CDM 2004 FEIS Aqueduct Connection

Transcription

The Village of I<iryas Joel
Final ~ n v ~ r o n ~ @ Impact
n t a l Statement
e FrQpOSedCOIln@ctiOntO the
New York City Catsltill Aqueduct
May 2004
Final Environmental Impact Statement
Village of Kiryas Joel
Proposed Connection to the
New York City Catsltill Aqueduct
Project Location:
Between Vails Gate and Iciryas Joel
in
Orange County, New York
Lead Agency:
Board of Trustees of the Village of Kiryas Joel
Municipal Building
51 Forest Road, P.O. Box 566
Monroe, NY 10950
Lead Agency Consultant:
Camp Dresser & McI<ee
Raritan Plaza I
Raritan Center
Edison, NJ 08818
Project contacts:
MI. Gedalye Szegedin
Village Clerk
P . 0 Box565
Monroe, NY 10950
(845) 783-8300
Mr Henry Boucher, P.E ,DEE
CDM
Raritan Plaza I, Raritan Center
Edison,NJ 08818
(732) 225-7000
Date of Acceptance by Lead Agency:
May 4,2004
Prepared for:
Prepared by:
Camp Dresser & McI<ee
Contents
Section 1
Introduction...................................................................................................
Section 2
Responses to Specific Comments............................................................
..
'1-1
..2-1
Appendices
Appendix A
Appeizdix B
Appendix C
Transcript of Public Hearing
Wxitten Comments on the DE,IS
Letter from New York State Office of Parks, Recreation
and Historic Preservation
i
Section 1
Introduction
Section 1
ntroduction
The residents of the Village of Kiryas Joel currently depend on groundwater wells for their
entire supply of potable water. Tlie existing water supply system in the Village of Kiryas Joel
includes nine active groundwater production wells and two water treatment plants,
The current average daily water demand in the Village of Itiryas Joel is approximately 0.98
million gallons per day (mgd), and peak daily water demand exceeds 1.3mgd. NYSDEC has
authorized Itiryas Joel to withdraw 1.0 mgd from nine wells in Kiryas Joel and 0.,31mgd from
five wells in an unincorporated area of the Town of Monroe near Mountain Lakes, for a total
of 1.31mgd. Due to internal growth and the corresponding increase in water demand, wells
in the Village have been heavily used, causing a net decrease in their output.. Since the Village
wells are no longer capable of producing the maximtun permitted yield, Iciryas Joel's water
system is unable to supply enough water on days of high demand To overcome the supply
deficit, the Village is occasionally forced to truck in additional water in preparation for
religious holidays, when peaks of water demand often occur.,The yield of the Village's water
supply system is only marginally capable of meeting the current demand of approximately
0.98 mgd. Under the frequent peak water demands, the water supply is inadequate.
The purpose of the proposed action is to provide a reliable and adequate supply of highquality potable water for the Village of IGryas joel. The Village of Kiryas Joel's existing water
supply system is minimally adequate for its present population, and the V i a g e will need
increasing amounts of potable water as it continues to grow As the rate of groundwater
withdrawal in the vicinity of Kiryas Joel grows larger in comparison to the groundwater
recharge rate, it will become increasingly difficult for a gro~mdwater-dependentsystem to
maintain an adequate water supply for a growing community,, To increase the reliability of
its potable water supply, Itiryas Joel needs to gain access to a substantial source of surface
water. The Catskill Aqueduct is the best available source of surface water.
The Village of I<iryasJoel proposes to connect to the Catskill Aqueduct near Riley Road in the
Vails Gate section of the Town of New Wmdsor. The Vails Gate location is proposed because
it is just upstream of the point where the aqueduct descends more than 1,000 feet to cross
under the Hudson River.
Water would be withdrawn from the Catslcill Aqueduct using a vacuum priming system, and
the water would be conveyed to a pump station. The water would be pumped through a 13mile pipeline that would follow State Route 94, County Route 27, State Route 208, and State
Route 17. The pipeline would end at a new water treatment facility adjacent to the site of the
existing water treatment facility on Berdichev Road in the Village of Kiryas Joel., After
treatment, the aqueduct water would be fed into the Village's water distribution system.
In September 2000, the Village of Itiryas Joel filed a n official request with NYCDEP for
conceptual approval to establisli a connection to the Catskill Aqueduct designed to withdraw
up to 2.,0mgd of water. In a letter dated November 27,2000, NYCDEP conceptually approved
1-1
Section 1
Introduction
the proposed connection and withdrawal of water. The letter acknowledged the Village's
estimate that Kiryas Joel would be entitled, pusuant to the NYC Administrative Code 524360(e),to withdraw 1 1mgd based on its population as measured by the 1990 Census. Based
on the 2000 Census, KiIyas Joel would be entitled to withdraw approximately 1.9 mgd,.
NYCDEP must still grant final approval of the proposed connection to the Catskill Aqueduct
Project development began with the examination of different potential technologies, various
pipeline routes, various water treatment plant and pump station locations, various pipeline
size alternatives and the preparation of a series of environmental documents in compliance
with the State Environmental Quality Review Act (SEQRA) procedures, On July 2,2002, the
Board of Trustees of the Village of ICiryas Joel circulated a Notice of Establishment as Lead
Agency to potentially involved agencies associated with the proposed action, Also included
in that correspondence was the full SEQRA Environmental Assessment Form (EAF) and the
Board's intention, if determined to be Lead Agency, to prepare a Positive Declaration for this
Type 1action, thereby requiring the preparation of an Environmental Impact Statement (ETS).
On August 6,2002, the Board officially assumed the role of Lead Agency for the Catskill
Aqueduct Connection project and issued a Positive Declaration. On April 2,2003 the Village
of IGryas Joel issued the Draft Scoping Document for the Environmental Impact Statement for
the Proposed Connection to the New YoIk City Catskill Aqueduct, notice of which was
published in ENEL A 23-day comment period was established where public and agency
comments were requested to be received by April25,2003 foI consideration by the lead
agency. The Final Scoping Document was adopted by the lead agency on June 3,2003, On
October 7, 2003, the Draft Environmental Impact Statement (DEIS) was deemed complete and
made available for public review, with an esiablished 49-day public and agency co&ent
period. For the purpose of receiving comments on the DEE, a public hearing was held at the
Ezras Choilim Health Center in the Village of Kiryas Joel on November 14,2003,.Comments
were received until November 24,2003 marking the end of the DEE comment period,.
i
This Final Environmental Impact Statement (FEE)document contains the substantive public
and agency comments on the DEIS and responses to them. Appendix A contains a hanscript
of the public hearing. Written public hearing statements and written comments received by
the Village of Kiryas Joel are reproduced in their entirety in Appendix B,.
Specific comments were received on elements of the DEE. Each specific comment is
identified by a two-part number (example: 2-5). The first number (2 in the example) refers to
the person malcirig the comment and the second number identifies successive comments by
the same person (comment 5 in the example). The first commenters listed are those who
spoke at the public hearing, in the order they spoke, followed by those who submitted written
comments in chronological order. The list of commenteIs with his/her assigned number is
provided on Table 1-1.
The comment summaIies were further categorized into subject matter groupings that
correspond for the most part to the sections of the DEIS. The response categories are listed on
'Table 1-2 and are self-explanatory, Also included is Table 1-3which identifies each
1-2
i
Table 1-1
List of Commenters
Public Hearing Speakers
November 14,2003
Commenter No.
1
Name
Charles Bohan
Supervisor of the Town of Blooming Grove
2
Nancy Calhoun
New York State Assembly
3
Paul Aggarwal
New York City Department of Environmental Protecrion
4
Geoff Welsh
Ramapo River Committee
5
Jennie Kiesling
6
Philip Chase
Representative, Deerpark to Upper Delaware Council
I
Manny Mangual
8
Ann Krawet
9
Dr Steven Benardo
Note: Mr Bill Douglass attended the Public Hearing as a Representative of the Upper Delaware Council
At the hearing Mr. Douglass read the Upper Delaware Council’s written comments into the record, The
comments are responded to in Section 2 and are identified as Commenter No 11, Upper Delaware Council.,
Written Comments
Commenter No.
10
Name
11
Upper Delaware Council
12
Village o i Washingtonville
13
Town of Blooming Grove
14
Town of Woodbury (Lorraine McNeill, Council Member)
15
Town of Woodbury (Sheila A COMOY,Supervisor)
16
Orange County
17
New York State Department of Environmental Conservation
18
Arnold M Frogel
New York State Thruway Authority
Table 1-2
Response Categories
for Section 2
PAUL AGGARWALI NYCDEP
WATER DEMAND AND SUPPLY PROJECTIONS
WASTEWATER TREATMENT CAPACITY
BACKUP WATER SUPPLY
WATER ACCESS
REGULATORY REQUIREMENTS AND INVOLVEDKNTERESTED AGENCIES
GROWTH INDUCEMENT
STREAMS
DELAWARE RIVER WATERSHED
M A P 0 RIVER WATERSHED
FLOODING
S TORMWATER
WETLANDS
THREATENED AND ENDANGERED SPECJES
VEGETATION
LAND
BLASTING
HISTORIC, ARCHITECTURAL AND ARCHAEOLOGICAL RESOURCES
POPULATION/DEMOGRAPHICS
FISCAL IMPACTS
COMMUNITY FACILITIES
LAND USEIZONING
TRAFFIC
NOISE
VISUAL
ENERGY
SOLID WASTEKLUDGE DISCHARGE
HAZARDOUS WASTE
CONSTRUCTION
PIPELWE ROUTE
VILLAGE WATER TREATMENT PLANT SITE
ALTERNATE PIPE SIZE
TOWN OF BLOOMING GROVE1 SUPERVISOR CHARLES BOHAN
VILLAGE OF WASHWGTONVILLE
TOWN OF NEW WINDSOR ALTERNATIVES
HUDSON RIVER ALTERNATIVE
WATER CONSERVATION
REGIONAL WATER PLAN
BEYOND THE SCOPE
2-2
2-5
2-10
2-13
2-15
2-16
2-18
2-21
2-23
2-24
2-25
2-26
2-21
2-28
2-29
2-30
2-32
2-33
2-35
2-37
2-38
2-39
2-40
2-42
2-44
2-46
2-48
2-49
2-50
2-51
2-52
2-53
2-54
2-56
2-57
2-58
2-59
2-60
2-62
(
Table 1-3
Commenterl Response Category
Summary Table
TRAFFIC
\ v m % DEMAND AND
SUPPLY PROJEfflONS
tROYrrH
PAUL AGGARWAU
NYCDEP
INDUCE ME^ w A E n DEMAND m n
SUPPLY PROECnONS
R$:!zfiz
TOWN OFBLOOhilNG
Gnaw SuPEnvison UACKUP w A r m SUPPLY
CHARLES BOHAN
G R O W T I INDUCEbIENT
THREAlENED AND
REGIONAL WATER PLAN
ENDANGERED SPECIES
BLASTING
HISTORIC,
ARCHIIEECTUML AND
ARCHEOLOGICAL
mounCES
TRAFnC
I
DELAWAN
rumn
WAlERSHED
BEYGNDTIESCGPE
WAlER ACCESS
GllGWTH INDUCEMEM CGhlMUNlTY FACILITIE
REGIONAL W a l E R PLAN
BEYOND THESCGPE
Table 1-3
Commenterl Response Category
Summary Table
Ill7
NYWCC
I
I
WATER DEMAND AND
SUPPLY PROJECnONS
u A z n DEMAND AND
w a n DEMAND AND
;UPPLY PROJECTIONS
iUPPLY PROIECnONS
WASTEWATER
WASIFWATER
RoWTH lNDUCEhlEM TREATMENT C A P A C I N TREAThlENT CAPACIF
\VASEWATER
NATh.EMC A P A C m
ROWTH INDUCEMEN?
,CKUPWATER
STREAMS
RAhlAPO RIVER
WATERSHED
WATER DEMAND AND
SUPPLY PROJECnONS
BACKUP WATER SUPPLY
REGULATORY
REQUlREhlENTS AND
lNVOLVEol l ~ R C s T E
AGENCIES
REGULATORY
REQUlREbIEMS AND
INVOLVEDIINTERESTED
AGENCIES
Gno'vmlNDUCEMEN
STORhlWATER
GROWTI{ INDUCEMENT
FLOODING
VEGETATION
WELANDS
STREAMS
LAND
HISTORIC,
.RCHlTECTURAL AND
ARCHEOLOGICAL
RESOURCES
LAND
POPULATION/
DEMOGRAPHICS
BLASTING
BLASIING
TRAFFIC
IKC1iI1ECIJIliL i C U
.,IlCIIEO!.OGICIL
illSTORIC
I
1
1ESOURik.S
SOPULATIONI
DEhlOGRAPHICS
ENERGY
LAND USEJZONINC
SOLID W A S N S L U D G I
DISCHARGE
TRAFFIC
NOISE
ENERGY
HAZARDOUS WASTE
PIPELINE R O U E
ALTERNATE PIPE SIZE
IREGIONALWATER PLA
FISCAL IMPACTS
L A N 0 USEJZONING
NOISE
VISUAL
CONSTRUCnON
VILLAGE WATER
TREAThlENT PLANT
TOWN O F NEW
WINDSOR
ALTERNATIVES
!GlONAL WATER SLAi
Secfion 1
Introduction
commenter and the corresponding response categories under which their comments are
addressed.
In order to eliminate the potential for confusion, each comment has been restated, the
comment identification number has been given and the appropriate response follows the
comment., In those cases where the same concern was expressed by several commenters the
comments are listed individually and a single response is given following those comments
summarized., This was done to avoid redundancy.
Those comments that do not pertain to the proposed water supply pipeline project aIe
considered to be beyond the scope of this Final E.nvironmenta1Impact Statement (FE.IS) and
are summarized and placed in the category "Beyond the Scope." No response to these
comments is offered.
The FEIS has been distributed to all involved agencies and is available for public review at the
Village Hall, 51 Forest Road, Monroe, NY.
The FE,IS, which incoIporates the DEIS (October 2003) by Ieference, is intended to provide the
Village of I<iryasJoel Board of Trustees with the environmental information it needs to issue
findings which will form the basis for future decision making on the project. The lead agency
will issue findings after a minimum of ten days from the notice of completion of the FEIS.
1-7
N
Seclion 2
Responses lo Specific Comments
OnSeS to
Specific Comments
All substantive comments, both written and oral, are summarized and reproduced in the text
that follows.,
As previously noted, each specific comment is identified by a two part number (example: 2-5)..
The first number (2 in the example) refers to the person or agency making the comment (or
the second commenter) and the second part identifies successive comments by the same
person (or the fifth comment by that same commenter)., The comment summaries were
further categorized into subject matter groupings that correspond for the most part to the
section of the DEIS.
In order to eliminate the potential for confusion, each comment has been restated, the
comment identification number has been given and the appropIiate response follows the
comment. In those cases where the same concern was expressed by several commenters, the
comments are listed individually and a single response is given following those comments
summarized. This was done to avoid redundancy
Those comments that do not pertain to the proposed water supply pipeline project are
considered to be beyond the scope of this FEIS and are summarized in the category ”Beyond
the Scope.” No response to these comments is offered.
2-1
Seclion 2
PAUL AGGARWAL/
NEW YORK CTTY DEPARTMENT OF ENVIRONMEbIAL PROTECTION
3-2
(
The Aqtredtrct connection has been designed for 2 million gallons per day water consumption.
W m t wejind is tlmt, according to the Village population and probably in the coming couple oj
years, that amount will proba5ly not be enough to meet the water supply needs of the Village.
So the question is how the Village plans to meet their water demand by the year 2020 or men
beyond to supply their consumers?
The proposed Aqueduct connection will meet the current water needs of Kiryas Joel. The
amount of water the Village is legally entitled to withdraw from the Aqueduct will grow in
proportion to the population of the Village.. 'The proposed pumping and water treatment
facilities would have a capacity of approximately 2 million gallons per day (mgd), but the
major element of the proposed project, the pipeline, would have a capacity substantially
greater than 2 mgd,. Water use in Kuyas Joel is projected to reach 2 mgd in approximately
2017 (see table in the response to comments 16-16 and 17-2 below),. If necessary in the future,
the Village could increase the capacity of the pumping and water treatment facilities and,
based on future aqueduct entitlements, request approval from NYCDEP to withdraw more
than 2 mgd from the Aqueduct.
Note: This comment-response is also included in the Water Demand and Supply Projections
response categoxy on page 2-5.
3-2
. . .qthe water supply is only for 2 million gallons zoe kind ofdo not see the point as to why the
(
line should be 24 inches ...Some reasons aregiven were given in the DEIS, but we believe more
reasons need to be done to just$) that.
'The project as proposed includes the use of a 24-inch diameter pipeline to transmit up to 2.0
mgd to the Village of K i p s Joel. This pipeline diameter was initially presented to the
NYCDEP in the conceptual plans for this project,. Given that the pipeline will have a service
life of 50 years or more, the choice of pipeline diameter was based not only on the Village's
current aqueduct entitlement request of 2 mgd but also on potential future entitlements due to
future growth. Also considered was the fact that reducing the pipeline diameter would not
reduce environmental impacts. 'Trench size, construction duration and potential
environmental impacts would be the same for a 24-inch diameter pipeline as for any other
size pipeline. Nevertheless, due to concerns that the pipe is oversized, a reduction in pipeline
diameter to 18 inches would be acceptable.,
Note: This comment-response is also included in the Alternative Pipe Size response category
on page 2-53.
3-3
2-2
I t is not mandatory by US, but the question of backup wafer supply is an important one. From
time to time we do take down our aqueducts for repairs, maintmnce, and any uiZfDreseen
problems. So, therefore, it is rather essential for the Village to have some sort of backup water
supply. Tlze existing water supply they have would have to be maintained, or there has to be
some understanding between the different communities that do take waterfrom the village thnt
i
Section 2
Responses to Specific Comments
when needed the Villnge cniz get thnt water bnck for their ozun cunstimers. The potnztinl likely
degree of relinnce in the Dnckup wnter siipply iniist be nddressed.
3-4
W h t is the stornge cnpncihj Ojtlze Villnge's,foiir wnter storage tanks?
As proposed, the Aqueduct connection would provide water to the Village, and the existing
Village water supply system, which will be regularly maintained, would provide backup to
the Aqueduct connection. The Village of Kiryas Joel currently has four water storage tanks
with a total capacity of approximately 2.5 million gallons. The tank storage capacities are: 1
million gallons, 0.,85million gallons, 0.37 million gallons and 0.30 million gallons.. In addition
to the four tanks presently utilized, the Village is in the process of designing a fifth tank with
a storage capacity of 2 million gallons. Together, the 4 current storage tanks and the 14
permitted wells can provide approximately 2 mgd of water for 3 days, 1.8mgd for 4 days, or
1.,6mgd for 5 days. In such circumstances, water management procedures also may be
implemented, as needed.
Note: Comment-response 3-3 is also included in the Backup Water Supply response category
on page 2-13,,
3-5
Once yoir hnve the nqueduct zunter, zuhnt hnppens to the demogrnphic mnke-irp of the town, the
Villnge, or the commtinity?
The proposed Aqueduct connection is not expected to have any impact on the demographic
makeup of the Town of Monroe, the Village of Kuyas Joel, or the larger community
Note: This comment-response is also included in the Population/ Demographics response
category on page 2-35.
3-6
The Villnge of Kiryns Joel's zunstezunter trent~iientplnnt lins n 0.9 ntillioiz gnllons cnpncity nnd
lenses 0.35 million gnllons of thnt cnpncity to Wnter (sic) District # l . The qiiestion is, will tlnt
nrrnizgemmt, whichjinishes in probnbly November 2004, continire betjond thnt, or ?the
Villnge zoould like to get thnt cnpncityfor their OZUIZ use?
The County has requested a 2 year extension of the lease agreement between the Village of
Kiryas Joel and Orange County Sewer District #1. The Village will continue to lease 0 35
million gallons of the Village's 0.,9million gallon capacity wastewater treatment plant to
Sewer District #1.,
Note: This comment-response is also included in the Wastewater Treatment Capacity
response category on page 2-10.,
3-7
W e ruould like to kizoru the tiinefrnine for deuelopineizt of ndditioiznl wells by the Villnge. More
itfomzntion sh~iilclbe given on the pnrcel outside the Villnge where ndditioiznl wells nziglit be
dmeloped.
Due to the nature of water exploration, no set timetable for the development of additional
wells can be developed. Watex must be located and tested for quality and quantity and
2-3
Sectiori 2
impact on neighboring public and private wells before application for taking authority can be
undertaken.. Currently, the Village is in the process of permitting two wells with an estimated
capacity of 0.8 mgd. One of these wells is a deep rock well located on the Brenner Property.
The second is a sand and gravel well located on a Village owned parcel. Parcels on which
additional wells may be developed are disclosed in the approval process for such wells.
Note: This comment-response is also included in the Backup Water Supply response category
on page 2-13.
3-8
Please discuss why the Village zuoiild not want to get their waterfrom the New Windsor water
tap on the apeduct?
Based on your comment, discussions have recently taken place between the Village of Kiryas
Joel and the Town of New Windsor regarding the use of the New Windsor aqueduct
connection and filtration plant. The Village is exploring this alternative with the Town. Such
a change will require prior approval by NYCDEP. Likewise, should these discussions result
in changes to the proposed project, the Village, as lead agency, remains obligated under
SEQRA to analyze such changes for potentially significant adverse environmental impacts.
Note: This comment-response is also included in the Tomi of New Windsor Alternative
response category on page 2-57
2-4
(,
Secfion 2
Responses to Specific Cornrnenfs
WATER DEMAND AND SUPPLY PROJECTIONS
2-1
I think you nlso note tlznt yoiir existinggroundrunter zuells in Brenner do supply enoiigli zunter
for your Villnge.
As stated in the DES, the total allotted or permitted yield of Kiryas Joel's groundwater wells
mgd, tlw sum of 0.,308mgd for the Brenner property wells and 1.0 mgd for wells in the
is 1.,31
Village. This would be sufficient to meet the current maximum daily water demand of 1.3
mgd. However, as noted in the DEIS, heavy use of the Village wells has reduced production
from the wells over time and/or low groundwater levels. Calcification and other mineral
actions have built up on the casing walls blocking the flow of water into the wells causing
increased drawdown water levels and a decrease in pump flow (Several of these wells have
been successfully redeveloped)" With such damage, the water system becomes less efficient
requiring longer pumping cycles and higher pump-energy to deliver the required volume of
water to support the community. Therefore, the Village is not able to produce the permitted
amount of water and has proposed the connection to the Catskill Aqueduct as a more reliable
water source. 'The connection to the aqueduct will reduce the dependence of the Village on
groundwater, minimizing stress and damage to the aquifer and Village wells. The connection
will establish a reliable water supply for the Village that avoids conflict and reduces impacts
on surrounding communities,, Through the connection to the Catskill Aqueduct, vulnerability
to drought will also be minimized by broadening the area from which water can be drawn.
3-1
The Aqueduct connectioiz hns been designed,for 2 million gnllons per dny wnter cons~.imption.
Whnt wejizd is thnt, nccording to the Village population and probnbly in the coming couple of
yenrs, that nmotint will probnbly not be enough to meet the wnter stipply needs ofthe Villnge.,
So the question is how the Villnge plnns fo meet thrir wnter demnrid by the yenr 2020 or even
bmjond to supply their coizsii7ners?
5-2
The Enuironinentnl Impnct Stntonent snys the popiilntion growth nt Kiryns Joel is 5.,9percent
n77d tlznt this project won't iizcrense growth, nor does it say thnt growth will decrense., 5.9
percent is not stistninnble growth.,.,. I wnnt to know zohetlzer the wnter siipply thnt yoti nre
predictingfvorn this plnn will den1 zuith thnf popi.ilntion?
15-1
The DEI5 clnims the proposed Aqueduct conizectioiz is needed to support the Villngefor the
next 20 yenrs, but dues not provide projections ofthe poptilntion for the next 20 yenrs.
Thertfore, one cniznot determine how long it would take for the Villnge to exceed the supply of
wnterfrom the Aqueduct--is it 10 yenrs, 15 yenrs, or 20 yenrs?
Using the approximate 6-percent nnnirnl popiilntion grozoth factor referenced throughout the
document, it is estimated that Villnge welZs wo~ildbe dencfiunted,foronly 4 yenrs following the
projected completion of the project iiz 2008. Using the same growth rate, by 2010, the ViZlnge
would need tu stnrt piimping its wells ngnin in order to supply the penkgenerntion on religiotis
holidnys (using n,fiigtire of 88 gnllons per cnpifn per dny cnlctilnted from 2002 penk zunfer use ns
shown in Tnble 2-1 of the DEIS, divided by the 2002 projected poptilntion of 14,762), which
would occur 50 to 75 dnys per yenr., By 2011, only 5 yews nfter cunnection to the nqiiedtict, it
is likely thnt the Villnge will hnue to nctiuate its grotindtunter wellsfir11 time i7z order to meet an
average dnily denznnd (bnsed on 82.83 gnllons per cnpitn per dny ns reported in Connection to
2-5
Section 2
N a o York City Aqueduct Preliminary Report for Conceptual Approval of 2.07 million g f l h z s
per day (MGD)
Again, using the projected nniztial grozoth rate, by 2020, only 14 years after completion of the
connection to the aqueduct, the Village's population zoill reach 42,132 residents, needing an
average of 3.49 MGU. Totaling thesefipres, it appears that in just 14 years the Village's
average daily demand will exceed both the stipply ofits existing grozindzoater zuells as well as
the proposed 2.0 MGDfronz the aqueduct connection,.
All of the above is predicated on a 6-percent growth rate. Hozoever, it should be noted that on
page 1-3 ofthe D E E it states that the marriage rate is increasing, which may rink this rate too
conservative, in zohich case the average daily demand will exceed both groiindwater roe11 and
aqueduct connections even sooner than 14 years.
We belime that the EIS should present a detailed projection of population, using numbersfrum
its o w n history, over the 20 yearsfiorn the completion of the project. This should include an
estimate of the amount of water needed each year, again based on historical recordsfor the
Village. Lnstly, the EIS should ideizt$i when the Village's population zoill exceed the capacity
of its well fields, then the capacity of the aqueduct and finally the capacity of khe wellfields and
the aqueduct zuorkiizg together.
Unless shown to the contrary, tapping into the Aqueduct will only temporarily satisffjthese
growth rates and water needs. In only a few years, much less than 20 years, the Village will
find itselfright back where it is nozu. This Ius sig7iijicnnt implications for stirrotinding
aquifers and private wells. While the aqueduct connection may provide temporary relief, in a
f a o years the demand will again be there to draw zoaterfrom the already inadequate local wells.
The EIS needs to address this
For the above reasons, the project sponsor's preferred alternative does not serve the purpose of
the proposed action for thefull planning period and additional altenzatives shozild be explored.
15-14 Will the Village keep its permits to withdraw 1.31 mgd for its water supply zuells? A t the
current growth iates, hozo long will it be bqore the Village zoill be required to use its zoells in
providing the average daily demandfor water? Hozu long will it be before the Village needs to
use its roells to provide for increased water demand on holidays or days of special-observances?
How often will the latter occur?
15-15 How does the aqueduct reduce stress on neighboring communities and property owners if such
entities will not have access to the 1.31 mgd currently permitted to K i y a s Joel, and i f X i y a s
Joel must restime pumping the aquifer to supply its average daily need again in the future?
The proposed Aqueduct connection will meet the current water needs of Kiryas Joel. The
amount of water the Village is legally entitled to withdraw hom the Aqueduct will grow in
proportion to the population of the Village. 'The proposed pumping and water treatment
facilities would have a capacity of approximately 2 million gallons per day (mgd), but the
major element of the proposed project, the pipeline, would have a capacity substantially
greater than 2 mgd. Water use in Kiryas Joel is projected to reach 2 mgd in approximately
2-6
Section 2
Yew
Dnily Wnter Deninnd
2000
1.9MGD
2010
2.6 MGD
2015
3.1 MGD
2020
3.6 MGD
2-7
4.2MGD
2025
Year
Projected Population
Water Supply Need (mgd)
2005
16,800
1.1
2010
21,400
1.4
2015
27,300
1.8
Section 2
Responses lo Specific Cornmenls
17-5
2020
34,900
2..3
2025
44,500
2.9
What woiild be the nvernge niiri iiinxiiiiuin dnily water demand for thejill buildout of the
Villnge uizder the Master land Use Plnn?
The Village projects that 1,447 to 1,781 new housing units could be built in the Village Based
on the average household size of 5.74 reported by the 2000 Census, these new housing units
could accommodate 8,300 to 10,200 additional residents., Based on the estimated 2002
population of 14,904, this would bring the Village population to between 23,200 and 25,100.
Based on the 2002 average per capita water consumption of 66 gallons per day, this
population would use approximately 1.53to 1.66 million gallons of water per day. The
maximum daily water demand would be approximately 2.3 mgd. Such development, if it
occurs, will likely take place over an extended period of time and be commensurate with the
projected population growth as identified in the previous response..
18-1
As n Nezu York City resiclent nnd City zunter supply nistomer, I lmoe n right to object to the
excessive volume of wntw thnt would be sipholzed off our source of supply ?the Village of
Kiryns Joel coiziiects lo the Cntskill Aqueduct.
New York State law provides that communities in the counties through which the aqueduct
passes are entitled to draw water from the Catskill Aqueduct. Therefore, the Village of Kiryas
Joel, as an aqueduct host community and with the approval of the New York City Department
of E.nvironmenta1Protection to tap into the Aqueduct, can withdraw from the Aqueduct in
accordance with this entitlement and approval.
2-9
Section 2
WASTEWATER 'TREATMEN1 CAPACITY
3-6
(
The Villnge of Xiryns Joel's wastaunter treatinent plant hns n 0.9 inillion gnllons cnpncity and
leases 0.35 nzillioiz gnllons of that cnpncity to Water (sic) District 81. The qtiestion is, will thnt
nnaizgement, zuhichjizishes irz probably November 2004, continue bqond that, or ifthe
Villnge would like to get tlat capacity for their own use?
'The County has requested a 2 year extension of the lease agreement between the Village of
KiIyas Joel and Orange County Sewer District #l.The Village will continue to lease 0.35
million gallons of the Village's 0,.9million gallon capacity wastewater treatment plant to
Sewer Dishict #l.
15-13 The disnission ofwastewater treatment included in the DEIS is not adeqtmte to conclude that
there zuill not be nn impnct to wastewater treatinent in connection zuith the proposed nction.
'The existing Harriman Sewer. Plant is being expnnded but is now operating atfull permitted
capncity. Whnt level ofgrowth for the Village of Kiryas Joel was included in planning the
expnnsion of the plant and is the cornbination ofthe plant nnd the Village adeqtinte to serve the
ndditionnl poptilntion supported by the proposed action?
