide comparative or baseline 

information. 

4j Alternative 2 was not selected as the preferred alternative, in part, because the NPS determined that the 

relatively greater number of different tenants occupying various buildings presented an increased potential 

for management and access conflicts. This alternative was also deemed to require more NPS management 

and involvement, resulting in higher staff and operational costs to the government. 
CONSULTATION AND COORDINATION

172 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 4 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 173 

Response to Comment Letter No. 4 (continued)

New Jersey Department of Environmental Protection, 

Office of Permit Coordination and Environmental Review (continued) 

4k The NPS has a long record of working with Liberty State Park on issues of mutual concern and is 

currently negotiating a short-term, and potentially long-term, solution with the staff of Liberty State Park 

on the matter of 24-hour access and a permanent security screening arrangement for vehicles traveling to 

Ellis Island through Liberty State Park. 

4l As noted in the preceding response, the National Park Service would continue to work closely with 

Liberty State Park and the Division of Forests and Parks to minimize any impact of a permanent bridge on 

the park. A future planning process, coupled with an environmental impact statement, would explore a 

range of alternatives for the design and location of the permanent bridge. The planning process would 

assess the impact of the bridge’s construction and use on Liberty State Park, including impacts on the 

operation, management, and use of Liberty State Park. 
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174 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 4 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 175 

Response to Comment Letter No. 4 (continued)

New Jersey Department of Environmental Protection, 

Office of Permit Coordination and Environmental Review (continued) 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

176 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 5
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 177 

Response to Comment Letter No. 5 

Glenn D. Cunningham – Mayor, City of Jersey City 

5a The NPS regrets that you disagree with this basic requirement of our security program to protect the 

Statue of Liberty and Ellis Island. Since the events of September 11, 2001, the NPS has sought the advice 

and expertise of both public and private security experts and has used these consultants to develop and 

implement a comprehensive security strategy. Limiting entry points is integral to this strategy. As 

explained on page 41 in the Draft Development Concept Plan / Environmental Impact Statement, the park 

has implemented a number of measures to ensure human and property safety on the island. Recognizing 

that the cost of the ferry may be an economic hardship for certain groups and individuals traveling from 

both New Jersey and New York, the park is currently exploring various means of providing targeted 

affordable ferry access and expects to initiate a pilot program. 
CONSULTATION AND COORDINATION

178 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 5 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 179 

Response to Comment Letter No. 5 (continued)

Glenn D. Cunningham – Mayor, City of Jersey City (continued) 

 See Response to “5a” on page 177. 
CONSULTATION AND COORDINATION

180 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 6 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 181 

Response to Comment Letter No. 6 

National Trust for Historic Preservation 

6a See response “4b” to New Jersey Department of Environmental Protection, Office of Permit Coordination 

and Environmental Review. 

6b As noted on page 30 of the Draft Development Concept Plan / Environmental Impact Statement, the NPS 

has determined that a limited access permanent bridge to Ellis Island is critical to providing for human 

safety and the rehabilitation, maintenance, and protection of the island’s historic structures. Given that a 

permanent service bridge would be needed, in any case, for evacuation, ambulances, and other vehicles to 

respond to potential emergency situations, it seems practical and reasonable to use it for other 

construction, maintenance, and operational uses. It is not feasible or advisable to have a fire brigade on 

Ellis Island. All general public visiting Ellis Island would continue to arrive and depart by ferry. 

Pedestrian visitor use of the bridge would not be permitted. 
CONSULTATION AND COORDINATION

182 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 6 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 183 

Response to Comment Letter No. 6 (continued)

National Trust for Historic Preservation (continued) 

6c The NPS welcomes the National Trust’s active participation as a consulting party under section 106 of the 

National Historic Preservation Act as a means of recognizing the Trust’s long-standing interest and 

involvement in Ellis Island issues. The park’s section 106 coordinator will contact both Wendy Nicholas 

in the Trust’s Northeast Regional Office and Elizabeth Merritt, the Trust’s Deputy Counsel in 

Washington, to initiate this process. 
CONSULTATION AND COORDINATION

184 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 7 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 185 

Response to Comment Letter No. 7

New Jersey Historic Trust 

7a The preferred alternative (alternative 3), if implemented, would result in the restoration and rehabilitation 

of all the remaining unoccupied and deteriorating buildings on Ellis Island. The historic use of the 

buildings would be interpreted. The most significant and evocative interior spaces would be preserved and 

accessible to the general public, as would all of the exterior areas of Ellis Island, with periodic limited 

exceptions, when necessary, for safety or security concerns. 

7b Please see response to comment “4i” above (note: alternative 1 is the no-action alternative). 

7c Under the preferred alternative, the history of the entire island would be expanded and enhanced. Access 

to every building is not necessary for the visiting public to gain a complete understanding of the historical 

significance of the south side of Ellis Island and its primary function as an innovative medical care facility 

for newly arrived immigrants. Areas of special interpretive significance or evocative areas, such as the 

morgue, would be interpreted and accessible to the visiting public. The intensity and mix of use under the 

preferred alternative would be consistent with the park’s mission and the preservation of these historic 

structures for future generations. 

7d Under the preferred alternative, visitors would have general access to most of the exterior portions of the 

island except where limited by safety or security concerns. Site waysides and self-guided tours would be 

supplemented by ranger-lead tours as staffing permits. The history and significance of all of Ellis Island 

would continue to be presented to visitors. With access to the entire island, this experience would be 

greatly enriched. As noted above, access to every building is not necessary to the understanding and 

appreciation of this historic site. 

7e The NPS agrees, and the preferred alternative provides, that significant interior spaces important to the 

understanding and/or experience of the site’s history would be preserved and accessible to the visiting 

public. Other areas would be adaptively reused. 
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186 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 7 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 187 

Response to Comment Letter No. 7(continued)

New Jersey Historic Trust (continued) 

7f Please see response to comment “2a” above. 

7g The NPS agrees, and it will continue to encourage development of opportunities to access Ellis Island by 

school children and disadvantaged populations. A pilot program is planned for autumn of 2004. 

7h The stabilization work that the park and Save Ellis Island (SEI) have accomplished is only a method of 

buying time for these historic buildings. Some of these priceless resources would potentially be lost 

within 10 to 15 years if not rehabilitated. And, while the projected implementation schedule for 

alternative 3 is projected to be relatively shorter, that was not the primary reason it was selected by the 

NPS as the preferred alternative. The success of this rehabilitation could only be achieved if the project 

were economically feasible, and alternative 3 provides the best opportunity for addressing this. 

7i The NPS agrees and recognizes its over-riding responsibility to protect and preserve the historic resource 

of Ellis Island. The NPS would impose and maintain sufficient oversight of the work and activities of its 

Ellis Island partners, both private and not-for-profit, in order to ensure its ability to carry out its 

stewardship responsibilities. 

7j Response: Alternative 3 does not unduly limit public access to Ellis Island and does not exclude a reuse 

plan that accommodates some thematically related nonprofit organizations in addition to the 

institute/retreat function. 

7k Response: The NPS has a Historic Structures Report that documents the construction and characterdefining features of all of the buildings on Ellis Island. Restoration and rehabilitation work would be 

consistent with The Secretary of the Interior’s Standards for the Treatment of Historic Properties. A 2002 

Cultural Landscape Report has also been completed for Ellis Island. 
CONSULTATION AND COORDINATION

188 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 8 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 189 

Response to Comment Letter No. 8

Save Ellis Island 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

190 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 8 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 191 

Response to Comment Letter No. 8 (continued)

Save Ellis Island (continued) 

8a The preferred alternative (alternative 3) recognizes the need for the NPS to complete the infrastructure 

and seawall improvements and/or repairs to demonstrate the government’s commitment to Ellis Island’s 

future and to leverage private-sector investment. The NPS has submitted these projects for funding 

through its Line Item Construction and Miscellaneous Rehab/Repair Programs, wherein this work would 

compete with other construction and repair needs throughout the National Park System.

8b The NPS has initiated a comprehensive examination of transportation issues through revision of the 1982 

General Management Plan (GMP) for both the Statue of Liberty National Monument and Ellis Island. 

Transportation for visitors, staff, and operations are being examined, and opportunities for greater 

efficiency and enhanced visitor access are being explored. Security requirements are factored into all 

aspects of park operations and will be incorporated in the updated General Management Plan. 

Recognizing the need to ensure affordable access to its island sites, the NPS, the concessioner, and Save 

Ellis Island are crafting a program to provide affordable ferry access for disadvantaged groups and 

individuals. A pilot program will be initiated in 2004. 

8c The NPS will continue to work closely with New Jersey Department of Environmental Protection and 

Liberty State Park officials in advancing the Transportation Master Plan update, including addressing 

land-based support activities and facilities for Ellis Island. 

8d See response “3a” above for the New Jersey Department of Environmental Protection. 
CONSULTATION AND COORDINATION

192 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 8 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 193 

Response to Comment Letter No. 8 (continued)

Save Ellis Island (continued) 

8e The NPS has made its best effort to establish estimated costs associated with the alternatives outlined in 

this Development Concept Plan / Environmental Impact Statement. Cost estimates are developed, in part, 

to permit a comparison of the relative costs of the alternatives. These estimated costs for the restoration of 

the abandoned building on Ellis Island are in line with previous estimates, which have been adjusted for 

inflation and that recognize the stabilized buildings continue to experience deterioration, although at a 

slower rate. Cost estimates would be refined and updated as additional investigation and design work 

permits. 

8f Consistent with the NPS’s recognition that multiple funding strategies would be required to carry out the 

preferred alternative; the use of Historic Tax Credits would be encouraged where appropriate. 

8g The National Parks of New York Harbor initiative is intended to increase general public awareness of and 

support for the numerous diverse NPS sites throughout the New York Harbor area. These sites provide a 

treasure of historic, natural, and recreational resources within a short distance of one of the nation’s most 

populated urban areas. The NPS hopes to increase visitor use and enjoyment of these sites through 

coordinated management strategy and enhanced programming and educational opportunities. In 

conjunction with and in support of this initiative, the NPS, in cooperation with the National Park 

Foundation, has established a private fundraising effort. The National Park Foundation fundraising effort 

will focus on Gateway National Recreation Area, Manhattan Sites, and Governors Island National 

Monument, but it will not be raising funds for the Statue of Liberty National Monument or Ellis Island. 

This initiative is not intended to take the place of ongoing efforts of the NPS’s long-standing fundraising 

partners in New York and New Jersey who have and are continuing to raise significant private funds for 

specific improvements at sites such as Castle Clinton National Monument, Statue of Liberty National 

Monument, and Ellis Island, including Save Ellis Island’s efforts to support the rehabilitation of the 

unrestored buildings of Ellis Island. The NPS will work to ensure that fundraising efforts are coordinated 

and information is shared among NPS fundraising partners in New York and New Jersey. 
CONSULTATION AND COORDINATION

194 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 9 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 195 

Response to Comment Letter No. 9

New York Landmarks Conservancy 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

196 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 9 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 197 

Response to Comment Letter No. 9 (continued)

New York Landmarks Conservancy (continued) 

9a Comment noted. 

9b Comment noted. 
CONSULTATION AND COORDINATION

198 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 10
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 199 

Response to Comment Letter No. 10

Battery Park City Authority 

10a The NPS has adopted sustainable building practices as an integral part of its national design and building 

program. The Ellis Island Request for Proposals would emphasize this goal and indicate that proposals 

would be judged, in part, on the extent to which they incorporate sustainable design and operating 

principles.
CONSULTATION AND COORDINATION

200 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 201 

Response to Comment Letter No. 11

National Ethnic Coalition of Organizations Foundation 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

202 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 203 

Response to Comment Letter No. 11 (continued)

National Ethnic Coalition of Organizations Foundation (continued) 

11a The purpose of the Development Concept Plan is to provide a general framework for how the NPS 

proposes to rehabilitate the many abandoned and deteriorating buildings on Ellis Island. The preferred 

alternative (alternative 3) proposes rehabilitating the abandoned buildings as the Ellis Island Institute and 

Retreat Center through an open and broadly advertised Request for Proposals. The Development Concept 

Plan is intentionally not prescriptive in proposing any specific uses other than those that would reflect and 

expand upon the broad interpretive themes of Ellis Island. A museum or exhibitory highlighting the 

contributions of various ethnic groups incorporated within an overall economically sustainable proposal 

for Ellis Island would be considered appropriate. 

11b Comment noted. 
CONSULTATION AND COORDINATION

204 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 205 

Response to Comment Letter No. 11 (continued)

National Ethnic Coalition of Organizations Foundation (continued) 

11c “Alternative 2: Ellis Island Partners  Day Use Only” is completely dependent upon future federal 

appropriations and private philanthropy by a number of potentially diverse nonprofit organizations and 

would likely be built on a phased basis over a number of years as funding becomes available. On the other 

hand, alternative 3, which incorporates the retreat function in conjunction with the Ellis Island Institute, 

would include private investment and conventional financing, allowing development to proceed in a more 

comprehensive and timely manner. Regarding an “integrated executive time plan,” it is not possible in the 

absence of known funding to project such a detailed plan for either alternative 2 or alternative 3. The NPS 

would, however, require that proposals submitted in response to the Request for Proposals, include a 

preliminary development schedule and estimated completion date.

11d An “economic multiplier effect” refers to indirect benefits of any expenditure. For example, money spent 

by the NPS and/or its partner to rehabilitate buildings on Ellis Island would go to buy supplies, hire 

construction personnel, and other expenses. The owner of the building supply store would spend some of 

this additional money in the local community for housing, food, or other goods, in effect “multiplying” 

the impact of the original expenditure. Either of the action alternatives would result in substantial 

additional economic benefits because of this, and the range of multipliers mentioned are appropriate. 

These benefits would continue for the life of the construction. In addition, some much smaller level of 

benefits related to increased visitor use of Ellis Island, including conference participants, would take 

place. However, because conference participants would spend the majority of their time on Ellis Island, 

revenues would likely be more confined to the island, concessioners, and the park’s partner that operates 

the conference center than might normally be the case for a landside conference facility. 
CONSULTATION AND COORDINATION

206 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 207 

Response to Comment Letter No. 11 (continued)

National Ethnic Coalition of Organizations Foundation (continued) 

11e The park archive has an extensive collection of both contemporary and historic photographs of Ellis 

Island that any member of the public can access for viewing. The cost of reproducing these photos in the 

EIS would be extensive, while adding minimal value for most readers. The NPS recommends that anyone 

interested in viewing the park’s image collection contact the park archives. Some images from the park’s 

collection may be included within a future Request for Proposals to convey to potential development 

partners, the distinctive architectural details of the island’s buildings and the campus-like quality of the 

landscape and the evocative nature of this historic island. 
CONSULTATION AND COORDINATION

208 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 209 

Response to Comment Letter No. 11 (continued)

National Ethnic Coalition of Organizations Foundation (continued) 

11f See response to your comment “11a” above. 

11g Director’s Order 12 and the National Environmental Policy Act dictate the content and format of all NPS 

compliance documents. Furthermore, it is appropriate to combine plans and impact analysis. For ease of 

reference, the “Alternatives” chapter of this Development Concept Plan / Environmental Impact Statement

discusses each of the alternatives individually, including the preferred alternative (alternative 3) plan. 
CONSULTATION AND COORDINATION

210 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 211 

Response to Comment Letter No. 11 (continued)

National Ethnic Coalition of Organizations Foundation (continued) 

11h This issue was covered briefly in the Draft Development Concept Plan / Environmental Impact Statement

(for example, see pages 108 and 120). In addition, alternative designs, including locations and alignments 

of the permanent service bridge, would be explored and the impacts, including those on flood control, 

would be analyzed in a subsequent design study and EIS following the appropriation of funding. 

11i NPS Director’s Order 28: Cultural Resource Management and section 106 of the National Historic 

Preservation Act govern the disposition of the sunken ferry, documentation, stewardship, and treatment of 

the vessel. 

11j Ellis Island, located within both New York and New Jersey, is a federal property and, therefore, not 

eligible for municipal bond financing. 
CONSULTATION AND COORDINATION

212 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 213 

Response to Comment Letter No. 11 (continued)

National Ethnic Coalition of Organizations Foundation (continued) 

11k Security screening measures that are comparable to those employed in airports have been implemented at 

the ferry terminals and are continually being re-evaluated to assess their effectiveness. The operation is 

overseen by the U.S. Park Police, who provide law enforcement services for the park. 

11l The preferred alternative (alternative 3) indicates that day-use visitors to Ellis Island may be restricted 

from portions of the retreat center, but only where their presence could interfere with the institute’s 

programs and/or function. Day-use visitors would, for example, have access to all of the exterior grounds 

on the south side and some interior common areas, including restaurants or other amenities that the 

institute might offer. Selected interior spaces having special interpretive value would be accessible by 

day-use visitors to Ellis Island. 

11m Thank you for your comment. The NPS is confident that our project managers will be able to keep the 

rehabilitation on schedule. 

11n The NPS agrees that a permanent bridge is needed for security reasons. Specific alternatives, such as a 

moving walkway, would be examined in the planning and compliance process for a permanent bridge. 
CONSULTATION AND COORDINATION

214 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 11 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 215 

Response to Comment Letter No. 11 (continued)

National Ethnic Coalition of Organizations Foundation (continued) 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

216 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 12
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 217 

Response to Comment Letter No. 12

Advocates For New Jersey History 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

218 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 12 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 219 

Response to Comment Letter No. 12 (continued)

Advocates For New Jersey History 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

220 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 12 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 221 

Response to Comment Letter No. 12 (continued)

Advocates For New Jersey History 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

222 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 12 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 223 

Response to Comment Letter No. 12 (continued)

Advocates For New Jersey History (continued) 

12a Thank you for your comment. 
CONSULTATION AND COORDINATION

224 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 13
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 225 

Response to Comment Letter No. 13

Liberty Science Center 

13a Thank you for your comment. 

13b The NPS has always sought to maintain a productive relationship with Liberty State Park. NPS and 

Liberty State Park officials meet periodically to discuss and coordinate areas of mutual concern. In the 

future, the NPS will broaden its coordination efforts as specific reuse plans are identified, and as Liberty 

State Park continues to develop and evolve as a major urban park and open-space resource. 
CONSULTATION AND COORDINATION

226 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 13 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 227 

Response to Comment Letter No. 13 (continued)

Liberty Science Center (continued)

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

228 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 14
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 229 

Response to Comment Letter No. 14

Friends of Liberty State Park 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

230 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 14 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 231 

Response to Comment Letter No. 14 (continued)

Friends of Liberty State Park (continued) 

14a The NPS would work closely with the New Jersey Department of Environmental Protection and the 

Division of Parks and Forestry to negotiate routing procedures and schedules for construction vehicles 

and deliveries during and following rehabilitation activities on Ellis Island in order to minimize impacts to 

Liberty State Park. The NPS would also require its development partner and other tenant(s) of the 

rehabilitated buildings on Ellis Island to adhere to such policies and agreements. 
CONSULTATION AND COORDINATION

232 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 14 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 233 

Response to Comment Letter No. 14 (continued)

Friends of Liberty State Park (continued) 

14b As noted above, the NPS would work closely with its development partner, Liberty State Park, and the 

New Jersey Department of Environmental Protection to mitigate the impact of construction and delivery 

vehicles but recognizes that there would be some impacts to Liberty State Park, including vehicular noise 

and emissions. These impacts are discussed in the “Environmental Consequences” chapter of the 

Development Concept Plan / Environmental Impact Statement in the sections on noise and air quality. 

