HomeMy WebLinkAboutPlum Island ZoningPLANNING BOARD MEMBERS
DONALD J. WILCENSKI
Chair
WILLIAM J. CREIVIERS
PIERCE RAFFERTY
JAMES H. RICH III
MARTIN H. SIDOR
PLANNING BOARD OFFICE
TOWN OF SOUTHOLD
MEMORANDUM
MAILING ADDRESS:
P.O. Box 1179
Southold, NY 11971
OFFICE LOCATION:
Town Hall Annex
54375 State Route 25
(cot. Main Rd. & Youngs Ave.)
Southold, NY
Telephone: 631 765-1938
Fax: 631 765-3136
To~
From:
Date:
F~e:
Elizabeth A. Neville, Town Clerk
Donald J. Wilcenski, Chairman
April 29, 2013
Resolution Number 2013-"276" A Local Law in Relation to
Amendments to the Marine II District and Plum Island Zoning".
Thank you for the opportunity to provide comments on the proposed
amendments to the Town Code referenced above. The Planning Board has
prepared a planning study in support of the 0roposed zoning for Plum Island, see
attached
In addition to the island, the federal government also owns and is proposing to
sell its parcel in Orient Point that contains the ferry dock and related buildings
serving the Plum Island facility. This parcel is already zoned Marine II. It is
prudent for the Town Board to consider the potential uses for this parcel should it
become privately owned, and in particular its potential future use as a ferry dock.
The Planning Board supports the proposed amendments to the Marine II zoning
district for the following reasons:
A ferry service has the potential to be an intense land use with the impacts
spreading far from the ferry landing site in the form of traffic and its assooiated
no~se and pollution. Experience in Southold Town has made it clear that there
are minimum land area needs for a ferry service to ensure it is able to operate
safely and with the least impact to surrounding communities
Ferries capable of carrying vehicles must have adequate space to stage the
vehicles arriving to board the boats. A staging area that cannot accommodate all
the vehicles arriving at the site will result in traffic backing up into the public
streets, increasing the possibility of accidents. In addition, there must be
sufficient area to park cars for passengers boarding on foot, and especially for
passenger-only ferries.
Mass transit in Southold is limited at this time, thus passengers wishing to walk
on to a ferry would likely be arriving in a personal automobile. Insufficient parking
leads to unsafe conditions for the public through overcrowded parking lots or
haphazard parking along the public streets.
The parking and staging area requirements are directly correlated to the number,
size and type (passenger or vehicle) of ferries landing at the site. The parking
calculation for passenger-only ferries is based on the capacity of the passenger
ferry and the assumption that the majority of passengers will drive a car to the
ferry and need to park at the site for the duration of their trip. If the ferry can
accommodate 300 passengers, for example, presumably all 300 passengers
could, in the worst case scenario, drive a car to the site. It is more likely,
however, that there will be a combination of situations ranging from one person
per car to four or more. To account for this variation, it is reasonable to assume
that a calculation based on one car per two people would likely provide enough
parking for a full schedule of passenger ferries.
For the auto ferry's parking calculation, we assumed that about 10% of the
passengers would arrive by car, but would walk on and park their car instead of
driving on. Again, we divided that number by two to account for the variation in
numbers of people per car, assuming that allowing for two people per car would
average out.
The new minimum lot size ensures that there will be enough land area to safely
accommodate the necessary parking and staging areas.
CC:
Scott Russell, Town Supervisor
Members of the Town Board
Town Attorney
Plum Island Planning Study
Southold Planning Board
April 23, 2013
Plum Island consists of an 816~ acre island about 1.5 miles from the tip of Orient Point. There
are two other parcels associated with Plum Island and located in Orient Point, a 9.5 acre
waterfront parcel containing the ferry terminal for Plum Island, as well as another parcel (0.2
acres) near the tip of Orient Point (an in-holding in Suffolk County's Orient Point County Park
containing the electric power transfer station).
Plum Island has been entirely under the control of the federal government since 1901, with some
federal ownership on the island beginning as early as 1826. It was used by the government for
military purposes, first as an army base, and then as a military research facility. Later the island
became an animal disease research facility, which has operated on the island since 1954 under
the US Department of Agriculture and currently controlled by the US Department of Homeland
Security. The island has never been officially assigned a zoning district by the Town, largely
because land being used by the federal government for a public purpose is exempt from local
zoning laws. Now that the island is scheduled for sale into private ownership by an act of
Congress, it is prudent for the Town to assign a zoning designation.
Plum Island infrastructure & resources
Currently the island contains 554,109 square feet of building space in 47 buildings, including the
Plum Island Animal Disease Center (PIADC) and associated buildings, historic Fort Terry
buildings in various states of repair, the Plum Island Lighthouse, and various other buildings,
some currently in use, and some vacant. There is an electrical system connected by underwater
cable to the main power grid on Long Island, as well as an emergency generator designed to keep
the lab in operation should electricity from the mainland fail. The water system is supplied by
freshwater wells on the island, and includes a 200,000 gallon water tower and water distribution
system, with a sustainable capacity of about 150,000 to 200,000 gallons per day (gpd)2. There is
~ The area of Plum Island is reported differently in different sources. We chose to use the size calculated by the
Town of Southold's GIS system, with line-work based on the Suffolk County Tax Map. The true size of the island
can only be determined by a survey.
2 BMT Entech, Inc. 2002. CERCLA program report for Plum Island Animal Disease Center. Contract No. 43-3K15-
1-0006. Prepared for U.S. Department of Agriculture.
also a wastewater treatment plant with a capacity of 80,000 gpd (although it is currently
permitted at 60,000 gpd)3.
Though used intensively at times in the past, a majority of the island has been left to grow wild
over time as the activity has been concentrated on the small area in the immediate vicinity of the
active lab buildings and support infrastructure. This has allowed natural habitats to m-grow
undisturbed, and the island is host to diverse populations of flora and fauna, including one of the
highest concentrations of rare plants in New York State. Plum Gut, the adjacent waterway
between Orient Point and Plarn Island, is designated by the State as a Coastal Significant Fish
and Wildlife Habitat. It is also identified by Audubon as an Important Bird Area for the 187
species of birds observed there, including thirteen New York State Species of Greatest
Conservation Concern that use the island as a breeding ground. In addition, the island is located
in the Atlantic Flyway, providing essential resting and feeding habitat for migratory birds.
