HomeMy WebLinkAbout02-26-19 Planning and Development Board Meeting Agenda
PLANNING & DEVELOPMENT BOARD AGENDA – Revised
The regular meeting of the PLANNING & DEVELOPMENT BOARD will be held at 6:00 p.m. on FEBRUARY 26TH, 2019
in COMMON COUNCIL CHAMBERS, City Hall, 108 E. Green Street, Ithaca, NY.
AGENDA ITEM Approx. Start Time
1 Agenda Review
6:00
2 Privilege of the Floor (3-minute maximum per person ― if you will be speaking about a project with a scheduled
PUBLIC HEARING below , you are highly encouraged to speak at that time)
6:05
3 Approval of Minutes: October 30, 2018, December 18, 2018, and January 22, 2019
6:15
4 Site Plan Review
A Project: Chain Works District Redevelopment Plan (FGEIS) 6:20
Location: 620 S. Aurora St.
Applicant: Jamie Gensel for David Lubin of Unchained Properties
Actions: Review of Town PDZ Review of Draft Findings FGEIS Notice of Completion
Project Description: The proposed Chain Works District seeks to redevelop and rehabilitate the +/-800,000 SF
former Morse Chain/Emerson Power Transmission facility, located on a 95-acre parcel traversing the City and
Town of Ithaca’s municipal boundary. The applicant has applied for a Planned Unit Development (PUD) for
development of a mixed-use district, which includes residential, commercial, office, and manufacturing. The
site’s redevelopment would bridge South Hill and Downtown Ithaca, the Town and the City of Ithaca, by
providing multiple intermodal access routes including a highly-desired trail connection. The project will be
completed in multiple phases over a period of several years with the initial phases involving the redevelopment
of the existing structures. Current redevelopment of this property will focus on retrofitting existing buildings and
infrastructure for new uses. Using the existing structures, residential, commercial, studio workspaces, and office
development are proposed to be predominantly within the City of Ithaca, while manufacturing will be within
both the Town and City of Ithaca.
The Final Draft FGEIS for circulation dated February 11, 2019 is available for download at:
https://www.cityofithaca.org/DocumentCenter/Index/949
Complete project materials are also available on the City website at:
http://www.cityofithaca.org/DocumentCenter/Index/119
B Project: North Campus Residential Expansion (NCRE) 6:50
Location: Cornell University Campus
Applicant: Trowbridge Wolf Michaels for Cornell University
Actions: Presentation Public Hearing
Project Description: The applicant proposes to construct two residential complexes (one for sophomores and
the other for freshmen) on two sites on North Campus. The sophomore site will have four residential buildings
with 800 new beds and associated program space totaling 299,900 SF and a 59,700 SF, 1,200 -seat, dining facility.
The sophomore site is mainly in the City of Ithaca with a small portion in the Village of Cayuga Heights; however,
all buildings are in the City. The freshman site will have three new residential buildings (each spanning the City
and Town line) with a total of 401,200 SF and 1,200 new beds and associated program space – 223,400 of which
is in the City, and 177,800 of which is in the Town. The buildings will be between two and six stories using a
CITY OF ITHACA
108 E. Green St. — Third Floor Ithaca, NY 14850-5690
DEPARTMENT OF PLANNING AND DEVELOPMENT
JoAnn Cornish, Director
Planning & Development – 607-274-6550 Community Development/IURA – 607-274-6565
E-Mail: dgrunder@cityofithaca.org
Start Times: Start times are approximate only — APPLICANTS are responsible for being available at whatever time(s) their agenda item(s) is actually discussed.
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Out of consideration for the health of other individuals, please try to refrain from using perfume/cologne and other scented
personal care products at City of Ithaca meetings. Thank you for your cooperation and understanding.
"An Equal Opportunity Employer with a commitment to workforce diversification."
modern aesthetic. The project is in three zoning districts: the U-I zoning district in the City in which the proposed
five stories and 55 feet are allowed; the Low Density Residential District (LDR) in the Town which allows for the
proposed two-story residence halls (with a special permit); and the Multiple Housing District within Cayuga
Heights in which no buildings are proposed. This has been determined to be a Type I Action under the City of
Ithaca Environmental Quality Review Ordinance (“CEQRO”) §176-4 B.(1)(b), (h) 4, (i) and (n) and the State
Environmental Quality Review Act (“SEQRA”) § 617.4 (b)(5)(iii), for which the Lead Agency issued a Negative
Declaration on 12/18/2018.
Due to large file sizes, we are not attaching the new Site Plan Review Materials dated February 8, 2019 to
this agenda. They are available for download at:
https://www.cityofithaca.org/DocumentCenter/Index/948
All NCRE project materials and public comments to date are available for download from the City website
at:
http://www.cityofithaca.org/DocumentCenter/Index/811
C Project: Harold’s Square 7:10
Location: 123-127, 133, 135, and 137-139 E. State Street, The Commons
Applicant: McGuire Development and CJS Architects
Actions: Project Changes
Project Description: The applicant is requesting building façade changes for the proposed Harold’s
Square Mixed-Use Project. The project was originally approved by the Board on August 27, 2013 and
was subsequently granted a two-year extension of Site Plan Approval until August 27, 2017. The Board
later approved building façade and materials changes on August 23, 2016, and again on May 24, 2017.
The applicant is now requesting additional façade changes, primarily affecting the Commons façade.
Project materials are available for download from the City website:
https://www.cityofithaca.org/DocumentCenter/Index/666
D Project: City Centre Signage 7:25
Location: 301 E. State/MLK St.
Applicant: Jeff Smetana for Newman Development Group, LLC
Actions: Review of Proposed Signage
Project Description: The project was approved by the Planning Board on May 27, 2017. The applicant is no w
seeking approval of the proposed signage, as conditioned in its original site plan approval. The project has
received approval for one sign. The proposed additional signage requires variances as it exceeds regulations for
the CBD Zoning Districts. New signage is subject to Design Review.
Project materials are available for download from the City website:
https://www.cityofithaca.org/DocumentCenter/Index/623
E Project: Falls Park Apartments (74 Units) 7:40
Location: 121-125 Lake Street
Applicant: IFR Development, LLC
Actions: Review of New Materials
Project Description: The applicant proposes to build a 133,000 GSF, four-story apartment building and
associated site improvements on the former Gun Hill Factory site. The 74-unit, age-restricted apartment
building will be a mix of one- and two-bedroom units and will include 7,440 SF of amenity space and 85 parking
spaces [(20) surface spaces and (65) covered spaces under the building]. Site improvements include an eight-
foot-wide public walkway located within the dedicated open space on adjacent City Property (as required per
agreements established between the City and the property owner in 2007) and is to be constructed by the
project sponsor. The project site is currently in the New York State Brownfield Cleanup Program (BCP). Before
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Out of consideration for the health of other individuals, please try to refrain from using perfume/cologne and other scented
personal care products at City of Ithaca meetings. Thank you for your cooperation and understanding.
"An Equal Opportunity Employer with a commitment to workforce diversification."
site development can occur, the applicant is required to remediate the site based on soil cleanup objectives for
restricted residential use. A remedial investigation (RI) was recently completed at the site and was submitted to
NYSDEC in August 2018. The project is in the R-3a Zoning District and requires multiple variances. This is a Type
I Action under the City of Ithaca Environmental Quality Review Ordinance (“CEQRO”) §176-4 B(1) (h)[2], (k) and
(n) and the State Environmental Quality Review Act (“SEQRA”) §617-4 (b) (11).
NOTE Additional SEQR materials submitted February 22, 2019 (including appendices) available at:
https://www.cityofithaca.org/DocumentCenter/Index/966
Project materials are available for download from the City website:
http://www.cityofithaca.org/DocumentCenter/Index/852
F Project: New Two-Family Dwellings 8:00
Location: 815-817 North Aurora Street
Applicant: Daniel Hirtler, architect, for owner Stavros Stavropoulos
Actions: Determination of Environmental Significance Preliminary and Final Site Plan
Approval
Project Description: The applicant proposes to demolish an existing two-family residential structure and
construct two new 1,290 SF two-family dwellings on a 9,590 SF lot. The existing residential building is a legally
non-conforming building with a side setback deficiency (2.9 feet instead of the required 5 feet). The proposed
redevelopment will include four parking spaces for four three-bedroom apartments. The applicant is requesting
the Board’s approval to use the landscaping compliance method for parking arrangement. The project site is
located in the R-2b Zoning District and meets all applicable zoning lot and setback requirements. This is an
Unlisted Action under the City of Ithaca Environmental Quality Review Ordinance (“CEQRO”) and the State
Environmental Quality Review Act (“SEQRA”).
Project materials are available for download from the City website:
http://www.cityofithaca.org/DocumentCenter/Index/859
G Project: Arthaus on Cherry Street 8:15
Location: 130 Cherry Street
Applicant: Whitham Planning & Design
Actions: Declaration of Lead Agency Project Overview
Project Description: The applicant proposes a five-story building approximately 63 feet in height with gallery,
office and affordable residential space at 130 Cherry Street, on the east side of the Cayuga Inlet. The site is
currently the location of AJ Foreign Auto. The program includes ground floor covered parking for approximately
52 vehicles, plus 7,000 SF of potential retail/office and amenity space geared towards artists’ needs. Building
levels two through five will house approximately 120 studio, one-bedroom and two-bedroom residential units.
The total building square footage is 97,500 SF. All residential rental units will be restricted to renters earning 50
to 80 percent of the Area Median Income. The building will be set back from Cherry Street approximately 23 feet
to create a linear parklet. The north edge of the property will include a publicly accessible path leading to an
inlet overlook. This has been determined to be a Type 1 Action under the City of Ithaca Environmental Quality
Review Ordinance § 176-4B(1)(k), (h)[2], (n), and the State Environmental Quality Review Act (“SEQRA”) §
617.4(b)(11).
Project materials are available for download from the City website:
https://www.cityofithaca.org/DocumentCenter/Index/946
H Project: Cayuga Street Townhomes 8:35
Location: 402 S. Cayuga Street
Applicant: Ithaca Neighborhood Housing Services
Actions: Public Hearing Recommendation to the Board of Zoning Appeals
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Out of consideration for the health of other individuals, please try to refrain from using perfume/cologne and other scented
personal care products at City of Ithaca meetings. Thank you for your cooperation and understanding.
"An Equal Opportunity Employer with a commitment to workforce diversification."
Project Description: The applicant proposes to construct four (4) for-sale townhomes that will target moderate-
income, first-time home buyers. The application and site plan was previously submitted and reviewed by the
Planning and Development Board and approved on March 24, 2015; however, after two years passed, the
approvals lapsed, necessitating resubmission of the application, as required by §276-10 of the City of Ithaca
Municipal Code. The applicant proposes the buildings to be two stories with parking below to take advantage o f
the sloped site. Architectural features include front porches, rear decks, shifting roof planes, and a varied color
palette. Site development includes a common asphalt driveway in the rear, walkways connecting each unit to
the existing sidewalk on Cayuga Street, and landscaping. The project site is in the R-3b Zoning District and
requires an Area Variance for a front yard setback. This is a Type I Action under the City of Ithaca Environmental
Quality Review Ordinance, §176-4 (h)(2), and the State Environmental Quality Review Act, §617.4 (11). The
Planning Board, as Lead Agency, has determined that the project is consistent with the Negative Declaration of
environmental significance issued on January 27, 2015, and therefore, no additional review is required.
Project materials are available for download from the City website:
https://www.cityofithaca.org/DocumentCenter/Index/726
I Project: Wood Street – Perdita Flats 8:55
Location: 402 Wood Street
Applicant: Stream Collaborative, Noah Demarest
Actions: Declaration of Lead Agency Public Hearing
Project Description: The applicant proposes to construct a three-story residential building on a vacant lot in the
Southside Neighborhood of Ithaca. The building will include four rental units priced at market rate: (1) three-
bedroom unit, (2) one-bedroom units, and (1) two-bedroom unit. The first-floor unit will meet ADA
requirements for accessibility. The parcel is located in the R-3b Zoning District and will require variances for off-
street parking requirements and rear yard setback. This has been determined to be an Unlisted Action under the
City of Ithaca Environmental Quality Review Ordinance and the State Environmental Quality Review Act
(“SEQRA”), both of which require environmental review.
Project materials are available for download from the City website:
https://www.cityofithaca.org/DocumentCenter/Index/945
J Immaculate Conception Site-Sketch Plan
5 Zoning Appeals 9:10
# 3118, Area Variance, 504 Meadow Street
# 3119, Area Variance, 402 S. Cayuga Street
# 3121, Special Permit, 1101 E. State Street
BZA materials available at:
http://www.cityofithaca.org/AgendaCenter/ViewFile/Agenda/_03052019-1808
Old/New Business 9:30
6
Reports
A. Planning Board Chair
B. BPW Liaison
C. Director of Planning & Development
9:35
7 Adjournment 9:45
If you have a disability & would like specific
accommodations to participate,
please contact the City Clerk at 274-6570 by
12:00 p.m., no later than 2 days (not including
weekends and holidays) before the meeting.
PROPOSED RESOLUTION
FGEIS Completion
Chain Works District Redevelopment Project
Final Generic Environmental Impact Statement (FGEIS)
City of Ithaca Planning and Development Board
February 26, 2019
WHEREAS:the City of Ithaca has received applications to the City of Ithaca Planning and Development Board (City
Planning Board) for Site Plan Approval and to the City of Ithaca Common Council (Common Council)for a Planned
Unit Development (PUD) for the Chain Works District (CWD)Project (Project) to be located at 620 S.Aurora Street,
by James Gensel for David Lubin of Unchained Properties (Project Sponsor), and
WHEREAS:the Project is a proposed mixed-use redevelopment ofthe 95-acre fomier Morse ChainlEmerson Power
Transmission facility (Site)that traverses the City and Town of Ithaca's municipal boundary. The Site is located
along the New York State Route 96B corridor and where Turner Street and South Cayuga Street meet the northern
edge of South Hill. The Project involves the redevelopment and rehabilitation of the existing architecture and
landscape into a 1.7 million square foot (SF)mixed-use "live, work,play"district. The Project consists of removing
approximately 92,320 SF of the existing 821,200 SF buildings,constructing 86,600 SF of vertical additions, and
constructing 890,700 SF of new buildings. The Project is estimated to be completed over a seven- to ten-year period.
The frrst phase (Phase I) will consist of redeveloping four existing buildings generally located at the northern and
southern most ends of the Site. These first four buildings are approximately 331,450 SF and will contain a mix of
office,residential,and industrial uses.Subsequent phases of development will be determined as the Project proceeds
and will include new structures to complete a full buildout of 1,706,150 SF consisting of approximately 915
residential dwelling units, 184,350 SF of commercial space and 260,900 SF of industrial use, and
WHEREAS:infrastructure work related to the full development of the Project will include the following: (1)
removing select buildings to create public courtyard areas and a network of open spaces and roads; (2)creating
pedestrian,bicycle, and vehicular connections throughout the Site from South Hill to Downtown Ithaca; (3)
improving the existing roads within the Site while creating new access points into the Site; (4)mitigating existing
environmental impacts from historic uses; (5)fostering the development of a link, the Gateway Trail, to the Black
Diamond Trail network; and (6) installing stormwater management facilities, lighting, public water and utilities,
landscaping and other Site amenities,and
WHEREAS:development ofthe Site is fostered by a proposed rezoning ofthe City portion of the Site into a Planned
Unit Development (PUD), and the Town portion into a Planned Development Zone (PDZ).Design Guidelines are
set forth in the proposed PUDIPDZ Zoning Code, and
WHEREAS:the Project Sponsor has also applied for Site Plan Approval from the Town of Ithaca Planning Board
and PDZ approval from the Town Board, and
WHEREAS:the Site is listed on the New York State Inactive Hazardous Waste Site Registry as a "Class 2 Site"
which indicates the property contains contamination that constitutes a significant threat to public health or the
environment.Implementation of the proposed Project will require remediation of contaminated portions of the Site
to an acceptable standard for the intended use, and
WHEREAS:this is a Type I Action under the City of Ithaca Environmental Quality Review Ordinance (CEQR),
§176-4 B. (1) (d), (i),G),(k) and (n), and (2), (3) and (6), and the State Environmental Quality Review Act (SEQRA)
(collectively,SEQR), §617.4 (b) (2), (3), (5)(iii) and (6)(ii)&(iv) and is subject to environmental review, and
WHEREAS:the Project requires approval from the City of Ithaca Common Council, the City Planning Board, the
Town of Ithaca Town Board, the Town of Ithaca Planning Board, the Tompkins County Department of Health, the
NYS Department of Health, the NYS Department of Transportation,and the NYS Department of Environmental
Conservation,and
WHEREAS:the City of Ithaca Common Council, the Town of Ithaca Town Board, the Town of Ithaca Planning
Board, the Tompkins County Department of Health, the NYS Department of Health, the NYS Department of
Transportation,and the NYS Department of Environmental Conservation,all consented to the City Planning Board
being Lead Agency for this Project,and
WHEREAS:the City Planning Board,acting as Lead Agency,made a Positive Declaration of Environmental
Significance on October 2,2014,directing the applicant to prepare a Draft Generic Environmental Impact Statement
(DGEIS)to evaluate potential impacts of the proposed Project,in accordance with SEQR,and
WHEREAS:on October 18,2014,the City Planning Board held a Public Scoping Session to identify issues to be
analyzed in the DGEIS,and
WHEREAS:the City Planning Board,after advertising a public comment period on the proposed scope, also solicited
written comments from involved and interested agencies and the public regarding the issues to be analyzed,and
WHEREAS:the City Planning Board did, on January 13,2015,approve a Final Scoping Document,and
WHEREAS:on January 26,2016 the Project Sponsor submitted a DGEIS to the City Planning Board,which v
examined possible environmental impacts,and
WHEREAS:the City Planning Board,did on March 8,2016,review the DGEIS for completeness and adequacy for
the purpose of public review and comment,and did,with the assistance of City staff and the City's special counsel,
Phillips Lytle LLP,find the DGEIS to be satisfactory with respect to its scope,content,and adequacy,and
WHEREAS:a Notice of Completion of the DGEIS and Notice of Public Hearing appeared in The Ithaca Journal on
March 18,2016 and the Environmental Notice Bulletin (ENE)on March 23,2016,and
WHEREAS:on March 29,2016,the City Planning Board held a public hearing to receive comments from the public
regarding potential environmental impacts of the proposed action as evaluated in the DGEIS,and
WHEREAS:due to extensive public interest in the Project and several requests made during the DGEIS public
hearing,the public comment period,originally scheduled to expire on May 10, 2016,was extended until May 25,
2016,and
WHEREAS:the City Planning Board has responded in the FGEIS to all substantive public comments received on
the DGEIS,and does on February 26, 2019 approve in substance the proposed responses to comments received on
the DGEIS,now therefore he it
RESOL VED,that the City Planning Board hereby issues the FGEIS for the Project,having duly considered the
potential adverse environmental impacts and proposed mitigating measures as required under 6 NYCRR 617 (the
SEQRA regulations)and Ordinance No. 90-13 ofCEQR,and be it further
RESOL VED,that the City Planning Board hereby directs the City of Ithaca Planning Staff to file a Notice of
Completeness of the FGEIS and issue the FGEIS as required under SEQR (6 NYCRR Parts 617.10 and 617.21 and
CEQR Part 36-10),and to distribute the FGEIS to all involved and interested agencies and the public .
Moved by:
Seconded by:
In Favor:
Against:
Abstain:
Absent:
Vacancies:
1
STATE ENVIRONMENTAL QUALITY REVIEW
CHAIN WORKS DISTRICT REDEVELOPMENT PROJECT
DRAFT FINDINGS STATEMENT
Pursuant to Article 8 of the Environmental Conservation Law (State Environmental Quality Review Act) and the
City of Ithaca’s Environmental Quality Review Ordinance (collectively, SEQR), and applicable implementing
regulations, the City of Ithaca Planning and Development Board, as Lead Agency under SEQR, makes the
following findings.
Name of Action: Chain Works District Redevelopment Project
Date: March 26, 2019
Lead Agency: City of Ithaca Planning and Development Board
108 East Green Street
Ithaca, New York 14850
Project Sponsor: UnChained Properties, LLC (UP)
Project Location: The Project is located on approximately 95 contiguous acres of land in central NYS,
South of Cayuga Lake in the Finger Lakes Region, and straddles the City and Town
border in Tompkins County (Site or Project Area). The Site is bounded as follows:
To the east, the Site follows South Aurora Street / NYS Route 96B, a major
transportation corridor that connects downtown Ithaca to South Hill, Ithaca College, and
the residential neighborhoods in the Town. It is a primary route for travelers from
Binghamton and points south.
To the north, the Site borders residential neighborhoods comprised primarily of single
and multifamily homes in the City.
To the west, the Site slopes steeply to meet Spencer Street in the City, then traces the
back of the residential properties lining the east side of Spencer Road. In the Town of
Ithaca, the property line traces the alignment of the former Lehigh Valley Railroad and
future Gateway Trail, as well as a large parcel of undeveloped land.
To the south, the Site borders the South Hill Business Campus in the Town.
Classification: Type I Action; Positive Declaration Issued; DGEIS and FGEIS Prepared
Contacts: Lead Agency: Project Sponsor:
Lisa Nicholas David Lubin
City of Ithaca Planning Department UnChained Properties, LLC
108 East Green Street 225 Colonial Drive
Ithaca, New York 14850 Horseheads, NY 14845
Phone: (607) 274-6550 Phone: (607) 739-3826
2
DESCRIPTION OF ACTION:
The Chainworks District (CWD) Project (Project or Preferred Alternative) is a proposed mixed-use
redevelopment of the 95-acre former Morse Chain/Emerson Power Transmission facility (Site) that traverses
the City and Town of Ithaca’s municipal boundary. The Site is located along the New York State Route 96B
corridor and where Turner Street and South Cayuga Street meets the northern edge of South Hill. The Project
involves the redevelopment and rehabilitation of the existing architecture and landscape into a 1.7 million
square foot (sf) mixed-use “live, work, play” district. Attached hereto as Attachment A is FGEIS Figure 2.3-2
Conceptual Site Layout Plan. The Project consists of removing approximately 92,320 sf of the existing
821,200 sf buildings, constructing 86,600 sf of vertical additions, and constructing 890,700 sf of new buildings.
The Project is estimated to be completed over a seven-to-ten year period. The first phase (Phase I) will consist
of redeveloping four existing buildings generally located at the northern and southern most ends of the Site.
These first four buildings are approximately 331,450 sf and will contain a mix of office, residential, and
industrial uses. Subsequent phases of development will be determined as the Project proceeds and will include
new structures to complete a full buildout of 1,706,150 sf consisting of approximately 915 residential dwelling
units, 184,350 sf of commercial space and 260,900 sf of industrial use.
Infrastructure work related to the full development of the Project will include the following: (1) removing select
buildings to create public courtyard areas and a network of open spaces and roads; (2) creating pedestrian,
bicycle, and vehicular connections throughout the Site from South Hill to Downtown Ithaca; (3) improving the
existing roads within the Site while creating new access points into the Site; (4) mitigating existing
environmental impacts from historic uses; (5) fostering the development of a link, the Gateway Trail, to the
Black Diamond Trail network; and (6) installing stormwater management facilities, lighting, public water and
utilities, landscaping and other Site amenities.
The development of the Site is fostered by a proposed rezoning of the City portion of the Site into a Planned
Unit Development (PUD), and the Town portion into a Planned Development Zone (PDZ). Design Guidelines
are set forth in the proposed PUD/PDZ Zoning Code. The PUD/PDZ Zoning Code is attached hereto as
Attachment B. The zoning and related Design Guidelines for the Project divide the development of the Site
into four (4) Sub Areas, each with its own set of Design Guidelines to focus the Project Sponsor’s vision for the
Project as an integrated whole. Sub Areas CW2 and CW3 were further enumerated into subsections, as
shown in FGEIS Figure 2.3-1 below.
The addition of subsections and building buffers are in response to comments received during the Generic
Environmental Impact Statement (GEIS) process, specifically regarding the character/size of the existing
residential structures adjacent to the Project and the additional need of a transition between the existing and
proposed structures along NYS Route 96B. The Sub Areas are defined as:
Natural Sub Area (CW1): A ± 23.9 acre conservation zone containing a mature Appalachian Oak-
Hickory forest to be used for passive recreation, generally located along the western portion of the Site.
Neighborhood General Sub Area (CW2): A ± 21.2 acre zone for clusters of new residential
development using a mix of housing styles and coinciding with primary points of access into the Site,
generally located at the southeastern end of the Site within the Town. The CW2 Sub Area is split into
subsections CW2A and CW2B. This allowed for the reduction from 6 to 4 stories in the CW2A in
response to GEIS comments.
Neighborhood Center Sub Area (CW3): A ± 39.7 acre zone for mixed uses ranging from residential to
industrial, using existing buildings at the core of the Site and clusters of new buildings at the northern
edge of the Site and along NYS Route 96B; all located in the City and Town. The CW3 Sub Area is split
into subsections CW3A, CW3B and CW3C in response to GEIS Comments. CW3A reduce the
maximum allowed above-grade stories from 6 to 4 and maximum allowed façade length from 180 feet
3
to 120 feet. CW3C also reduces the maximum allowed above-grade stories from 6 to 4 but also
prohibits below-grade stories.
Industrial Sub Area (CW4): A ± 10.3 acre zone for industrial uses centrally located on the Site using
existing buildings located in the City and Town.
FGEIS Figure 2.3-1 PUD/PDZ Sub Area Boundary Map (R+W)
Following a detailed design process with extensive public outreach and involvement, the Project Sponsor
unveiled a detailed conceptual site plan in October 2014. On October 20, 2015, the Planning Board issued a
positive declaration for the Project, requiring the preparation of a GEIS. The Lead Agency issued notices to all
then-known involved or interested agencies to solicit Lead Agency status for the Project on October 28, 2014.
The Project Sponsor then prepared a Draft GEIS (DGEIS), copies of which were made available for public
review. The DGEIS was accepted as complete by the Lead Agency on March 8, 2016, and a Notice of Public
Hearing appeared in the Ithaca Journal on March 18, 2016 and in the Environmental Notice Bulletin on March
23, 2016. A public hearing on the proposed Project was held on March 29, 2016. Due to extensive public
interest, the public comment period was extended from May 10, 2016 to May 25, 2016.
Many comments were received during the public comment period. Copies of all comments received are
provided in Appendices A and B of the Final GEIS (FGEIS), which also incorporates the DGEIS by reference.
Responses to every substantive comment received is provided in Chapter 3 of the FGEIS. Comments covered
the purpose and need for the Project, the alternatives considered, potential environmental impacts, and
mitigation measures, among other things. In light of the comments received, various changes were made to
the DGEIS. These changes are detailed in Chapter 4 and Appendix D of the FGEIS.
Final designs for less-defined, more conceptual Project phases and components, or any proposed changes to
the better-defined elements (collectively, Future Project Plans) will require further evaluation pursuant to
SEQR. The lead agency will be responsible for performing an environmental review on the Future Project
Plans proposed in relation to (i) the FGEIS and (ii) the Findings Statement. Once Future Project Plans have
been submitted to the lead agency, that agency must determine if the environmental impacts associated with
such Future Project Plans have been adequately addressed in the FGEIS and SEQR Findings Statement.
4
Additionally, the following reviews, permits and/or approvals are/were required to facilitate the proposed
Project:
SEQR: Preliminary Site Plan Approval of Conceptual Site Layout Plan and Final Site Plan Approval for
two Buildings (from the City of Ithaca Planning and Development Board)
Rezoning to a PUD (from the City of Ithaca Common Council)
Building and Demolition Permits; Certificate of Occupancy (from the City of Ithaca Code Enforcement)
Highway Work Permits; Water and Wastewater System Improvements Plan Approval (from the City of
Ithaca Board of Public Works)
Rezoning to a PDZ (from the Town of Ithaca Town Board) Preliminary Site Plan Approval of the
Conceptual Site Layout Plan and Final Site Plan Approval for two Buildings (from the Town of Ithaca
Planning Board)
Building and Demolition Permits; Certificate of Occupancy (from the Town of Ithaca Code Enforcement)
Water and Wastewater System Improvements Plan Approval (from the Tompkins County Department
of Health (TCDOH))
County Planning Review (from the Tompkins County Department of Planning (TCDP))
Highway Work Permit (from the New York State Department of Transportation (NYSDOT))
401 Water Quality Certification; State Pollutant Discharge Elimination System (SPDES) / Stormwater
Pollution Prevention Plan (SWPPP); (from the New York State Department of Environmental
Conservation (NYSDEC))
Water and Wastewater System Improvements Plan Approval (from the New York State Department of
Health (NYSDOH))
Federal and State Preservation (from the New York State Office of Parks, Recreation, and Historic
Places (NYSOPRHP))
Amendment to the current Record of Decision (ROD) to allow mixed-use development (NYSDEC)
Request for Boundary Modification to release southern portion of Site from Inactive Hazardous Waste
Disposal Site (IHWDS) Registry (NYSDEC)
5
FACTS AND INFORMATION RELIED UPON TO SUPPORT THE DECISION:
1. The City of Ithaca Planning and Development Board, as Lead Agency, conducted a coordinated review
pursuant to SEQR.
2. The City of Ithaca Planning and Development Board commenced the SEQR process for the Project in
October of 2014 by circulating a notice of intent to act as Lead Agency along with a Full Environmental
Assessment Form to all then-known Interested or Involved Agencies:
Involved Agencies
City of Ithaca (City)
City of Ithaca Board of Public Works
City of Ithaca Common Council
City of Ithaca Planning and Development Board (Lead Agency)
NYSDEC, Region 7
NYSDOH
New York State Department of Office of Parks, Recreation, and Historic Preservation (SHPO)
NYSDOT, Region 3
TCDOH
TCDP
Town of Ithaca (Town)
Town of Ithaca Town Board
Town of Ithaca Planning Board
Interested Agencies & Parties
South Hill Civic Association (SHCA)
Tompkins County Area Development
City of Ithaca School District
Community Advisory Group (CAG)
City of Ithaca Conservation Advisory Council (CAC)
City of Ithaca Bicycle/Pedestrian Advisory Council (BPAC)
City of Ithaca Shade Tree Advisory Committee (STAC)
Disability Advisory Council (DAC)
3. None of the Interested or Involved agencies objected to the City of Ithaca Planning and Development
Board acting as Lead Agency pursuant to SEQR and the City of Ithaca Planning and Development
Board was properly established as the SEQR Lead Agency for the Project in November of 2014.
4. Following a detailed design charrette planning process with extensive public outreach and involvement,
the Project Sponsor unveiled a detailed concept site layout plan for Chain Works in October 2014.
5. On October 2, 2014, the Lead Agency issued a positive declaration for the Project requiring the
preparation of the DGEIS.
6. Following issuance of the positive declaration, a Draft Scoping Report was issued. A Public Scoping
Meeting to solicit comments on the draft scope was held on October 18, 2014 and a Final Scoping
Document was approved on January 13, 2015.
6
7. Following issuance of the Final Scoping Document, the DGEIS was prepared by UP pursuant to the
requirements of SEQR. On March 8, 2016, the Lead Agency determined that the DGEIS was complete
and adequate for public review and scheduled a public hearing.
8. Copies of the DGEIS were made available for public review at the City of Ithaca Planning Department,
the Town of Ithaca Planning Department, the City of Ithaca Office of the Clerk and the Tompkins
County Public Library. A copy of the DGEIS was also posted on the CWD website.
9. A Notice of Completion of the DGEIS and Notice of Public Hearing appeared in The Ithaca Journal on
March 18, 2016 and the Environmental Notice Bulletin (ENB) on March 23, 2016.
10. A public hearing was held on March 29, 2016 at the Cinemapolis movie theater. Due to extensive public
interest in the Project and several requests made during the DGEIS public hearing, the public comment
period, originally scheduled to expire on May 10, 2016, was extended until May 25, 2016.
11. Notices of comment period extension were published in the Ithaca Journal, City of Ithaca Planning and
Development Board website and on the CWD website. Additionally, comments received after the end of
the public comment period prior to the issuance of the FGEIS have been accepted and responded to
within this FGEIS.
12. The FGEIS was issued on February 26, 2019 and a notice of completion of the FGEIS appeared in the
ENB on XXX.
13. The FGEIS was distributed to the Interested and Involved agencies and copies of the FGEIS were
made available for public review at The Planning Department at the City of Ithaca and the Tompkins
County Public Library – Central Branch. A copy of the FGEIS has also been posted on the CWD
website. Pursuant to SEQR, the FGEIS was held open and available for more than 10 calendar days in
order to afford agencies and the public a reasonable time period in which to consider the FGEIS before
the Lead Agency issued its written findings statement.
14. The Lead Agency has carefully and thoroughly reviewed the information contained in the DGEIS,
including all appendices and the comments to the DGEIS, and the FGEIS including all appendices
(collectively referred to as the GEIS). The Lead Agency finds that the GEIS provides a thorough
examination of all significant potential impacts that would result from undertaking the Project. The Lead
Agency has carefully reviewed, questioned and analyzed the various impacts of, alternatives to, and
potential mitigative measures for the Preferred Alternative and weighed these issues against the social
and economic benefits of the Preferred Alternative and other essential considerations.
15. The Lead Agency recognizes that qualified experts on any topic may differ in their conclusions and, in
particular, may differ in the judgments employed during analysis. Nevertheless, the Lead Agency has
carefully reviewed many hundreds of pages of documentation on the various issues that have been
submitted by government agencies, experts, interested stakeholders and the general public that reflect
hundreds of hours of examination of the Project during a SEQR process that has taken more than four
years. On balance, and after careful consideration of all relevant documentation and comments, the
Lead Agency believes it has more than adequate information to evaluate all the benefits and potential
impacts of the Project as a basis for considering whether to undertake the Project.
7
FINDINGS AND CONCLUSIONS SUPPORTING THE DECISION:
The GEIS provides a thorough and comprehensive analysis of the environmental, social and economic impacts
and details appropriate mitigation measures for the Preferred Alternative as well as the No Action Alternative,
Development in Accordance with Existing Zoning Alternative, and Maximum Development Alternative. A
summary of the relevant environmental impacts, facts and conclusions disclosed in the GEIS are described
below.
1. Land Use and Zoning
The GEIS examined the Project’s consistency with existing land use controls and local development
plans and policies to evaluate Project components alongside the visions for this area of the City and
Town. The predevelopment land use within the Site is industrial. The existing zoning for the majority of
the Site (64.37 acres) is classified as Industrial (I-1 in the City and I in the Town). The remainder of the
developable portions of the parcel is zoned medium density residential. The zoning for the adjacent
parcels is medium density residential except for the South Hill Business Park PDZ to the south of the
Site. The City of Ithaca adopted its Comprehensive Plan in September 2015 and PUD Zoning in
October 2014. The Town of Ithaca adopted its Comprehensive Plan in September 2014 and has been
using Special Land Use Districts (now called PDZs) since August 1984. There are currently 14 Special
Land Use (Mixed-Use) or PDZ districts within the Town of Ithaca.
Potential Impacts
The Project will create land use impacts in terms of both form and intensity of uses. The current
pattern of land use promoted by the existing land use regulations resulted in a large industrial
complex.
o The most substantial change in land use is the allowance for residential use where no
residential development is currently permitted.
o In terms of form, the existing zoning does not regulate the size, scale, massing or
disposition of buildings on the parcel in relationship to the surrounding land uses. In
contrast, the Project’s proposed PUD/PDZ Zoning Code will do so.
The most important potentially significant adverse impacts of a built-out landscape of
conventional zoning is the loss of the character along NYS Route 96B.
Existing zoning will be impacted by the Project through the rezoning of the Site as a PUD and
PDZ.
o Rezoning the City portion of the post-industrial Site as a PUD will allow the Project to
respond to and help implement planning and land-use concepts being set forth in the
City’s Comprehensive Plan which include the following impacts or opportunities:
Regional sprawl would be avoided by providing a mixed-use development that
bridges the City and Town, the Region, and Downtown.
Revitalizing the under-utilized Site with a mix of uses, including housing, would
extend and help implement the City’s goals to provide more housing and
revitalize the urban core.
Linkages between the City and Town, Ithaca College and Downtown, would be
strengthened by physically allowing the Site to be a link between them. This
would increase walkability and accessibility to Downtown, in turn reducing the
overall carbon footprint of the greater community.
A trail on the western side of the Site would link the Site and the City to a greater
network of trail connections within the City and beyond.
Natural areas will remain largely undeveloped to reduce stormwater runoff and
increase the acreage of environmentally valuable and sensitive areas.
o Rezoning the Town portion of the Site as a PDZ would allow the Project to respond to
the planning and land-use concepts set forth in the Town’s Comprehensive Plan, which
includes the following impacts or opportunities:
8
Sprawl would be avoided by providing denser clusters of housing with
significantly smaller footprints than other developments in the Town can offer.
Environmentally valuable areas would be preserved and protected as an amenity
for the neighborhood and surrounding community.
The CWD will promote human-scaled development and social connectivity within
the Project and around the community by providing a connection for the trail
network and between South Hill and Downtown Ithaca.
The new development will take on a cluster form avoiding environmentally and
visually sensitive areas.
CW1 Sub Area: This Sub Area is intended to remain undeveloped. With greater intensity of
uses adjacent to this Sub Area, there is a potential impact on the natural condition of this area
including the introduction of recreational trails bringing people within close proximity of a natural
area that has seen little human activity. There could be potential stormwater impacts in the
CW1 Sub Area as a result of the changes to intensity of land use in the CW2 Sub Area
upstream.
CW2 Sub Area: A potential impact on the surrounding natural areas could result from dense
residential development in what is currently an undeveloped wooded area.
o Having residential uses in close proximity to the CW1 Sub Area could increase the
amount of human activity within the natural wooded area.
o The increase in intensity of use will also impact the few off-site residential uses adjacent
to that area, but should have little effect on the commercial use to the south of the Site or
Ithaca College campus to the southeast.
o There will be a larger number of people moving by foot and by car between the Site and
the surrounding neighborhoods placing more stress on existing sidewalk and street
infrastructure.
CW3 Sub Area: A potential impact to the CW3 Sub Area includes impacts to the character of
the district and the relationship of new buildings and uses in close proximity to the existing
surrounding uses, specifically the Hillview-Turner place neighborhood.
o There will be a larger number of people moving by foot and by car between the Site and
the surrounding neighborhoods placing more stress on existing sidewalk and street
infrastructure.
CW4 Sub Area: The possibility of creating very large buildings with significant visual impact
exists by right without many restrictions in place.
Mitigation
The rezoning of the parcel to a PUD/PDZ with the establishment of Sub Areas and the adoption
of Design Guidelines will mitigate impacts to the form and intensity of land uses.
o Buffers will be maintained in areas adjacent to existing residential zones to control the
intensity of development.
o Form and intensity of uses will also be mitigated by following site plan review
procedures.
o Buildings within a 100-foot buffer along NYS Route 96B will be limited to a maximum of
four stories.
o In conjunction with the CWD PUD/PDZ Zoning Code approval, a Conceptual Site Layout
Plan will be submitted to the Town and City Planning Boards for preliminary site plan
approvals pursuant to §270-185 of the Town Code and §276-6 of the City Code.
o In the event a final Site Plan submitted for approval is not in substantial agreement with
the Conceptual Site Layout Plan and/or other Project thresholds are exceeded, the Town
and City Planning Boards - or whomever is the proper lead agency for the Project
component under consideration - will have the opportunity to determine whether such
changes warrant additional environmental review.
The Comprehensive Plans both describe the use of new mixed-use zoning as a tool to
implement shared land use goals for the Site.
9
The preservation of neighborhood is addressed through the development of the CWD PUD and
related Design Guidelines for the City and PDZ in the Town.
o In contrast to the existing pattern of development, the Project calls for compact
development, which integrates land uses, creates a strong multimodal network of streets
and paths, and makes for a more efficient use of infrastructure and existing services.
o The Design Guidelines will mitigate potential land use impacts by encouraging
development that will contribute to the CWD’s unique character. Moreover, the Design
Guidelines establish Site Plan Review procedures with specific regulations for the
district.
o The Design Guidelines have been prepared to provide clear and useful guidelines for the
design, construction, review, and approval of growth in the CWD. These standards will
help ensure that new buildings are compatible with either the existing historic industrial
buildings or the character of the immediate surrounding neighborhoods. The Design
Guidelines further address Site and building standards for each of the proposed Sub
Areas and identify site planning, thoroughfares, lighting, signage, and building design
requirements.
CW1 Sub Area: Retained a public passive recreation space. The Design Guidelines effectively
prevent the development of the CW1 Sub Area. There is no proposed specific mitigation for this
Sub Area because the preservation of this land as a natural area is in fact part of the proposed
mitigation for the other Sub Areas.
o Any potential buildings in CW1 would require design review by the Planning Board prior
to approval.
CW2 Sub Area: Allow the development of any Residential use. In response to DGEIS
comments, this Sub Area was split into two subsections.
o To the extent possible, the use of open space preservation techniques, such as the
clustering of dwelling structures, is encouraged for the undeveloped land within the Site
to mitigate impacts from dense development in other Sub Areas. This clustering
technique preserves the significant natural areas in the CW1 Sub Area and specific
designated trail linkages can be established to existing open space areas throughout the
Site during site plan review.
CW3 Sub Area: Same as CW2 (excluding detached dwellings) and including any Assembly,
Business, Educational, Factory, Mercantile or Storage use as defined by The Building Code of
New York State. This Sub Area was split into three subsections in response to DGEIS
comments. Buffers between the CW3 Sub Area and the existing residential uses are included in
the Design Guidelines to mitigate potential impacts from higher density uses in relatively close
proximity to lower density uses.
CW4 Sub Area: Any Business, Factory or Storage use as defined by The Building Code of New
York State.
2. Land
The GEIS examined the Project’s potential impacts to land for the 95 acre parcel including in-situ soils,
surface geology, and topography. Natural features of the Site include exposed bedrock along the
steeper slopes, and a heavily wooded area in the southern portion of the Site. The Site contains mostly
Lordstown series soils, similar to other hillsides in the area. The underlying in-situ soils have high
bearing capacity which makes the construction of buildings acceptable. The Site slopes steeply east-to-
west with the highest elevation, of approximately 800’, at the top of South Aurora Street and the lowest,
of approximately 440’, where the Site meets Spencer Street. Approximately 50% of the Site contains
slopes of less than 20%, which are deemed appropriate for development.
10
Potential Impacts
The Project will utilize standard cut and fill excavation methods during construction of the new
roads, parking areas and building pads. The potential option for grading of the Site estimates
68,000+ cubic yards of fill will be necessary to balance the Site.
o This bulk cut and fill estimate provides total volumes and does not account for
construction materials that are required to be imported nor does it include the void
volume required for below-grade structures such as storage and parking areas.
The amount of disturbance for Phase I is limited due to the intent to start initial occupation at the
Site in the buildings that require the least amount of preparation. The impacts associated with
the Phase I buildings are as follows:
o Building 21: Limited to the minor sidewalk and parking area restorations required to
occupy the building.
o Building 24: Limited to re-surfacing existing pavement areas and establishing pedestrian
access into the building from parking areas.
o Buildings 33/34: Depending on parking requirements of future tenant(s), the
development of the south parking areas which includes the demolition of the existing
metal storage building and construction of two parking areas.
As with all earthwork operations, the full development of the Project will expose soils which will
increase the potential for short and long-term erosion impacts and potential loss of sediment
from the Site.
o Short term erosion impacts are mainly due to the site construction phase.
o Potential long-term erosion impacts are due to improper construction techniques
including non-compliance with State Pollutant Discharge Elimination System (SPDES)
General Construction (GC) permit requirements for the stabilization of stockpiles or other
idled disturbed areas for periods exceeding 14 days as well as improper diversion of
stormwater flows through unstabilized areas of construction.
Potential impacts to adjacent parcels are anticipated to be limited due to the distance of the new
development from property lines. Other potential impacts include working in areas with
environmental concerns which are discussed in further detail under Public Health and
Environment.
Potential impacts for development beyond Phase I, listed by Zoning Sub Area, are as follows:
o Sub Area CW1: Impacts to soils and topography in the CW1 Sub Area are limited to the
sections where recreational trails or associated structures are constructed. Disturbance
due to the development of recreational features will be minimal. The largest potential
impacts to this Sub Area are due to the erosion potential associated with the
development of Sub Area CW2 located upgradient from CW1.
o Sub Area CW2: This Sub Area contains the potential for the most new development
within the Site and also the most potential impacts to Site soils and topography. CW2 will
be terraced to develop multi-family residential units configured in multiple stories that
benefit with the use of the sloping grades to construct structured parking under certain
residential buildings. Based on the previous geotechnical studies, it is anticipated that
blasting will not be required. Heavy construction equipment will be used to remove as
much of the fractured/weathered bedrock as feasible. If additional rock removal is
required, blasting may be necessary. The in-situ soils in CW2 are highly erodible.
o Sub Area CW3: The CW3 Sub Area consists mostly of terraced parking areas that will
be redeveloped for buildings, parking areas and roads. The portions of CW3 that are
anticipated to include new buildings and parking areas are uphill of the existing
developed portions of the core. The Conceptual Site Layout Plan was developed to
benefit from the existing terraced areas of the Site to limit total earthwork.
o Sub Area CW4: Impacts to CW4 are limited to the potential construction of two parking
areas that total less than 1 acre of disturbance. This is a minor amount of disturbance
and would normally not require a NYSDEC SPDES GC permit. However, since this is
11
part of a plan of common development, a full SWPPP will be required for this portion of
work.
Mitigation
Future development of new areas will be located primarily in areas with slopes less than 20%.
Sub Area CW1, which contains areas with slopes greater than 20%, will be preserved.
Development will be relocated away from areas with unstable soils.
o Such topographic restrictions on future development minimizes erosion and potential
impacts to topography while reducing the amount of cut and fill required.
The Conceptual Grading Plan prepared with the goal of balancing the amount of cut and fill
minimizes the import/export of materials to and from the Project.
o Detailed grading plans of each subsequent phase will be developed to mitigate the
excess fill requirements.
o Subsoils will be tested by a certified laboratory.
o Construction specifications will be developed based on the laboratory analysis and
recommendations of the geotechnical testing firm.
Side slope grades of all cut and fill areas are set to minimize the potential for future erosion.
Phase I Site Plan drawings include an existing conditions survey performed by a NYS Licensed
Surveyor.
o Subsequent Site Plans will also include existing conditions surveys.
Grading and Erosion Control plans and geotechnical reports for subsequent phases will be
developed during the Site Plan approval process.
Demolition and Grading Plans will be developed as part of all Site Plan submissions.
o Grading plans will be developed to balance cut and fill requirements with the desig n
intent of disposing of all excess material on-site.
o Excess soils created by the excavation for below-ground structure parking and storage
levels will be utilized as fill around adjacent structures and, if suitable, in pavement
areas.
o Complete construction specifications for earthwork and erosion control will be developed
for each phase.
Coverage under the NYSDEC SPDES GC Permit (GP-0-015-002) for erosion and sediment
control will be obtained. A SWPPP will be developed, and will require or implement the
following:
o Specific limits of disturbance (LOD) will be defined for each Phase to maintain impacts
within the permitted area.
o Develop Erosion & Sediment Control Plans as part of all Site Plan submissions.
o Minimize stream impacts from erosion by minimizing earthwork within 50 feet of the
banks as well as protecting from excess stormwater runoff during construction.
o Minimize the areas of disturbance for slopes exceeding 20%. Maintain those areas in a
vegetated state to the maximum extent practicable.
o Determine slope stability by a qualified engineer for development of slopes in excess of
3:1. Retaining walls, turf reinforcement mats or other Best Management Practices
(BMPs) will be designed by a qualified engineer for slopes exceeding 3:1.
o Inspect for site stabilization by a qualified inspector as part of the SPDES GC Permit to
achieve the same.
o Obtain written approval from the MS4 prior to the disturbance of five acres or more at
any one time.
o Obtain certification by a licensed professional engineer that attests to the construction
and implementation of the SWPPP upon completion of the site construction portion for
the individual phases.
Follow any applicable excavation management plan approved by NYSDEC to manage
appropriately any impacted soils encountered during construction.
12
If necessary, a system of controlled blasting would be specified that includes methodology,
mitigation and monitoring requirements.
o The blasting specifications will be developed in accordance with NYSDOT Geotechnical
Engineering Manual: Procedure for Blasting.
o All Local, National Fire Protection Association (NFPA), Occupational Safety and Health
Association (OSHA) and NYS Department of Labor (NYSDOL) requirements will be
followed.
o A written blast plan will be developed and pre-operations meetings will be conducted
with the Project Sponsor, Engineer, Contractor, and City and Town Staff.
3. Water Resources
The GEIS analyzed the impacts to water resources that would be associated with each of the
alternatives. In particular, the GEIS analyzed the potential impacts associated with stormwater
management, groundwater and hydrogeological conditions. There are three unnamed tributaries that
converge and run east-to-west within the Site to Six Mile Creek, which is located approximately 500
feet to the northwest of the Site. No other surface water or ephemeral water features are known to exist
on the Site. There are no Federal or State mapped wetlands inventoried on the Site. No wetlands were
encountered on field walks in the developable areas of the Site. Groundwater at the Site includes a
shallow fractured bedrock horizon and a deeper, competent bedrock in which groundwater resides in a
fractured vertical network. Groundwater may also be found in certain locations within the thin
overburden and fill material located throughout the Site. Pockets of “perched” groundwater can be
encountered in the overburden areas. On-Site stormwater infrastructure is in place from previous
development, all of which predate current State, Local, and Federal stormwater regulations.
Potential Impacts
Surface Water and Hydrogeological Setting: It is anticipated that there will be four crossings of
the unnamed tributary proposed for the Project, all in CW2, that could result in impacts typical of
crossing intermittent streams without proper mitigation. Such impacts include erosion or bank
destabilization resulting in blockage or redirection of flow through the stream.
o Even though the potential of on-Site flooding is minimal because of topography and
existing grades, the increased amount of impervious surfaces will consequently increase
stormwater peak runoff rates that potentially will impact downstream stormwater
conveyance systems.
o The total volume estimated during the 100-year design storm event increases by 2.992
acre-feet. Even assuming no infiltration or evapotranspiration, the potential increase in
the water surface elevation for Cayuga Lake is immeasurable (0.00084 inches).
o Additional potential impacts include erosive velocities of peak runoff rates depending on
the discharge location.
Groundwater: The Phase II ESA indicates areas of perched groundwater due to the on-Site
bedrock. This will potentially impact structures with subgrade levels, specifically structured
parking.
o Construction may be potentially impacted by high groundwater or perched pockets of
groundwater that may be experienced at various locations.
o Groundwater may impact the design of the foundation including the selection of
materials as well as construction methods.
o Groundwater dewatering may also impact downstream drainage structures. Because of
the impacts to groundwater from historic uses, special handling of groundwater at certain
locations on the Site may be necessary.
Stormwater: The creation of impervious surfaces is the main cause of increased stormwater
runoff rates and impacts to stormwater quality.
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o There are numerous existing catch basins and stormwater sewers to collect and
transport stormwater runoff along with grass swales. The full extent of the system and its
connection and outfalls are currently unknown.
o The Conceptual Site Layout Plan anticipates an increase of impervious surfaces of 11.2
acres (from 17.3 acres to 28.5 acres). The Project will maintain 35.75 acres, or 37% of
the Site, as pervious.
o The runoff flow and volume estimates for POS-A are anticipated to increase by
approximately 5% due to the utilization of the green areas adjacent to SR 96B.
o POS-B through POS-D consists of areas that are mostly redevelopment and are likely to
see negligible differences in the estimated runoff rates and storm volumes.
o POS-E, which includes all of zoning Sub Area CW1 and CW2, will be the area with the
most new development and therefore will have the greatest increase in stormwater
volume. The runoff rates for drainage Sub Areas E-3 and E-4 will peak higher but earlier
in the storm period. This will actually reduce the total peak stormwater runoff rates for
POS-E due to the much larger upstream area (Sub Areas E-1 and E-2).
Mitigation
The Town Code defines required setbacks for development along streams. A total setback of 50
feet for any new development along a stream will be maintained for this Project as required by
Town Code within the entire Site.
All stream crossings will be designed in accordance with NYSDEC standards.
The Generic SWPPP for the entire Site and SWPPPs for individual phases will provide specific
mitigation for surface water/hydrogeological resources.
Stormwater quantity and quality mitigation may include the following:
o The addition of more diversion swales.
o Use of the guidance for redevelopment projects in the NYS SWMDM Chapter 9.
o Runoff reduction practices in accordance with the NYS SWMDM Chapter 3.
o Utilization of traditional stormwater infrastructure such as curb, gutter and storm sewers
for collection/conveyance.
o Mitigation of stormwater velocity to insure protection from erosive flows including proper
groundcover protection (biological as well as structural).
o Green infrastructure mitigation which may include bioretention, planters, rain gardens,
green roofs, and other infiltration practices depending on the suitability of the in-situ soils
to mitigate both stormwater quantity and quality impacts.
o On-Site storage and reuse of stormwater flows as reduction practices such as
repurposing the on-Site underground water storage tanks near Driveway III or creation of
a new storage area in Sub Area CW2.
Alternative stormwater quality mitigation practices known as hydrodynamic systems such as
gravity and vortex separators will also be considered during site plan approval.
All existing stormwater utility structures will be mapped in accordance with the SWPPP.
All new stormwater facilities will be designed in accordance with the most current version of the
NYS Stormwater Management Design Manual.
Stormwater facilities will be reviewed for capacity during individual site plan reviews.
The NYSDEC will issue a ROD Amendment that identifies the required remedial work to support
mixed-use development and address previously unidentified potential impacts to groundwater
and stormwater from existing contamination in compliance with the Inactive Hazardous Waste
Site Program regulations and guidance documents. Typical remedial approaches associated
with any impacts to groundwater include:
o Excavation and off-Site disposal of source area materials to reduce or prevent
contaminants from impacting stormwater and groundwater.
o Capture/treatment of impacted surface or groundwater.
o Solidification/stabilization or capping of impacted soils to reduce or eliminate leaching.
o In-situ chemical treatment of impacted soil and/or groundwater.
14
o Routine monitoring of groundwater.
o Implementation of any applicable groundwater management plan approved by NYSDEC
for groundwater encountered during construction.
The proposed Phase I mitigation is depicted on the Site Plan Drawings and includes:
o Reduction of impervious areas within the Phase I project limits.
o Rehabilitation of existing stormwater collection system in the existing road and parking
areas in the Phase I Project limits.
o Construction of stormwater collection systems in new parking areas.
o Conservation of natural areas directly adjacent to Phase I.
o Installation of rain gardens and/or bioretention areas in and adjacent to parking areas.
4. Vegetation and Fauna
The existing vegetation and fauna on the Site have been surveyed as part of the GEIS. Seventy-seven
acres, or approximately 80% of the Site, are currently forested (34 acres/35%) or vegetated state (43.7
acres/45.5%), while 17.3 acres, or 20%, are comprised of buildings, roads, and other impervious
surfaces. The New York State Natural Heritage Program (NYSNHP) was consulted to obtain a
summary of rarities found in the Site vicinity. A qualified biologist was unable to find any of these, or
any other species, listed as Rare, Threatened, Special Concern, or Endangered in NYS by NYSNHP or
NYSDEC within the Site.
Potential Impacts
There are potential impacts to plant and wildlife habitat, particularly with regard to the removal of
some plants and habitat areas for the construction of the proposed new development.
The Conceptual Site Layout Plan anticipates an increase of impervious surfaces of 11.2 acres
(from 17.3 acres to 28.5 acres).
o The vegetated area will decrease by approximately 11.2 acres, resulting in an impact to
existing permeable surfaces. A majority of this decrease is planned to occur in areas
containing invasive plants identified throughout the Site, resulting in fewer quantities of
invasive species on Site. The Project will maintain 35.75 acres, or 37% of the Site, as
pervious.
With the reduction of vegetated areas, wildlife habitat may also be impacted. The qualities of
forested areas vary, with some being highly disturbed.
As a result of development in CW2, CW3, and CW4, fauna found in these zones of lesser
habitat quality will be displaced, likely relocating to CW1 where forests containing higher habitat
quality will be preserved. Development may have an impact on the native deer population.
o DGEIS Table 5.4-1 describes the acreage of vegetative cover lost in each Sub Area as a
result of the Project:
Sub-Areas Existing Area
(Acres)
Developed Area
(Acres)
Change
(Acres)
Change
(%)
CW1
Appalachian Oak-Hickory 16.68 16.68 - 0.00%
Successional Forest 7.18 7.18 - 0.00%
Total 23.86 23.86
CW2
Appalachian Oak-Hickory 6.23 2.83 (3.40) -54.57%
Successional Forest 0.33 0.26 (0.07) -21.21%
Successional Old Field 14.61 2.51 (12.10) -82.82%
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Lawn / Garden - 6.71 6.71
Impervious - 8.86 8.86
Total 21.17 21.17 -
CW3
Successional Forest 14.47 9.67 (4.80) -33.17%
Successional Old Field 0.40 0.12 (0.28) -70.00%
Formerly Cult. Successional Forests 2.71 0.89 (1.82) -67.16%
Lawn / Garden 3.65 10.99 7.34 201.10%
Impervious 18.50 18.06 (0.44) -2.38%
Total 39.73 39.73 -
CW4
Appalachian Oak-Hickory 0.13 0.13 -
Successional Forest 4.14 2.72 (1.42) -34.30%
Formerly Cult. Successional Forests 0.42 0.11 (0.31) -73.81%
Lawn / Garden - 1.37 1.37
Impervious 5.58 5.94 0.36 6.45%
Total 10.27 10.27 -
Entire Parcel
Appalachian Oak-Hickory 23.04 19.64 (3.40) -14.76%
Successional Forest 26.12 19.83 (6.29) -24.08%
Successional Old Field 15.01 2.63 (12.38) -82.48%
Formerly Cult. Successional Forests 3.13 1.00 (2.13) -68.05%
Lawn / Garden 3.65 19.07 15.42 422.47%
Impervious 24.08 32.86 8.78 36.46%
Total 95.03 95.03
The following describes what forest types will be impacted through full, partial, or selective
removal resulting from the Project by Sub Areas:
o CW1: Appalachian Oak-Hickory forest is a native, older growth forest containing high-
quality species and ecological habitat. All of this forest type located within CW1, which
constitutes 16.68 acres of the total 23.04 acres, or approximately 72.4% of this forest
type on the Site, will be preserved.
o CW2: This Sub Area consists of two types of vegetative cover:
Successional Old Field consisting of successional shrubs and young trees. The
make up of this vegetative cover largely consists of invasive species as is
typically found on disturbed sites. Portions of this vegetative cover will be fully
removed where new development will occur, and other areas will be selectively
removed and replanted as an open space amenity for CW2.
Appalachian Oak-Hickory as described in CW1 is in the north to northwestern
portions of this Sub Area, encompassing approximately 6.23 acres. A portion of
this vegetative cover is likely to be disturbed by proposed development in CW2.
o CW3: This Sub Area consists of three types of vegetative cover:
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Successional Forests, which are characteristic of disturbed sites, consisting
largely of invasive and pioneer species. These areas are located in the eastern
area of CW3. This forest type is also located around the existing structures in
CW3.
Formerly Cultivated Successional Forest containing species that have been
cultivated in the past and have naturalized and become invasive. Some species
include Barberry and Norway Maples. These zones are largely located at the
junction between single-family homes and the Site. This vegetative cover is
found in the area around Building 21.
Maintained Lawns/Garden Areas are largely lawns with some cultivated plants.
This vegetative cover is found in the northeastern area of CW3.
Portions of the vegetative cover described above will be fully removed where
new development will occur, and other areas will be selectively removed and
replanted as an open space amenity for CW3.
o CW4: Successional Forests, as described in CW3 above. This vegetative cover is found
around the existing structures in CW4. As with CW3, portions of this vegetative cover will
be partially or selectively removed in area will the redevelopment of the existing
structures will occur.
Mitigation
Forested and cultivated areas on portions of the Site, which have historically been disturbed,
are of poor quality and contain numerous invasive species. Although new impervious areas will
be constructed, abandoned existing impervious areas – walks, parking lots, and stairs – that no
longer serve a purpose, will be removed and replaced with vegetated areas of higher quality.
Phase I is designed to minimize impacts to the existing trees, however there are some removals
necessary. A majority of trees which will undergo removal are either invasive or naturalized
species with little ecological value for native habitats.
o A detailed tree survey will be performed when development occurs in conjunction with
site plan review to minimize impacts to older trees.
Mitigation for an increase of the Site’s impervious area resulting from the Project includes the
designation of a portion of the Site as a new Sub Area known as CW1.
o The Project Sponsor is willing to offer mechanisms such as appropriate deed restrictions
or conservation easements to memorialize the dedication of the CW1 Sub Area. A
majority approximately 72% of the high quality Appalachian Oak-Hickory forest is located
in the CW1 Sub Area, and will be preserved as an amenity and recreational area.
o The designation of the CW1 Sub Area will minimize disturbance in an area with high
quality native vegetation, provide the means for the development of long term
conservation plans in specified areas of the Site, and landscape and tree preservation
standards.
o Any wildlife that may be disturbed due to the development of other Sub Areas will likely
relocate to CW1 where forests containing higher quality habitat will be preserved. Under
the rezoning of the Site, this area is to be maintained as natural forest that will be
preserved in perpetuity.
o Additional trails will be developed to allow the recreational and educational use of the
higher quality forested CW1 Sub Area.
5. Public Health and Environment
The GEIS evaluated potential impacts to public health and the environment that the Project and each of
the alternatives may have due to existing contamination. The existing very comprehensive
environmental investigation data generated by the property owner and the Project Sponsor provide
sufficient data to analyze potential significant impacts from identified areas of concern (AOCs) as a
17
result of the Project and the alternatives as well as an analysis of mitigation measures to protect human
health and the environment from impacts that may arise from redevelopment of the Site.
Potential Impacts
Multiple AOCs were found to have contaminants exceeding their relevant cleanup standards for
soil and groundwater, including but not limited to Trichloroethylene and other VOCs, arsenic,
barium, cyanide, polychlorinated bi-phenyls, and petroleum products. If not addressed over time
these contaminants can have impacts to public health and the environment.
o Specifically, impacts in soil can leach to groundwater or if within the surface soil can be a
potential contact issue for people on site or off site if erosion occurs.
o Impacts in subsurface soils can be a concern in the event the future ground intrusive
work encounters those impacts and they are not properly handled.
o Impacts in groundwater can migrate off-Site and can present in surface water down
gradient in locations where bedrock fractures outcrop at the surface creating seeps.
o Volatile Organic Compounds (VOCs) impacting soils or groundwater beneath a building
can impact indoor air through soil vapor intrusion.
The Lead Agency understands that in anticipation that the Project will move forward in a manner
consistent with the Conceptual Site Layout Plan, NYSDEC has approved an Interim Remedial
Measure (IRM) Work Plan using, in some instances, the Soil Cleanup Objective (SCO) that
applies to the proposed use of an area based on the Conceptual Site Layout Plan. In other
instances, the Protection of Groundwater SCO is proposed.
o As part of implementing the IRM, select locations along the sanitary sewer lines will be
investigated to assess pipe integrity and potential impacts in soil beneath or adjacent to
the sewer lines.
o Any areas where soil impacts exist above the applicable SCOs will need to be
remediated.
The Lead Agency further understands that the property owner performed a Boundary
Reassessment Study that assessed conditions on the 36.76 acre undeveloped portion of the
Site to the south of the creek that runs east/west across the Site and produced evidence that
prior operations and/or disposal did not take place in that area. As a result, NYSDEC realigned
the IHWDS boundary to exclude that southern portion of the Site from remedial requirements of
the IHWDS Registry. Because of the presence of soil vapors in the vicinity of the sewer lines
running through that portion of the Site, the property owner filed a declaration of covenants and
restrictions requiring that the potential for soil vapor intrusion be addressed to the satisfaction of
NYSDEC and NYSDOH whenever any habitable structures are built within an 80 feet wide area
around the sewer lines.
The current Record of Decision (ROD) calls for the Site to be remediated to allow only for
industrial use. Therefore, NYSDEC will need to amend the ROD to allow for the proposed mixed
uses at the Site contemplated under the Project. The requirements for remediating the Site will
be more stringent for mixed-use with a residential component than industrial or commercial uses
alone. As a result, the Project will improve the existing impacts from the Site’s historic uses and
the Preferred Alternative will be more beneficial from a public health and environment
perspective than the No Action Alternative and the Existing Zoning Alternative.
This more stringent cleanup will mitigate impacts to the environment, public health, and
surrounding residences by: (1) completing the remediation of more contaminants for a mixed-
use than under an industrial use; (2) addressing previously unknown contaminants thus
significantly reducing the potential for migration downgradient and impacting the surrounding
community and environment; and (3) establishing proper management of the Site over time.
Specifically, for soils, the following AOCs will have to be addressed:
o Former department 507 Degreaser Area (AOC1).
o Building 24 area (AOC26).
o Former salt baths area (AOC27).
o Building 30/oil shed area (AOC28).
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o Former propane storage area (AOC29).
o Rice paddy area (AOC30).
o Upper Parking Lot 6 area (AOC31).
o Former spray pond area (AOC32).
o Area east of Buildings 13A and 14 (AOC34).
o East of Building 24 (AOC35A).
o Building 11A (AOC35C).
o Near Parking Lot 4 (AOC35D).
o South of Parking Lot 3 (AOC35G).
o Parking Lot 3 (AOC35H).
o Former railroad right-of-way (LBA-SB-240) (AOC35K).
o Former railroad right-of-way (DS-1) (AOC35L).
If the No Action or Existing Zoning alternatives were to be implemented only the industrial use
and, in some instances, the protection of groundwater SCOs would apply leaving the following
AOCs not remediated or remediated to a lesser extent for soils:
o AOC29
o AOC31
o AOC32
o AOC35A
o AOC35G
o AOC35H
o AOC35K
o AOC35L
Additional environmental issues that will need to be addressed to a greater degree than under
the No Action or Existing Zoning alternatives include:
o Vapor intrusion for VOCs for existing buildings that will be routinely occupied.
o Vapor intrusion for VOCs for any habitable structures to be built in the vicinity of the
NCR sewer or Ithaca College sewer lateral within Sub Area CW2 and an eastern portion
of CW3.
Construction for the Project will encounter impacted soil and fill materials. These activities have
the potential to impact the on-Site workers or the environment if not properly handled.
Specifically, the Project may incur the following impacts:
o General construction activity creating dust which could have contaminants such as
heavy metals or SVOCs.
o Excavations within areas of soil impacted with VOCs could create vapor emissions.
o Dewatering to support excavations could result in the discharge of contaminated
groundwater to surface soils, surface waters and/or the sewer system.
o Construction workers could come into contact with impacted media.
o Construction vehicles could transport impacted media off-Site to unregulated areas.
o Stockpiled soils exposed to precipitation could transport contaminants through runoff.
Typical remedial approaches discussed in the GEIS include:
o Excavation and off-Site disposal of impacted soils, which has been and is currently being
implemented by an IRM for 16 AOCs and previously employed for PCB impacted soils
around a former transformer pad.
o Placing a barrier or cap above soil/fill materials impacted with contaminant
concentrations above the applicable SCOs. Again, a technique currently being
implemented as part of a NYSDEC approved IRM.
o Solidification/stabilization of impacted soils.
o In-situ chemical treatment of impacted soil and/or groundwater.
o In-situ or ex-situ thermal treatment of soil and/or groundwater.
o Extraction and treatment of impacted groundwater and/or soil vapor.
o Routine groundwater monitoring.
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o Sub slab depressurization (SSD) systems and/or pressurization monitoring of buildings
for mitigation of potential soil vapor intrusion.
Mitigation
An amendment to the existing ROD must be approved by NYSDEC. The amendment will
facilitate development of the Site in a manner that protects public health and the environment
under a mixed-use redevelopment scenario with a residential component.
The specific final remedy or remedies at the Site will depend on the contaminant type, location
and impacts to groundwater. The pros and cons of each remedial approach will be evaluated as
part of the study of remedial alternatives that will be presented in a feasibility study and
reviewed by NYSDEC in a separate regulatory process that results in the further amendment of
the ROD. Specifically:
o A feasibility study evaluating remedial approaches will be completed by the property
owner for review and approval by NYSDEC. Following NYSDEC approval, all necessary
remedial work will be completed to the requirements of the use for the specific area
being developed or which will be affected by development.
o All disturbances of soil (e.g., construction of new buildings, renovation of existing
buildings, and/or utility work) within Sub Areas CW3 and CW4 and that portion of CW1
north of the creek that runs generally west to east across the Site will require the
implementation of an SMP and associated Excavation Work Plan, Groundwater
Management Plan and a Community Air Monitoring Plan (CAMP)
All such work would require an Environmental Monitor to complete appropriate
oversight and management/characterization of disturbed materials. This includes
continuous air monitoring for VOCs and fugitive dust, monitoring excavations for
potential impacted media, sampling of all water and soil generated, stockpiling
soils on plastic and covering with plastic until the final disposition of materials are
determined and approved by NYSDEC.
These measures will address concerns related to VOC emissions, transport of
impacted media off-Site, fugitive dust and run-off.
All work will be done by appropriately trained personnel, under oversight by an
environmental monitory and with NYSDEC approval.
The Site must be: (1) remediated to restricted residential, commercial and/or industrial SCOs,
as appropriate based on the proposed uses at the Site, or to protection of groundwater
standards if a particular area of the Site experiences impacts to groundwater above relevant
standards; (2) subject to groundwater treatment and/or monitoring in those areas where
groundwater impacts exceed applicable standards; (3) subject to appropriate use restrictions
consistent with the proposed uses at the Site; (4) subject to appropriate prohibitions on the use
of groundwater at the Site without approval from NYSDEC; (5) subject to development and
implementation of an appropriate Site Management Plan (SMP); and (6) subject to on-going
monitoring that institutional and/or engineering controls are being properly implemented and/or
maintained.
An SMP will be developed by the property owner and approved by NYSDEC after completion of
the IRMs and issuance of the amended ROD which will set forth engineering and institutional
controls for that portion of the Site north of the creek that remains on the IHWDS Registry.
o The SMP and its components will be used to facilitate redevelopment and be amended
as needed subsequent to installation of additional remedial systems and completing all
remediation activities at the Site.
o Implementation of an SMP will assure that the IRMs and other remedial actions selected
through a feasibility study and amendment of the ROD will remain functional and
effective.
o Regular inspection of the caps, soil covers, and permanent erosion controls (e.g., gravel
and vegetation) will identify potential problems and allow maintenance actions to be
taken before more serious issues arise.
20
o An inspection procedure and frequency will be developed as part of the SMP to record
and track Site conditions. Repair and maintenance procedures will be described to
restore the deficiencies to the desired conditions. The plan will include routine
maintenance activities such as sealing of asphalt cracks.
o The SMP will identify locations where contamination remains and will include procedures
for assuring the institutional controls remain in place and effective.
o An excavation work plan will address proper management of soils and groundwater that
may be encountered during any future ground intrusive activities. These plans will
provide the process by which one properly manages both known and any unknown
contamination that may be encountered during ground intrusive activities and require
monitoring of such activities by an environmental professional.
o In addition to soil excavation and groundwater management, the SMP will contain a
CAMP, and operation, monitoring and/or reporting requirements specific to the remedial
alternatives selected by NYSDEC for the Site.
o Finally, the SMP will contain operation, maintenance and monitoring requirements for
treatment systems and/or monitoring programs for groundwater treatment systems or
soil vapor intrusion systems that may be employed at the Site as part of the final remedy
along with a schedule of regular reporting on the activities conducted under the SMP to
NYSDEC.
o Enforcement of the SMP requirements will be through the filing of an environmental
easement covering the Site.
Areas of impacted concrete (Buildings 4, 8, 13A, 14 and 34) will require remediation which will
most likely take the form of removal or capping.
In the event air monitoring indicates fugitive dust or VOCs, appropriate vapor and/or dust
suppression actions will be taken.
Occupation of existing buildings and construction of new ones in the CW3 and CW4 Sub Areas
will require the Project Sponsor to address the potential for soil vapor intrusion via mitigation
and/or monitoring. Specifically, for the Preferred Alternative this includes:
o Mitigation of Buildings 1, 2 (basement portion), 3, 4, 5, 6 and 6A (remaining portions), 8,
9,10, 18, 21, 24, 33 (remaining portions) and 34.
o Monitoring of Buildings 13A and 17.
o Building 2 (upper portion) would require additional analysis to determine whether
additional actions are required to reduce exposure as part of the feasibility study.
o Evaluation of areas designated for new construction in CW3 and CW4 Sub Areas for the
potential for soil vapor intrusion followed by NYSDEC and NYSDOH approval.
o Compliance with the Declaration of Covenants and Restrictions that requires evaluation
of areas designated for new construction in the CW2 Sub Area for the potential for soil
vapor intrusion when habitable structures are planned to be constructed in the vicinity of
the former NCR and Ithaca College sewer lines.
Filing and compliance with an environmental easement that: (i) restricts the use of the portion of
the Site still on the IHWDS Registry to Restricted Residential, Commercial and Industrial uses
(as those terms are defined by the relevant NYSDEC regulations); (ii) restricts the use of
groundwater without NYSDEC approval; and (iii) requires the implementation of an SMP.
The property owner has commenced NYSDEC approved IRMs to address 16 different AOCs at
the Site based upon cleanup objectives consistent with the Conceptual Site Layout Plan. All
approve IRMs will be completed in compliance with NYSDEC-approved plans.
Mitigation also includes development of emergency action plans and compliance with
Community Right to Know requirements by tenants using hazardous substances.
o Pre-demolition/rehabilitation surveys will be performed during each phase of
development on those buildings where warranted based upon historical use, visual
evidence, and prior investigation results to further assess the need for special
management of demolition debris.
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6. Historic and Archaeological Resources
The GEIS evaluated the potential impacts on Cultural Resources listed on or eligible for listing on the
State or National Register of Historic Places (“S/NRHP”) in and in the vicinity of the Project Area. This
included evaluating potential effects to architectural and archaeological resources. A Determination of
Eligibility (DOE) was prepared for the Site for review by the New York State Office of Parks, Recreation,
and Historic Preservation (NYSOPRHP) to determine whether the above-ground historic architectural
resources are eligible for listing on the National Register of Historic Places. The Site has been
determined eligible for the National Register of Historic Places. A Phase 1A archaeological survey was
conducted under the supervision of a Registered Professional Archaeologist and in accordance with the
NYSOPRHP’s Phase 1 Archaeological Report Format Requirements. Archaeological investigations did
not result in information that would significantly add to the understanding of the construction, function,
or use of the manufacturing facility and no additional archaeological investigations were recommended.
Potential Impacts
In order to bring air and light into the redeveloped complex, and provide sufficient space for
circulation, selective demolition is planned, potentially resulting in impacts to the existing
structures through partial or full removal. These buildings are: Buildings 3A (1920s), 4A
(1920s), portions of 6 (1950s) and 6A (1940s), 8A (1920s), 9 (1900s), 10A (1940s), 11A (1940s)
and 14(1940s).
Mitigation
Currently the Project Sponsor is not seeking historic tax credits as originally considered during the
DGEIS process. Subsequent consultation with NYSOPRHP determined that the redevelopment of the
buildings as mixed-use structures utilizing the Architecture 2030 goals precluded coverage under the
historic tax credit system. The change of use and redevelopment of the existing buildings in
accordance to current energy/buildings codes will take precedence over the following historic
mitigation:
The Project Sponsor is pursuing a variety of options to retain the historical character and
significance of the CWD by retaining key individual structures, including the pre-1965 portions of
the factory building (all sections except 13B, 34 and 35), the Office Building (21), and the
Office/Commercial Building (24), to mitigate any potential impacts to the existing structures
resulting from the selective or full demolition of buildings.
The Secretary of the Interior’s Standards and Guidelines serve as a methodology to identify,
document, and evaluate which existing structures and areas within the Site are appropriate for
preservation and rehabilitation. These guidelines help determine how best to accommodate
building removal, how best to maintain/rehabilitate significant structures, and which how to
integrate complementary (adjacent and out-lying) new development. The Project Sponsor has
and will continue to employ these guidelines where feasible.
Pursuing certification by the USGBC for LEED ND, a framework for identifying, implementing,
and measuring green building and neighborhood design.
o Credits 6 and 7 require the retention of at least 20% of the surface of historic buildings
except when authorized by the Ithaca Landmarks Preservation Commission and/or
NYSOPRHP and to the extent allowed while maintaining compliance with applicable
energy codes and goals set forth under Utilities and Effects on the Use and
Conservation of Energy Resources.
Restoring and/or rehabilitating existing structures-to-remain in a way that preserves, reflects,
enhances and promotes the inherent historic and architectural significance of these selected
buildings.
Cleaning and repairing existing exterior walls as individual buildings are redeveloped and
occupied.
Repairing, enhancing and restoring existing fenestration at existing openings.
22
Replacing existing windows (deteriorated to the point of inoperability) to closely emulate the
design, pattern, color, and perhaps material construction of what currently exists on various
existing CWD structures.
Wherever possible, restoring and maintaining the interior character of key existing structures
with additional modifications developed to meet the needs and requirements of potential tenants
as well as applicable building codes.
Enacting architectural guidelines, as described in the PUD/PDZ Design Guidelines, that help
establish a common character for new Site development and which will in turn complement the
rhythm, variety, proportion, size, and scale of the existing and remaining historical structures.
Working with an appropriate professional to adequately photo document those structures that
will be demolished, so that a historical record of the architecture will remain.
Selectively preserving historically significant elements of buildings, both internal and external,
that contribute to the historical narrative of both the structure and the Morse Chain Factory itself.
7. Transportation and Circulation
The GEIS analyzed the potential impacts related to the local transportation network. A broad study
area was scoped in consultation with City and NYS Department of Transportation (NYSDOT). The
study locations consist of 30 existing intersections. The study intersections were observed during both
peak intervals to assess current traffic operations. Pedestrian, bicycle, and transit infrastructure are key
to providing a complete transportation system for residents and visitors of the City/Town. Within the City
alone, approximately 42% (15% Town) commute to work via walking (2012 American Community
Survey 5-year Estimates). The TCAT system provides transit service for over 100,000 Tompkins
County residents. Ridership has been increasing steadily over the past several years, with a 6.3
percent increase in trips between 2011 and 2013. Of the 33 routes that service the County, Route 65
provides rural commuter service along NYS Route 96B with stops at the nearby South Hill Business
Park and Longview and Route 11 provides downtown coverage and services Ithaca College and travels
along Coddington Road/Hudson Street. The Site is currently accessed via four drives along NYS Route
96B as well as a connection at Turner Place. Marginal access is also available via S. Cayuga Street.
