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Home My WebLink AboutUSDHS Plum Island Underwater Cables MAILING ADDRESS: PLANNING BOARD MEMBERS P.O. Box 1179 DONALD J.WILCENSKI Southold, NY 11971 Chair OFFICE LOCATION: JAMES H.RICH III Town Hall Annex MARTIN SIDOR 54375 State Route 25 PIERCE RAFFERTY (cor. Main Rd. &Youngs Ave.) �w L AMELIA JEALOUS-DANK ' Southold, NY� Telephone: 631 765-1938 www.southoldtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD November 27, 2023 John M. Searing, PE PMP Deputy Center Director Plum Island Animal Disease Center US Dept of Homeland Security Re: The United States Department of Homeland Security (DHS) Science and Technology Directorate (S&T)proposal to conduct activities relating to the abandonment in place of an existing undersea utility cable and the installation of a new undersea utility cable between Orient Point,New York(NY), and the Plum Island Animal Disease Center (PIADC) on Plum Island,NY. Dear Mr. Searing; The Southold Town Planning Board is submitting the following comments in response to The United States Department of Homeland Security (DHS) Science and Technology Directorate (S&T)proposal to conduct activities relating to the abandonment in place of an existing undersea utility cable and the installation of a new undersea utility cable between Orient Point, New York(NY), and the Plum Island Animal Disease Center (PIADC) on Plum Island, NY (Proposed Action). The Long Island Sound EstuaEy The Long Island Sound bounds the northern shorelines of the Southold Town land mass and islands. The watershed is one of the most significant coastal areas in the nation, spanning 16,000 square miles that traverses all of Connecticut and parts of New York, Massachusetts,New Hampshire, Rhode Island, and Vermont. Post World War II,the ecological health of the Sound began to decline. To address the decline, the Long Island Sound Study (LISS) was developed under the Environmental Protection Agencies National Estuary Program and authorized by Congress in 1985, establishing a collaborative partnership of federal, state, interstate, and local government agencies, industries, universities, and community groups in an effort to restore and protect the Sound. LISS partners work together to implement a Comprehensive Conservation and Management Plan to maintain the health of the ecosystem, restore coastal habitats, and increase Southold Town Planning Board Page 12 November 27,2023 public awareness of the Sound. Recognizing that the environmental concerns affecting the Sound cross political boundaries the LISS works together to share ideas, coordinate actions, and leverage financial resources to protect an entire ecosystem. The LISS initiated the Long Island Sound Futures Fund in 2005 through EPA's Long Island Sound Office and the National Fish and Wildlife Foundation. Over the years the Long Island Sound Futures Fund has invested$42 million in 570 projects. The program has generated an additional $54 million in grantee match for a total conservation impact of$97 million. (LISS Website). Significant Coastal Fish and Wildlife Habitats. The Town of Southold contains twenty-one (21) Significant Coastal Fish and Wildlife Habitats (SCFWH). These habitats are indicative of high ecological value. To designate a SCFWH, the New York State Department of Environmental Conservation (DEC) evaluates the significance of coastal fish and wildlife habitat areas, and following a recommendation from the DEC, the Department of State designates and maps the specific areas. Recent additions to the program include Pipes Cove (2005) and the Goldsmith Inlet and Beach(2005). The Town of Southold recognizes the importance of protecting and enhancing these valuable habitats. Twenty-one areas within the Town of Southold have been designated as SCFWHs by the NYS Department of State (DOS, 1987, 2005): Cedar Beach Point Conkling Point Corey Creek Cutchogue Harbor Wetlands Downs Creek Dumpling Islands & Flat Hammock Fishers Island Beaches, Pine Islands & Shallows Goldsmith's Inlet and Beach Great Gull Island Hashamomuck Pond Jockey Creek Spoil Area Little Creek and Beach Long Beach Bay Mattituck Inlet Wetlands and Beaches Orient Harbor Southold Town Planning Board Page 13 November 27,2023 Pipes Cove Creek& Moore's Drain Plum Gut, Port of Egypt Island Richmond Creek and Beach Robins Island The Race A list of the Significant Fish and Wildlife Habitats and their narratives can be found on the New York Department of State website at the following web address: http://wAvw. .os.il , zov/cottiiiiLinitieswaterli•oilts/coilsisiene/scfwhalaitats,html WaterQaliii All of the Town's coastal waters are assigned a classification by the New York State Department of Environmental Conservation based on best usage of a particular water body. The classifications set attainment goals and discharge standards for point sources, but do not necessarily indicate existing water quality conditions. Most coastal waters in the Town are classified as SA. The SA designation indicates that the primary use of the water body is shellfishing for market purposes, primary and secondary contact recreation, and fishing. These waters shall be suitable for fish propagation and survival (LWRP). By classifying waters as SA, the NYSDEC has set a management goal to achieve a level of water quality that is capable of supporting shellfish harvesting. This does not imply that the waters which are so designated are always considered harvestable.Although much of Southold's coastal waters are classified as SA, many of these same water bodies are not certified for direct market harvesting of shellfish due to the seasonal occurrence of pathogens. The classification is also important from an ecological and economic standpoint because healthy, productive waters support tourism and marine uses. Town departments and numerous organizations work to retain high-quality surface waters through local laws, The LWRP,the Peconic Estuary Comprehensive Conservation and Management Plan, and the Long Island Sound Study. Town of Southold Comments The Southold Town Planning Board is concerned that leaving the abandoned undersea utility cable in place could result in potentially significant moderate to large adverse impacts to this area of the Long Island Sound that are long-term in duration and unknown. Although we are not aware of the intricate chemical details of the decomposition process of the undersea utility cable,the life span of 25 years suggests that a level of degradation takes place and an influence to the surrounding soils and water quality is expected. The questions that we are seeking answers to include: Southold Town Planning Board Page 14 November 27,2023 1. How many undersea utility cables have been abandoned in place to date? 2. What is the undersea utility cable decomposition rate and what substances and or chemicals will it release into the soils and water? 3. Will heavy metals be released into the water body? 4. Is there a zone of influence established for the undersea utility cable decomposition? 5. Will bioaccumulation potential or toxicity to marine receptors be increased from the decomposition of the undersea utility cable if left in place? 6. Will the undersea utility cable if left in place become another potential pollution source and a stressor on the LIS ecosystem? 7. How long, what season and what size in the area would be restricted during the work cited? 8. What restrictions will be placed on vessel navigation of the area? New York State and the Town of Southold have spent years committing to restoring the LIS water quality and estuaries using millions of dollars in funding under the Clean Water Act. Leaving the abandoned undersea utility cable in place to decompose, over time, would seem to conflict with the Clean Water Act. The potential impacts to marine species from leaving the abandoned underwater cable in place needs to be adequately assessed to the Town of Southold Local Waterfront Revitalization Program (LWRP). The program provides strategies to encourage and protect the public waters and waterfront areas of the Town. It emphasizes the importance of the coastal zone and traditional maritime uses in terms of the commercial and recreational qualities of the Town. The coastal policies of an LWRP are used to review a project for consistency if the activity will occur within or affect that LWRP. All Federal and State actions require consistency with policies adopted under the program. Applicable policies include: Natural Coast Policies Policy 6. Protect and restore the quality and function of the Town of Southold's ecosystem. Policy 8. Minimize environmental degradation in the Town of Southold from solid waste and hazardous substances and wastes. Policy 11. Promote sustainable use of living marine resources in the Town of Southold. We thank you for the consideration. ercly, ��.. Donald Wi.lcenski, Chairman Cc: Scott Russell, Town Supervisor Southold Town Board