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HomeMy WebLinkAboutFire and public safety Rev7d FINAL - jkPage |Fire and Public Safety - 1 Rev7d FIRE AND PUBLIC SAFETY IMPACTS AND CONCERNS The DEIS scope requires the DEIS to “discuss the threat of fire and explosion on site from all ignitable sources” and “Include the evaluation of potential fire hazards, and if the Mattituck Fire Department (MFD) is adequately equipped to respond to a fire at the site” (p.23). The scope notes that this “is of special concern given the size of the structures and the combustibles within the stored boats.” The DEIS has not adequately addressed this concern. Recent fires at large indoor boat storage and service facilities1 (COMMENT FIGURES F1-F3), and a 2019 fire at Strong’s Water Club and Marina in Mattituck2, highlight the need to ensure that the proposed Project will not pose an increased risk to the environmental health and safety of Southold residents. Reports describing the recent fires and boat storage facilities highlight some of the problems faced by emergency responders and the potential environmental impacts associated with such fires. News coverage of a recent (February 2023) (COMMENT FIGURE F3) fire at an indoor boat storage/marina facility in Virginia noted the following: • the response required over 50 firefighters from eight volunteer fire departments; • doors could not be opened because of fears that wind coming through the door might push the fire inside throughout the building; • most boats had fuel in them and were made out of highly flammable fiberglass; • a HAZMAT team was needed to handle hazardous materials and to control fire water runoff along the shore; • the U. S. Coast Guard was called and arrived on the scene and Environmental Protection Agency (EPA) was notified; • firefighters used saltwater pumped from a river and freshwater from fire hydrants. News coverage of another recent (January 2023) boat storage/marina facility in Spain (COMMENT FIGURE F4) reported the following: • in a matter of minutes, flames devoured the structure until it collapsed with around 80 boats from 20 ft-40 ft inside; • some 30 firefighters, health services and a dozen civil protection volunteers were needed to extinguish the fire; • the fire spread at high speed through the materials and internal fuel sources; • the smoke was extremely toxic due to the nature of the burned materials; • a nearby hospital was told to keep windows closed as a precaution. 1 Toledo Beach Marina (La Salle, Michigan) in 2020: Woodland Marina (St. Charles County, Mo.) in 2020; Seattle’s South Park Marina in 2021. 2 Four boats destroyed during overnight fire at Mattituck Marina, Suffolk Times August 13, 2019. Page |Fire and Public Safety - 2 Rev7d The DEIS has not adequately addressed the possibility that the Mattituck Fire Dept. (MFD) may not have sufficient equipment (even with mutual aid from other nearby departments) and personnel to adequately respond to a major fire at the Project site. The MFD has been concerned about the number of volunteers in the department and has been engaged in an active recruitment campaign for some time.3 The MFD has frequently been required to call on other nearby departments for assistance.4 A February 2022 fire at a boat storage warehouse in Illinois required about 100 firefighters from departments in three counties more than 6.5 hours to get under control.5 A March 2023 fire at a marina indoor boat storage facility in Seattle required a “total of 14 fire engines, five ladder trucks, [a] fire boat . . . and additional support units . . . consisting of approximately more than 100 personnel.”6 As the Boat US Foundation notes: “Today's fiberglass/composite boats burn very quickly, and produce large volumes of toxic smoke that is equally as dangerous.” Burning fiberglass fumes include styrene (a suspected carcinogen), methyl ethyl ketone, and phosgene. All are considered hazardous air pollutants. Reports of a March 2023 boat storage warehouse fire in Illinois and the Seattle fire (COMMENT FIGURE F5) reported: “’They no sooner opened up the front doors, and all this smoke come out, and you could smell the fiberglass,’ he said. ‘The smoke was a combination of black smoke and yellow, and the yellow smoke was the fiberglass burning up,”7 and “Parts of the Seattle area saw air quality levels in the moderate to unhealthy for sensitive groups range as a result of the marina fire”.8 As proposed, the Project does not include adequate fire safety measures and will constitute an unnecessary and unacceptable safety risk to the community and the environment. Fire Safety Plan No Fire Safety Plan for the proposed Project is included in the DEIS. The Fire Safety Plan for the existing facility is defective and inadequate. 