HomeMy WebLinkAbout228 Cayuga Drive Completeness Review ^".. MRB Elevating Communities
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Group
April 22, 2026
Nathaniel Rogers, Town Planner
Town of Lansing
29 Auburn Road
Lansing, New York 14882
Re: LAKE HAWKEYE DATA CAMPUS -228 CAYUGA DRIVE
TAX MAP# 11-1-3.211
PRELIMINARY&COMPLETENESS REVIEW
MRB GROUP PROJECT NO. 1207.25000.000 PHASE 6
Dear Mr. Rogers:
MRB has conducted a detailed review of the Site Plan Application submission regarding the above
referenced project, dated March 25, 2026, and prepared by Terawulf, Inc. MRB Group provides the
following comments for consideration by the Planning Board. The project designer/applicant should
provide a brief written response to each comment.
PROJECT OVERVIEW
At full build-out, the proposed "Lake Hawkeye Data Campus"will house 300 MW of high-performance
computing capacity equipment contained in either four (4) or five (5) new buildings. These buildings
would be constructed in two phases over six years. In Phase 1, three (3) buildings would be
constructed upon the western half of the development site, each containing computers and
infrastructure to support 50 MW of computing capacity. The buildings are customized for this specific
use, containing cooling, computer racks and other components related to high-performance
computing. Phase 2 will result in one or two similar type buildings containing a total of 150 MW of
computing capacity. The largest proposed building will be 65' tall, 235' wide and 454' long. Each
building is anticipated to require approximately 12-14 months to build through to commissioning.Other
proposed site improvements include access roads, landscaping and lighting. The Project will contain
1.5 million gallons of fire protection fluid and 1.3 million gallons of water storage.
The Data Campus will operate continuously all year long. The subject parcel is 434 acres and is
located in the Industrial/Research (IR) zoning district.
SEQR COMMENTS
1. The proposed project is classified as a Type I Action under SEAR, requiring a coordinated review.
Upon determination that the application is complete in accordance with the Town Zoning Code,
145 Culver Road, Suite 160, Rochester, NY 14620 • 585.381.9250
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the Planning Board should initiate the coordinated SEQR review process, including formally
expressing its intent to serve as Lead Agency for the project. At this time, MRB Group has
determined that the application remains incomplete.
2. During prior meetings with Town officials, the applicant indicated that the project may include
battery energy storage. The applicant should confirm whether battery energy storage is proposed
as part of the project.
3. The Town of Lansing Planning Board is currently reviewing an application for a large solar energy
facility. This Cayuga Solar project would be located on several parcels, including a portion of the
Lake Hawkeye project parcel. If this is the case, then the Planning Board must contemplate all
planned and proposed developments upon the Lake Hawkeye property.The Lake Hawkeye FEAF
and application materials must include the scope and impacts of the portion of the Cayuga Solar
project sited upon the Lake Hawkeye parcel.
4. The Town of Lansing Planning Board is currently reviewing an application for a large-scale solar
energy facility (Cayuga Solar), which is proposed on multiple parcels, including a portion of the
Lake Hawkeye project site. If this overlap is confirmed, the Planning Board must consider all
existing, planned, and proposed development on the Lake Hawkeye property. Accordingly, the
Lake Hawkeye FEAF and supporting application materials should be revised to include the full
scope and potential impacts associated with the portion of the Cayuga Solar project located on
the subject parcel.
5. FEAF Question B.4 For all listed agencies, the specific approvals or permits required should be
clearly identified, along with the anticipated or actual dates of issuance. The applicant should also
confirm that all involved and interested agencies have been accurately identified in this section.
6. FEAF Question C.2.a. 4 The Town of Lansing 2018 Comprehensive Plan contains
recommendations related to the subject parcel. We recommend that in a separate narrative, the
application specify how the Project addresses the Plan's provisions related to the site.
7. FEAF Question C.2.b. -> The application affirms that the subject parcel is located in a Brownfield
Opportunity Area. We recommend that in a separate narrative, the application specify how the
Project addresses the BOA program's policies and goals.
8. FEAF Question C.2.b. 4 The project application should specify how the Project would address
provisions of the Town of Lansing Open Space Conservation Plan, and the Agricultural and
Farmland Protection Plan.
