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HomeMy WebLinkAbout2025-11-05 CPSC Final Minutes1 COMP PLAN STEERING COMMITTEE MEETING & PUBLIC HEARING Town of Ulysses Nov. 5, 2025 The meeting was held in person at the Town Hall at 10 Elm St., Trumansburg NY as well as via Zoom videoconference. Notice was 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. Weatherby called the meeting to order at 5:01pm. ATTENDANCE: In person- Committee members- Liz Weatherby (vice chair), Katelin Olson (arrived 5:22pm), Karl Klankowski, Allison Weaver, Karen Meador, Roxanne Marino, Mo Klein, Diane Cohen, Kim Moore, Tai Basilius Town Clerk- Carissa Parlato Town Planner- Niels Tygesen Via Zoom- Ann DiPetta (chair) OTHERS: Via Zoom- Jessica Geary & Matt Horn (from MRB Group), Linda Liddle, Leah Lea M., Warren’s iPhone, Clara, Linda Liddle (PB & WSPPC member) In person- Richard Goldman, Michael Boggs, Helen McLallen, Sue Poelvoorde, Bob Howarth, Sarah Adams APPROVAL OF AGENDA: Ms. Marino expressed concern that items she requested to be added to the agenda are not. She would like to add discussion of the timeline, as well as committee comments on the 10/17 draft. Ms. Weatherby requested to move approval of minutes to the end of the meeting and add discussion of timing and the 10/26 draft. MOTION: Ms. Weatherby moved to approve the agenda as amended. This was seconded by Mr. Klankowski. Ms. Weatherby amended motion to include a discussion of all drafts. This was passed unanimously. PRIVILEGE OF THE FLOOR: Ms. Poelvoorde spoke. (See attached comments). Mr. Howarth shared his history with the town- having served and chaired various boards. He said that the timeline for this project has been rushed and it appeared that the committee did not want public feedback. (See further comments attached.) 2 Ms. Weatherby suggested to the committee that the public be allowed 5 minutes to speak. Other committee members agreed. Ms. Cail said that she has read the draft but feels that the timeline and process have made it difficult for meaningful public input, even for those like herself who have been reading and attending the events. She is concerned that these things can make the town vulnerable to litigation. Ms. Weatherby asked if anyone else wanted to speak. Hearing no further comments, Mr. Klankowski moved to close Privilege of the Floor. This was seconded by Ms. Meador and passed unanimously. COMMITTEE RULES & PROCESS DISCUSSION: Ms. Weatherby thanked the group for their hard work over the last 2 years. She said that after hearing concerns, she would like to consider more time for the project and can discuss this in more detail later in the meeting. PUBLIC HEARING THE 2025-2045 DRAFT COMPREHENSIVE PLAN (ALL CHAPTERS): Ms. Weatherby moved to re-open the public hearing (from the 10/22 meeting). This was seconded by Ms. Weaver and passed unanimously. Ms. Adams concurred with previous concerns about the timeline. She feels this draft is trying to please too many people and is hard to understand. She shared feedback on format and suggested a map near the beginning of the document and additional workshops. She feels that the plan relies too much on things that have not yet been done. Ms. Liddle thinks this is a good reference document and a great tool for public engagement if the timeline is slowed. She suggested adding a page that shows the significant changes from the 2009 plan. Other concerns included removing the Conservation Zone, changing it to medium density, the lack of appendices, and lack of a recreation plan. Ms. Ritter introduced herself as a planner who has served on Ulysses boards. (See attached comments). Mr. Howarth expressed concerns on the following: • Industrial zones • Protecting the lakeshore zone • Errors on the map/data sources (See additional attached comments) Ms. Cail expressed the following: • Shares Mr. Howarth’s concerns • Like the transportation priorities of the plan • Disagrees with methods for protecting soils • Need to look at hydrology to find out where water goes • Shocked to see Development District in her area is commercial in new map. Wants DDs to be considered during this process 3 Ms. McLallen said that Mr. Howarth’s comments resonated with her. Her property is rural/ag and in new map is low-density agricultural. It is actively farmed and is orphaned in current map and she wants to know why. Ms. Poelvoorde spoke on behalf of her role as Cayuga Lake Scenic By-way Director. She expressed concern that the group was not notified of the hearing so was not given a chance to comment. She added that the By-way’s management plan is cited in the plan and should be part of the discussion. Ms. Liddle recommended that the plan needs to include more protection of private water supply. She also agreed with previous comments on the data sources used in creation of the map. Ms. Olson moved to table the public hearing. This was seconded by Mr. Klein and passed unanimously. At this time the group took a break. DISCUSSION ON TIMING: Ms. Weatherby invited comments from the committee on project