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CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14650 OFFICE OF CONSERVATION ADVISORY COUNCIL TELEPHONE: 272 -1713 CODE 607 Memo to: Bill Gray, Acting Supt. Chuck Baker, Chief Operator, Water Filtr. Plant BPW Police Chief McEwen Six -Mile Creek Committee Police Commissioners Cc: Common Council and Mayor Conservation Advisory Council Members 4 i 0 WA C AC Date: Jan. 7, 1991 From: Betsy Darlington, CAC Chair 'DVK j Re: DPW operations in Six -Mile Creek above the silt pond and Police Dept. activities in the firing range area Recently I have been told by various long -time residents of the area around the silt dam, and upstream of this, about problems they perceive with work the City does in that area. The first instance occurred when the Finger Lakes Land Trust was contacted by one resident (of over 50 years) who wants to give 20 acres of her land to the Land Trust. I asked her if she had considered giving it to the City, and her response, as well as that of her son and grandson, was that they felt the City was the worst of all possible stewards of the land they own. (As the result of further discussions, the Land Trust will probably be given a conservation easement on the land.) They have seen fish populations drop to nearly zero in the silt pond and just upstream of that. They have seen careless dredging in the stream which, in their opinion, increases siltation (partly responsible, they feel, for the decline in fish). The grandson has fished in that area for over 20 years, and says that trout and bass used to be plentiful. They're now virtually absent. The fish ladder at the north end of the silt dam is not functioning, so fish cannot get upstream, so this presents another major problem which the City has not taken care of. The other occasion when I heard complaints about the City's stewardship was yesterday at a meeting held by the Town of Ithaca for residents in the Six -Mile Creek corridor (to consider a Town proposal for tighter land use controls in that area). Several residents spoke about the problems caused by the City's removal of gravel from the creek -bed upstream of the silt pond. They felt that this work causes more siltation than any activities of any homeowners, and because of the manner in which the work is done, adjacent creek banks are often adversely affected, and cave in later. Residents also complained that dump trucks operate "all night long" carrying the gravel away, and noise from this was a disturbance. In addition, they see heavy equipment sitting in the creek getting loaded up, and meanwhile dripping oil and other pollutants into the water. On Dec. 31 st. I happened to see this work in progress when the above - mentioned grandson took me on a tour of the area. An enormous mound of gravel was piled up on the shore next to the creek, where the new pipeline crosses. The very nice bulldozer operator happened to be finishing for the day just as we were passing by, so we chatted at length. He said he was removing -- - - - -- "An Equal Opportunity Employer with an Affirmative Action Program—- a large gravel bar that had collected in the creek after heavy fall rains (a common phenomenon in Six - Mile). Another concern that was expressed concerned the way the City dredged the Upper Reservoir some years ago, apparently just dumping the silt in the area and leaving it, never planting grass on it, etc. A final concern had to do with the police firing range next to the silt pond. The man who spoke about this (a life -long resident) said that "tons" of lead are all over the area, even in the creek banks. In addition, the grandson I spoke of earlier said the police use the area like their own private park, for picnics, etc., and leave debris behind them. All of these complaints from neighbors (and I haven't given you the complete list!) raise a number of questions in my mind: 1. Why is gravel being removed from the creek above the silt pond? Does its presence interfere with the functioning of the silt pond, and if so, how? What is done to protect adjacent banks? 2. Has the DEC issued a permit for such gravel removals (what the residents called "mining ")? I am told that private landowners are not permitted by the DEC to remove gravel from the creek. 3. What training and supervision is given to the operators? What is done to protect adjacent banks? 4. What would it take to repair the fish ladder? 5. Shouldn't the DPW do environmental reviews before performing such activities in such a sensitive area? 6. What supervision is provided at the police f iring range? Why isn't the lead cleaned up after each practice session? Could the ground be covered with tarps before each practice session, to collect the bullets? Do we want lead bullets leaching into the public water supply? 7. If the charge is correct that the officers leave the place in a mess (I only have the resident's claims to go on), could something be done to correct this? A large number of people in the City and Town have been working for years to see that the Six -Mile Creek corridor is protected. If the residents' claims are even partly accurate, something clearly must be done to clean up the act. When you have adjacent landowners totally critical and distrustful of the way the City conducts its business, something is not right. The City must be above reproach. It's no wonder landowners don't want their land bought by the City or Town! I have been a strong advocate of municipal ownership of more land around the watershed, but I must say, after hearing the many complaints from neighbors, I can unde stand their resistance. Thanks for your help! I know it's hard to keep on top of everything when everything seems to be falling apart at once, and with the DPW understaffed. But I would like to hear what course of action can be taken. So, where do we go from here? I have addressed this letter to all of you because I don't know the answer. Since the DPW is at the center of most of the charges, and the Police Dept. some of them, I would think talks should begin there on what corrective measures to take. But Common Council should be involved to make sure things really are corrected. I think the DEC should also be involved, since they have ultimate jurisdiction over the creek. However, I have not copied this letter to them since I think everything could be done internally. CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14850 OFFICE OF CONSERVATION ADVISORY COUNCIL CHIEFS OFFIICE .IAN 1 01991 a r RHACA POLICE DEPT. TELEPHONE: 272 -1713 CODE 607 Memo to: Bill Gray, Acting Supt. Chuck Baker, Chief Operator, Water Filtr. Plant BPW Police Chief McEwen Six -Mile Creek Committee Police Commissioners Cc: Common Council and Mayor Conservation Advisory Council Members 4 Tawh CAC- Date: Jan. 7, 1991 From: Betsy Darlington, CAC Chair 'WX7s Re: DPW operations in Six-Mile Creek above the silt pond and Police Dept. activities in the firing range area Recently I have been told by various long -time residents of the area around the silt dam, and upstream of this, about problems they perceive with work the City does in that area. The first instance occurred when the Finger Lakes Land Trust was contacted by one resident (of over 50 years) who wants to give 20 acres of her land to the Land Trust. I asked her if she had considered giving it to the City, and her response, as well as that of her son and grandson, was that they felt the City was the worst of all possible stewards of the land they own. (As the result of further discussions, the Land Trust will probably be given a conservation easement on the land.) They have seen fish populations drop to nearly zero in the silt pond and just upstream of that. They have seen careless dredging in the stream which, in their opinion, increases siltation (partly responsible, they feel, for the decline in fish). The grandson has fished in that area for over 20 years, and says that trout and bass used to be plentiful. They're now virtually absent. The fish ladder at the north end of the silt dam is not functioning, so fish cannot get upstream, so this presents another major problem which the City has not taken care of. The other occasion when I heard complaints about the City's stewardship was yesterday at a meeting held by the Town of Ithaca for residents in the Six -Mile Creek corridor (to consider a Town proposal for tighter land use controls in that area). Several residents spoke about the problems caused by the City's removal of gravel from the creek -bed upstream of the silt pond. They felt that this work causes more siltation than any activities of any homeowners, and because of the manner in which the work is done, adjacent creek banks are often adversely affected, and cave in later. Residents also complained that dump trucks operate "all night long" carrying the gravel away, and noise from this was a disturbance. In addition, they see heavy equipment sitting in the creek getting loaded up, and meanwhile dripping oil and other pollutants into the water. On Dec. 31 St. I happened to see this work in progress when the above - mentioned grandson took me on a tour of the area. An enormous mound of gravel was piled up on the shore next to the creek, where the new pipeline crosses. The very nice bulldozer operator happened to be finishing for the day just as we were passing by, so we chatted at length. He said he was removing -An Equal Opportunity Employer with an Allirmative Action Program" a large gravel bar that had collected in the creek after heavy fall rains (a common phenomenon in Six - Mile). Another concern that was expressed concerned the way the City dredged the Upper Reservoir some years ago, apparently just dumping the silt in the area and leaving it, never planting grass on it, etc. A final concern had to do with the police firing range next to the silt pond. The man who spoke about this (a life -long resident) said that "tons" of lead are all over the area, even in the creek banks. In addition, the grandson I spoke of earlier said the police use the area like their own private park, for picnics, etc., and leave debris behind them. All of these complaints from neighbors (and I haven't given you the complete list!) raise a number of questions in my mind: 1. Why is gravel being removed from the creek above the silt pond? Does its presence interfere with the functioning of the silt pond, and if so, how? What is done to protect adjacent banks? 2. Has the DEC issued a permit for such gravel removals (what the residents called "mining ")? I am told that private landowners are not permitted by the DEC to remove gravel from the creek. 3. What training and supervision is given to the operators? What is done to protect adjacent banks? 4. What would it take to repair the fish ladder? 5. Shouldn't the DPW do environmental reviews before performing such activities in such a sensitive area? 6. What supervision is provided at the police firing range? Why isn't the lead cleaned up after each practice session? Could the ground be covered with tarps before each practice session, to collect the bullets? Do we want lead bullets leaching into the public water supply? 7. If the charge is correct that the officers leave the place in a mess (I only have the resident's claims to go on), could something be done to correct this? A large number of people in the City and Town have been working for years to see that the Six -Mile Creek corridor is protected. If the residents' claims are even partly accurate, something clearly must be done to clean up the act. When you have adjacent landowners totally critical and distrustful of the way the City conducts its business, something is not right. The City must be above reproach. It's no wonder landowners don't want their land bought by the City or Town! I have been a strong advocate of municipal ownership of more land around the watershed, but I must say, after hearing the many complaints from neighbors, I can understand their resistance. Thanks for your help! I know it's hard to keep on top of everything when everything seems to be falling apart at once, and with the DPW understaffed. But I would like to hear what course of action can be taken. So, where do we go from here? I have addressed this letter to all of you because I don't know the answer. Since the DPW is at the center of most of the charges, and the Police Dept. some of them, I would think talks should begin there on what corrective measures to take. But Common Council should be involved to make sure things really are corrected. I think the DEC should also be involved, since they have ultimate jurisdiction over the creek. However, I have not copied this letter to them since I think everything could be done internally. Harlin R. McEwen Chief of Police CITY OF ITHACA POLICE DEPARTMENT 120 EAST CLINTON STREET ITHACA, NEW YORK 14850 -5689 Police Dispatcher: (607) 272 -3245 Police Administration/ Records: (607) 272 -9973 M- E- M- O- R- A- N -D -U -M John A. Ecklund Deputy Chief TO: Betsy Darlington, Chair DATE: January 14, 1991 Ithaca Conservation Advisory Council FROM: Chief Harlin R. McEwen #PhM RE: Memo of January 7, 1991 - Police Firearms Range I was surprised to receive your memo regarding the Six Mile Creek Watershed and the area we use for the Police Firearms Range. This is the first time I have heard of the issues raised, and I am disappointed that you chose to distribute your allegations to numerous councils and committees containing dozens of persons without first discussing the matter with me. As far as I can determine, the allegation "that 'tons' of lead are all over the area" is totally without merit. While it is a fact that over the years lead bullets have been shot into the earth embankment behind the range target area, my staff informs me the lead is periodically removed and used to produce reloaded bullets. Insofar as the allegation "even in the creek banks ", this is ridiculous. We would have no reason, whatsoever, to shoot into the creek banks. In regards to the use of the area, I have no evidence that any police personnel are using the area as their private park or for picnics. We do not allow our personnel to be there without supervision, and a certified range instructor must be present at all times. I have been to the range on many occasions and have never observed any litter or debris. There are trash barrels at the site, and the city has always been helpful in periodically emptying them. Betsy Darlington January 14, 1991 Page 2 I am aware that the Town of Ithaca is currently looking at the watershed area and that this has caused controversy in the neighborhood. While I certainly support protecting the watershed area, I am distressed that someone has chosen to draw us into the controversy. I believe we act responsibly in our use of the area. If you have any further information concerning this matter, please call me at any time. HRM /rhk cc: See