3 https://patch.com/new-york/northfork/mattituck-fire-district-revisits-building-expansion 4 https://suffolktimes.timesreview.com/2022/05/mattituck-cutchogue-fire-departments-extinguish-barn-blaze/ 5 https://apnews.com/article/fires-chicago-kenosha-waukegan-e918913ddd34f1fb827750248e14c6c0 6 https://www.foxnews.com/us/seattle-police-probe-massive-marina-fire-damaged-30-boats-risked-spill-hazardous-chemicals 7 https://www.wzzm13.com/article/news/local/boat-owners-concerned-after-fire-sparks-at-muskegon-marina/69-6dadc2c3- 660b-44be-a70c-145b97fd62a9 8 https://www.usatoday.com/story/news/nation/2023/03/22/seattle-marina-fire-suspect-arrested-portage-bay/11521058002/ Page |Fire and Public Safety - 3 Rev7d The DEIS states that “at the recommendation9 of the Southold Fire Marshal, a Fire Safety Plan has been developed by SYC [Strongs Yacht Club] to provide hazard locations, utility and water supply information, and emergency procedures for its employees. A copy of this Fire Safety Plan is included in Appendix P” (p.190, see also p. xv). Appendix P contains what is titled “Proposed Fire Safety Plan” (emphasis added). It is dated September 21, 2021 and consists of two pages of bulleted items and two maps. The plan included in Appendix P is not a fire safety plan for the proposed Project: • the Building/Site Layout Information section lists the nine existing marina structures. No mention is made of the two enormous new structures being proposed;10 • the list of hazard locations does not include the four proposed 2000-gallon propane tanks, nor does the map of the marina’s facilities; • the Utility Information section does not include information about new utility installations associated with the proposed Project; and • the water supply section makes no mention of the new hydrant included in the Project description, and cryptically describes the primary water supply as “Hydrant supply to property at Main entrance from Naugles Dr. to Cox Neck direct to Yacht Center”. One of two maps in the plan 11 depicts a hand-drawn highlighted yellow line identified as “hydrant location” (COMMENT FIGURE F6). The fire safety plan included in Appendix P is not applicable to the proposed Project. In addition, it appears that the fire safety plan (existing and/or proposed) may not even comply with the OSHA’s Occupational Safety and Health Standards for Shipyard Employment regulations set forth at 29 CFR 1915.1502 or with other components of various fire codes. Section 3.9.3 of the DEIS states that “[F]urthermore, as evaluated in Section 3.9.2 [impacts associated with ignitable sources] of this DEIS, the proposed [fire safety] plan was submitted to the Mattituck Fire Department and no potential service issues were identified (p.190). This is misleading as it appears that a copy of the fire safety plan in Appendix P was never submitted to the fire department.12 9 The Southold Fire Marshall stated that “Although not required by code for this occupancy, it is recommended a fire safety plan be developed and trained upon by employees”. 10 In addition, the building numbering system used on the maps in the Fire Safety Plan do not correspond to the building numbers used in the DEIS (p.2). The potential for confusion in the event of an emergency is obvious. 11 The base map, obviously downloaded from the internet, bears a “Google Maps” logo. Streets, the shore of Mattituck Creek, and a marker labeled “Strong’s Yacht Center” are shown. No actual hydrant location is shown. Actual street names are illegible, as are the locations of any structures, including any of the existing marina facilities. The highlighted yellow line may be intended to represent the route from a hydrant at Naugles Drive to the SYC entrance. The second map in the plan has a hand annotation reading “hydrant on Naugles Drive .3 mi”, but neither map shows the actual hydrant location. 