The flora is also diverse, and includes at least 25 different natural communities, including four
considered significant from a statewide perspective: maritime dunes, maritime beach, maritime
bluff, and marine rocky intertidal. The marine environment at the edge of and surrounding Plum
Island is home to the state's largest seal haul-out site, and productive eel-grass meadows, and has
been shown to be a highly productive area for marine fish species.4
Rationale for creating new zoning districts for Plum Island
The existing zoning districts, as well as the other islands in Southold which are currently zoned,
were examined for their applicability to Plum Island. Upon review of the issues related to the
future potential uses of the island should it become privately owned, it is clear that none of the
current Southold Town zoning districts are suitable. Plum Island is unique in size, location and
uses, and new zoning designations must be crafted to adequately address the situation. The
rationale for creating new zoning designations to regulate future uses for Plum Island is based on
a study of the limited infrastructure, both on the island and in the eastern portion of Southold
Town, the community character of the Town, including along the main route to the island
through East Marion and Orient, the economic value of the current use of the island, the value of
the natural resources supported by the island, and the historic resources.
A study of the other islands' characteristics and zoning demonstrated that Plum Island is unique
among them for many reasons. Plum Island, at 816 acres is the only island of its size in the
Town. The three other islands of considerable size are Fishers Island at 2,644 acres, Robins
Island at 455 acres and Great Gull Island at 17 acres. The other seven islands range in size from
one tenth of an acre to three acres.
3 Details about the infrastructure of Plum Island are from the Draft: Environmental Impact Statement dated July 13,
2012, for the Public Sale of Plum Island, New York.
4 Schlesinger, M.D., A.L. Feldman, and S.M. Young. 2012. Biodiversity and ecological potential of Plum Island,
New York. New York Natural Heritage Program, Albany, New York.
Plum Island is unique in its recent past and current uses, both on the mainland and among the
other islands in Southold. Although other Southold islands are/were owned by the federal
government and used for various purposes (military and aids to navigation), Plum Island is the
only island with a major research facility (PIADC). After some history as a military fort, Great
Gull Island has been owned since 1949 by the American Museum of Natural History for the
purpose of a bird sanctuary. Robins Island was and is privately owned, and is protected by a
perpetual conservation easement held by The Nature Conservancy, which limits future
development to only a few structures. It is zoned R-400 Residential Low-Density District (ten-
acre minimum lot size), Southold's most restrictive zoning district, and the conservation
easement restricts the uses even further. Both Great Gull and Robins Island have issues similar to
Plum Island with regard to potential development, however both are protected from development
making it unnecessary for the Town to take any further steps to mitigate the potential impacts of
any future development.
Fishers Island's recent past and current use is very different from that of Plum Island in that it
has been developed primarily with residences with a small commercial center. More important
than its land use is the island's geographic location as a reason for it being unsuitable as a
comparison for zoning of Plum Island. Because of its proximity to Connecticut, Fishers Island's
residents have direct nearby access to necessary services in New London, CT, while Plum
Island's nearest access to services is through Orient, NY. It is the difference between these two
access points that make the case for Plum Island's uniqueness as compared to Fishers Island.
New London is a small city through which a major interstate highway runs. The city contains the
basic services that the residents need, including doctors, a hospital, and retail stores. Orient, by
contrast, is a small hamlet served by a two-lane road. The nearest grocery store, hospital and
other services are over eight miles away in Greenport, and these are limited in size to that
typically found in a small village. Once on the mainland, the nearest interstate is over 31 miles
away (a 45 minute drive).
Plum Island is also unique with regard to the mainland of Southold Town by the fact that it is a
small island located at the end of the peninsula, with its main access through the most sparsely
developed part of the Town. There is no other land in Southold Town with a comparable
situation.
For all the reasons stated above, Plum Island was found to be a unique situation not
contemplated in current zoning districts. All the existing zoning districts allow one or more uses
that are contrary to the goals for Plum Island to continue to provide high quality employment
opportunities, while minimizing the impact to the Town's most rural hamlets, and preserving the
natural and historic resoumes on the island.
Rationale for the proposed zoning
Transportation and access
When considering zoning for Plum Island, we must take into account the community character
and quality of life along the transportation route to and from the island and through the
neighboring hamlets. The nearest hospital, grocery store and other services to Plum Island's ferry
landing in Orient Point are located in Greenport and farther west, requiring a trip of at least eight
miles along a two-lane road through the hamlets of Orient and East Marion. They are the most
rural hamlets in Southold Town. Both are primarily residential hamlets with low density. For
example, Orient Hamlet includes a total of 765 residential units at an overall density of about 5
acres per unit.
Both hamlets are already adversely affected by intense pulses of traffic caused by the Cross
Sound Ferry operation. Any additional traffic would degrade the community character and
quality of life by adding noise, decreasing air quality from added vehicle emissions, and
decreasing the safety of the main road.
The transportation route is also a New York State designated Bike Ronte, and a New York State
designated Scenic Corridor. Adding traffic to this corridor would decrease the safety for cyclists,
and erode the scenic qualities.
All the current zoning districts in Southold Town Code, should any be applied to Plum Island,
have the potential to create adverse traffic impacts by nature of their minimum lot size
requirements and lack of detail and sensitivity to the unique situation of Plum Island. The
proposed zoning districts are designed specifically for Plum Island's unique situation as it relates
to traffic and transportation and the nearby communities that would be most affected by it.
Plum Island as a source of high-quality employment
Plum Island has long been a source of high-paying technical jobs for S outhold Town residents.
Currently the lab employs 60 people who live in Southold Town. Retaining a research and/or an
educational facility that will provide a similar number of jobs is of great importance to the Town.
The Plum Island Research District is designed to encourage this type of development by clearly
stating that type of use is allowed, and also by limiting the ability for the island to be subdivided.
This subdivision limitation (accomplished by the large minimum lot size), will ensure the site of
the research facility remains large enough to contain and maintain its own infrastructure, as well
as containing enough land for future expansion, and to retain flexibility in future design.
Preservation of natural and cultural resources
Water
While Plum Island's aquifer could support some level of future additional development, it is in
the best interest of the overall Town to limit the use of this precious resource. Having a nearby
4
source of potable water could be critical to the Town's future infrastructure and ability to provide
clean water for its citizens, especially in Orient which is served by their own sole source aquifer.
Orient's sole source aquifer is already suffering from some pollution and salt water intrusion.
Therefore it is good planning to preserve Plum Island's aquifer as a future source of potable
water for the Town.
The Plum Island Conservation District will accomplish the goal of protecting Plum Island's
aquifer by limiting the amount of development that will occur over the majority of the island,
and also limiting the type of development to that which would use very little water, and
contribute little or no pollution to the groundwater. It has been well documented that intense
development can contribute significant an~ounts of pollution to the groundwater in the form of
excess nitrogen and other pollutants through stormwater ranoff, septic systems, and the
application of fertilizers, and pesticides.
Habitat & Wildlife
Plum Island contains flora and fauna unique to the state in their quality and should be preserved
with as little disturbance as possible (see above for more details). The proposed Plum Island
Conservation District will accomplish this goal by limiting the amount of human disturbance on
the island. The new zoning will provide additional protection to wetlands and surface waters,
both of which contain important sensitive wildlife habitats, by ensuring that all structures and
impervious surfaces be set back at least three hundred feet from surface waters and wetlands.
