HomeMy WebLinkAboutNPV Substantive Review 6.26.23 N,ELSOnNse PnOPE ning VOORHIS
MEMORANDUM
To: Town of Southold Planning Board
From: Carrie O'Farrell,AICP, Senior Partner, Nelson Pope Voorhis and Osman Barrie, P.E.
Nelson + Pope Engineering
Cc: Heather M. Lanza,AICP, Planning Director and Mark Terry,AICP,Assistant Planning Director
Date: June 26, 2023
NPV No: 08265
Re: Strong's Yacht Center Proposed Boat Storage Buildings- DEIS Substantive Review
Nelson Pope Voorhis, LLC ("NPV") in association with Nelson + Pope Engineers, Architects, Surveyors ("N+P") has
reviewed the revised November 2022 Draft Environmental Impact Statement ("DEIS") for the Strong's Yacht
Center boat storage buildings proposed at 5780 West Mill Road in Mattituck. The purpose of this review is to:
• assist the Town Planning Board as lead agency in determining the accuracy, reasonableness and reliability
of the information, methods, analyses, and conclusions contained in the DEIS and to request additional
information and/or recommend additional mitigation where possible to prevent or minimize
environmental impacts to the maximum extent practicable; and
• review the DEIS for compliance with the State Environmental Quality Review Act ("SEQRA") and its
implementing regulations established pursuant to 6 NYCRR Part 617,Subsection 617.9(b) "Environmental
impact statement content."
Per our agreement with the Town, NPV's primary responsibilities for this DEIS review include consideration of
hydrology, hydrogeology and associated factors (e.g., groundwater, surface waters, wetlands, soils, and
topography). Nelson & Pope's (N+P's) primary focus is on traffic and transportation related impacts, analyses,
and mitigations.
Based on our review of the DEIS submission, NPV and N+P recommend that additional information, analyses
and/or clarification be provided in the Final EIS as follows.
HYDROLOGY/HYDROGEOLOGY
Comments:
1. The DEIS states that "[b]ased on SCDHS design flow factors of 0.00 gpd/SF for boat storage and 0.06
gpd/SF for non-storage (bathrooms), potable water usage for post-development conditions would
increase by 18 gpd from 1,058±gpd to 1,076±gpd." As previously noted, the projection of 18 gpd seems
quite low considering there would be 11 new employees and an increased number of patrons utilizing the
business's services and both proposed warehouses include bathrooms. NPV reviewed Suffolk County
Long Island: 70 Maxess Road, Melville, NY 11747 • 631.427.5665 nelsonpopevoorhis.com
Hudson Valley: 156 Route 59,Suite C6,Suffern, NY 10901 845.368.1472
Strong's Yacht Center Proposed Boat Storage Buildings
DEIS Substantive Review
Department of Health Services' (SCDHS)"Project Density Loading Rates&Design Sewage Flow Rates"and
found there is no flow factor provided for boat storage uses. How was the 18 gpd estimated?Additional
information is requested to determine the most appropriate multiplier to provide the best real world
sewage flow and water demand estimates:
• Each proposed warehouse will include a 19'x 8' (1S2 SF) bathroom and two new sanitary systems
are proposed, while one existing sanitary system will be abandoned. Therefore, the required
capacity to serve both existing and future employees must be demonstrated.
• How many employees currently work at SYC? Are the existing employees full-time, part-time or
mixed?
• What types of jobs will the 11 new employees fill? (e.g., boat storage and maintenance, office, or
other roles?)
• Are the new employees full-time, part-time or mixed?
• Which building(s), or work areas will the 11 new employees be assigned to? Will they all be
involved with the new yacht storage operations?
• Indicate whether office space or any other dedicated space will be included in the proposed
buildings.
• Indicate the square footage of any other dedicated spaces in the proposed buildings.
• Will the existing or proposed restrooms be open to the public/patrons (i.e., yacht owners and
their friends and families) or is bathroom use strictly for employees?
2. With regard to the 11 new employees, NPV believes that if the new employees'work area is in,around or
associated with the proposed buildings and their tasks involve yacht storage and maintenance, then the
projected flow rate for sanitary waste should be based on 7.S gpd per person based on full-time equivalent
(FTE) estimates or a volume determined by SCDHS as appropriate as expressed in a determination letter
from SCDHS. In addition, if any or all of the employees are assigned to existing spaces and facilities,there
will need to be an accounting of whether the flow projections for those buildings absorb the flow from
the additional employees and patrons.
