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NYC Audubon Letters
NYC Audubon Comments
NYC Audubon Testimony
Testimony of New York City Audubon
Before the Committee on Environmental Protection
City Council of the City of New York
Monday, June 26, 2006
RE: Int. No. 375 –
In relation to protecting the purity of the New York City drinking water supply
My name is Yigal Gelb and I am Program Director for New York City Audubon.
New York City Audubon was established as a permanent chapter of the National Audubon Society in 1980. We serve and represent over 10,000 members in the City’s five boroughs. Our primary mission is to protect wild birds and habitat within the City, improving the quality of life for all New Yorkers. Our areas of concern have long included the Catskill and Adirondack Parks and, most particularly, the watersheds of New York City’s Water Supply System. I am pleased to testify today in support of Int. 375 regarding protecting the purity of the New York City drinking water supply.
On behalf of New York City Audubon, I thank Speaker Christine Quinn, Chairman James Gennaro, Council staff members that worked on this bill, and all the Councilmembers who have co-sponsored this very important legislation. From our earliest days, New York City Audubon has been a staunch advocate of the City’s Water Supply System lands and facilities in the Catskill, Delaware, and Croton systems. Today, I am here to reiterate our commitment to this Watershed.
We believe that the ten year, willing-seller/willing buyer acreage goal for the Watershed set forth in the bill is feasible and would greatly help protect the downstate water supply. Protecting an additional 75,000 acres of the Watershed over the next ten years will carry tremendous benefits to both humans and wildlife:
For humans, the additional acreage offers many recreational opportunities. As development pressures increase throughout our region, securing areas that allow for hiking, fishing, and other activities that do not threaten water quality becomes ever more important. We strongly support making newly acquired areas available to both local residents and visitors from outside the area. Allowing local residents to enjoy these natural areas also guarantees that they continue to be our partners in safeguarding them.
For wildlife, the preservation of additional acres is imperative. As natural areas are constantly encroached upon, the protection of 75,000 additional acres means that tens of thousands of wild trees, shrubs, and other plants continue to grow every year. These plants provide both shelter and food for many different animals, from insects to great mammals. Many bird species rely on these natural areas for their survival, from the familiar resident birds such as woodpeckers and blue jays, to less common migratory species such as warblers and raptors.
Migratory bird species rely on these areas as a “stopover” on their long migration route from Central and South America to the vast Boreal forests up in Canada. Other species rely on these areas to grow the next generation of young, making their nests in shrubs and trees while feeding on plentiful quantities of insects. We now know that the most serious threat to wildlife comes from habitat destruction and fragmentation. Conserving and protecting large areas, as is proposed in this bill, will go a long way to help protect wildlife in our state.
The Watersheds in question already include natural areas that were identified as important for birds, many of which are at risk. Audubon New York, the state office of National Audubon, published the second edition of Important Bird Areas of New York: Habitats Worth Protecting. It lists 136 Important Bird Areas around the state, 28 of which have also been declared as Bird Conservation Areas by State Government. Those that are wholly or partially within the Catskill/Delaware watershed are 70,000 acres in the Ashokan Reservoir Area, 310,000 acres in the Catskill Peaks Area, 5,000 acres in the Pepacton Reservoir Area, and 65,000 acres in the Cannonsville Reservoir/Steam Mill Area.
Combined these sites support significant populations of nine so-called “species at risk.” Species at risk include those birds that are listed by Federal or New York State agencies as endangered, threatened, or of special concern, as well as those on Audubon’s Watch List of 2002. The nine species are American Black Duck, American Woodcock, Bald Eagle, Bicknells Thrush, Canada Warbler, Common Loon, Coopers Hawk, Northern Goshawk, and Red-shouldered Hawk. Additionally, the sites support 14 “Responsibility Species Assemblages,” that is, sites responsible for providing important habitat for substantial numbers of individual bird species that cannot survive in other types of habitat. Such sites are usually large, intact areas. The Responsibility Species are Baltimore Oriole, Black-and-white Warbler, Black-billed Cuckoo, Black-throated Blue Warbler, Blue-gray Gnatcatcher, Cerulean Warbler, Eastern Wood-Pewee, Least Flycatcher, Louisiana Waterthrush, Northern Flicker, Rose-breasted Grosbeak, Scarlet Tanager, Sharp-shinned Hawk, and Yellow-throated Vireo.
Fragmentation of habitat is the single-most dangerous threat to the survival of all the above listed species.
By protecting wildlife, this bill ensures that recreational opportunities available to local residents and other visitors are enhanced. Imagine meadows that are alive with singing birds, lakes and rivers full of vibrant fish, and forests that are home to big mammals – it is this type of environment that provides for great recreational opportunities, including local tourism. It is this type of environment that also guarantees a great supply of quality drinking water. Imagine – obtaining two great benefits through one simple action.