timing. Discussion highlights included the following: • Support for slowing the project but having a specific timeline and end date • Cost of extending the project • Making sure the public understands the document • Potential legal challenges if the plan is not well thought out • Map errors Ms. Olson suggested another open house on 11/19 at Town Hall for additional public engagement. MOTION: Ms. Marino moved that the committee takes up to 3 months (by March 31) to continue meeting to come up with a draft. This was seconded by Ms. Cohen. The group discussed taking on the document via subcommittees. The motion passed unanimously. MOTION: Ms. Weatherby moved to hold an Open House on 11/19. This was seconded by Ms. Olson. Discussion: The group discussed what the focus would be and how to market the event. Ms. Weatherby made a friendly amendment to include timing of the Open House (4-7pm). This was seconded by Ms. Olson. All voted in favor except for Ms. Marino and Ms. Cohen, who opposed. NEXT MEETING: MOTION: Ms. Weatherby moved to schedule the next meeting for Dec. 10th at 5pm. This was 2nded by Mr. Klein and passed unanimously. DISCUSSION ON CURRENT DRAFT: 4 Mr. Horn noted that the committee gave lots of comments on the current draft. Due to the timeframe, MRB grouped comments by theme. The group discussed the best way to share everyone’s comments and the next steps. MOTION: Ms. Weatherby moved that the CPSC reviews the 10/17 draft in correlation with the 10/31 draft, and provide additional comments on the 10/17 version by 11/26, and “like” comments by others. Ms. Weatherby made a friendly amendment that if 6 or more “liked” comments will get incorporated into that draft, and the others will be compiled into a list to discuss later. This was seconded by Ms. Moore and passed by all except Ms. Marino, who opposed. APPROVAL OF MINUTES of 10/22: MOTION: Ms. Olson moved to approve the 10/22/25 minutes. This was seconded by Mr. Klankowski and passed by all except by Ms. Marino, who abstained. ADJOURN: Mr. Klein moved to adjourn at 7:48pm. This was seconded by Ms. Moore and passed unanimously. Respectfully submitted by Carissa Parlato, Town Clerk, 12/3/25 Sue A. Poelvoorde and Donald R. Murray 6350 Boyd Hill Road Trumansburg, New York 14886 Privilege of the Floor – November 5, 2025 While I would absolutely like to adhere to your Rules & Guidelines for Public Comment with respect to giving verbal comment relative to items of CPSC concern NOT on the agenda, it is impossible to do so however considering that this may be your last meeting as noted at your October 22nd meeting by Ms. Weatherby. The public received notice that the CPSC would hold a public hearing on the individual draft chapters that will become part of the final draft of the Comprehensive Plan. I received the first notice in the Town’s e-newsletter delivered on October 24th, 3:32 p.m., but as I usually do I read it over my Saturday morning coffee. From that point, I now had 11 days (if I wanted to submit comments before the meeting) to read, digest, and prepare comments on 180 pages of text. If I had not gotten the email, I would have not gotten notice until either Monday or Tuesday of the following week when the postcard arrived in our mailbox, so using Tuesday that’s now 7 days to do the same work. I also note that the public was not given access to any of the appendices, which are substantial components to the Comprehensive Plan. As I attempted to begin my thorough review, I spent 2 ½ days listening to meetings of the CPSB and became even more concerned about the process and the speed at which this update was being finalized by the Committee. I contacted a member of the committee on Saturday, October 31st to discuss my concerns and learned at that time the committee had received a compiled full draft document on 10/17 to comment on, and then a further updated document with edits made by the consultants in response, on 10/31, after the chapters had been made available to the public for the hearing. So, in fact the public does not have the latest version of the chapters, and you will potentially be voting to move the document you have in your possession on to the Town Board tonight, not even considering the comments to be given by the public tonight and potentially incorporating them into a final draft document to go to the Town Board. As the person who chaired the committees who prepared the last two Comprehensive Plans for this town, served as a Town Board Councilperson for 5 years, Deputy Supervisor for two years and a professional planner for 30 years(now retired) and my husband and I being residents of this town for 46 and 42 years along with having our employer’s base of operation located here in the town, holding the public hearing tonight on the chapters that are at least two iterations old and then voting to move a document forward that the public has not seen is professionally unethical and far from showing concern that the public be encouraged to participate when we may have potentially wasted hours of our time going through outdated