HomeMy WebLinkAboutMN-ILPC-2009-04-09Approved by ILPC – 3/9/10
Ithaca Landmarks Preservation Commission
Minutes - April 9, 2009
Present:
Lynn Truame, Acting Chair
N. Brcak
K. Brennan
G. Holets
S. Jones
S. Stein
M. Tomlan, Council Liaison
L. Chatterton, Staff
D. Hoffman, City Attorney
Acting chairperson Lynn Truame convened the meeting at 7:06 p.m.
I. PUBLIC HEARING
A. None
II. PLEASURE OF THE CHAIR
A. Administrative Matters
B. Communications
C. Public Comment on Matters of Interest
III. OLD BUSINESS
A. Former Ithaca Gas Works, Individual Landmark
1. Draft Environmental Impact Statement (dEIS), determination of
adequacy for public review.
Dr. Judith Pastel, Superintendent of the Ithaca City School District
(ICSD), and Robert Tyson, Esq. Counsel for ICSD were present to address
the Ithaca Landmarks Preservation Commission (ILPC) concerning the
dEIS. ILPC members conducted a page-by-page review of the document.
It was noted by the ILPC that the overall tone of the document was more
one of advocacy for the demolition proposal and less a factual assessment
of environmental impacts. It was noted by the ILPC that deterioration has
resulted in part from lack of maintenance and that the building is in worse
condition now than it was at the time of the last appeal (Petitioner New
York State Gas & Electric (NYSEG), 2005.) M. Tomlan noted that in
recent years industrial buildings have become more appreciated. She
added that the “built environment” is as much a part of the dEIS as the
natural environment. ILPC members felt that the document does not fully
acknowledge that the original Record of Decision between the Department
of Environmental Conservation and NYSEG - calling for demolition of
the building and remediation of the site - was altered by the Explanation of
Differences, a new agreement - calling for the containment of hazardous
wastes underneath the building. The containment remedy was determined
by the DED to be protective of public health and safety.
In response to Commission comment, J. Pastel stated that the first priority
of the ICSD is to care for buildings that house children and that buildings
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Minutes – April 9, 2009
2
that do not house children are not eligible for state aid. In response to
Commission comment about ICSD plans for the site, J. Pastel stated that
when the ICSD purchased the four-acre parcel there was thought of
building a new school on the site. She indicated her feeling that the ICSD
must keep options for the site open adding that, with a scarcity of available
land downtown, it would be irresponsible for the ISCD not to reserve
flexibility with regard to the site, especially because the Beverly J. Martin
School enrollment is growing.
J. Pastel noted that, in conversation with the City’s Mayor, she had offered
to sell the building to the City for $1.00, but that the Mayor expressed
reluctance to take on additional debt. She added that the ICSD would
require that any potential buyer remove the building from the site. ILPC
staff responded that the Mayor has contradicted the ICSD assertion that
the building was offered to the City. M. Tomlan indicated that she knew
of interest on the part of at least one local developer. J. Pastel questioned
viability of those with “potential interest”. ILPC members questioned
whether or not the ICSD had made it known that the building could be
purchased. R. Tyson stated that the ICSD is under no obligation to
advertise or sell the building.
Following discussion R. Tyson agreed to some modifications of the
submitted dEIS. He indicated that the ICSD would agree to a time
extension that would allow for completion of the required environmental
review. In order to expedite the process, ILPC members authorized staff
to make a determination of adequacy and completeness, based on staff
judgment that issues specified in the resolution have been addressed.