For all the above reasons, New York City Audubon heartily supports the measures called for in Intro. No. 375
NYC Department of Environmental Protection letter
December 7, 2006
Ms. Emily Lloyd
Commissioner
New York City Department of Environmental Protection
59-17 Junction Boulevard
Flushing, New York 11373
Re: Recommendations of the Jamaica Bay Watershed Protection Plan Advisory Committee
Dear Ms. Lloyd:
New York City Audubon is a 10,000 member organization that protects wild birds and habitat in the five boroughs, improving the quality of life for all New Yorkers. Since 1981 we have been involved with the protection of Jamaica Bay, its wildlife habitat, its watershed, and the improvement of its water quality.
In reviewing the recommendations put forward by the Jamaica Bay Watershed Protection Plan Advisory Committee, NYC Audubon urges New York City Department of Environmental Protection (DEP) – the primary steward of Jamaica Bay’s water quality – to seize the opportunity to restore this important natural resource to its historic glory for the benefit of all New Yorkers.
At the heart of the Committee’s recommendations is a vision of a healthy bay that provides city residents with swimmable and fishable waterways in the City’s last remaining large wetland system. But today, the City’s sewage treatment plants daily release into the Bay approximately 300 million gallons of treated wastewater, containing thirty to forty thousand pounds of nitrogen. The Bay’s marshes are believed capable of removing only between a tenth and a fifth of these nitrogen inputs.
In order to reclaim our Bay, several key Priority Recommendations related to water quality must be implemented as soon as possible:
* Upgrade the 26th Ward and Jamaica Wastewater Treatment Plants to tertiary treatment to reduce nitrogen inputs into the Bay
* Minimize direct discharge of stormwater into Jamaica Bay through retention and post rain event treatment and by capturing and diverting the first flush stormwater from separate stormwater systems to Water Pollution Control Plants for treatment.
* Institute rezoning that will encourage the retention of natural permeable surfaces such as tree pits, lawns, gardens and unpaved parkland thereby reducing stormwater runoff.
The improved water quality that will follow from the implementation of these key recommendations will restore the Bay’s wetlands and marshes, many of which are disappearing at an alarming rate. Improved water quality coupled with functioning wetlands will then guarantee the ecological integrity of the Bay.
Not dealing with the high nitrogen levels and pollution head on will result in superficial improvements at best, while also wasting precious public resources. Without robust action, wetlands – which form the basis for a healthy, functioning natural system – will continue to disappear at an alarming rate.
We understand the tremendous cost involved in upgrading Jamaica Bay’s wastewater treatment centers to tertiary levels and in implementing an effective stormwater capture and treatment system, but we also recognize that there is no other credible way to protect, and restore, this vital watershed.
NYC Audubon urges you to take a bold and forward looking approach when preparing Jamaica Bay’s Watershed Protection Plan; one that will protect this vital natural resource for the benefit of current and future city residents.
Sincerely,
Peter Rhoades Mott
President of New York City Audubon
Cc:
Mayor Michael Bloomberg
Denise M. Sheehan, Commissioner, DEC
Joe Pane; DEC region 2
James F. Gennaro, New York City Council Member
Brad Sewell; Jamaica Bay Watershed Protection Plan Advisory Committee
Cadman Plaza letter
December 16, 2005
Commissioner Adrian Benepe
New York City Parks & Recreation
Central Park Arsenal
830 Fifth Avenue
New York, NY 10021
Dear Commissioner Benepe:
New York City Audubon is a grassroots community that protects wild birds and
habitat in the City, improving life for all New Yorkers. Representing over 10,000
members in the five boroughs, I urge you to oppose the use of artificial turf in
downtown Brooklyn's Cadman Plaza Park and instead support the restoration of the
Park's natural lawn.
Cadman Plaza Park is one of only a few large grassy areas in downtown Brooklyn.
We are concerned that the replacement of this large lawn with artificial turf, in this
area and in the city as a whole, will have a detrimental effect on the amount of food
available to birds and other wildlife, including insects and other small creatures.
We believe that a living, breathing park is of tremendous value not only to wildlife,
but also for the many residents of downtown Brooklyn. It provides people with an
opportunity to relax and enjoy a respite from the busy urban pace. For this reason,
we strongly believe that the restoration of the large lawn should be a top priority.
While artificial turf represents an easy solution for Cadman Plaza, we believe it
would do a disservice to local residents and wildlife. We strongly urge you to
abandon the artificial turf option, and focus instead on making the necessary
improvements to the grassy areas.
Thank you for your attention to this important matter.