Pages 3 and 4 Betsy Darlington January 14, 1991 Page 3 Copies have been sent to the following: William J. Gray, Acting Superintendent of Public Works Chuck Baker, Chief Operator, Water Filtration Plant Board of Public Works: Ben Nichols, Chair Carol C. Reeves, Vice Chair Denise Rusoff Paul Brandford Philip Cox Richard Berg Jill Tripp Barbara Blanchard, Common Council Liaison Six Mile Creek Committee: Carolyn Peterson, Chair Elizabeth Mulhulland Richard Fischer William Dress John Wertis Bill Lovejoy, Ranger Mitchell Levine Police Commissioners: Kirby Edmonds Michael Ellis Carol Seligmann Sara Shenk John Ware Daniel Hoffman, Common Council Liaison Common Council and Mayor: Robert S. Romanowski Barbara Blanchard Susan J. Cummings Joseph Daley John Johnson Richard S. Booth Neil H. Golder John Schroeder Carolyn K. Peterson Daniel L. Hoffman Benjamin Nichols, Mayor Conservation Advisory Council Members: Roger Ferrell John Wertis Judith W. Jones Barbara Hotchkiss Guy Gerard Rob Shapiro Cathy Emilian J. Keith Waldron Betsy Darlington January 14, 1991 Page 4 Conservation Advisory Council Ex- Officio Members: Benjamin Nichols Charles Guttman John Johnson, Common Council Liaison Carolyn Peterson, Common Council Liaison Callistra Paolangeli, City Clerk Barbara Blanchard, BPW Liaison Town of Ithaca CAC: John Whitcomb, Chair Celia Bowers Christiann Dean Richard Fischer Eva Hoffman Dooley Keifer Ruth Mahr Laura Marks Elizabeth Mulhulland Phillip Zarriello M E M O R A N D U M TO: Betsy Darlington, Conservation Advisory Committee FROM: Chuck Baker, Chief Operator WTP RE: Memo of January 7, 1991 DATE: January 11, 1991 CAC y CC- GI I have read your concerns about the watershed property above the silt dam and would like to try to answer these concerns. I will try to answer both the complaints by the residents and to your questions. The removal of silt and materials from behind the silt dam is a part of the necessary maintenance for this facility. The Kati silt dam was originally constructed to lower the silt loads flowing into the reservoir system. As a result, material is deposited behind the silt dam and in the creek. To remain effective the material has to be removed periodically. The silt dam itself has not been cleaned fully since the days the City �- owned its own dredge. Thus, instead of cleaning on a 3 -5 year cycle it is cleaned as much as possible on an annual basis. The Water Department does not have the staff to devote to the projectS�Q` 100 %. I should mention that alot of the material removed is r'4 accumulated from high flow periods in the creek. X' The banks along the creek have not been a problem. The exception is during the last high flow period which actually changed the lower flow course of the creek (due to deposited materials). This has been corrected. A permit from NYSDEC was obtained before the Water Department could do any work in the creek. Page 2 The silt load caused by the cleaning operations on the small scale that we do is considerably less than the natural loading rate of the creek during higher flows. Most of the work is being done a little at a time so the overall affect is even less. The City dozer is not being fueled in the creek. The Water Department does not have any amphibious fuel trucks to my knowledge. As to the machine itself being in the water, it is cleaned beforehand, and in actuality more, oils etc. come off of a roadway than would come off of the machine. The dredged material is piled up to allow it to dry. It is then hauled out to be stockpiled for use as backfill material. The trucks have to haul as time allows. This may be done subject to truck availability. I do not see a problem with this. The cleaning of the silt dam and resulting operations have been going on fo years. I am quite curious over the residents "voiced complaints" at this time. I believe the dredged materials that the residents thought should be planted was the silt that was removed in years past. The material was buried in the newer roadway (Burns Road) , screened and hauled away along with other past materials stockpiled. If they are referring to the present piles, I would question that anything would grow in it due to the coarseness of the material. The equipment operators performing the work would not be in the machine if they were not qualified to operate it. As to the work assigned, their direct supervisor, Ken Harding, Acting Director of Water and Sewer Operations, is very familiar with the operation and sees that it is done properly. The fish ladder has been out of service for a number of years. Is there a specific reason that it needs to be operational now? At least one of the fish species you mentioned, to my knowledge would not use such a device. Even if the fish ladder was in use, the conditions behind the silt dam, due to it never being completely cleaned (ie. loss of volume) would not be the best habitat. This may be the answer to the "declining" fish population behind the silt dam. The fish population in the 60' reservoir, mostly bass, seem quite healthy. If you feel that this fish ladder is essential then it might be a worthy volunteer project for CAC to pursue through its channel. On my end, it is i not a high priority maintenance concern. I Page 3 The Police Department range is used by many of the local low enforcement agencies. They have items stored on the premises (as well as the Water Department) for use in their training exercises. Part of the reasons for the "No Trespassing" under the Watershed Rules and Regulations is to discourage vandals from this area, the existing buildings and the range. The range is on Water Department property and the Police were given permission for the selected use. As to any other concerns over the Police supervision, I refer you to the Chief of Police. Any major events, such as qualifying and /or other major training are coordinated with the Water Department so we do not schedule any maintenance operations during that time. The range property and surrounding Water Department property is maintained by the Water Department. I personally have been through the area on many occasions and have never seen the area unkept or with debris thrown about. I find this complaint quite unfounded. our raw water supply has to meet certain criteria to be considered as a public supply. I have not noticed any changes in the lead levels. The lead would have to be subjected to conditions that would provide a corrosive surroundings for the lead to leach out. As the range area is well away from the water and has been in use for some time (with no ill effect), I would not consider the area a problem. Much of the lead is recovered and either sold as is or cleaned, melted and remolded for ammunition. I have some concern over these residents who seem to know alot of what happens on the property. There is no trespassing on the property without the Water Department's approval, yet these people seem to have quite a perception of the area. (Which would lead me to believe that they may be in violation of this rule.) out of courtesy, this rule includes notification from CAC or whomever if they plan to be on the property (alas, you too Betsy). This is not to hide anything but as managers of the property we have liability reasons that are a concern as well. A municipal agency (or private for that matter) will rarely be above reproach. To use part of an old cliche, "you cannot please all the people all the time." In my opinion people tend to be more critical to municipal operations, the City of Ithaca is no exception. I feel that the residents found it easier to voice a complaint than to look into the situation by gathering information first. (People still have a tendency to believe what they want.) Page 4 Management of the watershed property to ensure the water quality concern itself with land use management as well. This affects everyone located near the waterway. Residents will have to realize that this is a necessary concern for maintaining the water quality of Six Mile Creek, not only as a Public Water supply but as a natural watercourse. I hope that I have answered your concerns. If you or anyone else have any questions please contact William Gray, Acting Superintendent; Ken Harding, Acting Director of Water and Sewer Operations; or myself. CHB /dlp cc: File William J. Gray, P.E., Acting Superintendent of Public Works Kenneth Harding, Acting Director of Water and Sewer Operations Chief McEwen, Ithaca Police Department CAC y C G G -R; Gr_ `Or M E M O R A N D U M TO: Betsy Darlington, Conservation Advisory Committee FROM: Chuck Baker, Chief Operator WTP RE: Memo of January 7, 1991 DATE: January 11, 1991 I have read your concerns about the watershed property above the silt dam and would like to try to answer these concerns. I will try to answer both the complaints by the residents and to your questions. The removal of silt and materials from behind the silt dam is a part of the necessary maintenance for this facility. The a` silt dam was originally constructed to lower the silt loads, flowing into the reservoir system. As a result, material is deposited behind the silt dam and in the creek. To remain w effective the material has to be removed periodically. The silt •�`_� dam itself has not been cleaned fully since the days the City �- owned its own dredge. Thus, instead of cleaning on a 3 -5 year cycle it is cleaned as much as possible on an annual basis. The Water Department does not have the staff to devote to the project \ry 11 100 %. I should mention that alot of the material removed is accumulated from high flow periods in the creek. �l- The banks along the creek have not been a problem. The exception is during the last high flow period which actually changed the lower flow course of the creek (due to deposited materials). This has been corrected. A permit from NYSDEC was obtained before the Water Department could do any work in the creek. Page 2 The silt load caused by the cleaning operations on the small scale that we do is considerably less than the natural loading rate of the creek during higher flows. Most of the work is being done a little at a time so the overall affect is even less. The City dozer is not being fueled in the creek. The Water Department does not have any amphibious fuel trucks to my knowledge. As to the machine itself being in the water, it is cleaned beforehand, and in actuality more, oils etc. come off of a roadway than would come off of the machine. The dredged material is piled up to allow it to dry. It is then hauled out to be stockpiled for use as backfill material. The trucks have to haul as time allows. This may be done subject to truck availability. I do not see a problem with this. The cleaning of the silt dam and resulting operations have been going on fo years. I am quite curious over the residents "voiced complaints" at this time. I believe the dredged materials that the residents thought should be planted was the silt that was removed in years past. The material was buried in the newer roadway (Burns Road), screened and hauled away along with other past materials stockpiled. If they are referring to the present piles, I would question that anything would grow in it due to the coarseness of the material. The equipment operators performing the work would not be in the machine if they were not qualified to operate it. As to the work assigned, their direct supervisor, Ken Harding, Acting Director of Water and Sewer Operations, is very familiar with the operation and sees that it is done properly. The fish ladder has been out of service for a number of years. Is there a specific reason that it needs to be operational now? At least one of the fish species you mentioned, to my knowledge would not use such a device. Even if the fish ladder was in use, the conditions behind the silt dam, due to it never being completely cleaned (ie. loss of volume) would not be the best habitat. This may be the answer to the "declining" fish population behind the silt dam. The fish population in the 60' reservoir, mostly bass, seem quite healthy. If you feel that this fish ladder is essential then it might be a worthy volunteer project for CAC to pursue through its channel. On my end, it is not a high priority maintenance concern. 4 Page 2 The silt load caused by the cleaning operations on the small scale that we do is considerably less than the natural loading rate of the creek during higher flows. Most of the work is being done a little at a time so the overall affect is even less. The City dozer is not being fueled in the creek. The Water Department does not have any amphibious fuel trucks to my knowledge. As to the machine itself being in the water, it is cleaned beforehand, and in actuality more, oils etc. come off of a roadway than would come off of the machine. The dredged material is piled up to allow it to dry. It is then hauled out to be stockpiled for use as backfill material. The trucks have to haul as time allows. This may be done subject to truck availability. I do not see a problem with this. The cleaning of the silt dam and resulting operations have been going on fo years. I am quite curious over the residents "voiced complaints" at this time. I believe the dredged materials that the residents thought should be planted was the silt that was removed in years past. The material was buried in the newer roadway (Burns Road), screened and hauled away along with other past materials stockpiled. If they are referring to the present piles, I would question that anything would grow in it due to the coarseness of the material. The equipment operators performing the work would not be in the machine if they were not qualified to operate it. As to the work assigned, their direct supervisor, Ken Harding, Acting Director of Water and Sewer Operations, is very familiar with the operation and sees that it is done properly. The fish ladder has been out of service for a number of years. Is there a specific reason that it needs to be operational now? At least one of the fish species you mentioned, to my knowledge would not use such a device. Even if the fish ladder was in use, the conditions behind the silt dam, due to it never being completely cleaned (ie. loss of volume) would not be the best habitat. This may be the answer to the "declining" fish population behind the silt dam. The fish population in the 60' reservoir, mostly bass, seem quite healthy. If you feel that this fish ladder is essential then it might be a worthy volunteer project for CAC to pursue through its channel. On my end, it is not a high priority maintenance concern. s Page 3 The Police Department range is used by many of the local low enforcement agencies. They have items stored on the premises (as well as the Water Department) for use in their training exercises. Part of the reasons for the "No Trespassing" under the Watershed Rules and Regulations is to discourage vandals from this area, the