Historic Resoumes
Plum Island contains unique historic resources, including the Plum Island Lighthouse and Fort
Terry. In addition to any federal historical designations, the proposed zoning districts will
preserve and protect those historic resources by allowing uses of the island that are
complementary to historic preservation including educational facilities and museums.
Public Safety and Emergency Response.
Serving the public safety and emergency response needs of an island are challenges for small
Towns such as Southold. The rural Fire Districts have limited revenue and personnel. In the case
of Plum Island, the nearest Fire District is Orient. Presumably this Fire District would be called
upon to serve the emergency and fire needs of any development on Plum Island. Southold Town
Police would be the nearest law enforcement agency. The proposed Plum Island Research
District and Conservation District are designed to limit the potential strain on local first
responder and public safety resources by limiting the amount of development on the island and
concentrating the majority of potential development in one area. Currently the PIADC has their
own fire equipment, and some future similar use that fits in with the proposed zoning could
presumably do the same.
Navigation
The Plum Gut and other waters adjacent to Plum Island are important navigation channels. The
Cross Sound Ferry travels through Plum Gut, as well as other boat traffic on its way to CT,
Fishers Island, and Block Island. The proposed zoning districts address this by limiting the uses
to those that would not interfere with navigation.
Commercial & Recreational Fishing
Commercial and recreational fishing are important to Southold's economy. The waters
surrounding Plum Island are productive fisheries. The proposed zoning districts protect the
nearby fisheries by limiting future uses of the island to those that will not interfere with fisheries.
Conclusion
The federal government, and more particularly the U.S. General Services Administration, have
begun the process to sell Plum Island. While zoning was not necessary while the island was in
federal ownership (local zoning does not apply to the federal government), the Town of Southold
has found it prudent to zone the island in the event the island is sold into private hands. The
island has many resources important to the Town, is unique in many ways, and warrants its own
zoning designation to best regulate its future uses. The new zoning designations accomplish the
multiple goals for the island of protecting its exceptional natural resources, while also providing
for future economic opportunities. They also provide the necessary balance with the nearest
mainland connection at Orient Point, ensuring that the rural character of the hamlets of East
Marion and Orient is maintained.
6
TIMO}'HY H. BISHOP
COMMITTEE ON TRANSPORTATION
AND INFRASTRUCTURE
Hon. Scott Russell
Supervisor
Town of Southold
53095 Main Rd
P.O. Box 1179
Southold, NY 11971
May 1, 2013
Supe]wisor Russell:
On May 7th, the Town will hold a public hearing on the implementation of zoning districts on
Plum Island. I write today in strong support of the efforts the Town is undertaking. Preserving
the future of Plum Island, which is located in my district, is one of my top priorities in Congress.
The proposed zoning designations before you on May 7th represent a reasoned approach to both
economic development and environmental preservation. The proposed Plum Island Research
District will ensure the viability of this land for future economic development needs should the
current facility close. Plum Island represents tremendous potential and opportunity for future
scientific research and discovery.
Even more importantly, the Plum Island Conservation Dislrict will create and protect one of the
mom pristine and beautiful pmse~wes in the tri-state area. Plum Island is home to more than forty
rare, protected, and noteworthy vascular plants, and more than one-hundred bird species,
including the federally endangered roseate terns and federally threatened piping plovers. The
proposed conse~wation district would protect this valuable flora and fauna in perpetuity.
Regardless of the future of the research facility, protection of these valuable natural resources is
an important step forward.
I strongly favor the continued use of Plum Island as a federal research facility. As I continue to
work in Washington to prevent its closure, it is important that I have a strong partner in the Town
of Southold. The proposed zoning designations before you on May 7th are the fruits of a strong
partnership that will ensure the future of Plum Island is one of which we can all be proud.
Sincerely,
Tim Bishop
Member of Congress
Box 282 · ORIIiNT; NEW YORK 11957 ~ ORIENTAS,~OCllATI,ON.ORG
To: Southold Town Supervisor and Board
May 5, 2013
Ladies and Gentlemen,
On behalf of the Board and the Membership of the Orient Association, I wish to express our
support for the Proposed Zoning of Plum Island. As we have indicated at numerous community and
governmental meetings over the past year, the future use of Plum Island will have a very dramatic effect
on the quality of life for the residents and organizations located in Orient. It will also have a significant
impact on all of the people and businesses in the Town of Southold, the East End and even the rest of
Long Island.
The federal facility on Plum Island has been a complex neighbor. It plays an important role in
the safety of our country's agricultural interests, but poses challenges relating to safety and
environmental responsibility. The ecological importance of Plum Island deserves special attention and
very careful planning. Given the proposed sale by the General Services Administration (GSA), it is
imperative that the Town establish the zoning standards that will apply once the property is no longer
under federal control.
The Orient Association was particularly concerned to hear about some of the alternative usage
plans the GSA outlined in its draft Environmental Impact Statement. The possible creation of significant
numbers of residential units or extensive commercial use on the Island would have a seriously negative
effect on the community and place extensive burdens on the Town infrastructure. It would also
jeopardize an area that is now effectively a wonderful nature preserve, as well as an important historic
site. We believe that zoning to preserve the current level and type of usage would be in the best
interests of the residents and commercial interests of Orient and the Town as a whole.
The Town's proposed zoning plan is an excellent step in that direction. We support the two-
zone structure as planned. We also recognize the potential benefits of allowing some alternative energy
research and uses. However, the placement and type of that usage needs to be carefully planned to
avoid harming important plants and animals, and to support the use of the majority of the Island as a
nature preserve and educational resource. We understand that the Supervisor, Board and Staff of the
Planning Department are in the process of developing a comprehensive plan for alternative energy
usage throughout the Town. We also support this effort.
On behalf of the Association, I wish to thank the Supervisor, Board and Staff for the obvious
thou§htfulness and extensive efforts that have §one into this zonin§ proposal. We look forward to
workin§ with the Town to make this plan a reality.
Yours Sincerely,
Venetia Hands
President
North Fork Environmental Council
12700 Main Road
PO Box 799
Mattituck, NY 11952
Phone: 631.298.8880
Fax: 631.298.4649
Web: www. NFECl.org
3 May 2013
RECEIVED
Attn: Scott Russell, Supervisor
Southold Town Board
P.O. Box 1179
53095 Route 25
Southold, NY 11971
MAY 6 2013
Southold Town Clerk
RE: Proposed Zoning Plan, Plum Island
Dear Supervisor Russell and Southold Town Board Members.
The North Fork Environmental Council (NFEC) wishes to thank the Supervisor and the Town
Board for its foresight and its work in developing a zoning plan for Plum Island in advance of
any potential federal sale of the island. Such diligence will go a long ways towards ensuring
that any transfer of ownership of the island will be both on the terms of Southold Town and in
the best interests of the Town, its residents and the island's wildlife anc other natural
resources.
Therefore. the NFEC wishes to voice its support of the general zoning plan for Plum Island.