Sincerely,
E.J. McAdams
Executive Director
Governors Island letter
November 16, 2005
Governors Island Preservation and Education Corporation
10 South Street, Slip 7
New York, NY 10004
The following are comments of New York City Audubon. With 10,000 members we are
the largest of the National Audubon Society’s 500 chapters and a participating chapter of
the Audubon Council of New York State. As our mission states, New York City
Audubon is a grassroots community that works for the protection of wild birds and
habitat in the five boroughs, improving the quality of life for all New Yorkers.
Accordingly, while many of our members share interests in such vital matters as historic
preservation and applaud plans for the north end of the island, our comments relate
specifically to our mission and the future of the southern section, known as South Island.
First of all we want to thank you for the presentation at the Fashion Institute of
Technology outlining the various proposals for future development of Governors Island.
As our board member, Geoffrey Cobb Ryan, said at that meeting, he was struck that there
was no mention of birds in the proposals, nor was there mention of plantings of trees,
shrubs or grasses native to the Northeast coastal region that would help re-create habitat
attractive to birds and once present on Governors Island.
New York City is an important location on both the Atlantic and Hudson River flyways
for migrating birds. After flying long distances and arriving in the metropolitan area,
birds seeking sustenance see an astonishing landscape of high and low-rise buildings and
paved-over streets and parking lots. Oases, such as the City’s major parks, are relatively
few. This is particularly true in Lower Manhattan and western Brooklyn, which lack
substantial green space where birds can rest and feed and where residents can enjoy the
natural world.
Governors Island, with its location in New York Harbor and adjacent to lower Manhattan
and western Brooklyn, has the potential to become once again an important landfall for
some of the millions of birds that course along the Atlantic flyway, to serve as excellent
habitat for birds that live or over-winter in the City, and to provide that natural open
space that is balm for the soul of urban residents.
Accordingly, New York City Audubon advocates for the Minimum Build Island, which
would see all the buildings of South Island demolished; no new buildings(there are
portions of North Island still available for new buildings); and a basic park and open
space. Converting the currently rather barren acreage on South Island and particularly
around the shoreline to parkland vegetated with trees, shrubs, grasses and flowering
plants native to the northeastern coastal region, could turn those portions of the Island
into a great natural resource for birds and a sublime open space for New Yorkers starved
for access to nature. (We should mention here that native species of plants can be every
bit as beautiful and interesting as non-natives, which can become invasive and may not
provide the foods that our native birds adapted to thousands of years ago. Used in
abundance on Governors Island, they could also help to re-establish native plants in other
areas around the harbor.) The Minimum Build Option is the most economical and
perhaps the most environmentally beneficial of the options.
New York City Audubon could also support a combination of Minimum Build with other
options that, while more expensive and requiring some new building, would provide
significant opportunities for ecological research and education, related to both the island
and the harbor. Of course, we would recommend that a primary environmental value of
such a combination be the utilization of native vegetative species. The concept of creating
a breach in the seawall and a natural coastal wetland is particularly appealing to New
York City Audubon, as would creation of a freshwater or brackish pond and wetland.
Governors Island represents an extraordinary opportunity for the appropriate educational
institutions to establish such a research and educational program and facility.
Large scale natural areas, coupled with the historic buildings of the north end and an
esplanade with spectacular views of harbor and City from every vantage point would
make Governors Island a world-class park and destination point, a powerful attraction for
residents and tourists alike.
Therefore, New York City Audubon encourages the Governors Island Preservation and
Education Corporation:
• To opt now for pursuing the options described above and for eschewing the more
expensive and ecologically disruptive options;
• To commit the necessary funds, be it $200 or $300 million, now for infrastructure
needs, particularly for removal of buildings on South Island and for creation of natural
areas;
• To commit now to an esplanade with substantial native plantings along the
shoreline of the entire island;
• To restrict development of physical buildings, except as needed for
environmental research and education, to appropriate sites on North Island.
Historically Governors Island has served the civic good, albeit with limited access for
ordinary citizens. When it was transferred from federal to State/City control, the vision
was to create a space that would provide great public, as opposed to private, benefit. With
parklands and other public spaces delineated and created now, would-be developers of
other projects would be compelled to tailor their plans to accommodate the public good.
Without such advance planning and development, private interests will determine what
areas should be reserved for public use, a certain recipe for parklands being relegated to
the least desirable locations and to a lack of the environmental planning that would
ensure the best use of the land for both birds and the public.
Additionally, in conjunction with New York City Audubon’s Project Safe Flight, we ask
that any new buildings be designed and constructed utilizing the latest materials and
techniques for building bird-friendly structures. It is estimated that 100-million birds a
year are killed by collisions with buildings, particularly windows, in the United States
alone. Bird friendliness is a rapidly developing field of the green architecture movement
and is becoming a major concern of municipalities in the United States and Canada. It
seems appropriate that, as Governors Island is developed as a natural resource for birds
and people, that any new structures pose as little threat to avian well being as possible.
