Hudson River Waterfront Conservancy of NJ, Inc.
December 5, 2025
Project– WLRP File# LUP250001 – 0908-11-0001.2
HMH PALISADES MEDICAL CENTER EMERGENCY
DEPARTMENT EXPANSION
7600 RIVER ROAD
BLOCK No. 438, LOT No. 3, 4, & 5.01
TOWNSHIP OF NORTH BERGEN, HUDSON COUNTY, NEW JERSEY

On November 20, 2025, the Hudson River Waterfront Conservancy received a copy of WLRP File # LUP250001 – 0908-11-0001.2 for construction of an Expanded Emergency Medical Department and related flood prevention provisions at the Palisades Medical Center in North Bergen.

General – The Hudson River Waterfront Walkway (Walkway) has been constructed over the past 30+ years and has evolved into a vital and growing public transportation link and recreational facility for the public along the Hudson River. During that time, many lessons have been learned about construction, maintenance and operation of the Walkway. The HRWC seeks to apply the lessons learned and best practices in the on-going oversight of construction, maintenance and operation of the Walkway. This includes requesting appropriate exceptions to the Regulations administering the Walkway construction and maintenance where justified.

Overall Assessment – The Hudson River Waterfront Conservancy strongly denies any support for the proposed WDP and requests that the DEP reject this application. Reconstruction of a crumbling, dangerous and flood prone portion of the Hudson River Waterfront Walkway (The Walkway) has not been included, as it should have been in the permit request, leaving the public with a dangerous and inadequate Walkway.

Current Conditions – The waterfront area in North Bergen where the proposed facility will be built lies between the Waterside Restaurant to the north, and a major condominium to the south. Both have completed, well maintained, segments of the Walkway. The subject property has an approved section of the Walkway. However, this Walkway section has not been maintained by the applicant and is currently a crumbling, dangerous black top surface that floods with every rainstorm.

Proposed Construction – Using the Walkway to meet the “water dependent use” requirement, a revamped and expanded Emergency Medical facility with extensive stormwater management facilities is proposed. However, no refurbishment or repairs to the crumbling Walkway is included.

Considerations: –
Required Maintenance – Waterfront Development Permits include a requirement that waterfront property owners construct and maintain a section of the Waterfront Walkway. As can be seen below, the Walkway in this area is crumbling, flood prone and in disrepair. The applicant has not met their obligation to keep the Walkway safe for pedestrian and vehicle use.

Water Dependent Use – N.J.A.C. 7:7-9.23(d), Water Dependent Use. The applicant acknowledges that the Walkway is being used to comply with the requirement that there be Water Dependent Use as a condition of approval for a WDP. Use of the Walkway as a water dependent use requires that the applicant maintain the water dependent facility, so it is safe for use by the public. The applicant is in clear violation of the maintenance requirement.

Paved Walkway Area – While the Walkway easement of 30’ complies with the requirements of the Hudson River Waterfront Area, the paved portion of the easement is a narrow 10’ which is not in compliance with the Walkway Guidelines. This is in spite of plenty of adjacent land to construct the required 16’ paved area.

Construction without an approved WDP – As of December 4, 2025, construction of the proposed expansion of the Emergency facilities was underway without an approved WDP in violation of NJDEP regulations.

Recommendations – Require that the applicant, prepare a written commitment to repair and maintain the Walkway including widening the paved Walkway area to 16’ and clearing the Walkway of debris within 24 hours of any flooding.
Determine if the current construction is in violation of the DEP regulations and halt all construction work until a proper WDP is approved for the property.

Respectfully
Donald Stitzenberg,
Secretary
Hudson River Waterfront Conservancy
E-Mail – destitz@yahoo.com