A Traffic Impact Analysis was prepared to assess existing and future traffic operations on the street
network in the vicinity of the Site, to evaluate potential traffic impacts resulting from the Phase I
development and the full build out of the Site, and to identify appropriate mitigation measures to avoid
or minimize potential impacts to the transportation system (the Traffic Impact Analysis is included in
Appendix I of the DGEIS).
Potential Impacts
The Project significantly increases development density in an area characterized by a heavy
volume of commuter traffic to and from South Hill, including to Ithaca College via South Aurora
Street / NYS Route 96B. The Site is in close proximity to residential neighborhoods, which will
be impacted by increased traffic volume. The Site’s proximity to the downtown core and Ithaca
College makes it well situated for alternative modes of transportation (e.g., walking, biking,
carpooling, and mass transit).
A review of both AM and PM peak hour capacity analysis results for the pre-developed condition
indicate that the overall levels of service (LOS) operate at “D” or better at the signalized
intersections, which is an acceptable capacity level. The signalized intersections are the major
roads leading to and around the Site.
o The overall vehicle traffic in this area will be higher subsequent to completing the
Project.
o Availability of queue spacing has been identified as a potential impact.
The eastbound and westbound approaches at the intersection of Clinton Street/Aurora
Street/Prospect Street operate at LOS “F” during both peak hours for the pre-developed
condition.
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o Generally, all other approaches to the study area intersections operate at “D” or better,
with only four intersections operating with approaches of “E.”
The Phase I trip generation estimates are 228 vehicles per hour (vph) for the AM peak hour and
182 vph during the PM peak hour. The Full Development trip generation estimates are 945 vph
for the AM peak hour and 925 vph for the PM peak hour, as shown in FGEIS Table 5.7-5,
provided below:
PHASE LAND USES SIZE AM PEAK PM PEAK
ENTER EXIT ENTER EXIT
Phase I
Office 82.55 ksf 114 15 21 102
Residential 80 Units 8 25 26 15
Industrial 170.6 ksf 94 12 10 66
Sub-total 216 52 57 183
Trip Reductions -30 -10 -18 -40
Total New Trips 186 42 39 143
Phase II,
Full Build-out
Office 185.6 ksf 254 37 48 229
Residential 835 Units 84 240 259 159
Retail 52.2 ksf 47 13 88 105
Restaurant 7.2 ksf 0 0 36 18
Industrial 246.5 ksf 158 23 20 139
Sub-total 543 313 451 650
Trip Reductions -76 -63 -178 -180
Total New Trips 467 250 273 470
Full
Development Total New Trips Under Full Development 653 292 312 613
The cumulative effect of Project-generated traffic on the transportation network is dependent on
the origins and destinations of that traffic and the location of the access drives serving the Site.
o Based on the network’s traffic volumes, it is estimated that 62 percent of the total trip
generation will originate from west, north, and east of the Site.
o An estimated 8 percent will travel from NYS Route 96 and Elmira Road.
o The remaining 30 percent will originate from areas south of the Site.
The capacity analysis results shown in FGEIS Table 5.7-8 indicate most of the approaches and
overall LOSs at the study intersections will operate within acceptable parameters between
existing, background, and full development conditions.
o Additional traffic from the proposed Project may increase the potential for collisions.
o Proposed Driveway I/Aurora Street
Under Phase I full development conditions, the eastbound approach is projected
to operate at LOS “E” and “D” during the AM and PM peak hours, respectively.
Between Phase I and Phase II, the LOS is projected to decrease to LOS “F”
during both peak hours.
Driving patterns may change to reflect the typical operating conditions along NYS
Route 96B at the Site’s driveways and may utilize other points of ingress/ egress.
o Proposed Driveway II/Aurora Street
This intersection is projected to operate as an enter-only driveway.
Little to no delay is projected at this proposed intersection.
o Aurora Street (NYS Route 96B)/Proposed Driveway III
24
Between Phase I and Phase II full development conditions, the eastbound LOS
decreases from “C” and “B” during the AM and PM peak hours, respectively, to
“F” during both peak hours.
o Coddington Road/Danby Road/Driveway IV
Under Phase I full development conditions, the eastbound left/thru approach is
projected to operate at LOS “D” during both peak hours. Between Phase I and
Phase II full development conditions, the LOS decreases to “F” during both peak
hours. The anticipated delay and corresponding LOS for the eastbound
movement is characteristic of un-signalized side roads on heavily trafficked
arterials such as NYS Route 96B. Between both phases of full development, the
westbound approach from Coddington Road decreases in LOS from “C” to “E”
during the AM peak hour and from “C” to “D” during the PM peak hour.
o Proposed Driveway V/Danby Road (NYS Route 96B)
This intersection will be constructed during Phase II of full development
conditions. A LOS of “C” is projected for eastbound exiting traffic during the AM
and PM peak hours. All other approaches operate at LOS “A.”
o Clinton Street (NYS Route 96B)/Aurora Street/Prospect Street
The eastbound left and westbound approaches operate at LOS “F” between all
conditions during both peak hours. Between Phase I and Phase II full
development conditions during the AM peak hour, the eastbound right approach
decreases from LOS “C” to “E”.
o State Street/Aurora Street
The westbound left approach operates at LOS “C” during the AM peak hour and
“F” during the PM peak hour under Phase I development conditions. The AM
peak hour LOS for the approach decreases to “F” under Phase II full
development conditions. The northbound approach decreases from “B” and “C”
to “C” and “D” during the AM and PM peak hours, respectively, between Phase I
and Phase II full development conditions.
o Clinton Street/Cayuga Street
Between Phase I and Phase II full development conditions during the AM peak
hour, the overall LOS decreases from “D” to “E”. The southbound left approaches
decreases from “E” to “F” during both peak hours between Phase I and Phase II
full development conditions.
o Pine Tree Road/NYS Route 79
The southbound approach during the PM peak hour between Phase I
background conditions and Phase I full development conditions decreases from
LOS “E” to “F”. Between Phase I and Phase II full development conditions, delay
increases by 55.1 seconds.
o Access via Turner Place and Cayuga Street
The alternative capacity analysis performed shows that delays are projected to
increase for all approaches during both peak hours at the Aurora Street/Clinton
Street/Prospect Street intersection.
The Project Sponsor’s traffic consultant provided the following table which depicts the results of
queuing analysis at the proposed Site access driveways during Phase I and Full Development
Conditions:
AM Peak Hour Queuing Results
Site
Access
Driveway
Phase I Queue
Length
(in feet)
Full Development
Queue Length
(in feet)
Full Development
with Mitigation
Queue Length
(in feet)
Conceptual
Available Storage
to First
Intersection
25
Average 95th
Percentile Average 95th
Percentile Average 95th
Percentile
(in feet)
Driveway
I 20 49 46 78 52 91 160
Driveway
II NA NA NA NA NA NA N/A
Driveway
III 7 26 36 60 19 39 211
o Based on the above queuing analysis there are sufficient storage lengths at Driveways
IV and V during both peak hours. Driveway III during the PM peak hour is borderline
based on 95th percentile queues. However, queues of this length are expected to be
infrequent and are intended to illustrate a worst-case scenario. On the other hand,
Driveway I during the PM peak hour shows queues that are longer than the conceptual
available storage.
The Project Sponsor’s traffic consultant provided the following sight distance evaluation:
Drive North South
Drive I > 500 ft. 400 ft.
Drive II (proposed to be only an entrance) 400 ft. > 500 ft.
Drive III > 500 ft. > 500 ft.
Drive IV > 500 ft. > 500 ft.
Drive V > 500 ft. > 500 ft.
AASHTO Intersection Sight Distance
Speed Distance
40 mph 445 ft.
45 mph 500 ft.
Based upon the above data, there is sufficient sight distance at all the proposed access points
except for Drive I, south and Drive II, north.
Mitigation
Mitigation will include all direct access points to the Project including existing and proposed
drives on NYS Route 96B as well as extensions of Turner Place and South Cayuga Street into
the Project.
o The mitigation will include access drive improvements. Such improvements may include
signalization, signal coordination, turn lanes, and geometric improvements.
o Off-Site mitigation will consist of signalization optimization and other traffic control
measures.
o Additional mitigation will take the form of vehicle sharing and improvements to
pedestrian/bicycle facilities.
Phase I Specific Mitigation
Relative to Phase I, NYSDOT has specified certain mitigation requirements relative to Route
96B. Specifically, NYSDOT will require the following Phase I mitigation:
o Changing the four-lane section of NY 96B south from the city/town line to past Bella
Vista Dr. by reconfiguring the two southbound lanes to one through lane and
incorporating left turn lanes for both directions at intersections, and hatching where
appropriate.
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o Sidewalk will be required along the frontage of the Site on the western side of Route
96B, from the city/town line to the Coddington Rd. intersection.
o The proposed driveway, immediately south of city/town line, will be a one-way ingress
only; no traffic will be allowed to exit onto Route 96B at this location.
In addition, the Project Sponsor shall introduce and implement Transportation Demand
Management (TDM) strategies to reduce Single Occupancy Vehicle (SOV) trips to and from the
Site. The following potential TDM strategies will be considered for Phase I implementation:
o Market-priced parking
o Preferential parking for ridesharing services
o Bicycle parking facilities
o Subsidized transit passes
o Connections to transit stops (i.e. construct sidewalks to existing stop at Hillview Place)
o Dedicated shuttle service
o Transportation Alternatives Information
o Coordination with Smart Trips Ithaca
o Connected and improved pedestrian network within the Phase I limits (i.e.,
improvements to sidewalks within Sidewalk Improvement District No. 4)
o Pedestrian oriented design within the Phase I limits
o Bicycle network facilities within the Phase I limits and provide easement to nearby
Gateway Trail
o Follow Crime Prevention Through Environmental Design (CPTED) principles in all
design
o Coordination with Ithaca College and South Hill Business Park
Post-Phase I Mitigation
A post-Phase I Traffic Study will be performed as part of the Phase II site plan application.
The Lead Agency understands that Washington State’s Commute Trip Reduction (CTR)
program and CTR Efficiency Act, a law passed by the State Legislature, requires local
governments in urban areas with traffic congestion to develop programs that reduce SOV trips
and Vehicle Miles Travelled (VMT) per capita. The Project Sponsor has committed to adapt and
scale this program to the projected employment centers proposed within the CWD.
Addition TDM or CTR initiatives will be implemented as follows:
o Transit Coordination – Continued coordination with TCAT on transit routes and
marketing the nearby routes of 65 and 11. TCAT bus line will boost ridership through
increased awareness coupled with improved service.
o Route Expansion – Working with TCAT to provide new/expanded bus service through
the Site provides an opportunity for greater mode choice resulting in trip and parking
reductions.
o Bus Stop Amenities – A clean, well-lit, informative bus stop with shelters and seating
greatly improves the image of the transit serving an area. Bus stop amenities make
taking the bus a comfortable experience, while proper maintenance tells people that
transit makes up an important part of the neighborhood.
o Employer Carpooling – Carpooling will be encouraged by providing incentives and other
services such as ride-matching.
o Emergency Ride Home – In case of a personal emergency during the day, transportation
is provided at no cost to one’s vehicle, residence, or other place such as childcare,
doctor’s office, etc.
o Preferential carpool/vanpool parking – Investigate the use of vRide for employers
located on the Site.
o Transportation Alternatives Information – Bus schedules, walking and bicycling maps,
neighborhood and on-Site wayfinding will be made readily available.
o Telecommuting and compressed work schedules – Employers will be encouraged to
offer flexible work options. Employee vehicle trips are reduced by the percentage of
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employees that telecommute or have a “free” day gained through a compressed
schedule, on an average day.
o Location and Quantity of Bicycle Parking Spaces – The Project will include convenient
bicycle parking locations in clear sight of access points into buildings, safe and secure
longer term storage within parking areas, and a sufficient number of bicycle parking
spaces that encourages a greater number and demographic of residents, employees,
and visitors to utilize bicycling as a means of transportation.
o The Price of Parking – Parking spaces that are typically included in building and rental
costs will be reviewed, and “unbundled” parking, paid as a separate item, will be
considered.
o Financial Incentive Programs – Developing Commuter Financial Incentive Programs,
such as Parking Cash Out, offer employees the choice of receiving a subsidized parking
space an equivalent financial incentive.
o Bike Share – A micro bike share system that is developed for the Site or a more robust
system that is developed for the City and Town (i.e. Lime Bike) encourage more transit
ridership and provide additional public transportation options. A bike share system can
offer mobility, economic, health, safety, and quality of life benefits.
o Car Share – Coordination with Ithaca Carshare will be pursued during Phase I as
demand potentially grows through increased residential and commercial based
occupancy rates.
o Relationship with Ithaca College – The Site is located less than a half-mile from Ithaca
College. An integrated and coordinated approach to the development of the Site and
potential for interaction between the two entities should be explored.
o Electric Vehicle charging station – The County will be conducting a study to identify
needs and opportunities. This could be included in the Project as an amenity to
residents, and it supports the County’s goals to reduce greenhouse gas emissions.
In order to mitigate post Phase I traffic impacts to the maximum extent practicable, following
completion of Phase I, the Project Sponsor will implement an on-going Monitoring and Mitigation
Implementation Plan (MMI Plan).
The MMI Plan will include an update of traffic conditions based on full occupancy of Phase I of
the development utilizing field collected data and before the next phase of development begins
to verify underlying assumptions and evaluate the effectiveness of TDM strategies.
All traffic study updates will be reviewed by NYSDOT and a City Traffic Engineer.
This post-Phase I occupancy traffic update will evaluate the following intersections: (i) Aurora
Street/Prospect Street/Clinton Street, (ii) Aurora Street/State Street, (iii) State Street/Seneca
Way, (iv) State Street/Green Street, (v) Clinton Street/Cayuga Street, (vi) Cayuga
Street/Seneca Street, and (vii) Cayuga Street/Spencer Street.
o This post-Phase I occupancy traffic update will also include an evaluation of whether a
traffic signal is warranted at all site access driveways.
The MMI Plan will also provide for additional traffic study updates at the following stages of
development:
o Immediately following tenant occupancy of Phase I of the Project;
o When proposed post Phase I development within the CWD results in more than 75
vehicle trips per hour (cumulative over Phase I); and
o Each time a proposed post-Phase I development within the CWD will result in more than
150 vehicle trips per hour
o In addition, per NYSDOT, a traffic study update will be required for each phase of the
project where modifications and/or additional mitigation is proposed in the NYSDOT
R.O.W
Traffic study updates will verify trip distribution models and confirm when traffic mitigation
measures identified in the GEIS should be implemented. Other than the update immediately
following tenant occupancy of Phase I of the Project, all updates will be submitted and reviewed,
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per the thresholds established herein, in conjunction with proposed site plans for each phase of
development. The intersections to be analyzed in each traffic update include:
o Site Accesses 1 and 2
o Site Accesses 3, 4 and 5 (NYSDOT owned)
o Aurora Street/Prospect Street/Clinton Street
o Prospect Street/Turner Place
o Columbia Street/Aurora Street
o Aurora Street/State Street
o State Street/Seneca Way (NYSDOT owned)
o State Street/Green Street (NYSDOT owned)
o Clinton Street/Cayuga Street
o Cayuga Street/Seneca Street (NYSDOT owned)
o Cayuga Street/Spencer Street
o Pine Tree Road/SR 79 (NYSDOT owned)
o State Street/Stewart Avenue
o Turner Place corridor between site access and Prospect Street
o Cayuga Street corridor between site access and West Spencer Street
Additional mitigation measures at specific intersections (dependent upon and subject to future
traffic study updates) are described as follows:
o Prospect Street/S Aurora Street – Impacts to Aurora Street/ Clinton Street/Prospect
Street and potential mitigation does not include physical improvements to the
intersection, as ROW and existing buildings limit the ability to expand the intersection.
Additionally, a traffic signal is not an appropriate treatment. Therefore, higher capacity
people mover systems (i.e., new TCAT routes and improved headway, and potential
automated transit service between the Commons and the Site) are needed.
o S Aurora Street/Columbia Street – Traffic signal warrants are not met at this intersection
to alleviate delays for Columbia Street traffic. All traffic can be accommodated, as
needed, at the existing traffic signal at Aurora Street/Hillview Place. The reduction of
SOV trips and increased mode share of pedestrian, bicycle, and transit trips will reduce
total site generated traffic passing through this intersection.
o S Aurora Street/Site Access 3 – Delays at Driveway III are projected to decrease from
LOS “F” to LOS “E” with the installation of traffic signals at Driveway I and IV.
o Cayuga Street/Clinton Street – The Project Sponsor’s traffic consultant developed signal
timing adjustments for the PM peak hour and the associated capacity analysis results
which are presented at Appendix F of the FGEIS. These adjustments reduce the
projected LOS “E” for the northbound thru/right approach and LOS “F” for the
southbound left approach to LOS “D” for both approaches. The Project Sponsor has had
discussions with ITCTC about an automated fixed route system along Cayuga Street
that would shuttle people between the Commons and the Site. The Lead Agency
recommends that a feasibility study of such a system be performed by ITCTC with
participation from the Project Sponsor.
o The capacity analysis indicates most of the approaches and overall LOSs at the study
intersections will operate within acceptable parameters between existing, background,
and full development conditions. Project driveway specific results and mitigation are as
follows:
Driveway I: Under Phase I development conditions, the eastbound approach is
projected to operate at LOS “E” and “D” during the AM and PM peak hours,
respectively.
Between Phase I and Full Development, the LOS is projected to decrease
to LOS “F” during both peak hours.
This intersection should be monitored after redevelopment of the Phase I
buildings for delay and operation for drivers entering and exiting the Site
to determine what point in the future a traffic signal is installed.
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Internal roadways interior to the Driveway I access will be designed to
mitigate potential spillback into internal intersections.
The Project Sponsor’s proposed mitigation for Driveway I includes
installing advanced intersection warning signage (Manual of Uniform
Traffic Control Devices (MUTCD) W2-2L) for northbound approaching
vehicles.
Driveway II: This intersection is projected to operate as an enter-only driveway.
Therefore, little to no delay is projected at this proposed intersection. No
mitigation is warranted or recommended.
Driveway III: Between Phase I and Full Development conditions, the eastbound
LOS decreases from “C” and “B” during the AM and PM peak hours, respectively,
to “F” during both peak hours.
Driveway IV: Under Phase I development conditions, the eastbound left/thru
approach is projected to operate at LOS “D” during both peak hours. Between
Phase I and Full Development conditions, the LOS decreases to “F” during both
peak hours.
Driveway V: This intersection will be constructed during Full Development after
Phase I. A LOS of “C” is projected for eastbound exiting traffic during the AM and
PM peak hours. All other approaches operate at LOS “A”.
During Full Development conditions, all of the proposed driveways along NYS
Route 96B potentially warrant a left-turn lane during the AM peak hour. The
warrants during the PM peak hour are met for the proposed Driveway II,
proposed Driveway III immediately south of Grandview Avenue, and the
proposed Driveway V. Left-turn lanes are recommended at the proposed
Driveways III, IV, and V under Full Development if conditions warrant the same.
Under Full Development conditions, the guidelines for a full width right-
turn lane are satisfied at the proposed Driveway I under AM conditions
only. The remaining driveways are not met.
Based on the expected delays under Full Development conditions and a
traffic signal warrant analysis, a three-colored traffic signal is
recommended for the intersection of Coddington Road/Danby
Road/Driveway IV. The traffic signal should be designed to provide a
permitted/protected northbound and southbound left-turn phase. Left-turn
lanes are recommended at Proposed Driveways III, IV, and V.
Aurora Street/State Street (MLK Jr. Street): In order to improve the existing and
future peak hour operating conditions at this critical intersection, an alternative
that provides two westbound approach lanes on State Street was investigated.
By restriping the westbound approach to include separate left and right-
turn lanes (the right-turn lane should be restriped to include 100 feet of
storage), the overall delay decreases during the AM peak hour by 17
seconds per vehicle.
Similarly, during the PM peak hour there is a decrease in delay by over
13 seconds per vehicle. In order to provide the two approach lanes on
State Street, peak hour ONLY parking restrictions are recommended for
the two metered parking spaces on the approach to the intersection.
During off-peak hours of operation, drivers can continue to use the
approach as a single-lane approach with the ability to continue using the
two metered parking spaces on the north side of State Street.
Summary
Mitigation measures have been developed upon completion of Phase I and Full Development
(Phase II):
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PHASE LOCATION MITIGATION MEASURE
I
All signalized City intersections
System-wide signal timing update to ensure optimized signal
operation.
Aurora Street/Clinton Street/
Prospect Street
The use of TDM strategies should be utilized to reduce vehicle trips
generated as a result of the Project.
Seneca Street/Cayuga Street System-wide update of signal timings as mentioned above.
Clinton Street/Cayuga Street TDM strategies.
Pine Tree Road/Slaterville
Road
The intersection should be monitored for delay as it relates to
potential future signalization.
Proposed Driveway I/Aurora
Street
Consider installation of a three-color traffic signal after
redevelopment of the existing buildings, prior to new
development in Sub Areas CW3 and CW4. A study of
intersection delay at this point will confirm the need for a
potential signal. This signal should be coordinated with the
traffic signal at Hillview Place.
II
Aurora Street/State Street
Restripe the westbound approach to provide separate left and
right-turn vehicle movements during peak hours only. Enforce
peak hour ONLY parking restrictions on north side of State St.
approach.
NYS Route 96B/Coddington
Road/Proposed Driveway IV
Realign, restripe the intersection to include opposing
northbound/southbound left-turn lanes, and install a three-color
traffic signal. The Project Sponsor should work with NYSDOT and
the property owners affected by any intersection realignment.
Proposed Driveways III and V
at NYS Route 96B
Install northbound left-turn lanes at Proposed Driveways III and V.
Cayuga Street/Seneca Street System-wide update of signal timings.
Cayuga Street/Clinton Street System-wide update of signal timings.
Downtown Ithaca
Update a downtown circulation plan with the purpose of
developing a workable multimodal circulation system
supportive of all modes of travel in the Ithaca CBD. The plan
should be flexible to accommodate evolving modes of
transportation.
The Project will incorporate pedestrian, bicycle, and transit friendly accessibility and mobility
design characteristics where possible.
o Crossing treatments should be installed at all intersections and use high-visibility
treatments. Mid-block crossing locations may be installed, where feasible, and not be
located further than 400 feet from the nearest crossing location. In lieu of dedicated
bicycle lanes where street widths are too narrow for one to be installed (bicycle lanes are
required to be at least 5 feet in width adjacent curbs), shared lane markings – “sharrows”
– should be used to indicate bicycle friendly streets.
o Bicycle signage along the roadways can be used to increase driver’s awareness of
bicyclists as well as encourage bicycle ridership.
o An on-Site multi-use trail system should be considered to provide off-street circulation
routes for pedestrians and bicyclists. This trail system should be connected to the
Gateway Trail along the western ridge of the Site.
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o The internal pedestrian network should connect to the existing sidewalk network along
NYS Route 96B and allow connections to Ithaca College and Downtown through or
along the edge of the Site. As of April 2015, a Pedestrian Corridor Study is underway to
determine the appropriate locations for a sidewalk/off-road multi-use path system and
crossing locations between the City/Town line and King Road. Internal sidewalks should
be installed in the anticipation a complete sidewalk network is developed along NYS
Route 96B to encourage non-motorized travel.
Parking and parking lot Design Guidelines have been developed as further mitigation. While it is
important to provide parking as a component of the Project, a number of measures have been
incorporated into the plan to minimize the need for parking by increasing trail, pedestrian and
bicycle connections to strongly encourage walking and bicycling.
The proposed Gateway Trail will be developed via easements between the Project Sponsor and
the City and Town to connect to the South Hill Recreation Way to the existing Black Diamond
Trail.
Pedestrian sidewalks will be constructed in safe and convenient locations, connecting users of
the Project to the existing pedestrian network in adjacent neighborhoods.
Bicycle facilities will be present throughout the Site via on-street pavement markings and
signage directing riders to destinations on and off-Site.
Mass transit access will be provided in locations that are agreed upon through coordination
between the Project Sponsor and TCAT as the Site is developed. The Conceptual Site Layout
Plan depicts two on-Site bus stops.
8. Utilities
The GEIS evaluated the potential impacts to the utility infrastructure with additional emphasis on public
water supply, sanitary sewer and stormwater systems. The Site is currently served by public utilities
that have sufficient capacity to provide for additional demand and without the need of expanding public
district or service areas. The Site is supplied with potable water by the City. The water is connected to
the public water system on Turner Place and at a dead-end line on South Aurora Street near Parking
Lot 4. The City Department of Public Works (DPW) indicates there is adequate capacity and pressure
in the water supply system. The on-Site private portion of the water system consists of approximately
3,960 lineal feet of 12-inch water main. Approximately 2,340 lineal feet is located outside of the
buildings and 1,620 lineal feet is located inside the buildings. The watermain is a mixture of an older
cast iron pipe and a newer ductile iron pipe. All upgrades and repairs to the water system were
completed using ductile iron pipe. There are 15 fire hydrants connected to the private watermain that
protect the existing structures. The system performs with a static pressure of 90 to 130 psi with the
ability to provide up to 1,700 gpm for fire flow.
Potential Impacts
The total estimated water usage for the redeveloped core of the District is approximately
110,000 GPD and 161,500 GPD for the new buildings. This is an average demand of 188 gpm.
Using a peaking factor of 8.0, there is a peak demand of 1,500 gpm.
o Overall, the main impact to the water system is the increased usage estimated for the
Project.
The existing sanitary sewer system connects to the City sanitary sewer system at two locations.
There is a 12-inch sewer located on Turner Place, adjacent to building 21, and a 10-inch sewer
located on South Cayuga Street. The total flow capacity for these two mains is 2,033 gpm and
1,450 gpm, respectively. The wastewater generation rates will mirror the estimates for the
public water usage. The estimated wastewater generation is 271,500 GPD. This is an average
demand of 188 gallons per minute. Utilizing an 8.0 peaking factor, it is estimated that the peak
flows are approximately 1,500 gpm.
o The main impact to the sanitary sewer system is the increased usage estimated for the
Project
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The Site is currently served with stormwater drainage facilities consisting of catch basins,
stormwater sewers, and grassed swales.
o The Site does not have any stormwater control facilities, such as retention basins or
underground infiltration systems. The Site does not have good infiltration characteristics,
as it contains many rock outcroppings and generally the depth to bedrock is minimal.
o There is also very little existing green space to develop traditional drainage basins.
The existing 6” natural gas line serving the Site is rated at medium pressure which is currently
operating at approximately 20 psi. It is assumed that total energy consumption is 98,000 BTU/sf
for commercial space and 94,000 BTU/sf for residential space for the purposes of estimating
annual baseline usage. Natural gas usage is estimated at 32% of the total usage. Therefore the
natural gas usage annual base line is 45,900 MMBTUs.
The Site is served by the NYSEG South Hill electric substation located on South Cayuga Street.
The Coddington-South Hill 34.5 kV Line #526 traverses the Site from the South Hill substation
easterly to Coddington Road.
o The Site is also served by a private electric substation that is powered by Line #526.
This substation was sized to serve the entire Site at its peak operational needs. Based
on conversations with NYSEG Staff, depending on final electric usage as well as on-site
generation (i.e. photovoltaic), additional upgrades to the existing substation equipment
may be necessary.
The Project will require high-speed data to provide services expected in a new community such
as the CWD. The 915 dwelling unit and approximately 400,000+ gross square footage of space
dedicated to business uses will put a demand on these utilities.
Lighting from the Project, once fully developed, will be greater than under current conditions and
will increase light levels in the outdoor environment. Without proper planning and design, light
trespass (the spillage of light into a neighboring property) can occur. Light going up into the sky,
or sky glow, can reduce visibility of the stars.
Mitigation
Water/Sanitary Sewer
o The City may be able to restore the old cast iron pipe likely to have heavy tuberculation
that historically fed the three water storage tanks on Site to have better flowrates.
However, the City recommends adding a new public water connection point
further down South Aurora Street near the main entrance drive to loop the
system when the new buildings are constructed in the CW3 Sub Area.
If the tuberculation cannot be mitigated, then a replacement watermain will be
installed.
o Loop existing City water system through Sub Area CW3 from the current connection at
NYS Route 96B/Driveway III intersection to a new point of connection at the NYS Route
96B/ Driveway I intersection.
o Construct any new public water and sewer mains to have a minimum diameter of 8-
inches and be looped (if practicable). All work shall be in accordance with (Ten State)
Recommended Standards for Water Facilities and Water Works.
o Use NYS required water saving plumbing fixtures. The Project will follow LEED ND
guidelines for new buildings and buildings undergoing major renovations by reducing
indoor water usage 20% from a baseline, demonstrable through product cutsheets and
fixture schedules.
o Meter and audit individual buildings.
o Investigate the on-Site storage and reuse of stormwater by repurposing the on-Site
underground water storage tanks near Driveway III or creating a new storage area in
Sub Area CW2 to reduce on-Site water demand.
Stormwater Infrastructure
o At a minimum, the on-Site storm sewer collection system will be designed for the 10-
year design storm.
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o A full SWPPP and coverage under NYSDEC General Construction SPDES permit will be
required. The stormwater mitigation features for the redeveloped portions of the site will
designed in accordance with NYSDEC’s guidelines for redeveloped projects. The new
construction areas will fall under NYSDEC regulations for traditional development.
o A majority of stormwater controls will be green infrastructure suitable for the urban
setting. The “Water Quality Volume” and ‘Runoff Reduction Volume” will be treated using
a combination of green roofs, stormwater planters, and hydrodynamic separators.
o Develop an Operations and Maintenance (O&M) Plan to insure the proper use of the
stormwater conveyance system.
Electric/Natural Gas Energy Use
o Alternative energy measures are being investigated for the Site including PV, wind, and
CHP or cogeneration systems.
o New buildings will meet LEED criteria and include efficient design and renewable energy
systems necessary to achieve at least a 70% reduction in fossil fuel use in compliance
with the Architecture 2030 Challenge. That would reduce energy usage by up to 53,000
MMBTUs per year and return the usage estimates to pre-developed estimates for typical
industrial use of the existing Site based on the 821,200 sf GSA.
A full photometric plan will be submitted with each site plan application and will incorporate
“Dark Sky” techniques to confine and minimize light to the extent practicable while maintaining
proper safety.
9. Air Quality
The GEIS focused specifically on the potential impacts to area wide/regional air quality and air quality
on the Site. The Project Sponsor evaluated whether the Project would result in violations of ambient air
quality standards or health-related guidance values related to vehicle emissions, building emissions
and historical impacts. The area wide/regional air quality analysis included an evaluation of National
Ambient Air Quality Standards (NAAQS) for six common pollutants and an assessment of Greenhouse
Gas Emissions from on-Site emissions. The six common pollutants analyzed were carbon monoxide,
lead, nitrogen oxides, ozone, particulates and sulfur dioxide. On site air quality was analyzed by
studying numerous investigations of indoor and outdoor on site air quality for over a decade. The GEIS
also evaluated whether the Project would result in violations of ambient air quality standards or health
related guidance values for vehicle emissions, building emissions and historical impacts.
Potential Impacts
There will be some air quality impacts during construction due to vehicle emissions for a limited
timeframe.
In addition to the vehicle emissions, Greenhouse Gases (GHG) from Building emissions have
also been evaluated.
o GHG emissions resulting from the use of natural gas (45,901 mmBTU annually) to serve
the buildings for the Project are projected to total 2,686 Tons of Carbon Dioxide
equivalent (CO2e).
o The GHG components include Carbon Dioxide (CO2 - 2,685 MT/yr), Methane (CH4-
0.048 MT/yr) and Nitrous Oxide (N2O - 0.00025 MT/yr).
o Based on the criteria identified in the NYSDEC FEAF Workbook and the assessment of
the GHG emissions due to the Project, there are impacts to air quality from the Project
due to carbon dioxide emissions.
In addition to GHG from building emissions related to energy consumption, tenants with certain
types of commercial or industrial operations may emit pollutants into the air. The degree and
type of air pollutants emitted depends on the tenant’s specific operations.
Since the Project includes occupation of many existing buildings not routinely occupied, adverse
impacts have the potential to arise from the occupation of Buildings 1, 2, 3, 4, 5, 6, and 6A (any
remaining portions), 8, 10, 13A, 13B, 15, 24, 33 (remaining portions), 34 and 35.
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o The potential for SVI into existing buildings to be occupied and new buildings would
need to be addressed by mitigation, monitoring, or further analysis.
The analyses performed reveal no significant impacts to air quality with the exception of
potential exceedance of threshold criteria for carbon dioxide from building emissions and soil
vapor intrusion from historical impacts potentially effecting indoor air quality.
Mitigation
Vehicle Emissions: No mitigation measures are proposed beyond those set forth under traffic
mitigation measures.
Building Emissions: Will be mitigated via the following:
o Investigate alternative energy measures to reduce building emissions of carbon dioxide
o New buildings will meet LEED ND criteria and include efficient design and renewable
energy systems necessary to achieve at least a 70% reduction in fossil fuel use in
compliance with the Architecture 2030 Challenge. That would reduce total energy usage
by up to 53,000 MMBTUs per year (note, only a portion of this would be for on-Site
building emissions).
o Any commercial or industrial tenant operations with the potential to emit air pollutants
must identify and control those sources through the NYS Air Pollution Control Program
(6 NYCRR Part 201) and any other applicable laws and regulations.
Historic Impacts: The prior testing for soil vapor intrusion will be utilized by the Project Sponsor
in coordination with NYSDEC and NYSDOH to determine which structures warrant mitigation or
monitoring. Existing buildings likely to require mitigation, monitoring or additional analysis
include:
o Mitigation of Buildings 1, 2 (basement portion), 3, 4, 5, 6 and 6A (remaining portions),
8,10, 18, 21, 24, 33 (remaining portions) and 34
o Monitoring of Buildings 13A and 17
o Buildings 2 (upper portion), 10A, 13B, 15 and 35 may require some additional action to
identify sources and reduce exposure.
Prior to any new building construction in the CW3 or CW4 Sub Areas, the VOCs data for soil
and groundwater within the proposed building footprint will be analyzed for the potential for soil
vapor intrusion and mitigation will be included as part of the construction as warranted.
Mitigation measures set forth for Public Health and Environment and Traffic shall also serve to
mitigate impacts to air quality.
10. Visual and Aesthetic Resources
Visual and aesthetic resources are characterized by various elements that form a viewer’s perception
and aesthetic response to a place, object, or setting. The GEIS reviewed critical vantage and
viewpoints where the visual environment is considered an important aspect of the Site from within the
City and Town. Many of these views are listed in the Town Scenic Resource Inventory & Analysis and
the Tompkins County Scenic Resources Inventor. These views included Danby Road, Taughannock
Boulevard, Cliff Street, Hector Street, West Haven Park, Sheffield Road, Upper Botswick Road, East
Shore Park, and Tutelo Park. Specific points in the City include Meadow Street, Route 13 heading
south mid-way down the hill, Stewart Park, Allan H. Treman State Marine Park, Cass Park, South
Cayuga Street heading south, and Cornell University on East Hill.
A field analysis included a before/after comparison using photography to collect near and distant views.
Eighteen (18) existing views were documented in late February during leaf off conditions in order to
capture the maximum visual impact. Massing models have also been created to illustrate the potential
visual and aesthetic impacts of proposed development in the context of existing Site conditions. The
visual impact analysis includes the following:
Photographs of existing views of the Site during leaf off conditions, as identified in the
Scoping Document.
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Photographic perspectives, visual renderings, and visual simulations of the Project from
each critical receptor point, providing a before/after comparison.
Maps of each viewshed illustrating the sight lines and views internal and external to the
Site.
View descriptions from critical vantage points of the proposed development using
photographs.
Architectural elevation drawings of the Phase I buildings were developed.
Potential Impacts
The existing Site buildings are, and some proposed new buildings will be, visible from a number
of locations throughout the City and Town in varying degrees.
The visual and aesthetic character of Route 96B, as illustrated in viewsheds 9 and 10, will incur
the greatest impacts, as the Project will create a new and vibrant street front.
More distant views and views of limited visibility of the Project, such as viewsheds 1, 2, 3, 4, 5,
6, 7, 11, 12, 13 and 14 will have far less impacts, as the proposed new structures relate to and
blend with the existing structures from a distance.
Mitigation
Mitigation measures include strategies such as architectural approaches and themes consistent
with the surrounding neighborhood, visual screening and planting/landscaping and, carefully
locating components within the Project. The Conceptual Site Layout Plan serves as mitigation.
The Conceptual Site Layout Plan mitigates visual impact through the careful placement of
proposed structures in a manner that forms a relationship between the topography and the
structures across the landscape.
The Design Guidelines require development to be of similar character with the existing
structures. For example, the application of architecture strategies such as fenestration of the
proposed structures that continue the rhythm and character of the existing structures allows for
new structures to blend with the Site as it exists. The Design Guidelines include detailed limits
on the heights of proposed building (different limits for each Sub Area), building setbacks,
maximum façade length, and public frontages.
Sub Area CW1 is designated as a Natural Area, which includes the steep slopes on the western
side of the Site and will include the Gateway Trail. This Sub Area is highly visible from many
viewpoints and will be preserved. The existing vegetation in this area provides some screening
of the existing upslope buildings. Designating Sub Area CW1 as a Natural Area mitigates
potential impacts from proposed buildings.
The Project Sponsor will be following LEED ND guidelines including compact development,
tree-lined and shaded streetscapes, and minimized site disturbance.
11. Community Services
The GEIS analyzed the potential impacts to community services including Government Facilities, Solid
Waste Management, Educational Facilities, Cultural Facilities, Religious Facilities, Health Care
Services, and Public Safety. The Site, located in both the City and Town, is relevant to both
municipalities’ offices. The City of Ithaca City Hall is located at 108 East Green Street and the Town of
Ithaca Town Hall is located at 215 North Tioga Street, each respectively 0.5 miles and 0.6 miles north
from the Site. The United States Postal Service Downtown Ithaca Office is located at 213 North Tioga
Street, approximately 0.6 miles north of the Site. Additionally, a number of approved postal provider
satellite sites are located within a 1.5-mile radius from the Site.
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Potential Impacts
Government Facilities: The Project will result in a notable increase of the tax base, as described
under Cumulative Impacts, thereby increasing the revenue for the City, Town and County
Governments.
Solid Waste Management: The Project will result in an increase of solid waste. In addition to the
solid waste generated by residences on-Site, there will be an increase in commercial and/or
manufacturing waste, depending on tenants. Consultation with the TCRSWC revealed that it is
currently operating at 21% of its capacity for waste and 41% for recyclables.
Educational Facilities: The Site is located within the Ithaca City School District (ICSD) boundary.
The Project estimates there will be approximately 50 children living on-Site creating a new
demand on the ICSD. Based on correspondences with ICSD, schools in the ICSD have the
capacity to accommodate future residents of the CWD. Higher learning educational facilities in
close proximity to the Site include Cornell University (located approximately 1.0 mile northeast
of the Site) and Ithaca College (located approximately 0.5 miles to the southeast).
Cultural Facilities: The Site is positioned near a variety of existing cultural facilities. The
Tompkins County Public Library is located at 101 East Green Street, approximately 0.5 miles
from the Site. Cinemapolis, a 5-screen cinema house, is located at 120 East Green Street,
approximately 0.5 miles from the Site. The State Theatre of Ithaca, a historic 1,600 seat theatre
that hosts bands, dramatic performances, and films, is located at 107 West State Street, 0.6
miles from the Site. CSMA also offers public dances, musical events, and art shows.
o The Project will result in a greater demand on existing cultural facilities. It is expected
that some employees commuting to the CWD would use existing cultural facilities during
their non-work hours. The Project will also provide a significant amount of community
space resulting from the selective demolition of portions of existing buildings. This
increased internal open space will provide opportunities for markets, collective
gatherings, festivals, and other larger community events.
Religious Facilities: The City is the home to many religious institutions including over a dozen
within a 1 mile radius. The Project will result in a greater demand on the existing religious
facilities. Additionally, it is expected that some employees commuting to the CWD would use
existing religious facilities during their non-work hours. It is expected that this would result in a
negligible or otherwise positive impact through increased attendance, participation, and
donations.
Health Care Services: The City and Town have a number of facilities which provide health and
medical care. Cayuga Medical Center is the largest medical facility in the area, with a 204-bed
acute care hospital serving inpatient and outpatient needs and an Emergency Department that
is open 24-hours per day.
o The Project will result in a greater demand on the existing health care services due to
increased demand largely as a result of the increased residential population, but also to
a lesser extent, the workforce employed at the CWD. The Project’s residential population
is expected to be approximately 1,830, and the employee population to range between
approximately 800-1,000 people.
Public Safety Services: The Project Site is served by a City police station, fire station, County
sheriff’s office, NYS police and Bangs Ambulance service. The Project will construct
approximately 1,830 bedrooms, or approximately 915 units.
o This will impact the existing public safety services, requiring resources and staff time
from the police (City of Ithaca Police Department, the Tompkins County Sheriff’s Office
and at times the New York State Police), fire (the City of Ithaca Fire Department and as
needed adjacent and nearby community fire stations and departments) and emergency
medical services.
Mitigation
Analyses of the community services indicate that there will be adequate capacity for community
services despite increased demands resulting from the Project. Any increased demands from
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the Project on such services will be mitigated by the additional tax base generated by the
increased property assessment for the Site. The assessed value of the Site will increase from
$3.5M to an estimated $236M.
Additional mitigation includes sales tax and other taxes on revenue generated by the operations
of the Project as well as individual business operations located on-site. These additional taxes
have not been considered in this analysis but would nevertheless further mitigate the cost of
providing community services to the Project.
Although the Site lies in both the City and Town, there would be no jurisdictional confusion as
police protection operates on a “close-car” concept, and fire protection and emergency medical
services operate without regard to the City and Town distinctions.
12. Open Space and Recreation
The GEIS analyzed the potential impacts to open space and recreation as a result of the Project and its
alternatives within and adjacent to the Site, including parks, trails and other recreational resources. The
City, Town, and Tompkins County own many open spaces within a developed urban environment and
provide residents and visitors with a wide variety of recreational resources, including hiking, biking,
boating, fishing, and educational resources. There is a large quantity of trail networks within and
connecting to these parks and recreational resources. Buttermilk and Robert H. Treman State Parks
have their own internal hiking trails and are connected by the Finger Lakes Trail System. The Finger
Lakes Trail system is over 950 miles in length and runs from the Pennsylvania-New York border in
Allegany State Park to the Long Path in the Catskill Forest.
Potential Impacts
The existing impervious area on the Site is 35.75+/- acres. The Project will reduce the overall
potential open space on the Site by approximately 11% or 11.2 acres with an increase of
development and impervious surfaces in the future.
The Project will impact open space and recreation by allowing the construction of the proposed
Gateway Trail. The Gateway Trail will provide a missing link between South Hill Recreation
Way, Buttermilk Falls State Park, the Finger Lakes Trail, and the Black Diamond Trail, creating
broader connections between the City, Town, and Tompkins County.
The construction of the Gateway Trail will impact current residents and visitors to the City,
Town, and Tompkins County as a whole, as well as the future residents and employees at the
CWD.
The construction of the Gateway Trail will provide another pedestrian route to, from, and
through the Site. This will result in the Site becoming an important link and node in connecting
an extensive hiking and recreational trail network that allows for non-motorized activities such
as snowshoeing and cross-country skiing in the winter. This action promotes transportation
efficiency through multimodal transportation and impacts public health by facilitating physical
activity.
Mitigation
To ensure the long term benefits on open space, Sub Area CW1 Natural Conservation Area is
proposed to limit development and uses to only recreationally-base programming.
In addition to the Gateway Trail, with the development of the Project, the Site will become a
bridge between South Hill and Downtown Ithaca. A pedestrian network will traverse the Site,
connecting NYS Route 96B to S. Cayuga Street, allowing for greater accessibility to Downtown
amenities and services, and vice versa. A pedestrian network is also being established
internally within the Site with sidewalks along many streets and pedestrian-dominated
courtyards.
Open spaces, courtyards, and a pedestrian network of sidewalks and trails will provide passive
and active recreational opportunities throughout the CWD.
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The City of Ithaca and its consultants published a draft Parks and Recreation Master Plan in
November 2017. The Plan, among other things, highlights the future connection of the Gateway
Trail/Buttermilk Falls Corridor as one of the key planned trail system enhancements. A
permanent easement will be established along the western portion of the Site to assist with such
trail enhancements.
13. Construction Activities
The GEIS analyzed the potential impacts from Project construction activities and measures to mitigate
them. The Site has been utilized as a construction staging area for multiple off-Site projects in the area
including the City sponsored Commons infrastructure redevelopment project.
Potential Impacts
The Project calls for the full development of the Site over a seven to ten year period in multiple
phases. Planning and coordination will be required for the construction of the various phases.
The NYSDEC ROD amendment and market conditions will influence phasing and timing of the
redevelopment plan.
Because the Project will have multiple phases over many years, there are both short and long
term potential impacts. Many of these impacts are typical of any construction project, and
include work related to: (1) site work; (2) foundations; (3) steel work; (4) concrete flatwork; (5)
exterior wall construction; (6) roofing; (7) interior finish work; and (8) exterior site improvements.
Construction work for the Project in the CW3 and CW4 Sub Areas may encounter impacted
media and building materials such as concrete floor slabs. As such, these activities have the
potential to impact on-Site workers, neighboring properties, or the environment if not properly
handled.
Additional construction impacts typical for a project of this nature include:
o Construction Staging: Due to the multiple phases, a construction staging area may
potentially impact the residents/occupants of the Site as well as the adjacent property
owners.
o Soil Erosion/Dust: Development of the Site will include clearing and grading of land
which creates the potential for soil erosion due to land disturbance and stormwater
runoff. Particulate matter and dust generation is also a potential impact due to demolition
and grading.
o Solid Waste: Construction and demolition on the Site will generate related solid waste.
Those materials not reused or recycled will require disposal.
o Noise/Emissions: Noise, air emissions and vibration will be generated from construction
activities, worker traffic, heavy equipment operation and delivery vehicles.
o Construction Traffic: Traffic volumes will increase from the movement of construction
workers and off-Site construction equipment.
o Asbestos: Projects that involve demolition typically encounter asbestos containing
materials (ACM).
o Worker Safety: Projects of this type have potential impacts to workers including health
and safety concerns typically associated with construction activities.
Mitigation
NYSDEC ROD Amendment: A SMP (which includes an Excavation Work Plan and
Groundwater Management Plan) and various other Remedial Work Plans specific to the area
being addressed will be developed and implemented for all areas of the Site that remain on the
IHWDS Registry, i.e., all areas generally located north of the creek that runs west to east across
the Site.
All work at the Site involving the disturbance of impacted soils or groundwater in the IHWDS
areas will also be implemented under CAMPs and Health and Safety Plans in order to ensure
that impacts to on-Site workers and the surrounding community are mitigated.
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o This includes continuous monitoring during periods of impacted soil or groundwater
disturbance by an environmental professional.
Construction activity will be coordinated with NYSDEC-approved remediation to eliminate or
minimize disturbance of impacted media and building materials.
Construction Staging: The majority of the construction will be staged in former Parking Lot #6
(which is the parking area east and uphill of Building 34). This staging area is centrally located
and will allow ease of access to the Site and also provides a large paved area to reduce
temporary construction impacts. The area utilized for staging will be fenced and gated to control
access.
o Lot #6 will be used as a staging area and will minimize traffic interruptions by providing
two separate construction access points on NYS Route 96B that can easily be operated
and maintained with typical flagging in accordance with NYSDOT requirements or with
the addition of temporary traffic signalization. This central staging area will also maintain
the pedestrian, bicycle and vehicle access and parking for the CWD population
throughout the multiple development phases.
o Limits of disturbance during construction will be clearly delineated to reduce
encroachment into sensitive or prohibited areas and the areas of disturbance will be
limited to the extent practicable.
o The Site Plan drawings for Phase I include a detailed construction staging plan.
o Project identification and wayfinding signage to distinguish construction and public
access points will be used. Signage shall also be provided to indicate contacts for
complaints and/or questions regarding the Project. Signage shall be maintained
throughout the construction phase.
Soil Erosion/Dust: A generic SWPPP has been prepared for the full development of the Site. A
Full SWPPP is developed for the Phase I Site Plans in accordance with the NYS SWMDM and
the NYS Erosion and Sediment Control Manual. Mitigation will include coverage under a
SPDES General Construction Permit (GP-0-15-002), installation of proper erosion and sediment
(E&S) control measures in accordance with the approved SWPPP, and weekly inspections by a
Qualified Professional.
Dust creation is also mitigated by implementing the SWPPP. Specific mitigation will include
wetting of roadways and hydroseeding/mulching immediately upon grading to minimize dust and
promote vegetative cover. Potential fugitive dust emissions from material storage piles will be
controlled through the use of enclosures, seeding, covers or spraying with a dust suppressant
as necessary.
The generation of airborne demolition-related dust will be reduced through standard
construction practices including application of dust suppressants over the involved area to
minimize blowing and circulation of exposed soils/materials.
The need for blasting will be minimized as much as possible. If blasting is deemed necessary,
any permits and authorizations will be clearly identified and obtained as part of the Site Plan
approval process prior to commencing. Blasting specifications would be developed in
accordance with NYSDOT procedures for blasting. Any blasting will be minimized when
developing grading plans.
Solid Waste: Prior to demolition, the Project Sponsor will consult with Finger Lakes ReUse to
determine eligibility for their “deconstruction” program that identifies suitable buildings for
deconstruction, safely dismantles them by hand to harvest maximum materials, and then sells
the materials through their existing ReUse Center at discounted prices. All other metal
construction debris will be separated and recycled. Any remaining debris will be disposed of at a
permitted construction and demolition (C&D) landfill.
Construction disposal plan for non-recyclable construction waste handling and removal in
accordance with local regulations and following LEED guidelines will be developed. Phase-
specific disposal plans will be developed during the Site Plan Approval process.
All remaining demolition debris will be disposed of at C&D landfills or recycling facilities
permitted by NYSDEC (per 6 NYCRR 360 Solid Waste Management Facilities). NYSDEC
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requires demolished materials containing lead paints to be disposed of at permitted C & D
facilities.
Noise/Emissions: Proper maintenance of all construction equipment and appropriate muffler
systems on all equipment will be required. Construction vehicles will be shut down whenever
practicable and the idling of such vehicles will not be permitted.
The Project will be governed by the respective City and Town guidelines for construction
schedules and local noise ordinances. Hours of operation for exterior construction will be limited
to the hours of 7:00 am to 6:00 pm Monday through Saturday, or as per the City/Town
Ordinances for noise. Interior construction will be limited to Monday through Saturday from 7:00
am to 11:00 pm.
Construction Traffic: A safe construction/delivery routing plan will be developed. This includes
the development of a Maintenance and Protection of Traffic Plan for all work zone areas.
Parking for construction-related personnel will be located on-Site.
Asbestos/Hazardous Materials: An asbestos survey in accordance with 12 NYCRR 56 Section 5
will be completed for all structures scheduled for renovation or demolition prior to such activity to
determine the presence, if any, of asbestos-containing building materials. This survey will be
performed by a licensed asbestos inspector certified in compliance with 12 NYCRR 56 Section
3.2.
Worker Safety: All work will be completed in accordance with OSHA requirements including
developing an accident prevention program that provides for frequent and regular inspection of
the jobsites, materials, and equipment by competent persons designated by the employers in
accordance with 29 CFR 1926.20(b).
14. Irreversible and Irretrievable Commitments of Resources
As part of the impact analysis SEQR requires that the GEIS identify the irreversible and irretrievable
commitment of resources, if any. The GEIS identified several irreversible and irretrievable commitments
of resources required for construction and operation of the Build Alternatives, which would include
construction materials, energy (construction and operation phases), labor, capital, and land. The
Project Sponsor will undertake practical efforts to minimize impacts through the implementation of a
project-specific Sustainability Program, using LEED ND as the framework for the development and
operation of the Project.
Public and private financial commitment is likely to provide residents and municipalities in the
immediate area, region, and State with increased property and sales tax revenue, growth in land values
surrounding the Site, other revenues directly or indirectly generated by the new development, and other
intangible quality of life benefits to the City and Town such as the provision of improved access to
downtown and the 95 acre parcel itself. Therefore, the financial investment in the Project represents
long-term beneficial effects, rather than irreversible or irretrievable commitments of resources.
15. Unavoidable Adverse Impacts
SEQR also requires an analysis of unavoidable adverse impacts. The GEIS found that the Build
Alternatives are generally consistent with local and regional plans and policies for redeveloping the Site
and would result in significant short- and long-term benefits. However, some unavoidable adverse
impacts would result from implementation of the Build Alternatives. The unavoidable adverse impacts
are similar for each Build Alternative but may vary in degree of impact.
Construction-phase impacts would include localized and temporary impacts to soil erosion, solid waste
generation, sound levels, air quality, and traffic. Short-term noise impacts associated with construction-
related vehicles would be regulated by local and State regulations and standards. Soil erosion would be
mitigated through the NYSDEC SPDES process and the development of project specific SWPPPs. Air
quality impacts would be limited to short-term increases in fugitive dust and mobile source emissions
41
from construction equipment. Construction traffic will be minimized with the development of on-site
staging areas.
Overall, the Build Alternatives would have significant, positive long-term impacts. However, as with any
sizable urban development, there may be minor long-term impacts. These impacts include increased
vehicular traffic, noise and air quality resulting from denser development patterns. Some existing
viewsheds will be altered due to the placement of new structures on the site. In addition, there would
be impacts to public utilities due to increased usage including natural gas, electric, fiber optics, public
water, and sanitary/storm sewers.
16. Growth Inducing Aspects
Under SEQR the GEIS must also analyze potential growth-inducing aspects of the Project. The GEIS
identified the following growth-inducing aspects: The Project would provide significant investment and
potential growth in the City and the Town through the revitalization of a vacant industrial site. Through
the revitalization and transformation of a large, underutilized Site with identified environmental
challenges, the CWD will function as a lively, mixed-use, sustainable community and regional
destination.
In particular, the Project would include the construction of a substantial mixed-use neighborhood
including residential, commercial, office, and industrial/maker-space opportunities. This, in turn, would
expand the City’s employment base as well as add much needed new housing. The Project addresses
two of the underlying causes of gentrification: low housing supply and a shortage of developable land in
the City for new housing. Rezoning the CWD to allow the development of new housing will reduce
pressure on existing neighborhoods to accommodate Ithaca’s job growth and demand for housing in
walkable neighborhoods.
17. Effects on the Use and Conservation of Energy Resources
The construction and operation of the Build Alternatives would have both short-term and long-term
impacts on the use and conservation of energy resources. In the short-term, construction of all Build
Alternatives would require the use of nonrenewable energy resources including: gasoline, diesel fuel,
and electricity. In addition to construction-related energy use by equipment, the indirect use of energy
would also occur as a result of construction workers commuting to and from the construction site.
The long-term impacts of each Build Alternative on energy resources would differ in magnitude for each
of the Build Alternatives with the Low-Density Alternative having the least impact and the High-
Long-term impacts on the use and conservation of energy will result from the consumption of energy
from day-to-day Project operations, such as heating, cooling, powering various commercial and
industrial operations and lighting buildings, and from Project generated traffic. Long-term impacts on
the use and conservation of energy will result from the consumption of energy from day-to-day Project
operations, such as heating, cooling, powering various commercial and industrial operations and
lighting buildings, and from Project generated traffic.
New buildings will meet LEED ND criteria and include efficient design and renewable energy systems
necessary to achieve at least a 70% reduction in fossil fuel use in compliance with the Architecture
2030 Challenge. That would reduce total energy usage by up to 53,000 MMBTUs per year and return
the usage estimates to pre-developed estimates for typical industrial use of the existing Site based on
the 821,200 sf gross square area (GSA) .
Finally, the Project’s adaptive reuse of existing buildings allows for the preservation of the energy
embodied in existing buildings. By preserving the existing buildings where feasible, the Project will
avoid the disposal of thousands of BTUs worth of building materials. Building reuse extends the life
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cycle of buildings and conserves resources such as energy by requiring less manufacturing and
transportation of materials.
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THRESHOLDS:
Pursuant to SEQR, Agencies may prepare a GEIS when there is a need to assess a wide variety of impacts at
a more conceptual level on a larger geographic area, often including cumulative impacts, rather than project-
specific or site-specific EISs. As Project plans move forward, Project changes may occur as the conceptual
development plan is developed into final design proposals for the well-defined elements, but more likely, for the
less defined components. Such changes may specifically include proposed changes to the contemplated
development program.
The Project was evaluated utilizing a GEIS to analyze Site-specific impacts associated with various aspects of
the Preferred Alternative as well as more long-term and/or cumulative impacts associated with future phases of
Project development. Final designs for less-defined Project components as well as any proposed changes to
the more well-defined elements (hereinafter referred to as “Future Project Plans.”) would require further
evaluation pursuant to SEQR. The City of Ithaca Planning and Development Board, as Lead Agency, would be
responsible for performing an environmental review on Future Project Plans and must consider Future Project
Plans proposed in relation to the GEIS and the Findings Statement. Upon development of Future Project
Plans, the Project Sponsor would work with the Lead Agency to determine if the environmental impacts
associated with such Future Project Plans have been adequately addressed in the GEIS and SEQR Findings
Statement, taking into account whether the proposal exceeds any of the thresholds outlined below. Such a
determination must be made before any Future Project Plans are approved. A Checklist for Future Project
Plans Consistency with GEIS has been developed and is attached hereto as Attachment C.
In the event that the Lead Agency determines that:
I. Future Project Plans would be carried out in conformance with the conditions and thresholds
established in below, then no further SEQR compliance would be required;
II. Future Project Plans would be carried out in conformance with the conditions and thresholds
established below, but are not addressed or are not adequately addressed in this Statement of
Findings, then an amended findings statement must be prepared;
III. Future Project Plans are not addressed or are not adequately addressed in the GEIS for the
Project, but the proposal does not exceed any of the thresholds established below, or the
proposal does exceed a threshold(s) established in below, but would not result in any significant
adverse environmental impacts, then a negative declaration must be prepared; or
IV. Future Project Plans are not addressed or are not adequately addressed in the GEIS for the
Project and/or the proposal would exceed one of the thresholds established below and may
have one or more significant adverse environmental impacts, then a supplement to the GEIS
must be prepared.
Future Project Plans that exceed any one of the following conditions or thresholds shall not be considered to
have been addressed by the GEIS/Findings Statement and must be evaluated by the Lead Agency to
determine whether additional environmental review (e.g., a Supplemental Generic Environmental Impact
Statement) would be necessary:
Environmental Setting
Threshold/Condition
Land Use
Material changes to when site plan approvals are triggered; allowable uses
in Sub Areas; size and location of Sub Areas (see Figure 2.1-3 and Table
2.7-1); required buffers; maximum Sub Area coverage; and maximum
density.
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A material change to the Conceptual Site Layout Plan such as the general
location or grouping of structures and streets or Site access points.
Total square footage of uses (residential, commercial and industrial) as set
forth in Table 2.7-1.
Land – Topography
Development proposed on slopes greater than or equal to 20%.
Water Resources – Stormwater
Future proposed action likely to exceed total impervious site coverage rate
of 70%.
Vegetation
Non-recreational facilities proposed in CW1.
Material change to size (23.86 acres) and location of CW1.
Public Health and Environment
The NYSDEC Issued ROD Amendment to allow for the mixed-use of the
Site does not call for a remedial action different from those analyzed in the
GEIS.
Transportation
Future proposed action likely to exceed a mixed-use development of 1.7
MSF or square footage allocations for land uses set forth in Table 5.7-4.
Utilities
Water
Discharge to Turner Place Sewer
Discharge to South Cayuga Street Sewer
Total peak sewer discharge
Natural Gas / Electric
Light
Proposed action likely to cause the Project’s total demand to exceed:
271,500 GPD and peak @ 1500 gpm
2,033 gpm
1,450 gpm
1,500 gpm
143,400 MMBTUs
Not to exceed Design Guidelines, Table 13
Air Quality
Proposed action likely to cause Project’s total emission of carbon dioxide
equivalent to exceed 2,686 tons/year.
Visual and Aesthetic Resources
Proposed maximum building height exceeds Design Guidelines, Table 7.
Material change to size (23.86 acres) and location of CW1.
Open Space
Non-recreational facilities proposed in CW1.
Material change to size (23.86 acres) and location of CW1.
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CERTIFICATION OF FINDINGS:
Having considered the DGEIS and the FGEIS, including the comments received on the DGEIS and the FGEIS,
and having considered the preceding written facts and conclusions relied upon to meet the requirements of 6
NYCRR 617.9, the Lead Agency finds and certifies that:
I. The requirements of Article 8 of the New York State Conservation Law and the implementing
regulations of NYSDEC, 6 NYCRR Part 617, and local regulations, have been met; and
II. Consistent with social, economic and other essential considerations from among the reasonable
alternatives available, the action is one that avoids or minimizes adverse environmental impacts
to the maximum extent practicable, and that adverse environmental impacts will be avoided or
minimized to the maximum extent practicable by incorporating as conditions to the decision
those mitigative measures that were identified as practicable.
The City’s designees are hereby directed to file and distribute this Findings Statement as required by 6
NYCRR Part 617 pertaining to Article 8 of the Environmental Conservation Law (SEQR).
These Findings were adopted by majority vote of the City of Ithaca Planning and Development Board at a duly
called meeting held on ****, 2019.
City of Ithaca Planning and Development Board
108 East Green Street
Ithaca, New York 14850
Signature of Responsible Officer:__________________________________ Date:___________________
Name/Title of Responsible Officer:_________________________________
Doc #01-3226261.2
Findings PageSubject Revision to Findings StatementRevisions to FGEISRevisions to FGEIS/Comments MatrixReason17Public HealthADD Bullet: The Lead Agency further understands that the property owner performed a Boundary Reassessment Study that assessed conditions on the 36.76 acre undeveloped portion of the Site to the south of the creek that runs east/west across the Site and produced evidence that prior operations and/or disposal did not take place in that area. As a result, NYSDEC realigned the IHWDS boundary to exclude that southern portion of the Site from remedial requirements of the IHWDS Registry. Because of the presence of soil vapors in the vicinity of the sewer lines running through that portion of the Site, the property owner filed a declaration of covenants and restrictions requiring that the potential for soil vapor intrusion be addressed to the satisfaction of NYSDEC and NYSDOH whenever any habitable structures are built within an 80 feet wide area around the sewer lines. ADD to FGEIS Page 2-9 after third paragraph and Page 3-19 at the end of the fourth paragraph: As a result, NYSDEC realigned the IHWDS boundary to exclude that southern portion of the Site from remedial requirements of the IHWDS Registry. Because of the presence of soil vapors in the vicinity of the sewer lines running through that portion of the Site, the property owner filed a declaration of covenants and restrictions requiring that the potential for soil vapor intrusion be addressed to the satisfaction of NYSDEC and NYSDOH whenever any habitable structures are built within an 80 feet wide area around the sewer lines. ADD to FGEIS Appendix G Page 5-45 at end of first paragraph and Page 5-64 at end of third paragraph: As a result, NYSDEC realigned the IHWDS boundary to exclude that southern portion of the Site from remedial requirements of the IHWDS Registry. Because of the presence of soil vapors in the vicinity of the sewer lines running through that portion of the Site, the property owner filed a declaration of covenants and restrictions requiring that the potential for soil vapor intrusion be addressed to the satisfaction of NYSDEC and NYSDOH whenever any habitable structures are built within an 80 feet wide area around the sewer lines. ADD to Comment Matrix Summary 5.5-1, 5.5-4, 5.5-20 and 5.5-21: As a result, NYSDEC realigned the IHWDS boundary to exclude that southern portion of the Site from remedial requirements of the IHWDS Registry. Because of the presence of soil vapors in the vicinity of the sewer lines running through that portion of the Site, the property owner filed a declaration of covenants and restrictions requiring that the potential for soil vapor intrusion be addressed to the satisfaction of NYSDEC and NYSDOH whenever any habitable structures are built within an 80 feet wide area around the sewer lines.REVISE response to Comment Summary 5.5-35 to remove referenece to "NYSDEC is currently reviewing the Boundary Reassessment" to "NYSDEC has completed the review".Additional environmental work completed since DGEIS and now documented.21HistoricADD to Mitigation: Currently the Project Sponsor is not seeking historic tax credits as originally considered during the DGEIS process. Subsequent consultation with NYSOPRHP determined that the redevelopment of the buildings as mixed-use structures utilizing the Architecture 2030 goals precluded coverage under the historic tax credit system. The change of use and redevelopment of the existing buildings in accordance to current energy/buildings codes will take precedence over the following historic mitigation: DELETE in FGEIS "There are no revisions or updates to this Section" for Section 4.10 on FGEIS Page 4-6 and REPLACE with the following: REPLACE:Replace the text "Other mitigation measures include:" on DGEIS Page 5-65 with "Currently the Project Sponsor is not seeking historic tax credits as originally considered during the DGEIS process. Subsequent consultation with NYSOPRHP determined that the redevelopment of the buildings as mixed-use structures utilizing the Architecture 2030 goals precluded coverage under the historic tax credit system. The change of use and redevelopment of the existing buildings in accordance to current energy/buildings codes will take precedence over the following historic mitigation:"None required. Not a response to Comments.Meeting after the DGEIS with NYSOPRHP Officials. 21HistoricREPLACE: "preservation professional" with "appropriate professional".ADD to FGEIS Page 4-6 for Section 4.10 the following:REPLACE:Replace the term "preservation professional" with "appropriate professional" in DGEIS Section 5.6.3 on Page 5-65.None required. Not a response to Comments.This work can be performed by Architects, Engineers or Historians.NoneHistoricCORRECTION of Comment Summary ID.CORRECT on FGEIS Page 3-40 Comment ID 5.7-1 to 5.6-1 under the Historic & Archaeological Resources Section (DFEIS Section 5.6).None required. Not a response to Comments.Correction.25TrafficMOVE to Post Phase I Mitigation: The Lead Agency understands that Washington State’s Commute Trip Reduction (CTR) program and CTR Efficiency Act, a law passed by the State Legislature, requires local governments in urban areas with traffic congestion to develop programs that reduce SOV trips and Vehicle Miles Travelled (VMT) per capita. The Project Sponsor has committed to adapt and scale this program to the projected employment centers proposed within the CWD.ADD to FGEIS Page 3-48 the last sentence of the third paragraph: "… as part of the Post Phase I mitigation." ADD to FGEIS Appendix G Page 5-130 at end of first full paragraph: "…as part of the Post Phase I mitigation."ADD to the last sentence of third paragraph of Comment Matrix Summary 5.7-19: "… as part of the Post Phase I mitigation."CTR is only effective in large developments or on a Community scale. Phase I is too small for this to work.25-26TrafficMOVE to Post Phase I Mitigation the Entire section of: TDM or CTR initiatives will be implemented as follows: ADD to the end of the first sentence on Page 1-148 of the FGEIS Appendix G the following: "… as part of the Post Phase I Mitigation".ADD to Comment Matrix Summary 5.7-19: Post Phase ITDM or CTR initiatives will be implemented as follows:o Transit Coordination – Continued coordination with TCAT on transit routes and marketing the nearby routes of 65 and 11. TCAT bus line will boost ridership through increased awareness coupled with improved service.o Route Expansion – Working with TCAT to provide new/expanded bus service through the Site provides an opportunity for greater mode choice resulting in trip and parking reductions.o Bus Stop Amenities – A clean, well-lit, informative bus stop with shelters and seating greatly improves the image of the transit serving an area. Bus stop amenities make taking the bus a comfortable experience, while proper maintenance tells people that transit makes up an important part of the neighborhood.o Employer Carpooling – Carpooling will be encouraged by providing incentives and other services such as ride-matching.o Emergency Ride Home – In case of a personal emergency during the day, transportation is provided at no cost to one’s vehicle, residence, or other place such as childcare, doctor’s office, etc.o Preferential carpool/vanpool parking – Investigate the use of vRide for employers located on the Site.o Transportation Alternatives Information – Bus schedules, walking and bicycling maps, neighborhood and on-Site wayfinding will be made readily available.o Telecommuting and compressed work schedules – Employers will be encouraged to offer flexible work options. Employee vehicle trips are reduced by the percentage of employees that telecommute or have a “free” day gained through a compressed schedule, on an average day.o Location and Quantity of Bicycle Parking Spaces – The Project will include convenient bicycle parking locations in clear sight of access points into buildings, safe and secure longer term storage within parking areas, and a sufficient number of bicycle parking The structural elements of TDM are located in areas outside of Phase I. Also the remaining items require a large scale of development, larger than Phase I, to implement.33UtilitiesREMOVE: As a participant in the City NY Prize microgrid study.Revise FGEIS Page 4-6 Section 4.12 by adding the following: UPDATE By removing the following language from DGEIS Page 5-148: "As a participant in the City NY Prize microgrid study," so that is reads as follows: "Alternative energy measures are being investigated for the Site including PV, wind, and CHP or cogeneration systems. See Subsection 2.6.3 for further discussion."None required. Not a response to Comments.South Hill was removed from the Study by the Microgrid Consultants to focus on the remaining portion of the City.Last Updated: February 19, 2019Chain Works DistrictFGEIS Errata
Lead Agency: City of Ithaca Planning and Development Board
City of Ithaca
108 East Green Street
Ithaca, New York 14850-5690
Contact Person: Lisa Nicholas, $,&3Senior Planner
Department of Planning, Building & Economic Development
City of Ithaca
7
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Project Sponsor: UnChained Properties, LLC
225 Colonial Drive
Horseheads, NY 14845
Contact Person: David Lubin - T: 607-739-3826
Prepared By: Fagan Engineers and Land Surveyors, PC
113 East Chemung Place
Elmira, NY 14904
Contact Person:-DPHV*HQVHO3(&3(6&
7 H[W
( -DPHV*HQVHO#)DJDQ(QJLQHHUVFRP
Accepted and Issued by the City of Ithaca Planning and Development Board as Lead Agency. The
statutory ten day period is complete by ***, 2019
New York State Environmental Quality Review Act
Final Generic Environmental Impact Statement
CHAIN WORKS DISTRICT
REDEVELOPMENT PROJECT
620 South Aurora Street
NYS Route 96B
City of Ithaca
Town of Ithaca
Tompkins County
New York
Draft: February 10, 2019
Table of Contents
CHAIN WORKS DISTRICT
February 10, 2019
Final Generic Environmental Impact Statement
Table of Contents
Table of Contents Page i
CHAIN WORKS DISTRICT
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Final Generic Environmental Impact Statement
EXECUTIVE SUMMARY �����������������������������������������������������������������������������������������������������ES-1
CHAPTER 1: INTRODUCTION ��������������������������������������������������������������������������������������������1-1
1�1 The Final Generic Environmental Impact Statement����������������������������������������������������� ����1-1
1�2 Chronology of the SEQR Process ���������������������������������������������������������������������������������������1-2
1�3 Interested and Involved Agencies ���������������������������������������������������������������������������������������1-3
1�4 DGEIS Public Hearing and Comment Period ���������������������������������������������������������������������1-3
1�5 Additional Public Outreach ��������������������������������������������������������������������������������������������������1-4
1�6 Comments Received and Changes to DGEIS ��������������������������������������������������������������������1-4
1�7 FGEIS Consideration Period ������������������������������������������������������������������������������������������������1-4
1�8 Incorporation by Reference �������������������������������������������������������������������������������������������������1-4
CHAPTER 2: PROJECT DESCRIPTION �����������������������������������������������������������������������2-1
2�1 Overview ��������������������������������������������������������������������������������������������������������������������������������2-1
2�2 Project Location ��������������������������������������������������������������������������������������������������������������������2-1
2�3 Brief Description of the Preferred Alternative ��������������������������������������������������������������������2-2
2�4 Project Updates since Publication of the DGEIS ���������������������������������������������������������������2-5
2�4�1 Revised Conceptual Site Layout Plan
2�4�2 Revised Chain Works District Form and Use Regulations
2�5 NYSDEC Coordination Updates Outside of the GEIS Process ����������������������������������������2-5
2�5�1 Introduction and Background
2�5�2 Phase II Supplemental Remedial Investigation and Existing Conditions Update
2�5�3 Boundary Reassessment
2�5�4 IRM Work Plan and Update to Mitigation Measures
2�5�5 Feasibility Study and Update to Mitigation Measures
2�6 Summary of Impacts and Mitigation Resulting from Project Updates ���������������������������2-13
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CHAPTER 3: COMMENTS AND RESPONSES TO COMMENTS �������������������������������3-1
3�1 Overview ��������������������������������������������������������������������������������������������������������������������������������3-1
3�2 Comment Summaries and Responses ��������������������������������������������������������������������������������3-2
CHAPTER 4: DESCRIPTION OF CHANGES TO THE DGEIS ������������������������������������4-1
4�1 Introduction ���������������������������������������������������������������������������������������������������������������������������4-1
4�2 DGEIS Chapter 2: Project Description ��������������������������������������������������������������������������������4-2
4�3 DGEIS Chapter 3: Reasonable Alternatives �����������������������������������������������������������������������4-5
4�4 DGEIS Chapter 4: Public Participation �������������������������������������������������������������������������������4-5
4�5 DGEIS Chapter 5: Section 5�1 - Land Use and Zoning ������������������������������������������������������4-5
4�6 DGEIS Chapter 5: Section 5�2 - Land ����������������������������������������������������������������������������������4-6
4�7 DGEIS Chapter 5: Section 5�3 - Water Resources �������������������������������������������������������������4-6
4�8 DGEIS Chapter 5: Section 5�4 - Vegetation and Fauna �����������������������������������������������������4-6
4�9 DGEIS Chapter 5: Section 5�5 - Public Health and Environment �������������������������������������4-6
4�10 DGEIS Chapter 5: Section 5�6 - Historic and Archaeological Resources ������������������������4-6
4�11 DGEIS Chapter 5: Section 5�7 - Transportation and Circulation ��������������������������������������4-6
4�12 DGEIS Chapter 5: Section 5�8 - Utilities �����������������������������������������������������������������������������4-6
4�13 DGEIS Chapter 5: Section 5�9 - Air Quality ������������������������������������������������������������������������4-6
4�14 DGEIS Chapter 5: Section 5�10 - Visual and Aesthetic Resources ����������������������������������4-6
4�15 DGEIS Chapter 5: Section 5�11 - Community Services �����������������������������������������������������4-6
4�16 DGEIS Chapter 5: Section 5�12 - Open Space and Recreation �����������������������������������������4-7
4�17 DGEIS Chapter 5: Section 5�13 - Construction Activities �������������������������������������������������4-7
4�18 DGEIS Chapter 6: Irreversible and Irretrievable Commitment of Resources ������������������4-7
4.19 DGEIS Chapter 7: Unavoidable Adverse Effects ���������������������������������������������������������������4-7
4�20 DGEIS Chapter 8: Growth Inducing Aspects and Character of Community �������������������4-7
4.21 DGEIS Chapter 9: Effect of Proposed Project on Use and Conservation of Energy �����4-8
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LIST OF APPENDICES
Appendix
Appendix A:
Appendix B:
Appendix C:
Appendix D:
Appendix E:
Appendix F:
Appendix G:
Title
DGEIS Hearing Materials
Comments Received on the DGEIS
Index of Comments and Responses
PUD/PDZ Form and Use Regulations
Additional Public Health Documents
Supplemental Traffic Analysis Report
Redlined DGEIS Replacement Sections
Executive Summary
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Final Generic Environmental Impact Statement
Executive Summary
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ES.1 Introduction
This Final Generic Environmental Impact Statement (FGEIS) is issued for the Chain Works District (CWD
or the Project) by the City of Ithaca Planning and Development Board (Planning Board) as Lead Agency
pursuant to and in compliance with Article 8 of the New York State Environmental Conservation Law and
its implementing regulations commonly known as the State Environmental Quality Review Act (SEQR).
UnChained Properties, LLC (UP), is the Project Sponsor for the Project, which is a mixed-use real estate
redevelopment of the former Morse Chain / Emerson Power Transmission industrial facility that spans
both the City and Town of Ithaca, New York.
The FGEIS, incorporating by reference the Draft Generic Environmental Impact Statement (DGEIS) for
CWD, forms the basis for Project-related decision making. SEQR regulations require that the FGEIS
include the DGEIS, including any revisions or supplements to it; copies or a summary of the substantive
comments received and their source; and the Lead Agency’s responses to all substantive comments. All
volumes of the DGEIS which were accepted by the Planning Board on March 8, 2016 are incorporated
herein by reference in their entirety.
After the issuance of this FGEIS, the public and involved agencies will be afforded a reasonable time
period, not less than 10 calendar days, in which to consider the FGEIS. After this reasonable time period
has passed, the Planning Board as Lead Agency, as well as the Involved Agencies, will issue a
Findings Statement prior to making a determination whether to undertake the Project.
Following a detailed design charrette planning process with extensive public outreach and involvement,
UP presented an initial concept plan and SEQR Long EAF at the October 28, 2014 meeting where
the Planning Board declared Lead Agency in accordance with Ithaca Environmental Quality Review
Ordinance, §176-4 B. (6), and the State Environmental Quality Review Act, §617.4 (b)(3) and also issued
a Positive Declaration of Environmental Significance. The scope for the GEIS was adopted on January
13, 2015. Following a detailed design charrette planning process with extensive public outreach and
involvement, UP unveiled a detailed concept site layout plan and DGEIS for CWD at the January 5,
2016 Planning Board Meeting. On March 8, 2016, the Planning Board determined that the DGEIS was
complete and adequate for public review and scheduled a public hearing. Copies of the DGEIS were
made available for public review at the City of Ithaca Planning Department, the Town of Ithaca Planning
Department, the City of Ithaca Office of the Clerk and the Tompkins County Public Library. A copy of the
DGEIS was also posted on the CWD website. A Notice of Completion of the DGEIS and Notice of Public
Hearing appeared in The Ithaca Journal on March 26, 2016 and the Environmental Notice Bulletin (ENB).
