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HomeMy WebLinkAboutEnvironmental & Misc InfoMemo to: Planning Dept. Building dept. DPW City Attorney Mayor's Office --� City Clerk From: Betsy Darlington, CAC Chair 7 Date: Jan. 21/94 1 Re: EAF Subcommittee through April 14, and dates of Subcommittee meetings Subcommittee to review environmental assessments, through Feb. 10: Betsy Darlington Dan Hoffman Paul Salon Feb. 11 through April 14: Betsy Darlington Dan Hoffman Rob Shapiro We'll meet on the following dates (subject to change) at 7:30 PM, usually in 3rd floor conference room: Feb. 10 Mar. 10 Apr. 14 May 12 June 16 July 14 Aug. 11 Sept. 15 Oct. 13 Nov. 10 Dec. 15 • These fall on Thursdays. • The dates are timed to be in the week prior to the Planning Board Codes Committee's Tuesday meetings (3rd Tue. of each Month). • All EAF's should be in our hands -- mailed to each person on the subcommittee - -at least one week prior to each or our meetings, unless they are for simple matters such as minor lot line adjustments. • Large, complex projects are usually reviewed by the entire CAC as well. CAC meets the 2nd Monday of the month. Memo to: John Friedeborn, Beth Mulholland, City Atty. Chuck Guttman Cc: 6 -Mile Creek Committee CAC Board of Public Works From: Betsy Darlington, Conservation Advisory Council Chair Re: Comments on rehab. of Therm spill site At our Dec. 13th meeting, the CAC discussed Therm's restoration plan for a portion of the watercourse, and rehabilitation of the entire area that was damaged during the spill clean-up. It was decided that CAC member, Paul Salon, should visit the site with me and evaluate the Therm proposal as well as what might be needed in the larger damaged area. Paul's report is attached. He works for Soil Conservation Service in Big Flats, but wants it to be clear that he is making his recommendations as a CAC member, not an SCS employee; Tompkins County has an SCS employee who could be brought in to advise Therm and the City. The CAC agreed that next spring, the entire damaged area should be rehabilitated to as naturalistic and aesthetic a condition as possible. While erosion is one problem that must be dealt with, and some engineering measures are needed for this, the problems left by the spill clean -up demand more than an engineer's expertise. Someone with that additional knowledge should oversee the work. The community was assured last spring that the area would be returned to the natural beauty that existed there before the clean -up. By making this area once again a lovely place for people to walk, Therm can do much to restore its image in the community, and we are confident that Therm will seize this opportunity. Therm's plan addresses erosion control measures in a small section of the problem area, while Paul's looks at the whole area below the bike path. But, like Therm's plan, the measures Paul recommends address erosion problems only, not rehab. of the entire damaged area. His suggestions should be inexpensive but effective. For aesthetic reasons, only native stone should be used for any work, and plenty is available on -site. He also felt that much of the work could (and should) be done by hand, thus avoiding further damage from heavy equipment. After he had written up his suggestions, I asked him about John F.'s idea of using straw bales to divert the water from the roadway into the woods. He said this should work fine, temporarily, as long as it is still possible to stake them into place properly. Next spring, berms or diversion channels should be made. Straw rather than hay should be used because of the large number of invasive alien species that could be introduced in hay. If there are any questions about where each measure would be taken, I would be happy to meet at the site and show you what Paul showed me. Because of his long commute to work, he is only available on weekends. We hope these recommendations are helpful. ww CAC wtL LLuwi PQ4QSa�o� ( i.l,'f�erwi S) The^vi -;t r`co�1r _ r'e�tnr=,tion p1 .-�clr`�sse that portion c >f the pr`Oblem well , It would be good if some handwork was e done as. ,00n as possible to ma -I ntai n the center, 1 i ne of the stream ov r the existing -teep stone lined section. The silt should be raked out of the center, of the stream and ;stone 1.?i d to maintain the center`l i ne . This may prevent the possi bi 1 i ty Of the stream channeling its way ar`Ound the tx i sti ng stone lined cent:='r` du i rg spr-ing runoff. We agree with th,-; idea of using the exi .,sting stone and if more is n cled kr-s,i ng stone wi ch i similar to maintain the rr=:tur•alistic condition, as was m?ntioned in the plan. Any e:r`oSi on c:ontr•ol fabr`i c used should be made of bi odegr•adabl e mater`i al , We would recommend straw i n pr'efer'ence to hay clue to tt-er`e L)ei ng less weed _. _.eels i in the straw. seed mi xtur•es c,sed for er`osi on control ar'ir_l w. +ter,ways Based an soil drainage classes ar•e available from the soi "l conservation service. Two other, areas concern t',"e conser•vati on advi spry wommi ttee : the roadway leading down to the stream and the er'odi ng water`way flowing fr`om the cUl v6'r•t. In an effort to minirwize additional di stur•barce to the sit, by cutting and filling we recommend the carEful placement of additional f i l l be used to di ver•t water, +nd to stabilize the site. i-he road and road ditch has :started to erode. one or, two berms across the road, could di ver`t- water` off the road to be spread out in the woods. i he ver•ti cal cut bank on the lower` por•ti on of the e•oad d i t c : h w i l l need soil mater•i ,al to create a 2:1 slope to allow -tor, a seeding to stabilize the slope . As a r•esul t: the center` i i ne of the r•oad ditch would be moved toward the road. ::.orne t`> vegetation adjacent to the bi G< t, ;ail Wcul d be appr•opr•i.ate; due to the st"oneyne ss Of tf"�e sit some topsoil may be needed. '11,1e waterway leading down from the cul ver•t is eroding. it appear-s that the channel has sp l it and some of the water, is bypassing the ' er•osi on cor tr•ol str'uctur'e'. This could be f i xed vrith ,a little hand work, Ther`e will be er•osi on over-` tfr"i s winter, and spring with 5,,di ment being deposited in the str`e„rn. 1 "he remed i •ati on of this situation should consider, l I e°a ti vs 1 which mnuc hav a minimal di stur•bance to the si to . At a point about 1 r,o ft: fr•orrr where the water•aiay pt...eswril:l y enters the stream, z ;mall amount of fill could f:)e br`ought in to di ver`t the vr:� :ter,way along the: contour, to meet ti)e existing, .stream at ,a point upstream . This would a�;oi d ;ome er`osi on and al 1 o: +•1 ! or some sediment tosettle cot beror.•e r•eachi ng the str•earn Dins to the continual low flow of the water` flowing fr•cn, the cul ver`t. it will riot be possi b l e to establ i sf-) veyetat on in the center, of the ��ater­�1y. To handle this flow, a tile lin with a low flow str'uctur'e could be designed or rock lining the center, Of the water,way will be needed. :,t this late elate nothing major, cart be clone; deter,mi ni ng the dr`ai nage area above this site —� as we l as o ser'•vi ng the condition Of the site in the spr•i ng wi l 1 give us an idea as 'to further` action. / � ��`fk EjULQti((LL tr�lo�s4 TE' Gfl�'L OFFICE OF CONSERVATION ADVISORY COUNCIL CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK '14850 Date: January 30, 1994 To: Regulatory Affairs Division, DEC ATTN: Charles Lockrow, Jeff Sama From: CAC's: City of Ithaca, Village of Trumansburg CB: Town of Ithaca EMC: Tompkins County Subject: Proposed changes to NYCRR Part 617 (SEQR) Date: Jan. 30, 1994 TELEPHONE: 272 -1713 CODE 607 Each of the municipal advisory boards listed above has considered and approved the following comments on the DEC's proposed SEQR changes (as set forth in a February 16, 1993 survey handed out at the Association of Towns meeting). Note: although our comments were prepared in June of 1993, they were set aside due to a series of local distractions -- until now. We trust they will still be useful. Please advise us of the status of your revision process. We would appreciate seeing the results of the Assoc. of Towns survey. When will CAC's, CAB's, and EMC's be similarly surveyed? Thank you for your attention to these matters. was Betsy Darlington, Chair, City of Ithaca CAC (on behalf of the above boards) EMC Chair: Herb Engman, HDFS, G36 MVR, Cornell University, Ithaca, NY 14853 Village of Trumansburg CAC Chair: Barbara Page, 41 Prospect St., Trumansburg, NY 14886 Town of Ithaca CB Chair: Candace Cornell, 1456 Hanshaw Rd., Ithaca, NY 14850 "An Equal Opportunity Employer with an Affirmative Action Program" N Our comments are in two parts: first, general comments reflecting our pooled concerns about and local experience with SEQR; second, specific comments on the DEC's proposed changes, as set forth in the Feb. '93 survey. GENERAL COMMENTS: 1. SEQR needs more teeth; it is widely abused or ignored -- or simply treated as a hurdle to get over. It is not widely used as the planning tool it was intended to be. 2. The DEC should have "enforcement power" in any municipality that has not established procedures for environmental reviews -- i.e., DEC should periodically make sure that municipalities are using SEQR. 3. More training in SEQR is needed in many municipalities. At the very least, the SEQR Hand- book should be sent automatically to the chairs of planning boards and departments, town supervisors and City and Village mayors, superintendents of public works and highways, and others responsible for overseeing environmental review and /or creating the need for same. 4. The law should be changed to require, in addition to the lead agency, a designated body in each community to review EAF's and make recommendations to the lead agency. CAC's, CB's, and EMC's are well suited to doing this, and function in this way in Tompkins County. 