documents. There is no need to rush the process to complete the update. You the committee have not even been given adequate time to review and discuss each of your comments for the 10 chapters let alone have had time to thoroughly review the final edited document you may potentially vote on tonight, less than 5 full days after receiving it. The Town Board will not be able to adopt this plan before the end of the year having to follow the SEQRA process, which a minimum will take 70 days. I take exception to MRB’s position that if one person makes a comment on material in the plan it will not be considered substantive and not needed to be reviewed and discussed by the full committee. (10/22 meeting.) All comments are substantive and should be given equal weight to discuss. This is NOT MRB’s Comprehensive Plan, it is the Town’s. The Steering Committee should decide what is to be discussed and what is to be included in the plan, not the other way around. Additionally, you will have two new Town Councilpersons joining the Board in January and they should be included in the review process before a new Comprehensive Plan is adopted because they will be charged with deciding how to move forward with elements of the plan. So, another public hearing of this committee should be set and the public provided with a complete compiled document to review and provide comments on before moving it on to the Town Board giving us adequate time to review the document. Thank you for your time and thank you to those volunteering your time for this project. Respectfully submitted Sue A. Poelvoorde Donald R. Murray Susan Ri er 1194 Kra Road Ithaca, NY 14850 November 5, 2025 RE: Comments on the Town of Ulysses Dra Comprehensive Plan Dear Town of Ulysses Comprehensive Plan Commi ee: Thank you for the opportunity to comment on this ini al dra of the plan. I appreciate what a major endeavor the comprehensive planning process is and I applaud commi ee members for their commitment to this important undertaking. There has clearly been a lot of work that has gone into this document, but I urge the commi ee to con nue to shape and closely scru nize this plan so that it be er reflects the concerns and visions expressed by residents and is a workable and is easily understandable document. In the chapters I have had me to read (and I hope to have an opportunity to review more), I’ve offered a range of comments concerning data presenta on and analysis, organiza on of the chapters, wording choices, confusing sec ons, etc. But my biggest concern lies with the proposed Future Land Use Plan and Map. This dra plan is proposing major changes that will have far reaching implica ons if implemented. I ques on how this proposal has taken shape . Were commi ee members provided with maps and resources to assist in the ir analysis and decision making, did a detailed and robust discussion about this proposal occur, does the commi ee have consensus on this proposal? The adop on of a comprehensive plan is one of the most significant land use ac ons taken by a municipality and I implore you to take the me that’s needed, and to not feel unnecessarily rushed or harried, so that you can to create the worthwhile document that the Town of Ulysess deserves. My comments are below. Sincerely, Susan Ri er Introduc on – Chapter1  Pg 1 “Comprehensive plans are usually developed for a 15 to 20-year horizon with an cipated periodic updates made every 10 years. Less extensive revisions and updates may, and should, be incorporated into the comprehensive plan on an annual basis.” The recommenda on that the Ulysses Plan be updated annually is highly unusual for a small town that expects to see con nued slow growth and possibly declining popula on (see pg……). Plans are updated to reflect changing condi ons. Frequent revisions are more typical in a fast- growing urban area where plan elements, such as neighborhood plans, road and transit plans, etc. need to keep up with growing demands. Sugges ng that annual revisions will occur for the Ulysses plan, a er a mul ple-year endeavor, raises ques ons on the town’s intent. Instead, perhaps, the town should consider holding annual discussions to conduct a review of the progress being made to meet goals/objec ves and priori es for the coming year. 2  Pg. 2 “It is not possible to implement all policies called for by the Comprehensive Plan simultaneously.” Is there a sec on that outlines short, medium and long-term implementa on? This priori zing should be included so that boards and staff are able to move forward on short term policies immediately and not waste me going through the priori zing process. • Pg. 4 Throughout the dra plan the Tompkins Country Comprehensive Plan (2015) is referenced. Why is there a heavy reliance on this County plan? It seems outdated.  