12 The copy of the transmittal (dated June 17, 2021 in Appendix P) from the Applicant’s consultants (PWGC) included in Appendix P does not include a copy of the fire safety plan among its attachments, and does not reference that plan. In Page |Fire and Public Safety - 4 Rev7d The Applicant’s failure to include an appropriate and relevant fire safety plan in the DEIS, even though one may not necessarily be required at this stage of Project review, is significant because the “Proposed Fire Safety Plan” is offered by the Applicant as “proposed mitigation” in support of the DEIS’ conclusion that the Project would have “no significant adverse impacts to human health” (p.191). Section 3.9.3 of the DEIS also states that the “proposed development would not result in any significant adverse social or economic impacts. As such, mitigation is not required. Regarding fire safety, the following mitigation has been incorporated: At the recommendation of the Town Fire Marshal, a Fire Safety Plan has been prepared to provide hazard locations, utility and water supply information, and emergency procedures for its employees” (DEIS p. 283). The proposed fire safety plan included as DEIS Appendix P is inadequate and defective by any standard. It is not acceptable mitigation for increased fire risks associated with the proposed Project. It may not even be acceptable for the existing marina facilities. Fire Department and Fire Marshall Review According to the DEIS “in the reply correspondence dated July 27, 2021, the chief of the Mattituck Fire Department indicated that the department ‘has the capability to handle any fire situation on the proposed plan with the additional hydrant that is being installed’” (p.283). Although deference should be shown to the opinions and expertise of the Mattituck Fire Department, we would point out several areas of concern: According to NFPA 1 13 Chapter 18 ((Fire Department Access and Water Supply), Section 18.5.3, “Fire hydrants shall be provided for buildings other than detached one- and two-family dwellings in accordance with both of the following: (1) The maximum distance to a fire hydrant from the closest point on the building shall not exceed 400 ft (122 m). (2) The maximum distance between fire hydrants shall not exceed 500 ft (152 m)”. The new hydrant proposed as part of the project (which will be the only hydrant available to service both the existing marina and the proposed Project structures) will be located approximately 800 feet (straight-line distance) from the nearest part of proposed Storage Building No. 1, and even farther from proposed Storage Building No. 2. In addition, Suffolk County Department of Health Services (SCDHS) has recommended “the installation of an additional fire hydrant at the end of the line” (DEIS Appendix J). addition, the Fire Safety Plan is dated September 2, 2021—more than two months after comments were requested from the fire department. The fire department’s reply is dated July 27, 2021 13 National Fire Protection Association Code Page |Fire and Public Safety - 5 Rev7d No information was included in the original, December 2021, DEIS to indicate that minimum “fire flow”14 requirements for the proposed Project would be met.15 The revised DEIS contains a Water Design Report (in DEIS Appendix J) which does discuss fire flow. It states that the “water supply system has been designed for a maximum fire flow of 1,500 GPM with a total head loss of 29 PSI.” An accompanying table indicates water main service flows and pressures, including “Pressure Downstream @ Building.” The “Building” is not identified. This information was not available to either the Southold Fire Marshall, or the Mattituck Fire Department, at the time they prepared their comments on the Project. The Water Design Report also states that “The farthest connection is approximately 2,000 ft from the existing water main in Naugles Road and PWGC has performed design calculations to ensure that adequate pressure will be provided at this connection point.” However, it is unclear where that “farthest connection” is. The proposed hydrant would be located less than 1,000 ft from the existing water main in Naugles Road. The proposed water service line will extend as far as the bathroom in proposed Boat Storage Building No. 2, which is approximately 2,000 ft. away, but there is no indication that a fire department hose connection will be located there. In its last review of the Project, dated June 16, 2022 (see DEIS Appendix J), the SCDHS noted that information submitted by the Applicant “do not show fire separated from domestic service.” As noted above, the SCHDS also recommended “the installation of an additional fire hydrant at the end of the line.” According to IFC16 Appendix B (Fire Flow Requirements for Buildings) Section B103.1 “[T]he fire chief is authorized to reduce the fire-flow requirements for isolated buildings or a group of buildings in rural areas or small communities where the development of full fire-flow requirements is impractical.” The Planning Board needs to either confirm that fire flow requirements will be met, or that the fire chief has exercised his authority to reduce the required