As described in the D E E , the expnnsioiz ofthe Hnrriman Saver Plnnt is plnnned in order to
ncconimodnte 1.5 M G D of the efjiient anticipntedfroin already approved projects. Tlze DEIS
stntes the 0.35MGD of cnpacity ofthe Villnge Wnstauater Treatment Plnizt is cuirently leased
to neighboring corn7nzinities. the Village terminntes this lease, the neighboring communities
will increase their usage ofthe Haniman Sewer Plant. Therefore, it zooi.ild seem thnt there is
ctinnztly n o excess of sewer trentment at the Hnrriman Plnnt as expanded and the Xinjns Joel
Wastmater 'Treatment Plant. Details on the cunent capacities and current demnndsfor
sewerage trentment at the Harriman nnd the Kiryns Joel plant need to be provided. Also
projections should be niade as to thefuture capacity demands for sewerage treatment nt the
time of cornpletion of the aquedtict connection and a j v e , ten,jifteen nizd twenty years after the
aqtiediict connection.. ..The environmentnl document should detail how impacts to zuastezonter
trenhnentfrom the additional population to be supported by the aqtiedtrct will be mitigated nnd
jinded.
16-6
The DEIS fails to provide nlternatives to discharge into the County sewer in the event a permit
is not issued. It does not nddress the details of the dischnrge in t m s ofcontent, qtinntittj,
e8ect on hydraulic capacihj ofthe carrying lines, whether the discharge wodd occur during
peak or 08-penk hours, and where, zoithin the Coiinty snoer system, the discharge will occur.
16-7
Section 2.13.1.2 (Wastewater)fails to ndeqtiately address, quantitatively and qualitatively, how
zoastewatergeneratedfromthe increased water consumption, will be trented in the event'thnt
there is insti@cient treatment capacity at the Hararriman and Villageplnnts. This section states
thnt "[tjhe current expansion of both the Hanimnn W W T P and Kinjas Joel's o w n wnstewnter
trentnrentfncility would accommodate n large increase in zunstewater dischargesfrom K i y n s
Joel"'' The DEIS should provide qiiaiztifible information about these fncility capacities and this
"large increase.". ..This section fnils to project increased wnstewater treatment needs ofthe rest
ofthe District and hozo any such incrensed demand will impact the proposal. Nor does this
2-1 0
(
i
Secfion2
Responses to Specific Cornmenfs
section tnke into nccotinf the pnrticipntion in the e.ynnsion by minicipnl contrnct tisers ofthe
Hnrrimnn plnnt tlint nre not pnrt afthe OCSD#l. The Towns of Woodbunj and Blooming
Grove hnue nlrendy committed to pzrrclinsing n shnre of the ndditionnl cnpncity In nddition,
while the current lense between the C o m f yniid the Villnge e.xpires in 2004,the lense contniiis
nn option clntisefor two odditionnl one-yenr extnzsions ofthe lense,
16-12 The relntionship of incrensed wnter use to demands nnd capacity nt Sewer District 1 ns well ns
nlternntiue optionsfor necessniy sewnge trentment should befurther discussed.
16-24 Section 2, Environmentnl Setting, Direct Impncts a i d Mitigntio~ifnilstu ndeqnntely nddress
the relntionship of current, e.rpnnded, or new sewnge trentnient fncilities to the proposnl, This
is ofpnrticulnr interest to Ornnge County in relntionship to Ornnge C o m f y Snoer District 1
(see prior comments). Wiile Section 2.13 1.2 does suninznrize current conditions ns relnted to
wnstewnter treatment, the DEIS is silent on inipactsforfiiture sewnge trentment nssocinted
zuith thefncilitntion of'villnge growth uin improved zonter cnpncity.
17-3
The DEIS does not provide siifficient iilfonnntion in order to mnltrnte the potential for the
impnct on sewernge fncilities nnd the discharge of trented efjItient into men strenms. The DEIS
should indicnte the Villnge's current total used and unused snuer cnpncity either within the
Villnge or resmed for the Villnge in the Hnrrimnn Sauernge Trentment Plnnt (Ornnge County
Sewer District ##I)'will the 2.0 MGD ofwnterfiom tltis pipeline exceed t/ie total sewage
capacity nunilnble to the Villnge? If so, hozo will the Villnge gnnrniztee tlint wnterfroin the
pipeline will pot restilt in exceednnce ofthis cnpncity?
r
As noted in the DE.IS, the Village of Kiryas Joel is wit&in Orange County Sewer District No.,l
and is entitled to discharge their wastewater to the Harriman WWTP. In this regard,
expansion of the Haniman WWTP from 4,5 mgd to 6.,0mgd is about to begin in 2004. The
timing of the proposed water supply project is such that the aqueduct water would not
become available before the Harriman plant expansion has been completed. Moreover,
additional wastewater flow from Kiryas Joel (or any other community in the Orange County
Sewer District No. 1)would not happen immediately., Growth in Kiryas Joel and other
comqvgities of OCSD No.1 will utilize the additional wastewater treatment capacity over
time. It should be noted that expansion of the Harriman WWTP beyond 6.0 rngd to serve all
of OCSD No.1 has been recognized as a future need to plan for. Thus, as Kiryas Joel and the
other communities grow, expansion of the wastewater infrastructure can be reasonably
anticipated:
Additional treatment capacity is also available from the Village's own wastewater treatment
facility. The capacity of this facility has recently been expanded to 0.97 mgd. Currently,
Orange County has leased 0.35 mgd of this capacity for other communities. That lease expires
in November 2004.
In summary, between the approved 6.0 mgd capacity at the Harriman WWTP and the
Village's own 0..97mgd treatment plant, plus ongoing planning for future expansion of the
Harriman Wastewater Treatment Plant and the Kiryas Joel Wastewater Treatment Plant,
sufficient wastewater treatment capacity should be available for the gradual growth in
wastewater generation in Kiryas Joel resulting from increased water use up to 2 mgd, as
2-1 1
Section 2
proposed with the subject project Ihe availability of wastewater treatment capacity serves as
a growth limiting factor for the Village and all surrounding communities
2-12
(
Section 2
Responses io Specific Comments
BACKUP WATER SUPPLY
2-2
I woiild nlso note thnt the wells tllnt yoti currently hnve--I don't know if yoti ruotild hnve to pny
bnck the monies that were given to you as grnizts becniise of the fnct thnf they were largely
provided by botli stnte nnd federnl grants, I'm sure thetj don't give you grnntsfur intcriin use
T k j nsstinie it's going to befor perinnnoit zisnge nizd not ns a bnckiip system
All wells in the Kiryas Joel water system have been used and continue to be used as the
primary source of potable water for the Village., The Village has decided it needs a more
reliable primary source of potable water, After implementation of the proposed Aqueduct
connection, the existing water supply wells, which will still be regularly maintained as part of
the Village water system, would become the Village's primary water source at times when the
Aqueduct is shut down for maintenance or repair. The majority of the monies previously
received by the Village for water system development have been in the form of loans and
bonds. The Village remains obligated to meeting its loan and bond requirements.
3-3
It is not nmndntoiy by tis, but the qtiestion of bncknp wnter supply is niz importnizt one. From
tiwie to time we do tnke dozuiz our nqiiedlicts for repnirs, maintenance, and nny iiizforeseeiz
problons. So, therefore, it is rather essentinlfor the Villnge to hnve some sort uf bnckiip water
stipply. The existing runter supply thaj lime woiild hnve to be mnintnined, ur there lias to be
some understnnding between the diffcrent comintiizities thnt do tnke zunterfrom the villnge flint
when needed the Villnge cnn get flint wnter bnck for their owiz constiiners. The potentinl likely
degree of relinnce in flze bnckiip zunter szipply must be addressed,
14-.5
The 14 wells currently nsed by the Village nre being considered n bnckiip supply. Will this
backtip supply be ndeqtinte when the NYCDEP shiits down the Aqueduct ns thetj do on n
regzilnr basis @r npproximntely 3 days) nizd cuts off thnt wnter for use?
15-5
W e estiinnte flint ruithiiz 5 yenrs nfter completion of the nqiiedtict coiinectioiz, Khyns Joel woiild
once more be iiicrensi~zglydependent upon groundwater and woiild genernte potnztinl iinpncts
@v!z trnficfrom zunter tnnk trzicks nnd/or dnmnge to the nqziifer nizd izeighboriizg wellsfroin
oucr-yi,frping)on its neighbors whenever the nqliechct needs to be shtit down, either for
ninintennnce or for nnfureseeiz circiinistnnces.
15-16 NYC requires nztinicipnlities connected to their nqiiedtict nzust haven second sotirce of wntcr.
The DElS does not nddress bnck-up wnter supplies when the nqiiedzicts nre periodicnlly shut
down nor whnt provisions will be ninde to stipply nitemnte wnterfor a coJnmunihJ that will
become dependent upon the aqueduct fur its primnry wnter sozirce. .Iizformntion nboiit whnt
tlype ofback-up supply need to be addressed in the DEIS.
As proposed, the Aqueduct connection would provide water to the Village, and the existing
Village water supply system would provide backup to the Aqueduct connection. The Vilage
has four water storage tanks with a total capacity of approximately 2.5 million gallons. In
addition to the four tanks presently utilized, the Village is in the process of designing a fifth
tank with a storage capacity of 2 million gallons. Together, the 4 cwrent storage tanks and the
14 permitted wells can provide approximately 2 mgd of water for 3 days, 1 8 mgd for 4 days,
2-13
Section 2
Responses to Specific Cornrnenls
or 1.6mgd for 5 days. In such circumstances, water management procedures also may be
implemented, as needed,.
3-7
W e would like to know the tiniefr.aniefot development ofadditioiml wells by the Villnge. More
information should be given on the pnrcel outside the Village where additional wells might be
developed.
Due to the nature of water exploration, no set timetable for the development of additional
wells can be developed., Water. must be located and tested for quality and quantity and
impact on neighboring public and private wells before application for taking authority can be
undertaken,. Currently, the Village is in the process of permitting two wells with an estimated
capacity of 0,.8mgd,, One of these wells is a deep rock well located on the Brenner Property.
The second is a sand and gravel well located on a Village owned parcel..Parcels on which
additional wells may be developed are disclosed in the approval process for such wells,
2-14
Section 2
Responses io Specific Comments
WATER ACCESS
7-1
There nre iiinny people in the coininirnity thnt nre not necessnrily iiz agreematt witlz tlze
lendership., Would the water be nccessible to thosepeople ns well?
The water from the proposed Catskill Aqueduct connection would be available to all residents
of the Village of Kiryas Joel.
7-2
There nre mnizy wells izz the cominimity, soine privnte nrid some not so private. There is a grid
of wnter pipes in the VilZnge, so cozild there be n trndeoffofwnterfroin one side to be used on
another side oftlie Village?
The water supply pipes in the Village of Kiryas Joel are interconnected so that any building in
the Village can receive water from any well in the Village water system.
2-15
Section 2
REGULATORY RFQUIREMENT'S AND INVOLW?D:D/INTERFSTEDAGENCIES
(
15-26 W e believe thnt tnking n hnrd look at the potentinl impnctsfiom the ndditioirnl populntion
commenstrrnte zuith incrensed flUflihbilihj of drinking zunter is a S E Q X A reqtiirsnoit. This
requirenieirt is not nddressed by stating, contrary tofnct thnt popiilntion growth tan occtrr
without n simple drink of wnter. Despite the Villnge's religious prnctices, SEQRA nnd
Mtinicipnl Zoning require ncceptnnce of responsible lnnd innnngement prnctices.
16-1
W e request t h t the Ornnge County Sewer District No.1, the Ornnge Counhj Depnrtinent of
Enuironmentnl Fncilities, Public Works, nnd Planning listed ns involved agencies tinder SEQR
in relation to this proposnl.
16-4
On pnge 5-5 the Ornnge County Depnrtmmt of Environmerttnl Services nnd Orange Cotiirty
Sezuer District No.1 should be, but are not, included on the list ofngenciesfiom zuhich permits
nnd npprovnls mny be required.,
16-5
I n nddition, the Ornnge County Department of Public Works should be incliided on the list.
Reqnired npprovnls include, but nre not necessnrily limited to, n p m i t for the proposed
dischnrge of the bnckwnshfioin the proposed zonterfiltrntion plnnt into Omnge County Saoer
District No. 1 sewers.
16-8
On pnge S-5 is n list of the npprovnls that nre needed. They should ndd the Ornnge County
DPW to the list for nny work thnt is done within the right-of-wny Ofnny Cotinty rond. W e also
reqtiest thnt the Ornnge County Snuer District No.1, the Omizge County Depnrtment of
Environmentnl Fncilities, ntrd Planning be ndded ns ngencies hnving permitting nnd review
f
authority.
16-10 On pnge 1-20 the Coirnty DPW shotild be listed ns nn involved ngenq. County
Environmentnl Facilities and Planning should nlso be listed ns "interested pnrties."
16-18 On pnge 55, and throiighoiit other relevant nrens of the D E E , the Omrzge Colinhj Depnrtnzmt
of Environmentnl Fncilities nnd Services is not inclttded nnd it shotild be. This is especinlly
true with respect t o n potetitinl proposnl to discl.mrge bnch-wnsh zunter info OCSDl sezuers from
the new Wnter Filtmtion Plnnt proposed for construction on Berdichev Rand in the Villnge.
The purpose of SEQRA is to identify adverse environmental effects and to mitigate such
adverse effects to the maximum extent practicable., Human health and existing patterns of
population growth and community character are major components of the "environment" as
defined by SEQRA. Existing population growth, as opposed to population migration, is
dependent on the birth of children and on the availability of water for supporting the existing
population and their families.. The unavailability of sufficient wholesome, potable water may
have severe adverse impacts. The lack of such water results in unwholesome conditiorls,
disease and even death. Conversely, provision of a more reliable, safe water supply - the
action being analyzed under SEQRA - reduces the adverse impacts and preserves the human
health, population patterns and community character of the Village..The existing religious
practices of the residents of the Village are the major components of existing community
character and, therefore, do not conflict with the responsible application of SEQRA, municipal
2-1 6
(
Section 2
zoning or land use practices. The Aqueduct connection is in compliance with the Village's
municipal zoning as required by the Village's comprehensive plan. Therefore, the provision of
water supply actually furthers the goal of protecting the environment, supporting zoning and
furthering land use planning.
SEQRA notices and copies of the SE.QRA documents have been filed with Orange County
with the offices of the County Executive.. Comments have been received from County
agencies and have been reviewed. All County agency comments will be given due
consideration in the appropriate context. SEQRA defines an "involved agency'' as an agency
that has jurisdiction by law to make discretionary decisions to fund, approve or directly
undertake an action. 6NYCRR 617.,l(s).The Village, as lead agency, has exercised due
diligence in determining a list of involved agencies as included in the EAF, Final Scope, and
DEIS at Section 1.6.. With respect to a county highway permit, for example, the NYS Village
Law provides independent authority for construction of the aqueduct connection, stating that
"water pipes may be laid, re-laid, or repaired under any public highway in the county in
which any part of the Village is located." The only requirement set forth in this state law is
that the Village "cause the surface of such highway to be restored to its usual condition. Since
the Village has express statutory authority to lay the water pipes in the County highway and
the Village is conducting one of its essential governmental operations (which,'by nature, may
not be subject to the permitting authority of other municipalities pursuant to the public
interest test applied by the courts), The County highway work permit is ministerial in nature.
Therefore, the Village will cooperate with the County in its permitting processes in all those
matters which the Village finds reasonable and proper concerning the County's interests with
respect to the Village's project at such time as any County permit applications are submitted.
The County agencies, having appropriate areas of interest and expertise, will be added to the
list of interested agencies.
2-17
Section 2
GROWT'H INDUCEMENT
4-2
W e nre not hnppy zoith tlie genernl growth iiz Orange Cotinty and zoith the Villnge of K i y s
Joel nt the liendzonters of the Rnmnpo River waterslied we nre concerned with tlie level of
development thnt this project mny induce.
5-3
.But more renlisticnlly, givnz zunter is n j n i t e resotim shared hj all coiniiitinities, whether we
coiild jiistpj nny plnn thnt allows one community to hnve that growth rnte.
8-2
The DEIS snys that grozoth in tlze Village of Kiryns Joel is primarily internal. However, zoith
this nbimdnnf zunter I'm concerned ns a next-door neighbor that such growth zuoiild not be
internal, thnt it wotild nttrnct a lot of peoplefrom Nezu York .Wotild there be n trnizsparozt
mechnnism to prevent the infux of outsiders, non-KJgenernted peoplefrom migrating to the
nrea V t h e proposed Catskill Aq~iedtictTap project coiizes into effect? A transparent system so
thnt only people who live in this comrntinity and their children, rather thnn outsiders, wotild be
using this wnter?
14-7
Section 2.8.2, tlie incrense in the popiilntion due to lnrgefainily size is discussed. "The lack of
essnitinl seivices, such as drinking zunter has not slowed population grozoth in KinJns Joel."
While the intention ofthe project may not be to encournge "sigriificant ndditionnl growth" due
to an iizfzix ofresidentsfrom outside the villnge, it is very likely that such growth will occur.
The provision of an ndditionnl service (wnter supply) would supplement the nlrendy occurring
growth (due tofnmily size). l%is would hnve an iinmedinte effect on tlie infinstructure on the
surrotindiiig nrens nnd in the region, incliiding but not linzited to ronds nnd wastewnter
trentmentfncilities. Wliat plans are iii plnce to nddress these issues?
,
15-25 Why hasn't growth rrinnagement been investigated ns part of the DEIS? It is importniit to the
commtinity to plniz for a snfe and henlthfiil environment for itself'nnd its neighbors. A t some
point it will become physicnlly impossible to nccornmodnte ndditionnl populntion within Kiryns
Joel,. Shouldn't the DEIS nsk difFciilf questions such as hozu many people can be stipported 8
the existing inftnstriicttire and how will improvonents to infinstructure increases the carrying
lond of the land? A t the nziiiiintim the growth inducing aspects section slioiild assess how the
existing ii?f,.nstrticture (iizclziding sezunge trentment nizd roadwnys) of the Villnge nnd
surrotinding comintinities would be able to support the additional population.
15-27 Although the letterfiom the N Y C Water Bonrd acknowledges that Kinjns Joel is entitled to
zuithdraw 1.1 M G D based on its puptilatien (1990 cozs~is),the DEIS repeatedly states that the
Vilrage is now entitled to withdrnzu approximately 1.0MGD bnsed on the 2000 censtis. Which
is correct? Cnn one nssii7ne that the Villnge will inodiftl its entitlement requests after ench
census niid innease it's fnkiiig ofzuaterfrom the nqtiedtict?
15-29 There is a possibility that this action may support migration into the comnzunityfrom
elsewhere ns zuell as the natural growth of tlie comrntinity due to marriages and births. While
young women must remain in the Village to mise their families, do hiisbands comefrom
outside Xiryns Joel? TFze possibility of outside migrntion should be seriously explored tinless
the Village has n plnn to prevent stich migrationfroin occtirring.
2-18
i
Section 2
16-22 With the increased availability ofzuater supply and ruastezunter treatment and a large demand
for housing in areas outside the Village, how will the influx ofoutside community housing
developmoit be curbed, controlled and/or prevented within the Village?
16-25 We concur that the inherent nature of the specific proposal applies only to meeting zunter
denzands within the Village of K i y a s Joel and that grozuth-inducement outside of the Village as
a result ofaccess to the NYS Catskill Aqnednct is not intended zoith this project. However,
there is both a trend ofregional grozuth and a clear record ofinterest by the neighboring
irizuzicipalities along the proposed waterline regardingfuttire access to this pipeline and/or
shared use of the aqueduct tap., Those neighbors have expressed a range ofinferestsfrom access
as community backzip supplies, access to address certain, existing neighborhood shortages, as
zuell as the influences of improved water capacities on deuelopment expansionfroin the Village
into neighboring Towns. The DEIS should provide some,furtlzer discussion on these issues. At
a minimum, the DElS should, in Section 6, provide a record of grozvth trends and ruder needs
in the immediate region of the Village and along the pipeline routes, and the D E E should
reviezu any record or disctission with Town and Village leaden in this rep’oiz and along these
ratites releuant to water needs and prospective access to Catskill nqtiedtict wafer.
18-2
I can only v i m this additional water supply as a sign ofencotiraganent tofiirther residential
and business development in what is nozu open green space where peoplefrom our urban areas
can come to enjoy the nntzirnl beauty and wildlife, and the solitiide that have been vanishing at
a more rapid pace these dnys as zirbaiz sprawl brings with it more trafic, more pollution, and a
generally worsening qzialify of life.
The provision of adequate potable water supply is part of the Village’s growth management
plan., Proper growth management seeks to provide adequate infrastructure for the people’s
needs., The Village has ongoing programs to provide for such needs and this project is a next
step in a multi-year, multi-million dollar program to provide potable water supply for the
people of the Village., The Village‘s growth management plan seeks to sustain growth by
meeting the people’s needs. To date, the internal growth from the Village has been sustained
and the Village’s growth management policy seeks to sustain it in the future. While
neighboring Villages have an abundance of water supply, the Village has been working hard
to maintain sufficient supplies to meet peak demands., Comments made infer that “growth
management” is a code word for artificially withholding needed infrastructure to inhibit
growth. Such artificial limitations may be effective in limiting population migration, but not
in limiting natural internal growth,,
The Village’s projection of internal growth of its population is based on observation of the
population dynamic in the Village. Unlike the surrounding environment, virtually all
maturing young persons get married and raise children in marital family units which remain
stable throughout the lifetimes of the husbands and wives., The children are nurtured, raised
and supported in an environment which heasures them as divine gifts. The census data show
that the overall population of the Village is young and maturing. Young women remain in
the community, while young men move to where their wives reside. Some migration of
young men to’theVillage is expected, but is offset by young men moving to other
communities., Thus no significant growth from outside sources coming to the Village is
2-19
Section 2
observed
TIhe suggestions of some commentatoxs are that mechanisms for preventing population
migration or outside growth should be implemented. While such measures are deemed by
the Village to be unnecessaIy based on the lack of significant growth from outside sources,
such measures would be prohibited by constitutional principles which uphold the right of
people in the United States to move and live where they choose.
Since the Village project does not propose to supply water in areas outside the Village, growth
inducement in such areas is not being analyzed.. Growth inducement in those areas related to
water supply will be analyzed by those who undertake to supply water to those areas.
2-20
Section 2
STREAMS
14-1
Along the proposed route, tlzrre nre innjor strenin crossings nt Mood~?nCreek nnd Prriy
Creek. .More detniled plnnsfor mitigntion, especinlly in the instances ofbunjing the pipeline
for the stream crossing, shotrld be nddressed, Also niore detailed plans nnd preparation are
needed ~ J regard
I
to the proximihj of the many szirfnce runtrr areas ndjncent to the proposed
route.
I
The project design has not been completed; therefore, detailed plans for mitigation at stream
crossings have not been finalized. Stream crossings will be completed in accordance with
applicable State or Federal permit regulations (e.g,, NYSDEC Protection of Waters permit
and/or US Army Corps of Engineers Section 10/404 permits)., Any impacts to the flow or
water quality of the streams at these locations would be temporary and construction-related,
and proper construction mitigation measures would be employed to minimize such impacts.,
Pipeline stream crossings would be designed to allow the regulatory flood flow of water
under a bridge or through a culvert to prevent new flooding impacts. If practical, attaching
the pipeline to existing bridges or "boring or jacking" the pipe below the streambed
(preferred method of the Army Corps of Engineers), will be implemented to avoid steam
disturbance., However, should in-stream work be unavoidable, accepted methods of utility
stream crossing tliat may be put into practice include stream diversion, flume pipe crossing,
or cofferdam utility crossing, Stream work will be continuous and in compliance with State
and/or Federal requirements until the work is complete and the stream can either be rediverted or returned to previous conditions
During design, careful consideration will be given to the control methods used during the
utility stream crossings to protect sediment from entering into the stream during construction
and to minimize the amount of disturbance the stream experiences. A Soil Erosion and
Sediment Control (SESC) plan will be devised to assist in achieving minimal water and
natural resource disturbance. In accordance with the NYSDEC's Soil E,rosion and Sediment
Control Guidelines, surface runoff that is relatively clean and sediment free will be diverted
from flowing through areas of construction activity on the project site., Run off from land
disturbing activities will not be discharged off-site or into storm drains or watercourses unless
directed through a properly designed, installed and maintained structure, such as a sediment
trap, to retain sediment on-site. Additionally, the SESC plan will require the installation of a
silt fence around the perimeter of the pump station and water treatment plant locations and
along the preferred pipeline route to prevent off site movement of sediment produced by
construction activities. E,rosioncontrol blankets, straw mulch or other control measures will
be utilized in drainage swales and ditches, as well as on slopes exceeding 3:1 as a means of
stabilization and control. The extent of land alteration, including removal of existing
vegetation and land cover will be minimized to the greatest extent possible. Erosion control
blankets, straw mulch or other control measures will be utilized in drainage swales and
ditches, as well as on slopes exceeding 3:1 as a means of stabilization and control., Gabion
baskets, rip-rap, log cribbing 01vegetative measures will be used to minimize impacts to
stream beds and banks on-site and off-site that may be affected by land clearing, grading, and
construction activities. The SESC plan for the proposed project will be completed and
approved prior to construction and will remain in place until project completion.
2-21
Section 2
27-22 T7te DEIS does not indicate lzozu inany acres of'tnnpornny OT p m n n e i i t stormonto detention
potids ruill be needed. It does not indicnte where those detention ponds will be locnted and the
impacts of their construction. A similnr nnalysis is nlso ?reededfor nny piimp stntions or
tnnpornnj staging nrens dong the pipeline route.
A construction plan has not yet been prepared; therefore, the number <mdlocation of
detention ponds is not known at this time. These items will be provided for under the SPDES
conshuction permit for this project. Similarly, staging areas have not yet been determined for
the project. No pump stations are proposed along the pipeline route.
17-23 Plense diSCiLSS whether the proposed Wnter Trentmetit Plant zuill result in any discharge to
nearby strenmsfrom such things nsfilter bnckiunsh, alum, or any other dischnrge of process
wnter or effluentfiom the plant Please discuss whether men stream mound the proposed
Water Treitment PInnt site (or nny nltrrnnte sitefor it) cnn adequately nssimilnte sirch
discltnrges dtfring nonnnl a77d drought periods.
Any liquid discharge from the new water treatment processes would be to the sanitaIy sewer
system where it is treated pursuant to permit. Backwash water from the Village's current
water treatment plant is discharged to a wastewater heatment plant via the sanitary sewer
system .... Sludge would be disposed of as a solid waste. 'Iherefore, no area streams would be
directly affected by process water or effluent h a m the plant.
2-22
Section 2
DE.L,AWARERIVER WATFRSflED
11-1
The r.5 iinrst address potential impacts on the Delnzuare River zuntershed, iizclzidiizg flze men
belozu the N m York City reservoirs.
The reservoirs that are the source for Catskill Aqueduct water, the Schoharie Reservoir and
the Ashokan Reservoir, were created by diverting water from the Delaware River watershed
However, the proposed 2 mgd water withdrawal from the aqueduct represents only 0.3%of
the capacity of the Catskill Aqueduct (580 mgd). As a result, the proposed water withdrawal
will have a negligible impact on the Delaware River.
6-1
We hope there zuill be no taps on either the Catskill Aqtredtrct or Delaware Aqueduct until the
Hudson River is taken for water at 325 nz@
The development of the Hudson River as a source for New York City water would be a largescale initiative that is beyond the scope of the Kiryas Joel connection project. It is not
economically feasible for the Village of Kiryas Joel to withdraw and treat Hudson River water
for the proposed project,
2-23
Secfion 2
Responses to Specific Commenls
RAMAPO RIVER WATERSHED
4-1
W e request a Strpplonentnl Environniental Impnct Sttidy to address the iinpnct on the Rnmnpo
River wntershed mostly throtrglz the increase of treated snoage efluent thnt woirld restiltfiom
this connection. W e woirld hope that the strpplementnl zootrld include the lmel of treatment the
sezonge will get.
14-6
What studies h e been condircted to detennine the impact to the Rnmnpo River watershed?
The quantity and quality of wastewater treatment effluent discharged to New 'fork
watersheds is regulated by the State through State Pollutant Discharge Elimination System
permitting. Any additional wastewater generated from the Village of KiIyas Joel will be
treated at its own plant or at the Haniman treatment plant and would be subject to each
plant's respective existing permit limits. These limits s a v e to reduce the impact on water
quality based on the regulated uses of a receiving water body. The impact of wastewater
effluent on area streams has been studied in the permit applications for the wastewater
treatment plants to which Kiryas Joel wastewater will be discharged. No modifications to
these permits are antiapated to directly result from this project,. Therefore, there are no
additional significant adverse impacts anticipated from treated wastewater effluent and no
supplemental studies warranted.
2-24
(
Section 2
FLOODING
16-21 The DEIS states that there will be no problnii zuith the mnximiim Pozo ojMoodnn Creek dire to
the proposed pipeline being siispmided froin the bridge. Whnt yenrflood iiznrk wns used to
support this stntmnn7t?
The DEE concludes that there would be no flood impact from the pipeline because the invert
of the pipeline would not be below the existing Route 27 bridge structure. The bridge
structure beneath the roadway consists of four steel beams that appear to extend
approximately 4 to 5 feet below the base of the roadway,, Therefore, an l&inch or 24-inch
pipe affixed to the bridge would be placed up between these beams and not below the
existing bridge profile. The =,MA map of the bridge location shows that the surface of the
bridge roadway is not within the 100-year flood plain. Pipeline crossings of all streams would
be designed to allow the regulatory flood flow of water under a bridge or through a culvert to
prevent new flooding impacts.
2-25
Section 2
STORMWATER
17-14 Plense incltide a detailed discussion of stormzonter management duiing consfruction on steep
slopes.
A stomwater management plan pursuant to state stormwater permitting regulations would
be developed during the design phase of the project. All stormwater management during
construction of the pipeline would be executed in compliance with applicable regulations.
Any potential stormwater impacts would be monitored in the field, and steps would be taken
to prevent such temporary impacts to the extent possible,.The appropriate erosion and
sediment control approvals would be obtained prior to construction of the pipeline.
During design, careful consideration will be given to the control methods used during the
utility stream crossings to protect sediment from entering into the stream during construction
and to minimize the amount of disturbance the stream experiences. A Soil Erosion and
Sediment Conixol (SESC) plan will be devised to assist in achieving minimal water and
natural resource disturbance,. In accordance with the NYSDEC's Soil Erosion and Sediment
Control Guidelines, surface Iunoff that is relatively clean and sediment free will be diverted
from flowing through areas of construction activity on the project site. Run off from land
disturbing activities will not be discharged off-site or into storm drains or watercourses unless
directed through a properly designed, installed and maintained structuIe, such as a sediment
trap, to retain sediment on-site. Additionally, the SESC plan will require the installation of a
silt fence around the perimeter of the pump station and water treatment plant locations and
along the preferTed pipeline route to prevent off site movement of sediment produced by
construction activities. The extent of land alteration, including removal of existing vegetation
and land cover will be minimized to the greatest extent possible. Erosion control blankets,
straw mulch or other control measures will be utilized in drainage swales and ditches, as well
as on slopes exceeding 3:l as a means of stabilization and conkol. Gabion baskets, rip-rap, log
cribbing or vegetative measures will be used to minimize impacts to stream beds and banks
on-site and off-site that may be affected by land clearing, grading, and construction activities.
The SESC plan for the proposed project will be completed and approved prior to construction
and will remain in place until project completion.
2-26
i
'
Section 2
WETLANDS
142
More inclusive plnnizing is nlso required iiz regard to tlze wetlands (e g. those at Route 27 n e w
Mozriztniii Lodge Rond) ns well.
