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HomeMy WebLinkAbout2024-07-23-TB-FINAL-minutes1 TOWN BOARD MEETING Town of Ulysses July 23, 2024 The meeting was held in person at the Town Hall at 10 Elm St., Trumansburg NY as well as via Zoom videoconference. Notice of Town Board meetings are posted on the Town’s website and Clerk’s board. Video recordings of meetings are available on Youtube at https://www.youtube.com/channel/UCWVIs--g9CpHIxdk9YxZyPw. CALL TO ORDER: Ms. Olson called the meeting to order at 7pm. ATTENDANCE: TOWN OFFICIALS: In person- Supervisor- Katelin Olson Board members- Mary Bouchard, Rich Goldman, Michael Boggs Town Clerk- Carissa Parlato Town Planner- Niels Tygesen Planning Board chair- Karl Klankowski CSAC (Conservation & Sustainability Advisory Committee) member- Cait Darfler Via Zoom- WSPPC (Water Source Protection Plan Committee) & Planning Board member- Linda Liddle Absent- Board member- Liz Weatherby OTHERS: In person- George Patte, John Dennis, & Stephanie Redmond(Town of Enfield Supervisor) (from CLEAN (Cayuga Lake Environmental Action Now)), Nancy Zahler (on behalf of JCA (Jacksonville Community Association)) Via Zoom- Diane Hillmann, Matt Horn, Dale Strok, Peter Penniman APPROVAL OF AGENDA: Motion: Mr. Boggs moved to approve the agenda as amended. This was seconded by Ms. Bouchard and passed unanimously. PRIVILEGE OF THE FLOOR: none PRESENTATION- C.L.E.A.N. 2 (See Appendix for letter from CLEAN to NYS) Ms. Darfler introduced CLEAN and their presentation re: Cargill Salt mine and brine disposal in the lake area of the town. Mr. Patte is a lakeshore resident (formerly in the town but now on the east side). He said that in June 2023 Cargill expressed interest in using an abandoned cavern (Crowbar point) as a repository for leftover salt water. He feels that this is a local issue since Ulysses Lakeshore Zone boundaries go to the center of the lake as noted in chapter 212 of the Town’s code. He believes that this would trigger Cargill to need a use variance, which they do not have. He said this idea has been vetted by an attorney. Ms. Olson asked who owned the property. Mr. Patte said OGS (NYS Office of Government Services allows Cargill’s permit and NYS owns it but should be subject to local jurisdiction. Mr. Dennis says that Cargill is the largest corporation in America and doesn’t recognize NYS. Further, Cargill likes to work under water because you can get salt easier. And will have exhausted salt resources by 2032. Cargill tried to sell the empty mine but had no takers. CLEAN’s concern is that brine will seep into lake and salinize it. He shared information on a 1994 mine collapse and urged the town to use existing zoning code to reach out to Cargill to let them know about zoning. Mr. Patte said that if the BZA takes the issue up, it would be subject to SEQR. Ms. Olson said that this is a serious issue and a collapse would be catastrophic but if Cargill doesn’t respond to NYS, why to us? She wondered about the status of Cargill’s application to NYS. Mr. Dennis said he will follow up with DEC on the application status. The board agreed to move up the agenda DISCUSSION ITEM on this topic: Ms. Olson said that she spoke to legal and the town does not have the authority to regulate NYS. She said that we cannot subject the state to town regs and gave the example of Taughannock Park not needing to come before the town for anything they do in the park. She added that the town will need to be clear on this issue before trying to do anything on this issue. Mr. Patte said that their legal counsel is happy to discuss with us, as they believe that we do have jurisdiction. Mr. Dennis said that the town could still place a moratoria on mining under the land as Cargill has mineral rights. Ms. Olson said that a moratoria is a tool (rather than a solution) used to pause development in order to get zoning laws. Prohibition is a solution. Ms. Rose asked if the town can outlaw any practices that would help ban the practice like the way fracking was essentially banned by prohibiting large trucks. 