5. In cases of SEQR abuse, a citizen's only recourse for redress is to bring an Article 78 proceeding. Such an action is expensive, and out of reach of most members of the public. Has the DEC brainstormed any other mechanisms to recommend? In addition, if a citizen challenges a municipality in court and wins, attorney fees and costs should be paid. More training of local judges in environmental law is very much needed. At present, anyone bringing an Article 78 proceeding has to be prepared to lose locally and win only on appeal. 6. Ministerial acts can provide huge loopholes in many municipalities. We therefore recommend changing Part 617 to state that any action that meets or exceeds a local Type I threshold may not be treated as a ministerial act. In addition, municipalities must be free to remove things from the Type II list. 7. As currently interpreted by the DEC, SEQR is only triggered when a governmental action -- such as granting a permit -- is required. Thus, steep, forested hillsides can be stripped of all vegetation with no environmental review, if no permit is required. Developers -- and others -- can thus inflict significant harm on the environment. SEQR should be revised to apply to all actions with potential for environmental damage, not just those for which a permit has been applied. For example, any activity that meets a Type I threshold should be subject to SEQR, whether or not a permit is involved. 8. DEC's EAF forms should be revised. For example, the applicant's intentions should be addressed: e.g. why does he or she want to subdivide the land? We would rank this revision "A" -- high priority. 9. Thresholds in the Type I list should be lowered according to some formula based on the size of the community. The state thresholds are appropriate only for the largest cities. While municipali- ties are free to establish their own thresholds, many are reluctant to enact their own EQR ordinance. Many towns don't even have zoning, and it is unrealistic to expect them to enact EQR ordinances. 3 10. Actions in any wetlands, not just DEC - designated ones, should be Type I actions -- or the DEC should change its statewide threshold to, e.g., '/s -acre. SPECIFIC RECOMMENDATIONS ON THE DEUS PROPOSED CHANGES: (A = high priority, B = somewhat high priority; C = low priority) 1. Expand Type II list: We believe the list should be left as is, with one exception (given below). However, we would find it acceptable to expand the Type II list IF - -and only if - -the Type I list is expanded at the same time -- for example, to include actions on steep slopes and near wetlands and other waterways (according to some formula). Add to the Type II list: Adoption of a moratorium on construction by the local legislative body": A Municipalities must be free to remove items from the Type II list. A We would not oppose including in the Type II list: Individual area variances and construction or expansion of a single or two family dwelling, PROVIDED these actions would not be in environ- mentally sensitive areas, as defined in an expanded Type I list (or elsewhere in Part 617): C Docks and floating docks: ok on Type II list except in public waters. Catwalks ok provided they aren't in an environmentally sensitive area. Signs up to 5' x 3' ok on Type II list. Other appur- tenances listed -- decks, solar collectors, satellite dishes, cabanas, tennis courts, storage sheds- - acceptable to add to the Type II list provided another's solar access would not be blocked. C We are opposed to adding to the Type II list: office, school or commercial structure under 4000 s.f. in footprint; subdivision into 4 or fewer lots; adoption of capital budgets and agency requests for appropriations; remedial actions conducted according to a plan approved by an administrative agency; interpretation of an existing code, rule or regulation. 2. Reorganize EIS format: B Yes, but differently from DEC's proposal. In the proposed reorganized format, we recommend organizing the "impacts" section in three parts, as follows: a. Group together: "unavoidable adverse impacts," and "irreversible and irretrievable commitments of resources;" b. Treat separately: "growth inducing aspects of the proposed action;" C. Group together: "effects on the use and conservation of energy," "impacts on coastal resources," "effects on solid waste management," "effects on special groundwater protection areas." (Of course, only those applicable to the action would be included in an EIS.) 3. Require scoping for all EIS's and make it binding: NO! We are strongly opposed to this proposal. It would significantly weaken SEQR by preventing new information from being considered in the DEIS, as presented at the public hearing on the DEIS. There is no way to ensure that the public is fully informed at that early, scoping stage in the process, and no way to know that new information will not arise later. Therefore, this proposal is unacceptable. Also, see second paragraph under #4, below. 4. Restrict EIS's to only significant impacts: NO! We are strongly opposed. By briefly discussing in the EIS various impacts laid out in the scoping session, but which were found not to be significant after all, the public has the assurance that these items were considered. If, during scoping it is clear that certain impacts are not applicable, they are not included in the EIS to begin with. For example, if a proposed office complex would take place on a block devoid of migratory birds, the � yM bl W DEIS would not discuss that potential impact. But if migratory birds were a concern and the DEIS had to consider this possible impact, the public should know that it has been looked at, even if the conclusion was that there would be no significant impact. In addition, mitigations for one impact may lead to significant impacts themselves. E.g. if a highway were moved to avoid a wetland, the new location might be in an area with an endangered species or an old growth forest. The EIS should discuss such potential impacts of the proposed mitigations. 5. Streamline notice procedures: B The ENB is fine for this, as is, but we would like to see additional notice in local papers and on the radio, in the form of public service announcements. The general public is unaware of the existence of the ENB. What exactly is the DEC proposing by way of "streamlining ?" 6. Eliminate Critical Environmental Areas: NO! We are strongly opposed to this, and to the proposal that a generic EIS be prepared for CEA's. Why prepare an EIS for something that provides a small measure of protection for the environment? Also, a generic EIS does not make sense since a CEA is for a specific area. If there is a perceived problem with CEA's, requiring a statement justifying the CEA would be reasonable, however. Communities should have the ability to designate CEA's wherever they see fit. All a CEA does is trigger environmental review; it doesn't stop development. Permission was given for a subdivision in the only CEA we know of in Tompkins County, but the environmental review for the project was important for protecting at least some of the features for which the area was designated as a CEA. Re the final sentence of this section: What was the original goal, and how are communities diverging from this? We would appreciate a reply to this query. 7. Eliminate Unlisted category: NO! The Unlisted category provides flexibility to developers, agencies, and others. To require a full EAF for all projects would be needlessly time - consuming and a waste of paper; a short EAF is sufficient for numerous projects. If a question on this is answered "yes," then the full EAF must be filled out; a mechanism is in place for proper review of Unlisted actions. Essentially, if the Unlisted category were eliminated, there would have to be just a Type II list. Anything not on the Type II list would have to have a full EAF prepared for it. This seems excessive. If there is confusion regarding the three categories (Type I, II and Unlisted), this could be solved by better training and by changing the names of the categories. If each category had a name that was self - explanatory, much of the current confusion could be eliminated. 