HomeMy WebLinkAbout(3) PWGC Comment Letter on Final Scope.pdf OFFICE LOCATION: AIAILING ADDRESS:
Town Hall Annex t P.O.Box 1179
54375 State Route 25 Southold, NY 11971
(cor.Main Rd. &Youngs Ave.) c
Southold, NY Telephone: 631 765-1938
www.southoldtownny.gov
PLANNING BOARD OFFICE
TOWN OF SOUTHOLD
April 6, 2021
Charles R. Cuddy, Esq.
Box 17
Riverhead, 111
Dear Mr. Cuddy,
The Planning Boardhas reviewed your letter of February1 and the request to
reconsider items in the Final Scope for the project referenced above. Whilethe Board,
as Lead Agency, feels that there was nothing irrelevant in the scope as adopted,
have reviewed the list of objections provided by PWGC and provide a response to each
in the attached document.
Sincerely,A.,-,A ?.
James H. Rich III
Vice-Chairman
PlanningStrong's Storage Buildings
i s in Response
Amendment Request from the Applicant
April ,
2021
Item from
1. Impact on Water Resources
The Final Scope is requiring that the DEIS include the "impacts to groundwater
quantity available to neighboring wells...based on field studies over four seasons."
The proposed project includes a connection to the public water supply and discontinuing the
use of existing on-site private wells for the entire facility, thus reducing the amount of water
currently being withdrawn on the site to only that which may be required for landscaping.The
applicant has also consulted and obtained a letter of`eater availability from the Suffolk County
Water Authority (SCWA), which will be included in the DEIS. Conducting a four-season
groundwater quantity study would be appropriate for projects that are considering new
supply wells, or significant increases in supply wells,that would increase the volume of water
being withdrawn from the aquifer. As this project seeks to reduce the volume of ,vater
withdrawn on the site fora connection to the SCNVA,there is no rational basis for a year-long
study of groundwater quantity,We recommend removal of such study from the DEIS.
Planningoar Response
Conducting this study is necessary to analyze the impacts to groundwater quantity available
to the neighboring wells. This is rational because the DEIS must address potential moderate
to large impacts from significant soil excavation on-site that is potentially capable of
affecting the hydrology and zones of influence for nearby private wells, and the quantity of
water available after excavation is completed. Because the aquifer- can fluctuate seasonally,
conducting this study over time is important to account for all seasons including summer
when quantities may be significantly lower due to less rainfall.
Item from
The Final Scope is requiring that the DEIS "analyze and discuss in detail the impacts
on private wells in the surrounding area including technical details on groundwater
depth, quality, quantity, freshwater lens, saltwater interface, amount of flow in GPM,
direction of travel,and travel times.Include zones of influence from each wellhead."
This required study is requesting the applicant to monitor the individual,v=ellheads from all
private wells for a project that does not require the installation of new ,,Tells,but rather the
discontinuing of the use of existing supply wells. further, the application includes
conversion of the existing on-site individual sanitan- system to an I/A O\VTS. Tfi s
conversion would reduce nitrogen load and u-nprove groundwater quality.Additionallt°,the
STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
proposed project will recharge all stoiwater on site,which will continue to recharge the
aquifer. Finally, the proposed action does not involve any dewater ng or excavation in
groundwater. Accordingly, since the project is discontinuing the use of on-site wells, is
improving the conditions on site and does not involve dewatering,there is no rational basis
for such a study.We recommend removal of this analysis from the DEIS.
Planning BoardResponse
• The monitoring of specific wellheads is not intended to be included within the final
scope or DEIS.
• This is rational because the DEIS must address potential moderate to large impacts from
significant soil excavation on-site that is potentially capable of affecting the hydrology
and zones of influence for nearby private wells, and the quantity of water available after
excavation is completed. Because the aquifer can fluctuate seasonally, conducting this
study over time is important to account for all seasons including summer when
quantities may be significantly lower due to less rainfall.
