crty OFALBANY
OFFICE OF THE MAYOR
24 enue STREET
upaivy, NeW YORK 12207
TeLePHOMe (16) a36-5100
arity Sieeuan
Naor
December 7, 2015
‘Mr. Robert L. Megna, Executive Director
New York State Thruway Authority
200 Southern Boulevard
P.O. Box 189)
Albany, NY 12201-0189
Me. Basil Seggos, Acting Commissioner
"New York State Department of Environmental Conservation
625 Broadway
‘Albany, NY 12233-0001
Re: Lead Agency status on Pilgrim Pipeline proposal
Dear Mr. Megna & Commissioner Seggos,
‘The City of Albany isin receipt of the New York State Thruway Authority (“Thruwey
Authority") letter dated November 16, 2015 declaring intent of the Thruway Authority to assume
lead agency status onthe Pilgrim Pipeline proposal, within the meaning of New York's State
Environmental Quality Review Act (“SEQRA"). As your letter indicate, the City of Albany is
an involved agency for this proposal. After reviewing the preliminary draft environmental
impact statement ("EIS") dated August 2015, prepared by the project sponsor, Pilgrim
‘Transportation of New York, Inc. ("Pilgrim New York”), the City of Albany respectfully
requests designation ofthe New York State Department of Environmental Conservation
CDEC") as lead agency fortis project.In support of this request, the involved agencies and their respective jurisdictions as
{destitied in section 1.5 ofthe preliminary draft EIS, on table 1.5-1, pages 1-15 to I-17, and
‘maps presented in figures 1-2 through 1-S (attached), are hereby incorporated by reference. All
relevant information forthe DEC Commissioner's consideration of lead agency is contained
within the preliminary draft EIS, which is being provided to DEC with this letter. This request
for DEC to assume lead agency status is supported by several factors, including but not limited
to the following:
(1) While the majority of the pipelines” path would be located on Thruway Authority
‘property the anticipated impacts of the action under consideration are primarily
Statewide. The preliminary draft EIS identifies many environmental areas of concern that
are not located on Thruway Authority property, including but not limited to construction
and operation within “sites of concern” (EIS pages 3-29 to 3-31), clean water aquifers
(EIS pages 3-36 to 3-48, including table 3.1.3-3, identifying public water supply wells
within approximately one mile of project mainline), endangered species, agricultural
resources (EIS pages 3-187 to 3-193), and DEC designated state visual resources (EIS
page 3-222). Significant environmental impacts are presented at length in section 4 of
the preliminary draft EIS.
(2) DEC has the broadest governmental powers for investigation ofthe impacts of the
proposed actions,notably, the identification of environmental justice areas (EIS pages 3-
209 t0 3-214, with maps presented as figures 3.2.4, 3.24-2 and 3.24-3), including one
inthe City of Albany, which requires public notice and hearings associated with
‘mandatory scoping under current DEC poly. Iti our understanding that scoping would
‘not be mandatory were the Thruway Authority to assume the role as lead agency. Based
‘on past experience inthe City, we believe itis imperative o include the environmental
justice process in the scoping
(@) DEC has greater experience for providing the most thorough environmental
assessment of the proposed action. Lead agency determination should not be made
‘merely on the basis that much of the proposed work will be on Thruway Authority
property, as indicated inthe Thruway Authority etter dated November 16, 2015.
For these reasons, we believe it
State, to designate DEC as lead agency.
in Albany's bes interest, and the best interest ofthe
All comments regarding the request of DEC to assume lead agency status must be
‘submitted to the DEC commissioner within ten (10) calendar days after receipt ofthis request
Furthermore, @ review of the preliminary draft EIS supports a positive declaration within the
‘meaning of SEQRA at this stage.
Sincerely,
Kathy M, Sheehan
Mayor, City of AlbanyFederal Highway Admiistation FHWA)
USS. Army Corps of Engincers (USACE)
USS. Fish and Wildlife Service (USEWS)
US. Department of Treasury ~ Buea of Alcool, Tobacco and Firearms
US. Department of Transportation (USDOT), Pipeline & Haz. Materials Safety Admin,
(PSHMA), Office of Pipeline Safety (OPS)
‘New York State Department of Transportation (NYSDOT)
‘New York State Department of State (NYSDOS), Division of Coastal Resources (DCR)
New York Office of Parks, Recrestion and Historie Preservation (OPRHPYPalisades
Interstate Park Commission (PIPC)
‘New York State Office of General Services (NYSOGS)
New York State Department of Agriculture & Markets
‘New Jersey Department of Environmental Protection (NIDEP)
‘New Jersey Department of Transporation (NJDOT)
Pilgrim Transportation of New York Ine
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