8. Cumulative impacts: A We feel that better definition and explanation of "cumulative impacts" is badly needed, and that the EAF forms should include questions that address cumulative impacts. We hope the DEC solves the problem soon. 9. Adjust SEQR fees: B We feel that if changes are made it should be to make them tougher. Rather than being excessive, our sense is that the fees often do not reflect a municipality's actual costs. What, if any, is the factual basis for suggesting downward revision? We would appreciate a reply to this query. Dear Ben and Members of the Planning Board: May 15, 1994 I have heard, directly or indirectly, that some of you were surprised by the CAC EAF Committee's recommenda- tion of a neg. dec. for the Fane project in Collegetown, and in particular, in contrast to our pos. dec. recommendation on the Weisburd project. I wanted to give you my own thinking on the project. I am not speaking for the other member who voted with me on this. I might mention that there are some aspects of the project, esp. re parking, which we did not understand at the time we reviewed the EAF. First, let me make clear that this is not a project for which I have any fondness, it being essentially in my own back yard. I don't like the fact that it will block out what little is left of the views of distant hills as I walk down Dryden Rd. I still mourn the loss of the view of most of West Hill, now blocked by Collegetown Plaza. I don't like the fact that it would come right up to the sidewalk nor that no trees are in the site plan. If, added to these, the building is dark in color, the effect will be even more deadly. These are matters which we hope the Planning Board will remedy. I also would not like to see the removal of three attractive old houses, esp. the one on Dryden Rd. with the big front porch. Here are the positive aspects of the project, however: It would put students in housing very close to their destination point, thus reducing their need for a car. This, in turn, could reduce traffic congestion in the City. It should relieve pressure on housing in the downtown area, thus lowering rents there and making it more affordable for non - students. The project would thereby help reduce sprawl. The students who would live there are probably already spending large amounts of time in Collegetown, so the sheer numbers of bodies in that neighborhood may not increase significantly. It is already a densely populated area, and adding 150 more people probably would not have a large impact. The area in question is already developed. In fact, there are very few trees on the site, most of which is paved or built on. Most of these are arguments that the City made on behalf of earlier high- density projects in the same neighborhood, and in particular the Eddygate project. I do wonder, if Fane's project were billed as "affordable," if the opinions of some would be different. Deciding on a recommendation for the project was difficult. Did the minuses outweigh the pluses, esp. in view of the Planning Board's ability to mitigate some of the more serious minuses? In contrast to Fane's project, let's look at the West Inlet project: This would add approximately 90 people (figuring on about three per unit) to a small neighborhood. Traffic on Floral Ave. - -a narrow street with no shoulders - -is already something of a problem, with many people using it to avoid rte. 13. The cars of 32 more families will make a bad situation worse. There aren't even sidewalks along the street. Water pressure in the new homes and those of Glenside residents could be a problem. (The Board has not addressed this, as yet.) There is no neighborhood park for kids to play in. Far from helping reduce sprawl, the project is an example of sprawl, albeit within the City limits. Services for this many additional people are inadequate, and at some point, taxpayers or residents will have to pay to upgrade them. There are serious drainage problems associated with the project, stemming from the erodible soils and removal of vegetation from this steep site. The project would destroy a steep, forested site harboring several locally scarce species. It amazes me that at least one of you apparently feels this concern is frivolous. (The project already has damaged the site significantly, but left alone, it would recover.) The City's support for the Weisburd project has been premised on the "promise" of affordability. However, because of the constraints imposed by the site, this is highly unlikely to be possible, at least in the long term for the residents living there. In any event, the Weisburds have made clear that the current application is not an affordable housing project. That having been the only justification I have heard for destroying the hillside, I marvel at the continued advocacy for it. I would be happy to discuss this further with any of you. Sincerely, Si `��s`� Betsy Dat'lington r Memo to: Planning Board and Dept Jerry Weisburd (Housecraft Builders) Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Darlington, Salon, Hoffman) Re: EAF for West Inlet 2 - -a revised plan for development of 5-acre site on Floral Ave. Date: Feb. 11, 1994 Recommendation: Positive declaration unless: a) units are reduced in number so that less of the site will be covered with impervious surfaces; b) units are moved off the steeper slopes; c) measures are taken- -both during construction and thereafter - -to permanently protect the remaining undeveloped portions of the site; and d) measures are taken to permanently protect the red mulberry tree and those hackberries that are not in the path of the development. Comments: This appears to be a considerable improvement over the proposal two years ago. We would have liked to have had the overlay that's being prepared, showing the old plan, but the new one appears to spare more of the open space. We like the plan for common ownership of the open spaces and for double and quadruple houses. In the drawings, trees are shown that are not supposed to be removed, yet which are in the construction zone, and which, in any case, it is hard to imagine could be saved, given the proximity of construction activities. No mention is made of replacing these. Although the plan is improved, we feel that this steep site is not appropriate for such a high density of development. The fact that the zoning permits even more does not change this. We see no mention in the documents of the red mulberry tree, a rare species in these parts and a tree which the earlier plan protected. What will be done this time? What will be done to protect the hackberries, both during and after construction? The soils on the site are, for the most part, highly erodible, and considerable erosion of the new roadway occurred last year during various rainstorms. There was a plume of silt in the Inlet, and fresh silt deposits on vegetation in the channel through Wm. Lower's property. The seeding that was done, however, has taken well. Great diligence, and oversight by the Building Dept., will be needed to ensure that further significant erosion does not take place during construction. Recommendations: We recommend that no more units occupy the site than were in the earlier plan (27). (This may still be too many for the site, but may be a reasonable compromise.) The less site coverage there is, the less impact there will be on the steep slopes, the less destruction of vegetation and erosion and compaction of the site. �e� As much as possible of the area that has been or will be seeded, should be left unmown so that trees can regenerate there. Transplanting some young seedlings from sites to be bulldozed to sites that are being seeded would help in this. The more trees there are on the site, the less will be the harm (of various sorts). One of the functions served by woodlands is to control water flow from a site. Water can percolate through the soil and into the groundwater. From there, it is slowly released into waterways. The fewer trees on a site, and the greater the amount of impervious surface, the more water that flows off the surface. The result is greater extremes in nearby water bodies: greater highs during floods, and greater lows during droughts. It is essential that construction fencing be required (and maintained) to keep construction vehicles from damaging remaining trees. This should be placed out at least as far as the dripline of the trees. Soil should not be deposited over tree roots to a depth greater than 2 inches. Permanent protection measures should be provided for the communal open spaces, and in particular, for the trees. A conservation easement to the City of Ithaca would be one option. Measures should be taken in the drainage system to reduce the speed with which runoff leaves the site, and to remove silt. The earlier plan, we seem to recall, had such a design. In the drawings of the sanitary and storm sewer systems, these appear to be very close together in a few places. Will there be enough separation to prevent crossovers during big storms? Specific comments on the EAF, Part II: #1 Removal of veg. and topsoil from more than 1/2 acre: Check in column 2 (since threshold is met or exceeded), and in col. 3. Can be mitigated by reducing the number of units. (11 /2 acres have already been stripped and another 1 acre is slated to be.) #5 Impact on Cayuga Inlet: col. 2 and 3. Can be mitigated by enforcement of good construction methods. #6 Likely to cause siltation...: col. 2 and 3. Same as last mitigation. #7 Drainage: col. 3. Same as last mitigation. Also, the more trees, the less the harm. #10 Impact on species: both examples - -col. 2 and 3. (Impact on hackberries and two associated butterfly species, and on red mulberry.) Mitigate by reducing # of units, using careful construction methods, and leaving seeded areas unmown. #11 Effect on views: Col. 2 and 3. Mitigate by giving the trees permanent protection. #18 Effect on char. of commun.-- precedent: we disagree that this is a positive impact. It sets a precedent for intensive development on steep, erodible, forested slopes, and damage to locally rare species. Col. 2 and 3. Mitigations, as above. Memo +to: Planning Board and Dept. Weitsman & Son Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Salon, Hoffman, Darlington) Re: EAF for Weitsman & Son -Steel Warehouse along Cayuga Inlet Flood Control Channel Date: Feb. 11, 1994 Recommendation: Positive declaration, unless measures are taken to improve the appearance of the facility and to improve drainage, and unless certain questions are answered satisfactorily. We would like to receive a response to these issues, and an amended EAF: MITIGATING MEASURES: 1. Especially within view of the adjacent greenway and the Inlet, far more landscaping is needed, including large tree species adapted to the site conditions. The City must ensure that new projects enhance rather than detract. Many people row, canoe, fish, and walk nearby. A large metal wall facing them would be a considerable loss. Regardless of whether or not a bikeway is built, and which side it's built on, the warehouse must have attractive landscaping -- landscaping that will hide the building as much as possible. It is anticipated that public money will be spent on the bikeway project; such a commitment should not be undercut by nearby projects on either side of the Inlet. It should be noted that not even the tiny amount of landscaping shown near the greenway is promised by the applicant. 