• Below are clarifications of what must be included:
a. Will the proposed action adversely impact any wellhead zone of influence, or the quantity
or quality of water in the aquifer that supplies nearby residential wells?
b. An analysis of the groundwater on site and its contributions to the aquifer serving nearby
wells under existing conditions, and the potential adverse effects, if any, to the aquifer
serving nearby wells following excavation.
c. Conduct the analysis over the course of a year to account for seasonal fluctuation.
. Study and describe the nature of the aquifer that supplies the nearby wells, and the
relationship of the subject property as a contributing source to that aquifer; or show that
this subject property is not a contributing source and that the proposed excavation will
not affect the quantity of water available to nearby wells.
e. Direction of groundwater travel and travel times: What direction is groundwater
traveling on site? Would the excavation disrupt or interrupt groundwater travel or
timefra es to reach surface waters?
f. Depth of freshwater lens and elevation of the saltwater interface: Will the proposed
excavation alter the saltwater interface in a way that may cause saltwater intrusion into
the aquifer or nearby wellhead zones of influence? Will the proposed excavation cause
upconing and saltwater intrusion by reducing the amount of fresh water entering the
aquifer used by the nearby wells. At what elevations does potable freshwater begin and
end (at the expected saltwater interface) on site pre and post excavation?
Item from
The Final Scope is requiring e DEIS to "discuss the narrowness of the creek in
this area and tidal flow restrictions in an acceptable model.Include the increase tidal
ow volume and velocity restrictions that could res t from e increase in boats or
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STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
docks (if any)." On page 23 of the Final Scope, the "extent and quality of the
information existing and needed" indicates "Water/Tidal flow modeling/study in
front of the Marina including docks and boats (applicant generated)."
The proposed application is for the construction of two storage buildings for
indoor, heated storage,within a facility that has existed for nearly 60 years for the
purpose of boat storage, dockage, and maintenance.As repeatedly indicated by the
applicant and the project team,the proposed application does not include any docks.
Furthermore, the proposed application does not include any Inlet modification that
would alter tidal [low,and does not introduce a vessel length that is currently not using
the Inlet today. It is unclear why the use of Mattituck Inlet for boat travel to SYC for
the purpose of winter storage requires a water/tidal Row modeling/study.The DEIS
will present NO AA data as published at 1-atpsl- ,de.,;,,iildclirret-its,tioaa, as well as
an independent Mattituck Inlet Survey with soundings at low tide already conducted
by H&L Contracting LLC in April 2020.Please confirm that this is acceptable.
Planning Board Response
• The narrowness of the creek in the area and the effect of the proposed action on tidal
flow is being required to be discussed in the DEIS.
• Although the applicant states that "the proposed action does not include any docks; the
DEIS must discuss the proposed action in relation to potential growth and construction
of future new docks and marina expansion.
• If it is the intent of the applicant to not request the construction of new docks or a marina
expansion now, or in the future, that should be made clear in the IS.
• The NOAA data and Mattituck Inlet Survey suggested may be acceptable to include in
the DEIS in place of a new water/tidal flow model/study if they provide sufficient
information to determine whether there will be an impact to water quality resulting from
potential lower velocity of tidal flow from additional large boats.
• Discuss the effect of mooring large boats at the marina on tidal flow as compared to
current conditions, and if there are adverse impacts, what mitigation could be achieved.
• to from PWGC
2. Impacts on Transportation
• The Final Scope is requiring"real-time" traffic data and roadway user group
and analysis over four seasons.
It is unclear what the to "real-time traffic data" is intended to mean. In Traffic
Engineering terms, "real time" data usually refers to traffic data that is continuously
recorded and available whenever called for.Real-tinie data is used in Traffic NlarlagellieTIL
I
Systems such as NYSDOT's INFORM system in Hauppauge as input to the traffic
control system managing traffic signals,ramp meters,and variable message signs. Please
define"real-time data" for the purpose of this study.