Pgs 6-9 Demographic comparisons: - “The largest share of the Town’s popula on, 41.4% is over the age of 55, which is the highest of any geography. Similarly, the Town has the smallest propor on of residents aged 25 and younger, at 24.7% compared to 39.6% in the County and 31% in the Region - “The median age in the Town is 47.8, significantly higher than both the County and the Region median ages of 31.8 and 41, respec vely.” - “The Town has the lowest percentage of low-income households, with only 10.2% of households earning $25,000 or less annually and about a quarter earning under $50,000.” Using Tompkins County data to compare with Town of Ulysses data results in flawed assump ons that Ulysses is an outlier community demographically. The presence of a significant student popula on in the City and Town of Ithaca result in Tompkins County demographic data being skewed, par cularly for age, economics, and housing related indicators. But when compared to the adjacent towns of Newfield or Enfield, dispari es are diminished. For instance, according to the Census Report website (the U.S. Census website is not currently ac ve due to government shutdown), the Town of Newfield median age is 46.7, with 45% of the popula on over the age of 50, and with 25% of the popula on having an income below $50,000. Comparisons using the County data should be limited to elements that are not sta s cally affected by the large student popula on. Much of the demographic and housing data could stand on its own and do not necessarily need a community comparison, while some may benefit from comparison with adjacent towns. This county data comparison problem occurs in the Housing and Economic Development chapters also, and perhaps elsewhere. This looks sloppy and is misleading and should be addressed throughout the plan.  Pg 9 “The figure below shows the industry sector composi on of Tompkins County.” The figures are missing; there is nothing shown below. Are there any employment numbers for the town that could be included here? Chapter 2 Land and Rural Issues/Future Land Use Map  The Land Use and Rural Character Element chapter is confusing given the large amount of informa on provided. Seemingly lost at the end of the chapter are the goals/objec ves/policies largely directed at agriculture. Agricultural related goals/policies are also lightly sca ered in other chapters. It is quite common for a comprehensive plan to have a stand-alone agriculture chapter. As a dominant land use in the town, it would be very appropriate to have a separate 3 chapter related to agriculture to give it more emphasis and to place all related goals/policies in one loca on. This would also help to make Chapter 2 easier to follow.  The term "Highway 96" is used in Chapter 2 and possibly elsewhere. Change to State Route 96, Route 96 or Trumansburg Rd; no one calls it Highway 96.  Pg. 3, Map 1 Agricultural and Forest Subtypes, What is the source of this informa on? It appears to be only accoun ng for "priv forest" and there only appears to be one parcel that is owned by a nonprofit (Smith Woods). Other forested lands throughout the town are not included in the map, but should be. Or just call this an Agricultural Map.  Pg 9, Ag and Natural Resources: “Farms and mber lands…” “For these reasons, the Town is commi ed to preserving and enhancing a forest land base and promo ng a forestry industry.” The plan gives lip service to forestry and habitat protec on, but inser ng language that regards forested lands as simply “mber lands” and “promo ng ” a “forestry industry”, (much different than say, cu ng a few trees for a property owner’s needs) does not suggest genuine concern. The only forested land example provided is that located “south of Glenwood Heights Road to the Town of Ithaca municipal line” (see pg. 9). This forested area is a designated Unique Natural Area by Tompkins County. Industrial harves ng of trees in this and other sensi ve areas of the town will damage habitat needed for our local wildlife and birds that migrate through our region or nest locally. Timber harves ng on steep slopes will cause erosion and sedimenta on in local streams and Cayuga Lake. This sec on needs to be consistent with its goals. Chapter 2 - Future Land Use Map  Why are Conserva on and Lakeshore Zones being eliminated? The proposed Low Density Residen al designa on proposed along and adjacent to Taughannock Blvd is a major departure and inconsistent with the current zoning. The proposal for a 2-ac minimum lot size would subject many parcels to further fragmenta on (non-lake front parcels). Those zones were established in recogni on of the steep slopes, mature forests, fragile cliffs, plant and wildlife habitats, and numerous large and small streams that define the area. Much of this land is designated as Unique Natural Areas by Tompkins Country, which in addi on to the reasons cited above, also recognizes the corridor’s scenic and aesthe c significance. These UNAs connect with similar UNAs in the Town of Ithaca, crea ng an important biological corridor. Using Google Earth aerial imagery (free for users), one can see an almost con guous swath of forest and open space (~7 miles!) from the City/Town of Ithaca municipal line to Taughannock Falls State Park; a truly unique and important biological corridor. Anyone living in the area (myself included), or walking the Black Diamond Trail, can a est to the amazing variety of birds species, as well as other fauna and flora that u lize this important area. 4 These lands warrant extra considera on in recogni on of their important natural resource values. The steep slopes combined with an abundance of streams, both large and small (see Map 1 Ag & Forest Subtypes), poses risks for erosion and sedimenta on impacts. The Future Land Use Map proposes this same land use designa on to the upland parts of town, but these areas are not equivalent loca ons characteris cally.  