fire flow. In the latter case, the Planning Board should determine what Project modifications/alternatives, such as adding hydrants or standpipes, could satisfy fire flow requirements. If pumping water from Mattituck Creek, or use of existing on-site wells, is anticipated as part of any fire response plan 17 the potential environmental impacts should have been addressed in the DEIS. They are not. 14 “Fire flow” is the maximum rate and duration of water flow needed to suppress a fire. Fire flow is important for emergency response as it is the total capacity of the system that the fire department has available for use in response to a fire. 15The SCDHS also noted in its January 25, 2021 notice of application incompleteness to the Project engineers (DEIS Appendix J) that they needed to provide “hydrant flow data with and without fire flow as part of [a Water Design Report that also includes] the number of fixture units in the report, a riser diagram, & calculations for the needed fire flow using the ISO method”. 16 The International Fire Code (IFC) is a set of provisions designed to address life and property hazards associated with buildings and related premises. It is primarily focused on fire prevention and fire protection, and it is generally concerned with addressing potential harm from fires, explosions, hazardous materials, and unsafe use or occupancy of buildings and premises. The IFC has been adopted by New York State as part of the NYS Fire Code. 17 “Water Draft from Mattituck Inlet Creek” is identified in the Fire Safety Plan as a water source in addition to the primary source—the new hydrant proposed a part of the Project. Page |Fire and Public Safety - 6 Rev7d There is no discussion in the DEIS relating to the possible need for standpipes. Section 3604.2 of the New York State Fire Code requires that “Marinas and boatyards shall be equipped throughout with standpipe systems in accordance with NFPA 303. Systems shall be provided with hose connections located such that no point on the marina pier or float system exceeds 150 feet (15 240 mm) from a standpipe hose connection.” No existing or proposed standpipes are indicated on Project plans 18, although plans do indicate that water lines will be extended to service bathrooms in each of the proposed storage buildings. On June 17, 2021 the Applicant’s consultant requested comments on the Project from the Mattituck Fire Marshal, and the Fire Marshal responded on June 24, 2021 (DEIS Appendix P). In addition to noting a number of standard code requirements, the Fire Marshal specifically stated that “Fire Department access shall be provided within 150 feet of all portions of the exterior walls of all buildings”. The proposed Project site plan will not allow for adequate access to the north side of proposed Storage Building No. 1, and the east sides of both proposed Storage Building No. 1 and proposed Storage Building No. 2, as the distance between these structures and the adjacent proposed retaining wall will be only 10 feet 19. In addition, according to the Mattituck Fire Department, fire apparatus “need to park out of collapse zones of buildings, this would be approximately 30 feet . . .”20 The distance between the two proposed storage buildings is 60 feet. This means that if both structures were involved in a fire, fire apparatus would be required to enter the collapse zone. Given the heights of the proposed storage buildings, it is likely that aerial ladder trucks21 may need to be employed in the event of a fire. According to the New York State Fire Code22, “Aerial fire apparatus access roads shall have a minimum unobstructed width of 26 feet (4572 mm), exclusive of shoulders, in the immediate vicinity of the building or portion thereof.” According to the DEIS, although “the Fire Marshal recommended a 150-foot Fire Department access area from all exterior walls of the two proposed buildings . . . the Mattituck Fire Department’s [July 27, 2021] correspondence (explained above) was accepted by the Fire Marshal as adequate for not providing the recommended access area” (p.283). There is no evidence that this is the case. There is 18 The US Fire Administration (part of the Department of Homeland Security), in a report on the1989 boat storage structure fire at the Bohemia Bay Marina in Maryland, called out the lack of standpipes as a “key issue.” (USFA Technical Report TR- 026/January 1989. 19 According to NFPA 1, Chapter 18 (Fire Department Access and Water Supply) Section 18.2.3.4.1.1 “Fire department access roads shall have an unobstructed width of not less than 20 ft”. 