2. We also would like to see the building reoriented so the long, boring, blank wall will not face the Inlet. Could it face roughly to the south, e.g.? 3. Measures are needed to prevent runoff from forming gullies across the site, and, especially, across the land between the site and the Inlet. The Site Plan shows two main drainage paths. These paths need to be protected with vegetation, and in addition, designed so the water will spread out over a large area and thus be better able to percolate into the soil. It should be noted that runoff at similar sites, such as Wegman's, has cut rather large channels on its way to the Flood Relief Channel. 4. Unvegetated areas should be limited, and certainly should not extend past the building. QUESTIONS: I. Will there be outside storage? If so, where? How will it be screened from view? 2. What chemicals will be used in their operations and how will these be stored? Will there be any bulk storage of petroleum or chemicals? What measures will be taken to contain any leaks or spills? What kind of industrial gases are to be used /sold? Are these explosive? 3. Is the company committed to maintaining a porous surface? 4. Will pesticides be used to control weeds? If so, which ones? Specific comments on Part II of the EAF: (Any thresholds that are met or exceeded must be checked in Col. 2 and addressed in Part I1I.) #1: Water table - -check in Col. 2 "Other ": add, "Located in the 100 -year flood plain." Col. 2. #5: Impact on waterways -- Cayuga Inlet - -col. 2 and 3: can be mitigated by landscaping, improving the drainage, and preventing chemical spills from reaching the water. #7: Drainage: Increased runoff - -col. 2 and 3: can be mitigated by reducing the developed area, increasing the vegetation, and dispersing the flows. r rcor�er.�c�o, #11 & 13: Views: Col. 2 and 3: can be mitigated with landscaping (Views from the Inlet, the greenway on both sides, and Floral Ave.) #16: Noise: Will loud noises be contained in the building? Noise from this area carries all -to -well up the slopes of West Hill and into people's homes. #17: Pesticides: Will they be used on the site? #18: Precedent: Col. 2 and 3: City must ensure the attractiveness of this important greenway corridor. Permitting the project to go forward as proposed would set a poor precedent. I. Memo to: Planning Board and Dept. Robert Colbert, Garage deFrance Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Salon, Darlington, Hoffman) Re: Garage DeFrance: subdivision to create another lot behind existing one Date: Feb. 11, 1994 Recommendation: Negative declaration II. Memo to: BZA and Building Dept. Planning Board and Dept. Florence McCarthy Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Hoffman, Darlington, Salon) Re: EAF for use variance for 109 -111 Delaware Ave. Date: Feb. 11, 1994 Recommendation: Positive declaration. Granting this use variance would set a precedent which could do significant and irreparable harm to the character of neighborhoods throughout the City. Delaware Ave. has seen many conversions from single - family homes to student rooming houses. It is important to the long -term stability of the neighborhood to keep it a place where families want to live. Student housing with absentee landowners all- too -often becomes noisy, rundown, and littered with trash. Sidewalks are rarely, if ever, shovelled. The presence of the landlord on the site makes a huge difference. Comments: The CAC normally reviews entire EAF's, not just Part I. Items in Part II that we feel should be answered "yes" and marked in Column 2 (potential large impact) include the impact on neighborhood character ( #11 and #18), as noted above, noise ( #16), and likely public controversy (# 19) . We feel that a draft environmental impact statement would not make sense, in this case, should the applicant wish to pursue it further, but don't know if it is possible to issue a positive declaration without a DEIS being the next step. ANNUAL REPORT CONSERVATION ADVISORY COUNCIL, CITY OF ITHACA March 15, 1993 to March 30, 1994 Members: Betsy Darlington (Chair), Cathy Emilian, Bara Hotchkiss, Judy Jones, Peter McDonald (as of April, 1992), Paul Salon, Rob Shapiro, Keith Waldron, John Wertis, through most of 1993. Thereafter: Darlington, Jones, Salon, Shapiro, McDonald, Bart Guetti, Dan Hoffman Liaisons: from Common Council - -Dan Hoffman, then Rick Gray; from BPW - -Guy Gerard, then Jill Tripp; from Planning Board -- vacant (Darlington serves this purpose instead); to County Environmental Management Council -- Hotchkiss, then McDonald; to Solid Waste Advisory Council -- Jones; to Shade Tree Advisory Council -- Emilian, then vacant; to Parks Commission - -vacant (from P.C. - -Lani Peck, after Jan 1.); to Six -Mile Creek Committee- - informal, then Hoffman; Metropolitan Planning Organization -- Darlington and /or Gerard (informally), then Darlington (informally); Parking Garage -- Darlington 0 Reviewed and made recommendations on about 27 EAF's and the Treman Marina DEIS. • Our most time- consuming projects of the year were: Dealing with the Therm spill; The environmental review for the Weisburds' West Inlet II proposal on Floral Ave. (ongoing); The Wal -Mart proposal (ongoing); The SW Area Land Use Plan; Considering proposed changes in SEQRA; James Bay (Hydro Quebec) project • We are just beginning consideration of a recommendation to the City that it use chlorine -free paper. • Awarded our sort-of- biannual Commendation to Doria Higgins for her work on behalf of City Parks. - -Betsy Darlington WEISBURD - -WEST INLET II -- SUPPLEMENTARY COMMENTS Memo to: Planning Board Cc: Jerry Weisburd CAC From: CAC's EAF subcommittee (Darlington, Salon, Hoffman) Date: April 10, 1994 [Note: The enclosed topo map was provided by the Weisburds in 1992. The 1994 plan, with sample slopes, has been traced onto this. We used the original 1994 plan, not the new one, presented on March 22, with more parking lots sketched on.] In order to issue a negative declaration, the Planning Board has to agree on two things: First, that the information it has been given is accurate and complete, and second, that the proposed mitigating measures are sufficient to prevent (or reduce to an acceptable level) all of the potentially large impacts. Our review is based on the current site condition, not that of two years ago, and assumes that changes to date were made legally and properly. A review based on predevelopment conditions would indicate greater impacts. If even one significant impact cannot be adequately mitigated, and if that impact is deemed to be important, then the Planning Board must issue a positive declaration. We would argue that, as proposed, the project would have several significant and important impacts, that you do not have before you complete and accurate information, and that the proposed mitigating measures are not sufficient to prevent these impacts. By moving some units and eliminating others, the number of units could easily be reduced to a maximum of 20. The size of parking lots would then be reduced as well, and they could be removed from the steepest slopes. One of our greatest concerns has to do with the extensive cutting - and - filling that the proposed lots would entail, along with the associated distribution of excess fill. Note: Units 5 -8 are directly on one of the zones shown in 1992 as being unbuildable! (Dwg. 4 -R) (Purple or green highlighter on the enclosed map.) I. THE MATERIALS YOU HAVE BEEN GIVEN ARE INACCURATE, MISLEADING, AND INCOMPLETE: A. RECENT PLAN CHANGES: What plan is the Plannig Board acting on? • The Board was presented with drawings on March 22, showing new parking lots. Are these now part of the plan? Also, the proposed covenants for the homeowners' assoc. (if there is one) say more parking lots can be built -- negating some of the mitigating measures you are considering. Are you agreeing to this? (We realize that the increase in parking was not the developer's desire, but the Board's. The same goal could be accomplished by reducing,the number of units.) B. LEAF IS INACCURATE, INCOMPLETE, AND MISLEADING: E.g.: • Map 8 does not show the limit of land disturbance accurately: the road grading would extend considerably farther to the south (nearly to bottom of gully), and grading for the upper cul de sac would extend to fill the space between units 28 -32 and the paved areas below. In addition, road grading that has already taken place near the bottom appears to extend further up the slope than is shown on Map 8, and farther than is shown on the grading plan (map 10). Also, how much more grading will be needed on the steep hillside above Floral Ave. for the roadway? • On Map 8, no "limit of land disturbance" line is shown below units 15 -18. • The grading plan (map 10) only shows grading for the road. Grading for the parking lots and houses is not shown, nor is there any indication of where excess soil would go. • LEAF, part 3, March 15/94 states that the structures will be located "where slopes are relatively gentle. " Relative to what? About 18 -20 units are on slopes exceeding 15 %. We have never heard anyone