Comments on the Draft Environmental Impact Statement (DEIS)

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

Individuals

Organizations

Government Agencies

October 17, 2002

Chairman George Rohrman and Honorable Members of the Planning Board of the Town of Southeast

67 Main Street
Brewster, NY 10609

Re: Terravest International Corporate Park

By Fax and Surface Mail

Dear Chairman Rohrman and Honorable Members of the Board,

The Croton Watershed Clean Water Coalition, Inc. (CWCWC or Coalition) is submitting these comments regarding various proposed actions within the Terravest International Corporate Park. CWCWC comprises 52 groups throughout New York City, Westchester and Putnam Counties, who are concerned about protecting the Croton watershed and its reservoirs from pollution. The Croton is a critical component of the system that provides over nine million people with still unfiltered drinking water. The Terravest proposal could directly affect the Middle Branch reservoir of the Croton system.

The Stormwater Pollution Prevention Plan (SPPP)

A. The SPPP Should Be Included In The DEIS

The Board is undoubtedly aware that the Middle Branch is within a phosphorus restricted area of the Croton watershed. Under Section 18-39(c)(1) of the 1997 Memorandum of Agreement: “When any activity listed in paragraph (3) of subdivision (b) of this section is proposed to be undertaken in a phosphorus restricted basin, the stormwater pollution prevention plan shall include an analysis of phosphorus runoff, before and after the land disturbance activity. Such plan shall require measures to capture and treat the 2-year, 24-hour storm runoff from the disturbed area created by such activity.” The DEIS does not contain either the required analysis or the plan to treat the runoff from the disturbed areas. The applicant appears to be relying on the NYC Department of Environmental Protection (DEP) to provide the SPPP. It is possible, therefore, that the applicant will be faced with having to enlarge, reshape or reposition the proposed seventeen stormwater management facilities (15 water quality basins; 5 detention basins and one stormwater maze). This, in turn, could require the reconfiguration of some of the components of the plan, such as parking lots, loading utilities etc...In order to avoid such an outcome, we urge that the SPPP be an integral part of and included in the DEIS. In this way, the SPPP can be optimized to treat stormwater runoff rather than being retrofitted to the site plan after the latter has been approved.

The Board must also be aware that, at least, four major developments are being planned in the Middle Branch watershed in addition to Terravest. These are: The Fairways, 93 acres (Carmel); the Self-Storage Facility (Southeast); Meadows at Dean’s Corners, 139 acres (Southeast); Campus at Field Corners , 327 acres (Southeast).

An analysis entitled Nonpoint Source Implementation of the Phase II TMDLs (April 2001), conducted by the DEP in conjunction with the NYS Department of Environmental Conservation (DEC), concludes that Southeast’s contribution to the phosphorus overload of the Middle Branch is 114 lbs/year. We urge the Planning Board to adopt a holistic view and to require that the overall phosphorus input to the Middle Branch reservoir from these five developments be reduced.

B. The SPPP Must Contain An Analysis of Impervious Surfaces The proposed action includes three components:

1) T-2

Lot 1 (19.47 acres) - 295,000 ft2 of office/warehouse/light manufacturing (Ace Endico)
69 parking spaces
15 loading docks
38,265 ft2 storage for trailers

Lot 2 (8.8 acres) - 16,000 ft2 of office/warehouse/light manufacturing
18 parking spaces
2 loading docks

Lot 3 (8.74 acres) - 64,000 ft2 of office/warehouse/light manufacturing
58 parking spaces
2 loading docks

Lot 4 (7.93 acres) 43,000 ft2 of office space/warehouse/light
manufacturing
7.93 acres
41 parking spaces
2 loading docks

Adding up the square footage of the office/warehouse buildings and the storage for trailers yields 446,265 ft2 of impervious surface (about 10 acres). However, also included should be the impervious surfaces for parking spaces and loading docks. Apparently, the acreage for these is not provided in the DEIS. Even without these additions, the imperviousness is about 19% of the 52 acres that are drained post-development (see pages 132 et seq of Volume I of DEIS). It is now accepted by the leading authorities on stormwater runoff that when the imperviousness of a drainage basin reaches 10%, streambank erosion starts to manifest itself. Some of the damage can be mitigated by the appropriate design and placement of stormwater management practices. However, beyond 20% to 25%, no combination of stormwater practices will be able to reduce the phosphorus load below its natural background level. (See Watershed Management for Potable Water Supply: Assessing New York City’s Approach, National Academy Press, Washington, D.C.). This limit is probably reached when the parking areas and loading docks are included in the impervious surface analysis.