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STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
Planning Board Response
• In the context of the Lead Agency's Final Scope, real-time traffic data refers to traffic
counts in the field over a certain timeframe.
• For clarification, "roadway user group" means the user groups using the roadways and their
respective activities in type, frequency and location, including vehicles, pedestrians, runners,
and cyclists.
to from PWGC
Conduct of the traffic analysis over four seasons is inappropriate. The Institute of
Transportation Engineers (ITE) recommends that traffic analyses be conducted based
on average yearly traffic data (the average day throughout the year). The ITE,
NYSDOT and the Suffolk County Department of Public NVorks all use "Seasonal
Adjustment Factors"to adjust traffic data taken any time during the year to the Average
day's traffic.The same seasonal adjustment factors cart be used to take data taken any
time during the year to traffic experienced during any particular month. The "average
day is typically done throughout Long Island with the exception of the five eastern
Towns,where peak summer data is typically used.Weekday AM and PM Peak Hours
and the Saturday Peak Hours are studied to deteirnine the proposed project's impact
on roadway's experiencing peak traffic conditions. According to data from the
NYSDOT Permanent Count Station on Route 25 in the Town of Southold peak traffic
occurs during August.
It must be noted that the traffic analysis is intended to exan-nine the traffic impacts
related to the construction of the project and in particular the removal of sod,
construction of drainage facilities and the retaining walls.This work is going to be done
between September 15th and May 15th so as to not interfere surnmer activities in the
area. Boats stored in the completed project building are too large to trailer and will
arrive after Labor Day and be put back into the water in the Spring. The project«ffl
have no traffic impact in the Summer,and we see no valid reason to collect data during
the Summer.
Based on the above,it is recommended the traffic data be collected in April of 2021
and be adjusted as necessary using seasonal adjustment factors.
Planning Board Response
• "Traffic analysis is intended to examine impacts related to the construction of the project..."'
As you are aware, the intent of SE is to analyze the whole action. The Planning Board
finds it necessary to assess potential adverse impacts from traffic for all phases of
construction and operation of the Marina property. To omit the summer months in an
assessment would not meet the intent of SE QR regulations.
• The proposal to collect traffic data only in April of 2021 and adjust the numbers using
the seasonal adjustment factors is a deficient assessment. The Lead Agency requires
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STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
four seasons of traffic counts to ensure the analysis accurately reflects the traffic
situation in Southold Town.
• While August may appear to be the peak of traffic based on Rt. 25 counts,what happens
on the other roads is not captured by those counts and cannot be relied upon to accurately
reflect peak traffic times.
• Traffic influences in the Town of Southold are no longer limited to "seasons". It is
expected that day forward traffic data will reflect post pandernic increases in traffic due
to population increase and higher tourism influx. The NYSDOT Permanent Count
Station located on NYS Route 25 does not reflect traffic conditions on Suffolk County
Route 48 and therefore it is not accurate to extrapolate traffic conditions from there to
other roadways.
• As such, seasonal adjustment factors based on that one roaway's data are too
generalized to gauge the actual traffic impacts, and traffic counts must be done at key
intersections at several times of the year.
Item from
The Final Scope also does not speclIy the type of analysis to be conducted with
respect to roadways such as West Mill Road and Cox Neck Road.
The Final Scope does not define which roads are to be studied;but lists many roads;
some of which may never see project traffic. It is typical to set a threshold as an
indication of whether the projects traffic may have a potential impact. Typically,
the ITE recommends a 5% threshold,indicating that if the project@s traffic exceeds
5% of the existing traffic volume, that the projects impact on roadway or
intersection should be examined
Planningear Response
• In addition to Level of Service counts,the Lead Agency is requiring an analysis to assess
the impacts of the proposed action to the safety of all user groups along the route for
vehicles to and from the subject site. This includes a Traffic Safety Evaluation and a
Pedestrian and Cyclist Safety Evaluation.
• Elements of these evaluations include but are not limited to the following:
o Sight distances at intersections and around curves in the roadways
o Width of pavement
Locations and width of shoulders along the route.