Re:LAKE HAWKEYE DATA CAMPUS-228 CAYUGA DRIVE
Nathaniel Rogers,Town Planner
Town of Lansing
April 22,2026 2
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9. FEAF Question E.2.h. 4 The Lake Hawkeye project contains wetlands. The applicant will need
to coordinate with NYSDEC and/or the Army Corps of Engineers to identify any restrictions or
mitigations required. Copies of resulting communications with NYSDEC and ACOE should be
provided to the Town and to MRB Group.
10. FEAF Question E.h. 4 In the submitted FEAF, the applicant affirms that past spills have occurred
on the subject parcel. The applicant should provide documentation to establish status/cleanup for
these spills and that proposed construction and operations of the Project will address related
issues.
11. FEAF Question E.2.o. 4 Indicates that the project may impact endangered or threatened species.
Coordination with US Fish and Wildlife Service will be required and resulting communications are
to be provided to the Town and to MRB Group. If there are any mitigation measures identified,
they should be addressed within the application materials.
12. FEAF Question E.3.a. 4 Affirms that the Project may contain or be adjacent to historical resources
potentially eligible for listing on the National Register of Historic Places. Coordination with the
NYS Historic Preservation Office (SHPO) is required. Copies of communications with SHPO are
to be forwarded to the Town and to MRB Group.
13. The Project proposes to utilize water service provided by the Southern Cayuga Lake Water
Commission/Bolton Point. As the design of proposed water service to the Project proceeds,copies
of communications with the service provider should foe forwarded to the Town and to MRB Group.
SITE PLAN & GENERAL COMMENTS
14. The submitted Site Plan set lacks necessary information and detail. The plans should be revised
to clearly depict all proposed improvements, including but not limited to easements, structures,
fencing, and gates. Ownership information for the subject parcel and all adjacent properties must
be provided. The plans should also clearly delineate municipal boundaries, zoning districts, and
parcel boundaries. In addition, a Zoning Table summarizing applicable area and bulk requirements
should be included.
15. Based on the proposed project phasing, a detailed construction sequence should be provided,
including all utility work, as well as the demolition or removal of existing utilities.
16. Per Town Code 270 -40.7 -The Project Application Exhibit J Photometric and Lighting Layout
describes proposed site lighting as follows:
Re:LAKE HAWKEYE DATA CAMPUS-228 CAYUGA DRIVE
Nathaniel Rogers,Town Planner
Town of Lansing
April 22,2026 3
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Site lighting will consist of roadway pole mounted lights and exterior building wall packs for
safety and security. Both the roadway lighting and building wall packs will utilize a full cutoff
design technology directing 100% of the light downward in effort to mitigate any upward
emission. This design concept prevents light pollution and shields any direct light glare.
The applicant must provide a Detail for each proposed lighting fixture.All fixtures must be dark sky
compliant lighting to be added to the Photometric Plan and/or the Site Plan.
17. Per Town Code§270—40.3-The Project Application Exhibit E Planting Approach is a generalized
site-wide plan. The applicant should provide greater detail about proposed plantings within the
Site Plan set. Details about which species will be planted, and how they will be maintained and
replaced, should be included within the Site Plan as narrative sequencing of plant installation and
care and with accompanying Details.
18. Per Town Code§270-27(13)-The applicant should prepare an Emergency Response Plan (ERP)
for review by the Planning Board. The ERP should outline procedures to be followed in response
to potentially hazardous conditions, including but not limited to equipment shutdown protocols,
notification of service and repair personnel, and established communication procedures with the
fire department in the event of a system failure.The ERP should be subject to review and approval
by the Town Fire Chief and the Tompkins County Department of Emergency Response.
19. The application states that a Terawulf subsidiary company will establish a lease upon the 183-
acre Project area within the larger subject parcel. The applicant should provide a copy of this lease
agreement to the Town.
20. The Project application includes Exhibit F Agricultural District Statement which contains a map of
parcels surrounding the Project parcel that are located within a NYS certified Agricultural District.
This map should be revised to clearly demarcate parcel boundaries. The name of the affected
Agricultural District should be added to the map legend. The applicant must prepare and submit
an Agricultural Data Statement for each Ag District parcel located within 500 of the subject parcel
boundaries.
