Loading...
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