3 Ms. Darfler said that she doesn’t think Cargill is adding extra chemicals to the brine. Mr. Dennis said that they add extra salt and something else. Ms. Darfler added that CSAC is interested in this issue and added that we should be interested in what will happen when the mine is closed so we can start planning for it. Ms. Olson asked whether CLEAN has reached out to state reps. Ms. Redmond said that there is legislation being discussed on the issue but it is too minimal. OLD BUSINESS: UNITED WAY 2024-2025 IMPACT PARTNER MEMORANDUM OF AGREEMENT RESOLUTION # 127 OF 2024: UNITED WAY 2024-2025 IMPACT PARTNER MEMORANDUM OF AGREEMENT RESOLVED, the Town Board approves the Town Supervisor to sign United Way 2024-2025 Impact Partner Memorandum of Agreement; and be it FURTHER RESOLVED, the Town Board directs the Town Clerk to submit the signed agreement on behalf of the Town. Moved: Mr. Goldman Seconded: Ms. Bouchard Olson aye Boggs aye Bouchard aye Goldman aye Weatherby absent Vote: 4-0 Date Adopted: 7/23/24 COMPREHENSIVE PLAN CONSULTANT CONTRACT AUTHORIZATION Ms. Olson said that as per the board’s previous discussion, the contract will include an ethical barrier between engineering and planning. RESOLUTION # 128 OF 2024: COMPREHENSIVE PLAN CONSULTANT CONTRACT AUTHORIZATION WHEREAS, on June 25, 2024 the Town of Ulysses authorized the Town Supervisor to enter into contract negotiations with MRB Group to provide consulting services for the development of the Town’s 2025-2045 Comprehensive Plan; and WHEREAS, the contract may require additional minor changes in language to satisfy the Town’s attorney; and WHEREAS, the Town Planner understands from the NY DEC grant representative that the contract fulfills the grant’s requirements; NOW, THEREFORE, BE IT 4 RESOLVED, the Town Board authorizes the Town Attorney to make necessary minor alterations to the contract in order to fulfill the best interests of the Town; and be it FURTHER RESOLVED, the Town Board authorizes the Town Supervisor to sign the contract after approval by the Town’s attorney. Moved: Mr. Goldman Seconded: Ms. Bouchard Olson aye Boggs aye Bouchard aye Goldman aye Weatherby absent Vote: 4-0 Date Adopted: 7/23/24 AUTHORIZING USE OF THE AMERICAN RESCUE PLAN ACT (ARPA) FUNDS FOR SPECIAL PROJECTS RESOLUTION # 129 OF 2024: AUTHORIZING USE OF THE AMERICAN RESCUE PLAN ACT (ARPA) FUNDS FOR SPECIAL PROJECTS Whereas, the following projects have been previously been identified for funding through ARPA funds at a variety of previous Town Board meetings, and Whereas, estimates for these projects were used for place holders as the exact cost of these projects was not known at the time, Whereas, taking these project expenses into account, the balance of ARPA funds still to be appropriated is $255,335 Therefore, be it resolved that the following projects with final expenses will be offset with ARPA funds: a. Project: IT Modernization i.Original estimate: $42,000 ii.Actual: $27,069 b. Project: Parking Lot Renovation Scoping and Estimate Work i.Original estimate: $2,795 ii.Actual: $2,795 c. Project: Town Hall Safety Assessment i.Original estimate: $1,250 ii.Actual: $1,250 Moved: Mr. Boggs Seconded: Ms. Bouchard Olson aye Boggs aye Bouchard aye Goldman aye 5 Weatherby absent Vote: 4-0 Date Adopted: 7/23/24 NEW BUSINESS: TOWN BOARD/PLANNING BOARD COORDINATION ON FUTURE PROJECTS Ms. Olson suggested that a small, adhoc group meet to discuss and share information on future Planning Board projects and the importance of respecting and valuing planning board members. Mr. Boggs (Planning Board liaison) said that himself and the Planning Board started discussing waterways and identifying them as many are not on our maps. Mr. Klankowski said that the town also needs to work on signage, noise issues, GIS data, and defunct dev districts. He asked how the Town Board would like to prioritize. Ms. Olson reiterated that coordination is key so the two boards can work together to identify, define and work on issues. She is planning to seek out grant funds next year to be able to start a zoning update immediately after the comp plan is completed at the end of 2025. PRESENTATION- JACKSONVILLE COMMUNITY ASSOCIATION Ms. Zahler introduced Jon Froehlich, the JCA chair. Mr. Froelich shared a power point presentation with general information on the JCA’s inception, mission statement, and current projects (including bathroom, trail maintenance, and accessibility). ACTIVE PROJECTS (2024 AND BEYOND) Ms. Olson gave an update on current and upcoming projects to keep in mind as the 2025 budget is being formulated: • Solar panel • Parking lot • Comp plan update • ADA accessible door • DPW transition • Records-related projects • Zoning update- searching for funds next • Maplewood & Curry Rd. culverts • Camp Barton, recreation, youth development • Facilities issues 2025 BUDGET PROCESS Ms. Olson shared information on the tax cap – 2.98% and increase of ~$48,000. The town has never overridden it but has often passed a local law to override it as a safety valve. Ms. Olson asked the board whether they wanted to pass it pre-emptively. Mr. Goldman, Mr. Boggs and Ms. Olson think it is prudent to pass it as there are many unknowns. 