3. Please provide a total peak water demand projection in total gallons per day for existing and proposed
flow based on total projected sanitary flow and water required for boat washing, landscape irrigation and
any other operations that require the use of water.
4. Alternative 7: Alternative Material Mitigation Plan: Please further describe the area where the 13,500 CY
(12 inches) of soil would be placed. Is it flat?Will it be used to fill a topographic depression? Is it on a hill
or on a slope? Also,the area of soil placement under Alternative 7 is described as an area vegetated with
successional shrubland. What specific types of vegetation are present and are there any rare plants at
that location that may be affected? How much land will be cleared to accommodate the soil? How far is
the soil placement area from streets and property lines? The soil should be at least as far from the
property lines as the property's required yard setbacks. Please indicate in the DEIS that any soil that is
retained onsite will be clean uncontaminated soil.
5. One of the primary impacts from the project is the significant volume of soil to be removed and the
associated truck traffic. A letter dated June 24, 2021, was sent to SYC from H&L Contracting. The letter
states that H&L reached out to four different barge companies asking about the feasibility of utilizing
barges to export excess soil from the site and that these companies had indicated that it was not possible,
based on an anticipated draft of 10 feet and limited depth and width ("S" curves) along the creek. Please
provide the bases, essential information, and calculations if any to demonstrate that ten feet of draft
would be needed during low tide and that Mattituck Creek is too shallow to accommodate loaded barges
that may have less draft. Indicate the sizes (length, width, etc.) of the barges that would be used and if
there are alternatives such as smaller barges (with more frequent but smaller shipments) that might be
accommodated by the Creek. How much soil/ weight do the barges carry? How does the loading of the
barges affect its draft (e.g., ton/foot of draft)? How do (to what extent do) daily tidal cycles affect the
depth of the creek and hours per day that operations could be undertaken? Could barges be used with
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proper scheduling? How many barges would be needed? Where would barges be offloaded and what
would be the route taken for final disposal, reuse or stockpiling? Would soil be covered to prevent
siltation of the creek? Are there other alternatives or mitigations to lessen the impact of soil excavation
and export?
6. The groundwater model used by project consultants predicts a groundwater travel time of 4 to 4.5
years from the western boundary of the proposed excavation area to Mattituck Creek based on a particle's
expected curvilinear path from 40 feet below the water table to the Creek. How was this depth and path
determined? Based on the County's time of groundwater travel map,the time of travel is more likely 2-3
years and would be less where drainage and sanitary systems are proposed. If a volatile organic compound
or other chemical that is lighter than water is released into the ground wouldn't this pollutant remain at
the interface of the water table and vadose zone and reach the creek much sooner, especially if it is from
the septic systems or leaching galleys? If so,what would be the time of travel of a VOC to the Creek?
7. The last paragraph in Section 4, p. 28 of the Groundwater Modeling Report indicates that over the next
few decades sea level is expected to rise by 16±inches and groundwater beneath the proposed excavated
area would be expected to rise 1.31 feet but there is no indication of if or how, in conjunction with the
proposed project,this would impact nearby wells.
S. Page 4S, under"Water Supply and Surrounding Wells," includes an SYC annual water demand estimate of
1,0S8±gpd. Since activity at the yacht club is seasonal, what is the estimated demand in gallons per day
for water during the boating season? If demand is greater, how does that affect the hydrologic analyses?
9. Second paragraph, p. 106 regarding sea level rise states that: "MHW at the subject property coincides
with the top of the bulkhead and was mapped at approximately 4.0±feet. Based on a 16-inch or 1.33±feet
projection in the 2050s, MHW would be expected to increase to 5.3±feet AMSL. The existing bulkhead
ranges from 6.0±feet to 6.8±feet, and thus, would remain higher than MHW." The first sentence seems
to say that the existing bulkhead is at 4.0±feet, while the second sentence says that it ranges from 6.0±
feet to 6.8±feet. Please explain, correct or clarify the discrepancy.
10. The DEIS discusses fire prevention requirements for the proposed LPG tanks. LPG is known to be relatively
clean, however, based on the discussions in the DEIS, it is not stated definitively whether the new LPG
above ground storage tanks and their future contents are subject to the standards and requirements of
Article 12 of the Suffolk County Sanitary Code. Please provide a direct response as to whether the tanks
(LPG) are subject to these requirements or not, and why it is, or isn't subject to Article 12 requirements.
