CHNA RESPONDS
Gan Eden Developers Submit Scoping Document
HURLEYVILLE— The developers of the Gan Eden housing project proposed for the old Columbia Hotel property in Hurleyville have submitted their draft scoping document to the Town of Thompson Planning Board, and the Columbia Hill neighborhood Alliance citizens group has submitted a response.
The following are comments were submitted by CHNA for inclusion in the record at the Gan Eden Project’s Scoping Session before the Planning Board on July 8.
Comprehensive Plan and Community Character
The Town of Thompson-Village of Monticello 1999 Joint Comprehensive Plan embraces a commitment to ensuring new development meets a higher standard which “reflects the community’s commitment to preserve its natural environment and small town character” that are desirable to residents and visitors alike. The community character of the immediate area is rural and sparsely populated and local residents have repeatedly expressed their desire that it remain that way. This oversized project threatens to forever transform the community’s way of life in all the ways that the Joint Comprehensive Plan sought to avoid. Any potential benefits from the Project, such as tax revenue, primarily accrue to the Town of Thompson; while the majority of disadvantages, including well problems, flooding, and traffic increase, will be borne by the Town of Fallsburg and, in particular, the hamlet of Hurleyville. The Final Scope should require a comprehensive review of the elements that make up the small town community character of this area and how a residential development greater than the population of Hurleyville will permanently change that character.
Stormwater
Water and its respective sections in the applicant’s Full Environmental Assessment Form (FEAF) and eventual Draft Environmental Impact Statement (DEIS) constitute some of the most concerning aspects of this proposed development. The scoping document fails to address the problem of storm water runoff from this site which has plagued the downhill hamlet of Hurleyville for decades despite there being no structures or impervious surfaces on it at present. Placing 89 large structures, a community center, playgrounds, tennis courts, thousands of paved parking spaces and 2 miles of roads on the site will only exacerbate that situation. The applicant’s contention that the use of retention ponds and vegetated swales will decrease the amount of such runoff fails to address the fact that these measures already exist on the site and have not diminished the problem.
Wastewater Discharge
A substantial error in the FEAF seems to be the repeated assertion that the Class B Stream the developer plans on discharging its treated wastewater into is “on site.” A review of maps of the area clearly demonstrates this is not the case. In fact, an engineer representing Gan Eden Estates at a Thompson Planning Board meeting in July, 2016 indicated that they did yet not have a general discharge route for its Wastewater Treatment Plant (WWTP). The Town engineer expressed concern about obtaining an easement for that purpose and there is nothing in the scoping document to reflect that an easement has been obtained for that purpose. It is difficult to see how a project of this scale can proceed to obtain any of the numerous permits and approvals needed, while lacking this crucial component. The DEIS should determine whether an easement is necessary and possible.
It is not clear as to the type of WWTP the Project will utilize. A large WWTP potentially will have performance problems both in function and longevity. Larger WWTP require a constant year-round flow in order to work correctly and the components are subject to failure if not operated and maintained diligently. When questioned by a Planning Board member in July 2016 about the expected life span of the WWTP components, the same engineer representing Gan Eden indicated a five-year lifespan. The DEIS should describe in detail the WWTP, provide examples of its use in similar settings, describe the anticipated daily, weekly, monthly and yearly maintenance, and discuss the anticipated lifespan for the system.
Water Usage and Supply
In the FEAF there is a calculation on estimated water usage of 147,250 gallons per day in the first phase. We note that, to our knowledge, the developer has yet to complete the NYS DEC Water Conservation Program Form for Public Water Supply that requires an indication of the total population of the project. The Project should be required to provide information regarding anticipated usage that is properly verified and sourced so that it can be effectively reviewed and evaluated.
The town’s own consultant, Miller Hydrogeologic Inc., has questioned the accuracy of the developer’s 72-hour well testing done in October 2016 because the well test failed to follow established protocols and methodology. In preparing the DEIS, the developer should be compelled to redo the 72-hour well test during the peak summer season of July and August when the local population quadruples, to provide more accurate hydrological data than the 2016 pump test done in the fall months.
Safety
There is insufficient information regarding the ability of the Project’s water system to meet safety requirements, supply sprinkler systems and meet firefighting requirements. The Final Scope should require a detailed description of this system and require that the Hurleyville Fire Department be consulted and requested to weigh in on the adequacy of protective measures and water supply system at the Project site.
Water Tank and Aesthetics
The applicant should be required to provide detailed engineering information about the proposed 400,000-gallon water tank, particularly as regards functionality and location, the risk and impact of failure and its aesthetic impacts. This tank will be a prominent eyesore not only for local residents, but will also be a scar upon area viewscapes near and far. Scoping should include the aesthetic impact of a 109’ structure situated on top of a 1600’ altitude hill, as well as requiring the applicant to determine if the tower requires red blinking aviation warning lights and FAA review under the recent FAA guidelines modifications that apply to towers between 50 and 200 feet
Light
Another issue that needs to be addressed in the scoping document is light pollution from all outside lighting. Currently neighbors can view a star-filled sky, including the Milky Way, on cloudless nights. What will be the impact of 24/7 lighting and how can these impacts even be mitigated? Light impacts must be an issue assessed by the DEIS.
Traffic
Another matter requiring greater attention in the scoping document is the estimated additional 500 plus resident vehicles the Project will add to local traffic, not to mention delivery and sanitation trucks, taxis, contractors and other service vehicles on a regular basis. The three proposed exits have line of sight issues and require entering and exiting from already heavily travelled County Roads 103, 104 and 107 with speed limits of 55mph. Traffic signals and signage will be necessary to protect the public from these inevitable hazards of increased traffic, especially during the summer and winter months. The Sullivan County Department of Public Works and NYS Department of Transportation should be consulted and asked to provide input on these potential hazards.
Flora and Fauna
The nature of the flora and fauna on the site has been misrepresented and understated. Many more species than those listed in the FEAF are present or pass through this property. The scoping document should include an evaluation of the Project’s interference with the migration and movement patterns for predominant species. The scoping document must include an evaluation of any clear cutting of any forested parts of this site and the impacts upon the nesting of the Federal and New York State protected Northern Long-Eared Bat and any other protected species’ habitat.
Other Issues
The scoping document needs to include an evaluation of Project impacts on the local power grid and the potential for increased brownouts and/or blackouts in the area. The scoping document needs to evaluate additional infrastructure requirements such as substation, transformers and power lines as well as the environmental and community impacts of such additions.
The scoping document fails to include the impact of architectural features at the site. Certain building features and their impacts need to be evaluated. Will the heat retention properties of paved surfaces and asphalt roofing materials exacerbate and accelerate climate change conditions? Will sod lawns and decorative landscaping utilizing extensive fertilizer and pesticide application present problems of nitrogen loading and runoff? Such substances as well as the application of road salt in the winter can seep into the ground water polluting local wells and the Class B Stream.
The developer fails to acknowledge on the FEAF that there are facilities serving children, the elderly and people with disabilities within 1500 feet. The Center for Discovery has multiple sites within that parameter. The DEIS should provide a comprehensive identification of all facilities serving children, the elderly and people with disabilities within a quarter mile. The DEIS should also evaluate the frequency of vehicle traffic transporting children, elderly and people with disabilities between facilities along the roads that will be heavily impacted due to the Project.
The adjoining Loch Sheldrake-Hurleyville Rod and Gun Club’s members have deer hunting blinds in trees along the boundary line between the two parcels. Hunting happens not only at a lower elevation as stated in the FEAF, but all along that boundary.
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