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HomeMy WebLinkAboutComments on DEIS for Proposed Elmira Road Shopping Center - 11-28-2001 Comments on Draft Environmental Impact Statement for Proposed Elmira Road Shopping Center From: City of Ithaca Natural Areas Commission Date: November 28, 2001 DEIS = Draft Environmental Impact Statement (for Elmira Rd Shopping Center) NAC = Natural Areas Commission SWNA = Southwest Natural Area (a/k/a "designated substitute parkland") 1. The DEIS does not address potential impacts on the SWNA (such as noise, glare, fumes, litter, etc) other than drainage. 2. The DEIS does not address whether"remediated" soil will be or should be placed in SWNA, and, if so, exactly where it would be located. (The NAC reiterates its objection to the placement of any remediated soil from the clean- up on.the Widewaters site in or directly adjacent to the SWNA, because of concern that such placement will make it more likely that an increased level of contaminants will then affect the SWNA.) 3. The NAC reiterates its objection to the placement of the berm (intended to buffer the project from adjacent parkland) in the SWNA rather than on the project site. The NAC does not consider this to be a proper use of public parkland. Required screening should be provided on the applicant's property. 4. For the same reason, the NAC objects to the placement of stormwater treatment/detention in the SWNA rather than on the project site. It is the NAC's understanding of Section 267, A (2) of the City of Ithaca's Zoning Ordinance that it is not proper to allow stormwater from a new parking area to flow on to adjacent property. Since Widewaters is legally bound to convey the substitute parkland to the City, in exchange for City-owned land which Widewaters needs to construct its project, any building permit issued for the current site plan will result in a violation of the ordinance. Stormwater treatment should be required to take place on the applicant's property. 5. The detention ponds as proposed are not part of the Master Plan the City has adopted for the SWNA; they will interfere with trails and woods shown in the Plan. 6. If(despite the objections of the NAC)the City approves a site plan which allows the berm and/or the detention ponds (etc) to be located in the SWNA, then these facilities should be designed to be as compatible as possible with the nature and character and needs of a natural area, and this one in particular. For the various reasons set forth herein, the NAC does not find the current design to meet these criteria. 7. It is not clear from the DEIS how much runoff(by volume) will not be detained and treated by the retention ponds (and thus will run through the swales or spread out across the SWNA). This figure should be provided. Also, the DEIS does not explain what will happen to runoff that occurs after the "first flush" and whether it will displace the "first flush" from the detention ponds. 8. It is not clear from the DEIS and accompanying maps and diagrams exactly what the design of the proposed detention ponds would be. Depth and steepness of slopes could affect what plants will grow in the ponds and how much filtering occurs. 9. The NAC reiterates its preference to have as much stormwater runoff as possible from the project site enter the Inlet at the most northerly (downstream) possible point. The current plan shows most of the runoff entering at a more upstream location, in the midst of the unchannelized portion of the Inlet. It is the unchannelized portion that is the most ecologically rich and most prone to bank erosion. Directing the heavier flow of runoff(which will be warmer than water in the Inlet and contaminated with heavy metals) into the unchannelized section will result in more erosion and greater biological impacts. 10.The site plan should require the planting of approved trees (such as box elder) and other vegetation to buffer the mowed banks of the detention ponds from the rest of the SWNA. Otherwise, the banks will present an unnatural appearing visual impact when viewed from the SWNA. (Is it necessary for the banks to be mowed?) 11.The berm should have an average width of at least 75 feet, so it can accommodate at least 2 (staggered) rows of trees (not just one, as the current plan indicates); it should be planted with shrubs as well as trees; and should have variable contours rather running in a straight line. 12.The final site plan should require the developer to ensure the long-term survival (or replacement, as necessary) of all required plantings. 13.Any lights placed on the backs of the main buildings (next to the SWNA) should be located as low as possible and directed only downward, to minimize light spillover into the SWNA. 14.The NAC objects to (a) the lack of a connection between the Black Diamond Trail and the project site; and (b) the lack of a pedestrian connection from Route 13/project site to the SWNA. Notwithstanding the debate over who should pay for such connections, they should be designed into the site plan, for implementation by the appropriate party or parties. 15.The NAC is concerned about the proposed location and drainage of the "snow storage area." It appears that melt and runoff from stored snow will drain directly into the SWNA, without any treatment or detention. The NAC recommends that any snow storage area be designed to direct meltwater into a detention pond. Furthermore, the NAC recommends that the use of deicing agents be restricted because of the close proximity of the project site to the SWNA. 16.This past summer, a portion of the designated substitute parkland now held by Widewaters and under contract to be conveyed to the City as part of the SWNA was illegally plowed and planted in corn. This action destroyed recovering vegetation and eliminated a small wetland area. The final site plan should require the developer to take steps to remediate this damage in a timely fashion. The NAC recommends that the cornstalks be disked into the ground, that the ground be smoothed out and that a seed mix of native plants (only) be spread across the disturbed area. 17.The "alternatives" section of the DEIS should include a viable site plan with reduced scale of buildings and parking (showing the berm and detention ponds within the commercially-zoned area, rather than within the SWNA). The NAC reiterates its support for such a reduction, in light of the sensitivity of the adjacent natural area and the need to prevent the infringement of commercially-related uses into public parkland and open space. 18.The DEIS should include, in the "alternative stormwater management" section, a design which incorporates several wide, vegetated islands in the parking lot intended to help filter stormwater runoff and to support the health and growth of larger and taller trees. The NAC recommends implementation of such as design. 19.The NAC observes that most of the trees shown on the planting list submitted by the developer are not native species. Plantings on the berm or adjacent to the SWNA or the Black Diamond Trail should contain only native species - as suggested by the Design Guidelines for the Southwest Area and Elmira Road-Meadow Street Corridor and as specified by the Southwest Natural Area Master Plan.