Documente Academic
Documente Profesional
Documente Cultură
Dr. Howarth
EXHIBIT B
Dr. Ingraffea
EXHIBIT C
Dr. Dyrszka
EXHIBIT D
25
Proceedings 2
8 time.
25 comments.
Proceedings 3
7 timeline.
19 accepted by the lead agency, and then the other thing that
3 review the final EIS, they can provide their views to the
4 lead agency, who may take them into account when it makes
16 days, after the filing of the Final EIS. And I'm not
2 prolonged.
7 roughly two and a half times the minimum, and I think both
19 that serves and helps both the board and the applicant,
18 comment period.
23 with both state agencies and local agencies, and the thing
2 for that is that helps both the applicant and the lead
6 closes, you have a bright line. You know what that date
7 is, and any comments received after that date are not
9 accept them into the record, and many lead agencies do,
10 but what it does mean is the lead agency preserves its own
23 creates the legal risk that if, for whatever reason, and,
3 that creates risk both for you and for the applicant.
5 agency I've ever dealt with has said, you know, the
13 Thanks.
15 opportunity to talk.
5 tonight's meeting?
14 I'll turn it over to Mary Ann. Mary Ann and Pat have been
22 only stating my own opinion, the only reason this DEIS was
25 think that we still need to deal with the issues, and they
Proceedings 10
19 wires.
18 midstream. I've seen them done after the fact. I'm sure
20 they feel are significant, and then we'll talk about the
9 do that.
15 laid out for you right here; changes proposed for the
24 EIS.
15 through the EAF. We've done the pos dec. We've done the
18 are in between sort of ten and eleven here, you know, the
10 that correct?
18 supplemental to that?
24 out --
1 minute.
3 It's a lot to absorb. What I've tried to lay out for you
18 the time you can also call for a supplemental and have it
19 be a Supplemental FEIS.
24 what people are used to, it's what people are familiar
8 that. Okay.
14 wouldn't be ignored?
3 intent, the pos dec; you could do scoping. You don't have
11 findings statement. The pros for this is, this allows for
13 necessary.
21 if it's appropriate.
6 you're saying?
22 issues.
7 addressed.
19 this today, nothing requires you to; that you wait to get
22 know the vernal pool is one that we're looking at. Stream
1 2.5 formation.
3 feasible to do.
8 altered simulations.
22 know, as they have been ready for review, and before they
25 studies, as you got the studies that were the basis for
Proceedings 25
1 the DEIS. And you can review them and at the point where
14 the studies they are doing are the studies that our
4 what they will provide and how, and we can react to that.
12 know --
9 I'm talking. All right? If it's what they feel that has
14 we will all come out with all the answers that we need,
15 right?
1 should have been in the DEIS, and, you know, we can digest
2 what we think those are, and agree on them and then decide
6 identified.
17 about that.
7 mitigation.
6 through and presented, you know, and tried to pull out the
9 mitigation.
13 specific --
23 in the process.
12 added.
24 total project, all four pieces of it, not just one or two,
3 Wallkill.
13 The purpose for that is so that you can say, okay, here is
16 site. Here are the habitats that they need. Here are the
22 being forthcoming.
23 complete so far.
21 I agreed with the idea that at some point we're not going
1 right now.
7 information.
17 curious.
19 is put together.
22 get your --
1 material to review.
7 and that's possibly what may go on, and what I'm -- right
9 because they were waiting for this meeting to see what was
11 it, but they didn't -- did that have to be done for now or
19 bottom line.
21 we did.
23 the DEIS and we did, and now we're picking up the pieces
2 think --
8 point, but --
12 saying. This data has to come in. But then it will slowly
14 so, you know, you can't give a time period because, first,
15 whatever they give you, you have to review, and then you
1 those issues, so that can take longer, and the two weeks
4 little longer.
6 than after.