A public hearing was held on March 29, 2016 at the Cinemapolis movie theater. Due to extensive public
interest in the Project and several requests made during the DGEIS public hearing, the public comment
period, originally scheduled to expire on May 10, 2016, was extended until May 25, 2016.
Notices of comment period extension were published in the Ithaca Journal, City Planning and Development
Board website and on the CWD website. Additionally, comments received after the end of the public
comment period prior to the issuance of the FGEIS have been accepted and responded to within this
FGEIS.
ES.2 Description of the Project
Overview
DGEIS Chapter 3 provides a detailed description of the Preferred Alternative as well as UP’s goals,
objectives and constraints. As the entire DGEIS has been incorporated by reference, Chapter 2 of the
FGEIS is limited to a brief summary of the Preferred Alternative as well as a description of updates that
have been made to the Preferred Alternative since the publication of the DGEIS. Project updates are the
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Final Generic Environmental Impact Statement
result of comments received on the DGEIS as well as continuing design refinement associated with the
initial build-out.
Project Location
The Project is located on approximately 95 contiguous acres of land in central NYS, South of Cayuga
Lake in the Finger Lakes Region, and straddles the City and Town of Ithaca border in Tompkins County.
The Site is bounded as follows:
• To the east, the Site follows South Aurora Street / NYS Route 96B, a major transportation corridor
that connects downtown Ithaca to South Hill, Ithaca College, and the residential neighborhoods
in the Town. It is a primary route for travelers from Binghamton and points south.
• To the north, the Site borders residential neighborhoods comprised primarily of single and multi-
family homes in the City.
• To the west, the Site slopes steeply to meet Spencer Street in the City, then traces the back of the
residential properties lining the east side of Spencer Road. In the Town of Ithaca, the property line
traces the alignment of the former Lehigh Valley Railroad and future Gateway Trail, as well as a
large parcel of undeveloped land.
• To the south, the Site borders the South Hill Business Campus in the Town.
Brief Description of the Preferred Alternative
The Project Sponsor seeks to redevelop and rehabilitate the existing architecture and landscape of the
821,200 s.f. former Morse Chain / Emerson Power Transmission facility located on a 95-acre parcel
traversing the City and Town’s municipal boundary, into a 1.7 million square-foot mixed-use district
(Figure 2.3-2 Conceptual Site Layout Plan). The Preferred Alternative is designed to emphasize an urban
connection between the City and Town to develop a LEED ND mixed-use development. This will ensure
the best/highest use of the developable portions of the Site.
Project Updates since Publication of the DGEIS
A number of Project updates have been made to the Preferred Alternative since the publication of the
DGEIS. These Project updates are the result of comments received on the DGEIS as well as continuing
design refinement associated with the initial build-out of the Preferred Alternative.
While some of the revisions are substantial, none of them result in a change to the conclusions outlined
in the DGEIS Chapter 5. The revisions did not impact thresholds, such as building sizes or number of
parking spaces, but were in response to comments mainly due to the LEED ND designation as well as
the development of the PUD/ PDZ. A brief description of the updates follows.
Revised Conceptual Site Layout Plan
• The depiction of the on-Site electrical substation infrastructure.
• The inclusion of the conceptual location of the nature trails throughout the CW1 Sub Area.
• Additional sidewalks and trails to ensure connectivity between Sub Areas.
• The alignment of the proposed Gateway Trail through CWD as well as proposed Alternates in
case of trail closure.
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Revised Chain Works District Form and Use Regulations
• Sub Area enumeration was expanded to create additional sections within the CW2 (A/B) and
CW3 (A/B) zones to define additional design thresholds for areas along NYS Route 96B.
• Definitions were adjusted to ensure consistency between the PUD or PDZ with the corresponding
Zoning Law for each municipality. Duplicate definitions were then removed. The PUD definitions
were also revised to ensure consistency with the Collegetown Area Form District (CAFD).
• Required buffer areas were added to the Design Standards.
• A separate set of Design Guidelines was added to the Design Standards to set ideal parameters
for new development which may not be feasible for every project within CWD; as such, the
guidelines and intents should serve as a benchmark for projects pursuing site plan approval.
Summary of Impacts and Mitigation Resulting from Project Updates
As a result of the Project updates, the density of Project development has not changed and therefore do
not materially alter the impact and mitigation analyses in the DGEIS Chapter 5.
ES.3 Comments and Responses to Comments
A total of 280 distinct comments were identified during the DGEIS Public Comment period. Following
identification of each distinct comment, all of the comments were carefully reviewed. A summary for each
comment was created and a response identified, with similar comments grouped together by DGEIS
topic area. Comments were grouped into the following areas:
• Site Program
• SEQR
• Zoning
• Land
• Water Resources
• Vegetation and Fauna
• Public Health and Environment
• Historic and Archaeological Resources
• Transportation
• Utilities
• Visual and Aesthetic Resources
• Community Services
• Open Space and Recreation
• Construction
• Growth Inducing Aspects
• Character of Community
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Final Generic Environmental Impact Statement
• Use and Conservation of Energy
The FGEIS provides a summary of all substantive comments and responses to comments received on the
DGEIS. Copies of all emails, letters and the transcript of the public hearing are provided in Appendices
A and B of the FGEIS.
ES.4 Description of Changes to the DGEIS
The FGEIS incorporates changes to the DGEIS resulting from public/agency comments on the DGEIS,
Project redesign/refinement since the DGEIS, and the development of additional relevant information that
was not available at the time of publication of the DGEIS. While not an all-inclusive list, these changes
are briefly summarized below.
Land Use and Zoning
Zoning Sub Areas CW2 and CW3 were split into two subsections in response to multiple comments
regarding the need for variations in the zoning for sections of the project adjacent to NYS Route 96B/
Danby Road. Sub Area CW2 was split into CW2A and CW2B to further delineate allowable uses during
the review of the PDZ by the Town of Ithaca. Sub Area CW3 was split into CW3A and CW3B to reduce
the number of stories allowed in the development along NYS Route 96B.
The other major revision occurred during the review of the PUD and PDZ which altered the technical
guidance from Design Standards to Design Guidelines.
Land
No alterations to Land have occurred since issuance of the DGEIS.
Water Resources
No alterations to Water Resources have occurred since issuance of the DGEIS.
Vegetation and Fauna
No alterations to Vegetation and Fauna have occurred since issuance of the DGEIS.
Public Health and Environment
Using results and analyses from investigations that occurred after DGEIS publication, this subsection of
Chapter 4 of the FGEIS simply references Appendix G of the FGEIS which, presents a complete rewrite
of Section 5.5 of the DGEIS. This change in format makes the revisions arising from the significant
additional information easier to follow. The revised Section 5.5 of the DGEIS that tracks all the edits is
presented in Appendix G. The changes are briefly summarized below.
The Site is part of a larger 95.93-acre parcel (Property) which is listed on the New York State
Inactive Hazardous Waste Disposal Site (IHWDS) Registry because contamination from former
manufacturing operations have created a significant threat to human health or the environment. The
Site is designated Operable Unit-2 (OU-2). OU-1 (also known as the former fire water reservoir area),
currently undergoing long-term ground water treatment, will remain with the property owner. The
current Record of Decision (ROD) calls for OU-2 to be remediated to allow for industrial use of the
Property. Therefore, the New York State Department of Environmental Conservation (NYSDEC) will
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Final Generic Environmental Impact Statement
need to amend the ROD to allow for the Project Sponsor’s proposed mixed-use development of the Site.
The property owner completed a Phase II Supplemental Remedial Investigation after the DGEIS was
published. The investigation defined the nature and extent of contamination within Areas of Concern
(AOCs) discussed in the DGEIS. The investigation results allowed for defining the various AOCs with
better specificity than was set forth in the DGEIS. The contaminants of concern exceeding their cleanup
standards for ground water, seeps, soil and/or sediment at the Site have not changed and include barium,
other heavy metals, cyanide, petroleum products, polychlorinated biphenyls, volatile organic compounds
and semi-volatile organic compounds. If not addressed, these contaminants can impact public health
and the environment. The requirements for remediating the Site will be more stringent for mixed-use with
a residential component than what is required under the current ROD, i.e., industrial use only. As a result,
the Project will improve the existing impacts from the Site’s historic uses by causing a ROD amendment
to allow for the mixed-use.
In addition to the beneficial impact the Project Sponsor has already brought to the community by discovering
previously unknown historic impacts through its due diligence, the pending sale of the Property has
encouraged the property owner to propose Interim Remedial Measures (IRMs) to NYSDEC that would
remove both existing sources of contamination in soil impacting ground water and soil contamination that
exceeds cleanup standards to allow for mixed-use development with a residential component. These
proposed IRMs will remove more contamination than is required under the current ROD. They entail
soil excavation to the relevant cleanup standard followed by placement of a demarcation layer and
backfilling with clean material in all instances but one where utilities and other site constraints hamper
the excavation and another area where regrading of impacted soils will occur followed by placement of
a demarcation layer and one foot of clean fill. In that instance, an engineered cap will be placed above
the remaining contamination. Thereafter, soil sampling will occur to determine whether the cleanup
standards have been achieved and to document the remaining impacts. If confirmatory soil sampling
indicates the need, additional excavation will occur unless or until site constraints prevent further digging
or the cleanup standard is reached.
Various remedial actions to address contaminated ground water, seeps and soil vapor at the Site are
being evaluated by the property owner in a feasibility study. NYSDEC will then select the appropriate
remedial actions to implement as part of the ROD amendment process.
The confirmatory soil sample results will be documented and used in a Site Management Plan (SMP) when
designing the appropriate soil and ground water management plans that become a part of that document
and followed during any future ground intrusive activities. These plans will also provide the process
by which one manages any unknown contamination that may be discovered during ground intrusive
activities and require monitoring of such activities by an environmental professional. In addition to soil
excavation and ground water management plans, the SMP will contain a community air monitoring plan,
and operation, monitoring and/or reporting requirements specific to the remedial alternatives selected by
the NYSDEC for the Site. Enforcement by the NYSDEC of the SMP requirements will be through the
filing of an environmental easement covering the Site.
All the remedial techniques mentioned above and to be evaluated in a feasibility study were discussed
in the DGEIS as remedial alternatives and possible mitigation measures. As stated in the DGEIS, none
of these remedial approaches should prevent the safe proposed mixed-use of the Project as depicted in
the Conceptual Site Layout Plan.
The study to assess conditions on the southern-most undeveloped thirty-four acres of the Site discussed
in the DGEIS was completed by additional soil vapor sampling. The study results formed the basis of a
petition by the Property owner to the NYSDEC to have that southern area removed from the requirements
of the IHWDS Registry. Because of the presence of soil vapors in the vicinity of sewer lines running
through that portion of the Site, the property owner plans to file a declaration of covenants and restrictions
requiring that the potential for soil vapor intrusion be addressed to the satisfaction of the NYSDEC and
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Final Generic Environmental Impact Statement
the New York State Department of Health whenever any habitable structures are built within an 80-feet
wide area around the sewer lines.
Historic and Archaeological Resources
No alterations to Historic and Archaeological Resources have occurred since issuance of the DGEIS.
Transportation and Circulation
While other subsections to Chapter 4 of the FGEIS set forth only specific revisions to the DGEIS, this
subsection presents a complete rewrite of Section 5.7 of the DGEIS using results and analyses from
investigations that occurred after DGEIS publication. This change in format makes the revisions arising
from the significant additional information easier to follow. A draft of the revised Section 5.7 of the DGEIS
that tracks all the edits is presented in Appendix G. The changes are briefly summarized below.
Assumptions
As with any traffic impact study, there are multiple assumptions needed by the analyzing Engineer with
performing the analyses and modeling. These assumptions were reviewed by the New York State
Department of Transportation (NYSDOT) and City Traffic Engineer. Those include:
• Confirmation of the assumed 40-mph travel speed on S. Aurora Street by utilizing 2006 NYSDOT
Speed Count data.
• A supplemental narrative is included to reinforce the assumption of the 7% trip generation credit
for active transportation (bicycling and pedestrian).
Analysis
Based on the comments received by the NYSDOT and the City Traffic Engineer, additional analyses
were provided as a response. These analyses include:
• 10 intersections were reanalyzed to include 203 additional apartments as described in the DGEIS
page 5-108.
• In response to the City Traffic Engineer stated concerns of utilizing Cayuga Street and Turner
Place access, additional background information on the estimated Average Daily Traffic (ADT)
was provided. An alternative analysis was performed demonstrating the negative impacts of
removing the Turner Place Access.
• Site access driveway queue analysis to ensure adequacy of the internal roadway network depicted
in the Conceptual Site Layout Plan.
• Sight distance evaluation for each of the Site access driveways.
• Left turn lane/phasing warrant analysis for eastbound State Street at Stewart Avenue.
• Additional AutoTURN analysis for the fire apparatus movements to include access via Cayuga
Street, Turner Place and Site Access IV.
Mitigation
Mitigation measures have been revised and further refinement of definitions provided based on comments
Executive Summary Page ES-7
CHAIN WORKS DISTRICT
February 10, 2019
Final Generic Environmental Impact Statement
received. The revisions and updates to the mitigation include:
• Project Sponsor shall introduce and implement Transportation Demand Management (TDM)
strategies to reduce Single Occupancy Vehicle (SOV) trips to and from the Site. Specific TDM
practices are outlined for Phase 1 implementation and for subsequent phases.
• Due to the potential variability of the impacts from project phases beyond Phase 1, traffic mitigation
measures should be commensurate to identified traffic impacts, as well as be responsive to
potential deviations from the proposed Project phasing and timeline.
• In order to mitigate post Phase 1 traffic impacts to the maximum extent practicable, following
completion of Phase 1, the Project Sponsor will implement an on-going Monitoring and Mitigation
Implementation Plan (MMI Plan).
• Per NYSDOT, a traffic study update will be required for each phase of the project where
modifications and/or additional mitigation is proposed in the NYSDOT Right of Way (ROW).
• Quantifiable figures, such as modal distribution or average vehicle ridership (AVR), will be used
to report the effectiveness. AVR is the ratio of the total number of employees or residents to the
average daily number of vehicles used. An agreed upon AVR with local officials will be determined.
• An intersection sensitivity analysis that states clearly at what level of traffic volume per intersection
mitigation is necessary.
• In conjunction with the Project, the Project Sponsor will improve the adjacent sidewalk network
in coordination with City Staff as the Site is developed. The internal sidewalk network will be fully
developed in the Site Plan Review phase in coordination with LEED ND requirements.
Utilities
The only revision to the Utilities subsection included correction of the size from 8-inch diameter to 12-inch
diameter of the existing watermain traversing the southern portion of the Site.
Air Quality
No alterations to Air Quality have occurred since issuance of the DGEIS.
Visual and Aesthetic Resources
No alterations to Visual and Aesthetic Resources have occurred since issuance of the DGEIS.
Community Services
No alterations to Community Services have occurred since issuance of the DGEIS.
Open Space and Recreation
A reference to the City of Ithaca publishing a draft Parks and Recreation Master Plan in November 2017
was added.
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CHAIN WORKS DISTRICT
February 10, 2019
Final Generic Environmental Impact Statement
Construction Activities
No alterations to Construction Activities have occurred since issuance of the DGEIS.
Irreversible and Irretrievable Commitment of Resources
No alterations to Irreversible and Irretrievable Commitment of Resources have occurred since issuance
of the DGEIS.
Unavoidable Adverse Effects
The reference to the Ithaca Microgrid feasibility study was removed from the Energy portion of the Long-
Term Unavoidable Adverse Impacts.
Growth Inducing Impacts and Character of Community
A reference to the City of Ithaca publishing a draft Parks and Recreation Master Plan in November 2017
was added. Separately, the number of anticipated adult residents per housing unit was revised to 2.0 to
provide consistency with Chapter 2 of the DGEIS.
Effects of the Proposed Project on the Use and Conservation of Energy
The reference to the Ithaca Microgrid feasibility study was removed.
Thresholds for Future Actions
No alterations to Thresholds for Future Actions have occurred since issuance of the DGEIS.
Cumulative Impacts
No alterations to Cumulative Impacts have occurred since issuance of the DGEIS.
CHAIN WORKS DISTRICT
February 10, 2019Chapter 1: Introduction
Final Generic Environmental Impact Statement
Chapter 1:
Introduction
Page 1-1
CHAIN WORKS DISTRICT
February 10, 2019Chapter 1: Introduction
Final Generic Environmental Impact Statement
CHAPTER 1: INTRODUCTION
UnChained Properties, LLC (UP) (Project Sponsor) has prepared a Draft Generic Environmental Impact
Statement (DGEIS) pursuant to the State Environmental Quality Review Act (SEQR), and City of Ithaca’s
Environmental Quality Review Ordinance (CEQR) (collectively, hereinafter SEQR) to assess the social,
economic, and environmental effects of undertaking the proposed Chain Works District Redevelopment
Project, a 1.7 million square-foot mixed-use redevelopment of the former Morse Chain/Emerson Power
Transmission industrial facility to be known as the Chain Works District (Chain Works) (CWD) (collectively,
the Project).
The Project will transform 821,200 square feet of vacant former industrial space on a 95-acre parcel site
into a revitalized mixed-use “live, work, play” district, i.e., CWD. The Conceptual Site Layout Plan for the
Project (see FGEIS Figure 2.3-2) involves both well-defined elements, such as adaptively reusing many
of the existing buildings, and less defined components such as a market-based build out of future new
buildings projected for later phases of the Project anticipated to span approximately 10 years. Consistent
with the “live, work, play” theme for the district, uses within the CWD are anticipated to include residential,
office, commercial, retail, restaurants, warehousing, distribution, and manufacturing. FGEIS Figure 1-1
illustrates the overall vision for the CWD.
1.1 The Final Generic Environmental Impact Statement
This Final Generic Environmental Impact Statement (FGEIS) is issued for CWD by the City of Ithaca
Planning and Development Board (Planning Board), as Lead Agency pursuant to and in compliance with
SEQR. UP is the Project Sponsor for the Project, which is a mixed-use real estate redevelopment of the
former Emerson Power & Transmission facility that spans a 95 acre parcel in the City and Town of Ithaca,
New York Site.
The FGEIS, incorporating by reference the DGEIS, forms the basis for Project-related decision making.
FGEIS Figure 1-1: Bird’s Eye View of the Chain Works District (CJS)
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February 10, 2019Chapter 1: Introduction
Final Generic Environmental Impact Statement
SEQR regulations require that the FGEIS include the DGEIS, including any revisions or supplements to
it; copies or a summary of the substantive comments received and their source; and the Lead Agency’s
responses to all substantive comments.
After the issuance of this FGEIS, the public and involved agencies will be provided a reasonable time
period, not less than 10 calendar days, in which to consider the FGEIS. After this reasonable time period
has passed, the Planning Board as Lead Agency, as well as the Involved Agences, will issue a
Findings Statement prior to making a determination whether to approve the Project. This Findings
Statement will consider the relevant environmental impacts, facts and conclusions disclosed in
this FGEIS; weigh and balance relevant environmental impacts with social, economic and other
essential considerations; provide a rationale for the Lead Agency’s decision; certify that the
requirements of SEQR have been met; and certify that consistent with social, economic and other
essential considerations from among the reasonable alternatives available, the Action is one that
avoids or minimizes adverse environmental impacts to the maximum extent practicable.
As future development phases envisioned under the Project are fully defined and designed, they will be
reviewed against the thresholds and assumptions outlined in the FGEIS and Findings Statement. If the
scale and characteristics of such future development are consistent with such standards or thresholds,
no further documentation will be required under SEQR. Should a particular future component exceed
any threshold or standard established in the FGEIS or be determined to potentially result in an impact
not considered in the FGEIS or Finding Statement, an additional environmental review and possibly a
Supplemental EIS will be required.
1.2 Chronology of the SEQR Process
The Planning Board commenced the SEQR process by issuing notices to all then-known Involved or
Interested Agencies to solicit Lead Agency status for the Project on October 28, 2014. No objections to
the Planning Board serving as SEQR Lead Agency were made by any Interested or Involved Agency and
the Planning Board was properly established as the SEQR Lead Agency for the environmental review of
the Project in November 2014.
Following a detailed design charrette planning process with extensive public outreach and involvement,
UP unveiled a detailed concept site layout plan for Chain Works in October 2014. On October 20, 2014,
the Planning Board issued a positive declaration for the Project requiring the preparation of the DGEIS.
The DGEIS was prepared by UP pursuant to the requirements of SEQR. On March 8, 2016, the Planning
Board determined that the DGEIS was complete and adequate for public review and scheduled a public
hearing. Copies of the DGEIS were made available for public review at the City of Ithaca Planning
Department, the Town of Ithaca Planning Department, the City of Ithaca Office of the Clerk and the
Tompkins County Public Library. A copy of the DGEIS was also posted on the CWD website. A Notice
of Completion of the DGEIS and Notice of Public Hearing appeared in The Ithaca Journal on March 18,
2016 and the Environmental Notice Bulletin (ENB) on March 23, 2016. A public hearing was held on
March 29, 2016 at the Cinemapolis movie theater. Due to extensive public interest in the Project and
several requests made during the DGEIS public hearing, the public comment period, originally scheduled
to expire on May 10, 2016, was extended until May 25, 2016.
Notices of comment period extension were published in the Ithaca Journal, City Planning and Development
Board website and on the CWD website. Additionall y, comments received after the end of the public
comment period prior to the issuance of the FGEIS have been accepted and responded to within this
FGEIS.
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February 10, 2019Chapter 1: Introduction
Final Generic Environmental Impact Statement
1.3 Interested and Involved Agencies
The following is a list of the Interested and Involved Agencies for purposes of the Project:
Involved Agencies
•City of Ithaca (City)
•City of Ithaca Board of Public Works
•City of Ithaca Common Council
•City of Ithaca Planning and Development Board (Lead Agency)
•NYSDEC, Region 7
•New York State Department of Health (NYSDOH)
•New York State Department of Office of Parks, Recreation, and Historic Preservation (SHPO)
•New York State Department of Transportation (NYSDOT), Region 3
•Tompkins County Department of Health (TCDH)
•Tompkins County Department of Planning (TCDP)
•Town of Ithaca (Town)
•Town of Ithaca Town Board
•Town of Ithaca Planning Board
Interested Agencies & Parties
•South Hill Civic Association (SHCA)
•Tompkins County Area Development
•City of Ithaca School District
•Community Advisory Group (CAG)
•City of Ithaca Conservation Advisory Council (CAC)
•City of Ithaca Bicycle/Pedestrian Advisory Council (BPAC)
•City of Ithaca Shade Tree Advisory Committee (STAC)
•Disability Advisory Council (DAC)
1.4 DGEIS Public Hearing and Comment Period
The Public Comment Period on the DGEIS commenced upon acceptance of the DGEIS by the Planning
Board on March 8, 2016. A Public Hearing on the DGEIS was held at the Cinemapolis movie theater on
March 29, 2016 commencing at 4:00 pm. Included in Appendix A hereto are meeting materials, including
meeting notices, sign-in sheets, hearing presentation slides and a list of speakers from the Public Hearing.
The Public Hearing was opened by Garrick Blalock, Chair of the Planning Board. Following a presentation
by representatives of the UP development team, 6 members of the public testified about the DGEIS and
the environmental impacts of the Project. The hearing was closed at the April 26, 2016 Planning Board
Page 1-4
CHAIN WORKS DISTRICT
February 10, 2019Chapter 1: Introduction
Final Generic Environmental Impact Statement
meeting. The Public Comment Period closed at 5:00 PM on May 25, 2016.
1.5 Additional Public Outreach
All City of Ithaca and Town of Ithaca meetings to discuss the Project have been open to the public including
topics such as rezoning, PUD/PDZ legislation, site plan review, and SEQR approvals. Notification has
been distributed to all neighbors and stakeholders via USPS regular mail, email, municipal websites,
local newspaper of record (Ithaca Journal) and signage at the property.
Stakeholders and Impacted Property Owners
The Project Sponsor created a database of stakeholders and property owners to communicate Project
developments. These include the following:
•Private property owners such as the South Hill Business Park
•South Hill Residents - Unchained Properties representatives participate in meetings with the
South Hill Civic Association, a community organization committed to the health of the neighborhood
that will include the Chain Works site.
•Students – Project team members have worked with students from Cornell University and SUNY
ESF to utilize the project as a real-life exercise in their coursework. Their work product will be
on-display at the Project Center and portions incorporated in the FGEISThe Project Center is
located in a storefront in the Commons. The Project Center consists of a meeting space and
depository of project documentation and models.
•General Community
Meetings and tours of the site and the Project Center have been conducted by the Project Sponsor with
organizations and businesses that may have an interest in the Project or represent large segments of
the community including the Cooperative Extension and academic institutions such as Cornell University,
Ithaca College, and Tompkins Cortland Community College (TC3).
1.6 Comments Received and Changes to DGEIS
Many comments were received during the comment period. Copies of all comments received, including
those received at the Public Hearing, are provided in Appendices A and B. Comments covered the purpose
and need for the Project, the alternatives for the Project, potential environmental impacts associated with
the Project and mitigation measures. As a result of comments received, various changes were made to
the DGEIS. These changes are detailed in Chapter 4 and Appendix G.
1.7 FGEIS Consideration Period
SEQR requires that the Lead Agency shall afford other agencies and the public a minimum of 10 days
following the filing of the Notice of Completion in which to consider the FGEIS before issuing its written
findings statement.
1.8 Incorporation by Reference
All volumes of the DGEIS which were accepted by the Planning Board on March 8, 2016, are incorporated
herein by reference in their entirety. The DGEIS provides an analysis of: (i) the purpose of and need for
the Project; (ii) reasonable alternatives to the Project; (iii) the Project environmental setting; (iv) the
potentially significant adverse environmental impacts associated with the Project; (v) mitigation measures
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CHAIN WORKS DISTRICT
February 10, 2019Chapter 1: Introduction
Final Generic Environmental Impact Statement
for the Project; (vi) thresholds for future actions; and (vii) impacts that cannot be mitigated if the Project
proceeds. The DGEIS found that:
•Implementation of the Project would result in the permanent elimination of undeveloped areas
for new mixed-use residential, commercial and cultural space, parking areas and publicly
accessible open space;
•Implementation of the Project would result in a positive impact to community character with the
redevelopment of a former industrial facility;
•The Project would be generally consistent with adopted land use regulatory and policy documents,
including the City and Town of Ithaca Comprehensive Plans, among others;
•Adverse but minor stormwater impacts due to new impervious surfaces;
•Development of the Site will have minor impacts to vegetation and fauna;
•The Project would benefit the environment and public health by completing remediation for mixed
use which requires more stringent cleanup standards rather than for an industrial use and
addressing previously unknown contaminants that could otherwise impact the community;
•There are no known archaeological resources within the Site;
•The Project would result in minor traffic impacts;
•The Site is currently served by all public utilities and will require small improvements for Project
implementation;
•The Project would mitigate adverse impacts to air quality through traffic and energy designs;
•The Project would result in positive short-term and long-term economic and fiscal impacts;
•The Project would expand, link and enhance open space and recreational opportunities in and
adjacent to the Project area;
•There would be short-term visual, air quality and traffic impacts during construction; and
•Construction and operation of the Project would have both short-term and long-term impacts on
the use and conservation of energy resources.
In addition to the DGEIS, the following studies are incorporated by reference in their entirety :
•A Residential Analysis in Downtown Ithaca, New York prepared by the Danter Company, LLC for
the Downtown Ithaca Alliance dated September 1, 2016,
FGEIS FIGURE 1-1
BIRD’S EYE VIEW OF THE CHAIN WORKS DISTRICT (CJS)
CHAIN WORKS DISTRICT
February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
Chapter 2:
Project Description
Page 2-1
CHAIN WORKS DISTRICT
February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
CHAPTER 2: PROJECT DESCRIPTION
2.1 Overview
DGEIS Chapter 2 provides a detailed description of the Preferred Alternative as well as the UP’s goals,
objectives, and constraints. As the entire DGEIS has been incorporated by reference, this Chapter of the
FGEIS is limited to a brief summary of the Preferred Alternative as well as a description of updates that
have been made to the Preferred Alternative since the publication of the DGEIS. Project updates are the
result of comments received on the DGEIS as well as continuing design refinement associated with the
initial phase of construction.
2.2 Project Location
The Site is approximately 95 contiguous acres of land in central NYS, South of Cayuga Lake in the Finger
Lakes Region, and straddles the City and Town of Ithaca border in Tompkins County. FGEIS Figure
2.2-1 illustrates the Site’s location in relationship to NYS, Tompkins County, South and East Hills, and
Downtown Ithaca.
The Site is bounded as follows:
To the east, the Site follows South Aurora Street / NYS Route 96B, a major transportation corridor that
connects downtown Ithaca to South Hill, Ithaca College, and the residential neighborhoods in the Town.
It is a primary route for travelers from Binghamton and points south.
To the north, the Site borders residential neighborhoods comprised primarily of single and multi-family
homes in the City.
ITHACA
COLLEGE
CORNELL
UNIVERSITY
CITY OF ITHACA
TOWN OF ITHACA
CHAIN WORKS
DISTRICT
CAYUGA
LAKE VILLAGE OF
CAYUGA HEIGHTS
TO CORTLAND
(32 MILES)
TO WHITNEY POINT
(32 MILES)
TO HORSEHEADS
(28 MILES)TO HORSEHEADS
(36 MILES)
TO WATKINS GLEN
(24 MILES)
TO AUBURN
(37 MILES)
TO WATERLOO
(42 MILES)
TOWN OF
DRYDEN
UV930F
UV13A
UV89
UV34
UV79
UV13
UV96B
UV34
UV13
UV96B
UV366
UV96
UV13
UV79
PROJECT LOCATION:
CITY/TOWN OF ITHACATOMPKINS COUNTY
NEW YORK
FEGIS Figure 2.2-1: Location of the Project within NY State, the City, and Town (FE) *
Page 2-2
CHAIN WORKS DISTRICT
February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
To the west, the Site slopes steeply to meet Spencer Street in the City, then traces the back of the
residential properties lining the east side of Spencer Road. In the Town of Ithaca, the property line traces
the alignment of the former Lehigh Valley Railroad and future Gateway Trail, as well as a large parcel of
undeveloped land.
To the south, the Site borders the South Hill Business Campus in the Town.
The ALTA survey, performed by Lehr Land Surveyors for the entire parcel, along with the metes and
bounds property description, is included in Appendix B1 of the DGEIS. The Site is located along the NYS
Route 96B corridor, South Aurora Street / Danby Road, and where Turner Street and South Cayuga
Street meet the northern edge of South Hill.
2.3 Brief Description of the Preferred Alternative
The Project Sponsor seeks to redevelop and rehabilitate the existing architecture and landscape of the
821,200 square foot (s.f.) former Morse Chain / Emerson Power Transmission facility (see FGEIS Figure
2.3-1 for existing buildings on Site), located on an approximately 95-acre parcel traversing the City and
Town’s municipal boundary, into a 1.7 million s.f. mixed-use district (FGES Figure 2.3-2 Conceptual Site
Layout Plan). The Site is currently predominantly zoned as an Industrial Zone District in the City and as
Industrial in the Town. The Project Sponsor has applied for a PUD in the City and a PDZ in the Town
to rezone the Site to accommodate the development of a mixed-use district. This PUD / PDZ will be
called the CWD, which includes residential, commercial, office, retail, restaurant / café, warehousing /
distribution, and industrial uses. The completion of the Project is estimated to be over a seven-to-ten year
period. The first phase will consist of the redevelopment of four existing buildings (Buildings 21, 24, 33,
and 34). Subsequent phases of development will be determined as the Project proceeds and will include
new structures with the proposed full buildout of 1,706,150 s.f.
FGEIS Figure 2.3-1: Existing Site and Factory Buildings (FE)*
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CHAIN WORKS DISTRICT
February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
Related infrastructure work for the Project will include: (1) removing selected buildings to create courtyards
and a network of open spaces and roads as described in DGEIS Subsections 2.7.3.4 and 2.7.5; (2)
creating pedestrian, bicycle, and vehicular connections through the Site from South Hill to Downtown
Ithaca as described in DGEIS Section 5.7; (3) improving the existing roads / drives within the Site while
creating new access points into and within the Site as described in DGEIS Subsection 2.7.5; (4) mitigating
existing environmental challenges as described in DGEIS Section 5.5; (5) fostering the development of
a link, the Gateway Trail, to the Black Diamond Trail network as described in DGEIS Section 5.12; and
(6) installing stormwater management facilities, lighting, utilities, and plantings as described in DGEIS
Section 5.8.
Design Standards for the CWD are set forth in the proposed PUD / PDZ Zoning Code (FGEIS Appendix
D), and utilize LEED ND principles where appropriate as a framework. The PUD/PDZ Zoning Code has
been revised from the one presented in the DGEIS, Appendix C1. By rezoning the Site, it will be divided
into four (4) Sub Areas (FGEIS Figure 2.3-3) defined as:
•Natural Sub Area (CW1)
•Neighborhood General Sub Area (CW2 A&B)
•Neighborhood Center Sub Area (CW3 A&B)
•Industrial Sub Area (CW4)
Sub Areas CW2 and CW3 were further enumerated by creating within them additional subzones A and B
to define additional design standards for areas along NYS Route 96B.
LOADINGDOCK
LOADINGDOCK
10
8
10
RetainingWall
N16
LOADINGDOCK
N1
N2
N3
N5
N6
N7
N9
N10
N11
N12
N17
N20
N27
N31
N30
N29
N33
N34
N35
N36
N38
N32
N28
N13
N14
N15
N37
N18
N19
N21
N22
N23
E2-6
N24
N25
N26
N8
N4
FGEIS Figure 2.3-2: Overall Conceptual Site Layout Plan (Project Team) *
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CHAIN WORKS DISTRICT
February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
Of the 821,200 s.f. of existing buildings located within the CW3A/B and CW4 Sub Areas, 92,350 s.f. will
be removed leaving 728,850 s.f. of buildings to be redeveloped. Additions to these existing buildings
totaling 70,600 s.f .will be constructed to increase the total Gross Floor Area (GFA) of the repurposed
buildings to 799,450 s.f. The 906,700 s.f. of new buildings are located in the CW2A/B and CW3A/B Sub
Areas. The following FGEIS Table 2.3-1 summarizes the 1,706,150 s.f. of anticipated development within
each Sub Area:
CW1
CW3A
NATURAL SUB AREA (CW1)
TOTAL ZONE AREA - 1,039,404 GSF / 23.86 ACRES +/-
NEIGHBORHOOD GENERAL SUB AREA (CW2)
TOTAL ZONE AREA - 922,274 GSF / 21.17 ACRES +/-
CW4
NEIGHBORHOOD CENTER SUB AREA (CW3)
TOTAL ZONE AREA - 1,730,639 GSF / 39.73 ACRES +/-
INDUSTRIAL SUB AREA (CW4)
TOTAL ZONE AREA - 447,340 GSF / 10.27 ACRES +/-
CW2A
CW2B
CW1CW3B
CW3C
CW3B
Sub Area Approx.
Acreage
Existing
Buildings
Existing
Building
Areas
Removed
Existing
Building
Redevelopment
Additions
to
Existing
Buildings
New Building
Development
Total
Development
CW1 23.86
acres
0 s.f.0 s.f.0 s.f.0 s.f.0 s.f.0 s.f.
CW2A 9.85
acres
0 s.f.0 s.f.0 s.f.0 s.f.568,400 s.f.568,400 s.f.
CW2B 11.32
acres
0 s.f.0 s.f.0 s.f.0 s.f.
CW3A 4.83
acres
0 s.f.0 s.f.0 s.f.0 sf 322,300 s.f.922,850 s.f.
CW3B 33.32
acres
572,800
s.f.
58,850
s.f.
513,950 s.f.86,600 s.f.
CW3C 1.58
acres
0 s.f.0 s.f.0 s.f.0 s.f.
CW4 10.27
acres
248,400
s.f.
33,500
s.f.
214,900 sf 0 s.f.0 s.f.214,900 s.f.
Total 95.03
acres
821,200
s.f.
92,350
s.f.
728,850 s.f.86,600 s.f.890,700 s.f.1,706,150 s.f.
FGEIS Figure 2.3-1 PUD / PDZ Sub Area Boundary Map (R+W) *
FGEIS Table 2.3-1: Preferred Development Summary by Sub Area (FE)*
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CHAIN WORKS DISTRICT
February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
Each Sub Area has its own set of Design Guidelines (FGEIS Appendix D and revised from those presented
in the DGEIS, Appendix C2) and will serve as one mechanism to mitigate potential adverse impacts
of significance. The Design Guidelines provide standards for new and renovated buildings at the Site
including, but not limited to, buffer areas, compact development, multimodal circulation network, public
lighting, setbacks, building lot coverage rates, building heights, building disposition, frontage build out,
allowable usage, signage, parking layouts, common areas and plazas, conservation plan(s) for natural
areas, and other typical development aspects.
The initial Project application to the City and Town included the following:
• PUD Zoning Amendment for the City portion of the Site.
• PDZ Zoning Amendment for the Town portion of the Site.
• Full Environmental Assessment Form dated 05/30/2014.
• Site Plan Approval for Phase I including Buildings 21 and 24 in the City and Buildings 33 and 34
in the Town. See FGEIS Figure 2.3-2 for building locations.
The Phase I Site Plan includes the following:
• Building 21: Office Use - 43,340 s.f. (Redevelopment).
• Building 24: Residential / Office Use - 111,050 s.f. (Redevelopment) with 18,520 s.f. (New
Development) for 129,570 s.f. (Total).
• Building 33: Industrial Use - 22,000 s.f. (Redevelopment).
• Building 34: Industrial Use - 148,600 s.f. (Redevelopment).
• All subsequent development will require Site Plan approvals in the corresponding jurisdiction
following the local zoning process, and a threshold review in accordance with the GEIS process
outlined in DGEIS Chapter 10.
2.4 Project Updates since Publication of the DGEIS
A number of Project updates have been made to the Preferred Alternative since the publication of the
DGEIS (some of which are referenced in the brief description of the Preferred Alternative provided in
Section 2.3 above). These Project updates are the result of comments received on the DGEIS, continuing
design refinement associated with the initial build-out of the Preferred Alternative and on-going discussions
with City and Town Representatives on the zoning amendments. For the convenience of the reader,
these Project updates are summarized below.
2.4.1 Revised Conceptual Site Layout Plan
The Conceptual Site Layout Plan was revised to address comments received during the DGEIS Public
Comment phase, the City’s and Town’s staff review, the City Planning and Economic Development
Committee review, comments received during a public hearing. The revisions do not impact thresholds,
such as building sizes or number of parking spaces, but were in response to comments mainly due to the
LEED ND designation as well as the development of the PUD/PDZ. These revisions include:
• The depiction of the on-Site electrical substation infrastructure.
• The inclusion of the conceptual location of the nature trails throughout the CW1 Sub Area.
• Additional sidewalks and trails to ensure connectivity between Sub Areas.
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February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
• The alignment of the proposed Gateway Trail through CWD as well as proposed Alternates in
case of trail closure.
• Sidewalk required along NYS Route 96B along the frontage of the Site from the City to Coddington
Road intersection.
• Site Access Drive II will be a one-way, ingress only; no traffic will be allowed to exit onto NYS
Route 96B.
• Removal of the Site access drive adjacent to Building N18 (North).
2.4.2 Revised Chain Works District Form and Use Regulations
The original intent of the Project Sponsor was to develop a set of land use regulations that would be
commonly utilized as a set of design standards to both the City of Ithaca PUD and the Town of Ithaca
PDZ for the Project. During the development process with City and Town Staff, it became clear that the
discrepancies between the zoning laws for both municipalities were too great to allow for the development
of a homogenous document. Therefore, two separate sets of Design Guidelines were developed as
supplemental materials to the PUD and PDZ (FGEIS Appendix D). The revisions to the PUD/PDZ Form
and Use Regulations include:
• Sub Area enumeration was expanded to create additional sections within the CW2 (A/B) and
CW3 (A/B) zones to define additional design thresholds for areas along NYS Route 96B.
• Definitions were adjusted to ensure consistency between the PUD or PDZ with the corresponding
Zoning Law for each municipality. Duplicate definitions were then removed. The PUD definitions
were also revised to ensure consistency with the Collegetown Area Form District (CAFD).
• Required buffer areas were added to the Design Standards.
• A separate set of Design Guidelines was added to the PUD/PDZ Form and Use Resolutions to
set ideal parameters for new development which may not be feasible for every project within
CWD; as such, the Design Guidelines are intended to serve as a benchmark for individual projects
within the CWD during the design review process.
2.5 NYSDEC Coordination Updates outside of the GEIS Process
2.5.1 Introduction and Background
This section of the FGEIS presents an update to the Remedial Investigations and remedial actions
conducted and proposed by Emerson Electric Co. (Emerson) with the NYSDEC oversight under the New
York State Inactive Hazardous Waste Disposal Site (IHWDS) Remedial Program since the DGEIS was
published and how that information has been incorporated into the GEIS process1. It will summarize
the Site’s existing conditions and proposed mitigation at the time of DGEIS publication and how the
subsequent investigations and analyses modified that information.
1Emerson is the respondent under a certain Order on Consent (Index # A7 0128 87 09) to investigate and remediate
the Property. Since DGEIS publication, the Property was transferred to EMERSUB 15, LLC, a wholly owned
subsidiary of Emerson. Both of these entities have responsibility for the proper investigation and remediation of the
Property and are collectively referred to in the GEIS as “Emerson.”
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February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
The Site is part of a larger 95.93 acre parcel (Property) and operated as a manufacturing facility since the
early 20th century. The Property is listed on the IHWDS Registry as a “Class 2 Site” which indicates that
the Property contains contamination that constitutes a significant threat to public health or the environment.
The current Record of Decision (ROD) issued by the NYSDEC divides the Property into two Operable
Units (OU) with OU-1 constituting an area known as the firewater reservoir and OU-2 comprising the
remainder of the Property. Emerson has applied for subdivision of the Property to largely coincide with
the OU-1 and OU-2 areas. Long term groundwater treatment occurs within OU-1. Because the ROD
sets forth proposed remediation of the Property based on future industrial uses, the NYSDEC will need to
further amend the ROD to allow for the Project Sponsor’s proposed mixed-use redevelopment of the Site.
Investigations of the Site performed by the time the DGEIS was published identified multiple Areas of
Concern (AOCs) where contaminants exist above their cleanup standards for groundwater, soil, seeps
and/or sediment, including barium, other heavy metals, cyanide, petroleum products, polychlorinated
biphenyls (PCBs), volatile organic compounds (VOCs) and semi volatile organic compounds (SVOCs).
If not addressed, these contaminants can have impacts to public health and the environment.
The AOCs discussed in the DGEIS as existing conditions (Subsection 5.5.1) include: (1) trichloroethylene
(TCE) in groundwater and soil in the vicinity of Building 24; (2) barium impacts to soils, sub base,
incompetent bedrock, and groundwater, and cyanide impacts to groundwater in the vicinity of Buildings
14/15 (former salt pots/cyanide use areas); (3) free petroleum product contamination found subsurface
at several locations; (4) VOCs in groundwater sampled from MW 29, located between Buildings 2 and
17; (5) fill and soil impacted with VOCs, SVOCs, PCBS, and heavy metals in the southwestern portion of
the Site that includes Building 30, a service road, a former propane storage area, and an area known as
the “Rice Paddy”; (6) sediments located in several drainage channels impacted with PCBs, heavy metals
and SVOCs; (7) seeps where groundwater impacted with VOCs appear to surface on Site; (8) VOCs in
groundwater from MW 39, located northwest and downgradient of Building 5; (9) VOCs in soils located
approximately 50 feet east of Building 14 at a depth of 1 foot; (10) fill material with SVOCs and metals
impacts generally located south and east of Building 34 but north of the creek and beneath the parking
lot north and east of Building 24; (11) VOC impacts in the vicinity of the former 507 area degreaser once
located in Building 4; (12) soil vapor intrusion within various buildings on the Site; (13) isolated impacts to
several concrete slabs/building materials; and (14) three historic wells discovered in or about 2015. Note
that in an additional AOC, PCB impacts associated with a former transformer pad near Building 24 was
already remediated as discussed in Subsection 5.5.1.10 of the DGEIS.
While the methods of remediation to be employed at the Site are dictated by a separate regulatory
process under the jurisdiction of the NYSDEC, Subsections 5.5.1.19, 5.5.2 and 5.5.3 of the DGEIS
provide an evaluation of possible remedial approaches that may also serve as mitigation measures in
the GEIS process. The requirements for remediating the Site will be more stringent for mixed-use with
a residential component than what is required under the current ROD, i.e., industrial use only. As a
result, the Project will improve the existing impacts from the Site’s historic uses and future Site conditions
currently allowed by the NYSDEC under the ROD by causing a ROD Amendment to allow the mixed-use.
The remedial approaches discussed in the DGEIS included: excavation and off-Site disposal of impacted
soils; placing a soil cover over or otherwise cap impacted soil and manage them in place; solidification/
stabilization of impacted soils; in-situ chemical treatment of impacted soils and/or groundwater; in-
situ thermal remediation of soil and/or groundwater impacts; extraction and treatment of impacted
groundwater; groundwater monitoring; sub slab depressurization systems for soil vapor/indoor air; positive
pressurization systems for soil vapor/indoor air; positive pressurization of building to address potential
indoor air impacts; and institutional controls to reduce or prevent exposure to contaminants that remain
on the Site and ensure proper implementation and long term management of selected remedial actions.
In addition to the above, construction activity in the CW3 and CW4 Sub Areas involving the potential
disturbance of contaminated soils or groundwater will require implementation of a NYSDEC approved
Site Management Plan (SMP) with an associated Excavation Work Plan, Groundwater Management Plan,
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February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
Community Air Monitoring Plan (CAMP) and Health and Safety Plan, all with an Environmental Monitor
to oversee and assist with proper characterization and management of disturbed media. Occupying
existing buildings and constructing new ones in the CW3 and CW4 Sub Areas will require addressing
the potential for soil vapor intrusion (SVI) via mitigation and/or monitoring. Evaluation of various areas
designated for new construction in CW3 and CW4 Sub Areas for the potential for SVI will be performed
and submitted to the NYSDEC and the NYSDOH for approval.
None of the investigation results since publication of the DGEIS require consideration of additional
remedial approaches or significant revisions to the mitigation measures proposed in the DGEIS. Rather,
the results better define where such remedial alternatives or mitigation measures should be applied at
the Site.
2.5.2 Phase II Supplemental Remedial Investigation and Existing Conditions Update
As discussed in DGEIS Subsection 5.5.1.19, Emerson was in the process of performing a supplemental
Remedial Investigation (RI) with NYSDEC oversight when the DGEIS was published. The investigation
is now complete and the report documenting that investigation approved by the NYSDEC. The Phase II
Supplemental RI Report, revised November 14, 2017, and the NYSDEC letter to Emerson dated
January 12, 2018 approving the report with conditions may be found in Appendices E7 and E8,
respectively, of the FGEIS. The data from this investigation has been incorporated into the FGEIS,
and used to revise Section 5.5 of the DGEIS to provide additional information on the existing
conditions at the Site and to aid in determining whether mitigation measures to protect public health
and the environment presented in the DGEIS should be revised.
The Phase II Supplemental RI delineates the nature and extent of contamination identified in soil,
groundwater, seeps and sediment at the Site and characterizes water and residuals in sewer manholes.
The investigation was focused on the previously identified AOCs at the Site and addressed data gaps.
The Phase II Supplemental RI Report also presents results from additional investigations conducted in
AOC 1 (former department 507 degreaser area), first identified during the Supplemental RI conducted in
2008.
The additional data better defines the extent of each AOC and its contaminants of concern discussed in
Subsection 5.5.1 of the DGEIS and summarized above. In particular, areas of the Site where significant
amounts of fill material had been placed and contamination discovered prior to the DGEIS, such as
several parking areas to the east and southeast of the main buildings and the Building 30/Rice Paddy
area, now are identified as discrete AOCs (i.e., AOC 35A, 35D, 35G, 35H, 35K and 35L). Two additional
AOCs are characterized: (1) AOC 35C located in the vicinity of Building 11A impacted by chlorinated
volatile organic compounds (CVOCs) and SVOCs in soils and CVOCs in groundwater; and (2) a seep
discharging into a retaining wall sump impacted with CVOCs and cyanide located at the north end of
a retaining wall that runs parallel and west of Building 4. Through the select placement of additional
groundwater wells, the extent of groundwater impacts discussed more generally in the DGEIS have been
defined to a degree sufficient to satisfy the NYSDEC and allow for an analysis of remedial alternatives to
address such impacts. Additional areas on the Site with groundwater impacted by: (1) barium (Building
2 and 24 areas and west of Building 3); (2) cyanide (Building 30 and Rice Paddy areas and retaining wall
sump); and (3) CVOCs (Building 30 and Parking Lot 6 areas) were identified as well.
A more detailed summary of existing conditions is presented in Section 4.9 and Appendix G of the FGEIS.
2.5.3 Boundary Reassessment
Emerson petitioned the NYSDEC March 5, 2018 to modify the area of the Site subject to its Consent
Order with the NYSDEC, the ROD and any amendments, and the IHWDS Registry by removing 36.76
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February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
acres of undeveloped land on the south portion of the Site from the scope of those instruments.
The petition may be found in Appendix E2 of the FGEIS. This area of the Site includes the proposed
CW2 Sub Area and a portion of the CW1 Sub Area. A sewer that originates from the former NCR
property immediately south of the Site runs south to north across the Site (NCR Sewer) and an
Ithaca College sewer lateral that runs west to east into the Site connects with the NCR Sewer within the
area covered by the petition. Subsection 5.5.1.18 of the DGEIS presented data that formed a part of
the formal petition. It consisted of soil vapor data along the NCR Sewer, surficial and subsurface soil
sampling data, and groundwater sampling data focused on the southern most area of the Site. Other
than the presence of soil vapor impacted with CVOCs in the vicinity of the NCR Sewer, no significant
impacts were discovered within the southern area of the Site.
After publication of the DGEIS, Emerson performed additional soil vapor sampling in the area of the
NCR Sewer and Ithaca College sewer lateral. The results indicate a potential for indoor air impacts from
soil vapor should a structure be constructed in the vicinity of the NCR Sewer and Ithaca College lateral.
The petition concludes that the southern area of the Site has not been adversely impacted by industrial
activities once conducted on the northern portion of the Site. The petition also concludes that soil vapor
impacts on Site originate from CVOC contamination at the former NCR property to the south.
The additional soil vapor data obtained following DGEIS publication is consistent with the soil vapor
data presented in the DGEIS. As part of the petition, Emerson proposes a Declaration of Covenants
and Restrictions be placed on the relevant tax map parcels that would require the potential for SVI be
addressed using appropriate engineering controls approved by the NYSDEC and the NYSDOH when
any habitable structures within the CW2 Sub Area are proposed within an eighty feet wide area where
the existing sewer lines run through the south portion of the Site. The Project Sponsor informs the
Lead Agency that a similar requirement for the NCR Sewer running through the northern section of the
Site (CW3 Sub Area) will be folded into an SMP and noticed and enforced through an environmental
easement granted to the NYSDEC. These proposed engineering and institutional controls will serve as
mitigation measures and were disclosed in Subsection 5.5.3 of the DGEIS.
2.5.4 IRM Work Plan and Update to Mitigation Measures
Emerson submitted a draft Interim Remedial Measures (IRM) Work Plan to the NYSDEC in July 2017 to
address soil and sediment contamination and sanitary sewers at specified locations on the Site. Following
a public comment period and several revisions, the NYSDEC approved an IRM Work Plan dated August
8, 2018 by letter dated August 22, 2018. The NYSDEC letter of approval and IRM Work Plan may
be found in Appendices E5 and E6, respectively, of the FGEIS. The Lead Agency understands an
IRM to be an activity to address site conditions which can be undertaken without extensive
investigation and evaluation to prevent, mitigate or remedy environmental damage or the
consequences of environmental damage attributable to a property. 6 NYCRR 375 1.2(a)(b). From the
Lead Agency’s review of the IRM Work Plan, it understands that a primary goal of the IRM Work Plan is
to remediate 16 AOCs delineated at the Site with soil or sediment contaminants above their soil
cleanup objectives (SCOs) applicable to the anticipated future use of those areas of the Site or, in
those cases where the soil is deemed to be a source of contamination in groundwater, the Protection
of Groundwater SCO. FGEIS Table 2.5 1 presented below is reproduced from the IRM Work Plan. It
summarizes the AOCs proposed for an IRM, the applicable SCO, and the proposed remedy.
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February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
Table2.5-1Summary ofSoil AOCsand Interim RemedialMeasures IRMWork PlanFormer Emerson Power Transmission FacilityIthaca,NewYork (a)AOCAOC Description/Sub-AreaContaminant(s) (b)Affected MediaSCO Driver (c)Anticipated FutureLand Use (d)Anticipated Final Cover (e)Demarcation Barrier?IRM RemedyEstimated Excavation (CY) or Cap/Cover (SF) Restricted Residential/Mixed Use Area (d)1Former Department 507 Degreaser (exterior)CVOCsSoil, GroundwaterProtection of GroundwaterRestricted ResidentialAsphaltYes1. Excavate to 3 feet and dispose of CVOC soil offsite.2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Install cap consisting of clean soil backfill, geosynthetic clay liner, and asphalt1301,200 SF capBuilding 24 Interior (second floor)CVOCsSoil, GroundwaterProtection of GroundwaterRestricted ResidentialConcreteNo1. Excavate to bedrock and dispose of CVOC soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore concrete floor30Building 24 Exterior (parking lot)CVOCsSoil, GroundwaterProtection of GroundwaterRestricted ResidentialAsphaltNo1. Excavate to bedrock and dispose of CVOC soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore asphalt pavement77027Former Salt BathsMetals (Ba)Soil/Bedrock/GroundwaterRestricted Residential UseRestricted ResidentialTo be Determined (green space or plaza area) (f)No1. Excavate loose or fragmented bedrock (~2 feet) and dispose of material offsite2. Backfill with clean soil and cover with gravel (future grass by others)8031Upper Parking Lot 6Metals (As, Ba, Cd, Cr, Cu, Ni)SoilRestricted Residential UseRestricted ResidentialAsphalt/GrassYes1. Excavate to 2 feet and dispose of metals soils offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass20Former Spray Pond AreaPAHs, PCBs, and Metals (As, Ba, Pb, Hg)SoilRestricted Residential UseRestricted ResidentialAsphalt/GrassYes1. Excavate to 2 feet and dispose of PAH, PCB, and metals soil offsite 2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass950Former Spray Pond Area/Drainage DitchPAHs and MetalsDrainage Ditch SoilRestricted Residential UseRestricted ResidentialRiprap/GravelNo1. Excavate to 2 feet and dispose of PAH and metals soil offsite2. Backfill with clean soil and restore ditch lining50CVOCsSoilProtection of GroundwaterRestricted ResidentialPossible (g)1. Excavate CVOC soil that exceeds PoG SCO and dispose of soil offsite2. Collect confirmation samples of base and sidewalls (unless bedrock is encountered) and excavate additional soilif necessary3. Backfill with clean soil and restore asphalt/grass/gravel210PAHs SoilRestricted Residential UseRestricted ResidentialPossible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass or gravel35AEast of Building 24 (SB-103/SB-103SS)Metals (As)SoilRestricted Residential UseRestricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of arsenic soil offsite2. Backfill with clean soil and restore grass70CVOCsSoil/GroundwaterProtection of GroundwaterRestricted ResidentialNo1. Excavate to bedrock and dispose of CVOC soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and cover with gravel (future grass by others)140PAHsSoilRestricted Residential UseRestricted ResidentialPossible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and cover with gravel (future grass by others)35DNear Parking Lot 4 (SS-100)PAHsSoilRestricted Residential UseRestricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Backfill with clean soil and restore grass3035GSouth of Parking Lot 3 (LBA-B17-TSS-3)Metals (Ba)SoilRestricted Residential UseRestricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of barium soil offsite2. Collect confirmation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass4035HParking Lot 3 (LBA-TP-03)PAHsSoilRestricted Residential UseRestricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass6035KFormer Railway Right-of-Way (SB-240)Metals (As)SoilRestricted Residential UseRestricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of arsenic soil offsite2. Backfill with clean soil and restore grass4035LFormer Railway Right-of-Way (DS-1)PAHsSoilRestricted Residential UseRestricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass and ditch lining110Commercial Use Area28Oil Shed Area - NortheastCVOCsSoil/GroundwaterProtection of GroundwaterCommercialAsphaltPossible (g)1. Excavate CVOC soil that exceeds PoG SCO and dispose of soil offsite2. Collect confirmation and documentation samples of base and sidewalls (unless bedrock is encountered)3. Backfill with clean soil and restore grass (future paving by others)50029Former Propane Aboveground Storage Tank AreaPAHsSoilCommercial UseCommercialAsphaltYes1. Excavate to 2 feet and dispose of the PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Place and compact 2 feet of soil cover to the approximate original grade and restore grass (future paving by others)1150Industrial Use Area30Rice Paddy AreaPAHsSoilIndustrial UseIndustrialSoil (Grass)Yes1. Excavate to 1 foot and disposal of PAH soil offsite2. Excavate PCB hotspots at depths indicated on IRM drawings.3. Collect confirmation and documentation samples and excavate additional soil if necessary4. Backfill with clean soil and restore grass170a\ AOC = area of concern; IRM = Interim Remedial Measure; SCO = soil cleanup objective; CVOC = chlorinated volatile organic compound; PAH = polycyclic aromatic hydrocarbon; PCBs = polychlorinated biphenyls; CY = cubic yard; SF = square feet; NA = not applicable.b\ The contaminants include the constituents that are the primary drivers of the need for interim remedial measures; they do not include constituents present at concentrations minimally above the SCOs.c\ SCO source: Table 375-6.8(b), Title 6 New York Codes, Rules and Regulations Part 375, Subpart 375-6.d\ The term Restricted Residential/Mixed Use is defined as including one or more of the following: apartments and multi-family residences, offices, commercial endeavors, recreational areas, and green space. Restricted Residential Use SCOs are applicable in these areas.e\ The anticipated final cover is based on the current layout for redevelopment.f\ The current layout for the redevelopment plan indicates that the former salt baths area (Building 14) will be removed and used for green space or plaza area serving as an entry point for mixed use. The remaining portions of the AOC will be for industrial, warehouse, or storage uses.g/ A demaracation barrier will be installed only in areas where bedrock is not encountered after excavation to the prescribed detph.Asphalt/GrassTo be Determined 35C263234Area East of Buildings 13A and 14Building 11A (LBA-SB-250)WSPK:\EMERSON\Ithaca - 4507\IRM Work Plan\IRM Work Plan - August 2018 Submittal\Table\Table 3-1_080818Page 1 of 1Revised: 8/8/2018FGEIS Table 2.5-1: Summary of Soil AOCs and Interim Remedial Measures
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The proposed remedial action for all of the above referenced AOCs, except AOC 1, entails excavation and off-Site
disposal of soils or sediments above their applicable SCO followed by installing a demarcation layer, if bedrock
has not been reached, and backfilling with clean material. A demarcation layer installed before placement of soil
notifies future workers in that area of the potential presence of the impaceted soils beneath the layer. In the case
of impacted sediments removed from portions of drainage ditches found within AOC 32 and AOC 35L, restoring the
remedial area within the ditches will entail backfilling with clean soil, placing a geotextile lining and installing riprap
along the ditch bottom and banks. The proposed remedial action for AOC 1 is excavation and off-Site disposal of
impacted soils to a depth of approximately three feet, installation of a demarcation layer, backfilling with clean soils,
and placing an engineered low permeability cap and asphalt to minimize infiltration and migration of the remaining
contamination. The presence of utilities in and around AOC 1 prevent excavation of all impacted soils as a remedy.
In addition, the sanitary sewer network within the Site will be addressed further by evaluation of pipe integrity and
investigation of soil conditions beneath certain sections where pipe integrity is suspect. The residual liquids and
solids found in various sewer manholes at the Site and characterized in the Phase II Supplemental RI Report have
already been removed from the manholes, placed in containers and await off-Site disposal.
The IRM Work Plan provides greater specificity to the discussion about potential impacts and mitigation measures
found in Subsections 5.5.2 and 5.5.3 of the DGEIS, respectively. The specified remedial actions of excavation and/
or capping were discussed generally in the DGEIS as possible remedial alternatives and mitigation measures. The
IRM Work Plan applies those remedial alternatives to specified areas of the Site as set forth in FGEIS Table 2.5-1,
allowing for better specificity when establishing mitigation measures to address the Project’s potential impacts to
public health and environment.
Details about the proposed IRMs are presented in Appendix G of the FGEIS which contains a rewrite of the Public
Health and Environment Section of the DGEIS based upon the subsequent studies and work plans. The Project
Sponsor has informed the Lead Agency that Emerson anticipates conducting the IRMs during Fall 2018.
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2.5.5 Feasibility Study and Update to Mitigation Measures
The Project Sponsor has informed the Lead Agency that remedial technologies to address groundwater, seeps, and
indoor air impacts will be considered by Emerson in a feasibility study presented to the NYSDEC. With respect to
the soil/groundwater to indoor air pathway, the feasibility study will evaluate indoor areas in which CVOCs remain
at elevated levels in soil or groundwater to determine which buildings may require mitigation systems to prevent
impacts to indoor air or monitoring to ensure protection of public health. Groundwater related impacts for which
potential remedial actions will be evaluated include:
• Groundwater containing CVOCs, barium, or cyanide at concentrations above groundwater standards within
and downgradient of the areas presented in FGEIS Table 2.5-2 below:
FGEIS Table 2.5-2: Areas with Groundwater Impacts
Non-aqueous phase liquid (NAPL) in several monitoring wells and in groundwater present behind the
eastern foundation wall of Building 4, as well as off-Site areas OU-1 and a historic water well,
where recovery is ongoing. Potential long-term remedial alternatives to address conditions in
the historic well will be evaluated in the feasibility study. If appropriate, the feasibility study will
also recommend a remedy for implementation.
• Building 24 Seep, where TCE has been detected at concentrations above the groundwater
standards; discharge from this pipe is currently routed through a culvert in the Building 24 drainage
ditch, where it is treated using a granular activated carbon sock.
• Retaining Wall Sump, which receives groundwater accumulating behind the retaining wall west of
Building 4; the relationship between the sump and the storm sewer will be evaluated during the
feasibility study and appropriate remedial alternatives recommended (if any); water in the sump is
being treated using a granular activated carbon boom.
Specific remedial alternatives that may be applied to address groundwater and soil vapor impacts for each relevant
AOC will be proposed in the feasibility study. Based on discussions with the Project Sponsor, the Lead Agency
understands that technologies and process options that passed initial screening for applicability and received more
detailed evaluation in the feasibility study currently being drafted are listed in FGEIS Table 2.5-3. All of the remedial
approaches being addressed in the study were discussed in the DGEIS. Several options listed in FGEIS Table
2.5-3 may be combined to address a particular AOC. Institutional and engineering controls will be developed
as components of a SMP as well. The SMP and its institutional and engineering controls were discussed in
Subsections 5.5.2 and 5.5.3 of the DGEIS. The Lead Agency understands that the SMP will be prepared after
completion of the IRM so that all caps to be maintained as part of the plan and areas where residual impacts may
remain will be identified with specificity. The SMP will be amended as needed subsequent to installation of any
additional remedial systems. Implementation of the SMP ensures that the IRMs and groundwater remedies remain
functional and effective.
Contaminants
CVOCs Barium Cyanide
• Building 24 Area
• Building 2 Area
• Buildings 4 and 5 Area
• Building 30 Area
• AOC 1 (507 Degreaser Area
west of Building 4)
• Parking Lot 6 Area
• Building 24 Area
• Building 2 Area
• West of Building 3
• Former Salt Baths - Building 14
• Former Salt Baths - Building 14
• Building 30 Area and Rice
Paddy
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February 10, 2019Chapter 2: Project Description
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AOC/Condition Source
Removal via
IRM and
Groundwater
Monitoring
Groundwater
Extraction,
Treatment, and
Discharge
In-Situ
Treatment
Reroute and
Water
Quality
Monitoring
Collection,
Treatment and
Discharge
Site-Wide CVOCs
in Groundwater X X
509 Degreaser
Area, CVOCs
in Groundwater
(AOC-1)
X X X
Site-Wide Barium
in Groundwater X X
Site-Wide Cyanide
in Groundwater X X
Building 24 Seep,
CVOCs X X X
Retaining Wall
Seep, CVOCs X X
Free Petroleum
Products, Site-
Wide
X X
FGEIS Table 2.5-3: Remedial Options Retained for Detailed Evaluation in Feasibility Study
Remedial Options Considered in Detail
2.6 Summary of Impacts and Mitigation Resulting from Project Updates
As a result of the Project updates, the Conceptual Site Layout Plan for the Project development has changed slightly
and the approach to zoning has been refined. In light of the full Project scope, the Lead Agency has determined that
none of the revisions or updates had any bearing on the impact and mitigation analysis and conclusions outlined in
the DGEIS Chapter 5.
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February 10, 2019Chapter 2: Project Description
Final Generic Environmental Impact Statement
10
8
10
LOADING
DOCK
LOADINGDOCK
N1
N2
N3
N4
N5
N6
N7
N8
N9
N10 N11
N12
N17
N20
N27
N31
N30
N29
N33
N34
N35
N36
N38
N32
N28
N13
N14
N15
N37
N18
N19
N21
N22
N23
EXIST. BLDG'S 2-6
N24
N25
N26
N16
I
II
III
IV
V
NYS 96B ACCESS DRIVES#
FGEIS Figure 2.1-4: Overall Conceptual Site Layout Plan Indicating Proposed Parking Locations and Driveways (CJS + FE) *
10
8
10
LOADING
DOCK
LOADING
DOCK
N1
N2
N3
N4
N5
N6
N7
N8
N9
N10
N11
N12
N17
N20
N27
N31
N30
N29
N33
N34
N35
N36
N38
N32
N28
N13
N14
N15
N37
N18
N19
N21
N22
N23
EXIST. BLDG'S 2-6
N24
N25
N26
N16
I
II
III
IV
V
NYS 96B ACCESS DRIVES#
FGEIS FIGURE 2.1-4
OVERALL CONCEPTUAL SITE LAYOUT PLAN INDICATING PROPOSED PARKING LOCATIONS AND DRIVEWAYS (CJS + FE) *
ITHACA
COLLEGE
CORNELL
UNIVERSITY
CITY OF ITHACA
TO WN OF ITHACA
CHAIN WORKS
DISTRICT
CAYUGA
LAKE VILLAGE OF
CAYUGA HEIGHTS
TO CORTLAND
(32 MILES)
TO WHITNEY POINT
(32 MILES)
TO HORSEHEADS
(28 MILES)TO HORSEHEADS
(36 MILES)
TO WATKINS GLEN
(24 MILES)
TO AUBURN
(37 MILES)
TO WATERLOO
(42 MILES)
TOWN OF
DRYDEN
UV930F
UV13A
UV89
UV34
UV79
UV13
UV96B
UV34
UV13
UV96B
UV366
UV96
UV13
UV79
PROJECT LOCATION:
CITY/TOWN OF ITHACA
TOMPKINS COUNTY
NEW YORK
FGEIS FIGURE 2.2-1
LOCATION OF THE PROJECT WITHIN NY STATE, THE CITY, AND TOWN (FE) *
FGEIS FIGURE 2.3-1
EXISTING SITE AND FACTORY BUILDINGS (FE) *
LOADINGDOCK
LOADING
DOCK
10
8
10
RetainingWall
N16
LOADINGDOCK
N1
N2
N3
N5
N6
N7
N9
N10
N11
N12
N17
N20
N27
N31
N30
N29
N33
N34
N35
N36
N38
N32
N28
N13
N14
N15
N37
N18
N19
N21
N22
N23
E2-6
N24
N25
N26
N8
N4
FGEIS FIGURE 2.3-2
OVERALL CONCEPTUAL SITE LAYOUT PLAN (PROJECT TEAM) *
CW1
CW3A
NATURAL SUB AREA (CW1)
TOTAL ZONE AREA - 1,039,404 GSF / 23.86 ACRES +/-
NEIGHBORHOOD GENERAL SUB AREA (CW2)
TOTAL ZONE AREA - 922,274 GSF / 21.17 ACRES +/-
CW4
NEIGHBORHOOD CENTER SUB AREA (CW3)
TOTAL ZONE AREA - 1,730,639 GSF / 39.73 ACRES +/-
INDUSTRIAL SUB AREA (CW4)
TOTAL ZONE AREA - 447,340 GSF / 10.27 ACRES +/-
CW2A
CW2B
CW1CW3B
CW3C
CW3B
FGEIS FIGURE 2.3-3
PUD / PDZ SUB AREA BOUNDARY MAP (R+W) *
Table 2.5-1
Summary of Soil AOCs and Interim Remedial Measures
IRM Work Plan
Former Emerson Power Transmission Facility
Ithaca,New York (a)
AOC AOC Description/Sub-Area Contaminant(s) (b)Affected Media SCO Driver (c)
Anticipated Future
Land Use (d)Anticipated Final Cover (e)
Demarcation
Barrier?IRM Remedy
Estimated Excavation
(CY) or
Cap/Cover (SF)
Restricted Residential/Mixed Use Area (d)
1 Former Department 507 Degreaser
(exterior)
CVOCs Soil, Groundwater Protection of Groundwater Restricted Residential Asphalt Yes 1. Excavate to 3 feet and dispose of CVOC soil offsite.
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Install cap consisting of clean soil backfill, geosynthetic clay liner, and asphalt
130
1,200 SF cap
Building 24 Interior (second floor)CVOCs Soil, Groundwater Protection of Groundwater Restricted Residential Concrete No 1. Excavate to bedrock and dispose of CVOC soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore concrete floor
30
Building 24 Exterior (parking lot)CVOCs Soil, Groundwater Protection of Groundwater Restricted Residential Asphalt No 1. Excavate to bedrock and dispose of CVOC soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore asphalt pavement
770
27 Former Salt Baths Metals (Ba)Soil/Bedrock/Groundwater Restricted Residential Use Restricted Residential To be Determined (green
space or plaza area) (f)
No 1. Excavate loose or fragmented bedrock (~2 feet) and dispose of material offsite
2. Backfill with clean soil and cover with gravel (future grass by others)
80
31 Upper Parking Lot 6 Metals (As, Ba, Cd, Cr, Cu, Ni)Soil Restricted Residential Use Restricted Residential Asphalt/Grass Yes 1. Excavate to 2 feet and dispose of metals soils offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore grass
20
Former Spray Pond Area PAHs, PCBs, and Metals (As, Ba, Pb, Hg)Soil Restricted Residential Use Restricted Residential Asphalt/Grass Yes 1. Excavate to 2 feet and dispose of PAH, PCB, and metals soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore grass
950
Former Spray Pond Area/Drainage
Ditch
PAHs and Metals Drainage Ditch Soil Restricted Residential Use Restricted Residential Riprap/Gravel No 1. Excavate to 2 feet and dispose of PAH and metals soil offsite
2. Backfill with clean soil and restore ditch lining
50
CVOCs Soil Protection of Groundwater Restricted Residential Possible (g)1. Excavate CVOC soil that exceeds PoG SCO and dispose of soil offsite
2. Collect confirmation samples of base and sidewalls (unless bedrock is encountered) and excavate additional soil
if necessary
3. Backfill with clean soil and restore asphalt/grass/gravel
210
PAHs Soil Restricted Residential Use Restricted Residential Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore grass or gravel
35A East of Building 24
(SB-103/SB-103SS)
Metals (As)Soil Restricted Residential Use Restricted Residential Soil (Grass)Possible (g)1. Excavate to 2 feet and dispose of arsenic soil offsite
2. Backfill with clean soil and restore grass
70
CVOCs Soil/Groundwater Protection of Groundwater Restricted Residential No 1. Excavate to bedrock and dispose of CVOC soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and cover with gravel (future grass by others)
140
PAHs Soil Restricted Residential Use Restricted Residential Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and cover with gravel (future grass by others)
35D Near Parking Lot 4 (SS-100)PAHs Soil Restricted Residential Use Restricted Residential Soil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite
2. Backfill with clean soil and restore grass
30
35G South of Parking Lot 3
(LBA-B17-TSS-3)
Metals (Ba)Soil Restricted Residential Use Restricted Residential Soil (Grass)Possible (g)1. Excavate to 2 feet and dispose of barium soil offsite
2. Collect confirmation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore grass
40
35H Parking Lot 3 (LBA-TP-03)PAHs Soil Restricted Residential Use Restricted Residential Soil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore grass
60
35K Former Railway Right-of-Way
(SB-240)
Metals (As)Soil Restricted Residential Use Restricted Residential Soil (Grass)Possible (g)1. Excavate to 2 feet and dispose of arsenic soil offsite
2. Backfill with clean soil and restore grass
40
35L Former Railway Right-of-Way (DS-1)PAHs Soil Restricted Residential Use Restricted Residential Soil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Backfill with clean soil and restore grass and ditch lining
110
Commercial Use Area
28 Oil Shed Area - Northeast CVOCs Soil/Groundwater Protection of Groundwater Commercial Asphalt Possible (g)1. Excavate CVOC soil that exceeds PoG SCO and dispose of soil offsite
2. Collect confirmation and documentation samples of base and sidewalls (unless bedrock is encountered)
3. Backfill with clean soil and restore grass (future paving by others)
500
29 Former Propane Aboveground Storage
Tank Area
PAHs Soil Commercial Use Commercial Asphalt Yes 1. Excavate to 2 feet and dispose of the PAH soil offsite
2. Collect confirmation and documentation samples and excavate additional soil if necessary
3. Place and compact 2 feet of soil cover to the approximate original grade and restore grass (future paving by
others)
1150
Industrial Use Area
30 Rice Paddy Area PAHs Soil Industrial Use Industrial Soil (Grass)Yes 1. Excavate to 1 foot and disposal of PAH soil offsite
2. Excavate PCB hotspots at depths indicated on IRM drawings.
3. Collect confirmation and documentation samples and excavate additional soil if necessary
4. Backfill with clean soil and restore grass
170
a\ AOC = area of concern; IRM = Interim Remedial Measure; SCO = soil cleanup objective; CVOC = chlorinated volatile organic compound; PAH = polycyclic aromatic hydrocarbon; PCBs = polychlorinated biphenyls; CY = cubic yard; SF = square feet; NA = not applicable.
b\ The contaminants include the constituents that are the primary drivers of the need for interim remedial measures; they do not include constituents present at concentrations minimally above the SCOs.
c\ SCO source: Table 375-6.8(b), Title 6 New York Codes, Rules and Regulations Part 375, Subpart 375-6.
d\ The term Restricted Residential/Mixed Use is defined as including one or more of the following: apartments and multi-family residences, offices, commercial endeavors, recreational areas, and green space. Restricted Residential Use SCOs are applicable in these areas.
e\ The anticipated final cover is based on the current layout for redevelopment.
f\ The current layout for the redevelopment plan indicates that the former salt baths area (Building 14) will be removed and used for green space or plaza area serving as an entry point for mixed use. The remaining portions of the AOC will be for industrial, warehouse, or storage uses.
g/ A demaracation barrier will be installed only in areas where bedrock is not encountered after excavation to the prescribed detph.
Asphalt/Grass
To be Determined 35C
26
32
34 Area East of Buildings 13A and 14
Building 11A (LBA-SB-250)
WSP
K:\EMERSON\Ithaca - 4507\IRM Work Plan\IRM Work Plan - August 2018 Submittal\Table\Table 3-1_080818
Page 1 of 1
Revised: 8/8/2018
FGEIS TABLE 2.5-1
SUMMARY OF SOIL AOCS AND INTERIM REMEDIAL MEASURES
CHAIN WORKS DISTRICT
February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
Chapter 3:
Comments and Responses to
Comments
Page 3-1
CHAIN WORKS DISTRICT
February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
CHAPTER 3: COMMENTS AND RESPONSES TO COMMENTS
3.1 Overview
This chapter provides summaries and responses to the substantive comments received on the DGEIS.
As noted in Section 1.4, the Public Comment Period for the DGEIS commenced upon acceptance of the
DGEIS by the Planning Board on March 8, 2016. A Public Hearing on the DGEIS was held on March 29,
2016. The Public Comment Period closed at 5:00 PM on May 25, 2016. Many comments were received
during the comment period including emails, letters, as well as verbal comments from six speakers during
almost three hours of testimony at the DGEIS public hearing but are addressed herein. Transportation
related comments from the City and the NYSDOT were received after the close of the comment period.
The total number of commenters is 22. A copy of the transcript of the Public Hearing is provided in
Appendix A. Copies of all comments, emails, and letters are provided in Appendix B.
In order to process and respond to the comments received on the DGEIS, a number was assigned to
each person who testified at the DGEIS hearing and/or submitted an email or letter with comments.
Then each email, letter and the hearing transcript were carefully reviewed to identify distinct substantive
comments. Each substantive comment identified was then assigned a unique comment identification
based on: (1) Commenter Identification number; and (2) the particular letter assigned to each distinct
comment made by that person or entity. By way of example, Comment No. 18A refers to the first distinct
substantive comment made in the correspondence from the Town of Ithaca Planning Board as marked
in Appendix B. A total of 280 distinct comments were identified from the emails, letters and the hearing
transcript.
Following identification of each distinct comment, all of the comments were carefully reviewed. A comment
summary for each comment was created with similar comments grouped together and then assigned
a unique identifier and sorted by DGEIS Section number. By way of example, five distinct comments
relating to the Growth Inducing Aspects (DGEIS Section 8.2) of the Project were grouped, summarized
and responded to as summarized comments labeled 8.2-1 and 8.2-2. All responses were initially drafted
by the Project Sponsor and then reviewed and revised (as appropriate) by the Planning Board.
Attached in Appendix C is a chart that includes each comment identification, the name of the person
who made the comment (and organization if applicable) and the comment summary and response
identification. Note that in some circumstances, more than one comment summary and response may
have been relevant to a particular comment. In such cases, more than one comment summary and
response may be identified in the chart as responsive to the comment. To assist the reader in correlating
the comment summaries and responses to the text of the DGEIS, the comment summaries and responses
are presented in this chapter in the general order of the presentation of information in the DGEIS.