The Medium Density Residen al designa on described as permi ng up to 8 units/acre is a significant expansion of density in the town. Under this proposal well over 1000 acres would be eligible for poten al upzoning in the town, many of this in the state-cer fied Ag District. Combining 8 unit/acre with a proposed requirement of ≥ 50% undeveloped/open space requirement and spreading this designa on throughout the town is a recipe for excessive sprawl, exactly what this plan suggests it is trying to prevent. Increasing density makes sense, but only for targeted and limited areas of the town and it should be coupled with a much smaller open space requirement to make the most efficient use of land for development and to make expansion of u li es as cost-effec ve as possible. There is li le jus fica on for accelera ng this degree of development poten al in the town when popula on projec ons cited in the plan indicate slow growth in the town. Nor does this seem in concert with a realist picture for how water and sewer expansion should take place in the town, again impac ng areas designated as state-cer fied Ag District. .  Why is the en re ~118-acre Agard Road parcel, currently owned by Cayuga Compost/P&S Excava on, being designated in its en rety as “Industrial” when only approximately 15 acres is being used for the compos ng facility and the remainder is currently in mostly ac ve field crops and woods? This appears to be a serious flaw. Mike’s Marine, and Moore’s Marine are used as example areas, but they are not iden fied as Industrial on the Future Land Use Map.  Why is the compost facility and auto salvage yard even designated as “industrial”. Was this determined to be the best future use for this land if these businesses cease opera on? Does “industrial” fit the current use or would a different term(s) recognize current use and provide for a be er future vision?  "The Future Land Map/Plan and zoning regula ons work in tandem to create a full picture of how land will be used. For this reason, it is important to provide an assessment of the current zoning to determine what changes may be needed to be implemented for the future land use plan. Where are the assessments and recommended changes? Chapter 3 Housing Element  Pg 11 “The Town of Ulysses has the oldest housing stock a er the Southern Tier Region. Over half, 56.9%, of homes in the Town were built prior to 1970.” 5 This is another data comparison with Tompkins County data sugges ng that Ulysses is an outlier. Ulysses certainly has a large propor on of older houses, but does the town really have the oldest housing stock?  Pg 13 Importantly, the price of construc ng new housing has risen drama cally since 2000, more than tripling from around $124,000 to $428,000 in 2024 based on a survey by the Na onal Associa on of Home Builders. What does this data even refer to – what size, how many bedrooms, what part of the US? It would be more applicable to have local figures; such the construc on costs for single family homes ($/sq..) in Tompkins County over the recent years.  Pg. 17 “The median home value is $363,085 in the Town, which is over $30,000 more than the County and just under double the Region’s median home value.” Does this figure include homes located along Cayuga Lake and this may be the reason it is over the County median?  Pg. 30 “The Town also faces a shortage of overall housing supply. This scarcity, poten ally exacerbated by the prevalence of short-term rentals,…” Should an objec ve/policy be wri en to leave the door open for some sort of future regula ons of short-term rentals, if found to be a growing problem?  H.4.4 - Extend water and sewer to neighborhoods where housing growth is desired but not where land is intended to be protected H.1.5. Proac vely adver se to regional, responsible developers, engineers, and financial ins tu ons that the Town is open for housing growth within the proposed growth areas. Where are these neighborhoods and loca ons? Does this refer to all of the Medium Density Residen al areas? The plan is not clear on what is to be protected and where actual neighborhoods are desired. Chapter 5 Economic Development Element  Genera Comment: This chapter could be so much be er if it were significantly revised. Its organiza on is confusing, it contains pages of data found in other chapters, and provides no real economic picture of the community. This chapter lacks any clear picture of the local economy. There is no explana on of the