13 time period. They have said, let the studies get in, and
8 they are proposed they are not shown here. This is the
9 SP3 and also the SP4, and all of the big fold out plans,
10 the ones that I look at, right, the ones that the
12 no wires here.
16 way, and then 120 feet, averaging about 120 feet poles
19 some point over here and there may be another switch yard
24 You have your view shed mapping, based upon the action you
8 model does not have the wires in it. The view shed map
23 wires that go all this way, and I'll just show you what I
8 the plant. The wires extend all the way back up here,
4 far distant viewpoints are fine, the ones that are looking
5 from two miles away, you get the entire action, but it's
21 in this area. Now, what does that switch yard look like?
11 proposing wires.
13 keeps going like this. It's way off the screen. The size
17 don't see them at all and that they are an artifact of the
19 grass beyond. And then the wires, which will go this way.
11 you know, they ask where they are going to be. Some think
1 comments.
4 that there had been wires going all the way up that
10 and it's really not clearly disclosed what the action is,
25 underground.
Proceedings 53
10 work through them, and then present them back. It's only
16 property.
18 edge?
20 is --
4 it back, you clear them up, and then you come down to a
5 short list and say, okay, these are the ones, if they are
8 comments.
10 switch yard and the wires, they are two sides of the same
14 yard, but there are still the wires and the comments still
15 stand.
23 approach is.
10 says. But that will be, that will be part of this FEIS
11 process.
14 one could argue you could have done it at the DEIS stage,
17 that we put the language in the DEIS, and now we're going
7 about PM 2.5?
24 encompass?
1 would show, and we'll give you distances when we have the
2 analysis done.
8 approach.
23 and forth process will go, how many iterations, and most
25 be, but for the other issues, how are we going to get to
Proceedings 61
4 aware of some of those issues, and I know you all have sat
9 this rush, and then we don't feel we have done the job
14 reports and the back and forth and how long it's all going
15 to last.
20 with the DEIS very reluctantly, and did accept it. But we
4 think the applicants have that I believe, and what Ron has
17 time when we get the FEIS, so I can say, I can now tell
3 knows what we're looking for. And what I would say and
21 not in the DEIS. They did include in the DEIS one study
5 field work, with George and Mary Ann, and going to some of
16 comments that you get that I read and I think you read,
7 and what does someone who wants to buy your house see. So
12 recommendation.
3 one other thing, and you have more paper than you ever
4 need, but Ron and I read all the public comments, written
18 the FEIS.
12 three.
17 What I don't want to see happen is, okay, now we got, you
20 studies, and maybe we will get them in time for site plan.
2 as a whole.
9 work with the board in terms of a time line over the next
18 forward with anything else, and that you will waive the
19 time frames for FEIS until those studies are complete and
23 time frame.
2 frame.
7 contemplated.
14 again.
17 closed.
1 at them.
4 nothing else.
11 forward.
15 there hasn't been dialogue and you are concerned about it,
16 pick up the phone; either you or us, lets just get that
25 information.
Proceedings 72
7 moving along.
21 the ecological studies had been done, you were writing the
11 give everybody.
15 mode where I'm make a comment, and you respond, and then
2 a dialogue.
5 for the studies. That's the only new comments that you
6 heard.
4 lot of this stuff that comes our way comes from Ohio. So
6 go.
19 ___________________________
20 Neil Bostock
21 Official Reporter
22
23
24
25
Proceedings 78
41:25, 53:9, 54:9, 7:4, 7:9, 19:2, 19:19, air 10:11, 48:14,
48:17,
21:15, 21:25, 21:25, 8:5, 8:8, 13:12, 17:5, allow 17:4, 28:2, 30:3,
Page: 83 of 90
Concordance 85
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Concordance 89
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Concordance 93
controls 8:9, 21:20. criteria 13:8, 13:20, days 3:15, 4:12, 4:12,
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Concordance 117
existing 30:17, 43:8, 49:2, 49:9, 57:4, field 45:1, 46:6, 47:6,
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Concordance 125
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Concordance 129
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Concordance 137
17:20, 20:7, 20:10, kind 5:16, 5:23, 9:15, 55:9, 61:15, 63:7,
70:15, 72:17, 74:3. 39:4, 39:9, 40:15, late 7:15, 62:2, 62:7.
