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HomeMy WebLinkAboutMN-CAC-1997CONSERVATION ADVISORY COUNCIL MINUTES Meeting of January 13, 1997 Present: Dan Hoffman, Betsy Darlington, Guy Gerard, CC liaison Rick Gray, guest (and CAC applicant) Lee Adler, IHS guest Jeff Turton, Mr. Turton In Martin's absence, Darlington opened the meeting at 7:33 PM. Lacking a quorum, review of Dec. minutes was postponed. Community access to information about various environmental issues, such as proposals for projects that could affect the environment, was discussed. It was agreed that letters to the editor or regular columns in the papers about such matters would go a long way toward keeping the public informed. The "legals" are not widely read, and in any event, frequently do not adequately convey the extent of various proposals. Betsy agreed to contact someone at the Ithaca Journal and suggest having a regular column. It was pointed out that, while public participation is encouraged, and people are given opportunities to express their views to various lead agencies in the City, these bodies are in fact quite circumscribed in what they can or will do. Guy pointed out the importance of having a CAC rep. at Planning Board meetings, to express CAC's views. Southwest Area Land Use Study: We reviewed the draft resolution that Dan had prepared of CAC's comments on the plan, and made a couple of minor changes. We voted unanimously to approve the revised resolution. Since we didn't have a quorum, Dan and Betsy will contact those who were absent, send them copies, and see if they approve. Then it will be sent on to the Planning Board and Common Council /Mayor. Of foremost concern was that the Planning Board may be on the brink of accepting the plan despite the fact that there has not been an environmental review of it, and that the plan includes some elements that need revision. It was agreed that the CAC's resolution should be read at the upcoming Planning Board meeting. Adjourned at 8:35 PM! Submitted by Betsy Darlington NEXT CAC MEETING: FEBRUARY 10 , 7 :30 PM, CITY HALL Planning Board: Jan. 28 Common Council: Feb. 5 TO: Common Council Mayor Alan J. Cohen Planning and Development Board FROM: Conservation Advisory Council DATE: 1/21/97 RE: "Southwest Area Land Use Study (1994)" BACKGROUND The Conservation Advisory Council (CAC) has previously submitted comments on both the "Draft" and "Final" versions of the Southwest Area Land Use Study. Certain of the CAC's initial concerns were addressed in the "Final" (1994) report; however, the CAC did not receive a formal response to its comments on the "Final" report. Also, since the release of the "Final" report, an investigation has revealed the presence of extensive wetland areas within a significant part of the study area, namely, the current Southwest Park. The CAC is aware that the Department of Planning and Development has recommended that the "Final" report be adopted as part of the City's comprehensive plan, by the Planning Board and Common Council (see letter from H. Matthys Van Cort, dated 11/22/96). The following comments and suggestions are intended for consideration "by Common Council and the Planning Board prior to any action on the Planning Department's recommendation. CAC COMMENTS & SUGGESTIONS 1. Before the Planning Board or Common Council takes action to adopt the Southwest Area Land Use Study (SWALUS) recommendations or make them part of the City's comprehensive plan, adequate environmental review of the proposed action should be conducted. The CAC considers the adoption of a comprehensive plan or any component thereof (eg., this report) to be a Type I action under SEQRA and CEQRO. 2. Prior to environmental review, the SWALUS should be supplemented with an addendum that sets forth the newly - gathered information about wetlands in Southwest Park, and any recommendations or plans for addressing potential impacts of the proposed plan on the wetland areas. 3. Work on the alienation of the current Southwest Park, and particularly the acquisition of parcels that comprise the proposed substitute Southwest Park should not be delayed or affected by said environmental review. 4. Any plan approved for the Southwest Area should reaffirm the full boundaries of the substitute parkland (ie., all of the areas known as "Al" and 11A211). References to the "Wal -Mart site" as infringing upon the originally- designated substitute parkland (eg., Note A to Map 8) should be eliminated. CAC COMMENTS ON SOUTHWEST AREA LAND USE STUDY Page 2 1/21/97 5. Any approved plan should include recommendation(s) intended to protect the view from Buttermilk Falls Park, such as overlay zoning for the commercially -zoned land across Elmira Road from the Park. 6. Any approved plan should recommend rezoning that portion of the so- called "parcel S -4" (previously acquired by the City) which is outside the floodway /substitute park to parkland. 