Generally, the NPS does not believe it is feasible to limit deliveries to earlier than 8 A.M. or later than 

10 P.M. (the NPS assumed you meant 10 P.M. rather than 10 A.M. as your letter states); however, it may be 

likely that the bulk of construction staff, and at least one load of materials, would be across the bridge by 

8 A.M. 

14c The NPS is currently having active discussions with the administrators of Liberty State Park to determine 

the most appropriate short-term location for the bridge screening operation required for the temporary 

bridge. This matter would be re-examined in conjunction with the EIS that would be conducted to 

determine the location and design of the permanent limited-access bridge. 

14d The NPS would manage and supervise the construction phases of the project, along with Save Ellis Island 

and its development partner, to minimize as much as possible the impact to Liberty State Park and its 

operations. Methods to reduce potential impacts, including the use of barges and vessels, as well as 

reduced and/or off-hour access and egress to and from the worksite by the contractors, would be explored 

and agreed upon by the NPS and the State of New Jersey Department of Environmental Protection. 

However, the NPS recognizes that it is likely to be a significant factor in financial feasibility of the 

project. 

14e Given the relatively short construction season here in the northeast, it may not be feasible to bar all 

construction work on weekends during much of the year. The NPS would include a series of mitigation 

measures related to construction activity on Ellis Island. The mitigation measures would apply to all NPS 

activities and to those of contractors, suppliers, and tenants of Ellis Island. The mitigation measures are 

intended to lessen short-term impacts related to vehicular access and construction, which the NPS has 

determined are an unavoidable consequence of those actions required to prevent the loss of the remaining 

unoccupied historic structures on Ellis Island. 
CONSULTATION AND COORDINATION

234 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 14 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 235 

Response to Comment Letter No. 14 (continued)

Friends of Liberty State Park (continued) 

14f The location and design of a permanent bridge would be the subject of a subsequent conceptual design 

study and EIS to explore alternative bridge locations. Also, alternative 2 does propose a new bridge (see 

page 35 of the Draft Development Concept Plan / Environmental Impact Statement), and the language on 

page 30 of the document regarding the final alignment and design of a permanent bridge refers to both 

alternatives 2 and 3. In other words, both action alternatives (2 and 3) include a permanent bridge, and 

both include language indicating the NPS’s commitment to minimizing impacts of the bridge on both 

Ellis Island and Liberty State Park. 

14g The possible locations and other design features of a permanent bridge would be analyzed as alternatives 

in a subsequent design, planning, and compliance process. Public involvement would be an integral part 

of this process. 

14h The NPS would continue to work closely with New Jersey Department of Environmental Protection and 

Liberty State Park officials in advancing the Transportation Master Plan update including addressing 

land-based support activities and facilities for Ellis Island.
CONSULTATION AND COORDINATION

236 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 14 (continued)
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 237 

Response to Comment Letter No. 14 (continued)

Friends of Liberty State Park (continued) 

14i The general public visiting Ellis Island would arrive exclusively by ferry. The NPS would encourage 

institute and retreat participants to arrive and depart Ellis Island by ferry as much as possible. However, 

managed access via the service bridge would be provided to accommodate “drop-off” and “pick-up” 

service for attendees of scheduled functions sponsored by the institute and conference facility. The 

institute attendees would have substantially different access requirements than the general public in terms 

of frequency, ease, hours of operation, and duration. Such service would be scheduled and timed to 

accommodate particular functions occurring at the institute. 

14j Routine deliveries related to the operation and management of Ellis Island would increase slightly 

following the implementation of the reuse plan. The number of vehicles, however, is not expected to 

exceed 15 to 20 per day, spaced out over the course of the day. Between 6 A.M. and 6 P.M., the number of 

delivery vehicles would average between two and three per hour. The NPS would encourage its suppliers 

and vendors, as well as those of the institute and conference center, to make deliveries before 10 A.M. 

throughout the year in order to assist in mitigating impacts on Liberty State Park during the mid-day 

period. 

14k The general public visiting Ellis Island would arrive and depart by ferry. The park operates frequent staff 

ferry runs in the morning and late afternoon to both New Jersey and Manhattan. The great majority of 

employees commute to the island in this way. It is appropriate for some employees to come via the 

service bridge.

14l See response to comment “5a” above. 
CONSULTATION AND COORDINATION

238 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 14 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 239 

Response to Comment Letter No. 14 (continued)

Friends of Liberty State Park (continued) 

14m The NPS shares these same concerns and would employ due diligence to ensure that any and all privatesector partner(s) have had successful experience in similar private/public partnerships, come highly 

recommended, and have the demonstrated capacity to achieve all the park’s goals, including economic 

sustainability. All agreements would be monitored and strictly enforced. 
CONSULTATION AND COORDINATION

240 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 15 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 241 

Response to Comment Letter No. 15

Philip McKinley – ArchBloc 

15a Please see response to comment “4i” above. 

15b The Request for Proposals issued by the NPS would emphasize that the mission and focus of the Ellis 

Island Institute and retreat facility must complement the historic themes of Ellis Island that include 

immigration, ethnic diversity, and public health. The Request for Proposals would encourage that institute 

proposals include partnerships with well-established institutions and organizations such as the United 

Nations and the World Health Organizations. 

15c Please see response to comment “10a” above. 

15d The preferred alternative (alternative 3) commits the NPS and its development partner(s) to maintaining 

the integrity of not only the individual structures, but the entire cultural landscape of Ellis Island. The 

long-awaited restoration and rehabilitation of Ellis Island itself should stand as a strong symbol of this 

country’s commitment to honor the site’s historical significance and meaning. In addition, the Ellis Island 

Institute would provide a forum for discussion and debate on issues such as ethnic tolerance, immigration, 

and public health.

15e The NPS agrees and would work to ensure that the mission and program(s) of the Ellis Island Institute and 

the Ellis Island Immigration Museum achieve their highest potential, while remaining rooted to the 

historic themes of Ellis Island, such as immigration, ethnic tolerance, and public health. 

15f Please see response to comment “14i” above. 

15g Ellis Island and the Statue of Liberty National Monument are currently beginning an update of their 

General Management Plan, which, in the National Park Service, is the equivalent of a master plan. 
CONSULTATION AND COORDINATION

242 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Comment Letter No. 16 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 243 

Response to Comment Letter No. 16

Frank Mastromonaco 

16a Please see response to comment “11a” above. 
CONSULTATION AND COORDINATION

244 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Transcripts of Verbal Testimony From the July 28, 2003, Meeting 

Public Meeting Comment
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 245 

Response to Public Meeting Comment 

Mr. Louis E. Schindel 

No substantive comments requiring a response on this page. 
CONSULTATION AND COORDINATION

246 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Public Meeting Comment No. 17 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 247 

Response to Public Meeting Comment No. 17

Jersey City Department of Housing and Economic Development 

17a The decision to include a permanent bridge would be made by selecting either alternative 2 or 

alternative 3. Presently, there are no funds for a permanent limited-access bridge. In the fall of 2002, the 

temporary bridge underwent stabilization work to extend its life for 10 years; therefore, the planning 

horizon for the permanent bridge is likewise extended. When federal funding is appropriated, an 

environmental impact statement would be completed in conjunction with plans to determine the most 

appropriate design and location for the bridge and related security screening operations. 

17b Please see response to comment “5a” above. 
CONSULTATION AND COORDINATION

248 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Public Meeting Comments No. 17 (continued) and 18 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 249 

Response to Public Meeting Comments No. 18

Jersey City Department of Housing and Economic Development (continued)

Friends of Parks and Public Lands 

18a A primary objective of both action alternatives 2 and 3 is to prevent the complete loss of the remaining 

unoccupied, deteriorating structures on Ellis Island. The history and meaning of these resources would be 

conveyed to the visiting public in a number of ways. The visiting public would be able to access most of 

the exterior grounds of Ellis Island. Areas within some buildings that are most important to public 

understanding of Ellis Island’s history, or which have particular evocative meaning, would be accessible 

to the visiting public. 

18b Alternatives 2 and 3 are both consistent with the park’s 1982 General Management Plan (GMP), which 

determined over 20 years ago that most of the remaining unoccupied structures on Ellis Island are surplus 

to the needs of the NPS. The GMP determined that the most feasible means of preserving the buildings 

was through a private-sector partnership. That basic premise remains valid today. The NPS is currently 

updating the GMP to reflect the many operational and security issues that have arisen in recent years. The 

new GMP will incorporate the plans set forth in alternative 3 as described in this Development Concept 

Plan / Environmental Impact Statement. 

18c Parks regularly update their general management plans because the plans are only written to guide actions 

for 20 or so years. This does not mean that all park planning or other business stops while the GMP 

update is in progress. In fact, NPS and National Environmental Policy Act (NEPA) policies allow 

planning or project work to continue if it is accompanied by appropriate planning, public involvement, 

and documentation. 
CONSULTATION AND COORDINATION

250 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Public Meeting Comment No. 18 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 251 

Response to Public Meeting Comments No. 18 (continued)

Friends of Parks and Public Lands (continued)

18d Portions of most buildings would be accessible to the visiting public, with only limited exceptions. In 

addition, the Ellis Island Institute would constitute a public purpose, and most of its programs would be 

open to a wide and diverse audience. 

18e In the “Purpose of and Need for the Action” chapter, under the “Purpose and Need for the Action” 

section, it clearly states: “The purpose of this Development Concept Plan is to provide for the long-term 

rehabilitation, reuse, and protection of cultural and historic resources on Ellis Island.” 

18f The purpose and function of the Ellis Island Institute is not intended to be, nor would the NPS permit it to 

be, an elitist enterprise. While passage through Ellis Island during the years it operated as a federal 

immigration station was no doubt confusing, tedious, and in some instances frightening, people did not 

generally suffer and die there. It is not possible or appropriate to “recreate” the experience of Ellis Island. 

Alternative 3 provides for the rehabilitation of all of the historic structures and public access through 

much of the site and promotes the interpretation of the historic use and significance of the site. 

18g The NPS acknowledges the opinion expressed here, but feels that the plans set forth in the Development 

Concept Plan / Environmental Impact Statement are based appropriately on the park’s purpose and 

mission. The 1982 General Management Plan currently being updated will incorporate the planning 

completed under this Development Concept Plan / Environmental Impact Statement. 
CONSULTATION AND COORDINATION

252 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Public Meeting Comments Nos. 19 and 20 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 253 

Response to Public Meeting Comments Nos. 19 and 20 

William Stasic – Private Citizen 

19a This issue is outside the scope of this Development Concept Plan / Environmental Impact Statement. 

Essex County Sierra Club 

20a Please see responses to comments “14a, b, e, and j” above. 

20b The NPS agrees that the selected development partner must have an appreciation for the special meaning 

and historical significance of Ellis Island.

20c As noted in responses to other comments, locations for the permanent bridge and bridge landings would

be explored through a subsequent environmental planning and compliance process. 
CONSULTATION AND COORDINATION

254 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Public Meeting Comment No. 21 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 255 

Response to Public Meeting Comment No. 21 

Office of Congressman Robert Menendez 

21a Please see responses to comments “3c” and “5a” above. 
CONSULTATION AND COORDINATION

256 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Public Meeting Comment No. 22 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 257 

Response to Public Meeting Comment No. 22

New Jersey NAACP, New Jersey State Conference of NAACP Labor and Industry Committee

22a Please note that public involvement in this planning effort has been ongoing since December 2000. A 

summary of the history of public involvement is presented in the Draft Development Concept Plan / 

Environmental Impact Statement beginning on page 143. 

22b A feasibility analysis suggests that the retreat and conference facility would not be a profitable enterprise 

in the traditional sense. In conjunction with the Ellis Island Institute, its nonprofit partner, the retreat 

center, would operate at a net annual loss and would require subsidy in the form of individual, foundation, 

and/or governmental support. 

22c The NPS agrees and would explore appropriate opportunities to partner with area school systems 

including Jersey City. 

22d The NPS agrees. The park’s interpretive program endeavors to convey the full range of human 

experiences associated with the history of Ellis Island’s development and operation as an immigration 

station.

22e The NPS agrees with the speaker’s assertion that history must always be interpreted through a broad lens 

that reflects diverse perspectives, experiences, and beliefs. 

22f Please see responses to comments “3c” and “5a” above. 
CONSULTATION AND COORDINATION

258 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Public Meeting Comment No. 22 (continued) 
Comments and Responses

FINAL ENVIRONMENTAL IMPACT STATEMENT 259 

Response to Public Meeting Comment No. 22 (continued)

New Jersey NAACP, New Jersey State Conference of NAACP Labor and Industry Committee 

(continued)

22g The NPS has sought public comment on the Draft Development Concept Plan / Environmental Impact 

Statement in a number of ways. The Draft Development Concept Plan / Environmental Impact Statement

was completed and distributed in May 2003 and is available to the public at no charge by contacting the 

park’s superintendent. It is also available on the internet at http://www.nps.gov/elis/, which can also be 

accessed through computers at most public libraries and schools. Public meetings were held in both 

Manhattan and New Jersey. The NPS feels that holding additional public meetings at public schools is not 

necessary and would result in an unnecessary delay in implementing the Development Concept Plan. 
Appendixes 
FINAL ENVIRONMENTAL IMPACT STATEMENT 263

APPENDIX A: SCOPING MEETINGS SUMMARY 

FOR THE 

DEVELOPMENT CONCEPT PLAN / DRAFT ENVIRONMENTAL IMPACT STATEMENT 

The National Park Service held scoping meetings on this Development Concept Plan / Draft Environmental 

Impact Statement. Forty-four people attended the three meetings. During the three public forums, people’s 

concerns, issues, and ideas were recorded on flip charts and are summarized below. 

December 6, 2000 – Meeting was held at the New Jersey Department of Environmental Protection in 

Trenton, NJ; 13 people attended. 

State Historic Preservation Office 

• Preservation and stabilization 

• Honoring history 

• Access for all (affordable) 

• Self-sustaining economically 

• Majority of New Jersey residents feel strongly about Ellis Island 

• Rehabilitate rather than restore 

• Recognize public health role 

• International conference center 

• Regional history conference center 

Liberty State Park Development Corporation 

• “Blessed plots” 

• Supports Governor’s report 

• 8 million immigrants from railroad terminal 

• Link development and history of park with Ellis Island 

• Access/parking/transportation/mass transit concerns 

• Signage program in place 

• Jersey City = exciting destination 

• Pedestrian land bridge 

• Support for waterborne access for visitors to preserve immigrant experience 

• Bridge: affordable and considerate of Liberty State Park 

New Jersey Governor’s Advisory Committee 

• Respectful of history 

• Economically viable/sustaining 

• Save Ellis Island Inc. to work with NPS to secure money for rehabilitation of south-side buildings 

• Must be saved now 
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264 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

New Jersey Department of Health 

• Unique role in the history of public health 

• Public Health Learning Center 

− Screening 

− Treatment 

− Individual health 

• “Living History” 

• Disease-reducing technology 

• Education 

• National venue 

− History of health care 

− National/global awareness 

− Interactive opportunities 

− Repeat visits 

− Artifacts that support themes 

Liberty Science Center 

• “Reflection and inspiration” for others 

• Cluster of unique attractions 

− Statue of Liberty 

− Ellis Island 

− Liberty Science Center (most visited in New Jersey) 

• Thematically linked attractions 

• One-third of visitors to harbor area start in New Jersey 

• Planning must include traffic/access/parking/etc. in Liberty State Park area 

• Carrying capacity of Ellis Island 

• Natural disaster studies 

• Supports quality of research in the December 1999 report to the governor 

• U.N.E.S.C.O site potential; could help to expedite the planning process 

Other Comments 

• Permanent bridge 

• Center of Immigrant Contributions 

• Ellis Island International Conference Center; revenue to support other uses 

• Public Health Learning Center 

• Conservation and Preservation Center 

• Regional History Center (New Jersey and New York) 
Appendix A 

FINAL ENVIRONMENTAL IMPACT STATEMENT 265

December 7, 2000 – Meeting was held at the Ellis Island Main Building; 16 people attended. 

Preservation of New Jersey 

• “Going well so far” 

• Supports Governor’s report 

• Investment tax credit/long-term lease 

• New financial partnership? 

• Access (particularly from New Jersey) 

• Land use relationship 

• Emergency response 

• Long-term maintenance ($!) 

Other Comments 

• Is section 106 included? 

• Is a section 4(f) statement required? 

• What is the overall plan? 

• Will existing uses remain? 

• NPS response: 

− There currently is no plan 

− The exteriors will be preserved 

− Interiors will be rehabilitated and adaptively reused 

• Health museum potential? Other uses should be limited to historical resonance 

• Does Ellis Island currently get enough visitors via New Jersey? 

• NPS response: needs to be studied seriously in accordance with the New Jersey Governor’s report 

December 7, 2000 – Meeting was held at the Customs House, New York City; 15 people attended. 

New York Landmarks Conservancy 

• South-side buildings and Baggage and Dormitory Building 

• Stabilization = time to plan 

• Highest preservation standards 

• No demolition and minimal new construction 

• Economically feasible in the broadest terms 

• Interpretative issues paramount 

• Excellence in design 

− “Green” design 

− Life safety 
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266 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

− Americans With Disabilities Act 

• Transportation study (all modes) 

− Bridge 

• Accurate cost estimates 

− Capital and operational 

− Reflect inflation, etc. 

Other Comments 

• Immigration museum only for certain time period? 

• NPS response: there will be potential to increase interpretive experiences on south side; diversity of 

theme 

• Public health theme? 

• “Institutional architecture” a growing interest; chance to show the “darker side” of immigrant 

experience 

• Look at larger view of immigration history (present and past) 

• BBB: public groups to use time now to develop possible reuse ideas 

• South-side = “story of healing” (i.e., should not be too much emphasis on “darker side”) 

• “New York versus New Jersey” 

• NPS response: have been working with both sides toward similar goals 

• Public should voice opinion regarding the “evocative spaces” (e.g., view from psychiatric wards) 

• “Preserving the Ghosts” was part of the New Jersey governor’s report 

• Documentation of existing conditions? 

− NPS: currently documenting the stabilization progress; updates on the website 

− BBB: completed Historic Structure Report in late-80s; full documentation on six buildings and 

partial documentation on the remaining 

• Oral history (immigrants and employees) 

− NPS: currently has a program and is hoping to expand 

• Oral history available online? Good idea for schools. 

− NPS: there is potential to expand with the technology 

• Library of Congress Digital Collections? 

− “American Memory Program” 

− www.loc.gov 

• Ws medical area used for immigrants only? (seamen too?) 

− BBB: was used for military circa 1919 

• Any opportunities for volunteerism? 

− Yes, but it’s specialized 

− Lots of opportunities... 
Appendix A 

FINAL ENVIRONMENTAL IMPACT STATEMENT 267

• What are some of the reuse ideas? 

• New Jersey governor’s report response: 

− “Nation of immigrants” 

− Center for Immigration and Ethnic Learning 

− Public Health focus 

− International Conference Center 

− National Historic Preservation Center 

− Regional history context 

− Respect history 

− Better access to the south side 

− Economic sustainability 

• Buildings important as a whole 

• NPS: there are a number of “character defining” spaces that suggest interpretive experience (e.g., 

mortuary, autoclave) 

• “Stabilization as a relic” related to economic viability 

• RFP: must get interested parties to embrace preservation qualities 

• Federal government to be the decision maker 

• The National Park Service should tell the story of New Jersey / New York conflict as part of exhibits 

• Similar issues at Governors Island 

− Transportation 

− Competition of uses 

• NPS: looking at all parks in the harbor; common interpretive themes 

• Need for understanding immigration on both coasts (i.e., national) 

• Dialogue with other areas, which are less expensive to visit (e.g., Fire Island) 

• Circle Line only? 