Page: 143 of 90
Concordance 145
lead 3:19, 3:21, 3:23, light 5:15, 5:15, 34:8, 43:23, 43:23, 43:25,
25:16, 25:19, 25:20, list 28:12, 36:3, 40:6, 41:21, 41:23, 42:1,
29:4, 33:22, 48:23, 15:5, 15:7, 15:12, mean 7:8, 7:10, 8:22,
met 2:15, 18:24, 30:3, missing 10:18, 30:10, 41:10, 41:13, 42:23,
9:22, 26:11, 61:2, original 49:24, 63:22. page 62:3, 62:5, 62:22,
41:5, 41:11, 53:3, path 5:21, 16:7, 25:10, phase 33:25, 36:10.
plant 36:7, 36:8, 45:16, 59:15, 60:16, 61:1, potential 19:23, 36:11,
Page: 175 of 90
Concordance 177
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Concordance 181
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Concordance 185
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Concordance 193
58:4, 61:6, 72:2. site 30:18, 30:19, 33:9, Sort 2:21, 4:9, 6:7,
start 23:8, 23:25, 29:7, Steve 2:12, 3:8, 5:25, studied 48:21, 50:2.
suggest 6:16, 12:18, switch 44:3, 44:19, Ten 3:22, 3:25, 14:18,
50:9, 53:4, 57:20, tonight 2:2, 2:14, 2:17, 51:8, 51:10, 63:19,
Page: 207 of 90
Concordance 209
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Concordance 221
1:12, 1:12.
Page: 221 of 90
EXHIBIT F
GREENPIAN
Date: 4/22/09
Subject: CPV Valley Ene<gy Center - Technical Review of DEIS
Applicant: CPV Valley, LLC
We have completed our technical review of the Draft Environmental Impact Statement
(DEIS) Volwnes I-III dated February 2009 for the above captioned application. The DEIS
was accepted as complete on February, 23 2009 and has been subject to public and agency
comment since that time.
and interested agencies an opportunity to review and comment on them. If these are
only provided in the FEIS, the opportunity for public review will be extremely
Wawaya.nd2 PJanniog Boxd P>g<2 4/'12/09
limited. Further, we recommend you hold the public comment period on the DEIS PB12
open and once a submission has been made and circulated, select an appropriate date (cont'd)
to close the comment period. The Planning Board has the option of holding a public
hearing on the SEIS if it so chooses.
2. The entire action is not depicted on the Site Plans. The above gmund transmission
lines and its associated 150 foot right of way from the facility to 17M are missing
although it is discussed in the text and appears on various figures in the DEIS. This
has potential implications related to visual impacts.
3. Consistency with the Town's adopted Comprehensive Plan has not been adequately IPB1-4
addressed.
4. Issued related to fiscal impacts remain outstanding. IPB1-5
5. Community character has not been addressed adequately. IPB1-6
Section LO Executive Snmmaiy
6. Page 1-1. The applicant needs to provide justification for the statement "Due to PB1-7
efficiency of natural gas combined cycle technology, the CPV Valley Energy Center
is expected to help reduce dependency on the use of older and less efficient
generators that currently serve the region, thus improving the region's environmental
profile". Please define where the older and less efficient generators are located,
describe how this region will be less dependent on them and describe the region's
1
New Yod: Sate Enew Plan. (2002). l?g.13<1.