existing buildings and the range. The range is on Water Department property and the Police were given permission for the selected use. As to any other concerns over the Police supervision, I refer you to the Chief of Police. Any major events, such as qualifying and /or other major training are coordinated with the Water Department so we do not schedule any maintenance operations during that time. The range property and surrounding Water Department property is maintained by the Water Department. I personally have been through the area on many occasions and have never seen the area unkept or with debris thrown about. I find this complaint quite unfounded. Our raw water supply has to meet certain criteria to be considered as a public supply. I have not noticed any changes in the lead levels. The lead would have to be subjected to conditions that would provide a corrosive surroundings for the lead to leach out. As the range area is well away from the water and has been in use for some time (with no ill effect), I would not consider the area a problem. Much of the lead is recovered and either sold as is or cleaned, melted and remolded for ammunition. I have some concern over these residents who seem to know alot of what happens on the property. There is no trespassing on the property without the Water Department's approval, yet these people seem to have quite a perception of the area. (Which would lead me to believe that they may be in violation of this rule.) Out of courtesy, this rule includes notification from CAC or whomever if they plan to be on the property (alas, you too Betsy). This is not to hide anything but as managers of the property we have liability reasons that are a concern as well. A municipal agency (or private for that matter) will rarely be above reproach. To use part of an old cliche, "you cannot please all the people all the time." In my opinion people tend to be more critical to municipal operations, the City of Ithaca is no exception. I feel that the residents found it easier to voice a complaint than to look into the situation by gathering information first. (People still have a tendency to believe what they want.) a Page 4 Management of the watershed property to ensure the water quality concern itself with land use management as well. This affects everyone located near the waterway. Residents will have to realize that this is a necessary concern for maintaining the water quality of Six Mile Creek, not only as a Public Water supply but as a natural watercourse. I hope that I have answered your concerns. If you or anyone else have any questions please contact William Gray, Acting Superintendent; Ken Harding, Acting Director of Water and Sewer Operations; or myself. CHB /dlp cc: File William J. Gray, P.E., Acting Superintendent of Public Works Kenneth Harding, Acting Director of Water and Sewer Operations Chief McEwen, Ithaca Police Department S OFFICE OF CITY ENGINEER CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14850 M E M O R A N D U M TO: Conservation Advisory Council FROM: William J. Gray, P.E., City Engineer QrA RE: DPW Operations in Water Shed Silt Pond and Adjacent Area FILE: Water - 060.0 Water - 075.43 DATE: January 14, 1991 TEL: (607) 274 -6530 FAX: 272 -7348 This memo is generated after reading the Conservation Advisory Council's memo of January 7, 1991. "Since DPW is at the center of the charges ", and since I only answer to charges in court, I've decided not to answer the memo. However, I will offer a series of observations. I have reviewed the DPW operations in this area covering a period of approximately 80 years. There have been several changes in the DPW's operations in that area. They involve the decreased level of activity there to the detriment of the City's water system. The silt pond which use to be dredged and the reservoir itself which was dredged for an extended period of time have not been touched in approximately the last twenty years. The tangible result was that the City's water intake was plugged for a period of approximately 10 days in the fall of 1988 and the reservoir is substantially silted in. The only remaining operation is it approaches the silt dam. This is rate at which the silt dam and the r filling in. This work has been done (No. 7- 5007 - 00031/00001 -1) since the stream maintenance by NYSDEC and the the removal of the gravel as an effort to slow down the aservoir itself have been under a permit from NYSDEC institution of permits for Army Corp of Engineers. iJi Printed on Recycled Paper "An Equal Opportunity Employer with an Affirmative Action Program" ag -2 Re: DPW Operations in Water Shed - Silt Pond and Adjacent Area Date: January 14, 1991 If the Conservation Advisory Council is suggesting that the City should go out of the business of producing water, it should not take two pages to say that. If the Conservation Advisory Council wished to know whether the work was being done under DEC permit, and in accordance with the laws and regulations of the State of New York, it did not take a two page letter to ask that. If the Conservation Advisory Council finds that adjacent land owners are critical of an operation that has been ongoing for 80 years, and that it signals that something is not right, I suggest that you're probably right. (The classic example of this type of situation is an airport.) It's in the best interest of the City for the CAC to become acquainted with the operation, its history, goals, achievements and failures, and then explain to adjacent property owners why it has been ongoing for the last 80 years. Finally, as an example of proper motivation technique would the CAC please inform the Department of Public Works and the Board of Public Works why they would want to repair the fish ladder? It is my understanding that fish ladders are only for spawning fish. In this case their progress up Six Mile Creek is stopped at the natural water falls adjacent to the Van Atta Dam. There are two additional dams in Six Mile Creek before the Silt Dam which do not have fish ladders. What is the logic in expending $30,000 to $50,000 (if the work was done in house) to repair this fish ladder? cc: Board of Public Works Charles Baker, Chief Operator of WTP Police Chief McEwen Six Mile Creek Committee Mayor Nichols Common Council Memo to: Jon Meigs Susan Blumenthal From: Betsy Darlington, Conservation Advisory Council Chair5� Date: Jan. 29, 1991 Re: Carpenter Ind. Park — Ironics Subdivision The CAC's EAF subcommittee (Jones, Farrell, Wertis) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration (no significant impact) City of Ithaca Exterior House Paint Removal Ordinance Draft Copy (2 -11 -91) Background on Lead -Based Paint -- A Health Hazard Lead -based paint and its removal has been long been recognized as a serious, insidious Health hazard. Children naturally put. things in their mouths. They often chew on window sills, interior woodwork and peeling flaking paint chips. Even lead - based paint that has been covered by many layers of non lead - based paint can be hazardous. Children can chew through many layers of paint (including the lead- -based paint). Lead -based paint is also hazardous to remove. Burning, scraping or sanding lead paint can produce fine lead- containing dust particles. These particles stick to surfaces and to airborne household dust. Lead poisoning can cause serious health problems, including permanent brain damage (especially, in young children under seven years of age who are in stages of neurological and cognitive development) and death. Exterior Lead -Based Paint Most concern over lead -based paint relates to the indoor environment. However, exterior lead -based paint is also a serious health Hazard that is just beginning to be addressed. When paint flakes and chips through natural weathering, it becomes ground up and mixed with the soil. Paint that is removed by sanding or "grinding" can become mixed with soil or carried to vegetable gardens and areas where children may play. If this paint contain; lead, the soil may become contaminated. Soil can become inhaled and ingested by children and, adults alike. It can be tracked into the house as dust. Removal of lead -based paint can affect the residents in the vicinity of the house being painted. Lead has been banned from exterior paint nationally since 1973. Most lead -based paint was taken off the market prior to the early 1970s. However, much of our housing stock predates the removal of lead from paint. If a house was built prior to the 1950s, it probably has lead -based paint. Why the City of Ithaca Needs A Lead -Based Paint Removal Regulation A Most painters remove old paint by grinding. Grinding old paint off a house is one of the fastest, least expensive and most dangerous ways to remove the old paint.. Soil can become extremely lead contaminated after grinding paint from the exterior of a house. Soil near renovated houses in Massachusetts, where a lead -based paint removal law is in effect, had levels 10 to 20 times the established „range of concern" (500 to 1,000 parts per million). One house in Ithaca had lead levels in the soil that measured 5 percent lead (50 to 100 times the "range of Concern "). Levels were measured nearly one year after the old paint had been removed - -- b-,r grin.ing. Much of Ithaca's housing stock predates the federal ban of lead from paint. • Most lead poisoning from lead -based paint is preventable. Alternative: to grinding, safe cleanup ( including use of drop cloths), grinding on low wind days and notification of residents in the vicinity -- can go a long way to preventing lead poisoning. Treatment of lead- poisoning is much more difficult, painful and dangerous than prevention. While there are many precautions that should be mandated, perhaps the most effective first step involves education of the public and a requirement that neighbors in a one- quarter mile vicinity be notified in writing whenever exterior paint removal is to be done. The notifications should include the name, address and phone number of the company doing the work; a person at the company responsible for -the work; the dates and times work will be done; precautions that should be undertaken; symptoms of lead poisoning; and phone numbers of agencies that -t.est for lead poisoning and 'lead contaminated soil. Phone numbers fnr other agF:ruuies that can respond to related questions should be listed as well. As for enforc•erfient, there are a few options. it is possible that painters would have to file a notice with the City Buil -ding Department whenever they remove exterior paint. The Building Department WOUld ther-, have the re,4ponsi.bility of er-jforcing the la.w. However, the City Building Department, while sympathetic, is overtaxed and wants nothing to do with handling the enfore.ement:. Enforcement might be handled by informed neighbors. If a painter were violating the law, a neighbor could make a complaint to the Building Department or Police Department. Painters could be required to pass a licensing requirement, Much the same as plumbers must pass. Licensing would basically cover safety - -- safety for the work crew and neighbors. Painters who violated such a law could have their license revoked. However, this again would have to be enforced by some outside party, such as the City Building Devar•tment . The paint removal notification ma,,, read as follows: 14 City of ItMQ4 Notification of Exterior Paint removal Potential Lead Hazard Exterior house paint being removed from a house located at , in the City of Ithaca, may contain lead, a potentially hazardous substance. _ (Painting Contractor) will be removing paint from the aforementioned house on (dates). Please read the following notification and follow the suggested precautions to prevent potential contamination from lead. Should you notice any of the listed symptoms of lead poisoning, please contact your doctor or the Tompkins County Health Department. The painting contractor is responsible for delivering this notice to all residents, (homeowners and tenants) in a one- quarter mile radius of the address where work is being done (noted above). This notice must be delivered at least three days prior to the painting con-tractor's commencement of wort;.. Painting Contractor: Address: City: __— __ —__-- State: __- zip: — - _ -- Responsible Person: Phone: �r�caytions,._to Preven��,e�.�oisr�nlntt • Keep windows and doors shut when during paint removal. • Keep pets and `,young children inside when paint removal. • Wash your child's hands 1. especially before you give your child food. • Wash your window rills with water and tri -- sodium phosphate. 0 Eat food high in iron and calcium. There foods decrease the effects of lead that gets into the body. If paint is being removed from your house/or apartment: o Demand that the paint; not be removed by: Grinding Burning Sanding o Demand that drop cloths be used to collect paint scrapings. Drop cloths should be laid up against the house wall, extending out 12 to 15 feet. C1 Demand that the site be thoroughly cleaned up following every work clay. Flat-, surfaces should be washed (preferably with a solution of water and tri- sodium phosphate). Use a vacuum cleaner that has a high efficiency particle absorption (HEPA) filter to :lean up paint dust. O Test the soil prior to and after the paint removal. the soil shows elevated lead levels after paint removal, have the painting contractor remove the contaminated soil. The soil, paint and dust must he properly disposed of. 0 Make sure tenants and neighbors know that paint is being removed from your house, and they are aware of the precautions and hazards associated with lead. loss of appetite 0 stomach pains 1 constipation 0 tiredness or lack of energy • vomiting • anemia irritability insomnia unsteady walk. ++ convulsions coma y ou 5� _I,,ea��oi �tt�is�g an or Contaminat on If 0 Have your blood and your child's blood tested for evidence of lead. Call your doctor or the Tompkins County Health Department_ • Have your soil tested. Call Cornell Cooperative Extension_ WW Qto _Cont�ct for �E • 41 Testing for Lead Poisoning Tompkins ti ; : t j Health r E' i" Fitii 273 -7272 Onondaga County Health Department (315) 425 -3271 Your Family Doctor- Soil. Testing Cornell Cooperative 1':.:it@i.'fl:i.'.2o7'! 