If it is, how the storage facilities will comply or not comply, and any mitigation proposed.
TRAFFIC AND TRANSPORTATION
1. Planning Board memo, Comment#2:The mitigation proposed to address potential large adverse impacts
from the total number of trucks on the quality of life, community character and infrastructure along the
route.
The Applicant Engineer did not provide any mitigations. It is stated in the revised Traffic Study that
"The comparison of the impact of the projected truck traffic is minimal on all the proposed truck
routes except for West Mill Road which showed an increase in Equivalent Single Axle Loads (ESAL)
loading with a 11.14 percent increase and Bergen Avenue, if it is used as an alternative the truck
route (See later Section: Alternate Routing of Haul Material). While the increased ESAL loadings by
percentage are significant, the significance is due to the existing light traffic volumes found on the roads.
The number of ESAL loads projected to occur on West Mill Road are approximately one tenth of those
projected to occur on Cox Neck Road. TSPE,as part of the pavement evaluation,also examined the ability
of Town of Southold standard pavement section with 1.5 inches of top, 2.5 inches of binder and 4.0 inches
of stone or recycled concrete base will support the expected loads from the project truck traffic".
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DEIS Substantive Review
The following table is a summary of truck traffic impact on the study roadways:
Future Condition -With proposed
Existing Conditions project
Increased % Increase Heavy
Heavy Heavy Heavy in Heavy Vehicle%
Route AADT* Vehicle% Vehicles Vehicles Vehicles w/Increase
West Mill Road 413 4.60% 19 80 421% 23.97%
Cox Neck Road 2,393 6.50% 156 80 51% 9.86
Sound Avenue 16,262 5.88% 956 80 8% 6.37%
CR 43 6218 7.84% 487 80 16% 9.12%
CR 58 24,585 7.60% 1,868 80 4% 7.92%
*AADT:Annual Average Daily Traffic
In the response, include a column in the table for Vehicle Volumes to include the Adjusted Heavy Truck
Volume Percentage.
From the review of this table, the proposed project will increase truck traffic on West Mill Road by 421%
and on Cox Neck Road by 51%. This represents a significant increase in the amount of truck traffic on
West Mill Road and Cox Neck Road will add significant adverse impacts affecting the quality of life,
community character, and Town's infrastructure along said route.
2. NPV Comment#20,Section 3.10.2: Adequacy of 20 CY vs.30 CY trucks given the outcome of the AutoTurn
analysis. 20.b.i Based on the anticipated volume, the truck traffic due to use of a 20CY truck compared
to the 30CY truck will increase by approximately 1.5+/-times in order to complete the required volume
of trucking. From a numerical standpoint,the increased trips would negatively impact the community and
further degredate the Town's roadway infrastructure, due to the increased trips.
Traffic and Transportation Comments
3. Based on the AutoTURN Truck Movements supplied by Stonefield Engineering& Design, we find that the
existing roadway geometry will not accommodate the WB-50 trucks at the following locations:
West Mill Road 90deg Turn (West of Naugles Drive)—Heading to the Site
Cox Neck Road/West Mill Road at Bergen Ave
West Mill Road at
Bergen Ave 90deg Turn (North of Arbor Lane)
• Bergen Ave at Sound Avenue
The existing conditions and roadway geometry will not allow for safe and/or proper vehicular access along
the above mentioned roadways.These roadways may be impassable by pedestrians, bicyclists, and/or other
vehicles due to the inadequate remaining available road width, specifically around existing sharp curves or
intersecting roadways.
3.a.Concern at existing roadway curves may require the proposed truck traffic to encroach over the full
barrier/ double yellow center line and/or edge of pavement at the following locations, making these
segments of road impassable for other users:
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West Mill Road 90deg Turn (West of Naugles Drive)—Heading away from the Site
West Mill Road North of Bergen Avenue—Traveling in either direction
3.b. The width of the roadways(of concern)vary as follows:
West Mill Road -20FT
Cox Neck Road - 24FT+/-
• Bergen Ave-22FT+/-
Northville Tnpk-32FT+/-
Additional concern has been raised on the Town's single lane,two-way roadways that do not allow for
safe maneuvering of opposing vehicular traffic, bicycle traffic, and/or pedestrian use.
3.c. Based on the turning analysis, existing roadway width, geometry and curvature of the roadway, it is the
Nelson + Pope traffic engineer's opinion that bicycle and pedestrian traffic would not be safely
accommodated during these truck trips.