Wawa.y:andn Planning Booed Pogc3 4/22/09
10. Secti.on 1.7.2 indicates there ace no significant impacts to archeological resources.
However, the applicant is required to additional accheological field work according to
a December 23, 2008 letter from the NYS Office of Packs, Recreation and Historic
Preservation (OPRHP). Until this additional fieldworlc has been conducted to the
satisfaction of OPRHP, a conclusion related to impacts cannot be reached. The
PB1 -11
additional field work has been acknowledged by the applicant and this section of the
DEIS needs to accurately relect this situation.
11. Section 1.B. Typically, this section identifies both the impact and the related
mitigation measures. Table 1-2 should be revised to include the relevant impacts in
IPB1 -12
each section noted.
Section 2.0 Project Description
12. Page2-15. The ten notes that wastewater will be returned to the Middletown Sewage PB113
Treatment Plant or to the treatment plant outf.tll pipe. The applicant should indicate
if an option has been finalized and we defer to Allegiance Resources or Pat Hines to
determine if the cption selected has been analy:zed sufficiently.
13. Figure 2-6. This is inconsistent with the teitt which describes 130 feet of clearing and PB1 -14
transmission line poles in excess oflOO feet. We note this figures provides a very
good perspective on the scale of this project and how it relates with the surrounding
area including the DOT facility.
Section 3.0 Land Use
14. Page 3-4. In the description ofland use in the northeastem quadrant, there is
mention of the former Calpine project. 1bis not a current land use and it is not clear
why this project is mentioned or why it is relevant to this SEQR review.
15. In several places in the DEIS, it mentions that the project will occupy approximately
22 acres out of the 122 acre site. Please identify the nwnber of acres associated with
IPB1-15
PB1-16
environmental constraints which make certain portions of the site unsuitable for
siting a building, in particular the acreage of wetlands, so that a better understanding
of the impact on the site.
16. Page 3-15. In the subsection on Operation, the text accurately describes how the site it PB1-17
bounded by l-84 and Route 6. However, it fails to mention that this places the
facility in a highly visible area for people traveling along these roadways.
Additionally, Exit 3 from I-84 essentially serves as a gateway to three communities:
Wawayanda, Middletown and Goshen. There is no evaluation of how this land use
will impact this gateway area for these three towns.
17. Page 3-16. There is discussion of the physical separation of the facility to the PB1 18
workforce housing site Horizons at Wawayanda. Here the text notes there is
"separation consisting of primarily tree cover". The DEIS states that there will
clearing of 130 feet of trees and vegetation for the above ground transmission Jines.
It would seem that this "tree cover separation" does not accurately reflect the post
construction condition of the site or any assodated impacts. 1bis statement appears
to be inconsistent with the discussion of construction impacts on page 3-17.
IPB1-19
18. Discussion of impacts. Industrial uses are generally considered "incompatible" with
adjacent or neai:by residential uses. In fact, this is one of the reason zoning became a
.
Wav.-ayanda PfanningBoatd Pagc4 4/22/09
common practice in land use planning. The Town's Zoning recognizes issues of
incompatibility in the description of the intent of the MI zone, 1his district is
intended to pmvide areas for various industrial and manufacturing enterprises within
well-planned complexes on parcels with gocd access to the regional transportation
system, where they can be free ofpo&:ndally incompatible land llSes' [emphasis
PB1-19
(cont'd)
added]. This facility is proposed for an area in which development has already
occurred. This development include residences adjacent to and nearby to the project
site, including the workforce housing complex, and the Pine Hill cemetery. There is
no discussion of how this industrial project will impact the experience of those
burying their loved ones or those who visit the cemetery. This project will alter the
existing agriculture/open space land use to one with Iaige industrial buildings wruch
will produce noise, air pollutants and visible vapors. In our opinion, this pmject
creates incompatible land uses and this impact needs to be disclosed in this section.
19. Mitigation. Related to the item above, this section needs to acknowledge that the I PB1-20
incompatible land use issue is un-mitigatable.