Page 3-2
CHAIN WORKS DISTRICT
February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
3.2 Comment Summaries and Responses
The following comment summaries and responses are associated with information presented in DGEIS
Section 2.5 (Sustainable Design and LEED ND):
2.5-1. Project feels like two separate projects, one mixed-use and one suburban. Define the
LEED ND Boundary and explain how the project meets LEED ND Standards.
Response: LEED ND can only be applied to whole parcels. Different parts of the development vary in
density and mix but all are compact and have close proximity to live/work/play amenities. Accordingly,
the entire Site will be classified as LEED ND. The reason that portions of the Project seem suburban or
undeveloped is that large portions of the Site exceed 20% slopes, which makes these areas unsuitable
for development.
2.5-2. Explain how CW2 meets LEED ND standards and is a compact dense urban
development.
Response: The Design Standards describe CW2 as “primarily residential buildings. They may have a
wide range of building types including detached single family, multi-family, and rowhouses. Setbacks and
landscaping are variable. Streets with curbs and sidewalks define medium-sized blocks.” The proposed
layout includes mostly townhouses and the smallest blocks possible with the most connectivity possible
given Site constraints. This design is a significantly more compact and urban residential form than any
development that currently exists in the Town and it is walkable/bike-able to major employment and
educational amenities within and adjacent to the development, which makes this a compact dense urban
environment. The Conceptual Site Layout Plan has been revised to depict an expanded sidewalk network
to ensure connectivity of the developable areas as well as adjacent properties - see FGEIS Figure 2.3-2.
2.5-3. The Project Sponsor should consider taking a holistic approach to LEED ND
certification, focusing on obtaining the LEED ND credits that have the greatest
environment, economic and social benefits to meet relevant Comprehensive Plan goals for
the City and Town.
Response: The Project Sponsor is seeking LEED ND: Plan certification as required by the New York
State Energy Research & Development Authority (NYSERDA) Category 3 grant award received by the
Project Sponsor and is the basis for the Conceptual Site Layout Plan development. The LEED Rating
System is a voluntary, consensus driven, internationally-recognized green building certification system
developed by the US Green Building Council, providing third-party verification that a building or community
was designed and built using strategies aimed at improving performance across metrics such as energy
savings, water efficiency, greenhouse gas emissions reduction, improved indoor environmental quality,
and resource stewardship. The point allocation process employed by the LEED Rating System serves as
a method for producing a simplified guide for project teams to navigate complex and competing issues.
In LEED v4, the allocation of points among credits is based on the potential environmental impacts and
human benefits of each credit with respect to a set of impact categories. A combination of approaches,
including energy modeling, life-cycle assessment, and transportation analysis, is used to quantify each
type of impact. LEED v4 builds on the analytical framework of LEED 2009, which was based on the U.S.
Environmental Protection Agency’s TRACI3 environmental impact categories as the basis for weighting
each credit. TRACI was developed to assist with impact evaluation for life-cycle assessment, industrial
ecology, process design, and pollution prevention. Further details on the LEED v4 credit weighting
process are available from the US Green Building Council publication “LEED v4 Impact Category and
Point Allocation Development Process,” located at:
http://www.usgbc.org/sites/default/files/LEED%20v4%20Impact%20Category%20and%20Point%20
Allocation%20Process_Overview_0.pdf
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CHAIN WORKS DISTRICT
February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
The LEED for Neighborhood Development v4 rating system is designed primarily for the planning and
development of new green neighborhoods, whether infill sites or new developments proximate to diverse
uses or adjacent to connected and previously developed land. Thus, this LEED rating system was
selected for this Project for its specific prerequisites and credit categories related to redevelopment
of aging brownfield sites into revitalized neighborhoods by rewarding connections beyond the Site,
walkable streets within the Site, and the adaptive reuse of historic buildings and structures. Unlike other
LEED rating systems, which focus primarily on green building practices and offer only a few credits for
site selection and design, LEED for Neighborhood Development places emphasis on the site selection,
design, and construction elements that bring buildings and infrastructure together into a neighborhood
and relate the neighborhood to its landscape as well as its local and regional context. To achieve LEED
ND v4 Plan certification, this Project must document compliance with all prerequisites and a sufficient
number of credit requirements. The NYSERDA grant for the project requires LEED ND Certification of
Gold or higher.
The Town of Ithaca Comprehensive Plan’s Section 3.4.4 ‘Area of Special Concern: Emerson Center’ cites
redevelopment goals as a mixed-use complex that would include apartments, live-work space, studios,
retail, offices, and light industrial established by an approved redevelopment plan, with density taking full
advantage of the Site’s location near central Ithaca. The Goals of the City and Town Comprehensive Plans,
along with LEED ND credit weighting, were carefully considered during the design of the Conceptual Site
Layout Plan.
2.5-4. The applicant should strongly consider exceeding the LEED ND credit requirements
because some Site characteristics which contribute to LEED credits are endemic to the
Site location.
Response: This comment is acknowledged. The LEED for Neighborhood Development rating system
was specifically selected for its prerequisites and credit categories related to redevelopment of aging
brownfield sites into revitalized neighborhoods by rewarding connections beyond the Site, walkable
streets within the Site, and the adaptive reuse of historic buildings and structures. Site selection is a
core attribute of the LEED for Neighborhood Development rating system because where development
happens is important. Preference is given to locations close to existing town and city centers with existing
utilities, roads, and other infrastructure in place, sites with good transit access, infill sites, previously
developed sites, and sites adjacent to existing development. The Project meets each of these LEED
ND fundamentals. With this location efficiency, the benefits are multiplicative and reinforcing: convenient
transportation choices, such as buses, car sharing, bicycle lanes, and sidewalks, are generally available
near downtowns, which are also the locations associated with shorter automobile trips. It is important to
note that exceeding LEED for Neighborhood Development credit requirements may also exceed DGEIS
impact thresholds in some credit categories.
2.5-5. Key LEED ND credits which the applicant should strongly consider: Smart Location &
Linkage-Access to Quality Transit, Bicycle Facilities, Site Design for Habitat
or Wetland and Water Body Conservation; Neighborhood Pattern & Design- Housing
Types and Affordability, Reduced Parking Footprint, Transit Facilities, Transportation
Demand Management, Access to Civic & Public Space, Community Outreach and
Involvement; Green Infrastructure & Buildings- Certified Green Buildings, Optimize Building
Performance, Indoor Water Use Reduction, Outdoor Water Use Reduction, Solar Orientation,
Renewable Energy Production, District Heating and Cooling, Infrastructure Energy
Efficiency, Light Pollution Reduction.
Response: See response to Comment No. 2.5-4.
2.5-6. Excluding the following credits, the applicant should consider meeting the following
minimums for LEED certification: Excluded Credits-Site Requirements: Preferred
Locations – 10 credits, Brownfield Remediation – 2 credits, Housing and Jobs Proximity
Page 3-4
CHAIN WORKS DISTRICT
February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
– 3 credits, Visitability and Universal Design – 1 credits, Innovation – 5 credits, Regional
Priority Credit Defined – 4 credits.
Response: See response to Comment No. 2.5-4.
2.5-7. The Chain Works District (CWD) has the potential to become the largest consumer of fossil
fuels on South Hill within the next ten to fifteen years. For this reason I believe the CWD
developer, Unchained Properties (UP), should work cooperatively with IC and other large
energy consumers on South Hill to create a Climate Action Plan (CAP) that commits all
parties to the common goal of becoming fossil fuel free by 2050 or before.
Response: The design goal is to reduce energy use over regional average (assumes conventional energy
to be natural gas and grid electricity) for building type by 70% (Architecture 2030) and consumption per
finished 1 s.f. (the baseline used is 98,000BTU/s.f. based on the 2003 U.S. EIA Middle Atlantic Commercial
Building Survey, the most recent available.). The fossil fuel use reduction will be a combination of energy
efficiency and green energy generation. Section 5.8.3 of the DGEIS includes the estimate of energy
usage reduction of up to 53,000 MMBTUs per year. Also, The Project Sponsor intends to continue to
participate in the SHCA as well as continue cooperative energy conservation conversations with other
South Hill institutions such as Ithaca College.
2.5-8. Include in the FGEIS that monthly meetings be held within the South Hill community to
develop a CAP for South Hill and to discuss development of a South Hill Community
Microgrid. Community Sustainable Energy for all of South Hill should be an integral part
of the Chain Works Project.
Response: The Project Sponsor has actively attended SHCA meetings since investigating the feasibility
of the Project. The Project Sponsor intends to continue working with the SHCA on sustainability, microgrids,
energy and other issues of importance for the community as appropriate. The Project Sponsor intends to
incorporate sustainable energy however this Project focuses on the property that is under control of the
Project Sponsor. The CWD cannot commit other parties to a particular sustainability program.
2.5-9. I am strongly advocating that Community Sustainable Energy for all of South Hill be an
integral part of the Chain Works Project. I want you to seriously consider the impact on
the South Hill neighborhood at large and the benefits that incorporating community
sustainable energy would provide both environmentally and economically.
Response: See Response to Comment No. 2.5-8.
2.5-10. The DGEIS doesn’t mention the benefits of redevelopment of a former industrial site,
versus the impact from conventional development on greenfields that would otherwise
take place to satisfy market demand.
Response: The environmental benefits are outlined in the DGEIS as indicated by the LEED ND point
system. Additional points are provided for redevelopment/brownfield project sites. Nonetheless, the
comment is acknowledged and the DGEIS lists the benefits of developing the industrial site versus
typical greenfield development by highlighting the inherent benefits. These benefits include, but are not
limited to, preventing sprawl, increasing density near the city center which will reduce traffic impacts and
energy needs by encouraging pedestrian and transit use, insuring that the Site is utilized to enhance the
tax base, and facilitating the environmental remediation of the Site to allow residential and commercial
uses.
2.5-11. The DGEIS does not address a few key goals of the City and Town Comprehensive Plans
that are relevant to a project of this scale including the provision of a broad variety of
housing types and prices and the arrangement of open space.
Page 3-5
CHAIN WORKS DISTRICT
February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
Response: No single project can address all of the key goals listed in both the City and Town Comprehensive
Plans. However as stated in the DGEIS Section 2.6.5, Chain Works meets the key goals of concentrated
infill development in areas where existing infrastructure already exists and to promote redevelopment in
order to discourage urban sprawl.
2.5-12. Ithaca remains an aspirational community for those drawn to the environment of a
college town. Stating that “… it is clear that the regional “brain drain” is a solvable issue
with redevelopment of the site” seems like an exaggeration of the project’s potential benefits.
Response: Acknowledged.
2.5-13. Of the new housing units at Chain Works, about how many will directly satisfy non-student
community housing needs? How many will directly satisfy the affordable housing needs
for different income levels? Multiple elements found in the DGEIS hint at purpose-built
student housing – which does not directly satisfy housing demand among the general
public. If student housing will be a part of Chain Works, the DGEIS may be exaggerating the
project’s potential impact on “satisfy[ing] a community need for housing” and “making
housing more affordable”.
Response: The SEQR Handbook defines a GEIS as being more general or conceptual in nature. The
proposed Project is generalized by impact. This is done by estimating a total number of units with an
average number of bedrooms in an effort to estimate water usage, traffic impacts, community service
demand, etc. This also allows the Project Sponsor to estimate average rentals based on current market
demand. The higher level of rental determination requested by this Commenter requires the Project
Sponsor to specify actual residential unit layouts and furnishings. That is not part of the scope for a
Generic proposal such as this. Current average market prices for the surrounding area are outlined in
the 2016 DIA Residential Analysis performed by Danter Company, LLC.
The Project Sponsor proposes that the dwelling units will be market-rate with a great variability in rent
structures depending on the type and location of the unit. There are no plans to provide specific housing
types (i.e. student or low-income housing units) however, through a variety of rental types, there will be
a level of housing affordability accommodating different demographics.
The Project Sponsor does not intend to provide subsidized low-income affordable housing as part of the
Project. The costs associated with redeveloping the Site, such as costs to shepherd the Project through
approvals from two municipalities and an amended ROD from the NYSDEC; to perform extensive
environmental investigations of the Site; to comply with implementing a SMP during construction, and
operating and maintaining mitigation systems to prevent vapor intrusion; and to convert old industrial
structures and related infrastructure to allow mixed uses will be higher than if one were to develop a
greenfield. Thus rents will need to be market rate for this Project to succeed.
The Project Sponsor also does not intend to provide a student housing only complex or purpose-built
student housing. However, the housing stock made available through this Project will certainly create
more opportunities and choices for students wishing to live in the area. In addition, through supply and
demand, the cost of housing will be lower and thus more affordable with the Project’s additional housing
stock in the greater Ithaca market than if it were not available.
2.5-14. This section mentions the CW2 subarea will have a “variety of housing types”. These
housing types include “point-access”, “townhomes or double loaded”, and “multi-unit
corridor configurations”. These are not different types of housing, but different forms of
access to individual units in multi-unit buildings. Please correct this.
Response: See Response to Comment No. 2.5-13.
2.5-15. Evaluate existing market demand and need with a comparison to the proposed housing
Page 3-6
CHAIN WORKS DISTRICT
February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
portion of the Project.
Response: As part of the Site Plan process that involves residential uses, the Project Sponsor will
consult with the latest Ithaca oriented housing studies.
2.5-16. Without a well-defined, agreed upon definition of what constitutes the physical extent of
the existing housing market, there is no valid basis on which to “evaluate” market demand
nor can there be any valid “comparison to the proposed housing portion of the Project”,
both of which are required by the final Scoping Document.
Response: See Response to Comment No. 2.5-13.
2.5-17. Please describe how Chain Works will directly satisfy the projected demand for luxury,
upscale, affordable-moderate, and tax credit units, as the Downtown Housing Strategy
report describes and is referenced in the DGEIS.
Response: The Project Sponsor does not have a complete breakdown of every single unit type out of
the 915 proposed units in the GEIS process. There are a variety of unit types accommodating a wide
demographic including studios, one-bedrooms, two-bedrooms, 3-4 bedrooms, duplex buildings, lofts and
townhouses. There are expected to be approximately 1,830 bedrooms to assist in meeting the demand
outlined in the Downtown Housing Strategy. As discuss in the DGEIS, the Project Sponsor does not
propose any tax credit units.
2.5-18. The CWD project is an opportunity to achieve environmental remediation of the site.
Response: Acknowledged.
2.5-19. Need to see the full extend to cross section BB. Also need to see a cross section from
Aurora to Turner showing relationship to existing development adjacent to the site. Also
need visualization from Turner and Hillview Pl.
Response: The DGEIS Figure 2.7-3 has been revised to extend cross section B-B and include a new
cross section from South Aurora Street to Turner Place. The view of the Proposal from this location will
remain unchanged. The view from Turner Place and Hillview Place toward the CWD has been added to
the DGEIS as a revision.
2.5-20. CW-3 describes a mixed use program cluster at the entrances of driveways I & II - this
appears to be all residential on the layout plans. Please explain this.
Response: The CW3 program will allow mixed uses. For the purposes of the analysis, the Conceptual
Site Layout Plan for the entrances are residential.
2.5-21. Clarify if commercial uses will be allowed in the CW2 Sub Area and what percentage will
be residential versus commercial.
Response: Commercial uses will be allowed in the CW2 but such uses are estimated to be minor. See
DGEIS p. 2-20. The actual amount will be determined during the individual Site Plan process but will not
exceed the 184,350 s.f. of overall commercial use established for the entire Project as outlined in Table
2.7-1.
2.5-22. Does the BB Section conform to the conceptual Grading Plan?
Response: Yes.
2.5-23. Phase 1 includes a new road section connecting parking lots 7b & 7c. This is not mentioned
in the project description – need to include additional impervious surface.
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Response: This comment was received during DGEIS adequacy review. The new road section was
addressed in the published DGEIS.
2.5-24. There is an abundance of native species in the CW2 Sub Area, therefore it should remain
in a native state similar to CW1.
Response: The Project Sponsor states that the development of the CW2 Sub Area is a key component
of the CWD and cannot remain in its native state. The potential impacts of the development of the
CW2 have been thoroughly reviewed within the DGEIS. It should also be noted that a boundary will
be delineated for each individual project as part of site plan review. Site Plan approvals will require a
vegetation survey of the individual project boundaries.
2.5-25. The carbon impact of developing the CW2 should be analyzed.
Response: The analysis of the carbon impacts was not part of the Scoping Document and accordingly
was not included in the DGEIS. However, Chapter 9 reviews the effect on the use and conservation
of energy which is a closely related subject. The Project does preserve approximately 23.86 acres of
vegetation in the CW1 Sub Area. The development of 21.17 acres of forest/brush will be a negligible
impact on the overall issue of carbon impact/climate change.
2.5-26. The Town of Ithaca PB encourages exploring deed restrictions or conservation easements
to promote the permanent conservation of land where possible. This strategy should work
in conjunction with the proposed PUD/PDZ language related to the Chain Works project.
Response: Acknowledged. The Project Sponsor is proposing to preserve the CW1 (23.86 acres) Sub
Area allowing those uses consistent with passive recreation to benefit the community. The related zoning
restrictions within the PUD/PDZ are sufficient to accomplish that Project goal. The legal mechanism for
preservation will be determined during the site plan review process for individual projects in the CWD.
2.5-27. Clarify why the description of CW2 Sub Area states that the development shall not exceed
700,000 sf versus the 568,400 sf in DGEIS Table 2.1-1.
Response: These are two separate numbers in the DGEIS; the first (700,000 s.f.) is a threshold for
the maximum development of the CW2 Sub Area and the second (568,400 s.f.) is the amount of GFA
depicted in the Conceptual Site Layout Plan.
2.5-28. If 177,000 sf is the maximum residential area proposed for CW2 then why analyze and
additional 639,475 sf? Clarify if the floor area numbers refer to the 4 or 6-story scenario.
Response: The total gross size of the footprint is 177,000 s.f. depicted on the Conceptual Site Layout
Plan. This is not to be confused with the total GFA which is greater since there are multiple floors.
The rationale for including footprint in the DGEIS is that it is one variable utilized in analyses such as
stormwater impacts. The floor area numbers refer to the stories that are dedicated to the occupied use
and do not include the stories dedicated to structured parking.
2.5-29. Figure 2.7-3: Section through CW2 (Section A-A) is misleading showing only buildings in
the CW2 that are 3-stories tall versus the allowable 4-stories with the up to two additional
stories allowed below the uphill grade first story.
Response: Acknowledged. Figure 2.7-3 of the DGEIS has been revised to depict the maximum
development potential. See updated figure at the end of Chapter 4 of the FGEIS.
2.5-30. All CW2 related tables and numbers should be revised to indicate the most accurate bulk
and density information.
Response: Table 2.7-1 of the DGEIS provides a summary of the development within each Sub Area
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based on the Conceptual Site Layout Plan. This is a conceptual number only and is subject to change.
The information in the table will be updated as necessary to accurately reflect the individual Site Plans
proposed for approval.
2.5-31. Buildings stories need to have a “not-to-exceed height” for all Sub Areas. 4 Stories plus 2
additional stories on the downhill side in CW2 is excessive.
Response: The specific bulk and density requirements are included in the City PUD and Town PDZ. See
Appendix D.
2.5-32. Section 2.7.3.2 states Buildings 17 and 18 will be converted to about 10,400 ft² of restaurant/
café and event café space. However, Table 5.7-4 (Project Generated Trips) uses 7,200 ft² as
the basis for restaurant trip generation. Which information is correct?
Response: Trip generation does not include structured parking in the GFA.
2.5-33. There are some confusing numbers for parking spaces on page 2-23. The second paragraph
indicates that there will be an increase of 450-475 parking spaces from the “current 875
spaces.” But the last paragraph in the section notes that there will be a “total of 675
parking spaces in CW3.” Please clarify or correct if this is a typo.
Response: The description of the entire site parking is an increase of 450 spaces from the current 875
spaces for a total of approximately 1,325. Of these 1,325 spaces, there will be a total of 675 spaces
located within the CW3 Sub Area.
2.5-34. Please label all parking areas on the Conceptual Site Layout Plan with total number of
parking spaces. Provide analysis to verify that sufficient parking will exist for all land uses
without need for long walking distances.
Response: Acknowledged. In addition to the Conceptual Site Layout Plan, separate figures for each
Sub Area depicting parking areas with counts including structure parking to ensure sufficient parking for
each structure, are included at the end of Chapter 4 of the FGEIS.
2.5-35. Alignment of Gateway Trail should appear on Phase 1 Site Plans.
Response: Acknowledged. The Gateway Trail connection is included on the revised Conceptual Site
Layout Plan as well as the updated Phase 1 Site Plans.
2.5-36. A site plan should be provided illustrating what portion of the internal site circulation path
and site access points will be developed with Phase 1 of development.
Response: Acknowledged.
2.5-37. Changes to the Phasing sequence may require the submission of a supplemental EIS.
Response: The DGEIS states that the Phasing is not sequential and is presented only as a means of
identifying sections of the development. The DGEIS emphasizes long term over short-term impacts as
recommended in the NYSDEC SEQR Handbook. Since the DGEIS established cumulative thresholds
for the entire Conceptual Site Layout Plan, changes to the phasing sequence alone would not require a
Supplemental EIS.
2.5-38. The population of the CWD should be broken down by age.
Response: As indicated in Chapter 5 of the NYSDEC SEQR Handbook, a GEIS is used to address
broad planning questions. A Supplement EIS would be triggered if a significant adverse impact was not
addressed. The further breakdown by age group beyond that currently presented is not necessary to
weigh the benefits of the Project against its potential significant adverse impacts.
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2.5-39. A Rutgers University report based on NY Census data projects populations with age
breakdowns and can inform population estimates.
Response: The citing of the Rutger’s study is acknowledged. However the purpose of the GEIS is to
address broad planning questions. Therefore, the DGEIS utilizes an overall average of two bedrooms
per unit and an estimate of 50 school (K-12) aged children based upon the Project Sponsor’s projections.
The Rutgers University report cited by the Commenter generalizes on an overall city scale and was not
utilized in the development of the DGEIS. The actual development through the multiple Phases will be
reviewed with the estimates presented in the DGEIS. Should thresholds based upon those projections
be exceeded during the phased development (approximately 10 year) of the Project, the need for a
Supplemental EIS will be evaluated by the relevant Lead Agency.
2.5-40. There is too much emphasis on new development in the CW2 Sub Area and not enough on
redevelopment of existing buildings.
Response: The DGEIS evaluates the general development of the Site as a whole as recommended
in the NYSDEC SEQR Handbook. As per Table 2.1-1 of the DGEIS, the redevelopment of the existing
buildings accounts for 815,450 s.f. or approximately 48% of the Project Sponsor’s proposed maximum
development of the Site. Therefore, development of both the new construction and existing buildings
is planned. Phase 1 depicts redevelopment first and it is the intention of the Project Sponsor to pursue
Phase I first, dependent on the NYSDEC approvals.
2.5-41. Describe how CWD provides family-friendly housing and amenities.
Response: The Proposal will offer a variety of housing types including one-, two- and three-bedroom
apartments, as well as townhouse-type units. These are all viable family-friendly housing options that
are offered in successful, sustainable, and denser urban settings. The Proposal provides open outdoor
courtyards and assembly areas within its boundaries and access to hiking trails and natural landscapes
to the west and south. In addition, the CWD will locate housing units within a ten-to-fifteen minute walk to
the amenities offered by the City of Ithaca’s downtown core (restaurants, parks, theaters, services, etc.).
Family-friendly amenities will be developed during site plan review.
2.5-42. The project should provide a mix of housing suitable for seniors, families, and others at
various stages of life.
Response: According to the Project Sponsor, the majority of the units will be typical rental units with the
potential of some of the townhouse units for sale in the CW2 Sub Area. The Project does not specifically
target senior housing as that demographic is not part of the housing development’s program. The CWD
will be able to provide a variety of units, many of which will be suitable for families.
2.5-43. An active, engaging and safe public realm is central to a successful neighborhood. Site
redevelopment standards that incorporate sidewalks, public gathering spaces, structures,
etc. in the public realm of the new neighborhood should be incorporated in the proposed
PUD zone.
Response: The Conceptual Site Layout Plan includes several areas of public gathering spaces
designated throughout the Site with illustrative images demonstrating the intent. Thoroughfare standards
define the public rights of way with emphasis on the pedestrian experience. Detailed public amenities
will be developed as part of individual Site plans for specific projects as they are proposed. The Planning
Boards will have the ability to review and advise on any proposed design and development of the public
spaces as they are submitted overtime in lieu of including specific design standards. The GEIS evaluates
the general development of the Site as a whole as outlined in the NYSDEC SEQR Handbook. Within the
existing CWD core structures there is approximately +/-1.7 acres (74,100 s.f.) of dedicated open outdoor
space and connections (including the Gantry Garden, Annealing Courtyard, Assembly Yard and Chain
Drive). To the west the existing Buttermilk Falls State Park Trail will be extended north through the Site
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and will be accessible to the public. To the west and to the south there is an additional +/-28.6 acres
(1,245,000 s.f.) of wooded area dedicated to remain as natural landscape for public use. Finally, there are
miscellaneous green spaces on the Property that will also be available for public use (see FGEIS Figures
2.1-3 and 2.4-2). Any additional dedicated outdoor space will be evaluated and determined on a Project,
building or use-specific basis in conjunction with the site plan review process for individual projects within
the CWD and as market-driven needs require.
2.5-44. The DGEIS claims the project will “enable the construction of the Gateway Trail.” However,
the trail needs to be on the ground to realize its connectivity and amenity benefits.
Response: The Project Sponsor has actively sought to bring the City, Town and the current Property
Owner together to finalize an agreement that will allow construction of the Gateway Trail. The Project
Sponsor will incorporate the cooperatively developed Gateway Trail project in the corresponding Site
Plan drawings. If the Gateway Trail is not developed, other Site connectivity described in the DGEIS will
provide mitigation to the extent possible.
2.5-45. There are several vague statements in the DGEIS regarding the construction of the Gateway
Trail, but with no commitment as to how the trail will be constructed. The gateway trail
could be constructed without the Project.
Response: See Response to Comment No. 2.5-44.
2.5-46. The proposed redevelopment of the Site will be a transformative project. The City and
Town should use planning and design principles to establish PUD zoning.
Response: Acknowledged.
2.5-47. The Project supports the principles and policies of the 2015 Tompkins County
Comprehensive Plan.
Response: Acknowledged.
The following comment summaries and responses are associated with information presented in DGEIS
Section 2.8 (SEQR Process):
2.8-1. A section titled “Recreation” is called for in the Scope (2.5.5, p. 12) between DGEIS 2.7.3.4
(Common Areas, Open Space and Other Facilities and Services) and 2.7.3.5 (Parking), but
there appears to be no such section.
Response: 6 New York Codes, Rules and Regulations (NYCRR) 617.10 states that GEIS are “broader
and more general” and should discuss the “logic and rationale for the choices advanced”. It was
determined by the Lead Agency during the development of the DGEIS that the recreation section would
be combined under “Common Areas, Open Space and Other Facilities and Services” under each Sub
Area. Additional data on the approximate square footage has been added to the DGEIS. See FGEIS
Figure 2.3-2 on page 2-3 of the FGEIS.
2.8-2. There will be an impact on the existing housing stock with the addition of 900+ high-end
residential units.
Response: As outlined in 6 NYCRR 617.10, the purpose of the DGEIS is to address potential
environmental impacts of the entire development, not just the residential units as outlined in DGEIS
Chapter 5. Environmental impacts for the whole development have been addressed. The Project
Sponsor is offering a range of housing.
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2.8-3. The Chapter 5 formatting should be extended to Chapter 8.
Response: As outlined in the SEQR Handbook, there is no particular format required for the DGEIS
so long as the required “fundamental” elements are presented. Chapter 5 is the only chapter that is
split into the three sections (existing conditions, impacts, and mitigation). This is a typical EIS format.
SEQR regulations only require an overview discussion on Growth Inducing Aspects and Character of the
Community. Therefore, the discussion in the DGEIS on these topics are sufficient.
2.8-4. A bibliography should be added to the DGEIS.
Response: Acknowledged. A reference section was included in Section 13 of the DGEIS.
2.8-5. Secondary (i.e. previously gathered) data sources referenced but not compiled in a
comprehensive bibliography or reference list (e.g. 2013 ACS, Housing Needs Assessment,
2006, etc.).
Response: Acknowledged. A reference section was included in Section 13 of the DGEIS.
2.8-6. Please add the City of Ithaca Board of Public Works as an Involved Agency.
Response: The Lead Agency included the City of Ithaca BPW as an Involved Agency during Scoping.
2.8-7. Please add the Ithaca City School District as an Interested Agency.
Response: The Lead Agency included the Ithaca City School District as an Interested Agency during
Scoping.
2.8-8. The DGEIS is too voluminous to review within the 60-day SEQR timeframe.
Response: The Lead Agency acknowledged this comment and extended the comment period an
additional 15 days.
2.8-9. The material covered in chapter 6 of the scoping document has been split up and dealt
with under the headings in DGEIS chapter 5; this seems like a good idea.
Response: Acknowledged.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.1 (Land Use and Zoning):
5.1-1. Six story buildings in the City portion of the development are too tall.
Response: The ability to utilize six-story buildings under the PUD/PDZ will allow CWD to be developed
in accordance with LEED ND. The intent is to create a dense and vibrant neighborhood, and six-story
buildings help to achieve those goals in a manner consistent with more urban, city environments.
5.1-2. Design Standards – how do they address compatibility with existing historic structures
and off site residential development?
Response: The PUD/PDZ Form and Use Regulations address building form and disposition on the Site.
See Appendix D. Compatibility with existing historic structures and off-Site residential development will
likely be adressed in conjunction with the Design Review/site plan Review process for individual projects
within the CWD.
5.1-3. The development in CW-2 reads like ‘suburban apartment complex’ rather than
a neighborhood- your specifically state that your vision is to create the later and avoid the
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former.
Response: The vision of CWD is to develop a mixed-use district through the reclamation and revitalization
of existing structures and new areas of development. The proposed development on the CW2 project
site is guided by best practices as set forth by LEED-ND guidelines as they relate to development density
goals, site access (and accessibility) and limitations of building construction on existing sloping sites.
The CW2 Sub Area is comprised of large areas of sloping land in excess of 20% - limiting the land area
which can be developed in this zone. The extent of the proposed configuration minimizes construction
on steep slopes and strives to build on land that has less than a 20% slope. It is envisioned that existing
and new structures will develop a cohesive neighborhood (or “district”) via complementary programmatic
uses, density of development, a variety of building scales and massing and the establishment of unifying
Design Standards and aesthetics.
5.1-4. Do “visually sensitive areas” cited in Section 5.1.3.1 include the valley/lake view from Rt.
96B and viewshed impacts on surrounding hills and valleys?
Response: Yes. See Section 5.10 of the DGEIS for a complete list of views required in the Final Scope.
5.1-5. Buffers should also be maintained in areas adjacent to natural areas to prevent impingement
of development on green space.
Response: The designation of the open natural areas that could otherwise be developed is, in essence,
the buffer. The Project Sponsor is not proposing additional buffers to natural areas that will not be
developed.
5.1-6. The Zoning discussion should reference whether design standards will apply to accessory
buildings envisioned for CW-1 Sub Area.
Response: Design standards do not apply to CW1 because the only permitted building types have
no relationship to a dense, diverse, walkable urban form. Any potential buildings in the CW1 will be
addressed in conjunction with the Design Review/site plan review for individual projects within the CWD.
Design Standards have been removed from the PUD/PDZ and replaced with Design Guidelines.
5.1-7. Design guidelines should be established to support the PUD.
Response: No building design guidelines are proposed for this project. The planning Board has discretion
for allowing a wide variety of architectural styles to create a diverse and high quality neighborhood
experience.
5.1-8. To help mitigate visual impacts of the proposed new development the applicant should be
required to explore the use of landscape buffers and muted earth tones on building
exteriors as part of this DGEIS.
Response: The proposed conceptual Site plan considers landscape buffers both along the outside
perimeter of the Site boundary (between the CWD and the surrounding existing context to the north,
west and south) and within the Site itself. Visualizations developed and included in Chapter 5 do not
include tree lines that would provide visual buffers between buildings (which will/would effectively reduce
perceived building heights from various viewpoints). This visualization approach was taken in order to
clearly (and transparently) represent the height of the proposed structures. The color palette of building
exteriors will be reviewed when individual projects are submitted for / during the established design and
construction approval process for the CWD.
5.1-9. We suggested changing the Sub Area designation along the NYS Route 96B corridor to
CW2, thereby limiting the uses to residential and the building heights to a maximum of 4
stories (or shorter, with much lower than 24-foot story heights). We also recommended
revising the PUD-PDZ language to show design and architectural standards that would be
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unique to the NYS Route 96B frontage. Alternately, we suggested creating a new defined
area that pertains only to that corridor and contains its own set of architectural design
requirements.
Response: Acknowledged. To accommodate the intent of the comment, the buildings within a 100-foot
buffer along NYS Route 96B will be limited to a maximum of 4 stories as required in the PUD/PDZ Form
and Use Regulations. Sub Area 3 has been split into Sub Area 3A and 3B.
5.1-10. Regarding the conceptual designs shown for the structures in the photos on pages 5-171,
5-183, 5-190 and 5-192 of the DGEIS, we want to reiterate that the city and town specifically
indicated in their comments related to Adequacy that there should be special consideration
related to the proposed heights and designs of new buildings that will be constructed
along the Aurora Street/NYS Route 96B frontage in the CW3 Sub Area.
Response: See Response to Comment No. 5.1-9.
5.1-11. We understand that the allowable story height of up to 30 feet in the CW4 Sub Area is for
the first story of existing buildings only. Please confirm.
Response: That is correct. See PUD/PDZ Form and Use Regulations in Appendix D.
5.1-12. The conceptual PDZ regulations have no performance standards, buffering or screening
requirements, or other standards that would help mitigate the impact of potentially
intensive industrial uses near residential areas.
Response: There is buffering built into the Conceptual Site Layout Plan to protect adjacent residential
uses at a distance greater than what is allowed under the current industrial zone. The separation of
industrial and residential uses is prescribed through the Conceptual Site Layout Plan itself with a range
of housing options provided in various proximities to other mixed-uses. Buffering will be addressed in
conjunction with the Design Review/site plan review process for individual projects within the CWD.
5.1-13. Environmentally valuable areas should be identified. On-site and adjacent areas potentially
impacted by contamination should not be categorized as “environmentally valuable”
unless they are known to be in compliance with regulatory cleanup standards.
Response: The CW1 Sub Area was developed to protect the environmentally valuable areas and the
older, more valuable forest as outlined in DGEIS Section 5.4. Steep slope areas have also been identified
in Figure 5.2-2 of the DGEIS.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.2 (Land):
5.2-1. The USDA Soil Survey Map and accompanying description of the soils on the site indicate
that there are highly erodible soils in the areas within and around Sub Area CW2. However,
additional studies, including a possible supplemental EIS, may eventually be required in
order to adequately evaluate the actual development limitations related to soils and slopes.
Response: The in-situ soils in the CW2 Sub Area are highly erodible. Appropriate standard mitigation
measures are outlined in the DGEIS which follow the SPDES General Construction requirements in
New York State. Based on this information, soil stabilization in these soils can be performed with green
and hardscape measures to mitigate adverse impacts. Nonetheless, these issues will be evaluated in
detail in conjunction with the Design Review/site plan review process for individual projects within the
CWD to ensure appropriate mitigation. This mitigation can include detailed grading plans, erosion and
sediment control measures, the development of a full Stormwater Pollution Prevention Plan (SWPPP) and
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geotechnical investigations/recommendations. A Supplemental EIS would only be required if appropriate
mitigation cannot be implemented.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.3 (Water Resources):
5.3-1. A historical incident of flooding occurred in March 2011. The property of Jennifer Cleland,
located on Spencer Street, experienced water flowing across her property during a
prolonged, intense rain event. The on-Site, unnamed tributary south of the developed
portion of the Site (POS-E) had filled with stone and silt. This caused the unnamed tributary
to overflow its banks and the runoff flowed to the base of the hill, crossing Ms. Cleland’s
property.
Response: Acknowledged. This is documented in the Generic SWPPP as an existing condition. This
Project provides an opportunity to improve maintenance of the unnamed stream that traverses the Site
which in turn will reduce the chances of plugged drainageways causing flooding to downstream properties.
All upstream and downstream stormwater facilities will be reviewed for capacity during the site plan
review process for individual projects within the CWD. The proposed stormwater mitigation also includes
a SWPPP for the entire Site that requires ongoing Qualified Professional inspections/maintenance of all
stormwater facilities. The SWPPP also provides the opportunity to provide further mitigation such as
green practices, stormwater controls and runoff reduction.
5.3-2. The “unnamed” Class “2” Stream that traverses and drains CW-1 and CW-2 has been
the source of significant property damage to 333 Spencer Rd. for the past 36 years. On four
occasions, from 1980 until 2000, the stream flow exceeded the capacity of the existing
culverts.
Response: See Response to Comment No. 5.3-1.
5.3-3. The Planning & Development Board should require, as a condition to be fulfilled prior to
the approval of the subdivision, that the applicant install adequate and acceptable
stormwater management systems in accordance with municipal standards, as allowed
under NY GCT Law §33(2)(c). As an alternative to the requirement of the installation of
adequate and acceptable stormwater management systems, prior to Planning and
Development Board approval, a performance bond or other security sufficient to cover
the full cost of the same, as estimated by the Planning & Development Board or department
designated by the Planning & Development Board shall be furnished to the City of Ithaca
by the applicant, as allowed under NY GCT Law §33(8)(a).
Response: The Commenter references NY GCT Law §33 which pertains only to Subdivisions. The Project
does not include a Subdivision action. However, the Project will follow all City and Town development
regulations as part of the site plan review process for individual projects within the CWD. The Project
Sponsor will implement an “adequate and acceptable” stormwater management system in accordance
with the current the NYSDEC Stormwater Management Design Manual at the time of submission of
each site plan application for each individual phase of the CWD. Even though performance bonding is
not required, the associated NYSDEC SPDES permit requires implementation. The SPDES permit has
adequate enforcement measures as outlined in the NYSDEC SPDES General Permit for Stormwater
Discharges (GP-0-15-002). Inspection and maintenance is required by the SPDES General Construction
Permit.
5.3-4. Limit the amount of land cleared at one time due to steep slope and potential for erosion
and stormwater runoff during construction.
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Response: The NYSDEC SPDES General Construction Permit (GP-0-15-002) limits disturbance areas
to less than five acres at any time unless prior approval from the City and/or Town which can require
additional mitigation and inspections by a Qualified Professional (Part II.C.3) if the disturbance exceeds
five acres and requires additional levels of engineering review.
5.3-5. I have lived at 411 Spencer Road for 22 years, and experience a flood of water a score of
years ago. My side yards, the basement, my neighbor’s home looked like Buttermilk Falls.
Being that Stone Quarry Road is in my backyard and the Chain Works is up and beyond, I
have always wondered where the water came from.
Response: The generic SWPPP outlined in the DGEIS provides tributary mapping. See Response to
Comment No. 5.3-3.
5.3-6. Do significant precipitation events which occur during Phase I activities such as excavation,
filling, compacting, have the potential to change Site hydrology/hydrogeology?
Response: Yes. That is the rationale for the development of a Full SWPPP for the Site in accordance
with the SPDES General Construction Permit (GP-0-15-002) and the NYS Stormwater Design Manual.
5.3-7. Stormwater Infrastructure Stormwater from the new development at area CW-2 is shown
to run through POS E (full description in Appendix E). Given the topology of the site, the
new building runoff would drain directly to the existing railroad bed, thereby bypassing
POS E. The developer will need to submit a grading plan showing the method used to get
runoff to POS E.
Response: Acknowledged. The Project Sponsor will be required to submit a detailed grading plan as
part of the site plan review process for individual projects within the CWD.
5.3-8. The way the DGEIS is written seems to imply that the proposed methods will reduce the
water quantity coming off of a parking lot via a green roof, which is counterintuitive and
inaccurate. Overall, the proposed water quantity and quality methods will need further
review when the full SWPPP is done for this project.
Response: Runoff reduction techniques as outlined in Chapter 3 of the NYS Stormwater Management
Design Manual examines impervious surfaces as a whole within a drainage subarea that includes
both building and pavement areas. Runoff Reduction manages the impacts by using natural features
and practices to slow down the runoff, promote infiltration and evapotranspiration, and consequently
minimizes the need for the structural “end-of-pipe” practices. Mitigation will utilize multiple stormwater
mitigation measures in accordance with NYS and City/Town regulations. Final design of the stormwater
quality/quantity mitigation will be addressed during the site plan review process for individual projects
within the CWD to ensure mitigation of post-development impacts to the pre-development condition.
5.3-9. Finally, we recommend that the FGEIS include Ongoing Project Site Maintenance of
impacts originating from the CWD such as storm water impacts and trash.
Response: This is a requirement of the NYSDEC SPDES General Construction Permit (GP-0-15-002)
and is a typical site plan approval condition. Part VII.L of GP-0-15-002 requires the Property Owner to, at
all times, “properly operate and maintain all facilities and systems of treatment and control (and related
appurtenances) which are installed or used by the owner or operator to achieve compliance with the
conditions of this permit and with the requirements of the SWPPP.”
5.3-10. A 50’ setback is proposed from all streams. It would make more sense to base the setback
requirements and treatments on the topography. Site disturbance uphill from a streambank
will require a different mitigation than site disturbance downhill from a streambank.
Response: The DGEIS takes a conservative approach by requiring 50 foot stream setbacks for both the
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downhill and the uphill development at CWD.
5.3-11. Existing water resources should be more closely evaluated for each phase of the project.
Particularly for the presence of wetlands and perched water tables.
Response: The Site as a whole has been examined for wetlands with none found within the developable
areas. Nonetheless, during the site plan review process for individual projects within the CWD existing
conditions within the individual site plan areas will be reexamined to identify and include wetlands
and/or perched water tables.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.4 (Vegetation & Fauna):
5.4-1. Overall, the biological study appears to be complete and the proposed mitigation for areas
with the most tree removal appears to be adequate.
Response: Acknowledged.
5.4-2. The impact to the native deer population is understated.
Response: The Final Scope did not include an analysis of impacts to the native deer population. However,
this comment is acknowledged since any development of a greenfield will impact and displace native
species including the native deer populations. This impact will be adequately mitigated by retaining
significant portions of the Site in a native state including the 23.9 acre CW1 Sub Area.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.5 (Public Health and Environment):
5.5-1. The Site has been a significant environmental issue for decades and I have no confidence
it will get remediated prior to redevelopment.
Response: The Property has a long industrial history that has left an environmental legacy of significant
contamination at the Site. As outlined below, Emerson, the party responsible for remediating the Site,
has been working with the NYSDEC since contamination was first discovered at the Site in 1987:
• 1983 – Emerson purchases the Property
• 1987 – Emerson discovers contamination in the area of the fire water reservoir and reports the
contamination to the NYSDEC
• 1988 – Emerson enters into a consent order with the NYSDEC to investigate and remediate the
Property under the IHWDS Registry program
• 1990 – Initial RI completed for firewater reservoir area
• 1991 – A pump and treat system is installed for fire water reservoir area to extract and treat
groundwater/contaminants
• 1992 – Firewater reservoir is rehabilitated and put back into service
• 1994 – Initial NYSDEC ROD is issued
• 1996 – Firewater reservoir area pump & treat system is upgraded to Dual Phase Vapor Extraction
(DPVE) to increase the extraction of groundwater/contaminants
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• 2008 – Supplemental RI is completed for the Property under an industrial use scenario
• 2009 – ROD is issued based on 2008 Supplemental RI; includes requirement to upgrade the
groundwater extraction system at the fire water reservoir
• 2009 and 2015 – Enhancements are made to the extraction system
• 2010 – Emerson ceases operations and vacates the premises except for security
• 2017 – Emerson submits a final Phase II Supplemental RI, and a draft IRM Work Plan for the
NYSDEC approval.
• 2018 - Emerson submits a petition to modify the area of the site subject to IHWDS Registry
requirements for the NYSDEC approval. The NYSDEC approves the Phase II Supplimental RI
and IRM work Plan. The IRMs are anticipated to commence Fall 2018.
Despite the enhancements and the progress made in removing VOCs from groundwater and vapor
outlined above, the Property’s complex geology have added to the scope and duration of remediation
and mitigation efforts. Any remediation of impacts to groundwater in fractured bedrock, such as what
exists at the Site, has and will require long-term management and monitoring by Emerson. According
to the Project Sponsor’s consultant, this is due to a process known as “back-diffusion.” Contaminants
in contact with the bedrock diffuse into the rock matrix over years and decades. The contaminants will
slowly diffuse from the rock back into the groundwater over time. The DPVE system will continue to
remove contaminants from the subsurface as the contaminants diffuse out of the bedrock.
In addition, the science of investigation and remediation has evolved significantly since the 1980s and,
as indicated above, the remedial work at the site has been upgraded over time to incorporate such
advances to allow for more effective remediation in the future. Specifically, the remediation of the fire
water reservoir area was initially conducted via a groundwater pump and treat system. Per the Project
Sponsor’s consultant, this type of system utilizes groundwater extraction and treatment of the water only.
In 1996, the system was modified/upgraded into a DPVE system. The Project Sponsor’s consultant has
explained that DPVE is a process where soil vapor and groundwater are simultaneously removed. The
removal of the groundwater depresses the groundwater table and exposes impacted areas such that
those areas can be susceptible to volatilization with air. Since soil vapor can be extracted at a more
rapid rate, the vapor phase can remove contaminants quicker than the water phase. Thus, removal
and treatment of both soil vapor and groundwater increases the overall contaminant removal. The 2009
and 2015 upgrades to the extraction system were designed based on Emerson’s investigation activities
completed between 2009 and 2011. The investigations focused on identifying the presence or absence
of dense non-aqueous phase liquid (DNAPL) or residual source material in groundwater immediately
south and east of the Firewater Reservoir. The results of the investigations showed no evidence of
DNAPL or residual source material in groundwater at these locations. The highest VOC concentrations
in groundwater were found to occur approximately 18 ft. below the base of the reservoir within two
bedding plane fractures identified at 550 and 544 ft. above mean sea level (amsl). These fractures,
as well as a deeper bedding plane fracture at 515 ft. amsl, were noted by Emerson’s consultant as
the primary migration pathways for affected groundwater at the fire water reservoir. The objectives of
the system modifications were: (1) intercept impacted groundwater within the horizontal bedding plane
fractures in the C-zone between 550 ft., 544 ft., and 515 ft. amsl to the south and east of the fire water
reservoir; and (2) extract both aqueous- and vapor-phases for treatment. Specifically, the treatment
system modifications included:
1. Installation of a new extraction well (EW-9R-72C) to target extraction of impacted groundwater
and vapor from the bedding plane at 515 ft. amsl.
2. Conversion of existing monitoring well MW-14C to an extraction well in order to target the
bedding planes at 550 and 544 ft. amsl.
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3.Conversion of existing monitoring well EXB-2 to an extraction well in order to target the bedding
planes at 550 and 544 ft. amsl.
See Supplemental Pre-Design Investigation Firewater Reservoir, June 30, 2011 in Appendix E1 of
the FGEIS.
Data indicates that a substantial amount of VOCs have been removed from the subsurface by the
extraction system. Emerson calculates that the extraction system has removed over 125-pounds of
VOCs from groundwater and 2,101-pounds of VOCs from vapor between January 2009 and December
2014, before the system was most recently upgraded in the summer of 2015. Monthly operation and
maintenance as well as system monitoring have also occurred throughout the years to ensure that the
extraction system continues operating properly.
Moreover, Emerson continues to address areas identified in the 2009 ROD Amendment, which include
addressing the AOC to the west of the former ‘507 Degreaser’ area in Building 4 (also known as AOC
1)and removal of NAPL. In August 2016, WSP on behalf of Emerson completed a Supplemental Pre-
Design Investigation that summarized additional investigation activities to further assess VOC impacts in
the area of AOC 1. See WSP’s Revised AOC 1 Characterization Report dated August 2016 in Appendix
E7 of the FGEIS. Specifically, the following investigations/findings were summarized in the report:
• Borehole geophysical surveys were completed on three (3) monitoring wells (MW-24B, MW-25B
and MW-26B) in order to identify potential open fractures zones where groundwater flows.
Borehole geophysics utilizes a number of different instruments in order to assess the potential for
fractures that may convey water (and thus contaminants) which include: 3-arm caliper (measuring
of borehole width), temperature and conductivity probes (measuring differences to identify
groundwater flow), video (in order to visually assess the borehole and fractures, etc. the borehole
geophysics concluded that two of the monitoring wells (MW-25B and MW-26B) indicated an
upward migration of groundwater. Upward vertical flow of groundwater typically limits the ability
of contaminants to migrate deeper into the saturated zone.
•Soil sampling – A total of 27 surficial soil samples were collected from borings to the west of
building 4. Ten of the 27 surficial soil samples identified Site-related VOCs above the NYSDEC
Part 375-6 Protection of Groundwater SCOs and six of these also contained concentrations
above the NYSDEC Part 375-6 Restricted Residential SCOs. In addition, 34 subsurface soil
samples were also collected; however, only four of the samples identified VOCs at concentrations
above the NYSDEC Part 375-6 Protection of Groundwater SCOs.
•The investigation also included an assessment of bedrock aquifer characteristics. Specifically, the
slug tests were completed on four wells in order to assess the hydraulic conductivity for
groundwater in the area. WSP concluded that overburden groundwater (A-zone) is in
communication with the uppermost bedrock groundwater (B-Zone) and that the retaining wall
to the west acts as a boundary to lateral migration. Groundwater in the overburden and B-Zone
discharge to a seep and groundwater sump that manage discharges behind the retaining wall.
• WSP concluded that the vertical delineation of VOCs was complete.
In addition to the above, WSP, on behalf of Emerson, has been monitoring and removing NAPL (‘free oil
product’) from monitoring wells where it has been identified.
While these activities by Emerson show a continued commitment to remediate the Property, the Lead
Agency expects that the Project will have a significantly beneficial impact on the pace of remediation,
which is already evidenced by Emerson’s submission to the NYSDEC of a Phase II Supplemental
RI Report and a draft IRM Work Plan in July 2017 which has now been revised and approved by the
NYSDEC in August 2018 after a public comment period. The remediation was initially being conducted
with a goal of continued industrial use at the Property. During the first phases of investigation and interim
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remediation, the Property was an active industrial site with remediation goals to match the continued use
(e.g., one task of the remediation in the 1990s was to get the fire water reservoir repaired and placed
back into service). After Emerson ceased operations in 2010, the objective of the remediation changed
to make the Property suitable for another industrial use. With the Project Sponsor’s involvement, the
Project has become a catalyst for a re-assessment of the entire Site. The Project Sponsor has informed
the Lead Agency that its contractual arrangement requires Emerson to be responsible for remediation
of contamination that is known or discovered before remediation is deemed complete at the Site unless
such contamination is caused by a release after transfer of ownership to the Project Sponsor. The
Project Sponsor shall also be responsible for any contamination that existed prior to it taking ownership
of the Site but not discovered until after Emerson’s remedial actions at the Site are deemed complete by
the NYSDEC . Therefore, the Project Sponsor is very motivated to find contamination at the Site before
taking ownership.
The Project Sponsor’s motivation is demonstrated, in part, by the LaBella Phase I and Phase II ESAs
performed on behalf of the Project Sponsor that identified a number of additional AOCs at the Site.
Because these AOCs required further delineation of their nature and the extent of impacts before the need
for and type of remediation can be determined by the NYSDEC, Emerson performed additional testing at
the Site to complete the needed delineation of the various AOCs. That investigation is presented in the
Phase II Supplemental RI Report found in Appendix E7 of the FGEIS.
Emerson has also submitted and the NYSDEC has approved, following a pubic comment period
and revisions, an IRM Work Plan to address soil and sediment contamination and sanitary sewers at
specified locations on the Site. The primary goal of the IRM Work Plan is to remediate all soil and
sediment within AOCs delineated in the Phase II Supplemental RI and the previously known AOC
referred to as the Former Department 507 Degreaser Area or AOC 1 to meet applicable SCOs
consistent with the proposed redevelopment plans that because none of the ditches with impacts
constitute aquatic habitat the NYSDEC determined that SCOs will apply to ditch sediments. In addition,
the sanitary sewer network within the Site has been addressed through removal of residual liquids and
solids from designated manholes and the trench drain. Emerson also plans to evaluate pipe
integrity and investigate soil conditions beneath certain sections of the sewer pipe. The approved IRM
Work Plan is provided in Appendix E6 of the FGEIS and more details about the IRMs are presented in
PH Comment Summary Response No. 3.
In addition, Emerson has performed a Boundary Reassessment Study (consisting of several investigations)
to confirm that there are no impacts within the southern portion of the Site that require remedial action.
As a result of that study, Emerson petitioned the NYSDEC March 5, 2018 to modify the area of the
Site subject to its Consent Order with the NYSDEC, the ROD Amendment and the IHWDS Registry
by removing 36.76 acres of undeveloped land on the south portion of the Site from the scope of those
instruments. As part of the petition, Emerson, with cooperation from the Project Sponsor, proposes a
Declaration of Covenants and Restrictions be placed on the relevant tax map parcels that requires the
potential for SVI be addressed with appropriate engineering controls approved by the NYSDEC and
the NYSDOH when any habitable structures are proposed wholly or partially within an eighty feet wide
area where existing sewer lines serving Ithaca College and the former NCR site run through that south
portion of the Site or when any sewer laterals are to connect to those same sewers. The potential for SVI
may exist because of contamination that migrated or may be migrating along those sewer lines from the
adjoining parcels. The petition may be found in Appendix E2 of the FGEIS.
The Lead Agency notes that the Project Sponsor is motivated to see the Site remediated in a
manner that allows its reuse consistent with the Project Sponsor’s plans. The Project Sponsor has
informed the Lead Agency that Emerson has committed to conduct any necessary remedial actions in a
timely, diligent manner. As such, while this Site has been the subject of on-going investigations and
remediation for almost 30 years, the Project will facilitate more stringent remedies on a much more
aggressive timeline than what has occurred historically and the Site will be appropriately remediated in
conjunction with the Project.
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5.5-2. This is a very heavily contaminated Site which poses a real threat to the community.
Response: The information in the DGEIS indicates that there is a significant amount of contamination
at the Site as evidenced by the fact that the Property is listed as a Class 2 site on the State of New York
IHWDS Registry, meaning the Property is one at which contamination constitutes a significant threat to
public health or the environment. However, as noted in PH Comment Summary Response No. 1 above,
the Project has been a catalyst for additional RI at the Site, which has located additional impacts, and will
facilitate more stringent remedies at the Site on a much more aggressive timeline than what has occurred
historically.
5.5-3. The DGEIS is not specific enough about what remedy will be used to remediate the Site.
Response: Remedial options that may be selected for the Site are discussed in Subsections 5.5.1.19
and 5.5.2 of the DGEIS. However, all the remedies that will be used to remediate the Site will not be
known until the NYSDEC completes the ROD Amendment Process. By letter dated August 22, 2018,
the NYSDEC approved an IRM Work Plan to address soils and sediments in 16 of the AOCs at the Site.
The remaining AOCs will be addressed by remedies examined through the feasibility study process.
The IRM Work Plan underwent public review, comment, and several revisions prior to the NYSDEC
approval. The Lead Agency understands that because the IRMs selected can serve as a final remedy for
the impacts they are inteded to address, the IRMs will most likely be part of final remedies selected in
the ROD amendment process. The Project Sponsor has correctly pointed out during the GEIS process
that the remedy selection is subject to the exclusive jurisdiction of the NYSDEC. See Town of Moreau
v. N.Y. State Dep’t of Envtl. Conservation, 178 Misc. 2d 56 (Sup. Ct. Albany County, 1998) (“To permit a
local municipality through its municipal code to prevent this kind of NYSDEC -approved site remediation
is, in the court’s view, a violation of the delegation to the NYSDEC by the Legislature of the authority
to oversee and control such sites and ‘to contain, alleviate or end the threat to life or health or to the
environment.’ Such a restriction would place unreasonable restraints on the NYSDEC in its overriding
obligation to preserve and protect both human health and the environment.”) See also, the NYSDEC
Division of Environmental Remediation Proposed Part 376 Response to Comments, p. B47 (June 2006)
(“The [NYSDEC] is mindful that it is the unmistakable legislative intent to preempt entirely local control
over remedial programs conducted pursuant to [State Superfund]. It could not have been the legislative
intent to create such a comprehensive administrative scheme to address contaminated sites and yet allow
a dissenting municipality to delay or completely frustrate the execution of the scheme by withholding a
permit”).
As stated in Sections 5.5.1.19 and 5.5.2 of the DGEIS, the remedies that the NYSDEC will choose will
be based on the types of media located throughout the Site. For contaminated soils, the remedies
will be based on the SCOs set forth under 6 NYCRR § 375-6.8(b) and will depend on the anticipated
uses of a particular area of the Site (i.e., residential, commercial, or industrial). For those areas where
residential uses are proposed, the Restricted Residential SCOs will be used as the basis for selecting
the appropriate remedial action by the NYSDEC. For areas of commercial use and industrial use, the
Commercial and Industrial SCOs will be considered by the NYSDEC, respectively. Different SCOs
between different areas of the Site may be used so long as such areas are defined and described in the
environmental easement to be applied to the Site. All necessary institutional and engineering controls
will be implemented, maintained, monitored, and enforced through a site management plan (SMP). See
6 NYCRR § 375-2.8(c)(3). The SMP will also set forth regular reporting requirements to the NYSDEC
following remediation of the Site.
Remedies to protect and control groundwater will also be dictated by the amended ROD. The Lead
Agency understands that generally, such measures will involve: (1) removal or control of any areas
deemed sources of groundwater contamination, e.g., excavation or in situ remediation of soils with
contamination above protection of groundwater standards (protection of groundwater SCO) (see PH
Comment Summary Response No. 5 for more details); (2) to the extent feasible, restore groundwater to
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groundwater quality standards; and (3) to the extent feasible prevent further migration of any groundwater
plumes off-Site. These requirements are set forth in 6 NYCRR §§ 375-1.8(d). The Project Sponsor
has informed the Lead Agency that based upon the results of the environmental investigations to date,
in addition to the removal of soils exceeding the Protection of Groundwater SCOs via the approved
IRM, Emerson is considering the following groundwater remediation technologies and expects to further
analyze the usefulness and feasibility of these technologies in an upcoming remedial feasibility study for
the NYSDEC:
1.groundwater extraction and ion exchange treatment to possibly address barium;
2.expanding the number of extraction wells tied to the existing groundwater treatment system
associated with the firewater reservoir to address CVOCs at Site locations;
3.in-situ treatment, such as chemical oxidation, to treat CVOCs;
4.in-situ chemical oxidation to address cyanide in groundwater;
5.in-situ treatment to address petroleum/NAPL; and
6.monitoring.
Other technologies may also be considered by Emerson in the feasibility study and presented to the
NYSDEC.
SVI will be addressed through management of the contamination to prevent exposure, e.g., implementation
of SVI systems. More details on the methods most likely to be used at the Site are set forth in PH Comment
Summary Response No. 18. Impacted sediments in on-Site creeks or ditches will be addressed in a
manner similar to soils, most likely excavation. Additionally, institutional and engineering controls will be
implemented through an environmental easement, regardless of what specific remedies are selected by
the NYSDEC.
As first discussed in PH Comment Summary Response No. 1, Emerson submitted a draft IRM Work Plan
to the NYSDEC in July 2017 to address soil and sediment contamination and sanitary sewers at specified
locations on the Site. Following a public comment period and several revisions, the NYSDEC approved
the IRM Work Plan dated August 8, 2018, by letter dated August 22, 2018. From the Lead Agency’s
review of the IRM Work Plan, it understands that a primary goal of the IRM Work Plan is to remediate all
soil and sediment within 16 AOCs delineated at the Site to the SCO applicable to the anticipated future
use of that area of the Site or, in some cases where the AOC is deemed to be a source of contamination
in groundwater, the Protection of Groundwater SCO. Below is a Table reproduced from the IRM Work
Plan that summarizes the AOCs proposed for an IRM and the applicable SCO.
The selected remedial action for all of the above AOCs but AOC 1 entails excavation and off-Site disposal
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Table3-1Summary of Soil AOCs and Interim RemedialMeasures IRM Work PlanFormer Emerson Power Transmission FacilityIthaca, New York (a)AOCAOC Description/Sub-AreaContaminant(s) (b)Affected MediaSCO Driver (c)Anticipated FutureLand Use (d)Anticipated Final Cover (e)Demarcation Barrier?IRM RemedyEstimated Excavation (CY) or Cap/Cover (SF) Restricted Residential/Mixed Use Area (d)1Former Department 507 Degreaser (exterior)CVOCsSoil, Groundwater Protection of GroundwaterRestricted ResidentialAsphaltYes1. Excavate to 3 feet and dispose of CVOC soil offsite.2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Install cap consisting of clean soil backfill, geosynthetic clay liner, and asphalt1301,200 SF capBuilding 24 Interior (second floor) CVOCsSoil, Groundwater Protection of GroundwaterRestricted ResidentialConcreteNo1. Excavate to bedrock and dispose of CVOC soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore concrete floor30Building 24 Exterior (parking lot) CVOCsSoil, Groundwater Protection of GroundwaterRestricted ResidentialAsphaltNo1. Excavate to bedrock and dispose of CVOC soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore asphalt pavement77027 Former Salt BathsMetals (Ba)Soil/Bedrock/GroundwaterRestricted Residential Use Restricted ResidentialTo be Determined (green space or plaza area) (f)No1. Excavate loose or fragmented bedrock (~2 feet) and dispose of material offsite2. Backfill with clean soil and cover with gravel (future grass by others)8031Upper Parking Lot 6Metals (As, Ba, Cd, Cr, Cu, Ni)SoilRestricted Residential Use Restricted ResidentialAsphalt/GrassYes1. Excavate to 2 feet and dispose of metals soils offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass20Former Spray Pond AreaPAHs, PCBs, and Metals (As, Ba, Pb, Hg)SoilRestricted Residential Use Restricted ResidentialAsphalt/GrassYes1. Excavate to 2 feet and dispose of PAH, PCB, and metals soil offsite 2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass950Former Spray Pond Area/Drainage DitchPAHs and MetalsDrainage Ditch Soil Restricted Residential Use Restricted ResidentialRiprap/GravelNo1. Excavate to 2 feet and dispose of PAH and metals soil offsite2. Backfill with clean soil and restore ditch lining50CVOCsSoilProtection of GroundwaterRestricted ResidentialPossible (g)1. Excavate CVOC soil that exceeds PoG SCO and dispose of soil offsite2. Collect confirmation samples of base and sidewalls (unless bedrock is encountered) and excavate additional soilif necessary3. Backfill with clean soil and restore asphalt/grass/gravel210PAHs SoilRestricted Residential Use Restricted ResidentialPossible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass or gravel35AEast of Building 24 (SB-103/SB-103SS)Metals (As)SoilRestricted Residential Use Restricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of arsenic soil offsite2. Backfill with clean soil and restore grass70CVOCsSoil/GroundwaterProtection of GroundwaterRestricted ResidentialNo1. Excavate to bedrock and dispose of CVOC soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and cover with gravel (future grass by others)140PAHsSoilRestricted Residential Use Restricted ResidentialPossible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and cover with gravel (future grass by others)35D Near Parking Lot 4 (SS-100)PAHsSoilRestricted Residential Use Restricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Backfill with clean soil and restore grass3035GSouth of Parking Lot 3 (LBA-B17-TSS-3)Metals (Ba)SoilRestricted Residential Use Restricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of barium soil offsite2. Collect confirmation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass4035HParking Lot 3 (LBA-TP-03)PAHsSoilRestricted Residential Use Restricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass6035KFormer Railway Right-of-Way (SB-240)Metals (As)SoilRestricted Residential Use Restricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of arsenic soil offsite2. Backfill with clean soil and restore grass4035LFormer Railway Right-of-Way (DS-1)PAHsSoilRestricted Residential Use Restricted ResidentialSoil (Grass)Possible (g)1. Excavate to 2 feet and dispose of PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Backfill with clean soil and restore grass and ditch lining110Commercial Use Area28 Oil Shed Area - NortheastCVOCsSoil/GroundwaterProtection of GroundwaterCommercialAsphaltPossible (g)1. Excavate CVOC soil that exceeds PoG SCO and dispose of soil offsite2. Collect confirmation and documentation samples of base and sidewalls (unless bedrock is encountered)3. Backfill with clean soil and restore grass (future paving by others)50029Former Propane Aboveground Storage Tank AreaPAHsSoilCommercial UseCommercialAsphaltYes1. Excavate to 2 feet and dispose of the PAH soil offsite2. Collect confirmation and documentation samples and excavate additional soil if necessary3. Place and compact 2 feet of soil cover to the approximate original grade and restore grass (future paving by others)1150Industrial Use Area30 Rice Paddy AreaPAHsSoilIndustrial UseIndustrialSoil (Grass)Yes1. Excavate to 1 foot and disposal of PAH soil offsite2. Excavate PCB hotspots at depths indicated on IRM drawings.3. Collect confirmation and documentation samples and excavate additional soil if necessary4. Backfill with clean soil and restore grass170a\ AOC = area of concern; IRM = Interim Remedial Measure; SCO = soil cleanup objective; CVOC = chlorinated volatile organic compound; PAH = polycyclic aromatic hydrocarbon; PCBs = polychlorinated biphenyls; CY = cubic yard; SF = square feet; NA = not applicable.b\ The contaminants include the constituents that are the primary drivers of the need for interim remedial measures; they do not include constituents present at concentrations minimally above the SCOs.c\ SCO source: Table 375-6.8(b), Title 6 New York Codes, Rules and Regulations Part 375, Subpart 375-6.d\ The term Restricted Residential/Mixed Use is defined as including one or more of the following: apartments and multi-family residences, offices, commercial endeavors, recreational areas, and green space. Restricted Residential Use SCOs are applicable in these areas.e\ The anticipated final cover is based on the current layout for redevelopment.f\ The current layout for the redevelopment plan indicates that the former salt baths area (Building 14) will be removed and used for green space or plaza area serving as an entry point for mixed use. The remaining portions of the AOC will be for industrial, warehouse, or storage uses.g/ A demaracation barrier will be installed only in areas where bedrock is not encountered after excavation to the prescribed detph.Asphalt/GrassTo be Determined 35C263234 Area East of Buildings 13A and 14Building 11A (LBA-SB-250)WSPK:\EMERSON\Ithaca - 4507\IRM Work Plan\IRM Work Plan - August 2018 Submittal\Table\Table 3-1_080818Page 1 of 1Revised: 8/8/2018FGEIS Table 3-1: Summary of Soil AOCs and Interim Remedial Measures
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of soils or sediments above their applicable SCO followed by installing a demarcation layer, if bedrock has
not been reached, and backfilling with clean material. In the case of impacted sediments removed from
portions of drainage ditches found within AOC 32 and AOC 35L, restoring the remedial area within the
ditches will entail replacement of the contamination layer if necessary, backfilling with clean soil, placing
a geotextile lining and installing riprap along the ditch bottom and banks. The proposed remedial action
for AOC 1 is excavation and off-Site disposal of impacted soils to a depth of approximately three feet,
installation of a demarcation layer and placement of clean soils followed by installation of an engineered
low permeability clay cap and asphalt to minimize infiltration and migration of the remaining contamination.
A demarcation layer is installed if excavation has not reached bedrock before placement of the clean soil
to notify future workers in that area of the presence of the impacted soils beneath it.
The Project Sponsor has informed the Lead Agency that remedial technologies for the groundwater and
seep impacts and the potential for SVI will be considered by Emerson in the feasibility study presented
to the NYSDEC .
It should be noted that although the Lead Agency and Project Sponsor cannot identify what specific
remedies will be used at the Site until the NYSDEC amends the ROD, the purpose of a GEIS is to
assess a wide variety of impacts at a more conceptual level on a larger geographic area such as the
Site. GEISs that are prepared for larger developments at an early stage in the planning process give
agencies an opportunity to plan future courses of action to avoid or mitigate such impacts. A GEIS may
include site-specific analysis for components of a project that are well defined and establish thresholds
for impacts from project elements that are more conceptual or not yet fully developed at the time of
assessment. The Lead Agency is evaluating a number of mitigation measures to ensure impacts from
environmental contamination are avoided and/or mitigated to the maximum extent practicable. The
Lead Agency will be proposing the inclusion of thresholds and/or mitigation measures to ensure that
the Site: (1) is remediated to restricted residential, commercial and/or industrial remedial objectives, as
appropriate based on the proposed uses at the Site; (2) will remediate groundwater contamination to the
extent required by applicable law; (3) will be subject to appropriate use restrictions consistent with the
proposed uses at the Site; (4) will be subject to appropriate prohibitions on the use of groundwater at
the Site without approval from the NYSDEC; (5) will be subject to development and implementation of
an appropriate SMP; and (6) will be subject to on-going monitoring that institutional and/or engineering
controls are being properly implemented and/or maintained. Therefore, the Lead Agency believes that
the discussions of remedial alternatives in the GEIS are sufficient to meet the requirements under SEQR
to allow the various agencies to make appropriate approval decisions within their jurisdictions.
5.5-4. What is the ROD Amendment process and how does it relate to the DGEIS and conceptual site
layout plan?
Response: Allowing the Site to be used for residential and commercial purposes is a fundamental
change to the existing ROD. The Lead Agency understands that this requires the NYSDEC to follow
the same process in amending the ROD as what was needed to develop the original remedy, including
citizen participation, documentation, and approvals. See, DER-2/Making Changes to Selected Remedies
(last revised April 1, 2008), p. 4. The existing data, including data generated through the Phase II
Supplemental RI, which has now been submitted by Emerson and approved by the NYSDEC, identify the
nature and extent of contamination at the Site and will be used to identify potential remedial alternatives
consistent with the proposed mixed-uses at the Site. The alternatives will be presented to the NYSDEC
and analyzed in a supplemental feasibility study.
Once Emerson submits the feasibility study, the NYSDEC will select a remedy and issue a proposed
amended ROD for public review. The NYSDEC’s regulations require the following process for public
review of the ROD amendment:
•The NYSDEC mails a notice and brief analysis of the proposed amended ROD to those on the
Site contact list, which includes sufficient information to provide a reasonable explanation of the
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proposed amended remedy, including but not limited to, a summary of the NYSDEC’s reasons for
preferring it over other remedial alternatives considered and the construction and site management
requirements of the proposed remedy. 6 NYCRR 375-2.10(c)(1).
•The NYSDEC provides the public thirty (30) days to comment on the development and
implementation of the ROD amendment, including an opportunity to submit comments at a public
meeting. 6 NYCRR 375-2.10(c)(2).
•Written and oral comments received during the comment period are summarized and made
available to the public upon issuance of the amended ROD. 6 NYCRR 375-2.10(c)(3).
After the citizen participation is closed, the NYSDEC will finalize the amended ROD, documenting:
•Location and description of the Site.
•A history of the operation of the Site.
•The current environmental and public health status of the Site.
•An enforcement history and current status of the Site.
•The specific goals and objectives of the remedy selected for the Site.
•A description and evaluation of the remedial alternatives considered.
•A summary of the basis for the NYSDEC’s decision.
•A list of the documents the NYSDEC used in its decision-making.
•A responsiveness summary. 6 NYCRR 375-2.8(e).
The final documents, notices, and fact sheets will then be made available in the document repository. 6
NYCRR 375-2.10(e).
The Project Sponsor has informed the Lead Agency that Emerson has decided to proceed with some
remedial actions as IRMs. Emerson has submitted to the NYSDEC and the NYSDEC has approved after
public comment period and revision an IRM Work Plan to remediate specific AOCs identified at the Site.
The AOCs to be addressed with the IRM Work Plan and the proposed remedial measures to be employed
are discussed in PH Comment Summary Response No. 3 and a copy of the IRM Work Plan is provided
in Appendix E6 of the FGEIS.
The Lead Agency understands an IRM to mean an activity to address both emergency and non emergency
site conditions, which can be undertaken without extensive investigation and evaluation, to prevent,
mitigate or remedy environmental damage or the consequences of environmental damage attributable to
a property. 6 NYCRR 375-1.2(a)(b). When an IRM is likely to represent the remedy or a significant portion
of the remedy for a site, the NYSDEC will require a 30 day comment period. 6 NYCRR 375-1.10(h). In
fact, the NYSDEC provided for a 45 day public comment period and held a public workshop. The Lead
Agency also understands that when an IRM has been implemented, the NYSDEC may determine, based
on Site-specific circumstances including post-implementation investigation and/or monitoring, that the
IRM satisfies the goal of the remedial program for the Property, where only continued implementation of
a SMP associated with the IRM or other engineering or institutional controls are required. In such a case,
the NYSDEC will propose no further action as the alternative for that particular AOC. 6 NYCRR 375-
2.8(d). Thus, the IRM may become part of the final remed y. Due to the IRMs selected for the specific
AOCs at this Site, the Project Sponsor anticipates that the IRMs employed will be a part of the final
remedy for this Site. Such a determination will be finalized in the ROD amendment.
The Lead Agency also understands that Emerson has petitioned the NYSDEC March 5, 2018 to modify
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the area of the Site subject to its Consent Order, the ROD Amendment and the IHWDS Registry by
removing the undeveloped land on the southern portion of the Property, approximately 36.8 acres, from
the scope of those instruments and any remedial obligations thereunder. Additional details about that
petition are set forth under PH Comment Summary Response Nos. 20 and 21. A copy of the petition may
be found in Appendix E2 of the FGEIS. The Lead Agency’s review of the petition indicates that the basis
for this revision to what constitutes the Site for remedial purposes is the fact that additional investigation
in the southern portion of the Site has not revealed impacts requiring remedial action. As a part of
Emerson’s proposal, a Declaration of Covenants and Restrictions will be placed on the tax map parcels
where the sewer lines coming from the former NCR property and Ithaca College exist. The Declaration
of Covenants and Restrictions will require that engineering controls approved by the NYSDEC and the
NYSDOH be installed to prevent SVI from those sewer systems into habitable buildings.
The Project Sponsor has informed the Lead Agency that the NYSDEC may grant the petition by following
the process set forth in the NYSDEC’s program policy DER-2 (last revised April 1, 2008) which sets forth
the process by which it makes changes to selected remedies. The NYSDEC considers redefining the
boundaries of what constitutes the Site for purposes of remediation as a change in the selected remedy.
The policy divides such changes into three categories, minor, significant and fundamental. The degree of
change dictates the procedure used to make the change. A “minor” change, which the Project Sponsor
understands to be the category the NYSDEC has placed the petition for Site boundary modification, is
defined as one with little to no impact. A “significant” change is defined as one that impacts an essential
part of the remedy. A “fundamental” change involves a new approach to the remedy or may add/subtract
significant components of the remedy. For significant changes, the NYSDEC issues an Explanation
of Significant Difference which serves as notice that a change to a remedy has been made. Formal
amendment to the ROD is not deemed necessary because the NYSDEC is not reconsidering the overall
remedy.
In terms of how the ROD relates to the GEIS and the Conceptual Site Layout Plan, the GEIS process
considers, but cannot control, the ROD amendment. Instead, the GEIS is a “hard look” for any
adverse impacts the proposed PUD/PDZ codes, Design Standards, and the Conceptual Site Layout
Plan may have under SEQR. Although this review must necessarily include an analysis of any public
health and environmental impact the potential remedies may have and how those remedies may affect
Site redevelopment and/or mitigate impacts therefrom, the GEIS is not a review of any specific ROD
amendment nor what remedies will be selected by the NYSDEC. As noted above, the public will have a
separate opportunity to comment on the ROD amendment specifically.
As discussed in Chapters 5 and 10 of the DGEIS, the way that the GEIS is analyzing potential impacts
of the types of remedies the NYSDEC may chose is reviewing typical remediation methods, engineering
controls, and institutional controls used at sites with similar contamination and site uses. If the remedy
the NYSDEC selects is one of the potential remedies analyzed in the GEIS, the ROD amendment will
have no effect on the PUD/PDZ, conceptual plan, or SEQR review because the remedy will be within
the thresholds already analyzed in the GEIS. If the NYSDEC selects a remedy or remedies that is
not one of the potential remedies analyzed in the GEIS, the Lead Agency will determine whether a
Supplemental EIS is needed to analyze any public health and environmental impact the selected remedy
may have and how those remedies may affect Site redevelopment and/or mitigate impacts therefrom. As
noted above in PH Comment Summary Response No. 3, at this point, the Lead Agency is evaluating a
number of mitigation measures to ensure impacts from environmental contamination are avoided and/
or mitigated to the maximum extent practicable. The Lead Agency will be proposing thresholds and/
or mitigation measures to ensure that the Site: (1) is remediated to restricted residential, commercial
and/or industrial remedial objectives, as appropriate based on the proposed uses at the Site; (2) will be
subject to appropriate use restrictions consistent with the proposed uses at the Site; (3) will be subject
to appropriate prohibitions on the use of groundwater at the Site without approval from the NYSDEC;
(4) will be subject to development and implementation of an appropriate SMP; and (5) will be subject to
on-going monitoring that institutional and/or engineering controls are being properly implemented and/or
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maintained.
In regards to the timing between the ROD amendment, GEIS, and the Conceptual Site Layout Plan, the
Project Sponsor has informed the Lead Agency that Emerson has committed to remediating the Site in a
manner consistent with the Project Sponsor’s Conceptual Site Layout Plan as it exists at the time of the
transfer of the Site to Project Sponsor. Because the use of the Site as described in the Conceptual Site
Layout Plan informs the remedial goals to be achieved and remedial methods to be used, conclusion of
the EIS process and approval of the Conceptual Site Layout Plan need to occur prior to or at the same
time as any ROD amendment.
5.5-5. Sources of contamination must be dug out and removed from the Site as there is no
effective way to cap the Site.
Response: The Lead Agency understands that the NYSDEC may require Emerson to dig out sources of
contamination and remove them from the Site. A “source area” or “source” of contamination is defined
by the NYSDEC regulations as:
Source area or source means a portion of a site or AOC at a site where the investigation has identified
a discrete area of soil, sediment, surface water or groundwater containing contaminants in sufficient
concentrations to migrate in that medium, or to release significant levels of contaminants to another
environmental medium, which could result in a threat to public health or the environment. A source
area typically includes, but is not limited to, a portion of a site where a substantial quantity of any of the
following are present:
1.concentrated solid or semi-solid hazardous substances;
2.NAPLs; or
3.grossly contaminated media.