claim that this is a gentle slope. • Same para. says that any significant removal of veg. has already occurred, yet when we walked the site recently, many mature and young trees of a variety of species remained in areas where structures, parking lots, and grading are proposed. • Same para. says incorrectly that further cut and fill will be minor. • As you can see on the enclosed map, certain parking lots (or portions of them) are on steep slopes. To give the lots a 4% slope, there will have to be a great.deal more cutting and filling, and associated loss of trees, 2 contrary to LEAF, para. 1 of part 3. On the drawing presented March 22, showing the original and new grades of a section of parking lot, the example selected for illustration is in the one area of the site that has a gentle grade. An illustration is needed for a lot that's on a 20% slope, or the portion of the one that's on 28.5% slope. If one of the problems is inadequate parking (a concern of at least one member of the Planning Board), and one of the project's mitigating measures is limiting the amount of impervious surface, shouldn't the mitigation be reducing the need for parking by eliminating some of the dwelling units, not adding more parking lots or permitting more to be added later? A map showing the grading plan for the parking and structures is badly needed. (Must the lots have a slope of 4% or less, or could they conform better to the existing slopes ?) • The topo lines are drawn differently from the topo map provided two years ago. For example, the latter puts the parking lot that is farthest back on the site right in the middle of the more southern gully. The new map ( 0) shows this parking lot as being in one side of the gully. Has the gully been moved or is one of the maps (maybe both) inaccurate? • Building a parking lot and the upper cul de sac in one of the gullies conflicts with the stated goal of protecting the gullies. • The drainage calculations were made assuming 2 acres of impervious surfaces. Did this take into account loss of vegetation from much of the site? It appears from map #8 (grading, drainage and layout) that about 31/4 -4 acres are within the area shown as "limit of land disturbance." • How much more frequently will there be high water events contributing to erosion in the gully /stream below Floral Ave., after completion? • What trees, realistically, will remain? You do not have an accurate map of this. • Information is lacking on potential effects on the remaining trees from the radical alterations in drainage and from root disturbance, compaction, and other construction damage. Will excess soil from cutting -and- filling be spread over other parts of the site? This would further damage the root systems of remaining trees. • What measures will be taken to protect trees during construction? • What measures will be taken to protect the hackberries and red mulberry? While many of the former are in the gullies, only the bottom of the gullies would be protected. Note that roughly the upper third of the southerly gully would be obliterated. • How can there be a 10 -foot buffer next to parking lots that come virtually to the property line? H. SIGNIFICANT AND IMPORTANT IMPACTS A. IMPACT ON LAND FROM LOSS OF TREE COVER AND PERMEABLE SURFACES, ON STEEP SLOPES: Significantly more water flow, and more high -water events, in the already overloaded off -site stream /gully, and associated erosion of gully; Loss of groundwater recharge (interrelated with last two problems); Erosion; Siltation of off -site stream and Cayuga Inlet; Aesthetic degradation Discussion: • Trees hold the soil, draw moisture from the soil, and reduce the force with which rain hits the ground. The sparser the trees, the more runoff, erosion, siltation, and high water events downstream, and the more degraded the appearance of the site. The steeper the slope, the worse the problems - -esp. on a site such as this with highly erodible soils. In addition to the County Soil Survey, two years ago we were told by Empire Soils that their results showed soils that are highly erodible. Also read Gary Lamont's (Soil Conservation Service) letter of two years ago, attached. • It appears, after making careful comparisons, that some aspects of this plan may be even more destructive than the one proposed two years ago. Although helpful, the proposed mitigations are insufficient. E.g. even if a house is "built to fit the site" and has minimal cutting into the hillside, it still replaces trees with impermeable surfaces - -esp. problematic on this steep, erodible site. The obliteration of the upper portion (1/3 ?) of the southerly gully should also be of concern to the Board. And if parking lots must be graded to 4 % or gentler slopes, large areas will be damaged. • In terms of the appearance of the site, especially serious will be the loss of most of the pine grove just above Floral Ave., protection of which was a major concern of the Planning Board two years ago. Many were cut for the road, and units 4 -8 will take out much of the rest. Moreover, engineering methods for preventing erosion from cuts 3 made in steep slopes can be unsightly (e.g. Towerview's gabion retaining walls). You need to know, prior to approval, what will be used so you can evaluate its aesthetic impact. Add to this the loss of much of the site's tree cover, and the City will be left with an eyesore. Over time, still more trees will be lost due to construction damage. B. LOSS OF OPEN SPACE: 0 If there is a homeowners' association: Is it true that these typically last only about 20 -25 years? If so, what happens to the protected areas after that? • If there isn't a homeowners' assoc.: How can the mere offering of land to the City be a mitigating measure? Isn't the mitigation the land's acceptance by the City? What if the City doesn't accept it? Is it proposed that the City also own the 10 -foot buffer and the gullies? If not, what protection will there be? Why can't the open space simply be protected as a condition of the approval, and shown on the plat? This is common practice for subdivisions; surely other developers have been able to get financing. • Why are so many treed portions of the site not included in the protected areas? E.g.: below units 1- 8, 9, 14, 23 -26, 15 -22, and three sides of 27 -32. • Why is it proposed to protect only the bottom of the gullies? If the remaining open space is not provided with sufficient long -term protection, the problems in A, above, will be even worse. C. WATER SERVICE AT HOMES BEYOND THE SITE: At least in the Glenside neighborhood, water pressure is already a problem. More info is needed on this. D. IMPACT ON THE NEIGHBORHOOD OF THE ABOVE PROBLEMS III. ADDITIONAL COMMENTS: • Two years ago the CAC warned of the huge amount of cutting and filling that would be required for the road. If the Board had understood just how much, perhaps it would have made a different decision. (When will the serious erosion problems of the new bank be corrected ?) • The CAC also predicted, correctly, that blasting would be needed for the lower part of the roadway but was told this was very unlikely. • One of the members of the CAC EAF review committee for this project has over 15 years of experience in erosion control, drainage, and reclamation. Our comments incorporate his assessment of the potential problems on this site. • Engineering is not the exact science we expect it to be. Notice the Flood Control Channel's badly eroding banks and the collapsing bank along Burns Rd. • Economic feasibility for the developer is irrelevant to the environmental review and should have no bearing on your decision. But in any event, we learned at the March 22/94 meeting that reducing the # of units wouldn't affect economic feasibility afterall. • It certainly is desirable to prevent sprawl and promote more housing in the City. However, in choosing sites where this is feasible, consideration should be given to existing infrastructure and the characteristics of the site. The City still has space in which more housing could be built without having the major impact that this project would. • The Board needs to see alternate plans which would protect the steeper slopes, reduce runoff, and reduce loss of tree cover. • The fact that the current proposal incorporates some mitigating measures does not mean that these are sufficient to prevent significant and important impacts. The proposed mitigations must be combined with a reduction in coverage and tree loss on steep slopes. Memo to: BZA Applicants Cc: Planning Board Common Council and Mayor CAC members BPW, DPW City Attorney From: Conservation Advisory Council's EAF Subcommittee (Hoffman, Shapiro, Darlington) Re: Three use variances Date: April 14, 1994 1. 315 Thurston Ave. Recommendation: We are not sufficiently familiar with the situation to make a recommendation. Setting a precedent and the potential impact on the viability of the neighborhood for family residences are our major concerns. 2. 310 Fourth St. /604 Hancock/207 Fifth St. Recommendation: Again, we are not sufficiently familiar with the situation, and are not even clear exactly what is being proposed. 3. 