Comments on the Draft Environmental Impact Statement (DEIS)

Terravest Phase II and III Developments in the Town of Southeast.

Individuals

Organizations

Government Agencies

Subject: Terravest (Phases II and III)

Dear Mr. Rohrman,

Thank you for taking the time to read my comments regarding a project that is currently before the Southeast Planning Board: Terravest (2nd & 3rd phases).

As a resident of Southeast and a taxpayer, I am concerned about several elements of this project and would like to be assured that these concerns are acknowledged by your board and addressed by Town officials and the applicant.

It is clear from recent articles in the Putnam County Courier and Putnam County News and Recorder that the State Governor, County Executive, at least one County Legislator, the County Planning Department, Southeast's Town Board and Supervisor, and the Economic Development Corporations of the State and county all welcome Ace-Endico as the key occupant in this project. It is also evident that every effort has been made to advance this project while accommodating the applicant using every tool available to regional officials, in and out of government.

Senior housing is simply "residential development" in sheep's clothing: This applicant is planning 72 single-family, detached homes as part of a project whose entire property (on that side of Route 312) would not be large enough to accommodate that number of homes using any other zoning formula in our Comprehensive Master Plan.

While the "Senior Housing" alternative permits this level of density, it comes with a series of requirements that are not being met by the applicant. These requirements include "neighborhoods" which do not exist in this locale and nearby shopping and facilities that are not part of this application.

While our Town Board should be commended for up-zoning wherever possible and for instituting and renewing building moratoriums, this project is obviously "getting a pass" using a variety of loopholes designed expressly to allow applications that meet none of the stated objectives of that well-publicized legislation.

Food processing and warehousing: Ace-Endico's primary business is one of processing and repackaging food products for distribution to institutions, end-users and retailers. Among the products they handle are meat, poultry, fish, fruits and vegetables. (These facts were taken from the Ace-Endico website and from publicity about their company found elsewhere on the Internet.) Therefore, although the nature of Ace Endico' s proposed operations were not adequately described in the DEIS, we can assume that a food processing and warehousing facility will have food processing waste, spoiled food waste (including meat and fish), and chemical treatment or cleaning materials all flowing into the stormwater runoff and/or wastewater system. None of these likely effects were considered in the DEIS.

Wetlands & wetland buffers: The applicant discussed disturbance of wetland and wetland buffer areas and outlined mitigation measures that rely mainly on maintaining existing vegetation, reseeding disturbed areas, and the creation of water detention and water quality basins.

Those measures can not be sufficient to replicate the beneficial functions performed by the wetlands and wetland buffer areas. Town of Southeast regulations require a 100' buffer around all wetlands, and the buffer cannot perform its essential functions if it is disturbed by construction activities and largely covered by impermeable surfaces. It seems apparent that, in effect, there is no real mitigation plan.

Implementation of a stormwater management plan is not a substitute for actual mitigation, especially where 8 of the 17 stormwater basins will be located in the buffer areas. Therefore, the Board should not allow any disturbance to the wetland or critical buffer areas, and the site-plans should be revised to remove impervious surfaces and other disruptive activity from these areas.

The future of Route 312, Route 6 and Route 22: Due to a cause-and-effect relationship, commercial space at the proposed location will almost certainly induce secondary growth, including subdivisions, strip malls, supermarkets, fast-food restaurants, and other services in Southeast and other parts of the Croton Watershed. The resulting sprawl would bring further degradation to the watershed and the increased traffic would further degrade mobility on Route 312, Route 6 and on the already over-burdened Route 22.

Yours truly,

Denis Castelli

Cc: Lois Zutell, Town Supervisor

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