6 NYCRR § 375-1.4 (au).
In addition, the Lead Agency understands that the NYSDEC established SCOs include standards for
protection of groundwater at 6 NYCRR § 375-6.8(b). If soil in an area of groundwater contamination has
the same contaminant above the Protection of Groundwater SCO as is also found in the groundwater, the
NYSDEC will typically treat that area as a source of contamination and select a remedy to best address
that source. In some instances, that may be excavation but it does not necessarily have to be. For VOCs
in soil, it may also be a technology that removes the contamination from the soil in situ such as soil vapor
extraction.
The Lead Agency understands that the Phase II Supplemental RI did not identify any grossly contaminated
soils but the following areas of soil impacts were identified to be above the Protection of Groundwater
SCO and thus may be addressed by excavation or some other method to remove the “source.”
•AOC 1 - Former Department 507 Degreaser (exterior)
•AOC 26 - Building 24 Interior (second floor) and Building 24 Exterior (parking lot)
•AOC 27 - Former Salt Baths
•AOC 28 - Oil Shed Area
•AOC 29 - Former Propane Storage Area
•AOC 30 - Rice Paddy Area
•AOC 31 - Upper Parking Lot 6
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•AOC 32 - Former Spray Pond Area
•AOC 34 - Area East of Buildings 13A and 14
•AOC 35A - East of Building 24
•AOC 35C - Building 11A (LBA-SB-250)
•AOC 35D - Near Parking Lot 4
•AOC 35G - South of Parking Lot 3
•AOC 35H - Parking Lot 3
•AOC 35K - Former Railroad Right of Way (DS-1)
•AOC 35L - Former Railroad Right of Way (SB-240)
In fact, Emerson’s approved IRM Work Plan dictates excavation and off-Site disposal of soils impacted
above the relevant SCOs for all the above AOCs, except AOC 1. For AOC 1, Emerson proposes a
combination of excavation and an engineered low permeability cap because utilities in the area prevent
excavation only. See Appendix E6 of the FGEIS.
Based upon the above, the Lead Agency will establish as a threshold that the NYSDEC require either
excavation or some in-situ remedial technology that treats the contaminants n soils in the above referenced
areas to be protective of public health and environment. For AOC 1, the Lead Agency will establish as
a threshold a combination of excavation and capping of impacted soils left behind because of utilities.
However, it should be understood that the NYSDEC will make the final decision about what remedies
will be implemented at the Site based on the Conceptual Site Layout Plan. As noted in PH Comment
Summary Response No. 5.5-3 above, the Project Sponsor has correctly pointed out that municipalities
may not require a different or more stringent remediation plan than what is selected by the NYSDEC.
Public comments about what remedy should be undertaken at the Site should be directed to the NYSDEC
during the public participation process of the ROD amendment, as noted in PH Comment Summary
Response No. 5.5-4, above.
5.5-6. The proposed development will spur needed remediation.
Response: The Lead Agency agrees with this comment. If the Project does not go forward, the Property
will continue to be remediated to an industrial use standard, and the Lead Agency has no indication that
a more aggressive remediation schedule spurred on by a motivated buyer and seller would occur. See
also PH Comment Summary Response No. 5.5-1 above
5.5-7. What is the timing of remediation in relation to Site development?
Response: The Project Sponsor has informed the Lead Agency that, based upon the results of the Phase
II Supplemental RI, Emerson has decided to proceed with conducting some remediation pursuant to the
NYSDEC approved IRM Work Plan to address impacted soils and sediments that exceed the protection
of groundwater standards and the applicable SCOs based upon the proposed use of the relevant AOC as
depicted on the Conceptual Site Layout Plan starting Fall 2018. Those areas of the Site proposed to be
addressed by an IRM are shown on Figures 3-1 through 3-7 of the IRM Work Plan found under Appendix
E6 of the FGEIS. The remedial action selected for all of these AOCs except for AOC 1 are excavation
and off-Site disposal of soils impacted above the relevant SCO. The proposed remedy for AOC 1
includes excavation down to three feet below the surface followed by placement of a demarcation layer
and clean soils then installation of a low permeability clay cap and asphalt. Complete excavation of
impacted material is not possible in this area because of the proliferation of utilities. The Lead Agency
understands
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that this work is intended to be completed prior to the future amendment of the Amended ROD.
As discussed under PH Comment Summary Response No. 5.5-4, except for IRMs, neither remediation
nor the Site development can start until the Amended ROD is further amended by the NYSDEC to
establish what remedial activities will be implemented at the Site and allow its redevelopment consistent
with the Conceptual Site Layout Plan. The Project Sponsor has informed the Lead Agency that at this
time Emerson plans to only use the IRM process for those AOCs set forth in the IRM Work Plan.
The Lead Agency understands that once the Amended ROD is further amended, a SMP will be developed
and submitted at the same time as the work plans for impacted groundwater in the areas of the Phase I
redevelopment (or shortly after work plan approvals). The IRM is anticipated to address any impacted
soils in these areas. The SMP will cover the entire Site but may be revised as specific remedial actions
at other areas of the Site are conducted. The SMP will include a soil excavation/management plan; a
groundwater management plan; Community Air Monitoring Plan (CAMP); and health and safety plan, all
of which will be implemented during remedial and/or construction activities. The SMP will also contain
operation and maintenance plans for any remedial systems in operation at the Site; and a monitoring
and reporting plan. Should capping or in-situ stabilization, as opposed to excavation, be selected by the
NYSDEC as a remedy for contaminated soils anywhere on the Site, the SMP will dictate that the capped
or stabilized areas must be inspected by a professional engineer on a regular basis and the professional
engineer and site owner will need to certify to the NYSDEC that the capped/stabilized area remains in
place. The certifications are typically provided annually. Groundwater monitoring will be required at the
Site either as part of any active remedial system or as the selected remedy. The SMP will require that all
groundwater monitoring be reported on a regular basis to the the NYSDEC . Operation and maintenance
plans for all remedial systems implemented at the Site including groundwater as well as vapor intrusion
systems, will also be part of the SMP. The SMP will also protect any occupied portions of the Site (e.g.,
Phase I) during subsequent remediation and construction. For example, as described in PH Comment
Summary Response No. 5.5-34, the Community Air Monitoring Plan will require the Project Sponsor to
monitor the air within and at the boundaries of any construction area or area where a remedial system is
being installed for VOCs and fugitive dust so that if any VOCs or fugitive dust within or at the edges of the
remediation/construction area exceed acceptable standards, all work will stop until the issue is remedied.
After the SMP is developed and land use approvals for Phase I of the redevelopment are obtained,
Emerson will begin remediating those portions of the Site not already addressed by the IRMs as soon as
practicable to allow for its reuse consistent with the Conceptual Site Layout Plan, the Order on Consent with
the NYSDEC, and its agreement with the Project Sponsor. Because the Site will be developed in phases
to allow for timely remediation and redevelopment of the Site, the schedule of the actual remediation
work and Site development will be intertwined. First, remediation will be implemented in those areas
not already addressed by the IRMs that are part of the Phase I redevelopment (i.e., Buildings 21, 24,
33 and 34, and land surrounding those buildings as designated in the Phase I Site plan submission) to
protect public health and protect and/or treat groundwater. At this time, the Project Sponsor anticipates
that the only areas within the Phase I redevelopment that might require further remedial action of the
soils following the IRMs would be those areas where demolition of a structure to allow for the proposed
redevelopment exposes impacted soils above the applicable SCO that would not be capped by asphalt
for parking or concrete for building pads such as the oil shed south of Building 34.
The Project Sponsor informed the Lead Agency that remediation of groundwater, other than by
excavation of the soils with impacts above Protection of Groundwater SCOs, will be addressed as part
of the amendment to the Amended ROD. The remedial action selected through the ROD process for
groundwater impacts in the vicinity of Building 24, including the “seep” that discharges from a pipe running
under Building 24, will be designed prior to any construction activity and implemented either prior to or
during construction. See Figure 4-1 of the Phase II Supplemental RI. Groundwater remediation selected
for the area to the south of Building 34 will also be designed prior to construction and implemented either
prior to construction or during the course of construction activity in that area. See Figure 4-3 of the Phase
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II Supplemental RI in Appendix E7. Remedial actions to prevent SVI within Buildings 21, 24, 33 and
34 (as well as other buildings with impacted or the potential for impacted indoor air) will be designed
and implemented prior to occupancy of those buildings.
Remediation and redevelopment of the remainder of the Site will follow a similar pattern, except that
Emerson will likely proceed with required remedial actions at other areas of the Site in advance of
redevelopment should the Project Sponsor not yet be ready for its next phase of the Project because
Emerson is contractually committed to the Project Sponsor to proceed with remedial efforts in a diligent
and timely manner. Any remediation of soils involving excavation that may be required will be performed
prior to construction activity commencing in that area. Because parking areas and building foundations
often serve as appropriate caps for impacted soils, the NYSDEC will review and approve the relevant
construction plans before construction begins when a cap is the selected remedy. If construction in an
area to be capped will not be proceeding for some time, the NYSDEC will likely require a “temporary” cap
be placed over the area for the interim. Any required active treatment or monitoring of groundwater not
already being conducted in a particular area shall commence prior to or during construction in that area
depending on whether Project Sponsor is in a position to commence the planned construction activity.
Any vapor intrusion systems will be designed, approved by the NYSDEC and the NYSDOH, installed and
tested prior to occupancy of any structure that may require such a system.
5.5-8. Who is responsible for Site cleanup after the Site ownership is transferred?
Response: As noted in the PH Comment Summary Response No. 1, Emerson remains responsible
under the Consent Order with the NYSDEC and the contract with Project Sponsor for remediation of the
Site after transfer of the Site to the Project Sponsor for any contamination discovered on the Site prior to
remedial actions being completed. However, if contamination comes to exist on the Site after transfer of
the Site to the Project Sponsor because of a spill or release after closing or contamination that existed
prior to transfer of the Site is discovered after Emerson’s remedial actions are deemed complete at the
Site by the NYSDEC, the Project Sponsor will be responsible for its remediation.
5.5-9. Who is responsible for off-Site remediation after property ownership is transferred?
Response: Emerson remains responsible under the Consent Order with the NYSDEC for off-Site
remediation (OU-3) and the fire water reservoir area (OU-1) after ownership of the Site is transferred to
the Project Sponsor.
5.5-10. I am concerned about off-Site impacts from the migration of Site contaminants through
groundwater, including on-going off-Site migration of pollutants remediated to use-specific
standards within the Site.
Response: Emerson will remain liable for off-Site contamination through groundwater and will remedy any
migration pursuant to the remedy selected by the NYSDEC. The method Emerson will use in addressing
groundwater migration, though, is the same regardless of whether use-specific standards are used at
the Site. Use specific standards are limited to soil and range in stringency based on the use of the Site.
Groundwater, on the other hand, is compared to the NYSDEC Part 703 Groundwater Quality Standards,
which are the same regardless of use.
If a contaminant found in groundwater is also found in soils above the NYSDEC’s protection of groundwater
standard, the NYSDEC will consider that soil to be a source area. The NYSDEC would then require
Emerson to properly remediate and eliminate any such source, regardless of the use-specific standard
otherwise relevant to the contaminated soil.
5.5-11. Depressurization systems in off-Site homes may not be effective.
Response: Existing off-Site contamination and related remedial actions are outside the scope of the
Project and therefore the GEIS. Emerson will maintain responsibility for off-Site contamination under its
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existing consent order with the NYSDEC and the NYSDEC therefore maintains oversight over all off-Site
remedial activities.
5.5-12. We should not rezone Site unless/until we know what the remedial actions are; the
remedial actions occur; and we can determine that they are effective to allow the proposed
uses or otherwise meet the degree of remediation we desire.
Response: As legislative bodies charged with rezoning decisions, the Ithaca City Council and Ithaca Town
Board have full discretion over the rezoning of the Site. However, as noted in PH Comment Summary
Response No. 5.5-3 above, the NYSDEC has exclusive authority to select appropriate remedial measures.
As such, although the City Council and the Town Board could decide to not rezone the Site until after the
remedial actions have been selected or occur, such a delay would not affect the remediation required
by the NYSDEC in a positive manner. The NYSDEC as already selected specific remedies for the Site
based on established Protection of Groundwater SCOs and for the planned residential, commercial and/
or industrial uses at the Site through approval of the IRM Work Plan. The IRMs commenced Fall 2018.
The NYSDEC’s selection of other remedies at the Site through further amendments of the Amended
ROD is likely to occur the Winter of 2018/2019. The NYSDEC will determine these remedial measures
regardless of the rezoning of the Site unless the NYSDEC has reason to believe or otherwise become
concerned that the rezoning may not occur at all, in which case remediation of the Site will most likely be
to an industrial standard as is the case currently.
In addition, the Project Sponsor has stated that delaying the rezoning until the NYSDEC further
amends the Amended ROD will jeopardize the Project, which in turn could further delay or otherwise
derail remediation of the Site or result in remediation that is limited to industrial standards. Emerson’s
commitment to remediating the Property is tied to Project Sponsor’s proposed uses at the time ownership
transfers to the Project Sponsor. The Project Sponsor has stated that it is not willing to take ownership
of the Site until it has received the necessary approvals for the Project, which includes completion of
the SEQR review for the Project, rezoning and Site plan approval of Phase I. A delay in making a
rezoning and site plan decision until remedial actions are established when such delay will not impact the
remediation required but could postpone or discourage the Project Sponsor from taking title to the Site
and begin redevelopment may not be overall beneficial to the community.
As noted above in PH Comment Summary Response No. 3, at this point, the Lead Agency is evaluating
a number of mitigation measures to ensure impacts from environmental contamination are avoided and/
or mitigated to the maximum extent practicable. This is likely to include but is not limited to inclusion of
thresholds and/or mitigation measures to ensure that the Site: (1) is remediated to restricted residential,
commercial and/or industrial remedial objectives, as appropriate based on the proposed uses at the
Site; (2) will be subject to appropriate use restrictions consistent with the proposed uses at the Site; (3)
will be subject to appropriate prohibitions on the use of groundwater at the Site without approval from
the NYSDEC; (4) will be subject to development and implementation of an appropriate SMP; and (5)
will be subject to on-going monitoring that institutional and/or engineering controls are being properly
implemented and/or maintained.
5.5-13. To protect the community and assure remediation, all development should be limited to
the existing footprint before other development takes place.
Response: The first phase of the Project entails redevelopment of four existing buildings (21, 24, 33
and 34). While subsequent phases of development will be determined as the Project proceeds, the
Project Sponsor has informed the Lead Agency that it intends to continue with redevelopment of the core
industrial buildings as its next phase of the development. However, the Project Sponsor has explained
that if remediation of the core area, to a degree that allows for its safe development and occupancy,
should take longer than suitable to allow for a successful Project, it may be necessary for the Project
Sponsor to develop clean portions of the Site while contaminated areas continue to be remediated.
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The Lead Agency also notes that Emerson has committed to the Project Sponsor to proceed with remedial
efforts to allow reuse of the Site in a timely, diligent manner. Such commitment is evident by Emerson’s
submission of an IRM Work Plan and implementing the approved IRM Work Plan in Fall 2018. The
Project Sponsor’s consultant believes that given the contamination delineated by all the investigations
and the menu of remedies likely to be applied at the Site, remedial actions in the core areas of the
Site should be implemented to the degree necessary to safely allow reuse within two to three years of
remedy selection. In addition, any source area removal required by the NYSDEC to improve significantly
the groundwater quality would receive priority. In fact, the approved IRM Work Plan implemented by
Emerson conducts source removal from the relevant AOCs by addressing those areas of soil impacts
above protection of groundwater standards.
The Lead Agency is also mindful of the fact that remediating groundwater with contamination in a fractured
bedrock setting similar to the Site and larger Property (i.e., firewater reservoir) can take many years and
even decades after the remedial system has been installed. However, so long as potential exposure to
the occupants of the Site and public at large has been addressed through the remedies selected such
as, for purposes of example only, vapor intrusion mitigation systems and capping of impacted soils, and
the groundwater system(s) are designed and constructed in a fashion that the redevelopment will not
interfere with its/their operation, redevelopment activity can occur while groundwater treatment is ongoing.
As noted above in PH Comment Summary Response No. 5.5-3, at this point, the Lead Agency is
evaluating a number of mitigation measures to ensure impacts from environmental contamination are
avoided and/or mitigated to the maximum extent practicable. This is likely to include but is not limited to
inclusion of thresholds and/or mitigation measures to ensure that the Site: (1) is remediated to restricted
residential, commercial and/or industrial remedial objectives, as appropriate based on the proposed uses
at the Site; (2) will be subject to appropriate use restrictions consistent with the proposed uses at the
Site; (3) will be subject to appropriate prohibitions on the use of groundwater at the Site without approval
from the NYSDEC; (4) will be subject to development and implementation of an appropriate SMP; and
(5) will be subject to on-going monitoring that institutional and/or engineering controls are being properly
implemented and/or maintained.
5.5-14. Less stringent cleanup standards, such as industrial, should only be considered if it is
determined that current and potential impacts from that area will not impact the areas with
more stringent cleanup standards.
Response: The Lead Agency understands that the NYSDEC is required to evaluate a number of factors
when selecting a remedy, including mobility of contamination. Per State law, a remedy or remedies
cannot be selected that is not protective, both on- and off-Site, of human health and the environment.
5.5-15. The CW4 area should be smaller to reduce the number of impacts the contamination
has on stormwater and entire watershed and so that more area will be remediated to
Restricted Residential Standards.
Response: The Commenter correctly points out that the level of remediation required by the NYSDEC
in CW4 will be less than the level of remediation at other areas of the Site because CW4 is proposed for
non-residential uses. The Project Sponsor indicates that the size and scope of the CW4 area is driven
by a desire to appropriately reuse existing industrial structures. Those buildings situated in the CW4 are
more appropriate for reuse as industrial buildings, rather than for additional residential uses. However,
because certain proposed allowed uses in the CW4 such as “warehousing” are classified as “commercial”
by the NYSDEC for purposes of applying the use based SCOs, much of the CW4 will be remediated
to the commercial use SCO instead of the less stringent industrial use SCO. Figure 3-1 found within
Appendix E7 of the FGEIS depicts which area of CW4 will be remediated to the NYSDEC ’s commercial
use SCO and which area will be cleaned up to the industrial SCO.
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Nonetheless, the Lead Agency notes that even as an industrial sub area, impacts by contamination to
stormwater runoff will be addressed through remedial actions such as capping, excavation, in-situ soil
stabilization, or other remedial alternatives for soils discussed in Sections 5.5.1.19 and 5.5.2 of the
DGEIS. A SMP, which includes a soil excavation/management plan, groundwater management plan,
CAMP and health and safety plan, will also be in place to protect the watershed from site contamination
during construction of other instances of soil disturbance. Also, as part of the SMP, monitoring and
regular reporting to the NYSDEC will be required to ensure any caps or other engineering controls
remain in place.
Additionally, the Project Sponsor indicates that the NYSDEC regulations specifically provide that an area
using commercial or industrial SCOs employ appropriate removal or engineering controls to address
migration to be protective of adjacent residential uses. 6 NYCRR § 375-6.7(c). For soil remediation in
industrial areas where impacted soils are left in place, the NYSDEC will require a cap existing of at least
one foot of clean soil or the area to be covered by buildings or pavement. Such a cap combined with
regular monitoring and reporting of the cap condition to the NYSDEC is protective of stormwater and
adjacent areas and will likely be included as a threshold.
5.5-16. Contaminated soil and groundwater must be addressed through containment strategies
and replacing downgradient water and sewer systems and trenches to ensure migration
off-Site or into municipal sewers will not continue.
Response: As detailed in the DGEIS and PH Comment Summary Response No. 1, a DPVE and treatment
system has been operating at the Site to capture and treat impacted groundwater and soil vapor from
the fire water reservoir/OU-1 area since 1996. The Project Sponsor has explained that DPVE is a
process were soil vapor and groundwater are simultaneously removed. The removal of the groundwater
depresses the groundwater table and exposes impacted areas such that those areas can be susceptible
to volatilization with air. Since soil vapor can be extracted at a more rapid rate, the vapor phase can
remove contaminants quicker than the water phase. Thus, removal and treatment of both soil vapor
and groundwater increases the overall contaminant removal. Several upgrades to this system have
been completed by Emerson over the years, including the expansion of the system in the summer of
2015 to provide further hydraulic control, i.e., containment and treatment of impacted groundwater. The
recent upgrades to the extraction system were designed based upon investigation activities completed
between 2009 and 2011. The investigations focused on identifying the presence or absence of DNAPL
or residual source material in groundwater immediately south and east of the fire water reservoir. The
results of the investigations showed no evidence of DNAPL or residual source material in groundwater
at these locations. The highest VOC concentrations in groundwater were found to occur approximately
18 ft. amsl. These fractures, as well as a deeper bedding plane fracture at 515 feet amsl, were noted
by Emerson’s consultant as the primary migration pathways for affected groundwater at the fire water
reservoir. The objectives of the system modifications were: (1) intercept impacted groundwater within
the horizontal bedding plane fractures in the C-zone between 550 feet, 544 feet, and 515 feet amsl to the
south and east of the firewater reservoir; and (2) extract both aqueous- and vapor-phases for treatment.
Specifically, the treatment system modifications included:
1.Installation of a new extraction well (EW-9R-72C) to target extraction of impacted groundwater
and vapor from the bedding plane at 515 ft. amsl.
2.Conversion of existing monitoring well MW-14C to an extraction well in order to target the
bedding planes at 550 and 544 ft. amsl.
3.Conversion of existing monitoring well EXB-2 to an extraction well in order to target the bedding
planes at 550 and 544 ft. amsl.
See Supplemental Pre-Design Investigation Firewater Reservoir, June 30, 2011 in Appendix E1 of
the FGEIS.
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Monitoring of this system is to be continued as part of the remedy in this area of the Property, which is
not part of the Site.
In addition to the dual-phase extraction and treatment system upgrades, any additional areas in which
the off-Site migration of impacted media is possible will be addressed through remedy selection. One
objective of the Phase II Supplemental RI was to assess potential off-Site migration of impacts identified in
other areas of the Site. The Phase II Supplemental RI delineated the nature and extent of contamination
in other areas of the Site and did not identify any other areas where contamination is migrating off the
Site. The investigation included on-Site sewers and discovered that some sludges within manholes
contained contaminants at concentrations that require remediation. The Lead Agency’s review of the
approved IRM Work Plan indicates that the work proposed includes removal and off-Site disposal of
residual liquids and solids from designated manholes, evaluation of pipe integrity, and investigation of
soil conditions beneath certain sections of the sewer pipe that were previously identified as potential
AOC. See IRM Work Plan under Appendix E6 of the FGEIS. It is the Lead Agency’s understanding that
the removal of residual liquids and solids from manholes as well as trench drains has already occured.
A report titled South Hill Sanitary Sewer Network Alternatives Analysis Report dated September 3, 2009
by WSP evaluated potential options to address impacts. The report concluded that excavation of a
portion of the sewer line within Turner Place and East Spencer Street should occur (approximately 300 ft.
section), the sewer line replaced and a venting system installed to address soil vapors within the bedding
materials of the sewers. The NYSDEC approved the planned action; however, it is understood that
citizen’s concerns have stalled its implementation.
5.5-17. On-site tricholorethene contamination and related vapor intrusion issues must be
addressed.
Response: The Lead Agency understands that TCE contamination is being addressed in the firewater
reservoir area through a DPVE system, which is not part of the Site. The Phase II Supplemental RI (see
Appendix E7 of the FGEIS) delineates the extent of TCE impacts on the Site. Emerson is in the process
of evaluating remedial alternatives to address contamination, including TCE, at the Site as part of a
feasibility study. As previously discussed, the NYSDEC will evaluate the data and issue an amended
ROD that will address any necessary remediation of TCE and other contaminants discovered at the Site.
5.5-18. Disclose each building’s specific vapor intrusion mitigation measure.
Response: The Lead Agency understands that the specific vapor intrusion mitigation method will depend
on the final building construction/development planned and the subsurface conditions of that building,
specifically the sub-slab ‘communication’ or ability for vapors or air to flow beneath the slab. The Lead
Agency further understands that, in general, the mitigation measures will all include radon-type systems
which essentially consist of PVC piping that extends below the floor slab where a void space is created
in order to collect/extract vapors. The piping runs to above the building roofline where a fan is placed to
create the suction beneath the floor slab and extend a pressure field or capture zone. Alarms are used
to monitor the system. All mitigation systems will be created in this general fashion. According to the
Project Sponsor’s environmental consultant, in the event that there is poor sub-slab communication, a
variation to the traditional radon-type system is to place a drain board (i.e., thin board with void space
to allow a place to collect vapors from) on top of the existing slab and pour a new concrete slab on the
drain board. This approach would be used in areas where the existing sub-surface is too ‘tight’ to allow
a comprehensive vacuum to be established. A preliminary assessment of some buildings has been
completed to evaluate the system type. Of the buildings assessed, the following is anticipated: Non-
Drain Board System – Buildings 3 (portion of building), 8, 10, 21, 24 (basement level), 33, 34; and, Drain
Board System – Buildings 3 (portion of building), 4, 6A, 24 (upper level). The Lead Agency anticipates
that it will require appropriate vapor intrusion mitigation be established at the site plan review stage.
All mitigation systems will require a design approved by the NYSDEC/NYSDOH and will include post
mitigation monitoring to confirm the efficacy of the system.
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5.5-19. What is the timeline for remedial activities listed under the No Action Alternative?
Response: The Project Sponsor has indicated that the Project cannot move forward under the No Action
Alternative and that it would not take title to the Site if the No Action Alternative was selected. As such,
any remedial activity under the No Action Alternative to remediate to industrial standards would continue
to be undertaken by Emerson pursuant to the current ROD. It is unclear what the timeline for remediation
would be without the Project.
5.5-20. Has DEC responded to the Boundary Assessment report?
Response: Since the DGEIS was issued and per the Project Sponsor, Emerson, in consultation with
the Project Sponsor, the NYSDEC, and the NYSDOH, elected to perform additional soil vapor testing at
select locations along the NCR sewer line as described in the Soil Vapor Delineation Letter Work Plan
dated June 2, 2016 and the NYSDEC letter approving the work plan with conditions dated July 5, 2016.
See FGEIS Appendix E4. The results along with the results of other investigations performed in the
south section of the Site are summarized in Emerson’s petition to modify the area of the Site subject to
its Consent Order, the ROD amendment and the IHWDS Registry by removing the undeveloped land
on the south portion of the Property, approximately 36.8 acres, from the scope of those instruments and
any remedial obligations thereunder. The purpose of the additional sampling was to better delineate
potential soil vapor impacts as one moves further from the centerline of the existing sewer. The results
are discussed below in PH Comment Summary Response No. 21. The Lead Agency’s review of the
petition indicates that the basis for Emerson’s request is the fact that additional investigation in the south
portion of the Site has not revealed impacts requiring remedial action. As a part of Emerson’s proposal,
a Declaration of Covenants and Restrictions will be placed on the tax map parcels where the sewer
lines coming from the former NCR property and Ithaca College exist. The Declaration of Covenants
and Restrictions will require that engineering controls approved by the NYSDEC and the NYSDOH be
installed to prevent SVI from those sewer systems into habitable buildings.
The Project Sponsor has informed the Lead Agency that the NYSDEC may grant the petition by following
the process set forth in the NYSDEC’s program policy DER-2, which sets forth the process by which
it makes changes to selected remedies. The NYSDEC considers redefining the boundaries of what
constitutes the Site for purposes of remediation as a change in the selected remedy. The policy divides
such changes into three categories, minor, significant and fundamental. The degree of change dictates
the procedure used to make the change. A “minor” change, which the Project Sponsor understands to
be the category the NYSDEC has placed the petition for site boundary modification, is defined as one
with little to no impact. A “fundamental” change involves a new approach to the remedy or may add/
subtract significant components of the remed y. A “significant” change is one that impacts an essential
part of the remedy. Formal amendment to the ROD is not deemed necessary because the NYSDEC is
not reconsidering the overall remedy. Concurrence from the NYSDOH is required before final approval.
5.5-21. What are the impacts from the NCR sewer line?
Response: The NCR Sewer impacts are due to an off-Site source of VOCs that originated from the South
Hill Business Park Campus. Testing has been completed numerous times as part of the investigation of
the sewer. Testing in 2007 included soil vapor testing above the sewer line in order to assess potential
migration of contamination within the sewer or along its bedding. This testing identified elevated levels of
CVOCs in the soil gas. The highest concentration of VOCs were identified slightly downgradient of where
the Ithaca College sewer connects to the NCR Sewer. See soil vapor point SV-51 on Figure 3 from WSP
March 1, 2016 Boundary Reassessment Soil Vapor Sampling Report, FGEIS Appendix E3.As shown
on this figure, 1,1,1-trichloroethane (TCA), perchloroethene (PCE) and TCE were identified in the soil
vapor sample. To further evaluate the extent of impacts, additional sampling was completed in April and
November 2015. This testing consisted of collecting additional samples in proximity to previous sampling
areas. Results of this testing indicated that concentrations of VOCs in soil gas generally reduce as
distance from the NCR sewer increases. See Figure 4 from WSP March 1, 2016 Boundary Reassessment
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Soil Vapor Sampling Report. However, due to sample SV(2)-51-12 with elevated concentrations of VOCs,
additional sampling was proposed by Emerson and was implemented in August 2016. The August 2016
testing utilized a passive soil gas sampling approach in combination with traditional soil vapor testing at
two locations in order to correlate the passive soil gas test results with the previous soil vapor testing.
The NYSDEC and the NYSDOH approved the approach and the work was implemented in August 2016.
The testing included installation of a grid of passive soil gas samplers extending up to 90 ft. from the
NCR Sewer. The highest VOC concentrations detected in the passive soil gas samplers was at location
PSG-16 which was located approximately 30 ft. from the NCR Sewer line. The line of passive soil gas
samplers extending east away from the sewer decreased with distance from the sewer until the furthest
location (PSG-13) which was non-detect. An exception to this was the northern most line of passive
soil gas samplers where the concentrations slightly increased with distance from the sewer; however,
the concentrations detected were only slightly above the minimum detection limit and were significantly
lower than the concentrations detected in PSG-16 and PSG-13. As such, the results of this additional
testing also support the premise that concentrations of VOCs decrease with distance from the sanitary
sewer. The above described investigations are presented in a Petition for Boundary Reassessment to the
NYSDEC from WSP March 5, 2018 and is included in Appendix E2 of the FGEIS.
5.5-22. Will the sidewalk shown over NCR sewer easement create health risks to users of the trail?
Response: According to the Project Sponsor’s consultant, the NCR Sewer impacts are due to an off-Site
source of VOCs and at the low concentrations seen in soil vapor in the vicinity of the sewer line, VOC
impacts are not a concern for sidewalks and other open air settings. The Project Sponsor further notes
that Emerson, the Project Sponsor, the NYSDEC, and the NYSDOH are working together to identify any
controls that may be necessary for development of Site structures within proximity of the NCR Sewer as
part of the petition to adjust the boundaries of the Site subject to IHWDS Registry program requirements.
See PH Comment Summary Response No. 5.5-20.
5.5-23. Firewater Reservoir contamination is still concerning.
Response: Contaminated groundwater from the firewater reservoir area is being contained, extracted,
and then treated through a DPVE system. This system was recently upgraded in order to increase the
capture area. The system is routinely monitored and is equipped with automated alarms. The routine
monitoring also includes quarterly groundwater monitoring of wells to confirm the efficacy of the system
in regards to capture of the groundwater within the plume area and a decreasing trend in groundwater
impacts. Emerson calculates that the extraction system has removed over 125-pounds of VOCs from
groundwater and 2,101-pounds of VOCs from vapor between January 2009 and December 2014, before
the system was most recently upgraded in the summer of 2015. Sub-slab depressurization systems (i.e.,
vapor mitigation systems) have been installed in numerous residences down-gradient of the fire water
reservoir area to mitigate potential indoor air exposure issues associated with the historical impacts from
the firewater reservoir.
Ownership and responsibility for the firewater reservoir area (OU-1) and off-Site impacts from the Property
(OU-3) shall remain with Emerson. It is not part of the Site nor the Project.
5.5-24. Off-site areas with suspected or known impacts should also be addressed.
Response: Emerson will continue to be liable for off-Site areas with suspected or known impacts under
the Consent Order, while the Project Sponsor is responsible for mitigating off-Site impacts of the Project
(e.g., impacts directly related to PUD/PDZ and/or Conceptual Site Layout Plan itself, such as viewshed
impact that requires off-Site screening).
5.5-25. Additional site testing discussed in DGEIS should be disclosed in FGEIS.
Response: The Phase II Supplemental RI, which provides the results of additional testing discussed
in the DGEIS, has been completed by Emerson and approved by the NYSDEC. A copy of Phase II
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Supplemental RI Report revised November 14, 2017 and the NYSDEC letter approving the report with
conditions dated January 12, 2018 are attached to the FGEIS as Appendix E7 and E8, respectively.
Appendix G of the FGEIS contains revisions to the Public Health and Environment Section 5.5 of the
DGEIS that incorporate the results of that investigation.
5.5-26. Has the applicant/DGEIS considered the necessity of additional voluntary soil testing
during Phase I of the redevelopment?
Response: The Project Sponsor has informed the Lead Agency that it does not intend to perform “voluntary”
soil testing during redevelopment at the Site. However, the Project Sponsor will be implementing a
NYSDEC-approved SMP. The soil excavation plan, a typical component of an SMP, will dictate the need
for any additional testing of soils that may be required during redevelopment of the Site. In addition, a
CAMP will be implemented that entails monitoring the air at the boundaries of the construction area for
VOCs and fugitive dust. When applicable standards are exceeded, the work will cease until corrective
action is taken to prevent the exceedance. In addition, the Lead Agency has reviewed the results of
the Phase II Supplemental RI and conclude that it has sufficiently delineated the nature and extent of
contamination at the Site, including impacts to soil, to allow the Lead Agency to make its required finding
under SEQR.
As noted above in PH Comment Summary Response No. 5.5-3, at this point, the Lead Agency is
evaluating a number of mitigation measures to ensure impacts from environmental contamination are
avoided and/or mitigated to the maximum extent practicable. This is likely to include but is not limited to
inclusion of thresholds and/or mitigation measures to ensure that the Site: (1) is remediated to restricted
residential, commercial and/or industrial remedial objectives, as appropriate based on the proposed uses
at the Site; (2) will be subject to appropriate use restrictions consistent with the proposed uses at the
Site; (3) will be subject to appropriate prohibitions on the use of groundwater at the Site without approval
from the NYSDEC; (4) will be subject to development and implementation of an appropriate SMP; and
(5) will be subject to on-going monitoring that institutional and/or engineering controls are being properly
implemented and/or maintained.
5.5-27. A Restrictive Declaration should be used on the Site to ensure protection of public health
before zoning changes are granted.
Response: An environmental easement is already required under the Amended ROD to: (a) limit the
use and development of the Property to industrial use (it is anticipated that the ROD amendment will
amend this requirement so that residential, commercial, and industrial uses are allowed at the Site); (b)
comply with an approved SMP; (c) restrict the use of groundwater as a source of potable or process water
without necessary water quality treatment as determined by the NYSDOH; and (d) require the property
owner to complete and submit to the Department a periodic certification of institutional and engineering
controls. Elements (b) through (d) of the environmental easement described above are not expected to
change with the ROD amendment, but the content of the SMP of course will.
It should be noted that although the City and the Town are allowed to place reasonable restrictive
covenants on the Site as a condition to a rezoning, municipalities are preempted from holding
environmental easements. Environmental Conservation Law § 71-3605(7). The Lead Agency believes
that the remedial actions selected by the NYSDEC for the Site through the ROD Amendment process,
along with the existing Consent Order and contractual commitments of Emerson to remediate the Site
to allow development of the Conceptual Site Layout Plan, and the environmental easement held by the
NYSDEC to hold the Project Sponsor accountable for its on-Site activities will be sufficiently protective of
human health and environment.
5.5-28. How were bedding fracture zone boundaries identified?
Response: According to the Project Sponsor’s environmental consultant, bedding planes and fractures
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have been defined in a number of ways. Numerous bedrock wells have been installed since 1987 and
rock cores have been obtained from a majority of the wells to assess the rock type and fractures (over
100 bedrock wells and associated rock cores have been installed/assessed). See WSP Supplemental
RI Report dated April 4, 2008, attached as Appendix G2 of the DGEIS. Additionally, in July 2005 a
Geophysical Survey consisting of Electrical Resistivity imaging was completed to assess potential water-
bearing zones in the bedrock (documented in the Geophysical Survey Investigation Report dated October
31, 2005 by ESC and a Supplemental Geophysical Survey Report dated November 27, 2006 by WSP.
Both of these reports have been added to Appendix E9 of the FGEIS). Electrical Resistivity imaging is
a tool used to remotely image the subsurface by installing electrodes in a survey line and applying a
measured current. The voltage across electrodes is measured and the voltage/current ratio is used to
evaluate resistance. This imaging identifies high and low resistivity zones which were then assessed
through exploratory borings. The exploratory borings were advanced via rotary drilling equipment and
including coring of bedrock and retrieving the bedrock cores to assess bedding planes and fractures.
This large data set has been utilized in identifying the geology and hydrogeology of the Site.
The Lead Agency notes, as explained above, that ultimately it is for the NYSDEC to evaluate this data
and take such information into account in establishing appropriate remedial measures in the amended
ROD.
5.5-29. Clarify the “resampling” process of the B-18 seep.
Response: According to the Project Sponsor’s environmental consultant, the Phase II ESA included
sampling of two seeps from the basement of Building 18. The seeps are essentially locations where
groundwater is infiltrating the basement. Emerson later re-sampled one of the seeps, which identified
TCE. The original sample from the Phase II ESA and re-sample by Emerson (which LaBella observed)
were collected by simply placing the appropriate laboratory supplied bottles (40-milliliter glass vials
with hydrochloric acid as a preservative) beneath the seep and allowing the bottles to fill with zero
headspace (i.e., no air bubbles). The bottles were then placed on ice and shipped to the laboratory for
analytical testing. The results indicated no chlorinated VOCs above groundwater standards. See Phase
II Supplemental RI Report dated July 2017, included with the FGEIS Appendix E7.
5.5-30. BI8-SEEP-1 and BI8-SEEP-2 should be investigated further to characterize the depth and
breadth of the seep contamination.
Response: Further investigation of B18-SEEP-1, B18-SEEP-2 and the Building 24 seep was completed
as part of the Phase II Supplemental RI, which was approved by the NYSDEC with conditions by
letter dated January 12, 2018. Concentrations of targeted compounds (including those which were
previously identified above groundwater standards) were not identified above their respective NYSDEC
groundwater standards in samples B18-SEEP-1 and B18-SEEP-2. TCE was detected above the
NYSDEC groundwater standard of five micrograms per liter (ug/L) in the sample from the Building 24
seep, which is actually discharge from a pipe. The TCE concentration in water from the Building 24 pipe
was detected at a concentration of 40.7 ug/L. The discharge from this pipe currently flows into an 18-inch
diameter corrugated high-density polyethylene culvert installed in the ditch and treated for VOCs using
an activated charcoal boom.
5.5-31. AOC 10 needs to be investigated and remediated to Restricted Residential Standards.
Response: AOC 10 is partially located off-Site and partially in the CW1 Sub Area, a conservation zone to
be used for passive recreation along the western portion of the Site and the balance of AOC 10 is off-Site.
WSP Supplemental RI Report dated April 4, 2008, attached as Appendix G2 of the DGEIS.
AOC 10 is a drum disposal area that includes three or four separate geographic areas on and mostly
off-Site (which is not a part of this GEIS) but a portion of AOC 10 extends into the CW1 Sub Area. As
documented in Section 3.1.9. of the WSP Supplemental RI Report dated April 4, 2008 and summarized
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in the LaBella Phase I report, empty drums have been discovered and removed from AOC 10 on various
occasions since 1970. The most recent investigations and remedial efforts were completed in 2004
and 2005 and are documented in a February 22, 2005 letter by Environmental Strategies Consulting,
LLC, which is attached to the FGEIS as Appendix E10. As documented in this letter, a survey of the
wooded areas on and adjacent to the western portion of the Site was conducted in December 2004 and
additional drums/containers were identified. Subsequently, in December 2004 and January 2005 the
drums were removed and soil sampling of shallow soils beneath the drums was completed under the
NYSDEC oversight.
Because passive recreational use is a “Commercial Use” under New York State regulations, the
Commercial Use SCOs will therefore apply to CW1. See 6 NYCRR § 375-1.8(g)(2)(iii). Based on the
2005 shallow soil samples, three (3) out of the fourteen (14) locations that were sampled can be identified
as having contaminates above the Commercial Use SCOs laid out in Table 375-6.8(b) of 6 NYCRR Part
375:
•DL-6, where benzo(a)pyrene was found at 2,800 ppb (the SCO for Commercial Use is 1,000 ppb)
•DL-12, where benzo(a)pyrene was found at 1,700 ppb
•DL-14, where benzo(a)pyrene was found at 1,200 ppb and Aroclor 1254, a PCB, was found at
1,600 ppb (the SCO for PCBs for a Commercial Use is 1,000 ppb).
DL-6, DL-12, and DL-14 are all located along the hillside between the west side of the buildings and the
former railroad bed. Like other areas of the Site, the NYSDEC will determine whether excavation, capping,
and/or another remedy is appropriate to remediate those areas in AOC 10 above the Commercial Use
standards under the amended ROD. The SMP will also dictate what monitoring and maintenance will be
required.
Potential drum disposal areas were also investigated during the WSP’s 2008 Supplemental RI when
WSP investigated a depression in the wooded area located southwest of Building 34 that appeared to
contain drums in a 1976 aerial photograph. See Area A on Figure 4 of the Supplemental RI. WSP took
five (5) shallow soil samples from different points in the area and tested for VOCs, SVOCs, TAL metals,
and PCBs. None of these samples, however, identified contaminates above the Unrestricted Use SCO
laid out in Table 375-6.8(a) of 6 NYCRR Part 375.
5.5-32. More investigation of impacts and potential impacts to walls and floors of Buildings 13A,
34 and 4 should occur.
Response: The Phase II ESA included assessment of concrete utilizing an X-Ray Fluorescence meter,
which evaluates for heavy metals. This screening was conducted at 263 screening points within 21
buildings, including Buildings 4, 13A, and 34. The screening in these buildings included Building 4 (6
locations), Building 13A (37 locations), and Building 34 (42 locations). Known/documented areas of
chemical use were included in the screening in addition to a grid-like pattern used to cover remaining
portions of the building. This testing identified elevated metals concentrations in Building 34 which will
require addressing during remediation and/or redevelopment. Additional investigation was conducted
within Building 13A in areas proximate the former salt baths located within Building 14 as documented
in the Phase II Supplemental RI. As documented in the Revised Supplemental Pre-Design Investigation
Report by WSP dated April 22, 2013 and included in the FGEIS as Appendix E11, a portion of the Building
4 floor slab was removed in 2012 and concrete sampling was also conducted at that time. The floor slab
removal in Building 4 was part of an investigation into the source of VOCs in AOC-1.
5.5-33. How will cadmium impacts in Building 34 be addressed?
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Response: According to the Project Sponsor’s consultant, the cadmium impacts identified in Building 34
include impacts to concrete, which will likely be addressed (subject, of course, to the NYSDEC approval
and oversight) through removal of all of the concrete or simply scarifying the surface of the concrete.
Scarifying the surface involves removing the uppermost layer of concrete which is where the cadmium
impacts likely resolve. The Project Sponsor further indicates that under either approach confirmatory
testing of the concrete that remains would be completed to assess efficacy of the work, and removal of
the concrete would continue until confirmatory sampling indicated that the concrete no longer contains
cadmium above applicable standards.
5.534. Fugitive dust from working on this contaminated Site need to be addressed.
Response: Fugitive dust will be addressed throughout the remediation and redevelopment phases of
the Project through the use of a the NYSDEC approved SMP and a CAMP, which is part of the SMP.
The SMP puts into place the procedures and requirements for all subsurface activities at the Site. These
requirements will include dust control measures such as wetting excavation surfaces or applying other
dust suppression techniques. The CAMP will provide specific plans/requirements for air monitoring. The
air monitoring will include upwind and downwind air monitoring stations during all ground intrusive work
within the boundaries of the Site that remain on the Registry to ensure that fugitive dust is not a concern
for downwind receptors/residents. The CAMP will identify specific action levels that will require activities
to cease and/or additional dust control measures to be implemented prior to proceeding with the work.
The implementation of a SMP with a CAMP with the safeguards highlighted above is anticipated to be
established as a threshold.
5.5-35. P-cresol and metals above unrestricted use cleanup standards noted in the Boundary
Reassessment Study in CW1 and CW2 should be remediated and remediation details
should be provided.
Response: The Lead Agency understands that the NYSDEC is currently reviewing the Boundary
Reassessment work and the NYSDEC will determine the scope of the required remediation and/or
declaration of covenants and restrictions as part of that review. See PH Comment Summary Responses
Nos. 20 and 21. As noted by the Project Sponsor, the report notes that there was no fill material or debris
found where the p-cresol and metals were detected and the presence of these compounds in those areas
were not indicative of impacts associated with historical operations. In addition, the concentrations of
these compounds appear to be localized and none of these compounds were found in the groundwater
sample from the well placed down-gradient of these areas. The Project Sponsor anticipates that, based
upon all of these facts, the NYSDEC may very well determine that remediation of these localized areas
with slight exceedances of p-cresol and metals will not be necessary to be protective of human health
and the environment.
5.5-36. The DGEIS is not specific enough about the historical operations at the Site.
Response: Section 2.3 of the DGEIS, Background and History, is intended to be a summary of
historical operations at the Site; for more detailed information, please refer to the December 13, 2005
Onsite Assessment, November 2013 Phase I Environmental Site Assessment, March 2014 Phase II
Environmental Site Assessment, and the additional documents, figures, and photographs all attached as
Appendix G1 to the DGEIS.
5.5-37. I am in favor of reestablishing Ithaca’s Superfund.
Response: The Lead Agency is not aware of the Ithaca Superfund or what, specifically, this Commenter
is referring to. Nonetheless, the Lead Agency notes that the NYSDEC will make the final decision about
what remedies will be implemented at the Site. However, as noted above in PH Comment Summary
Response No. 5.5-3, at this point, the Lead Agency is evaluating a number of mitigation measures to
ensure impacts from environmental contamination are avoided and/or mitigated to the maximum extent
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practicable. This is likely to include but is not limited to inclusion of thresholds and/or mitigation measures
to ensure that the Site: (1) is remediated to restricted residential, commercial and/or industrial remedial
objectives, as appropriate based on the proposed uses at the Site; (2) will be subject to appropriate use
restrictions consistent with the proposed uses at the Site; (3) will be subject to appropriate prohibitions on
the use of groundwater at the Site without approval from the NYSDEC; (4) will be subject to development
and implementation of an appropriate SMP; and (5) will be subject to on-going monitoring that institutional
and/or engineering controls are being properly implemented and/or maintained.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.6 (Historic & Archaeological Resources):
5.7-1. There is reference to architectural guidelines in the Design Standards to protect historic
character.
Response: No architectural guidelines are included as part of the Project. Design Guidelines within the
PUD/PDZ address building form and disposition and relationship to the pedestrian experience but do not
cover subjective aesthetic or stylistic elements of the buildings.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.7 (Transportation):
5.7-1. The study should clarify on what basis the existing, base condition, and future with
development conditions signal timing/phasing assumptions were based.
Response: According to the Project Sponsor’s traffic consultant, the signal timing information was based
upon a combination of City of Ithaca SYNCHRO files, the NYSDOT SYNCHRO files (specifically for the
intersections of State Street/Fulton Street and Fulton Street/Meadow Street/Clinton Street), and field
checks. Refer to Page 5-72 of the DGEIS for more detail on the sources of traffic data utilized in the traffic
analysis.
5.7-2. A list of the intersections reanalyzed per the addition of the 203 apartment units described
on page 5-108 of the DGEIS should be provided.
Response: As per the Project Sponsor’s traffic consultant, the following intersections were reanalyzed:
• NYS Route 96B at Site Access Driveways 1, 3, 4, and 5
• NYS Route 96B/Grandview Avenue
• Aurora Street/Prospect Street/Clinton Street
• Aurora Street/State Street
• Cayuga Street/Seneca Street
• Cayuga Street/Clinton Street
• State Street/Stewart Avenue
The reanalysis appears at page 5-108 of the DGEIS.
5.7-3. Further information on the methodology used to estimate origin/destination of trips to and
from the site should be provided to justify projected trip distribution.
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Response: The proposed arrival/departure distribution of traffic to be generated by the Project is based
on several key parameters, including the following:
• Employment centers;
• Retail centers;
• Population centers;
• Ithaca College;
• Cornell University;
• Existing traffic patterns; and
• Existing traffic conditions and controls
Using existing traffic volumes, the Project Sponsor’s traffic consultant calculated percentages of entering
and exiting trips entering and exiting the study area. This information, in turn, provided the basis for
calculating trip distribution for the Site. A particular trip distribution was generated for each Sub Area of
the Project with the understanding that access controls and circulation varied between areas of the Site.
A summary of trip distribution pattern percentages for each area of the Site is provided on pages 5-92 to
5-96 of the DGEIS with a more detailed explanation included in DGEIS Appendix I.
5.7-4. Based on a review of the projected site trip distribution, it appears that a higher percentage
of vehicles accessing the site from Cayuga Street/Albany Street from the north and
Clinton Street/Green Street Seneca Street might access the site via the Cayuga Street
and Turner Place access point than what is projected in the study. Given this potential, there
is concern that additional traffic would impact the character of these existing, low traffic,
narrow dead-end roadways. This raises significant concerns about the impacts on these
roadways and whether these are appropriate access points for the proposed site.
Response: The Project Sponsor’s traffic consultant has carefully evaluated this comment and provides
the following analysis in response:
Cayuga Street and Turner Place have historically served as access points to the Site and continued use
for Site access is appropriate. First, in terms of the impact of the Project on the character of these streets,
it is important to differentiate traffic impacts from a resident’s perspective versus the typical drivers’
perspective. Traffic impact studies typically evaluate impacts on Levels of Service (LOS). The concept
of LOS as defined in the Federal Highway Administration’s Highway Capacity Manual, represents “a
qualitative measure describing operational conditions within a traffic stream, and their perception by
motorists and/or passengers.”
While traffic flow measures in this context are solely from the vehicle occupant’s perspective, an equally
important measure, which is generally lacking in most traffic impact studies involving residential areas, is
to also take into account a resident’s viewpoint of traffic. As noted in this comment, the influence of traffic
on the quality of life (or livability) of the residents within the vicinity of a project is often as important a
consideration as impacts on LOS.
Each person’s concern for traffic and its impact on his/her quality of life is a function of numerous variables:
traffic volume and speed, vehicle composition, temporal distribution of traffic, dwelling setback from the
street, presence of children, and numerous resident demographic factors. As such, no one single volume
threshold at which residents normally become irritated can be generally applied. The type of roadway and
the perception the roadway exhibits to the residents greatly influences the threshold levels. Residents’
complaints about traffic volumes escalate whenever the actual conditions on the street differ from the
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Residents’ expectations as to what conditions on that particular street should be. Although there is not
a linear relationship between complaints and traffic volume, there is a certain volume range in which
Resident expectations seem most likely to differ from actual conditions.
Local street design considerations, specified in Residential Streets, Third Edition, 2001, developed
jointly by the National Association of Home Builders, American Society of Civil Engineers, Institute of
Transportation Engineers (ITE), and the Urban Land Institute provides definitions of the various street
classifications. As well, Transportation and Land Development, Second Edition, 2002, developed by ITE
was consulted. Based on the definitions provided by that document, Turner Place and Cayuga Street
are categorized as Minor Residential/Local Streets with an Average Daily Traffic (ADT) range between
400 – 1,500 vehicles per day.
Based upon the peak hour volumes on Turner Place and Cayuga Street as shown in Figures 5.7-3, 5.7-
20, 5.7-25, and 5.7-26 of the DGEIS (existing, background, Phase 1 development conditions, and full
development conditions); the ADT comparisons are shown in the following Table.
TURNER PLACE AND CAYUGA STREET: AVERAGE DAILY TRAFFIC COMPARISONS
Adjacent
Roadway
Two-way AM(PM)
Peak Hour Volume (vph)
Estimated Average Daily Traffic (ADT)
Volume (vpd)
Existing Background Phase
1
Phase 2
Full Dev.Existing Background Phase
1
Phase 2
Full Dev.
Turner
Place 56(69)58(71)85(86)162(164)690 710 860 1640
Cayuga
Street 41(53)41(55)83(70)144(106)530 550 700 1060
The above comparison indicates that existing and full development ADTs on both roadways is within, or
slightly above, the threshold limits outlined for Minor Residential/Local Streets.
The Project Sponsor’s traffic consultant also performed an alternative analysis at the Clinton Street/
Turner Place and Aurora Street/Clinton Street/Prospect Street intersections under the scenario whereby
Project related traffic is prohibited from traveling along Turner Place to determine what the elimination of
this access point would have on surrounding intersections. This alternative analysis, the results of which
are presented in the following table, has been reviewed by the City’s Traffic Engineer and will be added
to the DGEIS traffic impact analysis (see FGEIS § 4.11 and Appendix F):
ALTERNATIVE CAPACITY ANALYSIS RESULTS
PROHIBITED PROJECT-RELATED TRAFFIC ALONG TURNER PLACE
Intersection
Full Development (Phase II)Full Development (Phase II)
with Prohibitions
AM Peak PM Peak AM Peak PM Peak
Aurora Street/Clinton Street/
Prospect Street
Eastbound left – Clinton Street F(*)F(*)F(*)F(*)
Eastbound right – Clinton
Street E(41.7)C(26.0)F(66.3)D(27.2)
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Westbound – Prospect Street F(*)F(*)F(*)F(*)
Northbound – Aurora Street A(9.4)A(9.0)A(9.6)A(9.2)
Southbound – Aurora Street A(0.0)A(0.0)A(0.0)A(0.0)
Clinton Street/Turner Place
Westbound – Clinton Street A(9.4)A(9.4)A(9.5)A(9.5)
Northbound – Turner Place C(23.0)E(47.9)C(22.5)E(39.0)
The results show that with the redistributed Turner Place traffic onto Aurora Street, delays are projected
to increase for all approaches during both peak hours at the Aurora Street/Clinton Street/Prospect Street
intersection. However, at the Clinton Street/Turner Place intersection, projected delays decrease for the
northbound approach during both peak hours. Redistributing Project-related traffic away from Cayuga
Street will likely exacerbate the projected conditions at the Aurora Street/Clinton Street/Prospect Street
intersection, therefore it is not recommended. Accordingly, both Cayuga Street and Turner Place are
appropriate access points to the Site.
5.7-5. It is unclear from the traffic study if ingress-only or full access will be provided to the site
via Cayuga Street. The site plan shows 2-way circulation. The Phase 1 trip generation
figure (5.7-22) shows ingress and egress traffic, while the Phase 2 trip generation shown
no egress traffic from the site.
Response: As per page 5 and 48 of the Scoping Document, the Project Sponsor is proposing 2-way
circulation via Cayuga Street. The reason that Phase 2 trip generation shows no egress traffic on Cayuga
Street is that trip distribution pattern percentages related to Phase 2 were not projected to utilize Cayuga
Street. This is due to the location of Phase 2 development on-Site and the projected travel paths to and
from such development (see Response No. 5.7-3 above for more detail on trip distribution methodology).
While there may be variability as to how many vehicles may use this street, any Phase 2 traffic is projected
to be very low. Refer to the Response No. 5.7-4 above regarding Minor Residential/Local Street traffic
volumes and Figures 5.7-25 and 5.7-26 of the DGEIS for an illustration of Phase 1 and Full Development
traffic volume distribution.
5.7-6. Traffic volumes along the main line of Clinton Street/Prospect Street are significantly
different between intersections in Figure 5.7-26.
Response: According to the Project Sponsor’s traffic consultant, the difference in traffic volumes is due
to: (i) temporal variations between intersections (that is, the time it takes for vehicles to travel between
intersections); (ii) the impact of the traffic detour in downtown Ithaca at the time of data collection
(adjustments were made to the 2014 Existing Conditions based upon historical traffic volumes collected
throughout the downtown as referenced on Page 5-72 of the DGEIS); (iii) peak hours; and, (iv) the
existence of side streets and driveways between the intersections along NYS Route 96B. The traffic
consultant employed vehicle balancing in the analysis to achieve relative balance between intersections,
where necessary.
5.7-7. A figure should be provided showing anticipated am, pm and daily traffic at key intersections
internal to the site.
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Response: Acknowledged. A figure depicting the scale of trip generation based on the Conceptual Site
Layout Plan is provided in the DGEIS updates (See updated FGEIS Figure 2.3-2 at the end of Chapter
4). Projected turning movement counts during AM and PM peak hours will be illustrated and addressed
during the site plan review process for individual projects within the CWD.
5.7-8. No trip distribution is shown to site access driveway 5 with Phase 1 development. Please
clarify if this access point will be open with Phase 1 development.
Response: The Project Sponsor informs the Lead Agency that the Site Access Driveway 5 will not be
operational for Phase 1 Development.
5.7-9. As stated in the traffic study, the pedestrian network between the site and anticipated
pedestrian destinations (particularly in the City) is not complete. The internal sidewalk
network is also not complete. Due to this limitation, it appears some of the trip reduction
assumptions for walking might be lower than assumed in the report. Further justification
of the reduction or proposed improvements to the pedestrian network should be evaluated.
As an example, the existing sidewalk along Cayuga Street near the site is in very poor
condition.
Response: In conjunction with the Project, the Project Sponsor will improve the adjacent sidewalk network
in coordination with City Staff as the Site is developed. The Lead Agency understands that the portion
of the Site within the City’s jurisdiction is located within Sidewalk Improvement District 4. Therefore, any
development that occurs will be subject to the required associated fees for such construction projects. The
internal sidewalk network will be fully developed in the site plan review phase in coordination with LEED
ND requirements. Thus, the trip reduction assumptions in the traffic analysis appear to be appropriate.
5.7-10. A queue analysis is needed at the proposed site access locations to determine if anticipated
queues will spill back into internal intersections or onto adjacent roadways. Available
queue spacing appears especially limited exiting the site at Site Access 1.
Response: The Project Sponsor’s traffic consultant provided the following table which depicts the
results of queuing analysis at the proposed Site access driveways during Phase 1 and Full Development
Conditions. Supplementary queuing analysis is provided in the DGEIS updates (see FGEIS § 4.10 and
Appendix F).
DRIVEWAY QUEUING ANALYSIS: PHASE I AND FULL DEVELOPMENT
AM Peak Hour Queuing Results
Site
Access
Driveway
Phase 1 Queue
Length
(in feet)
Full Development
Queue Length
(in feet)
Full Development
with Mitigation
Queue Length
(in feet)
Conceptual
Available Storage
to First
Intersection
(in feet)Average 95th
Percentile Average 95th
Percentile Average 95th
Percentile
Driveway
I 20 49 46 78 52 91 160
Driveway
II NA NA NA NA NA NA N/A
Driveway
III 7 26 36 60 19 39 211
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Driveway
IV 6 24 40 72 52 83 475
Driveway
V NA NA 36 73 29 48 422
PM Peak Hour Queuing Results
Site
Access
Driveway
Phase 1 Queue
Length
(in feet)
Full Development
Queue Length
(in feet)
Full Development
with Mitigation
Queue Length
(in feet)
Conceptual
Available Storage
to First
Intersection
(in feet)Average 95th
Percentile Average 95th
Percentile Average 95th
Percentile
Driveway
I 31 69 290 358 98 154 160
Driveway
II NA NA NA NA NA NA N/A
Driveway
III 9 29 115 231 30 52 211
Driveway
IV 24 54 60 117 63 106 475
Driveway
V NA NA 35 53 41 73 422
Based on the above queuing analysis there are sufficient storage lengths at Driveways IV and V during
both peak hours. Driveway III during the PM peak hour is borderline based on 95th percentile queues.
However, queues of this length are expected to be infrequent and are intended to illustrate a worst-case
scenario. On the other hand, Driveway I during the PM peak hour shows queues that are longer than the
conceptual available storage. Accordingly, to mitigate this impact, the internal roadways interior to the
Driveway I access onto Aurora Street shall be required to be designed to mitigate potential spillback into
internal intersections.
5.7-11. Capacity analysis should be provided for the intersection of Cayuga Street/Spencer Street
Response: Acknowledged. The capacity analysis has been added to the corresponding figures which
are presented in the DGEIS updates (see FGEIS Appendix F for complete analysis and updated figures
at the end of Section 5.7 in Appendix G of the FGEIS).
5.7-12. A sight distance evaluation should be provided for all proposed access points.
Response: The Project Sponsor’s traffic consultant provided the following sight distance evaluation:
North South
Drive I > 500 ft. 400 ft.
Drive II* 400 ft. > 500 ft. * - Note: Drive II is proposed to be an entrance only.
Drive III > 500 ft. > 500 ft.
Drive IV > 500 ft. > 500 ft.
Drive V > 500 ft. > 500 ft.
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AASHTO Intersection Sight Distance is:
40 mph 445 ft.
45 mph 500 ft.
Based upon the above data, there is sufficient sight distance at all the proposed access points except
for Drive I, south and Drive II, north. The Project Sponsor’s proposed mitigation for Driveway I includes
installing advanced intersection warning signage (Manual of Uniform Traffic Control Devices (MUTCD)
W2-2L) for northbound approaching vehicles. Drive II is an entrance only and therefore does not require
mitigation. In addition, the NYSDOT stated a concern about sight distance for northbound vehicles
(especially trucks) approaching stopped vehicles waiting to turn left into Site Access 1. This can be
addressed by removing trees/brush and other obstructions within the NYS 96B right-of-way or providing
a left-turn lane at Site Access Drive No. 1. This mitigation will be reviewed by the NYSDOT and the City
during the site plan review process for individual projects within the CWD.
5.7-13. Warrants should be provided to demonstrate the potential need for left-turn phasing on
eastbound State Street at Stewart Avenue before and after development of Phases 1 and 2
of the site.
Response: The Lead Agency understands that the guidelines for the use of left-turn phasing described
by the Federal Highway Administration (FHWA) are as follows:
1. Product of opposing and left-turn hourly volumes exceeds a value of 50,000
2. Left-turn maneuver crosses three or more lanes of opposing through traffic
3. The posted speed limit of opposing traffic is greater than 45 MPH
4. A recent crash history for a 12-month period indicates five or more left-turn collisions that could
be prevented by the installation of a left-turn signal
5. Sight distance to oncoming traffic is less than the minimum recommended distance
6. The intersection has unusual geometric configurations
7. An opposing left-turn approach has a left-turn signal or meets one of the criteria listed above
The Project Sponsor’s traffic consultant has provided the following analysis:
DRIVEWAY QUEUING ANALYSIS: PHASE I AND FULL DEVELOPMENT
Guideline
No Build – Phase 1 No Build – Full
Development
Phase 1
Development Full Development
AM Peak
Hour
PM Peak
Hour
AM Peak
Hour
PM Peak
Hour
AM Peak
Hour
PM Peak
Hour
AM Peak
Hour
PM Peak
Hour
1 Met
(50,622)
Met
(50,112)
Met
(52,394)
Met
(51,935)
Met
(53,600)
Met
(52,930)
Met
(65,700)
Met
(65,912)
2 Not Met Not Met Not Met Not Met Not Met Not Met Not Met Not Met
3 Not Met Not Met Not Met Not Met Not Met Not Met Not Met Not Met
4 N/A N/A N/A N/A N/A N/A N/A N/A
5 Not Met Not Met Not Met Not Met Not Met Not Met Not Met Not Met
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6 Not Met Not Met Not Met Not Met Not Met Not Met Not Met Not Met
7 Not Met Not Met Not Met Not Met Not Met Not Met Not Met Not Met
Based on the guidelines above and the LOS results listed in the DGEIS at page 5-113 which indicates
a “B” or better during the AM and PM peak hours under all conditions, with the exception during the AM
peak hour under Full Development Conditions (LOS “E”), it does not appear that left-turn phasing is
required as mitigation. However, the intersection shall be monitored in conjunction with the Monitoring
and Mitigation Implementation (MMI) Plan to determine at what point in the future mitigation, if any, is
needed. Refer to Response No. 5.7-19 below for more information regarding the MMI Plan.
5.7-14. AutoTURN analysis of the fire truck should be expanded to include access to Cayuga
Street, Turner place and Site Access 4.
Response: Acknowledged. The AutoTURN analysis has been updated to include access to Cayuga
Street, Turner Place and Site Access IV. The analysis demonstrates that the fire apparatus operated by
the City and Town Departments that serve the area are able to maneuver through the Site. This analysis
is included in the Supplemental Traffic Analysis Report (see FGEIS Appendix F).
5.7-15. The assumption of a 40-mph travel speed on S Aurora Street stated on Page 5-125 should
be verified with a speed count.
Response: A 2006 NYSDOT Speed Count for the NYS 96B from the Ithaca City Line to CR 179 indicates
that the average speed for northbound traffic is 42.3 mph and 43.3 mph for southbound traffic. This
information is included in the DGEIS updates (see FGEIS Appendix F).
5.7-16. Please provide clarification of what sections of the site pertain to “Areas A-G” shown in
figures 5.7-15-21.
Response: The designation of the Traffic Impact Study (TIS) Areas corresponds to the proposed Site
Plan Sub Areas as follows: Area A = CW3, Area B = CW3, Area C = CW4, Area D = CW3, Area E = CW3,
Area F = CW3, and Area G = CW2
5.7-17. A technical appendix must be provided with the HCM analysis spreadsheets, any traffic
signal and turn lane warrants and trip generation and reduction analysis (including
relevant sheets from Trip Generation Handbook and Shared Parking). More detailed
spreadsheets illustrating the specific trip reductions for internalization, transit, walking,
pass-by trips and other factors should be shown separately for verification of calculations.
Response: This information is provided in the Appendices to the TIS which is located in Appendix I of
the DGEIS.
5.7-18. Analysis for signalized intersections should show operations of individual turning
movements at the intersection instead of just overall level of service.
Response: Acknowledged. The associated Figures have been updated (See Appendix F for complete
analyses).
5.7-19. It is unclear which of the mitigation measures that are listed in the DGEIS the applicant
is proposing to accomplish as part of developing the site and which mitigation measures
are recommended by the traffic study, in general. A list of the proposed mitigation measures
(signal optimization, road diets, other) by the applicant should be provided with associated
timeline in development when the mitigations measures will be implemented.
Response: Page 5-131 of the DGEIS highlights the proposed traffic mitigation measures for the Project.
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These measures are divided between Phase 1 of the Project and post-Phase 1 development at the
Site. The Project Sponsor informs the Lead Agency that Phase 1 has a proposed build-out timeframe of
approximately two years. The remaining phases are projected to be developed over a period of eight years
following occupancy of Phase 1. Nonetheless, it is acknowledged that future development beyond Phase
1 has a moderate degree of variability. Therefore, traffic mitigation measures should be commensurate
to identified traffic impacts, as well as be responsive to potential deviations from the proposed Project
phasing and timeline.
Relative to Phase 1, the NYSDOT has specified certain mitigation requirements relative to Route 96B (see
Response No. 5.7-26). In addition, the Project Sponsor shall introduce and implement Transportation
Demand Management (TDM) strategies to reduce Single Occupancy Vehicle (SOV) trips to and from the
Site. The following TDM strategies have been proposed for Phase 1 implementation:
• Market-priced parking
• Preferential parking for ridesharing services
• Bicycle parking facilities
• Subsidized transit passes
• Connections to transit stops (i.e. construct sidewalks to existing stop at Hillview Place)
• Dedicated shuttle service
• Transportation Alternatives Information
• Coordination with Smart Trips Ithaca
• Connected and improved pedestrian network on and adjacent the Site (i.e., improvements to
sidewalks within Sidewalk Improvement District No. 4)
• Pedestrian oriented design within the Site
• Bicycle network facilities within the Site and connections to nearby Gateway Trail
• Follow Crime Prevention Through Environmental Design (CPTED) principles in all design
• Coordination with Ithaca College and South Hill Business Park
It is noted that these TDM strategies are consistent with actions Ithaca Tompkins County Transportation
Council (ITCTC) has identified in the 2035 Long Range Transportation Plan (LRTP) and Cornell
University’s GEIS TDM program. Several of these TDM actions will need to be implemented on a tenant
by tenant basis. The Lead Agency understands that Washington State’s Commute Trip Reduction (CTR)
program and CTR Efficiency Act, a law passed by the State Legislature, requires local governments
in urban areas with traffic congestion to develop programs that reduce SOV trips and Vehicle Miles
Travelled (VMT) per capita. This program targets workplaces with 100 or more full-time employees. The
Project Sponsor has committed to adapt and scale this program to the projected employment centers
proposed within the CWD.
In order to mitigate post Phase 1 traffic impacts to the maximum extent practicable, following completion
of Phase 1, the Project Sponsor will implement an on-going MMI Plan. The MMI Plan will include an
update of traffic conditions after full occupancy of Phase 1 of the development and before the next
phase of development begins to verify underlying assumptions and evaluate the effectiveness of TDM
strategies. For instance, the implementation of TDM programs and the integration of the sidewalk and
trail system between the Site and adjacent neighborhoods could have a greater benefit than is currently
estimated. This post Phase 1 occupancy traffic update will evaluate the following intersections: (i) Aurora
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Street/Prospect Street/Clinton Street, (ii) Aurora Street/State Street, (iii) State Street/Seneca Way, (iv)
State Street/Green Street, (v) Clinton Street/Cayuga Street, (vi) Cayuga Street/Seneca Street, and, (vii)
Cayuga Street/Spencer Street. This post Phase 1 occupancy traffic update will also include an evaluation
of whether a traffic signal is warranted at all site access driveways.
The MMI Plan will also provide for additional traffic study updates at the following stages of development:
(i) immediately following tenant occupancy of Phase 1 of the Project; (ii) when proposed post Phase 1
development within the CWD results in more than 75 vehicle trips per hour (cumulative over Phase 1); and
(iii) each time proposed post Phase 1 development within the CWD will result in more than 150 vehicle
trips per hour (cumulative over the 75 vehicle trips per hour post Phase 1 traffic study update). In addition,
per NYSDOT, a traffic study update will be required for each phase of the project where modifications
and/or additional mitigation is proposed in the NYSDOT R.O.W (See Comment No. 5.7-29) Traffic study
updates will verify trip distribution models and confirm when traffic mitigation measures identified in the
DGEIS should be implemented. Other than the update immediately following tenant occupancy of Phase
1 of the Project, all updates will be submitted and reviewed, per the thresholds established herein, in
conjunction with proposed site plans for each phase of development. The intersections to be analyzed
in each traffic update include:
• Site Accesses 1 and 2
• Site Accesses 3, 4 and 5 (NYSDOT owned)
• Aurora Street/Prospect Street/Clinton Street
• Prospect Street/Turner Place
• Columbia Street/Aurora Street
• Aurora Street/State Street
• State Street/Seneca Way (NYSDOT owned)
• State Street/Green Street (NYSDOT owned)
• Clinton Street/Cayuga Street
• Cayuga Street/Seneca Street (NYSDOT owned)
• Cayuga Street/Spencer Street
• Pine Tree Road/SR 79 (NYSDOT owned)
• State Street/Stewart Avenue
• Turner Place corridor between site access and Prospect Street
• Cayuga Street corridor between site access and West Spencer Street
If traffic conditions at the above intersections degrade to LOS E or degrade to a higher delay LOS E
condition for any approach relative to the previous phase of development condition, mitigation will be
required before further development can occur.
An operations methodology shall be established for the Turner Place and Cayuga Street corridors to
ensure that development does not degrade operations to unacceptable levels on these narrow residential
streets. The Project Sponsor will propose an analysis methodology for approval by the City. If corridor
traffic conditions are projected to degrade beyond acceptable levels, mitigations must be provided before
further development can occur.
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The timing of all proposed mitigation identified in the DGEIS associated with Phase 2 will be determined
based on projected trip generation of development proposals. This will ensure that the proposed mitigation
at that point is commensurate with projected impacts. As part of the MMI Plan, these future traffic impact
assessments to be performed at the Site driveways and intersections identified above and will provide
updated trip distribution and generation figures resulting from development of the Site utilizing actual
traffic assessment data. The MMI Plan will provide that additional intersections will be added to traffic
updates if any previous traffic study projected a LOS of E or worse. These traffic impact assessments
will go beyond standard theoretical capacity analysis, utilizing actual traffic assessment data, such as
intersection delay studies, queuing analyses, and gap studies. Overall, the MMI Plan will be used to
refine the projected traffic impacts and determine the most effective and responsive mitigating strategies.
Moreover, impacts to the Site Driveways are expected to be mitigated through signalization of Driveway
I and IV. As well, Danby Road/Aurora Street is recommended to be restriped, as part of a road diet, to
include left-turn lanes at Driveway IV and Driveway III. This is described on Pages 5-121 and 5-122 of
the DGEIS. These improvements are recommended when the associated warrants are met and through
close coordination with the City, the NYSDOT and the Town of Ithaca. These additional traffic study
updates shall be reviewed and considered by the appropriate Planning Boards at the site plan review
stage.
In addition to the MMI Plan, as further mitigation of traffic impacts associated with the Project, implementation
of TDM will be required throughout the life of the Project. Long-term, TDM strategies may be the most
effective form of traffic mitigation. For instance, one strategy to address impacts to intersections, such
as Aurora Street/Clinton Street/Prospect Street and State Street/Aurora Street, is high capacity people
moving systems. This strategy will require dedicated shuttles and a commitment to working closely with
Tompkins Consolidated Area Transit (TCAT) to expand transit routes and increase headways. Off-Site
Park and Rides (existing or new) or underutilized parking lots (through shared use agreements) can be
utilized to shuttle employees, visitors, and residents to and from the Site. The Lead Agency understands
that an example of this is Guthrie Packer Hospital in Sayre, PA. All employees are required to park at an
off-Site lot and are shuttled to the Hospital. The Project Sponsor commits to providing two on-Site transit
stops. TCAT service is flexible and can be increased to respond to any increases in demand (i.e., vehicle
trips and, ultimately, person trips). The Project Sponsor is also committed to providing, in part, resources
to study the feasibility of a larger, integrated people-mover system; automated transit and gondola to/
from CWD. This is also supported by the 2010 Personal Rapid Transit (PRT) Feasibility Study for the
City of Ithaca. Within the document, it is recognized that there are challenges to implementing such a
system; however, it is consistent with the overall systems approach to transit (or similar) that ITCTC has
stated in their LRTPs. This PRT was conceptually laid out through the Project to be a part of a system
wide circulator system. The Project Sponsor has committed to contributing towards further study of this
emerging technology.
In order to monitor this effort and the implementation of other TDM strategies, in addition to traffic
study updates, the MMI Plan will incorporate a transportation modal survey (i.e., similar to the National
Household Travel Survey) to better understand the effectiveness of the TDM strategies employed on-
Site. Quantifiable figures, such as modal distribution or average vehicle ridership (AVR), will be used to
report the effectiveness. AVR is the ratio of the total number of employees or residents to the average
daily number of vehicles used. An agreed upon AVR with local officials will be determined. This is an
appropriate mitigation strategy since the Project Sponsor has control over the entire Site and therefore
will be able to provide accurate population data including numbers and types of users. The TDM strategy
evaluation will also include discussion of new or developing TDM strategies for consideration.
5.7-20. The following intersections are projected to degrade to Level of Service E or worse
operation under Phase 1 operations. Mitigation measures should be provided by the
Project Sponsor to prevent this degradation:
a. Prospect Street/S Aurora Street
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b. S Aurora Street/Columbia Street
c. S Aurora Street/Site Access 3
d. E State Street/Pine Tree Road
Response: It should be immediately noted that physical capacity-oriented improvements at intersections
may not be feasible due to physical constraints. With that, the following intersections and recommended
mitigation measures are described:
a) Prospect Street/S Aurora Street – The context of this intersection and adjacency to nearby structures
make physical capacity improvement difficult to implement. Therefore, TDM strategies are highly
recommended to offset any adverse impact to the intersection. A thorough review of the 2035 LRTP
prepared by ITCTC showed that this corridor is in a state of congestion under exiting conditions. A future
land use and transportation scenario prepared as part of the report showed that an increase in alternative
vehicle mix (i.e., more efficient vehicles and greater variety of higher occupancy vehicles) along with
reducing SOV trips can reduce congestion through this area. Refer to the response for Comment ID 8 for
more detail. Further analysis by the Project Sponsor’s traffic consultant using an extension of Synchro,
SimTraffic, demonstrate that delays may be less than those indicated (LOS B during both AM and PM
peak hours for the eastbound and westbound approaches). Delays will be even less for all other times
of the day.
The Project Sponsor’s traffic consultant considered a traffic signal for this intersection. The Lead Agency
understands that the MUTCD describes nine warrants for use when determining the need for a signal.
• As part of this analysis, the MUTCD provides guidance on evaluating minor street traffic,
particularly for approaches with separate left and right-turn lanes. In this case, the degree of
conflict of Clinton Street traffic is considered to be minimal based on field observations and the
capacity analysis. Therefore, the volume of traffic for this approach is not solely considered, and
does not meet the warrants for a traffic signal.
• The volume of Project-related traffic is approximately 5-6% of the total traffic entering this
intersection.
• Limited Right of Way (ROW) and existing building limit the ability to add capacity through additional
traffic lanes.
• Grade and weather considerations.
The Project Sponsor’s traffic consultant’s SYNCHRO analysis results with a traffic signal in place are
included in Appendix F of the FGEIS. The results are depicted in the following table.