By identifying a Plum Island Research District and a Plum Island Conservation District, the
zoning plan at its minimum supports the "status quo." This is important as it defines and
protects the island's assets now and into the future, but it also acknowledges and protects the
quality of life so valued by the residents of Southold Town, especially those from Greenport to
Orient Point. By remowng the spectre of vast residential and commercial expansion on the
island, the zoning plan also greatly reduces the possibility of any associated expansion of
traffic on local North Fork roads,
But we must be aware that passage of this zoning plan is s~mply a first, important step in what
looks robe a long road ahead. And as we look ahead, the NFEC wants to work with the Town
and other parties to ensure that if the federal sale of the island proceeds, that future uses of
both the Research and Conservation Districts protect the island's unique ecosystems and do
not adversely impact the way of life on the North Fork, especially traffic along Route 25
between Greenport and Orient Point.
page 2
In considering the Town's proposed zoning, the NFEC supports the changes suggested by the
Preserve Plum Island Coalition. They include:
1) to move the majority of the coastline around the proposed Research District into the
Conservation District so that as much of the natural shoreline as possible will be
protected
2) move approximately 35 acres of untouched upland growth to the west of the main lab,
along the western shoreline bluffs, to the Conservation District
3) move approximately 2 acres of wetlands and ponds to the southeast of the lab into the
Conservation District
4) to remove the language which allows up to 20% of the Conservation District to be used
for solar arrays as such coverage would be detrimental to plant and animal life, even if
placed in an area where little or no clearance of vegetation is required
We believe that these relatively small changes will better serve to protect the unique
ecosystems and nature of Plum Island and thus protect the native plant and native and
visiting species of birds and animals with no impact on the use and value of the Research
District.
The NFEC looks forward to working with the Town and all interested parties in making sure
that the future of Plum Island serves the best interests of the Town and its residents, as well
as protects one of last remaining unprotected coastal conservation areas on Eastern Long
Island.
Sincerely,
president NFEC on behalf of the NFEC Board of Directors
CC;
Bob DeLuca, Group for the East End
Randy Parsons, The Nature Conservancy, Long Island Chapter
Charles Rothenberger, Connecticut Fund for the Environment
Leah Schmalz, Save the Sound
John Turner, Preserve Plum Island Coalition
Diana van Buren, North Fork Audubon Society
PLANNING BOARD MEMBERS
DONALD J. WILCENSKI
Chair
WILLIAM J. CREMERS
PIERCE RAFFERTY
JAMES H. RICH III
MARTIN H. SIDOR
PLANNING BOARD OFFICE
TOWN OF SOUTHOLD
MAILING ADDRESS:
P.O. Box 1179
Southold, NY 11971
OFFICE LOCATION:
Town Hall Annex
54375 State Route 25
(cot. Main Rd. & Youngs Ave.)
Southold, NY
Telephone: 631 765-1938
Fax: 631 765-3136
MEMORANDUM
To: Martin Finnegan, Town Attorney
From: Mark Terry, Principal Planner \~
Date: May6, 2013
Re:
SEQRA Review of the Plum Island Planning Study (2013) prepared by the Town of
Southold Planning Department
The proposed action of the preparation of the Plum Island Planning Study (2013) has been reviewed
to Chapter 130 Environmental Quality Review of the Southold Town Code and the New York State
Department of Environmental Conservation regulation 6NYCCRR Part 617 State Environmental
Quality Review and it is my determination that pursuant to Part 617.5C (21) provided below, the
action, as proposed is a Type II action and therefore not subject to SEQRA review.
(21) conducting concurrent environmental, engineering, economic, feasibility and other studies and
prefiminary planning and budgetary processes necessary to the formulation of a proposal for
action, provided those activities do not commit the agency to commence~ engage in or approve
such action.
Please contact me with any questions.
Cc: Heather Lanza, Director of Planning
) Audubon N E W YO R K
Supervimr Scott Russell
Member~ o£tho Town Bo~rd
Town Hall
53095 Main Rd
P.O. Box 1179
8outhold, NY 11971
MAY 7 2013
May 7, :2013 S0ulh0ld Town Chrk
RE: A Local Law in r*lation to the Marine Cfi) District and Plum Island Zoning
Dear Supervisor Russell and Meanbex~ of the Southold Town Board.
On bohalfofAudubou Now York and Audubon Conneetianr, the state program~ of the
National Audubon Society (Audubon), we thank you for thc opportunity to provide
tho following comments in support of the Tow~ of Southold's proposed "A Lo~l Mw
in relation to the Marine (II) District and Plum lsbnd Zoning." We commend the
Town for advancing this zl~ong proposal to protec~ the imporumt ~cologie~ fe~tures
of this incredibl~ mSoure~
Thc mission of Audubon is to conserve and ~ pan]va/ecosystems, focusing on '
birds, other wildlife, and their habitats for thc benefrt of humanity and thc earth, s
biulogieal diversity. To go}idc our conservation offom, Audubon has idanfified
Important Bird A-mas (fflAs) throughout thc mm and nation that provide crlti~l
habitat for birds based on a set of standardized sit~ criteria, in addition to identifying
IBAs, Audubon is also engaged in Im'g~ scale eeosyfft~ restorl~llon campaigns, and
has been a leading foreo working to secure d~sI~mtely needed fed~ funds to restore
the water quality and pro~em-t tho important habit, ts of Long lslnnd Sound.
With its mixture of rocky shoreline, t~md boaobo~, wetlands, and verlo~
shrub, graasland, and forc~t habitats, Plum Iskmd sumds out as a critically important
habitat and a key migratory bird s~topover site on Long Island Sound. In 1997 Plum
Island was recognized as part of the Orient Point to Plum Island IBA b~anse it
suppor~ large cone~mtrations of birds, including at-risk species like thc federally
thrca!~ned Piping Plover and endangered Roseate Term Since flint time we have
worked heav~y to ensure tim future protecedon oftJ~z amm~g r~ouroe, and remain
conoeamed over efforts by the Federvfl Government to sell thc Island without
restrictions to protect the ecological foatm'es that make it significant for blr&q and
other wildlife. In 2005, to further the proteol/on of this IBA, Audubon New York
COnvened a group of parm0rs to identify the greatest threats and conservation needs
for this eroa. The result of that effort was a Conservation Action Plan for th~ IBA that
was final-izod bt 2009, Th, plan ompha~qz~s the n~d to pro,eot tho c~ical natural
resources of Plum Island and one of tho priority trtralegica identified h2 the plan is to
increase our understanding of bird usage on Plum Island. Over the last $
Audubon has pertioipat~t in bird surveys to better dooument birds' usage of the site.
Through the~e surveys, over 190 bird species have beeo documented brooding or
fm'ai~g on phm~ Island and adjacent ecastal wat0rs, inoleding birds-of-prey,
~ombkd~, wading birds, waterfowl, ami songbird species. However, we lmow that
these limited surveys are only providing us wlth a Snal~hOt of the ecologloal value of
Plum Island and it is likely moro speoins depend on it than we are aware.