As stated in the DEE (page 2-16), a field survey of the mapped (NWI and NYSDEC) wetland
areas was conducted to generally confirm the presence of mapped wetlands along the
proposed pipeline route. The focus of the analysis was to identify potential areas of impact so
that the design could be focused to avoid the potential for such impacts, During design the
DE.ISrecommends delineation of several areas (including Route 27 at Mountain L.odge Road)
in order to identify the full extent of wetlands and to avoid impacts to these wetlands during
construction. The delineation would be conducted in accordance with the appropriate
Federal/State requirements as part of the final design of this section of the pipeline route.
As noted in the DEIS, no permanent wetland impacts (permanent fill) requiring a permit are
anticipated,,
2-27
Secfion 2
THRE!ATENED
AND ENDANGERED SPECIES
2-3
...Route 27, nlso knozoiz as Clove Road, there is a lnrge infestation of the timber rattlesiznke
144
In Section 2.3.3 T7ie DEIS disctisses Endangered and Threatened Species and although “ no
Federal or Stake listed or proposed endaizgered or threntened species are known to exist zoifhiiz
the project sttidy area”, zohnt plans for mitigation does the proposed project have in the emit
that such species are discovered in the project area?
As described in section 2.3.1of the DEE, no Federal or State listed or proposed endangered or
threatened species are known to exist along the proposed area of disturbance,.Therefore,
development of mitigation measures is not required. I f during final project design and/or
project construction endangered or threatened species are discovered, the appropxiate
agencies (Le, NYSDEC) will be notified and specific measures will be implemented as
directed by that agency.
15-23 The DEIS has not explored the potnitidfor eizdarigered or threatened species at the alternative
water treatment site. ‘The DEIS should contact DEC’s Nattirnl Heritage program to determine
the presence of endangered or threatened species, The alternative zoater treatment site should
bejeld checked for endangered and threatenedjora and fauna; timber rattlesnakes are known
to inhabit the Schunnemtink Mozintains.
‘TheNYSDEC was contacted to determine if sitings of threatened or endangered species were
recorded for any of the thxee pipeline routes, the connection to the aqueduct site, and pump
station and treatment plant locations. No sitings were identified,.As the alternative water
treatment plant located on Seven Springs Road just west of Bakertown Road is not the
preferred location for the water heatment plant, there i s no need to field check the site for the
presence of such species.
2-28
Section 2
VEGE,TATION
17-20 Ifany constritcfion is outside ofthe road pnumnenf,how inany ncres oftrees and slzriibs ruiIl be
removed in order to instnll the pipeline? How ninny ncres will be replnnfed?
As described in the DEE, the pipeline would be placed in the roadway shoulder, easement or
the roadway itself. Therefore, it is unlikely that the installation of the pipeline would require
the removal of trees and large shrubs. To the extent any vegetation will be removed, it will be
minimized to the greatest extent possible. The contractor’s staging areas may require the
removal of existing vegetation. These areas will be re-vegetated at the conclusion of their use
by the contractor.
17-24 The DEIS doe,s not indicate zuhether fhe pipeline trench will be constnrcted within 50.f. ofnny
mnttire trees, and ifso, wlzat annlysis would be done on whether such construction coirld
dnmnge or destroy the root system of these trees. Please provide a 7nethodolopjfor such
nizalysis nnd a17 indication ufhow impacts to innttrre trees will be avoided or prevented.
As stated in the DEIS, the pipeline would be placed either within the shoulder, easement or
the roadway itself. The placement will be determined by many factors including, but not
limited to, the existence of utilities within a roadway, the width of a roadway shoulder or its
easement, and the presence of wetlands or potential historic/archaeological resources.
During final design the location of trees required to be protected under local tree preservation
regulations within 50 feet of the pipeline trench will be identified., Efforts will be made to
place the trench outside the area of the tree’s root system. Temporary fencing will be placed
to prevent accidental disturbance of these trees,.
2-29
Section 2
LAN0
15-6
The DElS stntes thnt the nqiiedtict pipeline zoill moss the Moodna Creek and potentially other
streams, via attncltments to existing bridges. Hozo does this assure tknt the pipelirie is not
siisceptible to damage during extremely cold weather, damage during bridge nnd roadway
repnirs/improvements, and to damagefroin intentiorid mischiqfor sabotnge?
16-2
The D E E shotild explnin mnintenance responsibilities for this pipeline ns roe11 as protocols for
mnintenance during bridge work or reconstruction.
Standard pipeline maintenance and protection measures will be developed during the design
phase of the project.. The constant flow of water through the pipeline would help reduce the
risk of freezing during unusually cold weather, During a bridge repair, it would be the
responsibility of the Village to work with the entity repairing the bridge to temporarily or
permanently relocate or otherwise protect the pipeline. The risk of sabotage is present for any
water supply; indeed, greater attention is being focused on this threat across the nation.
Appropriate security measures would be investigated to protect the pipeline at any point
where it is exposed.
17-13 Altkozigh the DElS disctisses the potential for otcoiintering steep slopes or slmllozo bedrock in
generlc ferms,it did not identifij the specific areas where theses problems might be encotintered.
It did not provide a mnp or pnntifij how many htindreds of tkotisnnds of linenr feet of this
proposed pipeline might encounter these types of difficult construction arens. Please qiinntifij
in detail where these areas might be located, their length, and how steep are the slopes or kozo
shallow is the bedrock in these areas. Please disctiss site-specific construction techniques to
reduce impacts on land, trnffic, strenms, and nenrtrj businesses for each ofthese mens.
The project route has not yet been surveyed. This would be completed during the design
phase of the project, At that time, detailed information and construction planning regarding
steep slopes or bedrock would be presented as part of the State permitting process.
A Soil Erosion and Sediment Control (SESC) plan will be devised to assist in achieving
minimal water and natural resource distuIbance,. In accordance with the NYSDEC’s Soil
Erosion and Sediment Conhol Guidelines surface runoff that is relatively clean and sediment
free will be diverted from flowing through areas of construction activity on the project site.
Run off from land disturbing activities will not be discharged off-site or into storm drains or
watercourses unless directed through a properly designed, installed and maintained
shucture, such as a sediment trap, to retain sediment on-site. Additionally, the SESC plan
will require the installation of a silt fence around the perimeter of the pump station and water
treatment plant locations and along the preferred pipeline route to prevent off site movement
of sediment produced by constxuction activities. Erosion control blankets, straw mulch or
other control measures will be utilized in drainage swales and ditches, as well as on slopes
exceeding 3:l as a means of stabilization. Gabion baskets, rip-rap, log cribbing or vegetative
measures will be used to minimize impacts to stream beds and banks on-site and off-site that
may be affected by land clearing, grading, arid construction activities The SESC plan for the
proposed project will be completed and approved prior to construction and will remain in
place until project completion.
2-30
I
Section 2
16-3
l77e Villnge mny hnue to i~zstnllthe pipe in tlze shoulder or rondiuny dire to ndjncent wetlnnds.
This could pose n snfehj thrent to the trnueliizg p i l b k $the pipe should merfnil. Afloru of
1,400 GPM coiild ensily wnsh out the rondzony. Give71 thnt this is not n zoell-lit rond nizd thnt
it hns n grent den1 ofboth uerticnl n~zdhorizontnl curuntilre, n zunsh oiit nt ~zightcould be l$e
threntening to mybody driving on it.,
Any pipe theoretically can fail and if undetected such a failure could cause washouts.
However, with modern design and construction techniques combined with today's materials,
the likelihood of pipe failure is low., Should a failure occur, corrective action would be
implemented as soon as possible to minimize impacts.,
16-9
The trench is described ns being 4' wide nizd 4.5' deep. The depth of the trench has to be grenter
thnn that to nllow forfuture drninnge instnllntioizs. T\Je depth to the top ofthe wnfer nznin
should be 4.5', miniinurn.
The pipeline would be installed under Orange County roads in compliance with County and
NYSDOT standards such as the Npiu York Stnte Depnrtmeizt of Trnizsportntiotz Reqzriretnents,for
the Design nizd Coizstrzrcfio~roflJ~zdergrozmdUfilityI~zstnllntionsWithin the Stnte Higlzwny Xighfof-Wny., The depth of cover over the pipe would be increased to 4.5 feet if required
2-31
Section 2
BLASTING
2-4
Additiorrnlly, there is discussion nbout blnsting nnd blnsting is n renl concern in Bloonzing
Grove. When you go nlong Clove Rond there nre nrens knozon ns Glenwood Hills nnd
Motintnin Lodge Pnrkniid mnJly yenrs ago in the 1980's there zuns a proposnl to bring sezoer
lines up Lo thnt nren, nnd this zuns turned down vehemmtly by the people tlzere nnd by
en@ering sttidies thnt led to the conclusion thnt blnsting in tlznt nren cotrld impnct the zoells
people hnd and nlso theirfotindntions oftheir homes. This cnn be dociimentedfram the 1980's,
so I think tlint zootrld be something thnt on Route 27 would bring major concerrz,.
15-7
Pnge 2-40 lists thefirst two mitigntions for blnsting nnd discusses ndkerence to Inws nnd
pernzitting procedures. The DEIS stntes thnt the requirement of inspection of off-site properties
previous to blasting zuoiild O J Zbe~ condtrcted
~
when requested or nnthorized by the owner.
Some property ozuriers may not tinderstnnd their rights to request inspection ns the mitigation
is presently written. W e recommend thnt the project sponsor be required to send notice of
blasting by certiJ7ed mnil to nll property owrrers within 500 feet of blasting, This notice should
incliide i~?for?nntionin clenr language regnrdfng how the property owner cnn mnke an
appointment for pre- nnd post-blnsting inspections. W e nlso recommend monitoring of nny
public nnd privnte runter supply wells within 500 feet ofblnsting. A plnn for this monitoring
should be made pnrt of the DEIS so thnt it can be commented upon by the public, especially
those directly nfected..
17-15
These (construction techniques) shoiild include a detailed discussion of.. .blnsting impncts in
nrens ofshallow bedrock. DEC recommends a pre-blast stirvty of the foundntions nnd zoells o f
rill homes, institutions nnd businesses within 500). of blnsting.
Because the pipeline is proposed to be installed in existing paved roads or road shoulders,
blasting is not expected to be required. Blasting would be used as a last resort if bedrock or
large boulders were encountered and alternative means such as ripping were not feasible.
Blasting would be limited to the smallest area possible. If blasting is necessary, it would be
done in conformance with state and local rules and regulations. This includes notices to
surrounding property owners as required by any applicable regulations,.
Precise pre- and post-blast survey plans will be developed during design, based on geologic
investigations for design, locations of proposed blasting (if any), and state and local
requirements,.
2-32
i
i
Section 2
Responses to SpecificComments
HISTORIC, ARCHITECTURAL AND ARCHEOLOGICALRESOURCES
2-7
. . .n
venj higlily regnrded, but he is deceased, the lnte Roger King, is n hisforinn. And he
brought to my nttnifioiz that on Route 208 proceeding u p tozonrd the Peddler Hill nren, there is
n rondzuny thnt was changed -Route 208, was chnnged in the 1920s and it goes tliroirg?~n
1700s conetenj. And by using infrored Mr. King 11irnselJhndgone nnd semi that there nre
iitiineroiis bodies of historical significnnce buried in the shoulder ofRoiife 208. ..,.,whichis riglit
nlong the nren where you nre looking to go,.
In response to this comment, local repositories were researched by €PI, cultural resources
specialists for the EIS The information found suggests past re-routing of the road (now Route
208) did occur in the vicinity of a small cemetery and buried remains may have been moved.
(See the response to the comments below for a description of the protocol to be followed to
avoid sensitive cultural resources or mitigate potential impacts should resources be
encountered.) Additionally, the Town of Blooming Grove installed a sewer force main in the
easterly shoulder of Route 208 in this area without any adverse effects (Le.,no human remains
were unearthed).
14-3
regard to Archeologicnl Sites nnd nrens ofHistoric sign$cnnce, reliance on nnecdotal
evidence or genernl trends (e.8“”Native Anierican settleinents or villages tended to be located
nenr critical resozirces, sticlz ns water,flat or gently sloped fertile lands, or vantage points on
the Inndscnpe”) are not sntisfnctoryfor rnitigntion eflorts. I t is higldIj likely thnl‘ czrrreiitly
unknozun locntioiis of historicnl nnd nrcheologicnl irnportniice will be encotrnter~d.“As rond
locntioiis hove chnizged, it is possible tlint some early historic sites are located u d e r current
rondbeds.” Agnin, more specijic plnnning is required and shozrld be delineated i7i the
Eiivironnientnl lnzpncf Stntonent. Also, inore specific plans are required for the knozuii
nrcheologicnl and hisforic sites szich as those on the wesf side of Riley Rond., (USN
#07115.0000706 mid USN07Z15.0000707n77d fhe historic sites nloiig Rt 94).,
Iii
The following protocol will be incorporated as special conditions in the SEQRA Findings to be
issued for this project to avoid adverse effects on cultural resources.
1. The Stage 1-A investigation will be used to assess and identify general areas of
potential archeological or historic sensitivity in the project corridor including
alignment, staging areas, temporary access roads, etc. Maps of the preferred
pipeline route shall also be assessed to confinn that construction will occur in areas
of prior disturbance.
2. For the known archeological site locations and the areas of potential sensitivity
identified in step 1, an evaluation based on construction drawings, USGS
topographic maps, and observations made during a site visit will be completed to
verify those areas that have been disturbed and can be eliminated from further
consideration.
3.
Stage 1 B archeological testing, per Office of Parks, Recreation and Historic
PreseIvation (OPR“) guidelines, will be conducted at sites or areas of sensitivity
within the preferred route that cannot be documented to have been disturbed. The
2-33
Section 2
archeological field-testing will be done sufficiently in advance of construction to
allow appropIiate consultation regarding potential impacts to archeological sites.
4. When Stage 1B evaluation results in the discovery of archeological materials,
additional investigation will be carried out to determine the extent of archeological
site integrity and significance. OPRHP shall be consulted and given the
opportunity to review and approve avoidance or mitigation plans prior to the start
of construction in the area
5. ‘Theimplementation of the work identified in steps 1-4 will be administered by a
35CFR61-qualified archeologist.
The New York State Office of Parks, Recreation and HistoIic PreseIvation has concurred in
the foregoing protocol to address any potential adverse impacts on cultural resources. ‘The
letter received from the New York State Office or Parks, Recreation and Historic Preservation
is included in this document as Appendix C.
17-6
Although Appendix “B” ofthe DEIS contnins a Stage 1 - A Culture Resources Report by n
professional nrchaeologist, that Report recommends a Stage 1-B sfudy in selected areas d o n g
the pipeline where there is n potential for the remnnnts of abnridoned mill sites. However, i f is
unclear whether this study should consider areas used for staging construction equipment, ns
well ns pump sfntions that may be necessary dong the pipeline route. Plense address this
question and providea revised Report ifthe current did not consider these nreas. Additionally,
the Stage I - B study must be completed as ynrt of prepnration of any revised D E E or a n F E E .
The Stage 1-A Cultural Resources Report contained in Appendix B to the DEIS includes
procedures to be implemented in areas such as the contractor’s staging area. This discussion
is contained on page 31 of that Ieport. In summary, where the contractor‘s staging area
would be located in an area that may be sensitive for historiclarcheological resources, the
report recommends the use of either a geo-filter on the existing grade or depositing a few
inches of topsoil so that a distinct horizon is formed and the potential for impact to these
resources is avoided,. These areas would be restored and not reused for other purposes once
this project is implemented,.
As clarification, the ‘potential abandoned mill sites’ are located at the major stream crossings
only, as these are water-dependent structures. The Stage 1-A report recommends that these
areas have limited monitoring of excavation conducted only within the zones specifically
sensitive for histoIic mills (as noted on Figure 3-19 of the ELS)..
The protocol descIibed in response to comnient 14-3 will be incorporated as special conditions
in the SEQliA Findings to be issued for this project to avoid adverse effects on cultural
resources.
As noted above, the New York State Office of Parks, RecIeation and HistoIic Preservation has
concurred in the foregoing protocol to address any potential adverse impacts on cultural
resources. ‘The letter received from the New York State Office or Parks, Recreation and
Hiisto~icPreservation is included in this document as Appendix C.
2-34
i
Seclion 2
Responses lo Specific Commenls
POPULATION/DEMOGRAPHICS
15-2
The D E E clniins the proposed Aqtredzrct coiiiiectioii is needed to support the Villngefor the
next 20 yenrs, but does not provide projections of the popzrlntioii for the next 20 yews.
16-23 TJ7e D E B lncks ndeqzrnte doctrineiitntioii qnnntifjiiig current ngninstfiitzrre groroth. Our
recominendntioii is thnt Section 1 2, "Need," inclirde some elnborntioiz oiifutirregrowth,
ideally using a qzrnntljcinble inethodolopj and projected out in timefor n rensonnble period
related to the liinitations ofthe proposnl.
17-2
The DEIS fnils to provide niiy popirlntion projections
Population growth in Kiryas Joel is now almost entirely internal, meaning it results from
births occurring within the Village rather than from people moving into the Village Analysis
of age distribution data from the 1990 Census and the 2000 Census indicates that the internal
component of population growth in Kiryas Joel between 1990 and 2000 was approximately 5
percent per year.
The table below shows population projections for Kiryas Joel based on continuation of the
internal growth rate of 5 percent per year indicated by US. Census data.
Year
Projected Population
2005
16,800
2010
21,400
2015
27,300
2020
34,900
2025
44,500
The proposed Aqueduct connection is needed to meet the water needs of the projected
internal growth of the Village population
SEQRA requires a statement of need for the proposed action solely in order to provide the
lead agency something to balance against the action's unmitigated impacts in its SEQRA
Findings Statement The Village has identified a need for an additional reliable water supply
given its current demand and the limitations on its current groundwater supply SEQRA
does not require the EIS to make any further determination of need, or future forecast, than
that. To project water supply needs over 25 years, as one commenter suggests, is the type of
speculation not required by SEQRA.
The only unmitigated impacts to balance, if any, will be the short-term construction impacts.
These shoIt-term impacts will be the same regardless of whether the Village need exceeds its
capacity in the future 5,10, or 20 years from now
2-35
Section 2
3-5
Once yoti hove the nquecluct wnter, zvlrnt hnppens to the clemogrnphic mnke-up ofthe town, the
Village, or the community?
Tlie proposed Aqueduct connection is not expected to have any impact on the demographic
makeup of the Town of Monroe, the Village of w a s Joel, or the larger cornxnbty
2-36
i
Section 2
Responses to Specific Cornmenis
FISCAL IMPACTS
17-9
Plense provide nnd compnre tlre projected costs,for the design, coizstriiction and the yearly
operntions ofthis ronter siipply project nnd the nlternntives disciissed.
As stated in the DEIS, the total estimated cost of the proposed Aqueduct connection project is
$25 million. This estimate consists of approximately $3.9 million in the design, permitting and
financing phase and approximately $21.9 million in construction phase costs. The estimated
annual operation and maintenance cost is $570,000 per year.
As stated in the DEIS, reducing the pipeline diameter from the proposed 24 inches to 18
inChes would reduce the construction cost by approximately $1million, or 4 percent of the
estimated project cost. Use of a smaller pipeline would increase the projected electrical cost of
pumping water through the pipeline, approximately $140,000 per year, by approximately 10
percent.
As stated in the DEE, selecting either of the alternative pipeline routes would not
significantly affect the cost of the project.. Similarly, siting the pumping station on New York
City p r o p e q near the New Windsor water treatment facility instead of at the New Windsor
facility would not significantly affect project cost.
27-10 PIcnse describe the impacts ofthe proposed project on the Villnge's nninicipnl budget. Plense
also include the yearly opernting costs nnd debt pnyinents of mrrintnining the existing rue11
fields on stnndby.
As stated in the DE,IS, implementation of the proposed Aqueduct connection would increase
the cost of the Kiryas Joel water supply system, because the existing groundwater pumping
system would be maintained as backup to the Aqueduct connection.,Approximately one
quaIter of the existing water cost of $2,75per thousand gallons is the cost of electricity to
operate the existing groundwater pumps. Implementation of the proposed Aqueduct
connection would largely eliminate this component of current water costs. Overall, it is
estimated that the proposed Aqueduct connection would increase the cost of water in Kiryas
Joel by 10 to 15 percent
2-37
Section 2
Responses to Specific Cornrnenis
COMMUNITY FACILITIES
9-1
Eiistiriiig thnt children have a home thnt is complete with bedrooms and access io zonter and nll
of the ofhm issires are the most important nlviroiimenf to me,. Environment ofthe home.
Eiivironmeiit ofthe commtinity.
I h e purpose of the proposed project is to provide a reliable and adequate supply of highquality potable water for the residents of the Village of Kliryas Joel.. The water supply will
reduce vulnerability to drought, reduce the dependence on groundwater and minimize
conflict and competition fox water among sumomding communities. 'Ihe proposed Catskill
Aqueduct Connection will pIovide a vital facility for a livable environment in KiIyas Joel.
2-38
i
Section 2
Responses fo Specific Comments
LAND USE/ZONING
17-4
The DElS does not provide n copy o f f h e Villnge's Master Land Llse Plan or Zoizing Mflp
shozoing the remnining trndeveloped or tliiderdeveloped parcels in the Village thnt could be
developed with Z U n f e r f i O i r I this pipeline. The
nko does not indicate zuhether this proposed
wnter line, and thefuture development thnt zuotild result from it, are in keeping zuith thnt
Master Plai?. The DEIS should identft) nll undeveloped or tinderdeve!oped parcels in the
Village, their nllownble land use uiider the locnl zoning plan, nJ?d the number ofizew residents
thnt could be allowed f a l l this land were developed.
An analysis by the Village of Kiryas Joel has determined the approximate number of new
residents for whom housing could be provided within the existing borders of Kiryas Joel. The
analysis indicates a total of 185.4 acres of developable land, which could accommodate 1,447
to 1,781 dwelling units., This would provide for 8,306 to 10,223 new residents.,Future options
the Village may consider include changes in zoning to allow greater housing density, and
adding more land to the Village..
1.5-8
Urider larid use analysis, Figzrre 2-12 tised USGS satellite image?') to denote the uses along Ihe
proposed nquedirct routes. More detailed and nccurate dntn is nvailablefiom Ormzge Couizty
Water Authority. W e believe thnt ?the DEIS considered the land use data nunilable from
OCWA, t h q zuotrldfind that n grenfer dmsihj of residential nnd nonresidential uses exist
nlong some of the State and Coiinty corridors. We reqtrest thnt the land use nnnlysis be
repeated with the OCWA dntn.
Data available from OCWA were used as much as possible in the DEIS. More accurate land
u s e mapping does not appear to be available from OCWA. The mapping prepared by USGS
based on satellite imagery, which appears in Figure 2-12 in the DEIS, is the best regional land
use mapping available.
2-39
Section 2
TRAFFIC
1-3
My people in Blooming Grove are vm]concerized that no matter which way it (the pipeline)
goes (..it's going to have a tremendous impact on our traffic sittintion over there. W e have
one-way in and one-zoay otrf of Blooming Grove and that's Route 208 and Clove Road, which is
,,
27.
Pages 2-60 to 2-69 of the DEE contain a complete discussion of existing traffic conditions,
potential project impacts on traffic and recommended mitigation measures. The conclusions
of the analysis are that with implementation of the recommended mitigation measures (i,.e..
alternating one-way traffic; work hour reshictions; public notifications; signage), traffic
impacts will be minor and temporary and significant adverse impacts will not occur.
Note: This comment-response is also included in the Town of Blooming Grove/ Supexvisor
Charles Bohan response category on page 2-51,.
2-5
. .~yoiirreferences in the DEIS say that Route 27 terminates at Mill Road and that leaves n
sniall section ofland, the rope ojClove Road that continues to connect with Route 94. I think
you want to check and see if that is or is not a town road, becatrse ifRoufe 27 terminates, what
is left is obviotisly going to be a town road.
The commenter is comet. Route 27 terminates at Orrs Mill Road (County Route 20). The
section of Clove Road between State Route 94 and County Routes 27 and 20 is a town road,
2-6
...I live on Route 208. It's n grozuing community. Your notation is of16,500 in trafic and I
think that is probably tinderestinzated. The t r a i c on that road in the morning and evenings is
very substantial.
'Ihe Average Annual Daily Traffic (AAIX') foI 2001 reported by the New York State
Department of Transportation is 16,500 between the intersection with U.S. Route 6/State
Route 17 and the intersection with County Route 27,. Because AADT is based on actual traffic
counts it is not an underestimate. Morning and afternoon commute hours are the peak hours
for traffic. Up to 10% of daily traffic typically OCCUIS during the morning or afternoon peak
hour. It is because of this increase in traffic during commute hours that construction
reshictions aIe anticipated to be specified for the morning and aftemoon commute hours.
13-3
The proposed routing will sign$cantly increase the traffic congestion in the Town dtiring
constniction, especially along Route 208, Clove Road and through Salisbury Mills. Please
address how these safety and trafic congestion concerns will be mitigated.
Based on the analysis in the DEIS, the increase in traffic congestion during conshuction, while
unavoidable, will not be significantly adverse with the implementation of the traffic control
measures described in the DEIS.
Tmffic safety and congestion mitigation recommendations are addressed in detail on pages 268 and 2-69 of the D E E Site-specific measuxes along particular sections of the pipeline
routing such as through Salisbury Mills and along Clove Road (CR 27) and N Y S Route 208 in
2-40
(
Secfion 2
Blooming Grove will be developed in consultation with the Town of Blooming Grove officials
during detailed design to reduce traffic impacts on the community
Note: This comment-response is also included in the Town of Blooming Grove/ Supervisor
Charles Bohan response category on page 2-51..
15-10 The DEIS discirsses possible restrictiolls prohibiting constrnctioli diiring com~ntrterhotirs.
Tlzis sliotild d@nitely be ident$ed ns a required ~nitigntioizon all Stnte and County roads.
Careful plan~zingiieeds to go into work schedules, not$jing the public ofwork schediiks nrtd
detours sons to be less disrnptiue io thegniernl public.
Agreed., Careful planning and necessary restrictions during construction will be developed
during detailed design and included in the construction contract requirements., Specific
construction restrictions during morning and afternoon commute hours (such as maintaining
two lanes of traffic) are anticipated for the proposed project.,
15-24 I n reviewing the nlternntive nnalyses, it ions not 7nnde clear wltnt inzpacts to trnflcflow coirld
be niiticipated for end7 nltmintive co~zstrtictioriroute. T%isis extremely inzportnnt for Rt. 32
nlternntiues becnnse the Rt. 32 corridor is nlrendy over its d e s i p cnpacity a17d e.yeriences low
levels of service. W e strongly belitwe that the environmentnl impnctsfi07n purstring the
nlternnfe routes has not been exnirtined nt nn ndeqtinte level ofdetnil. If the project sponsor
intends to ptirsiie either nlternnte routes, 7niich more n~zalysisrniist be provided with the
opportunity to respond to this prior to the FEIS. For exnmple, the enuiron~nentnlreview
should incliide n "hard look" nt iinpncts to trnficflozu, incltiding trnflcflow nt intnsections
both sotrth nnd north of'nrens of co~zstrtrctio~z.
Ifthe prefclred route is uin Blooming Grove then
there is I J O need to pirrsiiefirrther impact n~znlysison the other nlternnte rolrtes.
The preferred route for the pipeline is via Routes 94,27, and 208 though the Town of
Blooming Grove.,
16-14 Pnge 2-64 states thnt the intersectiofi O f N Y S Route 208 and CR 27 is controlled with n trnfic
sigfznl. TlJnt is in error ns the intersection is controlled with n stop s i p .
The commenter is correct. The intersection of N Y S Route 208 and CR 27 is controlled with a
stop sign at the CR 27 approach.,
26-13 On page 2-64 is n list ofthe AADT for roads along the coiistrticfionpath. However, the DEIS
fails to show the A A D T f o r thefirst 2 miles o f C R 27 starting nf the irrtersectioiz o f C R 27 and
N Y S Route 208. The AADT for thnt stretch of CR 27 is 5060. The AADT for the balance of
C R 27 is shozun ni7d is approximntely 3300,.
The comment, from the County Deparhnent of Public Works, is acknowledged. The AADT
for the stretch of CR 27 starting at N Y S Route 208 of 5060 does not change the traffic impact
analysis for this section of the proposed project pipeline construction.
2-41
Section 2
NOISE
15-11 There semis to be an inconsistenaj in the document concerning noise and hours of
construction. ‘TheDEIS states that as n mitigation thnt “...nighttime and weekend
construction zuotrld be avoided to the maximum extend (sic) possible.” However, as a
mitigation to traffic the DEIS states that ”. . .consideration would be given to utilizing
nighttime construction to help minimize traffic.” We recommend that the DEIS provide
critmja for detenniningarens of the pipeline route where nighttime constrtiction may be
preferable. Nighttime and weekend construction schedules should balance the needs to
commuters with the needs for limited noise in residential areas thnt could interfere with
people’s sleep and work activities.
As stated on p. 2-69 of the DEE, nighttime conshuction does not appear to be necessary.. No
areas along the pipeline route have been identified at this time where nighttime construction
would be preferable. Weekend construction is not anticipated either. This is consistent with
the recommendation in Section 2-11, Noise, to avoid nighttime and weekend conshuction to
the maximum extent possible.
Nighttime construction would be considered only if daytime traffic conditions require it. This
will be evaluated further during design; however, based on current traffic conditions, placing
restrictions on construction during normal commute hours is expected to sufficiently address
daytime traffic control such that nighttime constntction can be avoided
15-12 Weftrrther request thnt constrnction on weekends or during commtiter hours be expressly
prohibited veither of the other alternnte pipeline routes ore considered.
Comment noted,, The alternative pipeline routes, which partially pass through the Town of
Woodbury, are not being considered as the preferred alternative at this time.
17-25 The evnluation of Locnl Noise regulations in Section 2.11.2.1 does not inclirdenny noise
regulations for the Village of Kinjas Joel. Please provide them and analyze how potential
sources ofizoise can meet these regulations or wotrld have to be mitigated to meet them.
The Village of Kiryas Joel noise law (Local Law No. 4 of 1993, as amended) contains
provisions relating to prohibited noises, permitted noises, sound device prohibitions,
violations and remedies and enforcement,. PeItinent to the proposed project is the prohibition
of 1)construction, including excavation, demolition, alteration or repair, of any structure
otheI than between 800 a.m. and 8 0 0 p”m.,except in case of urgent necessity in the interest of
public safety, 2) the creation of a loud and excessive noise in connection with the loading and
unloading of any vehicle, and 3) the discharge into the open air of engine exhaust except
through a muffler 01similar noise-attenuating device. Sounds created by public utilities in
caIIying out operation of permitted franchises are permitted. Thew are no numerical sound
level limits prescribed in the law.
2-42
Section 2
Based on the foregoing, construction and operation of the project is anticipated to comply
with the Village noise law.
17-26 The eunliintioii of 1.ong-TennNoise inipncts in Section 2.11.4.2 of the DEIS does not prouide
bnckground iioise snmpliiig datafor the proposed Water Trentmnrt P h i t site within the
Villnge. It also does not identifiJ the lienrest residentid receptors Ofiioise or their distnncefiom
the property line of the proposed plant site. Plense prouide this ii?formatioiz and revise your
eunlziation appropriately.