7. Any approved plan should at the most recommend reservation of specified "transportation corridors," rather than construction of actual roadways. The plan should explicitly state that future proposals to build actual roads would require separate, additional environmental review. 8. Any approved plan should incorporate at least a connecting corridor of non - commercially -zoned land between Nate's Floral Estates and any new residential area in the current Southwest Park (so that the two residential areas are not separated by conflicting land- uses). 9. Any approved plan should provide for an adequate buffer between Nate's Floral Estates and any adjacent land to be zoned commercial. 10. Certain portions of the current Southwest Park should remain undeveloped, including wooded portions on the westerly side (bordering the flood control levee and City -owned land along the Flood Control Channel), as well as the remnant flood plain forest noted in the current SWALUS. As the identified wetlands lie primarily in the southern half of the Park, it may make sense to concentrate development in the northern half, and /or to consolidate the largest wetlands into the most southerly portion. 11. If the current Southwest Park is to be developed, residential use should be the preferred recommendation. In addition to the need for more housing in the City, creative residential development is more likely (than commercial uses) to be compatible with retention of undeveloped areas on the site. 12. If the Cherry Street Industrial Park is to be expanded to the south, a wider buffer (including vegetation) should be provided between any new buildings and the Black Diamond Trail. Ideally, any new buildings should be located to the east of the extended Cherry Street. Approved, 7 -0. cc: H. Matthys Van Cort, Director of Planning & Development MINUTES CONSERVATION ADVISORY COUNCIL Meeting of Monday, February 10, 1997 Present: Martin Violette (Chair), Jill Brantley, Betsy Darlington, Dan Hoffman, Guy Gerard; CC liaison Rick Gray 1. Dec. and Jan. Minutes were approved unan. 2. Betsy agreed to take minutes. 3. Dan suggested that resolutions be attached to the Minutes that are filed in the Clerk's Office. Martin said the Clerk keeps a separate file of these, but agreed it would be good to have a copy attached to the minutes, as well. He'll ask the Clerk to put the lavender garden resolution with the Dec. Minutes, and the SW Area resolution with the Jan. Minutes. 4. Betsy reported on proposed and implemented changes in the Planning Dept. Jon Meigs's position ( "Planner II ") will be terminated at the end of the year. Meigs will take early retirement at that time and be called in as a consultant, as needed. Another Planner II position also may be eliminated but replaced with a position called "neighborhood and historic preservation planner ", presumably to be held by Leslie Chatterton. Other changes - -such as a new Economic Planner position - -in the Dept. are on hold until Common Council, the Mayor, and the Planning Dept. decide on how to reorganize it. Consensus was that it is important for the Dept. to have a dedicated individual overseeing environmental issues, a role Meigs has served very well. Consensus also was that the CAC needs to be kept in the loop. Important to attend Planning Committee /Board meetings where critical issues will be discussed. Martin will ask to have agendas of these committees sent to all CAC members. Betsy reported that the Mayor is not planning to reappoint her, but that she can continue to serve until he finds a replacement. Jill said she and others are being treated the same way. Betsy was asked why he isn't reappointing her and she said he felt it was good to have turnover on committees (get rid of dead wood ?). He plans to reappoint Judy and Paul, who can continue to serve until reappointed. He hasn't decided on Lee Adler's appointment. 