MA¥-7-2013 14:05 FROM: TO:16317GS1B2~
Notable species found on Plum Island include; brooding Piping Plovers (a federally threatened species),
nesting Osprey, an active Bank Swallow colony, several dozen Roseate Te. ms (a federally endangered
species), and saveml hundred Common Terns (aNYS threatened species), which feed in nearby
surrounding waters. The waters sun~unding Plum l'slund are rich in nutrients and ate vital feeding and
courting grounds for birds such aS terns and waterfowl. Plum Island also provides important stopover
habitat for many fall and spring migrant raptor, songbird ~d shorebird species. Finally, Common Eiders,
known to breed on nearby Fishers Island, may also breed on Plum Island; if so this would ba only the
second lo, atica in the State whore this sea duck breeds. All this highlights the biologic impermnee of'this
island and its unique cou~ibution to the ,~ology of the Long Island Sound Estuary. Efforts must be mad~
to eqsure these unique natural asmts am protected in perpetuity, and we appreciate the Town's auantian
re this.
Conserving this area long term not only makes good environmental sense, but ropre.~ents good fiscal
policy as well. Bird watching is the fastest growing OutdOOr recreation in New york and across the
nation, with an estimated 3.8 million bird and wildlife watchers ia New York contributing $4,2 billion to
the state aero,amy as estimated by the'US Fish and Wildlife Service. Ensuring the future protection et'
this critical area, that supports such a great d{versiiy of bird species, will help Communities surrounding
Plum Island continue to capitalize on this eeotnurism reveuue and provide altemafve options to market
the island as a tourist destination,
With this in mind, Audubon strongly supports the proposed zoning changes by the Town that delineates a
conservation district, inaluding the Piping Plover hOSting area and important wetland habitat, in order to
onhane~ this propose~I conseevatian district, whi¢~ do~ not cover all tho areas on the lslmld that ate
impoaant to birds, we ask that the Town ~onsider-a few additional items when planning £ot the future of
Plum bland.
We urge that any future dovelopmant in thc Reseaecfi District he required to maintain the same footprint
as the existing development, In addition, v~ ask that w~tlunds within the Research District be conserved
(e,g,, the cattail marsh) and that the areas surrounding the sewage i~aUnent pond cOntinue to be
maintained in a way that provides bird habitat. To bolster the prot~tions afforded in the Conservation
District, we recommend that future land uses he restricted tn only those which maintain or enhance the
habitat in thc Conservation District. Industrial use~, such as siting photovoltaie ~ells, would undermine
the habitat value of'the Conservation Distriat and should Im avoided, fn addition, it's impel'taut to Rote
that although the' historic Piping Plover nesting areas am contained within the conservation district, thee
are additional stretches of shoreline that have the potential to provide habitat to beaeJa n~t. lng birds and
should be protected.
Wa once again c, ommend the Town for advancing this zoning proposal that will help ensure the most
important habitat areas on Plum Lqland are protected from future land use changeS, We woutd be happy
to me~t with h'm Town tn discuss any of ~ese n~ommeedatioos further, and please don't hesitate to
contact dillian Liner at 60%254-2437 or j!in~q'~udubon.om.
Sincerely,
Jillian Liner
Audubon NY Dirgtor o~Bird Conservation
Patrick M. Core,ns
Audubon CT Dh~ctor o~Bitd Conservation
CITIZENS .ADVISORY COMMITTEE
OF THE LONG ISLAND SOUND STUDY
Website: htto://www, loneislandsoundstudv.net
A Partnership to Restore and Protect the Sound
CITIZENS ADVISORY
COMMITrEE
OFTHE
LONG ISLAND SOUND
STUDY
OFFICERS
Curt Johnson
Connecticut CAC Co-Chair
Nancy Seligson
New York CAC Co-Chair
Martin Garrall
Secretary
CACSUBCOMMITYEES:
Advocacy, Legislative & Policy
Tracking & Accountability
Local Government
LISS WORK GROUPS
Habitat Restoration
Stewardship
Nonpoint Source/Watersheds
Communications
Nutrients
CAC ADDRESS
Long island Sound Study
Citizens Advisory Committee
c/o EPA LIS Office
Stamford Government Center
888 Washington Blvd, Suite 6-5
Stamford, CT 06904
Office: 203 977-1541
Fax: 203 977-1546
The CAC meets quarterly on the
second Thursday of March, June,
Septetnbel; attd December at
alternating locations in New
York attd Connecticut. Meetings
are open to the public.
Supervisor Scott Russell
Members of the Town Board
Town Hall
53095 Main Rd
P.O. Box 1179
Southold, NY 11971
May 7, 2013
Dear Supervisor Russell and Members of the Southold Town Board:
On behalf of the Citizens Advisory Committee ("CAC") of the Long Island Sound
Study ("LISS"), we provide these comments in support of Southold's new proposed
zoning of Plum Island, New York. The CAC represents a broad array of citizen,
environmental and business organizations from New York and Connecticut that has
long advocated for the restoration of Long Island Sound. We provide guidance and
advice to the LISS Management Committee on LISS decision making on behalf of the
diverse stakeholders in the region. Our membership and meetings are open to all
interested parties in the region that use, or have concerns about, the Long Island Sound.
The CAC is the only body in the Long Island Sound Study that can adopt official
positions on issues and topics. CAC positions are adopted by a majority vote of
Citizens Advisory Committee members and are reflective of these stakeholders, but do
not necessarily reflect the opinion of the Long Island Sound Study or partners.
Attached is a list of our CAe membership.
Our interest in Plum Island is in assuring the conservation of undeveloped habitat on
the island as well as the safe re-use of the developed portions of the island. To that
end, we have provided comments to the General Services Administration ("GSA")
during its scoping and Draft Environmental Impact Statement public comment periods,
urging it require a mixed conservation/re-use sale. We assert that the language of the
Consolidated Security, Disaster Assistance, and Continuing Appropriations Act of
2009 requiring the sale of Plum Island provides GSA with the flexibility to effectuate
such a sale. However, thus far it appears that GSA is not moving forward with this
approach, leaving the task of protecting the natural areas and wildlife on Plum Island to
the Town of Southold. It is for this reason that we submit these comments in
enthusiastic support of the Town of Southold's new zoning proposal for the island.
The Long Island Sound Stady is a cooperative Federal/state Management Conference researching and addressing the priority environmental problems of the
Sound identified in the Comprehensive Conservation and Management Plan (CCMP). The Citizen 's Advisory Committee provides advice on public edacation
activities to the Management Committee in implementing the CCMP.