Assessment of the amount of space a pedestrian or cyclist would have on
the pavement when two vehicles pass each other.
Assessment of any other existing traffic, pedestrian or cyclist safety
infrastructure (e.g. signage or pavement markings).
Assessment of the safety of a pedestrian when two vehicles pass each
other while a cyclist or pedestrian is traveling on the shoulder.
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STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
■ Assessment of the perceived safety by pedestrians and cyclists given the
pavement width and speed limits along the route and expected traffic
generated by this project.
• Assessment of large trucks' turning radii and their ability to complete
safe turning movements at all intersections and safely navigate all
comers in the streets along the route, e.g. truck template for route
traveled by the largest vehicles expected to make regular trips in and out
of the site.
o Accident data from the New York State Accident Location Information System
for the last three years for intersections and their immediate vicinity.
a Driveway locations and operation including the potential for stacking on the
public street during busy times.
• West Mill Road and Cox Neck Road in particular must have these evaluations.
Item from
The Final Scope does not identify the study intersections requiring a Level-of Service
analysis.
Final Scopes typically define the intersections to be studied. The intersection of Sound
Avenue at North Road (CR 48) and Cox Neck Road could be appropriate although it
is very unlikely to show any impact, as the additional traffic added by the project will
would not typically influence the capacity of the intersection.
Planning oar es o se
Level of Service analyses should correlate to the routing plan for vehicles to and from
the subject site. At a minimum the following intersections should be included:
o Intersection of West Mill Road and Cox Neck Road
a Intersection of Cox Neck Road and Sound Avenue/ County Route 48
Item from
• The Final Scope is requiring the DEIS to "provide a comprehensive boat (vessel)
traffic study analysis...of the potential moderate to large significant increase of boats
to the Mattituck Inlet.Include the existing conditions analysis and potential impacts
one Water Quality — include a discussion on the current and potential adverse
moderate to large impacts to surface water quality in the short and long term
(duration). Provide the T14YSDEC shellfish closure areas, types of pollutants
occurring in the creek currently, types of chemicals in marina and vessel
maintenance needs in the proposed construction and operation of the marina facility
and mitigation.Include,but not limited to,dissolved oxygen,clarity,eutroicatio ,
and sustaiaility for estuarine and marine life, as well as existing sources of
stormwater. The potential for sedimentation during construction, and resulting,
post-construction, long-term stormwater runoff contributions from e site will be
described and quantified."
6
STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
On page 23 of the Final Scope, the "extent and quality of the information
existing and needed" indicates "Water quality assessment of current conditions
in Mattituck Inlet overall all four seasons (applicant generated)."
First, an assessment of the potential impacts to water quality due to boats arriving to
the site for storage and leaving the site to return to their base marinas or docks is more
appropriately addressed in the Impacts to Water Resources (Gruund,,vaLcu and Surface
Waters). We propose to move this assessment out of the transportation section,which
best addresses the impacts on transportation infrastructure.
Planning Board Response
0 The Planning Board agrees that the potential impacts to water quality could be addressed
in the Water Resources section.
Item from PWGC
Second, we would like to request clarification of the assessment included. The Final
Scope seems to suggest that the applicant is to collect surface water quality, data to
document the water quality of the Mattituck Inlet although published data through
various programs is available, including data provided by the Suffolk County
Department of Health - Bureau of Marine Resources for five water quality sampling
locations in Mattituck Creek from 2000 to 2020. The DEIS proposes to rely upon the
published data from Suffolk County, as sourced below, as well as scientific data and
literature that exists for the Mattituck Inlet,including:
Suffolk County Department of Health Services (SCDHS), 2021. Surface water
quality monitoring data provided by the SCDHS Office of Ecology,Yaphank,N.Y
Existing Cornell Program data at the SYC Facility (Cornell Cooperative
Extension of Suffolk County—Long Island Shellfish Restoration Project)
NYSDEC water quality data for shellfish protection—to be obtained through
FOIA request to Town of Southold Trustees office for data.