5. Dan updated us on the proposal for a Natural Areas Commission. Currently, no group deals with non -park, non -6 -Mi. Cr. natural areas that are owned by the City. 6 -Mi. Cr. Committee, which would become a part of the new committee, has been concerned that oversight of 6 -Mi. Cr. would be diminished. As part of the substitute parkland exchange, the City will be acquiring Ithaca Falls and, presumably, more land near Negundo Woods, to substitute for SW Park. These areas will need oversight. for Cornell to give up Ithaca Falls, it is requiring that there be an oversight committee with Cornell represented on it. We reviewed the draft Dan had prepared and made a few suggestions for changes. 6. Community access to info on issues involving the environment: a. CAC's recommendations to Pl. Bd. and Dept.: some felt our comments are ignored (e.g. on EAF's). Betsy and Martin said they felt that this was not usually the case. Consensus was that oral presentations should be made at the Planning Bd. meetings, on the bigger issues (EAF's and otherwise). b. Media: Betsy spoke to City Editor at Ithaca Journal and suggested covering upcoming meetings where decisions will be made on big projects, since most people don't read the legals. Also suggested to her that environmental issues such as burn barrels and wood stoves be covered in the Journal. C. Everyone agreed we should attend important meetings and give our comments verbally, and be available for questions. d. It was agreed that Martin would give a report on CAC actions on EAF's at each of our meetings. Everyone was encouraged to attend the EAF subcommittee meetings when possible. 7. Martin summarized the EAF's Guy, he, and Betsy reviewed this evening: Valvoline -- recommended more big trees; deferred on the technical aspects of spill control, etc. since we lacked the needed expertise. Bank of Finger Lakes: Larger - -and more - -trees needed, esp. in SE corner and along S property line. Sidewalk needed. Floor just 0.8' above flood level! Vision Center: Hasty job by applicant and landscaping details weren't given. This is needed. Hope for large shade tree species. Adjourned about 9:15 PM - -Betsy Darlington CONSERVATION ADVISORY COUNCIL MINUTES: Meeting of March 10, 1997 Present: Guy Gerard, Jill Brantley, Betsy Darlington, Paul Salon, Judy Jones, Dan Hoffman,; EMC rep.: Barbara Ebert; CC liaison: Rick Gray; Guest: Doria Higgins Absent: Daryl Anderson, Martin Violette Martin being out -of -town, Betsy opened the meeting at 7:30 PM, following the EAF subcommittee meeting. 1. Doria passed out the Findings Statement for the Treman Marine Park Master Plan which has just been officially adopted by State Parks (OPRHP) in Albany. Doria pointed out a sampling of discrepancies, both within the master plan itself and between the plan and the findings statement. Since the findings statement is based on the master plan, the discrepancies within the latter are of special concern. None of us had seen the master plan and didn't know if a copy had been sent to Martin. We all agreed that State Parks should provide CAC with at least one copy, and that we should continue to be involved. Rick said that he thought any City action was on hold until State Parks requests the land transfer. Dan said that, prior to deciding about the transfer, the City must prepare a findings statement. We agreed that there was nothing for the CAC to do until the City has to take some action. It also was agreed that we need to see the plan. Judy stressed that protection of the Hog Hole is top priority. Dan said CAC should compare Common Council's August 1993 resolution with the master plan and the findings statement. Dan, Guy, and Jill agreed to do this. Con- sensus was that CAC's focus should be on the transfer of the land, and on what demands may not have been met. 2. Betsy described a proposal to change the City's handling of recyclables, with trash tags perhaps being replaced by clear plastic bags which one would buy from the City. The idea was greeted with considerable skepticism, but no action was taken since no proposal has yet been put forth. 3. February minutes were approved unanimously. 4. Rick said that all CAC members whose terms expired have been reappointed by Mavor -Cohen and CC. In addition, the Mayor wanted youth representation on the CAC and has appointed Derek Keil of 316 Fall Creek Drive to fill the vacant spot. 5. Dan reported on progress of the proposed Natural Areas Commission. Six -Mile Creek Committee is likely to endorse it, with certain conditions. Cornell is requiring that the City have a NAC as a condition of selling its land around Ithaca Falls to the City (part of the City's Inlet Island exchange). To the surprise of all, including Rick who said Common Council hadn't even seen it, Cornell is putting forth a contract it expects the City to sign as a condi- tion of the purchase. Some felt it was odd that Cornell was putting in so many restrictions on use when its own stewardship of the area has been less than exemplary. The contract has a number of restrictions which we felt must substantially lower .the property's fair market value. This was not taken into account in the appraisal of the property, however. Members wondered if the City should even be acquiring this land. It was agreed that the CAC should request to be involved in the discussions, to receive correspondence relating to the purchase, and to receive a copy of the contract. 