4. TSPE provided ESAL calculations based on the requested 5-year design lift and anticipated truck traffic
volumes,which appear to provide a numerical value for review, however does not utilize the correct truck
traffic data. .Although it does not reflect a true representation of what the Town's roadway standards are
capable of handling, at the least, the pavement evaluation report shall be re-run to reflect the correct
Heavy Vehicle Percentage based on inclusion of the proposed truck trips. This may not affect roadways
with higher AADT values as much but will dramatically affect the local roadways with low AADT volumes.
It is anticipated that the numbers may still fall within an acceptable range, however, it should be noted
more accurately for analysis and reporting purposes. The ESAL calculation method utilizes the NYSDOT
Pavement Materials evaluation which may be argued to be equivalent to the local municipal roadway
materials, however, cannot be guaranteed. NYSDOT Material standard specifications and requirements
typically exceed the Towns Standards and/or Specifications based on the higher level of magnitude a state
road may hold over a local Town road (with respect to traffic volumes and use). It does appear that the
general Town's standard roadway pavement section would meet the required design calculations with
respect to general depth of material; 6" Base + 2.S" Binder+ 1.S" Top. However, it should be noted that
no existing pavement cores were performed to confirm the existing roadway section, and that some of
the existing roadways may already be nearing the end of their lift cycle. Any additional heavy traffic
imposed on a roadway nearing the end of its life cycle may be more susceptible to maintenance issues
and possible subgrade infrastructure damage,which may require more extensive repairs. It may be in the
best interest of the Town to require a maintenance agreement for the affected roadways during this time
of additional heavy trucking.
OTHER GENERAL COMMENTS
As previously noted, NPV and N+P's focus was on hydrology (groundwater, surface waters, wetlands) and
associated or interrelated factors that affect hydrology(soil,topography,drainage,etc.),and traffic. Nevertheless,
some additional issues were noted during the normal course of the review that should be addressed.
1. The DEIS indicates that the proposed haul road will be between 16 and 30-feet-wide. Is this wide enough
for two 30-yard trucks to pass one another in areas that are 16 feet wide? NPV supports limiting the width
of the road as proposed to limit clearing and disturbance, but the process for managing conflicts between
incoming and outgoing trucks should be discussed.
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2. The DEIS states that "[o]nce [the Evergreen Macro Gravity Retaining Wall System is] in place and
backfilled, seeding and use by bird species will promote growth in the trays that are built into the wall to
create a "green" wall over a period of two-to-three years." Please be specific as to how the design will
prevent erosion and sedimentation of adjacent tidal wetlands and surface waters or the creation of dust
if it will take birds 2 to 3 years to fully seed the area and establish sufficient growth? Please indicate why
the wall is not going to be fully seeded, planted and stabilized immediately after construction?
3. The vibration analysis indicates that it is based on Federal Transportation Authority (FTA) and New
Hampshire Guidelines. Does the State of New York(NYSDOT)have its own guidelines for vibration analyses
or are the New Hampshire Guidelines the best available?
4. The DEIS mentions an April 8, 2022, letter from Nancy Herter of the New York State Office of Parks,
Recreation and Historic Preservation. Has there been further correspondence or developments in this
regard since that date? If so, please submit correspondence, and address any outstanding issues
accordingly.
S. Page ii of the DEIS states: "Due to the height and length of the expected boats to be stored, the existing
buildings at SYC cannot be used. Specifically, the height of the doors on the existing buildings are
approximately 24 feet. The current yachting market is producing both longer and taller vessels with the
height of a typical yacht at 35+feet. The proposed buildings would be constructed with door and ceiling
heights capable of accommodating such vessels." Page xix also states that the "proposed height of the
buildings would be 39 feet-3 inches from grade to the eaves and 45 feet-8 inches from grade to the top of
ridge. The mean roof height is 42 feet-6 inches." However, the "General Layout" plan indicates that
proposed building heights will be "<35 feet." The described building heights and needs are inconsistent
with buildings that are<35 feet in height.The DEIS and site plans must be consistent.
6. Page ii states: "The proposed two storage buildings would be placed to the west of existing Buildings 7 and
8 and are depicted as proposed Building 9 and Building 10 on the site plans." Some of the site plans,
however, identify the proposed buildings as Buildings 9 and 10 while some identify them as Buildings 1
and 2. One example in the text is on page ix which describes Building 1 as a residence,while some of the
plans show Building 1 as one of the proposed yacht storage buildings.
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