CAPACITY ANALYSIS RESULTS – AURORA STREET/CLINTON STREET/PROSPECT STREET
Description of Approaches
Full Development
(Phase I)
Full Development
(Phase II)
Full Development
(Phase II) with
Traffic Signal
AM Peak
Hour
PM Peak
Hour
AM Peak
Hour
PM Peak
Hour
AM Peak
Hour
PM Peak
Hour
Eastbound left – Clinton Street F(78.0)F(*)F(*)F(*)C(25.7)D(40.4)
Eastbound right – Clinton Street C(17.3)C(16.8)E(41.7)C(26.0)B(19.9)B(17.4)
Westbound – Prospect Street F(107.5)F(*)F(*)F(*)C(24.1)C(31.6)
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Northbound – Aurora Street A(8.6)A(8.4)A(9.4)A(9.0)D(44.7)D(54.8)
Southbound – Aurora Street A(0.0)A(0.0)A(0.0)A(0.0)N/A
Southbound thru – Aurora Street
N/A N/A
A(3.9)A(2.8)
Southbound right – Aurora Street A(0.8)A(0.7)
Overall LOS C(27.0)C(34.1)
Note:
(*) = delays greater than two minutes
NA = Approach does not exist and/or not analyzed under this condition
The eastbound left and westbound approaches increase from LOS “F” to “D” or better during both peak
hours under signalized conditions. As well, the eastbound right LOS improves from LOS “E” and “C” to
“B” and “B” during the AM and PM peak hours, respectively. However, the results for the major approach,
in this case the northbound Aurora Street approach decrease from LOS “A” to LOS “D” during both peak
hours. The overall LOS is “C” during both peak hours under signalized conditions.
The Project Sponsor’s traffic consultant performed a traffic safety review at this intersection using the
Tompkins County High Crash Road Segment and Intersection Report. For the most recent six-year period,
any intersection reporting six or more crashes were included for analysis. This intersection reported five
or less intersections over the six-year period; thus, offering no discernible crash pattern.
A field inspection was also performed by the consultant to determine the feasibility of installing a northbound
left-turn lane. This inspection determined that due to the vehicle mix of traffic (e.g., cars, buses), turning
radii of such vehicles, and required tapers needed to install this configuration, the physical constraints of
this intersection do not allow for this treatment.
For these reasons, as well as the position the LRTP takes, no physical improvements are recommended
for this intersection under Phase 1 Development Conditions.
TDM strategies are needed to reduce added vehicle trips to the intersection and reduce delays. These
actions include, for example, the use of shuttles or higher capacity people-movers. At full occupancy
and operation of Phase 1, a shuttle service or other transit opportunity will be provided to reduce SOV
trips. As it relates to the commercial component of Phase 1, the Project Sponsor is committed to work
with commercial tenants to establish staggered arrival and departure of employees during off-peak time
periods for the Project site. Reducing directional vehicle trips of 20 northbound vehicles during the PM
peak hour can reduce side road delays. Thus, the TDM strategies that the Project Sponsor has committed
to are appropriate mitigation measures for Phase 1 and beyond.
b) S Aurora Street/Columbia Street – Columbia Street is a low volume side street (fewer than 10 vehicles
exiting Columbia Street during the AM and PM peak hours. Very little to no traffic is projected to be added
to the Columbia Street traffic volumes. The project delays are characteristic of side streets on heavily
trafficked roads, such as S Aurora Street. All approach LOSs are projected to be “C” or better during
both peak hours. Volume warrants for a traffic signal are not met. One vehicle every 6 to 8.5 minutes is
projected to exit Columbia Street during the AM and PM peak hours, respectively. Residents will have the
ability to use the traffic signal at Hillview Place during peak times or adjust their travel times and routes
to avoid delays.
c) S Aurora Street/Site Access 3 – Mitigation to improve capacity conditions is addressed via mitigation
measures at Site Access Driveways 1 and 4. Over time, visitors and residents of the Project Site will
learn the most efficient ways to exit the Site in order to reduce their delay. Additionally, as the Project
Site develops and more intensive mitigation measures are installed (e.g., traffic signals), those users
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can be guided to use those access points giving them a guaranteed opportunity to exit the Project Site
with reduced delay. Thus, prior to signalization of Driveways I and IV, the projected traffic volumes
exiting Driveway III are 111 lefts and 71 rights. The projected traffic volumes exiting Driveway III under
redistributed conditions are 38 lefts and 27 rights. The LOS for this approach is “C” during the AM
peak hour and “B” during the PM peak hour. See updated figures at the end of Section 5.7 included in
Appendix G of the FGEIS.
d) E State Street/Pine Tree Road – This intersection, as is stated in the TIS (page 5-118), should be
monitored to determine at what point in the future mitigation (e.g., traffic signal), if any, is necessary for
implementation. Currently, the southbound approach operates at LOS “E” during the PM peak hour. The
v/c ratio, which the Lead Agency understands is referred to as degree of saturation which represents the
sufficiency of an intersection [or approach] to accommodate the vehicular demand, is 0.83. At 0.85-0.95,
an intersection or approach operates near capacity. The Project Sponsor’s traffic consultant performed
a signal warrant analysis was performed under existing conditions, of which the description of such a
study is presented in the DGEIS at page 5-123. Based on the volume warrants alone for this intersection,
Warrant 1 (eight hour) Condition A is satisfied for 8/8 hours; Warrant 1 (eight hour) Condition B is satisfied
for 5/8 hours; Warrant 2 (four hour) is satisfied for 4/4 hours; and Warrant 3 (peak hour) is satisfied.
Therefore, the traffic consultant concludes that a traffic signal may be warranted under existing conditions
using only the volume warrants. The traffic consultant’s analysis with a traffic signal installed at this
intersection shows LOS “B” or better under existing and Phase 1 conditions and appears at Subsection
5.7.3, which begins on page 4-102 in the FGEIS.
The warrants presented are an initial assessment and provide a guideline to determining the need for a
traffic signal. Additional design and coordination with the NYSDOT will be performed during the permitting
process with the Involved Agency.
5.7-21. The following intersections are projected to degrade to Level of Service E or worse
operation under Phase 2 operations. Mitigation measures should be provided to prevent
this degradation. The proposed peak hour parking restriction on Eastbound E State Street
at Aurora Street is not acceptable for the City.
a. Prospect Street/S Aurora Street
b. S Aurora Street/Columbia Street
c. S Aurora Street/Site Access 3
d. Cayuga Street/Clinton Street
e. E State Street/Pine Tree Road
f. E State Street/Aurora Street
g. E State Street/Seneca Way
Response: The intersections and recommended mitigation measures are described as follows:
a) Prospect Street/S Aurora Street – Refer to response to Comment ID 2. Impacts to Aurora Street/
Clinton Street/Prospect Street and potential mitigation does not include physical improvements to the
intersection, as ROW and existing buildings limit the ability to expand the intersection. Additionally, a
traffic signal is not an appropriate treatment due to the reasons described in Comment ID 2. Therefore,
higher capacity people mover systems (i.e., new TCAT routes and improved headway, and potential
automated transit service between the Commons and the Site or a gondola) are needed.
b) S Aurora Street/Columbia Street – Refer to response to Comment ID 2. Traffic signal warrants are
not met at this intersection to alleviate delays for Columbia Street traffic. All traffic can be accommodated,
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as needed, at the existing traffic signal at Aurora Street/Hillview Place. The reduction of SOV trips and
increased mode share of pedestrian, bicycle, and transit trips will reduce total site generated traffic
passing through this intersection.
c) S Aurora Street/Site Access 3 – Refer to response to Comment ID 2. Delays at Driveway III are
projected to decrease from LOS “F” to LOS “E” with the installation of traffic signals at Driveway I and IV.
The effect of these traffic signals is described on pages 5-124 through 5-126 in the DGEIS.
d) Cayuga Street/Clinton Street – The Project Sponsor’s traffic consultant developed signal timing
adjustments for the PM peak hour and the associated capacity analysis results which are presented at
Appendix F of the FGEIS. These adjustments reduce the projected LOS “E” for the northbound thru/right
approach and LOS “F” for the southbound left approach to LOS “D” for both approaches.
The Project Sponsor has had discussions with ITCTC about an automated fixed route system along Cayuga
Street that would shuttle people between the Commons and the Site. The Lead Agency recommends that
a feasibility study of such a system be performed by ITCTC with participation from the Project Sponsor.
As stated in the TIS (page 5-131) and found within the 2035 LRTP, it is recommended that a review and
possible upgrade of the traffic signals in downtown Ithaca be performed to address existing conditions.
This would entail assessing the need for improved coordination, installation of smarter vehicle and multi-
modal sensors, signal phasing priority given to transit, and an overall better integration of pedestrian and
bicycle systems. Traffic signal timing updates are recommended, as well as system-wide optimization
of the traffic signal network, to reduce the projected delays. This will be accomplished over time as
part of typical operations and maintenance of the system by City Forces. The Project team has had
discussions with ITCTC about an automated fixed route system along Cayuga Street that would shuttle
people between the Commons and the Site. The Lead Agency recommends that a feasibility study of
such a system is recommended to be performed with the participation of the Project Sponsor
The Project Sponsor developed signal timing adjustments for the PM peak hour and the associated
capacity analysis results (included with this submittal). These adjustments reduce the projected LOS “E”
for the northbound thru/right approach and LOS “F” for the southbound left approach to LOS “D” for both
approaches.
e) E State Street/Pine Tree Road – Refer to response to Comment ID 2. NYS Route 79/Pine Tree Road
currently meets traffic signal warrants that deal solely with existing traffic volumes. Introduction of project-
related traffic will increase delays.
f) E State Street/Aurora Street – Refer to response to Comment ID 3, Item D. Page 5-127 of the DGEIS
describes an alternative to reduce vehicular delay and increase the LOS for the westbound approach
from “F” to “E”. The westbound approach can be restriped to include separate left and right-turn lanes.
The right-turn lane would include 100 feet of storage and would require restriction of peak hour parking
for two metered parking spaces. During off-peak hours, drivers can continue using the parking spaces.
However, this mitigation is not feasible based on the presence of a loading zone along the north side
(westbound approach) of State Street.
The Project Sponsor’s traffic consultant reassessed the physical geometry of the intersection based
on actual operating conditions. The traffic consultant concluded that, although a northbound right-turn
channelized turn lane is present in the capacity analysis conditions described in the DGEIS, the effect
is not apparent in the analysis. The following table depicts the revised analysis during both peak hours
under all conditions. The net effect this revision has is the reduction of the northbound LOS.
CAPACITY ANALYSIS RESULTS – AURORA STREET/EAST STATE STREET
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Description
of
Approaches
Existing
Conditions
No Build
Phase I
No Build
Phase II
Full Dev.
Phase I
Full Dev.
Phase II with
Mitigation
AM
Peak
Hour
PM
Peak
Hour
AM
Peak
Hour
PM
Peak
Hour
AM
Peak
Hour
PM
Peak
Hour
AM
Peak
Hour
PM
Peak
Hour
AM
Peak
Hour
PM
Peak
Hour
WB –
State Street C(26.8)E(68.4)C(27.3)E(76.0)C(27.9)F(84.5)C(32.4)F(83.1)D(51.0)D(54.7)
NB Thru –
Aurora Street B(16.1)B(15.2)B(16.3)B(15.3)B(16.5)B(15.5)B(16.5)B(16.0)C(24.2)D(36.9)
NB Right –
Aurora Street A(6.3)A(5.9)A(6.4)A(6.0)A(6.5)A(6.1)A(6.4)A(6.4)A(9.7)B(18.3)
Overall LOS B(19.5)D(41.4)B(19.9)D(45.4)C(20.2)D(49.8)C(22.4)D(47.7)C(34.9)D(41.7)
The Lead Agency agrees with the traffic consultant’s recommendation that signal timing adjustments
be implemented to increase the green time given to the westbound approach under Full Development
Phase 2 Conditions. Doing so keeps the projected Levels of Service at an acceptable “D” or better during
both peak hours.
g) E State Street/Seneca Way – Refer to response to Comment ID 3, Item D. TDM and higher capacity
people moving systems are needed to mitigate traffic impacts. Physical constraints restrict the ability to
increase capacity through adding travel lanes. This intersection will also be included in the review and
optimization of the traffic signal network to ensure peak performance.
The Project Sponsor’s traffic consultant examined the impact of signal timing adjustments during the PM
peak hour and concluded that the projected LOS under Full Development Phase 2 Conditions will be
improved. The following table depicts the LOS results.
CAPACITY ANALYSIS RESULTS – EAST STATE STREET/SENECA WAY
Description of
Approaches
Full Development (Phase II)Full Development (Phase II)
with Traffic Signal
AM Peak
Hour PM Peak Hour AM Peak
Hour PM Peak Hour
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Eastbound – State
Street D(44.1)F(*)
No mitigation
recommended
D(54.4)
Westbound – State
Street D(40.5)E(68.7)D(35.8)
Northbound left –
Seneca Way C(24.8)C(26.0)C(27.8)
Northbound thru –
Seneca Way C(24.5)C(29.9)C(31.7)
Overall LOS D(36.6)E(67.1)D(38.5)
The Lead Agency understands that with the recommended signal timing adjustments in place, the
eastbound and westbound approaches improve in LOS from “F” and “E” to “D” and “D”, respectively,
during the PM peak hour. Meanwhile, the overall LOS improves from LOS “E” to “D”.
TDM or other recommendations to consider in order to reduce SOV trips are dedicated shuttles between
the Site and common destinations (e.g., The Commons, retail along NYS Route 13, Cornell University,
Ithaca College) or automated people mover systems (i.e., Personal Rapid Transit) mentioned by ITCTC.
Refer to the response for Comment ID 8 for more detail on short term implementation of TDM strategies.
5.7-22. A plan must be provided for proposed timing of installation of a traffic signal at site Access
Point 1 and 4 relative to development.
Response: Refer to Response to No. 19 above (specifically the response regarding the MMI Plan) and
pages 5-115 and 5-123 of the TIS for a description of the traffic signal mitigation and warrants at the
proposed access points. During redevelopment and construction of Phase 1, underground traffic signal
conduit should be installed at the Aurora Street/Proposed Driveway I or 2 intersection with the assumption
that a future traffic signal will be required to mitigation traffic impacts. Upon completion of Phase 1, a
subsequent traffic signal warrant study will be performed to evaluate actual traffic patterns and delays at
Driveways I and 2, and determine when construction of the proposed traffic signal is warranted.
Installation of a traffic signal at this intersection is projected to attract a portion of exiting vehicle trips from
the Site. This will have the effect of reducing trips added to the Project driveways, specifically Driveway III.
5.7-23. The proposed signalized traffic signal on Aurora Street at Site Access 1 is located
approximately 325 feet from the existing traffic signal at the intersection of S Aurora Street
and Hillview Place. Given the close proximity of the proposed traffic signal spacing, it
will be necessary to coordinate the traffic signals in order to prevent unacceptable queueing
and delay between the intersections. Detailed analysis must be provided proving that
adequate progression can be provided with this minimal spacing. Additionally, the
existing controller at the Hillview Place/S Aurora Street intersection is likely not capable
of such coordination and would probably need to be replaced by the applicant along with
any related infrastructure in order to accomplish coordination of the two traffic signals.
Response: The mitigated conditions at the proposed Site Access 1 driveway are coded with a coordinated
signal system with the nearby S Aurora Street/Hillview Place signalized intersection. The Project Sponsor
will be required to provide the proposed mitigation. The Project Sponsor will also be required to perform
all necessary upgrades to the traffic signal at S Aurora Street/Hillview Place to allow for coordination
between the subject traffic signal and the proposed signal at Driveway I. A detailed analysis of this
condition is included in Appendix I of the DGEIS.
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5.7-24. The TDM section of the report describes many strategies that could be used at the site but
does not provide a plan to ensure implementation. A more structured plan is needed to
justify trip reductions.
Response: The Project Sponsor proposes the following TDM strategies for short-term, Phase 1
implementation as the early development of the Project advances:
• Market-priced parking
• Preferential parking for ridesharing services
• Bicycle parking facilities
• Subsidized transit passes
• Connections to transit stops (i.e. construct sidewalks to existing stop at Hillview Place)
• Dedicated shuttle service / rideshare participation (i.e. Zipcar)
• Transportation Alternatives Information
• Coordination with Smart Trips Ithaca
• Connected and improved pedestrian network on and adjacent the Site (i.e., improvements to
sidewalks within Sidewalk Improvement District No. 4)
• Pedestrian oriented design within the Site
• Bicycle network facilities within the Site and connections to nearby Gateway Trail
• Follow CPTED principles in all design
• Coordination with Ithaca College and South Hill Business Park
As the Site continues to be built-out, as discussed in Response No. 19 above, regular traffic updates will
be prepared pursuant to the MMI Plan and these traffic updates will incorporate a transportation modal
survey to better understand the effectiveness of the TDM strategies. The TDM strategy evaluation will
include discussion of new or developing TDM strategies for consideration. Existing research of TDM
strategies by the Project team are presented in the Supplemental Traffic Analysis Report (see FGEIS
Appendix F).
5.7-25. NYSDOT’s preferred mitigation is installing a signal and left/right turn lanes at the
Coddington Road/proposed driveway before any site work begins. Traffic/accident patterns
in this location cause some concern for us not mitigating before Phase 1. However,
NYSDOT is also aware that the expense of full mitigation at the initial project startup can
hinder development. For this reason, NYSDOT is requesting that you supply a table or a
list which would clearly state at what level of traffic volume per intersection mitigation
would be needed. In this case, NYSDOT would require an update on traffic counts at a
specified interval to verify the traffic patterns to require mitigation should this be the
approved method to move forward. Basically, NYSDOT will be requiring a sensitivity
analysis so that they can determine when to implement all appropriate mitigations for the
entire project.
Response: The following table notes at approximately what point in future traffic generation from the
proposed CWD will trigger the need for mitigation assigned to the noted intersections.
INTERSECTION SENSITIVITY ANLAYSIS
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Intersection Recommended Mitigation Future Traffic Volumes
Triggering Mitigation Needs
Route 96B/
Proposed Driveway I Three-color traffic signal 40 eastbound exiting vehicles
during PM peak hour
Route 96B/
Proposed Driveway III Northbound left-turn lane 13 northbound left-turn
vehicles during AM peak hour
Route 96B/
Coddington/Proposed Driveway
IV
Install three-color traffic signal 30 eastbound left/thru vehicles
during PM peak hour
Route 96B/
Proposed Driveway V Northbound left-turn lane 18 northbound left-turn
vehicles during AM peak hour
Route 96B/
Hillview Place Upgrade existing traffic signal In conjunction with Route 96B/
Proposed Drive I or II mitigation
Route 79/
Pine Tree Road Install three-color traffic signal Consider installation under
existing conditions
Cayuga Street/
Clinton Street
Review/update signal timing set-
tings (system-wide)
1340 total intersection
volumes
E State Street/
Seneca Way
Review/update signal timing set-
tings (system-wide)
1070 total intersection
volumes
The need for additional mitigation at Route 96B/Coddington Road/Proposed Driveway IV, aside from the
left-turn lanes along Route 96B will be considered as part of the site plan review process for individual
projects within the CWD (beyond Phase I).
5.7-26. NYSDOT will require the following Phase 1 mitigation relative to Route 96B
a) Changing the four-lane section of NY 96B south from the city/town line to past Bella Vista
Dr. by reconfiguring the two southbound lanes to one thru lane and incorporating left turn
lanes for both directions at intersections, and hatching where appropriate.
b) Sidewalk will be required along the frontage of the site on the western side of Route 96B,
from the city/town line to the Coddington Rd. intersection.
c) The proposed driveway, immediately south of city/town line, will be a one-way ingress
only; no traffic will be allowed to exit onto Route 96B at this location.
Response: These comments are acknowledged. The Project Sponsor will seek to partner with the Town
of Ithaca, Ithaca College, the South Hill Business Park, and others, as applicable, to implement the noted
reconfiguring project.
5.7-27. NYSDOT will not consider signal timing adjustment as an option for or form of mitigation
during Phase 1 of the project. Should larger traffic volumes than expected result from
Phase 1 construction, it may be necessary to look at utilizing the signal to help, but will not
be the main form of mitigation. It should also be noted NYSDOT found numerous errors in
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the TIS for the modeled signals, but for Phase 1 they will not require resubmitting a revised
TIS. NYSDOT will work with the developer on the next submittal to correct any errors.
Response: These comments are acknowledged. These changes will be incorporated in future analyses.
5.7-28. The unsignalized driveway at the Coddington Rd. intersection can only be a one lane exit,
rather than dual exit lanes as modeled on SYNCHRO. This can be changed once a signal
is installed, but we do not allow dual exiting lanes at un-signalized intersections.
Response: This comment is acknowledged.
5.7-29. NYSDOT will require a revised TIS for each phase of the project where modifications and/
or additional mitigation is proposed in the NYSDOT R.O.W.
Response: This comment is acknowledged.
5.7-30. Currently, a cross-property connection with the business park immediately to the south
of CWD is not shown. NYSDOT would support property owners should they desire to
pursue the connection of properties, since this business park has a signalized access to
Route 96B.
Response: This comment is acknowledged. The Project Sponsor and Lead Agency agree to consider
this issue during the site plan review process for the individual projects within the CWD.
5.7-31. The driveway between Coddington Road and the southernmost access will not be allowed
by NYSDOT; this is the access proposed near building N18.
Response: This comment is acknowledged. The Conceptual Site Layout Plan has been revised. See
updated FGEIS Figure 2.3-2 at the end of Chapter 4.
5.7-32. Additionally, NYSDOT has concerns with potential sight distance at the northern-most
access drive, northbound on Route 96B, when crossing from the town to the city-owned
portion of Route 96B. Their concern is with regard to the significant downhill grade, which
continually increases when traveling north into the city. Large vehicles, specifically trucks,
will have a difficult time slowing down for left-turning vehicles waiting to turn left into the
site. For this reason, NYSDOT strongly encourages the consideration of a northbound left-
turn lane at this intersection.
Response: The Project Sponsor recognizes that the northernmost driveway (Driveway 1) has potential
sight and horizontal curve characteristics that might make Site Access 2 a better candidate for signalization.
Further analysis is needed and will be provided with Phase 1 application. Regardless of whether Site
Access 1 or 2 is signalized, interconnect and coordination will be required with the Hillview Place/Aurora
Street intersection. Per Comment No. 22, this will require replacement of the existing traffic signal
equipment at the Hillview Place/Aurora Street intersection per Comment No. 22. It is acknowledged that
left-turn lane warrants are met for Site Accesses 1 and 2 per Phase 1 projections. The Project Sponsor
acknowledges that left-turn lane construction or restriction will be required for northbound vehicles
entering the Site at Site Accesses 1 and 2.
5.7-33. Please provide documentation of conversations with TCAT regarding plans for transit
accommodation on and near the site. How will TCAT handle future demands for transit?
Response: TCAT is a vital Interested Agency in the GEIS process. The Project Sponsor’s traffic
consultant made initial verbal contact with TCAT in August 2014. There was an additional meeting
between Project Sponsor’s consultant team and TCAT on December 18, 2014. The Project Sponsor’s
traffic consultant had additional conversations with TCAT on July 14, 2016. Documentation of those
discussions are provided at Appendix F of the FGEIS. TCAT will continually be an Interested Agency
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during the site plan review process for individual projects within the CWD.
As of July 14, 2016, TCAT (Matt Yarrow) stated that Route 65 is not ideal for the Project as it is a
commuter-based Route. Route 11 is best situated to service the Site once critical demand is met; this
demand will be closely monitored through continued coordination between Site employers, Site residents,
the Project Sponsor, City Staff and TCAT. An additional Route may be necessary to meet future demand
and will be considered as part of the Monitor and Mitigation Implementation Plan.
The current service frequencies and capacity may not likely be able to handle the anticipated need of
future residents, visitors, and employees of the Site upon full development of the Project. Therefore, the
Project Sponsor has committed, through continued coordination with TCAT, to monitor future demands of
transit during the course of the development; this includes adding two transit stops on-Site and potentially
increasing the headway needed to meet these demands.
5.7-34. It is unclear why the site plan does not show proposed sidewalk along the S Aurora Street
frontage near Residential Area N18.
Response: The Project Sponsor has revised the Conceptual Site Layout Plan to include sidewalks along
all Sponsor controlled properties (See updated FGEIS Figure 2.3-2 at the end of Chapter 4). Sidewalk
design and details will be addressed during the site plan review process for individual projects within the
CWD.
5.7-35. It appears that the orientation of vehicles accessing Lower Morse Place from the parking lot
south of (Existing) Building 18 could create sight distance limitations based on its acute
intersection angle. The intersection of Lower Morse Place with South Cayuga Street
presents similar limitations. Sight distance should be investigated at these locations.
Response: The final design and geometry of the internal roadway network, including providing turn
movement analysis, will be addressed during individual site plan review of each Phase. Specific to the
comment, the Lead Agency understands that the Lower Morse Place roadway will have a speed limit of
20 mph as well as be one way which will improve site distance.
5.7-36. The site plan shows significant gaps in the internal sidewalk network in the vicinity of
Scout Path and the two parking areas nearby. Please provide analysis of how pedestrian
access will be accommodated.
Response: Acknowledged. The Project Sponsor has revised the Conceptual Site Layout Plan to add
these connections (See FGEIS Figure 2.3-2 in Appendix G). The final design of the internal pedestrian
network will be addressed during the individual site plan review of each Phase.
5.7-37. It is unclear from the site plan where the proposed bus stop locations will be provided and
whether these bus accommodations at these sites will be accessible the ADA standards.
Further information should be provided, including timeline for implementation.
Response: The Conceptual Site Layout Plan identifies two potential bus stop locations. The final
locations will be addressed the site plan review process for individual projects within the CWD.
5.7-38. Some areas of the site plan are labeled with the total number of parking spaces. Please
label all parking areas with total spaces per area for ease of review and provide analysis to
verify that sufficient parking will exist for all land uses without need for long walking
distances.
Response: Acknowledged. The Project Sponsor has revised the Conceptual Site Layout Plan to label
all surface parking areas as depicted. The final design of the parking areas will be addressed during the
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site plan review process for individual projects within the CWD.
5.7-39. A site plan should be provided illustrating what portion of the internal site circulation path
and site access points will be developed with Phase 1 of development.
Response: The internal Site circulation and roadway network is included with the Phase 1 Site Plan
Drawings (see Appendix B-2 of the DGEIS).
5.7-40. Turning movement analysis should be provided to demonstrate that the roadway area
south of Residential Area N38 is sufficient for turnaround of vehicles.
Response: The final design and geometry of the internal roadway network, including providing turn
movement analysis, will be addressed during the site plan review process for individual projects within
the CWD.
5.7-41. It is unclear where stop signs will be provided in the grid of streets in the vicinity of Housing
areas N27 – N38.
Response: Internal traffic controls will be addressed during the site plan review process for individual
projects within the CWD.
5.7-42. Stop signs are not shown on the site plan for egress from Site Access 3.
Response: Acknowledged. The Project Sponsor has revised the Conceptual Site Layout Plan to show
proposed stop sign locations (See updated FGEIS Figure 2.3-2 at the end of Chapter 4). The final
location of internal traffic controls will be addressed during the site plan review process for individual
projects within the CWD.
5.7-43. The stop sign shown near Residential Area N4 appears to be misplaced. It was probably
intended to be located at the nearby four-leg intersection with only one stop sign shown.
Response: As noted above, the final location of internal traffic controls will be addressed during the site
plan review process for individual projects within the CWD.
5.7-44. The driveway access to Residential Area N2 appears as if vehicles will need to pull in and
out directly into an internal intersection. Clarification should be provided on the access
scheme.
Response: The final design and geometry of the internal roadway network, including providing turn
movement analysis, will be addressed during individual site plan review of each Phase.
5.7-45. The number of PM peak egress trips shown in Figure 5.7-22 appears to show 124 egress
vehicles, while the trip generation table shows 143 egress trips.
Response: Acknowledged. The correct trips are shown on DGEIS Figure 5.7-22. The revised trip
generation table to reflect the correction is included in the DGEIS updates (see FGEIS § 4.10 and FEGIS
Appendix F).
5.7-46. Eastbound Clinton Street traffic left-turn and through volumes approaching Turner Place
on Figure 5.7-22 appear to be switched. Please verify that the analysis reflects correct
volumes.
Response: Acknowledged. The corresponding figure has been revised and is presented in the DGEIS
updates (see FGEIS § 4.10 and FGEIS Appendix F).
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5.7-47. Phase 1 and Phase 2 PM Peak development scenarios shown in Figures 5.7-28 and 5.7-
30 show improvement of the eastbound Columbia Street approach to S Aurora Street
relative to background condition. Please verify that this reflects the analysis results
correctly.
Response: Acknowledged. The corresponding figure has been revised and is presented in the DGEIS
updates (see FGEIS Appendix F and FGEIS Appendix G).
5.7-48. There appear to be discrepancies between some vehicles leaving and entering adjacent
intersections on Figure 5.7-23. Additionally, PM trips do not appear to match trip generation
shown in the traffic study trip generation tables.
Response: Acknowledged. The corresponding figures have been revised and are presented in the
DGEIS updates (see FGEIS Appendix F and FGEIS Appendix G).
5.7-49. Figure 2.7-24 shows some trip distribution as percentages and some as actual trips.
Response: Acknowledged. The corresponding figures have been revised and are presented in the
DGEIS updates (see FGEIS Appendix F and FGEIS Appendix G).
5.7-50. No capacity analysis has been provided for the existing roundabout at the Spencer Street/
Albany Street/Park Street intersection.
Response: Acknowledged. The corresponding figures have been revised and are presented in the
DGEIS updates (see FGEIS Appendix F and FGEIS Appendix G).
5.7-51. The “help document” just provided by the applicant indicates (p. 32) that several
intersections on the list have apparently not been studied. The first of these, “State/Tuning
Fork” has, I think, been addressed as “State/Seneca Way,” but the last three (Stone Quarry/
Spencer, S. Meadow Ext./Spencer, and S. Meadow Ext./Elmira) appear from the list on pp.
5-67 and 5-68 to be missing from the DGEIS.
Response: As noted in the DGEIS, Page 5-68, “Reviewing agencies, such as the New York State
Department of Transportation (NYSDOT), use a guideline that if a proposed project is projected to add
100 vehicles per hour (vph), then it should be studied for potential traffic impacts.” Given that the Proposed
Action is anticipated to generation 68 vph or fewer at the S. Meadow Ext./Elmira Road intersection, and
negligible traffic volumes at the S. Meadow Ext./Spencer Road and Stone Quarry Road/Spencer Road
intersections during any of the peak hours, the adjacent intersections and surrounding roadway network
are unlikely to experience any significant adverse traffic impacts; thus, no further study is required. This
is supported by the City of Ithaca and Town of Ithaca in review and acceptance of the September 2014
Phase 1 Scoping/Trip Generation/Trip Distribution Report.
5.7-52. The DGEIS also does not include King Street and Stone Quarry in terms of its parking,
traffic impacts and for the volume of individuals who are coming down from out of town,
I do believe that it will impact those individuals who will just bypass Aurora and go down
Stone Quarry to get into town and that should be included in the traffic analysis.
Response: The comment is acknowledged. Refer to response to Comment No. 5.7-51. Based on the
low projected trips to travel down King Road, the impact from the Proposed Action is minimal.
5.7-53. Analyze existing intersections during peak hour and including the following: Please add
the following intersections into this analysis (pg. 26): ~ Stone Quarry/Spencer Road ~S.
Meadow St. Extension/Spencer Road ~S. Meadow St. Extension/Elmira Road/Meadow St.
Response: The comment is acknowledged. Refer to response to Comment No. 5.7-51.
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5.7-54. The following intersections should be included in the traffic study: a)West King Road/
Stone Quarry Road, b) Stone Quarry Road/Spencer Road, c)Spencer Road/South Meadow
Street Extension, and d)Old Elmira Road/South Meadow Street Extension/South Meadow
Street.
Response: The comment is acknowledged. Refer to response to Comment No. 5.7-51.
5.7-55. What specific ITE land use category was the basis for the trip generation estimate for
a certain land use? What is the pre-adjustment average trip generation rate for the land
use categories? Do the “AM Peak” and “PM Peak” projections represent just one peak hour,
or the two-hour peak ranges (7:00 AM - 9:00 AM, 4:00 PM - 6:00 PM) the DGEIS uses
elsewhere? Also, limiting data and projections to peak hours doesn’t give a full picture
of impacts throughout the day, including vehicle trips during off-peak hours (about 60% of
the total). If applicable, describe any adjustment for purpose-built student housing (lower
vehicle ownership, shuttle service, etc.).
Response: Refer to the TIS in Appendix I1 for a breakdown of the ITE land use categories used for trip
generation purposes. The “AM Peak” and “PM Peak” projections represent trip generation for a one-
hour peak during the two peak periods analyzed. Typically, traffic impact studies analyze traffic during
the peak hours of operation on adjacent roadways and project-related travel. These times reflect the
greatest potential impact of critical movements. Although daily traffic is considered, peak traffic is more
appropriately used if/when traffic control measure changes are needed in the study area. Purpose-built
student housing was not explicitly analyzed as part of the trip generation estimates since that is not part
of the Site program. All residential components were estimated using typical apartment rates within a
denser setting offering a more conservative approach. The inclusion of student housing and available
alternative modes of transportation can reduce overall trip generation estimate.
5.7-56. The Appendix briefly touches on the long-term impacts of a “no build” alternative, but not
the DGEIS. While trip generation numbers for Chain Works seem daunting, its overall
impact should be lower than the alternative -- conventional suburban development that
would otherwise satisfy market demand.
Response: The comment is acknowledged.
5.5-57. The Trip Reduction Adjustments - The methodology for trip generation reduction on pages
5-89 through 5-91 is reasonable, and the adjustment seems conservative.
Response: The comment is acknowledged.
5.7-58. The office, retail and industrial areas in Table 2.7-3 (Anticipated Employee Population)
do not match those of the traffic projections in Table 5.7-4 (Projected Generated Trips).
Which information is correct?
Response: The trip generation rates utilized for the TIS is based on size of the projected land use except
for the residential component which is based on number of units.
5.7-59. Complete streets: Complete Streets consider the needs of all users, including pedestrians,
bicyclists, public transportation riders, motorists and citizens of all ages and abilities,
including children, the elderly and the disabled. The internal street network of the project
should be required to provide sidewalks on both sides of all streets, high-quality pedestrian
crossings, bike lanes, and narrow streets to help calm traffic and promote an urban
neighborhood experience.
Response: Acknowledged. This is a key component of developing the Project in accordance with LEED
ND principles.
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5.7-60. The TIS will estimate the add’l demand for transit. A demand analysis is not included.
The Project Sponsor seems to state that there should be a motor vehicle trip reduction of
4% based on transit, but that’s not a demand analysis. That same paragraph states there will
be a detailed on-Site multi-modal transportation plan including detailed locations and
descriptions of sidewalks, bicycle lanes, trails and pedestrian connections to both IC
and downtown. I don’t see a detailed plan, just some more generalized notes. Maybe
this is still forthcoming because it’s in the mitigation measures section, but it also seems
to be something that was to be included in the TIS.
Response: The Conceptual Site Layout Plan includes detailed locations for sidewalks, trails and
pedestrian connections. Additional specifics on the geometry for lanes and sidewalks are included in the
Design Guidelines under the Thoroughfare Assemblies section. The final details and locations of specific
assemblies will be developed during the site plan review process for individual projects within the CWD.
5.7-61. The Transit and Pedestrian/Bicycle Trip Reduction section states that the transportation
study assumes a 7% trip generation credit for active transportation (bicycling and walking).
This is ambitious considering the Chain Works project is on a hill and reaching the area
from the flats on foot or by bicycle will be a challenge for most users. Chain Works
offers a unique configuration of housing and employment that makes it difficult to predict
how the existing averages from active transportation use from other parts to the Ithaca
Urban area will relate to the project. Except for connecting to Ithaca College, the GEIS
does not make any particular proposals to facilitate bike/pedestrian movement to
destinations outside the project area other than linking to the City’s sidewalk network and
linking the Gateway Trail to the South Hill Recreation Way. I suggest that the developers
work with City staff to identify preferred bike/pedestrian routes to connect the Chain Works
project to outside destinations: the Commons, TCAT’s Green St. bus facility, Cornell
University, west end shopping area, etc. These routes could be considered for enhancements
that will facilitate the effective use of active transportation to access the Chain Works
project. I will gladly meet with project or City representatives to explore potential
enhancements to better connect the project area to the rest of the urban area via active
transportation.
Response: The comment is addressed via a supplemental analysis to the DGEIS. See FGEIS Appendix F.
5.7-62. The On-site Multimodal Transportation Plan calls for the use of sharrows and signage on
roads too narrow to accommodate bike lanes. Sharrows and signs by themselves do not
provide adequate bicycle facilities, nor do they indicate a street is bike friendly. Assuming
the installation of a dedicated bicycle right-of-way - i.e. some form of bicycle lane - is not
possible, the use of sharrows and signs must be accompanied by installation in low traffic
areas and/or by significant traffic calming in order to reduce the speed differential between
cars and bicycles.
Response: The comment is acknowledged. All relevant and required signage and/or markings will be
used when designating a particular roadway, a recognized bicycle facility. All internal roadways are
proposed to be limited to 20 mph speed limit.
5.7-63. If level of service E conditions are documented for any intersections approach to be
monitored, the applicant will be responsible for mitigation of the condition to LOS D
or better before additional development can occur. This criteria is consistent with NYSDOT’s
standards for operation, so all study intersections will be subject to the same evaluation
criteria. If no physical mitigation is identified due to technical infeasibility, the applicant
will be required to document a reduction in site trips to the intersection through TDM
or other measures allowing for LOS D or better operations for all movements before
further development can occur. Regarding the Turner Place and Cayuga Street corridors,
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the applicant will be responsible for ensuring that acceptable traffic operations are
maintained along these midblock sections and that traffic volumes do not cause a change
in the character of these roadways.
Response: It is our understanding that existing conditions, such as an LOS of E, are not the responsibility
of the Project Sponsor and that mitigation by the Project Sponsor is commensurate of its Project impacts.
The Project Sponsor will be required to obtain permits through the NYSDOT and will be obligated to
comply with its standards of mitigation.
5.7-64. The Phase 1 site access scheme and internal transportation network cannot be identified
completely or agreed on until the specific locations associated with Phase 1 are finalized.
The extent of the initial phase of development and its location within the site will dictate
what access points need to be developed and whether they should be signalized. This will
involve collaboration between the City and State to determine.
Response: The comment is acknowledged.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.8 (Utilities):
5.8-1. In DGEIS Figure 5.8-1, the existing water main that crosses the site from east to west to the
railroad bed is 12 inches in diameter, not 8 inches as shown in the figure.
Response: Figure 5.8-1 in the DGEIS has been revised accordingly. See updated figure in § 4.11 and
at the end of Chapter 4 of the FGEIS.
5.8-2. All water mains should be looped and contain as few dead ends in the system as possible.
Response: Acknowledged. The final design of all utilities will be addressed during the site plan review
process for individual projects within the CWD.
5.8-3. The sanitary sewer main that parallels NYS Route 96B leaked during the 1980s. There is a
concern that this caused contamination.
Response: Acknowledged. See Public Health Subsection 5.5.1.9, on page 5-56 of FGEIS Appendix G
for discussion.
5.8-4. Housing in area CW-2 is downhill from the existing sanitary sewer service. The sanitary
sewer for this housing area would need to be pumped uphill to the existing gravity sewer.
If the proposal involves multiple owners (e.g. HOA), then the developer will need to set up
a Sewage Works Corporation for maintenance of these facilities.
Response: Acknowledged. The final design of all utilities will be addressed during the site plan review
process for individual process for projects within the CWD. The intent of the Project Sponsor is that the
Property will be under single ownership.
5.8-5. You have a goal of 70% fossil fuel reduction. What is this a reduction from? How will it be
monitored?
Response: Architecture 2030 states that all new buildings, developments and major renovations shall be
designed to meet a fossil fuel, GHG-emitting, energy consumption performance standard of 70% below
the regional (or country) average/median for that building type. The 70% fossil fuel reduction referenced
in the DGEIS is compared to conventional buildings of the same occupancy and type at this time. This
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can be achieved in many ways including more reliance of on/off-Site renewable energy, higher efficiency
MEP systems and/or building envelope improvements. The DGEIS and the Conceptual Site Layout Plan
is conducive to allowing the integration of renewable energy systems as outlined in the Architecture 2030
Challenge with a goal of a 70% reduction of fossil fuel usage as stated in Section 2.6.3. This strategy
exceeds the NYS Energy Conservation Construction Code and the goals set forth in the DGEIS are in
alignment with the Tompkins County Energy Roadmap goals.
5.8-6. The DGEIS should consider mitigation strategies that exceed NYS Energy Conservation
Construction Code standards so that the Tompkins County Energy Roadmap goals for
2050 are met.
Response: See Response to Comment No. 5.8-5.
5.8-7. The DGEIS should also consider mitigation strategies to allow more integration of
renewable energy systems.
Response: See Response to Comment No. 5.8-5.
5.8-8. The document states that the extent and details of the stormwater facilities on site are not
completely known or understood. When will we know the extent of the stormwater system
and how stormwater can be management be evaluated without this knowledge?
Response: The conceptual stormwater management plan for the entire Project Site is outlined in the
DGEIS. Final stormwater management designs and a SWPPP based on the conceptual plan will be
addressed during the site plan review process for individual projects within the CWD.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.9 (Air Quality):
No Comments Received.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.10 (Visual and Aesthetic Resources):
5.10-1. Finer grained visualization showing more information about proposed heights, and
sections are needed to understand this relationship between height and topography.
Response: The Proposed Action calls for a maximum area of 568,300 s.f. of new development in the
CW2 Sub Area that can range from one-story up to four-stories in height. This maximum area can be
achieved by constructing buildings of varying heights. The originally referenced visuals use three-story
structures as the basis of achieving the proposed maximum development in this subzone, which are the
maximum allowed along NYS Route 96B as proposed in the PUD/PDZ. See FGEIS § 4.14. The use of
the white/light colored structures was determined for ease of review in building massing. Actual building
materials/colors will be developed during the site plan review process for individual projects within the
CWD.
5.10-2. DGEIS Figure 5-10c is remarkable in that the new buildings are at the highest point of the
site and appear to tower over the existing. More information should be provided.
Response: See Response to Comment No. 5.10-1.
5.10-3. The visual analysis is thorough. However, the photos related to the conceptual structures
along Aurora Street/Route 96B (DGEIS pages 5-171, 5-183, 5-190, 5-192), only show three
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story structures.
Response: See Response to Comment No. 5.10-1.
5.10-4. The photos from West Haven Preserve were actually taken from the EcoVillage fields above
the preserve (Page 5-168, Figure 5.10-1).
Response: Acknowledged. See Response to Comment No. 5.10-1.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.11 (Community Services):
5.11-1. Correspondence with ICSD indicated that planning would be necessary to accommodate
50 children in some situations. The DGEIS does not address how a potential influx of
children would be facilitated/planned with ICSD.
Response: The planning necessary to receive the additional school-aged children is the responsibility
of Ithaca City School District (ICSD). The purpose of the GEIS is to ensure that the ICSD will not be
negatively impacted by CWD. The number of students were estimated by the Project Sponsor based on
the anticipated Site development. Additional State Aid and the related ad valorum taxes associated with
the development will provide the financial means for ICSD to implement facility planning, if it is deemed
necessary by the District. Coordination with ICSD, an Interested Agency to the Project, is ongoing.
Updates on Site development will be sent to the ICSD during the site plan review process for individual
projects within the CWD.
5.11-2. Does the school tax revenue take into account the STAR Rebate?
Response: The Project Sponsor understands that the STAR Rebate provides property tax relief.
Residents are eligible for STAR if they own their own house as a primary residence and have a combined
income of less than or equal to $500,000. The CWD DGEIS makes no mention of the STAR Rebate and
how it would affect tax revenue. For those that qualify for STAR property tax relief, they would receive a
STAR credit in the form of a check, rather than receiving a property tax exemption. The dollar value of the
credit will be the same as the property tax exemption. Because the household receives a STAR credit,
property tax revenue for the school system should remain the same.
5.11-3. The Commenter disagrees with the DGEIS estimate for school age children and provides
their own estimate that the CWD will create a demand of 119 elementary school students.
Further discussion on existing school population and potential impact based on the
Commenter’s estimate should be stated and discussed with ICSD.
Response: The comment is acknowledged. See response to Comment No. 5.11-1.
5.11-4. It would be helpful to know the cost of full time police officers.
Response: In 2011, the last year the City of Ithaca and the Ithaca PBA had a contract, the current salary
for a police officer at the Ithaca Police Department is $70,000. The benefit package for each police officer
costs the City of Ithaca an additional $49,000 dollars. With those two amounts combined, each police
officer costs the City of Ithaca approximately $119,000. As of the writing of the comment response, the
Ithaca Police Department has 66 sworn officers.
The Sheriff’s Office contract has expired and is currently in arbitration. The current salary for a work rate
deputy is $65,000 plus fringe benefits. The Tompkins County Sheriff’s Office has 27 full time deputies.
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The following comment summaries and responses are associated with information presented in DGEIS
Section 5.12 (Open Space and Recreation):
5.12-1. Please provide trail connections through the CW1 Zone.
Response: Acknowledged. See Revised Conceptual Site Layout Plan that depicts conceptual locations
for recreational areas. See updated FGEIS Figure 2.3-2 at the end of Chapter 4. The actual design of
the recreation/public amenity areas will be developed during the site plan review process for individual
projects within the CWD.
The following comment summaries and responses are associated with information presented in DGEIS
Section 5.13 (Construction Activities):
5.13-1. There’s going to be fugitive dust problems.
Response: Mitigation for construction dust is governed by the required the NYSDEC SPDES Permit
for General Construction (GP-0-15-002). This includes developing a Full SWPPP for each individual
Phase that requires dust control, temporary soil cover, erosion blankets and other standard BMPs. Also,
a CAMP will be developed as required by the NYSDEC as part of the RI.
5.13-2. Where is the cut & fill analysis for Phase 1?
Response: See Figure 5.2-3 in Section 5.2.2 of the DGEIS for the cut & fill analysis for the entire site
based on the Conceptual Site Layout Plan. Each site plan review package will include a cut & fill analysis
as part of the design of each individual phase and will be reviewed by the applicable Planning Board at
that time to ensure no adverse impacts that are not addressed in the GEIS.
5.13-3. Blasting may be required in certain areas. Therefore, it would make sense to outline the
environmental impacts and mitigations to prevent reopening on the GEIS review later.
Response: Section 5.2.3 of the DGEIS outlines standard mitigation if controlled blasting is required.
5.13-4. We recommend that the FGEIS include a means to mitigate community impacts during
construction.
Response: Section 5.13.3 of the DGEIS delineates mitigation measures for construction impacts to the
community.
The following comment summaries and responses are associated with information presented in DGEIS
Chapter 8 (Growth Inducing Impacts and Character of Community):
8-1. The format of the Scoping Document is different than the DGEIS making it harder to review.
Chapter 8 of the DGEIS reads like an advertisement.
Response: During the development of the DGEIS, the Project team changed the structure of this
Chapter based on comments by City/Town Staff however all of the content listed in the Scoping
Document is covered in the DGEIS. Chapter 8 specifically focuses on the how the investment in the
Project impacts growth and community character. This chapter outlines how this Project aligns with
many of the planning initiatives outlined in City/Town documents such as the Comprehensive Plans.
The following comment summaries and responses are associated with information presented in DGEIS
Section 8.2 (Economy / Tax Base):
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8.2-1. The property value increase is not netted out in a figure for the actual tax revenues on the
re-assessed property.
Response: From Scoping: “The Project would provide jobs, economic stimulus and tourism. These
impacts will be estimated based on the Project’s anticipated construction cost and employment.” The
existing assessment on the property is $3,500,000. After full development, the assessment of the Property
is estimated at $236,000,000 by the County Assessor. The ultimate assessment is determined by the
Assessor and the tax rate is set by the individual municipality/district. The tax revenue, as estimated with
2016 data, from the re-assessed property value will be $4.3M for the Ithaca City School District (DGEIS
Table 5.11-4), $1.55M for the Town of Ithaca and $2.39M for the City of Ithaca (DGEIS Table 5.11-2). All
estimates are based on the Conceptual Site Playout Plan presented in the DGEIS as well as current tax
rates.
8.2-2. There is no attempt at all to gauge the effects of an increase in tourism (if any).
Response: It is not anticipated that the CWD will be a large tourism generator. For example, no
destination type attractions are included in the Conceptual Site Layout Plan however it is the Project
Sponsor’s intention to hold public events within the development.
The following comment summaries and responses are associated with information presented in DGEIS
Section 8.3 (Population / Demographics):
8.3-1. There is no attempt made to provide, as required, the projected number or percentage of
the proposed 900+ residential units that will fall into each of size and type categories or
associated pricing.
Response: Of the proposed 915 units, it is anticipated that approximately 7% will be studio units, 55%
one-bedroom units, 20% two-bedroom units, 3% three-bedroom units and 15% townhouse units. These
are based on preliminary conceptual studies of the existing and proposed new development and subject
to change as the Project is developed over its anticipated 7-10 year timeframe. The actual distribution
of constructed unit types will be determined by market-driven needs at the time of design and site plan
review process for individual projects within the CWD. As indicated in Section 8.3, the average 2-bedroom
unit is expected to rent for approximately $2,400 based on the current market for similar units.
8.3-2. The Project Sponsor does not identify the geographic boundary of the housing market
study nor specific consumer market demographic.
Response: The purpose of the GEIS is to address broad planning questions and long-term, cumulative
environmental impacts from the development of the Project. The market study data is provided in this
context to generally assess local conditions. The DGEIS presents information about existing housing
stock, vacancy rates and the positive impact of the proposed 915 dwelling units to the existing housing
shortage in the Ithaca area. The DGEIS references the Downtown Ithaca Alliance’s 2012 study performed
by the Danter Company which concludes that there is a demand for over 1,350 unit in the downtown Ithaca
area. Tompkins County is in the process of drafting the Tompkins County Housing Needs Assessment.
When this assessment is finalized and as other housing studies are performed, the Planning Boards will
reference the most up to date studies during the site plan review process for individual projects within
the CWD.
8.3-3. No inclusion of primary data for the housing market analysis.
Response: See Response to Comment No. 8.3-2.
8.3-4. In DGEIS Section 2.7.7 the anticipated population is 1,830 for the 915 dwelling units and
Section 8.3 estimates 1.75 adult residents per dwelling unit. No reference is provided to
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February 10, 2019Chapter 3: Comments and Responses to
Comments
Final Generic Environmental Impact Statement
the inconsistent estimates.
Response: Acknowledged. Section 8.3 of the DGEIS will be revised to match the total anticipated
residential population of 1,830.
8.3-5. The Rutgers Study cited by the Commenter presents their own estimate of population and
believes that the existing municipal recreational programs for youth/seniors fall short of
meeting demands in available resources, physical space and funding.
Response: The population estimate set forth in the DGEIS was developed based on the Site development
plan. The Site will be programmed for such uses as outdoor markets, gatherings, festivals, community
events, maker / artist spaces, galleries, and other uses, in partnership with engaged cultural organizations.
The CWD will provide the opportunity for community groups that serve a diverse population to develop
specific social, cultural, and recreational programs to meet their specific needs. Potential partners in
programming these spaces might be such groups as the Ithaca Youth Bureau, the YMCA, Cornell
Cooperative Extension, ScienCenter, Tompkins County Public Library, Community School of Music and
Arts, Greater Ithaca Activity Center, the Ithaca Children’s Garden, Lifelong, Office for the Aging, Southside
Community Center, Northside Community Center, Ithaca Generator, as well as potential partnerships
with local colleges and universities. As the Project is developed, these issues will be reassessed during
the site plan review process for individual projects within the CWD to ensure that no adverse impacts
have not been addressed in the GEIS.
The following comment summaries and responses are associated with information presented in DGEIS
Section 8.4 (Gentrification):
8.4-1. The DGEIS does not have adequate detail to address existing market demand, the potential
impacts of the proposed housing portion of the Project and gentrification of urban areas.
Response: The purpose of a GEIS is to address broad planning questions. See Comment Responses
for Section 8.3 regarding the existing market demand and the potential impacts of the proposed housing
portion of the Project. The DGEIS cites the 2012 DIA Housing Market Demand Study which documents
a need for up to 1,350 units in the downtown area. The proposed 915 dwelling units in CWD will assist
in meeting that demand.
As to the third part of the Comment, gentrification is defined generally as the arrival of wealthier people
in an existing urban residential district which includes a related increase in rents and property values.
This in turn changes the district’s character and culture. The term is often used negatively, suggesting the
displacement of poor communities by rich outsiders. The DGEIS finds that the proposed project does not
displace any residents therefore on-Site gentrification will not occur.
Gentrification generally occurs in areas where commercial and residential land is cheap relative to other
areas within the City. A review of recently sold properties indicate the transactions within the South Hill
area are similar if not slightly higher than the average sales price in other residential areas of the City.
For example, there are two single-family residential properties currently listed for sale in the immediate
vicinity of the Project site at $297,000 and $299,000. There are three comparable properties for sale on
W. Green and W. Clinton Streets (Near NYS 34) for $152,000, $163,000 and $199,000. Therefore, this
area of the City/Town does not lend itself to gentrification.
The proposed Project will improve the overall neighborhood but it is not anticipated to have large impacts
to the overall tax assessments to the adjacent parcels. In fact, the added tax base should help stabilize
City, Town, School District and other associated tax districts by increasing the tax base by an estimated
$236M according to the County Assessor (DGEIS Table 5.11-4).
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February 10, 2019Chapter 3: Comments and Responses to
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Final Generic Environmental Impact Statement
As outlined in the SEQR Handbook, the DGEIS demonstrates how the proposed action is capable of
serving a public use, benefit, or purpose. Specifically answering the Comment, the proposed project
provides additional housing to reduce gentrification pressures on other areas of the community and
provides increased tax revenues through additions to the local taxable base and fulfillment of shopping.
8.4-2. While gentrification is a “difficult phenomenon to measure”, this does not exempt the
applicant from presenting a more in-depth analysis than the one page that is currently
offered.
Response: See Response to Comment No. 8.4-1.
8.4-3. There is no evidence that the Project Sponsor has attempted to address gentrification as
it specifically relates to the scale of the proposed Project.
Response: See Response to Comment No. 8.4-1
8.4-4. Discuss the gentrification of urban areas and the impacts to the City and Town with a
concentration on the scale of the development and tax revenues.
Response: See Response to Comment No. 8.4-1
The following comment summaries and responses are associated with information presented in DGEIS
Section 9 (The Use and Conservation of Energy):
9-1. The DGEIS is vague as to what specific alternative energy sources will be utilized. Also,
the Project is included in the City of Ithaca NY Prize Grant; provide more details of the
Study.
Response: The purpose of the GEIS is to address broad planning questions. The timeframe for the
development of the Project is 7 to 10 years. The means of generating alternative energy is rapidly changing
such that today’s state of the art technology will be obsolete when implementing later phases of the CWD
development. Therefore, the DGEIS approach is to state generically the multiple alternative energy
techniques may be utilized with a specific performance goal of achieving at least a 70% reduction in fossil
fuel use in compliance with the Architecture 2030 Challenge. See also response to Comment No. 2.5-7.
The following comment summaries and responses are associated with information determined to be
Errata / Clarifications:
Errata 1. Chapter 3 is mislabeled in the DGEIS. Also, the maximum development scenario was
reduced from 2.65 MSF in the Scoping Document to 2.125 MSF in the DGEIS.
Response: Noted and corrected. During the development of the DGEIS, it was determined that the 2.65
Thousand Square Foot (MSF) maximum development scenario was not feasible therefore that alternative
analysis was scaled back to 2.125 MSF.
Errata 2. Clarify that specific City zoning regulations do not apply to the Town and vice versa.
Response: Acknowledged. The PUD/PDZ outline specific regulations for development within the CWD
by Sub Area. Where applicable, the PUD/PDZ utilizes existing City/Town regulations. The intent of
this reference is quite clear, which is to allow the same form and intensity of uses across municipal
boundaries to avoid conflicting ordinances. The documents were revised in different manners during the
development of the separate regulations with each municipality. The PUD and PDZ are two separate and
distinct documents that reflect the zoning priorities of the City and Town, respectively.
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Final Generic Environmental Impact Statement
CHAIN WORKS DISTRICT
February 10, 2019Chapter 4: Description of Changes to DGEIS
Final Generic Environmental Impact Statement
Chapter 4:
Description of Changes to
the DGEIS
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
CHAPTER 4: DESCRIPTION OF CHANGES TO THE DGEIS
4.1 Introduction
This chapter of the FGEIS discusses changes to the DGEIS resulting from public/agency comments
on the DGEIS, Project redesign/refinement since the DGEIS, or the development of additional relevant
information that was not available at the time of publication of the DGEIS. The text in this chapter
predominately addresses Chapter 2 through 5 of the DGEIS. To help guide readers through this FGEIS
and identify how the DGEIS is revised for all sections except Sections 5.5 and 5.7, the FGEIS presents
revisions by the following method: the following sections include gray, highlighted text that indicates the
type of action for the text (e.g. UPD ATE, REPLACE, ADD, and SUPPLEMENT). The subsequent italic
text provides additional direction to where the change occurs within the chapter, and a brief explanation
of why the change had been made. Following the italic text is the actual text amending the DGEIS.
Because the revisions to Sections 5.5 (Public Health and Environment) and 5.7 (Transportation and
Circulation) are so numerous, the FGEIS presents their revisions by producing completely rewritten
sections. Appendix G of the FGEIS presents comparisons of the fully revised sections found in this
chapter against the sections found in the DGEIS so one can determine what revisions were made to the
DGEIS.
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
4.2 DGEIS Chapter 2: Project Description
REPLACE:
Figure 2.1-2 in DGEIS Section 2.1 (now know as FGEIS Figure 2.3-2) is updated to address comments
provided during the DGEIS. Major revisions include the addition of conceptual trail system in the CW1
Sub Area and the removal of the site access drive near buildings N17 and N18.
UPDATE:
During the review process for the PDZ/PUD Zoning Regulations and Design Guidelines, additional
differentiation was requested by the City and Town for the CW2 and CW3 Sub Areas. Both Sub Areas
have been split to include additional requirements. The following text updates the Sub Area listing:
By rezoning the Site, it will be divided into four (4) Sub Areas (FGEIS Figure 2.1-3) defined as:
• Natural Sub Area (CW1)
• Neighborhood General Sub Area (CW2A/B)
• Neighborhood Center Sub Area (CW3A/B/C)
• Industrial Sub Area (CW4)
FGEIS Figure 2.3-2: Overall Conceptual Site Layout Plan (Project Team) *
LOADINGDOCK
LOADINGDOCK
10
8
10
RetainingWall
N16
LOADINGDOCK
N1
N2
N3
N5
N6
N7
N9
N10
N11
N12
N17
N20
N27
N31
N30
N29
N33
N34
N35
N36
N38
N32
N28
N13
N14
N15
N37
N18
N19
N21
N22
N23
E2-6
N24
N25
N26
N8
N4
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
Sub Area Permitted Uses
Natural Sub Area (CW1)Public Passive Recreation; Public and semi-public institution whose
purpose is education; Public Pavilions; and sheds related to the
maintenance of the Sub Area.
Neighborhood General Sub Area (CW2)a) Any Residential use as defined by The Building Code of New York
State.
b) Nursery school, child day care center.
c) Bed and Breakfast Homes and Inn.
d) In-home occupations with no more than 2 employees.
Neighborhood Center Sub Area (CW3)Same as CW2 excluding detached dwellings and including the
following:
a)Any Assembly, Business, Educational, Factory, Mercantile or
Storage use as defined by The Building Code of New York State.
Industrial Sub Area (CW4)Any Business, Factory or Storage use as defined by The Building
Code of New York State.
FGEIS Table 4-1
CW1
CW3A
NATURAL SUB AREA (CW1)
TOTAL ZONE AREA - 1,039,404 GSF / 23.86 ACRES +/-
NEIGHBORHOOD GENERAL SUB AREA (CW2)
TOTAL ZONE AREA - 922,274 GSF / 21.17 ACRES +/-
CW4
NEIGHBORHOOD CENTER SUB AREA (CW3)
TOTAL ZONE AREA - 1,730,639 GSF / 39.73 ACRES +/-
INDUSTRIAL SUB AREA (CW4)
TOTAL ZONE AREA - 447,340 GSF / 10.27 ACRES +/-
CW2A
CW2B
CW1CW3B
CW3C
CW3B
FGEIS Figure 2.3-3: PUD / PDZ Sub Area Boundary Map (R+W) *
REPLACE:
Figure 2.1-3 in DGEIS Section 2.1 (now known as FGEIS Figure 2.3-3) is replaced with the following
that includes additional Sub Area differentiation for CW2 and CW3.
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
REPLACE:
The following text in the corresponding portion of DGEIS Section 2.1 after Table 2.1-1 is replaced to
reflect Project refinement during the PDZ/PUD review.
Both the PDZ and PUD will have a set of Design Guidelines (Appendix D1 and D2) that will serve as one
mechanism to mitigate potential significant adverse impacts. The Design Guidelines provide guidance
during the site plan review process for individual projects within the CWD including, but not limited to,
buffer areas, compact development, multimodal circulation network, public lighting, setbacks, building
lot coverage rates, building heights, building disposition, frontage build out, allowable usage, signage,
parking layouts, common areas and plazas, conservation plan(s) for natural areas, and other typical
development aspects.
REPLACE:
Figure 2.4-2 in DGEIS Section 2.4 has been updated with the following to match the revisions to FGEIS
Figure 2.3-2.
REPLACE:
The following portion of text in the DGEIS Section 2.6.3: “The Site is also currently part of a NY Prize
Microgrid feasibility study sponsored by the City where it has been proposed to house power generation
of 5 MW up to 15 MW. This can meet the needs of the development, as well as critical services in the
surrounding area. Most prominently, the development of a microgrid could support neighboring Ithaca
College, the largest consumer of electricity in the South Hill neighborhood.” is replaced to reflect revisions
to the Microgrid feasibility study being performed by others as follows:
The Project Sponsor is investigating multiple renewable energy system elements to be finalized during
the site plan review process for individual projects within the CWD.
REPLACE:
The term “Design Standards” with “Design Guidelines” in DGEIS Section 2.7 as part of the review process
with the City and Town in the final development of the zoning regulations.
REPLACE:
The following text in the corresponding portion of DGEIS Section 2.7.3 is replaced to reflect Project
refinement during the PDZ/PUD review.
This Sub Area allows residential, commercial, and industrial. The total area of building footprint within
the Sub Area may not exceed 80% of the total size of the CW3 Sub Area. Façade lengths will be limited
to 180 feet by right and 250 feet conditional. In the CW3A Sub Area, development is limited to 4 stories.
Development in the CW3B Sub Area is limited to 6 stories, allowing for an additional 1-2 stories on the
downhill side. Story height of any new building will be limited to 24 feet.
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
4.3 DGEIS Chapter 3: Reasonable Alternatives
There are no revisions or updates to this Chapter.
4.4 DGEIS Chapter 4: Public Participation
There are no revisions or updates to this Chapter.
4.5 DGEIS Chapter 5: Section 5.1 – Land Use and Zoning
SUPPLEMENT:
The following text supplements the CW2 Sub Area description in DGEIS Section 5.1.3.2:
The CW2 Sub Area has been split into two subsections, CW2A and CW2B to further delineate allowable
uses at the request of the Town of Ithaca during the review of the PDZ. The major difference between
the CW2A and CW2B is the removal of Apartment buildings, Courtyard buildings and Main Street Mixed
Use buildings in the CW2A.
SUPPLEMENT:
The following text supplements the CW3 Sub Area description in DGEIS Section 5.1.3.2:
The CW3 Sub Area has been split into two subsections, CW3A and CW3B to further delineate allowable
uses at the request of the Town of Ithaca during the review of the PDZ. The major difference between
the CW3A and CW3B is the number of allowable stories. In the CW3A Sub Area, development is limited
to 4 stories. Development in the CW3B Sub Area is limited to 6 stories, allowing for an additional 1-2
stories on the downhill side.
REPLACE:
Replace the term “Design Standards” with “Design Guidelines” in DGEIS Section 5.1.4 as part of the
review process with the City and Town in the final development of the zoning regulations.
REPLACE:
Replace the term “Design Standards” with “Design Guidelines” in DGEIS Section 5.1.4.2 as part of the
review process with the City and Town in the final development of the zoning regulations.
REPLACE:
Replace Table 5.1-4 in DGEIS Section 5.1.4.2 as required during the refinement of the PUD/PDZ Zoning
Regulations with the City and Town.
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
REPLACE:
Replace the term “Design Standards” with “Design Guidelines” in DGEIS Section 5.1.4.3 as part of the
review process with the City and Town in the final development of the zoning regulations.
4.6 DGEIS Chapter 5: Section 5.2 – Land
There are no revisions or updates to this Section.
4.7 DGEIS Chapter 5: Section 5.3 – Water Resources
There are no revisions or updates to this Section.
4.8 DGEIS Chapter 5: Section 5.4 – Vegetation and Fauna
There are no revisions or updates to this Section.
4.9 DGEIS Chapter 5: Section 5.5 – Public Health and Environment
See Appendix G.
4.10 DGEIS Chapter 5: Section 5.6 – Historic and Archaeological Resources
There are no revisions or updates to this Section.
4.11 DGEIS Chapter 5: Section 5.7 – Transportation and Circulation
See Appendix G.
4.12 DGEIS Chapter 5: Section 5.8 – Utilities
Figure 5.8-1 in DGEIS Section 5.8.1 is revised and replaced to capture the correct size (12” diameter)
of the east-west existing watermain. Included at the end of this Chapter.
4.13 DGEIS Chapter 5: Section 5.9 – Air Quality
There are no revisions or updates to this Section.
4.14 DGEIS Chapter 5: Section 5.10 – Visual and Aesthetic Resources
There are no revisions or updates to this Section.
4.15 DGEIS Chapter 5: Section 5.11 – Community Services
There are no revisions or updates to this Section.
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
4.16 DGEIS Chapter 5: Section 5.12 – Open Space and Recreation
SUPPLEMENT:
The following text supplements DGEIS Section 5.12.3 – Mitigation Measures
The City of Ithaca and its Consultants published a draft Parks and Recreation Master Plan in November
2017. Section 2.2.1 of the Plan highlights the future connection of the Gateway Trail/Buttermilk Falls
Corridor as one of the key planned trail system enhancements.
4.17 DGEIS Chapter 5: Section 5.13 – Construction Activities
There are no revisions or updates to this Section.
4.18 DGEIS Chapter 6: Irreversible and Irretrievable Commitment of Resources
There are no revisions or updates to this Chapter.
4.19 DGEIS Chapter 7: Unavoidable Adverse Effects
REPLACE:
The following text replaces the corresponding portion of DGEIS Section 7.2 to reflect Project redesign
and refinement.
• Energy Use – There will be energy requirements for the proposed uses. The Project is planned in
accordance with LEED ND and Architecture 2030 energy conservation principles. See Sections
5.8 and Chapter 9.
4.20 DGEIS Chapter 8: Growth Inducing Aspects and Character of Community
REPLACE:
The following text replaces the corresponding portion of DGEIS Section 8.1 to reflect Project refinement
and to reference a new City planning document.
The Project will also enhance recreational opportunities for residents and visitors of the Site. As Section
5.12 describes, the addition of the Gateway Trail as a connection between other surrounding trail
networks will create continuity within the overall network and increase recreational opportunities for the
Ithaca area. The City of Ithaca and its Consultants published a draft Parks and Recreation Master Plan
in November 2017. Section 2.2.1 of the Plan highlights the future connection of the Gateway Trail/
Buttermilk Falls Corridor as one of the key planned trail system enhancements. The Project’s open space
network will allow for both active and passive recreational opportunities, with flexible outdoor spaces
to hold community events and markets. The CW1 Sub Area will be a conservation zone for passive
recreational opportunities to take place for activities such as hiking, birding, and snowshoeing.
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February 10, 2019Chapter 4: Description of Changes to the DGEIS
Final Generic Environmental Impact Statement
REPLACE:
The following text replaces the corresponding portion of DGEIS Section 8.3 to provide consistency with
DGEIS Section 2.7.7.
Based on an assumed 2.0 adult residents per housing unit, the Project will house more people than it
employs.
4.21 DGEIS Chapter 9: Effect of the Propose Project on the Use and Conservation of Energy
DELETE:
Delete references to the Ithaca Community Microgrid in DGEIS Chapter 9 to reflect the Scope change in
the Microgrid Study where the Consultant reduced the study area to remove the South Hill section
LOADINGDOCKLOADINGDOCK10810RetainingWallN16LOADINGDOCKN1N2N3N5N6N7N9N10N11N12N17N20N27N31N30N29N33N34N35N36N38N32N28N13N14N15N37N18N19N21N22N23E2-6N24N25N26N8N4FGEIS FIGURE 2.3-2OVERALL CONCEPTUAL SITE LAYOUT PLAN (PROJECT TEAM) *
CW1CW3ANATURAL SUB AREA (CW1)TOTAL ZONE AREA - 1,039,404 GSF / 23.86 ACRES +/-NEIGHBORHOOD GENERAL SUB AREA (CW2)TOTAL ZONE AREA - 922,274 GSF / 21.17 ACRES +/-CW4NEIGHBORHOOD CENTER SUB AREA (CW3)TOTAL ZONE AREA - 1,730,639 GSF / 39.73 ACRES +/-INDUSTRIAL SUB AREA (CW4)TOTAL ZONE AREA - 447,340 GSF / 10.27 ACRES +/-CW2ACW2BCW1CW3BCW3CCW3BFGEIS FIGURE 2.3-3PUD/PDZ SUB AREAS
EPT SUBSTATIONCODDINGTON - SOUTHHILL 34.5 kV LINE #526NYSEG SOUTH HILLSUBSTATIONDOMINION GASTRANSMISSION MAINFGEIS FIGURE 5.8-1EXISTING SITE UTILITIES
Chain Works District
PDZ Draft 1-30-2019
1
LOCAL LAW NOO OF THE YEAR 2019
A LOCAL LAW TO AMEND ZONING CHAPTERS 270 AND 271 OF THE TOWN OF ITHACA CODE TO PROVIDE A PLANNED
DEVELOPMENT ZONE FOR THE CHAIN WORKS DISTRICT
Be it enacted by the Town Board of the Town of Ithaca as follows:
Section 1. Chapter 270 of the Town of Ithaca Code, Article IV, § 270-6 entitled “Enumeration of zones” is amended by
adding at the end of subdivision A thereof the following:
Planned Development Zone NoO 16 - In accordance with and pursuant to Local Law NoO _- 2019 [Chain Works District]
Section 2. Chapter 271 of the Town of Ithaca Code is hereby amended by adding Section 271-17: Planned Development
Zone NoO 16 - In accordance with and pursuant to Local Law NoO _- 2019 [Chain Works District]
271-17.1 Introduction
The Comprehensive Plan recommends focusing new development where adequate infrastructure and services exist, near major
employers and transit services, and in a manner that promotes sustainability, energy efficiency, walkability, and connectivityO
The Chain Works District, located in both the City of Ithaca and the Town of Ithaca, is uniquely positioned to take advantage of
the site’s close proximity to existing neighborhoods, downtown, and Ithaca CollegeO The Chain Works District is designed to
transform the former Emerson manufacturing plant into a productive mixed-use neighborhood that promotes sustainability
and provides an array of community benefits supported in the PlanO
The Planned Development (PD) zone enables and guides the repurposing of the former factory buildings, along with new
construction on undeveloped portions of the 95-acre site, into a mixed-use community that consists of residential, office,
commercial, retail, industrial, recreational and open space usesO This PD zone uses a form-based zoning strategy, with objective
yet flexible standards that are intended to create an aesthetically pleasing neighborhood and foster a sense of community and
connectivity with the surrounding city and town neighborhoodsO
The design for the development follows traditional neighborhood development (TND) principles and features a distinctive mix
of uses and densities that exceed or differ from what Town Code §270 (zoning) allows in the Industrial zone or other current
zoning districtsO New construction will include a variety of housing types and building configurations, storefront space for
neighborhood commercial uses, and an interconnected grid of streets and pathways that will link the project to the Gateway
Trail and connect to the greater South Hill neighborhood in the city and the townO
The development will also:
• Create an identifiable community that bridges the city and town by reactivating a property with an idle industrial
complexO
• Protect environmentally valuable and sensitive areas by limiting all intense new development to approximately one-
third of the 95-acre property, while retaining open space as an ecological and recreational amenity for the
neighborhood and surrounding community
• Encourage a vibrant and walkable mixed-use neighborhood, designed to accommodate pedestrians and cyclists with
pedestrian-oriented pathways and streets that encourage walking, biking, car sharing, and public transit, and
• Provide much-needed housingO
271-17.2 Transect subarea
A transect subarea defines parts of the larger site that will have certain physical and functional characteristicsO There are six
transect subareas in the PD site areaO Figure 1 is an illustrative example of transect subarea location and allocationO
Chain Works District
PDZ Draft 1-30-2019
2
CW1 Natural Subarea ❶
Total zone area: 1,039,404 GSF / ±23O85 acres
CW2A, CW2B Neighborhood general subarea ❷ ❸
Total zone area: 922,274 GSF / ±21O17 acres
CW3A, B Neighborhood center subarea ❹ ❺
Total zone area: 1,730,639 GSF / ±39O73 acres
CW4 Industrial subarea ❻
Total zone area: 447,340 GSF / ±10O27 acres
❶ CW1: Natural subarea. This subarea consists of lands approximating or reverting to a natural state including lands
unsuitable for development due to topography and hydrologyO CW1 is intended for preservation as open space, with uses
limited to passive recreational activitiesO Development is limited to trails and small structures associated with grounds upkeep
and visitor amenities (iOeO pavilion, visitor comfort station, maintenance shed)O
❷ CW2A: Neighborhood general subareaO This subarea is a locale for primarily residential uses in a compact, pedestrian-
scaled neighborhood settingO The subarea allows limited complimentary commercial usesO Building types include detached
dwellings, 3-4 unit dwellings, townhomes, and mixed use buildingsO Because of its topography and prominent location
adjacent to Danby Road, this subarea limits building types to those having a smaller-scale and lower height, to complement
the streetscape pattern found elsewhere along the Aurora Street/Danby Road corridorO Setbacks and landscaping are variableO
Streets with curbs and sidewalks define medium-sized blocksO
❸ CW2B: Neighborhood general subarea. This subarea is a locale for primarily residential uses in a compact, pedestrian-
scaled neighborhood settingO This subarea allows limited complimentary commercial usesO The CW2B subarea allows all uses
and building types that the CW2A subarea allowsO The CW2B subarea also allows building types having a greater mass and
height, given its downhill location away from the nearby Danby Road/Aurora Street corridorO
❹ CW3A: Neighborhood center subarea. This narrow subarea along the roadway corridor is a locale for a mix of uses,
including residential and commercial, in a dense, pedestrian-scaled urban settingO This subarea allows a wide variety of
building types, but given its prominent location along the Aurora Street/Danby Road, development heights are limitedO
❺ CW3B: Neighborhood center subarea. This subarea is a locale for a mix of multiunit housing; limited office, commercial,
and service uses; and complementary uses, in a higher-density, pedestrian-scaled urban settingO The subarea is intended to
have a tight network of streets, with sidewalks, and buildings set close to sidewalksO Open spaces incudes plazas, in and green
spaceO
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PDZ Draft 1-30-2019
3
❻ CW4: Industrial subarea. This subarea will accommodate industrial and manufacturing uses in existing rehabilitated
structuresO
271-17.3 Permitted principal and accessory uses
The following table shows permitted uses in each transect subarea, with specific location limitations where applicableO
Key:
P permitted use
permitted with special permit by the Planning Board SP
• not allowed
Where the table separately lists a specific use that might also fall under another use category, the description and conditions
for the specific use applyO (Example: the “retail and service” use does not include adult uses or restaurant/bar uses because the
table lists those specific uses separately; the respective parameters applicable to adult uses and restaurant/bar uses apply to
those usesO)
A use must follow use-specific conditions and standards (if any), and applicable performance standards in this section and
other applicable laws and regulationsO If any use-specific conditions and standards or performance standards found in other
laws and regulations conflict with this section, those in this section will governO
Residential use Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Private residence Principal dwelling unit, for occupancy by a person, or family plus ≤1
boarder. • P P P P •
Collective living Principal dwelling unit, for occupancy by ≥ 3 unrelated people where
collective living arrangement is intentional, and lease terms are not less than
30 days, temporary, or seasonal, The term “seasonal” includes a period of an
academic year or less. Occupancy not to exceed 2 per bedroom or a
maximum of 6.
• P P P P •
Live-work housing Principal dwelling unit, with separate but connected space for a non-
residential use the subarea allows.
• Non-residential space may occupy ≤75% of the GFA of a live-work unit. It
must have direct internal access from living space.
• The operator of a non-residential use in live-work space must live in the
live-work unit as their primary residence.
• SP SP SP P •
Residential care Multi-unit or group housing, with on-site supervision, services, and care, to
people who need help with daily living activities, or who cannot care for
themselves
• Adult day health care (10 NYCRR §425), day programs, social adult day care
(9 NYCRR §6654.20), or outpatient physical rehabilitation, may be an ancillary
use.
• SP SP SP SP •
Rooming and boarding Group housing where residence is limited to a specific group or membership
(Examples: fraternity or sorority house, student co-op, convent, monastery.) • SP SP SP SP •
Lodging use Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Inn Facility with 4 - 20 rooms for overnight accommodation to paying guests. • SP SP SP P •
Hotel Facility with more than 20 rooms for overnight accommodation to paying
guests. • • • SP P •
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Office use Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Health/wellness practice Establishment providing outpatient medical, medical allied health care, or
alternative medical services, and/or wellness activities including Yoga, Tai-
Chi, meditation, Pilates, dance, and similar wellness activities.
• P P P P •
Professional office Establishment providing professional, administrative, clerical, or information
processing services. • P P P P •
Veterinary practice Establishment providing veterinary services.
• Veterinary care may include short-term boarding for recovery and
observation.
• • • • P P
Retail and service use Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Adult use Refer to Town Code 270-5. • • • • • •
Indoor recreation: Establishment or facility, not associated with or ancillary to a civic use,
providing an indoors recreation or entertainment-oriented activity to the
public.
• • • • P P
Day care center Child day care (18 NYCRR §418-1), small day care (18 NYCRR §418-2),
school-aged child care (18 NYCRR §414), adult day health care (10 NYCRR
§425), social adult day care (9 NYCRR §665-.20), or adult day program for
children or adults in a protective setting.
• A fence 4’ to 6’ high must enclose an outdoor play area.
• A day care center may be an accessory use to a place of assembly, or
primary or secondary school.