Tompkins County economy and how the Town of Ulysses fits into it and it provide no specifics for the town itself. The major employers/industries in the county should be iden fied (i.e. Cornell, Ithaca College, BorgWarner, Ithaca City School District, Cayuga Medical Center, etc.) and a discussion of how it relates to Ulysses. Many Ulysses residents work/worked directly for these en es, and many who do not work or do business directly s ll benefit from their presence in the greater local community. Higher educa on tends to fluctuate less with market condi ons 6 and this has provided a stable founda on for our local economy. Ulysses would be a much different place without these major employers. The chapter lacks any descrip on of who the major employers and employment sectors are in the town and/or adjacently in the Village of Trumansburg (Trumansburg School District, Rackers Center, service providers, etc). Page 20 contains the following statement “the Town’s largest industries include educa on, healthcare, government, and retail, along with a robust tourism industry centered around the Town’s natural resources”, but specific industries are never iden fied in the chapter. Are they referring to town industries or the greater local economy of Tompkins County? Shouldn’t there be some men on of key businesses in the town? Aren’t we, as residents, very fortunate to have a large grocery store and drugstore located here. There is no men on of this. If Shur-Save was to close, that would be a huge loss for the community and surrounding area. How are they doing? Is there anything the town can do to make sure they maintain viability here? What about the existence and benefits of the services and businesses in Trumansburg?? This chapter really lacks a local picture of what exists and what is really happening and needed in the community. And what about the arts/music/cultural aspects of the economy? Is discussion about this important aspect of the community in a another chapter?  Pg. 3 Objec ve #3.1 Understand the role of agriculture in the local economy and support the businesses of local farmers. These ac on items would make more sense being placed in a separate Agricultural Chapter and referred in this economic sec on.  Pg 7-16 The inventory sec on contains numerous pages with tables containing demographic data and housing data that are presented in previous chapters. These tables provide li le support to this chapter and contain no accompanying narra ve as to how they factor into the Ulysses economic picture. They seem superfluous and more appropriate for the housing sec on.  Pg 13 A commu ng map showing that 8,521 commuters enter the County daily, but there is no explana on as to why this map is included here, why it may be important, or where these commuters are going? (i.e. it relates to the strong job market here).  Pg 17-18 Challenges for Economic Development All these challenges were discussed in previous chapters. Couldn’t this be significantly abbreviated and reference where more informa on can be found?  Suggest that the Goals/Objec ves/Policies sec on be re-evaluated a er a thorough revision of this en re chapter 7 State Environmental Quality Review/Long Environmental Assessment Form  Why has an incomplete (Part I only) SEQR Full Environmental Assessment Form (FEAF) been provided for the public hearing? Is the purpose to indicate the town’s intent to complete the SEQR process in the future? And that comple on of the FEAF Parts II and III will be forthcoming upon submission of a fully ve ed version of the dra Comprehensive Plan, including consensus reached by the commi ee and Town Board on the Future Land Use Plan and map?  The Full Environmental Assessment Form is required because adop on of a comprehensive plan is classified as a Type I ac on in the SEQRA regula ons: “the adop on of a comprehensive plan is more likely to have a poten ally significant, adverse impact on the environment, and, therefore, more likely to require the prepara on of an EIS”. The NYS Department of Environmental Conserva on and the NYS Department of State both recommend the use of the generic Environmental Impact Statement for comprehensive plans. “The generic EIS is specifically designed to analyze a c ons that call for a series of subsequent ac ons such as a comprehensive plan. In most cases, the comprehensive plan will set out a series of follow-up ac ons such as the amendment or wri ng of zoning laws or ordinances. Second, the adop on of a comprehensive plan can be one of the most significant land use ac ons taken by a municipality.”  If the Town is not intending to prepare a GEIS, there s ll needs to be a robust analysis of the impacts that result from the proposal. Under the scenarios presented in the current proposed Future Land Use Plan, which includes expanding development and residen al density in large parts of the town from what is currently allowed via zoning, impacts listed in Part II of the FEIS will need to be analyzed and addressed in Part III in order to make a determina on on environmental significance.