314 -316 E. Seneca St. Recommendation: Negative declaration. The use was long - established- -and accepted -- before the fire, and provided much - needed housing. Calvin and Hobbes IF WE DOES, WE'RE DEAD! SHE'LL PRO6MLV STICK %I HEAD ON A STAKE 14,4C TM ALMOST FRONT YARD AS SVRE THAT A WARNING TD W U VIOLATE OVER KIDS 93ME ZONING SH SM -SWS! ORDINANCE. O 7 by Bill Watterson I. Memo to: Planning Board and Dept. Cornell (Blakeney and Uhlberg) Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Shapiro, Hoffman, Darlington) Re: Reconstruction of Central Ave. Date: April 14, 1994 Recommendation: Negative declaration Comment: Hurray! II. Memo to: Planning Board and Dept. Jason Fane Cc: (Same as above) From: Conservation Advisory Council's EAF Subcommittee (Hoffman, Shapiro, Darlington) Re: 151 Dryden Rd. - -site plan for 150-unit structure with retail on first floor Date: April 14, 1994 Recommendation: Negative declaration (vote was 2 -1) Comments: While concerns were raised regarding the very large increase in density on the site, it was also agreed, that the project could free up - -and lower prices for -- housing downtown, and could also reduce the number of students living out -of -town who must drive in each day. It puts the students near campus and should reduce their need (if not desire) for a car. Recommendations: 1. Trees are badly needed throughout the parking lots, for both aesthetic and climatic reasons (to help mitigate the heat sink phenomenon). What little vegetation is on the site now will be removed. Nina Bassuk might be asked for her soil mixture for use under paving: tree roots can penetrate it even when compacted. 2. One street tree is to remain in front of the bldg. but if this isn't damaged during construction, it very likely will be from continuous shading. Money for a replacement should be provided, and the species selected should be one that is shade tolerant. 3. Can the existing houses be recycled - -e.g. through INHS or Historic Ithaca? 4. Windows should be of the highest quality, from an energy conservation viewpoint, and the blinds, to be provided by the applicant, should be a type that conserves energy. This project would be ideal for use of solar power, anesuggest that the applicant include this. The City Energy Commission might be able to give advice. 5. We like the fact that windows can be opened. 5. Can the building be set back from the sidewalk? This street will be like a canyon. 6. Good construction technics should be used, such as controlling the soil so that it doesn't leave the site. (Silt barriers, stabilized exits from site, being sure tires of construction vehicles are clean before leaving the site, etc.) Memo to: John Schroeder and Planning Committee Rick Gray, CAC liaison from Common Council Cc: Other Common Council members and Mayor Date: April 14, 1994 From: CAC Chair, Betsy Darlington —s Re: Critical Environmental Areas in the City At our CAC meeting of April 11, we voted unanimously to recommend that Common Council designate certain special resource areas in the City as Critical Environmental Areas (CEA's). Any project requiring City approval (e.g. for a building permit) that would occur in a CEA automatically becomes a Type I action, meaning that it is subject to full environmental review under SEQRA. (That does not mean that an env. impact study must be done, but increases the likelihood of it.) Ithaca is unusual in NYS for not having any CEA's, and yet we have a wonderful tool for selecting places for designation - -the Tompkins County Unique Natural Area Inventory. The process is not difficult. Common Council names the areas it wishes to designate, states why, and prepares a map showing the location of each one. A public hearing is held, then CC votes, and if the vote is favorable, sends the information to the DEC. That's IT! I'm enclosing for John Schroeder and Rick Gray a copy of the UNA info for each piece, and a copy of SEQR's instructions for designating CEA's. • We hope this proposal can move ahead expeditiously, and we look forward to hearing from you. Please feel free to call me if you have any questions (273- 0707). Memo to: Planning Board and Dept. Jerry Weisburd Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Betsy Darlingtion, Re: Error in our April Date: April 27, 1994 Conservation Advisory Council Chair 10/94 memo This is for those of you who were not at the last Planning Board's Codes meeting. I discovered the night before that meeting that I had mixed up the parking lots, thinking the one Jerry had shown a section of was the one off the lower cul de sac, when in fact it was north of the roadway near the top of the site. Therefore, the statement at the top of Page 2 (first full sentence on the page) is incorrect and should be deleted. While this one, at about 16 % slope, is not the steepest parking lot on the site, it is certainly not the gentlest either. I apologize to you for the error. Memo to: Planning Board and Dept Alumni Services -- Carpenter Industrial Park Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Darlington, Jones, McDonald) Re: Offices for Stewart Howe Alumni Services, at Carpenter Ind. Park Date: May 10, 1994 Recommendation: Positive declaration unless the site landscaping and building design are altered so as to live up to the claims made in Part 3, #'s 11 and 18. Is this what we want to "set the standard of ensuing development in the rest of the site "? Or to form "the first impression on visitors entering the City from the north "? Not one tree or shrub is shown on the site plan, yet large numbers of trees and shrubs are badly needed if this is not to be just another rte. 13 eyesore. Integrating the design with Community Gardens is needed, as well as creating a project that will be pleasant to look at for travellers on rte. 13 or the bike trail. When the Carpenter Industrial Park was first being reviewed in 1989, we were assured that any project there would have to meet rigorous City design standards. The current proposal falls far short of what we were led to believe would be required of developers. As proposed, the project would set an unfortunate precedent. Comments: 1. Why is only Phase 1 addressed in the EAF? We believe this violates both the letter and the spirit of SEQR. While the precise architecture of Phase 2 may not be known at this time, and therefore might best be reviewed later, surely the amount of lot coverage and vegetation for the completed project could be addressed now. An EAF is supposed to deal with an entire project, not just one portion of it. What is the City Attorney's view on this? 2. Site location map should show railroad tracks and power lines. 3. EAF, Part 1: A -3: Figures given for type of cover after completion are inconsistent with B -3. What is "other" (16,958 s.f. of it)? A -16: Community Gardens should be listed here. B -2: Where will the 1010 c.y. of earth be removed to? Will this mainly be the fill now on the site? B -3: (Vegetation removal.) Inconsistent with A -3 and B -5. B -5: (Revegetation.) Should be answered "no" or "partially." The only revegetation proposed is a tiny amount of grass in a few narrow strips. 4. EAF, Part 2: #1: (Physical changes to site.) 8th example should be checked in col. 2 (removal of veg. from more than 'h acre). (See Part 1, A -3) #11: (Effect on views or visual character.) All three examples should be checked in col. 2. #16: (Noise, etc.) 3rd example, col. 1 (to be consistent with Part 1 #19- -page 5). (During construction.) #18: (Effect on character of community.) 5th example- -set a precedent: col. 2. (A most unfortunate one.) 5. EAF, Part 3: #1: (Impact on land.) Replacing grass - covered soil with impervious material will certainly (and significantly) change the "ground's ability to absorb water." Mud - tracking not only could, but must, be prevented. Stabilizing the exits from the site with gravel, and other construction measures should be required. Also- -what will be done to prevent parking lot effluents from entering the City storm sewers? #11: (Impact on visual resource.) We took the most exception to the statements in this paragraph, as discussed above. #18: (Impact on ... character of community...) We agree that it "will set the standard" for the rest of the Park- -and therein lies one of the major problems with the design, as discussed above. We do not agree that 4he project would have a positive visual impact on the City. i Memo to: Common Council and Mayor Cc: Planning Board and Dept. CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Jones, McDonald, Darlington) Re: Two zoning changes Date: May 10, 1994 Recommendation: 1. Minimum height provision: we don't feel qualified or sufficiently informed to comment. 2. Rezoning on Seneca St.: Negative declaration (no significant impact). Memo to: Planning Board and Dept John Novarr, et al. Johnson Buchanan Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Jones, McDonald, Darlington) I. Re: 106 -bed apt. building at 304 College Ave. Date: June 14, 1994 Recommendation: Negative declaration (no significant impact) Comments: 1. We are concerned about increased traffic on Catherine St., a very narrow street. Also, will cars and garbage trucks be able to make the sharp turn into the parking lot under the building? 2. Although the project would greatly increase the density in Collegetown, it would put students close to their destination, at least reduce their need for a car, and reduce the # of students driving into the City. , The bldg. would free up more space in downtown and rents there should become more affordable. 3. Concern was raised about snow and ice sliding off roof and onto pedestrians below. Mr. Novarr said that they can easily address this. 4. We recommend recycling of as much of the materials in the houses to be demolished as possible- -INHS, Historic Ithaca, private citizens, e.g. 5. We recommend that the most energy efficient materials and design be used in the construction. 6. During construction measures should be taken to prevent mud from leaving the site (silt fences, hay bales, etc.). 7. We recommend providing space and racks for bicycles. 