• P P P P •
Pet care/boarding Establishment providing a supervised area where groups of pets can socialize
and play. This includes related training, grooming, and/or overnight
boarding.
• Outdoor play yard use ≥8:00 AM to ≤8:00 PM.
• • • • SP SP
Restaurant / bar Establishment preparing and selling food, drinks, and/or alcoholic beverages
in a ready-to-consume state, to customers onsite or delivery offsite.
• In the CW2A, CW2B, and CW3A the following limitations for ancillary
alcohol production and packaging for distribution offsite may not be
exceeded; in the CW3B and CW4 a special use approval is required to exceed
these limits.
◦ Production and packaging area: ≤50% of total gross floor area.
◦ Beer: 15 barrels of beer/17.5 hectoliter (hl) brewing system.
◦ Distilled spirits: 150 gal/6.0 hl still capacity.
◦ Wine or cider: 1,700 gal/65 hl fermenter capacity.
• SP SP SP P P
Retail and service Retail/rental or service activity providing a service or tangible product to the
general public, less than 10,000 ft² GFA. • SP SP SP P P
Retail - outdoor market Regularly recurring grouping of allowed retail and service or restaurant uses
at a dedicated site (Example: farmers’ market, food truck corral). • P P P P P
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Industrial and semi-
industrial use
Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Artisan Establishment or studio where people use handheld tools or small-scale
equipment to make art or products by hand. This includes related sales
onsite.
• P P P P P
Industrial - low impact Manufacture mainly from previously prepared materials, preparation,
processing, indoor warehousing, or repair of items for offsite distribution or
sale, where impacts are minimal or undetectable beyond the site; involving
no flammable or explosive material; or processes involving hazardous
material.
• • • • P P
Industrial - high impact Basic processing or manufacture of materials or products mainly from
extracted or raw materials; storage or manufacturing processes using
flammable or explosive materials; or storage or manufacturing processes
involving hazardous conditions.
• • • • • SP
Research/laboratory Establishment conducting scientific research, investigation, testing, or
experimentation. This includes related manufacture or sale of products
incidental to the main purpose of the laboratory.
• • • • SP SP
Self-storage facility Facility providing secured storage units or areas in a structure for passive,
short-term storage of household items, or other non-hazardous, non-
perishable durable items.
• Storage units/areas must be in a fully enclosed structure. A storage facility
must not have outdoor storage.
• Related sales of packing, moving, and storage supplies may be an ancillary
use.
• A storage unit/area must be for passive storage only. It must not have
active uses (examples: office or manufacturing work, band practice, art
studio, auto repair).
• A storage unit/area must not have electrical outlets, plumbing, or other
improvements that could make it useful for active uses. Electrical service to a
storage unit/area must be for lighting and climate control.
• • • • • P
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Civic use use Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Makerspace Community facility providing an open, collaborative environment for people
to learn, experiment, invent, or make things using shared tools, resources,
and knowledge.
• P P P P P
Cultural facility Facility for display, performance, or enjoyment of heritage, history, arts, or
sciences. (Examples: museum, gallery, library, arts performance venue by a
public or private entity.)
• P P P P •
Government facility Facility or office owned, occupied, or run by a government agency.
(Examples: town hall, courthouse, government office, social service facility,
public works facility.)
• P P P P •
Park/open space Land used mainly for active or passive recreation, or natural resource
protection. Small ancillary structures such gazebos, pavilions and
maintenance sheds allowed. See section 271-17.4 2 for park/open space
types and requirements.
P P P P P P
Place of assembly Facility used mainly for public/resident assembly for worship, meeting, or
community purposes. (Examples: religious congregation, secular assembly,
community center, common house, amenity center.)
• P P P P •
Private club Facility of a private club or organization, mostly available only to club
members and their guests. (Examples: service organization, lodge-based
organization, social club, veterans’ club, labor union.)
• • • P P •
Public safety Police station, fire station, ambulance service, or other public safety service. • • • P P •
School: primary /
secondary
Institution providing primary or secondary education. (Examples:
kindergarten, elementary school, junior high school, middle school, high
school.)
• P P P P •
School: vocational Establishment providing training in technical subjects or skills for specific
occupations or trades. • P P P P P
Utility and infrastructure
use
Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Utility control facilities Facility for collecting, processing, or distributing a public utility commodity.
(Examples: electrical substation, water tank and pumps, telephone switching
office and exchange.)
An enclosed building, or vegetative screening or screening wall that is
architecturally compatible with the nearest principal building, must screen
and conceal a utility substation, switchyard, or other area with exposed
outdoor equipment (examples: transformer, regulator, breaker, switch,
pump) from public vantage points and adjacent uses. Screening does not
need to be taller than 12’.
• P P P P P
District heating/cooling
plant
Facility providing centralized heating or cooling for multiple buildings or
developments. • • • • P P
Accessory uses Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Home occupation Business activity subordinate to a residential use in a housing unit.
See Town Code Section 270-219.2. • P P P P •
Temporary building A temporary building for commerce or industry, where such building is
necessary or incidental to the development of buildings including, but not
limited to, a construction office and/or sale office.
A temporary building may be continued through project completion.
• P P P P P
271-17.4 Neighborhood design
Requirements in sections 17O4 through 17O5 are mandatoryO Design guidelines in section 17O6 are mandatory, to the extent
practicable, as determined by the Planning BoardO
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(1) Dwelling units
Number of dwelling units for each subarea, and the PD site as a whole, is:
• CW2A / CW2B (cumulative area): ≤ 450 unitsO
• CW3A / CW3B (cumulative area): ≤ 50 unitsO
• PD site total (cumulative area): ≤ 500 unitsO
(2) Civic and open space
(a) Required civic area
The PD site must have an area assigned for a civic siteO It should be located at or close to the center of a built-up area; next to a
civic/open space or at the axial termination of a prominent thoroughfareO
(b) Required open space area
The PD site must have ≥15% of its gross area assigned for community open spaceO
Open space types, settings and requirements include the following:
Public/open space type Description and conditions CW1 CW2A CW2B CW3A CW3B CW4
Neighborhood park A medium-scale public space that provides a balance of active and passive
recreation for residents in the surrounding neighborhood. May include open
play areas, open shelters with picnic tables, playgrounds, athletic fields and
courts, dog park.
• Perimeter with street frontage: ≥ 50%
• Size: ≥ 1 acre
• ✓ ✓ ✓ ✓ ✓
Trail / linear park A linear space for off-street walking, hiking, and cycling. Includes shortcuts
through blocks, linkages between neighborhood areas and trails through
open space areas.
• Perimeter with street frontage: n/a
• Size: n/a
✓ ✓ ✓ ✓ ✓ ✓
Green / square A public space for civic purposes, gathering, unstructured recreation, and
other passive uses. Spatially defined by building frontages, tree-lined streets
and landscaping..
• Perimeter with street frontage: ≥ 50%
• Size: 10,000 ft2 - 2 acres
• • ✓ • ✓ ✓
Pocket park A small-scale public space in an urban setting, providing recreational
opportunities where publicly accessible parks or open space is limited. The
range of character can be for intense use or aesthetic enjoyment; low
maintenance is essential.
• Perimeter with street frontage: ≥ 25%
• Size: 2,500 ft2 - 10,000 ft2.
• ✓ ✓ • ✓ ✓
✓ - park / open space type allowed
(c) Community open space calculation does not include the following:
• Areas inside a site envelope for a residential, commercial, or civic buildingO
• A yard, balcony, patio, or other outdoor space for use or access only by a specific dwelling unit or limited number of
dwelling unitsO
• Public or private thoroughfare/street right-of-way, or integral features (such as sidewalks and tree lawn areas)O
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• Parking area or drivewayO
• Stormwater detention/retention facility or drainage swale area, unless design allows practical use as an accessible year-
round amenity for residents of the development (picnic area, passive recreation area, playground, and the like), or it is a
bioswale that visually integrates into the larger open space siteO
• Entry feature, median, or traffic islandO
(d) Public and open space configuration
An open space area must function as part of the broader public realm and allow community-wide access and passageO
The outer edge of a public or open space area must have as much direct frontage on a thoroughfare as possible, so 1) it is
visible and promotes a sense of physical safety, and 2) to reinforce its role as a shared or community resourceO The preceding
sentence does not apply to trail/linear parksO
Key factors in public and open space location are:
• Ease of access from the surrounding neighborhood;
• Central location for its service area; and
• Linkage to other public and open space areas within and beyond the siteO
(3) Thoroughfares
(a) Intent
Thoroughfare assemblies for the Chain Works District intend to create streets, roads and sidewalks that prioritize slow and safe
travel for people walking; people riding bikes; people taking transit; people driving in cars; and people moving freightO The
specific dimensions focus on keeping lane widths as narrow as practical in order to calm trafficO On-street parking is
encouraged wherever possible to buffer and protect people walking on sidewalks from auto trafficO Vehicular traffic speed and
counts are kept low in order to facilitate shared multi-modal usesO Many thoroughfare assemblies are designed around a yield
condition, where two-way traffic is allowed but vehicles must yield to oncoming traffic to passO This yield condition is described
by American Association of State Highway and Transportation Officials (AASHTO) as “typical” for residential streets and it
creates the conditions most conducive to naturally slow and careful driving, as is necessary to make roads safe for people
walking and bikingO
(b) Thoroughfare types and designs
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Assembly type A is intended to serve most of the developmentO This yield condition street may include occasional bump-outs
into the parking area to accommodate street trees if there is not room for a continuous tree lawn due to site topographyO With
two 8’ travel lanes, average size cars (6’ wide) will easily pass each other but will naturally slow down to do soO On rare
occasions when two larger vehicles encounter each other, they may need to yield to pass in driveways, intersections or open
parking spacesO People riding bikes will ride in the traffic lanes due to the low expected speeds and traffic counts on these
streetsO
Thoroughfare type Street Parking lanes 2 sides / 7’ wide marked
Subarea CW2, CW3 Curb radius ≤10’
Right-of-way width ≥56’ Walkway type Sidewalk ≥5’ wide (≥4’ see C), ≥8’ wide at mixed
use
Pavement width 30’ Planter type ≥7’ wide planter bump outs
Movement Slow Curb type Barrier curb
Design speed (traffic) ≤25 MPH Landscape type Trees at ≤30’ on center avg (20’ min / 40’ max)
Vehicle travel lanes 2 lanes / 8’ wide Transportation provision Bus route and bikes share lane
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Assembly type B is intended to be used between residential clusters where parking is not needed and as access between
existing surface parking lotsO This yield condition street will handle low traffic volumes and will encourage slow travel speeds
where walking and biking are prioritizedO With 16’ clear space in the lane and the availability of adjacent sidewalk space
without obstructions, firetrucks will be able to access and spread supports easily in emergency situationsO However,other large
vehicles should not frequently use these roads under non-emergency circumstancesO
Thoroughfare type Street Parking lanes None
Subarea CW2A, CW2B, CW3A, CW3B Curb radius ≤10’
Right-of-way width ≥40’ Walkway type Sidewalk ≥4’ wide (≥5’ see C), ≥8’ wide at mixed
use
Pavement width 16’ Planter type ≥8’ wide continuous tree lawn
Movement Slow Curb type Barrier curb
Design speed (traffic) ≤25 MPH Landscape type Trees at ≤30’ on center avg (20’ min / 40’ max)
Vehicle travel lanes 2 lanes Transportation provision Bikes share lane
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Assembly type C is a one-way alley/driveway with parallel parking on one sideO The narrow lanes, low speeds and limited
traffic make this assembly appropriate for people riding bikes to share the lane with slow moving carsO
Thoroughfare type Street Parking lanes 1 side / 7’ wide unmarked
Subarea CW2A, CW2B, CW3A, CW3B Curb radius ≤10’
Right-of-way width ≥36’ Walkway type Sidewalk ≥4’ wide (≥5 see C)
Pavement width 15’ Planter type ≥8’ wide continuous planter
Movement Slow Curb type Barrier curb
Design speed (traffic) ≤25 MPH Landscape type Trees at ≤30’ on center avg (20’ min / 40’ max)
Vehicle travel lanes 1 lane Transportation provision Bikes share lane
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Assembly type D is a truck and bus access route to Buildings 33 and 34O Active industrial uses in this area will require access
by large trucks, other kinds of vehicles, and pedestriansO
Thoroughfare type Industrial access Parking lanes None
Subarea CW4 Curb radius ≤30’
Right-of-way width n/a Walkway type ≥3’ wide sidewalk at buildings only (5’ see C)
(3’ not ADA compliant)
Pavement width 20’ with 4’ shoulders Planter type ≥8’ wide continuous tree lawn
Movement Slow Curb type Mountable or no curb
Design speed (traffic) ≤30 MPH Landscape type Trees at ≤30’ on center avg (20’ min / 40’ max)
Vehicle travel lanes 2 lanes Transportation provision Bikes share lane
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Assembly type E is a typical residential area street for places where topography and building widths do not constrain the
width available for road spaceO Where area is slightly more constrained, travel lanes may be =8 to 9 feet wide, to calm speeds
and encourage yield driving conditionsO
Thoroughfare type Street Parking lanes 2 sides / 7’ wide marked
Subarea CW2A, CW2B, CW3A, CW3B Curb radius ≤10’
Right-of-way width ≥60’ Walkway type ≥4’ wide sidewalk (≥5’ see C), ≥8’ at mixed use
Pavement width 34’ Planter type ≥7’ wide planting strip
Movement Slow Curb type Barrier curb
Design speed (traffic) ≤30 MPH Landscape type Trees at ≤30’ on center avg (20’ min / 40’ max)
Vehicle travel lanes 2 lanes Transportation provision Bus route and bikes share lane
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(c) Thoroughfare layout
A thoroughfare must be permanently open to the public and provide community-wide access as part of an overall connected
street networkO A thoroughfare must not have gated accessO
A thoroughfare (not including an alley or stub-out provision) must begin and end at other thoroughfaresO A neighborhood
primary or secondary street may not begin or end at an alleyO
A thoroughfare network should have blocks ≤800 feet long (measured where thoroughfare center lines meet, not including
alleys) on their longest side where practical given site topography and other physical limitationsO
Thoroughfares should intersect at approximately right angles as much as possibleO
The street pattern must have stub-out thoroughfares to provide future access to adjacent development or redevelopment sites
and ensure broader neighborhood interconnectivityO A stub-out thoroughfare must have the same level of improvements as
other thoroughfares on the PD siteO
The standards show a minimum width of 4’ for some sidewalksO In general, sidewalks should be 5’; however, the Town of Ithaca
Planning Board may grant approval for the ADA minimum, 4’, at its discretion if all ADA conditions are met and special site
conditions such as topography or very low expected pedestrian traffic merit an exceptionO
A thoroughfare must have hard surface paving (porous or solid asphalt, concrete, or segmental pavers) for sidewalks, parking
lanes, and travel lanesO
(4) Utilities
Permanent utilities (natural gas [if any], district heating/cooling, electricity, wired communications and the like) must be
undergroundO Short-term utility service for construction activities may be above groundO
A utility easement must be in a location where maintenance or repair work will cause the least disruptionO Utility easement
location must not prevent or undermine street tree plantingO
271-17.5 Site and building design
(1) Site envelope configuration
A site envelope is the functional equivalent of an individual building lot for site planningO Site envelopes must not overlapO Site
envelopes define building setback lines for building sitesO Site envelopes do not imply or enable a current or future subdivision
pattern or individual ownershipO
(2) Building types and disposition
(a) Principal building types, and the transect subarea they can be part of, include the following:
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Building type CW1 CW2A CW2B CW3A CW3B CW4
Small house • ✓ ✓ ✓ • •
Large house • ✓ ✓ ✓ • •
3-4 unit house • ✓ ✓ ✓ • •
Cottage • ✓ ✓ ✓ • •
Town house • ✓ ✓ ✓ ✓ •
Mansion apartment • ✓ ✓ ✓ ✓ •
Apartment • • ✓ ✓ ✓ •
Courtyard building • • ✓ ✓ ✓ •
Single story shopfront • • • • • •
Main Street mixed use • ✓ ✓ ✓ ✓ •
General building • • • • ✓ •
Service station • • • • • •
Large footprint • • • • • ✓
✓ - building type allowed • - building type not allowed
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Small house
Detached building with one or two dwelling units, ranging in height from 1 to 2 1/2
stories, with a ground floor footprint of <1500’²O
• Required frontage element: stoop or porchO
• Main entrance location: facing sidewalkO
• Reflective wall surface material must have visible light reflectance (VLR) of ≤15%O
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min/max) • 1500-5000 ft² 1500-5000 ft² 1500-5000 ft² • •
B Lot width (min/max) • 20-50’ 20-50’ 20-50’ • •
C Building coverage on lot (max) • 70% 70% 70% • •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • 5-15’ 5-15’ 5-15’ • •
E Facade length (max) • 24’ 24’ 24’ • •
F Side setback (min/max) • 0-10’ 0-10’ 0-10’ • •
G Rear setback (min) • 5’ 5’ 5’ • •
H Parking setback (min) • 10’ 10’ 10’ • •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (min/max) • 1 - 2 1/2 1 - 2 1/2 1 - 2 1/2 • •
1st story height (min) • 9’ 9’ 9’ • •
Story height (min) • 9’ 9’ 9’ • •
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Large house
Detached building with one or two dwelling units, ranging in height from 1 to 3
stories, with a ground floor footprint of ≥1500 ft²O
• Required frontage element: stoop or porchO
• Main entrance location: facing sidewalkO
• Reflective wall surface material must have visible light reflectance (VLR) of ≤15%O
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min) • 3000 ft² 3000 ft² 3000 ft² • •
B Lot width (min/max) • 35-100’ 35-100’ 35-100’ • •
C Building coverage on lot (max) • 70% 70% 70% • •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • 5-15’ 5-15’ 5-15’ • •
E Facade length (max) • 36’ 36’ 36’ • •
F Side setback (min/max) • 5-25’ 5-25’ 5-25’ • •
G Rear setback (min) • 25’ 25’ 25’ • •
H Parking setback (min) • 10’ 10’ 10’ • •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • 2 1/2 2 1/2 2 1/2 • •
1st story height (min) • 9’ 9’ 9’ • •
Story height (min) • 9’ 9’ 9’ • •
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3-4 unit house
Detached dwelling with three or four dwelling units, ranging in height from 1 to 4
storiesO
• Required frontage element: stoop or porchO
• Main entrance location: facing sidewalkO
• Reflective wall surface material must have visible light reflectance (VLR) of ≤15%O
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min) • 6000-18000 ft² 4000-8000 ft² 4000-8000 ft² • •
B Lot width (min/max) • 30-90’ 30-60’ 30-60’ • •
C Building coverage on lot (max) • 80% 80% 80% • •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • 5-15’ 5-15’ 2-8’ • •
E Facade length (max) • 44’ 44’ 44’ • •
F Side setback (min/max) • 5-30’ 5-30’ 5-20’ • •
G Rear setback (min) • 25’ 25’ 25’ • •
H Parking setback (min) • 10’ 10’ 10’ • •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • 3 3 3 • •
1st story height (min) • 9’ 9’ 9’ • •
Story height (min) • 9’ 9’ 9’ • •
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NOTE: FRONT LOT LINE SHOULD BE BEHIND THE SIDEWALK, NOT THE OTHER SIDE OF THE STREET
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Cottage
Detached dwelling unit on a ≤1200 ft² lotO Cottages may be grouped together
around a court, used individually on small infill lots, or located as accessory dwelling
units on lots with a larger primary residential buildingO
• Required frontage element: stoop or porchO
• Main entrance location: facing courtyard or sidewalkO
• Reflective wall surface material must have visible light reflectance (VLR) of ≤15%O
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (max) • 1500 ft² 1500 ft² 1500 ft² 1500 ft² •
B Lot width (min/max) • 20-40’ 20-40’ 20-40’ 20-40’ •
C Building coverage on lot (max) • 70% 70% 70% 70% •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • 5-15’ 5-15’ 5-15’ 5-15’ •
E Facade length (max) • 24’ 24’ 24’ 24’ •
F Side setback (min/max) • 5’ 5’ 5’ 5’ •
G Rear setback (min) • 5’ 5’ 5’ 5’ •
H Parking setback (min) • 10’ 10’ 10’ 10’ •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • 2 1/2 2 1/2 2 1/2 2 1/2 •
1st story height (min) • 9’ 9’ 9’ 9’ •
Story height (min) • 9’ 9’ 9’ 9’ •
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Mansion apartment
Building with 4 to 9 dwelling units, ranging in height from 1 to 4 stories, on a
≥10,000 ft² lotO
• Required frontage element: stoop or porchO
• Main entrance location: facing courtyard or sidewalkO
• Reflective wall surface material must have visible light reflectance (VLR) of ≤15%O
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min/max) • 10000-36000 ft² 10000-36000 ft² 10000-36000 ft² 10000-36000 ft² •
B Lot width (min/max) • 60-100’ 50-100’ 50-100 50-100’ •
C Building coverage on lot (max) • 50% 50% 50% 50% •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • 15-50’ 15-50’ 15-50’ 15-50’ •
E Facade length (max)
(minimum: 30% of lot width) • n/a n/a 60’ 60’ •
F Side setback (min/max) • 20-50’ 20-50’ 20-50 5-20’ •
G Rear setback (min) • 40’ 40’ 40’ 20’ •
H Parking setback (min) • 10’ 10’ 10’ 10’ •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • 3 3 3 3 •
1st story height (min) • 9’ 9’ 9’ 9’ •
Story height (min) • 9’ 9’ 9’ 9’ •
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Townhouse
Dwelling on a narrow lot that shares a party wall with an adjoining similar residential
buildingO A townhouse may have 1 to 3 dwelling units, and a height of ≤4 storiesO
• Required frontage element: stoop or porchO
• Main entrance location: facing courtyard or sidewalkO
• Reflective wall surface material must have visible light reflectance (VLR) of ≤15%O
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min/max) • 1200-3000 ft² 1200-3000 ft² 1200-3000 ft² 1200-3000 ft² •
B Lot width (min/max) • 15-40’ 15-40’ 15-30’ 15-30’ •
C Building coverage on lot (max) • 50% 50% 50% 70% •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • 5-15’ 5-15’ 5-15’ 0-10’ •
E Facade length (max) • 40’ 40’ 40’ 40’ •
F Side setback (min/max) • 0-15’ 0-15’ 0-15’ 0-15’ •
G Rear setback (min) • 5’ 5’ 5’ 5’ •
H Parking setback (min) • 10’ 10’ 10’ 10’ •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • 3 4 4 4 •
1st story height (min) • 9’ 9’ 9’ 9’ •
Story height (min) • 9’ 9’ 9’ 9’ •
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Apartment building
Building with multiple dwelling units, with a maximum height of 4 to 6 storiesO
• Required frontage element: stoop, porch, or at-grade entryO
• Main entrance location: facing sidewalkO
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min/max) • • 10000-72000 ft² 10000-72000 ft² 10000-72000 ft² •
B Lot width (min/max) • • 40-200’ 40-200’ 40-200’ •
C Building coverage on lot (max) • • 60% 60% 75% •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • • 10-20’ 10-20’ 0-15’ •
E Facade length (max)
(minimum: 70% of lot width) • • 180’ 180’ 180’ •
F Side setback (min/max) • • 5-15’ 5-15’ 5-15’ •
G Rear setback (min) • • 25’ 25’ 25’ •
H Parking setback (min) • • 10’ 10’ 10’ •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • • 4 3 6 •
1st story height (min) • • 9’ 9’ 9’ •
Story height (min) • • 9’ 9’ 9’ •
Required building articulation:
• Q: Vertically oriented projections or recesses ≤30’ apart (exceptions: not required above 5th story, or where windows are
consistently recessed ≥4”)O
• R: Horizontally oriented projection between the 1st and 3rd storiesO
• S: Buildings ≥50’ tall must have a ≥4’ front facade stepback between 20’ and 60’ above gradeO
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Courtyard apartment building
Building with multiple dwelling units, with a maximum height of 4 to 6 stories, with
a courtyard recessed into the front facadeO
• Required frontage element: stoop, porch, or at-grade entryO
• Main entrance location: sidewalkO
The original description allows courtyard apartment buildings with storefronts, but
standard apartment buildings do not allow storefrontsO Clarification?
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min/max) • • 10000-72000 ft² 10000-72000 ft² 10000-72000 ft² •
B Lot width (min/max) • • 60-240’ 60-240’ 60-240’ •
C Building coverage on lot (max) • • 80% 80% 80% •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • • 0-10’ 0-10’ 0-10’ •
E Facade length (max) • • 200’ 200’ 220’ •
F Side setback (min/max) • • 5-15’ 5-15’ 5-15’ •
G Rear setback (min) • • 10’ 10’ 10’ •
H Parking setback (min) • • 10’ 10’ 10’ •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • • 4 3 6 •
1st story height (min) • • 9’ 9’ 9’ •
Story height (min) • • 9’ 9’ 9’ •
• Q: Vertically oriented projections or recesses ≤30’ apart (exceptions: not required above 5th story, or where windows are
consistently recessed ≥4”)O
• R: Horizontally oriented projection between the 1st and 3rd storiesO
• S: Buildings ≥50’ tall must have a ≥4’ front facade stepback between 20’ and 60’ above gradeO
• U: Minimum courtyard depth: 20’
• V: Minimum courtyard width: 30’
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Single story shopfront building
One-story commercial building on a small lotO
• Required frontage element: storefrontO
• Main entrance location: facing sidewalkO
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min/max) • • • • • •
B Lot width (min/max) • • • • • •
C Building coverage on lot (max) • • • • • •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • • • • • •
E Facade length (max)
(minimum: 50% of lot width) • • • • • •
F Side setback (min/max) • • • • • •
G Rear setback (min) • • • • • •
H Parking setback (min) • • • • • •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • • • • • •
1st story height (min) • • • • • •
Story height (min) • • • • • •
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Main Street mixed use building
Contains ground floor retail space; and upper floors that include additional retail,
apartments, offices, or light manufacturing spaceO Main Street mixed use buildings
are up to 4 to 6 stories tall, with a ground floor height of ≥12’O They are built up to
the sidewalk, and typically share party walls with neighboring buildingsO
• Required frontage element: storefrontO
• Main entrance location: facing sidewalkO
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min) • 4000 ft² 4000 ft² 4000 ft² 4000 ft² •
B Lot width (min/max) • 20-100’ 20-100’ 20-150’ 20-200’ •
C Building coverage on lot (max) • 80% 80% 80% 80% •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • 5-15’ 0-10’ 5-15 0-10 •
E Facade length (max)
(maximum: 12’ unbuilt) • 80’ 80’ 120’ 180’ •
F Side setback (min/max) • 5-15’ 5-15’ 5-15’ 5-15’ •
G Rear setback (min) • 25’ 25’ 25’ 25’ •
H Parking setback (min) • 10’ 10’ 10’ 10’ •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (max) • 4 4 4 6 •
1st story height (min) • 12’ 12’ 12’ 12’ •
Story height (min) • 9’ 9’ 9’ 9’ •
• Q: Vertically oriented projections or recesses ≤30’ apart (exceptions: not required above 5th story, or where windows are
consistently recessed ≥4”)O
• R: Horizontally oriented projection between the 1st and 3rd storiesO
• S: Buildings ≥50’ tall must have a ≥4’ front facade stepback between 20’ and 60’ above gradeO
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General building
A building with 2 to 6 stories, that may or may not have retail frontage on the
ground floorO
• Required frontage element: storefront, at-grade entryO
• Main entrance location: facing sidewalkO
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min) • • • • no minimum •
B Lot width (min/max) • • • • 100-300’ •
C Building coverage on lot (max) • • • • 80% •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • • • • 0-10 •
E Facade length (max)
(minimum: 50% of lot width) • • • • 180’ •
F Side setback (min/max) • • • • n/a •
G Rear setback (min) • • • • 10’ •
H Parking setback (min) • • • • n/a •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories (min-max) • • • • 2-6 •
1st story height (min) • • • • 9’ •
Story height (min) • • • • 9’ •
• Q: Vertically oriented projections or recesses ≤30’ apart (exceptions: not required above 5th story, or where windows are
consistently recessed ≥4”)O
• R: Horizontally oriented projection between the 1st and 3rd storiesO
• S: Buildings ≥50’ tall must have a ≥4’ front facade stepback between 20’ and 60’ above gradeO
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Service station
A mixed use building with 2 to 6 stories, with ground floor retail that is associated
with one or more fueling or service stations for cars and trucksO
• Required frontage element: storefrontO
• Main entrance location: facing sidewalkO
Lot dimensions CW1 CW2A CW2B CW3A CW3B CW4
A Lot area (min) • • • • • •
B Lot width (min/max) • • • • • •
C Building coverage on lot (max) • • • • • •
Building disposition CW1 CW2A CW2B CW3A CW3B CW4
D Front setback (min/max) • • • • • •
E Facade length (max)
(minimum: 50% of lot width) • • • • • •
F Side setback (min/max) • • • • • •
G Rear setback (min) • • • • • •
H Parking setback (min) • • • • • •
Building height CW1 CW2A CW2B CW3A CW3B CW4
Stories • • • • • •
1st story height (min) • • • • • •
Story height (min) • • • • • •
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Large footprint
Large commercial building with 2 to 6 stories, on a ≥50,000 ft² lotO Large footprint
buildings are allowed by special permit onlyO [Every building this size would require
Planning Board review; redundant?] They should be reserved for important
community service uses such as a civic center, hotel, grocery, parking garage, or
department storeO
• Required frontage element: storefront or at-grade entryO
• Main entrance location: facing sidewalkO
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(b) Town Code §270 (zoning) (or successor code) provisions allowing certain building features to encroach beyond setback or
height limits also applyO
(3) Other buildings
An accessory building must be ≥30 feet from a site envelope line fronting on a thoroughfare; and ≥5 feet from other site
envelope linesO
An accessory building must be behind the front and corner side elevation of the principal buildingO
(4) Building form and design
(a) Four-sided design
A building must have consistent material treatment, architectural details, proportions, and colors on all exterior wallsO
(b) Accessory structures
A permanent accessory building must have material treatment, architectural details, proportions, and colors that are consistent
with the principal buildingO
(c) Exterior materials
Vinyl siding must be ≥0O044 inches thickO This does not apply to temporary buildings for construction field offices and similar
short-term uses, or to buildings in CW4O
(d) Utility and service areas
Rooftop or ground-mounted mechanical equipment, utility areas, and trash enclosure or storage areas require concealment or
screening to hide them from view beyond the site envelopeO Form of concealment or screening must be architecturally
consistent or integral with the host structureO This does not apply to solar panels or buildings in CW4O
(5) Parking
(a) Off-street parking lot location
Off-street surface parking may be in the rear of a site envelope, or interior of a blockO Access must be from an alley or a
driveway ≤16 feet wide, unless a wider width is required for emergency vehicle accessO
Surface parking areas and shared garage/carport structures must be dispersed through the developed part of the site as much
as possible to reduce visual impactO
(b)O Off-street parking lot design
A parking area must not be visually dominantO Building siting, landscaping, or architectural treatment must screen a parking
area (not including an individual driveway) from thoroughfares and residential areas outside of the PD siteO Screening may be
shrubs (that grow to form a continuous hedge of ≥3 feet within three years of planting), or a wall (3 to 4’ feet high)O This
requirement does not apply to parking areas existing as of the effective date of this law that will be retainedO
A parking area must have a sidewalk or paved walkway to provide pedestrian access from nearby thoroughfaresO
(c) Parking surfaces
Parking areas must have a fixed impervious or porous surfaceO
Pavement edge must have clear definition, using curbs or a different durable materialO Curbing allowing water runoff (rollover
curb, or barrier curb with gaps) is preferable to curbing that traps stormwaterO
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(d) Landscape area
A parking lot must have ≥1 landscaped interior island (≥8O5 feet wide, ≥160 ft²) for every 10 parking spacesO
A row of parking spaces must have a landscape island (or equivalent landscape area) at each endO
A row of parking that is not interrupted by a landscape island must be <10 spaces longO
A landscape island should function as part of the larger stormwater management system of the PD siteO
(e) Renewable energy
Any parking space (on-street and off-street, for any type of vehicle) may have an electric vehicle charging stationO
≥5% of new off-street parking spaces must have utility provisions for future electric vehicle charging stationsO
A solar carport may cover any off-street parking spaceO
(6) Landscaping
(a) Tree classes
"Street tree" refers to trees in a tree lawn or tree well alongside a street, or traffic islandO
"Canopy tree" and "short tree" refer to trees in yards, courts, landscaping areas, open space areas, and similar areasO
(b) Thoroughfare tree lawns
A tree lawn area on a primary or secondary street must have ≥1 street tree every 20 to 40 feet along its length, with average
spacing of ≤30 feet along the block lengthO
A maximum of 25% of the trees on the entire site as a whole may be from a single tree speciesO
(c) Off-street parking areas
Off-street surface parking areas must have tree planting, with a combined canopy that will shade ≥50% of the parking area
(parking spaces and drive aisles) at maturityO Solar carport coverage area may substitute for tree canopy areaO
A parking lot landscape island must have ≥1 canopy tree for every 160 ft² of landscape island areaO
(d) Tree species for required planting
Tree species for required plantings must have these traits:
• Native or adapted to upstate New York (USDA hardiness zone 5a, 5b, 6a)O
• Not invasive (according to the most recent Tompkins County Regional Invasive Species and Worst Invasive Species lists), or
species with known parasites or pathogens, including ash and hemlockO
• Follow requirements for allowed or prohibited tree species in Town Code §270 (zoning) s, if applicableO
Street tree species must also have these traits:
• CW2A and CW2B subareas: mature height of ≥40 feetO
• CW3A and CW3B subareas: mature height of ≥30 feetO
• A crown that can grow to shade a sidewalk and streetO
• Downward-oriented root systemO
• Salt tolerantO
• Not brittle or prone to dropping heavy fruitO
• Canopy tree species must have a mature height of ≥40 feetO
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• Short tree species must have a mature height of ≥20 feetO
• A street tree or canopy tree planting must have a diameter at breast height (DBH) of ≥2 inchesO
• A short tree planting must have a DBH of ≥1O5 inchesO
(e) Other landscaping requirements
For ≤50% of all required canopy trees in other landscape areas, two short trees may substitute for one canopy treeO
Exposed ground surfaces must have groundcover planting or mulch to cover otherwise exposed soilO
(7) Fences and walls
Fence or wall height may be ≤3 feet in a front setback area, and ≤6 feet elsewhereO
Acceptable materials for walls include brick, stone, split-faced block, decorative blocks, cast stone, and glass blocksO
Acceptable materials for fences include wood, composite fencing, wrought iron, PVC/vinyl, or welded wire panelsO This does
not apply to deer fencing, snow fencing, and temporary fencing for construction and short-term activitiesO
Barbed wire, concertina wire, and chain link are not acceptableO This does not apply to temporary fencing for construction
activitiesO
(8) Signs
• Signs must conform to the then-current Town of Ithaca Sign Law (or successor code) standards for the following:
• CW1 subarea: standards for Residential and Conservation zones (§ 270-254)
• CW2A and CW2B subareas: residential and other uses: standards for the Residential and Commercial (or successor)
ZzonesO
• CW3A and CW3B subareas: attached signs on storefronts: standards for Commercial (or successor) zoneO
• CW4 subarea: standards for the Commercial and Industrial zones (§ 270-256)
(9) Outdoor lighting
(a) Light output
Photometric performance must conform to current Town of Ithaca Outdoor Lighting Law (or successor code) standardsO
(b) Freestanding fixtures/poles
Height:
• Neighborhood primary and neighborhood secondary streets: ≤16 feetO
• Elsewhere: ≤12 feetO
Design and location:
• Pole design should have a distinct base, middle and topO
• Maximum form base/sonotube top is <4 inches above gradeO
• Poles must not block sidewalks or walkwaysO
(c) Attached fixtures
• Fixture design should be consistent with the architectural style and detailing of the host structureO
• Sconces, gooseneck fixtures, and recessed fixtures are allowedO Wall pack lighting is not acceptable, except in the CW4
subareaO
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271-17.6. Design guidelines
(1) Applicability
These design guidelines assist in design and review of new construction and modifications to existing sites and structures in
the PD zoneO These guidelines provide substantive direction while also providing reasonable flexibility in their applicationO
Although these guidelines use the term “should”, new buildings and modifications should comply with them as much as
practicable, as the Planning Board determinesO The applicant has the burden of demonstrating why it is not practicable to
apply a certain guideline, or why the design is a superior alternative to a design that follows these guidelinesO Cost alone does
not justify approval of noncompliant designO
(1) Design guidelines for all building types
(a) Design consistency on visible elevations
Building elevations facing a street, courtyard, or the public realm should have a similar style and quality of windows, doors,
trim, decorative moldings, and wall articulationO
(b) Roof form
If a building has a sloping roof, the most prominent roofline should have a pitch of slope of:
• Front gable end: ≥ 6:12 (26O6°)
• Side gable end, hip, butterfly, shed: ≥ 5:12 (22O6°)
(c) Roof materials
A sloping roof surface should use one or more of these materialsO
• Composite polymer shinglesO
• Concrete or ceramic roof shingles or tilesO
• Asphalt shingles with a ≥ 25 year manufacturer warrantyO
• Green roof with an anti-slip systemO
• Metal, wood, slate, or stone shinglesO
• Solar/photovoltaic shingles or tilesO
• Standing seam metalO
(d) Cladding materials
This table shows cladding materials that this PDZ allows for specific building typesO
• ≤ 100% of cladding area on a wall should be one or a combination of an allowed primary (P) cladding materialO
• ≤ 40% of cladding area on a wall may be one or a combination of an allowed secondary (S) cladding materialO
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Cladding material Small house Large house 3-4 unit house Cottage Mansion apartment Townhouse Apartment building Courtyard building Main Street mixed use building General building Large footprint building Architectural wall panel S S S S S S S S S S S
Block (polished, or integral dye or pigment color; not “natural” with no
integral color) S S S S S S S S S S S
Brick (integral color, nominal size ≥ 3 units/ft²) S S S S S S P P P P P
Brick (integral color, nominal size ≥ 4 units/ft²) P P P P P P P P P P P
Metal: corrugated or standing seam (made for architectural use) S S S S S S S S S S S
Precast masonry, ceramic, or terra cotta trim and cornice elements. P P P P P P P P P P P
Shingles or shakes (wood, fiber cement, polymer) P P P P P P S S S S S
Siding: horizontal/lap or vertical (wood, fiber cement, polymer;
not plywood-based, or OSB without zinc borate treatment) P P P P P P S S S S S
Siding: horizontal/lap or vertical (vinyl ≥ 0.044”/1.2mm thick, steel ≥
0.0179”/0.45mm thick) P P P P P P • • • • •
Stone (natural or manufactured) P P P P P P P P P P P
Stucco or EIFS (drainable) P P P P P P P P P P P
(e) Cladding material change on an elevation
Cladding material along a wall or elevation should only change:
• At an inside corner;
• At a return ≥ 2’ from an outside corner;
• At a horizontal plane; or
• Where a pilaster, pilaster strip, or similar projecting element that vertically divides a facade, separates the different
cladding areasO
• A sill or cap should define horizontal material change from masonry to another materialO
(f) Trim
Exterior walls with siding should have the following trimO
• Doors and windows: surround ≥ 3O5” wide on all windows and doorsO
• Outside corners: ① corner board ≥ 3O5” wide on all outside corners; or ② mitered edges aligning materials on each wallO
• Roof overhangs and eaves: frieze ≥ 3O5” wideO
(g) Window and door area
An elevation of a principal building or detached accessory unit (not including garage doors or garage door bays) should have
the following window and door areaO
Applicable to: small house, large house, 3-4 unit house, cottage, mansion apartment, townhouse
• Front, corner side, and public realm-facing elevation: ≥15% window/door area on each storyO
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Applicable to: apartment building, courtyard building
• Front, corner side, and public realm-facing elevation: ≥15% window/door area on each storyO
• Upper stories - other walls (not including party walls: ≥10% window/door area on each storyO
Applicable to: Main Street mixed use building, general building, large footprint building,
• Ground story - storefronts: ≥ 70% window/door area between 2’ and 12’ above gradeO Functional entries to the building
must be an average of ≤75’apart along street frontagesO
• Ground story - general: front, corner side, and public realm-facing elevations: ≥15% window/door areaO Functional entries
to the building must be an average of ≤75’ apart along street frontagesO
• Upper stories - front, corner side, public realm-facing, and downhill side elevation: ≥15% window/door area on each storyO
• Upper stories - other walls (not including party walls: ≥10% window/door area on each storyO
(i) Awnings
Awnings should take the form of a traditional wedge with valence, lateral arm retractable, or concave awningO Awnings should
not take the form of vinyl waterfall or bubble awningsO
Awnings should not be backlitO
Awnings on storefronts should be ≥ 4’ deepO Adjustable roll-up awnings are encouragedO
Shopfront awnings may encroach into the public pedestrian way, if all parts of it are ≥ 7’ above gradeO
(j) Blank wall area
On building elevations facing the public realm, horizontal separation between window/door openings and ① other
window/door openings or ② an outside corner on an elevation should be ≤ 10’ on each storyO
(l) Rooftop equipment screening
Rooftop HVAC, utility, and mechanical equipment, enclosures, ducts, or related accessories should have visual screening of the
same height or higher to conceal themO Screening should be ① visually opaque, and ② architecturally integral to the building
(examples: roof well, parapet wall, pitched roof element, architectural roof screen that matches building colors)O This does not
apply to antennas or solar panelsO
Color of a plumbing or exhaust vent, pipe, or flue that penetrates a roof should match the roof colorO
(m) Dwelling unit individuality
Applicable to: 3-4 unit house, townhouse
Architectural design should include one of or more of these elementsO
• Bays or offsets that give each unit their own visual identityO
• Different massing, fenestration pattern, or cladding material use for each unitO
• Prominent wing or bay projecting from each unitO
• Different gable orientation or roof profile for each unitO
• Gable, hip, or shed dormersO
• Variation in design of porches or stoopsO
• Horizontal articulation for buildings on a slopeO
(3) Building entrance and frontage features
(a) Required frontage feature
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A principal building should have a visually prominent entrance on the front elevation, with an allowed frontage feature for the
building typeO
Frontage feature Small house Large house 3-4 unit house Cottage Mansion apartment Townhouse Apartment building Courtyard building Main Street mixed use building General building Large footprint building Porch ✓ ✓ ✓ ✓ ✓ ✓ • • • • •
Stoop ✓ ✓ ✓ ✓ ✓ ✓ • • • • •
Storefront • • • • • • • • ✓ ✓ ✓
At-grade entry • • • • • • ✓ ✓ • ✓ ✓
✓ - allowed frontage feature for the building typeO • - frontage feature not allowed for the building type
(b) Porch
A porch is a raised, roofed platform that is architecturally integral to a building, forming an articulated entryway and semi-
private social spaceO (A deck, sunroom, or three-season room is not a porchO)
Dimensions
• Width: ≥ 12’
• Depth (not including stairs): ≥ 6’
• Height (above grade): ≥ 1O75’ or ≥ 3 steps (guideline)
Requirements
• A porch on the front elevation should be unenclosedO
• The area under a porch and its stairs should be enclosed with a material that ① is visually solid, or ② has a ≥ 3:1 solid-to-
void ratioO
• A roof that is architecturally integral to the building should fully cover the porchO (Stair coverage is optionalO)
• A porch should have a door that is an entrance to the buildingO
(c) Stoop
A stoop is a small raised platform, structurally and architecturally integral to a building, forming part of an entrywayO A
deck, or prefabricated metal or fiberglass entrance stair system, is not a stoopO
Dimensions
• Width: ≥ 4’
• Depth (not including stairs): ≥ 3’
• Height (above grade): ≥ 1O75’ or ≥ 3 steps
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Requirements
• A stoop should have an entrance to the building with one or more of these featuresO
• Portico or porte-cochere covering ≥ 16 ft², with ≥ 8” wide support columnsO
• Vestibule projecting ≥ 3’ from the exterior building wallO
• Entrance recess ≥ 2’ into the exterior building wallO
• Pediment with flanking ≥ 8” wide pilastersO
• Entry door with ① a sidelight and transom window, or ② sidelight windows on both sidesO
(d) Storefront
A storefront is a ground floor facade with a highly transparent surface area, designed to serve primarily as a display area and
primary entrance for retail, commercial, or service usesO
Dimensions
• Bay width through vertical articulation (columns, piers, pilasters, or other architectural treatments): ≤ 30’
• Height (bottom of bulkhead to top of fascia): 9’ to 18’O
• Entrance recess: 2O5’ to 6’ into the exterior building wallO
Requirements
A storefront should have all of these featuresO
• Piers, or other vertical elements that define the shopfront bayO
• Display windows ≥ 6’ tall, 2’ to 3’ above the sidewalkO
• Fascia, signband, transom window, or potential awning area for signageO
• Transparency (window and door coverage) requirements are in the window and door area requirements aboveO
(e) At-grade entry
An at-grade entry is a ground level (0 or 1 step) entrance into a building foyer, lobby, or entrance hallO
Requirements
• An at-grade entry should have an entry door with one or more of these featuresO
• A structurally and architecturally integral ① roof, ② portico, or ③ porte-cochere covering ≥ 32 ft², with support columns
≥ 10” wideO
• An entrance recess ≥ 3’ into the exterior building wall, covering ≥ 32 ft²O
• A vertically defined bay with a different cladding pattern than other baysO
(4) Precedent Images
These images show examples of qualities or characteristics that are reflective of and complementary to the project goals of
creating a vibrant, human-scaled mixed–use development, while respecting and enhancing the specific industrial heritage of
the Chain Works siteO
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CW2A: strong neighborhood characteristics, medium scale, classic detailing, townhouses and small apartment buildings
These images exhibit preferred characteristics related to:
▪ Building height
▪ Building massing
▪ Building scale
▪ Material / cladding variety
▪ Glazing percentage
▪ Façade length – short increments
▪ Architectural variety
▪ Human scale details on first floor and at roofline
▪ Traditional vertical proportions of windows and massing
This image exhibits medium sized housing types including
townhouses and small apartments in small scale traditional
buildingsO
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CW2B: larger scale apartment buildings, longer facades, well buffered from surrounding neighborhoods, buildings humanized
with classic design elements
These images exhibit preferred characteristics related to:
▪ Building massing
▪ Building scale
▪ Material / cadding variety
▪ Glazing percentage
▪ Façade length – longer buildings in this area
▪ Base, middle, and top building organization/detailingO
▪ Human scale details on first floor and at roofline
▪ Traditional vertical proportions of windows
▪ Architecturally articulated entries
▪ Simple vernacular building shapes
▪ Frequent entries along the fronts of buildings
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CW3A: Small scale but dense townhomes and small apartment buildings with high quality architectural detail and materials
sympathetic to neighborhood context
These images exhibit preferred characteristics related to:
▪ Building massing
▪ Building scale
▪ Material / cladding variety
▪ Glazing percentage
▪ Façade length – longer buildings in this area
▪ Base, middle, and top building organization/detailingO
▪ Human scale details on first floor and at roofline
▪ Traditional vertical proportions of windows
▪ Architecturally articulated entries
▪ Simple vernacular building shapes
▪ Frequent entries along the fronts of buildings
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These images exhibit preferred characteristics related to:
▪ Building massing
▪ Building scale
▪ Material / cladding variety
▪ Glazing percentage
▪ Façade length – longer buildings in this area
▪ Base, middle, and top building organization/detailingO
▪ Human scale details on first floor and at roofline
▪ Traditional vertical proportions of windows
▪ Architecturally articulated entries
▪ Simple vernacular building shapes
▪ Frequent entries along the fronts of buildings
▪ Integrating classic design with some modern
elements/materials
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CW3B: existing buildings – scale, massing, and articulation
These images exhibit preferred characteristics related to:
▪ Building height
▪ Building massing
▪ Building scale
▪ Material / cladding variety
▪ Glazing percentage
▪ Blank wall extents
▪ Façade length
▪ Front façade
▪ Integration of existing and new
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This image exhibits preferred characteristics related to:
▪ Building height
▪ Building massing
▪ Building scale
▪ Glazing percentage
▪ Blank wall extents
▪ Façade length
▪ Compact streetscape
These images exhibit preferred characteristics related to:
▪ Building height
▪ Building massing
▪ Building scale
▪ Material / cladding variety
▪ Glazing percentage
▪ Blank wall extents
▪ Façade length
▪ Integration of existing and new
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271-17.7 Definitions
These words or terms have a special meaning in § 271-17 for this PDO
BLOCK (CONTEXT OF ROADS OR THOROUGHFARES)
Area bounded by thoroughfares, or a combination of thoroughfares and barriers to continued development (examples: public
land, waterway)O
ELEVATION (context of structure)
Side or face of a building, from a head-on parallel projection viewO
ELEVATION, CORNER SIDE
Ffor a building on a corner lot, the building side facing a bounding secondary street, perpendicular to the front elevationO
ELEVATION, FRONT
Building side facing a bounding street right-of-way, thoroughfare, court, or other common area, forming its “face”O
DESIGN SPEED
Selected speed used to determine the various geometric features of the roadwayO The assumed design speed should be a
logical one with respect to the topography, anticipated operating speed, the adjacent land use, and the functional classification
of the highwayO Designers should select a design speed to use in geometric decisions based on safe operating speeds in a
complex environment rather than observed speedsO Bring the design speed in line with the target speed by implementing
measures to reduce and stabilize operating speeds as appropriateO Narrower lane widths, roadside landscaping, speed
humps, and curb extensions reduce traffic speeds and improve the quality of the bicycle and pedestrian realm
DISTRICT HEATING/COOLING
Facility providing centralized heating or cooling for multiple buildings or developmentsO
DWELLING UNIT (USE IN § 271-17O3 Permitted Principal and accessory uses)
An apartment, or a room or group of connected rooms, occupied or set up as separate living quarters for living, sleeping,
cooking, eating, bathing, and sanitation purposesO
FRONTAGE
Area between a building facade and a neighboring thoroughfare or court, including built and vegetated componentsO
FRONTAGE BUILDOUT
Length of building along frontage within setbacks of a blockO
PAVEMENT, FIXED
Durable, fixed surface formed from asphalt, concrete, tightly spaced segmental pavers, and/or similar durable materials, both
pervious and imperviousO
PAVEMENT, POROUS
Durable surface allowing easy passage of water through poresO This includes segmental pavers, open cell pavers, and similar
products; and ribbon/double track driveways with wheel strips of a durable pavement materialO This does not include crushed
stone, wood chips, dirt, grass, or other loose or unimproved surfacesO
SETBACK, AVERAGE
Average of the setbacks at 10 equally spaced points along a building side or elevationO
SITE ENVELOPE
A boundary on a site plan designated by the applicant as the limit within which a building or other feature of a Planned
Development will be placedO This device is intended to act as the functional equivalent of an individual building lot for a site
with a single owner, and does not imply or enable a current or future subdivision plat or individual ownershipO
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STUBOUT THOROUGHFARE
Improved dead-end thoroughfare ending at the boundary of a development site, serving as a provision for later extension and
connection to thoroughfares and development beyond the siteO
THOROUGHFARE
Paved travel way with travel lanes for vehicles and bicycles, parking lanes, and/or sidewalks or paths; and related infrastructure
and/or amenities; in a dedicated right-of-way, lot or easementO
271-17.8 Administration
(1) Site plan
(a) The Town will not issue a building permit for a building or structure in the Planned Development Zone area unless the
proposed building, structure, occupancy and/or use complies with a site plan the Planning Board approves under Article 23of
Town Code §270 (zoning)O The provisions of paragraph 2 below govern site plan modifications instead of §270-191O O In
addition to the requirements in §270-186, the site plan must show subzone locations (§ 271-17B)O
(b) Modification of site plans
A site plan that has received final site plan approval, or a structure existing before the initial approved final site plan for this PD
zone, may be modified upon the application of the owner for such modificationO The application must comply with § 271-17O8,
and Article 23 of Town Code §270 (zoning)O The review process is the same asas an initial application for site plan approvalO
Planning Board approval of a modification is required if the modification involves or includes any of the following:
• Enlarging the square footage of an existing or previously approved structure that by more than 20%, or 2,000 ft² gross
floor area, whichever is lessO
• Construction or relocation of five or more parking spaces;
• Construction, alteration, or renovation of the interior of a building involving a change in use;
• Alterating traffic flows and access, or a significant increase in the volume of traffic;
• A significant (in the judgment of the Director of Planning) change in the aesthetic appearance of any structure or site plan
element, including landscape and lighting details, from the last approved site planO
• A change in the impacts of the project on surrounding properties, such as an increase in noise, water runoff, light
illumination, or obstructions to views;
• Violation of any express conditions (including, without limitation, buffer zones, setbacks, and similar restrictions) last
• imposed by the Planning Board for site plan approval, or
• The Director of Planning determines that a movement or shift of a location of one or more buildings laterally or vertically
from the location or elevation shown on the final site plan:
o materially affects the overall site layout or specific elements of the site, including roads, traffic movements, sidewalks,
parking areas, viewshed, drainage, and buffer areas; and
o such shift violates any express conditions (including, without limitation, buffer zones, setbacks, etcO) imposed by the
Planning Board for site plan approvalO
Numerical criteria for the exceptions from the requirement of obtaining Planning Board approval are an aggregate maximum
[iOeO, if a 700 ft² addition is constructed on an existing 5,000 ft² building without obtaining Planning Board approval, pursuant to
Subsection 2(a)[1] above, construction of a second addition larger than 300 ft² would require Planning Board approval of a
modified site plan]O
Waiver of the requirement of Planning Board approval does not intend to allow construction that violates any other provision
of this section or of Town Code §270 (zoning); nor the requirement to obtain a building permit in those circumstances when
otherwise required by the terms of this section, Town Code §270 (zoning), or the Building CodeO
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Demolition, or a proposed demolition, of an existing or previously approved building, is a modification of a site plan subject to
the terms of this § 271-17O8O
(2) Miscellaneous
(a) Violations and enforcement
Any violations of the terms of this section is a violation of Town Code §270 (zoning)O It will be punishable according to Town
Code §270 (zoning) and New York State Town Law §268O Each week’s continued violation is a separate offenseO Regardless, the
Town of Ithaca reserves for itself, its agencies, and all other persons having an interest, all remedies and rights to enforce the
provisions of this sectionO This includes, without limitation, actions for any injunction or other equitable remedy, or action and
damages, in the event the owner of the parcel covered by this section fails to comply with any of the provisions hereofO
If any building or land development activity is installed or conducted in violation of this section, the Code Enforcement Officer
may withhold any building permit, certificate of occupancy, or certificate of compliance and/or prevent the occupancy of the
building or landO
(b) Town Code applicability
Except as otherwise specified in this section, all provisions of the Town of Ithaca Code s apply to all development, structures
and uses in Planned Development Zone NoO 16O
271-17.9 PD area
The following metes and bounds description defines the area of Planned Development Zone NoO 16 (PD-16)O Adoption of this
planned development zone amends the Official Zoning Map of the Town of Ithaca is by adding the PD-16 district at this
locationOO
Description of area rezoned to Planned Development Zone NoO 16
All that tract or parcels of land situate in the Town of Ithaca, County of Tompkins, State of New York, bounded and described
as follows:
ALL THAT TRACT OR PARCEL OF LAND situate in the Town of Ithaca, County of Tompkins, State of New York, being bounded
and described as follows:
<<Insert metes and bounds descriptions>>
Goldsmith Response to Comments from Wilson.docxJ:\Planning\GROUPS\Planning and Dev
Board\Miscellaneous\2019\Goldsmith Response to Comments from Wilson.docx
Goldsmith Response to Comments from Wilson
Hi all,
Thanks, Brian and Joe, for coming in today. I wanted to address a couple of the suggestions you made to
the planning board on January 9, and some other items that came up in the meeting.
"Codify Green Building Policy by July 4 with NO "INSTITUTIONAL EXEMPTIONS"--Institutions like Cornell
who are seeking this Exemption are already heavily subsidized by us tax payers because they are tax
exempt."
As I mentioned today, we do have to explore the idea of an institutional compliance path, but the
Working Group does have numerous concerns about the idea of allowing a separate path for
certain sectors.
We have a working goal of bringing a draft of the "plain English" green building policy to PEDC
for its June 5th meeting. This version would contain all of the content of the final law, but not
necessarily in code language.
"Adopt Greenhouse Gas Emission Reduction goals consistent with the most ambitious one's in the State"
To the best of my knowledge, this is done - the City's long term goal of 80% reduction in GHG
emissions by 2050 (Comprehensive Plan page 123, Energy Action Plan page 9) is in line with
adopted state goals, as well as the Paris Agreement. Governor Cuomo's January proposal for
a Green New Deal, included in the 2019 Justice Agenda, does mention a goal of carbon neutrality
economy wide, but does not include a date.
I think the case can be made that the City (and County, State, etc) should consider the goals of
reducing carbon emissions 50% by 2030 and 100% (carbon neutrality) by 2050; this is in line
with the science behind the latest IPCC report.
If you are referring to other NYS goals, please specify which one's you think are appropriate for
the City.
"Rejuvenate Energy Commission and have it report directly to the Mayor"
The Community Life Commission is tasked with Sustainability issues, so under the current
system, that would be the best place to bring discussion of energy issues. I am happy to attend
any meetings where energy and sustainability are on the agenda.
I was a little surprised by the comment that you would like the Green Building Policy to be more
ambitious.
Your voices, and those of others in the community, influenced the policy recommendations in the
GBP report, making the final recommendations more stringent than earlier versions. Your input
improved the proposed policy.
We are proposing an immediate 40-50% reduction in carbon emissions for new construction,
compared to NYS energy code and local building practices. The long term proposal is carbon-
neutral new construction by 2030.
I believe we need this level of efficiency mandated to have any chance of meeting our current
GHG reduction goals. That being said, this would be the strongest energy code in the state, and
there are not many others state or local codes in North America that are as stringent. Adoption
Goldsmith Response to Comments from Wilson.docxJ:\Planning\GROUPS\Planning and Dev
Board\Miscellaneous\2019\Goldsmith Response to Comments from Wilson.docx
would put us on the path to a carbon-neutral building stock - and a carbon-neutral city - by 2050.
Of course there is much, much more work to do!
Please provide additional explanation of the ways in which you believe the GBP falls short.
As discussed, the City is also interested in improving existing buildings. It was recommended in the GBP
report to do a similar, in-depth study of existing buildings and the policies and incentives that could be
enacted to dramatically improve efficiency.
We do not have the staff capacity to move that project forward while we are working on the
Green Building Policy. However, I do have some initial ideas for ways to make progress on this
issue; it is possible this could be completed by an intern, a college class, or by interested
community members, with guidance from City staff. I am happy to discuss further.
o Define an achievable scope of work for a GBP - Existing Buildings study.
o Research existing policies in the U.S.: California, NYC, Seattle, Boulder, elsewhere.
o Research best practices and emerging policy tools: benchmarking, mandated audits and
retrocommissioning, mandated upgrades at certain trigger points, voluntary programs
with high level of success.
o Develop menu of potential voluntary/mandatory programs to be considered in Ithaca.
o Analyze impacts: GHG reductions by 2030 and 2050; costs for various building types,
workforce implications, etc.
Thanks again for your time, and I look forward to working together productively to help meet community
climate action goals.
Regards,
Nick
Nick Goldsmith
Sustainability Coordinator
City of Ithaca, NY
Town of Ithaca, NY
City Office: 607-274-6562
Town Office: 607-273-1721 x136
Cell: 917-270-1683
http://cityofithaca.org/421/Sustainable-Ithaca
www.town.ithaca.ny.us/sustainability
www.facebook.com/IthacaSustainabilit y
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Phill ipsLytle LLP
C ity o f Ith aca Pla nnin g &Develo pm e nt Boa rd
108 E.G reen Stree t
Ith aca ,NY 14850
Re:Prop osed No rth C a mpus Resid ential Exp a n s io n
Site P la n Revie w Ap plica tion
Lette r from C.Bra yme r De manding Rehearin g
Dea r Me mbe rs o f t he Plann ing &Developme nt Boa rd :
Febru ar y 11,2019
As yo ur co unse l, w e h ave carefully r ev iewed th e lette r th at yo u rec e ive d d ate d Janu a r y
20,2019 fro m a tto rney C la udia Bra ymer r e lative to th e N o rth Campu s Residenti al
Ex pans io n p ro jec t ("NC RE"or "P ro ject")th at is c urre ntly p ending be for e th e Planning
&Developm ent Boa rd ("Planning Bo ard").We h av e carefull y co n s id e red M s.
Bray m e r 's d em ands for a re hea ring a nd a n ew v o te o n th e d et erminati on o f s ig nifica nce
mad e pursu ant to State En v iron m e ntal Qu alit y Revi e w Act /City En v ironmenta l
Q uality Revie w O rd in a nce ("EQ Rs").As we und erst and it,Ms .Braymer 's d em ands are
base d o n a llegatio n s that th e De cember 18,2018 un animous vo te o f th e Planning Boa rd
was m a d e b y a Board w ith a m ajority o f m embe rs who h ad im p e rmissible co nflicts o f
in te res t"and "w a s a lso m ade a t a m ee tin g for w hich proper n o tice w as n ot provided ."
As s u m ma r ize d be low , o u r re view o f th e fac ts a nd a p p lica ble law d o n o t s up port Ms.
Br ayme r's a lle ga tion s o r d e m a nd s .
I.Alle ga t ion of Imper miss ible Co nflicts o f Interest
Rega r ding Ms.Bra y m e r's a lleg atio n o f impermis sibl e co nflic ts o f int erest ,as w e
und er st and it ,Ms . Bra ymer 's basic a llegatio n is th at becaus e four m embers of th e
Planning Boa rd a re e mplo yees of Corn e ll Univ e rsity ,th ey a re di squalified from v o tin g
o n a ny m atter r elated to th e Pr o ject.As Ms .Bra ymer noted in h er letter ,conflicts of
in terest fo r Plannin g Board m ember s ar e gov e rn ed by C hapte r 55 o f th e Cit y o f Ithaca
C o d e ("C h a pte r 55 ")a nd Ar ticle 18 of N YS Ge ner a l Municipal La w ("Ar ticle 18").Bo th
C hapte r 55 a nd A r ticle 18 prohi bit Bo ard Me mbe rs fro m v o tin g in m atter s in w hic h th e y
ha v e a co n flict o f in te res t .H ow e v e r,"the m ere fac t o f e m p lo y ment ...d oes n o t
m and at e d isqual ifica ti on o f th e p ublic o fficial in vo lv ed in ever y i ns tance."Sara toga
S prings Pres.FOI/Ild .1'.Boff,110 A.D.3d 1326,1330 (3d De pt.2013)cit ing Ma tt eroj Scltupak
AT T O ~N E:'I'S AT L"w
AD A'"S .WALTER S,P ARTN ER D I R E CT 71 6 847 7023 AWAL TERS .P I-I I L L IP S LYTL E.CO M
ON E C AN Al-SIDE 125 MA li...ST RE ET BUFFALO,N Y 14203 -2887 P H ON E 7 16 847 8400 F AX 716 8 52 6100
N E W YO RK :A LBA N Y,B U F F ALO . C H A U T A U Q U A , G A RD EN C I TY,N E W V O R K .R O C H E S T E R I WA S H I NG TON .DC I C "NA DA :W AT ER L O O R E GI ON I P H I LL I PSLY T L E .CO M
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Febr uary 11,2019
P .Zoning Bo ard of A ppeals of Tawil of tvui rbletoion.31 A .D .3 d 1018 (3d Dept 2006) a nd
M ll tter of Ea die P .Tawil Boa rd of Tawil of N .Gree nbush,47 A.D .3d 1021 (3d Dep't 2008).
See als o,De Pao lo P .Tawil oj t thnca,258 A.D .2d 68, 72 (3d Dept.19 99),and Dudley P .
TO/I'll Boa rd of Tall 'l l of Pmttsburgh,2009 NY Slip Op 30426(U), St euben Cty,2009).
T he case of De Paolo P.To ton of ltluu:a,258 A.D.2d 68, 72 (3d Dept.1999)is p articularly
in structive o n thi s iss ue. In vi rtually id entical ci rcu ms tances,co mmunity m embers
opposed to a p roject being u ndertaken by Co rnell a rgued th at a d ecision of th e Ith aca
Tow n Board "m u s t be ann ulled because the Town Boa rd 's vo te was tainted by th e
participation of fo ur Board me mbers w ith p rohibited a nd undisclosed co nflicts o f
interests ."TaW Il of It/wen,258 A .D.2d a t 72.I n rejecting p etitioners 'c hallenge, th e Co urt
explained th at th ere was no co nflict of int erest beca use n o Bo ard m embers 'individu al
employment duties in volved the preparation,p ro curement o r p erf ormance o f a ny part
o f Co rnell's c hallenged project,nor was th eir remuneration directly a ffected b y th e
proj ect. Similarly,as noted in Ms.Braymer 's letter, C hapter 55 in structs employees to
a void taking a ction that will ben efit his o r h er car eer advancem ent,s alary or standing
w ith th e en tit y th at e mploys him or h er.Up on ca reful revi ew o f Ms.Braymer's letter,it
d oes not a ppear that M s.Braymer has o ffered an ything bey ond m ere co njecture a nd
s upposition t hat th e fo ur Board Members e mployed by Co rnell w ill face so me type o f
advers e repercussions to their ca reer a dva ncement,sa lary o r e mplo y ment s tanding if
the y faile d to vo te fo r th e n egativ e d eclaration w hich w as issued pursuant to the EQRs
o n Decembe r 18, 2018.
We a lso n ote, as ack nowledged by M s.Braymer in h er letter,th at th e issue of Plann ing
Board m ember e mploym e nt co nflicts w as ra ised during th e Pri vilege o f th e Floor
portion of th e December 18th meeting b y a m ember o f th e public b efore th e Planning
Board vo ted to unanimously a pp rove a ne g ativ e d eclaration pursu ant to the EQ Rs.
That led to a di scussi on am ongst th e Plannin g Bo ard with m e, o n the record,pri or t o
a ny vo te takin g pl ace .Each Board Member wa s clearly and unequivocally in structed
th at if,b y v irtue of the ir e mploy ment at Co rnell (or fo r an y o ther r eason),th ey w ere
u nable to ex ercise th eir d uties as a Planning Bo ard m ember in revie wing th e P roject
impartially a nd fairly,th at th e y w ere o bligated to recuse th emselves from a ny vo te o n
t he Project. Eac h m ember o f th e P lanning Board publicl y a ffir med th eir a bility to
ex ercise fair a nd impartialjudgment in th ei r review o f th e Pr oject.Moreover,the record
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Fe b rua ry 11, 2019
in t his m atter clearl y s hows th at P lannin g Board m e mbers have taken an ex t reme ly
har d look a t t h e NCRE a ppli ca ti o n ov e r th e co urse of m an y m onths of painstaki n g
review .Eac h and eve ry conce rn a bout p ot ential e n v iron mental impac ts (an d th e r e have
bee n hu ndre d s o f comme nts rai s in g co nce rns)ha s b een ca refully co nsi d e re d .Fro m m y
perspect ive,th e m e mb ers of th e P la nnin g Board have bee n cle ar in th eir in te nt to re ach
a t horoug h,we ll-supp orted co ncl us ion d espite NC RE's u npopula rity w ith s o me
ind ividu a ls wi thin th e co mmun i ty .
II.A llega tion s o f a Fa ilure to Co mply W ith Ci ty No tice Require m ents
Re garding Ms.Bra ym er 's d e mands for a re hea ring and new vo te bas ed upon th e
P lannin g Boa rd 's a lleged failure to comply w ith th e Cit y C ode 's m eeting n otice
re quire m e nts, Ms .Brayme r put forth thr ee differ ent arguments:1)a llega tions that the
timin g o f th e public notice s d istributed w ere in sufficient,2)a llega tions th at th e s p ace
pr o vid ed for public m eetings w as not lar ge e n o u g h to a ccommodate a ll th os e who
w is hed to participat e ,and 3)a lleg ations th at speakers were impermissibly limited by
th e Planning Board in th e tim e that the y w ere p ermitted to s peak at m eetings r e garding
th e P roject.W e a ddress ea c h arg ument :
A.T he Timing of th e Public No tices
Th e P la nnin g Bo ard ge nera lly p rovid es n otic e o f a ll m eetings o n th e Ci ty's we bsite
ca lendar m on ths in a d va nce o f th e actual m e eting d ate.Th e Dec ember 18,2018 mee ting
was inad vert entl y listed fo r Decem ber 24,2018 o n th e calen dar a s th e regul ar Planning
Boa rd meet in g is n ormally h eld o n th e 4th T ue sd ay of ever y m onth.H o w e ver ,s ince
December 24 th was C hristmas Eve,th e m eeting was m ov ed up a w eek.Thi s c hange
w as di scu ss ed a t th e Novem be r 27 th P lannin g Bo ard mee tin g a nd th e P lannin g &
Deve lopmen t Bo ard P rojec t Review Co mmittee N o tice of Mee ting &Age n da,d ated
Novem ber 30 2018,clea rl y lis ted th e ne x t Pla nnin g Board m e etin g d at e as Dece mb er 18,
2018.
We also note that,d e spite Ms.Bra ymer 's a lleg a tio n s th at n otice w as impro per ,t he
Decem be r 18 th Pla nning Boa rd m eeting w as we ll a tt e nd e d by co mmunity m ember s
w ho s hare h e r cl ie nt's v ie ws a n d, d urin g th e Pr ivilege o f th e Floor p ortion o f th e
mee ting, a dvoca ted clea rl y a nd p assio na te ly for th e Planning Bo ard to requ ire th e
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Febru ary 11,2019
p re pa ratio n o f a n Environ mental Impact Stateme n t.Agai n,th ese co mm e nts were
ca refully co ns ide re d b y the P lannin g Board p rior to t aking a v o te o n th e d et erminati on
of s ignificance for th e Proj ect.
Finally, eve n if th ere w e r e a n issu e wi th p rop e r n otice o f th e m e etin g (as di scussed
a bove,we d o n ot be lieve tha t t here was),Cit y Co de §78·8,ex plicitly provi de s th at a n
un in tentiona l fail ure to co m p ly w i th Ci ty C ode m ee tin g n oti ce p rovisio ns "shall n ot
a lo ne be grou nds for in valid ating a ny ac tion ta ken."
B.S pace Pr ovide d for P ublic Atten dance o f P lanning Board M ee tings
Ms. Braym er h as a lso a llege d that "there have be en se ve r a l m ee tin gs in w hic h th e s pace
was n o t la rge e nough to s u fficiently a nd sa fe ly a cco mm o da te a ll o f th e p e opl e w h o
we re in teres ted in o bse rving th e Planning Boa rd 's d eliberati on o n th is m atter ."In m y
ex per ience,incl uding th e Planning Bo ard m eet ings th at I a tt e nd e d o n O ctober 30,2018,
Nove mbe r 27,2018 a nd December 18,2018 w he n th e P roje ct wa s o n th e ag e nda ,th e
Plannin g Boa rd m ade e ve ry e ffo rt to acco mm oda te th os e m embers of th e publ ic w h o
wi s hed to be p h ysica lly pres ent for th e m e etings.O nce th e r egula r s ea tin g a r eas
beco me full , a d d ition a l se ating wa s s upplie d o n th e s ide a nd to w a rd s th e fro nt o f th e
m e eting roo m.New York O pe n Me e tin gs Law provides t h a t th e P la nnin g Bo ard m u s t
make a ll reasonabl e effo r ts to acco m mod ate th e p ublic.'T hi s is p r ecisely w hat th e
Pla nnin g Board d id .
C.Public O p port un i ty to Speak a t P lann ing Bo ard M ee tin gs
Fina lly,Ms.Bray m er d ema nd s a r e hearing a nd ne w vo te o n th e d ete rminatio n o f
s ig n ifica nce fo r th e Proj ect based o n a n a llegatio n th at th e Planni ng Boa rd hind er ed
publ ic p a rticipa tio n in th e Project's re view p roces s b y lim iting s p eake r s who w is h ed to
s pea k a bout th e P roj ect durin g Pri vilege o f th e Floo r to 90 seco nds.This ar gument
a ppe ars w h o lly w ith o ut m erit.The Plan ning Bo ard is under n o legal o bliga tio n to tak e
a ny p ublic co m ment o n a p roj ect und e r r e view o utsid e of a n y publi c h e aring.Pr ivile g e
of th e Floor h as been es tablishe d to g ive m e mb ers o f th e publi c a n o pp o rtunity to
I "Public bodies s ha ll m ake or cause to be made a ll reasonable efforts to e ns u re t ha t m eetings a re he ld in a n
a p p ropr ia te faci lity w hic h c a n adeq ua tely ac co mmodate me m bers of t he pu blic w ho w is h to a tt e nd s uch
mee tings ."N .Y.P u b.O ff.Law §103(d)(M cKinney)(e mp hasis a d ded).
-
-
C ity o f Ith aca P lanning &Deve lopment Boar d
Page S
Fe b ruary 11, 2019
p ro vide o n-going input a nd fe edback as p rojects proce ed th rou gh th e r eview process .
Me mbers of th e pu blic a re a lso e ncou raged to p ro vid e w ritten co mment o n projects
thro ughou t Pl anning Bo ard p rocee dings. T he limitation o n t ime for eac h s peaker
d uring P rivilege o f th e Floor was th e s imple res ult of th e n umber o f pa rticip ants w ho
w ished to m ake th eir views o n th e P roject k nown. H ad th e Pl a nning Bo ard a llowe d fo r
more tim e per s peaker,t hen far fewe r indi viduals w ould h ave b een a ble t o p articip ate
in th e P rivilege of th e Floor.
Ms .Braymer's letter a lso ma kes vague reference to o ther "subtle ways th at th e Pl anning
Boar d h as hindere d public p articipation."H owev er,du ring a ll of th e m e etings th at I
a tte nded,th e Pl anning Bo ard ac tively encou raged public p articipation a nd co mment o n
the P roject. Mo nths o f review w ere co nducted in the public light w ith a ll public
co mments given a ttent ion a nd r eview. S peaking time was a ffor ded to th e publ ic, a
g enero u s g rant o f tim e a nd r es ources from th e Planning Boa rd,so th at th e public co uld
q uite lit erall y vo ice th eir co mmen ts.A t n o t ime h as th e P lanning Board s hied away
from th e opportunity to involve th e publ ic in th e co ns idera tion o f NC RE.T he s imple
fac t th at t he P lanning Bo ard d id n ot,ultimately ,s ide w ith M s.Bra ymer's clie nts'
p osition,i n no w a y de mons trates that Ms .Braymer's clients 'a bility to ex p ress th eir
v iews was in any way hindered.In fa ct, th e r ecord m ore th an amply d emon strates th at
th is was s imply n ot th e case.
CONCLUSION
As d etailed a bove,a revi e w o f th e available facts a nd t he a pplicable law d o n ot s upport
Ms. Bra y mer's a llega tions or d em ands.
Ve ry tr uly y o ur s ,
P hillips Lvtl e-t:I::
B Y ~-~
Adam S. Wa l ters
cc:Cla udia K.Bray m er
ASW
f)p c #01·1 2 1-1 107 .1
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BRAYMER LAW, PLLC
PO Box 2369
Glens Falls NY 12801
(518) 882-3252
claudia@braymerlaw.com
January 20, 2019
Via E-mail Only
Planning and Development Board
City of Ithaca
City Hall
108 E. Green Street
Ithaca NY 14850
Re:Proposed North Campus Residential Expansion
Site Plan Review application (Cornell University)
Dear Planning and Development Board Members:
I represent a group of citizens who are concerned about the adverse environmental
impacts of the North Campus Residential Expansion (“NCRE”) proposed by Trowbridge Wolf
Michaels Landscape Architects for Cornell University. It continues to be the position of this
group of concerned citizens that the preparation of an environmental impact statement is
necessary to ensure that the adverse impacts of the proposed NCRE project can be fully reviewed
by this Board, all involved and interested agencies, and the public.
Although the Planning and Development Board (“the Board”) determined that this
proposed project may proceed without an environmental impact statement, that decision was
made by a Board with a majority of members who had impermissible conflicts of interest. It was
also made at a meeting for which proper notice was not provided .
We demand a rehearing and a new vote on the determination of significance, at a properly
noticed meeting, with the conflicted Board Members recused. We further demand that the Board
proceed hereafter, in full compliance with State and local laws.
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I.The Hearing was Fatally Flawed by Impermissible
And Numerous Conflicts of Interest
First, we want to acknowledge that the Board is made up of hard-working individuals.
We are not accusing any Board member of intentional wrongdoing. Conflict of interest rules are
not, however, simply meant to prevent intentional corrupt behavior. They are also meant to
protect decisionmakers from bias and to protect public processes and respect for the rule of law.
By making a significant environmental decision where a majority of members were employed by
the applicant, the Board has fatally injected bias into its decision making. Where the applicant
itself further failed to identify and disclose these conflicts, as it is required to do, the applicant
has compounded the conflict issue. This concern was raised by a member of the public at the
meeting on December 18, 2018. That person, a retired Sociologist, noted the problem of human
bias, whether it be conscious or unconscious, as it relates to the Members employed by Cornell.
As stated in the City’s Code of Ethics, “City officials and city employees must exercise
their official duties solely in the public interest and must avoid actual conflicts of interest to the
greatest extent possible.” Code of Ethics § 55-7. “City officials and city employees should avoid
circumstances which compromise their ability to make impartial judgments solely in the public
interest and should, to the greatest extent possible, avoid even the appearance of conflict of
interest.” Code of Ethics § 55-7.
Each Board Member must avoid “potential conflicts of interest when voting or taking
other discretionary action regarding all matters with which he or she deals on behalf of the city.”
Code of Ethics § 55-7. A Board Member
“shall exercise particularly careful diligence in avoiding any actual or potential conflict of
interest when voting or taking other discretionary action on any matter brought before
any element of the city government by any entity that employs said [Board Member]. In
any such case, the involved [Board Member] should attempt to avoid taking any action
that could reasonably be interpreted as benefiting his or her career advancement, salary or
standing within the entity that employs him or her.” Code of Ethics § 55-7.