20 https://mattituckfiredepartment.com/truck-company 21 e.g. Mattituck FD’s Ladder 8 company with its 95-foot ladder. 22 Appendix D (Fire Apparatus Access Roads) Section D105.2 (Width). Page |Fire and Public Safety - 7 Rev7d nothing in the Fire Marshal’s response indicating he has accepted the failure to provide adequate fire department access to all sides of the proposed structures. The DEIS is non-responsive to the Southold Fire Marshal’s comment that a sprinkler system is required and must meet code requirements. The Southold Fire Marshal also noted the need for a sprinkler system for the Project: “An automatic sprinkler system shall be installed in accordance with NFPA 13. Design of the sprinkler system should include but is not limited to: o Evaluation of water supply – is the capacity/location adequate for firefighting efforts. o What are the area (sq. ft.) limitations of the sprinkler system? o What is the hazard level of the building? Classification of commodities? o What are the specific design features required found in Chapters 12, 15, 17 and 20?” (June 24, 2021 correspondence from Southold Fire Marshal, DEIS Appendix P). There is nothing in the DEIS indicating that these questions have been answered. Although there presumably (?) will be one, no mention of a sprinkler system is included in the DEIS’ Project description, and no sprinkler system is shown on the Project’s utility plans (DEIS Appendix C).23 NFPA 1 requires that when “a structure exceeds 5,000 sq. ft., it is required to have a fire sprinkler system installed regardless of construction type—unless an AHJ [Authority Having Jurisdiction] permits the omission of sprinklers based on certain factors.”24 There is no indication in the DEIS that the appropriate AHJ25 has waived the requirement for sprinklers.26 In fact, the fire department and Fire 23 Correspondence dated August 2, 2021, from the Project’s consulting engineer, Jeffrey T. Butler, P.E., P.C., to PSE&G (DEIS Appendix P) references the need for electrical loads to service “Dry system sprinkler pumps” in the proposed storage buildings. If it the intention of the Applicant to install a dry sprinkler system, it should be noted that such systems have numerous disadvantages compared to wet systems. Disadvantages include increased complexity (dry pipe systems require additional control equipment and air pressure supply components which increases system complexity. Without proper maintenance this equipment may be less reliable than a comparable wet pipe system); Increased fire response time - Up to 60 seconds may pass from the time a sprinkler opens until water is discharged onto the fire. This will delay fire extinguishing actions, which may produce increased content damage. 24 NFPA 303:6.3.3.4 “Existing facilities shall not be required to be protected by an automatic fire-extinguishing system where acceptable to the AHJ. NFPA 303: A.6.3.1.3 “Where clearly impractical for economic or physical reasons, the AHJ could permit the omission of an automatic fire-extinguishing system when considering water supply availability and adequacy and size of facility.” It is unknown whether or not existing structures at the Project site are equipped with a fire suppression system. 25 It is unclear whether the Southold Fire Marshal or the Mattituck Fire Department chief is the AHJ for the Project. 26 The US Fire Administration (part of the Department of Homeland Security), in a report on the1989 boat storage structure fire at the Bohemia Bay Marina in Maryland, called out the lack of sprinklers as a “key issue.” (USFA Technical Report TR- 026/January 1989. Page |Fire and Public Safety - 8 Rev7d Marshall reviews assumed that the new storage buildings would be equipped “with fire suppression systems.” The DEIS states that “based on the above-described coordination with both the local fire department and Town Fire Marshal, the proposed action would not create any potential fire safety issues” (p.283). This seemingly definitive statement is not supported by the “above-described coordination.” As noted, the Fire Marshal raised several issues that have not been adequately addressed. In addition, although the fire department indicated that it “has the capability to handle any fire situation on the proposed plan,” that is not the same thing as saying that the plan does not create any new potential fire safety issues beyond those that may currently exist at the marina. For example, the addition of four 2000- gallon propane tanks, even if properly installed and maintained creates a “fire safety issue” even if all fire code requirements are satisfied. Likewise, the