21. Per Town Code 270-27 (17) - The Project Application Exhibit H Site Plan Renderings provides
views of the proposed Project from the air. The application states that development is "confined
to an interior plateau screened by natural topography and year-round vegetation."We recommend
that the applicant provide additional view simulations of the Project from the following locations: 1)
Re:LAKE HAWKEYE DATA CAMPUS-228 CAYUGA DRIVE
Nathaniel Rogers,Town Planner
Town of Lansing
April 22,2026 4
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Cayuga Lake water surface, 2) Western lakeshore, 3) Viewpoints along public roads east of the
Project area.
22. With access being provided to Ridge Road (NYS Route 34B), further coordination will be required
for any site improvements being provided within the right-of-way. All communications from
NYSDOT are to be provided to the Town and Town Engineer(s).
23. The application materials should be revised to clearly identify the number and size of buildings
proposed as part of the Project's second phase.
24. The application materials should be revised to describe the current status and potential future
disposition of the former power plant site, which has been inactive for several years. The applicant
should also clarify the extent to which the Lake Hawkeye project would utilize, traverse, or
otherwise interact with the former power plant site and its associated infrastructure.
25. Ownership and parcel data for adjacent parcels should be clearly depicted upon the Existing
Conditions and Site Plan sheets.
26. The Project parcel is located within a designated Local Waterfront Revitalization Program area;
The Town of Lansing participates in this Tompkins County-program. The applicant should explain
how the Project addresses policies and goals within Chapter Three of the"Cayuga Lake Waterfront
Plan". Cayuga Lake Waterfront Plan
27. Per Town Code § 270-27 (12) - The applicant should describe how the Project addresses the
goals and policies of the Town's "2018 Comprehensive Plan", noting particularly the Plan's stated
goals for the former Cayuga Power plant. 2018 Comprehensive Plan
28. Pursuant to New York State General Municipal Law (GML) §§ 239-1 and 239-m, the project
application must be referred to the Tompkins County Planning Board for review.
29. The applicant should confirm whether a Payment in Lieu of Taxes (PILOT)agreement and/or Host
Community Agreement (HCA) will be pursued with the Town or any other applicable taxing
jurisdictions.
30. The subject parcel is located within a Town of Lansing designated Unique Natural Area (UNA-
195). The UNA designation "provides an alert to municipal planning and decision-making
processes...." The applicant should explain how the Project could impact the subject parcel and
the larger UNA-195 considering established goals. Related to this requirement, the applicant
Re:LAKE HAWKEYE DATA CAMPUS-228 CAYUGA DRIVE
Nathaniel Rogers,Town Planner
Town of Lansing
April 22,2026 5
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should provide a map of the subject property's natural resources as may be produced in the
NYSDEC Resource Mapper.
31. The project will require a significant electrical load, and upgrades to the utility substation and
transmission system are proposed. The utility provider responsible for approving interconnection
to the electrical grid may require a Coordinated Electric System Interconnection Review (CESIR)
Report. Copies of any such report should be submitted to the Town and to MRB Group upon
completion.
32. The Conceptual Site Plan should be revised to improve overall clarity and presentation. Site plan
components should be color-coded and otherwise visually distinguished by category, including but
not limited to buildings, impervious surfaces, landscaping, and water storage. In addition, the
legend should be enhanced to improve readability, as current symbols and labels are faint and not
sufficiently differentiated.
33. The proposed location of the Point of Interconnection shall be shown on the plans. Service
between the system and Point of Interconnection shall also be shown as overhead poles,
underground service)
Please feel free to contact our office with any comments or questions you may have in this regard.
Respectfully submitted,
V
Shaun Logue
Project Manager I
Cc Kelly Geiger, Clerk- Planning & Code Enforcement Department
Dean Shea, Planning Board Chairperson
Ruth Groff, Town Supervisor
Mike Mosley, DPW Superintendent
Heather Dries, Code Enforcement Officer
Jack Young, ZBA Chairperson
Fred DelFavero, TeraWulf, Inc.
Adam Millspaugh, TeraWulf, Inc.
Re:LAKE HAWKEYE DATA CAMPUS-228 CAYUGA DRIVE
Nathaniel Rogers,Town Planner
Town of Lansing
April 22,2026 6
T . G . MILLER , P . C .