8. We're glad to hear that they will be working closely with Nina Bassuk on the tree plantings. --------------------------------------------- II. Re: 603 Utica St. - -minor subdivision Recommendation: Negative declaration (no significant impact) lb C c - R..C� . A 44—s COMMENTS ON PROPOSED AMENDMENTS TO SEQR AND THE sv c u of � R1. — P"'.. • st,+ DRAFT GEIS FOR THESE AMENDMENTS A{l,o..y, Ny ►aai; -ltso from the City of Ithaca Conservation Advisory Council July 12, 1994 General comment on the proposed amendments: While some of the changes could be more protective of the environment than is currently the case, other changes weaken the protections. We oppose weakening SEQR. 1. Conditioned negative declarations: Page 8 of Draft GEIS [and 617.2 (i) and 617.6 (h)]: This needs to be better defined. Is it a CND if an agency requires certain mitigating measures which the developer then agrees to include in the project? Or is it only a CND if the conditions imposed by the agency are ones over which they have no direct control - -e.g. the rerouting or enlarging of a state highway? 2. Scoping: Page 13, last para. [and 617.7 (h) & (i)] : It should be made explicit that issues can be raised after the final scope. The lead agency, NOT the project sponsor, should determine whether or not to include these additions. 3. Shortening of timeframe for determining adequacy of DEIS from 60 to 30 days: Page 14 [and 617.8 (b)(i & 2)]: Although the intent is to involve the public much earlier, and therefore not need as long for public input at the DEIS stage, all too often it will probably remain the case that the public will not be adequately informed and involved until the DEIS stage. 30 days is an awfully short time in which to review DEIS's, especially for large projects. A possible compromise might be to provide 45 days. 4. Filing requirements: Page 17 [and 617.10 (a)(1 & 2)]: A "reasonable" length of time is much too vague. One day might be reasonable to some and forever, to another. At the very least, the amendment should include the advice given in the discussion paragraph, that "agencies would be wise to keep the EIS's and appendices because they contain valuable information on existing environmental conditions." Couldn't some minimum timeframe be given in the regs.? 5. Clarification of "cumulative impacts ": Page 17 [and 617.11 (a)(10 & 11), (b)(3)]: Good changes, but could be better. We recommend using the NEPA and CEQA definition and consider past, present and reasonably foreseeable future actions. We disagree that this would be limitless and impose an unfair burden on applicants. If it's ok in Cal. and under NEPA, why not for SEQR? 6. Unlisted qualifier: Page 19, "proposed revision ": the word, "only" is not in the correct place. It should read, "...to clearly indicate that e* Unlisted actions are elevated to Type I status only when the threshold is triggered." (The law is clear that this is the meaning you intend.) 7. Items not requiring envir. review: Page 21 -22, #3, 4, 5 [and 617.13 (c)(3,4,5)]: Such construction should remain unlisted. We disagree that these actions cannot have severe environmental impacts, even if it is uncommon. A short EAF is not burdensome on an applicant, and these cases are quickly and easily dealt with, using a short EAF. The proposed change would constitute a potentially serious weakening of SEQR. Would a $1 million home built right on a lakeshore not have a potentially large impact? Or a large expansion occurring along a waterway or on a steep slope? These items are far too inclusive and unprotective of the environment, and we see no reason not to leave them as unlisted actions. We also do not agree that the primary impacts associated with these types of actions "are usually infrastructure related concerns such as traffic, storm water drainage and sewage disposal or nuisance issues such as noise, lighting and littering." Even though an EIS will only rarely be needed for these cases, it is still useful to require an EAF for them. The EAF review process can bring out many issues that need to be addressed even though an EIS may not be called for. 8. Model assessment forms are valuable and should be included, as before. 9. P. 16 [and 617.9 (d) (5)] (Findings statement for final EIS and certification that the alternative chosen is the one that minimizes adverse impacts): It should be the lead agency, NOT the project sponsor, that identifies an alternative as practicable. 10. Positive and negative declarations for Type I actions should be published in local newspapers, in addition to the ENB. 11. EIS should include a summary list of mitigations and impacts mitigated. 12. It should be made clear that the "no action" alternative is always available, and that this need not meet the objectives of the project sponsor. Vote was unanimous for the above comely 11, 1994 meeting of the City CAC. Betsy Darlington, ChairS� OFFICE OF CONSERVATION ADVISORY COUNCIL CITY OF ITHACA 106 EAST GREEN STREET ITHACA, NEW YORK 14850 p, )z(qkf TELEPHONE: 272 -1713 CODE 607 A F s (-�C4��:.4t, -(�- &�� 3 CVO - V4 oc�_ l3) Ta 5610 v� ti p. I'5- x;30 �, �� • �3 1:30 �i �.. o.,u �..� v�,.�- >�..,�, --1,� u� � �x o.� a w-eA -� tom.. ���- cc _ d � 0 c�-✓ "An Equal Opportunity Employer with an Affirmative Action Program Memo to: Planning Board and Dept. Robert Colbert, Jr. (Threshold Partners) Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's ERC Subcommittee (Salon, Darlington) Re: EAF for new commercial development behind Garage de France Date: August 11, 1994 Recommendation: Negative declaration (no significant impact) Comments: In general, this looks like an attractive project, and one which should not generate substantial new traffic since the largest of the proposed businesses (a specialty food store) will mainly draw people already going to Wegmans or Tops. There appears to be an excessive amount of parking for the proposed uses of the buildings. Could some parking be built only after a need for them has been demonstrated? In the meantime, those areas could be attractively landscaped. We urge that more trees, especially of large species, be planted throughout, but especially in and around the paved areas. The eastern border with Garage de France shows only very low - growing shrubs (Potentilla), two pear trees and one juniper. Larger trees would do much to enhance the site, hide the lot behind the garage, and help cool the parking lot. In the main parking lot, junipers are shown. Could some large shade trees be substituted for some of these or added to them? We suggest keeping as many of the trees and shrubs which have moved in along the southern portion of the site as possible, both to help with drainage and to mediate pollution from the parking lots. What measures will be taken to prevent petroleum hydrocarbons, heavy metals, and other parking lot effluents from draining off the site and into the drainage channel immediately to the south? The drainage calculations were made for a 25 -year flood. We recommend that these be made for a 100 -year flood as well since the site is at least mapped as being in the 100 -year flood plain. (It appears to have been raised above that since the 1981 maps were made.) If a flood such as the one in 1993 were combined with one like the 1972 flood in which creeks went well over their banks, would the site be inundated? EAF Comments: Part I: Page 1: Almost all of the site is fill with early successional vegetation. Virtually 100% is vegetated. (The drainage plan describes it quite accurately.) Page 2, #4 (soils) Also loam (acc. to drainage report) #14: A large drainage channel is next to the site on the south; this drains into the flood relief channel quite near the site, to the west. Page 3, #3 (veg. removal): about 3.5 acres Page 4, #14 (a): shown on FIRM map as in 100 -year flood plain but probably has been raised above it since the map was made. � wr 1 OFFICE OF CONSERVATION ADVISORY COUNCIL CITY OF ITHACA 10B EAST GREEN STREET ITHACA, NEW YORK 14850 gq_� U, I TELEPHONE: 272 -1713 CODE 607 To: State University Construction Fund, c/o Mary Ellen Rajtar PO Box 1946, Albany, NY 12201 -1946 From: City of Ithaca Conservation Advisory Council, Betsy Darlington, Chair lsl�s� Date: August 11, 1994 O Re: Mann Library expansion DEIS (SUCF # 16069/167/198) We urge you to withdraw the DEIS until further work can be done to make it complete and adequate for public review, and to reschedule the public hearing. We have identified the following issues that need clarification, explanation, correction, or additional details in order for the public to evaluate the project: 1. A plat is needed showing the site design, including details of the landscaping, drainage, etc., and - -most important -- location of Beebe Lake and Forest Home Drive. 2. Information is needed in the text on the amount of additional shading that the addition would cause. "More than two hours" is insufficient. 3. Information is needed regarding shading during the month of April and early May, since that is the time when forest herbs depend the most heavily on sunlight. 4. Information is needed about changes in wind currents and the potential for damage to the trees. 5. Documentation is needed for the statement that the woods appear to be in a state of decline. 6. A more complete discussion is needed of forest regeneration, including what species would regenerate under the new conditions and what ones probably would not. 7. Details are needed of mitigating measures if trees die because of the new site stresses. Saying that the forest should be monitored by the Plantations staff and mitigation plantings be made if trees fail is inadequate. Also, who would pay for these measures? Is that provided for in the project budget? 