− NPS: currently exclusive, but expires in 2004; therefore, will open the competition 
268 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

APPENDIX B: LETTERS TO STATE HISTORIC PRESERVATION OFFICES 

AND THE ADVISORY COUNCIL ON HISTORIC PRESERVATION 

December 6, 2000 

Don Klima, Director 

Office of Planning and Review 

Advisory Council on Historic Preservation 

Old Post Office Building 

1100 Pennsylvania Avenue, NW, #809 

Washington, DC 20004 

Attn: Ms. Martha Catlin 

Dear Ms. Catlin: 

The National Park Service is preparing a Development Concept Plan (DCP) for the rehabilitation of 29 historic 

buildings located on the south side of Ellis Island and the Baggage and Dormitory building on the north side. 

This plan will establish the criteria for evaluating development proposals for these historic buildings and also 

evaluate alternative modes of appropriate, safe, and economically viable access to Ellis Island to utilize the 

rehabilitated facilities. 

Pursuant to 36 CFR 800.8 (a)(3)(c), providing for early coordination of section 106 with the NEPA process, the 

park is notifying the Council for the intention to prepare an Environmental Impact Statement (EIS) and to use 

this document and the NEPA process in lieu of the procedures set forth in Sec. 800.3 through 800.6 for the 

stabilization of these historic buildings on Ellis Island and evaluating safe, affordable access. 

The park intends to prepare the EIS so that it meets the standards described in 36 800.8(a)(3)(c)(1) and to submit 

the EIS to consulting parties prior to making the document available for public review. 

The public meetings scheduled for December (see attached schedule) are scoping meetings to begin the public 

review process and provide the initial public involvement. 

Thank you for your continued support for the Statue of Liberty National Monument and Ellis Island. 

Sincerely, 

(signed) Cynthia R. Garrett 

Diane H. Dayson 

Superintendent 

Cc: Commissioner Bernadette Castro 

 Dorothy Guzzo 

 Paul Weinbaum 

Attachment 
Appendix B 

FINAL ENVIRONMENTAL IMPACT STATEMENT 269

December 6, 2000 

Ms. Dorothy P. Guzzo 

Administrator 

State of New Jersey 

Department of Environmental Protection 

Division of Parks and Forestry 

Historic Preservation Office 

CN-404 

Trenton, NJ 08625-0404 

Dear Ms. Guzzo: 

The National Park Service is preparing a Development Concept Plan (DCP) for the rehabilitation of 29 historic 

buildings located on the south side of Ellis Island and the Baggage and Dormitory building on the north side. 

This plan will establish the criteria for evaluating development proposals for these historic buildings and also 

evaluate alternative modes of appropriate, safe, and economically viable access to Ellis Island to utilize the 

rehabilitated facilities. 

Pursuant to 36 CFR 800.8 (a)(3)(c), providing for early coordination of section 106 with the NEPA process, the 

park is notifying the Council for the intention to prepare an Environmental Impact Statement (EIS) and to use 

this document and the NEPA process in lieu of the procedures set forth in Sec. 800.3 through 800.6 for the 

stabilization of these historic buildings on Ellis Island and evaluating safe, affordable access. 

The park intends to prepare the EIS so that it meets the standards described in 36 800.8(a)(3)(c)(1) and to submit 

the EIS to consulting parties prior to making the document available for public review. 

The public meetings scheduled for December (see attached schedule) are scoping meetings to begin the public 

review process and provide the initial public involvement. 

Thank you for your continued support for the Statue of Liberty National Monument and Ellis Island. 

Sincerely, 

(signed) Cynthia R. Garrett 

Diane H. Dayson 

Superintendent 

Cc: Commissioner Bernadette Castro 

 Paul Weinbaum 

 Martha Catlin 

Attachment 
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270 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

December 6, 2000 

Commissioner Bernadette Castro 

New York State Office of Parks 

Recreation and Historic Preservation 

Peebles Island 

P.O. Box 189 

Waterford, New York 12188-0189 

Dear Commissioner Castro: 

The National Park Service is preparing a Development Concept Plan (DCP) for the rehabilitation of 29 historic 

buildings located on the south side of Ellis Island and the Baggage and Dormitory building on the north side. 

This plan will establish the criteria for evaluating development proposals for these historic buildings and also 

evaluate alternative modes of appropriate, safe, and economically viable access to Ellis Island to utilize the 

rehabilitated facilities. 

Pursuant to 36 CFR 800.8 (a)(3)(c), providing for early coordination of section 106 with the NEPA process, the 

park is notifying the Council for the intention to prepare an Environmental Impact Statement (EIS) and to use 

this document and the NEPA process in lieu of the procedures set forth in Sec. 800.3 through 800.6 for the 

stabilization of these historic buildings on Ellis Island and evaluating safe, affordable access. 

The park intends to prepare the EIS so that it meets the standards described in 36 800.8(a)(3)(c)(1) and to submit 

the EIS to consulting parties prior to making the document available for public review. 

The public meetings scheduled for December (see attached schedule) are scoping meetings to begin the public 

review process and provide the initial public involvement. 

Thank you for your continued support for the Statue of Liberty National Monument and Ellis Island. 

Sincerely, 

(signed) Cynthia R. Garrett 

Diane H. Dayson 

Superintendent 

Cc: Dorothy Guzzo 

 Paul Weinbaum 

 Martha Catlin 

Attachment 
FINAL ENVIRONMENTAL IMPACT STATEMENT 271

Appendix C 

Draft 

Analysis of Relative Financial Feasibility 

and Economic Sustainability 

of EIS Alternatives 

August 26, 2002 
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272 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND
Appendix C 

FINAL ENVIRONMENTAL IMPACT STATEMENT 273
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Appendix C 

FINAL ENVIRONMENTAL IMPACT STATEMENT 293
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296 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND
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APPENDIX D 

I. DRAFT PROGRAMMATIC AGREEMENT

AMONG 

THE NATIONAL PARK SERVICE 

THE NEW JERSEY STATE HISTORIC PRESERVATION OFFICER 

NEW YORK STATE HISTORIC PRESERVATION OFFICER 

AND 

 THE ADVISORY COUNCIL ON HISTORIC PRESERVATION 

REGARDING 

THE REHABILITATION OF ELLIS ISLAND’S STRUCTURES AND LANDSCAPE

WHEREAS, The National Park Service (NPS) proposes to lease a portion of Ellis Island through the historic 

leasing program for the purpose of rehabilitating and reusing currently vacant and deteriorating buildings which 

are surplus to NPS needs; and 

WHEREAS, the approach of utilizing the historic lease program on Ellis Island was the preferred NPS 

alternative in the 1982 General Management Plan (GMP) and will incorporated within the new GMP which is 

currently in development; and 

WHEREAS, the NPS has prepared a Development Concept Plan/Environmental Impact Statement (DCP/EIS) 

for this PROJECT which includes the NPS goals for rehabilitation, the structures which will be made available 

for rehabilitation, and the justification for a permanent managed access bridge to New Jersey; and 

WHEREAS, the NPS has defined the Area of Potential Effect (APE) for this undertaking to be Ellis Island and 

the view sheds as depicted within DCPEIS, as part of the Statue of Liberty National Monument, listed on the 

National Register of Historic Places (NRHP) as nationally significant; and 

WHEREAS, the NPS has consulted with the New Jersey State Historic Preservation Officer (NJSHPO), the 

New York State Historic Preservation Officer (NYSHPO), Army Corps of Engineers (ACE), and the Advisory 

Council on Historic Preservation (ACHP), and the interested public pursuant to 36 CFR 800, regulations 

implementing Section 106 of the National Historic Preservation Act (16 U.S.C. 470f); and Sections 110(f) and 

110(k) of the same Act (16 U.S.C. 470h2(f)); and 

WHEREAS, the NPS intends to seek one or more development partners to participate in the implementation of 

the long-term rehabilitation and compatible reuse of Ellis Island; and 

WHEREAS, development partner(s) may be identified through a broad solicitation of for-profit developers, i.e., 

Request for Proposals (RFP) whose proposed development plans will be evaluated on the basis of their 

feasibility and compatibility with the Mission and Purpose Statement contained in the Development Concept 

Plan and Environmental Impact Statement (DCP/EIS); and 

WHEREAS, the NPS may also negotiate with one or more not-for-profit organizations to evaluate the feasibility 

of their proposed development plans and compatibility with the Mission and Purpose Statement contained in the 

DCP/EIS; and 

NOW THEREFORE, the NPS, NJSHPO, NYSHPO and the ACHP agree that the PROJECT shall be 

implemented in accordance with the following stipulations in order to take into account the effect of the 

undertaking on historic properties. 
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298 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

STIPULATIONS 

The NPS shall ensure that the following measures are carried out as part of the PROJECT. Failure to meet these 

stipulations will constitute a violation of this Agreement. 

I. GENERAL APPROACH 

A. The NPS will solicit, through the issuance of a RFP, proposals from private for-profit developers for 

uses that are consistent with the Secretary of the Interior’s Standards for the Treatment of Historic 

Properties (36 CFR 68), the DCP/EIS, and as approved by the NPS. 

B. All solicitations, negotiations and conditions regarding leasing with not-for-profit organizations and forprofit entities will be guided by and administered under the auspices of the NPS’ historic leasing 

program (36 CFR18). 

II. APPLICABLE STANDARDS 

• Secretary of the Interior’s Standards for the Treatment of Historic Properties (36 CFR 68) with 

Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic Buildings 

• Secretary of the Interior’s Standards for Rehabilitation (36 CFR 67) 

• Secretary of the Interior’s Standards and Guidelines for the Treatment of Cultural Landscapes (1996) 

• Secretary of the Interior’s Standards for Archeology and Historic Preservation [As amended and 

annotated by the NPS] (1995) 

• Secretary of the Interior’s Profession Qualification Standards (48 FR 22716, 1983) 

• Secretary of the Interior’s Standards and Guidelines for Identification (48 FR 44720-23) 

• Protection of Archeological Resources (46 CFR 7) 

• Curation of Archeological Collections (36 CFR 79) 

• Leases and Exchanges of Historic Property (36 CFR 18) 

• NPS, in consultation with the SHPOs, will develop Historic Structures and Cultural Landscape 

Treatment requirements. 

III. RFP REQUIREMENTS 

A. The RFP will include: 

1. NPS’ Program Goal as stated in the DCP for the rehabilitation and reuse of Ellis Island; and 

2. NPS’ Historic Preservation Goals as stated in the DCP that shall be wholly consistent with the 

Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for 

Preserving, Rehabilitating Restoring and Reconstructing Historic Buildings; and 

3. A summary of Historic Structure and Cultural Landscape Treatment Requirements that shall be 

developed by the NPS in consultation with the SHPOs; and 
Appendix D

FINAL ENVIRONMENTAL IMPACT STATEMENT 299

4. A listing of all of the properties and associated cultural landscape features included within the lease 

offering; and 

5. Identification of any and all improvements that will be carried out by the NPS or other entities and 

therefore not the responsibility of the development partner(s) 

6. A statement indicating that limited new construction may be proposed when such construction is in 

direct support of the overall rehabilitation plan. Applicable standards for new construction within a 

National Historic Landmark (NHL) district will apply; and 

7. A statement outlining the applicability of the Historic Tax Credit Program in the rehabilitation of 

Ellis Island; and 

8. Building Maintenance and Occupancy goals; and 

9. Minimum Business Terms and Conditions of the rehabilitation and occupancy of historic 

properties; and 

10. An outline of submission requirements and proposed schedule for review; and 

11. The selection factors to be used by the NPS to evaluate proposals. 

B. The NPS will emphasize to all respondents that the proposals should be persuasive as to their feasibility 

and should reflect a realistic understanding of Ellis Island’s historic structures and cultural landscape, 

including their potential and limitations for adaptive reuse. 

C. The substance of the selected proposal, as approved by the NPS, will be incorporated in the lease, the 

performance of which in all significant regards will be the basis for determining effective compliance. 

D. The final acceptance of any proposal will be conditioned upon satisfactory negotiation and execution of 

the lease and approved by the Director, Northeast Region, NPS 

E. Prior to the execution of a historic lease with a development partner(s) pursuant to the RFP described in 

III.3, the NPS will consult with the SHPOs to amend and update this PA to reflect the actual 

rehabilitation plan, a detailed time schedule for the submission, review and approval of construction 

documents, and establish a standing procedure for routine SHPOs’ review and comment throughout 

design and construction. 

F. Prior to construction of the permanent controlled access bridge, the NPS will consult with the SHPOs 

and ACE and others to mitigate any adverse effects that may include but not be limited to the bridge’s 

use, sitting and design profile, etc. 

IV. SCOPE OF SERVICES FOR PROJECT MANAGEMENT SERVICES 

Following execution of a historic lease between the NPS and a development partner(s), and before undertaking 

any onsite work, said partner(s) will provide NPS with a detailed proposal for the implementation of the 

rehabilitation of the leased structures and associated landscape on Ellis Island. The proposal will include the 

anticipated sequence or phasing of actions with responsible individuals identified by name or position, a 

description of all tasks, intermediate completion points, estimated costs and identification of operational or 

programmatic priorities. 

The complete scope of services for project management services will be developed by the development 

partner(s) in consultation with the NPS for approval by the NPS and the SHPOs. At a minimum, the Scope of 

Work will include: 
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300 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

A. A plan of work that details the scope of preservation/rehabilitation work to be undertaken including 

both interior and exterior work, new construction, demolition, and site work and any activity that will or 

might impact architectural, archeological and cultural landscape resources. 

B. Procedures for direct communication on technical issues between the NPS and those providing project 

management services and architectural, cultural landscape and archeological expertise as determined 

necessary by the NPS and Park 106 Advisors. 

C. Provision for direct involvement by these 106 Advisors in the development of the plans and 

specifications for all aspects of work on the site to ensure that all appropriate steps are taken to integrate 

the preservation of cultural resources including landscape elements into these plans at the project 

development stage. 

D. Provision for informing all development partner (s)’ staff, contractors and subcontractors about the 

Protection of Archeological Resources regulation (43CFR7, 1997) including penalties for unauthorized 

removal of Federal property. 

E. The requirements and qualification criteria for conducting archeological monitoring of the site 

throughout construction activities; this work will be conducted under contract with the development 

partner(s). 

F. The authority for the NPS to halt work on the site if any activity conflicts with the Secretary of the 

Interior’s “Standards for Treatment of Historic Properties” 

V. QUALIFICATION OF PERSONNEL 

A. The NPS shall ensure that qualified professionals meeting the NPS professional qualifications for the 

appropriate discipline [National Park Service Professional Qualification Standards, Secretary of the 

Interior's Standards and Guidelines for Archaeology and Historic Preservation (48 FR 44738-39)] are 

used in this project, to include archeological surveys and testing, historic structure inventories and 

documentation, and cultural landscape documentation. 

B. On site Work: 

1. Prior to the initiation of any work on site, the development partner(s) will contract for the 

professional services of a firm to act as project manager to develop plans for and oversee all 

execution of site clearing, archeology monitoring, hazardous materials abatement, stabilization and 

protection of contributing structures and landscape elements, and preparation for construction for 

all work covered under this PA; the project manager will also oversee the construction covered 

under this PA. 

2. Prior to any negotiations by the development partner(s) to contract for these services, the NPS and 

Park 106 advisors will verify that the firms submitting proposals to the development partner(s) 

have the requisite expertise to conduct all activities regarding or having the potential to affect 

historic structures or the cultural landscape pursuant to this PA. This work must be carried out by, 

or be under the direct supervision of, a person or persons meeting at a minimum, the Secretary of 

the Interior’s “Professional Qualifications – Standards for Historic Architect” (48 CFR 44738-9) 

and NPS cultural landscape professional qualifications. All activities regarding or having the 

potential to affect archeological resources pursuant to this PA are carried out under the direct 

supervision of a person or persons meeting at a minimum the Secretary of the Interior’s 

“Professional Qualifications – Standards for Archeology” (48 CFR 44738-9), with at least 5 years 

experience in historical archeology. 
Appendix D

FINAL ENVIRONMENTAL IMPACT STATEMENT 301

VI. IDENTIFICATION AND EVALUATION OF HISTORIC PROPERTIES 

A. Archeological Sites: 

The NPS shall ensure that archeological surveys within any uninvestigated and under investigated 

portions of the APE are conducted in a manner consistent with the Secretary of the Interior's Standards

and Guidelines for Identification (48 FR 44720-23) and take into account the NPS publication The

Archeological Survey: Methods and Uses (1978) and the state guidelines for conducting archeological 

surveys. The survey shall be conducted following consultation with the SHPOs, and a report of the 

survey, consistent with the SHPOs’ Guidelines for Preparing Cultural Resource Management 

Archaeological Reports Submitted to the SHPO (December 1994), shall be submitted to the SHPO for 

review and consultation. 

For areas that have been previously surveyed to the depth of the proposed impact or otherwise 

examined by archeological investigations, monitoring during construction should be done provided that: 

• background investigation or pertinent historical documents show no cultural or archeological 

resources in the APE; and 

• the results of the archeological survey or previous archeological investigation showed no 

significant archeological remains. 

If potentially significant archeological resources are discovered during monitoring, ground-disturbing 

activities in the area of the resource shall cease. Consultation between the NPS and the SHPOs shall 

begin at the time of discovery. Attempts should be made to avoid impacting the resource, preserving it 

in place. If avoidance is impossible, data recovery will be implemented as described in Section VII B1 

(and following) in this PA. 

B. The NPS shall consult with the SHPOs in the evaluation of the significance of the cultural landscape to 

Ellis Island. The objective is to identify National Register listed or potentially eligible cultural 

landscapes and affected view sheds within the project area that may be affected by the Project 

implementation, and to determine whether they meet the National Register criteria set forth in 36 CFR 

60.4. 

The NPS shall ensure that the identification and evaluation of historic properties that may be effected by 

each phase of the Project activities is completed prior to the initiation of any formal action by the 

development partner(s) including rehabilitation, demolition, new construction, etc. The NPS and the SHPOs 

shall consider the views of the public and interested parties in completing the identification and evaluation 

responsibilities. 

VII. TREATMENT OF HISTORIC PROPERTIES 

The preferred treatment for rehabilitation is to preserve the historic character of historic properties. Deteriorated 

historic materials and features should be repaired and severely deteriorated features should be replaced, using to 

the greatest extent possible, matching new materials. The NPS shall, to the extent feasible, avoid adverse effects 

to historic properties either through project design changes, interim protection measures, realignments, 

landscaping, or other measures that will protect historic properties. If, in consultation with the SHPOs, 

avoidance of adverse effects is determined to be infeasible, the NPS shall develop and implement mitigation 

plans. 

The NPS shall explore preservation in place, where possible. Preservation in place may entail partial avoidance 

or protection of historic properties against project related activities in proximity to the property. The NPS shall 

preserve properties in place through project design, i.e. incorporating color, texture, scale, materials that are 

compatible with the architectural or historic character of the historic property, preservation of vegetation 
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302 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

including mature trees, landscaping and planting. If the NPS, in consultation with the SHPOs, determines that 

preservation in place is infeasible, the NPS shall develop and implement mitigation plans. 

A. Buildings and Structures: 

1. Rehabilitation: The NPS shall ensure that plans and specifications for rehabilitation activities for 

historic buildings and structures shall adhere to the recommended approaches in The Secretary of 

the Interior's Standards for the Treatment of Historic Properties (36 CFR 68) with Guidelines for 

Preserving, Rehabilitating, Restoring and Reconstructing Historic Buildings and other standards.