6. DEIS for Novarr project on College Ave. Project would replace the Collegetown Motor Lodge and its parking lot with a 118 -unit (252 beds) apartment building with an 84 -space parking lot under it. This is the minimum parking required under zoning for the area. Not much can probably be done about this since it complies with the zon- ing, but there was dismay at the impacts this will have on Collegetown: As parking becomes ever -more scarce, there will be even greater impetus to tear down houses to build parking lots or even another parking garage; there will be further erosion of neighborhood character; businesses will come under greater stress from inadequate parking; and sooner or later, the City will feel compelled to build a bigger or a new garage which taxpayers will have to pay for. It was agreed that developers should have to bear some of the public costs that will result from their projects. It was remarked that it was better to have these big buildings near where students have to go, but that surely there must be a limit to how far the City wants to go in transforming Collegetown. Jill told about the transformation of Bethesda from a charming place to live to a huge, ugly canyonland of big apt. buildings. She forecast the same for Collegetown. She recommended that the zoning in Collegetown, esp. regarding parking requirements, be re- examined by the City. Dan warned that this had been a huge battle a few years ago and few are likely to want to revisit it. Betsy said that, even if the parking requirement were increased, more and more houses would be tom down to provide space for park- ing lots. Jill asked that next month we begin to look at the zoning requirements and consider reopening the battle. Betsy reminded people that the public hearing for the project is March 25 at 7.30 PM. Meeting was adjourned at 9:35 PM. - -Betsy Darlington NEXT MEETING: MONDAY MARCH 13, 1997 , 7.30 PM, City Hall I. Memo to: Planning Board Valvoline Cc: Common Council and Mayor City Attorney CAC members BPW, DPW Building Dept. From: Conservation Advisory Council's EAF Subcommittee Re: Valvoline Project on Rt.13 Date: March 12, 1997 Comments: We appreciate the changes that Valvoline has made in the site design, especially the inclusion of a sidewalk along Rt. 13 and more trees. We do not have the technical expertise to evaluate other potentially problematic aspects of the project, having to do with the wet, peaty site conditions and drainage. H. Memo to: Planning Board - Christopher George Corporation Cc: Common Council and Mayor City Attorney CAC members BPW, DPW Building Dept. From: Conservation Advisory Council's EAF Subcommittee Re: Catherine St. subdivision Date: March 17, 1997 Recommendation: Without knowing how large a structure could be built on the newly formed property, we cannot evaluate the impact of the proposed change in lot lines. The" application indicates 11 units more, but how large would each- unit be? If the new lot would be able to accommodate a very large building, we are concerned about the impact this would have on neighborhood character, especially along Catherine St., but also on the larger Collegetown area- -from both the aesthetic effect and the effect on availability of parking. If a very large structure could be built on the new lot, we recommend a positive declaration. CONSERVATION ADVISORY COUNCIL MINUTES: Meeting of April 14, 1997 Present: Jill Brantley, Betsy Darlington, Guy Gerard, Dan Hoffman, Derek Keil, Paul Salon, Martin Violette; CC liaison: Rick Gray; Guest: Doria Higgins Absent: Judy Jones, Daryl Anderson 1. April minutes approved. J. Brantley commented about "forcing the zoning issue" and said all present were in favor. 