on-site indoor storage of large vessels containing gasoline, diesel fuel, and large amounts of wood and fiberglass reinforced polyester, has the potential to significantly increase the severity of any fire emergency. It is for this reason that the New York State Fire Code classifies indoor dry boat storage structures in structure group S-1 (Moderate-hazard storage). NFPA 303.7.2.1.5 states that “Where a boat is to be dry-stored for the season or stored indoors for an extended period of time . . . the following precaution shall be taken: . . . Permanently installed fuel tanks shall be stored at least 95 percent full.” The DEIS never discusses the potential hazard associated with the large volume of fuel that would present on vessels being stored. The designation of the Project’s on-site construction haul road as a post-construction fire access road occurred after the Fire Marshall and the Fired Department completed their reviews.27 As discussed below, this road does not satisfy code requirements for fire access roads. Post-Construction Use of the Haul Road The proposed emergency access road (the haul road) does not conform to code requirements. According to the DEIS, a “haul road would be constructed from the proposed Construction Excavation Area to West Mill Road, as shown on the Excavation Phasing Plan and Haul Road Plan in Appendix C. This haul road would be used for the entirety of Phase 1 and would remain as an emergency access road post-construction (pp. xxx, 18, 34) . . . for use by police, fire, or ambulance vehicles, as necessary” (p.288, see also pp. ii, xiv, 163, 209, 212, 217, 222, 285). The referenced Haul Road Plan does not show the eastern terminus of the haul road, or how close it will come to the proposed storage buildings. However, the “Aerial Overly” graphic in DEIS Appendix C does [COMMENT FIGURE F7]. The haul road would allow fire apparatus to come close to the Project site at 27 The original DEIS never identifies the “emergency access road” as a fire access road. The revised DEIS states that the road “could be used to direct water down from the higher elevation onto a structure fire” (DEIS pp. 19, 290). Page |Fire and Public Safety - 9 Rev7d the top of the retaining wall, but “[T]here would be no access for vehicles or personnel past that point” (p.18, 285). As the DEIS notes, the haul road “could be used to direct water down from higher elevation onto a structure fire.” However, no readily available water source exists to service that location. Firefighters would have to rely on tanker trucks.28 Fire department access roads require 20 ft of unobstructed width.29 The proposed haul road will be only 16 ft wide for most of its length. In addition, the haul road would not provide adequate turn-around space for fire apparatus as required by code 30. Propane Tanks, Lithium Batteries, and Other Potential Fire Dangers The Project includes the installation of four 2000-gallon propane tanks.31 Although the DEIS mentions that it will comply with 2020 NYS Fire Code and National Fire Protection Association (NFPA) 58 as they relate to the liquid propane gas (LPG) tanks proposed for the Project, it never discusses, or even mentions, Chapter 36 (Marinas) of the New York State Fire Code 32, or NFPA 303 (Fire Protection Standard for Marinas and Boatyards). Chapter 7 of NFPA 303 deals specifically with berthing and storage. Even when installed according to code and properly maintained, propane tanks still present a danger. On rare occasions, propane tank explosions can occur from the pressure of the propane tank reaching higher than the pressure that the tank can safely vent, causing the tank to burst open. This can occur if the structure adjacent to the tanks (e.g., the proposed storage buildings) is on fire. This kind of explosion is called a Boiling Liquid Expanding Vapor Explosion (BLEVE). The DEIS should have addressed this possibility and evaluated the potential impact, and the ability of the Mattituck Fire Department to adequately respond. The DEIS makes no mention of how often the propane tanks would require refilling. The DEIS notes that “the tanks are subject to compliance with the 2020 NYS Fire Code and the National Fire Protection 28 The Mattituck Fire Department possess only one 8500-gallon tanker in addition to water carried on other apparatus. 29 NYS Fire Code Section 503.2.1. Because of its length, the proposed road would require a greater width. 