Suffolk County Sub\-,,,,itershed Wastewater Management Plan,jul3,2020.
Long Island Sound Study and the 2015 revised Coiziprehonsits, Conservalioll alld
Matia,oeviecl Plan.
As excerpted from the NYSDEC's SEAR Nlanual, Fourth Edition, 2020, "the use of
existing comprehensive plans, prior ElSs, and natural resource inventories expedites
scoping and reduces the need to develop extensive ne-w data for the current EIS."
Accordingly,our proposed methodology is consistent with the NYSDEC guidance.Please
verify if such baseline data is acceptable.
Planning Board Response
Existing water quality baseline data are acceptable to be included within the DEIS so
long as they are current (2020 data are acceptable).
Item from PWGC
7
STRONGaS FINAL SCOPE OBJECTIONS
To assess the potential water quality impacts from the additional boats traveling to and
from SYC for winter storage purposes, the LEIS will rely upon the aforementioned
published resources for baseline data and the potential impacts of the boats to be stored
on site would be evaluated as follows,
> Number of existing boats under the control of Strong's Marine that use the Inlet.
> Number of projected additional boats that would travel to/from SYC for dic
purpose of entering and exiting storage (i.e., 88).
> Quantify for the expected additional boats: boat type (length and make); types
of engines; and environmental discharge data from the boat and/or engine
manufacturers for in water movement and at idle.
Total number of boats that utilized Mattituck Creek/Inlet in the 2020 boating season.
A Impact of the projected additional boats for storage facility.
The comprehensive boat (vessel) traffic study analysis is further requested to
"discuss the impact of increased boat traffic due to the expanded activities
including devising a methodology to police and monitor the water quality."
This request seems to further the general misunderstanding that this project Nvill lead to an
increase in continuous boat traffic that will lead to an impact to the quality of the Inlet The
proposed action includes two buildings for the purpose of winter boat storage. The project
does not include the use of these buildings year-round, does not propose year-round boat
traffic in an out of the facility, does not propose any additional docks, or any other facilities
to house boats that arrive to the site for storage. As expressed by the applicant throughout
the process to date, the purpose of the project is to provide indoor,heated storage for boats.
The boats will arrive to die facility at the close of boating season (i.e., October-November)
and the same boats will be removed from storage and exit die Inlet in the beginning of the
boating season (i.e.,April-May). It is estimated that approximately SS boats per season would
be stored in the new buildings. Accordingly, given an eight-week timeframe for entry to
storage in the Fall and the same t_' eframe to remove boats from storage in the Spring, this
equates to an average of approximately 11 boats per week or less than two boats per day.
Based on the actual proposed use, the request for the applicant to devise methodology to
police and monitor water quality suggests a much more intense use.
Also, it is important to note that the Mattituck Inlet currently has three marinas/docking
facilities (Strong's Yacht Center, Strong's eater Club & Marina and Mattituck Fishing
Station), two public boat launches (k4attituck Creek Watetway Access Site and North Load
Inlet), two fueling stations (at the two Strong's-owned marinas), one pump out boat owned
by SYC (as the existing pump out station at the IVlattituck Creek Wateiway Access Site has
been inoperable for m7o years), and is an authorized area for boats to anchor overnight.
Recognizing, that klattituck Creek is a heavih,-traveled waterway in the Town, there is no
possible way to police and monitor water quality solely related to boats that dock or elect to
be stored at SYC. We propose to address those items that are within the control of SYC.
Planning oarResponse
Thank you for the clarification on the boat storage operations. Please include this
discussion within the DEIS. Although the increase in boat traffic in the inlet as a result
of this action is a fact. The discussion on potential impact to water quality (turbidity
8
STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
impacts and chemical introduction through bottom paints and other boat maintenance
practices) to the water body must be discussed in the Water Resources Section.