2. Discussion of Festival Lands transfer. D. Hoffinan handed out copies of Common Council resolution of 8/93 on Treman Marina, and a comparison of requests in the resolution and responses (or lack of) in the FEIS. Discussion followed on whether the City should transfer this land to the state, based on the informa- tion at hand. Hoffman proposed a resolution opposing transfer of this land from the City of Ithaca to the state, which was passed unanimously. (copy of resolution attached) 3. M. Violette handed out copies of the Tompins County Waterfront Plan, which will be discussed at the May meeting. 4. DEIS, Lake Source Cooling Project. This voluminous DEIS was presented for discussion, with comment to the DEC due by April 21. J. Brantley noted that the size and relative unavailability of the document made public review difficult. M. Violette noted that he agreed but thought the document is well organized and can be reveiwed in a timely fashion by the CAC. A comparison of scoping document outline with DEIS Table of Contents was made, and showed the DEIS to correspond to the scoping document in this respect. A sample check of approximately seven responses to public comments listed in the scoping document revealed two comments, one on synergistic effects and another on controlled lake level effects, to have seemingly inadequate responses in the DEIS. Given the short period of time left to reply, M. Violette agreed to compare the rest of the public comments and their responses in the DEIS, and to check to see whether SEQR requirements appear to have been met in the DEIS, and to formulate a comment to the DEC by 4/21 as required. Visitor D. Higgins remarked that the time allowed for this stage of the SEQR process seemed inadequate, and all agreed. Meeting was adjourned at 9:45 PM. -- Paul Salon NEXT MEETING: MONDAY May 12, 1997 , 7.30 PM, City Hall EAF Committee, 7:00 PM Conservation Advisory Council City of Ithaca Memo to: BZA and Building Department Applicants as noted below Copy to: Common Council and Mayor Planning Board & Dept. City Attorney CAC From: Conservation Advisory Council's Environmental Review Subcommittee (Darlington, Gerard, Violette) Subject: EAF Review(s) Date: April 14, 1997 1. Appeal #2330,1071/2 Dryden Road, Mauro Daigle. Comments: Appears to be a use which conforms with existing conditions, and we agree that parking prob- lems are not likely to be exacerbated. Recommendation: Negative declaration. 2. Appeal #2331,116 Mitchell Street, CSP Management/ Beth and Jay Hyman. Comments: We do not find any of the arguments in this appeal convincing. Existing zoning regulations in this section of the City need to be strictly enforced to preserve the existing balance between various types of occupancy, and no compelling reasons are evinced to justify modifying these regulations. Recommendation: Positive declaration. Conservation Advisory Council City of Ithaca Memo to: Planning Board & Dept. Applicant(s), as noted below Copy to: Common Council and Mayor BZA and Building Dept. City Attorney CAC From: Conservation Advisory Council's Environmental Review Subcommittee (Darlington, Gerard, Violette) Subject: EAF Review(s) Date: April 14, 1997 1. Lama/Agway Subdivision Comments: None Recommendation: Negative declaration. 2. 104 -110 Cottage Place Comments: None Recommendation: Negative declaration. CITY OF ITHACA 108 EAST GREEN STREET ITHACA, NEW YORK 14850 OFFICE OF TELEPHONE: 272 -1713 CONSERVATION ADVISORY COUNCIL CODE 607 RESOLUTION from the Conservation Advisory Council FESTIVAL LANDS TRANSFER (4/14/97) WHEREAS, the New York State Office of Parks, Recreation and Historic Preservation ( OPRHP) wants the City of Ithaca to transfer the so- called "Festival Lands" to the State of New York, which transfer would make the City-owned land part of Allan H. Treman State Marine Park ( AHTSMP); and WHEREAS, OPRHP recently completed environmental review of a proposed "Final Master Plan" for AHTSMP, adopted "findings" based on the Final Environmental Impact Statement (FEIS), and then adopted the Plan; and WHEREAS, while the Final Master Plan incorporates improvements suggested by Common Council, the Conservation Advisory Council and others during environmental review, the Plan and the FEIS fail to address several serious concerns, particularly those pertaining to the following elements of the Final Master Plan: - relocation of the entrance road - severing of the vehicular connection between AHTSMP and Cass Park - reconfiguration of the parking lots (requiring the loss of a number of mature trees) - possible expansion of seasonal boat slips within the marina basin; and WHEREAS, the construction of a new entrance road, severing of the connection with Cass Park and cre- ation of new boat slips all involve and require control of the Festival Lands; and