20. Page 3-17. This section of the DEIS treats the electrical interconnect almost as a PB1-21
separate part of the action. Tills is not appropriate as the entire action, in totality,
needs to be evaluated. Further, the section on impacts indicates these will be
compatible with the existing transmission lines in the area. Again, this is not
disclosing the potential incompatible land uses, particular for the workfurce housing
project and the cemetery. The mitigation sections needs to acknowledge there will be
un-mitigatable impacts.
21. Page 3-19. There is additional discussion of the workforce housing project along PB1-22
with the Bradley Comers hotel project and it states these sites would be buffered
from the project through landscaping and wooded open space on both properties.
This needs to be clarified and quantified. Is the applicant proposing to landscape the
workforce housing and hotel site? How much buffering exists on these parcels? The
te..'<t uses the phrase "soften the views from this location". Describe in more detail
how the view is "softened" as this is a large industrial complex with very tall bo~ type
buildings. We are unable to tell from the site plans where the clearing of trees and
other vegetation will occur for the transmission lines. We note the Visual Assessment
does not .pro"1de any photo simulations of the electric transmission lines.
22. This pmject has the potential to affect the future development potential of vacant PB1-23
land due to visual, water quality, air quality and community character impacts. There
needs to be additional qualitative and quantitative analysis of these lands including a
map showing the parcels, the zoning district they are located in overlaid on the
theoretical viewshed map.
23. Section 3.4. This section does not adequately describe the information contained the PB1-24A
Town of Wawayanda Comprehensive Plan. The purpose of a comprehensive plan is
to be a guide for decision making on public and private development proposals. It
compares how a community appears at the time of the adoption to what it vision is
for the future. This is important document and the FEIS needs to:
* Include the vision statement found on page 1.2; IPB1-24B
jPB1-24C
and Direr.ri!)', particularly the statement regacding "encouraging clean low impact
commercial entexprises";
* Address section 2.2 -Maintaining and Snpporling WmJJ'!)'anda's &1ral Character,
specifically the "desire to maintain the scenic quality and rural character of the
Town 11 :
I PB1-24D
I
(conrd)
PB124E
*Address the recommendation (p. 5.1) to "Establish more prominent gateways into
Town" (We note Route 6 and 17M ace considered "important focal points'');
I PB1 24F
Address the recommendation (p. 7.4) to "Protectwaterquality in Wawayanda's I PB1-24G
lakes and streams";
*Identify the roads recommended to noted as view corridors (pg. 9.7) I PB1 24H
24. The Comprehensive Plan makes a recommendation for the Town to research
potential types of agriculture-based tourism. Will this project present a barrier for the PB1 -25
Town in pursuing this strategy in terms of the community image because this large
industrial proposal is in a prominent acea?
25. Tbe Comprehensive Plan recommends all Zoning districts need to be examined in PB1 26A
terms of size and allowable uses. Specifically, it states (p. 12.3) "Currently, the MI
district in Wawayanda is lacge and allows certain uses (i.e. "other manufacturing" or
mining) that are vague or not in line with the Town's vision". This type of language
in the plan would presents challenges for the proposed action to justify how it is
consistent with the plan. It is not difficult to imagine that the crafi:ers of this plan
would also consider "other industrial" uses in a similar way as 11 other manufacturing11
is described above.
description varies from the description offered in the DEIS on page 3-25.
Specifically, the DEIS adds phrases such as "major land uses" and "industrial".
28. The OC Plan offers strategies, priorities and recommended action on a variety of
areas including industrial/office parks (p. 52). Many of strategies and priorities are
noted in the Town of Wawayanda Comprehensive Plan. While the DEIS touches on
PB128
(cont'd)
PB1-29
some of these, the DEIS does not address bullet 3 - ''Encourage the development of
well- designed industrial and office parks that provide an attractive setting for
business 11
29. Due to the deficiencies regarding the Town of Wawayanda Comprehensive Plan and PB130
the OC Plan as noted above, the section on potential impacts and mitigation is
inadequate. An analysis of consistency (i.e. impacts) with these two plans including
the additional information requested above needs to be included in the FEIS. In our
opinion, there are impacts to land use and the mitigation section should identify any
un-mitigatable impacts as well as any mitigation measures offered.