Thank you for your consideration of these matters.
Sincerely,
E.J. McAdams
Executive Director
Gennaro letter
December 9, 2005
Council Member James F. Gennaro
185-10 Union Turnpike, Fresh Meadows
Fresh Meadows, New York 11366
Dear Council Member Gennaro:
New York City Audubon is a grassroots community with over 10,000 members
throughout the five boroughs. It protects wild birds and their habitat in the city,
improving the lives of all New Yorkers. I am writing to thank you for your
leadership involving two very important bills – the Jamaica Bay Protection Act
(Int. No. 565-A) and the Wetlands Protection Bill (Int. No. 566-A). Throughout
this process, your commitment to our city’s wetlands has been a true inspiration to
many people in our organization.
Wetlands are a vital part of a healthy environment and are the most biologically
diverse of all the ecosystems on earth. In addition to providing habitat and
feeding grounds to countless birds and other animals, wetlands play a vital role in
water filtration and buffering against floods and shoreline erosion. This later
benefit has been underscored by the recent events of Hurricane Katrina in New
Orleans and surrounding areas. It is estimated that over 80% of New York City’s
historical wetlands have been developed. The two bills you helped pass into law
will greatly assist in the protection of the remaining areas, benefiting both current
and future city residents.
We also thank you for the role you played in securing a seat for NYC Audubon on
the Wetlands Taskforce. We are honored to serve in this important role and
commend you for your commitment to the future and health of the City of New
York.
Warmest Regards,
E.J. McAdams
Executive Director
Bloomberg letter
December 9, 2005
Mayor Michael R. Bloomberg
City Hall
New York, NY 10007
Dear Mayor Bloomberg:
New York City Audubon is a grassroots community with over 10,000 members
throughout the five boroughs. It protects wild birds and their habitat in the city,
improving the lives of all New Yorkers. I am writing to thank you for signing
into law the Jamaica Bay Protection Act (Int. No. 565-A) and the Wetlands
Protection Bill (Int. No. 566-A) and for your continued commitment to New York
City’s environment.
Wetlands are a vital part of a healthy environment and are the most biologically
diverse of all the ecosystems on earth. In addition to providing habitat and
feeding grounds to countless birds and other wildlife, wetlands play a vital role in
water filtration and buffering against floods and shoreline erosion. This later
benefit has been underscored by the recent events of Hurricane Katrina in New
Orleans and surrounding areas. It is estimated that over 80% of New York City’s
historical wetlands have been developed. The two bills passed into law will assist
in the protection of the remaining areas and benefit both current and future city
residents.
With the signing of these two bills, you have once again demonstrated your
commitment to the city’s environment. We commend you for your efforts in
securing the environment of our city and its surrounding communities.
Sincerely,
E.J. McAdams
Executive Director
Re: Intro 470 - Crime Reporting in Parks
March 30, 2005
Honorable Gifford Miller
Speaker of the City Council
City Hall
New York, New York 10007
Re: Intro 470 - Crime Reporting in Parks
Dear Speaker Miller,
I am writing to you on behalf of NYC Audubon's 10,000 in the five boroughs members to urge you and the entire Council to make Intro 470 a law as soon as possible.
By requiring regular reporting by the New York City Police Department to the New York City Council on crime that occurs in parks, this bill will help ensure good government practices. It will also enable NYC Audubon to advocate on behalf of parks, making them safer for birders. This bill would also improve the protection of natural areas located in parks. The protection of natural areas is the focus of NYC Audubon and New Yorkers for Parks' (NY4P) Natural Areas Initiative. A brochure detailing this initiative is included with this letter.
With your leadership, Mr. Speaker, 42 other council members have already recognized the need to track and report on crime in parks. In addition, on February 3, 2005, there was an in-depth hearing before the Public Safety Committee where more than 40 groups and individuals from throughout the City came forward in support of this bill.
Given the overwhelming support for this bill, as well as its role in making our city parks safer, we ask you to pass Intro. 470.
Thank you,
E.J. McAdams
Executive Director
NYC Audubon Oppose Access to Harbor Heron Islands during Breeding Season
New York City Audubon uses its experience and expertise to testify before the Waterfronts Committee of the City Council about the egrets, herons and ibis that nest on the islands of NY Harbor. The testimony, along with more information about the Harbor Heron Islands including a recently completed Nesting Report, can be found on our Harbor Heron Islands project page.