0 Poisoning of Pets 1 t.. w York State College o f r, e . t.. i nary Med3.C:il'te at (Cunt..!, Uni.v1<.i'rsX.t;/ Memo to: Planning Board Linda Tsang and Jon Meigs (Planning Dept.) From: Betsy Darlington, Conservation Advisory Council Chair Date: Mar. 12, 1991 Re: Guidelines for new construction When the CAC reviews an EAF, we have several things we usually look for or recommend. We thought it might be helpful to list these for you - -both to help the Planners in preparing the EAF's and to help the Board in its review: * For parking lots: Catch basins or other means to prevent effluents from leaving the site (runoff from streets and parking lots is a major, and serious, source of water pollution); Shade trees (the more the better) in and /or around the lot - -to mitigate a number of problems: air pollution, aesthetic degradation, runoff, "heat- sink" problem; Species should be ones that are tolerant of the harsh conditions of a parking lot. Enough space around such trees to assure their survival even when mature. Use of as little de -icing salts as possible, or substitution of more benign materials or plowing. * Tree guards (during construction) located below drip -line of branches. * Replacement of trees removed by the construction. * High construction fence around work site. * Regular cleanups adjacent to, and on, the site -- daily, weekly, or as needed - -to prevent the all - too - common problem of materials escaping from the site. * Sedimentation and erosion control measures - -esp. during construction, and including stabilizing worksite exits and cleaning mud off tires before they leave the site. * Provision for •a recycling area. Use of energy- efficient materials and construction designs. * Use of natural gas for heat instead of electricity (less polluting). * No use of pesticides, or if use of these materials is anticipated, then using Integrated Pest Managament. (In many cases, no such use is even needed, but is applied anyway with the intent of "preventing" unknown potential problems.) * Plenty of good landscaping (including large shade tree species, when possible). * Potential traffic or safety problems. * We also, of course, look to see if the form has been filled out completely and accurately. (We suggest that Part I not be accepted by the Pl. Dept. - -and the application therefore should not be considered complete -- unless this has been done. Please send it to us after this has been done.) This is not intended to be a complete list for every project but just a checklist of likely concerns, with some omitted and others added as needed. Three possible sources of advice for developers: 1. IPM at Cornell can help - -e.g. Norm Hummel -- 255 -1629 (specialty is ornamentals). 2. NRI, Inc. - -Terry Forbes - -168 Pleasant Grove Rd. -- 257 -6393, 387 -5420. (We don't know much about them so this is not so much a recommendation as simply a possible source to look into.) NRI stands for something like Natural Resources I 3. Gary Lamont at Soil Conservation Service (Community Corners). Memo to: Ithaca Landmarks Preservation Commission -i Planning Board and Dept. (Chatterton) Cc: Common Council and Mayor CAC members BPW & DPW Building Dept City Attorney From: Date: Re: Betsy Darlington, Conservation Advisory Council Chair April 8, 1991 EAF for demolition of historic structure at 214 Thurston Ave. The CAC's EAF subcommittee (Emilian, Shapiro, Darlington) has considered the above EAF and has the following recommendations: Recommendation: We feel that this is a bit out of our realm and we are not in a position to make a recommendation regarding significance of impact. Comments: We are not architects, but we do have some questions and general comments about this project: If permission is given to go ahead with the project, won't this set a precedent for other historic structures in Ithaca? * It's unfortunate to remove the one attractive part of the structure and leave the ugly addition, even if the plan is to improve its appearance somewhat. Why not demolish that and build a compatible structure in its place? It's hard to tell just what the new building would look like. So often, drawings look fine, but the ultimate product is a disappointment. Although the drawings look quite nice, it is doubtful that the new building will be as distinguished as the one to be demolished. * Is it really less expensive to demolish and rebuild than to renovate and bring the building up to code? What is the cost difference? Would the new building use as high quality building materials (oak, perhaps ?) as were used in the old building? If not, how long a life will the new structure have? Would it be possible to remodel the newer wing to be more compatible with the main house, and to accomplish other design objectives at the same time? * If a couple of bedrooms were added to the downstairs, would it still have to have an elevator to the second floor? If not, would the code permit a far less expensive electric carrier running up the side of the staircase? * Part 1 (page 3, #5) of the EAF says there will be "revegetation to replace that removed during construction." What's to be removed, and what are the landscaping plans? * If permission is granted, what will be done with the materials from the demolished building? Will wood and other materials be salvaged for reuse or just sent to the landfill? Specific comments on the EAF: Part 2: Note: If any threshold is met or exceeded it must be checked in column 2, and then addressed in Part 3. Page 2, #1: should be checked in col. 2 (construction to take 15 months) Page 6, #12: (Historic structure) (Although thresholds should have been checked in col. 2, the effect was the same since the concerns were addressed in Part 3.) Page 8, # 16: Noise during construction: (probably col. 1 ?) Page 9, # 18: Same comment as for # 12. Also: 5th threshold re precedent- setting: we feel should be checked- - in col. 2 - -and then discussed in Part 3 . Memo to: Planning Board and Dept. Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: April 15, 1991 Re: EAF for Tompkins Co. Trust Co.: addition of another drive - through, and other site changes at 775 S. Meadow St. The CAC's EAF subcommittee (Shapiro, Emilian, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration (no significant impact) Comments: TCTC is to be commended for the attractiveness of the present site, and as far as we can tell from the materials we were given, this same high standard will be maintained. One concern is the anticipated increase in runoff to the street drains. Will this increase flooding in the street? What could be done to mitigate this - -e.g. could the runoff be channelled through a landscaped island? (Plants would absorb some of the water, and the rest would be slowed down.) Will the new catch basin trap effluents from the parking lot so these can be removed? We recommend this. If the transplanted oak tree and yew hedge don't survive, are there plans to replace them? L- A v V � Li "C l_t� (,-' -u_ �—__c Memo to: Building Dept. Randy and Melanie Murphy Planning Board and Dept. Cc: Common Council and Mayor CAC members BPW & DPW City Attorney From: Betsy Darlington, Conservation Advisory Council Chair 1145 Date: April 16, 1991 1,vck v-o�. r-a.&,. h-1 1-4 , P_� 494- jA vim C. Re: EAF for construction of single - family house next to Cliff Park Brook. The CAC's EAF subcommittee (Emilian, Shapiro, Darlington) has considered the above EAF and has the following comments and recommendations: Recommendation: Positive declaration unless the conditions listed below are met. Comments: Our biggest concerns have to do with: a) Setting a precedent; N Potential impacts on the creek, both during and after construction- - especially, bank erosion, pollution and sedimentation of the stream. a) If permission is given to build on this small site, it will be very difficult to ever say "No" to a future applicant. Our feelings of sympathy for the applicants should not enter into the decision, nor should our sense that this particular owner would treat the site carefully. Future owners might not. Our greatest concern has to do with the precedent- setting nature of a decision to grant permission. b) The entire site is within 90 feet of Cliff Park Brook, and falls within the area that Common Council has determined should be given an extra measure of protection. (The City's SEQR ordinance gives 100 feet from the bank as the protected zone.) The house would sit only 10 feet from the top of the bank. (The original plan was to place the house much closer to the creek, and the applicants made changes in their plans to move it back.) On the one hand, the applicants exercised due caution in buying the site. They checked it out with a lawyer, and they went through a realtor. The latter certainly should have known that the entire lot was within the critical area next to a designated stream, and if permission is denied to give a building permit, the realtor should be held accountable. If the Murphys told the lawyer that the site was next to a creek, then the lawyer also must bear some responsibility. The applicants have altered their plans in ways that attempt to address concerns expressed by reps. of the CAC, Planning Dept., and Building Dept., but we are not sure it is possible to squeeze a house into this small site without endangering the creek. In other parts of the City, homes built close to streams have indeed had a variety of negative impacts. While we are sorry about the applicant's predicament, the CAC's primary concern must be for protection of the creek, and for giving advice that is consistent with Common Council's directives and the City's SEQR ordinance. Once a house is built on the site (no matter how carefully the job is done and no matter how careful the current owners might be), it will be difficult to prevent future abuses on the site that could impact stream quality as well as detract from the attractiveness of the site for the neighborhood. Some future owner might decide to build an addition on the creek side or dump debris down the bank (extremely common, even in the "best" neighborhoods) or alter the drainage in ways that could affect the bank or water quality. Numerous scenarios can be imagined - -and in fact, seen in various places around town at sites predating the gorge - protective ordinance as well as along streams that are not covered by the ordinance. If permission to build is granted, we recommend that it only be under the following conditions: * The applicants donate to the City a perpetual conservation easement prohibiting, for example: future construction on the site, alterations of the drainage from the site in ways that would redirect flow to the creek, alteration or manipulation of the creek itself or the bank, disposal of debris, use of pesticides, fertilizers, and de -icing salts. The Building Dept. or some other City body should retain the right to monitor the site periodically to ensure compliance, especially regarding erosion and other drainage concerns. Conduct construction in a manner that will not disturb the soil on the bank (is this possible if the house is to be only 10 feet from the top of the bank ?). Due to the special nature of the site, we encourage the Building Dept. to make frequent inspections during the construction period. Divert all drainage from the house and driveway away from the stream, allowing it to percolate through the soil. (Is depth of soil, and soil type adequate for this? Info on this was not provided.) Place a construction fence around the site and clean up (daily) any building debris that escapes to the other side. Place tree guards below the drip line of trees during construction. * Install sedimentation and erosion control devices for the construction period. (We see in Part 3 of the EAF that this is their intention.) If there will be construction delays, apply quick - growing temporary vegetation or mulch to disturbed areas. Comments on the LEAF: Part l: Page 2: #4 a, and 5 b & c weren't answered (soil type, depth to bedrock and water table) . 3 : -6� L.o-s v-.ow bsx,,,.. e-9W a,.& &f # 12- -Yes (scenic views) (esp. of the creek corridor) Page 4: #9- -Jobs after completion -(0). (Not answered.) # 15- -Solid waste (applicant probably didn't understand question, but answer, we assume, is "Yes" to a and b, and County Landfill, to c, and "No" to e. (Both during and after construction.) Part 2: Page 2, # 1- -2nd and 3rd thresholds (depth to bedrock and water table less than 3 feet): since this info wasn't given, there's no way of knowing the answer. homey 3 : sce. Y-4 1400v— Page 7, #1 3--"othe r"-- We'd put in "scenic impacts" and check in first column. Page 9, # 18 -- (Precedent- setting). We'd check in col. 2. This, we feel, could be a major impact. Part 3: 2nd para. - -we feel it is unlikely that there will be no impact on the gorge, and this could be a large impact, if preventive measures aren't taken. -4 Memo to: Planning Board and Dept. Wm. Benson Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: May 31, 1991 Re: Proposed subdivision along Floral Ave., adjacent to Flood Control Channel The CAC's EAF subcommittee (Emilian, Shapiro, Darlington) has considered the above EAF and has the following recommendation and comments: Recomrnendation: Positive declaration (could have a significant impact on the environment) Comments: We have several concerns about this proposal, centering primarily around what we believe will be the major significant impacts: Effect on Cayuga Inlet from alterations to drainage patterns, aesthetic impacts, and precedent- setting. While it is true that the 2.7 acres is zoned R -3, and the owner's proposal would have less of an impact than more intense development allowed under R -3, dividing this site into 5 lots (including one with the current new house) would create substantial problems. It is surprising (deplorable!) that this is zoned R -3. Incidentally, most of the site is within the 100 -foot distance from the Inlet that is specified in the City's SEQR ordinance as requiring special attention. Of course, any large project proposed for the site could be prevented under site plan review. Under SEQR, if significant impacts cannot be mitigated sufficiently, permission may be denied. 