RESOLUTION Regarding Completeness and Adequacy for
Public Review of Draft Environmental Impact
Statement for
Demolition of the former Ithaca Gas Works by the
Ithaca City School District
WHEREAS, the Ithaca City School District (referred to hence as either
ICSD or “the District”) has requested a Certificate of Appropriateness
from the Ithaca Landmarks Preservation Commission for the proposed
demolition of the former Ithaca gas works, a building first occupied by the
Ithaca Gas Company (also known as “Markles Flats” – the name of the
alternative school occupying the building in the 1970s). The building is
located at the corner of West Court Street and North Plain Street on an
approximately 2-acre piece of property owned by ICSD. The former gas
works building is a two-story, brick masonry industrial structure with a
38’ by 93’ 4” footprint constructed in 1899 to replace an earlier building
also used by the Ithaca Gas Company. Based on its association with
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3
Ithaca’s early development and the building’s architectural design, the
building was designated a local landmark in 1977. Significant design
elements include those that reflect its industrial function such as the
rooftop retorts, as well as design features typical of late 19th architecture
such as the heavy, rusticated stone window sills and lintels and the brick
corbelling at the building’s eaves. The property was acquired by ICSD in
1964 from New York State Electric & Gas Corporation (NYSEG); and
WHEREAS, as a result of release and/or disposal of hazardous wastes
associated with the building’s earlier use as a coal gas manufacturing
plant, the property is listed as a Class 2 Site on the New York State
Registry of Inactive Hazardous Waste Disposal Sites. NYSEG is
currently undertaking remediation of contamination on other portions of
the 2-acre site by excavating and removing contaminated soils. The
remedy for treatment of identified contaminants underneath the gas works
building, as agreed upon by the New York State Department of
Environmental Conservation (DEC), is to pump out contaminants
underneath the building, containing any remaining containments with a
subsurface corrugated metal barrier at the building’s perimeter and
inclusion of a system for ongoing monitoring of soil gas vapors, and
WHEREAS, the proposed action consists of demolition of the building
that is in deteriorated condition and that ICSD has stated, “seriously
interferes with the District’s future use of the site.” Following proposed
demolition the site would be remediated in the same manner as other
portions of the site. ICSD states that the remediated site would be used for
proposed construction of a new building to house ICSD administrative
office use and for recreational purposes associated with Beverly J. Martin
Elementary School located on the block across West Court Street.
WHEREAS, the demolition of a building designated a local landmark
under municipal law and determined eligible for listing on the New York
State and National Registers of Historic Places is a Type I Action subject
to environmental review under the provisions of the State Environmental
Quality Review Act (SEQRA) and City Environmental Quality Review
Ordinance (CEQRO) and
WHEREAS, the ILPC, as lead agency, made a positive Declaration of
Environmental Significance on February 12, 2009, directing the ICSD to
prepare a Draft Environmental Impact Statement (dEIS) to evaluate
potential impacts of the proposed demolition of the former Ithaca gas
works building, and
WHEREAS, after the February 12, 2009 declaration, the ILPC
communicated in writing the results of an informal scoping to assist the
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applicant in assembling a dEIS that would focus on matters that are of
most concern to the ILPC, and
WHEREAS, on March 30, 2009 ICSD submitted a dEIS to the ILPC, and
WHEREAS, the ILPC, as Lead Agency for the environmental review, has
reviewed the dEIS for completeness and adequacy for the purpose of
public review and comment, and has with the assistance of City staff
discussed the dEIS with respect to its scope, content, and adequacy, in
light of the informal scoping guidelines, now therefore be it
RESOLVED that the ILPC, as Lead Agency, hereby finds that the dEIS
for the demolition of the former Ithaca gas works building as submitted on
March 30, 2009, is not complete or adequate, with respect to its scope and
content, unless it is modified so as to address the stipulations set forth
below and as discussed in the dialogue between the ILPC and the
applicant on April 9, 2009. In the event that a revised dEIS is submitted
by the applicant, prior to the next meeting of the ILPC, staff to the ILPC is
in that case authorized to determine whether said stipulations have been
satisfied by the revised dEIS, thus rendering it suitable for public review
and comment, pursuant to SEQRA and CEQRO.
Moved by K. Brennan
Seconded by S. Stein
RECORD OF VOTE: Approved 6 – 0 – 0
Yes
L. Truame, Acting Chair
N. Brcak
K. Brennan
G. Holets
S. Jones
S. Stein
No
0
Abstain
0
1. Pumping out of contaminants currently underneath the building,
containment of remaining contaminants with a metal barrier,
monitoring of soil gas vapors.
The remedy selected by NYSEG involves the pumping out of
contaminants underneath the building, containment of any remaining
contaminants with a metal barrier at the building’s perimeter and
monitoring of soil vapors inside the building. Since the DEC and the
NYS Department of Health have approved this approach, it is reasonable
to assume that the remedy has been determined adequate in terms of
public safety.