Comments on the Draft Environmental Impact Statement for the Belleayre Resort at Catskill Park
Submitted by
New York City Audubon Society
E. J. McAdams, Executive Director
April 21, 2004
Mr. Alexander F. Ciesluk Jr.
New York State Department of Environmental Conservation
21 South Putt Corners Road
New Paltz, NY 12561-1696
Dear Mr. Ciesluk:
Re: Proposed Development of Belleayre Resort at Catskill Park
The following are the comments of New York City Audubon concerning the above-referenced development proposal and associated Environmental Impact Statement.
Since its founding in 1979, New York City Audubon has advocated for protection of the watersheds and reservoirs that provide water to over nine million residents of the City and State. Indeed, New York City Audubon was a registered intervenor in opposition to the proposed Prattsville Pumped Storage Power Project that would have had profoundly deleterious impacts on water quality in the Schoharie and Ashokan Reservoirs and the Esopus Creek. New York City Audubon also has a long history of advocating for the natural resources of both the Catskill and the Adirondack Parks, which were established more than 100 years ago in the State Constitution to protect those regions from the grandiose schemes and depredations of would-be developers and lumber barons. New York City Audubon has supported the establishment of the Watershed Agricultural Council and, subsequently, the historic New York City Watershed Memorandum of Agreement, both of which serve to protect water quality while enabling relatively benign economic development in the watersheds of the Catskill Region and Park.
In addition, New York City Audubon is a member of the Audubon Council of New York State, which has resolved that it is opposed to this project as proposed. It is noteworthy that the Council's resolution was moved and seconded by the Northern Catskills Audubon Society and the Sullivan County Audubon Society, both having territory within the Catskill Park.
New York City Audubon has a particular interest in this proposal for reasons related to its longstanding concerns and the Audubon mission of protecting birds, other wildlife and their habitat.
The proposed project threatens water quality in both the Ashokan and Pepacton Reservoirs, the largest components, respectively of New York City's Catskill and Delaware Water Supply Systems. The United States Environmental Protection Agency has granted the City a "filtration avoidance" waiver for water from both of these systems. Loss of that waiver would force the City to build a mammoth filtration plant at a cost to water-and-sewer rate payers in the City (and many more in Westchester County) of anywhere from $4 billion to $8 billion in capital costs, plus annual maintenance and operation costs in the hundreds of millions of dollars.
Belleayre Mountain is at the edge of the "Catskill Important Bird Area" as identified by scientists associated with Audubon New York (the state office of the National Audubon Society). The Catskill Important Bird Area is one of the largest, most intact contiguous habitats for the assemblage of forest responsibility species in the Appalachian Mountains Bird Conservation Region part of New York State. Responsibility species are those that rely on the particular habitat of a region for their long-term conservation because they are found at high relative abundances and/or have a disproportionately high percentage of their populations in the particular Bird Conservation Region. The forest assemblage of the Appalachian Mountain Bird Conservation Region is composed of the following species: Black-and-white Warbler, Black-billed Cuckoo, Black-throated Blue Warbler, Blue-gray Gnatcatcher, Canada Warbler, Cerulean Warbler, Eastern Wood-Pewee, Hooded Warbler, Least Flycatcher, Louisiana Waterthrush, Northern Flicker, Rose-breasted Grosbeak, Scarlet Tanager, Sharp-shinned Hawk, Wood Thrush, Worm-eating Warbler, Yellow-throated Vireo. Many other more common species also nest within the region. While not all of the above-listed species breed within the Catskill Important Bird Area or on Belleayre Mountain, most do and all may utilize the region during migrations before and after the breeding season. Massive development, such as the proposed Belleayre Resort, would cause fragmentation of this habitat and would destroy the functionality of a significant segment of this important Bird Conservation Region.
The development may be the largest scheme proposed since the Constitution sought to protect vast areas of the Catskill Park. It is the very antithesis of "Smart Growth," the planning concept that discourages urban/suburban/rural sprawl, encourages preservation of open space, and supports growth utilizing existing infrastructure and population centers. Audubon New York has been a leader of the smart growth movement. New York City Audubon, as well as other Audubon chapters in the state, has supported various smart growth initiatives. And, under the current administration, smart growth concepts are being utilized in policies and programs on New York State government. (The developer's restoration of the Emerson Hotel at Mount Pleasant is the kind of smart growth project that New York City Audubon applauds.)
The project would encompass two sites on 1,960 acres in the scenic Central/Western Catskills. Proposed are an extraordinary number of buildings, connecting roadways and other impervious surfaces -- two large hotels with 400 rooms, multiple restaurants, shops, spas, swimming pools and tennis courts, 98 buildings with 256 detached lodging units, a 21-lot residential sub-division, and assorted outbuildings. The enormity of the project makes it larger in scope than any of the fabled and failed grand hotels that were developed more than a century ago. And, at an average of two persons per unit (conservative), the population of 1,354 is larger than most of the villages and all of the hamlets in the Catskill Region.