2. New Additions/Alterations: The NPS shall ensure that the design of new additions and alterations 

to historic buildings do not destroy historic materials and are compatible with the architectural 

character, scale, setting, massing, size and color, of the historic buildings on the site. New work 

should be differentiated from the old, yet compatible. If the NPS and the SHPOs concur that the 

addition may affect a building or structure that is part of a view shed, then the NPS shall document 

the relationship between the historic building and its view shed and, as appropriate, consider 

additional mitigation measures to preserve the view shed. 

B. Archaeological Sites 

1. The NPS shall develop a data recovery plan for archeological remains that the NPS and SHPOs 

agree cannot be avoided or appropriately preserved in place. The data recovery plan to retrieve 

significant archeological information, will be developed and implemented by the NPS or its 

representative(s), following approval from the SHPOs and prior to the mitigation of project-related 

activities within or in the vicinity of the archaeological sites. 

2. The NPS shall ensure that the data recovery plan for each eligible site addresses substantive 

research questions developed in consultation with the SHPOs. The plan shall be consistent with the 

Secretary of the Interior's Standards and Guidelines for Archeological Documentation [as 

amended and annotated by the NPS] (48 FR 44734-37) and take into account the ACHP’s 

publication, Treatment of Archeological Properties. Each plan shall specify, at a minimum, the 

following: 

a) The property, properties, or portions of properties where data recovery is to be carried out; 

and 

b) The research questions to be addressed through the data recovery, with an explanation of 

their relevance and importance; and 

c) The methods to be used, with an explanation of their relevance to and effectiveness in 

addressing the research questions; and 

d) A discussion of the potential research value of any human remains that may be 

encountered, as well as a process for consultation with the SHPOs, the ACHP, any 

descendent communities, and any persons or groups that have expressed an interest, to 

develop a treatment plan for human remains; and 

e) A proposed schedule for the submission of progress reports and the draft data recovery 

report to the SHPOs. 

3. The NPS shall submit data recovery plans to the SHPOs for review and approval. They will 

consult to resolve any objections to the data recovery plan as proposed. The data recovery plan 

shall be implemented by the NPS once approved by the SHPOs. If no response is received from 
Appendix D

FINAL ENVIRONMENTAL IMPACT STATEMENT 303

the SHPOs after 30 days of receipt of adequate documentation, the NPS may assume the SHPOs’ 

concurrence and proceed with implementation of the plan submitted. 

4. The NPS shall ensure that the data recovery plan(s) will be carried out by or under the direct 

supervision of an archeologist(s) who meets, at minimum, the Secretary of the Interior's

Professional Qualifications Standards (48 FR 44738-9). 

5. The NPS, in consultation with the SHPOs, shall develop adequate provisions for site security 

during data recovery to avoid vandalism. 

6. The NPS or its designee, in consultation with the SHPOs shall ensure that all materials and records 

resulting from the survey, evaluation, and data recovery conducted for the Project will be curated in 

accordance with Curation of Federally-Owned and Administered Archaeological Collections (36 

CFR Part 79). 

7. The NPS shall ensure that all final reports resulting from actions pursuant to this PA will be 

provided, to the SHPOs, and upon request, to other interested parties. All such plans shall be 

responsive to contemporary standards. Final plans shall be submitted to SHPOs for review and 

approval. The NPS shall implement approved final plans. 

C. Cultural Landscapes 

1. Rehabilitation: The NPS shall ensure that rehabilitation activities and treatment for cultural 

landscapes shall adhere to the recommended approaches in The Secretary of the Interior's 

Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural 

Landscapes (1996) and Protecting Cultural Landscapes, National Park Service Preservation Brief 

Number 36. 

2. New Additions/Alterations: The NPS shall ensure that the design of new additions and alterations 

to historic buildings is compatible with the character, scale, and setting of the cultural landscape. 

VIII. DOCUMENTATION 

A. Prior to the initiation of any work, the development partner(s) will contract for professional 

photographic services to document every structure (interior and exterior) and landscape area that will be 

affected by the project. The photographic documentation will be done to Secretary of the Interior’s 

Standards for Architectural and Engineering Documentation and be carried out by an experienced 

individual or firm approved by the NPS. A complete set of photographs will be furnished to the NPS at 

the conclusion of the project. 

B. During the course of construction, the development partner will retain the services of a professional 

photographer to routinely document the rehabilitation process. Particular care will be taken to document 

architectural details and portions of buildings not normally visible, where unusual or unexpected 

conditions are encountered during construction. Landscape elements uncovered during the project will 

be documented. The NPS will be notified for further documentation/recovery. 

IX. PUBLIC PARTICIPATION 

A. In consultation with the SHPOs, the NPS shall develop a plan to inform the interested public about the 

project and the existence of this PA. Copies of this PA and relevant documentation prepared pursuant 

to the terms of this PA shall be made available for public inspection (information regarding the 

locations of archeological sites will be withheld in accordance with the Freedom of Information Act and 

National Register Bulletin 29, if it appears that this information could jeopardize archeological sites). 

Any comments received from the public under this PA shall be taken into account by the NPS. 
APPENDIXES

304 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

B. Public Objections. The NPS shall review and resolve timely and substantive public objections. Public 

objections shall be considered timely when they are provided within the review periods. The NPS shall 

consult with the SHPOs, and as appropriate with the ACHP, to resolve objections. Project actions that 

are not the subject of the objection may proceed while the consultation is conducted. 
Appendix D

FINAL ENVIRONMENTAL IMPACT STATEMENT 305

X. GENERAL PROVISIONS 

A. Reporting 

On or before October 1 and April 1 of each year commencing after executing of a RFP with the 

developing partner(s) until the NPS, the ACHP and the SHPOs agree in writing that the terms of this 

agreement have been fulfilled, the development partner(s) shall prepare and provide a report as a 

summary of the completed activities and proposed activities for the next six months to NPS addressing 

at a minimum, the following topics: 

• Progress in the rehabilitation of the site 

• Progress in site preparation 

• Progress in design and construction 

• Status of any interim protection of historic properties 

• Progress in archeological monitoring and data recovery 

• Any problems or unexpected issues encountered during the report period 

The NPS will submit these reports to the SHPOs and consulting parties until the project-related 

activities are complete. The SHPOs may request a site visit to follow up information in the report or to 

monitor activities carried out pursuant to this PA, at their discretion. 

B. Resolving Objections 

1. Should any signatory (as defined in the ACHP’s regulations, 36CFR Section 800.6.c) to this 

agreement object to any action carried out or proposed by another signatory with respect to the 

development of the site or to the implementation of this PA, the NPS shall consult with the 

objecting party to resolve the objection. If after initiating such consultation, the NPS determines 

that the objection cannot be resolved through consultation, the NPS shall forward all 

documentation relevant to the objection to the SHPOs , including the NPS’s proposed response to 

the objection. Within 30 days after receipt of all pertinent documentation, the SHPOs shall exercise 

one of the following options: 

a) Advise the NPS that the SHPOs concur in the NPS’s proposed final decision, whereupon the 

NPS will respond to the objection accordingly; or 

b) Provide the NPS with a recommendation, that the NPS shall take into account in reaching a 

final decision regarding its response to the objection; or 

c) Notify the NPS that the objection will be referred for comment to the Council, pursuant to 

36CFR Section 800.6(b), and proceed to refer the objection and comment to the ACHP. 

2. Should the SHPOs not exercise one of the above options within 30 days after receipt of all 

pertinent documentation, the NPS may assume the SHPOs’ concurrence in its proposed response to 

the objection. 

3. The NPS shall take into account the SHPOs’ recommendations or comments provided in 

accordance with this stipulation with reference only to the subject of the objection. All 

responsibilities under this agreement that are not the subject of an objection shall remain 

unchanged. 
APPENDIXES

306 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

4. At any time during the implementation of the measures stipulated in the agreement, should an 

objection pertaining to the agreement be raised by a member of the public, the NPS shall notify the 

signatories to this PA and take the objection into account, consulting with the objector and with any 

of the signatories to this PA to resolve the objection. Upon receipt of such notification, should a 

signatory agree with the objection raised, the signatory will notify the NPS. The NPS will then 

follow the process in Stipulation 10.a. All responsibilities under this PA that are not the subject of 

an objection shall remain unchanged 

C. Review of Implementation 

All plans, documents, reports, and materials shall be submitted to the NPS 106 advisors for review and 

comment. Following revision of said plans, documents reports and other materials to the satisfaction of 

the NPS 106 advisors, NPS shall submit said materials to the SHPOs for a 30-day review period unless 

otherwise stipulated. If the SHPOs fail to comment within the specified time, the NPS shall request the 

ACHP`s comments except when this PA provides for the NPS to assume the SHPOs’ concurrence when 

the 30-day review period has elapsed. 

When consulting parties are participating in the review of activities or actions, outlined in this PA, the 

NPS shall ensure that all consulting parties are provided documentation at the time it is forwarded to the 

SHPOs and afforded a 30-day review period. As appropriate, the NPS shall submit the comments of 

consulting parties to the SHPOs to facilitate further consultation. 

D. Dispute Resolution 

The SHPOs shall have 30 days to object to determinations, evaluations, plans, and 

documents submitted by the NPS . The NPS and the SHPOs shall attempt to resolve any disagreement 

arising from implementation of this PA. If there is a determination that the disagreement cannot be 

resolved, any of the parties shall request the ACHP’s recommendations or request the comments of the 

ACHP in accordance with 36 CFR Part 800.6(b). 

Any ACHP recommendations or comments provided in response will be considered in accordance with 

36 CFR 800.6(c), with reference only to the subject of the dispute. The NPS shall respond to the ACHP 

recommendations or comments indicating how the NPS has taken the ACHP's recommendations or 

comments into account and complied with same comments prior to proceeding with Project activities 

that are subject to dispute. Responsibility to carry out all other actions under this PA that are not the 

subject of the dispute will remain unchanged. 

E. Amendments 

Any signatory to this agreement may propose to NPS that the agreement be amended, whereupon NPS 

shall consult with the other signatories to this agreement to consider such an amendment. 36 CFR Part 

800.5(c) shall govern the execution of any such amendment. 

F. Termination 

Any signatory to this PA may terminate it by providing thirty days notice to the other parties, provided 

that the parties will consult during the period prior to termination to seek agreement on amendments or 

other actions that would avoid termination. In the event of termination, the NPS will comply with 36 

CFR Sections 800.4 through 800.6 with regard to individual undertakings covered by this PA. 
Appendix D

FINAL ENVIRONMENTAL IMPACT STATEMENT 307

G. Sunset Clause 

This PA will continue in full force and effect until the construction of the Project is complete and all 

terms of this PA are met, unless the Project is terminated or authorization is rescinded. 

Execution and implementation of this PA evidences that the NPS has satisfied its Section 106 responsibilities for 

all individual undertakings of the Project, and that the NPS has afforded the SHPOs an opportunity to comment 

on the project and its effects on historic properties. 

IN WITNESS WHEREOF, the parties have caused this instrument to be executed by their authorized 

representatives the day and year last written below. 

NATIONAL PARK SERVICE 

By______________________________________________ Date:_____________________________ 

Cynthia Garrett, Acting Superintendent, 

Statue of Liberty NM and Ellis Island Immigration Museum 

NEW JERSEY STATE HISTORIC PRESERVATION OFFICER 

By______________________________________________ Date:_____________________________ 

Dorothy P. Guzzo, Administrator 

NEW YORK STATE HISTORIC PRESERVATION OFFICER 

By______________________________________________ Date:_____________________________ 

Bernadette Castro, Commissioner 

ADVISORY COUNCIL ON HISTORIC PRESERVATION 

By______________________________________________ Date:_____________________________ 

John Fowler, Executive Director 

ARMY CORPS OF ENGINEERS 

By______________________________________________ Date:_____________________________ 
308 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

APPENDIX E: LIST OF THREATENED 

AND ENDANGERED SPECIES AND SPECIES OF CONCERN 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 309
APPENDIXES

310 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 311
APPENDIXES

312 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 313
APPENDIXES

314 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 315

LETTER FROM NEW JERSEY 

DEPARTMENT OF ENVIRONMENTAL PROTECTION AND SPECIES LIST 
APPENDIXES

316 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

LIST OF ENDANGERED PLANT SPECIES AND PLANT SPECIES OF CONCERN 

SEPTEMBER 2001

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Acer Nigrum Black Maple G5 S2 

Acorus Americanus American Sweetflag G5 S1 

Actaea Rubra var. Rubra Red Baneberry G5T5 S3 

Adlumia Fungosa Climbing Fumitory G4 S2 

Aeschynomene Virginica Sensitive Joint-Vetch G2 S1 LT E LP 

Agalinis Auriculata Ear-Leaf False Foxglove G3 SX 

Agalinis Fasciculata Pine Barren Foxglove G5 S3 

Agalinis Paupercula var.

Paupercula 

Small-Flower False Foxglove G5T? S3 

Agalinis Setacea Thread-Leaf False Foxglove G5? S3S4 

Agastache Nepetoides Yellow Giant-Hyssop G5 S2 

Agastache Scrophulariifolia Purple Giant-Hyssop G4 S2 

Agrimonia Microcarpa Small-Fruit Grooveburr G5 S2 

Agrimonia Striata Britton's Grooveburr G5 S3S4 

Agrostis Geminata Ticklegrass G5 S1 

Alisma Triviale Large Water-Plantain G5 S1 E 

Alnus Incana Ssp Rugosa Speckled Alder G5T5 S3S4 

Alopecurus Aequalis var. 

Aequalis 

Short-Awn Meadow-Foxtail G5T? S2 

Alopecurus Carolinianus Tufted Meadow-Foxtail G5 S3S4 

Amaranthus Pumilus Seabeach Amaranth G2 S1 LT E 

Amelanchier Humilis Low Service-Berry G5 S1 

Amelanchier Sanguinea Round-Leaf Service-Berry G5T5 S1.1 E 

Amelanchier Stolonifera Running Service-Berry G5 S3 

Amianthium Muscitoxicum Fly Poison G4G5 S2 

Ammannia Latifolia Koehn's Toothcup G5 S1 E 

Andromeda Glaucophylla Bog Rosemary G5T5 S1 E 

Andropogon Glomeratus var. 

Hirsutior 

Hairy Beardgrass G5T5 SH.1 

Andropogon Gyrans Elliott's Beardgrass G5 S2 

Andropogon Ternarius var. 

Ternarius

Silvery Beardgrass G5T? S2 

Anemone Canadensis Canada Anemone G5 SX 

Anemone Cylindrica Long-Head Anemone G5 S1 E 

Anemone Virginiana var. Alba Riverbank Anemone G5T4T5 S2 

Angelica Venenosa Hairy Angelica G5 S2 

Antennaria Neglecta var. 

Canadensis

Canada Pussytoes G5T? S1 E 

Aplectrum Hyemale Puttyroot G5 S1 E 

Arabis Drummondii Drummond's Rockcress G5 S1.1 E 

Arabis Hirsuta var. Pycnocarpa Western Hairy Rockcress G5T5 S2 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 317

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Aralia Hispida Bristly Sarsaparilla G5 S3S4 

Aralia Racemosa Ssp 

Racemosa 

American Spikenard G4G5T4

T5 

S3S4 

Arceuthobium Pusillum Dwarf Mistletoe G5 S1 E 

Arenaria Stricta Rock Sandwort G5T5 SH E 

Arethusa Bulbosa Dragon Mouth G4 S2 

Arisaema Dracontium Greendragon G5 S3S4 

Arisaema Triphyllum ssp. 

Stewardsonii 

Northern Jack-In-The-Pulpit G5T4 S2 

Aristida Dichotoma var. 

Curtissii 

Curtiss' Three-Awn Grass G5T5 S2 

Aristida Lanosa Woolly Three-Awn Grass G5 S1 E 

Aristida Longispica var. 

Geniculata

Plains Three-Awn Grass G5T5? S3S4 

Aristida Oligantha Prairie Three-Awn Grass G5 S3S4 

Aristida Virgata Wand-Like Three-Awn Grass G5T4T5 S2 

Aristolochia Serpentaria Virginia Snakeroot G4 S3 

Armoracia Lacustris Lake Water-Cress G4? SH E 

Arnica Acaulis Leopardbane G5 SX.1 

Arnoglossum Muehlenbergii Great Indian Plantain G4 SX.1 

Artemisia Campestris ssp.

Caudata 

Beach Wormwood G5T5 S2 

Asarum Canadense var. 

Acuminatum

Long-Tipped Wild Ginger G5T?Q S2 

Asclepias Exaltata Tall Milkweed G5 S3S4 

Asclepias Lanceolata Smooth Orange Milkweed G5 S2 

Asclepias Purpurascens Purple Milkweed G4G5 S3S4 

Asclepias Rubra Red Milkweed G4G5 S2 LP 

Asclepias Variegata White Milkweed G5 S2 

Asclepias Verticillata Whorled Milkweed G5 S2 

Asclepias Viridiflora Green Milkweed G5 S3S4 

Asimina Triloba Pawpaw G5 S1 E 

Asplenium Bradleyi Bradley's Spleenwort G4 S1 E 

Asplenium Montanum Mountain Spleenwort G5 S2 E 

Asplenium Pinnatifidum Lobed Spleenwort G4 S1 

Asplenium Ruta-Muraria var. 

Cryptolepis

Wall-Rue G5T5 S3 

Asplenium Trichomanes ssp.

Trichomanes 

Maidenhair Spleenwort G5T5 S2S4 

Aster Borealis Rush Aster G5 S1 E 

Aster Concolor Eastern Silvery Aster G4? S2 LP 

Aster Ericoides var. Ericoides White Heath Aster G5T5 S1 

Aster Ericoides var. Prostratus Prostrate White Heath Aster G5T? S3 

Aster Firmus Shining Aster G5T5 SH.1 E 

Aster Lanceolatus var. Interior Inland Tall White Aster G5T5 S1S2 

Aster Lateriflorus var. 

Horizontalis

Spreading Calico Aster G5T4T5 S2S3 
APPENDIXES

318 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Aster Novi-Belgii var. Elodes Marsh New York Aster G5T? S2 

Aster Patens var. Phlogifolius Phlox-Leaf Aster G5T5 S3 

Aster Praealtus Willow-Leaf Aster G5T5? S1 E 

Aster Prenanthoides Crooked-Stem Aster G4G5 S2 

Aster Radula Low Rough Aster G5 S1 E 

Aster Tradescantii Tradescant's Aster G4Q S2 

Aster Urophyllus Arrow-Leaf Aster G4 S2 

Astragalus Canadensis var. 

Canadensis 

Canadian Milk-Vetch G5T5 SX.1 

Athyrium Pycnocarpon Glade Fern G5 S1 E 

Atriplex Subspicata Saline Orache G5 S1.1 E 

Azolla Caroliniana Eastern Mosquito-Fern G5 S1 

Betula Papyrifera var. 

Papyrifera

Paper Birch G5T5 S2 

Betula Pumila var. Pumila Swamp Birch G5T? S2 

Bidens Beckii Water-Marigold G4G5 S1 E 

Bidens Bidentoides Estuary Burr-Marigold G3 S2 

Bidens Comosa Leafy-Bract Beggar-Ticks G5 S3S4 

Bidens Eatonii Eaton's Beggar-Ticks G2 S1.1 E 

Bidens Mitis Small-Fruit Beggar-Ticks G4? S1 

Boltonia Asteroides var.

Asteroides 

Aster-Like Boltonia G5T4T5 S2 

Botrychium Lanceolatum var. 