As you know, Plum Island boasts large populations of loons, scoters, buffieheads, piping plovers,
common, least and roseate terns and dozens of other species, along with wild orchids and other
rare plants. There are numerous federal programs and LISS related policies whose goals include
protecting critical areas like this one. The CAC has a strong interest in ensuring those programs
and policies are implemented. The Town's proposed zoning will help protect Plum Island's open
space for future public use and enjoyment, and essential plant and wildlife habitat, consistent
with the goals of Long Island Sound CCMP.
Plum Island and The Long Island Sound Stewardship Initiative
The Long Island Sound Stewardship Initiative was created by a Resolution of the Policy
Committee dated September 28, 2006 (attached). One month later it was codified by an act of
Congress (see the Long Island Sound Stewardship Act of 2006). It formally adopted the policy to
achieve the permanent protection, restoration, and conservation of various critical Long Island
Sound areas, and to increase public access to appropriate recreation and education. Through this
action thirty-three inaugural Stewardship Areas around Sound were formally endorsed.
Plum Island, together with Little Gull and Great Gull, form the Plum-Gulllslands complex,
which was identified for protection as an inaugural stewardship site by the Long Island Sound
Stewardship Initiative. This trifecta was found by scientists to possess "exemplary" ecological
value and is considered a crown jewel filled with unspoiled habitat types and federally
endangered species. (See attached Stewardship Site Atlas).
The LISS endorsement was formally signed by all the members of its Policy Committee
including the Region I and II Regional EPA Administrators and the Environmental
Commissioners of New York and Connecticut, and represents a strong and unequivocal
governmental interest in ensuring the conservation of the undeveloped portions of Plum Island.
We are pleased that the Town of Southold's proposed zoning for the island recognizes the need
to protect this ecologically valuable site.
Plum Island and The Comprehensive Conservation and Management Plan
In addition to the Long Island Sound Stewardship Initiative, the CCMP--the Long Island Sound
Management Plan adopted by federal and state governments to restore its waters and habitats--
itself highlights the need to protect areas like Plum Island.~
The Management and Conservation of Living Resources and Their Habitats section on
"Managing Habitats" states "The destruction of coastal habitats has had a major impact on the
diversity and abundance of plants and animals in the Sound." And that "Long Island Sound is an
area that has undergone rapid industrialization and rapid diminution of areas remaining in their natural
condition. It is desirable to identify areas of land and water of outstanding or exemplary scientific,
See http://longislandsoundstudy.net/wp-content/uploads/2011/lO/management~lan.pdf
pp.104-107; pp.126; and pp.132-133.
The Long Island Sound Study is a cooperative Federal/state Management Conference researching and addressing the priority
environmentalproblems of the Sound identified in the Comprehensive Conservation and Management Platt (CCMP). The
Citizen's Advisory Committee provides advice on public edacation activities to the Management Committee in implementiag the
CCMP.
educational, or biological value to reflect the regional differentiation and variety of ecosystems and
address all the significant natural habitats found in Long Island Sound. These sites would be combined to
form a Long Island Sound Reserve System. Many of these sites are already in public ownership or held
for conservation purposes. Therefore, acquisition priorities should emphasize sites not currently held for
conservation purposes." This section resulted in the creation of the above described Stewardship
Initiative, of which Plum Island is included. It is clear, that given the current potential for those
significant habitats to change from federal to private hands, that the island is considered a priority area for
conservation. This is bolstered from the action item list in this same section of the CCMP under "What
Needs to Be Done": "...Conservation of natural resources and open space is vital to the protection of the
Sound."
There are two other sections of the CCMP that align with Southold's vision to zone portions of
Plum Island as conservation areas. First, the Conserve and Enhance Natural Resources and
Open Spaces section outlines "Preserv[ing] open space and natural areas" as a key objective.
Second, the Land Use and Development provision states that "preserving environmentally
sensitive habitats, such as forests, and maintaining open space minimizes runoff pollution and
provides wildlife habitat." It further outlines that "existing federal, state, and local open space
or other land acquisition programs should support Long Island Sound water quality and habitat
objectives."
Plum Island and the U.S. Fish and Wildlife Service
The Town's move to preserve Plum Island also meshes with the United States Fish and Wildlife
Service ("USFWS") assessment. It identified a host of important habitat functions and federal
designations recognizing the ecological value of Plum Island and its adjacent waters.
Specifically, the USFWS recognized the ecological importance of the site that is part of the
Orient Point - Islands Complex of regionally significant fish and wildlife habitat (USFWS
1991)2 and a part of the USFWS Coastal Barrier Resource system, unit numbers NY-24 and NY-
25.
The value of the ecologically interconnected chain of islands in this area of Long Island Sound
has been recognized as providing unique opportunities for collaborative natural resource
management. As the USFWS presented to the GSA: the Long Island National Wildlife Refuge
Complex was founded in order to "conserve, manage, and where appropriate, restore wildlife and
plant species and their habitat for the benefit of present and future Americans.''3 In that same
letter, the USFWS noted their ongoing efforts to encourage Least and Roseate Tern nesting at the
recently acquired Gardiner's Point Island, referring to the island's proximate location to both
Plum and Gardiners Island and underscoring the tremendous wildlife and habitat potential of all
three islands.4 While the CAC believes the best way to conserve the island is for it to remain in
federal hands and to be incorporated into the USFWS Refuge system, we applaud Southold's
effort to ensure that even if the federal government moves forward with a public sale, the island
will be protected.
2 The USFWS highlighted that this Habitat Complex "underscores its high value for nesting colonies of piping
plover and least tern.., and colonial wading bird rookeries of black-crowned night heron.., and great egret."
USFWS Letter to GSA dated June 16, 2010.
3 USFWS Letter to GSA dated June 16, 2010
4 USFWS Letter to GSA dated June 16, 2010, pp.4-5
The Long Island Sound Study is a cooperative Federal/state Management Conference researching and addressing the priority
envir~nmentalpr~blems~ftheS~undidenti~edintheC~mprehensiveC~nservati~nandManagementPlan(CCMP). The
Citizen's Advisory Committee provides advice on public education activities to the Management Committee in implementing the
CCMP.
Plum Island and SoundVision
In 2011, the CAC recognized that there had been significant progress in the implementation of
the 1994 CCMP but noted that the region's heritage--which is centered on appreciating beautiful
views of the coast, enjoying our beaches, sailing and kayaking, clamming and fishing--remained
threatened. In an effort to protect the watershed landscape, not only for the birds, fish and other
animals that depend on special habitats, but also to re-build the economically vibrant legacy of
shoreline industries and neighborhoods the CAC, advised by the best Long Island Sound
scientists and experts, developed a practical and attainable Action Plan to heal and restore the
Sound.
The SoundVision Plan identifies four priority areas, one of which is "Creating Safe and Thriving
Places for All Sound Creatures." A key Action Step for this priority area is to "Improve
management and acquisition of key coastal and island wildlife refuges" by "Protect[ing] Plum
Island from unfettered development and encourage[ing] the US Fish and Wildlife Service to add
it to its network of preserved habitats? Again, Southold's effort to create "Plum Island
Conservation District" demonstrates the town's commitment to do what it can to help protect the
island from rampant development.