Background noise in the vicinity of the proposed water treatment plant site is expected to be
similar to monitoIing location 1, near the New Windsor treatment plant site., At that location,
the measured L.eq sound levels ranged from 57 to 59 dBA
The nearest residential receptors to the proposed site are the boarding students at the UTA
Mastiva rabbinical college about 100 feet across Berdichev Road from the proposed plant site
property line (see DEE, p 2-54).. The nearest houses are on top of a hill overlooking the site,
about 300 feet from the property line of the proposed plant site., At these distances, a minor to
moderate increase in noise (3 to 6 dBA) is pr'ojected. No significant noise impact is
anticipated.,
17-27 As disciissed enrlier, there is no detailed locntioir may or site plnnfo? the proposed plant nnd no
wny to understnnd whether the new plnizt is closer to residentid receptors. Witkout this
informtion, it is V ~ d$fficzilt
J
to i77depe~1delitlyevnlziate the conclusion in this section ofthe
D E E that there zuill iiot be n noise impact. It also does iiot explain how the estimated
ninxinitim opernting soiind level of GO d B A nf the property line wns determined.,
The new treatment plant is proposed to be located on the existing Village water treatment
plant site., Although a site plan has not been designed for the project yet, the new plant is
expected to be adjacent to the existing plant building and would be the same distance from
the rabbinical college and residential receptors as the existing plant.
The estimated maximum operating sound level of 60 dBA at the property line actually
pertains to the proposed pumping station in New Windsor and is a pIoposed specification to
be met in the project design to achieve compliance with the Town of New Windsor noise
ordinance.,
2-43
Section 2
VISUAL
17-11 T/ie DEIS does not provide a Visual Irnpnct Analysis ( V I A )for the proposed Water Trenntment
Plant, Piimp Station or dong the pipeline route ....
17-12 DEIS does not identi& nny nreas nlong the proposed pipeline route wlzere trees and shrubs zuill
be removed and whether they c u ~ e n t l act
y as a vistrnl buffer for residentinl or other lnnd wes.
PIeflse identif?l and disciiss the benefits impacts ofrestoring all sigrzificant strnnds of trees
and shrubs, shortly after construction is completed.
NYSDEC‘s Guidance or1 ”Assessing and Mitigating Visual Impacts” (DEP-00-2) states under
heading III, Policy; ’‘When a facility is potentially within the viewshed of a designated
aesthetic resource, the Department will require a visual assessment, and in the case where
significant impacts are identified, require the applicant to employ reasonable and necessary
measures to either eliminate, mitigate, or compensate for adverse aesthetic effects.”
The proposed Catskill Aqueduct Connection project does not require a VLA because the
proposed facilities to be constructed are not within the viewshed of any designated aesthetic
resource- The pipeline route is to be constructed in existing roads and road shoulders, in
existing rights of way; therefore, few or no trees or shrubs will be removed before, during or
after construction. Should it be necessaIy to remove any foliage that act as visual buffers for
residential or other land uses, the disturbed areas will be re-vegetated promptly to restore the
buffer. Furthermore, the pipeline will typically be underground and have no long-term
impact on visual aesthetics. In instances where the terrain requires the pipeline to run along
side of bIidges it will be painted to harmonize with its sumoundings.
In choosing the preferred locations of the pump station and water treatment plant, visual
aesthetics played a role.. As stated in the DEE, construction of a connection to the Catskill
Aqueduct and a pump station near the New Windsor water treatment facility would be
consistent with existing land use. Construction of a new water treatment facility at the site of
the existing Kiryas Joel water treatment facility on Berdichev Road would also be consistent
with existing land use. Both prefened locations are in areas that already house similar
structures and project development would require limited disturbance to natural lands and
visual aesthetics.
The proposed action includes a pumping station in the vianity of the New Windsor treatment
plant and pump station. As the New Windsor treatment plant site is dedicated to water
treatment and pumping activities, the proposed action would be a continuation of its current
use. The site and adjacent area (a tower line easement) is generally free of trees and shrubs,
which will limit visual impacts mainly to construction only. ‘Ihislocation is not in the direct
line of sight of any residences and is only visible to individuals traveling along Riley Road in
the Vails Gate section of New Windsor.
The pIoposed action also includes a Water Treatment Plant adjacent to the current water
treatment plant used by the Village of Kiryas Joel. Located across Berdichev Road from the
UTA Masivta rabbinical college, the proposed site is a fenced parcel and curIently supports
2-44
Section 2
Responses fo SpecificCommenfs
the Village of Kiryas Joel’s operating water treatment plant and former heatment plant A
limited number of individuals will have a clear view to the proposed site; these are the
boarding students at the UTA Mastiva rabbinical college about 100 feet across Berdichev Road
from the proposed plant site property line (see DEE p 2-54) The nearest houses are on top of
a hill overlooking the site, about 300 feet from the property line. Trees between the treatment
plant parcel and the residential units provide a visual buffer One alternative is to demolish
the former plant building and replace the struchlre with the proposed water treatment plant
Tlus would reduce visual impacts to an even greater extent because it would simply replace a
former structure rather than add a third. Development on the treatment plant site would
require minimal or no tree removal, minimizing long-term visual impacts to the residences
The treatment plant location is not in the direct line of sight of major roads
2-45
Section 2
ENERGY
15-17 Whnt is the electricity currently consumed to run all ofthe Villnge’s wells?
Electricity usage to operate the Village wells incurs an energy cost of approximately $0.70 per
thousand gallons,.At $O,.lO per kilowatt-hour, this translates into 7 kilowatt-hours per
thousand gallons. ‘TheVillage of Kiryas Joel currently yields 1.3lmgd of groundwater, the
sum of the 0,308mgdfrom the Brenner property wells and 1.0mgd hom wells within the
Village. Therefore, with a consumption rate of 7 kilowatt-hours per thousand gallons,
approximately 9170 kilowatt-hours per day is used when all the wells that support the Village
are in operation
15-18 Bnsed on our [the Town of Woodbun/]cnlciilntions in less tlznii 15 yenrs the Village zoill need
to nin existing wells in nddition to the nqueduct to support the jittire poptilntion. How much
electricity would be needed to run the wells, the well zonter trentmeiztfncilities, the nqueduct
pump stntion, nnd the nqueduct zuater treatmentfncilities?
Because the facilities have not yet been designed and an energy system has not yet been
developed there is not enough information to determine the total amount of energy required
to run the weUs, the well water treatment facilities, the aqueduct pump station and the
aqueduct water treatment facility simultaneously,.
15-19 On considerntion ofthe recent electricnl problems thnt were experienced ncross the enst const
nnd the occnsionnl oiitnges thnt occtir yendy, zohnt methods cotild be e-xplored to tnitignte some
of this significnnt electricnl consumption? Could solnr energy be intepnted into the systnn?
Would additionnl zunter stomge tank cnpncity help to mitigate spikes Ofhigher electricnl
consumption nssocinted zoith penk wnter demnnd?
At this stage in the project, the energy design has not yet been completed. A main objective
during design will be energy efficiency and alternative sources will be considered including
solar energy; however, it is unlikely that solar power will be used as an energy source in the
operation of the pump station or water treatment plant.
In addition to the nine active groundwater wells in the Village and the five wells located on
the Brenner property, the Village’s cunent water supply infrastructure includes four storage
tanks, approximately 11miles of transmission mains,and two treatment plants. ‘The
proposed project does not include additional storage tanks. Furthermore, the Village is
currently in the process of designing a 2 million gallon capacity storage tank to provide
additional water storage. Future water projects may involve tank expansion or tank
construction; however, for the purpose of this project, additional tank capacity is beyond the
project’s scope.
15-20 How would the ndditionnl popttlntion supported by the incrensed water supply contribute to an
incrense in electricnl consumption?
2-46
Secfion 2
As stated in section 6 of the DEIS says, the proposed connection to the Catskill Aqueduct is
not anticipated to be the direct cause for growth in Kiryas Joel and its surrounding
communities. Therefore, increased residential energy consumption is not anticipated to result
from the proposed aqueduct connection project.
15-21 In fhe cnse of n11 extended blackout, such ns the one recently experienced, will there be n back-up
generntor to inaintnin zuntn setvice to the commtiizify nnd to reduce the potential zunterhninmn as described iiz the DEIS? Shoiild electricity fail, how long woiild stornge water last
nizd shotild expanding the Villages volumes be explored?
Should an energy failure occur, both facilities, the pump station and water treatment plant,
will have back up generators to continue operation. Should electricity fail for an extended
period of time, the stored water should last for several days with a water management plan in
place.
26-20 On pnge 2-6, a 24" diameter pipeline is justified due to energy cost snuings. For the proposed
ratite has a system head cziive for the 13-nziles of 24" dinnreter pipeline been generated and can
it be provided forfiirther reuiezu? Wlmt is the cost effective, nrnximtrin cnmjing cnpncify of the
proposed 24" dianzeter x 23-mile long pipeline?
A system head curve has not been generated for the proposed route. It will be generated
during the design phase after the locations of the pump station and water treatment plant
have been confirmed.. Pumping costs were estimated for the 2 mgd flow based on an
estimated daily energy requirement for three different pipe diameters, 12", 18" 24", along the
proposed route. At a flow rate of 2 mgd a pipe diameter of 12" would consume 7272
KWh/day. The cost per day would be $691 or $252,140 annually. An 18" diameter pipe is
more efficient with a requirement of 4391 KWh/day and costs of $417 per day and $152,253
per year The 24" diameter pipe is the most energy and cost efficient with a daily energy
requirement of 4040 KWhlday, This energy cost is $384 per day or $140,076 per year.
2-47
Section 2
SOLID WASTE/ SLUDGE DISCHARGE
16-17
The type oftrentmeizt required at the n m zunterjiltmtion plnnt zuill genernte rnw sltidge thnt
will require handling nnd disposnl. How zuill the raw sludge be hnndled and tiltiinntely be
disposed of? Whnt dnily voltiirie of raw sludge will be produced? What percent solids will the
rnzo sliidge consist of nnd zuhnt elements will the raw sltidge consist of?
Sludge produced by the new water filtration plant will be treated in the same manner as
sludge from the existing plant is currently treated. That sludge is thickened and transported
to a wastewater treatment plant for treatment and disposal. The plant will most likely
produce alum sludge, a coagulation sludge that is common for plants using alum
(polyaluminum hypochlorite) as a coagulant. On average 48kg of alum sludge/1000m3 of
water is produced. 'Therefore, the new water filtration plant will produce approximately 801
Ibs/day or 292,365 Ibs/year. The composition will most likely consist of 15-40%A1203 x 5.5
H20 (aluminum hydroxide and bound water), 35-70% silicates and inert materials, and 1525% organics
2-48
i
Section 2
HAZARDOUS WASTE
1 22
The DEIS stnfes thnt “Because ofsinnll qiiniztities of{polyalunrinum chloride nizd sodiunz
hypoclilorifel iizvolved liiz w t e r treatmenil, even n sudden arid complete tnnk fniltire zuould be
unlikly to cnuse significnnt henlth problems in tlie time if would fnke to evnciinfe the nffected
nren.” The nffected nren should be described. Will the nffected nren include n i y lnnds locnted
ndjncozt to or zoifhin the boziizdnries of Woodbtiiij?
The nearest boundary of the Town of Woodbury is approximately 2 miles east of the
proposed site of the Water Treatment Plant. Therefore, in the unlikely event that the facility
experiences tank or operations failure the Town of Woodbury and lands located adjacent to or
within the boundaries of Woodbury will not be affected. The affected area would not extend
beyond the treatment plant grounds. Should a hazardous situation arise, immediate response
personnel will be notified immediately to assess and control the situation., Prior to start up of
the water treatment plant, an emergency response plan will be filed in compliance with
applicable laws.
Both treatment materials, polyaluminum chloride and sodium hypochlorite, will be stored in
liquid form and in storage tanks at the Water Treatment Plant minimizing the likelihood that
a tank failure will affect areas offsite. Sodium hypochlorite used in liquid form produces
minimal chlorine air emissions precluding potential effects on sensitive receptors in the study
area. Sodium hypochlorite is the coagulant used at the Harriman Wastewater Treatment Site..
Polyaluminum hypochlorite is a stable chemical that will be used in small quantities as a
coagulant in the water treatment process. Under normal conditions the chemical is stable
and has minimal health hazards (eye, skin, mouth, throat, stomach irritation); under
exeemely high temperatures (e.,g., fire conditions) the chemical may release hydrochloric acid
vapors; at such time immediate response personnel would be notified.
2-49
Section 2
CONSTRUCTION
17-17 Please discuss coizstrtictioiz iinpncts on the nqtiedtrct itself. What is theage of the aqtredtict nt
the locntion o f f h e tap? What is a potentinl for short-term or long-term damage to the aqtiedtict
dtiriizg constrtiction of n connection to it? Whnt nltemntives nre nuailable thnt zuotild redtice or
completely avoid disturbance ofthe aqiiedtict itselfiiz order to obtain the water?
The Catskill Aqueduct was constructed between 1907 and 1917. While there is potential for
damage to the aqueduct during the construction of the connection, standard construction
methods would be used in order to minimize this potential. Prior to construction, detailed
reviews of the project’s construction plans and specifications will be conducted by the City of
New York DEP and other regulatory agencies. Numerous standard practices will be built into
the construction documents to minimize disturbance of the aqueduct and environment.
Frequent construction inspections will be conducted to assure that proper procedures and
protocol are carried out during the project’s construction,. With the above in place, minimal
disturbance to the Catskill Aqueduct will OCCUI‘.
17-18 Please indicnte how much area zvotild be needed to temporarily store constrtiction rnatnials
dong the pipeline. Please disctiss where excess excavated matm’nls be disposed of nnd how will
the Villnge veri& that mntnials will not be disposed ojin any state orfiderally regulated
wetland area?
17-21 Please discuss how mnny cubic ynrds of excess soil, rock, nsphnlt, concrete, etc. will be removed
porn the work corridor and where zoill it be disposed oj?
Construction planning would be completed during the design and permitting phase of the
project,. At that time, staging and disposal areas would be determined. Materials excavated
during pipeline installation will be backfilled to the greatest extent possible limiting the
amount of materials that require stockpiling or transport.. Removal and disposal of excess
materials and fill are the responsibility of the contractor and will be conducted in accordance
with state and local waste disposal protocols. No disposal will take place within a wetland
unless the proper wetland fill permit weIe obtained; it is not anticipated that disposal of fill
material in a wetland area would be necessary,.
17-19 The DEIS did not disciiss whether any ptinrp stations would be needed along the 23-7nile ratite,
the locations ofpiimp stations, the dimensions stich pump stntions and construction or
opernting impacts of these piimp stations.
Other than the single pump station located at the aqueduct connection site, no other pump
stations would be required along the pipeline route.
2-50
Seclion 2
PII'E,LINE ROUTE
10-1
We h u e no objections to the doctiinent [DEIS], and conciir with the prSfened nlternntive
route.
25-31
Should the desired route chnngefio~nthe preferred route presented in the DEIS to OJIC ofthe
nlternntive roiites we ask thnf the colnniunities involved in the 17ewly prSfmed route be given
the opportunity to respond to a reuised plan.
Comments acknowledged.
2-51
Secfion 2
Re,spon,sesto Specific Comrnenfs
VILLAGE WATER TREATMENT PLANT SITE
17-16 Please provide a site plan for each alternative location considered. Please provide a disctrssioii
of the miriirniini sqtiare footage (or acreage) needed to construct a water treatment plant of the
size asslimed necessnnj for this project. Please include a tlrorozrgh search ofall vacant lands
near tl7e fet7ninirs of the pipeline in the Village that meet this minimum size criteria.
As noted on page 3-5 of the DEE, the new water treatment plant would require
approximately 1acre of land. The Village’s current water treatment plant site on Berdichev
Road was identified as a logical candidate because it is located near the alternative pipeline
routes and it is land currently owned by the Village of Kiryas Joel that has already been
identified for water supply use,
Use of the Village’s current water treatment plant site for the construction of the new plant to
treat Catskill Aqueduct water would represent a continued use of this site. Currently, treated
water enters the Village’s dishibution system at this location making this a logical location for
the construction of the new plant. The location on the filter plant site for the new plant is
currently a parking area and storage area for trailers. Limited clearing of natural vegetation,
if any, would be needed to construct the new facility .The most feasible candidate ‘alternate’
treatment plant site, based on a search of suitable available vacant lands in or near the Village,
is located on the eastern side of the Village. New construction east of the Village’s boundary
would require additional pipeline construction to allow the treated water to enter the existing
distribution system ‘Thiswould represent an added capital cost and disturbance to the
natural environment over that as described under the ’proposed action’.
i
2-52
Section 2
ALTERNATE PIPE SIZE
3-2
...ifthe zunter supply is oizly,for 2 inillion gnlluns rue kind of do not see tlie point as to why the
line should be 24 inches. . .Some rensuns are given zuere given iiz the PEIS, but zue belieue more
reasons need to be done to j t i s t ~ that
j
15-28
I n support of a 24 inch diameter water main, the PEIS iizdicates flint it is needed to sntisjii the
20 yenr design period (and tu snue nierpj). I t also notes tlnt iizfrnstriicture oftltis time is
ustially in service for a ininimiim of 50 years, often closer tu 100 years.. . Althozigh an 18 inch
diameter pipe could provide 2 MGD, the hend-loss nf 4.2 M G D wotild begreat and most likely
zuoiild require a second booster pump station. Hozuever, 4.2 M G P could be transnzitted easily
through a 24 incli diameter pipe.
The project as proposed includes the use of a 24inch diameter pipeline to transmit up to 2.0
mgd to the Village of Kiryas Joel. This pipeline diameter was initially presented to the
NYCDEP in the concephk plans for this project. Given that the pipeline will have a service
life of 50 years or more, the choice of pipeline diameter was based not only on the Village’s
current aqueduct entitlement request of 2 mgd but also on potential future entitlements due to
future growth. Also considered was the fact that reducing the pipeline diameter would not
reduce environmental impacts, Trench size, construction duration and potential
environmental impacts would be the same for a 24-inch diameter pipeline as for any other
size pipeline. Nevertheless, due to concerns that the pipe is oversized, a reduction in pipeline
diameter to 18 inches would be feasible,,
2-53
Section 2
Responses to Specific Cornmerits
TOWN OF BLOOMING GROVE/ SUPERVISOR CHARLES BOHAN
1-1
I zunnt to determine whether or not niy tozun zuill hnve nccess to the zunter thnt is going tu be
c o m i n g ~ o n the
i nqtiecitict thi otigh nzy toiuii to get to Kiryns Joel
1-2
. i f y o t i nre going to linve n trentrneizt plant nt the Villnge thnt it's bnsicnlly rnzu Tonier, socnlled, tlint is coining thiutigli nzy tozun, zuhicli nienns that f l had to nccess it in nnyzuny I'd
also have tu btiild n trentineiit plnizt That doesn't nznlce very mtich sense; it zuotildjirther
inzpnct nzy prubleni
13-1
We request tlint the DEIS address nllozuing the Town of Bloonzing Groue to tnp the proposed
transmission iriaiiz and ti tilize the wnter ns nri ntixilini~j/sstipplemeritnl/eniergeii~
stipply
dtiring extended periods of drought, or cntnstropliic ineclinnicnl fniltire.
13-2
Tlint the Village of Kiryns Joel consider nn nlternntiue trentnzent plant site to allozu/or treated
water to be conveyed throtigh the transmission main.
,
'The project as proposed does not contemplate any interconnections. Ptoviding emergency
access to the aqueduct water through a connection from the proposed Village pipeline would
require preparation of an application to NYCDEP accompanied by an environmental
assessment of the potential effects of such an action.. 'This type of anangement would work
best if the water were treated at the existing aqueduct tap rather than at a new plant in Kiryas
Joel. Formal consideration of such an action by the Village and other potentially involved
agencies must await prepatation of plans by Blooming Grove and Washingtonville and is
subject to envitonmental review and requisite governmental approvals, including NYCUEP.
I
'The Village, as lead agency under SEQRA, will analyze any changes to the current ptoposed
project in accordance with the law and regulations.
1-3
My people in Blooming Grove nre urn) concei-tied thnt 110 matter zuhicli zuny it (the pipeline)
goes . . .it's going to have n trenzeizdotis impact on otir trnfic sittintion over there. We hnue
one-wny in and one-wny utit a/ Blooming Grove niid thnt's Route 208 nnd Clove Rand, zuhich is
27.
'Transportation and traffic impacts are important issues with this project. Pages 2-60 to 2-69 of
the DEE contain a complete discussion of existing traffic conditions, potential ptoject impacts
on traffic and recommended nutigation measures. The conclusions of the analysis are that
with implementation of the recommended mitigation measures, traffic impacts will be minor
and temporaty and signtficant adverse impacts will not occur,.
13-3
The proposed routing zuill sign$cnntly incrense the trnfjrc congestion in the Tuzuii dtiring
cunstrtiction, especially along Route 208, Clove Rand and through Snlisbtiry Mills Please
address how these safety nnci trnfftc congestion concerns zuill be mitigated,
Based on the analysis in the UEIS, the increase in traffic congestion during construction, while
unavoidable, will not be significantly adverse with the implementation of the traffic control
measures described in the D E E
2-54
i
Section 2
Traffic safety and congestion mitigation recommendations are addressed in detail on pages 268 and 2-69 of the DEIS Site-specificmeasures along particular sections of the pipeline
routing such as through Salisbuxy Mills and along Clove Road (CR 27) and N Y S Route 208 in
Blooming Grove will be developed during detailed design to minimize traffic impacts on the
community
2-55
Section 2
VILLAGE OF WASHINGTONVILLE
12-1
W e request that the DEIS nddress allozuing the Village of Washingtonville to tap the proposed
transmission main and utilize the water as nn nuzilianj/stipplenz~zttnl/enzergetzcllstiPPl1I
during extended periods ofdmuglzt, or catastrophic nzechanicalfailzrre,
12-2
That the Village of Kiryns Juel consider a n alternative treatment plant site to allowfor treated
water to be conveyed through the transmission main
12-3
W e request that the DElS allozu the Village of Washingtonville to supplement the aqiiedtict
water zuhen the excess zvater is aunilnblefionz our wells and during periods of aqziediict
shrrtdozun, since the Village ofKiyns Joe/ wells will not be able to sntisjj tlzefiittire projected
denznnd, as a back-up source.
The project as proposed does not contemplate any interconnections. Providing emeIgency
access to the aqueduct water through a connection from the proposed Village pipeline would
require preparation of an application to NYCDEP accompanied by an enviIonmenta1
assessment of the potential effects of such an action. This type of arrangement would work
best if the water were heated at the existing aqueduct tap rather than at a new plant in Kiryas
Joel. Formal consideration of such an action by the Village and other potentially involved
agencies must await preparation of plans by Blooming Grove and Washingtonville and is
subject to environmental review and Iequisite governmental approvals, including NYCDEP.
With regard to allowing the Village of Washingtonville to provide backup water to the Village
of E y a s Joel when the aqueduct is shut down and Washingtonville has excess water
available, this is a wor thwhile suggestion with positive environmental implications.
The Village, as lead agency undeI SEQRA, will analyze any changes to the current proposed
project in accordance with the law and regulations.
2-56
i
Secfion 2
Responses io Specific Commenfs
TOWN OF NEW WLNDSOR ALTERNATIVES
3-8
PIense discuss why the Villnge wotrld 170t runrit to get their iunterfrom the New Windsor ionter
tap on the nquedtict?
17-7
In accordnnce with nn earlier letterfium the Town of N e w Windsor's Toion Engineer, plense
nddress tlie environmental impacts nnd benefits of not constrtrctiiig n separnte connection to the
nqueduct near the Riley Rond Filtrntion Plant. As the Town hns suggested, plense consider the
benefits and impacts on the Aqueduct itseljofsl~nringthe Town's existing tnp on the nqzredtrct.
Plense nlso consider their other suggestions of construction of n 1in0horizontal tap into the
nqtreduct that could be used jointly by the tzoo municipnlities, lo prevent problems during low
,flow periods in the nqiredtrct. The Village shotild also evalunte the benefits and iinpncts ofjoiizt
use ofan enpnnded Riley Road Filtrntion Plant by the two n7unicipnlities ns cotizpnred to a
sepnrnte stnndnlone Wnter Filtrntion Plnnt for the Village.
Discussions have recently taken place between the Village of Kiryas Joel and the Town of
New Windsor regarding the use of the New Windsor aqueduct connection and filtration
plant The Village is exploring this option with the Town Likewise, such a change will
require approval by NYCDEP Should these discussions result in changes to the proposed
project, the Village, as lead agency, remains obligated under SEQRA to analyze such changes
for potentially significant adverse environmental impacts
2-57
Section 2
Responses to Specific Cornrnenls
?KIDSON RDIER ALTERNATIVF!
11-2
Since a wafer treatment plant is nppnrenfly pnrt of the proposnl nnywny, we suggest that the
prmiously eonltiafed Hzrdson River wafer nltmintive be used instead of tapping into the
Catskill Aqueduct.,
Although it is hue that both the proposed action and the Hudson River alternative would
require the construction of a water tr’eatment plant, the type of treatment facility required is
no2 the same. Because the water quality of the Hudson River is low, specifically, the water is
brackish; a multi-stage treatment process would be required. Desalination would be required,
a process which generates a large quantity of waste (solid and liquid) that would require
additional treatment and disposal.. Pumping water from the Hudson River to the Village
could require crossing Storm King Mountain or other lands with significant elevations.,
Treatment costs and pumping requirements make this option very costly, while the treatment
process itself would generate large quantities of wastes that would require additional
treatment and disposal. Use of Hudson River water as a potable water supply for the Village
is, therefore, not a feasible alternative at this time..
i
2-58
Seciion 2
WATER CONSERVATION
15-30 Uiider ~nitigationthere shotrld be a discussion of zunter conservation planning..I . . " , . Pnge 2-3,
under "Prmioirs Work to Expand the Water Stipply" refermces implnnentation of water
conservation inensures btit does not elaborate as to what these methods are, hozo long they lime
benz in eflect a i d hozu sirccesshrl t h q hnve been.
Conservation measures have been in-place and were upgraded in early 2000. Measures
include: community education, installation and replacement of water meters, a leak detection
program, and the distribution of water conservation kits.. The resident per capita water
consumption rate in the Village is relatively low due to their social practices, which include
the absence of traditional high demand uses such as outdoor swimming pools, outdoor
bathing and car washes,
2-59
Secfion2
IEGIONAL WA'TER PLAN
5-1
.Whnt I woiild like to knozu is given thnt I live in n commtinity in zohich the zuells nre not
ndeqtinte, why there is no comprehensive plan for the wnter supply of nll of the communities
nnd zohy zue nre tnlking nbotit nny Villnge?
8-1
...ifthere is some kind of n water connection thnt willsupply water to one pnrtictilnr nren in
I.
this counhj thnt the entiregotip of people in the county should benble to avail themselves at
the snme price and the same cost to thnt wnter, since in fact, thefedernl nnd stntrfiiizds nre
zohnt is going to create this system.
15-9
A priority nddressed in the Environmentnl lnfrnstnicttire Strntegj section of the Ornnge
County Comprehensive Plnn is to ...."gi
ve priority to regionnlizing water resources by
interconnecting systems. " Wliile the DEIS repentedly stntes thnt neighboring communities
hnve beeri tinwilling to help Kinjns Joel meet its drinking water needs, it nlso stntes thnt these
comniirnities hnve been experiencing growth of their own.___ This hns le? commtinities iriinble
to help ench other with drinking wafer shortnges, and hns resulted in on environment zuliere
communities are constantly monitoring ench other's consumption.. . W e request thnt nnother
alternative be included in the DEIS thnt considers a regionnl nppronch to providing drinking
zunter including nssessing the possibility of pnitnering with neighboring communities to share
the benefits nnd the costs of tnpping into the nqiierltrct nnd withdrnzoing lnrger amounts of
zunter to benefit the region, perhaps only on nn emergency bnsis, such ns during the 2002
summer's drought.
,
16-19 However,there is both n trend ofregionnl growth nizd n s clenr record of interest hi the
neighboring ~ntrnicipnlitiesalong the proposed wnterline regnrdiiigfiiture nccess to this
pipeline nnd/or shnre use ufthe nqtiediict tap,
17-8
Plense discuss ~ J detnil
Z
the suggested nltenintive of shnring pipeline wnter and shnring costs
with other municipnlities along the pipeline route so thnt they too cnn take their own
entitlement water from the New York City Aqueduct system. Plense nlso discuss the
environmental beizefits and impncts of n possible regioiinl nppronch to providing the Neru York
City nititlonetit zunter through the offices of the Ornnge County Government or possibly the
Orange County Water Authority.
SEQRA requires that an EIS evaluate only reasonable alternatives that are feasible,
considering the objective and capabilities of the project sponsor. The objective of the project
sponsor is to provide a reliable water source to the Village. It is unreasonable to demand that
the Village assess and provide for the entire region's needs. Consideration of a regional water
supply alternative or additional taps for other communities is not required and as such would
not be reasonable or feasible for the Village to undertake and such alternatives would not be
under the Village's control (Le",the Village itself does not have the authority to provide such
alternatives)..
2-60
Secfion 2
The Village of Kiryas Joel originally proposed this action for its needs The Village is willing
to cooperate with the County and the surrounding communities; however it is not its
responsibility or within its power to develop a comprehensive regional water supply plan for
the neighboring communities. The Village needs a more reliable water supply now to assure
that the community of E y a s Joel has a viable and safe environment for living
Comprehensive water plans to address the water needs of the Village and the surrounding
communities along with the necessary systems would best be prepared by the Orange County
Water Authority and/or the County of Orange in coordination with the NYCDEP. Such
planning is beyond the scope of this project as well as beyond the Village’s means It should
be noted that only emergency, backup water supply has been requested by neighboring
Regarding the Orange County Comprehensive Plan (OCCP),the Village’s proposed project is
an attempt to provide the water resources needed for its community members while incurring
minimal impacts on the surrounding communities. The OCCP focuses development on
Priority Growth Areas, historic cities, villages, and hamlets and their immediate
surroundings, where public infrastructure such as central water, sewer, and higher capacity
roads exist, or could be efficiently extended to accommodate future growth, The Village of
Kiryas Joel is identified as a Priority Growth Area in the County Plan. The central idea of the
OCCP is to encourage growth that can be supported efficiently and minimizes disturbance to
the rural countryside. The proposed action does just that., As a Priority Growth Area, the
Village of Kiryas Joel is attempting through the proposed project to ensure it is able to
maintain its community and provide a livable environment with adequate water, housing,
schools, etc.,,focusing on already built up areas and developing areas that will have minimal
adverse impacts.,
2-61
Section 2
BEYOND 'IHE SCOPE
The following corrunents have been determiried to be beyond the scope of this environmental
review process. Although the comments raise interesting points or questions, they are not
within the scope of this EIS.
6-2
[We hope1 thnt NYC builds the recommended EPAfiltration plnnt for all its water szrpply
systems, nnd prevents the wastage of lenknge of between 30 and 100 million gallons of wnter a
day, and considers the health and the ecologi/ ofthe rivers ofotir wntershed so we can have 0117
maximtrm ecotowism.
8-3
...as the popzrlation will grozu in this village becnuse of the auailnbility ofwater, shotrld it come
into effect, would this uillagegouen~mentanticipate at a pnrticular point of population
zuithdrazuingfroin the 7own of Monroe?