• The Planning Board remains concerned about the effects of boats not only traveling to
and from the storage facility, but also the effect of multiple large boats potentially
stacking up in the inlet as they wait to be lifted and stored. Also what effect the new
facility might have during the summer. Will there be additional boats traveling to the
site for repairs during the summer?
• The Planning Board amends the requirement regarding the need to develop a
methodology to police and monitor water quality to only those actions within the control
of the applicant.
Item from C
3. Impacts on Air Quality
The Final Scope is requiring an air quality analysis for boat traffic.
The request for an air quality analysis is not reasonable when considering the projected
number of boats (88 vessels twice per year) and the purpose of the project(i.e.,indoor,
heated storage). Given an eight-week timeframe for entry to storage in the Fall and the
same tieframe to remove boats from storage in the Spring,this equates to an average
of approximately 11 boats per week or less than two boats per day.Averaged annually,
the total 176 trips (88 boat trips in the Spring and 88 boat trips in the Fall) equates to
0.48 boat trips per day.
Planning oar es ose
Thank you for the information on the projected number of boats. Note that SEQR
requires assessment not of just what is proposed, but also existing conditions. The
Planning Board will remove the requirement for an air quality analysis for boat traffic
but continues to require an assessment on the potential adverse impacts to air quality
from construction activities and marina operations.
Item from
4. Construction-Related Impacts
"Mining" is not proposed and the Final Scope should be amended to reflect
the proposed project.
9
STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
Repeated throughout the Final Scope is the term "mining,"which is not proposed as
part of this development and the proposed action is not subject to a SDEC
Mined-Land Reclamation Permit. "Mining," as defined by the NYSDEC,is defined
as "the exIniction of ocerburden and minvolr fi-am 117e earth; the Pre,Parafion andp roc ei'shn, of
minerals, includiii,.g any actirifies or processes used for-the e-wraction or resnowl of mineralffiross
their original location and the reparation such ax;pasbina, cleaniego, crushing, Is s ckpilin.g or other
processing at the mine location that makes a mineral suitable Jor 6emnertial, or
construction use." The use of the term "mining" is suggesting that this applicant IS
proposing to remove materials for some monetary benefit and should be revised to
??excavation" or "cut".
Planning Board Response
0 Please provide official documentation in the DEIS that no action on-site constitutes
mining.
to from PWGC
5. Consistency with Community Plans and Studies
0 The Final Scope requires the DEIS to include "an in-depth analysis of the
action on the following policy and planning documents, legislation, and
implementing rules and regulations...2019 Suffolk County Special Grand jury
Report: Illegal Dumping& Mining, Suffolk County."
The inclusion of this document in this applicant's Final Scope suggests some illicit
,activity or involvement in "Operation p'ay Dirt." As the proposed removal of material
from the subject property is for the sole purpose of constructing marine development
at-grade With me Mattituck Creek, the inclusion of this source suggests othelwise and
should be removed in its entirety from the Final Scope.The DEIS will not address this
source and the applicant requests an amended Final Scope be issued,
Planning Board Response
0 The reference to the "2019 Suffolk County Special Grand Jury Report: Illegal
Dumping and Mining Suffolk County" was an oversight and will be removed from
the final scope.
to from PWGC
0 The Final Scope is requiring studies and analyses that seem to be in direct conflict
with the Town's recently adopted (September 2020) Comprehensive Plan Update.
The subject property has existed for marine use for oN,cr 60 years. In 201-7t c St o g
I
Marine famili acquired the former lWattituck Inlet 1\1arina and Shipp and(nov,-Strong s Yacht
10
STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
Center and applicant) as well as Matt-a-Mar (now the Strong;s Water Club &Marina), and
only one other marina (Mattituck Fishing Station) remain on the Mattituck Inlet.