1. Effect on Inlet: Currently, water flows onto the site through a culvert from West Hill. This then meanders through the site, and is (we think) largely responsible for the wetland that occupies the southern portion of the site. The current pattern provides for filtering of sediment and pollutants before the water reaches the Inlet. The water also is slowed down, reducing both the volume of water and the speed with which the Inlet can fill up during a flood event. If development is permitted, the City has said that the water must be piped directly to the Inlet from Floral Ave., thus eliminating the above functions provided by the wetland. Furthermore, the amount of permeable surface area will be substantially reduced on the site. Lawn chemicals, de -icing salts, pollutants from vehicles, and so on will run directly off the site into the Inlet, with virtually no buffering from the land, and volume of water will be increased. Delineation of the wetland prior to proceeding further we feel is essential. How else can the City give subdivision approval in good conscience (or the seller sell the parcels)? This will include soil testing - -a piece of information that is lacking in the EAF. How the site would respond to development depends to some extent on what the soils are like. (Some soils are impractical to build on at all.) The fact that the land is made up of dredgings from the Inlet does not give us the information needed to determine if any development is appropriate here. During construction there could be considerable siltation of the Inlet, and great care will be needed to prevent it. Another point regarding drainage is the plan to redistribute on the site soil removed for foundations. Where would it be redistributed, and what impact would this have? It should be noted that the site is within the 100 -year flood plain, so in addition to concerns regarding loss of wetland function, there are concerns with the effect of building in such a zone (for example, the cost to future unsuspecting landowners as well as to the City, in the event damage occurs from a flood). In Part 3 of the EAF, the statement is made that the owner's intent is to minimize z adverse impacts on the land and that this is a mitigating factor. We do not think that the owner's intent will have a mitigating effect. Once the land has been sold, it will be out of his control. A buyer could put up any structure he or she likes, could pave over the entire lot, could subdivide still further or put up a mammoth structure, even more out of character than single - family homes would be on this site. Deed restrictions have been mentioned, but we have not seen what these might be nor how they would be enforced. While the owner may intend that no more than 4 more houses be built, will enforceable deed restrictions limit development to this? Our understanding is that deed restrictions are notoriously lacking in permanence -- relatively easy to break in court (or in practice). The only way the owner can really protect this attractive site is to leave it undeveloped. (And we recommend that the area be rezoned!) 2. Aesthetics: Waterways are precious and need careful planning. In city after city, this important resource has been destroyed by inappropriate development. The Inlet is used by many boaters, people walk on the other side (and may bike there on a new bikeway someday), and many people drive on Floral Ave. To all of these people, the appearance of this space next to the water is important. While the owner's house is, in itself, an attractive structure, we have all heard numerous comments from people that it is out -of- place and a bit of shock. Does its presence now make it too late to protect the remaining acreage between this house and the next one to the south? That open space is lovely to look at and enhances the view for many people. Putting four more houses there would destroy this. In addition, there will be no control over how the owners use their lots or how much they pave for their cars. 3. Precedent - setting: With each approval that is given for development in a sensitive area it becomes harder to say no the next time. This is a special place and deserves careful consideration. That is the sort of precedent we'd like to see set here. 4. Another concern is that, to our knowledge, no inventory has been made of the plants and wildlife. The Inlet Valley is an important corridor for migrating birds, for example, and as more and more resting /feeding places (esp. wetlands, even small ones) are eliminated, it becomes increasingly difficult for these birds to survive. The site should at least be inventoried. Ornithologist Dave Nutter bicycles past every day and could probably give information on birds he has seen or heard in passing. While it may seem unlikely that any rare plant species are on the site, there's no way of being sure if no one checks. This could be done at the same time as wetland delineation. Specific comments on the EAF: (These items should be corrected before accepting the EAF as complete.) Part 1: Page 1, A -3: Figures in the two columns of numbers don't add up. Page 2, 4a: Soil type must be given 4b: How was 80% well- drained arrived at? We would guess it's much lower. 5c: Depth to water table - -given as 6.5 ft., but Ichthy. Assoc. says it's probably 2 -51. 12: Important scenic views: yes! Page 3, lc: Acreage to remain undeveloped, appears to be zero (see page 1) If: 12 parking spaces is probably a realistic figure, and highlights the extensive amount of impervious surface that would result from development. lh: Ultimate - -5 houses (4 additional) - -IF enforceable deed restrictions limit development to this. 2: Where would this dirt be redistributed? 4: (Removal of locally important veg.): Yes, since the vegetation is both aesthetically and hydrologically important. Page 4, 16: Pesticides: (answered yes, and we believe there would be no practical way of preventing it, short of legislation) 3 Page 5, 20: 4 (not 3) additional houses (and maybe much more, depending on deed restriction situation) 21: (Water consumption) Figuring on 3 people per house, 1000 to 2000 gals. per day is more likely. 23: Approvals needed: (also Planning Board) Part 2: Page 2 (Any threshold that is met or exceeded must be checked in col. 2) 1: (Physical change to site) Last and third - from -last thresholds (removal of topsoil and vegetation from more than 1 /2 acre) - -(not checked) - -yes in 2nd column (one of the major impacts of the proposal) Page 3, #5: (Impact on Cayuga Inlet) Last threshold (list of creeks) should be checked in Col. 2 Under "other impacts " - -check in col. 2, and re -word to read, "Possible siltation and pollution of Inlet during development and after - -from West Hill and the site. (Pesticides, de=icing chemicals, car pollutants, etc.)" Page 4, 6: Effect on surface or groundwater quality): Last threshold (siltation or other discharge that will cause visual contrast to natural conditions) - -col 2 Under "other impacts ": Increase in volume of water reaching the Inlet (from West Hill and the site itself) (Col 2) 7: Last threshold (project incompatible with existing drainage patterns) - -col 2 (this is one of the major impacts of the whole proposal) Under "other ": reword to: "major redirection of surface drainageways is likely " - -coT2 Page 5, #9: Threatened species -- unknown 10: Effect on non - threatened species: Change to "yes, and probably col 1 for first threshold (interfere with resident or migratory species) 2nd threshold (removal of over 1/2 acre of locally imp. veg.)- -yes -- col.2 Page 6, 11: Effect on views: Last threshold -- elimination or screening of important scenic views: yes - -col 2 Page 7, 13: Effect on open spaces or recreation: 1st threshold (foreclose future rec. opportunities development would make especially unlikely the possibility of the proposed bikeway being on the west side of the Inlet. (Both sides are being considered.) Under "other" - -check col. 2 (development of currently open land) Page 9, 18: Effect on character of community: checked threshold (precedent - setting for future projects) - -2nd. col. (A major impact of the proposal) Page 10, 19: Controversy: judging from the many people who have commented negatively on the one house that's been built there recently, we can expect considerable controversy - -IF anyone finds out about it. Part 3, Item H: Let's see the proposed deed restrictions, and hear about how they'll be enforced. Re mitigating effect of owner's good intentions: see comment above. Letter from Army Corps. of Engineers: Note that it says, "If no other wetlands are present within the entire parcel, the future lot owner can apply for, and probably will receive, a permit to shift the stream further south." The next sentence says, "However, if other wetlands are present within the parcel which would require alteration due to their location, the entire parcel will have to be considered for a permit." Our impression is that it isn't that hard to get a permit, and wetlands continue to be destroyed at an alarming rate. It may be that preventing such loss at the local level is the only sure way. Memo to: Common Council Planning Board and Dept. Cc: Common Council and Mayor BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Date: May 31, 1991 Re: GIAC pool Conservation Advisory Council Chair The CAC's EAF subcommittee (Shapiro, Emilian, Darlington) has considered the above EAF and has the following recommendation : Recommendation: Negative declaration Comments: Concerns about the NYSEG coal tar materials appear to have been thoroughly dealt with. While there could be some impacts on the neighborhood, any negative impacts we feel (e.g. from noise) will be more than outweighed by the positive ones. (Regarding noise, there already are large numbers of kids using the site anyway.) Could a stop sign or traffic light be placed at the mid -block pedestrian crossing? Memo to: Planning Board and Dept. Common Council and Mayor CAC members Wm. Benson From: Betsy Darlington, Conservation Advisory Council Chair �TSAs� Date: June 2, 1991 Re: EAF for subdivision between Floral Ave. and flood channel (the Inlet) At last week's Planning Board meeting when Mr. Benson's application was being discussed, Barbara Blanchard, who was sitting near me, asked me if we hadn't reviewed an EAF for this project a year ago. She particularly remembered our mentioning an animal running over Jon Meigs's foot while we were looking at the site. I answered that I didn't think so, that I had just written a memo about it. At the time, I only vaguely remembered even that. Her question jogged my memory and I decided to check through my files for such a memo. I found that Barbara was absolutely right; we HAD reviewed an EAF for the site last May 15! The application at that time was for just two new lots, not four. Because of the sensitivity of the site, the entire CAC reviewed the EAF rather than our subcommittee. In reading the memo, I found that we had said almost exactly the same things last year as this, including a highlighted section that recommended that Common Council rezone the area. Then at least high density housing could be prevented. (It's a poor location for any housing.) If permission is granted to create any new lots, some mechanism must be established to create enforceable deed restrictions, including at least the following (mostly from our review a year ago): * limits on yard size * limits as to placement and size of houses and driveways limit to single- family occupancy * prohibition on further subdivision * prohibition on use of pesticides (e.g. to kill mosquitoes and weeds) limits on alteration of vegetation * prohibition on altering the course of the stream, or filling or altering the wetland My own opinion is that these would not sufficiently mitigate the adverse impacts of developing this site. NOTE: This memo is from me, not the EAF committee, since we wrote up our review before I found last year's memo. memo to: Planning Board and Dept. David and Susan Watkins, 201 Hillview Pl. Cc: Common Council and Mayor DPW Building Dept. From: Betsy Darlington, Conservation Advisory Council Chaire,+sy Re: EAF for minor subdivision at 201 Hillview -129 S. Hill Ter. I y (move lot line between the two lots to provide room for a deck at 201 Hillview) Date: June 14, 1991 The CAC's EAF subcommittee (Shapiro, Emilian, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration (no significant impact) Comment: Hay bales (or a silt fence or some other device) should be strategically placed to trap muddy runoff during the period when the soil will be exposed. Memo to: Thys Van Cort, Director of P & D P & D Board Cc: Bldg. Dept. DPW, BPW Common Council From: Betsy Darlington, CAC Chair Date: June 15, 1991 Re: Timing of CAC receipt of EAF's Thanks for your memo of June 1 1 and the copy of the 1989 schedule. You're right that what I proposed would mean getting things to us 1 1/2, not 2 1/2, weeks before the Codes meeting. Unless I'm confused about the calendar (again!), my proposal would not add any time to the process out- lined in the Oct. 11 /89 proposal. In fact, the 189 schedule gives us more time and is better for us than what I proposed, so let's stick with that. For big projects, the extra few days it provides would be very welcome and sometimes needed. In a month in which Tue. does not fall on the first day of the month, e.g. this June: By the 1989 schedule, the EAF would be sent to us on Friday, May 31. We'd probably receive it on Monday, June 3, review it as a subcommittee on Wed. June 12, and get comments to P & D in time for their Codes meeting on June 18. In a month in which Tue. falls on the first of the month, e.g. Jan. 1991: EAF by the 1989 schedule would be sent to us on Fri. Dec. 28. We'd receive it about Monday, Dec. 31, review it on Wed. Jan. 9, and have comments in time for the Codes meeting on Jan. 15. The 1989 memo, by the way, went on the assumption that the entire CAC would review the EAF's, and suggested we meet on the first Monday in months where the first day of the month falls on a Tue. As I said at that time, we were unwilling to do that since it would cause too much confusion and people would miss meetings. (I think it was about that time that we went to a committee system for our reviews, thus making any change in our regular meeting time unnecessary.) By timing our committee meeting to the Codes meeting time, I think things will work out better for everyone than the proposal would have when the entire CAC did the reviews. The only potential for problems would be in months that start on a Tuesday and in which we must do a review which I feel the entire CAC should take a look at. Luckily, neither event happens often, so it's unlikely to be a problem. In other words, the 1989 schedule I think is fine - -in fact, better than what I proposed to you last week. The problem simply has been that it hasn't been followed. Memo to: Planning Board and Dept. Cc: Common Council and Mayor BPW & DPW Building Dept. and BZA City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: June 20, 1991 Re: EAF for changes in area variance criteria The three of us on the EAF subcommittee (Shapiro, Emilian and Darlington) feel that we aren't qualified to make any recommendation regarding this proposal. To the extent that the changes will give the BZA more flexibility in taking into account adverse environmental impacts (for example, tree removal, neighborhood aesthetics), the changes could be beneficial. We hope this will be the case. If the BZA would like our sugges- tions on this type of concern when projects are up for review, we'd be happy to help. Memo to: Planning Board and Dept. Common Council and Mayor Cc: CAC members BPW & DPW Building Dept. From: Betsy Darlington, Conservation Advisory Council Chair I" Date: July 17, 1991 Re: EAF for West Hill Master Plan The CAC's EAF subcommittee (Darlington, Shapiro, Waldron) has considered the above EAF and recommends a negative declaration (no significant impact). Comments: 1. We received the plan on July 12, and the LEAF on July 17. With our meeting scheduled for July 17, this gave us very little time to digest everything. (Comments from us are expected by the Planning Board subcommittee by July 22.) 