Plum Island and LISS Action Agenda
In addition to the CAC's SoundVision Action Plan, the LISS Management Committee adopted
its 2011-2013 Action Agenda for Long Island Sound. Similar to SoundVision, it contains a goal
to "Restore and maintain Long Island Sound in a healthy, productive and resilient condition so
that it can provide the services humans want and need." One of the top priorities is to "Protect
820 acres of coastal habitat" by 2013.6 Plum Island is one such coastal habitat, as identified by
the Stewardship Initiative.
According to this Agenda
Healthy coastal habitats provide critical feeding, breeding, and migratory stopover sites
for the diverse abundance of plants and animals that use LIS. In 1996, the LISS
established the Habitat Restoration Initiative, and in 1998 established a goal of restoring
and protecting 12 priority LIS habitat types around the Sound. The Initiative uses
partnerships to accomplish the restoration objectives and leverage limited state, local, and
federal funds. In addition, the LISS established the Stewardship Initiative in 2006 to
conserve natural areas, increase access to the Sound, protect important habitats, and plan
for multiple uses. The Stewardship Initiative identified places with significant ecological
or recreational value throughout the Sound and developed a strategy to protect and
enhance these special places. In 2006, the LISS adopted thirty-three inaugural
Stewardship Areas that represent lands of outstanding or exemplary scientific,
See http://wwxv.lisoundvision.or~/pdf/Sound-Vision-Final.odf pp.14-16.
See http://~ngis~ands~undstudv.net/wp--c~ntent/up~ads/2~/~9/Fina~-L~SS-Acti~n-A~enda 2011 20131-1.pdf
pp.8-10.
Tbe Long Island Sound Study is a cooperative Federal/state Management Conference researching and addressing the priority
environmental problems of the Sound identified in the Comprehensive Conservation and Management Plan (CCMP). The
Citizen's Advisory Committee provides advice on public education activities to the Management Committee itt implementing the
CCMP.
recreational, educational, or biological value for protection, management. These areas
provide opportunities around the Sound to enhance the public's awareness and personal
connection with our special estuary.
By providing zoning requirements that protect habitats and provide for limited public access for
enjoyment of the island and potentially learning opportunities, Southold is once again doing its
part to ensure the goals and policies established for Long Island Sound are met.
In addition to offering our support on your zoning plan for the island, we extend a resource as
well. One of our partner Long Island Sound Study committees, The Stewardship Work Group,
has provided GSA with information on the rare wildlife and habitats found on Plum Island.
They offer their wide variety of resources and expertise to the Town Board should you need
additional factual information moving forward. They can be reached by email at
David. Kozak(~ct.gov (David Kozak, CT DEEP) and Basso. Georgia(&epamail.epa.gov (Georgia
Basso, U.S. Environmental Protection Agency and U.S. Fish and Wildlife Service).
We are supportive of Southold's plan, and encourage it to make a couple of minor modifications
and explain one apparent discrepancy, all of which are identified and described in more detail by
the Preserve Plum Island Coalition. First we recommend that the 35 acres surrounding Plum
Island lighthouse that also runs along the shoreline in each direction, along the edge of the dock
facility, along the edge of the main laboratory facility, and to the paved road be included in the
Plum Island Conservation District ("PIC"), not the Plum Island Reseamh ("PIR") District.
Second, we do not believe solar energy installations should be permitted within the PIC, unless
they are incorporated into/on-top of existing structures. Lastly, we note that the combined totals
of the PIR and PIC districts fall short of the island's actual size, is there a particular reason that
the acreages differ?
We sincerely appreciate the Town's willingness to protect and preserve this rare jewel and
applaud your effort to do what the federal government has not yet done: Save Plum Island.
Yours truly,
Nancy Seligson
New York CAC Co-Chair
Nancv18b(&aol.com
914 834 4953
ciohnso'a~/)cfen .ore -
203 787 0646/ext. 111
The Long Island Sound Study is a cooperative Federallstate Management Conference researching and addressing the priority
environmental problems of the Sound identified in the Comprehotsive Conservation and Management Plan (CCMP). The
Citizen's Advisory Committee provides advice on public education activities to the Management Committee in implementing the
CCMP.
RESOLUTION
OF THE
LONG ISLAND SOUND STUDY
POLICY COMMITTEE
CONCERNING
LONG ISLAND SOUND STEWARDSHIP
W hereas, Long Island Sound is recognized as a National treasure of great
cultural, environmental, ecological, and economic importance; and
Whereas, as a highly urbanized estuary, the Long Island Sound ecosystem is
under stress from both sustained human uses as well as emerging global
and regional environmental conditions; and
Whereas, the Comprehensive Conservation and Management Plan for Long
Island Sound calls for creation of a system to identify areas of land and
water of outstanding or exemplary scientific, educational, or biological
value for protection, management or acquisition; and
Wcereas, at the direction of the Policy Committee under the Long Island
ound 2003 Agreement, the Long Island Sound Study Management
ommittee has worked to identify key areas in the Long Island Sound
watershed that reflect regional differentiation, a variety of ecosystents and
significant natural habitats found in the Sound, and public access to this
magnificent body of water;
NOW TIIEREFORE BE riv RESOLVFJ) THAT, the Long Island Sound Study
Policy Committee, assembled in Rye, New York on September 28, 2006,
hereby endomes the work of the Management Committee in recommending
thirty-three inaugural Stewardship areas, and hereby adopts them as part of the
Long Island Sound Stewardship Initiative.
Rob~m W. Varney, Regional
US Environmental Prot~tion Agency
New England Region
Alan-J; ~teinbe~t, Regional Administrato~
US Environmental Protection Agency
Region Il
Environmental Protection
Denise M. Sheehan, Ctnnmissioncr
New York State Department of
Environmental Conservation
The Long Island Sound Study is a cooperative Federal/state Management Conference researching and addressing the priority
environmental problems of the Sound identified in the Comprehensive Conservation and Management Plan (CCMP). The
Citizen's Advisory Committee provides advice on public education activities to the Management Committee in implementing the
CCMP.
Stewardship of Plum Island
Plum Island and the adjacent Great Gull and Little Gull Islands have been recognized by the Long
Island Sound Study (LISS) as a Stewardship Area of ecological value.
LISS is a bi-state partnership of federal and state agencies, user groups, concerned organizations,
and individuals dedicated to restoring and protecting the Sound. LISS's Stewardship Initiative was
created to protect the diverse plants and animals that make their home in or near the estuary. The
Stewardship Initiative also seeks to ensure that the Sound's citizens will continue to have access to
the natural seascapes that make the area an enjoyable place to live. In 2006, the Stewardship
Initiative work group identified 33 inaugural areas around the Sound with significant biological,
scientific, or recreational value.