30 NYS Fire Code Section 511.2.2 “When driveways are in excess of 500 feet in length and do not exit to another fire apparatus access road or public street, a turn-around shall be provided suitable for use by fire apparatus.” In addition, Section D103 requires that dead-end fire apparatus access roads meet specific turnaround requirements. Roads between 501 and 750 feet long require the turnaround to be a “120-foot Hammerhead, 60-foot “Y” or 96-foot diameter cul-de-sac.” 31However, p.161 of the DEIS states that “In total, there would be four (4) LPG tanks for each building . . .” (emphasis added). Presumably this an error, but it is another example of the lack of care with which the DEIS has been prepared. 32 “Chapter 36 addresses the fire protection and prevention requirements for marinas. It was developed in response to the complications encountered by a number of fire departments responsible for the protection of marinas as well as fire loss history in marinas that lacked fire protection. Compliance with this chapter intends to establish safe practices . . .and provide fire fighters with safe operational areas and fire protection methods to extend hose lines in a safe manner” (2020 Fire Code of New York State, pp. xiii, 335). Page |Fire and Public Safety - 10 Rev7d Association 58 – Liquified Petroleum Gas Code, which sets forth requirements for installation, setbacks, and protection from vehicle impacts” (DEIS pp. vii-viii, 77). However, no consideration is given to the possibility the proposed protection would be adequate to protect against impact from an 85-ton travelift transporting yachts to and from the proposed storage buildings. According to the DEIS, yacht repair and maintenance activities would occur within the on-site buildings and/or at the existing dock. Those activities are planned to occur inside the proposed storage buildings and will include potential ignition sources. Given that stored yachts will be generally have full fuel tanks, a substantial fire risk will be created. The DEIS fails to take into account potential fire hazards associated the presence of lithium batteries on boats and yachts that will be stored in the proposed storage buildings. Larger new cruising yachts have been routinely fitted with lithium-ion boat batteries for the past few years. Sailing yacht manufacturer Arcona, for instance, says up to 90% of their larger yachts--the largest is 15.8 m [52 ft]--now leave the factory equipped with them. Lithium batteries are being installed on boats and yachts because it allows for cooking facilities to be changed from gas to electric induction cooking, and to change from a gas-powered tender to an electrically powered one. “However, there is so much power concentrated in a lithium boat battery that its chemistry is more lively than that of conventional batteries, with a potential thermal runaway situation able to create a self-sustaining fire that’s impossible to control.”33 According to 2022 information from ITA Yachts Canada, on boats within the 2 – 24m (6.5 – 78.7 ft) range, lithium technology has already replaced many combustion engines and lead-acid batteries for electrically powered boats. These batteries are also becoming more popular for recreational boats. Niche markets such as yachts, watercraft, and underwater vehicles will also eventually switch to lithium batteries.34 In July 2022, the American Boat & Yacht Council (ABYC) introduced ABYC Standard E-13, Lithium Ion Batteries. The May 23, 2023 issue of Soundings-Trade Only notes that “batteries are an evolving technology, we expect lithium-ion batteries to be a growing part of marine electrical systems.”35,36 33 https://www.yachtingworld.com/gear-reviews/lithium-boat-batteries-upgrade-electrics-128151 34 https://itayachtscanada.com/lithium-ion-batteries-in-the-boating-world/ 35 https://www.tradeonlytoday.com/post-type-feature/lithium-ion-batteries-are-coming-of- age?utm_campaign=Trade%20Only%20Today%20Newsletter&utm_medium=email&_hsmi=256488758&_hsenc=p2ANqtz- 8b-LXqeXFDO1QRzErruLGKI4E-jU- Twt195M1IpxTTH7CmS4q8Bt9QhSaSluzTHpc1kHtKHERC_eNGa2KEuthhing8jg&utm_content=256488758&utm_source=hs_e mail 36 At the April 15, 2023 meeting of the Southold-Peconic Civic Association, the Applicant was asked “Do any of these boats have those lithium-ion batteries?” The Applicant answered: “They do not currently.” This does not seem credible. Page |Fire and Public Safety - 11 Rev7d On February 21, 2023, a yacht insurance underwriter at the Beasley Group, expanded his comments on lithium battery fire hazards that appeared in the January 2023 issue of Boat International.37 The underwriter noted that “there has been a lot of speculation as to the cause of several [yacht] fires in the last couple of years, with the toys [e.g. jet skis, electric