2-62
i
Appendix A
APPENDIX A
TRANSCRIPT
Public Hearing on the Draft Environmental lmpact Statement
November 14,2003
S T A T E O F NEW YORK
COrJNTY O F ORANGE
:
VILLAGE OF KIRYAS J O E L
:
V I L L A G E BOARD
______________-________-_--_-___-___-__-__---
X
I N THE MATTER
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5
OF
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7
a
P U B L I C H E A R I N G ON T H E D R A F T E N V I R O N M E N T A L
I M P A C T S T A T E M E N T ON T H E P R O P O S E D C A T S K I L L
A Q U E DUCT C 0 N M E C T I 0 N
_______-_--____----_____________________-___-
9
Ezras Choilim Health Center
V i l l a g e of K i r y a s J o e l
N o v e m b e r 14, 2003
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11
12
13
B E F O R E :
ARI
FELBERMAN,
MODERATOR
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15
V I L L A G E BOARD
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ABRAHAM W I E D E R ,
MAYOR
17
ia
SAMUEL LANDAU,
YUDEL KAHAN,
TRUSTEE
TRUSTEE
19
MENDEL SCHWIMMER,
TRUSTEE
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JACOB MITTLEMAN,
TRUSTEE
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22
23
24
ROCKLAND & ORANGE R E P O R T I N G
25
20 S o u t h M a i n S t r e e t
N e w C i t y , Mew Y o r k
10956
( 8 4 5 ) 634-4200
+I
X
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2
2
(
A P P E A R A N C E S :
3
4
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6
JACOBOWITZ L G U B I T S , LLP
A t t o r n e y s f o r V i l l a g e of
158 O r a n g e A v e n u e
P O B o x 367
Walden, N e w Y o r k
12586
BY:
DONALD G . N I C H O L , ESQ..
Kiryas Joel
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8
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C A M P D R E S S E R L M c K E E , INC,.
R a r i t a n P l a z a I, R a r i t a n C e n t e r
08818
E d i s o n , New J e r s e y
BY:
HENRY R . B O U C H E R , P . E . , P . P .
THOMAS S O H O E T T L E , P . E . , P . P .
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12
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WHITEMAN O S T E R M A N & HANNA, E S Q S .
V i l l a g e o f K i r y a s Joel S E Q R C o u n s e l
One Commerce Plaza
A l b a n y , N e w Y o r k 12260
BY:
MICHAEL G. STERTHOUS, ESQ.
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15
ALSO PRESENT:
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GEDALYE S Z E G E D I N ,
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Village Clerk
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I
Proceedings
1
THE MODERATOR:
2
3
Good morning and welcome
3
to the Village o f Kiryas Joel.
4
begin I ask that you please rise and join
5
Mr.
6
allegiance.
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8
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10
Before we
Don Nichol in the citing of the pledge of
[Whereupon the pledge of allegiance was
recited. )
THE MODERATOR:
Thank you..
Allow m e t o introduce myself, my name is
11
Ari Felberman.
12
Governmental Relations Coordinator., The
13
mayor requested that I serve a s the moderator
14
of this public hearing.
15
I'm Kiryas J o e l ' s
On behalf o f Kiryas Joel's Mayor, the
16
Honorable Mayor Abraham Wieder, and on behalf
17
of the Village Trustees; Mr.. Jacob Mittleman,
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Mr. Samuel Landau, M r . Mendel Schwimmer and
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Mr. Yudel Kahan, I thank you f o r joining us
20
today for this public hearing.
21
22
23
Seated on my right are t h e Village's
elected officials that I just mentioned.
And seated to my left a r e the Village's
24
professional staff, allow m e a quick moment
25
to introduce them.
Immediately to my left is
1
Proceedings
4
2
Village Clerk, Gedalye Szegedin; Mr.. Mike
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Sterthous, from the law firm of Whiteman,
4
Osterman
5
other end of t h e table; Village Attorney, Don
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Nichol o f Jacobowitz
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Mr. Tom Schoettle and Hank Boucher of the
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Camp Dresser
&
Hanna, in Albany, New York, at the
&
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Gubits Law Firm; and
McKee Engineering Firm.
Ladies and gentlemen, this is a public
9
10
hearing on the Draft Environmental Impact
11
Statement o f the Village of Kiryas Joel's
12
proposed water supply project.
T h i s project calls for tapping into the
13
14
New York City Catskill Aqueduct i n Vails G a t e
15
i n Orange County and f o r the water t o be
16
transported via a transmission pipeline to
17
the Village of Kiryas Joel.
18
calls for a pumping station and a water
19
treatment plant.
This plan also
T h e Draft Environmental Statement was
20
21
accepted by the Village of Kiryas Joel Board
22
of Trustees as the lead agency o n October 7,
23
2003.
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25
T h i s public hearing is being held in
accordance with Part 617 of the New York
Proceedings
1
5
2
State Regulations implementing t h e State
3
Environmental Quality Review Act k n o w n also
4
as SEQRA - - SEQRA, not secret.
5
I t ' s public.
The purpose of this public hearing is to
6
receive your comments on the environmental
7
issues associated with this project.
8
wishing to be heard, as I mentioned before,
9
should please complete the speaker's cards
I'll then call upon
10
and bring it up to me.
11
you to address the lead agency.
12
Those
I ask that the duration of your comments
13
be no longer than three minutes, this way we
14
will have a chance to hear all opinions and
15
all comments.
16
was already said by a previous speaker I
17
would request that you yield to t h e next
18
speaker.
19
opinion be heard.
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If what you are about to say
Again, for the purpose that every
A stop watch will be reset before every
21
speaker and at the sound of t h e stop watch
22
you know that your time is up and please try
23
to cut it short or get to the point if you
24
haven't already done so.
25
F o r the sake of time management, before
Proceedings
1
6
2
each speaker begins his or her statement I'll
3
announce the name of the following speaker so
4
they will be ready t o follow right after.
5
When your name is called please approach
6
t h e speaker's podium to my left, state your
7
n a m e clearly for the record.
8
Stenographer seated right before the
9
speaker's podium will record your comment.
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The
Now, just not t o tire h e r out too much
11
please speak slowly so she d o e s n ' t have to
12
o v e r d o it.
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Thank you.
I want to stress from t h e get-go that
14
this is a public hearing, not a question and
15
answer session.
16
respond t o your comments or questions at this
17
time.
18
i n the Final Environmental Impact Statement,
19
a l s o known a s t h e EIS.
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The lead agency will not
They will incorporate their response
I further want t o point out that t h e
21
l e a d agency will respond in writing only to
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t h e substantive comments received today at
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t h i s public hearing.
24
l e a d agency's responses will become part of
25
t h e official record o f the Final E I S ,
The comments and the
Proceedings
1
2
3
1
Environmental Impact Statement.
A n d when I say substantive comments I
4
mean those comments that will be addressing
5
environmental issues.
6
T h e Final EIS will be reviewed by the
7
lead agency and will be accepted in the same
8
manner a s the Draft EIS.
9
subject to a 10 day comment period.
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It too will be
Before opening the hearings to your
11
comments I' 1 call upon a representative o f
12
the Village s engineering firm of Camp
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Dresser
14
Hank, t o provide an overview o f the project
15
along with
McKee, Mr. Henry Boucher, known a s
&
a
summary o f t h e Draft EIS.
16
T h a n k you.
17
Let me just remind you again, Mr.
18
Boucher will not respond to any questions
19
either, it will a l l be in the Final EIS.
20
Thanks.
BOUCHER:
Thank you.
Good morning.
21
MR
22
I' 1 use these boards i n order to
23
provide a brief summary description of t h e
24
project.
25
As the Moderator indicated, this is a
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2
p r o j e c t t o c o n n e c t t h e V i l l a g e of Kiryas J o e l
3
water s y s t e m t o t h e N e w York C i t y C a t s k i l l
4
Aqueduct.
5
t h e proposed p r o j e c t .
On t h i s b o a r d s h o w s a d e p i c t i o n o f
T h e N e w York C i t y C a t s k i l l Aqueduct
6
is
7
coming t h r o u g h t h e V a i l s G a t e a r e a and t h e
8
p r o j e c t would c o n n e c t t o t h e a q u e d u c t a l o n g
9
R i l e y Road.
Where t h e a q u e d u c t p a s s e s
10
t h r o u g h t h e r e would b e a pumping s t a t i o n a t
11
t h a t connection.
12
v i c i n i t y of
13
W i n d s o r water t r e a t m e n t p l a n t i n t h a t
14
v i c i n i t y t h a t taps t h e aqueduct.
15
would o c c u r . t h e r e , t h e r e would b e a n
16
a p p r o x i m a t e l y 13 m i l e p i p e l i n e t o be l o c a t e d
17
i n existing roads,
18
w o u l d come down R o u t e 9 4 ,
19
t h r o u g h Blooming Grove,
20
2 0 8 , come down t o t h e s o u t h , a n d t h e n h e a d
21
a g a i n towards t h e V i l l a g e a l o n g Route 6 and
22
17,
23
t h e e x i t ramp and i n t o t h e V i l l a g e .
24
25
T h i s would be i n t h e
t h e -- t h e r e i s an e x i s t i n g Mew
not
The t a p
cross-country,
and
down R o u t e 2 1
c o n n e c t up w i t h Route
on t h e n o r t h s i d e o f R o u t e 6 a n d 17 a l o n g
The c u r r e n t p r o p o s e d l o c a t i o n f o r t h e
t r e a t m e n t f a c i l i t i e s w o u l d be a t t h e
2
3
9
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Village's existing water treatment plant.
Those are the basic components of the
4
project; the connection to the aqueduct, the
5
pumping station in that vicinity, the
6
pipeline in existing roads, and a treatment
7
facility at t h e water treatment plant.
8
9
Essentially the goals of t h e project are
to provide a consistent and reliable source
10
of high quality drinking water to the Village
11
to meet its current water demands.
12
goals of the project are to reduce the
13
dependance o n groundwater wells for supplying
14
drinking water to meet its current water
15
demands.
16
Other
Another goal of t h e project is t o reduce
17
the vulnerability or the susceptibility to
18
drought and to provide greater options in
19
terms o f sources of water in terms of drought
20
or other circumstances like that.
21
to do this i n such a way as t o minimize
22
adverse environmental impacts in the Village,
23
in the neighboring communities, and to the
24
environment.
25
Before settling
--
And also,
before deciding on
1
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the proposed project as the preferable
3
alternative a number of other alternatives
4
were evaluated - - and this i s all documented
5
in t h e Draft Environmental Impact Statement.
10
6
Among the alternatives that were
7
evaluated was the alternative of taking no
8
action; a n alternative t o d r i l l additional
9
groundwater wells t o provide t h e needed
10
drinking water.
11
alternative routes for the transmission
12
pipeline.
13
sizes for the transmission pipe and
14
alternative locations for the pumping
15
station.
16
alternat ves that have been
17
previous y eliminated i n prior - - prior
18
efforts.
19
We also looked at
And we also looked at alternative
And also considered any other
--
that were
T h e two main alternative routes that
20
were evaluated for the pipeline were what I
21
refer t o on this diagram a s t h e New York
22
State Thruway alternative and t h e Route 32
23
alternative.
24
25
I n the case of the Route 32 alternative
the connection would be at the same location,
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2
but t h e pipeline, instead of going west o n 9 4
3
would go east on 9 4 , g o through the five-way
4
intersection at Vails Gate, and then go south
5
on Route 32 all the w a y down t o the Highland
6
Mills a r e a , and then c o m e ahead towards t h e
7
Village on Route 4 4 , and terminate - - the
8
pipeline would terminate on t h e north side of
9
the Village where a n e w water treatment plant
10
11
would have to be built..
T h e other alternative for the pipeline
12
that was evaluated i n t h e Environmental
13
Impact Statement was the alternative o f
14
because the Thruway is near the connection - -
15
near the connection point, that alternative
16
that was considered was t o go over t o t h e
17
Thruway and come down t h e Thruway
18
right-of-way t o the point where the Thruway
19
and 32 cross.
20
alternative would become the same as the
21
Route 3 2 alternative and continue down 32 for
22
a short distance and then towards the Village
23
on Route 44.
24
25
--
And a t that point the Thruway
Essentially the conclusion of the
alternatives evaluation i n the Draft
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2
Environmental Impact Statement was that the
3
proposed project before you today was
4
determined t o be the preferred alternative
5
among the alternatives because it was the
6
alternative that best met the goals and
7
objectives of the project minimizing adverse
8
environmental i m p a c t s .
9
Let me now give you a summary of some of
lo
the findings o f the environmental impact
11
evaluation o f the preferred alternative,
12
which as I mentioned is the alternative that
13
routes the pipeline down 94, 27, and 208.
14
After selecting that as t h e preferred
15
alternative t h e E I S takes a detailed
16
examination of that particular proposed
17
action i n t e r m s of potential environmental
18
impacts and t h e need to mitigate, or take
19
measures, or design measures to minimize any
20
potential impacts.
21
The overall findings of our evaluation
22
are that there would be n o significant short
23
o r long-term adverse impacts to the
24
environment.
25
impacts, some unavoidable consequences,
There are some unavoidable
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2
mainly in the short-term, mainly during
3
construction, that are described and detailed
4
in the Draft Environmental Impact Statement.
5
And there a r e some environmental resources,
6
some sensitive environmental resources, along
7
the pipeline route that will have to be
8
avoided during construction and the design of
9
the pipeline will have to take into account
10
those resources so a s t o minimize any
11
disturbance to them.
12
And what I ' m referring t o - - this is a
13
map showing the proposed project overlaying
14
the New York State DEC wetlands in the study
15
area.
16
generally the route avoids DEC wetlands.
17
There is one area along Route 27 where there
18
is a DEC wetland tha.t comes right up to the
19
edge of the road, or near t o t h e road.
And what we found was generally - -
20
This area.
21
(Indicating.)
22
MR. BOUCHER:
The Environmental Impact
23
Statement describes a s a sensitive area where
24
during design some more precise field
25
delineation will be necessary t o delineate
1
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2
exactly where that wetland is in relation to
3
the proposed pipeline.
4
As I mentioned, the pipeline is designed
5
to be constructed i n the road or along the
6
shoulder of the road in order to avoid
1
undisturbed areas and to minimize impacts.
8
But in this area careful attention i n the
9
design will have t o be taken so that t h e
10
wetland disturbance will b e reduced to an
11
absolute minimum.
12
disturbance it would be a short-term
13
construction related disturbance that can be
14
mitigated during construction arid a n y
15
disturbance can be restored.
16
of the DEC wetlands in t h e study area are
17
away from t h e proposed project and as a
18
consequence we concluded that t h e project
19
would not have any adverse wetland impacts.
20
And i f t h e r e is any
Otherwise most
Similarly, when we looked at areas of
21
potential historic o r archeological resouIces
22
for all of the proposed routes - - and this
23
map depicts the areas that are considered
24
sensitive for either historic o r prehistoric
25
archeological and historic resources.
There
1
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2
are some areas along Route 94 and along Route
3
2 1 that are considered sensitive for historic
4
resources.
5
Environmental Impact Statement are to avoid
6
- _ during construction to avoid disturbing
1
those areas as much as possible and to
8
provide monitoring during construction in
9
c a s e historic resources are encountered.
The recommendations in the
10
This does not indicate there are historic
11
resources there, it simply means that the
12
archeologist determined that there is a
13
potential based on historic records in
14
encountering resources.
15
EIS recommends that special measures be
16
implemented during construction i n these
1 7
sensitive areas so that if there are any
18
resources there they can - - they will not be
19
adversely affected.
20
So the design, the
Most of the other unavoidable impacts
21
that we found in the draft were o f the
22
construction related variety and have to do
23
with the unavoidable traffic disruption
24
during construction, since t h e project will
25
be constructed in roads it will be like one
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2
commonly e n c o u n t e r s w h e n d r i v i n g a l o n g .
3
Where t h e p r o j e c t p i p e l i n e i s b e i n g i n s t a l l e d
4
t h e r e w i l l b e a l t e r n a t i n g one-way
5
setup.
6
would be no need a t t h i s p o i n t
7
for detours,
8
f l a g g e r s a n d one-way
9
b e some s h o r t - t e r m
The t r a f f i c a n a l y s t s concluded t h e r e
i n the design
i t c o u l d be h a n d l e d w i t h
So t h e r e w i l l
traffic.
inconvenience t o
b u t t h e r e w i l l b e no l o n g - t e r m
10
motorists,
11
long-term
12
c o n s t r u c t i o n n o i s e and d u s t ,
13
short-term
14
traffic
effect.
--
Similarly with
these are a l l
impacts.
So t o s u m u p ,
t h e proposed p r o j e c t has
15
b e e n f o u n d i n t h e D r a f t E I S t o -- t h e r e would
16
be n o s i g n i f i c a n t a d v e r s e e n v i r o n m e n t a l
17
i m p a c t s a n d t h e few s h o r t - t e r m
18
u n a v o i d a b l e impacts can b e m i t i g a t e d t o
19
minimize t h e environmental impact.
20
21
22
23
24
25
Thank you.
and
I ' d l i k e t o t u r n i t b a c k now
t o o u r Moderator.
THE M O D E R A T O R :
Thank you,
Mr.
Boucher,
f o r your p r e s e n t a t i o n and overview.
Before w e open t h e hearing f o r p u b l i c
comment I w o u l d l i k e t o ,
again,
for t h e f o l k s
1
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2
that came in after I first announced it, we
3
have speaker's cards.
4
speak who has not filled one out yet can get
5
one right here by t h e Village Clerk.
6
fill it out and we will call upon you.
1
Anybody interested t o
Please
We will now open for public hearing.
I
8
call upon first, a s a professional courtesy,
9
we will call upon elected officials that are
10
11
with us today.
So I call upon M r . Charles Bohan, he is
12
the Supervisor of the Town of Blooming Grove,
13
t o address this public hearing..
14
SUPERVISOR BOHAN:
Good morning.
15
Basically, I'm here this morning to try
16
and determine whether or not what you are
11
attempting t o do i s favorable to my
18
municipality or unfavorable, or whether or
19
not my town will have access t o the water
20
that is going t o be coming from the aquedu
21
through my town t o get t o Kiryas J o e l .
22
I'm under the impression, just looking
23
at it, if you are going t o have a treatment
24
plant a t the Village that it's basically raw
25
water, so-called, that i s coming through my
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2
town, which would mean that if I had to
3
access it i n anyway I'd also have to build a
4
treatment plant.
5
sense, it would further impact my problem.
6
Just like everybody else i n every other
7
municipality w e suffer for water and sewage
8
and everything t h a t goes with it.
That doesn't make very much
I'm basically trying to determine what
9
10
this will mean to my municipality.
11
on the fact t h a t I haven't seen the Draft
12
Environmental Impact Statement i t ' s sort o f
13
hard to comment on just how thoroughly it may
14
impact.
I ' l l be looking forward to hearing from
15
16
And based
you to let me know basically where I'm at.
My people in Blooming Grove are very
17
18
concerned over the fact that no matter which
19
way it goes, or whether o r not we can use it,
20
it's going to have a tremendous impact on our
21
traffic situation over there.
22
one-way i n and one-way out of Blooming Grove
23
and that's Route 208 and Clove Road, which is
24
27
25
We have
I
To a point where we are in the middle of
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2
a building moratorium now t o try and slow
3
things down to put some sort of order into
4
development so we don't a l l end up at the
5
same intersection at the s a m e time one of
6
these days.
7
We are really getting t h e r e .
I d o n ' t know what your project is going
8
t o mean t o us in that respect.
And,
9
basically, I'm here to get information to
10
bring back to the people that put me in
11
office.
12
Thank you.
T H E MODERATOR:
Thank you, Supervisor
I almost regret saying I wasn't going
13
Bohan.
14
t o respond because we can g i v e you many
15
responses to your issue, but I have to stick
16
t o the program.
17
day public hearing period and hopefully it
18
will solve everyone's problems.
19
We will respond after the 10
I now call upon the Honorable
20
Assemblywoman Nancy Calhoun t o address this
21
public hearing.
22
ASSEMBLYWOMAN CALHOUN:
Good morning,
23
Honorable Village Board Members, Honorable
24
Professionals, Mr. Felberman.
25
My name is Nancy Calhoun and up until
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2
December 31st of this past year for 10 years
3
I was the representative in this area.
4
have a 20 year history in government in the
5
Town o f Blooming Grove, having served since
6
1982 first a s a Town Board Member, Supervisor
7
and now Assembly Member.
8
represent Blooming G r o v e and the Town o f
9
Woodbury, which i s neighbors t o the Village.
10
I had the opportunity to briefly review
And I
And I do currently
11
your DEIS and I would like t o certainly bring
12
a number of concerns that I have to your
13
attention.
14
I ' m rather puzzled because many many - -
15
and I believe your gentleman, Mr. Boucher,
16
also mentioned that t h i s is intended t o meet
17
current yields or current needs.
18
t h e comments are, KJ's water system is unable
19
t o supply enough water on days o f high
20
demand.
21
about 50 t o 75 days a year.
22
time I notice in any other community in t h e
23
county if this were true you would not be
24
able t o continue t o build, there are
25
restrictions i f you cannot supply water.
In fact,
And the DEIS went forward t o talk
And at the same
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21
I see at t h i s point, construction, just
3
coming into your meeting here today, has
4
substantial development at a time when your
5
own DEIS by a a n extremely reputable
6
engineering firm says that 20 percent of the
1
time there is not sufficient water in the
8
town.
9
I think also that you also note that
10
your ex sting groundwater i n your wells in
11
Brenner d o supply enough water for this
12
project or for your Village.
13
note that the wells that you currently
14
have - - I don't know if you would have to
15
payback the monies that were given t o you as
16
grants because of the fact that they were
17
largely provided by both state and federal
18
grants.
19
for interim use.
20
be for permanent usage and not as a backup
21
system.
22
municipality that was able t o apply and get a
23
grant that ultimately would be used a s a
24
backup, i t ' s supposed to be for your primary
25
current usage.
I would also
I'm sure they don't give you grants
They assume it's going t o
I've never heard o f another
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'7
22
It's obvious that your D E I S notes that
But I
3
your needs will grow a s time passes.
4
think this is something that i s kind of like
5
a Catch-22.
6
maintain you have enough at times, and now
7
you are looking to increase, but you can only
8
t a k e the amount that you need for today.
9
a s I understood it it would be up to 1.9
You need more water, you
So
--
10
1 . 9 million gallons per day under the current
11
2000 year amounts.
12
Letting myself go onto another issue,
13
and I'm absolutely certain and was very
14
pleased to hear that y o u ' r e environmentally
15
concerned.
16
o f Blooming Grove over those 2 0 years with
17
t h e help of engineer J i m Farr and others.
18
o f the couple items that have not been
19
mentioned at all and I saw there were five
20
items that were listed as potential
21
environmental - - I guess y o u call them bog
22
23
24
25
And I have a tremendous knowledge
A
,
turtles, and other sensitive environmental
impacts.
And the one you left o u t , which is
probably the most important is coming along
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2
Route 2 7 , also known as Clove Road, is there
3
is a large infestation of the timber
4
rattlesnake.
5
with it it is a highly protected species and
6
is not even mentioned i n t h e DEIS as having
7
impact in this area.
8
9
And while I don't always agree
Additionally, there is discussion about
blasting and blasting i s a real concern in
10
Blooming Grove.
11
there are areas known a s Glenwood Hills and
12
Mountain Lodge Park and many years ago in the
13
1980's there was a proposal to bring sewer
14
lines up to that area, and this was turned
15
down vehemently by the people there and by
16
engineering studies that led t o the
17
conclusion that blasting in that area could
18
impact the wells people had and also their
19
foundations o f their homes.
20
documented from the 198O's, so I think that
21
would be something that on Route 2 1 would
22
bring major concern.
23
When you go along Clove Road
This can be
Just as a point, you have the
24
intersection with State Route 208 to 2 7 as a
25
three-way, which is correct, and you have it
1
2
controlled by a traffic signal.
3
have a traffic signal there, but there is
4
none a t t h e present time.
5
We'd love to
And I make another comment, it's my
6
understanding you are trying to stay within
7
right-of-ways o f county roads and state
8
roads, but your references in the DEIS say
9
that Route 27 terminates at Orrs Mills Road
10
and that leaves a small section of land, the
11
rope o f C l o v e Road that continues u p to
12
connect with Route 9 4 .
13
check and s e e if that is or is not a town
14
road, because if Route 21 terminates what is
15
left is obviously going to be a town road.
16
I think you want to
You mentioned that i n the DEIS that you
17
did not want to use Route 32 because of the
18
fact there would be traffic congestion.
19
Well, I c a n tell you
--
20
(Whereupon the stopwatch sounded.)
21
ASSEMBLYWOMAN CALHOUN:
22
you f o r another couple minutes.
23
quick.
24
25
(
T H E MODERATOR:
exempt.
I would indulge
I'll be very
Elected officials are
(
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3
4
25
ASSEMBLYWOMAN CALHOUM:
I ' l l make it
quick.
Route 208, I live on Route 208.
It's a
5
growing community.
Your notation is of
6
1 6 , 5 0 0 in traffic and I think that is
7
probably underestimated.
8
road in the mornings and evenings is very
9
substantial.
T h e traffic on that
10
One other thing which came to our
11
attention recently, a very highly regarded,
12
but he is deceased, the late Roger King, is a
13
historian.
3.4
that o n Route 208 proceeding up toward the
15
Peddler Hill area, there is a roadway that
16
was changed - - Route 208, was changed in the
17
1920's and it goes through a 1700's cemetery.
18
And by using infrared M r . King himself had
19
g o n e and seen that there are numerous bodies
20
of historical significance buried in the
21
shoulder of Route 208.
22
is something that has t o be fully addressed.
23
T h e fact is these are people who - - I believe
24
it was called Blaggsville - - it was a very
25
early colonial settlement.
And he brought t o my attention
So I think that this
And if you look
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2
there is a cemetery presently very visible on
3
either s d e of t h e road.
4
Mr. King
5
testify, did make the statement that there
6
are significant burials of 1700's on both
7
sides in the shoulders of that roadway, which
8
is right along t h e area where you are looking
9
to g o .
10
And, again,
who cannot be here today t o
I think that pretty much covers my
11
concer-ns, but I think the most important
12
concern is the divergence with whether this
13
is for current demand, which seemed to be the
14
statement, or for future demand.
15
And I also note, and I have t o say I
16
read it in the newspaper, that there was an
17
application placed f o r EFC funding.
18
understanding that funding normally must be
19
for current usage.
20
you a r e looking t o d o it for future demand
21
you c a n ' t be going and saying it's for
22
current.
23
current demand covered then you don't need it
24
for current.
25
demand covered then the County of Orange
It's my
So I would say that i f
And if you a r e saying you have
I f you don't h a v e the current
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2
should be looking very seriously a t the
3
current trend o f building here, which is
4
bringing automatically more people i n while
5
your own papers are maintaining you don't
6
have sufficient water t o cover your current
1
water demands.
a
I will be pleased t o sit down and let others
9
speak
I
T H E MODERATOR:
10
11
I thank you f o r your time and
Thank you very much,
Assemblywoman Calhoun.
I now call upon Paul Aggarwal from the
12
13
New York City Department of Environmental
14
Protection.
You too, sir, are exempt from the three
15
16
minute.
MR. AGGARWAL:
17
First of all, a very good
ia
morning t o the Village Board and all of you.
19
My name is Paul Aggarwal from New York City
20
DEP.
21
Basically, the aqueduct belongs to our
22
department and the application has been made
23
t o make a connect t o t h a t aqueduct.
24
result we have a lot of investment in this
25
project.
So as a
We had been already corresponding
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with C D M ,
especially Mr. Hank Boucher.
3
handling t h e most of the c o m m e n t s .
28
He is
4
But still, there a r e two issues I think
5
are very important to u s and I would like to
6
bring t h e m up here as quickly a s I can.
1
A s the Assemblywoman pointed out, I
8
think that was a very good comment, that
9
right now this connection has been made for
10
two million gallons a day water consumption.
11
W h a t we find is that, according to t h e
12
Village population and probably in the coming
13
couple o f years, that that amount will be
14
probably not enough to meet the water supply
15
for the Village, the two million gallons a
16
day.
17
So the question is how the Village
18
perceives to meet their water. demand by t h e
19
year 2 0 2 0 o r even beyond t o supply their
20
consumers?
21
Second question would be that if the
22
water supply is only for two million gallons
23
we kind o f d o not see t h e point a s to why the
24
line should be 24 inches - - t h e project is
25
proposing t h e 24 inch wide pipe, 13 mile
i
Proceedings
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29
2
long.
Since we do quite a few projects for
3
the different communities anyone taking that
4
nine to ten to twelve million gallons goes to
5
about 18 to 24 inch line
6
t w o million gallons a 24 inch line, somehow
7
it does not appear to me - - what I'm saying
8
i s we would like t o see some rationale behind
9
t h i s 2 4 inch line for the t w o million gallon
And here just for
10
water supply.
11
DEIS, but we belive more reasons need t o be
12
done t o justify that
13
Some reasons were given in the
Also, not that it's mandatory by us,
14
however, the question of backup water supply
15
is an important one.
16
being that from time to time we do take down
17
our aqueducts for repairs, maintenance, a n d
18
any unforeseen problems.
19
t h e Village would not have any water supply
20
from the aqueduct.
21
rather essential for the Village to have a
22
backup water supply.
23
The reason for that
And at that time
So, therefore, it is
A s I was mentioning, that i f we have t o
24
take t h e aqueduct down for repairs,
25
maintenance, or any unforeseen circumstances
1
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30
2
I think it behooves the Village to have some
3
sort of backup water supply.
4
water supply they have, which is
5
approximately 1.3 million gallons, including
6
14 wells, 9 of their own and 5 on the Brenner
7
property, would have t o be maintained by the
8
Village, or there h a s t o be some
9
understanding between the different
So t h e existing
10
communities that d o take water from the
11
Village that when needed the Village can get
12
that water back for their own consumers.
13
that has t o be addressed in the DEIS as well.
14
At one point t h e report mentioned that
15
the Village has four storage tanks.
16
like t o know what the storage capacity o f
17
those four tanks?
18
So
We would
Also, some o f the questions that we had
19
written t o CUM o n the SEQR that document need
20
to be addressed.
21
of the proposed project should provide the
22
requirements o f t h e Village and t h e potential
23
likely degree of reliance in t h e backup
24
supply must be addressed.
25
mentioned anywhere in the document.
Mainly, that the capacity
That has not been
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31
The other thing is that once you have
3
the aqueduct water
4
definitely a question that - - what happens to
5
the demographic makeup of t h e town, the
6
Village, or t h e community?
7
been addressed.
8
few more businesses, commercial in nature, or
9
it could provide any other entity.
--
I think this is
And that has not
Basically it could provide a
And I
10
think that should be addressed a s t o what
11
sort of makeup we can expect in the f u t u r e .
12
I think last, but not t h e least, there
13
is also a concern about the wastewater.
14
Actually, what happens, as the operation
1s
increases so does the wastewater.
16
wastewater, if not treated properly, is
17
definitely a threat t o groundwater sources.
18
We believe the Village has .9 million gallons
19
capacity today and - -
And the
20
(The speaker cannot be understood.)
21
MR.
AGGARWAL:
Some o f the water,
22
probably all of t h e water c a n be transferred
23
to the Harriman wastewater treatment plant.