Angustisegmentum 

Lance-Leaf Moonwort G5T4 S3 

Botrychium Multifidum Leathery Grape Fern G5 S1 E 

Botrychium Oneidense Blunt-Lobe Grape Fern G4Q S2 

Botrychium Simplex var.

Laxifolium 

Upland Least Moonwort G5T? S1 

Botrychium Simplex var.

Simplex

Least Moonwort G5T5 S1.1 

Botrychium Simplex var. 

Tenebrosum 

Slender Least Moonwort G5T4?Q S2 

Bouteloua Curtipendula Side-Oats Grama Grass G5T5 S1 E 

Brachyelytrum Septentrionale Northern Shorthusk G4G5 S3S4 

Bromus Ciliatus var. Ciliatus Fringed Brome G5T5 S2 

Bromus Kalmii Kalm's Brome G5 S2 

Bromus Latiglumis Early Brome G5 S2S3 

Buchnera Americana Bluehearts G5? SX 

Cacalia Atriplicifolia Pale Indian Plantain G4G5 S1 E 

Calamagrostis Pickeringii Pickering's Reed Grass G4 S1 E 

Calla Palustris Wild Calla G5 S3 

Callitriche Palustris Marsh Water-Starwort G5 S2 

Callitriche Terrestris Austin's Terrestrial WaterStarwort 

G5 S3S4 

Calystegia Sepium ssp.

Angulata 

Angled Bindweed G5T5 S2S4 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 319

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Calystegia Sepium ssp.

Appalachiana 

Appalachian Bindweed G5T4? SH 

Calystegia Sepium ssp.

Erratica 

Occluded Bindweed G5T? SH.1 E 

Calystegia Spithamaea Erect Bindweed G4G5T4

T5 

S1 E 

Cardamine Angustata Slender Toothwort G5 S3 

Cardamine Diphylla Two-Leaf Toothwort G5 S3 

Cardamine Douglassii Purple Bittercress G5 S2 

Cardamine Longii Long's Bittercress G3 SH E 

Cardamine Maxima Large Toothwort G5Q S1.1 E 

Cardamine Pratensis var. 

Palustris

Meadow Cuckoo-Flower G5T5 S3 

Cardamine Rotundifolia Round-Leaf Bittercress G4 S1 E 

Carex Aggregata Glomerate Sedge G5 S1 

Carex Albursina White Bear Lake Sedge G5 S1 E 

Carex Alopecoidea Foxtail Sedge v S1 E 

Carex Amphibola var. 

Amphibola

Narrow-Leaf Sedge G5T4Q S1 E 

Carex Appalachica Appalachian Sedge G4 S3S4 

Carex Aquatilis Water Sedge G5 S1 E 

Carex Arctata Drooping Wood Sedge G5? S1.1 E 

Carex Argyrantha Hay Sedge G5 S3S4 

Carex Backii Back's Sedge G4 SH.1 E 

Carex Bebbii Bebb's Sedge G5 S2 

Carex Bicknellii var. Bicknellii Bicknell's Sedge G5T5 S2 

Carex Brunnescens Round-Spike Brownish Sedge G5T5 S1 E 

Carex Bushii Bush's Sedge G4 S1 E 

Carex Buxbaumii Brown Sedge G5 S3 

Carex Canescens var. 

Canescens

Silvery Sedge G5T5 SH 

Carex Caroliniana Carolina Sedge G5 S3 

Carex Cephaloidea Thin-Leaf Sedge G5 S2 

Carex Complanata Flattened Sedge G5 S3S4 

Carex Conjuncta Soft Fox Sedge G4G5 S3 

Carex Conoidea Field Sedge G5 S2 

Carex Crawei Crawe's Sedge G5 S1 E 

Carex Crawfordii Crawford's Sedge G5 S2 

Carex Cryptolepis Small Yellow Sedge G4 S2 

Carex Cumulata Clustered Sedge G4? SH E 

Carex Deweyana Dewey's Sedge G5T5 S1 E 

Carex Diandra Lesser Panicled Sedge G5 S2 

Carex Disperma Soft-Leaf Sedge G5 S1 

Carex Eburnea Ebony Sedge G5 S2 

Carex Emoryi Emory's Sedge G5 S3S4 

Carex Formosa Handsome Sedge G4 S1.1 E 
APPENDIXES

320 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Carex Frankii Frank's Sedge G5 S3 

Carex Granularis var. Haleana Hale's Meadow Sedge G5T4 S2S3 

Carex Haydenii Cloud Sedge G5 S1 E 

Carex Hitchcockiana Hitchcock's Sedge G5 S2 

Carex Hyalinolepis Shore-Line Sedge G4G5 SX.1 

Carex Jamesii James' Sedge G5 S1 E 

Carex Joorii Cypress-Swamp Sedge G4G5 S1.1 E 

Carex Lasiocarpa var. 

Americana 

American Slender Sedge G5T5 S2 

Carex Laxiculmis var. Copulata Coupled Sedge G5T? SH 

Carex Leavenworthii Leavenworth's Sedge G5 SH 

Carex Leptalea var. Harperi Harper's Sedge G5T4T5 S2S3 

Carex Leptonervia Fine-Nerve Sedge G4 S1 E 

Carex Limosa Mud Sedge G5 S1 E 

Carex Lonchocarpa Southern Long Sedge G5 SH.1 

Carex Louisianica Louisiana Sedge G5 S1 E 

Carex Lupuliformis Hop-Like Sedge G4 S1 E 

Carex Meadii Mead's Sedge G4G5 SX.1 

Carex Mesochorea Midland Sedge G4G5 S1 

Carex Mitchelliana Mitchell's Sedge G3G4 S2 

Carex Molesta Troublesome Sedge G4 S2S3 

Carex Oligocarpa Few-Fruit Sedge G4 S1 E 

Carex Pallescens Pale Sedge G5 S2 

Carex Peckii Peck's White-Tinged Sedge G4G5 SH E 

Carex Plantaginea Plantain-Leaf Sedge G5 S1.1 E 

Carex Polymorpha Variable Sedge G3 S1 E 

Carex Prairea Prairie Sedge G5? S2 

Carex Projecta Necklace Sedge G5 S3S4 

Carex Pseudocyperus Cyperus-Like Sedge G5 S1 E 

Carex Retroflexa Reflexed Sedge G5 S3S4 

Carex Retrorsa Retrorse Sedge G5 S2 

Carex Siccata Hillside Sedge G5 S1 E 

Carex Silicea Seabeach Sedge G5 S2 

Carex Sterilis Dioecious Sedge G4 S2 

Carex Stipata var. Maxima Large Awl-Fruit Sedge G5T? SH 

Carex Straminea Straw Sedge G5 S3S4 

Carex Striatula Lined Sedge G4G5 S3S4 

Carex Styloflexa Bent Sedge G4G5 S3S4 

Carex Tenera Quill Sedge G5 S1 

Carex Trisperma var. Billingsii Billings' Three-Seed Sedge G5T? S3S4 

Carex Tuckermanii Tuckerman's Sedge G4 S1 E 

Carex Typhina Cat-Tail Sedge G5 S3 

Carex Utriculata Bottle-Shaped Sedge G5 S2 

Carex Viridula ssp. Viridula Green Sedge G5T5 S2 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 321

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Carex Willdenowii var. 

Willdenowii

Willdenow's Sedge G5T5 S2 

Castanea Pumila Chinquapin G5 S1 E 

Castilleja Coccinea Scarlet Indian-Paintbrush G5 S2 

Celtis Tenuifolia Dwarf Hackberry G5 S2 

Centella Erecta Erect Coinleaf G5 SX.1 

Centrosema Virginianum Spurred Butterfly-Pea G5 SH E 

Cerastium Nutans var. Nutans Nodding Mouse-Ear 

Chickweed 

G5T5? S3S4 

Ceratophyllum Echinatum Spiny Coontail G4? S1 E 

Cercis Canadensis Redbud G5T5 S1 E 

Chaerophyllum Procumbens

var. Procumbens

Spreading Chervil G5T5 S3 

Chamaelirium Luteum Devil's-Bit G5 S3 

Chasmanthium Latifolium Indian Wood-Oats G5 SX.1 

Cheilanthes Lanosa Hairy Lipfern G5 S2 

Chenopodium Berlandieri var. 

Macrocalycium

Large-Calyx Goosefoot G4 S2 

Chenopodium Pratericola Narrow-Leaf Goosefoot G5 S2 

Chenopodium Rubrum Red Goosefoot G5 S1 E 

Chenopodium Simplex Maple-Leaf Goosefoot G5 S2 

Chenopodium Standleyanum Stanley's Goosefoot G5 S2 

Chionanthus Virginicus Fringetree G5 S3 

Cinna Latifolia Slender Wood-Reed G5 S1 E 

Cirsium Altissimum Tall Thistle G5 SH 

Cirsium Virginianum Virginia Thistle G3 S1 E 

Claytonia Virginica var. 

Hammondiae

Hammond's Yellow Spring 

Beauty 

G5T1 S1.1 E 

Cleistes Divaricata Spreading Pogonia G4 S1 E LP 

Clematis Occidentalis var. 

Occidentalis

Purple Clematis G5T5 S2 

Clinopodium Vulgare Wild Basil G5 S3S4 

Clintonia Borealis Yellow Clintonia G5 S3S4 

Clitoria Mariana Butterfly-Pea G5 S1 E 

Coeloglossum Viride var. 

Virescens

Long-Bract Green Orchid G5T5 S2 

Coelorachis Rugosa Wrinkled Jointgrass G5 S1 E 

Commelina Erecta Slender Dayflower G5T5 SH.1 E 

Conioselinum Chinense Hemlock-Parsley G5 S1 E 

Corallorhiza Trifida Early Coralroot G5 S2 

Corallorhiza Wisteriana Spring Coralroot G5 SX 

Corema Conradii Broom Crowberry G4 S1 E LP 

Coreopsis Rosea Rose-Color Coreopsis G3 S2 LP 

Cornus Amomum var. 

Schuetzeana 

Pale Dogwood G5T? S1 E 

Cornus Canadensis Bunchberry G5 S2 

Cornus Foemina Stiff Dogwood G5 S2 
APPENDIXES

322 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Corydalis Flavula Yellow-Harlequin G5 S3S4 

Corylus Cornuta var. Cornuta Beaked Hazelnut G5T5 S3S4 

Crataegus Calpodendron Pear Hawthorn G5 S1 E 

Crataegus Chrysocarpa var. 

Chrysocarpa 

Fireberry Hawthorn G5T? S1 

Crataegus Dodgei Dodge's Hawthorn G4 S2 

Crataegus Holmesiana Holmes' Hawthorn G5 S1 

Crataegus Pedicellata Scarlet Hawthorn G5 S1S2 

Crataegus Pennsylvanica Pennsylvania Hawthorn G3Q S1.1 

Crataegus Punctata Dotted Hawthorn G5 S2 

Crataegus Succulenta Fleshy Hawthorn G5 S1 E 

Croton Willdenowii Elliptical Rushfoil G5 S2 LP 

Cryptogramma Stelleri Slender Rockbrake G5 SH.1 E 

Cuphea Viscosissima Blue Waxweed G5? S3 

Cuscuta Cephalanthi Buttonbush Dodder G5 S1 E 

Cuscuta Coryli Hazel Dodder G5 S2 

Cuscuta Indecora Collared Dodder G5T2T4 S1.1 E 

Cuscuta Polygonorum Smartweed Dodder G5 S2 

Cynoglossum Virginianum var.

Boreale 

Northern Wild Comfrey G5T4 SH.1 E 

Cynoglossum Virginianum var. 

Virginianum

Wild Comfrey G5T5 S2 

Cyperus Engelmannii Engelmann's Flat Sedge G4Q S2 

Cyperus Hystricinus Bristly Flat Sedge G4 SH E 

Cyperus Lancastriensis Lancaster Flat Sedge G5 S1 E 

Cyperus Plukenetii Plukenet's Flat Sedge G5 SH E 

Cyperus Polystachyos Coast Flat Sedge G5T5 S1 E 

Cyperus Pseudovegetus Marsh Flat Sedge G5 S1 E 

Cyperus Refractus Reflexed Flat Sedge G5 SH E 

Cyperus Retrofractus Rough Flatsedge G5 SH E 

Cyperus Squarrosus Awned Flat Sedge G5 S3S4 

Cyperus Tenuifolius Low Spike Sedge G5 SH E 

Cypripedium Candidum Small White Lady's-Slipper G4 S1 E 

Cypripedium Parviflorum var. 

Makasin

Fen Small Yellow Lady'sSlipper G5T4? S2 

Cypripedium Parviflorum var. 

Pubescens

Large Yellow Lady's-Slipper G5T4T5 S3S4 

Cypripedium Reginae Showy Lady's-Slipper G4 S1 E 

Cystopteris Bulbifera Bulblet Fern G5 S3S4 

Cystopteris Protrusa Lowland Fragile Fern G5 S2 

Dalibarda Repens Robin-Run-Away G5 SH.1 E 

Deschampsia Caespitosa Tufted Hair Grass G5 S3 

Desmodium Cuspidatum var. 

Cuspidatum 

Toothed Tick-Trefoil G5T5? S3 

Desmodium Humifusum Trailing Tick-Trefoil G1G2Q SH E 

Desmodium Laevigatum Smooth Tick-Trefoil G5 S3 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 323

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Desmodium Nuttallii Nuttall's Tick Trefoil G5 S3 

Desmodium Ochroleucum Cream-Flower Tick-Trefoil G2G3 SX.1 

Desmodium Pauciflorum Few-Flower Tick-Trefoil G5 S1 E 

Desmodium Sessilifolium Sessile-Leaf Tick-Trefoil G5 S1 E 

Desmodium Strictum Pineland Tick-Trefoil G4 S2 LP 

Desmodium Viridiflorum Velvety Tick-Treefoil G5? S2 

Dicentra Canadensis Squirrel-Corn G5 S1 E 

Dicentra Eximia Wild Bleeding-Heart G4 SH.1 E 

Diodia Virginiana Larger Buttonweed G5T5 S1 E 

Dioscorea Villosa var. 

Hirticaulis

Hairy-Stem Wild Yam G4G5T3

Q 

S2 

Dirca Palustris Leatherwood G4 S2 

Doellingeria Infirma Cornel-Leaf Aster G5 S2 

Draba Reptans Carolina Whitlow-Grass G5 SH E 

Dryopteris Celsa Log Fern G4 SX 

Dryopteris Clintoniana Clinton's Woodfern G5 S3 

Dryopteris Goldiana Goldie's Wood Fern G4 S3 

Echinochloa Muricata var.

Microstachya 

Small-Spike Rough Barnyard 

Grass 

G5T5 SH 

Echinodorus Parvulus Dwarf Burrhead G3Q SH.1 

Elatine Americana American Waterwort G4 S2 

Elatine Minima Small Waterwort G5 S2 

Eleocharis Brittonii Britton's Spike-Rush G4G5 S1 E 

Eleocharis Compressa Flat-Stem Spike-Rush G4 S1 E 

Eleocharis Elliptica Elliptic Spike-Rush G5 S2 

Eleocharis Engelmannii Engelmann's Spike-Rush G4? S3S4 

Eleocharis Equisetoides Knotted Spike-Rush G4 S1 E LP 

Eleocharis Erythropoda Bald Spike-Rush G5 S2S3 

Eleocharis Halophila Salt-Marsh Spike-Rush G4 S2 

Eleocharis Intermedia Matted Spike-Rush G5 S2 

Eleocharis Melanocarpa Black-Fruit Spike-Rush G4 S1 E 

Eleocharis Minima Small Spike-Rush G4G5 SH.1 E 

Eleocharis Pauciflora Few-Flower Spike-Rush G5 S1 E 

Eleocharis Quadrangulata Angled Spike-Rush G4 S2 

Eleocharis Tenuis var.

Pseudoptera 

Winged Spike-Rush G5T? S3S4 

Eleocharis Tenuis var.

Verrucosa 

Warty Spike-Rush G5T3T5 S1.1 E 

Eleocharis Tortilis Twisted Spike-Rush G5 S1 E 

Elephantopus Carolinianus Carolina Elephant-Foot G5 SH E 

Ellisia Nyctelea Aunt Lucy G5 S1 E 

Elymus Hystrix var.

Bigeloviana 

Bigelow's Bottle-Brush Grass G5T? S2S3 

Elymus Trachycaulus Slender Wheatgrass G5 S1 E 

Elymus Trachycaulus ssp. 

Subsecundus

One-Sided Wheatgrass G5T5 S1 
APPENDIXES

324 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Elymus Trachycaulus ssp. 

Trachycaulus 

Slender Wheatgrass G5T5 S1 

Epilobium Angustifolium ssp. 

Circumvagum 

Narrow-Leaf Fireweed G5T5 S1 

Epilobium Ciliatum var. 

Ciliatum 

Northern Willowherb G5T5 S3S4 

Epilobium Leptophyllum Bog Willowherb G5 S2 

Epilobium Strictum Downy Willowherb G5? S2 

Equisetum Pratense Meadow Horsetail G5 S1 E 

Equisetum Sylvaticum Woodland Horsetail G5 S3 

Equisetum Variegatum Variegated Horsetail G5T5 S1 E 

Eragrostis Frankii Frank's Love Grass G5 S2 

Eragrostis Hypnoides Smooth Creeping Love Grass G5 S3S4 

Erechtites Hieraciifolia var.

Megalocarpa 

Large-Fruit Fireweed G5T? SH 

Eriocaulon Parkeri Parker's Pipewort G3 S2 

Eriophorum Gracile Slender Cotton-Grass G5T? SH E 

Eriophorum Tenellum Rough Cotton-Grass G5 S1 E 

Eriophorum Vaginatum var. 

Spissum

Sheathed Cotton-Grass G5T5 SH E 

Eriophorum Viridicarinatum Thin-Leaf Cotton-Grass G5 S3 

Eryngium Aquaticum var.

Aquaticum 

Marsh Rattlesnake-Master G4T4 S3 

Eryngium Yuccifolium var.

Yuccifolium 

Tall Rattlesnake-Master G5T5 SX 

Euonymus Atropurpurea var. 

Atropurpurea 

Wahoo G5T5 S1 

Eupatorium Album var. Vaseyi Vasey's Boneset G5T? S1 

Eupatorium Altissimum Tall Boneset G5 S2 

Eupatorium Aromaticum var.

Aromaticum 

Smaller White Snakeroot G5T5 S1 

Eupatorium Capillifolium Dog-Fennel Thoroughwort G5 S2 E 

Eupatorium Coelestinum Mist-Flower G5 S3 

Eupatorium Godfreyanum Godfrey's Boneset G4 SH.1 

Eupatorium Hyssopifolium Var. 

Laciniatum 

Torrey's Boneset G5T4T5 S2 

Eupatorium Maculatum var. 

Maculatum

Spotted Joe-Pye-Weed G5T5 S3S4 

Eupatorium Resinosum Pine Barren Boneset G3 S2 E LP 

Eupatorium Rotundifolium var. 

Cordigerum

Heart-Leaf Boneset G5T? S2 

Eupatorium Sessilifolium var. 

Brittonianum 

Britton's Upland Boneset G5T? S2 

Euphorbia Corollata Flowering Spurge G5 S2 

Euphorbia Purpurea Darlington's Glade Spurge G3 S1 E 

Euthamia Caroliniana Slender Bushy Goldenrod G5 S3S4 

Filipendula Rubra Queen-Of-The-Prairie G4G5 SH E 

Fimbristylis Caroliniana Carolina Fimbry G4 S2 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 325

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Fimbristylis Castanea Marsh Fimbry G5 S3 

Fimbristylis Puberula var.