Being in the direct employ of the applicant is a clear conflict. Under analogous state law,
a municipal officer “shall be deemed to have an interest in the applicant when he, his spouse, or
their brothers, sisters, parents, children, grandchildren, or the spouse of any of them . . . is an . . .
employee of the applicant”. See Gen. Mun. Law § 809. Accordingly, where a Board Member is
employed by the applicant in a matter pending before the Board, the Board Member “shall
immediately declare the nature of the conflict of interest and shall refrain, where appropriate,
from taking any action or inaction that would affect the outcome of the matter.” Code of Ethics §
55-8.
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Here, four of the seven Members of the Board are themselves employed by Cornell ,
so those Members have an interest in the applicant. To date, they have all participated in the 12
review of the project, and have shaped the deliberation on the SEQRA question of determination
of significance. Where the number of impermissibly biased members forms a majority, the
decision is fatally infected with bias, and the public can have no confidence in the resulting
decision.
In fact, when hearing issues related to this project, the Town of Ithaca properly noted and
avoided this exact conflict. The Planning Board’s Vice Chair, Liebe Meier Swain, is Cornell
Health’s Director of Benefits & Finance, Assistant Director of Administrative Services. Unlike
here, she recused herself, and did not participate in the discussion of this project, so as not to
improperly influence the Town Planning Board’s decision making.
Cornell management has impressed upon its faculty, staff, students, and the public that it
does not want to spend the time to prepare an environmental impact statement for this important
project, estimated to cost $175 million. Cornell hoped to have at least part of the project
completed for occupancy in the fall semester of 2021 to: “. . . address a significant deficit of
on-campus housing for Cornell students, as well as accommodate an anticipated increase in
enrollment”. The Ithaca Voice, May 15, 2018, quoting Kimberly Michaels, Principal for
Trowbridge Wolf Michaels Landscape Architects LLP. According to Cornell: “Vice Presidents
Ryan Lombardi and Rick Burgess held an open forum for faculty and staff, during which they
discussed the NCRE.” Kimberly Michaels’ October 12, 2018 letter to Planning Board, p. 13.
The message of Cornell’s urgency to complete the project quickly would have been
conveyed to the four Members of the Board who are employed by Cornell. In fact, Ms.
Michaels, representing the employer of four Board members, actually conveyed that message to
the Board Members at the Board meetings.
1 Upon information and belief, Board Member Matthew F. Johnston is employed by Cornell as a
Manager of Facilities in the Division of Facilities and Campus Services, which is the Division of
Cornell that oversees the proposed project. Mr. Johnston’s Division provides oversight of
planning and maintaining university buildings, utility infrastructure, and energy and
sustainability efforts for the physical camps. Mr. Johnston has a direct conflict of interest and
should have recused himself from all review of the project, including the vote on the negative
declaration.
2 Upon information and belief, Board Member Jack Elliott is employed by Cornell in the
Department of Design and Environmental Analysis. Upon information and belief, Board
Member Mitch Glass is employed by Cornell in the Department of City and Regional Planning
and Landscape Architecture. Upon information and belief, Board Member Garrick Blalock is
employed by Cornell as an Associate Professor in the Dyson School of Applied Economics and
Management. These Board Members have a clear conflict based on their employment by
Cornell.
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Given Cornell’s status as the employer of the majority of Board members, the Board
Members employed by Cornell must refrain “from taking any action or inaction that would affect
the outcome of the matter.” Code of Ethics § 55-8.
Therefore, we demand that the Planning Board re-take its vote on the SEQRA
determination of significance of this project. Failure to do so will result in any subsequent
consideration of the project to rest upon a fatally flawed initial determination. Failure to do so
would, in our view, provide grounds for a legal challenge to the Planning Board’s decisions, and
perhaps more importantly will result in a lack of confidence in the Planning Board Members’
“ability to make impartial judgments solely in the public interest.” Code of Ethics § 55-7.
II.Public Notice
City Code § 78-5(A) requires public notice of a meeting to be given at least one week
prior to the meeting. See City Code § 78-5(A). One member of the public expressed concern at
the December 18, 2018 meeting that adequate public notice of the meeting was not given as a
result of the meeting being moved up from December 24 to December 18. We recognize that the
Board was likely juggling holiday obligations, and was not wanting to delay the meeting. Again,
we are not accusing you of intentional wrongs. However, in a case like this where the public has
a clear interest in the meeting, and where the project is significant, it is fair to ask that the board
strictly adhere to the rules put in place to ensure fairness.
In addition, there have been several meetings (e.g., October 30, 2018) in which the space
was not large enough to sufficiently and safely accommodate all of the people who were
interested in observing the Planning Board’s deliberation on this matter. See City Code §
78-1(A). Also, despite the notice provided in the agenda that those wishing to speak during
privilege of the floor would have three minutes to do so, the Planning Board has limited speakers
to 90 seconds if they were commenting on the NCRE project. This is just one of several subtle
ways that the Planning Board has hindered public participation.
The NCRE project is important to many members of the public. The Planning Board
must make every effort to ensure that the public is given the opportunity to participate in, as well
as observe, the Planning Board’s review of the proposed NCRE project. The Planning Board
must give adequate notice and then must conduct the meeting in accordance with the notice
provided.
III.Conclusion
A rehearing and new vote are necessary so that any subsequent decisions are not based on
an illegal foundation. In addition to the legal issues outlined above, we have some substantive
comments on the Board’s site plan review of the project. Those comments are enclosed
herewith.
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Thank you for your consideration and careful deliberation in this matter.
Sincerely,
/s/ Claudia K. Braymer
Claudia K. Braymer
cc: City of Ithaca Common Council
Town of Ithaca Town Board
Town of Ithaca Planning Board
Village of Cayuga Heights Trustees
Village of Cayuga Heights Planning Board
Clients
enc.
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BRAYMER LAW, PLLC
PO Box 2369
Glens Falls NY 12801
(518) 882-3252
claudia@braymerlaw.com
January 20, 2019
Enclosure to January 20, 2019 Letter from Braymer Law, PLLC
Comments to City of Ithaca Planning and Development Board
Re:Proposed North Campus Residential Expansion
Site Plan Review application (Cornell University)
I.The Planning Board Should Obtain an Independent Consultant
The City Code allows the Planning and Development Board (“the Board”) to use
consultants “to aid [your] decision on the proposal”. City Code § 276-6(C)(2). However, the
Planning Board failed to engage the services of an independent technical consultant to assist with
the review of this large and environmentally complex project. The Planning Board’s failure to
use its own consultant further compounded the bias present in the review of the proposed project.
The proposal is a massive project that will impact 25.6 acres of land, and will include
2,000 new student beds, a dining hall, and central student lounge/social spaces across a total of
five buildings, between two and six stories in height (with the tallest building being 77 feet high),
covering 767,400 square feet of space. Energy use and its environmental impacts are clearly
complex and in question for this project.
Cornell paid its own consultant, Taitem, for assistance with evaluating the project’s
impacts. In addition, at its meeting on December 5, 2018, the Common Council approved the
Planning Division’s request to retain Adam Walters, for a sum of up to $20,000.00, to provide
legal counsel to the Planning Board for your review of the proposed NCRE project. The
rationale for approval was that the “project spans three municipalities and consists of two
residential complexes with 2,000 beds, a 1,200-seat dining facility, and associated program space
. . . [and that] the potential environmental issues of the project are particularly complex and have
generated an unusually large amount of public interest [, and to] produce the most defensible
environmental record possible”.
Similarly, the Planning Board should have its own expert, independent technical guidance
to review a project of this magnitude. Several names of qualified consultants have been provided
to the City’s Sustainability Coordinator Nick Goldsmith. The City Code specifically allows for
the Planning Board to hire an independent consultant. Therefore, the Planning Board should
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have an independent technical consultant review the proposal and provide its comments to the
Planning Board to aid in your decision making.
II.The Project as Proposed Does Not Meet the Site Plan Review Criteria
As the Planning Board proceeds with reviewing the proposed project, you should
remember that the goals of site plan review include:
A.Preserving and enhancing neighborhood character.
B.Achieving compatibility with adjacent development and uses.
C.Mitigating potentially negative impacts on traffic, parking, drainage, the
landscape and similar environmental concerns.
D.Improving the design, function, aesthetics and safety of development projects and
the overall visual and aesthetic quality of the City.
E.Promoting environmental sustainability in new development, redevelopment and
long term planning.
City Code § 276-1. The project as currently proposed does not satisfy the goals or
criteria for granting site plan review approval. Therefore, the project application must be
modified or denied.
A.Impacts on Trees
The site plan review criteria emphasize the “protection of existing mature vegetation,
especially trees over eight inches DBH (diameter-breast-height)”. City Code § 276-7(A)(1)(b).
The proposed project would result in at least 291 trees, including 41 trees over 12” DBH, being
cut down. Even the applicant’s Arborist Report provided recommendations for specific,
important trees or tree stands to be preserved, but that were presently slated for removal. See
Cornell’s Application Appendix. The applicant must be required to avoid the removal of the
existing trees, particularly those trees over 8” DBH. See City Code § 276-7(B).
B.Impacts on Community Character and Historic Resources
The site plan review criteria also emphasize the “[p]rotection of, and compatibility with,
other nearby features and areas of importance to the community, including but not limited to
parks, landmarks, neighborhoods, commercial areas, and historic districts”. City Code §
276-7(A)(1)(c). The project is adjacent to the Cornell Heights Historic District, an historic site
in the City of Ithaca. As demonstrated by the applicant’s visual simulations, the proposed project
will be visible from the Cornell Heights Historic District and has the potential to cause
significant adverse impacts on the historic district and the character of the community in that
neighborhood. Moreover, the proposed project will be highly visible from Jessup Road and
Pleasant Grove Road, and will be in sharp contrast to the current land use visible from those
public rights of way.
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The Planning Board’s environmental assessment form, Part III (p. 7), already recognized
that “much can be done to minimize any potential impact to views during Site Plan review
through the selection of building materials and colors, and the development of a landscape plan
that incorporates year-round screening in particularly sensitive areas”. Therefore, at the very
least, the applicant must be required to incorporate compatible building materials and colors and
develop a landscape plan with year-round screening. The applicant’s new building and
landscaping plans must be made available for the public to review.
Additionally, the project has the potential to negatively impact the Fuertes Observatory,
an important nearby community asset. The Planning Board must review the project’s lighting
plan carefully to “confirm that all lighting is dark sky compliant, no spillage occurs onto adjacent
properties, and that nighttime lighting of buildings does not impact adjacent city neighborhoods”
(environmental assessment form, Part III, p. 18) or the Fuertes Observatory.
C.Impacts on the Visual Quality of the Site and its Vicinity
The proposed project would alter 26 acres of land, add six new buildings, and reorganize
existing parking lots, vehicular access and recreation fields. The illustrated site plan and
renderings of the proposed layout of the buildings show that the project lacks a “perceivable
form and order”, and that there is no “relationship between the proposed development and the
nearby streetscape, landscape, and the [existing] built environment”. City Code §
276-7(A)(3)(a),(d). The Planning Board must require changes to the project to ensure that the
layout of the project’s elements is orderly, proper and effective, and appropriate in arrangement,
form, scale, proportion, color, pattern and texture of buildings and other site improvements. City
Code § 276-7(A)(3).
D.Impacts on Traffic
The proposed project would reduce the level of service at four intersections, result in the net
removal of 396 parking spaces from North Campus, and would increase pedestrian and bicycle
traffic. The Planning Board must ensure that the parking areas meet the requirements of Code §
276-7(C), that the project has the required bicycle parking spaces in appropriate locations and
designs per City Code § 276-7(D), and that the project provides sidewalks for safe student
pedestrian access and circulation. See City Code § 276-7(A)(5)-(8). Merely exploring the
“possibility” (environmental assessment form, Part III, p. 12) of improved vehicular and
pedestrian traffic plans is not sufficient; the applicant must be required to incorporate actual
traffic improvements into its proposed site plan.
E.Energy Efficiency, Renewable Energy, and Green Design
The proposed project would increase the physical footprint of the campus, and would
“increase overall energy usage on campus by 1.4%” (environmental assessment form, Part III, p.
14). The Planning Board’s review so far has not discussed design alternatives in any meaningful
way. Merely accepting the mitigation proposed in the report provided by Cornell’s expert,
Taitem, does not satisfy the Planning Board’s obligation to conduct its own, independent review
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of alternatives and mitigations measures. The Planning Board must require Cornell to examine,
in the site plan review process, the use of alternative building designs (including Passive House
design principles), positioning, and alignment in order to increase the energy efficiency of the
proposed project. See City Code § 276-7(A)(10).
Even with a continued reliance on Cornell’s Combined Heat and Power plant, the
project’s gas consumption could be reduced by using an enhanced building envelope. A case
study was previously provided to the Planning Board showing that a Passive House dorm was
constructed at a lower cost than a LEED dorm, while substantially reducing energy demand.
Cornell should be required to examine this alternative because it could reduce energy demand,
without increasing the cost of construction.
In addition, the Planning Board must require Cornell to examine the use of these
renewable energy sources to power the new buildings, rather than the proposed use of the
Combined Heat and Power Plant, which is fueled by a non-renewable energy source (natural
gas). See City Code § 276-7(A)(10). This is a major new construction project that can be
designed to use renewable energy sources, which are available to Cornell now. Cornell has the
capabilities and resources to accomplish the goal of using renewable energy, and it should be
required to use this fuel source for this new construction project.
Furthermore, the use of a non-renewable energy source for the proposed project would
not be compatible with the City’s Climate Smart Community Pledge, the City’s Green Building
Policy, or Cornell’s Climate Action Plan. See City Code § 276-7(A)(11). Therefore, the project
as proposed must be modified to use renewable energy sources, or it should be denied.
III.An Environmental Impact Statement Is Needed
A project of this magnitude, in terms of its size and impacts, needs an environmental
impact statement (“EIS”). The proposed project is classified as a Type I action, which “carries
with it the presumption that it is likely to have a significant adverse impact on the environment”
requiring the preparation of an environmental impact statement. 6 NYCRR § 617.4(a).
Previously, in recognition of the potential for significant adverse impacts due to its major dorm
construction projects, Cornell prepared an EIS.
Here, instead of preparing an EIS, Cornell prepared a report of the environmental impacts
of the project and its proposed mitigation measures. The Planning Board adopted Cornell’s
assessment of the environmental impacts of the project and incorporated Cornell’s report,
including the discussion of impacts and mitigation measures, into its State Environmental
Quality Review Act (“SEQRA”) environmental assessment form (“EAF”) Part III.
The Planning Board’s environmental review was inadequate and legally flawed because
the SEQRA EAF cannot “legitimately serve as a substitute for an EIS and the attendant analysis
and public discussion entailed in a proper SEQRA review”. S.P.A.C.E. v. Hurley , 291 A.D.2d
563, 565 (2d Dept. 2002) quoting Matter of West Branch Conservation Assn. v. Planning Bd. of
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Town of Clarkstown , 207 A.D.2d 837, 840 (2d Dept. 1994). In Matter of West Branch
Conservation Assn. , the Court held that the “the Planning Board should have issued a positive
declaration and required the preparation of an EIS.” Matter of West Branch Conservation Assn.
v. Planning Bd. of Town of Clarkstown , 207 A.D.2d 837, 841. In that case, the Court found that
in “discussing mitigation techniques and manners in which to protect the environment, the
Planning Board inherently acknowledged that the project may cause significant environmental
impacts”. Id . at 840-841. Therefore, the “Planning Board’s negative declaration was arbitrary
and capricious and unsupported by the record.” Id . at 841. The Court remitted the matter to the
Planning Board for the preparation of an EIS.
Here, the Planning Board’s rationale for issuing a negative declaration discussed in detail
the project’s impacts and the proposed mitigation measures to reduce those impacts. In doing so,
the “Planning Board inherently acknowledged that the project may cause significant
environmental impacts”. Id . at 840-841. Accordingly, the “Planning Board’s negative
declaration was arbitrary and capricious”. Id . at 841.
Notably, the Planning Board’s negative declaration was also arbitrary and capricious
because the board ignored or misconstrued the SEQRA criteria for determining the potential
significance of the impact of the applicant’s proposed energy use, including making a spurious
comparison between the project’s emissions and nation-wide emissions in the Planning Board’s
EAF Part III findings.
More generally, the Planning Board failed in its findings to address the many comments
describing missing information necessary to a competent SEQRA analysis, and failed to provide
substantive responses to the many relevant comments documenting faults in the SEQRA process
and determinations.
Upon reevaluating the determination of significance for this project, the Planning Board
should issue a positive declaration and require the preparation of an EIS, which will allow all of
the project’s impacts to be fully and properly examined and mitigated or avoided.
IV.Conclusion
This Board must diligently and fairly review and consider the proposed project, and work
to avoid and mitigate the project’s negative impacts as part of the site plan review process. See
City Code §§ 271-1, 276-7(A)(1). We look forward to observing a robust review process by the
Planning Board. Hopefully Cornell will embrace this opportunity to improve its project and
demonstrate that it is a global leader in responsible project design. If we can be of any assistance
to the Planning Board, please let me know.
5
PROPOSED RESOLUTION
Approval of Project Changes
City of Ithaca
Site Plan Review
Harold's Square (Mixed-Use Project)
123-127,133, 135 &137-139 E.State St.(The Commons)
Planning &Development Board
February 26, 2019
WHEREAS:the project applicant is requesting materials and building facade changes for the proposed
Harold's SquareMixed-Use Project. The project was originally approved by the Board on August 27,
2013, and for which the Board subsequently granted a two-year extension of Site Plan Approval until
August 27, 2017. The Board later approved building facade and materials changes on August 23, 2016,
and on May 23, 2017, and
WHEREAS:in accordance with §276-6 D.,"Changes to approved site plan,"the Director of Planning
and Development has reviewed the changes and determined the changes are significant enough to require
re-opening the review, but not significant enough to require a new Site Plan Review Application,and
WHEREAS:The applicant is now requesting the following changes:replacement of precast concrete
elements on the first floor north and west facades with Terra Cotta, as previously approved for the 2
nd to
5th floors;replacement of precast concrete copings on the 5
th story roof at the north and west facades with
aluminum composite panel copings; the addition of residential balconies to the NW, SE and SW comers
of the building;elimination of two windows per floor on the south facade of the building to comply with
the percent openings allowed by the 2015 International Building Code as adopted by New York State;
redistribution of the windows on the five-story portion of the west facade,retaining the same number of
windows;removal of 30 micro-units from the 2
nd to 5
th floors to accommodate 10,000 SF of commercial
space;increasing the Terra Cotta cladding on the east elevation of the 2
nd to 5
th floors to cover the entire
facade facing the courtyard (replacing insulated metal panel on this portion of the facade); and
introducing Terra Cotta cladding on the 1st floor of the Sage Building west elevation facing the courtyard,
and
WHEREAS:the Board has on February 26, 2019,reviewed and accepted as adequate:revised plans
entitled "Proposed Building Materials,North Elevation,""Proposed North Elevation,""Comparative
Partial North Elevation,"and "Comparative North Elevation Perspectives,"dated February 15, 2019, and
all prepared by CJS Architects,and
WHEREAS:the Board has, on February 26,2019,determined that the proposed changes are consistent
with the Negative Declaration of Environmental Significance filed on June 25, 2013,therefore,no further
Environmental Review is required,now,therefore,be it
RESOL VED:that the City of Ithaca Planning and Development Board approves the changes proposed by
the applicant,subject to the following conditions:
Unmet Agreed Upon Mitigations as Per FEAF,Part 3,Adopted on June 25,2013
i.Noise-producing construction activities shall be limited to Monday through Friday between 7:30
a.m. and 7:30 p.m., and
11.Rehabilitation of the Sage Block will include the following:
a.Maintaining the existing terra cotta cornice at the north and northwest comer of the
building,and
b.Cleaning,repointing,and repairing the existing exterior masonry walls, and
c.Repair and/or replacement of the existing roof, and
d.New fenestration at existing masonry openings on the north and west sides of the
building.When practical,existing windows will be repaired,but if they are deteriorated
to the point of requiring replacement,they will be replaced to match design, color,
texture, and perhaps material construction,and
e.Replacement window design will reflect a characteristic William H. Miller divided-light
pattern at the upper window areas, similar to what currently exists on the Sage Block
building, and
f. The incorporation of the west fenestration into the new project atrium space, and
g. The existing interior character will be restored and maintained wherever possible, with
additional modifications developed per the needs and requirements of potential tenants,
and
iii. Plans for the exterior renovation of the Sage Block will require review and approval by the Ithaca
Landmarks Preservation Commission (ILPC), using the same standards it uses to evaluate
proposed work on locally-designated buildings. Of particular interest are (1) the preservation of
the entire cornice; (2) evaluation of the existing fenestration by a qualified professional with
significant experience in restoring wood windows; (3) proper techniques for cleaning,repointing
and repairing the existing exterior masonry; and (4) reconstruction of the northwest comer where
brickwork is interlocked with the brickwork of 135E. State Street, and
IV.The carved limestone detailing and green roof tiles of 123-127E. State Street shall be salvaged
and donated to an architectural elements reuse firrn or agency - or,if feasible, the salvaged
carved limestone detailing could be used in the interior of the Harold's Square project,if the
applicant so desires, and
Additional Unmet Conditions Identified in Site Plan Review:
v. Submission to Planning Board of site details, including, but not limited to, lighting, signage, site
furnishings and paving materials, and
vi.Submission to the Project Review Committee of the final-t"floor roof plan (now 5
th floor); this
plan shall incorporate a light-colored roofmg material and,if feasible, some areas of green roof,
and
VII.Tower roof shall also be of light-colored roofing material, and
VIII.Bicycle storage for retail, office and residential tenants shall be provided within the building, and
IX.Approval from the Planning Board of the proposed bridge connection to the Green Street Parking
Garage, and
x. Bridge connection to the Green Street Parking Garage requires approval from the Board of Public
Works, and
Xl.Applicant must obtain an encroachment agreement for any portion of the project, including door
swings, that impacts City property, and
XII.Any changes to the design of the building that affects the exterior appearance, including rooftop
mechanicals,must be reviewed and approved by the Planning Board, and
xiii.Approval in writing from the Fire Department confirming the project complies with all life safety
needs, and
XIV.Approval in writing from the City Stormwater Management Officer.
Moved by:
Seconded by:
In Favor:
Against:
Abstain:
Absent:
Vacancy: None
HAROLD'S HOLDINGS LLCITHACA, NYHAROLD'S SQUAREPROPOSED BUILDING MATERIALSNORTH ELEVATIONUPDATED VERSIONFEBRUARY 15, 2019S I G N A G ES I G N A G EF - INSULATED METAL PANEL SYSTEMF1F2COLOR:CHAMPAGNE GOLDCOLOR:BRONZEG1*G2COLOR:CHAMPAGNE GOLDCOLOR:BRONZEG - ALUMINUM STOREFRONT SYSTEMH1H2COLOR:CHAMPAGNE GOLDCOLOR:BRONZEH - ALUMINUM WINDOW SYSTEM *FIXED AND WITHPROJECTING AWNING VENT*FIXED AND WITHPROJECTING AWNING VENT*A - TERRACOTTA RAINSCREENA1 - SMOOTHA2 - STRIPEDVARIED COLORS:PEARL & CREAMCOLOR: FLINTA3 - SMOOTHCOLOR: FLINTD - ALUMINUM COMPOSITE METAL PANELCOLOR:CHAMPAGNE GOLDE - MECHANICAL SCREEN SYSTEMLOUVERED PROFILECOLOR:CHAMPAGNE GOLDG2A3G1A2A1A1A3A1A2A2A3A3A2A2DDEF1F2F2H2H1H2F2A3A3A3S I G N A G ES I G N A G ES I G N A G ES I G N A G E
HAROLD'S HOLDINGS LLCITHACA, NYHAROLD'S SQUAREPROPOSED NORTH ELEVATIONUPDATED VERSIONFEBRUARY 15, 2019S I G N A G ES I G N A G ES I G N A G ES I G N A G ES I G N A G ES I G N A G E
HAROLD'S HOLDINGS LLCITHACA, NYHAROLD'S SQUARECOMPARATIVE PARTIAL NORTH ELEVATIONUPDATED VERSIONFEBRUARY 15, 2019S I G N A G ES I G N A G EJUNE 22, 2017 VERSIONS I G N A G ES I G N A G ES I G N A G ES I G N A G E
HAROLD'S HOLDINGS LLCITHACA, NYHAROLD'S SQUARECOMPARATIVE NORTH ELEVATION PERSPECTIVESJUNE 22, 2017 VERSIONUPDATED VERSIONFEBRUARY 15, 2019
Phone: 607.379.9175 Email: whitham@whithamdesign.com 142 East State Street, Rear Ithaca, NY 14850
February 18, 2019
Lisa Nicholas, Deputy Director of Planning
Division of Planning and Economic Development, City of Ithaca
108 E. Green Street, 3rd Floor
Ithaca, N.Y. 14850
RE: City Centre Signage-Downtown Design Guidelines
Dear Lisa,
Thank you for reminding us to address the Downton Design Guidelines in regard to our signage submission. On behalf
of the City Centre developer and design team, we have outlined how each of the proposed signs follow the Design
Guidelines.
City Centre
The internally illuminated letters and logo of the proposed City Centre sign will be constructed of acrylic faces with 5"
deep brushed aluminum returns attached directly to a black non-illuminated aluminum box backer. This system allows
the face of the letters and logo to glow at contained lighting levels with no light seepage from behind. The font used is
clean with no serifs and all caps. The black box backer relates to the black accents used throughout the building including
the window frames and paneling. The white face-lit letters and logos contrast the black backer box and match the color of
the other building signs (Chase and Ithaca Ale House). This double-sided projection sign will run vertically attached to
the façade, emphasizing the vertical nature of the buildings brick columns and multi-colored metal paneling system.
Chase
The face of the internally illuminated letters of the proposed Chase sign will be constructed of matte finish white acrylic
adhered to the acrylic returns which attach to aluminum returns and back. The returns for the letters will be translucent
blue acrylic with 3M diffuser adhered to acrylic face. The octagon logo of the Chase sign will have a thermoformed
translucent blue acrylic face with aluminum returns and backing. Both the letters and the logo have aluminum backing,
eliminating any light seepage. The sign is composed of all capital letters in the Chase font with the Chase octagon logo.
This sign will be secured to an aluminum raceway which mounts to the face of the radial canopy at the corner of E. State
St. and S. Aurora St. The raceway will match the finish color of the canopy structure.
Ithaca Ale House
The face of the internally illuminated letters of the proposed Ithaca Ale House sign will be constructed of matte finish
white acrylic with aluminum returns and backing, eliminating any light seepage. This sign is not using a perforated black
vinyl covering, so the sign will appear white both during the day and night. The sign uses a clean font in all caps with no
serifs. This sign will be secured to an aluminum raceway which mounts to the face of the radial canopy at the corner of E.
State St. and S. Aurora St. The raceway will match the finish color of the canopy structure.
Should you have any questions, please do not hesitate to let us know.
Sincerely,
Gaelin Walsh
Ph one: 607.379.9175 Email: whitham@whithamdesign.com 142 East State Street, Rear Ithaca, NY 14850
February 15, 2019
Lisa Nicholas, Deputy Director of Planning
Division of Planning and Economic Development, City of Ithaca
108 E. Green Street, 3rd Floor
Ithaca, N.Y. 14850
RE: City Centre project – Conditions for final SPA – Signage
Dear Lisa,
Thank you for reviewing this revised submission detailing the proposed signage for the City Centre project. All
proposed signs are included in this package except for Collegetown Bagels which will be included in a separate
submission.
On behalf of the developer and design team, we are attaching the following signage package in compliance
with the Conditions of Final Site Plan Approval, as detailed in the Approved Resolution dated January 24,
2017.
Items included in this package are as follows:
•Page #1
o Sign Locator Map - indicates the location and size of each proposed sign
•Page #2
o Sign #1 Detail & Elevation Drawing (City Centre sign – pursuing a sign variance)
•Page #3
o Rendering Looking East on E. State Street
•Page #4
o Rendering Looking West on E State Street
•Pages #5 - #8
o Sign #2 Details (Chase Bank sign)
•Page #9
o Sign #3 Details (Ithaca Ale House sign)
Sincerely,
Gaelin Walsh
DNDNUP8'-3"1'-11"9'-0"2'-7"SHEET #TITLEL000 SITE AND PLANTING PLANL100LAYOUT PLAN AND MATERIALSSCHEDULEL100-ALAYOUT PLAN: CORNER AURORA &STATE STREETL100-BLAYOUT PLAN: GREEN ROOFL100-CLAYOUT PLAN: 8TH FLOOR TERRACEL101DETAILS PLANL102SOILS PLANL103 STREET LIGHT CIRCUITRY PLANL200PLANTING SCHEDULE AND KEYL018TH FLOOR ROOF TERRACEPLANTING PLANL01 BULB8TH FLOOR ROOF TERRACE BULBPLANL02STATE STREET PLANTING PLANL02 BULBSTATE STREET BULB PLANL03STATE STREET PLANTING PLANL03 BULBSTATE STREET BULB PLANL04GREEN STREET NORTHERN CORNERPLANTING PLANL05AURORA STREET PLANTING PLANL05 BULBAURORA STREET BULB PLANL06GREEN ROOF WEST PLANTING PLANL06 BULBGREEN ROOF WEST BULB PLANL07GREEN ROOF PLANTING PLANL07 BULBGREEN ROOF BULB PLANL08GREEN ROOF PLANTING PLANL08 BULBGREEN ROOF BULB PLANL09GREEN STREET SOUTHERN SLOPEPLANTING PLANL10GREEN STREET PLANTING PLANL301-AGREEN ROOF DETAILSL302 PLANTING DETAILSL303STREET AND PAVING DETAILSL401-AMANUFACTURER DETAILSL401-BMANUFACTURER DETAILSDRAWING LIST8TH FLOOR TERRACE1"=10'-0"SIGN LOCATOR MAPPage #1SIGN #1'CITY CENTER' w/ 'C' logo on aprojection sign (illuminated letters)Variance requiredTotal: 200 sq.ft. (100sq.ft. each side)SIGN #3'ITHACA ALE HOUSE'Permitted by code21 sq.ft.SIGN #2'CHASE'Permitted by code20.7 sq.ft.VARIANCE REQUIREDPERMITTED BY CODE
SIGN #1 DETAIL & ELEVATIONDNDNDNDNUPUPDRAWING LISTE. STATE ST.
S. AURORA ST.GREEN ST.Page #2
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RENDERING LOOKING WEST ON E. STATE STREETDAYNIGHTPage #4SIGN #1SIGN #1
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Trowbridge Wolf Michaels Landscape Architects LLP
1001 West Seneca Street, Suite 201 Ithaca, New York 14850 ph: 607.277.1400
www.twm.la
February 22, 2019
Lisa Nicholas, Deputy Director of Planning
Planning Division, City of Ithaca,
108 E. Green Street, 3rd Floor
Ithaca, NY 14850
Dear Lisa, JoAnn and Members of the Planning and Development Board
Attached please find additional CEQR materials related to the environmental remediation actions for the Falls
Park Apartments project at 121 – 125 Lake Street. This package is being submitted with the intent to provide
the Planning Board with a clear and concise description of the contamination and clean up history of the site.
Related supporting record documents have been assembled and included as appendices to this package.
The final portion of this package includes additional information regarding the conceptual approaches for the
environmental remediation related to the proposed construction of the multi-family apartment building and
the public walkway.
TABLE OF CONTENTS
A. Eastern Parcel (parcel #11-3-1.22)
i. Overview of existing contamination
ii. Milestones for future environmental remediation
iii. Summary of previous environmental remedial actions
B. Dedicated Open Space (City-owned Parcel) (parcel #11-3-1.21)
i. Remaining Contamination
ii. Summary of previous environmental remedial actions
C. Western Parcel (parcel #11-3-1.23)
i. Overview of existing contamination
ii. Overview of remedial approaches to be considered
iii. Milestones for future environmental remediation
D. Overview of Conceptual Approaches to Construction
i. Construction within the Dedicated Open Space
LIST OF FIGURES
Figure 1: Conceptual Environmental Plan
LIST OF APPENDICES
Documents related to parcels 11-3-1.22 (Eastern Parcel*) and 11-3-1.23 (Western Parcel*)
*Referred to as the “Former Ithaca Gun Factory Site” as administered by the NYSDEC Brownfield Cleanup
Program (BCP).
Appendix A. Remedial Investigation Report (RIR) and associated appendices, November 2018
Documents related to City-owned parcel 11-3-1.21 (Dedicated Open Space**)
2 of 8
**Referred to as the “Ithaca Falls Overlook Environmental Restoration Project” as administered by the
NYSDEC Environmental Restoration Program (ERP).
Appendix B. Site Investigation Report (SIR), March 2016
Appendix C. Record of Decision (ROD), September 2017
Appendix D. Site Management Plan (SMP), October 2017
Appendix E. Final Engineering Report (FER), January 2018
Appendix F. Certificate of Completion (COC), October 2018
3 of 8
A. Eastern Parcel
A.i. Overview of Existing Contamination
The following excerpt from the September 14, 2018 site plan review submission provides a summary of
existing contamination. Amended text is displayed as bold & italicized text.
The building will be constructed on the east parcel of the Former Ithaca Gun Factory Site which is
currently in the New York State Brownfield Cleanup Program (BCP). The Site was entered into the
BCP by the developer who is considered a ‘Volunteer’ under the program, meaning they have no
connection to the operation of the facility or the origin of the contamination that is present. A
remedial investigation (RI) was recently completed at the site under the New York State Brownfield
Cleanup Program (BCP). The Remedial Investigation Report (RIR) was submitted to NYSDEC in
August 2018 and is now available for public review and comment was approved by the NYSDEC on
November 23, 2018. Copies can be viewed at the Tompkins County Library located at 101 East
Green St. Ithaca, NY.
The Remedial Investigation Report (RIR) describes the results of the site investigation. Under the
BCP, specific soil clean up objectives (SCOs) are used to assess the need to clean-up based on an
intended future use that is protective of human health and the environment. Consistent with the
multi-family residence building designed for this parcel, restricted-residential SCOs were identified as
the applicable screening criteria for soil. Concentrations of compounds detected in groundwater were
compared to the New York State (Class GA) groundwater standards. The remedial investigation
identified that constituents are present above the applicable criteria in both soil and groundwater on
the Eastern Parcel.
The primary contaminant of concern in surface and subsurface soil on the Eastern Parcel is lead,
found at concentrations above the restricted-residential SCOs. Polycyclic aromatic hydrocarbons
(PAHs) have also been detected in soil above the restricted-residential SCO in an isolated area near
the former driveway. The thickness of soil and fill materials on the development parcel ranges from 0
to 11.5 feet on the site. The building design requires lowering of the current grades by as much as
15 feet. This activity will require removal of most of the soil and fill material as well as some bedrock
across most of the site. As a result, most of the lead-impacted material will be removed. In areas
where soil remains, it will be covered by the foundation of the building or other NYSDEC-approved
cover materials designed for protection of public health.
Volatile organic compounds (VOCs) were detected in groundwater above the Class GA standards.
The highest concentrations were generally associated with trichloroethene (TCE) and cis-1,2-
dichloroethene. However, several other VOCs were detected less frequently at lower concentrations
but above standards. Groundwater occurs at depths of approximately 30 ft below grade and within
fractures of the underlying bedrock. Exposures to these VOCs by contact or ingestion are not likely
given the depth and the fact that the groundwater beneath the site is not used as a potable water
source (public water is supplied). The horizontal bedding and associated fractures further limit the
potential for vertical migration of vapors to the interior of the building. The presence of an
unoccupied parking garage as the lowest level will also offer protection against any potential vapor
migration into the upper occupied spaces. In addition, per applicable codes, garage ventilation will
be provided at a rate of 25,600 cfm. This provides a sufficient air exchange rate to prevent build-up
of exhaust gasses from vehicles and is also considered an effective mitigation measure for potential
vapor intrusion.
4 of 8
A.ii. Milestones for Future Environmental Remediation
The next milestones within the New York State Brownfield Cleanup Program are as follows:
1. Property owner’s consultant conducts a Remedial Alternatives Analysis (RAA) and prepares a
proposed Remedial Action Work Plan (RAWP) - evaluate and recommend remedial actions, and
their effectiveness, to address site contamination for DEC's consideration
2. DEC approves RAA/RAWP as complete
3. 45-day public comment period
4. DEC approves RAWP - selected remedy via a decision document summarizing how the remedy
must be implemented
5. Following remediation, property owner submits a Final Engineering Report (FER)
6. Submission of Site Management Plan (SMP) for DEC approval
The SMP document will outline requirements for periodic inspection, monitoring, and maintenance
of the components of the remedy. It will also provide requirements for notification and handling of
potentially impacted materials should subsurface work need to be completed in the future as part of
site maintenance and improvement activities. Activities completed as outlined in the SMP will be
documented in Periodic Review reports.
7. DEC issues Certificate of Completion subject to filing of Environmental Easement* and SMP
8. Property owner gains environmental indemnification from NYS and eligible for tax credits
* An Environmental Easement will be placed on the Site as part of the closure process. The
easement is a legal document that is connected to the land and contains the use restriction(s)
and/or any prohibition(s) on the use of land in a manner inconsistent with engineering controls and
provides the NYSDEC with the right to enforce those restrictions.
A.iii. Summary of Previous Environmental Remedial Actions
A complete account of previous environmental investigations and remedial actions that include, but are not
limited to, the Eastern Parcel can be found in Appendix A, Section 2.2.1.
Following environmental investigations that began in 1995, the USEPA delineated and removed
approximately 2,000 tons of hazardous materials (i.e. soil contaminated lead and other heavy metals
originating from lead shot and slag materials) from several locations.
In approximately 2001, the former Ithaca Gun Company property was entered into the Voluntary Cleanup
Program administered by the NYSDEC. Additional environmental investigation was conducted under this
effort confirmed nine areas where lead exceeded Soil Cleanup Objectives.
Between January and June 2009, demolition of several on-site structures including the main manufacturing
building was completed, as part of the Empire State Development ReStore NY (ESDRNY) program. As part
of the demolition, multiple contaminants were removed and disposed of, including but not limited to,
asbestos containing materials. Additional environmental sampling was conducted after the structures were
demolished. The results of this analysis showed elevated concentrations of VOC in groundwater samples
taken from on-site monitoring wells.
5 of 8
B. Dedicated Open Space. City-owned Parcel
B.i. Remaining Contamination
Remaining contamination within the Dedicated Open Space parcel includes lead contaminated soils located
below 2 feet and covered with an approved cap system (ref.: App. D, Section 2.5.1), groundwater within the
fractured bedrock that has been impacted by VOCs, sVOC, and Inorganics (ref.: App. D, Section 2.5.2), and
elevated levels of TCE and other low-level VOC detections observed in soil vapor samples (ref.: App. D,
Section 2.5.3).
B.ii. Summary of Previous Environmental Remediation Actions
A complete account of previous environmental investigations and remedial actions that include, but are not
limited to, the Dedicated Open Space parcel can be found in Appendix D, Section 2.3.
Environmental investigation conducted between 1995 and 1998 confirmed elevated levels of lead and other
metals. Under the United States Environmental Protection Agency (EPA) and NYSDEC, Removal
Assessment began in 2000. From 2002 through 2004, the USEPA removed contaminated soils from
subareas of the current Dedicated Open Space parcel defined as the Island, Raceway and Plunge Pool, and
Western Accessway, as well as within the Fall Creek gorge and other off-site areas. As part of this
remediation, buildings located on the Island were demolished in 2002.
In 2015, the City of Ithaca took ownership of this parcel (subdivided at this time/), further environmental
investigation and remediation was conduction as part of the NYSDEC Environmental Restoration Program
(ERP) under the guidance and oversight of both the NYSDEC and NYSDOH. Lead contaminated soils were
removed and the current two foot cap system was installed. A total of five permanent bedrock groundwater
monitoring wells were installed – three within the ERP site and two additional wells in downhill locations.
Groundwater samples with elevated levels of VOCs and chlorinated solvents were obtained in both the on-
site and off-site monitoring wells.
During this time, the NYSDEC conducted a separate interim remedial measures project that removed 435
tons of lead contaminated overburden soil from the Island and in the Raceway. The former bridge to the
Island was also removed as part of this project.
Additional off-site investigations led by the NYSDEC and USEPA based on the findings from the ERP site
investigations. As a result, the following additional remediation efforts were conducted. In 2015, the USEPA
removed additional led impacted soil within Ithaca Falls gorge. The NYSDEC has installed sub-slab
depressurization systems in residential homes in the east Fall Creek neighborhood located downhill and
west of the site to mitigate potential exposures from soil vapor intrusion.
While the origin of off-site groundwater contaminants is believed to have originated within the former Ithaca
Gun Factory site, the NYSDEC is responsible for the management of off-site contamination. The NYSDEC
has placed multiple monitoring wells in off-site locations downhill of the proposed redevelopment site will
continue to conduct soil gas vapor sampling within the Fall Creek neighborhood.
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C. Western Parcel
C.i. Overview of Existing Contamination
Environmental investigation documents unconsolidated materials on the Western Parcel contain elevated
concentrations of lead. The depth of unconsolidated material on the Western Parcel ranges from 4.8 to 15.5
feet thick across the majority of the site with a thin veneer of soil or exposed rock present on steeper sloped
areas on the northern end. The unconsolidated materials consist of a mixture of native soil and fill with
gravel placed at the surface on the southern end to provide access for vehicles. Buried foundations of
former buildings are also present. A single soil sample was found to contain PCBs at a concentration
exceeding 50 ppm. Only three of 57 additional samples from this parcel contained PBC concentrations
greater than 1 ppm and these concentrations were less than 2 ppm indicating that the occurrence of PCBs
greater than 50 ppm is highly localized.
C.ii. Overview of remedial approaches to be considered
The following is an overview of the remedial approaches to be considered for the Western Parcel. These
approaches will be further assessed as part of the Remedial Alternative Analysis (RAA) being conducted as
part of the Brownfield Cleanup Program and subject to approval by New York State Department of
Environmental Conservations (NYSDEC) and the New York State department of Health (NYSDOH).
As no development will take place on the Western Parcel, the remedy for this area is expected to include
removal of the material containing PCBs greater than 50 mg/kg which was identified in one soil sample. This
activity will also require removal of the smoke stack and above-grade structures. Once the removals are
complete, the majority of the surface of this parcel will be graded and covered with a demarcation material
followed by a soil cover. The steeper sloped portions of this parcel will be screened for the presence of lead
and impacted materials will be removed or covered with 2 foot of approved material, as appropriate.
C.iii. Milestones for Future Environmental Remediation
While the Western Parcel is not part of the redevelopment proposed for the Eastern Parcel, it is part of the
same New York State Brownfield Cleanup Program environmental remediation project. As such the future
milestones listed under Section A.ii also apply to the Western Parcel.
D. Overview of Conceptual Approaches to Construction
The following presents the remedial program components envisioned to mesh with the proposed
redevelopment. These components will be evaluated during the RAA and are subject to review by NYSDEC
and NYSDOH. The NYSDEC and NYSDOH will select the final site-wide remedy in a process that will include
time for public review. Figure 1: Conceptual Environmental Plan is provided to illustrate the bullet points
below.
The proposed redevelopment project will cover most of the Eastern Parcel with building, parking lots
and walkways.
The surface of the Eastern Parcel will need to be lowered as much as 25 ft in some areas.
To facilitate construction, fill/soil mixture will be removed from most of the Eastern Parcel. It is
estimated that approximately 3,500 cubic yards of fill/soil material would be removed and disposed
off-site as part of this process.
Soil/fill material that remains in place will primarily be located on the northwest boundary along the
ERP parcel (i.e. Dedicated Open Space) and east of the retaining wall on the southeast corner of the
parcel.
7 of 8
Prior to construction, material to remain on the northwest corner will be covered with a demarcation
layer and a 2-foot minimum thickness of clean fill for protection during construction activities.
Material to remain on the southeast corner has generally been found to have concentrations of lead
below the soil cleanup objectives listed in 6NYCRR part 375 for Restricted-Residential Use (400
mg/kg). Additional screening and analytical data will be collected from the exposed material and
cover will be placed as needed as part of the remediation.
No groundwater is present in the unconsolidated material. Water management during construction
will include precipitation and stormwater runoff. The precipitation that accumulates within the
excavation areas will be removed and disposed off-site. Stormwater runoff will be managed under a
construction erosion and sediment control plan. This will include measures to clean truck tires prior
to leaving the site.
Air monitoring will be completed during all remedial and ground intrusive activities pursuant to the
approved Community Air Monitoring Plan for the site. Additional dust control measures, specific for
actions at the site, will be incorporated into the remedial work plan.
Soil removal and disposal activities will include pre-characterization of soil to demonstrate that it
meets the requirements for disposal at the NYS-permitted facility (to be selected during RAWP
development). This may be done during construction or as part of a pre-construction activity. Soil
that does not meet requirements may be amended with a stabilizing compound so that it meets
requirements dictated by the disposal facility and New York State regulations.
Groundwater at the site occurs within fractures in the bedrock at depths of 42.5 ft to 57 ft below
grade on the Eastern Parcel. No groundwater use takes place in the vicinity of the Site. The RAA will
consider technologies to reduce contamination concentrations in the groundwater to the extent
practicable.
The potential for vapor intrusion into the new building will also be evaluated as part of the RAA. If
warranted based on the site conditions and building configuration, NYSDOH-approved mitigation
measures will be integrated into the design and construction of the building.
D.i. Construction within the Dedicated Open Space
The proposed redevelopment includes the construction of a publicly accessible walkway with the Dedicated
Open Space City-owned parcel. As part of the previously completed environmental remediation of this site
(see Addendum F Certificate of Completion, October 2018) contaminants remained below ground, buried
under a minimum of 20 inches of clean backfill and 4” of clean topsoil (see Addendum E: Final Engineering
Report). Both the proposed construction of the residential building foundations sited along portions of the
property line shared by the Eastern Parcel and the Dedicated Open Space and the elevated portion of the
proposed walkway will disturb below the clean cover of the remediated site. These elements will be
structurally supported by micropiles. A conceptual technical approach for the use of micropiles follows. All
proposed construction activities within the Dedicated Open Space will be subject to the review and approval
of the NYSDEC and be required to comply with agency regulations. The proposed activities will disturb
remaining contaminated material and must be conducted in accordance with the Site Management Plan
(ref.: App. D: SMP).
Micorpiles will be used in steeply sloped areas where subsurface environmental contamination remains.
Micropiles will be constructed by advancing an approximately 10-inch diameter steel casing to rock and
drilling an open-hole rock socket in the sound rock. Drilling will be performed using compressed air as the
drilling fluid. The air will be mixed with water so that the drill spoil does not become dusty or airborne. The
drill fluid and spoils will be sent from the foundation drill through a sealed hose to a cyclone. In the cyclone
the spoil solids and water will be separated from the air as the velocity is reduced and the solids and liquid
will drop out into a drum or roll-off container for management and disposal. Air Monitoring, Personal
8 of 8
Protective Equipment, Equipment Decontamination and other Environmental requirements will be followed.
At the conclusion of the micropiling work, each pile will consist of a permanent steel casing to and seated in
rock. The casing will include cement grout and reinforcing steel. The rock socket below the casing will
consist of cement grout and steel reinforcing.
Note on Digital Format of Appendices
The following supporting record documents have been compiled as an appendices to this submission in
order to provide a comprehensive account of historic and ongoing environmental remediation actions
related to the original consolidated parcel once occupied by the Ithaca Gun Factory (and subsequently
subdivided into three separate parcels).
Due to the considerable length of these reference documents, they are being provided only in a digitally
format. They are to be filed in a central location on the City of Ithaca Site Plan Review project directory
(link: http://www.cityofithaca.org/DocumentCenter/Index/852) as previously coordinated with the Department
Division of Planning & Economic Development.
Documents related to parcels 11-3-1.22 (Eastern Parcel*) and 11-3-1.23 (Western Parcel*)
*Referred to as the “Former Ithaca Gun Factory Site” as administered by the NYSDEC Brownfield Cleanup
Program (BCP).
A. Remedial Investigation Report (RIR) with associated appendices and NYSDEC
Report Approval Letter, November 2018
Documents related to City-owned parcel 11-3-1.21 (Dedicated Open Space**)
**Referred to as the “Ithaca Falls Overlook Environmental Restoration Project” as administered by the
NYSDEC Environmental Restoration Program (ERP).
B. Site Investigation Report (SIR), March 2016
C. Record of Decision (ROD), September 2017
D. Site Management Plan (SMP), October 2017
E. Final Engineering Report (FER), January 2018
F. Certificate of Completion (COC), October 2018
If you have any questions or require further information, please do not hesitate to call. We are looking
forward to further discussing the project at your February 26, 2019 meeting.
Sincerely,
Kimberly Michaels
Principal
Cc: Nels Bohn, Anne Redmond, Frost Travis, Chris Hyde, Ryan Kovac, Andrew Sciarabba, Susan Salsbury
¥FORMER
ITHACA GUN FACTORY SITE
ITHACA, NEW YORKPLOTDATE: 02/13/19 3:48:50 PM NewtonJMI:\Ithaca-Falls.17546\63923.Ithaca-Gun-Ri-I\Docs\DWG\MXD\RAA\CONCEPTUAL_ENV_PLAN.mxd0 40 8020
Feet
CONCEPTUAL
ENVIRONMENTAL
PLAN
LEGEND
[FENCE
BCP PARCEL BOUNDARY
REMOVE OVERBURDEN
REMOVE TO 10.5 FT BGS AND BACKFILL
TO MATCH SURROUNDING GRADE
SCREEN FOR LEAD AND REMOVE OR
APPLY COVER AS APPROPRIATE
REMOVE OVERBURDEN AND BACKFILL
TO MEET CONSTRUCTION GRADE*
2 FT ENGINEERED SOIL COVER
REMOVE MINIMUM 2 FT AND PLACE 2
FT ENGINEERED SOIL COVER
PROPOSED ELEVATED WALKWAY
(MICROPILES)
PROPOSED WALKWAY AT GRADE
(CONCRETE)
!!!!
!!!!APPROXIMATE ERP PROPERTY
17546.63923
FEBRUARY 2019
FIGURE 1
O'BRIEN & GERE ENGINEERS, INC.
NOTE:
* FINAL ELEVATION TO BE BASED ON DESIGN
PARAMETERS.
- FINAL REMEDY WILL BE SUBJECT TO NYSDEC
APPROVAL
E A S T E R N PA R C E L
E A S T E R N PA R C E L
W E S T E R N PA R C E L
W E S T E R N PA R C E L
PROPOSED RESOLUTION
CEQR Negative Declaration
Site Plan Review
815-817 N Aurora St
Two New Two-Family Dwellings
City of Ithaca Planning and Development Board
February 26, 2019
WHEREAS:6 NYCRR Part 617 of the State Environmental Quality Review Law and Chapter 176.6 of
the City Code,Environmental Quality Review, require a lead agency be established for conducting
environmental review of projects, in accordance with local and state environmental law, and
WHEREAS:the City of Ithaca Planning and Development Board has one pending application for Site
Plan Review for two new two-family residences at 815-817 N Aurora, by Daniel Hirtler on behalf of the
owner, and
WHEREAS:the applicant proposes to demolish an existing two-family residential structure and construct
two new 1,290 SF two-family dwellings on a 9,590 SF lot. The existing residential building is a legally
non-conforming building with a side setback deficiency (2.9 feet instead of the required 5 feet). The
project site is located in the R-2b Zoning District and meets all applicable zoning lot and setback
requirements. The proposed redevelopment will include four parking spaces, including two exterior
parking spaces and two parking spaces in a detached garage for the four three-bedroom apartments, and
WHEREAS:this is an Unlisted Action under the City of Ithaca Environmental Quality Review
Ordinance ("CEQRO")and the State Environmental Quality Review Act ("SEQRA"),and
WHEREAS:the City of Ithaca Planning Board, being the local agency which has primary responsibility
for approving and funding or carrying out the action, did on November 27,2018 declare itself the Lead
Agency for the environmental review of the project, and
WHEREAS:the Planning Board, acting as Lead Agency in environmental review, has on February 26,
2019 reviewed and accepted as adequate: a Full Environmental Assessment Form ("FEAF"), Part 1,
submitted by the applicant, and Parts 2 and 3, prepared by Planning staff and amended by the Planning
Board; and a site plan review application including the following drawings:"Context Map" and "Survey
Map" (Figure AO,1 of 8) revised February 5, 2019;"General Site Plan" (Figure Ala,2 of 8);"Utility and
Drainage Plan" (Figure Alb,3 of 8);"Landscaping Plan" (Figure A1c, 4 of 8); elevation drawings
(Figure A2, 5 of 8) all revised February 5, 2019; floor plans (Figure A3, 6 of 8) revised and dated January
15, 2019; "Site Plan showing Context," "Site Plan Showing built area, pavement and green space,"
"Demolition Plan," and "Construction Fencing and Tree Protection Plan" (Figure A4, 7 of 8) revised and
dated February 5, 2019; construction details (Figure A5, 8 of 8) revised and dated January 5, 2019; and a
completed Residential Infill Neighborhood Compatibility Worksheet and associated materials, dated
December 13, 2018, all prepared by Daniel R. Hirtler, Architect, on behalf of the owner, and
WHEREAS:the Parks, Recreation and Natural Resources Commission, the Tompkins County
Department of Planning and Sustainability, and any interested parties have been given the opportunity to
comment on the proposed project and any comments received to date on the aforementioned have been
considered, and
WHEREAS:the Planning Board, acting as Lead Agency, has determined, as more clearly explained in
Part 3, that the applicant has mitigated any potential negative impacts of the project to the maximum
extent practicable, and any future changes to the site plan may require further environmental review,
now,therefore,he it
RESOL VBD:that the City of Ithaca Planning and Development Board determines the proposed project
will result in no significant impact on the environment and a Negative Declaration for purposes of Article
8 of the Environmental Conservation Law be filed in accordance with the provisions of Part 617 ·of the
State Environmental Quality Review Act.
Moved by:
Seconded by:
In Favor:
Against:
Abstain:
Absent:
Vacancies:
PROPOSED RESOLUTION
Preliminary &Final Approval
Site Plan Review
Two New Two-Family Dwellings
815-817 N.Aurora Street
City of Ithaca Planning and Development Board
February 26, 2019
WHEREAS:an application has been submitted for review and approval by the City of Ithaca Planning and
Development Board for two new two-family dwellings located at 815-817 North Aurora Street by Daniel
Hirtler, on behalf of the owner, and
WHEREAS:the applicant proposes to demolish an existing two-family residential structure and construct
two new 1,290 SF two-family dwellings on a 9,590 SF lot. The existing residential building is a legally
non-conforming building with a side setback deficiency (2.9 feet instead ofthe required 5feet). The project
site is located in the R-2b Zoning District and meets all applicable zoning lot and setback requirements.
The proposed redevelopment will include four parking spaces for four three-bedroom apartments, and
WHEREAS:this is an Unlisted Action under the City of Ithaca Environmental Quality Review Ordinance
("CEQRO")and the State Environmental Quality Review Act ("SEQRA"), and
WHEREAS:the City of Ithaca Planning Board, being the local agency which has primary responsibility
for approving and funding or carrying out the action, did on November 27, 2018, declare itself the Lead
Agency for the environmental review ofthe project, and
WHEREAS:legal notice was published and property posted, and adjacent property owners notified in
accordance with Chapter 290-9 C. (1), (2),&(3)of the City of Ithaca Code, and
WHEREAS:the Planning and Development Board held the required Public Hearing on December 18,
2018,and
WHEREAS:the City of Ithaca Parks, Recreation, and Natural Resources Commission, the Tompkins
County Department of Planning and Sustainability, and other interested parties have been given the
opportunity to comment onthe proposed project and any comments received to date on the aforementioned
have been considered, and
WHEREAS:the Planning Board, acting as Lead Agency in environmental review, has on February 26,
2019 reviewed and accepted as adequate: a Full Environmental Assessment Form ("FEAF"), Part 1,
submitted by the applicant, and Parts 2 and 3, prepared by Planning staff and amended by the Planning
Board; and a site plan review application including the following drawings:"Context Map" and "Survey
Map" (Figure AO,1 of 8) revised February 5, 2019; "General Site Plan" (Figure Ala,2 of 8);"Utility and
Drainage Plan" (Figure Alb,3 of 8);"Landscaping Plan" (Figure Ale,4 of 8); elevation drawings (Figure
A2, 5 of 8) all revised February 5,2019; floor plans (Figure A3, 6 of8)revised and dated January 15, 2019;
"Site Plan showing Context," "Site Plan Showing built area, pavement and green space,""Demolition
Plan," and "Construction Fencing and Tree Protection Plan" (Figure A4, 7 of 8)revised and dated February
5, 2019; construction details (Figure A5, 8 of 8) revised and dated January 5, 2019; and a completed
Residential Infill Neighborhood Compatibility Worksheet and associated materials, dated December 13,
2018, all prepared by Daniel R. Hirtler, Architect, on behalf of the owner, and
WHEREAS:the Planning and Development Board did on February 26, 2019 make a Negative Declaration
of Environmental Significance for the proposed project, and now,therefore,he it
RESOL VED:the Planning Board does hereby grant Preliminary and Final Site Plan Approval to the
project, subject to the following conditions:
1.Submission to the Planning Board of project details, including but not limited to lighting, signage,
exterior furnishings, bike racks,residential style canopies etc., and
11.Submission of a revised detail sheet showing planting specifications in conformance with the Site
Plan Review Ordinance, and
Ill.Tree protection for street trees to be in conformance with recommendations of the City Forester,
as communicated in a February 13, 2019 correspondence, and
IV.Bike racks must be installed before a certificate of occupancy is granted, and
v. This site plan approval does not preclude any other permit that is required by City Code, such as
sign permits, tree permits, street permits, etc.
Moved by:
Seconded by:
In favor:
Against:
Abstain:
Absent:
Vacancies:
City of Ithaca
FULL ENVIRONMENTAL ASSESSMENT FORM – Part III
Project Name: 815-817 North Aurora Street Proposed Two Family Residences
Date Created: 11/15/2018, Modified 02/19/2019
PROJECT DESCRIPTION
The applicant proposes to demolish an existing two-family residential structure and construct two new 1,290
square foot two-family dwellings on a 9,590 square foot lot. The existing residential building is a legally non-
conforming building with a side setback deficiency (2.9 feet instead of the required 5 feet). The exterior
parking area would hold two cars, which would be positioned in the buildable area of the lot, with a ten foot
wide drive. The other two required off street parking spaces would be handled inside a wood framed garage.
The project site is located in the R-2b Zoning District and meets all applicable zoning lot and setback
requirements.
This is an Unlisted Action under the City of Ithaca Environmental Quality Review Ordinance (“CEQRO”) and the
State Environmental Quality Review Act (“SEQRA”), and is subject to environmental review.
IMPACT ON LAND
The project site is located in an urban setting on flat terrain that has previously been disturbed for housing
construction and is not anticipated to impact any natural features. According to the Demolition Plan Bb,
provided in a November 14, 2018 submission with the latest revision dated February 5, 2019, limited
vegetation removal is required as part of the project, and will include removal of three mature trees.
According to supplemental information provided by the applicant on November 14, 2018, the following
construction methods are proposed:
“The foundation of the existing building will be removed and the cellar hole will be filled with
structural material. The new buildings will be a slab on frost walls building. Approximately 200
cubic yards of material will be excavated for the frost walls and the drainage material which will
be replaced in and around the foundation. Minor grading will be required to provide positive
drainage of excess surface water to catch basins connected to the city sewer. The site is
anticipated to remain relatively level at its existing elevation. Concrete pavement is proposed to
connect the housing units to the parking area and City sidewalk. Crushed stone pavement will be
used for parking and automobile traffic on the site.”
The Lead Agency has determined that based on the information above, no significant impact to land is
anticipated.
IMPACT ON GEOLOGIC FEATURES
There are no unique or unusual land forms on the site that will be impacted as part of the project.
The Lead Agency has determined that based on the information above, no significant impact to geologic
features is anticipated.
City of Ithaca
FULL ENVIRONMENTAL ASSESSMENT FORM – Part III
Project Name: 815-817 North Aurora Street Proposed Two Family Residences
Date Created: 11/15/2018, Modified 02/19/2019
IMPACT ON SURFACE WATER
The project is located in a built-out urban area and is not located contiguous or in proximity to any water
features.
The Lead Agency has determined that based on the information above, no significant impact to surface water
is anticipated.
IMPACT ON GROUNDWATER
The proposed project is located in an area that is serviced by public utilities (e.g., water and sewer). In
addition, the project is a proposed residential development, similar to surrounding uses, and will not
substantially increase demand on the water supply. The project is also not anticipated to introduce
contaminants into the environment due to the proposed residential use.
The Lead Agency has determined that based on the information above, no significant impact to groundwater
is anticipated.
IMPACT ON FLOODING
The project is not located in the 100 or 500 year floodplain, and will not impact any waterbody that may
contribute to flooding.
The Lead Agency has determined that based on the information above, no significant impact to flooding is
anticipated.
IMPACTS ON AIR
According to information provided by the applicant, construction is projected to last approximately seven
months. Excavation and preparation of foundations create the potential for increased airborne dust and dirt
particles. Impacts to air quality will be limited to the period associated with construction activities.
During construction, the applicant will employ the following applicable dust control measures, as appropriate:
Misting or fog spraying the site to minimize dust;
Maintaining crushed stone tracking pads at all entrances to the construction site;
Re-seeding disturbed areas to minimize bare exposed soils;
Keeping roads clear of dust and debris;
Requiring trucks to be covered;
Prohibiting burning of debris on site.
The Lead Agency has determined that with the mitigation measures during construction identified above, no
significant impact to air is anticipated.
City of Ithaca
FULL ENVIRONMENTAL ASSESSMENT FORM – Part III
Project Name: 815-817 North Aurora Street Proposed Two Family Residences
Date Created: 11/15/2018, Modified 02/19/2019
IMPACTS ON PLANTS AND ANIMALS
According to the NYSDEC Environmental Mapper, there are no rare or significant plant or animal communities
located on or around the project site. The project is located in a developed urban area and therefore no impact
to any state or federally listed species is anticipated. As depicted in the Demolition Plan Bb revised February 5,
2019, three mature trees are identified to be removed during construction: a 20’ dbh apple, a 17’ dbh silver
maple and a 20’ unspecified tree. The applicant is proposing to replace one tree. There are several large trees
on the adjacent property near the rear property line, and a city street tree located in the public right-of-way. In
a revised drawing set dated February 5, 2019, the applicant proposes to protect the existing street tree from
construction activities with a 4-foot high wood fence on a ground mounted frame which will protect a ground
area of 8-feet by 8-feet centered on the tree and aligned with the edge of the sidewalk. A 6-foot high chain link
construction fence set 10-feet off the rear property line will be established and will be off limits to construction
and construction staging to protect trees on the adjacent rear properties from damages associated with soil
compaction.
The City Forester has reviewed the tree protection plan and has stated the following in a correspondence dated
February 13, 2019:
“Fencing should be placed in the entire length of the tree lawn to focus site access through the
driveway area and not allow cutting across the tree lawn area with vehicles and equipment.
Placing the green space in the back of the property will be beneficial for preserving the large trees
on the neighboring lots, however the demo plan shows the back corner as ‘materials storage.’ If
the area is used for construction purposes like material storage or vehicle parking, it will negatively
impact the neighbor’s trees by causing soil compaction and root damage. The garage in the NE
corner of the property will likely impact the neighbor’s trees. Without knowing the size and species
of the tree it is hard to say how much it will be impacted.”
The Planning Board will take the City Forester’s observations and concerns into consideration during
the Site Plan Review process, and address them accordingly with the applicant.
The Lead Agency has determined that with mitigation measures identified by the applicant and with further
review by the Planning Board during the Site Plan Review process, no significant impact to plants and animals
is anticipated.
IMPACT ON AGRICULTURAL RESOURCES
The project site is located in an urbanized area, and there are no agricultural resources located in proximity to
the project site.
The Lead Agency has determined that based on the information above, no significant impact to agricultural
resources is anticipated.
City of Ithaca
FULL ENVIRONMENTAL ASSESSMENT FORM – Part III
Project Name: 815-817 North Aurora Street Proposed Two Family Residences
Date Created: 11/15/2018, Modified 02/19/2019
IMPACT ON AESTHETIC RESOURCES
The project site is visible from the public right-of-way used for routine, multi-modal travel by area residents.
The project removes an existing duplex, replacing it with (2) two-family housings. Each building is comparable
in size to surrounding residential land uses. The second two-family structure is sited to be constructed behind
the other unit, and will therefore be mostly screened from public view. Renderings of the proposed building will
be provided for review and modified, as needed, through the site plan review process
Refer to section on Impacts to Community Character.
IMPACT ON HISTORIC AND ARCHAEOLOGICAL RESOURCES
The site is not located within a historic district, and the existing structure slated for demolition is not a
designated historic resource. According to City records, however, the unit is a two-family Greek Revival
residence constructed in 1890 as such. Although not formally designated, the structure is therefore historic in
nature. There are no designated historic resources located within proximity of the project site. The site has
previously been disturbed as a result of prior residential construction.
The Lead Agency has determined that based on the information above, no significant impact to archaeological
resources is anticipated (see Community Character section).
IMPACT ON OPEN SPACE AND RECREATION
The project will not impact any existing open space or recreational areas. The increased number of units
proposed on the site, however, will provide housing for more residents with access to area amenities, such as
the Falls Creek Elementary School, which has active recreational opportunities available. The project
additionally proposes green space on-site to be available for use by residents.
The Lead Agency has determined that based on the information above, no significant impact to open space
and recreation is anticipated.
IMPACT ON CRITICAL ENVIRONMENTAL AREAS
There are no Critical Environmental Areas located within the City of Ithaca.
The Lead Agency has determined that based on the information above, no significant impact to critical
environmental areas is anticipated.
IMPACT ON TRANSPORTATION
The project will use the existing neighborhood right-of-way for access. Vehicular access to the property by
residents will be from the north, with parking accommodated on the project site (4 parking spots). Pedestrian
access to the property will be from an existing sidewalk on the south side. Concrete pavement will be installed
to connect all housing units to the parking area and city sidewalk.
City of Ithaca
FULL ENVIRONMENTAL ASSESSMENT FORM – Part III
Project Name: 815-817 North Aurora Street Proposed Two Family Residences
Date Created: 11/15/2018, Modified 02/19/2019
There will be temporary transportation impacts during the construction period, from January 2019 to August
2019. Construction vehicles will be staged in the rear yard (measuring 33 feet, 4-inches), with 10-feet fenced
off with 6-foot high chain link fencing to protect the rear yard and neighboring trees from construction related
impacts. The width of the site will be used during construction with the property perimeter protected by
construction fencing. There will be no need to close the sidewalk or use the tree lawn during construction.
The sidewalk and tree lawn will be fenced with 6-foot high chain link construction fence to separate it from
the construction site. The gate in the fence will be aligned with the existing curb cut and driveway apron.
Crushed stone pavement will provide a non-muddy surface for construction vehicles to enter and exit the site.
No right-of-way impacts are proposed.
The Lead Agency has determined that based on the mitigation measures during construction activities
identified above, no significant impact to geologic features is anticipated.
IMPACT ON ENERGY
No new infrastructure will be required to service the proposed residential development. The applicant has
provided the following information related to proposed energy reduction efforts, which complies with the first
five elements of the Tompkins County Energy Recommendations for New Construction:
“Energy Efficient Fixtures and Appliances: The applicant propose to use water fixtures
that meet the EPA Water Sense requirements, and permanent appliances will be Energy
Star rated.
Energy Efficient heat pump HVAC System: The project is planned to be heated and
cooled by an energy efficient, electric, air source electric, mini-split type heat pump
system. Hot water heaters will specify conventional electric units of energy efficiency as
required by New York State.
Solar Receptivity and Solar Collection Systems: The project will have a solar ready roof
with east, south and west facing major roof surfaces (hipped roof) to include roof vents
placed outside the useful solar collection area of the main roof surface, and the roof shall
be designed to carry solar panel system loads in addition to the other required roof
loads. No photovoltaic system will be installed at this time.
Energy Efficient Building Design: The window to wall ratio is 14.9 percent, which is less
than the recommended maximum ratio of 25 percent. The project is designed to have a
simple, compact rectangular shape. The project has a simple, compact rectangular
shape. The project will be designed to meet the requirements of the current NYS Energy
Code using Rescheck. The wall insulation is planned to be spray-foam insulation which
reduces air infiltration into the building compared to fiberglass batt wall insulation. The
roof truss system will be designed with a raised “energy” hell to permit a full R-49 over
the full ceiling area of the building. The building will be constructed using best practices
for minimizing air infiltration, but will not include testing in excess of that required by the
Residential code of New York.
City of Ithaca
FULL ENVIRONMENTAL ASSESSMENT FORM – Part III
Project Name: 815-817 North Aurora Street Proposed Two Family Residences
Date Created: 11/15/2018, Modified 02/19/2019
Lighting and Controls: the building will be supplied with LED lighting. The decorative
light fixtures which are mounted below the ceiling will be incandescent fixtures which
are fitted with self-contained LED incandescent bulbs to permit bulb replacement
without the need to replace the base fixture. The general flood lighting will be LED disk
lights, and exterior lighting will be LED fixtures.”
The Lead Agency has determined that based on the information above, no significant impact to energy is
anticipated.
IMPACT ON NOISE, ODOR & LIGHT
Impact on Noise and Odor
According the site plan review application provided by the applicant construction will last approximately 7
months. The project is located in a densely developed residential area. Noise producing construction activities
will temporarily impact residents in the immediate area. Noise producing construction activity will be limited
to the hours of 7:30 a.m. to 7:30 p.m. Monday through Friday.
The Lead Agency has determined that based on the information above, no significant impact to noise and odor
is anticipated.
Impact on Light
Site lighting may cast light onto adjoining properties. The project proposes to incorporate LED light fixtures as
the exterior light source. A final lighting plan will be submitted during site plan review.
The Lead Agency has determined that based on the information above, no significant impact to light is
anticipated.
IMPACT ON HUMAN HEALTH
The site has an existing older residential structure that is slated for demolition. It is likely that the structure
contains asbestos. Removal of any asbestos-containing material in the existing building will be completed by a
NYS Licensed Asbestos Contractor.
The site is not an existing remediation site, and therefore no hazardous waste is anticipated to be
encountered as part of site construction activities or future land use.
The Lead Agency has determined that based on the mitigation measures identified above, no significant
impact to human health is anticipated.
CONSISTENCY WITH COMMUNITY PLANS
The existing structure is a legally nonconforming building due to a side yard deficiency. The project proposes
to demolish the existing structure and construct (2) two-family units that are in conformance with the bulk
City of Ithaca
FULL ENVIRONMENTAL ASSESSMENT FORM – Part III
Project Name: 815-817 North Aurora Street Proposed Two Family Residences
Date Created: 11/15/2018, Modified 02/19/2019
and use standards associated with the R-2b Zoning District, in which it is located. The R-2b Zoning District was
designated to preserve the urban residential character of the Fall Creek neighborhood, and encourage
compatible development.
In addition, the project will introduce housing stock in an area targeted for residential uses, supporting the
goals articulated in the 2015 Comprehensive Plan (see Community Character section).
The applicant originally proposed to use the Landscape Compliance Method instead of the Setback
Compliance Method for interior parking. In a revised submission dated February 5, 2019, the applicant
proposed exterior parking to accommodate two vehicles, positioned within the buildable area of the site and
parked parallel within the ten foot wide drive. The two additional required parking spaces are to be
accommodated in a wood framed garage, to be finished in similar materials and colors to the two proposed
residential buildings.
The Lead Agency has determined that based on the information above, no significant impact to community
plans is anticipated.
CONSISTENCY WITH COMMUNITY CHARACTER
The Falls Creek neighborhood is characterized primarily by residential development, with a mix of older single-
family and multi-family housing units. The proposed project is similar in scale and land use to surrounding
residential units. The original submission, dated October 15, 2018, proposed two residential structures (i.e.,
two primary structures) on a single lot, unlike other developed properties in the neighborhood. In the original
proposal, parking was proposed in the interior lot between the two structures, as well as in the side yard to
accommodate the four required parking spaces.
Based on concerns expressed by the Planning Board, the applicant revised the site layout in a submission
dated February 5, 2019 to reflect the following changes to address concerns regarding community character:
The addition of a porch on the primary structure facing closest to North Aurora Street;
Removal of parking from between buildings; and
The addition of a garage to accommodate two of the required parking spaces, with the other two to
be provided in the buildable area of the lot in the ten-foot wide drive.
The Lead Agency has determined that based on the mitigation measures proposed by the applicant, no
significant impact to community character is anticipated.
Prepared by: Lisa Nicholas, AICP, Senior Planner and revised by the Planning Board
RE: 815-817 N Aurora -- Jeanne Grace
Actions
In response to the message from Anya Harris, 2/8/2019
To:
Anya Harris
Wednesday, February 20, 2019 7:29 AM
Anya,
One more late comment from the Shade Tree Committee.
The North Aurora St project has landscaping planned that will probably be severely damaged by deer
browsing. Some suggested species changes are:
"... I would swap out the planned Rhododendron for a Mahonia aquifolium (Oregon Grape Holly) or
Boxwood if they want evergreen or Sambucus spp. if evergreen is not important. All of these are deer
resistant
The Arborvitaes and Yews will be decimated in that area. If a taller shrub is desired Buxus sempervirens
‘Dee Runk’ is a tall upright form."
Thanks,
Jeanne
Jeanne Grace
City Forester
City of Ithaca
Department of Public Works
Division of Parks and Forestry
245 Pier Rd
Ithaca NY 14850
607-272-1718
fax 607-272-4374
815-817 N Aurora St
Wednesday, February 13, 2019 8:00 AM
Comments for Feb agenda:
815-817 N Aurora St -
Need to show tree protection around the street trees from demo to construction completion. Fencing
should be placed in the entire length of the tree lawn to focus site access through the driveway area and
not allow cutting across the tree lawn area with vehicles and equipment. Placing the green space in the
back of the property will be beneficial for preserving the large trees on the neighboring lots, however the
demo plan shows the back corner as "materials storage". If the area is used for construction purposes like
material storage or vehicle parking, it will negatively impact the neighbor's trees by causing soil
compaction and root damage. The garage in the NE corner of the property will likely impact the neighbor's
tree. Without knowing the size and species of the tree it is hard to say how much it will be impacted.
Jeanne Grace
City Forester
PROPOSED RESOLUTION
Declaration of Lead Agency
Site Plan Approval ,
130 Cherry Street -Arthaus
City of Ithaca Planning &Development Board
February 26, 2019
WHEREAS:6 NYCRR Part 617 of the State Environmental Quality Review Law and Chapter 176.6 of
the City Code,Environmental Quality Review,require that a lead agency be established for conducting
environmental review of projects,in accordance with local and state environmental law, and
WHEREAS:State Law specifies that for actions governed by local environmental review,the lead
agency shall be that local agency which has primary responsibility for approving and funding or carrying
out the action,and
WHEREAS:the City of Ithaca Planning and Development Board has one pending application for Site
Plan Review for a mixed-use development located at 130 Cherry Street, by Whitham Planning &Design,
applicant for owner, and
WHEREAS:the applicant proposes an as-of-right five-story building approximately 63 feet in height
with gallery,office and affordable residential space at 130 Cherry Street, on the east side of the Cayuga
Inlet.The program includes ground floor covered parking for approximately 52 vehicles,plus 7,000 SF
of potential retail/office and amenity space geared towards artists'needs.Building levels two through
five will house approximately 120 studio,one-bedroom and two-bedroom residential units.The total
building square footage is 97,500 SF. The building will be set back from Cherry Street approximately 23
feet to create a linear parklet.The north edge of the property will include a publicly accessible path
leading to an inlet overlook,and
WHEREAS:This is a Type 1 Action under the City of Ithaca Environmental Quality Review Ordinance
§176-4B(1)(k),(h)[2], (n), and the State Environmental Quality Review Act ("SEQRA")§617.4(b)(11),
both of which require environmental review,and
WHEREAS:the Tompkins County Department of Planning &Sustainability Tompkins County Department
of Health,Tomkins County Industrial Development Agency,NYS Homes and Community Renewal,and
the NYS Department of Environmental Conservation,have all been identified as potentially Involved
Agencies in Environmental Review,and
WHEREAS:,the Tompkins County Department of Planning &Sustainability,Tompkins County
Department of Health,Tomkins County Industrial Development Agency,NYS Homes and Community
Renewal,and the NYS Department of Environmental Conservation,have all consented to the City Planning
Board being Lead Agency for this Project,now therefore be it,'
RESOL VED:that the City of Ithaca Planning and Development Board,being that local agency which
has primary responsibility for approving and funding or carrying out the action,does, by way of this
resolution,declare itself Lead Agency in Environmental Review for the proposed project.
Moved by:
Seconded by:
In favor:
Against:
Abstain:
Absent:
PROPOSED RESOLUTION
Declaration of Lead Agency
Site Plan Approval
402 Wood Street
City of Ithaca Planning &Development Board
February 26, 2019
WHEREAS:6 NYCRR Part 617 of the State Environmental Quality Review Law and Chapter 176.6 of
the City Code, Environmental Quality Review, require that a lead agency be established for conducting
environmental review of projects, in accordance with local and state environmental law, and
WHEREAS:State Law specifies that for actions governed by local environmental review, the lead
agency shall be that local agency which has primary responsibility for approving and funding or carrying
out the action, and
WHEREAS:the City of Ithaca Planning and Development Board has one pending application for Site
Plan Review for construction of a three-story residential building located at 402 Wood Street, by Noah
Demarest, applicant for owner, and
WHEREAS:the applicant proposes to construct a three-story residential building on a vacant lot in the
Southside Neighborhood of Ithaca. The building will include four rental units priced at market rate: (1)
three-bedroom unit, (2) one-bedroom units, and (1) two-bedroom unit. The frrst-floor unit will meet
ADA requirements for accessibility. The parcel is located in the R-3b Zoning District and will require
variances for off-street parking requirements and rear yard setback, and
WHEREAS:this is an Unlisted Action under the City of Ithaca Environmental Quality Review
Ordinance and the State Environmental Quality Review Act ("SEQRA"), both of which require
environmental review,now therefore be it,
RESOL VED:that the City of Ithaca Planning and Development Board, being that local agency which
has primary responsibility for approving and funding or carrying out the action, does, by way of this
resolution, declare itself Lead Agency in Environmental Review for the proposed project.
Moved by:
Seconded by:
In favor:
Against:
Abstain:
Absent:
Vacancies: