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.