WHEREAS, while the current OPHRP plan for AHTSMP includes environmentally positive elements and only relatively modest intrusions into the "undeveloped" portions of the Park, said plan is not immune to a change in philosophy at the State level; furthermore, it is the descendant of much more environmentally damaging designs, which were altered by OPRHP only as a result of vigorous and sustained public pressure; and WHEREAS, OPHRP has stated that its highest priority for AHTSMP is to serve the perceived needs of boaters from throughout the region; and WHEREAS, the City of Ithaca is likely to be more responsive to local concerns about access and non- boating oriented uses of the area; now therefore be it RESOLVED, that the Conservation Advisory Council reaffirms its earlier recommendation that Common Council retain title to and control of the "Festival Lands "; and it is further RESOLVED, that the Conservation Advisory Council urges Common Council and the Office of Parks, Recreation and Historic Preservation to cooperate in reducing traffic and parking problems associated with the existing entrance to ATSMP (without requiring construction of a new road) and in implementing a joint management plan that will keep the Festival Lands, Hogs Hole area and Lake shoreline in as natural a state as possible. Unanimously passed, April 14, 1997 "An Equal Opportunity Employer with an Affirmative Action Program" CITY OF ITHACA I OEI EAST GREEN STREET ITHACA, NEW YORK 14850 OFFICE OF TELEPHONE: 272 -1713 CONSERVATION ADVISORY COUNCIL CODE 607 April 18, 1997 Mr, Michael K. Barylski Deputy Regional Permit Administrator NYSDEC Division of Compliance Services t285 Fisher Avenue Cortland, NY 13045 -1090 Re: Comments on the Draft Environmental Impact Statement for the Cornell University Lake Source Cooling Project Dear Mr. Barylski: The Conservation Advisory Council of the City of Ithaca submits the following comments on the draft EIS for this project. We have examined this document for adequacy in three areas: 1), that it corresponds to the scoping document; 2), that comments received from the public on the draft scoping document are responded to adequately; and 3), that it conforms to requirements set forth in SEQR regulations. 1. In our review, the DEIS appears to completely conform to the requirement that it corresponds to the scoping document. 2. As a result of our examination of the responses to public comments contained in the DEIS, we would like to make the following comments: Comment 11, "Consider how a controlled change in lake level might alter the impacts of the pro- ject". Our original comment was "4. 2.3.1.2. should be expanded to include q fects of permanent lower- ing of the lake level_for_tlood control, and appropriate sections should discuss these effects. ". The relevant section cited (2.3.2.2.6) does not contain comments about this issue. Comment 12, "Discuss the possibility of synergistic effects ". Our original comment was -6. There needs to be a discussion of the potential for synergistic effects of the various impacts, and especially of worst case scenarios, perhaps in a separate chapter. " The intent of the question was to explore the consequences of the concurrent impacts of separate environmental conditions, for example, a lowering of lake levels through man -made controls, intensified global warming, and the necessity to revert to chemical mussel control. We do not see this directly addressed in the DEIS. Comment 20, "Explain the impact of biofouling controls on drinking water quality". We feel it might have been informative to add 2.3.6.2.2.5 as a section where this issue is addressed. Comment 34. "Consider alternative energy sources (hydrogen, clectrolumineseence, wind, solar) ". Sec- tion 1.2.2 mentions, but does not "consider" such alternatives. 3. Conformance to SEQR requirements. In our view. SEQR requirements for a (D)EIS can be divided into two broad categories, one which governs the substance of the document, and a second which governs its style. in terms of substance, this DEIS, except as noted above, appears to be completely responsive. All required elements are present. In terms of style, there are two aspects of the DEIS we think deserve comment. First, this document is exemplary in its readability, by reason of its clear language and its excellent organization. Our task was made much easier by these characteristics. On the other hand. SEQR requirements for EIS content refer to the necessity for being "concise" and not "encyclopedic" [6.1.7.9(bX I and 2)]. We recognize