30. Page 3-32. The discussion of the NYS Bike Route 17 does not accurately reflect the
PB131
visual simulation of a point along the route - please see viewpoint 11 taken from
Route 6. ln regards to the simulation, the DEIS states (p5-19), "The planting of
trees along the southern edge of Route 6 will help to soften the impact, but the scale
of the facility is such that at this distance no landscaping can fully mitigate the impact
from this distance." 'lb.is needs to be addressed and the impact needs to be
acknowledged.
31. Zoning compliance -Section 195-9. The applicant did not address item B of this
section and the DEIS incorrectly states "blinking or flashing lights" are a prohibited
use. The Zoning states "blinking or flashing signs" are a prohibited use.
32. Page 3-52 states a variance will be required for a nwnber of buildings/ facilities. We
believe the applicant does not need a variance for the water storage tank as it is listed
I
PB1-32
PB133
as an exemption in 195-l!B. The Planning Board should verify this with Mr.
Bavoso. There should be some clarification regarding the buildings which will
require a variance. The building references should be consistent with the descriptions
on page 2-5. The applicant has not indicated there is a need for a variance for the
stean:i generation building which is no.ted .to be 102 feet high on page 2-5.
33. We defer to Allegiance Resources to provide guidance on compliance with I PB1-34
195-19C & D.
34. We direct the Planning Board's attention to 195-19Hwhich states "No emission of
fly ash, dust:, fumes, vapors, gases or other forms of air pollution shall be permitted PB1-35
on a regular or continuing basis which can cause any damage to health, animals,
vegetatio.a, orotberfoDJJSofpropertyorwhich can cause any excessive soiling"
[emphasis added). The DEIS states that the project will be in compliance with all
applicable federal and state air standards. We defer to Allegiance Resources for their
verification however; we note that compliance with standards does not always mean
there will be no impact. No doubt your Zoning has set a very high standard in
regards to air pollution. If this project cannot achieve this standard (e.g the DEIS
states project can emit 95 tons/year of PM 2.5), then the Planning Board should
.. '
W:iw2yanda Plarming llou:d P.g< 7 4/22/09
Please note the text in the last paragraph refers to "Item B", but item Bis not
articulated in the DEIS.
I PB1-39B
I PB1-40
39. Does CPV have a letter from the City of MidcDetown Superintendent which concurs
with the evaluations made in the DEIS?
40. 389-53 indicates there are discharge limits for certain pollutants however the DEIS
does not include the list or the limits but simple states there will be compliance.
IPB1-41
, . . -.. '
indicating what is meant by the phrase and more fully describing what type of noise
can be eapected.
Section 5.0- VisualResowces and Aesthetics
46. Comments are being provided by Geotge Janes and Associates in separate
PB1-46
(cont'd)
memorandum.
Section 6.0- Community Facilities
47. Comments related to community facilities are being provided by the Hudson Group
in a separate memorandum.
IPB1-47
Section 7.0 - Socioeconomics and EnvironmentaIJnstice
48. Comments on socioeconomics are being provided by the Hudson Group in a PB1-48
separate memorandwn.
49. It is our understanding comments are environmental justice are being provided by PB1-49
Allegiance Resources.
Section 8.0 -T r:iffic and T r.msponation
50. It is our understanding Pat Hines is providing comments on this section. PB150
Section 9.0-Air Quality
51. It is our understanding Allegiance Resources is providing comments on this section. PB151
things including land use plans and regulations and even surrounding areas. For
example, the City of Middletown is likely to have a broader range of socioeconomic
classes and mix of land uses than Wawayanda It is considerably more ucban whereas
Wawayanda is more suburban and nmtl. These examples are offered to assist the
Planning Board in thinking about the distinguishing qualities of your town. The
PB1-57
(cont'd)
Town's adopted Comprehensive Plan speaks of the residents desire to maintain the
scenic quality and rural character of the Town, to protect natural resources and notes
the "existing character of the Town's hamlets, scenic roads, and agricultural features
should be preserved through the development and application of design guidelines".