We urge the Planning Board to take a careful look at the total amount of impervious surface in Terra-2 and have the applicant reduce it by the appropriate amount to prevent any increase in phosphorus above the background level.

Similar analyses should be carried out for T-2 and T-9. In the case of T-3, the playing fields should be regarded as being close to 100% impervious.

Impacts to Wetlands

T-2 has a 7.1 acre wetland along the western portion of the site. According to Map # 8-3, Sheet T2-L1.1 (Volume 1), there are three water quality basins in the buffer plus a level spreader. Also, there is some disturbance to the wetland itself. A swale, within the buffer, is being proposed for the northwest corner. There will be stormwater discharge into the wetland and buffer at this particular area.

T-3 contains three town-regulated wetlands: a central wetland corridor of 4.6 acres; a 1.5 acre wetland corridor in the southeast corner and a 0.19 acre wetland in the southwest corner at the intersection of Zimmer and Holmes roads. The 4.6 acre wetland contains a DEP watercourse. Map # 8-3, Sheet T3-L1.1 shows two water quality basins in the buffer. A very steep gradient is shown to be in the buffer between the edge of the southern senior housing and the edge of the wetland. Approximately 12 houses are situated at the edge of this very steep gradient and could cause erosion problems and damaging stormwater flow into the buffer. Map # 8-3, Sheet T3-L1.2 shows a similar very steep gradient between the northern senior housing and the edge of the wetland, within the buffer. Additional buffer infractions include a snack bar and restrooms; 28 parking lots for the Town Park; portions of the four playing fields. Also, the grade across the Town Park is proposed to be changed, resulting in the drainage basins being on the wetlands side of the fields.

The applicant states that only a minimal amount (0.04 acres) of wetland will be disturbed, and only 10 acres of buffers (which are regulated by the Town of Southeast). However, the buffers will be impacted by 12 water quality basins, 5 detention basins and a stormwater maze. We urge the Planning Board to disallow stormwater practices within wetland buffers since they will, undoubtedly, alter the hydroperiod within the wetland itself with probable ensuing damage to the continued viability of the wetland. Without the protection of a healthy buffer, the chances of the wetland being able to survive are severely diminished. Filling in a small amount of wetland with a road can have consequences far beyond the small amount removed. The normal flow that replenishes the wetland could be stopped or altered and the wetland would be unable to survive. The consequences of the 0.04 acres of fill should be evaluated.

Miscellaneous Comments

Page 28, Volume 1. States that except for Ace Endico, all other commercial uses are speculative. It is extremely disturbing, particularly for the residents whose homes abut the proposed development, to not know who their neighbors are going to be. Will these future unknown neighbors’ businesses require the use of considerably more trucks, create more noise, more garbage, more traffic? What will be their business hours? Will there be disturbing truck traffic during the night? All these questions need hard a nswers.

Page 29, Volume 1. States that all commercial lots will be serviced by on-site wells and connection to the Terravest WWTP which will be located on T-3. A force main pipe will be extended from T-2 across Zimmer Road to the WWTP. The design flow for the WWTP is 51,800 gpd, a not inconsiderable amount. How much acreage will be taken up by the WWTP? How large is the leaching field and the supplemental leaching field. “The area of the leaching field will be cleared of trees” (page 132, Volume 1). How many trees will have to be cut down ? How will odor problems be mitigated? This is particularly important since the WWTP is located in close proximity to both sections of the proposed senior housing.

Finally, there is no reference to a scientific investigation of the possible presence of threatened and/or endangered species. Significant areas of the proposed development still are forested and have wetlands. These should be thoroughly researched before any encroachments are allowed.

Thank you for this opportunity to comment.

Marian H. Rose,
President CWCWC

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