Puberula 

Hairy Fimbry G5T5? S2 

Fragaria Vesca var. Americana American Woodland 

Strawberry 

G5T5 S3S4 

Fraxinus Profunda Pumpkin Ash G4 S1 E 

Fuirena Squarrosa Hairy Umbrella-Sedge G4G5 S3 

Galactia Volubilis Downy Milk-Pea G5 SH E 

Galium Boreale Northern Bedstraw G5 S3S4 

Galium Concinnum Shining Bedstraw G5 SX.1 

Galium Hispidulum Coast Bedstraw G5 S1 E 

Galium Labradoricum Labrador Marsh Bedstraw G5 S1 E 

Galium Obtusum Var Filifolium Thread-Leaf Marsh Bedstraw G5T? S2S4 

Galium Palustre Marsh Bedstraw G5 S3 

Galium Trifidum Small Bedstraw G5T5 S1 E 

Gaultheria Hispidula Creeping-Snowberry G5 S1 E 

Gaura Biennis Biennial Beeblosom G5 S3 

Gentiana Andrewsii var.

Andrewsii 

Fringed Bottle Gentian G5?T5? S2 

Gentiana Autumnalis Pine Barren Gentian G3 S3 LP 

Gentiana Catesbaei Catesby's Gentian G5 SH.1 

Gentiana Linearis Narrow-Leaf Gentian G4G5 SH E 

Gentiana Saponaria Var 

Saponaria 

Soapwort Gentian G5T? S3 

Gentiana Villosa Striped Gentian G4 SX.1 

Gentianella Quinquefolia var.

Quinquefolia 

Stiff Gentian G5T4T5 S2 

Geum Rivale Chocolate-Root G5 S3 

Geum Vernum Spring Avens G5 S2 

Geum Virginianum Cream-Color Avens G5 S3S4 

Glaux Maritima Sea-Milkwort G5 SX.1 E 

Glyceria Borealis Small Floating Manna Grass G5 SH.1 E 

Glyceria Grandis American Manna Grass G5T5 S2 E 

Glyceria Laxa Northern Manna Grass G5 S1 

Glyceria Melicaria Long Manna Grass G5 S3 

Gnaphalium Helleri Small Everlasting G4G5T3

? 

SH E 

Gnaphalium Macounii Winged Cudweed G5 SH E 

Gnaphalium Obtusifolium var. 

Praecox

Early Life Everlasting G5T5 S2S3 

Goodyera Tesselata Checkered RattlesnakePlantain 

G5 SH.1 E 

Gratiola Pilosa Hairy Hedge Hyssop G5? S2 

Gratiola Virginiana Round-Fruit Hedge-Hyssop G5 S2 

Gymnocarpium Dryopteris Oak Fern G5 S2 

Gymnopogon Ambiguus Bearded Skeleton Grass G4 S3 

Gymnopogon Brevifolius Short-Leaf Skeleton Grass G5 S1 E 
APPENDIXES

326 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Hasteola Suaveolens Sweet-Scent Indian-Plantain G3 SX.1 

Helianthemum Bicknellii Hoary Frostweed G5 S3 

Heliopsis Helianthoides var.

Helianthoides 

Smooth Ox-Eye G5T? S3S4 

Heliopsis Helianthoides var, 

Scabra

Rough Ox-Eye G5T5 S1S2 

Helonias Bullata Swamp-Pink G3 S3 LT E LP 

Hemicarpha Micrantha Small-Flower Halfchaff Sedge G4 S1 E 

Heteranthera Multiflora Bouquet Mud-Plantain G4 S2 

Hieracium Kalmii Canada Hawkweed G5T? S1 E 

Hieracium Marianum Maryland Hawkweed G? SH 

Hieracium Scabrum var.

Scabrum 

Rough Hawkweed G5T? S3S4 

Honckenya Peploides var. 

Robusta 

Seabeach Sandwort G5T4 S2 

Hottonia Inflata Featherfoil G4 S1 E 

Houstonia Longifolia Long-Leaf Summer Bluet G4G5 SH 

Humulus Lupulus Var 

Lupuloides 

American Hop G5T5 S3S4 

Hybanthus Concolor Green Violet G5 S1 E 

Hydrastis Canadensis Golden Seal G4 SH.1 E 

Hydrocotyle Prolifera Canby's Marsh-Pennywort G5T5? S1 

Hydrocotyle Ranunculoides Floating Marsh-Pennywort G5 S1 E 

Hydrocotyle Verticillata var.

Verticillata 

Whorled Marsh-Pennywort G5T5 S2 

Hydrophyllum Canadense Broad-Leaf Waterleaf G5 S1 E 

Hypericum Adpressum Barton's St. John's-Wort G2G3 S2 E 

Hypericum Dissimulatum Disguised St. John's-Wort G5Q S3S4 

Hypericum Ellipticum Pale St. John's-Wort G5 S3 

Hypericum Gymnanthum Clasping-Leaf St. John's-Wort G4 S1 

Hypericum Majus Larger Canadian St. John's 

Wort 

G5 S1 E 

Hypericum Prolificum Shrubby St. John's-Wort G5 S1 E 

Hypericum Pyramidatum Great St. John's-Wort G4 S3 

Ilex Montana Large-Leaf Holly G5 S1 E 

Isanthus Brachiatus False Pennyroyal G4G5 S1 E 

Isoetes Lacustris Lake Quillwort G5 S1.1 E 

Isoetes Melanopoda Black-Base Quillwort G5 SH E 

Isoetes Riparia var. Riparia Shore Quillwort G5?T5?

Q 

S3 

Isoetes Tuckermanii Tuckerman's Quillwort G4? SH.1 E 

Isotria Medeoloides Small Whorled Pogonia G2 S1 LT E 

Jeffersonia Diphylla Twinleaf G5 S1 E 

Juglans Cinerea Butternut G3G4 S3S4 

Juncus Articulatus Jointed Rush G5 S2 

Juncus Brachycarpus Short-Fruit Rush G4G5 SH E 

Juncus Brachycephalus Fen Rush G5 S3 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 327

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Juncus Brevicaudatus Narrow-Panicle Rush G5 S2 

Juncus Caesariensis New Jersey Rush G2 S2 E LP 

Juncus Coriaceus Awl-Leaf Rush G5 S1 E 

Juncus Dudleyi Dudley's Rush G5 S3 

Juncus Elliottii Elliott's Rush G4G5 SH.1 E 

Juncus Greenei Greene's Rush G5 S2 

Juncus Nodosus var. Nodosus Knotted Rush G5T? S3S4 

Juncus Torreyi Torrey's Rush G5 S1 E 

Juniperus Communis var.

Depressa 

Dwarf Juniper G5T5 S3 

Kalmia Polifolia Pale-Laurel G5 S1 E 

Kosteletzkya Virginica Virginia Seashore-Mallow G5 S3S4 

Krigia Dandelion Potato Dwarf-Dandelion G5 SH.1 E 

Kuhnia Eupatorioides False Boneset G5T5 S1 E 

Lactuca Floridana var.

Floridana 

Florida Blue Lettuce G5T5? S3S4 

Lactuca Graminifolia var.

Graminifolia 

Grass-Leaf Lettuce G5?T3T

5 

S1 

Lactuca Hirsuta var.

Sanguinea 

Red-Stem Hairy Lettuce G5?T5? S3 

Larix Laricina American Larch G5 S3S4 

Lathyrus Japonicus var.

Maritimus 

Smooth Beach-Pea G5T4T5 SH 

Lathyrus Ochroleucus Cream Vetchling G4G5 SH E 

Lathyrus Palustris Marsh Vetchling G5 S3S4 

Lathyrus Venosus Veiny Vetchling G5 SH E 

Lechea Intermedia var.

Intermedia 

Large-Pod Pinweed G5T4T5 S2 

Lechea Pulchella var.

Pulchella 

Leggett's Pinweed G5T4 S3S4 

Lechea Tenuifolia Narrow-Leaf Pinweed G5 S1 E 

Ledum Groenlandicum Labrador Tea G5 S1 

Lemna Perpusilla Minute Duckweed G5 S1 E 

Lemna Trisulca Star Duckweed G5 S3 

Lemna Valdiviana Pale Duckweed G5 S1 E 

Leptochloa Fascicularis var.

Maritima 

Long-Awn Sprangletop G5T3T4

Q 

S2 

Lespedeza Stuevei Stueve's Downy Bush-Clover G4? S2 

Lespedeza Violacea Violet Bush-Clover G5 S3S4 

Liatris Pilosa var. Lasia Pine Barren Blazing-Star G5?T? S3 

Liatris Scariosa var. NovaeAngliae Northern Blazing-Star G5?T3 SH E 

Liatris Spicata var. Spicata Blazing-Star G5T5? S3S4 

Lilium Philadelphicum var.

Philadelphicum 

Wood Lily G5T4T5 S3 

Limosella Subulata Awl-Leaf Mudwort G4G5 S1 E 

Linnaea Borealis Twinflower G5T5 SH E 
APPENDIXES

328 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Linum Intercursum Sandplain Flax G4 S1 E 

Linum Sulcatum Grooved Yellow Flax G5T5 S1 E 

Linum Virginianum Woodland Flax G4G5 S3S4 

Liparis Lilifolia Lilia-Leaf Twayblade G5 S3S4 

Listera Australis Southern Twayblade G4 S2 LP 

Listera Cordata Heartleaf Twayblade G5T5 S1 E 

Listera Smallii Appalachian Twayblade G4 S1.1 E 

Lithospermum Canescens Hoary Puccoon G5 SX 

Lobelia Boykinii Boykin's Lobelia G2G3 S1 E LP 

Lobelia Canbyi Canby's Lobelia G4 S3 LP 

Lobelia Dortmanna Water Lobelia G4 SH E 

Lobelia Kalmii Kalm's Lobelia G5 S3S4 

Lobelia Puberula var. Puberula Downy Lobelia G5T5 S3S4 

Lonicera Canadensis American Fly-Honeysuckle G5 S1 E 

Lonicera Dioica Smooth-Leaf Honeysuckle G5 S3S4 

Lonicera Sempervirens var.

Sempervirens 

Trumpet Honeysuckle G5T5 S3S4 

Ludwigia Brevipes Tucker's Island PrimroseWillow 

G4G5 SX.1 

Ludwigia Hirtella Hairy Primrose-Willow G5 S2 LP 

Ludwigia Linearis Narrow-Leaf Primrose-Willow G5 S2 LP 

Lupinus Perennis Wild Lupine G5 S3 

Lupinus Perennis var.

Occidentalis 

Hairy Sundial Lupine G5T? S2 

Lupinus Perennis var.

Perennis 

Sundial Lupine G5T? S3 

Luzula Acuminata Hairy Wood-Rush G5T4T5 S2 E 

Luzula Bulbosa Bulblet Wood-Rush G5 S3S4 

Lycopodiella Caroliniana var.

Caroliniana 

Carolina Club-Moss G5T4 S3S4 

Lycopodiella Inundata Northern Bog Club-Moss G5 S2 

Lycopodium Annotinum Stiff Club-Moss G5 S1 E 

Lycopodium Hickeyi Hickey's Ground-Pine G5 S1S2? 

Lycopodium Tristachyum Wiry Ground-Cedar G5 S3S4 

Lycopus Americanus var.

Longii 

Long's Bugleweed G5T? S2S3 

Lycopus Rubellus Stalked Water-Hoarhound G5 S2 

Lygodium Palmatum Climbing Fern G4 S2 LP 

Lysimachia Hybrida Lowland Loosestrife G5 S3 

Lysimachia Lanceolata Lance-Leaf Loosestrife G5 SH 

Lysimachia Thyrsiflora Tufted Loosestrife G5 S3 

Lythrum Alatum var. Alatum Winged Loosestrife G5T5 S3 

Lythrum Lineare Narrow-Leaf Loosestrife G5 S3 

Maianthemum Canadense var.

Interius 

Western False Lily-Of-TheValley G5T4 S1.1 E 

Maianthemum Stellatum Star-Flower Spikenard G5 S3S4 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 329

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Malaxis Bayardii Bayard Long's Adder's-Mouth G2 SH E 

Malaxis Monophyllos White Adder's-Mouth G4Q SH E 

Malaxis Unifolia Green Adder's-Mouth G5 S2 

Malus Angustifolia var.

Puberula 

Spiny Wild Crabapple G5?T2T

4 

S2 

Malus Coronaria American Crabapple G5 S3S4 

Melanthium Latifolium Broad-Leaf Bunchflower G5 S3S4 

Melanthium Virginicum Virginia Bunchflower G5 S1 E 

Menyanthes Trifoliata Buck-Bean G5 S3 

Mertensia Virginica Virginia Bluebells G5 S3S4 

Micranthemum 

Micranthemoides 

Nuttall's Mudwort GH SH E 

Milium Effusum Tall Millet Grass G5 SH.1 E 

Mimulus Alatus Winged Monkey-Flower G5 S3 

Mimulus Moschatus var.

Moschatus 

Muskflower G4G5T? S2 

Mitella Prostrata Creeping Bishop's-Cap G2G4Q SH.1 

Monarda Clinopodia Basil Beebalm G5 SH E 

Monarda Didyma Oswego-Tea G5 S2 

Monarda Media Purple Bergamot G4? SH 

Monotropa Hypopithys Pinesap G5 S3S4 

Morella Caroliniensis Sensu 

Stricto 

Evergreen Bayberry G? S2S4 

Muhlenbergia Capillaris Long-Awn Smoke Grass G5T? S1 E 

Muhlenbergia Glomerata Eastern Smoke Grass G5 S2 

Muhlenbergia Sylvatica var. 

Robusta 

Large Woodland Dropseed G5T? S2 

Muhlenbergia Sylvatica var.

Sylvatica 

Woodland Dropseed G5T? S3 

Muhlenbergia Torreyana Pine Barren Smoke Grass G3 S3 LP 

Myosotis Verna Spring Forget-Me-Not G5 S3S4 

Myrica Gale Sweetgale G5 S3 

Myriophyllum Heterophyllum Variable-Leaf Water-Milfoil G5 S2 

Myriophyllum Pinnatum Cutleaf Water-Milfoil G5 S1 E 

Myriophyllum Sibiricum Common Water-Milfoil G5 S1 E 

Myriophyllum Tenellum Slender Water-Milfoil G5 S1 E 

Myriophyllum Verticillatum Whorled Water-Milfoil G5 SH E 

Najas Gracillima Thread-Nymph G5? S3S4 

Najas Guadalupensis var.

Guadalupensis 

Southern Water-Nymph G5T5 S3 

Narthecium Americanum Bog Asphodel G2 S2 C E LP 

Nelumbo Lutea American Lotus G4 S1 E 

Nuphar Lutea Ssp Rubrodisca Red-Disk Yellow Pond-Lily G5T3T5 S3 

Nuphar Microphyllum Small Yellow Pond-Lily G5T4T5 SH E 

Nymphaea Odorata Ssp 

Tuberosa 

Tuberous White Water-Lily G5T5 S2 

Nymphoides Cordata Floatingheart G5 S3 LP 
APPENDIXES

330 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Obolaria Virginica Virginia Pennywort G5 S2 

Oenothera Fruticosa ssp. 

Glauca 

Common Sundrops G5T5 S3S4 

Oenothera Humifusa Sea-Beach Evening-Primrose G5 S2 E 

Oenothera Nutans Nodding Evening-Primrose G4 S2S4 

Oenothera Oakesiana Oakes' Evening-Primrose G4G5Q S2 

Oenothera Parviflora Northern Evening-Primrose G4? S3S4 

Oenothera Perennis Small Sundrops G5 S3S4 

Oenothera Villosa Ssp Villosa Hairy Evening-Primrose G5T? S1 

Oldenlandia Uniflora Clustered-Bluets G5 S3 

Onosmodium Virginianum Virginia False-Gromwell G4 S1 E 

Ophioglossum Pusillum Northern Adder's-Tongue G5 S3 

Ophioglossum Vulgatum var.

Pycnostichum 

Southern Adder's-Tongue G5 SH E 

Orobanche Uniflora Naked Broom-Rape G5 S3S4 

Orthilia Secunda Sidebells G5 S2 

Oryzopsis Asperifolia White-Grained Mountain-Rice 

Grass 

G5 S1 E 

Oryzopsis Pungens Slender Mountain-Rice Grass G5 SH.1 E 

Osmunda Cinnamomea var.

Glandulosa 

Glandular Cinnamon Fern G5T? S2 

Oxalis Violacea Violet Wood-Sorrel G5 S3S4 

Panax Quinquefolius American Ginseng G3G4 S2 

Panicum Aciculare Bristling Panic Grass G4G5 S1 E 

Panicum Acuminatum var.

Acuminatum 

Walter Benner's Panic Grass G5T5 SH 

Panicum Amarum var.

Amarulum 

Southern Seabeach Grass G5TU S3 

Panicum Anceps Beaked Panic Grass G5 S3S4 

Panicum Boreale Northern Panic Grass G5 S1 E 

Panicum Dichotomum var.

Roanokense 

Bluish Panic Grass G5T4? SH 

Panicum Dichotomum var.

Yadkinense 

Spotted-Sheath Panic Grass G5T3T4

Q 

SH 

Panicum Flexile Wiry Panic Grass G5 S1 E 

Panicum Gattingeri Gattinger's Witch Grass G4 S1S2 

Panicum Hemitomon Maiden-Cane G5? S2 LP 

Panicum Hirstii Hirst Brothers' Panic Grass G1 S1 C E LP 

Panicum Leucothrix Rough Panic Grass G4?Q S2 

Panicum Linearifolium Linear-Leaf Panic Grass G5 S3S4 

Panicum Longiligulatum Coastal-Plain Panic Grass G4G5Q SH.1 

Panicum Oligosanthes var.

Oligosanthes 

Few-Flower Panic Grass G5T5? S1S2 

Panicum Oligosanthes var.

Scribnerianum 

Scribner's Panic Grass G5T5 S2 

Panicum Rigidulum var.

Condensum 

Dense Panic Grass G5T? S2 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 331

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Panicum Sabulorum var.

Patulum 

Hemlock Witchgrass G5T5 S3S4 

Panicum Scabriusculum Sheathed Panic Grass G4 S2 

Panicum Sphaerocarpon var.

Isophyllum 

Small Round-Fruit Panic Grass G5T5 S3S4 

Panicum Tenue White-Edge Panic Grass G5T4T5 SH 

Panicum Wrightianum Wright's Panic Grass G4 S2 

Panicum Xanthophysum Slender Panic Grass G5 SH.1 E 

Parietaria Pensylvanica Pennsylvania Pellitory G5 S3S4 

Paronychia Fastigiata var.

Paleacea 

Chaffy Forked Nailwort G5T3T5 S3S4 

Paronychia Montana Mountain Nailwort G4 SH 

Parthenocissus Vitacea Thicket Creeper G5 S3S4 

Paspalum Dissectum Mudbank Crown Grass G4? S2 

Paspalum Floridanum Florida Crown Grass G5 S3 

Paspalum Laeve var. Pilosum Long-Hair Crown Grass G4T?Q S3S4 

Paspalum Setaceum var. 

Ciliatifolium 

Ciliate-Leaf Crown Grass G5T5Q S2 

Paspalum Setaceum var.

Psammophilum 

Prostrate Crown Grass G5T4? S2S3 

Pedicularis Lanceolata Swamp Lousewort G5 S3 

Pellaea Glabella var. Glabella Smooth Cliffbrake G5T5 S2 

Penstemon Laevigatus Smooth Beardtongue G5 S1 E 

Phaseolus Polystachios var.