the difficulty of preparing an EIS for a project of the magnitude and level of innovation such as the Lake Source Cooling Project, but the practical effect of a DEIS of this size is that reviews such as ours, done by agencies which may meet only once during the time period given, and then only towards or at the end of this time period, are done somewhat in haste. SEQR specifies that the minimum period for this part of the review process is 30 days, which is what has been allowed, but we would like to note that a longer review period would have been more appropriate, given both the size and the technical nature of the material we were required to examine. We would also like to express our concern that an adequate number of copies (at least of vols. 1 & 11) be made available to the public during the next phase of the process. Please feel free to call me at 607- 277 -2699 if you have any questions or comments. Sincerely yours, Martin Violette. Chair Conservation Advisory Council, City of Ithaca cc: Mayor and Common Council. City of Ithaca Robert Bland, Cornell University Lanny Joyce, Cornell University Conservation Advisory Council City of Ithaca Memo to: BZA and Building Department Applicants as noted below Copy to: Common Council and Mayor Planning Board & Dept. City Attorney CAC From: Conservation Advisory Council's Environmental Review Subcommittee (Darlington, Gerard, Kell, Violette) Subject: EAF Review(s) Date: June 23, 1997 1. Appeal #2333, 416 Hillview Place Comments: We agree with comments from neighbors that this will be a change for the better, provided a limit of five people is applied. Recommendation: Negative declaration 2. Appeal # 2334, 531 Esty Street Comments: Although this appears to be a suitable use for the location, parking considerations are the most important issue here. Can this problem be resolved through the use of parking on other properties as suggested, or will on- street parking problems be made worse. This needs to be completely resolved before approval. Recommendation: Negative declaration, if the above conditions are met. CONSERVATION ADVISORY COUNCIL City of Ithaca 108 E. Green St. Ithaca, NY 14850 September 8, 1997 Mr. Michael K. Barylski Deputy Regional Permit Administrator NYSDEC Division of Compliance Services 1285 Fisher Avenue Cortland, NY 13045 -1090 Re: Final Comments on the Draft Environmental Impact Statement for the Cornell University Lake Source Cooling Project Dear Mr. Barylski: The Conservation Advisory Council of the City of Ithaca submits the following final comments on the draft EIS for this project. These comments are based on input received from members of the Ithaca community, as well as our own deliberations during the public review period which ends today. These comments are intended to supplement, rather than replace, our earlier written comments. We find that certain deficiencies persist, in our view, in the dEIS. These are as follows: 1. Under 617.9(5)(iii)(`d') of SEQR, "growth inducing aspects" are required to be discussed. Chapter 6 discusses only the growth in utilization of this technology by Cornell, and does not include a discussion of other possible "growth ". Specifically, the possibility that this project will invite other agencies, organiza- tions, institutions or businesses to to use lake source cooling for their physical plants should be discussed . 2. In the same section of SEQR, under 617.9(5)(v)(`a' through `g'), a discussion of "reasonable alterna- tives" is required. Although it seems that other approaches were considered, for example a "closed- loop" system, no mention is made of these, so it is impossible to judge whether they were fairly evaluated. 3.617.9(6) requires a discussion of "information about reasonably foreseeable catastrophic impacts" which may be "essential to an agency's SEQR findings ". We have repeatedly asked for such a discussion under the rubric of "synergistic effects ", but we still note the lack of such a discussion. 4. We do not see an adequate discussion of the handling of dredge soils, as required by 617.9(5)(iii)(`a), "reasonably related... environmental impacts ". 5. Is there sufficient backup so that there is no economic dis- incentive to cease operations if unforeseen major environmental impacts occur? Please feel free to call me at 607 - 277 -2699 if you have any questions or comments. Sincerely yours, Martin Violette, Chair Conservation Advisory Council, City of Ithaca cc: Mayor and Common Council, City of Ithaca Robert Bland, Cornell University Lanny Joyce, Cornell University