In the Southold 2020 Comprehensive flan,adopted September 2020,one of the economic
development goals stated is "goal a I ciX g ra,,� ..anted „{.woLitisiLgc to _u )ort
Eistia�c trncl I°°tit ae l I.g it nae 1 c :ts nz Ins, runt yaa5trless Sector witifin the F1'Own's
F ont)nj "''The ability for large marinas to expand services that crater to customer needs
was sperifically recngni�zed. its excerpted from the stated Objective 5.4 for F,ronomic
Development, "Large marinas are facing pressures to expand their services to include
swimming pools,restaurants, boat rentals, storage space, and other services that cater to
their customer's needs. In order to accommodate this demand and continue to promote
Southold's traditional maritime heritage,the Town should consider zoning amendments for
marinas of appropriate size and location to better match the needs of their
clients."(emphasis added)While this objective seeks zoning amendments to allow for such
uses,the subject application does not require any such relief under the Marine-II zoning.
Furdler, the importance of Mattituck Inlet was specifically- addressed in Objective 5.7 to
"Enhance the connection between Mattituck Wet and the h rnlc't center-" As excerpted,
"Mattituck Inlet is an important economic,environmental,and recreational resource in the
hamlet of Mattituck.Located just north of the hamlet center,Mattituck Inlet runs two miles
into the Forth Fork from Long Island Sound,and is the only harbor on the±50 mile stretch
between Dort Jefferson and Orient Point. As such, Mattituck serves as an important
maritime location with the Inlet being a popular destination for boaters. The hamlet's
accessibility to water, in addition to a designated anchorage, a Town park and boat ramp,
marinas, and maritime uses located close to the hamlet center make it a key economic
driver."
It is recognized that viewshed and maintaining the community character is of importance
(Objective 5.5e l'rescn�e the scenicac is rlca aq1 tl q _ -QN rr"s shorcline, thri-,nro�h r;r'arttintled;
tl�tt sic t�cal"evdaacrfartra� 1rr'calacr°ta°, la,ilt�scirif tt to g tc _nclud p escrved landand :a a°:t¢u of
outdoor ac1jY t1KN alict public recr e,,ition),and the Final Scope has identified the potential visual
impacts as an impact issue to be evaluated. However,the request for year-long studies of traffic,
roadway user groups,surface water qualit},and groundwater quality given the scope of the project
for storage space only, seems to be in direct contradiction to the stated economic development
goals in the Town's comprehensive plan
Planning BoardResponse
The discussion about requiring studies that are in direct conflict with the Southold
Town Comprehensive Plan (2020) is noted and should be included within the LEIS.
However, none of the goals and objectives mentioned preempt the regulatory
authority of SEAR assessment of a Type I action.
Item from C
6. DEIS Outline is Redundant or Too General
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STRONG'S FINAL SCOPE OBJECTIONS AND RESPONSES
The Final Scope includes sections for Impacts on Ecological Resources,and Impacts on Plants
and Animals.These sections are proposed to be combined as Ecological Resources includes
plants and animals.
• The Final Scope includes a section for Impacts on the Environment,requesting the DEIS
to "discuss the operations of the site and the overall impact on the environment.'"
Pursuant to Section 617.2(1) of the implementing regulations of SEQRA, the definition
of"environment"is as follows:
(1) Eni,ironvienl means The physical conditions Mal xill be qYeaed �iy a prqposed
action, includieg land, air,2valen minerals,flora,fauna, noise, resource,r qfagiicallural,
archeokgical, historic or aesthetic s gnz icance, exishn,a Patterns of population
concenlralion, distribution orgroiPth, existing communiY or neigabborhood cbaracter,
and human bealth.
Accordingly, the Impacts to the Environment is accomplished through the preparation
of the DEIS and the various impact sections and is not appropriately handled in its own
section as it would require summarizing the content of the DEIS.We propose to address
the requested elements (Items 2, 3 and 4) in their respective sections — ecological
resources and water resources.
• The Impacts on Transportation includes a comprehensive boat (vessel) traffic study
that includes water quality assessment that is more appropriate for inclusion in the hater
Resources section.We propose to address the potential impacts on surface water quality
in the Water Resources section.
