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HomeMy WebLinkAboutWater supply comments Rev2a FINAL - jkPage | Water Supply-1 WATER SUPPLY The “post-development benefits of the water supply main” have been indirectly overstated and the DEIS is misleading as to the extent of those benefits. The DEIS scope calls for the DEIS to evaluate “the extension of the public water supply main to the subject property . . . based upon consultations with the SCWA [Suffolk County Water Authority].” The Applicant contacted the SCWA “regarding the availability of public water service.” The SCWA replied that “the nearest water main is at Naugles Dr. In order to service your property, a water main extension of approximately 765 feet would be required” (DEIS Appendix K). No copy of the Applicant’s request to the SCWA is included. It is therefore unclear whether the SCWA’s response was meant to apply only to the existing marina facilities, or the Applicant’s property after the Project is constructed. Suffolk County Dept. of Health Services (SCDHS) Consultation Project approval is subject to permits and approvals from the Suffolk County Department of Health Services (SCDHS) (water supply and wastewater disposal) (DEIS p. xliv). According to the DEIS, an “application for Article 6 Permit was initially filed with the SCDHS in 2018 and consultations with the SCDHS are ongoing” (p.76). The DEIS text (p.75) mentions the December 27, 2018 Notice of Incomplete Application from the SCDHS, but not he superseding notices dated January 25,2021, August 10, 2021, January 26, 2022, February 23, 2022, and June 16, 2022 notices included in DEIS Appendix J. According to January 2021 notice, the SCDHS requested the Applicant to “[S]ubmit a Water Design Report to demonstrate that the site will have adequate pressure under all anticipated flow conditions (i.e. the residence given the ~40’ elevation change & boat storage #2) at the furthest connection. Identify on plan the location of all water valves, thrust blocks, and hydrant & specify the diameter of the main. Submit hydrant flow data with and without fire flow as part of this report. In addition, include the number of fixture units in the report, a riser diagram, & calculations for the needed fire flow using the ISO method.” None of this information was included in the original December 21, 2021 DEIS. However, a water design report, last revised September 6, 2022 is included in the revised DEIS. The revised DEIS still indicates only that “consultations with the SCDHS are ongoing” (DEIS p. vi, 76). No mention is made of the deficiencies noted in the SCDHS’ last review dated June 16, 2022. Page | Water Supply-2 The Project has also requested a variance vary the design flow factor for the storage buildings from SCDHS (DEIS pp. vi, 76; DEIS Appendix J).1 Suffolk County Water Authority Consultation The DEIS exaggerates the potential benefits of the water main extension proposed as part of the Project. The DEIS scope calls for the DEIS to identify and evaluate the “post-development benefits of the water supply main.” As noted above, the DEIS states that the “proposed action includes an extension of the SCWA water main from Naugles Drive by 765± feet to allow for the site to be served by the public water supply system. The extension of the public water main would allow for existing landowners to connect to the public supply system, by request to the SCWA. Information was obtained from SCWA noting those properties that could connect, if requested, and is included in Appendix K” (p.16). The last two of these statements are incorrect, misleading and inconsistent with information provided in DEIS Section 2.2.1, DEIS Table 12, DEIS Appendix A Figure 14, and DEIS Appendix K. Section 2.2.1 of the DEIS states: “According to the SCWA, in correspondence dated October 21, 2020 (see Appendix K), of the 40 nearby properties, two (2) are connected to public water and seven (7) have public water connection available. The remaining 31 properties were indicated as not being connected to public water and a connection ability could only be confirmed with an application to the SCWA” (emphasis added) (p. 46). In other words, connection ability has not been determined, and it is unknown whether the water main extension proposed as part of the Project would result in the ability of additional properties to connect to water service. What the DEIS text and DEIS Table 12 fail to call out is that the 31 presently unconnected properties include several on the east side of Mattituck Inlet, several properties on North Drive, vacant properties, agricultural lands, the Mill Creek Preserve, and properties as distant as 1700 feet from the nearest point on the proposed water line. 2 Clearly none of these would be able to, or reasonably desire to, connect to public water as a result of the installation of the proposed water line. Two properties that will be able to connect as a result of the new water line are the Old Mill Restaurant and a residential property owned by the Applicant. Table 12 identifies properties only by their tax lot numbers. Had street 1 The Applicant’s Project Fact Sheet, posted on his Project website since February 2022, continues to state that “NO VARIANACES ARE REQUESTED.” 2 This is illustrated in Figure 14 in DEIS Appendix A. However, that figure is somewhat misleading in that it shows properties within 500 feet of the marina tax parcels, not the Project area or the area within 500 feet of the proposed water line. Figure 14 also incorrectly depicts properties that the SCWA identified having an “unknown” availability to public water, as “Lot with Private Wells, Available to connect to SCWA Public Water.” Information in the inset table is correct. Page | Water Supply-3 addresses been included, the fact that all but two of the 31 properties would be unable to connect to the proposed water line would be obvious to a reader of the DEIS. The statement in the DEIS that “[A]s confirmed by SCWA, the extension of the public water main would also allow for existing landowners to connect to the public supply system, by request to the SCWA” (p.73), is not accurate. SCWA has made no such confirmation. The SCWA’s October 20, 2017 correspondence (DEIS Appendix K) indicates only that the proposed water main extension from Naugles Drive to the marina property would be necessary to service the marina. The attached table only indicates which of the 41 tax parcels listed have public water available and which are connected to public water. No evaluation of the realistic ability of unserved parcels to connect once the Applicant completes the water extension is included. The Proposed Water Line is Not Part of the Project. According to statements made by the Applicant 3, and confirmed in conversations with the SCWA on April 19, he has already contracted with the Suffolk County Water Authority to install the line. SWCA has advised that construction is scheduled for May 2023. Any public benefit resulting from the installation of the water line is not a benefit that can be attributed to the Project. Water Use The DEIS states that the Project, when in operation, “will require, 220 gallons per year for each boat that requires service prior to/after storage (170± gallons for spring washing and 50± gallons for fall power washing)” (DEIS p. 170, 175, 311)4. This means that at full capacity, with 88 yachts in storage, water usage will increase by at least 19,380 gallons per year, in addition to an increase of 18± gpd for potable water. The DEIS notes that potable water currently used for boat washing operations comes from wells, and that replacing well water with water from the SCWA would decrease local withdrawal. This is correct. However, what the DEIS fails no note is that the SCWA water line will be available independently of the Project (see above), and SCWA-water will be available for boat washing purposes even if the Project is not approved. This means that the claim that the Project will reduce local withdrawal is incorrect. In fact, the Project will result an increase in total water usage of more than 20,000 gallons annually. 3 In a statement made at the April 15, 2023 meeting of the Southold-Peconic Civic Association, Mr. Strong stated “we have already contracted with the Suffolk County Water Authority to extend the main public water main from Naugles Drive, which isn’t too terribly far away, but we’re paying to have that brought in to this property—it’s a 12-inch main. We’ve been working on that for three years. I think its scheduled to begin sometime in May.” 4 Wash activities are also capable of introducing pollutants to surface- and groundwater, leading to serious environmental degradation.