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Minutes – April 9, 2009
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Throughout the dEIS, ICSD makes reference to contaminants that “will”
remain underneath the building “indefinitely,” and clearly implies that the
current remedy is less protective of public health, but presents no scientific
evidence for this position. In a letter to the ILPC dated February 4, 2009,
NYSEG strongly advised that the ILPC “ is not the proper forum to
debate” the “complex issue” of remediation methods.
Such statements of the comparative effectiveness or safety of remediation
approaches should be deleted from the dEIS, unless they are backed up
with credible scientific evidence.
2. “…the District may be legally obligated to maintain the containment
structure. Any costs associated with the maintenance of the structure
will be borne solely by District taxpayers.” p. 13
The imposition of a legal obligation on the District to maintain the
containment structure should be supported by documentation that specifies
what the maintenance would include and its anticipated frequency, in
order for the ILPC to fully evaluate the impact of the obligation. In
addition the document suggests a cost to be borne by the District of
maintaining the containment structure and monitoring the soil gas vapors
but does not attempt to quantify those costs. In fact, economic
considerations are not the appropriate subject of an EIS and were not
identified in the informal scoping. These unquantified references to costs
should be deleted from the dEIS. (Such concerns are certainly part of the
ILPC’s consideration of the application, and can be addressed outside the
dEIS.)
3. “…the District may be subjected to restrictions on the use of the
property that will be determined by the New York State Department of
Environmental Conservation (“DEC”) in the future. The precise nature
of those restrictions is not known at this time…`p.13
It is difficult to assess the impact of any use restrictions without knowing
what they are. Unless the ICSD can provide additional information as to
what the use restrictions would be, this speculative statement should be
deleted from the dEIS.
4. “Although it was deemed a local landmark in 1977, the Markles Flats
Building is currently in a dilapidated state. …Given the current
condition of the building, the demolition of the Markles Flats Building
will not have an adverse impact on the aesthetic resources of the
community.” p 10
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Minutes – April 9, 2009
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The condition of an historic building is not typically a measure of its
significance. The dEIS should show that the District has a full
understanding of the building’s historic significance, which information is
largely absent. While a full recitation of the reasons for the building’s
historical importance and designation, in the main text of the dEIS, would
be the preferred remedy to this problem, the ILPC suggests that an
acceptable approach would be to reference the following background
documents in the main text of the dEIS, and include the documents
themselves as appendices: the New York State Building Structure
Inventory Form, the Secretary of the Interior’s criteria for listing on the
National Register, and the letter from the New York State Office of Parks,
Recreation and Historic Preservation stating the eligibility of the gas
works for listing on the New York State and National Registers of Historic
Places it. These documents can be provided to ICSD by ILPC staff.
5. “The masonry exterior is severely impacted by spalling of the soft
brick, and this has structural implications and long-term maintenance
implications. One portion of the building has been identified as having
brick deterioration that Novelli Engineering believes represents an
imminent hazard. As time passes, the condition of the Markles Flats
Building, if not renovated, is expected to worsen. The Markles Flats
Building is located immediately adjacent to a public sidewalk, and its
condition presents a risk to persons in the immediate vicinity of the
structure, whether they are on the District property or passing by on the
sidewalk. …Additionally, renovation of the Markles Flats Building so
that it could be inhabited could only be accomplished at excessive
expense.” p.6
The dEIS should supplement this information with an explanation of the
District’s investment in and efforts toward routine maintenance of the
building, over the course of its ownership.
Has this building been subject to the same level of routine maintenance as
other facilities under ICSD stewardship?
In light of the District’s recent lack of maintenance have there been efforts
to transfer the building to a party with greater interest in this historic
building or to publicize its availability?
6. “While many members of the public recognized that historic
preservation and environmental remediation are both important
considerations, the majority of the commenters indicated that in this
instance, their preference was for the environment to be favored, even if
that meant that demolition of the Markles Flats Building resulted.