Read more at www. longislandsoundstudy.net/stewardship.
Plum & Gull Islands Southold, New York
Stewardship Sites: Plum Island, Little Gull Island, and Great Gull Island
Ecological significance:
· Exemplary colonial waterbird habitat, including sites that are of national--if not international--significance
· Small rocky islets dominated by grassy and herbaceous vegetation
· Colonized by over 6,000 pairs of common terns and approximately 1,200 pairs of roseate terns, making this the
second largest breeding population of this endangered species in North America
· Identified by the USFWS as a Significant Coastal Habitat
Long Island Sound
Stewardship Initiative
Inaugural Stewardship Areas
~/~ISOUND
~STUDY
Nancy Seligson
Town of Mamaroneck, Citizen's Advisory Committee New York Co-chair
Long Island Sound Study
Citizens Advisory Committee
Curt Johnson (Leah Schmalz)
CT Fund for the Environment/Save the Sound, Citizen's Advisory Committee Connecticut Co-chair
Martin Gan'ell
Aldephi University, Citizen's Advisory Committee Secretary
Paul DeOrsay
Friends of the Bay
Allen Berrien (Walter Raleigh)
Milford Harbor Marina
Sandy Breslin (Tom Baptist)
Audubon Center at Bent of the River
Sean Mahar
Audubon New York
Abbie Coderre
Saybrook Point Inn & Spa
Chantal Collier (Nathan Fmhling)
Director, LIS Program
Tanya Court
The Business Council of Fairfield County
Carol DiPaolo
Coalition to Save Hempstead Harbor
Kay Eisenman
Westchester County Dept. of Planning
William Evanzia
J. B. E. Associates
Daniel Fucci
Nassau County Public Works Dept
Fred Grimsey
Save the River/Save the Hills
Rachel Gruzen (Elizabeth DeCelles)
Great Ecology and Environments
Jennifer Herring (Jamie Alonzo)
The Maritime Aquarium/Norwalk
Jim Hutchinson
New York Sportfishing Federation
W/~SOUND I
Sarah Kd'use
PSEG Power Connecticut LLC
Long Island Sound Study
Citizens Advisory Committee
Cesare Manfredi (Warren Ross)
Federated Conserv. of Westchester County
John McDonald (Bud Raleigh)
Darien Advisory Comm./Coastal Waters
Donald McKay
Coalition/Protection of Ll Groundwater
David Miller
Ecology and Environment, lnc
Jim Moriarty
Town of Oyster Bay
Maureen Dolan Murphy (Adrienne Esposito)
Citizens Campaign for the Environment
Daniel Natchez
Daniel S. Natchez & Assoc.
Joel Rinebold
Joel Rinebold LLC
Dianne Selditch
SoundWaters, Inc.
Daniel Snyder
Shoreline Shellfish, LLC
Eric Swenson
I-Iempstead Harbor Protection Committee
Tim Visel
The Sound School
Howard Weiss
Project Oceanology
Grant Westerson
CT Marine Trades Association
Jennifer Wilson-Pines
Manhasset Bay Protection Comm.
Paul Winters
Regional Plan Association
Joel Ziev
Town of North Hempstead
2
15:05 ~1~5~-~0~ S C PL~ ~PT ~A~£ 02
Steven Bellone
Dep~rtment of
Economic Development und Planning
Joanne Minierl
Deputy County Executive and Commissioner
Division of Planning
nnd Environment
May 15, 2013
RECEIVED
Town of Southold
P,O. Box l 179
Southold, N.Y. 11935
ACm: Elizabeth Neville, Town Clerk
MAY ] 6 20]3
Southold Town Clerk
Applicant: To~ of Southold
Zoning Action: Local Law, "Marine (ii) District and Plum Island
Zoning"
Resolutlon No,: 2013-276
Dear Ms. Neville:
Staffmade aR error h the revi~-,v oft. he above referenced application. This r~ferred application has been
plac~d on the Agenda for the ~'une 5, 2013 Suffolk County Planning Commission Meeting. Please be
advised that the local determination decision letter, that was sent to the Town of Southold on April 16,
2013, has been rescinded. Additional correspoRdence will be fotthceming.
Director of planning
Chief Planner
APF:cd
Oysterponds Rod.and Gun Club, Inc'
Dear Honorable Supervisor Russell and Town l~ard Members, June 10, 2013
/
The Oysterponds Rod and Gun Club is one of the oldest associations of its kind, founded in 1903
when local wildlife was threatened with extinction due to over-harvesting. Our b'~h paralleled
the great conservation movements of the time, leading to the formation of the New York State
Conservation Department, the foremrmer of our modem New York State Department of
Environmental Conservation (NYSDEC). We lea~e and patrol lands in Orient adjacent to the
NYSDEC Tidal wetlands, in one of the last places on Long Island where conservation and
preservation of our land and water resources continues to provide a broad range of exceptionally
high quality environmental experiences for the public and our members.
Our long history of supporting conservation activities in the Orient area includes: providing early
support for the purchase of Orient Point by Suffolk County, maintaining wildlife sanctuaries
patrolled by our deputized wardens; replacing invasive species with wildlife plantings, providing
emergency feed for wildlife ia harsh winters and constructing numerous nest boxes and Osprey
platforms. The Club has an annual fishing contest, open to all, in which the waters surrounding
Plum Island play a prominent role.
Our club would like to go on record as cautiously supporting the proposed zoning of Plum Island.
We are, however, concerned that any zoning of the island provide universal fishing access to the
entire shoreline of the island and would cantion the Town Board that limiting the proposed
preserve areas to "passive recreation", if that means "no hunting", may not be in the best interests
of preservation and conservation. Plum Island's current ecological status is a direct consequence
of an animal extermination policy of the USDA, which has been in effect for over half a eentttry.
We are concerned that the island, which will undoubtedly repopulate and overpopulate with deer,
may become over-browsed, killing vegetation and reducing song bird nest sites. When
overpopulated with deer, it may require expenditures of public monies for government sharp-
shooters to control them. The killing of birds by Plum Island employees stopped some time ago,
creating one of the first havens for Canada Geese, which now plague the mainland. Given the
history of goose and deer problems in Southold Town, we would suggest that any determination
concerning restricting legal wildlife harvest under "passive recreation" controls be carefully
vetted by the wildlife and habitat professionals of the New York State Department of
Environmental Conservation before enactment and after we know whether DHS/USDA/GSA
may create an overarehing wildlife control program in the Final Environmental Impact
Statement, covenanted to the island's sale.
The Oysterponds rod and Gun Club would like to thank the Town Board for this opportunity for
input on the proposed zoning of Plnm Island.
Robert W. Sorenson, Jr., Pres.
Orient, lXTY
CC: Town Clerk, Elizabeth Neville; Town Planner, Heather Lanza
RECEIVED
JUN 1 2 2013
Southold Town Clerk