To construct the buildings, roads, golf courses and related facilities, the developer proposes to radically re-configure the landscape, not only by timbering hundreds of acres, but by detonating explosives in bedrock and moving earth around with heavy machinery. (Hundred-year-old trees may be second growth, but they are still mature, vital components of the existing environment that clean our air and provide scenic amenities, food and shelter for birds and other wildlife.) The associated destruction and construction would disrupt the neighborhood, environment and wildlife over an eight-year period. No matter the care claimed in the Impact Statement, erosion of this steeply sloped landscape certainly would occur and inflict its damage on local waterways, some of which are valuable trout streams, and the Ashokan and Pepacton Reservoirs. The completed project would remove permanently the ravaged acreage from its former natural functions and present two massive eyesores in this most scenic section of the Catskill Park.
Each of the sites would require a wastewater treatment facility. Treated wastewater would contain phosphorus, a contaminant that encourages growth of algae that, in turn, cause water quality problems in reservoirs. The Ashokan Reservoir, being within the 60-day travel time of the City as defined in the Watershed Memorandum of Agreement, is subject to limitations on coliform input and total maximum daily loads of phosphorus. The project would not only increase loads, but might deprive others with more modest ambitions of the ability to build. Additionally, the developer apparently wishes to utilize New York City's Pine Hill Wastewater Treatment Plant to accommodate wastewater from the Big Indian Plateau portion of the project. Since this project presents numerous threats to the water quality of its two largest reservoirs, it would be foolhardy of the City to accommodate the developer. While the Pine Hill Plant currently has some excess capacity, accepting wastewater from this project would be prejudicial to the future needs of the residents of Pine Hill and to the best interests of water quality in the City's Ashokan Reservoir. Existing homes, currently outside the sewer district and reliant on possibly faulty septic systems, and new houses could be prevented from tying into the village's sewer system - initiatives that might be protective of water quality in Birch and Esopus Creeks and the Ashokan Reservoir.
Each of the two locations would have 18-hole golf courses, notorious for their use of pesticides that have adverse impacts on water quality and a wide range of biota, including amphibian, aquatic, avian, human, mammalian, reptilian and insectivorous life. Fertilizers, along with treated wastewater, would add phosphorus to the waters feeding Ashokan and Pepacton Reservoirs. Proper control of storm water and prevention of related pollution is virtually impossible on sites of the size and steeply sloped terrain associated with this project. Pesticides and fertilizers from lawns and golf courses along with pollutants in waste and storm water would eventually find their way into the aquifers and streams that feed New York City's Ashokan and Pepacton Reservoirs.
Given the drastic droughts of recent years, when the City's Catskill and Delaware System Reservoirs were drawn down to alarmingly low levels, the Impact Statement's assertion that the water supply system of the Village of Fleischmanns would meet both the human consumption and irrigation needs of the project's Wildacres Resort is highly questionable.
Equally alarming as the proposed project itself are the ancillary developments that are likely to occur if the development were to come to fruition.
Over the years, concerned citizens have expressed reservations about New York State Department of Environmental Conservation proposals to expand the facilities of the Belleayre Mountain Ski Center into Catskill Park terrain that is constitutionally designated as "Forever Wild." Over the years, those constitutional provisions have been over-ridden to accommodate such expansions and, should the Belleayre Resort come to pass, there would be increased demands for further expansions. This is not only contrary to the Constitution; it is contrary to the vision of the Catskill Park as a natural amenity for all New Yorkers as opposed to those who can afford expensive ski equipment and the proposed resort's luxurious accommodations and amenities.
The Environmental Impact Statement makes some astonishing claims. One is that, "The project will have few, if any, impacts or increased demand on community resources. The roadways will be private with private security. The vacation Resort will add few, if any, students to the local school systems which are not running at capacity in any case." Elsewhere the statement extols the benefits of the project for local communities. Among them would be 3,879 of full-time and indirect or generated employment during the construction period and another 1,083 full-time, part-time and seasonal employment when the project is fully operational.
When thousands of workers and resort users, whether permanent or transient, are added to a population, there is an increased demand for law enforcement services. It was precisely such demand that led to the formation of the New York City Department of Environmental Protection Police Department nearly 100 years ago. At times, DEP Police have provided the only 24-hour law enforcement coverage in Delaware County. Currently, courts in Delaware County are declaring that citations issued by DEP Police are null and void. Accordingly, there have been increased demands on other enforcement agencies in the county and lessened effective highway patrols. The notion that private security, without legal standing, can take the place of official police officers on the project property is a pipe dream. The implied notion that resort guests and employees won't involve law enforcement agencies off the resort grounds is ingenuous, to say the least.