…Ensuring that the interests of the individuals who live in close
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Minutes – April 9, 2009
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proximity to the Markles Flats Building are satisfied is another public
benefit of demolition.” pp. 7-8
In this case, the public has generally been presented with only two options
considered to be “reasonable”: demolition of the building or an agreed
upon remedy that includes partial removal of the contaminant, indefinite
containment of the remaining contaminant and ongoing monitoring of soil
gas vapors. Prior to the meeting held on February 12th the ILPC received
a letter from NYSEG dated February 4, 2009, stating that demolition will
have a “secondary benefit” of allowing a more complete remediation of
the coal tar under the building. (According to the letter, the primary
benefit is the elimination of cost to the District taxpayers of the 2.5 million
dollar cost to renovate the building.) The letter goes on to state,
“demolition is not the only way to achieve this secondary benefit. NYSEG
has investigated two methods, moving the building or supporting it during
excavation under it. While costly and not without risk, they are certainly
possible.” A separate, earlier email communication dated 1/2/2009 stated,
“if permission to demolish the building is not granted, NYSEG will
continue to explore more aggressive clean up options. We have begun
discussions with a vendor that claims they can destroy the coal tar under
buildings with the use of chemical oxidants.”
The ILPC asks that these communications be mentioned in this section of
the dEIS, so as to provide a more complete view of the situation, and that
the letters themselves be appended to the dEIS so that they are part of the
record and available for public review.
7. “ …demolition of the structures on the District property has thus
afforded an opportunity for the District to enhance recreational
opportunities for the students who attend Beverly J. Martin Elementary
School (“BJM”). The District property, in a fully remediated state,
would be suitable for student recreation, whether in a gym class, or for
“field days” that are commonly held at other District schools. As the
owner of a fully remediated property in such close proximity to BJM, the
District would certainly seek to use the property to benefit the BJM
students. However, the District also stated that the continued presence
of the Markles Flats Building would interfere with this use. p. 17
The dEIS states that retention of the former gas works interferes with the
District’s proposed use of the site. The dEIS lists some general, potential
uses for the site and also makes reference to a potential new building to be
constructed on the site to house administrative offices.
It is not clear that the retention of a building with an approximately 4000
square foot footprint and/or the transfer of some additional property to
create a parcel viable for redevelopment would seriously interfere with the
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Minutes – April 9, 2009
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District’s use of the two acre site. The district should provide some
additional information or a sketch plan to show how the site can or cannot
accommodate the district’s desired mix of uses, if the building was to be
retained.
In discussion that occurred during the April 9, 2009 meeting it was agreed
that the ICSD would provide additional information on actual plans for the
site and its objective to reserve options for future uses.
8. The District states “transfer of the Markles Flats Building to the City
would appear to be an appropriate and reasonable solution for all
parties. … In fact the District has offered, on more than one occasion, to
work with the City to do just this. …the City would be required in that
circumstance to incur costs to renovate the Markles Flats Building, and
in discussions approximately 3 years ago, the City informed the District
that it could not take on any additional debt service. That rationale is
understandable, and provides an explanation for why a transfer to the
City has not occurred.”
This statement is not backed up with any documentation of a serious offer
to transfer the building to the City or any other potentially interested party,
and City officials have a different recollection. Unless such
documentation can be provided, the statement should be deleted from the
dEIS. It is noted that to be feasible, such an offer would likely need to
include some portion of land around the building to allow reasonable
space for an economically viable redevelopment or to meet a parking
requirement. Has there been any effort to let the public know that the
building may be available?
9. Solid waste impacts: What is the volume and weight of materials
to be transported and disposed of? What is the expenditure of energy
in removing the materials from the site? What are the costs of
demolition given the statement of asbestos involved?
2. Establishment of public comment period
ILPC members directed staff to establish a public comment period, to be
30 days from staff determination of completeness and adequacy for public
review. Because there had already been opportunity for public comment,
no formal public hearing on the dEIS was scheduled.
Ithaca Landmarks Preservation Commission
Minutes – April 9, 2009
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IV. NEW BUSINESS
V. ADJOURNMENT
Respectfully submitted,
Leslie A. Chatterton, Staff,
Ithaca Landmarks Preservation Commission