The
Preserve-Development map and EPA Compliance Order reveal that much of
the Hackett Hill property actually will be turned into a bizarre
mixture of concrete and foliage. Islands of development, accompanied
by roads, will be closely adjacent to the valuable forested wetlands.
The fragmentation that will result will severely compromise any
possibility of maintaining the present biodiversity of the Preserve.
Animal "corridors" will be destroyed, and some species will decline
in numbers and ultimately disapear, since a "breeding population
size" will be unattainable.
Scientific data suggested that the existing parking lot-road complex on the property would be the worse possible place for development, since direct damage to adjacent swamp communities would probably result from it. It is not surprising that the City of Manchester plans to ignore these warnings. Development in this area clearly will be less costly due to the pre-existing "infrastructure" it contains, and thus the land can be marketed at a considerable profit. However only one of the five development areas which are slated to be situated as "islands", surrounded or nearly-surrounded by protected land, would actually be located on the abandoned parking lot-road complex. The other areas appear to require additional "infrastructure" in order to be reached from the property exterior. Therefore the question must be asked: How would the location of these other sites satisfy "the City's need for reasonable economic gain from disposition of its property?" (as expressed in the Compliance Order)
An answer to this question can be derived from a New Hampshire Sunday News article on Hackett Hill in which Manchester's City Economic Director, Jay Taylor, is quoted as saying that the natural communities on the property would serve as "amenities for businesses." In other words, the areas on the property which have been identified by environmentalists as being most in need of protection, are also aesthetically pleasing, and they can therefore become marketing tools for the city of Manchester. This manner of thinking is clearly lacking in environmental ethics. It is also completely inappropropriate for the present decade, when environmental awareness on the part of the public is growing by leaps and bounds, and corporate America is not generally held in high esteem.
Mark Durcan, a Sierra Club member, has written an essay about the Hackett Hill land sale, titled "Controversies Over Development". In it, he has responded specifically to Mr. Taylor's comment. He wrote:
"Next to the comment (in the newspaper) was a color photograph of a black gum tree on the property. Its thick, scarred blackened bark indeed attests to an agelong, primordial quality. My immediate response to this photograph was a sense that it would be an act of shameful irresponsibility to threaten this tree, which has somehow survived nearly half a millennium despite the ever-encroaching enterprise of man. I also felt a swelling anger at the hubris and greed of humans who would threaten natural treasures to advance their short term business or political interest. Shouldn't our generation of human begins have evolved past the ceaseless impulse to exploit the landscape? Shouldn't we now desist from this practice wherever possible? Shouldn't preservation of beauty, rarity and wilderness in the natural world be accorded a higher value as we enter a new millennium?"
It
appears that both appointed and elected Manchester city officials can
be held responsible for the low priority given to protection of the
Hackett Hill wetlands. At a meeting of the Manchester Conservation
Commission held in late summer of 1998, Planning Director Robert
MacKenzie outlined some of the initial Hackett Hill development
plans. In addition to the Commissioners, several representatives of
the Nature Conservancy and the public sector were in attendance. In
his presentation, Mr. MacKenzie referred to the Hackett Hill property
as being "vacant" land! A similar lack of appreciation for the
natural resources found on the property was demonstrated at a meeting
of the Board of Mayor and Aldermen where possible uses of the land
were initially discussed. There were many comments and questions
about the various types of development that might be appropriate for
the property, but the plant and animal species located there were not
mentioned.
The USNH, which despoiled the Hackett Hill property with an extensive "infrastructure" for development in the 1970s, has continued to show a lack of appreciation for this land in the 1990s. Data collected during ecological studies performed on the property by UNH affiliates in 1993, 1995 and 1998 indicated that development in nearly all areas would be ill-advised. These studies were completely ignored by the USNH Board of Trustees, who sold the property to the City of Manchester, knowing that extensive development was planned. UNH has strong environmental programs at its Durham campus, many of which concern its internationally-known marine field station. It could easily have converted the Hackett Hill property to a wetlands field station, but the University Board of Trustees did not even bother to investigate this possibility. Instead, they focused on short term financial gain. The transfer of the Hackett Hill-located branch of UNH to the downtown millyard may prove to be helpful both to the University and the city, but it should not overshadow the fact that the University has "walked away" from an opportunity to right past wrongs.
With respect to the EPA, it seems inappropriate for this agency to publicize the finalized arrangements as a great achievement. The EPA-sanctioned Manchester-USNH purchase-sales agreement was considered by the agency to "have kept the Hackett Hill property intact." The claim was made that if the property had been sold off in small parcels by USNH, then protection of its unusual natural communities might have been impossible to achieve. It was also claimed that without the SEPP portion of the EPA Compliance Order, it was doubtful that the City of Manchester would have shown much regard, if any, for the future of these natural resources. However, the protection finally agreed upon has been severely compromised by the five "Sensitive or Potential Development Areas", and the public was given little or no knowledge of this compromise as negotiations were conducted in secret.
Conceivably the EPA-city CSO negotiations and final arrangements could have been conducted completely independently of the sale of the UNH-owned property to the city. The disposition of the property could then have become a public matter at the time of the sale, and various alternatives proposed and debated. The Master Plan of the City of Manchester (1993) notes that the "Manchester Cedar Swamp" is "an area of vital concern that merits attention and should be preserved." Also, a Regional Resource Protection Inventory was prepared by the Southern New Hampshire Planning Commission in June,1998. It includes "the large White Cedar swamp adjacent to Hackett Hill Road" and assigns the swamp "the highest priority for protection in Manchester."
Furthermore, it is unknown if the EPA-mandated requirements for "sensitive development" procedures , even if rigidly adhered to,will prevent damage to the highly-specialized swamps. There is no established precedent for this particular situation. Also, if a periodic inspection reveals that any of the requirements have been disregarded, any penalities that will be imposed as a consequence are not really meaningful, since they will be imposed "after the fact", i.e., after the damage has been done.
Finally, the EPA's involvement with Manchester seems to be out of keeping with its behavior and reputation. This agency is currently providing large amounts of funding at other locations in the country for the restoration of Atlantic white cedar swamps which have been damaged by human activities*. Also, the enhancement of commercial activity in the northwest corner of Manchester will clearly promote "urban sprawl" here - a phenomenon which has been opposed by EPA officials in other areas. In addition, the EPA has tolerated a considerable lack of disrespect shown by the city towards the agency. Frank Thomas, Director of Public Works for Manchester, was quoted in a Manchester Union Leader article as saying that the city, at one point in the Hackett Hill negotiations, contemplated telling the EPA to "take a hike" - apparently when the agency pushed for a larger amount of land to be protected.
The Public Be Damned?
The initial plans
for the purchase and disposition of the Hackett Hill property were
presented at public hearing called with only two days notice on
September 30, 1998. By this time, concerns of environmentalists for
the natural resources on the property appeared to have finally had an
impact, since in several instances city officials made comments about
the "global significance" of these resources, and how important it
would be to protect them. Nevertheless, when the finalized, more
specific development plans appeared in the Compliance Order, a
document that was made public in March, 1999, they did not conform to
this outlook.
Citizens of Manchester were given no opportunity to express their opinion about the location of the five "Sensitive or Potential Development Areas." In fact, they had very little chance to express their opinion as to whether or not development of any sort should take place on the Hackett Hill property. In addition, there was no opportunity for the public to become fully informed about the natural history of the Hackett Hill "urban forest." Many members of the public are extremely interested in this topic, but have only a superficial understanding of it - a situation which obviously plays into the hands of those individuals who promote development of the area.