24
However, at this time I think the
2s
Village has at least about .35 million
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32
gallons to Water District Number 1..
The question is, will that arrangement,
3
4
which finishes in probably November 2004,
5
will continue beyond that, or if the Village
6
would like to get the - - that capacity with
7
them for their own use..
I believe I have covered most of t h e
8
9
10
issues in my notes.
Yes.
Also, some more wells have to be
11
installed, we would like t o know what is the
12
t i m e frame?
13
And the parcel that t h e report talks
14
about outside the V i l l a g e ’ s boundaries that
15
they might have some more wells, that I think
16
should be also addressed i n the report.
17
And lastly, I think w e had asked t h e
18
question that, why the Village would not want
19
t o get their water from t h e New Windsor water
20
t a p on the aqueduct?
21
reasonable explanation t o that question.
There has been n o
We definitely would want the Village to
22
23
take a second look to t h e connection of New
24
Windsor.
25
site.
They have a filtration plant at the
And a s far as t w o million gallon
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2
33
supply is concerned, Mew Windsor - -
3
(The speaker cannot be understood.,)
4
M R . AGGARWAL:
They can definitely
5
supply t h e Village if they desire.
6
to have an answer to that question..
1
T h a n k you very much.
8
T H E MODERATOR:
9
W e ' d like
Thank you very much, Mr.
Aggarwal"
10
Before we continue I would request that
11
everybody please shut off their cell phones,
12
it's just very disruptive.
13
I hope I ' m reading this correctly.
14
Geoff Welch from the Ramapo River
15
Committee?
16
MR. WELCH:
17
I looked over the Draft Environmental
18
Impact S t u d y , you know, just a s I came in.
19
But I really didn't know about t h e project so
20
I'd like t o get a copy o f the complete
21
Environmental Impact Study.
22
it's available on CD-ROM, but that would be a
23
handy format t o get it in.
24
25
Yes.
T H E MODERATOR:
Thank you.
I d o n ' t know if
And - -
Just a moment, that
question - - is there an exception?
Can we
2
a n s w e r t h i s now'?
MR.
SCHOETTLE:
4
MR.
WELCH:
5
THE MODERATOR:
Not h e r e t o d a y .
Very g o o d .
Okay,
we w i l l g e t i n
t o u c h w i t h you t h e n .
Very good.
7
MR.
8
I -- i t ' s n o t your f a u l t ,
9
BOUCHER:
but
I wish
t h a t all p r o j e c t s t h a t h a v e s i g n i f i c a n c e f o r
10
t h e w a t e r s h e d o f t h e Ramapo R i v e r t h a t we
11
w o u l d h a v e down r i v e r n o t i f i c a t i o n o f
12
interested parties.
13
o n e time w i t h t h e b l e w Y o r k S t a t e D E C .
14
I
(
Can he r e c e i v e i t ?
3
6
34
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1
We t r i e d t o s e t t h i s u p
i
B u t t h e Ramapo R i v e r i s a n i n t e r s t a t e
15
water supply t h a t c o n t r i b u t e s water t o over
16
two m i l l i o n p e o p l e i n N e w York a n d N e w
17
Jersey.
18
R o c k l a n d C o u n t y i s d e r i v e d f r o m 10 w e l l s
19
a l o n g t h e Ramapo R i v e r f r o m U n i t e d W a t e r ,
20
t h e r e is four f o r t h e Village of
And t h e w a t e r s u p p l y down i n
. .
Suffern.
21
I'll s h o w you t h e w a t e r s h e d q u i c k l y .
22
And down t h r o u g h N e w J e r s e y t h e r e i s
23
a q u i f e r water wells i n t o t h e g l a c i e r and s a n d
24
and water a q u i f e r t h a t i s r e c h a r g e d a t a r a t e
25
of a b o u t 60 p e r c e n t
from s u r f a c e water i n t h e
i
I
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1
2
3
35
Ramapo River.
So at Pompton Lakes, I should mention
4
New Jersey, down at t h e bottom here, water is
5
piped through a large interconnections to the
6
Wanaque Reservoir, which is 29.5 billion
1
gallon reservoir that supplies Northern New
8
Jersey, many communities in Northern New
9
Jersey.
10
But Kiryas Joel is here at the very
11
headwaters of the Ramapo River watershed, so
12
it's always good t o think in terms o f these
13
great natural systems that we all depend on.
14
And everything is i n line is also a
15
federal sole source aquifer area as result of
16
a petition in 1992 from the Village of - -
17
Township of Mahwah, New Jersey from the E P A .
18
So I don't know if there is any federal
19
dollars involved then you have t o address the
20
impacts on the watershed, but we would hope
21
the environmental impact study would do that
22
anyway, so we would request a Supplemental
23
Environmental Impact Study t o address the
24
impact on the Ramapo River watershed mostly
25
through the increase of treated sewage
1
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2
effluent which would result from this
3
connection.
4
36
And, obviously, t h i s is a close inducing
5
project, which doesn't seem t o be adequately
6
addressed.
7
of impervious material surfaced in a
8
watershed effects surface water quality.
9
Any increase of over 10 percent
And y o u have a tributary coming down
10
into the Rainapo River, we a r e not happy in
11
general with the growth in Orange County at
12
the headwaters of the watershed.
13
is - - t h e r e ' s malls that have been put in,
14
there's been horrific runoff o f siltation
15
loading into the Ramapo River from Orange
16
Count y .
17
And there
We have had a major problem with just a
18
small development along Sterling Road i n
19
Tuxedo and Tuxedo has a lot o f development.
20
T h e problem with the Ramapo watershed is
21
there is n o management plan f o r it.
22
interstate water supply.
23
doing marvelous things protecting their water
24
supply i n t h e Catskill and we a r e making a
25
strategic planning mistake by not having an
It's an
New York City is
Proceedings
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37
2
interstate water supply plan for the Ramapo
3
River.
--
4
So here at the headwaters
5
(Whereupon the stopwatch sounded
6
MR. WELCH:
)
Having this level of
7
development, you know, is a concern and we - -
8
just a couple other points.
9
See we would hope the supplemental could
10
address those questions and the level of
11
treatment that the sewage will get.
12
with modern sewage treatment plants the
13
Geological Survey through recent studies has
14
shown
15
Even
U.S.
--
M R . FELBERMAN:
Okay, he is going to
16
make it short, it's very disruptive, another
17
minute or so, please.
18
19
MR. WELCH:
Yes, I ' l l wrap up in a
minute.
20
There are impacts from even treatel
21
sewage because many of the substances we use
22
i n daily l i f e actually still emerge from
23
sewage treatment plants, these are organic
24
wastewater contaminants, and they have
25
measured certain levels in t h e Ramapo River.
2
38
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1
S o we w o u l d a s k f o r t h e s u p p l e m e n t a l a n d
3
maybe t h a t t h i s p r o j e c t i s a g o o d p r o j e c t ,
4
b u t w e s h o u l d a d d r e s s a l l of t h e s e issues
5
b a s e d o n t h e f a c t t h a t t h e Ramapo R i v e r i s a n
6
i n t e r s t a t e w a t e r s u p p l y and t h e s o l e s o u r c e
7
aquifer designation.
Thank you.
Thank you,
Mr.
8
THE MODERATOR:
9
I c a l l upon J e n n y K e e s l i n g .
10
11
12
MS. K E E S L I N G :
I want t o
Thank you.
make t h r e e c o m m e n t s v e r y b r i e f l y .
One o f which I t h i n k i s germane t o t h i s
although i t ' s probably t h e least
13
gathering,
14
interesting.
15
Welch.
I do r e p r e s e n t an endangered
species.
And R o u t e 21 i s a v e r y
16
I ' m a cyclist,
17
u n u s u a l r o a d i n t h e low t r a f f i c d e n s i t y .
18
T h e r e a r e n o t v e r y many p l a c e s w h e r e y o u c a n
19
ride i n t h i s county.
20
trucks and a c a r .
21
s o I would l i k e you t o t h i n k a b o u t t h a t .
22
I ' v e b e e n h i t b y two
I know w h a t
I t a l k about,
T h e o t h e r two c o m m e n t s a r e p e r h a p s
23
a d d r e s s e d t o t h e wrong a u d i e n c e ,
24
t o s a y t h e s e somewhere.
25
The f i r s t i s ,
but
I l i v e i n Monroe.
I need
I have
Proceedings
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39
My h u s b a n d a n d I d o n o t t a k e b a t h s ,
2
a well.
3
w e take very s h o r t showers.
4
toilets without thinking about it.
5
under very severe water r a t i o n i n g .
We d o n o t
flush
We l i v e
6
What I w o u l d l i k e t o know i s g i v e n t h a t
7
I l i v e i n a community i n w h i c h t h e wells a r e
8
not adequate,
9
p l a n f o r t h e w a t e r s u p p l y o f a l l of
why t h e r e i s n o c o m p r e h e n s i v e
the
10
c o m m u n i t i e s a n d why w e a r e t a l k i n g a b o u t a n y
11
Village?
12
I t h i n k t h a t may n o t b e p a r t o f
13
jurisdiction,
14
raised.
15
but
your
I t h i n k t h e issue ought t o
The o t h e r i s t h a t y o u r E n v i r o n m e n t a l
16
Impact Statement s a y s t h e p o p u l a t i o n growth
17
a t Kiryas J o e l is 5..9 p e r c e n t and t h a t t h i s
18
p r o j e c t won't i n c r e a s e t h a t growth,
19
it say t h a t t h a t growth w i l l decrease.
20
point nine percent is n o t sustainable growth.
21
I d o n ' t have a c a l c u l a t o r w i t h me,
22
rough e s t i m a t e ,
23
w i l l be o v e r 40,000 i n t h e y e a r 2020.
24
w h a t I w a n t t o know i s w h e t h e r t h e w a t e r
25
s u p p l y t h a t you are p r e d i c t i n g from t h i s p l a n
nor does
Five
b u t my
t h e p o p u l a t i o n of K i r y a s J o e l
And
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2
will deal with that population?
But more
3
realistically, given water i s a finite
4
resource shared by all communities, whether
5
we could justify any plan that allows one
6
community t o have that rate of growth.
7
Thank you.
8
THE MODERATOR:
9
Mr. Philip Chase, the r e p for the
10
11
12
13
Thank you, M S . Keesling.
Deerpark t o Upper Delaware Council.
MR. CIHASE:
Thank you for the
opportunity t o speak today.
I ' m from Port Jervis, New York.
We are
14
on the other side of the Kittatinny Ridge and
15
the Shawangunks, which means our watershed i s
16
the Delaware, not the Hudson.
You people
17
live in the Hudson watershed.
We are in the
18
Delaware watershed, which m e a n s that every
19
drop o f water that doesn't evaporate will end
20
up in the Delaware River.
21
However, the City of New York
22
constructed three reservoirs i n the Delaware
23
watershed area; the Neversink, Pepacton, and
24
Cannonsville.
25
aqueduct such a s you are talking about
And from those we have an
1
Proceedings
41
2
tapping into.
3
aqueduct, which is also influenced by the
4
Catskill Aqueduct.. Whoever is taking out of
5
those, they love t o g o to the Delaware
6
aqueduct.
7
the water that the city gets c o m e s from our
8
aqueduct
9
And ours is the Delaware
And approximately 50 percent of
I
Our rivers are not managed properly by
10
the New York City DEP, they do absolutely
11
zero for management of our rivers.. And this
12
is
13
A study was done in 1996 in Hancock, New
14
York, a small town on the west branch of the
15
Delaware, showing for that year, and we have
16
had mostly poor years other than t h a t , 11.9
17
million dollars just from trout fishing.
18
spin off was 30 million dollars.
a
very important thing for our ecotourism,
19
However, within a few years they had
20
drawn Cannonsville down to three percent,
21
killed the reservoir.
22
we get n o management for our rivers..
The
As I mentioned before
23
Way back i n 1951 Mew York C i t y was
24
trying t o determine if they would g o to the
25
west branch of the Delaware and flood it and
Proceedings
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42
2
make it into the Cannonsville Reservoir, so
3
they hired a panel of experts.
4
were engineers and environmentalists and they
5
came up t o the conclusion that the Hudson
6
River was the appropriate place t o get 325
7
million gallons of water a day.
8
Hudson River water supply was a better source
9
than non-filtered Catskill water, which is
These experts
A filtered
10
what we have at the present time.
T h e city
11
has done everything it c a n not t o build the
12
recommended - - the E P A recommended filtration
13
plant, which would be i n t h e billions of
14
dollars, and that would filter all of the
15
water for the city.
16
There is also presently a pumping
17
station at Chelsea where t h e city c a n take
18
100 million gallons o f water from t h e Hudson,
19
which is not being used.
20
Our rivers are the l i f e blood of the
21
Delaware watershed.
22
more water from us our rivers are more and
23
more jeopardized, it's been shown year after
24
year a s they are downgraded and we get no
25
cooperation.
As New York City takes
Proceedings
1
2
43
I've gone to the Delaware River Basin
3
Commission meetings for the last eight years
4
and I'm on the Upper Delaware Council.
5
a r e in charge of the w i l d scenic portion of
6
t h e Delaware River from Port Jervis u p to
7
Hancock, 75 miles.
8
9
We
In conclusion, I would just like to
state that we hope there will be no taps on
10
either the aqueduct o f the Catskill or the
11
Delaware aqueduct until t h e Hudson is taken
12
for water a t 3 2 5 million gallons a day, that
13
Mew York City builds the recommended E P A
14
filtration plant for all its water supply
15
systems, and prevents t h e wasteage of leakage
16
o f between 30 and 100 million gallons of
17
water a day, and considers the health and the
18
ecology of the rivers o f our watershed so we
19
c a n have our maximum ecotourism.
Thank you.
20
MR. BOUCHER:
21
M r . Aggarwal, you got more than you
22
Thank you, Mr. Chase.
counted for.
23
I call upon Mr. Manny Mangual.
24
MR.
25
First, I just wanted to commend you.
MAMGUAL:
Good morning, gentlemen.
I
Proceedings
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44
2
think it was, you know, there is a problem
3
and a s the stewards of the Village I believe
4
that you went and sought - -
5
resolve to t h e problems here.
OX
sought some
And it's interesting that many
6
7
complaints were about the wells and about,
8
you know, the growth and the water you a r e
9
taking from the surrounding community.
-- I
10
would
11
more support from the area politicians.
12
Arid I
a m just surprised you wouldn't get
I also think that in some areas I think
13
that when there is a problem that involves
14
many communities you would expect your
15
legislators to help resolve these issues.
16
They have not come t o offer a n y kind of a - -
17
any kind of resolution, or offer any kind of
18
mediation, or anything, and instead they've
19
come to attack, so t h a t ' s a shame.
LO
But I h a v e two questions and it's
21
regarding the community itself.
One is, as
22
you know, that there are many people in t h e
23
community that are not necessarily in
24
agreement with the leadership.
25
question is would t h e water be accessible t o
And so the
Proceedings
1
2
45
those people a s well?
3
And my second question i s - - is that
4
there are many wells in the community and
5
some private and some not so private, and
6
can
7
somebody opens up a little power plant, you
8
know, everybody gets t o use it.
9
this grid o f water pipes in t h e Village so
--
you know, kind of like electricity if
You have
10
could there be a trade off of water from one
11
side to be used on another side of the
12
Village?
13
So those are two questions that I have.
14
I think specifically you know what I'm
15
talking about.
16
concerns, but, again, I just want t o applaud
17
you for coming t o finding a solution t o the
18
needs of this community.
19
THE MODERATOR:
20
Mr. Bill Douglas from the Upper Delaware
21
22
And so those are my two
Thank you, M r . Mangual.
Council.
Before Mr. Douglas begins his remarks
23
are there any others that would like t o make
24
any comments today?
25
anybody that hasn't yet, please bring your
Could you please
--
Proceedings
1
2
c a r d s up.
Thank you.
3
Mr.
Douglas,
4
MR.
DOUGLAS:
5
Welcome.
6
46
go ahead.
Thank you v e r y much.
The Upper D e l a w a r e C o u n c i l i s a w a r e from
1
a n o t i c e i n t h e October 22,
8
Environmental N o t i c e B u l l e t i n t h a t t h e Board
9
of T r u s t e e s of t h e Village of
2 0 0 3 i s s u e of t h e
Kiryas Joel,
as
has accepted a Draft
10
l e a d agency,
11
E n v i r o n m e n t a l Impact S t a t e m e n t on a p r o p o s e d
12
C a t s k i l l Aqueduct c o n n e c t i o n .
13
The a c t i o n involves construction of
a
14
t a p of t h e C a t s k i l l a q u e d u c t a n d a
15
t r a n s m i s s i o n main t o t r a n s p o r t water s u p p l i e s
16
t o t h e Village of Kiryas J o e l .
17
w i l l include a water t r e a t m e n t p l a n t and
18
pumping s t a t i o n .
19
e x t e n d f r o m t h e M e w York C i t y C : a t s k i l l
20
Aqueduct c o n n e c t i o n i n Mew Windsor,
21
a l o n g R i l e y Road,
22
County Route 27,
23
Route 1 7 t o i t s t e r m i n a t i o n i n t h e V i l l a g e of
24
Kiryas Joel,
25
u n d e r s t a n d t h a t a p u b l i c h e a r i n g w i l l be h e l d
The p r o j e c t
The water s u p p l y l i n e w i l l
New York
S t a t e R o u t e 9 4 , C l o v e Road,
S t a t e R o u t e 208, a n d S t a t e
Orange County,
N e w York.
We
1
Proceedings
1
47
2
on November 14, 2003 at t h e Village Hall and
3
that comments will be accepted until
4
November 24, 2003..
5
T h e U D C ’ s comments a r e about impacts to
6
the environment, economy, water quality, and
7
flows in the Delaware River Basin, primarily
8
down stream of the Cannonsville, Pepacton,
9
and Neversink Reservoirs which are owned and
T h e UDC is
10
operated by New York City.
11
concerned that the cumulative effect of new
12
connections into the New York City water
13
supply system, including the Catskill
14
Aqueduct, will ultimately mean more demand
15
making less water available for the Delaware
16
River as it flows downstream through the
17
states of New York, Pennsylvania, New Jersey
18
and D e l a w a r e ”
19
Fully ha f of the 1.3 billion gallons of
20
water that the City of New Y o r k uses on a
21
daily basis comes from the Delaware River
22
watershed.
23
Delaware River water out of t h e Delaware
24
basin into the Hudson basin there is less
25
available to satisfy all of t h e needs of the
Because of this exportation of
Proceedings
l
2
3
48
Delaware River .
T h e proposed pipeline will only
4
encourage additional growth and a n even
5
greater demand for Delaware River watershed
6
water.
7
and must address potential impacts on the
8
Delaware River watershed, including the area
9
below t h e New York C i t y reservoirs.
We believe that the EIS is deficient
10
Since a water treatment plant is
11
apparently part of the proposal anyway, we
12
suggest that the previously evaluated Hudson
13
River water alternative be used instead of
14
tapping into the Catskill Aqueduct.
15
The tipper Delaware Council is the
16
oversight body responsible for the
17
coordinated implementation of the"River
18
Management Plan for t h e Upper Delaware Scenic
19
and Recreational River, a component of the
20
National Wild and Scenic Rivers System.
21
voting members are t h e two states, New York
22
and Pennsylvania, and eleven local
23
governments, New York towns and townships,
24
which border on the tipper Delaware River.
25
T h e Delaware River Basin Commission is a
Our
1
Proceedings
49
2
non-voting member of the Council.
3
under a direct contractual relationship with
4
the National Park Service for the oversight,
5
coordination, and implementation of many
6
elements of the River Management Plan.
1
We operate
Please add the Upper Delaware Council to
8
your list of interested parties for this
9
proposal.
10
11
Thank y o u for the opportunity to comment
on this Draft EIS.
12
THE MODERATOR:
13
The address we have o n the card is the
14
Thank you, Mr.. Douglas.
address you want the information sent?
15
M R . DOUGLAS:
Yes.
16
THE MODERATOR:
17
I call upon Ms. Ann Krautin (phonetic)"
18
MR. KRAUTIN:
Thank you.
Good morning, gentlemen,
19
good morning, everybody.
I ' m glad that you
20
are here with all of you looking at this
21
problem and perhaps solution.
22
First I would like t o say, just very
23
briefly, that the area politicians as well a s
24
everyone that made all the statements are
25
responding t o all of the people in the
1
Proceedings
2
community and not just o n e particular
3
segment.
4
50
And in particular in the Town of Monroe
5
there was a very strong turn out in the
6
recent election a n d o n e prior t o that for
7
people, including myself, who want to retain
8
the quality of life that has been here for
9
many years.
10
We are not against growth.
We a r e for
11
controlled growth.
12
people have been speaking with our local
13
representatives about.
14
our representatives o n that basis I think is
15
erroneous.
16
And this is what a lot of
So that t o criticize
Secondly, a point was previously made I
17
would like t o reiterate, that i f there is
18
some kind of a water connection that will
19
supply water t o o n e particular area in t h i s
20
county that the entire group o f people in the
21
county should be a b l e t o avail themselves at
22
t h e same price and same cost t o that water,
23
since, in fact, t h e federal and state funds
24
a r e what is going t o create this system.
25
Third, there w a s mentioned about K J ' s
Proceedings
1
51
2
growth, it says that your growth is primarily
3
internal
4
I ' m concerned as a next-door neighbor that
5
such growth would not be internal, that it
6
would attract a lot of people from New York
7
that - - a s already is happening in this area,
8
in this Village.
9
However, with this abundant water
Would there be a transparent mechanism
10
to prevent the influx o f outsiders, non-KJ
11
generated people, in the - - i n the
12
do have this aqueduct tapping come into
13
effect?
14
people who live in this community and their
15
children, rather than outsiders, would be
16
using this water?
17
--
if we
A transparent system so that only
Finally, my last point is that as
18
population will grow in this Village because
19
of the availability of water, should it come
20
into effect, would this Village government
21
anticipate at a particular point of
22
population withdrawing from t h e Town of
23
Monroe?
24
your o w n water supply, you would have - - a s I
25
read i n the paper
Since, in effect, you would have
--
your own library, your
Proceedings
1
52
a n d w o u l d be i n t h e m a j o r i t y
2
own sewer p l a n t ,
3
or c l o s e t o t h e m a j o r i t y a t t h a t t i m e .
4
p e o p l e i n t h e Town o f M o n r o e h a v e d i f f e r e n t
5
p e r s p e c t i v e s a n d would p r e f e r t o h a v e c o n t r o l
6
o f t h e i r own p o l i t i c a l s y s t e m ,
7
be impossible i n t h e event t h a t t h i s water
8
s i t u a t i o n d o e s g o f o r w a r d t h e way y o u w a n t
9
t o go f o r w a r d .
10
11
12
and t h a t would
T h a n k you v e r y much,
it
Ms.
.
I c a l l on D r .
S t e v e n B e n a r d o from t h e
13
K i r y a s Joe1 S c h o o l D i s t r i c t , t h e
14
Superintendent
15
Many
Thank y o u .
THE M O D E R A T O R :
Kraut i n
(
~
MR. BENARDO:
I hadn't
Good m o r n i n g ,
quite
intended t o speak,
but
16
frankly,
17
h e a r i n g s o many p e o p l e s p e a k a b o u t
18
environmental issues I feel an obligation t o
19
speak .
20
(
I have an environmental background
I a m on t h e Henry Hudson S c e n i c
21
myself.
22
Byway T a s k F o r c e .
23
R e c r e a t i o n S u b c o m m i t t e e o f t h e Community
24
P l a n n i n g Board i n t h e N o r t h w e s t B r o n x .
25
addition,
I'm
I a m on t h e Parks and
on t h e R i v e r d a l e N a t u r e
In
i
Proceedings
1
53
2
Preservancy Council a n d I ' v e spent
3
time working on environmental issues in my
4
own community.
5
a
long
In addition, a s Superintendent of the
6
school district here I've had an opportunity
7
over the course of t h e 14 years I have been
8
in the school district to address each member
9
of the Board of Trustees o n various occasions
10
concerning an issue o f concern to me, which
11
is, that adequate housing i s an environmental
12
issue i n education.
13
Ensuring that children have a home that
14
is complete with bedrooms and access t o water
15
and all of the other issues are the most
16
important environment t o me.
17
the home.
Environment of
Environment of the community.
18
Secondly, I ' v e heard a number of
19
concerns about other communities, not
20
responding t o their issues.
21
here I've seen that the Board of Trustees or
22
other organizations within the community have
23
worked tirelessly to ensure a fire
24
department, or ambulance service, or a school
25
district for that matter.
In the 14 years
And I think this
Proceedings
1
2
is just one more area that t h e y ' v e proven
3
they care about their community and other
4
communities certainly can l e a r n from that
5
level of concern.
I wish you the best of l u c k with your
6
7
project .
T H E MODERATOR:
8
9
54
Thank y o u very much, Dr.
Benardo"
10
Being that there are no others that
11
would like to address the l e a d agency I g u e s s
12
this public hearing comes t o a close.
And I thank you all, l a d i e s and
13
14
gentlemen, for participating i n this public
15
hearing.
16
and will be responded t o and will become part
17
of the Final EIS.
Again, thank you very m u c h , have a good
18
19
20
21
22
23
24
25
Your comments have been duly noted
day.
i
55
THE FOREGOING IS CERTIFIED t o b e a
t r u e and c o r r e c t t r a n s c r i p t i o n of t h e o r i g i n a l
s t e n o g r a p h i c m i n u t e s t o t h e b e s t o f my a b i l i t y
LAWYER’S NOTESIERRATA SHEET
I__
Line
Page
-
-_
I
--
w
APPENDIX B
WRITEN COMMENTS
On the Draft Environmental Impact Statement
h n L Buono
~airrnan
John T Briueil. P E.
Deputy Executive
DireclorlChief Engineer
New York Division
4 Executive Boulevard
Sufiern, NY 10901
Nancy E Carey
Board Member
John R Riedman
Board Member
Rarnesh Mehta, PE
Division Director
Phone
(845) 916-2500
Fax
(845) 918-2594
ny us
Michael R Fieischei
Executive Director
CAMF DRESSER & McKBctober 31, 2003
EDISON, NEW JERSEY
Mr..Gedalye Szegedin, Village Clerk
PO Box 566
Monroe, NY 10950
RE: Draft Environmental Impact Statement
V/ Kiryas J o e l Water Supply Project
MP 50 to 56; Orange County
ar Mr. Szegedin:
The Thruway Authority, as an involved agency, has received a copy of the
October 2003 Draft Environmental Impact Statement (DEIS) for the proposed
subject project. We have no objections to the document, and concur with the
preferred alternative route.
Thank you for the opportunity to provide comments.
ques-tiois, please call me at 845-918-2510.
Very truly yours,
\ V k -
D. Hohman, P.E.
/Division Highway Management
JDH : an
:
Mr. R. Mehta
Mr. A. Shareef, NYSDOT Region 8 Planning
Mr. H. Boucher, PE, CDM
Should you have any
William E. Douglass. Executive Director * David B . Soete. Senior Resource Specialist
Laurie Ramie. Public Relationfiund Raising Specialist Carol Coney. Office Manager
November 6,2003
GEDALYE SZEGEDIN, VILLAGE CLERK
VLLLAGE OF KIRYAS JOEL
PO BOX 566
MONROE NY 10950
RE:
DRAM' EIS on the proposed Catsliill Aqueduct Connection
Dear Clerk Szegedin:
The Upper Delaware Council (UDC) is aware from a notice in the October 22,2003 issue of
the Environmental Notice Bulletin that the Board of Trustees of the Village of Kiryas Joel,
as lead agency, has accepted a Draft Environmental Impact Statement (EIS) on the
proposed Catskill Aqueduct Connection. The action involves construction of a tap of the
Catskill Aqueduct and a transmission main t o transport water supplies to the Village of
Kiryas Joel. The project will include a water treatment plant and pumping station. The
water supply pipeline will extend from the NYC Catskill Aqueduct connection in New
Windsor, NY along Riley Rd., State Rt. 94, Clove Rd.,,County Rt. 27, State Rt., 208, and
State Rt 17 to its termination in the Village of Kiryas Joel, Orange County, N y . , We
understand that a public hearing on the Draft EIS will be held November 14,2003 at the
Village Hall and that comments will be accepted until November 24, 2003,.
The UDC's comments are about impacts t o the environment, economy, water quality, and
flows in the Delaware River Basin primarily down stream of t h e Canncnsville, Pepacton,
and, Neversink Reservoirs which are owned and operated by New York City.. The ZDC is
concerned that the cumulative effect of new connections into the New York City water
supply system, including the Catskill Aqueduct, will ultimately mean more demand for
Delaware River watershed water, maldng less water available for the Delaware River a s it
flows downstream through the states of New York, Pennsylvania, New Jersey, and
Delaware.
Fully half of the 1..3billion gallons of water that the City of New York uses on a daily basis
comes from the Delaware River watershed. Because of this exportation of Delaware River
water out of the Delaware Basin into the Hudson Basin, there is less water available to
satisfy all the needs of the Delaware River.,
The proposed water pipeline will only encourage additional growth and an even greater
demand for Delaware River watershed water., We believe that. the EIS is deficient and
must address potential impacts on the Delaware River watershed, including the area below
the New York City reservoirs.
Since a water treatment plant is apparently part of the proposal anyway, we would suggest
that the previously evaluated Hudson River water alternative be used instead of tapping
into the Catskill Aqueduct..
-
Working together to conserve the Upper Delaware Scenic and Recreational River
-
-
-
-
Town of Hamock Town of Fremonr * Ibwn of Delaware Town of Cochecton * Town of Tuusten * Town of Highlnnd Town o f l d e r l m d
Town of Deerpork Lockmuoren Township Shoirola Townrhip * Wesfall Townrhip * State of New York Commonwealth of Pennsylvania
Delaware River Enrin Commission * I n pornemhip with the National Pork Service
f
Gedalve Szeeedin. Villaee CLerk. Villaee o f K i n a s Joel. November 6,2003
Pace 2
The Upper Delaware Council is the oversight body responsible for the coordinated
implementation ofthe River Management Plan for. the Upper Delaware Scenic and
Recreational River, a component of the National Wild and Scenic Rivers System. Our
voting members are t h e two states (NY and PA) and eleven local governments ( N y Towns
and PA Townships) which border on the Upper Delaware River. The Delaware River Basin
Commission (DRBC) is a non-voting member of the Council. We operate under a direct
contractual relationship with the National Park Service for. the oversight, coordination, and
implementation of many elements of the River Management Plan,.