2. The plan seems to be well thought out. Planning ahead for park space and location of roads and pedestrian paths should make reaction to future development proposals much easier and more effective. We suggest providing for bike lanes /paths, as well. 3. Map #6 shows reservation fora road to run westerly, from between the words "Hector" and "Street." It looks as though this may be a steeper grade than the plan proposes for new roads. 4. The review often speaks of addressing various potential problems during the environmental review for a project, yet many projects do not require environmental review. Therefore, we agree with the recommendation that stream corridors, woodlands, and steep slopes (15% or over) be given greater protection through new ordinances. Conservation overlay zoning would be one way to go. An excavation - and -fill ordinance is also needed. 5. We feel that R -2C zoning is too dense for Cayuga Inlet and for steep slopes (over 15 % ?). For these areas, we suggest R -1A. As the report points out, Cayuga Inlet is a significant recreational resource, and it could easily be spoiled by development - -even at the R -1 A level. In addition, parts of it are in the 100 -year flood plain and contain small wetlands. The more surface area along the Inlet that becomes impervious, the more runoff there will be into the Inlet. And pollutants and sediment will have less opportunity to be filtered out. Construction on steep slopes can be quite destructive. In addition, large scale development in these places would have a major impact on the view of the hillside from other points in the City. 6. Sedimentation and pollution of streams and Cayuga Lake should, as the report states, be prevented at sites undergoing development. We hope the Building Dept. can require that measures be taken, in those cases where a project is not subject to environmental review. tues4 "C6A�(. A,14 of Memo to: Planning Board and Dept. Mutual Housing Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair tars Date: July 17, 1991 Re: EAF for Northside Housing (Pogo Parcel) The CAC's EAF subcommittee (Waldron, Shapiro, Darlington) has considered the above EAF and recommends a negative declaration. Comments: 1. The project seems to have been well thought out, and should be quite attractive. 2. We hope that the park sees no further shrinkage. 3. During construction, we assume measures will be taken to prevent muddy runoff from the site to nearby Cascadilla Creek. Truck tires, for example, should be cleaned off before leaving the site (and the mud filtered out) so they won't track mud onto the street. Memo to: Planning Board and Dept. Raymond and Donna Hoyt Cc: Common Council and Mayor CAC members BPW & DPW From: Betsy Darlington, Conservation Advisory Council Chair -M-:6-.� Date: July 17, 1991 Re: EAF for minor subdiv. (lot line change between two parcels) at 227 Wood St. The CAC's EAF subcommittee (Shapiro, Darlington, Waldron) has considered the above EAF and recommends a negative declaration (no significant impact) Memo to: Planning Board and Dept. County Planning Dept., James Hanson Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: July 17, 1991 Re: EAF for joint transit facility on Pier Rd. The CAC's EAF subcommittee (Darlington, Waldron, Shapiro) has considered the above EAF and recommends a negative declaration. Comments: 1. The plans look much more attractive than the typical bus garage. 2. Fuel storage: underground fuel tanks, but water table is only 5 feet down. How will this be handled? 3. VVe assume all effluents from the buses, etc. will be trapped and discarded properly. Runoff of these to Fall Creek must be prevented. 4. Part 1, # 14: scenic views from the site (golf course. Stewart Park, Fall Creek, etc.). 5. # 19: (Odors) Buses are fairly smelly, and snouldn't be left idling (also would violate the City's new idling ordinance). 6. Page 5, #7 (Nearby land uses) Add "recreation" Memo to: Planning Board and Dept. Mutual Housing Bill Gray Cc: CAC members Re: Mutual Housing proposal on Pogo Parcel y Mr-0- m: Betsy Darlington, CAC Chair 1 Date: July 23, 1991 In our comments on the EAF for the above project we didn't discuss concerns relating to the fact that the site is in the 100 -year flood plain. When we raised this once before, we were told that buildings in such a zone must be built according to certain design standards - -e.g. with a way for water to pass through the foundations /basements so that the buildings do not become a barrier to the water and cause worse flooding on adjacent sites. When the Board considers this proposal, I hope you will look at the plans for mitigating adverse impacts from floods - -both to those living on the site and to adjacent sites. For example, if soil is to be removed for foundations, and redistributed on the site, won't that raise the level in such a way as to increase flooding on nearby sites? (The water has to go some- where.) Having a park between the buildings and the creek should help mitigate adverse impacts from flood water, and the more trees and shrubs, the better the protection will be. Another mitigating measure is the scale of the project itself; previous proposals for the site called for much greater density, and no park. Around the country, many places (including Ithaca) have experienced considerable suffering from floods. If there are ways to prevent such tragedies from occurring on this site or ones near it, Bill Gray probably knows what they are and perhaps could advise Mutual Housing. DRAFT — please call Betsy with suggestions -- August 1/91 RESOLUTION TO GOVERNOR MARIO CUOMO FROM The City of Ithaca Conservation Advisory Council, Regarding the JAMES BAY II- HYDRO- QUEBEC CONTRACT 1. WHEREAS, the New York Power Authority has entered into a 20 -year contract with Hydro - Quebec, calling for a supply of 1000 megawatts of power annually, beginning in 1991, and 800 megawatts on a seasonal basis, beginning in 1999, to total 7% of New York State's consumption of electricity; and 2. WHEREAS, this contract is serving as a major impetus for the completion of the hydroelectric project in northern Quebec known as James Bay I1, and is a crucial financial component of said project, with a total contribution of $19.5 billion; and 3. WHEREAS, the Governor of the State of New York has the authority to direct the N.Y. Power Authority to exercise its option to withdraw from the above contract by November 30, 1991 without incurring loss or liability for the State of New York; and 4. WHEREAS, the completed James Bay I and the proposed Jaynes Bay II will flood over 14,000 square kilometers and will have a devastating impact on a vast pristine ecosystem; and 5. WHEREAS, the affected bioregion encompasses Canada's largest wetland and supports a rich diversity of life, including, among others, the largest known concentration of aboriginal forest dwellers in North America, the world's largest caribou herd, polar bears, rare freshwater seals, the world's largest population of Beluga whales, many thousands of migratory birds, and some of the world's largest virgin forests; 6. WHEREAS, the James Bay I project, completed in 1985, has had the following impacts: a) mercury contamination of fish, humans and other species; b) dislocation of 1000 Cree Indians from their homes, and loss of the wildlife on which they depend for food, with serious social, cultural, and health repercussions; c) destruction of vast, critical habitat for many species of wildlife; d) change of salinity of James Bay, with as yet unknown impacts on marine mammals, fish, birds, invertebrates, and the vegetation on which they depend; and 7. WHEREAS, the self - sufficient way of life of thousands of Native Americans will be eroded at an accelerated pace, if Phase II is implemented; and 8. WHEREAS, the Hydro - Quebec project calls for continued construction of a vast network of roads and for government- subsidized massive clearcutting of timber; and 9. WHEREAS, Hydro- Quebec is marketing the entire bioregion to mining operations, with ensuing chemical pollution of waterways; and 10. WHEREAS, data from the New York State Energy Research and Development Authority indicate that energy conservation and increased efficiency are viable, environ- mentally beneficial, less costly alternatives to importing hydroelectric power; and H. WHEREAS, energy conservation and efficiency further strengthen the State's economy by keeping funds in the State; and 12. WHEREAS, purchasing power from Hydro Quebec will shift New York State from a demand -side to a supply -side management system; and 13. WHEREAS, energy conservation and efficiency could easily make up the 7% of the total consumption of electricity by New York State that is sought through the Hydro - Quebec contract; now therefore be it RESOLVED, that the Conservation Advisory Council of the City of Ithaca, New York, calls upon the New York Power Authority and New York State elected officials to make conservation of energy and energy efficiency the state's primary tools in meeting the energy needs of New York State; and be it further RESOLVED, that the Conservation Advisory Council of the City of Ithaca, New York, calls upon the New York Power Authority and Governor Mario Cuomo to withdraw from the State's contract for hydroelectric power from James Bay II. The above resolution was approved at the Council's meeting of August 12, 1991. � - -r I DRAFT — please call Betsy with suggestions RESOLUTION FROM CONSERVATION ADVISORY COUNCIL to COMMON COUNCIL Regarding JAMES BAY II- HYDRO- QUEBEC CONTRACT August 1, 1991 PREAMBLE: New York State energy policy is a matter of concern to all New Yorkers, and it is essential for State lawmakers to hear from local communities regarding energy management. Economic, social, and environmental consequences of energy policy decisions made in Albany can have far - reaching consequences, touching the lives of every New Yorker. The City of Ithaca has an obligation to inform State legislators of the City's views regarding State energy policies. 1. WHEREAS, the New York Power Authority has entered into a 20 -year contract with Hydro - Quebec, a Canadian utility, calling for a supply of 1000 megawatts of power annually, beginning in 1991, and 800 megawatts on a seasonal basis, beginning in 1999, to total 7% of New York State's consumption of electricity; and 2. WHEREAS, this contract is serving as a major impetus for the completion of the hydroelectric project in northern Quebec known as James Bay II, and is a crucial financial component of said project, with a total contribution of $19.5 billion; and 3. WHEREAS, the Governor of the State of New York has the authority to direct the N.Y. Power Authority to exercise its option to withdraw from the above contract by November 30, 1991 without incurring loss or liability for the State of New York; and 4. WHEREAS, the completed James Bay I and the proposed James Bay II will flood over 14,000 square kilometers and will have a devastating impact on a vast pristine ecosystem; and 5. WHEREAS, the affected bioregion encompasses Canada's largest wetland and supports a rich diversity of life, including, among others, the largest known concentration of aboriginal forest dwellers in North America, the world's largest caribou herd, polar bears, rare freshwater seals, the world's largest population of Beluga whales, many thousands of migratory birds, and some of the world's largest virgin forests; 6. WHEREAS, the James Bay I project, completed in 1985, has had the following impacts: a) mercury contamination of fish, humans and other species; b) dislocation of 1000 Cree Indians from their homes, and loss of the wildlife on which they depend for food, with serious social, cultural, and health repercussions; c) destruction of vast, critical habitat for many species of wildlife; d) change of salinity of James Bay, with as yet unknown impacts on marine mammals, fish, birds, invertebrates, and the vegetation on which they depend; and 7. WHEREAS, the self - sufficient way of life of thousands of Native Americans will be eroded at an accelerated pace, if Phase II is implemented; and 8. WHEREAS, the Hydro- Quebec project calls for continued construction of a vast network of roads and for government - subsidized massive clearcutting of timber; and 9. WHEREAS, Hydro - Quebec is marketing the entire bioregion to mining operations, August 13, 1991 To the Editor: It has come to the attention of the City's Conservation Advisory Council that a number of incinerators are operating in the City of Ithaca, for example at some of the large apartment complexes. Surprisingly, these are legal in the City and New York State, as long as the operators have the proper permits. The Department of Environmental Conservation is respon- sible for issuing State permits and for enforcing State standards. However, incinerators may be operating under permits that have expired. If you know of incinerators that sometimes emit foul odors, ash, or other materials, this should be reported to the DEC, and the enforcement officer will check out the equipment. Contact Norman Boyce, Air Quality Control Officer, DEC, 615 Erie Blvd. W., Syracuse, NY 13204; phone: (315) 426 -7552. If it is not operating properly, he will shut it down until it complies. New air quality standards are in the works for New York State, and it is thought that, once these are in place, they will effectively shut down many of the older incinerators because it will be too costly to bring them up to standard. In the meantime, pressure might be put on operators to shut down their incinerators, and to institute recycling and composting programs for trash. Almost everything that might go into an incinerator can now be composted or recycled - -the major exceptions being glossy paper, non- corru- gated cardboard, and certain types of plastic. There is no excuse for our city to continue to be exposed to emissions from these facilities. Betsy Darlington, City Conservation Advisory Council Chair CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14650 OFFICE OF CONSERVATION ADVISORY COUNCIL August 13, 1991 Ida Weber Ithaca Scrap Third St. Ithaca, NY 14850 TELEPHONE: 272 -1713 CODE 607 Dear Mrs. Weber: Every so often the Conservation Advisory Council awards someone for his or her contribution to our City's environmental well- being. At last night's meeting, we voted unanimously to give such a commendation to you for your many years of recycling huge quantities of the community's dis- cards. You perform an extremely valuable service for all of us - -the impor- tance of which people are finally beginning to appreciate. We will be writing up a statement for the media and Common Council (I'll send you a copy), and would like to present you with a certificate (made by Ashley Miller, former CAC Chair) at the September 4th Common Council Meeting, if you can be there. Would this be possible for you? Congratulations, and thanks for all you do for us! Sincerely, Betsy Darlington, Chair An Equal Opportunity Employer with an Affirmative Action Program DRAFT — PLEASE GIVE COMMENTS TO BETSY RESOLUTION TO COMMON COUNCIL FROM THE CONSERVATION ADVISORY COUNCIL Regarding rezoning along Cayuga Inlet August 13, 1991 WHEREAS, the Cayuga Inlet Flood Control Channel is an important recre- ational resource for residents of, and visitors to Ithaca; and WHEREAS, the scenic beauty of the strip of land that runs between Floral Avenue and the Channel contributes significantly to the enjoyment of those using the stream corridor for boating, fishing, or walking; and WHEREAS, part of this strip is maintained by the City as a public park; and WHEREAS, the privately owned portions of this area receive drainage from West Hill, thus slowing down and filtering this runoff; and WHEREAS, the privately owned portions are currently zoned R -3a, which could lead to more intense development of this sensitive piece of land than is compatible with adjacent uses along the Flood Control Channel; and WHEREAS, the new West Hill Master Plan proposes reducing the density of R -3a zones (including the above strip) on West Hill to R -2c; and WHEREAS, the Conservation Advisory Council feels that R -2c is also too dense for the above strip of land; now therefore be it RESOLVED that Common Council change the zoning of the strip of land between Floral Ave. and the Cayuga Inlet Flood Control Channel from R -3a to R -1 a; and be it further RESOLVED that Common Council prohibit construction of any structures within 200 feet of the top of the bank along the Channel. Passed _ at the Sept 9 Meeting. Memo to: Planning Board and Dept. City Health Club Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: Sept. 1, 1991 Re: EAF for City Health Club parking lot The CAC's EAF subcommittee (Waldron, Shapiro, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration (no significant impact) Comments and suggestions: 1. Could you include a few more large shade trees? 