Conversely, the developer's proposal promises local merchants great benefits from all the shoppers that will come from the resort to their businesses. Given the developer's demonstrated penchant for commercialism, it is more likely that the many shops, restaurants and other facilities at the resort would draw business away from existing businesses in local villages and hamlets - the exact opposite of smart growth principles.
As is well-known, many of these employment opportunities would be filled not by the local populace, but by people who presently live outside the region. Many of those people would want or need to move to the area, and many of those, e.g. chamber maids and maintenance workers, would be in the lower economic brackets, who, along with part-time and seasonal employees, would be likely candidates for unemployment, welfare and Medicaid assistance and other social services.
Employees moving to the area would create demands for more residential housing than may be available or affordable. Since most developable land in the area lies in the lower lying stretches near roadways, waterways and flood plains, new construction would add more impervious surfaces, more rushing storm water and more threats to water quality. Children would utilize schools and travel on buses, families would require all the other community resources - ambulance and medical services, hospitals, social services, libraries, shops, parking lots, etc. - that citizens in every community demand.
Virtually all resort workers and visitors would drive along the Route 28 corridor. The Impact Statement claims that, "a detailed microscale air quality analysis is not necessary since this project will not increase traffic volumes, reduce source-receptor distances or change other existing conditions to such a degree as to jeopardize attainment of the national and New York State ambient air quality standards for carbon monoxide."
The dramatic increase in motor vehicles and buildings emitting airborne pollutants would certainly impact adversely the region's air quality. In addition, Route 28, arguably the most scenic main road in the Park, is already a heavily traveled two-lane road that is the main corridor through the central Catskills. With the addition of literally thousands of vehicles utilizing Route 28 on a busy day, resultant periods of heavy traffic would cause accidents and lead to demands for creating a four-lane highway. The Impact Statement's claim that, "an increase in traffic of this magnitude will typically not be noticeable" is laughable to anyone familiar with Route 28. Additional vehicles mean additional pollution from petroleum products that leak to the roadways from vehicles. That, in turn, means more pollutants washing off roadways into streams that feed the reservoirs. It should be noted that many coniferous trees along Route 28 appear to be dead or dying, no doubt because of winter de-icing materials and roadway pollutants in combination with vehicular exhaust emissions and acid rain.
Associated with that increase in traffic, would be development of roadside shops and other businesses. The notion, as expressed in the Impact Statement, that "a significant amount of new [commercial] construction" is not anticipated, ignores the realities of the commercial impulse in America. Over the years, a progression of "miracle mile" development along Route 28 has steadily advanced westward from New York State Thruway Exit 19 at Kingston into the Catskill foothills and in isolated areas within the Park itself. Construction of the proposed development at Belleayre would inevitably invite more of these commercial ventures, which blight the American landscape wherever they appear, and would most assuredly detract from the scenic and natural values of the Catskill Park. Inevitably, pollutants from their parking lots and related impervious surfaces would be carried by storm and ground water to the streams that course along the Route 28 corridor and ultimately feed the Ashokan and Pepacton Reservoirs.
The developer has been quoted as saying that the Belleayre Resort would "save the Catskills." In fact, it would ravage the Catskills. In his book, Green Enchantments: A Catskill Outdoor Guide, Michael Boyajian characterizes the Catskills as "an island of biodiversity." The proposed project would do substantial damage to that biodiversity and to the concept behind the creation of the Catskill Park. The resort would be contrary to the best interests of the citizens of New York State and the Catskills and of the consumers of water from New York City's Catskill and Delaware Water Supply Systems.
It would be ironic, indeed, if allowing this project for private gain would force the residents of New York City and some upstate communities to spend billions of dollars on a filtration plant for waters from the Catskill and Delaware Systems. It would be ironic, indeed, if the people of New York State were deprived of their right to enjoy the scenic and natural amenities of this portion of the Catskills because of a developer's grandiose schemes. It would be ironic, indeed, if birds and other wildlife were deprived of their homes because of the inevitable fragmentation of habitat that would occur should this project be allowed to go forward.
Sincerely,
E. J. McAdams
Executive Director
Scoping comments regarding the proposed NASCAR project
April 25, 2006
Robert Dobruskin, Director
Envtl. Assessment & Review Div.