Please add the Upper Delaware Council to your list of interested parties for this proposal,
Thank you for the opportunity to comment on this Draft EIS
Sincerely,
Bruce Selneck,
Chairman
cc:
Hon..Charles Schumer, US Senator NY
Hon. Hillary Clinton, 'US Senator NY
Hon,.Arlen Specter, US Senator PA
Hon. Rick Santorum, US Senator PA
Hon. Sue W. Kelly, US Congresswoman NY 19th District
Hon..Maurice D . Hinchey, Jr., US Congressman NY 22nd District
Hon. James T. Walsh, US Congressman NY 25th District
Hon. Donald Sherwood, US Congressman PA 10th District
Delaware River Basin Congressional Task Force members
Hon,,George E. Patalci, Governor, New York
Ron. Edward G. Rendell, Governor, Pennsylvania
Hon..Michael R. Bloomberg, Mayor, New York City
Hon. John Bonacic, NY State Senator 42nd District
Hon. Charles D. Lemmond, Jr., PA State Senator 20th District
Hon. Aileen Gunther, NY State Assemblywoman 98th District
Hon.,Clifford Crouch, NY State Assemblyman 107th District
Hon. Jerry Birmelin, PA State Representative 139th District
Hon..Sandra J. Major, PA State Representative 111th District
Jane M. Kenny, Regional Administrator, US EPA -Region 2
Donald S.Welsh, Regional Adminiskator, US EPA -Region 3
Christopher Ward, Commissioner, NYC DEP
Carol Collier, Executive Director, DRBC
Gary Paulachok, Deputy Delaware River Master
William Rudge, N Y S DEC and UDC Rep.
Wayne Elliot, Fisheries Manager, NYS DEC
Marian Hrubovcak, PA DCNR and TJDC Rep.
David Lamereaux, PA DEP and UDC Alt.
Ross B. Decker, Mayor, Port Jervis
James Chandler, Supervisor, Town of Deerpark
Richard V. Gassmann, Mayor, Matamoras
Kenneth L. Thiele, Chairman, Westfall Township Supervisors
David Fomey, Superintendent, National Park Service UDSRR
file
I
NOU-20-2003
MCGOEYrHRUSER 8 EDSRUrPC
18:15
570 296 2767
P.02/03
..
i
Vru, C b k
ChrL-rneShenkman
436.3221
29 Wesr Main Strccr
Washingconville, NewYork 10992-1412
Fax (845)496-1990
E-mail: washingronvill&@hvcrccom
Websire:washingtonuihny.org
Seuhd I723 Inmrpordicd I%YS
-
SrrvTr
49 6-7488
PalicsDtpapamnmp
496-9123
Dqammmrffibiic Wv&
17 November 2003
496-1032
Ufm7
496-1 034
Hon. Gedalye Szegedin
Village Clerk
PO Box 566
Monroe, New York 10950
REFERENCE:
COMMENTS - DElS FOR VILLAGE OF KIRYAS JOEL
PROPOSED CONNECTION TO NEW YORK CITY
CATSKILL AQUEDLJCT
Dear Han. Szegedin:
On behalf of Mayor Leonard Curcio, the Village of Washingtanville Baard of Trustees
and our residents, we have reviewed the above referenced document. Our Village also
currently relies on a groundwater aquifer for our water supply. During periods of
extended drought, we have difficulty satisfying our water demands. We respectfully
request that the DEtS address the following issues:
1" Allowing the Village of Washingtonville to tap the purposed transmission main
and utilize the water as an auxiliary/supplernentl/emergency supply during
extended periods of drought, or catastrophic mechanical failure.
2. That the Village of Kiryas Joel consider an alternative treatment plant site to
allow for treated water to be conveyed through the transmission main.
3. Allowing the Village of Washingtonville to supplement the aqueduct water when
excess water is available from our wells and during periods of aqueduct shutdown, since the Village of Kiryas Joel wells will not be able to satisfy the future
projected demand, as a back-up source.
.NOU-Z@-2E303
18:15
Hun. Szegedin
MCGOEY,HFlUSER X; EDSALLsPC
-2-
17 November 2003
On behalf of the residents of the Village of Washingtonville, we sincerely appreciate
your consideratiori of our requests.
If you or your engineers would like to discuss our technical comments, please feel free
to contact me at (888) 296-2765.
Very truly yours,
James M. Farr. P.E.
Village Engineer
cc:
Mayor Curcio and Village Board
Mr. Kevin Kropchak, UPW Superintendent
Mr. Art Jefferies. Water Works
NOU-21-2003
18:25
MCGOEY 7 HRUSER X, ELISALLI PC
5'70 296 2'76'7
P.02/03
Eugene T.Jaques
R u i M y rnyermr
(845) 676-7011
(Fax)496-1915
20 November 2003
Revised 21 November 2003
P.0. BOX 358
HORTON ROAD and ROUTE 94
BLOOMING GROVE, N.Y. 10914
Hon. Gedalye Szegedin
Village Clerk
PO Box 566
Monroe, New York 10950
REFERENCE:
COMMENTS - DEIS FOR VILLAGE OF KIRYAS JOEL
PROPOSED CONNECTION TO NEW YORK CITY
CATSKILL AQUEDlJCT
Rear Hon. Szegedin:
On behalf of Town of Blooming Grove Supervisor Charles Bohan, the Town Board and
our residents, we have reviewed the above referenced document. The proposed
transmission main routing will either adjoin or be in close proximity to three (3) Town
administered water districts along Route 208. These Districts rely on a bedrock
groundwater aquifer for their water supply. Each of these water districts is completely
built-out. Similar to the Village of Kiryas Joel situation, there are periods when the
groundwater wells can not satisfy the water demand, requiring water to be tankered into
the district. We respectfully request that the DEIS address the following issues:
1.
Allow the Town of Blooming Grove to tap the purposed transmission main and
utilize the water as an auxlliary/supplemental/emergency supply during extended
periods of droughts, catastrophic mechanical failure, or inadequate supply.
2.
That the Village of Kiryas Joel consider an alternative treatment plant site to
allow for treated water to be conveyed through the transmission main.
3.
The proposed routing will significantly Increase the traffic congestion In the Town
during construction, especially along Route 208, Clove Road and through
Salisbury Mills. Please address how these
safety and traffic congestion
concerns will be mitigated.
NOU-21-2003
10:25
MCGOEY,HFIUSER & EDSFILLrPC
Hen. Szegedin
-2-
570 296 2767
P.03/03
Revised 21 November 2003
On behalf of the residents of the Town of Blooming Grove, we sincerely appreciate your
consideration of our requests.
If you or your engineers would like to discuss our technical comments, please feel free
to contact me at (845) 496-4177.
Very truly yours,
&om
--.
m-
James M. Farr, P.E.
Town Engineer
cc:
Supervisor Bohan and Town Board
Ms.Barbara Decker, Town Clerk
ECO
K:\1999\99-20 Blwming Grove\P9-20!99-20 3Wesponse to DEI$ KJ doc
i
11/24/2003 1 Y : l Y
PAGE
8457823341
8f;lce Phone
815-928-7578
845-928-6823
Fax
845-928-8214
arnall
[email protected]
TOWN BOARD
TOWN OF WOQDBURY
51 1 ROUTE 32 * EO. BOX 1004
HIGHLAND MILLS, N E W YORK 10930
Sheila A. Conroy, Supewisor
November 21" 2003
Mr. Gedalye Szegedin, Village Clerk,
PO Box 566
Monroe NY 10950
Dear Mr. Szegedln:
I am writing In response to the Draff Environmental Impact Statement for the "Proposed
Connection to the New York City Catskill Aqueducr. Iwould like to address issues relativeto the
impacts on the wetlands and surface water, historical and archeologicalsites, endangered and
threatened species and growth with it's subsequent impacts (e.g. lnfastfuaure demands;
wastewater).
Along the pmposed route, there are major stream crossings at Moodna Creek and Perry Creek
Section2.2.3.2page 2-10 indicates "would require the pipeline to be a&xed to biidges or
culverts or buried under streams as conditions dictate". More detailed plans for mitigation,
especially in the instances of burying the pipeline for the stream crossing, should be addressed.
Also more detailed plans and preparation, not just reactionsto those impacts "monitoredin the
fieldnare needed in regard to the proximity of the many surface water areas adjacentto the
proposed route. More inclusive planning is also required in regard to the wetlands (e g. Those at
RT. 27 near MountainLodge Road) as well.
In regard to Archeological Sites and areas of Histcric significance, reliance on anecdotal evidence
or general trends ( e.g. "Native American settlements or villages tendedto be located neat critical
resources, such as water, flat or gently sloped fertile lands, or vantage points on the landscape")
are not satisfactoryfor mitigation efforts. It is highly likely that currently unknown locations of
historical and archeologicalimportance will be encountered. "As road locations have changed, it
is possible that some early historic sites are located under current roadbeds". Again, more
specific planning is required and should be delineated in the Environmental Impact Statement.
Also more specific plans are requiredfor the known archeological and historic sites such as those
on the west side of Riley Road (USN #07115.0000706 and USNO7115.0000707 and the historic
sites along R t 94.
In Section 2.3.3 The DElS discusses Endangeredand Threatened Species and although "no
Federal or State listed or proposed endangered or threatened species are know to exist within the
project study area". What plans for mitigation does the proposed project have in the event that
such species am discovered in the project area?
The 14 wells currently used by the village are being wnsldered as a backup supply. Will this back
Up supply be adequate when the NYCDEP shuts down the Aquedud as they do on a regular
basis (for approximately3 days) and cuts off that water for use?
02
11/24/2003 19: 19
-
8457823341
PAGE 03
Page two, Response to UEIS. continued
Have the impacts to the region been considered in any detail? Does the pmject mnsider impacts
to the watershed areas in the region? What studies have been conducted to determine the impact
to the Ramapo River watershed?
Section 2.8.2, the increase in the population due to large family size is discussed. "The lack of
essential seruices, such as drinking water has not slowed populationgrowth in Kiryas Joel'.
While the intention ofthe project may not be to encourage "significant additional growth" due to
an influx of residents from outside the village, it is very likely that such growth will occur. The
provision of an additional essential service (water supply) would supplement the already
occurring gmwth (due to family size),.This would have an immediate effecton the infrastructure
on the surrounding areas and in the region, Including, but not limited to roads and wastewater
treatment facilities. What plans are in place to address these issues?
Based on the information !hat I have presented here, I find the plans discussed in the DElS
inadequate. I ask that better preparationsbe made to address fhese issues.
Sound regional pianningwill benefit those in the Village of ffiryas Joel and their neighbors in
the surroundirig a m .
Thank you for your time arid attention in this matter
r-\
Council Member, Town of Woodbury
511 R t 32
HighlandMills NY 10930
CE Honorable Sheila Conmy
Honorable Nancy Calhoun
Honorable Bill Larkin
Town Clark
file
I
11/24/2003
8457823341
19:19
Otlice Phone
845-928-8214
TOWN BOARD
TOWN OF WOODBURY
511 ROUTE 32 RO. BOX 1oocl
HIGHLAND MILLS, NEW YORK 1093a
email
[email protected]
Sheila A. Conroy, Supervisor
845-928-7578
845..928*6829
Fax
November 23,2003
Mr. Gedalye Szegedin, Village Clerk
Municipal Building
51 Forest Road, P. 0.Box 566
Monroe. New York 10950
RE: Comments on D.E.I.S.
Village of Kiryas Joel Connection to N.Y.C. Aqueducrt
Dcar Mr. Szegedin:
Thank you for including the Town of Woodbury as an interested party and for a copy of the complete
D.E.I.S. Since the preferred pipeline route in this document is indicated as going via Blooming Grove, some
of our earlier comments about impacts to Woodbury, in the scope document, (Elating to noise, dust, traffic
id other conshruction issues) have been reduced. We do have, howcvm, some comments on the c u m t
document, which are as follow:
1)
DEIS,Section 1.2 and Throu~houtthe Document: Need for the Proposed Aotion
A) This section of the DEI3 states that there is need for additional sourccs of drinkiig water for the
Village. Page 3-1 1 further states that the planning time frame for the aqueduct connection i s 20 yeas
However, here and thugbout the document there is no concrete analysis that p j e c t s the population of
w
a
s Joel 20 years into the future in order to determine how muchwater is needed to support the needs
identitied above. In other words, the DEE claims the project is needed to support the Village for the
next 20 years, but does not provide projections ofths population for the neKt 20 years. Therefore. onc
cannot determine how long it would take for the Village to exceed the supply h r n the aqueduct-- is it
10 years, 15 years, or 20 years? There is no way to verify or determine this from the information in the
DEIS.
Using the approximate 6% annual population growth kctor referenced throughout the document, it i s
estimated that ViUage wells would be deactivated f i r only 4 (four) years following the prbjected
completion of the project in 2008. Using the same growth rate, by 2010, the Village would need to start
pumping its wells again in order to supply the peak generation on religious hoiidays (using a figure of 88
gallons per capita per day calculated fi-om 2002 peak water use as shown in Table 2-1 of this documen\
divided by the 2002 projected population of 14,762), which would occur 50 to 75 days per yea'. By
201 1, only S years after connection to the aqueduct, it is likely that the Village will have to activate its
groundwater wells &I1 time in order to meet an average daily demand (based on 82.83 gallons per capita
per day as reported inConnection to New York City Aquedvci Preliminmy Reportfor Conceptuai
Approval of 2.07 mdday.
PACE
DEIS :Aqueduct Connectioa
Page #2
a5
November 23.2003
Again, using the projected annual growth rate, by 2020. only 14 years after completion of the connection
to the aqueduct, the Village‘s population will rcach 42,132 iesidcnts. needing an average of3.49 mglday.
Totaling these figures, it appears that in just 14 years, the Village’s average daily demand will exceed
both the supply o f its existing groundwater wells as well as the proposed 2.0 MGD fiom the aqueduct
connection.
AII of the above is predicated on a 6% gmwrh rate. However, it should be noted that on pages 1-3 of the
DEIS it stares that the m i a g e rate is increasing which may make this rate too conservative in which
m e the average daily demand will exceed both groundwater well and aqueduct connections even sooner
than 14 years.
We believe that the DEIS should present a detailed projection of population, using numbers from its own
history, over the twenty years fiom the completion of the project. This should include an estimate of the
amount of water needed each year, again based on historical records for the Village. Lastly, the DEIS
(
should identify when the Village’s population will exceed the capacity of its well fields, then the capacity
o f the aqueduct and finally the capacity ofthe well fields and the aqueduct working together. The DEIS
does not give quantities for the current shortfall during holidays. For example, how much water is
trucked in when the shortfalls occur? Are there other occasions, besides religious holidays, when there
are water shortages? On Page 1-2 and 1-3, the DEIS states: “As a result of the commudty’s religious
practices, peak flows are generally caused by preparation h r holiday periods and the Sabbatk High
demands have occwed during the temporary influx ofpopulation for holidays, and also on the
anniversary o f the death of Grand Rabbi Joel Teitelbaum, founder of Kiryas Joel. Peak daily demands
typcially occur 50 to 75 days per year.” What are these peaks---how much additional water is needed?
what is the actual consumption on those 50 to 75 days?
Unless shown to the contrary, tapping into the Aqueduct wiU only temporarily satisfy these growth rates
and water needs. In only a fkw years, much less than 20 years, the Village will find itselfright back
where is it now. This has sigaifiwat ~
~ for swronnding
~
aquifers
~
and private
~
walls.~
While the aqueduct connection may provide temporary relie$ in a few years the d e m d will again be
there to draw water from the already inadequate local wells. The DEB needs to address this.
k
On Page 1-1 ofthe DEIS, it states that the average per capita water consumption in the Village is
sub-tially
lower than in both Orange County and New Yo& State. Please provide nmbers and
documentation, such as fiom meter readings, to substantiate this claim. Thesc per capita figures
should also include water usagc for communal fiicilitics.
2. DEIS.Section 1.3: P m s e of Proiect
The DEIS states that the purposes of the projecr are:
o
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Establish a long-term consisrent high-quality water supply for a gtowhg community,
* Reduce the dependence ofthe Village on groundwater as its source ofdrinking water.
B
Establish a drinking water supply that avoids conflict with surrounding communities,
e Reduce vulnerability to drought by broadening the area from which water can be drawn,
e Avoid or minimize adverse impacts to the environment, the Village, and surrounding communities.
(I
Using the CalcuIations shown above, connection to the aqueduct will serve the stated purposes of the
projeet for only 5 to 14 years after its completion We estimate that Within 5 years after completion
of the aqueduct connection, Kiryas Joel would ome more be inmasingly dependent upon groundwater
and would generate potential impacts (from traffic gom water tank trucks and/or damage to aquifm and
neighboring wells kom over pumping --see B Groundwater Resources) on its neighbors whenever the
aqueduct needs to be shutdown, either for maintenance or for unforeseen circumstances. Ilk would
potentially raise conflicts betweenthe communities With which it shares the aquifer. Met 14 years, the
Vdlage would be dependent again on its fill permitted groundwater capacity and would be susceptible to
local droughts. Therefore, the project sponsor's pre&rred alternative does not serve the purpose of the
proposexi action for the full planning period and additional ahernatives should be explored.
3. DEIS. Section 23: Surface Water Resources
The DEIS states that the aqueduct pipeline will cross the Moodna Creek and potentially other streams, via
attachments to existing bridges. It is agreed that this would be less disruptive to the environment, but
how does this assure that the pipeline is not susceptible to damage during extremdy cold weather, damage
duriag bridge and roadway repairsliprovements, and to damage &om intentional mischief or sabotage,
Damage to the pipeline or any interruption of service could drastically decrease the water supply in the
Village, especially as it continues to grow and becomes dependent upon this supply (which has been
demonstrated above).
4.
DEIS. Section 2.4: Geology
A. Page240 lists the first two mitigations for blasting and discusses adherence to laws and permitting
procedurm. The DEIS states that the requirement of inspection ofoff-site properties previous to
blasting would only be conducted when requested or authorized by the owner. Some property owners
may not understand their rights to request mspection as the mitigation is presently written. We
recornmead that the project sponsor be required to send notice of bIasting by certified mait to alI
property owners within 500 feet of blasting. This notice should include information in clear language
regarding how the property owner can make an appointment for pre- and post-blasting inspections. We
aIso recommend monitoring of any public and private watm supply wells within 500 feet of blasting. A
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plan for this monitoring should be made part ofthe UEIS sa that it can be commented upon by the public,
especially those directly affected.
5. DER. Section 2.9. Land Use
A. Under land use analysis, Figure 2-12 used USGS satellite imagery to denote the uses dong the proposed
aqueduct mutes. More detailed and accurate data is available fromOrange County Water Authority.
We believe that ifthe DEIS considered the land use data available 60m OCWA, they would find that a
greater density ofresidential and nonresidential uses exist along some of the State and County conidors.
We request that the land use analysis be repeated with the OCWA data
B. The DEIS addresses the recently adopted Orange County Compreheusive Plan by correctly describing
K k y s Joel’s status as a priority growth area. However, the Plan goes beyond just describing where
growth should occur. A priority addressed in the Envimnmena I n f r a s t r u c ~Strategy section of the
Plan is to “...give priority to regionalizing water resourses by hterconnecthg systems.” while the
DEIS repeatedly states that neighboring communities have been ~nwillingto help Kirym Joel meet its
drkkiig water needs, it also states that these communities have been experiencing growth of their own.
In &ct, all of southeast Orange County has been dealing withwater shortage problems recently and
communities inthe area have all been required to issue water use restrictions OMC the last five years.
This has left communities unable to help each other with drinking water shortages, and has resulted in an
environment where cornunities are constantly monitoring each other’s consumption. Neighboring
communities have been loolcing to deal with water needs in a variety of ways including summer water
restrictions, increasing water usage rates in the summer, modifying zoning by looking at both potable
water and wasterwater needs. We q u e s t that another a l t d i v e be included inthe DEIS that considers
a regional approach to providing drinking water including assessing the possibility of partaring with
neighboring communities to share the benefits and the costs of tapping into the aqueduct and
withdrawing larger amounts of water to benefit the region, perhaps only on an emergency basis, such as
duriug the 2002 summer‘s drought.
6. DEIS.Section2.10:
Traffic
The DElS discusses possible restrictions prohibiting construction during comuter hours. This should
definitely be identified as a required mitigation on all State and County roads, Careful planning needs to
go into work schedules, notlfying the public ofwork schedules and detours so as to be less disruptive to
the general public.
(
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LDEIS. Section 2.1 I: Noise
There seem to an inconsistency in the document concerning noise and hours of construction The DEIS
states that as a mitigation that “...nighttime and weekend construction would be avoided to the maximum
extend possible,” However, as a mitigation to traffic the DEIS states that “...consideration would be
given to utilizing nighttime construction to help minimize traffic.” We rccommend that the DEIS provide
cliteria for detenninmg areas ofthe pipeline route where r&httime construction may be preferable
Nighttime and weekend construction schedules should balance the needs to commuters with the needs for
limited noise inresidential areas that could interfere with people’s sleep and work activities.
We &rther requst that construction on weekends or during commuter hours be expressly prohibited if
either of the other alternate pipeline Toutes are considered.
-DEIS. Section 2.13:
Utilities
A. The discussion of wastewater treahent included in the DEIS is not adequate to conclude that there
will not be an impact to wastewater txeatment inconnection with the proposed action. The existing
Harriman Sewer Plant is being expanded but is now operating at full permitted capacity. What level of
growth for the Village of Kiryns Joel was included in planaing the expansion of the plant and is the
Combination of the plant and the Village adequate to serve the additional population supported by the.
proposed action?
As described in the DEIS,the expansion of the Harriman Sewer Plant is planned in order to accommodate
1.5 MGD of effluent anticipated from already approved projects. The DEIS states that .35 MGD of
capacity of the Village Wastewater Treatment Plant is cumntly leased to neighboring communities. If the
Village terminates thB lease, the neighboring communities will increase their usage of the Harriman
Sewer Plant Therefore, it would seem that there is currently no excess of sewer treatment at the Harriman
Plant as expanded and the Kiryas Joel Wastewater Treatment Plant. Details on the current capacities, and
c ~ ndemands
t
for sewage treatment at the Harriman and the Kiryas Joel plant need to be provided. Also
projections should be made as to the future capacity and demands for scwage treatment at the time o f
completion of the aqueduct connection and at five, ten, fifceen and twenty years d e r the aqueduct
connection.
We do not believe that there is an existing way to dispose ofthe additional 0.7 MGD ofwastewater that
would be generated by the population that would be supported when groundwater wells are down and the
weduct is brought on line. Unless growth mitigation is suggested at some time in the future. it is likely
.iat the Village will be ushg both its groundwater wells and the aqueduct. At that time. up to 2MGD of
additional Wastewater treatment capacity will be rcquired beyond what is available to the region today.
The environmental document should detail how impacts to wastewater treatment %om the additional
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November 23,2003
population js to be supported by the aqueduct will be mitigated and hnded
Increased water availability and usage must be evaluated at both ends of the equation--- drinking water
and wastewater. The DEIS does nor adequately address the wastewater end of the equation.
B. Throughout &e DEIS,the document states that the proposed action would reduce stress on the aquifer
from which water is currently drawn. On page 2-84 the DEIS states. “This would reduce the potential for
Kiryas Joel’s wells to compete with private wells for the same groundwater.”
We note that when the aqueduct connection is completed in 2006, the Village will have a projected
population of 18,636. At this point, the population of the Village would demand an average of
1.54 MGD. This demands exceeds the permitted yield of the Village’s wells. Ifthe aqueduct is deactivated for any reason, (the DEIS discusses regular deactivation by NYC &r maintenance),the
(
ill not have adequate back up to supply its needs and it may be forced to over pump the q ~ e r
Viuage w
or bring in water via trucks to compensate. In either case, Woodbury would be impacted Born potential
damage and draw down ofits water supply aquifer with potential negative impacts on surrounding wells
and increased traftic for trucking in needed water.
WiU the Village keep its &ts
to withdraw 1.31 MGD for its water supply wells? At the cuxrent
growth rates, how long will it be behre the ViUagc will be required to use its wells in providing the
average daily demand for water? How long will it be befbre the Village need to use its wells to provide
for increased water demands on holidays or days of special observances? How often will the latter
occur? How does the aqueduct reduce st~esson neighboring communities and property owners if such
entities willnot have access to the 1.31 MGD currently permitted to Kiryas Joel, and ifKkyas Joel must
resume pumping the aquifer to supply its average daily nced again in the future, which seems very
likely and sooner rather than later.
Backup Wen Supply Impacts to Area Wells:: NYC requircs nnroicipalities connected to their aqueducts
must have a second source o f wafer. This is required in case the city must shut down aqueducts for
Wection and/or maintenancdrepairs. Inspections are &Frequent, but d
y ofshort d d o a
Hotvever, maintenance canrequire removal fiom service for extended periods of tirnc. The DEJS does
not address this at all nor what provisions will be made to supply alternate water h r a community that
will become dependent upon the aqueduct for its primary water source. If the aqueduct is shut down
%ra major q a k requiring use o f an alternate water supply for say six months or longer and the Village
has increased water demand to 3 MGD or 4 MGD, the existing well supplies will not be sufficient.
(
Additionally, ifgrowth continues without regard to land management techniques. adequate auxiliary
water supply will nor be available to make up the gap. The DEIS aliudes to the need f i r back up when it
states on Page 3-3: “ Akhough groundwater supply wells do not meet the objectives as stated in Sectim
1,3 of this docwtent. under the proposed action, existing and future groundwater wells would be required
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to provide a back-up water source if the Aqueduct flow were interrupted (e.g., For maintenance).” While
the DEIS c o m the need for a back-up source, it does not elaborate on how this will be
accomplished. Information about what type ofback-up, how much supply need to be addressed
DEIS. This could have significant impact to the Village andlor New York City’s ability to properly
operate and maintain its aqueduct system.
9. DEIS, Section 2.14 Enerq
__ The document states thai 4.900 kwh would be required to DUW the maximum oermitted flow thmunhout
the aqueduct. It Mer &es that this would be 0-Betby {he decrease in electrkty needed to operate the
Village’s groundwater wells. what is the electricity that is cunentIy consumed to run all ofthe Village’s
wells? The Village wiil eventually need to run existing wells in addition to the aqueduct to support the
future population By our calculations, this will be in less than Z 5 years. How m c h electricity would be
needed to run the wells, the well water treatment famrlties. the aqueduct pump station, and the aqueductwater treatment facilities? In consideration of the recent electrical problems that were experienced across
the east coast and the occasional outages that occur yearly, what methods could be explored to mitigats
some of this significant electrical consumption? Could solar energy be integrated into the system? Would
additional water storage tank capacity help to mitigate spikes of higher electrical consumption associated
with peak water demand, such as in the summer or during religious holidays? How would the additional
population suppoded by the increased water supply contribute to an increase m electrical consumption?
In the c a s of an extended blackout, such as the one recently e-enced,
wiU thme be a backup
generator to maintain water service to the cornunity and to reduce the pokential water-hammer as
described in the DEIS (page 2-8) as ‘Yhe most significant design issue?” Should electricity fail, how long
would stored wafer last and should expanding the Village’s volumes be explored?
10. DEIS,Section2.16: Haxardous Waste
.- The DEIS states that
“Because ofthe small quantities of {polyaluminumchloride and sodium
hypochlorite) involved {in water treatment), even a sudden and complete tank &lure would be unlikely
to cawe significant health problems inthe time it would take to evacuate the effected area.” The effected
area should be described. Will the ef&cted area include any lands located adjacent to or within the
boundariesO f Woodbury? Please describe fully.
11. DEB. Section 3.3: Alternate Piueljne R o u b
A. The DEIS has not explored the potential for endangered or threatened species at the altrrrnate water
Treatment site. The DEIS should contact DEC‘s Natural Heritage program to determine the presence of
endangered or threatened species. The alternative water treatment site should be field checked for
endangered and threatened flora and fauna :timber rattlesnakes are known to inhabit the Schumemunk
Mountains.
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B. We agree that the project sponsor’s preferred route of Rt. 208/27/94would cause less disruption to
traffic rhan using Rt. 32 and County Rt. 44. In reviewing the alternative analyses, it was not made clear
what impacts to traffic flow could be anticipated for each alternative construction route. ’Ibis is
extremely important for Rt. 32 alternatives because the Rt. 32 corridor is already over its design capacity
and experiences low levels ofservice. We strongly believe that the environmental impacts fiom pursuing
the alternate mutes has not been examined at an adequate level of detail. I f the project sponsor intends to
pursue either alternate routes, much more analysis must be provided with the opportunity to respond to
this prior to the FEIS. For cxample, the environmental review should include a “hard look” at impacts to
traffic flow, including traffic flow at intersections both south and north ofareas of construction- Ifthe
p r e f d mute is via Blooming Grove then there is no need to pursue futher impact analysis on the other
alternatc mutes.
12. DBS.Section 6: Induced Growth
A. The DEIS states that this project will not induce growth because water will not be made available to
neighboring communities and because the ViUage must grow due to its religious requirements. More
specifically, the DEIS states that large fkmilies are a response to religious obligations and that women
must stay in the community to raise their own h i l i e s . The DEIS states that, ‘Whether or not the
proposed aqueduct connection is implemented, U y a s Joel will continue to grow.”
i
All life on the planet is bound by natural limitations to popuJation. In New York State, water and sewage
treatment are two factors that determine the population that a given tract o f land can support. The
statement in the DEIS belies the f i t s : a population cannot be supported without an adequate drinking
water supply and a sa% means to treat resulting sewage.
Kicyas Joel is already the densest community in Orange County (according to the 2000 census) and may
already ~ V reached
E
double the population density ofthc next densest community, the City ofNewburgh.
Questions wise as to why g~owthmauagement has not been investigated as part of this DEB. it is
i m p o m to the commUnity to plan fir a safl: and healrhful environment Eor itself and its neighbors. The
DEIS should address this. At some point it will become physically impossible to accommodate additional
population withh Kiryas Joel. Rather than wait until the next time the Village runs out of water, sewer,
vacant land, road capacity, or any other naturaI constraint to growth, shouldn’t this DEIS ask difficult
questions such as how many people can be supported by existing infrastructure and how wiil
improvements to hftastmcture increase the carrying load ofthe land. At the ~~I&TXUILtbe Growth
Inducing Aspects section should a s s how many Village residents currently are able to acquire adequate
amounts of water to maintain a healthful standard of living; and how many additional persons would be
(
accommodated with the additional water to be supplied by the aqueduct. The Growth Inducing Aspects
section should also assess how the existing infrastnrcture (including sewage treatment and roadways) of the
Village and surrounding communities would able to support the additional population. We believe that
taking a hard look the potential impacts ifom the additional population comcnmrate with increased
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availability of drinking water i s a SEQRA nquuement. This requirement is not addressed by s t a t h .
contraxy to hct, that population growth can occur without a supply of drinking water. Despite the
obligations of the Village's religious practices, SEQRA and Municipal Zoning require acceptance of
responsible land management practices.
In terms ofgrowth, it ic important to note certain themes repeated in the DEIS regarding growth and water
supply:
e
D
Although the letter fiom the MYC Water Board acknowledges that &as
Joel is entitled to
withdraw 1.1 MGD based on its population (1990 census), the DEIS repeatedly states that the I
Village is now entitled to withdraw approximately 1.OMGR based on the 2000 census. Which is
correct? From this, can one assume that the Village w
ill modify its entitlement requests after each
I
c m w and increase it taking ofwater from the aqueduct?
In support of a 24 inch diameter water main, the DEIS indicates that is needed to satis@the 20
design period ( and to save energy). It also notes that infrastructureof this type is usually in service
for a minimum ofSO years, often closer to 100 years. Although pipe selection is reported to have
been based on a2MGD design, the DEIS acknowledges that the Village is already entitled to 1.9
MGD (using the 2000 census). In reality, if the Village continues to grow at 6% per year as the
DEIS states, they will increase 320% h i n their current size within the 20 year design period ofthis
project. Since water demand during recent peak periods is over 1.3 MGD @El& page 1-3), a
320% increase would require approximately 4.2 MGD. Although an 18 inch diameter pipe could
provide 2 MGD,the head-loss at 4.2 MGD would be great and most likely would require a second
booster pump station. However, 4.2 MCJD could be transmitted easily through a 24 inch diameter
pipe.