2. How about offering customers and employees incentives to ride bikes or take public transportation to your facility? E.g., secure (and covered) bike racks, and bus tokens. (This might reduce the number of spaces needed for cars enough to provide extra space for more trees.) 3. We think the appearance of the site will be improved by the proposed changes. Memo to: Common Council and Mayor Cc: CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: Sept. 1, 1991 Re: EAF for change in variance procedures (to give those who get variances two years, rather than one, to implement their plans before the variance expires). The CAC's EAF subcommittee (Shapiro, Waldron, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration Memo to: Planning Boarc and Dept. Common Council and 'Mayor Client Committee Cc: CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair 2zs Date: ©c-�. 8 , 1991 Re: EAF for new court facility The CAC's EAF subcommittee (Shapiro, Waldron, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Insufficient information regarding appearance of site (replacement of wooded hillside with large building) and possible impact on Six -Mile Creek (esp. possible drainage -- erosion problems). These are the areas of greatest concern to us, and we hope that everything possible will be done to lessen the impacts. Great care must be taken during construction to prevent erosion and sedimentation, and to keep construction debris from getting into Six -Mile Creek. Also, measures should also be taken to prevent an increase in runoff from the site after completion of the project. Comments on EAF: Part I: A -3: Numbers given are confusing. One question: will the entire site be stripped, then 2800 sq. ft. re- vegetated after building's completion? Page 2, # 12: (Views) From Woolworth's and nearby sites, this wooded hillside provides some relief from urban closeness. Page 3, B -1 -b: Should this be .173 and .254 acres? (Or does second figure include areas to be re- vegetated ?) B-1-c: ? .08 ac? B-2, 3: Where will excavated material and vegetation be taken? B-5: (Re- vegetation plans) (What are the plans ?) Page 4, #6, 7: One phase or two? What should dates be? (Some typos here.) #15: (Solid waste disposal) How about C &D debris? And where to? Part II: Page 2, #1: 1 st threshold should be checked in col. 2 if threshold will be met or exceeded. 5th threshold: ditto Page 3, #5: (Effect on water bodies) Yes; 3rd threshold, col. 2. (At least, a potential for this. Care needed to prevent sediment or debris out of creek.) #6: (Effect on surface or groundwater) Yes; last threshold. Same comments as above. 15% of site is on 15% or greater slope. #7: (Alter drainage flow or patterns or surface runoff) Yes; under "other " -- replacing well - vegetated slope with large bldg. and parking lot -- potential for erosion and increases in amount of runoff. Page 6, #11: (Views) Last two thresholds: col. 2 Elimination of attractive view from Woolworth's lot and nearby areas. J Memo to: Planning Board and Dept. Amerada Hess Corp., 1 Hess Plaza, Woodbridge, NJ 07095 Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair , Date: Oct. 8, 1991 Re: EAF for site changes to Hess gas station on Rt. 13- Meadow St. The CAC's EAF subcommittee (Waldron, Shapiro, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration. Comments: 1. We assume that Hess Corp. will take this opportunity to install vapor recovery systems at the tanks and pumps, since this will probably be required in upstate NY in the near future. (In any event, it would be a good advertising ploy in this environmentally aware community!) 2. The view to the west is very nice - -or would be, if there weren't an obstructive green - and -white metal fence in the way. (Grass, then mature trees, then wooded hillside.) Why hide this natural asset behind an ugly fence? 3. The tank removal risks, we understand, will be managed by DEC and the fire dept. 4. Water table depth is given as "unknown." This should be given. We thought it was very near the surface in that area. If so, what implications does that have for underground fuel storage? 5. Where will all the construction debris be taken? 6. Gas stations must be especially scrupulous in their house - keeping, given the toxic nature of their product. What measures will be taken to trap effluents from vehicles, and accidental spills from pumps? Specific comments on EAF: Part I, page 2, #5-b, c: Depth to bedrock and water table should be given. #6: (Slope) (Typo - -100 %) #12: Scenic views to west (near and far) (if fence were removed) Page 3, B-2, 3: C & D debris? Grass - -where to? Page 4, #15: Construction debris? Trash generated on the site? (We assume Landstrom Landfill.) Part II, page 2, #1: 2nd threshold: Construction where water table is less than 3 feet is checked in col. 1. If depth is less than 3 ft., check should be in col. 2. (Depth not given in Part I.) Page 3, #6: (Groundwater impacts) Yes. 4th threshold -- always this potential, though we assume all regs. will be followed, and good housekeeping technics used. Page 4, #S: (Air quality) Yes. Last threshold (Other) - -Vapor recovery system at pumps and tanks would help mitigate this. (And advertize it!) Memo to: All Dept. Heads 1 From: Betsy Darlington, CAC ChairT Re: EAF subcommittee for Oct., Nov., Dec. Date: Oct. 8, 1991 The CAC's EAF subcommittee for Oct., Nov., and Dec. will be: Rob Shapiro Bara Hotchkiss Betsy Darlington Please send copies of EAF's (and documentation needed to understand projects being reviewed) to all three. Thanks? Memo to: Planning Board and Dept Chartwell Associates, Rick Cowles Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: Oct. 8, 1991 Re: EAF for "Fairfield Crossing " -14 unit development behind Dairy Queen, on Spencer Rd. The CAC's EAF subcommittee (Shapiro, Waldron, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration Comments: Our major concerns are with appearance of the buildings and with drainage. 1. a. The landscaping plans look very nice, and should greatly improve the appearance of the site. One suggestion, however: how about some large trees along Spencer Rd., to provide shade and to hide the very plain buildings? One large one could go just to the left of the driveway as you're about to enter the parking lot. Others could go NE of this, near the shrubs. Some large deciduous trees to shade the buildings in summer would also be desirable. Perhaps STAC would give some advice on this. b. We realize the developer is trying to keep costs low, but couldn't he still provide more attractive buildings? Perhaps Mutual Housing or INHS could give some help. The "structures proposed for the Pogo Parcel, and earlier plans for a project on Floral Ave., were designed to be affordable, yet still blended well with nearby residen- tial neighborhoods. Two suggestions, though these alone would not be sufficient, would be to make the pitch of the rooves steeper and to provide some roof overhang. Every attempt should be made to provide structures that are compatible, not with the commercial structures of Elmira Rd., but with nearby residential neighborhoods. In Part III of the EAF, we see that the developer wants to use bright and unusual colors for the structures. This we would emphati- cally discourage - -even if an attractive design is chosen for the buildings, but especially if the current design goes through. Bright, unusual colors will merely draw attention to the undistinguished design. (Even on buildings that have greater architectural interest than these, garish colors can be devastating -- witness Cornell's Performing Arts Building!) 2. What provisions will there be to trap parking lot effluents so they won't enter the storm sewers? 3. The EAF was riddled with omissions and errors —as noted in the margins by Linda Tsang— perhaps in his haste to get the project on next week's agenda. We trust the EAF will be corrected prior to next week's meeting. The only addition we would make to her comments is on page 4 of Part II -47. To her comment, we would add the phrase, ";...effluents from the parking lot should be trapped and removed." Memo to: Planning Board. and Dept. Peter Demjanec Ching Po Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair mss, t� , Date: Oct. 8, 1991 Re: EAF for subdivision at 812 E. State and Blair St., with plans to construct a 6- bedroom dwelling for students. The CAC's EAF subcommittee (Waldron, Shapiro, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration, but with reservations Comments: We have several concerns about this proposal: 1) Impact on neighborhood character and stability; 2) Impact on traffic congestion and safety at the Mitchell -Blair -State intersection; 3) Impact on aesthetics, noise, and pollution, from removal of vegetation, esp. trees. 4) An earlier concern -- increased runoff to the adjacent lot and E. State St. - -has now been addressed by adding a second dry -well, and reducing # of parking spaces. Not being engineers, we are unable to evaluate the effectiveness of this, and assume DPW has taken (or will take) a look at it. The developer is to be commended for his speedy response to this concern. 1) Our understanding is that this neighborhood is now largely composed of students, a change that has occurred over the past 25 years. Orchard Place, right in the middle, is still single - family, however. Apparently, there is a good deal of controversy concerning this project, and that may be sufficient to issue a positive declaration. At what point does the balance tip from nearly unbearable to unbearable? Would this additional house, packed in closely to adjacent student houses, tip the balance? Not living in that neighborhood, we are not in a position to say, but two of us live in student neighborhoods and are well aware of the adverse impact on a neighborhood of packing things too densely with students. Will single - families finally be driven out entirely? In addition to noise and traffic problems, student housing tends to have trash problems. (In fact, the house currently on the lot to be subdivided has garbage and trash strewn about in two areas - -both unsightly and unsanitary. In view of the large raccoon and skunk population in the area, and the new danger from rabies, this is more than just am aesthetic concern, and we urge the owner to take immediate steps to secure the garbage, cleanup the trash, and educate the tenants.) Perhaps the biggest impact of moving to an entirely short -term transient population is the loss of neighborhood stability and cohesion. Again, not being residents of the neighborhood, we cannot do more than point to this as a possible large impact of the proposal. 2) Traffic and safety: the Mitchell -State St. intersection is not an easy one to negotiate (albeit much improved since DPW put in the island). Traffic from Blair St. adds an additional element of "excitement." The new house would add, presumably, 6 more cars (assuming the limit of six students is adhered to), plus guests. The assertion in the EAF that the house would generate just 4 trips a day we feel is unrealistically low. Once again, we do not feel qualified to judge if these additional 6 cars (and cars of guests) would tip the balance at that intersection. 3) The site is almost totally covered with vegetation - -young and mature trees, brush, etc. The loss of most of this vegetation could have several impacts: First of all, currently it is absorbing much of the water that falls (or runs) onto the site. (And, of course, water is able to percolate into the soil.) The dry -wells may be an adequate substitute, however. The many trees on the site (as compared with hedges, grass, etc.) are especially efficient at reducing air pollution, cooling the surrounding environment, and reducing noise (both from heavy traffic and from students). Obviously, stripping much of the site and replacing the vegetation with pavement and a building will eliminate these amenities. And, finally, loss of vegetation will have an aesthetic impact. We urge the developer to plant as many trees as will fit on the site, both in front and in back. The proposed hedge extension in front is fine - -but not nearly enough. (The property's value - -both to potential tenants and potential purchasers - -would also be enhanced. Trees also involve far less maintenance than hedges.) Specific comments on the EAF: Part I: A -3: (Nit -picky detail -- column 1 should add up to 9158, not 9154.) Page 2, #4-a: Soil type should be given. #4-b: Since soil type is unknown, how was it determined that 100% is well - drained? #5 -b, c: (Depth to bedrock and water table) How was figure arrived at? #16: (Land use within 1/4 mile radius): Also single - family. Page 3, #1 -b: Numbers don't seem to add up. We think first one should be .053 acres 2312 sq. ft.). #1 -f: How`were 4 trips per day and 4 per hour arrived at? At least the per - day figure seems like an underestimate. #2: (Natural material to be removed from site) What will happen to material excavated for the house, and other construction debris? #3: (Vegetation removal) We couldn't tell from the revised site plan and the sketch showing the two drywells what would be removed. The two drawings do not match up. #5: (Re- vegetation) Are there plans for new trees? If so, where? #I 2-a, b: ( Liquid waste disposal) Yes -- sewage. Page 5, #19: (Noise during construction) Yes. #20: (We urge use of gas heat, not electric, since it is less polluting and less expensive.) #21: (Water usage) 400 gals. would be about what to expect from just four people. Actual figure for 6 would probably be closer to 600 gal. Part U: Page 2, #1: (Effect of physical change to site) First threshold (constr. on slopes of 15% or more)) should, we think, be checked (in col. 2). 2nd and 4th thresholds (re depth of water table and bedrock) perhaps should be checked -- unless the statement earlier-that depth is over 4 feet is accurate. Were test pits dug? If so, were soils determined at the same time? Page 7, # 14: (Transportation) 2nd threshold (traffic problems) should be checked- - probably in col. 2. Page 9, # 18: (4th threshold -- Influx of particular age group with special needs) We think this should be checked (col 1 or 2). (Last threshold -- other) We'd add to Meigs's statement, the following: ...and conversion from family neighborhood to student neighborhood. Page 10, #19: (Public controversy) This perhaps should be checked in col. 2, not 1. Memo to: Planning Board and Dept. Wm. Cleary Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: Oct. 10, 1991 Re: EAF for proposed Quick -tube between Monro's and Arby's on -` Rt. 13 The CAC's EAF subcommittee (Waldron, Shapiro, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration (no significant impact) Comments: 1. Our major concern with this proposal is any potential for groundwa- ter contamination. Groundwater is high on the site, and the basement with the oil storage tanks will be below groundwater level. If one of the tanks were to spring a leak, how much could the containment room contain? While the walls may be effective barriers, how about the door? What federal and /or state rules and regs. apply to such facilities? Does the DEC or EPA inspect them? Also, will our Fire Dept. and DPW be checking the plans, and then, after construction, the facility? # 10 on the SEAF, page 1, is checked "yes" but applicant forgot to list what agencies must give approval. The material supplied seems to indicate a very clean, well main- tained facility, with several advantages over other methods of changing the oil in cars. 2. How will parking lot effluents be trapped and removed, so they don't enter the storm sewers? 3. We strongly recommend incorporating some landscaping into the plans -- especially trees - -in line with other City and business attempts to upgrade the appearance of Elmira Rd. 4. Mr. Cleary did a commendable job of supplying us with material to help us understand both the project and the site characteristics - -even making a video of two similar facilities. (He gets an A on his first -ever video production!) Memo to: Planning Board and Dept. (Meigs) Charles Klinko, Elizabeth Stevenson Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair�5� . Date: Oct. 21, 1991 Re: EAF for minor subdivision at 209 -211 Cliff St. (Two houses on one lot; owner wants to sell one house, after first dividing the property in two.) The CAC's EAF subcommittee (Hotchkiss, Shapiro, Darlington) has considered the above EAF and has the following recommendation: Recommendation: Negative declaration (no significant impact) Memo to: Planning Board and Dept. (Meigs) Charles Klinko, Elizabeth Stevenson Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair, Date: Oct. 21, 1991 Re: EAF for minor subdivision at 209-211 Cliff St. (Two houses on one lot; owner wants to sell one house, after first dividing the property in two.) The CAC's EAF subcommittee (Hotchkiss, Shapiro, Darlington) has considered the above EAF and has the following recommendations: Recommendation: Negative declaration (no significant impact) 204 Fairmount Ave. Ithaca, NY 14850 Nov. 17, 1992 Mayor Ben Nichols City Hall, Ithaca Dear Ben: Beavers! Scourge of the earth! Destroyer of forests, threat to humanity! I was sorry you couldn't make it to last Friday's beaver walk with Roger Miner, the DEC's wildlife specialist (he also happens to be a trapper, including of beavers). His assessment was the same as it was last spring: a. The stretch of Six -Mile Creek from Van Atta's Dam to 30 -foot Dam is very poor beaver habitat. b. There is very little beaver damage and it is highly unlikely that there are any more than two - possibly three — beavers in that area. C. They have just one active lodge, at the last bend before 30 -foot Dam. The two lodges near the Giles St. Bridge have not been mudded over, indicating that they're inactive. d. The pair at the lodge upstream will visit these old lodges to get food - -hence the activity people observe there. e. When habitat is poor, their reproductive rate is low. Also, two -year -olds are kicked out, and since the habitat is so poor, undoubtedly they are moving out of the area. Beavers will travel long distances, overland as well as along stream corridors. f. The creek is unsuitable for a dam; if they ever make one, during some low -water stage, it will wash out when the water level and speed of flow return to normal. These were things he said to all of us. g. In addition, I asked him if he thought the DPW's fear of branches cut by the beavers washing downstream to Van Atta's Dam and causing the City a big removal expense was a realistic fear. He told me he doubted it very much. (Others were not within earshot at the time we had that brief conversation.) Now, for some of my thoughts on all this: 1. Beavers have been along that stretch on and off for thousands of years. 2. They have not to my knowledge caused major maintenance problems for the City although that has been watershed territory for most of this century. 3. Beavers cut trees to eat them (or the bark) or to use them in their lodges. Trees that are falling from natural bank erosion are far more likely to drift downstream. Any increase in this that might be caused by beavers, given their small numbers there, would be negligible. 4. Actually, the beavers in that area have cut very few trees anywhere, let alone along the bank. Unfortunately, some people see one large cut tree (or worse, several) and they think the end has come! I've been watching beavers on CT Hill and at Michigan Hollow for about 28 years, and the amount of cutting going on along Six -Mile is miniscule. 5. Many of my students at Belle Sherman are from downtown. Many kids these days, but especially those kids have little opportunity to really experience nature. I wish you could see their excitement when they come to school and tell me about seeing a beaver at Van Atta's Dam. From their reaction (and the reaction of adults who have called me or stopped me on the street), this is one of the high points of their lives. Are we going to take this joy away from so many because of some imagined, hypothetical, only remotely possible problems? We have managed nature almost out of existence. Will this be just one more victim of our penchant for making everything after our own image of how the world should be? 2 6. I have never heard of beavers posing a threat to other wildlife. On the contrary, they are known for their mostly beneficial impact on habitat and species diversity. In their current location at Six -Mile in the City, there are too few of them to cause harm. If the population grew to a high number there, this could be an instance where they might cause harm, but Roger Miner's opinion is that this is extremely unlikely since the habitat is so inferior for them. 7. The wildflower preserve is not threatened at all by the beavers- -they are staying out of the major flower areas. 8. Even if they did cut a few trees in those areas, it would cause no harm. As any forester would tell you, some selective cutting in a forest can be a good thing and can enhance wildflower growth. When the canopy becomes too closed in, the plants close to the ground can be shaded out. Luckily, enough trees are falling of their own accord so that apparently is not happening there. 9. If the beavers were numerous and causing extensive damage, I'd support removing (i.e. killing) all but a couple of them. I've been teaching nature at Belle Sherman for 21 years, and taking kids to Six -Mile Creek every spring to see the wildflowers. That resource is special, and significant threats to it (e.g. too many deer) should be dealt with. At this point, the beavers are not posing a threat to the wildflowers. If they ever do, I'll join with those advocating trapping. (Relocating them is not an option - -it is no longer legal to do that.) 10. I have never heard of injuries or death from a beaver -cut tree falling on someone. In any event, far more trees are falling in there from wind, old age, and disease than from beavers. 11. The danger of someone falling on and being seriously injured by a small pointy stump where a beaver has cut off a small tree is a remote possibility. Not so remote is the danger of drowning in the creek, falling off a cliff, falling on a sharp stone, falling on branches of trees that have fallen of their own accord. Or being hit by a car while crossing the street or shot by someone's bullet. If people stay on the trails as they are supposed to, they will not fall on those spikey cut trees. (It helps to look where you are going, too.) Ben, we cannot remove every hazard from our natural areas unless we cut down all the trees, remove all the rocks, fence off the streams and cliffs and turn the place into a lawn - -and then there's no natural area. Kids can be taught to be careful, just as they can be taught to look both ways before crossing the street. Cars and guns are far more hazardous to people than anything they'll encounter in the woods. When this matter comes to the vote a or BPW ,f h, ere is, a tieJ I hope you will cast the deciding vote on the side of the beavers. You are a strong advocate of affordable housing, a laudable goal. 1 hope you will also be a strong advocate for quality of life in other respects as well- - in particular for those in our City who are less fortunate. If you vote to exterminate the beavers, you will be taking something very special away from those kids (and many of their parents as well) that is irreplaceable. Please show you care - -and at the same time avoid what would surely be a huge controversy, given how so many feel about those two innocent beavers. Thanks for listening! Yours, Betsy Llington Memo to: Planning Board and Dept. Quick -lobe applicant Cc: Common Council and Mayor CAC members BPW & DPW Building Dept. City Attorney From: Betsy Darlington, Conservation Advisory Council Chair Date: Nov. 25, 1991 Re: Quick -Lube proposal to heat facility with usedmotor oil When our EAF subcommittee reviewed the EAF for construction of a Quick -lube facility on Rt. 13, we were unaware of the problem of lead in the used motor oil they were proposing to burn in a heater, to heat the building. I just learned that the plans for the site are being changed, and therefore the applicant will have to go through site plan review again. I urge the Planning Board to deny permission for them to burn used motor oil to heat the building. In the past couple of weeks, I have read two articles about the significant lead pollution hazard caused by such burning. I imagine the applicant, like us, was unaware of the danger. The most recent article was in the Dec. -Jan., 1992 issue of National Wildlife. It claims that the burning of used motor oil is "the largest source of lead in the nation's air." (See attached photocopy.) The other article I think was in the Ithaca Journal. Because the large doors of the facility will have to be open most or all of the time, I would guess that a fairly significant amount of oil would have to be burned in order to keep the building at a comfortable temperature for the workers. With this new information, I am sure the applicant will want to abandon the plan to heat the building in this manner. However, in the event that this is not the case, I would suggest delaying the application until a thorough study can be made of these heaters and their emissions. (Other Quick -lubes use this method, so it might not be too hard to get the necessary information.) Civen the terrible health consequences of lead poisoning, especially in children, perhaps the City should consider banning heaters that burn used motor oil. Do any other facilities in the City use them? But lacking such an ordinance, I would think the Planning Board, as part of its environmental review of proposed projects, could deny permission for any new facilities to do this. z'BURMNGUSED Environmental groups have blast - OII, CALL ed EPA's proposal to allow contin- MAJOR SOURCE ued burning of used motor oil, the OF LEAD IN AIR - largest source of lead in the na- tion's air. More than 85 percent of used oil that is recycled is burned as fuel in unregulated, boilers, according to the Natural Resources Defense Council and the Hazardous Waste Treatment Council. Already contaminated with high levels of lead and carcinogens, used oil is. often illegally mixed with other hazardous wastes before it is burned, mak- ing it an even more dangerous souice of air pollution. The watchdog groups are urging EPA to regulate used oil as a hazardous waste after it is picked up from community col- lection centers, a move that would stem uncontrolled bum - ing without discouraging recycling. IAAA 014 OFFICE OF CONSERVATION ADVISORY COUNCIL CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14850 December 17, 1991 Mayor Ben Nichols Members of Common Council City Hall Ithaca Dear Ben an Members of Council: With Roger Farrell's resignation in November from the CAC, the City lost its official representation on the County EMC. His resignation therefore was a double loss, for he served on both bodies with dedication and commitment. TELEPHONE: 272 -1713 CODE 607 However, bad news often is followed by good, and I am happy to report that at our December meeting the CAC chose Barbara Hotchkiss as its rep, to the EMC. The CAC's liaison is officially the City's rep. Bara has shown tremendous energy, enthusiasm, and good sense on the CAC, and will represent the City with dedication and commitment, as did Roger. The City is very fortunate in having people like Bara and Roger who are so willing to give of themselves on our behalf. Sincerely, Betsylarlington, CAC Chair Cc: Bara Hotchkiss CAC members An Equal Opp011unily Employer with an Affirmative Action Program'