It is clear from the Comprehensive Pl:an that character of the community is an
important issue.
59. Overtime, the character ofa community may change. For example, many PB1-58
communities in the Hudson Valley were once primarily agricultural and now they are
more suburban. This is noted in your plan where it states "As growth from the New
York City metropolitan area expanded from Westchester, Bergen and Nassau
Counties to Orange, Putnam and Dutchess counties, communities such as
Wawayanda began to experience a change in character as development increased.
However, agricultural and vacant or environmentally constrained lands remain
prominent land uses in Town, while development oflow-density single-family
residential uses continue." The question is not whether community character will
change but rather wiU the change introduced by this proposed action be inconsistent
with existing character. Community character cannot be justifies by stating the use is
explanation as to how tlUs use is consistent or not consistent with the Town's vision.
.... . ~ .
Wa:wayanda P&nning Doud p'!l" 10 4/22/09
62. All data in thls section points to an attractive community with a high quality oflife
which people axe seeking out to pur:chase homes and make Wawayanda their place of
residence. Does this project, due its massive scale, location, noise and air quality
impacts, have the potential to alter the character of the community so that people no
longer seek it as a primary residence? If the additional studies requested by the
PB1 -61
Hudson Group and members of the public in fuct show devaluation in property
values, does this project then alter the socio-economics of the community?
63. In section 16.7 -Impacts to Community Character, the DEIS states "The siting of PB1-62
the project allows economic development without threatening the goals of the other
themes in the Town's Comprehensive Plan." As noted earlier in this memorandum
on the Land Use section, there was not enough information provided from the Plan
on the themes and goals in the DEIS or an evaluation of consistency from which
you can draw thls conclusion.
Section 17.0- Cumulative lmpacts
64. Section 17.2 discusses cumulative socio economic and fiscal impacts. We note the PB1-63
Hudson Group has provided which call for additional analyses which may require
some changes to this section, however, this is not known at this time.
65. Section 17.2 ends with a conclusion that states "In summary, from a cumulative PB164
socio-economic standpoint, the large revenues related to the CPV Valley Energy
Center will provide much needed revenue for the Town and will help offset the
additional costs for municipal services that will result from the other proposed
projects". Without additional information on the PU.OT or the costs associated with
the other projects, it is not possible to evaluate the merit of this claim.
Section 18.0 - Other Environmental Impacts
66. Section 18.3.1 incorrectly states the intent of the MI district. According to the PB165
Schedule of Zoning District Regulations for the MI district, "1bis district is intended
to provide areas for -,.arious industrial and manufacturing enterprises within well-
planned complexes on parcels with good access to the regional transportation
system, where tbey can be free ofpotentially incompatible land use$' [emphasis
added]. 1bis last phrase was omitted from the DEIS and in its place is the phrase
"which allows electric genecating &dlities by special permit". This is also incorrect
The list of special uses does not include electric generating facilities. 1bis proposed
use has been described as "other industrial" in other sections of the DEIS.
67. Section 18.4.4 states that development of the facility is consistent with the goals of PB1-66
the Town of Wawayanda. Please see our earlier comments on Section 3.0 -Land
Use. 1bis statement may need to be revised once additional analysis is provided in
the FEIS. Further, the reference to "expressly allows electric generating facilities by
special permit" needs to be corrected as oared in the previous item.
68. It is our understanding Section 18.7 is being reviewed by Allegiance Resources. PB1-67
Section 19.0 -Alternatives
69. It is our understanding Allegiance Resources is providing comments on this section. PB168