There is a possibility that this action m y support migration into the community fkomelsewhere as well
8s the natural growth ofthe community due to marriages and births. For example, while young
women must remain inthe Village to raise their families, do h b a n d s come fiom outside Kiryas Joel?
The possibility o f outside migration should be seriously explored unless the Village has a plan to
prevent such migration from occurrinp.
Under mitigations, there should be discussion ofwater conservationplanning. such as educating the
community on ways to reduce water usage, testing for and implementing a program to reduce leaks in
the system so as to not lose water in this rnmner, requiring water saving plumbing in all business and
residential construction, testing ofboth residential and commercial water meters to insure that they arc
accurate so that the Village kocws how much water is really being used, tracking water bills to tind
ones that show an abnomally high reading in a cycle which might indicate a leak. Such a plan could
reduce sewage outflow. Page 1-3, under "Previous Work to Expand the Water Supply" references
implementation of water conservation measures but does not elaborate as to what these methods are.
how long they have been in effect and how succcssfUl they have been. Considering the growing
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population and water needs, an aggressive water conservation program i s mcial and should be detailed
more fi~llyin the DEIS.
Lastly, these comments have focused on the Bloomiug Grove route since that is the one that seems to
be preferred and was examined the most fully in this DQS. The other two alternatives were addscssed
minimally, which is understandable since they appear to not be the one chosen. However, should this
change, it is hoped that the communities involved in the other alternatives wiU be given the opportunity
to respond to a&ed plan. It seems time consuming to go into detailed responses on these two
alternate mutes unless there is xeconsiderau'on ofeither one as the actual route to be selected.
Thank YOU for the 0pportUnity to review the document and to attend the public hearing. We attended
CA
the hearing but decided to put our comments into W I ~ ~ ~form.
Sincerely yours,
Sheila A. Conroy
Cc: TownClerk
Town Board
i
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DAVID E. CliURC1%,RlCP
COhfiIISSIONER.
Novnnber 24,2003
Gedalye Szegedin
Village Clerk, Village of Kiryas Joel
PO Box 566
Momoe, New York 10950
re: Preliminary Conments
DEIS Proposed Connection to the New York City Catskill Aqueduct
The Orange County Departments of Environmental Facilities, Public Works,and Planninshave
cooperatively reviewed the Draft Environmentd Impact Statement (DEIS)fm tbe haposed
Conaection to the Ncw Yo& City Catskill. Aqueduct, dated October 2003, and together forward
to you the followiqg commts. We also appreciate your willingness to extend, by two days,
our opportunify to comment ns per your telephone conversation with David Church,
Commissioner of Planning,
Knitially, these Departments need to make three (3) l a d comments, First, WE request that
Orange County, Orangc County Sewer District No. 1, and all three D'epanmenrs noted above be
listed as involved agencies under SEQR in relation to this proposal. Second,we ask for your
patience inreceiving our comments as there rnnains a question as to whether each or any of
these CountyEgerKk have received complete prior, public notice. This has agpavatcd ow
abiliw to promptly review this important DEIS within your schedule. Therefore, we are @king
for an additional ten (1 0) day extension to allow the County r~ be sure that we €we completed
OWreview in light ofthis tight riming.
Third, we together raise the important question, under N Y S SEQq as to whelbm the DEE Bs
presented has met the test oftaking a '%hard look" at some issues that are particdarly important
to the County. These issues are elaborated below and include: village growth projections and
tbeirrelatimsbip to water usage, associated sewage treatment requirments with growth in
population end water usage, and alternatives to manage population growlh, water usage and
sibsequent sewage treatment.
A. The Department of Public Works' Comments FUEfocused on the proposed 24" pipcline
muing along County Route (CR)27 to supply water to the Village o f Kiryas Joel
1.
Page 5-2 o f the DEIS discusses the need TO attech the pipe to the County bridge across
the Moodna Creek. The document also sate9 that intention to ntt~chthe pipe to other bridges
along the way. At 2MGD the pipe will transmit almost 1,400 GPM. The DEIS should explain
maintmmce responsibilities for this pipeline as well as protocols for maintenance during
orang?County ~0mr)lenrSonDEIS, Proposed Catskill Aqueduct Connection, Village of Tziryas Joel
November 25,2003 page 1 o f 5
lJ!XLWI.I
bridge work or reconstruction.
i
On page 5-2 i t says that the Village may have to insrdl the pipe in the shoulder or
2.
roadway due to adjacent wetlands. This could pose a safety threat ta the traveling public if the
pipe should ever fail. A flow of 1,400 GPM could easily wash out rhe roadway. Given char
this is not a well-lit road and that it has a great deal of both v d c d and horizon& cmafme, a
wash out at night could be life threatening to anybody driving on it,
On page S-5 the Orange County Department of Environmental Services and Orange
3.
County Sewer District No. 1 should be, but are nor, included on &e lis1 o f agencies fiom which
permits and approvals n a y bc required. In addition, the Urangc County Depa\tment of Public
Works should be included on the list. Required approvals include, but are nor nccessady
limited to, a pe,mit for the proposed discbarge of &e backwash kom the proposed water
filtrationplant into Orange County Sewer District No, 1 sewers. The DEJSGIs to provide
altematives to discharge into the County sewer in &e event a permit is not issued.. It does not
addrcss the details ofthe dischargein terms of content, quantity, effect on hydraulic capacity of
the @ne;
tines, whether rhe discbarge would o c a during peak or OR-peak how$, and
where, within the County sewer system, the disdwge will occur.
Sedon 2.13.12 (Wasrewater) fails to adquarely address, qmtiutively and qualitatively, how
wastewater generated tiom the increaed water consumption, will be bented in the event rfm
them is k f f i c i e n t treatment capacity at the Hamman and Village plants. This section stares
that "[tlhe current expansion ofboth the HgIiiman TKwrp and Kiryas Joel's own wastewater
treatmcnr facility would accommodate a large increase in wastewater discharges fromKiryas (
Joel." The DEIS should provide quantifiableinformation about these faciltity capacities and
this 'large haease?'.
The proposed 2.0 MGD additional water capaciry appereatly exceeds the combined, available
trcabnent capacity of the expanded H&m and Village treatment pia&, wen if there was no
additional capacity from other p q m t k i within the spwer district. This section fails to ptoject
increasedwastewater treatment needs ofthe rest of the District and how any such increased
demand will impact the proposal. Nor does the section take into account the participation in
the expansion by municipal capltraa users of the Haniman plant that are not part o f OCSD #f 1
which would reduce the available, expanded keatment capacity within OCSD #l. "he T o m
of Woodbury and Blooming Grove have already committed to purchasing a share of the
additional capacity, In addition, while tho current lease between the County and the Village
expires in 2004, the lease contains an option clause for two additional onP.year extarsions of
the lease.
On page S-5 i s a list of the appovals that are needed. They should add the Orange
County DPW to the list for any work that is done within the right-of-way of my Corntyroad
The full list of County agencies provided on page 1, paramp112 should also be added M each
may have permitting or review authority.
4.
5.
On page 1-8 the trench is described as being 4' wide and 4.5' deep. The depth o f the
trench has to be greater than that to allow for furure drainage installations. Tne depth to the top
i
O f the Water main should be 4,5', minimum.
Orange County cammems on DEIS, Proposed CatskiU Aqueduct Connection, Village of K i m 5 JOG1
November 25,2003 page 2 of 5
On page f -10 the County DPW should be listed as an involved agcncy. County
6.
Environmental Facilities and Planning should also be listed as “interested pnrties”.
Page 2-53, Table 2-7lists projected population growh out to the year 2025. Using a
7.
daily watm demand of 60 gallons per capita for water consumption, we gct the Follolving watcy
needs for Kiryas Joe[ and m o u n d i n g municipalities:
2000
2010
2015
-
.- 2020
2025
.“_-
Even wi& the Aqueduct connection, the VilIage may not have enough watcr much pest
the year 2015. ms amount of population growth and water use will also require M e r
expansions o f the Orange County Sewer District 1 treatment plant in Harriman. The
relationship of increased w m use to demands and capacity at Sewer District 1 as well as
dtmative options fox necessary sewage treatment should be further discussed.
7.
On page 2-64 i s B list of the AADT for roads dong the construction path. However, the
DEB fails to show rhe AADT for the first Z miles of CR 27 starting at the intersection o f CB
27 and NYS Route 208. The AADT for that stretch of CR 27 is 5060. The AADT for the
balance ofCR 27 i s shown and is approximately 3300.
Page 2-64 states thar the intersection of NYS Route 208 and CR 27 is controllcd with a
8.
Wfio signal. That i s in error a8 the intersection i s controlled with a stop sign.
B. The Department ofEpvironmeotaI Facilities and Services offersthe following additional.
comments.
On Page SI, 1-1, and throughout otha relcvant arms of the report, the Census population &om
1990 and 2000 is used to project mualgrowth rate @ 5.9%. The report also discusses a less
than average water usage ptz capita rate for W a g e residents without reporting the value us&
in the report. What is the water use per capita value CDM is using for the Village of KiVaS
Joel? The report should include a, tabulated projection of papulation and water consumption for
the next 25 years to complement the assessment of impacts tha! are associated with
constructiono f the proposed w&er transmission line.
On page S2, and throughout other relevant arm of the repoa, the construction of E new water
in the Viliage will need to be c o n m c r e d The ~cypeof
f i ~ ~ plant
0 5offfBerdichev Road
treatment reipired is discussed in the report and suggests the generation ofraw sludge that will
require handling and disposal How will the raw sludge be handled a d ultimately disposed off
Orange County comments onDEIS. Proposed Catskill Aqueduct Connection, Village o f Kiryas Joel
November 25,2003 page 3 of 5
OUPLAEl
PAGE
05
rliw
u*
What daily volume ofraw sludge v d l be produced? What pacent solids will the raw sludge
consist of snd what elemmu and compounds will the raw sludge consist of!
(
On Page S5, and throughout other relevant areas of the DEIS, the Orange County Deparhnent
of Environniental Facilities and Sm’ces i s not included and it should be. ’This is especially
me with respecr ro a potential proposal to discharge backwash water inro OCSDl Sewers from
the new Water Filtration Plant proposed for con&uction on Berdichev Road in the Village.
On Pagc 1-6, a 24“ diameter pipeline is justified due to energy cost savings. For the proposed
route, has a System Head Curve for the 13 miles of 24“ diameter pipeline been generated md
can it be provided for ?
.%&a revim7 What is the cost effective, maximum carrying capacity
of rhe proposed 24” diameter X 13-mile long pipcline.
On Page 2-10, the DEIS states that there will be no problem with the rnaximm flow of the
Moodna Creek due to the proposed pipeline being suspended &ORI the bridge. What year fl aod
mark was ked to support this sratement and what i s the differmud between the invert of the
pipe for the flood mark used as well as for the 100-Year Flood Mark if different?
“he Planning Department’s primary authority in reviewing the DEB is via N Y S Qeneral
a focus on ‘’intercommunity’’ or county-wide concern. As @dancein
Municipal Law
our review, we xefkrmce the 2003 Orango County Comprehensive Plan T h a t Plan supports (
the vitality ofthe Village of x(iryas Joel, and identifies the Village as an e l m a t of the Priority
Growth Areas of the County. The 2003 County Plan also identifies rhe importance of defining
the ‘%anycapacitid’ of comnunjties, notably in the context of public water and sewage
treatment; the Plan alw emplaasizes the necessity ofmunicipd partnerships in addressing these
and other key issues.
I
The~efore,we appreciate your proactive effons towards overwming waIer carrying capaciry
limitations given the rate of growth and development the Village has shown d a n g your fmt
25 years ofincorporation. The County appreciates your proposal’s objective in “estnblishing 4
potable water supply that avoids conflictwith surrounding comrnunifies.” However we have a
certain commentg in that context.
(1) Section 1.2.4, pqge 1-4 of the DEI3 sets the two key conditions motivating the Village of
Kiryas Joel to advance this proposal as outlined in the DEIS, (1) ‘The Village of Kiryas
Joel’s aisthg water supply system is minimally adequate for its present population. ,.,,
and (2) ..the Village will need increasing amounts of potable watcr as it continues to
grow.” Section 1.3 goes on in.establishingfive (5) objectives for rhe proposal consistent
with these key conditions. Unfortunately, the DEE lacks adequate documentation
qumtifying current aminst future growth nor do= it translate such quantifiahle analysis
hm fume water demands. With the incrcaaed availability of water supply and wastewater
trearmeat and a large demand for housing in areas outside ofthe Village, how will the
influx of outside community housing development be wbed, controlled andlor prevemed
(
within Che ViUage? Our recommendation i s thar Section 1.2Weed” includes same
daboxation on future g o w h and demands for water infrastsuctllre, ideally using a
quantifiable methodology and projected out in time for a reasonable period related 10 The
I
‘I..
orange couoty conunents on DEE, Proposed Catskill Aqueduct Connection, Village o l E r y a s Joel
November 25.2003 m e e 4 of S
PAGE
rkl:c
06
',.A
limitations of %heproposal
(2) Sedion 2, Environmental Setting, Direct hpacrs and Mitigation fails to adeqwrely addrcss
&e rclatiowhip of current,expanded, or new sewage treatment faoiljties to the proposal.
This is ofparticularly interest to Orange County inrclationship to Orange Comw Sewer
District I (see prior commenrs). While Section 2.13.1,2 does summarize current conditions
as relared to wastewaster treatment, the DEIS is silent an impacts for future sewage
treatment associated with the facilitation of Village growth via improved water capacity.
(3) Section 6, Growth-Jhducing Aspects, as welf as elsewhere in 'the DEIS. We concut that the
inherent name of the specific proposal applies only to meeting water demands within the
Villagc of Kiryas Joel agd that growth .inducement outside of the Village as a result of
access io the N Y S Catskill Aqueduct is not intendedwith this p j e c t . Howevet, there is
bo& a trend of regional growth and a Clem rrcord of interest by the neighboring
municipalities along &e proposed waterline regarding futurc access to this pipeline andor
s h e use of the aqueduct tap. Those neighbots have expressed B range of interests from
access a9 Community backup ~ u p p k iaccess
,
to address cefin, existing neighborhood
shortages, as well as &e influences of improvcd water capacities on development expansion
from the Village into neighboring Towns. The DEIS should provide same further
fiscussion on these issues. At a mhimum, die DEIS should, in Section G, provide n record
ofgrowtb trends and water needs in the immedixte region ofthe Village and along rbe
pipeline routes, and the DEE should review any recard or discussion wi& Town and
Village leaders in this region awd dong these routes relevant to water needs and prospective
access to CatskiIll aqueduct water.
Should you have any questions please contact Edmund Pares,Commissioner af Public Works,
David Churcb, Commissioner afPlaming,
Submittea on behalf of the Orange County depparunents of Public Works, Environmental
Facilities and Services, and Planning,
David Church
Commissioner of Planning
cc:
Edmund Fares, Commissioner ofpublic Works
William Gunther, Commissioner o f Environmental Facilities
Ormge Coumy commcnts on DEIS, Proposed Calskill Aqueduct Connection, Villagc of Kiryas Joel
November 2S,2003 page 5 o f 5
12/01/2003 17:06
PAGE
8457823341
02
New York State Department of Environmental Conservation
Division of Environmental Permits, Region 3
.aCorners Road, New Pa&, New York 12561-1696
21 Sou
Phone: (845) 256-3054 FAX: (845) 255-3042
Website: w.dec.state.ny us
0
~ r i nM. crony
Commissioner
Novemher 24,2003
ATIN: GEDALYE.SZECEDIN, VILLAGE CLERK
VILLAGE OF KIRYAS JOEL
MUNICIPAL BULDING. P.0. BOX 566
50 FOREST ROAD
MONROE, NY 10950
RE:
PROW:
LOCATION:
Proposed Catskill Aqueduct Connection
DEC ID #3~3399~00028/00001
V-Kiryas Joel, Various Towns, Orange County
Resuonse to Draft EE
Dear Mr. Szegedin:
Thank you for the opportunity to commeiit on the October 2003 Drafc Environmental Impact
Statement (DEIS) for the Village’s proposed connection to the New York City Cac;kill Aqueduct.
In the DEIS the Village proposes to connect ies water supply system to the Catskill Aqueduce in the
vicinity of Vails Gate in the Town ofNew Wiiidsor. The project also involves consrruction of a
pump srationac the aqueduct, COI?5KrUCtiOnof a 13-mik water transmission pipeline to chc Village’s
existing Berdichev Road water treatnienc facilicy and consrruccion of a new watcr neacmenc plant
wichin the Village. The purpose of coiznecriiig eo the Cacskill Aqueduct is to provide the Village
with a new primary, long-term, consistent, high-quahty source of drinking water. The Village
proposes to take up to 2,000,000 gallons of water per day (MGD) rhrough a pipeline char would
follow State Rourc 94, County Route 27, State Route 208, and Snce Route 17. The Village would
retain its existing wells on standby status.
c
Based our review, the Department has the following qucstions, commenrs and concerns.
Water Demand Estimates:
Thc DEIS does a good job of presenting the current water sirpply needs of the Village, and the fact
that the Villagc’s needs will grow in chc future. However, the DEIS fails to provide any population
projections and fails tu quantify the number of gallons per day that might be needed by the Village
in the nest 5, 10 or 20 years. Although Section 3.5 briefly mentions a minimum 20,year plaming
period, it does not explain how “1.0 MGD would meet the Village’s needs for approximately 10
years.“ Wirhout establishing a specific, verifiable water supply need, it is not possible to compare
chese n c d s with the potenrial adverse environnicntal inipacts caused by the construccion and
operation of rhis new water supply syscem.
PAGE
Sewer Facilities:
The primary concern of chis Jkprtmencis a potential impact CXI sewage facilicies and the discharge
of created effluent into area streams. The DEIS does iioc provide sufficient informarion in order to
evaluate thepocenrial for chis impacc. The DE.ISshould indicate the Village’s current coral used and
unused sewer capacicy either within the Village or reservcd for the Village in [he Harrimm Sewage
Treatment Plant(0range County Sewer District #1) Will che 2.0 MGD ofwacer from this pipeline
exceed the total sewage capacity availahle to che Village? If so, how will the Village guarantee chat
water froin che pipeline will not resiilc in exceedance of this capacity?
I
Master Land Use Plan or Zoning Plan:
In conjunction with these sewage capacity concern identified above, die DEIS does not provide a
copy of the Village’s Master Land Use Plan or Zoning Map showing che remaining un+developedor
under-developed parcels in the Village that could be developed wich water from this pipehe. The
DEE also does riot indicate whether chis proposed wacer line, and the future development tlzac
would result froin it, are in keeping with rhac Master Plan. The REIS should identify all un,.
developed or under.developed parcels in che Village, their allowable land-use under the local zoning
plan and number of new residents rhac could be allowed ifall this land were developed. W h a t would
be che average and maximum daily water demand for the full build-.oucof the Village under the
Master Land Use Plan?
Please noce thac the above requested population and water demand estimate must exclude vacanc
land within the Village that is currently identified as wetlands regulated by this Department. Please
also subnacc from chat estimate all acreage that may be needed for future school facilities, hospital
facilities and other necessary service facilities before decerniinlng the net tocal buildout ofthe Village.
State Historic Preservatioa Act “PA):
Althaugh Appendix “B”of the DEE contains a Stage LA Culture Resources Report by a professional
archaeologisc, thac Reporcrecornmends a Stage 1-B srudy in selected areas along the pipeline where
there is a pocencial for the remnants of abandoned mill sices. However, it is unclear whether this
study should considered areas used for staging consnuctionequipment, as well a5 pump stations thac
may be necessary alorig the pipeline rouce. Please address chu questionand provide a revised Report
if the curreiic did not consider chese areas. Additionally, the Stage 1.B study niust be completed as
parr of preparation of any revised DEE or an FEE.
Alternatives:
In accordance with a n earlier leccer frorii the Town ofNew Windsor’sTown Engineer, please address
the environmental impacts and benefics u f m consrructing a separate connection to the aqueduct
near the Riley Road Filtration Plant.. As the Town has suggested, please consider the benefits and
irnpaccs on the Aqueduct itself of’ sharing the Town’s existing cap on che aqueducc. Please also
consider their d i c r suggesrions ofconstruccion ofa new horironcal cap inco [lie aqueduct, rhaccould
be used jointly by the nvo municipalities, to prevent problems during low flow pcriods in the
aqueducc. The Village should also evaluate the benefits and impacts of joint use of an expanded
03
12/01/2083
17:86
8457823341
PAGE
Conirncncs on Draft EIS for Aqiicdricr Xtp
Nnvmiber ZJ , ?@S3
-
.-.
DEC R: 3-3399~00i)ZS-O@001
Paw 3 of 6
Rilcy Road Filtration Plant by the two municipalities as compared to a separare standalone Water
Filcrncion Pkmt for thc Village.
Please discuss in detail the suggcsred alternative of sharing pipeline water and sharing costs with
otlier municipalities along the pipeline route so that chey too can take their own entitlement water
from the New York City Aqueduct system. Please also discuss the environment benefits and impacts
of a possible regional approach to providing this New York City entitlement water through die offices
of the Orange Cbunty Government or possibly the Qrange County Water Authority.
In accordance with Question #I9 of the Full Environmental Assessment Form (Full EAF) and as
a follow up to the above discussion of the financial impacts of various alternatives, please describe
the impaccs of the proposed projecc on the Village's municipal budget. Please provide and compare
the projected costs for the design, construction and the yearly operation of this water supply project
and die alternacives discussed elsewhere in these comments. Please also include the yearly operating
costs and debt payments of maintaining the existing well fields on standby.
Visual Xmuacts:
The DEIS did not provide a Visual Impact Analysis (VIA) for the proposed Water Treatment Plant,
the pump stations along a pipeline route, or the pumpscation a t the aqueduct itself. Please use the
Department's "Guidance in Assessing Visual Impacts" which is available at che web add.ress (see our
letterhead on page I), or at our New Paltz office. The VIA should identify the existing visual
concent around each the proposed structure. It should go on to identify how the design and
dimension of each proposed structure worild visually impact the surrounding area and how those
impacts would be avoidcd, minimized or mitigated by die siting, design, construction, materials to
be used, etc., for each of these proposed structures.
The DEIS does noc identify any areas along the proposed pipeline route where crees and shrubs will
be removed and whether they currently act as a visual buffer for residential or ocher land uses. Please
idencify and discuss the benefics &..inipaclcsof rescoring all significance stands of trees and shrubs,
shortly after construction is completed, in any area where such stands of crees or shrubs act as a
visual buffer. ,This is particularly relevant wicliin the densely populated Village boundaries and in
residential neighborlioods or around schools or public institutions.
Irnoacts on Landi
Although Section 2.4.1.4 discusses the potential for cncatintering steep slopes or shallow bedrock
in generic terms, the DEE did not identify the specitic areas where these problems might be
encountered. It did not provide a map or quantifjr how inany hundreds or thousands oflinear feet
of che proposed pipeline might encounter these types ofdifficult construction areas. Please quantify
in detail where rhese areas niight be located, rlieir length, and how steep are the slopes or how
shallow is chc bedrock in these areas. Please discuss site Dpecific construction techniques to reduce
impacts on land, traffic, streams, and a nearby homes and businesses for each of these areas. Tnese
should include a decailed discussionofstormwacer management during construction onstecp slopes
a4
and blasting impacts in areas of shnllow bedrock. UEC recommends a pre-blast survey of the
foundatiovls and wells of all homcs, institutions and businesses within 500 fc. of blasring.
Consrruction of a proposcd new Water Treatment Plant is mentioned but ics location is only casual
noted is as being adjacent 10 the Village's existing Water Treatment Plant and a derailed site plan
was not provided. Please provide a site plan of the primary location chosen for the proposed new
water treatment plant and one for each alternative locations thar was considered. Please provide a
discussion of the minimum square footage (or acreage) needed co construct a water treatment plant
of the size assumed necessary for this project. Please include a rhorough search of all vacant lands
near the terminus of the pipeline in the Village that meet this minimum size criteria.
~
- I _ .
..
.
Please discuss construction impact5,on che aqueduct itself. What is the age of the aqueduct at the
location of the tap! Whar is a potential for short-.term or long-term damage to the aqueducc during
construction of a connection to it! What alternatives are available chat would reduce or completely
avoid disturbance ofthe aqueduct irselfin order to obtain die water, such as the alternates identified
in these comments?
Please indicate how much area would be needed to temporarily score conscruccion macerials along
che pipeline. Please discuss where excess excavated material will be disposed of and indicate how
the Village would verify thar the macerial will not be disposed of in any state or federally regulated
wetland area.
The DEIS did not discuss whether any pump stations would be needed along the 13-mile route, the
locarionof pumpsratioils, the dimensions such pump stations and construction or operaringimpacts
of these pump stations.
If any construction is outside of the road pavement, how many acres of trees and shrubs will be
removed in order EO install che pipe line? How many acres will be replanted!
Please discuss liow many cubic yards of excess soil, rock, asphalt, concrete, ecc, will be removed from
work corridor and where will be disposed of?
lmuaccs on Surface Waters:
The DElS does not indicate how many acres of temporary or permanencscormwacer decention ponds
will be needed. It does not indicace where chose derenciorl ponds will be located and the impacts of
their construction. Asimilar analysis is also needed for any pump stations or temporary staging areas
along the pipeline route.
Please discuss whether the proposed Water Treatment Plant will result in any discharge ro nharby
streams fromsuch things as filter backwash, alum, or any other discharge of process water or effluent
from the plant. Please discuss whecher area screams around the proposed Water 'Trearmenc Plant
site (or any alternate site for it) can adcqunteiy assimilate such discharges during normal and droughc
periods.
12/01/2003 17: 06
8457823341
PAGE
06
Impacts on Veretation:
DEIS does not indicate whether thc pipeline trench will hc construcced within 50 ft. of any
macure ttces, and ifso, whar analysis would be done on whether such conscrucrion could damage or
destroy the root systcni OF rhcse trees Please provide a mechoclology for such analysis and an
indication of how impacts co mature Crees will be avoided or prevented.
_.
Noise Imoacts:
The evaluacionofLocalNoise regulations inSectian2.11.2.1 does not include any noise regulations
for the Village of Kiryas Joel. Please provide them and analyze how potenrial sources of noise can j
meet these regulations or would have to be initigaced to meet them.
*.
The evaluation of Long.Term Noise impacts in Section 2.11.4.2 of che DEIS does not provide
background noise sampling data for the proposed Water Treatment Plant site within the Village.
It also does not identify the nearest residencial receptors ofnoise or their distance from [he property
line of the proposed plant sice. Please provide this information and revise your evaluation
appropriately.
As discussed earlier, there is no detailed location map or sice pIan for the proposed plant and no way
to understand whether the new planc is closer to residential receptors. Wirhout this information,
it is very difficult co independently evaluace che conclusion in this sectionofthe DEIS char there will
noc be a noise impact. It also does not explain how che estimated maximum operating sound level
of 60 dBA at the property line was determined.
'
~
The Deparcmenr has no comments on the review in the DEIS of impacts on Air Quality, Traftic,
Energy, Endangered Species and Solid &,Hazardous Waste.
Thank you again for the opportunity to comment on the DEIS For chis project. If you have any
quescions about the above requested information, please contact me in New Palm at 845-256-3165.
Sincerely,
Michael D. Nerriman
Deputy Regional Permit Administmoor
i
:
'
12/01/2003 17:06
8457823341
PAGE a7
(
cc:
H. Boucher, PE ac Camp Dresser in McKee
Supervisor, Town of New Windsot
(CDM)
Sirpervisor, Town of Cornwall
Supervisor, Town of Woodbury
Supervisor, Town of Monroe
Supervisoc, Town of Blooming Grove
R. Pier$%, NYS OPRHP, Wgterford
M. Montysko, NYS DOH, Troy
gwcc: M. Moran; M. Duke; W. Rosenbach;
L. Meyerson; M.George; P. Ferracane; M. Ilolt; j. Gamy;
,-4
. .2.-. .
i
PAGE
340 West 28'h Street g14A
New Yo&, NY 10001
Nov 30: 2003
Art: Gedalye Szegedin,
Village Clerk
P.0 Box566
Monroe, NY 10950
In reference to the planned connection o f the Village oFKiryas Joel to the
Catskill Aqueduct, since this project is meant to increase die current supply
of water to your community, I, as a New York City resident and City water
supply consumer, have a riglit to object to the excessive volume of water
that would be sipboned off our source o f supply. I can only view it as an
sign of encouragement to further residential and business development in
what is now open green space where people froin our urban areas can CODE
to enjoy the natural beauty and Wildlife, and the solitude that have been
vrinishing at a more rapid pace these days:as ur.bsn:sprtwl briiygs:s'Yriithit
more traffic, more pollution, and a genera~iywors&ng qiiality of l i f e ,
If there is a plentifiil local water supply from the Brenner farm, then
certainly that should fidfill the current needs of your community, so I say-by all means use that.
04
n
APPENDIX C
Letter
New York State Office of
Parks, Recreation and Historic Preservation
03/16/04
FIELD SVCES. BUR-
TIIE 15:45 FAX 518 233 9049
WWWBTATC
n
New Yo& State Oflice of Parks, Recreation and Hidorlo hesenrelion
Hlstorlc Preservation Field Services Bureau
Paebles Island, PO Box 169, Waterford. New York 12188-0180
51 8-237,+E43
March 16,2004
Michael Sterthcus
Whiteman, Osteman
One Commerce Plaza
Albany, NY 12260
Hanna, U P
Dear Mr. Sterthous:
Re:
DEC 3-3399-0026/0001
Proposed CatsWll Aqueduct mnnectlon
Village of KIryas Joel, Orange County, NY
OZPR04346
Thank you for requesting the comments of the OR= of Parks, W e a t i o n and Hr;loric
Preseivation (OPRHP) with regard to the potential for this project to affect significant
hlstorical/culLural resources, OPRHP has reviewed your letter cF Februaty 25, ‘2004,whlch
outlines: a propsed protcml for conducting archaeological investigations. While we typically
recommend that the Phase 18 archaeological work be completed prfor to our review, we
understand that In this case, R wlll be neolsmiy to continue Wither Into the SEQRA p r o w to
allow a more mmplrrte design of the project to be prepared. We also u n d e w n d that the
reviewing agency has lndfcated that they would not provide clearancetr, continue thls prows,
wlthout receiving our mmmenk. Therefore, OPRHP will comment on the proposed protocol.
It is the opinion of the OPRHP that the proposed protocol will ad to help Identify, protect
and/or mitigate any adverse Impacts to archaeological resources that may be Identifled. OPRNP
recommends that any reviewing agencies indude this protocol as a mndlflon of any process
under their =view and that no constructian be allowed to pmtzed until these cundlaons have
hwn met. Wth these conditions In place, OPRHP ha5 no objections to the project applicant
belng allowed to proceed in the dfslgn process.
Please amtact me at extendon 3291 IF you have any q u d o n s regardlng these
commentss,
Historic Prwrvation Program Analyst
Archaeology
QCDMka resirrered 1rademurkofCemp Dreirei eMcKee inc

CDM 2004 FEIS Aqueduct Connection

Transcription

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