September 24, 2004 John Weisman, Chairman Planning Board RE: Casperkill Country Club Dear Chairman Weisman: Cider Mill Friends of Open Space & Historic Preservation, Inc.(Cider Mill Friends) appreciates the opportunity to review the Draft Scoping Document, dated July 26, 2004, prepared by The Chazen Companies for the above-noted project. Cider Mill Friends is a non-profit organization dedicated to protecting open space, and natural and historic resources in the Town of Poughkeepsie through restoration, advocacy programs and land acquisition. For a project of this scope and scale in the Town located on Route 9, one of Dutchess County's most congested highways, and being one of the Town's most significant parcels of remaining open space, we urge you to consider hiring Karl Kehde. Karl Kehde promotes the collaborative land use process, has been successful in dozens of similar projects across the country, and has received national awards for his achievements. All of us would greatly benefit from the experience and knowledge Karl Kehde would bring to this project. And now is the time to enlist these professional services. In a review of the project file, a letter from Cuddy & Feder to the Planning Board, dated September 3, 2004, transmitted a document titled “SEQR Positive Declaration & Notice of Public Scoping session to be held on September 28, 2004,” dated August 19, 2004. On page 7 of this document, a section reads “ A copy of this Notice is being sent to: Involved Agencies, ...” and concludes with “Any Other Parties Requesting a Copy.” Please add Cider Mill Friends as a party interested in receiving copies of all future documents relating to this project. Our mailing address is noted below. Regarding our review of the Draft Scoping Document, please note the following comments: 1. INTRODUCTION, 2 nd paragraph, p 1 - the positive declaration was not attached as referenced. 2. DEIS SCOPE AND CONTENT, 1.0 EXECUTIVE SUMMARY, p 2 - a section is needed that addresses lead agency history containing relevant SEQR dates such as date of lead agency, date for receipt of comments, date for public hearing, date for acceptance, etc. 3. DEIS SCOPE AND CONTENT, 1.0 EXECUTIVE SUMMARY, 1.3 Description of the Proposed Action, p 2 - this section should contain a description of the existing vegetative conditions. 4. DEIS SCOPE AND CONTENT, 2.0 DESCRIPTION OF THE PROPOSED ACTION, 2.3 Description of Action, p 4 - include detailed descriptions for natural areas to remain; total area to be disturbed, quantified and mapped; areas of cut and fill, quantified and mapped; utilities to be used such as water supply sources, waste water generation, solid waste generation and sanitary disposal method. 5. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.1 SOILS AND GEOLOGY, 3.1.1, Existing Soils and Geologic Conditions, p 5 - include soil test results as an appendix. 6. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.1 SOILS AND GEOLOGY, 3.1.2, Potential Soils and Geologic Impacts, p 5 - include and address the following two topics in this section: the effect of tree removal from site with associated impacts on site soil moisture and runoff, and the effects of construction and development with impervious surfaces and replacement of soils on the hydrology of existing stream and wetland systems. 7. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.1 SOILS AND GEOLOGY, 3.1.3, Soils and Geologic Mitigation Measures, p 6 - the blasting mitigation plan should include a pre-blast survey and evidence of a performance bond; the amount of rock and earth to be removed from site needs to be quantified and its destination identified. 8. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.2, SURFACE WATER RESOURCES, 3.2.1, Existing Surface Water Resources, 5 th bullet, p 7 - add “The wetland delineation will define the extent of all contiguous wetlands beyond the site boundary. The total area of contiguous and hydrologically connected wetlands both on and off site will be calculated.” 9. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.2, SURFACE WATER RESOURCES, 3.2.2, Potential Surface Water Impacts, p 7 - 7 th bullet, add “...to wetlands and water bodies ...”; add “A stormwater pollution prevention plan will be prepared and discussed.”; add “The extent and effects of disturbance to State and Federal wetlands will be described and evaluated as well as compliance with the Town's Aquatic Resources Protection Ordinance.” 10. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.2, SURFACE WATER RESOURCES, 3.2.3, Mitigation Surface Water Measures, p 8 - 4 th bullet, mitigation of wetland impacts will include creation of buffer areas, stream mitigation plan as necessary, flood plain mitigation as necessary, and conservation easements to protect wetlands and water bodies. 11. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.4, VEGETATION, 3.4.1, Existing Vegetative Conditions, p 8 - 1 st bullet, include “A discussion and identification of all existing vegetative communities...”. 12. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.4, VEGETATION, 3.4.1, Existing Vegetative Conditions, p 9 - 2 nd bullet, add “Field survey for currently listed Threatened, Endangered, and Special Concern species and an inventory of all existing species will be undertaken during appropriate times and different seasons. This work will be conducted by a qualified biologist.” 13. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.4, VEGETATION, 3.4.1, Existing Vegetative Conditions, p 9 - 3 rd bullet, add “Location and number of trees with diameter of 8" or greater will be identified.” 14. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.4, VEGETATION, 3.4.2. Potential Vegetative Impacts, p 9 - add “A map showing vegetative impact areas including location and approximate number of any trees with a diameter of 8" or greater that will be removed.” 15. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.4, VEGETATION, 3.4.2. Potential Vegetative Impacts, p 9 - 2 nd bullet, add “The impacts of the loss and conversion of native vegetation will be assessed from the viewpoint of soil erosion, evapotranspiration, precipitation recharge and provision of food and cover for wildlife pre- and post- development. 16. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.4, VEGETATION, 3.4.3. Vegetative Mitigation Measures, p 9 - add “Mitigation measures with respect to restrictive clearing in areas of particular ecological concerns will be addressed and may include recommendations of fencing or signage in order to avoid significant impacts to plant communities. Specific, detailed tree protection and wetland protection plans will be provided including, as appropriate, clearing limits, fencing prior to construction and measures to protect specific threatened plants.” 17. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.5, FAUNA, 3.5.1, Existing Faunal Conditions, p 9 - add “An identification of known and potential on-site and transient animal species will be included.” 18. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.5, FAUNA, 3.5.1, Existing Faunal Conditions, p 9 - 2 nd bullet, the ecological assessment should include field assessments during different seasons. 19. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.5, FAUNA, 3.5.2, Potential Faunal Impacts, p 10 - add “A discussion of potential impacts from the project, including wetland disturbance and fragmentation of habitat supporting relevant on-site and off-site fauna due to change in habitat and migration patterns. The Biodiversity Manual for the Hudson River Estuary Corridor (2001) will be used as a reference to evaluate impacts due to pressure from this land development.” 20. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.5, FAUNA, 3.5.3, Faunal Mitigation Measures, p 10 - add “As necessary conservation easements, wildlife crossings, trees and understory preservation, replanting native species and protection or establishment of wildlife corridors, as well as timing to avoid impacts on breeding and migration will be included.” 21. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.6, CULTURAL RESOURCES, 3.6.1, Existing Cultural Resources Conditions, p 10 - 3 rd bullet, based on the findings of the phase 1A and 1B, a more broad based phase 2 cultural resource survey may be needed in addition to the Abraham Fort Homestead area. 22. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.6, CULTURAL RESOURCES, 3.6.3, Cultural Resources Mitigation Measures, p 11 - add “A plan for implementation of recommendations from Phases 1A, 1B, 2 and the Historic and Architectural Report will be included. 23. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.7, VISUAL, 3.7.1, Existing Visual Conditions, p 11 - add Kingwood Park, Kingwood Drive, South Gate Drive and Anthony Drive as critical receptor points. 24. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.7, VISUAL, 3.7.2, Potential Visual Impacts, p11 - the photographic simulations in the visual impact analysis need to contain both leaf on and leaf off conditions. 25. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.8, TRANSPORTATION, 3.8.1, Existing Transportation Conditions, p 12 - 1 st bullet, a description of all available traffic data “including accident data for the most recent 3 year period”...; 2 nd bullet, a description and examination of on-site “and off-site” pedestrian “and bicycle” amenities; and 4 th bullet, peak hours for weekday “and weekend”. 26. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.8, TRANSPORTATION, 3.8.3, Traffic Mitigation Measures, p 13 - include discussion of roadway improvements as needed for intersection improvements and signalization; drainage improvements or surface improvements as well as mitigation measures for impacts resulting from construction vehicles/access; access points relative to traffic safety; and consideration of emergency access locations to adjoining roads. 27. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.11, SCHOOL DISTRICT SERVICES, 3.11.1, Existing School District Services, p 14 - 1 st bullet, include “...enrollment data by grade level ...”. 28. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.11, SCHOOL DISTRICT SERVICES, 3.11.2, Potential Impacts to School District Services, p 14 - 1 st bullet, include “number of public school children by grade level ...”. 29. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.12, UTILITIES - WASTEWATER, 3.12.3, Wastewater Mitigation Measures, p 15 - the discussion should include alternatives without the use of the Town's system. 30. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.15, RECREATION AND OPEN SPACE RESOURCES, 3.15.1, Existing Recreation and Open Space, p 16 - include “A discussion of the site's and the Town's ...”. 31. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.15, RECREATION AND OPEN SPACE RESOURCES, 3.15.2, Potential Impacts to Recreation and Open Space, p 16 - include a discussion on the National Recreation and Park Association Standards for the project population; additional users of existing facilities; and potential reuse, alteration or loss of facilities. This discussion will also address the possibility of providing land for recreational use with an associated site plan. The payment of fees in lieu of recreation space by the applicant should not be the preferred method on this project. 32. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.15, RECREATION AND OPEN SPACE RESOURCES, 3.15.3, Recreation and Open Space Mitigation Measures, p 16 - recreation and open space preservation with conservation easements and land in lieu of fees should be the preferred mitigation method. At a minimum, the Fort Homestead and 2 to 3 acres surrounding the homestead should be preserved for the Town and community with public access. Land along the Casperkill Creek should be preserved with conservation easements or as land in lieu of fees for the potential location of a future trail system. These discussions should be occurring now at the beginning of the planning process. 33. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.16, NOISE AND AIR RESOURCES, 3.16.2, Potential Impacts to Noise and Air, p 17 - include discussion of the potential increase in noise resulting from vehicular traffic and construction related noise. The impacts of construction activities and blasting during this phase on the project will be described with respect to the impacts on both neighbors and wildlife. Long range impacts that might be associated with the noise from the proposed sanitary pump station will be included in this discussion. 34. DEIS SCOPE AND CONTENT, 3.0 POTENTIAL ENVIRONMENTAL IMPACTS, 3.16, NOISE AND AIR RESOURCES, 3.16.3, Noise and Air Mitigation Measures, p 17 - for noise, include identification of specific mitigation measures which could be implemented prior to use of the site (i.e. landscaping)' construction limited to normal operating hours and appropriate noise suppression techniques. For air mitigation measures, include vehicular access and circulation to avoid vehicle idling, dust control measures during construction and additional measures as necessary. 35. DEIS SCOPE AND CONTENT, 5.0 ALTERNATIVES, p 17 - an alternative that considers the establishment of conservation easements, dedication or deed restrictions for a minimum of 10% of the site, to include the most sensitive upland and wetland areas. 36. DEIS SCOPE AND CONTENT, 7.0 GROWTH INDUCING ASPECTS, p 18 - this section needs to include the full range of cumulative and secondary impacts analysis resulting from the project. The existing conditions can include a list of projects and their descriptions from the Town being proposed in the project area. The potential impacts can include a discussion of the cumulative impacts on streams and water bodies, storm water, wetlands, steep slopes, wildlife and wildlife habitat, traffic, schools and recreational facilities. In addition, the relationship of this project to the proposed Town Master Plan revisions needs to be addressed. 37. A hazardous waste section needs to be included in the DEIS to address issues such as pesticide use on the golf course, past land uses like the shooting range, the gas pumps associated with the maintenance yard to list a few. Thank you for the opportunity to submit comments on this important project. If you have any questions, please contact us at 845-462-3970 or cidermillfriend@aol.com. Very truly yours, Lisa D. Weiss, RLA cc: Supervisor Davis and Town Board members |