E N G I N E E R S A N D S U R V E Y O R S
605 W.State Street I Ithaca,NY 14850 1 phone 607-272-6477 1 fax 607-273-6322 1 www.tgmillerpc.com
April 17, 2026, Revised April 28, 2026
Nathaniel Rogers
Town of Lansing
29 Auburn Road
Lansing, NY 14882
Re: Proposed Lake Hawkeye Data Campus
228 Cayuga Dr, Lansing, NY 14882
Site Plan Review
Dear Mr. Rogers:
We have received an electronic copy of the FEAF Part 1, Stormwater Management Design
Memo #1, dated 3/25/2026, and Site Plan Application, Revision 0, dated 3/25/2026 for the
above referenced project. These documents were prepared by TeraWulf Inc. and Ramboll. We
have completed a review of the documents for compliance with Town regulations regarding
stormwater and potable water and offer the following comments. Additional comments will be
provided based upon the additional information requested and the submission of materials with
greater design and detail.
We have revised this letter to include additional comments and questions based on materials
and remarks made at the 4/27/2026 Planning Board meeting.
Miscellaneous
1. Identify the agency and approval required by each agency.
2. FEAF Part 1, D.1., b. and the Table in E.1., b. do not correspond. Update accordingly.
3. Coordinate with the Tompkins County Highway Superintendent and the Town of Lansing
Highway Superintendent to determine if any road use agreement or other improvements
are required for this project.
4. There has been mention of shoreline improvements for community benefits. Please
update the plans to identify these areas and any proposed earth disturbances.
5. There appears to be discussions occurring regarding possible subdivision of the lease
area. Please ensure the lease and/or subdivision provides appropriate legal means for
inspections and maintenance of any offsite stormwater improvements that will convey
the site discharge to the lake. A SOMRA will be required for all post practices and
stormwater conveyance means.
6. Identify the quantity of spoils to be removed from the site and the intended fill location.
Additional approvals for the fill site may be required based on its location. An individual
SWPPP for the fill site may be required depending on the volume and location.
David A.Herrick,P.E. Donald M.Harner,P.E. Lee Dresser,L.S.
Owen B.Barden,P.E. LEED A.P.,C.P.E.S.C. Jacqueline L.Dresser,L.S.
David L.O'Shea,P.E.
Stormwater
1. The FEAF identified an increase of 80 acres of impervious surfaces. The provided
SWPPP only identifies an increase of 43 acres. Please clarify and update associated
documents as necessary.
2. A Full SWPPP must be submitted in accordance with NYSDEC SPDES General Permit
for Stormwater Discharges from Construction Activity (CGP) and Ch 225 of the Code of
the Town of Lansing. The SWPPP must be complete and provide the required
information. Some, but not all, of the requirements are as follows:
a. Calculations showing that the CPv, Qp, and Qf rainfall events are conveyed to
the Lake without creating erosive velocities and storm infrastructure is sized
appropriately.
b. Identify site soil hydraulic groups.
c. Provide plans, details, and supporting calculations for all temporary and
postconstruction practices in accordance with the NYS Standards and
Specifications for Erosion and Sediment Control and the Stormwater
Management Design Manual.
d. Provide plans separated in phases. The plans must be inclusive of all proposed
improvements (substations, road improvements, utilities, etc.).
e. The construction phase plan must be inclusive of all temporary activities
(concrete plant, crushing, temporary haul roads, material storage piles, lay down
area, etc.)
3. The FEAF identified that on-site processing (crushing) may occur for material reuse.
Appropriate practices shall be incorporated into the SWPPP to contain any by products
and sediment laden waters.
4. Clarify if this project is subject to a Multi-Sector General Permit (MSGP) or other SPDES
permit(s). Provide a summary of any current or ongoing multi-sector permit requirements
for the site and how this project may impact any active permits. Provide a copy of any
correspondence from NYSDEC as applicable. The inclusion of BMPs in the SWPPP
may be required.
a. Please identify how the mister cooling water will be collected and
discharged/disposed of. If the intent of the water is to be collected and
discharged to a stormwater system, please provide communications from the
DEC that this chlorinated water with an elevated temperature can be discharged
to the lake. A SPDES permit may be required, and this should be included in the
MSGP.
5. There appears to be overlapping development areas between the Cayuga Solar Project
and this project. For example, the water tank farm is showing in the same footprint as
proposed solar panels. Clarify what is being proposed in conflicting locations. How are
overlapping areas being coordinated between projects?