• In the "Proposed Organization and Over-all Content of the DEIS",it is noted that
➢ Section 4.1 duplicates Section 3.8
�, Section 4.2 duplicates Section 3.1
• Our proposed outline is as follows:
Planning Board Response
• The Planning Board agrees with the amended outline for the DEIS
Executive Summary
1.0 Description of the Proposed Action
1.1 Project Location and Site Conditions
1.2 Project Design and Layout
1.3 Project Objectives and Benefits
1.4 Construction and Operations
L5 Required Permits and Approvals
2.0 Natural Environmental Resources
2A Impact on Soils and Topographi
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STRONGa
S FINAL SCOPE OBJECTIONS AND RESPONSES
2.1.1 Existing Conditions
2.1.2 Potential Impacts
2.1.3 Proposed Mitigation
2.2 Impact on eater Resources (Groundwater and Surface Water)
2.2.1 Existing Conditions
2.2.2 Potential Impacts
2.2.3 Proposed Mitigation
2.3 Impact on Ecological Resources
2.3.1 Existing Conditions
2.3.2 Potential Impacts
2.3.3 Proposed Mitigation
2.4 Impact on Flooding
2.4.1 Existing Conditions
2.4.2 Potential Impacts
2.4.3 Proposed Mitigation
3.0 Human Environmental Resources
3.1 Impact on Human Health
3.1.1 Existing Conditions
3.1.2 Potential Impacts
3.1.3 Proposed Mitigation
3.2 Impact on Transportation
3.2.1 Existing Conditions
3.2.2 Potential Impacts
3.2.3 Proposed Mitigation
3.3 Impact on Aesthetic Resources
3.3.1 Existing Conditions
3.3.2 Potential Impacts
3.3.3 Proposed Mitigation
3A Impact on Community Character
3.4.1 Existing Conditions
3.4.2 Potential Impacts
3.4.3 Proposed Mitigation
3.5 Impact on Open Space and Recreation
3.5.1 Existing Conditions
3.5.2 Potential Impacts
3.5.3 Proposed Mitigation
3.6 Impact from Noise
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STRONG'S FINAL SCOPE OBJECTIONS
3.6.1 Existing Conditions
3.6.2 Potential impacts
3.6.3 Proposed Mitigation
3.7 Impact on Air Quality
3.7.1 Existing Conditions
3.7.2 Potential Impacts
3.7.3 Proposed Mitigation
3.8 Social and Economic Impacts
3.8.1 Existing Conditions
3.8.2 Potential Impacts
3.3.3 Proposed Mitigation
3.9 Construction-Related Impacts
3.9.1 Description of Proposed Construction Schedule and Activities
3.9.2 Potential Impacts
3.9.3 Proposed Mitigation
3.10 Consistency with Community Flans and Studies
3.10.1 Existing Conditions
3.10.2 Potential Impacts
3.10.3 Proposed Mitigation
3.11 Impact on Archeological and Cultural Resources
111.1 Existing Conditions
3.11.2 Potential Impacts
3.11.3 Proposed Mitigation
4.0 Other Required Sections
4.1 Use and Conseivation of Energy
4.2 Adverse Impacts That Cannot Be Avoided (Short-Term and Long-Term)
4.3 Irretrievable and Irreversible Commitment of Resources
4A Growth-Inducing Impacts
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FINAL SCOPE OBJECTIONS
5.0 Alternatives d Potential Impacts
5.1 Alternative 1-No-Action
5.2 Alternative 2-Alternative Material Removal flan Using Barges
5.3 Alternative 3- Construct Project on Another Parcel
5.4 Alternative 4—Construct Proposed Storage Building(s)'Without Excavation
5.5 Alternative 5—Construct Smaller building(s)with Less Excavation
5.6 Alternative 6—Reconfigure or Reconstruct Existing Buildings On-site for
Larger Boat Storage.
6.0 References
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