8. The map showing tree species on the site needs to be made readable. With very few exceptions, the reduction makes deciphering the words impossible. 9. Figure 7 shows the "area of potential impact to forest floor," but does not give details regarding species of plants (canopy and understory trees, shrubs, herbs) within that area. Also, why does this area not coincide with the maps showing significant increased shade? 10. Sept 15's map could only be correct if the plans call for lowering the existing Mann library building. Are the other shading maps inaccurate as well? 11. Figures 9 and 10 appear to be looking west and east, respectively, not east and west, as labeled. 12. Figure 10 shows trees up against the building where there almost certainly will be none. This drawing needs to be made accurate. 13. Appendix C: Bore logs map is unreadable and upside down; profile on next page appears to show only part of the profile (left side may be cut off) . 14. The .DEIS states incorrectly that the project is consistent with the campus plan. "An Equal Opportunity Employer with an Affirmative Action Program" OFFICE OF CONSERVATION ADVISORY COUNCIL CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14850 Mr. Frank DeVilbiss Engineer for Vegetation Management Conrail 1634 Six Penn Center Philadelphia, PA 19103 TELEPHONE: 272 -1713 CODE 607 Sept. 12, 1994 Dear Frank: This letter is with my other hat on, as Chair of the City of Ithaca's Conservation Advisory Council. It has been a long time since we have heard from you, and we are wondering where things stand regarding a new spraying regime for the Conrail tracks through the City. Has any progress been made on this? We would appreciate receiving a copy of the new plan. Thanks a lot for your help. Sincerely, —&4,sl Betsy Darlington, Chair 607 - 273 -0707 "An Equal Opportunity Employer with an Affirmative Action Program" EAF reports for Planning Bd. and Building Dept. I. Memo to: Planning Board and Dept. Jagat Sharma for Countywide Appliance Service; 312 E. Seneca St. Cc: Common Council and Mayor CAC members BPW, DPW Building Dept. City Attorney From: Conservation Advisory Council's EAF Subcommittee (Salon, Shapiro, Darlington) Re: Reconstruction of Countywide Appliance Service in advance of DOT taking and demolition Date: Sept. 16/94 Recommendation: Negative declaration (no significant impact) Comments: This area badly needs trees, and the need will be even greater after the new Fulton St. is built. We hope the Planning Bd. requires some trees on the site, not just some bushes (the current landscaping plan). Part I of LEAF, page 1 says there will be "lawn and planter." If there's lawn, where is it? Could it be replaced with something more interesting, if trees aren't possible? Perennials, e.g.? If done right, these would require less maintenance, too- - e.g. if native field flowers are used such as asters, goldenrods, milkweed. We also hope the building has an attractive color (but not garish). H. Memo to: Building Dept. Cornell - -Robert Stundtner, 116 Humphreys Service Bldg., Ithaca 14853 Cc: Planning Board and Dept. Common Council and Mayor CAC members BPW, DPW City Attorney From: Conservation Advisory Council's EAF Subcommittee (Shapiro, Salon, Darlington) Re: Upgrade of Olin Chem Lab ventilation system and fire alarm system Date: Sept. 16, 1994 Recommendation: Negative declaration (no significant impact) Comments: If the plans include erosion and sedimentation controls during construction, we couldn't find them in the very brief time we had to review the plans. It is very important that this be addressed. Although the soil disturbance will be relatively small, it will be on a steep slope near Forest Home Dr. and Beebe Lake /Fall Creek. Mud must not leave the site where it would deposit silt into Fall Creek. Zce Memo to: Planning Board and Dept. Hoyt and Rebecca Benjamin Cc: Common Council and Mayor CAC members From: Re: Date: BPW, DPW Building Dept. City Attorney Conservation Advisory Council's EAF Subcommittee (Salon, Shapiro, Darlington) Addition to B & W Supply, Sherwin Williams Paints 10/16/94 Recommendation: at 3rd St. and rt. 13, probably for The main issue with this building is one of appearance from rt. 13, the Community Gardens, and the entrance drive to Carpenter Industrial Park. We felt that the Planning Board was better equipped to address this than we. Hence we decided not to make a recommendation regarding significance of the action's impact on the environment. The area proposed for the addition is currently lawn. We note that the dumpster and loading dock would be located between the addition and the Gardens, and urge that these be screened, preferably with vegetation, from rt. 13 and the Gardens. As part of the project, the area behind the warehouse, currently used for haphazard outdoor storage of debris, will have to be cleaned up to make way for parking spaces - -for once these constituting an improvement in appearance. Would it be possible to include a tree island in the middle of the new back parking lot? OFFICE OF CONSERVATION ADVISORY COUNCIL NY Public Service Commission Attn. Peter Seidman 3 Empire State Plaza Albany, NY 12223 -1350 CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14850 October 21, 1994 �Cv ` TELEPHONE: 272 -1713 CODE 607 Dear Members of the PSC: I just learned this morning that NYSEG and other public utilities in the state are proposing to reduce their Demand -Side Management budgets by some 70 %. This would defeat the state's energy plan goals and once again increase the need for more generating plants. The proposal is truly outrageous and I trust that you will deny permission. If there is any problem with NYSEG's program, it is the poor way it is administered, so poor, in fact, that many customers either are unaware of it or just don't bother. Let me tell you about an experience I had with NYSEG that led me to wonder if it was less than committed to its program and actually hoped to discourage customers' use of it by making things so difficult that they would give up. Several months ago I called NYSEG up and asked if they had any program to reduce the cost of energy - efficient flourescent bulbs. Yes, they could send me a coupon. I described the type of bulb I planned to buy in great detail and they sent me a coupon which required that I send it in with the receipt. I did so. I got a letter back saying that, too bad, I had not enclosed the bar code from the package. Well, the coupon I had been sent didn't say that and I had thrown away the box. I wrote back saying that my coupon hadn't required the bar code and I was disappointed in NYSEG for changing the rules midstream. I got back a very snitty note from some bureaucrat who said they did not change the rules, that I had used the wrong coupon for the bulb I had bought. The correct coupon was enclosed with the bar code requirement underlined. In comparing it with my coupon, also enclosed, I discovered that the schematic pictures on the two coupons were indeed different, and the coupon matching my bulb's design did require the bar code. I was defeated since I no longer had the box, and I didn't have the time to pursue the matter further with a complaint. Why wasn't I sent the correct coupon to begin with? Why do they require the bar code anyway? Shouldn't the receipt be enough? Why do they require that one go through all these hoops? Also, why didn't they advertise that you could get rebates? I found out about it only because I happened to know that they had a DSM program and thought a rebate might be possible. Most people wouldn't even be aware of it. Providing flourescent bulbs to service organizations to sell cheaply is something NYSEG used to do and was very effective. Do they do this anymore? I have not been aware of it. I would like to propose that, rather than slashing their DSM budgets, they be required to redouble their efforts to streamline it and increase its effectiveness. Make it easy for people to save electricity! One has to be almost a fanatic to do so as things stand now, as well as be able and willing to spend considerable amounts of money up front. Is NYS committed to reducing energy consumption or not? Please, DO NOT permit NYSEG, et al. to cut their DSM budgets. Sincerely, Betsy Darlington, CAC Chair "An Equal Opportunity Employer with an Affirmative Action Program" I. Memo to: Planning Board Samuel Frank, PO Box 4207, Ithaca 14852 -4207 Copy to: Common Council and Mayor BPW, DPW Building Dept. City Attorney CAC From: Conservation Advisory Council's Environmental Review Subcommittee (Wildes, Shapiro, Darlington) Date: Dec. 13, 1994 Re: SUBDIVISION OF 4.28 -ACRE LOT AT 422 TAYLOR PL. INTO FOUR LOTS Recommendation: Negative declaration (no significant effect) Comments: 1. EAF says water table is only 10 -24 inches below the surface. This is from the soil maps. If accurate, a buyer intending to build a house would want to that this might be the case on the site, and construct the house accordingly. 2. Drainage is mentioned as a potential problem on adjacent sites. Again, a buyer should plan to build carefully to prevent such problems. 3. Who would pay for extending Taylor Place to the north? 4. We did not receive Part II of the EAF. It makes it hard to do a careful review without it. H. Memo to: Planning Board Mutual Housing, c/o INNS, 520 W. Green St., Ithaca Copy to: Common Council and Mayor BPW, DPW Building Dept. City Attorney CAC From: Conservation Advisory Council's Environmental Review Subcommittee (Wildes, Shapiro, Darlington) Date: Dec. 13, 1994 Re: REDESIGN OF MUTUAL HOUSING PROJECT AT ADAMS /FIRST /FRANKLIN STS. Recommendation: Negative declaration (no significant effect)