6 The group briefly discussed fire and ambulance billing. RECOGNIZING TOWN SUPERVISOR KATELIN OLSON AS BUDGET OFFICER RESOLUTION # 130 OF 2024: RECOGNIZING TOWN SUPERVISOR KATELIN OLSON AS BUDGET OFFICER Whereas, Michelle E. Wright was appointed as Budget Officer at the 2024 Organizational Meeting, and Whereas, Michelle’s role will be changing and reduced to lesser weekly hours as she transitions to full time enrollment in school Therefore, be it resolved that Town Supervisor Katelin Olson will take over as the Budget Officer starting August 12th, 2024. Moved: Mr. Goldman Seconded: Mr. Boggs Olson aye Boggs aye Bouchard aye Goldman aye Weatherby aye Vote: 5-0 Date Adopted: 7/23/24 BUDGET REQUESTS DUE JULY 26, 2024 UPCOMING EVENTS: August 13 – Regular Meeting, 7pm @ Town Hall Week of August 19- possible Special Town Board mtg August 27 – Regular Meeting Cancelled September 2 – Town Facilities Closed for Labor Day APPROVAL OF MINUTES: RESOLUTION # 131 of 2024: APPROVAL OF MINUTES RESOLVED, that the Ulysses Town Board approve the 7/9/24 meeting minutes as amended. Moved: Mr. Goldman Seconded: Mr. Boggs Olson aye Boggs aye Bouchard aye Goldman aye Weatherby absent Vote: 4-0 Date Adopted: 7/23/24 7 PRIVILEGE OF THE FLOOR (3 min limit per person): Ms. Rose shared concerns related to town development, property codes and pesticide use. (see Appendix). EXECUTIVE SESSION Mr. Goldman moved to go into Executive Session at 8:45pm to discuss union negotiations. This was seconded by Ms. Bouchard and passed unanimously. Ms. Bouchard moved to end Executive Session at 8:55pm. This was seconded by Mr. Boggs and passed unanimously. ADJOURN: Mr. Goldman made a motion to adjourn at 8:55pm. This was seconded by Ms. Bouchard and passed unanimously. Respectfully submitted by Carissa Parlato, Town Clerk 8/9/24 8 APPENDIX: COMMENTS FROM MS. ROSE: Preserving Town Environmental Health through Zoned Requirements for Native Species Plantings— Resources Submitted to Town of Ulysses Board 7/23/2024 for use in enacting 1) Local Law assuring private property owners’ right to cultivate and maintain native habitat in place of invasives, clone cultivars, and turf lawns; 2) Town zoning that requires all developers to use at minimum 70% native plant species in landscaping; 3) Town practice of installing and maintaining only native plant species on Town owned or maintained property; 4) Local Law barring use of NYS listed prohibited or invasive plants on any property. New York State Property Maintenance Code does not protect private property owner rights to cultivate habitat to support pollinator or bird species. Habitat incorporates native species plantings and low-impact/no pesticide-herbicide use cultivation practices to provide 5 essential characteristics: water, nesting, nectar/food, cover, and overwintering. Town of Ulysses Town Board has already established a Bee Committee. As zoning goes forward, it has the opportunity to support Town environmental health by incorporating required use of native plant species only on Town properties and in development zoning, and by explicitly allowing cultivated pollinator and bird habitat on business and residential properties. New York State NY DEC study documenting NY native pollinator decline 2017-2021 https://www.nynhp.org/projects/pollinators/ Birds and Bees Act Protection Act of 2023 (restricts use of some pesticides after 2027) https://www.governor.ny.gov/news/governor-hochul-signs-birds-and-bees-act-nation-leading- legislation-protect-new-yorkers-and NY Pollinator Pathway Program through Cornell Cooperative Extension https://extapps.dec.ny.gov/docs/wildlife_pdf/pollinatorpathway.pdf Tompkins County https://www.pollinator-pathway.org/towns/tompkins-county Town of Ulysses https://www.townofulyssesny.gov/boards/ulysses-bee-committee/ Model Legislation Maryland 2021 disallows property restrictions limiting owner right to low-impact landscaping https://legiscan.com/MD/text/HB322/2021 CT Townships require municipalities and developers to plant native plants https://50789496-1896-4174-a2f8- c054f57a30c4.usrfiles.com/ugd/507894_ceeeb48cb69a481393dba2ac9b3b1cd5.pdf 9 Town of Sylva NC zoning regulations 2021 (Section 7.8 Landscaping Regulations p. 7-33 and Appendix) requires retention of native trees in all development and “use of Native Plants” in all landscaping requirements. https://web.archive.org/web/20230625191045/https://sylvanc.govoffice3.com/vertical/sites/%7B95 F568B6-3344-493D-BB06- 9C8755ED7CA2%7D/uploads/Sylva_Zoning_Ordinance_Update_and_160D_FINAL(1).pdf Town of Victor NY requires all plantings to “to satisfy