T.G.Miller,P.C. 2
6. The CGP defines a Common Plan of Development or Sale as:
"a contiguous area where multiple separate and distinct construction activities
are occurring, or may occur, under one plan. The "common plan"of development
or sale is broadly defined as any announcement or piece of documentation
(including a sign, public notice or hearing, marketing plan, advertisement,
drawing, permit application, State Environmental Quality Review Act (SEQR)
environmental assessment form or other documents, zoning request, computer
design, etc.) or physical demarcation (including boundary signs, lot stakes,
surveyor markings, etc.) indicating construction activities may occur on a specific
plot.
A common plan of development or sale is comprised of two or more phases.
Common plan of development or sale does not include separate and distinct
construction activities that are occurring, or may occur, under one plan that are at
least 114 mile apart provided any interconnecting road, pipeline or utility project
that is part of the same "common plan"is not concurrently being disturbed."
Has there been any coordination regarding a larger common plan of development?
7. Please clarify how the site will be served by electricity. Will additional clearing be
required for electrical transmission lines? Will additional lines and infrastructure be
constructed? If so, show the limits on the plans or clarify if this will be installed under a
separate project. This may also be considered part of the Common Plan of
Development.
a. Similar to electricity, clarify what additional off-site improvements may be
required to support the project (broadband, etc.) and the proposed locations.
8. There appears to be separate wetland mapping exhibits between Cayuga Solar Project
and this site showing differing results. Mapping should be verified to ensure accurate
limits are shown. Have correspondences with the DEC and USACE indicated if any
wetland mitigation required as part of the project?
9. In accordance with the CGP, additional permits/authorizations will be required prior to
MS4 approval. These include, but are not limited to, the following:
a. Part I.A.3. requirements (endangered and threatened species)
b. Part I.A.4. requirements (historic property)
c. Part I.A.7. requirements (UPA permits)
Potable Water
1. Applicant has identified an average potable water consumption of+/- 30k gallons per
day and a peak of+/- 700k gallons per day. Additional information is needed identifying
the following information:
a. Frequency and duration of peak usage.
b. Anticipated daily average and peak usage patterns.
c. Please identify domestic and fire flow requirements independently.
T.G.Miller,P.C. 3
2. D.2.; c.; ii.: District serving the site is the Town of Lansing Consolidated Water District.
Additional information is needed to determine if there is adequate capacity to serve the
project. Once the above information is obtained, the Town water model can be updated
to better understand system capabilities to service the project. Additional coordination
will be required with the Southern Cayuga Lake Intermunicipal Water Commission
(SCLIWC)Aka: Bolton Point.
Please feel free to reach out to either Dave or myself if you have any questions.
Respectfully,
Donald Harper, P.E., C.P.E.S.C.
David O'Shea, P.E.
T.G.Miller,P.C. 4
TOWN of AANSING
G _ 'Horne of Industry,Agriculture and Scenic Beauty"
�`. ZONING, PLANNING AND CODE ENFORCEMENT
PO Box 186
29 Auburn Road
Lansing, NY 14882
i�
;& E-mail: tolcodes@lansinotown.com
2t
May 1, 2026
Scott Kobylarz
Director of Construction
Beowulf Electricity& Data I A TeraWulf Company
Re: 228 Cayuga Drive Sketch Plan Conference
Completeness Review
A completeness review was conducted by Town of Lansing Planning staff of any sections which
were not included as part of consultants initial reviews. Additional materials are required to
consider the proposed site plan application at 228 Cayuga Drive complete. This list represents
comments and requirements identified by staff and members of the Town of Lansing Planning
Board during their April 27th sketch plan conference.
1. There is no index, and there are no page numbers in the application. Typical organization and
formatting measures are needed to properly discuss different sections during Planning Board
Meetings.
2. Traffic data included is insufficient. More information is needed on anticipated traffic during
construction and regular operations.
3. The executive summary states that "No new electric generation facilities are proposed as part of
this application.", More information is needed on the exact number of backup generators to be
installed on site.
4. The executive summary states that "No rezoning or variance is required."According to the Full
Environmental Assessment Form the building will be 65 feet tall, the elevations show the
building will be at least 57 feet tall, and the maximum building height in the IR zoning district is
35 feet. An area variance will be needed once a full application is completed.