Polystachios 

Wild Kidney Bean G4T? S2 

Phegopteris Connectilis Northern Beech Fern G5 S2 

Phlox Divaricata Wild Blue Phlox G5T? S1 E 

Phlox Maculata var. Maculata Spotted Phlox G5T? S3 

Phlox Pilosa Downy Phlox G5T5 SH E 

Phoradendron Leucarpum American Mistletoe G5 S2 LP 

Phyla Lanceolata Fogfruit G5 SH E 

Physalis Grisea Strawberry-Tomato G? S1 

Physalis Longifolia var.

Subglabrata 

Smooth Ground-Cherry G5T4T5 S3S4 

Physalis Pubescens var.

Integrifolia 

Husk-Tomato G5T5?Q SH 

Picea Mariana var. Mariana Black Spruce G5T5 S3S4 

Picea Rubens Red Spruce G5 S1 E 

Pilea Fontana Lesser Clearweed G5 S3S4 

Pinus Pungens Table Mountain Pine G4 S1.1 E 

Pinus Resinosa Red Pine G5 S1.1 E 

Pinus Serotina Pond Pine G5 S2 

Pinus Taeda Loblolly Pine G5 S2 

Pityopsis Falcata Sickle-Leaf Golden-Aster G3G4 S3 LP 

Plantago Major var. 

Scopulorum 

Salt-Marsh Plantain G5T? S3 
APPENDIXES

332 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Plantago Maritima var.

Juncoides 

Seaside Plantain G5T5 S2 

Plantago Pusilla Dwarf Plantain G5 SH E 

Platanthera Ciliaris Yellow Fringed Orchid G5 S2 LP 

Platanthera Cristata Crested Yellow Orchid G5 S3 LP 

Platanthera Flava var. Flava Southern Rein Orchid G4T4?Q S1 E 

Platanthera Flava Var.

Herbiola 

Tubercled Rein Orchid G4T4Q S2 

Platanthera Grandiflora Large Purple Fringed Orchid G5 S2 

Platanthera Hookeri Hooker's Orchid G5 S1 E 

Platanthera Hyperborea var.

Hyperborea 

Leafy Northern Green Orchid G5T5 SX 

Platanthera Integra Yellow Fringeless Orchid G3G4 S1 E LP 

Platanthera Nivea Snowy Orchid G5 SH E 

Platanthera Orbiculata Round-Leaf Orchid G5? S1 E 

Platanthera Peramoena Purple Fringeless Orchid G5 S1 E 

Platanthera Psycodes Purple Fringed Orchid G5 S2 

Pluchea Camphorata Camphorweed G5 SX.1 

Pluchea Foetida Stinking Fleabane G5T5 S1 E 

Poa Autumnalis Flexuous Spear Grass G5 SH.1 E 

Poa Languida Drooping Spear Grass G3G4Q S2 

Poa Saltuensis Old-Pasture Spear Grass G5 SH E 

Poa Sylvestris Woodland Spear Grass G5 SH 

Podostemum Ceratophyllum Threadfoot G5 S3 

Polanisia Dodecandra ssp.

Dodecandra 

Clammy-Weed G5T? S1 

Polemonium Reptans Greek-Valerian G5 S1 E 

Polemonium Vanbruntiae Jacob's Ladder G3 SX.1 

Polygala Ambigua Loose-Spike Milkwort G5? S2 

Polygala Incarnata Pink Milkwort G5 SH E 

Polygala Mariana Maryland Milkwort G5 S2 LP 

Polygala Paucifolia Fringed Milkwort G5 S3S4 

Polygala Polygama Racemed Milkwort G5 S2 

Polygala Ramosa Low Pine Barren Milkwort G5 SX.1 

Polygala Senega Seneca Snakeroot G4G5 S1.1 E 

Polygala Verticillata var.

Isocycla 

Fernald's Whorled Milkwort G5T5 S3S4 

Polygonatum Biflorum var.

Commutatum 

Giant Solomon's-Seal G5T5 S3S4 

Polygonum Amphibium var. 

Stipulaceum 

Water Smartweed G5T5 S3S4 

Polygonum Buxiforme Small's Knotweed G5 S2 

Polygonum Cilinode Fringed Black-Bindweed G5 S3 

Polygonum Densiflorum Dense-Flower Knotweed G5 S1 E 

Polygonum Erectum Erect Knotweed G5 S1 

Polygonum Glaucum Sea-Beach Knotweed G3 S1 E 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 333

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Polygonum Hydropiperoides 

Var. Opelousanum 

Opelousas Water-Pepper G?Q S2 

Polygonum Robustius Stout Smartweed G4G5 S3S4 

Polygonum Setaceum var.

Setaceum 

Bristly Smartweed G5T3T5 S2 

Polygonum Tenue Slender Knotweed G5 S3S4 

Polymnia Uvedalia Bear's-Foot G4G5 S1 E 

Populus Heterophylla Swamp Cottonwood G5 S2 

Porteranthus Trifoliatus Indian Physic G4G5 S2 

Potamogeton Alpinus Northern Pondweed G5 S1 E 

Potamogeton Confervoides Algae-Like Pondweed G4 S3 

Potamogeton Illinoensis Illinois Pondweed G5 S1 E 

Potamogeton Natans Floating Pondweed G5 S3S4 

Potamogeton Nodosus Long-Leaf Pondweed G5 S3S4 

Potamogeton Oakesianus Oakes' Pondweed G4 S2 

Potamogeton Obtusifolius Blunt-Leaf Pondweed G5 S1 E 

Potamogeton Praelongus White-Stem Pondweed G5 S1 E 

Potamogeton Pulcher Spotted Pondweed G5 S3S4 

Potamogeton Robbinsii Robbin's Pondweed G5 S2 E 

Potamogeton Spirillus Spiral Pondweed G5 S3S4 

Potamogeton Vaginatus Sheathed Pondweed G5 SH 

Potamogeton Zosteriformis Eel-Grass Pondweed G5 S1 E 

Potentilla Arguta var. Arguta Tall Cinquefoil G5T? S3 

Potentilla Palustris Marsh Cinquefoil G5 S1 E 

Potentilla Tridentata Three-Toothed Cinquefoil G5 S1.1 E 

Prenanthes Autumnalis Pine Barren Rattlesnake-Root G4G5 S2 LP 

Prenanthes Racemosa Smooth Rattlesnake-Root G5T? SH E 

Proserpinaca Intermedia Mackenzie's Mermaidweed G3G4Q S3 

Prunus Alleghaniensis Allegheny Plum G4T4 S1 E 

Prunus Angustifolia Chickasaw Plum G5T4T5 S2 E 

Prunus Pumila var. Depressa Low Sand Cherry G5T5 S2 

Prunus Pumila var.

Susquehanae 

Appalachian Cherry G5T4 S3 

Ptelea Trifoliata Wafer-Ash G5T5 S1 E 

Puccinellia Fasciculata Saltmarsh Alkali Grass GU S2 

Pycnanthemum Clinopodioides Basil Mountain-Mint G2 S1 E 

Pycnanthemum Setosum Awned Mountain-Mint G3? S3 

Pycnanthemum Torrei Torrey's Mountain-Mint G2 S1 E 

Pyrola Chlorantha Greenish-Flower Wintergreen G5 S1 E 

Quercus Imbricaria Shingle Oak G5 S1.1 E 

Quercus Lyrata Overcup Oak G5 S1 E 

Quercus Michauxii Basket Oak G5 S3 

Quercus Muehlenbergii Yellow Oak G5 S3 

Quercus Nigra Water Oak G5 S1 E 

Quercus Prinoides Dwarf Chestnut Oak G5 S3S4 
APPENDIXES

334 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Ranunculus Allegheniensis Allegheny Mountain Buttercup G4G5 S1.1 E 

Ranunculus Ambigens Water-Plantain Spearwort G4 S2 

Ranunculus Cymbalaria Seaside Buttercup G5 SH E 

Ranunculus Fascicularis Early Buttercup G5 S1 E 

Ranunculus Flabellaris Yellow Water Buttercup G5 S3 

Ranunculus Longirostris Long-Beak Water Buttercup G5 S2 

Ranunculus Micranthus Rock Buttercup G5 S2 

Ranunculus Pensylvanicus Bristly Buttercup G5 S3 

Ranunculus Pusillus var.

Pusillus 

Low Spearwort G5T4? S2 

Ranunculus Reptans Creeping Spearwort G5T5 SH E 

Ranunculus Trichophyllus var.

Trichophyllus 

Thread-Leaf Water Buttercup G5T5 S2 

Rhamnus Alnifolia Alder-Leaf Buckthorn G5 S3S4 

Rhexia Aristosa Awned Meadow-Beauty G3 S1 E LP 

Rhexia Interior Showy Meadow-Beauty G5T4T5 S1 E 

Rhododendron Atlanticum Dwarf Azalea G4G5 S1 E 

Rhododendron Canadense Rhodora G5 S1 E 

Rhododendron Prinophyllum Mountain Azalea G5 S3 

Rhynchospora Capillacea Capillary Beaked-Rush G5 S1 E 

Rhynchospora Cephalantha Large-Head Beaked-Rush G5 S3 LP 

Rhynchospora Filifolia Thread-Leaf Beaked-Rush G5 S1 E 

Rhynchospora Globularis Coarse Grass-Like BeakedRush 

G5? S1 E 

Rhynchospora Glomerata Clustered Beaked-Rush G5T5? SH E 

Rhynchospora Inundata Slender Horned-Rush G3G4 S2 LP 

Rhynchospora Knieskernii Knieskern's Beaked-Rush G1 S1 LT E LP 

Rhynchospora Microcephala Small-Head Beaked-Rush G5T5 S1 v 

Rhynchospora Nitens Short-Beaked Bald-Rush G4? S2 

Rhynchospora Oligantha Few-Flower Beaked-Rush G4 S2 

Rhynchospora Pallida Pale Beaked-Rush G3 S3 

Rhynchospora Rariflora Rare-Flower Beaked-Rush G5 S1 E 

Rhynchospora Scirpoides Long-Beak Bald-Rush G4 S2 

Ribes Cynosbati Prickly Gooseberry G5 SH 

Ribes Glandulosum Skunk Currant G5 S1.1 E 

Ribes Missouriense Missouri Gooseberry G5 S1 E 

Ribes Triste Swamp Red Currant G5 S1 

Rosa Blanda var. Blanda Smooth Rose G5T?Q SH 

Rotala Ramosior Toothcup G5 S3 

Rubus Alumnus Oldfield Blackberry G5 S2 

Rubus Andrewsianus Andrew's Blackberry G4? S3 

Rubus Argutus Saw-Tooth Blackberry G5 S1 

Rubus Ascendens Clausen's Dewberry G? S1 

Rubus Canadensis Smooth Blackberry G5 S1 E 

Rubus Depavitus Aberdeen Blackberry G5?Q S1S2 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 335

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Rubus Elegantulus Showy Blackberry G4?Q S1 

Rubus Enslenii Southern Dewberry G4G5Q S2S3 

Rubus Gnarus Pollock's Mill Blackberry G3? SH.1 

Rubus Hypolasius Pineland Dewberry G1?Q S1 

Rubus Longii Long's Blackberry G4?Q S1 

Rubus Michiganensis Michigan Dewberry G5?Q S2S3 

Rubus Novocaesarius New Jersey Dewberry G1? SH.1 

Rubus Originalis Cold Spring Blackberry G3? S2 

Rubus Ostryifolius Highbush Blackberry G3?Q SH.1 

Rubus Parcifrondifer Silver Creek Blackberry GUQ SH 

Rubus Pervarius Davis' Dewberry G4? SH.1 

Rubus Plicatifolius Plait-Leaf Dewberry G5 S2S3 

Rubus Recurvicaulis Blanchard's Dewberry G4? S1.1 

Rubus Roribaccus Lucretia Blackberry G4?Q S2S3 

Rubus Setosus Bristly Blackberry G5 SH.1 

Rudbeckia Fulgida Orange Coneflower G5T4? S1 E 

Rudbeckia Fulgida var.

Speciosa 

Showy Coneflower G5T4? SH.1 

Ruellia Caroliniensis Carolina Petunia G5 SH E 

Ruellia Strepens Limestone Petunia G4G5 SX.1 

Rumex Hastatulus Engelmann's Sorrel G5 SH 

Sabatia Campanulata Slender Marsh-Pink G5 S3 

Sabatia Dodecandra var.

Dodecandra 

Large Marsh-Pink G5?T4T

5 

S2 

Saccharum Alopecuroidum Silver Plume Grass G5 SH 

Saccharum Giganteum Giant Plume Grass G5 S3S4 

Sacciolepis Striata American Cupscale G5 SH E 

Sagittaria Australis Southern Arrowhead G5 S1 E 

Sagittaria Calycina var.

Calycina 

Mississippi Arrowhead G5T5? S2 

Sagittaria Calycina var.

Spongiosa 

Tidal Arrowhead G5T4 S3 

Sagittaria Cuneata Arum-Leaf Arrowhead G5 S1 E 

Sagittaria Filiformis Narrow-Leaf Arrowhead G4G5 SH 

Sagittaria Latifolia var.

Pubescens 

Hairy Arrowhead G5T5 SH 

SAGITTARIA SUBULATA AWL-LEAF ARROWHEAD G4 S2 

Sagittaria Teres Slender Arrowhead G3 S1 E 

Salix Candida Hoary Willow G5 S2 

Salix Humilis var .Tristis Dwarf Upland Willow G5T4T5 S3S4 

Salix Lucida Ssp Lucida Shining Willow G5T5 S1 

Salix Pedicellaris Bog Willow G5 S1 E 

Salix Petiolaris Meadow Willow G5 S3S4 

Salix Serissima Autumn Willow G4 S2 

Sambucus Racemosa var.

Pubens 

Red Elderberry G5T5 S3S4 
APPENDIXES

336 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Sanicula Trifoliata Large-Fruit Black-Snakeroot G4 S1 E 

Saxifraga Pensylvanica Swamp Saxifrage G5 S3S4 

Scheuchzeria Palustris Arrow-Grass G5T5 SH E 

Schizachne Purpurascens Purple Oat G5 S1 E 

Schizaea Pusilla Curly Grass Fern G3 S3 LP 

Schoenoplectus Acutus var.

Acutus 

Hard-Stem Bulrush G5 S3 

Schoenoplectus NovaeAngliae 

New England Bulrush G5 S2 

Schoenoplectus Smithii Smith's Club-Rush G5? S2 

Schoenoplectus Torreyi Torrey's Bulrush G5? S1 E 

Schwalbea Americana Chaffseed G2 S1 LE E LP 

Scirpus Atrocinctus Black-Girdle Woolgrass G5 S1 

Scirpus Expansus Woodland Bulrush G4 S3S4 

Scirpus Longii Long's Woolgrass G2 S2 E LP 

Scirpus Maritimus Saltmarsh Bulrush G5 SH E 

Scirpus Microcarpus Barberpole Bulrush G5 S1 E 

Scirpus Pedicellatus Stalked Woolgrass G4 SH E 

Scirpus Pendulus Reddish Bulrush G5 S3 

Scleria Pauciflora var.

Caroliniana 

Carolina Nut-Rush G5T4T5 S2 

Scleria Pauciflora var.

Pauciflora 

Papillose Nut-Rush G5T? S1 

Scleria Verticillata Whorled Nut-Rush G5 S1 E 

Sclerolepis Uniflora Bog Buttons G4 S2 LP 

Scutellaria Leonardii Small Skullcap G4T4 S1 E 

Scutellaria Nervosa Veined Skullcap G5 S2 

Sedum Telephioides Allegheny Stonecrop G4 SX.1 

Selaginella Rupestris Rock Spike-Moss G5 S2 

Senecio Anonymus Small's Groundsel G5 SH 

Senecio Pauperculus Balsam Ragwort G5 S3 

Senecio Tomentosus Woolly Ragwort G4G5 S2 

Senna Hebecarpa Northern Wild Senna G5 S3S4 

Sesuvium Maritimum Seabeach Purslane G5 S2 

Setaria Magna Giant Fox-Tail G4G5 S2 

Silene Caroliniana var.

Pensylvanica 

Wild-Pink G5T4 S3 

Silene Nivea Snowy Catchfly G4? S1 E 

Sisyrinchium Fuscatum Sand-Plain Blue-Eyed Grass G5? S2 

Sisyrinchium Montanum Strict Blue-Eyed Grass G5T4 S2 E 

Smilacina Trifolia Three-Leaf False Solomon'sSeal 

G5 S1 E 

Smilax Hispida Bristly Greenbrier G5 S3 

Smilax Laurifolia Laurel-Leaf Greenbrier G5 S3S4 

Smilax Pseudochina Bamboo Vine G4G5 S3 

Smilax Pulverulenta Downy Carrion-Flower G4G5 S3 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 337

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Smilax Walteri Coral Greenbrier G5 S3S4 

Solidago Elliottii Elliott's Goldenrod G5 S3 

Solidago Hispida var Hispida Hairy Goldenrod G5T5 SH 

Solidago Rigida Prairie Goldenrod G5T5 S1 E 

Solidago Rugosa Ssp Rugosa 

var. Sphagnophila 

Summer Goldenrod G5T? S3 

Solidago Speciosa var.

Speciosa 

Showy Goldenrod G5T5? S3 

Solidago Squarrosa Stout Ragged Goldenrod G4? S3S4 

Solidago Stricta Wand-Like Goldenrod G5 S3 LP 

Solidago Tarda Late Goldenrod G4?Q S3 

Solidago Uliginosa var 

Linoides 

Flax-Leaf Bog Goldenrod G4G5T? S3 

Solidago Uliginosa var.

Uliginosa 

Bog Goldenrod G4G5T? S2S3 

Sorbus Americana American Mountain-Ash G5 S3S4 

Sparganium Angustifolium Narrow-Leaf Burr-Reed G5 SH E 

Sparganium Chlorocarpum Green-Fruited Bur-Reed G5 S3 

Sparganium Eurycarpum Large Burr-Reed G5 S3S4 

Sparganium Minimum Small Burr-Reed G5 S1 E 

Sphagnum Angustifolium Sphagnum G5 S1 E 

Sphagnum Austinii Sphagnum G4 SH E 

Sphagnum Capillifolium Sphagnum G5 S2 

Sphagnum Carolinianum Sphagnum G3 S2 

Sphagnum Centrale Sphagnum G5 S1 E 

Sphagnum Contortum Sphagnum G5 S1 E 

Sphagnum Cyclophyllum Sphagnum G3 S2 

Sphagnum Fuscum Sphagnum G5 S2 

Sphagnum Macrophyllum Sphagnum G3 S2 

Sphagnum Macrophyllum var. 

Floridanum 

Sphagnum G3T3 S1 E 

Sphagnum Majus ssp.

Norvegicum 

Sphagnum G5?T? S1.1 E 

Sphagnum Perichaetiale Sphagnum G5 S2 

Sphagnum Platyphyllum Sphagnum G5 SH.1 E 

Sphagnum Portoricense Sphagnum G5 S2 

Sphagnum Quinquefarium Sphagnum G5 S1 E 

Sphagnum Riparium Sphagnum G5 S1 E 

Sphagnum Squarrosum Sphagnum G5 S2 

Sphagnum Strictum Sphagnum G5 S1 E 

Sphagnum Subfulvum Sphagnum G? S1.1 E 

Sphagnum Subsecundum Sphagnum G5 S1 E 

Sphagnum Subtile Sphagnum G5?Q S2 

Sphagnum Tenellum Sphagnum G5 S2 

Sphagnum Teres Sphagnum G5 S2 

Sphagnum Warnstorfii Sphagnum G5 S2 
APPENDIXES

338 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Sphenopholis Pensylvanica Swamp Oats G4 S2 

Spiraea Alba var. Alba Narrow-Leaf Meadow-Sweet G5T5 S1 

Spiranthes Laciniata Lace-Lip Ladies'-Tresses G4G5 S1 E 

Spiranthes Lucida Shining Ladies'-Tresses G5 S2 

Spiranthes Ochroleuca Yellowish Nodding Ladies'-

Tresses 

G4 S3 

Spiranthes Odorata Fragrant Ladies'-Tresses G5 S2 

Spiranthes Tuberosa Little Ladies'-Tresses G5 S3 LP 

Spiranthes Vernalis Spring Ladies'-Tresses G5 S3S4 

Sporobolus Clandestinus Rough Rush-Grass G5 S3 

Sporobolus Compositus var.