surfboards, electric underwater scooters] onboard being cited as the most probable cause. The Maltese Marine Safety Investigation Unit’s report into the fire on [one yacht] concluded that ‘that the Li-ion batteries on board were either the cause of the fire, and / or a contributing factor to the intensity and spread of the fire.’38 It does not appear that the Mattituck Fire Department or the Mattituck Fire Marshall considered the potential dangers associated with the presence of lithium-ion batteries on yachts stored in the proposed storage buildings when they conducted their reviews of the Project. The Southold community has recently expressed special concerns about the hazards of the lithium-ion battery fires associated with proposed BESS facilities, emphasizing the difficulties in extinguishing such fires. In February of 2023 a lithium-battery-powered Tesla was involved in an accident in East Marion. “First responders from Orient, East Marion and Southold arrived and, only after two hours of pouring large amounts of water on the burning vehicles, managed to bring the fire under control. . . [A}re our fire departments, staffed by volunteers, equipped to put out electric fires such as the one that claimed the lives of four people Friday night?”39 Lithium-ion batteries located on yachts in the proposed storage buildings not only present a possible ignition source, they would create special problems if involved in the fire department’s response to any fire within the proposed buildings. Impacts on Emergency Responses The DEIS has failed to address impacts associated with delays in emergency response times to locations located along the Project truck routes, especially to locations along West Mill and Cox Neck Roads. The more than 10,000 truck tips generated by the Project during the six-month-or-more-long excavation phase means that it is likely that at least one Project haul truck will be travelling on those roads at all times during that period. Research shows that traffic slows down fire trucks and EMS vehicles arriving at the scene of an emergency, and increases the average monetary damages from fires.40 37 https://www.boatinternational.com/yachts/news/yacht-fires-lithium-ion- batteries?j=347744&sfmc_sub=14182049&l=55_HTML&u=9542140&mid=500009995&jb=2006&utm_source=sfmc&utm_me dium=email&utm_campaign=Deep+Dive+newsletter+140123&utm_term=ARE+LITHIUM- ION+BATTERIES+TO+BLAME+FOR+RECENT+BOAT+BLAZES%3f+CTA&utm_id=347744&sfmc_id=14182049 38 https://www.beazley.com/en-001/articles/are-lithium-ion-batteries-blame-recent-boat-blazes 39 https://suffolktimes.timesreview.com/2023/02/editorial-the-electric-car-fire-that-cost-four-lives-is-a-warning/ 40 Brent, Daniel and Louis-Philippe Beland (2020), Traffic congestion, transportation policies, and the performance of first responders, Journal of Environmental Economics and Management 103:1-28 Page |Fire and Public Safety - 12 Rev7d COMMENT FIGURE F1 Toledo Beach Marina in Monroe County in southeastern Michigan (December, 2020) https://www.detroitnews.com/story/news/local/michigan/2020/12/04/monroe-county-boat-storage-facility- flames/3821844001/ https://www.fox2detroit.com/news/massive-fire-breaks-out-at-toledo-beach-marina-in-monroe-county Page |Fire and Public Safety - 13 Rev7d COMMENT FIGURE F2 Woodland Marina in St. Charles County, Missouri (October, 2020) https://www.ksdk.com/article/news/local/fire-woodland-marina-st-charles-county/63-5e9823c3-34ba-4345-9a24- f989b509ebb0 https://www.ksdk.com/article/news/local/fire-woodland-marina-st-charles-county/63-5e9823c3-34ba-4345-9a24- f989b509ebb0 Page |Fire and Public Safety - 14 Rev7d COMMENT FIGURE F3 South Park Marina in Seattle, Washington (September, 2021) https://komonews.com/news/local/fire-explodes-in-south-park-marina-workshop-sends-one-to-hospital The Boatyard at Christchurch near Urbanna, Virginia (February, 2023) https://chesapeakebaymagazine.com/fire-threatens-100-boats/ Page |Fire and Public Safety - 15 Rev7d COMMENT FIGURE F4 Marina Marbella (Spain) (January 2023) https://boattest.com/article/fire-storage-facility-destroys-80-boats Page |Fire and Public Safety - 16 Rev7d COMMENT FIGURE F5 Smoke rises from a fire at Safe Harbor Great Lakes Marina (Muskegon, Illinois) on March 6, 2023 https://www.woodtv.com/news/muskegon-county/crews-battle-fire-at-muskegon-boat-storage-building/ A marina fire on Seattle’s Portage Bay (Seattle Fire Department photo) (March 2023) Page |Fire and Public Safety - 17 Rev7d COMMENT FIGURE F6 Page |Fire and Public Safety - 18 Rev7d COMMENT FIGURE F7 Haul Road Plan (DEIS Appendix C) Aerial Overlay (DEIS Appendix C)