The Naugatuck Pomperaug Chapter of Trout Unlimited
wish the Sub Council to reconsider the findings and decision of
the Trustee Work Group (TWG) incorporated into their report as it
relates to the Chapter’s detailed proposal regarding phase
II of the Housatonic River Basin Natural Resources Restoration Project.
In reviewing the Trustee Work Group’s report we find the following,
1. While some proposals indicated that items could
be separated into respective smaller projects, the Trustee Work
Group unilaterally separated the Naugatuck/Pomperaug TU Chapter’s
proposal into two segments. In turn, one segment was accepted for
“further consideration” and it was stated that the other
segment of the arbitrary separation, “does not warrant additional
consideration at this time.” Further, the proposal review
requirements and scoring criteria do not stipulate that there can
be, or should be, any, separation of the proposal by the Trustee
Work Group. We would like the Sub Council to reconsider the findings.
2. The TWG project evaluation summary
indicates,
a. “Trout stocking is widely used as a method
of increasing populations.” While quite accurate on its own
merits and as a stand alone item, it is also a method to ensure
breeding populations, natural reproduction and sustainability of
the natural resource.
b. (Trout stocking) “May require permit for
transportation of fish across state lines.” Again, while quite
accurate on its own merits as a stand alone statement, the proposal
clearly identifies native Connecticut trout hatcheries as a first
priority before seeking out-of-state resources.
Further, the proposal recognizes the need for permitting as a DEP
requirement and would seek the required permitting if and when the
proposal was accepted. It would appear to be presumptuous of the
TWG to infer that the TU Chapter did not recognize the permit requirement.
Further, it would be a waste of time, effort, energy and resources
to initiate the obtaining of permits before the proposal was accepted.
We would like the Sub Council to reconsider the findings.
3. The TWG project evaluation summary indicates,a.
“Ninety-eight percent of the budget is for trout stocking
(over five years). All labor is to be donated (value not assigned.)”
The statement itself should be very clear. If there is no cost incurred
for labor, how can there be a value assigned i.e., it is at no cost.
If the RFQ would have requested “relative value” then
perhaps the proposal would have responded accordingly. We would
like the Sub Council to reconsider the findings.
4. The TWG project evaluation summary indicates,
a. “The project would result in low to moderate benefits,
but does not demonstrate long-term sustainable ecological and recreational
benefits.” It is not clear what criteria or how the TWG determined
“low to moderate benefits” for this project. The proposal
clearly addresses the ecological and recreational benefits
And, the proposal is very clear in establishing a
study to determine through the use of monitoring and data to determine
long-term ecological benefits with the assistance of the DEP. The
TU Chapter believes that the DEP should clearly be interested in
conducting such a study to determine the efficacy of stocking. Although
we do not wish to determine DEP’s methods for this, the study
could include electro-shocking and angler surveys as proposed in
other projects that were selected for further consideration. We
would like the Sub Council to reconsider the findings.
5. The TWG project evaluation summary indicates,
a. “The applicant may have the technical expertise and administrative
capabilities to implement the project, but specific examples and
qualifications are not provided. The proposal is quite clear in
stating that the TU Chapter has other similar projects and stipulates
the Beacon Falls Riverfront Park System as an example. This is noteworthy
and difficult to reconcile, since the Beacon Falls Riverfront Park
System project was accepted for further consideration by the Trustee
Work Group. It should also be noted that Trout Unlimited is a national
organization and a history and qualifications of implementing projects
much larger that those proposed in response to the RFP. We would
like the Sub Council to reconsider the findings.
6. The TWG project evaluation summary indicates,
a. “The high cost relative to benefits” It is difficult
to determine the basis for this conclusion by the TWG. We would
like the Sub Council to reconsider the findings.
The Naugatuck/Pomperaug Chapter of TU is troubled with the findings
in other areas. The basic premise and title of the RFP is the “Housatonic
River Basin Natural Resources Restoration Project. In the English
language, the word “restoration” means to “return
something to its former state.” “Restoration”
also has synonyms including “return, reinstatement, re-establishment,
reinstallation, repair, refurbishment and renewal.” Each of
these synonyms speaks directly to putting something in place that
may have previously been in existence. We believe that this is the
underlying purpose of the Housatonic River Basin Natural Resources
Restoration Project.
It is particularly troubling that many of the projects selected
for further consideration have no merit in being restorative in
nature. Some are public works projects disguised as restoration.
Some are easements, land preservation and access projects that have
nothing to do with the restoration intended in the GE settlement.
Some are dam modifications, while worthwhile projects, again they
are not restorative as it relates to the GE case and better suited
to another funding forum.
Based on and in light of these seeming inconsistencies, we would
request that the Naugatuck/Pomperaug Trout Unlimited’s proposal
be reviewed and reconsidered. The Chapter is prepared to offer additional
information and expertise as required to conduct a further review.
Sincerely,
Robert Perella,
President
Naugatuck/Pomperaug Chapter of TU
February 2008
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