City Planning Commission
22 Reade Street, Room 4E
New York, NY 10017-1216
Re: Comments for the scoping phase of the proposed Motorsports Entertainment Complex on Staten Island, CEQR No. 05DCP043R
Dear Mr. Dobruskin:
Please accept New York City Audubon's comments regarding the proposed Motorsports Entertainment Complex on Staten Island. Our comments on the scoping document concern only issues related to NYC Audubon's mission which reads as follows: NYC Audubon is a grassroots community that works for the protection of wild birds and habitat in the five boroughs, improving the quality of life for all New Yorkers. The proposed project will affect a special natural area which has been described in detail in Peter Blanchard III's An Islanded Nature. Given the extent of this project, we are very concerned about adverse affects to birds and habitat at this site.
We strongly urge that the Natural Resources, Air Quality, and Noise sections of the Environmental Impact Statement (EIS) address in detail the following important issues:
1. Wetland Habitat:
The applicant has proposed the preservation of significant acres of wetlands. The EIS should fully describe how these wetlands will be managed as well as how to secure their preservation. While these issues may be addressed in New York State Dept. of Environmental Conservation (NYS DEC) permitting actions, the full integration of this approach into the overall environmental impact analysis should be developed during the EIS stage. Most importantly, NYC Audubon is requesting that specific guarantees be put in place so that the wetland habitat may be preserved in perpetuity. Such guarantees would be in the form of conservation easements, deed restrictions, or similarly enforceable arrangements.
The EIS should also evaluate if and how the proposed wetland mitigation plan will add foraging habitat to be used by long-legged wading birds.
2. Upland Habitat:
The plan calls for the destruction of approximately 90 acres of upland habitat which will then be replaced by grass parking/open space. The EIS should conduct a complete inventory of the animal and plant communities in these areas, and qualified research scientists should pay special attention to species that are listed by NYS DEC or United States Fish and Wildlife Service as endangered or threatened. Given the potential enormous impacts to wildlife from the destruction of the coastal meadows and forest, alternatives to habitat destruction should be explored in depth, including the option of making this area a wildlife preserve. The developer should also provide sound reasoning for not including the lawn parking area within the major off-site parking in New Jersey.
Additionally, the creation of grass areas could attract grassland birds to nest in the parking area only to have their nests destroyed by mowers. This possibility should be evaluated, and if required, a management plan to prevent the creation of fatal breeding traps should be put in place.
3. Leaded Gasoline:
Concerns have been raised with NASCAR events in other locations about the impact of the use of leaded gasoline in racing vehicles from the stadium on local wildlife. A full study of these impacts should be conducted and an analysis of the project using alternative fuels should be developed.
4. Noise:
Concerns have been raised with NASCAR events in other locations about the impact of noise on the surrounding environment. A detailed study should evaluate the noise impacts on the wildlife in the area.
5. Heliport:
The large heliport planned for the site could adversely impact wildlife, including the various birds that breed at the site. These impacts should be examined and alternatives should be considered.
6. Impacts to Specific Bird Species:
For over 20 years NYC Audubon has conducted a regular census, called the Harbor Herons Project, to monitor the wading bird population on the islands of the Arthur Kill. As stewards of these nesting sites, it is very important for NYC Audubon to ensure that future re-colonization of Pralls Island, the island closest to the project site, is not hampered by this project. The site on which the Motorsports Center is proposed has also been recognized as a significant natural area and habitat for birds and is adjacent to an internationally recognized Important Bird Area. Michael Burger and Jillian Liner note in the 2005 Important Bird Areas of New York that "the islands and associated wetlands found here have supported large proportions of the state's wading birds." They stress that "success of the colonies requires ample foraging areas, many of which remain unprotected."
Given the importance of this site, the impacts of waterfront traffic, the aforementioned air quality and noise issues should be specifically addressed with respect to the herons, egrets, and ibis that nest and forage on and around the proposed development site.
7. Bird Collisions with Glass:
Careful analysis of the construction of the stadium, retail center, and other structures should address measures and materials to avoid the problem of bird collisions with glass. Avian fatalities from glass collisions are the second greatest threat (after habit loss) to bird populations; notable researcher Daniel Klem estimates that over 100 million victims are claimed annually in the United States alone. The material and design, including lighting and landscaping must be fully addressed in the EIS with respect to bird/glass collision.
We note that the applicant has named NYC Audubon as a research resource for the Natural Resources and Water Quality Analysis. Therefore, specific relevant research done by NYC Audubon and our Audubon affiliates with respect to the aforementioned issues should be included for analysis.
We look forward to reviewing the draft EIS.
Sincerely,
E.J. McAdams
Executive Director
Cc:
Amanda Burden; Dept. of City Planning
John Merolo; City Planning Commission
Ethan Goodman; Wachtel & Masyr, LLC
Michael P. Printup; International Speedway Corporation
James P. Molinaro; Staten Island Borough President
City Council member James S. Oddo
City Council member Michael E. McMahon
City Council member Andrew Lanza
Congressperson Vito Fossella
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