5. Measurements on the elevations do not go to the top of the building. Accurate elevations
showing the full height of the building are needed to effectively review the proposed building.
6. The submission only includes a conceptual grading map, which states "GRADING SHOWN IS
CONCEPTUAL ONLY AND IS PENDING SLOPE STABILITY ANALYSIS FROM A LICENSED
GEOTECHNICAL ENGINEER." It is not possible to comprehensively review a site plan without
topographically accurate maps. Applicants propose creating an area with a steep slope while
leveling the site.A retaining wall is mentioned, but not shown on any renderings. Details
regarding any proposed retaining walls and efforts to stabilize the slope are needed.
7. The application only assesses wetlands surrounding the proposed building site. The map
included does not exactly match with the wetland map of the full parcel provided by Cayuga
Solar in their ORES submission. If the current state wetland regulations are upheld in court,then
Cayuga Solar will likely get a jurisdictional determination from the DEC first, potentially
rendering some maps inaccurate.
8. Several of the wetland determination sheets have sections left blank that should be completed.
9. Several tree trenches are proposed 2 feet from bedrock. Details regarding plantings which are
viable at that depth are needed.
10. The map of the agricultural district included is not an agricultural data statement, which is
required for further review. Blank copies of the agricultural data statement form are available
on the town website.
11. Sections of the Full Environmental Assessment Form are left TBD. Accurate information
regarding the amount of water to be impounded is needed.
12.The Full Environmental Assessment Form describes that a 2,500 KW backup generator will be
installed in each phase. It is currently unclear if this refers to the subphases, or if one generator
will be installed during phase 1 and phase 2.
13. Question E.2.e on the Full Environmental Assessment Form claims—100%of the site is
moderately well drained. According to the Soil Resource Report earlier in the application some
areas are somewhat poorly drained. Sections must be updated to be consistent.
14. Each of the site renderings shows different access road designs and different landscaping.
Certain site elements like the water tanks appear to be missing from the renderings.
15. The vegetative screening in the Acoustical Assessment Report does not match the site
renderings or landscape design plans. The predicted noise contours also appear heavily
impacted by this screening, so updated landscape plans are needed.
16. None of the lights shown in the lighting plan appear in the architectural renderings. Renderings
should match details shown in submitted site plans.
17. The construction sequencing describes that there will be "Expansion of mechanical and
electrical infrastructure to support added load" and that "The project will include significant
electrical and mechanical infrastructure to support data center operations. Utilities will be
installed and expanded in a coordinated, phased manner." More information about expanded
electrical infrastructure is needed.
18. Construction staging appears to be located in areas which may be affected by the proposed
Cayuga Solar facilities. Applicants are advised to verify that there will be no conflicts with
neighboring planned construction activities.
19. Given a data center, solar facility, and large scale battery energy storage facility are proposed on
a site with a vacant coal plant and coal ash storage,there may be issues with keeping all
development under 80% lot coverage. Applicants are advised to take caution to remain under
the maximum lot coverage.
20. A copy of the lease must be submitted, clarifying the boundaries of the area to be developed.
21. Applicants must clarify who will own the additional substation being developed to support the
project.
22. More information is needed on the structure for the "Annual fund to support local schools,
parks, and community initiatives".
23. Please detail any decommissioning plans that are under discussion or will be created around the
proposed project, including at the former coal power plant site.
24. More information is needed regarding the temporary concrete production facility.
25. Maps must clearly show if all buildings meet current setback requirements from the boundary
between tax parcel 11.-1-3.212 and tax parcel 11:1-3.211.
26. More information is needed to show that proposed excavation will not interfere with aquafers
serving surrounding properties.
27. The site logistics and construction plans must be updated to show how residents living along
Milliken Station Road Extension and Old Orchard Road will be able to access their properties.
28. More information is needed regarding what will be done with fill removed during excavation on
site.
29. Please detail what approvals and permits will be secured for blasting on site, and what
notifications will be given to the salt mine and neighboring property owners.
30. Additional information is needed on the current anticipated costs for phase 1 and phase 2.
Respectfully,
/V0k��h4 �C)��e"
Nathaniel Rogers
Planner
29 Auburn Road,
Lansing,NY 14882
Office: (607)533-7054