landscaping and landscaped area requirements shall be comprised of at least 70% native plant species” https://ecode360.com/8088346#8088345 Regional Resources Habitat Gardening in Central New York, Syracuse-based regional chapter of the national organization Wild Ones: Native Plants, Natural Landscapes providing trainings, garden tours, plant sales and more https://www.hgcny.org/ Finger Lakes Native Plant Society for the study and appreciation of native plants: presentations, garden tours, annual plant sale, newsletter and searchable list of Tompkins County native plants by characteristic and need https://flnps.org/ Ithaca Native Landscape Symposium annual continuing education for NYS licensed landscape architects https://www.ithacanativelandscape.com/ How To for private property owners Our Habitat Garden in Central New York https://ourhabitatgarden.org/ provides information about one couple’s transformation of a suburban lawn into habitat and edible/vegetable gardens. Homegrown National Park https://homegrownnationalpark.org/ recognizing that no government is addressing the decline of biodiversity, helps homeowners rebuild habitat by cultivating keystone species (host to most kinds of native pollinators and insects) one property at a time. Certifications Are offered by Xerces Society for native pollinator gardens, National Wildlife Federation for habitat gardens, Wild Ones for habitat gardens, and Homegrown National Parks for planting “keystone” species. Local Native Plant Species Sources Grow Wild, 245 Speed Hill Rd., Brooktondale NY https://www.growwildnatives.com/ The Plantsmen, 482 Peruville Rd., Groton NY https://www.plantsmen.com/ Cayuga Landscape (has some native trees and shrubs) 2712 N. Triphammer Rd., Ithaca NY White Oak Nursery Geneva/Canandaigua by appointment http://whiteoaknursery.biz/ Cornell Plantations spring sale (has plants from Finger Lakes Native Plant Society members CLEAN Steering Committee 893 Cayuga Heights Rd, Ithaca, NY 14850 P: 607-227-5172 CLEANCayugaLake@gmail.com www.CLEANcayugalake.org February 12, 2024 Ms. Dereth Glance Regional Director NYS Department of Environmental Conservation Region 7 By e-mail to: dereth.glance@dec.ny.gov Re: NOIA sent to Cargill re application to modify permit to allow flooding to S3 portion of Cayuga Salt Mine Dear Ms. Glance: As you may have noticed in my letter to you of February 5th, I say at the end that the renewal of Cargill’s mining permit cannot be treated as an automatic administrative procedure due to Cargill’s stated need to flood the south end of the mine. On the contrary, a “good hard look” is needed, meaning that DEC and the Office of General Services (OGS) should not allow irreversible flooding of the mine to proceed without evaluation of the consequences. In this letter I provide additional detail, including the following points: • Proposed storage of water/brine under the lake in the 6-level mine is a material change. • Proposed storage of water/brine under the lake in the 6-level mine does not fall automatically (ministerially) within the permission to mine rock salt that has been granted to Cargill under the terms of its lease or “consent order” from OGS. • OGS needs to be an involved agency, along with DEC, in reviewing the proposed storage. • Proposed storage of water/brine under the lake in the 6-level mine will be, for all intents and purposes, irreversible flooding and disposal rather than temporary storage. • Proposed storage of water/brine under the lake in the 6-level mine will affect and may foreclose future use of State resources, including mineral resources, in ways that cannot responsibly be ignored or dismissed without appropriate review. • There are foreseeable consequences of the proposed storage of water/brine under the lake in the 6-level mine. 2 Proposed storage of water/brine under the lake in the 6-level mine is a material change The nature, scale, and irreversibility of the proposed storage make this a material change. We are aware of and disagree with the statement, on p. 2 of the June 2023 application submitted to DEC by Cargill consultant JMT, that: There are no proposed changes to Cargill’s existing and approved mining operations and methods. Part of the same application document, in the section of its “S3 Water Storage Overview” quoted below, directly contradicts Cargill’s claim of “no proposed changes”: The Cayuga mine’s primary water storage has historically been in the abandoned workings on 4-Level. To extend the mine’s water storage capacity, Cargill plans to establish a water storage area in the abandoned S3 mains and adjacent E3-E9 panels at the south end of the mine.... This plan of “establish[ing] a water storage area in the abandoned S3 mains and adjacent E3-E9 panels” is clearly a change. Its nature, scale, and irreversibility make it a material change, as we show here and are in the process of demonstrating in more detail. Furthermore, having reviewed 19 years of annual reports to DEC and many other documents, we consider the claim of “no proposed changes” to be untrue for various reasons including: 1) Whereas DEC did allow brine storage ponds to be created at U58 and U60 with a storage capacity of 5.5M gallons, these were temporary ponds designed to hold process and leakage waters associated with the upboring of Shaft No. 4. Recent Cargill Annual Reports to DEC do not list any inflows to the mine from Shaft #4 and thus we assume that these ponds are no longer receiving new inflows, and may have been depleted or even emptied for dust control uses on mine roadways, such that they have served a genuine purpose of temporary brine storage rather than the current proposal’s purpose of irreversible brine disposal. See below for further discussion of irreversibility. 2) Whereas brine storage ponds have been allowed on the 4-level mine for many years, these have been largely under land and wholly within a level of the mine that is no longer contributing to active production in any way. 3) Brine from “U12 depressurizing boreholes” (see pp.4-5 of the 2 August 2023 Boyd Report to DEC) is the first instance we know of in the history of this mine for the use of depressurizing boreholes at U12 or anywhere else in the mine. It is also the first Cargill- acknowledged instance of a brine source from within the mine as opposed to from shaft leakage waters or saline water piped from the surface. Such use of depressurizing also constitutes a material change in mining conditions. We are in the process of reviewing this issue in more detail and will provide additional information in the near future. 3 Proposed storage of water/brine under the lake in the 6-level mine does not fall automatically (ministerially) within the permission to mine rock salt that has been granted to Cargill under the terms of its lease or “consent order” from OGS The plain language of Cargill’s lease or “consent order” covers the mining of salt. We recognize that OGS as lessor might expand the terms of such lease to cover brine storage or disposal within the portion of the mine that lies under the lake, but any OGS decision to do so would be discretionary rather than ministerial. It cannot be treated as an automatic decision or lack of decision. Note that New York’s other operating rock salt mine, located in Livingston County, is said not to store water/brine underground, so mining of salt doesn’t necessarily encompass underground water/brine storage. Nor is this exclusively a matter for OGS. DEC has authority under the Public Lands Law (PBL § 75(7)(g)(ii)) to notify OGS of any failure to comply with conditions of a lease, easement or other interest, and may potentially be involved in steps taken to correct such failure. We bring this issue to DEC’s attention because of the authority thus granted under PBL 75(7)(g)(ii). OGS needs to be an involved agency, along with DEC, in reviewing the proposed storage The role of an involved agency is spelled out in the SEQR implementing regulations at 6 NYCRR 617.2(t), which certainly applies to the present circumstances where the proposed water/brine storage needs both a DEC permit modification and an OGS lease modification. We see that the Environmental Assessment Form (EAF) dated June 15, 2023, does not acknowledge either the role of OGS or certain other discretionary decisions mentioned in this letter. Given these omissions, and given the issuance of the NOIA on January 17, 2024, what’s the procedure for changing or replacing the existing EAF in light of such omissions and the issues set forth in the NOIA? More generally, how have DEC and OGS coordinated their respective SEQR obligations when, as here, there may be impacts associated with how state lands are used? For example, when OGS renews a lease, how does OGS determine whether or not there may be impacts? Does OGS ask DEC for an opinion? Is there a formal interagency policy on such coordination, relating either to DEC and OGS generally or relating specifically to coordinating the Cargill mine permit with the Cargill mine lease? Is such an interagency policy written, for example as a Memorandum of Understanding? If so, may we have a copy from you or by FOIL? Proposed storage of water/brine under the lake in the 6-level mine will be, for all intents and purposes, irreversible flooding and disposal rather than temporary storage Irreversibility of the proposed storage, making it permanent disposal rather than temporary storage, is apparently recognized. See, for example, the January 17 NOIA in which DEC asks 4 about “the approximate dates that convergence monitoring stations will be inundated, preventing safe access and necessitating the abandonment of the stations.” This indicates that the proposed storage is expected to be irreversible. See below for further discussion of this topic. Proposed storage of water/brine under the lake in the 6-level mine will affect and may foreclose future use of State resources, including mineral resources, in ways that cannot responsibly be ignored or dismissed without appropriate review While we would generally not promote further mining under the lake, we recognize the right of future generations to have reasonable access to resources they may deem valuable. Policies that preserve future access to such resources are important, not only in our view but also as a matter of state policy. See, for example, the following excerpt from DEC’s SEQR Handbook, 4th edition, page 121, which outlines how review processes should address irreversible and irretrievable commitments of resources: The extent to which a proposed action may cause permanent loss of one or more environmental resources should be identified as specifically as possible based upon available information. Resources which should be considered include natural and manmade resources that would be consumed, converted or made unavailable for further uses due to construction, operation, or use of the proposed project, whether those losses would occur in the immediate future, or over the long term. Simply put, deliberate flooding such as the proposed water/brine storage would make the mine “unavailable for further uses” in the sense discussed in the SEQR Handbook. A decision to flood or not to flood may be justified when current and future priorities are reviewed and compared, but, in any case, such a decision is discretionary and needs to be supported by environmental review. There are foreseeable consequences of the proposed storage of water/brine under the lake in the 6-level mine • There are known problems with depressurizing rock units above a mine, as we outlined in our recent poster presentation at the Finger Lakes Institute research conference. We are now in the process of combining that information with recently released information from Boyd and other sources on depressurization above the Cayuga Mine, and also with historic information on some of the drastic consequences that prompted Cargill to abandon mining in the S3 area in the first place. While we are still in the process of reviewing this issue in more detail and expect to provide additional information in the near future, it’s clear that attention will need to be paid to the foreseeable consequences. 5 • Studies done to date on global stability of the mine, whether by RESPEC or Agapito Associates or others, need to be available to independent third-party reviewers before they can be regarded as valid safeguards against foreseeable consequences. Geophysical models are generally simplifications of the real world; are the simplifications justified? What stress fields are included? Is regional compressive tectonic stress included? Is stress redistribution due to depressurization included? How is the continual stress redistribution due to ongoing subsidence modeled? These and various other questions need to be reviewable in a reasonably open process. • When considering foreseeable consequences, it’s useful to recognize how these are handled in a SEQR context. The procedure spelled out in 6 NYCRR 617.9 (b)(6) covers steps needed in an environmental review “if information about reasonably foreseeable catastrophic impacts to the environment is unavailable because the cost to obtain it is exorbitant, or the means to obtain it are unknown, or there is uncertainty about its validity, and such information is essential to an agency's SEQR findings…” As noted, we expect to provide additional information in the near future. In the meantime, we look forward to hearing from you on the important matters set forth above. Best regards, John V. Dennis President, CLEAN Copies: -Kevin Balduzzi, Regional Permit Administrator, DEC Region 7 -Margaret Sheen, Regional Attorney, DEC Region 7 -Jonathan Stercho, Deputy Regional Permit Administrator, DEC Region 7 -Stephanie Redmond, Program Manager, CLEAN -Raymond Vaughan, PhD, PG, geologist consultant advising CLEAN