Compositus 

Long-Leaf Rush-Grass G5T5 S2 

Sporobolus Neglectus Small Rush-Grass G5 S1 E 

Stachys Hyssopifolia Hyssop Hedge-Nettle G5 S2 

Stachys Palustris var.

Homotricha 

Hairy Hedge-Nettle G5T? SH E 

Stachys Tenuifolia Smooth Hedge-Nettle G5 S3 

Stellaria Alsine Bog Chickweed G5 S3S4 

Stellaria Borealis Boreal Starwort G5T5 S1 E 

Stellaria Pubera Star Chickweed G5 SH E 

Streptopus Amplexifolius White Twisted-Stalk G5T5 S1 E 

Streptopus Roseus Rosy Twisted-Stalk G5T5? S1 E 

Stylisma Pickeringii var.

Pickeringii 

Pickering's Morning-Glory G4T2T3 S1 E LP 

Stylosanthes Biflora Pencil-Flower G5 S3 

Suaeda Calceoliformis American Seablite G5 S2 

Suaeda Rolandiiia Integerrima Yellow-Pimpernel G5 S3S4 

Taxus Canadensis American Yew G5 S2 

Teucrium Canadense var.

Canadense 

American Germander G5T5 S3S4 

Teucrium Canadense var.

Occidentale 

Hairy Germander G5T5? SH 

Thalictrum Revolutum Waxy Meadow Rue G5 S3S4 

Thaspium Barbinode Hairy-Joint Meadow-Parsnip G5 SX 

Thaspium Trifoliatum var.

Trifoliatum 

Purple Meadow-Parsnip G5T5 S3 

Thuja Occidentalis Arborvitae G5 S1 E 

Tiarella Cordifolia Foamflower G5T5 S1 E 

Tipularia Discolor Cranefly Orchid G4G5 S3 

Tofieldia Racemosa False Asphodel G5 S1 E LP 

Torreyochloa Pallida var.

Fernaldii 

Fernald's False Manna Grass G5?T4Q S1 

Toxicodendron Pubescens Poison-Oak G5 S3 

Tradescantia Ohiensis Ohio Spiderwort G5 S2 

Triadenum Fraseri Fraser's St. John's-Wort G4G5 S3 

Triadenum Walteri Walter's St. John's-Wort G5 S1 E 

Trichomanes Intricatum Weft Fern G3G4 S1.1 E 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 339

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Trichostema Setaceum Narrow-Leaf Bluecurls G5 S2 

Tridens Flavus var. Chapmanii Chapman's Redtop G5T? SH E 

Trifolium Reflexum Buffalo Clover G5 SX 

Triglochin Maritima Seaside Arrow-Grass G5 S1 E 

Trillium Erectum Red Trillium G5 S3S4 

Trillium Undulatum Painted Trillium G5 S3 

Triosteum Angustifolium Narrow-Leaf Horse-Gentian G5 S1 E 

Triphora Trianthophora Three Birds Orchid G3G4 S1 E 

Trollius Laxus ssp. Laxus Spreading Globe Flower G4T3 S1 E 

Ulmus Thomasii Rock Elm G5 SX.1 

Utricularia Biflora Two-Flower Bladderwort G5 S1 E 

Utricularia Gibba Humped Bladderwort G5 S3 LP 

Utricularia Inflata Large Swollen Bladderwort G5 S1 

Utricularia Intermedia Flat-Leaf Bladderwort G5 S3 

Utricularia Minor Lesser Bladderwort G5 S1 

Utricularia Olivacea Dwarf White Bladderwort G4 S1.1 E LP 

Utricularia Purpurea Purple Bladderwort G5 S3 LP 

Utricularia Radiata Small Swollen Bladderwort G4 S3S4 

Utricularia Resupinata Reversed Bladderwort G4 S1 E LP 

Uvularia Puberula var. Nitida Pine Barren Bellwort G5T3? S2 E 

Vaccinium Oxycoccos Small Cranberry G5 S2 

Valerianella Chenopodiifolia Goose-Foot Cornsalad G5 SH.1 

Valerianella Radiata Beaked Cornsalad G5 S1 E 

Valerianella Umbilicata Navel Cornsalad G3G5 SH E 

Verbena Simplex Narrow-Leaf Vervain G5 S1 E 

Verbena Urticifolia var.

Leiocarpa 

Smooth-Fruit White Vervain G5T? S3S4 

Vernonia Glauca Broad-Leaf Ironweed G5 S1 E 

Veronica Catenata Sessile Water-Speedwell G5 S1 E 

Veronicastrum Virginicum Culver's-Root G4 S3S4 

Viburnum Alnifolium Witch-Hobble G5 S1 E 

Viburnum Dentatum var.

Venosum 

Veiny-Leaf Arrow-Wood 

G5T4T5 

S2 

Viburnum Opulus var.

Americanum 

Highbush-Cranberry G5T5 S3 

Vicia Americana var.

Americana 

American Purple Vetch G5T5 S2 

Vicia Caroliniana Carolina Wood Vetch G5 S1 E 

Viola Blanda var. 

Palustriformis 

Large-Leaf White Violet G4G5T4

T5 

S3 

Viola Brittoniana var.

Brittoniana 

Britton's Coast Violet G4G5T4

T5 

S3 

Viola Brittoniana var. Pectinata Cut-Leaf Coast Violet G4G5T3

?Q 

SH.1 

Viola Canadensis Canadian Violet G5T? S1 E 

Viola Hirsutula Southern Wood Violet G4 S2 
APPENDIXES

340 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Global 

Rank 

State 

Status 

Federal 

Status 

State 

Status 

Other 

Rank 

Viola Lanceolata var. Vittata Southern Lance-Leaf Violet G5T? S2S4 

Viola Rostrata Long-Spur Violet G5 S3S4 

Viola Rotundifolia Round-Leaf Violet G5 S3S4 

Viola Septentrionalis Northern Blue Violet G5 S1 E 

Viola Triloba var. Dilatata Dilated Violet G5T? S1.1 

Vitis Aestivalis var. Bicolor Blue Grape G5T4T5 S3S4 

Vulpia Elliotea Squirrel-Tail Six-Weeks Grass G5 S1 E 

Vulpia Octoflora var. Glauca Slender Six-Weeks Grass G5T5 SU 

Waldsteinia Fragarioides var.

Fragarioides 

Barren-Strawberry G5T5 S2 

Wolffia Brasiliensis Pointed Watermeal G5 S3S4 

Wolffiella Floridana Sword Bogmat G5 S1 E 

Woodsia Ilvensis Rusty Cliff Fern G5 S3S4 

Xanthium Strumarium var. 

Glabratum 

American Cockleburr G5T? S3S4 

Xyris Caroliniana Sand Yellow-Eyed-Grass G4G5 S1 E LP 

Xyris Fimbriata Fringed Yellow-Eyed-Grass G5 S1 E 

Xyris Jupicai Richard's Yellow-Eyed-Grass G5 S1 

Xyris Montana Northern Yellow-Eyed-Grass G4 S1.1 E 

Zigadenus Leimanthoides Death-Camus G4Q S1 E 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 341

ENDANGERED AND THREATENED WILDLIFE OF NEW JERSEY 

ENDANGERED AND NONGAME SPECIES PROGRAM 

NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION 

AND ENERGY 

DIVISION OF FISH, GAME AND WILDLIFE

Endangered Species are those whose prospects for survival in New Jersey are in immediate danger because of a 

loss or change in habitat, over-exploitation, predation, competition, disease, disturbance or contamination. 

Assistance is needed to prevent futurec extinction in New Jersey. For more information, visit the Endangered 

and Nongame Species Program web site. Threatened Species are those who may become endangered if 

conditions surrounding them begin to or continue to deteriorate. 

BIRDS 

Species Name Common Name 

Birds Endangered

Podilymbus podicepsa Pied-billed grebe 

Botaurus lentiginosusa American bittern 

Haliaeetus leucocephalusb Bald eagle 

Circus cyaneusa Northern harrier 

Accipiter gentilisa Northern goshawk 

Buteo lineatusa Red-shouldered hawk 

Falco peregrinus Peregrine falcon 

Charadrius melodusb Piping plover 

Bartramia longicauda Upland sandpiper 

Sterna dougalliib Roseate tern 

Sterna antillarum Least tern 

Rynchops nigera Black skimmer 

Asio flammeusa Short-eared owl 

Cistothorus platensis Sedge wren 

Lanius ludovicianus Loggerhead shrike 

Pooecetes gramineusa Vesper sparrow 

Ammodramus henslowii Henslow’s sparrow 

Birds Threatened 

Nycticorax nycticoraxa Black-crowned night heron 

Nyctanassa violaceus Yellow-crowned night heron 

Haliaeetus leucocephalusb,c Bald eagle 

Calidris canutusc Red knot 

Pandion haliaetusa Osprey 

Buteo lineatusc Red-shouldered hawk 

Accipiter cooperii Cooper’s hawk 

Laterallus jamaicensis Black rail 

Asio otus Long-eared owl 

Strix varia Barred owl 

Melanerpes erythrocephalus Red-headed woodpecker 
APPENDIXES

342 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

Species Name Common Name 

Rynchops nigerc Black skimmer 

Passerculus sandwichensisa Savannah sparrow 

Ammodramus savannaruma Grasshopper sparrow 

Dolichonyx oryzivorusa Bobolink 

Pooecetes gramineusc Vesper sparrow 

 

a. Only Breeding population considered endangered or threatened. 

b. Federally endangered or threatened. 

c. Nonbreeding population only. 

REPTILES 

Species Name Common Name 

Rebtiles Endangered

Clemmys muhlenbergia Bog turtle 

Eretmochelys imbricataa Atlantic hawksbill 

Caretta carettaa Atlantic loggerhead 

Lepidochelys kempia Atlantic ridley 

Dermochelys coriaceaa Atlantic leatherback 

Elaphe g. guttata Corn snake 

Crotalus h. horridus Timber rattlesnake 

Reptiles Threatened 

Clemmys insculpta Wood turtle 

Chelonia mydasa Atlantic green turtle 

Pituophis m. melanoleucus Northern pine snake 

 

a. Federally endangered or threatened. 

AMPHIBIANS 

Species Name Common Name 

Amphibians Endangered

Ambystoma tremblayi Tremblay’s salamander 

Ambystoma laterale Blue-spotted salamander 

Ambystoma t. tigrinum Eastern tiger salamander 

Hyla andersonii Pine Barrens treefrog 

Hyla chrysoscelis Southern gray treefrog 

Amphibians Threatened 

Eurycea longicauda Long-tailed salamander 

Pseudotriton montanus Eastern mud salamander 
Appendix E 

FINAL ENVIRONMENTAL IMPACT STATEMENT 343

MAMMALS 

Species Name Common Name 

Mammals Endangered

Myotis sodalisa Indiana bat 

Lynx rufus Bobcat 

Neotoma floridana Eastern woodrat 

Physeter macrocephalusa Sperm whale 

Balaenoptera physalusa Fin whale 

Balaenoptera borealisa Sei whale 

Balaenoptera musculusa Blue whale 

Megaptera novaeangliaea Humpback whale 

Balaena glacialisa Black right whale 

 

a. Federally endangered or threatened. 

INVERTEBRATES 

Species Name Common Name 

Invertebrates Endangered

Alasmidonta heterodona Dwarf wedgemussel (mussel) 

Alasmidonta varicosa Brook Floater (mussel) 

Lasmigona subviridis Green Floater (mussel) 

Cicindela d. dorsalisa Northeastern beach tiger beetle 

Nicrophorus americanusa American burying beetle 

Neonympha m. mitchelliia Mitchell’s satyr (butterfly) 

Pyrgus wyandot Appalachian Grizzled Skipper (butterfly) 

Atrytone arogos arogos Arogos Skipper (butterfly) 

Lycaena hyllus Bronze Copper (butterfly) 

Invertebrates Threatened 

Lampsilis radiata Eastern Lampmussel (mussel) 

Leptodea ochracea Tidewater Mucket (mussel) 

Lampsilis cariosa Yellow Lampmussel (mussel) 

Alasmidonta undulata Triangle Floater (mussel) 

Ligumia nasuta Eastern Pondmussel (mussel) 

Pontia protodice Checkered White (butterfly) 

Callophrys irus Frosted Elfin (butterfly) 

Bolaria selene myrina Silver-bordered Fritillary (butterfly) 

 

a. Federally endangered or threatened. 
APPENDIXES

344 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

FISH 

Species Name Common Name 

Fish Endangered

Acipenser brevirostruma Shortnose sturgeon 

 

a. Federally endangered or threatened. 

List revisions: 

 March 29,1979 

 January 17, 1984 

 May 6, 1985 

 July 20, 1987 

 June 3, 1991 

 July 19, 1999 

 March 18, 2002 

Copyright © 2003 New Jersey Audubon Society 

All rights reserved. 
References 
FINAL ENVIRONMENTAL IMPACT STATEMENT 347

REFERENCES 

Anderson, K. 

1990 “Liberty State Park — Diversity is Where You Find It.” NJ Andubon 24-5. 

Beyer, Blinder, Belle / Anderson, Notter, Finegold 

1988 Historic Structure Report: Ellis Island, Vols. 1-14. Prepared for National Park Service, Denver 

Service Center, U.S. Department of the Interior. 

Bowles, Ann E. 

1995 “Responses of Wildlife to Noise,” pp. 109-156 in Wildlife and Recreationists, eds Richard L. 

Knight and K. J. Gutzwiller. 

H.F. Lenz Company 

2001 Existing Conditions Report, Ellis Island Utility System. Draft. Prepared for the National Park 

Service, Denver Service Center, U.S. Department of the Interior. 

Hunter Research, Inc. 

1993 Archaeological Investigation in Connection with the New Wall of Honor, Ellis Island, City of 

New York, New York County, New York. Hunter Research, Inc., Trenton, New Jersey. Prepared 

for the Statue of Liberty – Ellis Island Foundation. 

Mueser Rutledge Consulting Engineers (MRCE) 

1993 “Preliminary Boring Investigation, Enhanced Access to Ellis Island.” Report, July 14. 

National Park Service (NPS), U.S. Department of the Interior

1976 National Register of Historic Places Inventory Nomination Form for Federal Properties.” NPS, 

Boston, Massachusetts. (Officially on file with the Keeper of the National Register; copy 

available, Library, Statue of Liberty National Monument). 

1980 Analysis of Alternatives (Environmental Assessment) for the General Management Plan. 

National Park Service, Denver Service Center. 

1982 Statue of Liberty National Monument General Management Plan. 

1995a “Internal Draft Environmental Impact Statement, Ellis Island Bridge and Access Alternatives.” 

1995b List of Classified Structures, Statue of Liberty National Monument. NPS, Northeast Regional 

Office, Boston. 

1995c The Secretary of the Interior’s Standards for the Treatment of Historic Properties. Code of 

Federal Regulations, Title 36, Part 68. Federal Register 60 (July 12). 

1998 Director’s Order 28: Cultural Resources Management. Washington, DC. 

2001a Director’s Order 12: Conservation Planning, Environmental Impact Analysis and Decision 

Making, and DO-12 Handbook. Washington, DC. 

2001b Ellis Island Cultural Landscapes Inventory. Draft. 

2001c Management Policies. Washington DC. National Park Service. 

2002 Cultural Landscape Report for Ellis Island (95% draft). Prepared by Olmstead Center for 

Landscape Preservation. 
REFERENCES

348 STATUE OF LIBERTY NATIONAL MONUMENT AND ELLIS ISLAND

New Jersey Department of Environmental Protection (NJDEP) 

1984 Inventory of the Fishery Resources of the Hudson River from Bayonne to Piermont. Division 

of Fish, Game and Wildlife. 

1988 “Liberty Walk and Amphitheater, Liberty State Park, Jersey City, New Jersey — Waterfront 

Improvement Plan Schematic Design Manual.” Division of Parks and Forestry, Department of 

Environmental Protection: Division of Building and Construction, Department of Treasury, 

State of New Jersey. 

1990 “Summary of Sampling Data. Liberty State Park — Freight Yard Site.” July 7. 

1993 Liberty State Park Status Report: Natural Resource Inventory of Undeveloped Area Division 

of Parks and Forestry. 

1994 “The Birds of Liberty State Park.” Division of Parks and Forestry. 

1999a New Jersey Department of Environmental Protection 1999 Chrome Update 28 Report, Site 

Remediation Project—Known Contamination Sites. NJDEP web address: 

www.state.nj.us/dep/frp/chrome/update/28.htm 

1999b New Jersey Department of Environmental Protection 2000. Publicly Funded Cleanup Site 

Status Report 1999, Site Remediation Program. NJDEP web site: 

www.state.nj.us/dep/frp/publications/site_status/1999/html/hudson.htm#4 

Pirnie, Malcolm 

1994 Ellis Island Bridge and Access Alternatives, Statue of Liberty National Monument and Ellis 

Island. Wildlife and Vegetation Report. 

Pousson, John 

1986 “Overview and Assessment of Archaeological Resources on Ellis Island Statue of Liberty 

National Monument New York.” National Park Service, Denver Service Center, Eastern Team, 

Rockville, Maryland. 

Syska & Hennessy 

1984 Ellis Island Site Utilities, Technical Feasibility Study. Prepared for the National Park Service, 

U.S. Department of the Interior. 

Texas Instruments 

1976 Liberty State Park Ecological Study. Final Report. The Port Authority of New York and New 

Jersey. 

Unrau, Harlan D. 

1984 Historic Resource Study (Historical Component). Volumes I-III. Prepared for the National 

Park Service, U.S. Department of the Interior. 

1981 Historic Structure Report: Ellis Island: Historical Data. Prepared for the National Park 

Service, Denver Service Center U.S. Department of the Interior. 

U.S. Supreme Court 

1998 State of New Jersey vs. State of New York, United States Supreme Court, Syllabus of May 26, 

1998 Decision. 

Vollmer Assoc, LLP 

2002 Liberty State Park Transportation Master Plan Update. Prepared for the Governor’s Advisory 

Committee on the Preservation and Use of Ellis Island. 
As the nation’s principal conservation agency, the Department of the Interior has responsibility for

most of our nationally owned public lands and natural resources. This includes fostering wise use

of our land and water resources, protecting our fish and wildlife, preserving the environmental and

cultural values of our national parks and historic places, and providing for the enjoyment of life

through outdoor recreation. The department assesses our energy and mineral resources and works to

ensure that their development is in the best interests of all our people. The department also promotes

the goals of the Take Pride in America campaign by encouraging stewardship and citizen responsibility

for the public lands and promoting citizen participation in their care. The department also has a major

responsibility for American Indian reservation communities and for people who live in island territories

under U.S. administration.

NPS D-93B (November 2005)
National Park Service

U.S. Department of the Interior

United States

Department of the Interior

National Park Service