CRGD weighs in on Dover Town Board’s Completeness Review on the Preliminary Draft Environmental Impact Statement
February 22, 2009
CRGD President Carolyn Handler recently added to the Dover Town Board’s discussion and debate of the completeness of the Dover Knolls DEIS. The Coalition notes that the Town Board was under no legal obligation to make the document available to the public and appreciates the openness with which Supervisor Courtien has chosen to conduct the review.
In a letter dated February 11th, addressed to Supervisor Courtien and members of the Town Board, Handler begins with acknowledging this process:
“CRGD recognizes that the formal public comment period for the DEIS will not begin until the Town Board determines the DEIS to be substantively complete and thereafter schedules a public hearing to receive comments. We also note that the Town Board made the DEIS available to the public on the Town’s website not long after it was filed by the Applicant on Christmas Eve, having rightly concluded that given the complexity and size of the Proposed Project, the public should begin the process of familiarizing itself with the contents of the DEIS at the earliest juncture– even though, as we recognize, the DEIS is currently undergoing revision as a result of the Town Board’s own completeness review as lead agency.”
Taking advantage of the the opportunity provided by Supervisor Courtien’s decision to make the “preliminary” DEIS available to the public, The Coalition analyzed the document and found several serious omissions which we chose to share with the Town Board in the hopes they would be addressed and incorporated into the “final” DEIS, for public comment.
As Handler lays out omissions from the DEIS, she observed first and foremost, “No well documentation or aquifer study has been supplied to show there will be enough water for the Proposed Project. This is critical water supply information which was listed in the Final Scoping Document as an element of the DEIS and its absence cannot be excused. Delaying submission of the pump test data until the final EIS will come far too late in the SEQRA process. Substantial concerns have been raised by members of the public repeatedly at pubic meetings for several years regarding the issue of ground water quality and quantity. This is of particular importance because there is only one source of drinking water in the valley bottom. Degradation and/or overtaxing of the aquifer will have a negative environmental impact under SEQRA.”
Although the Applicant stated it would be filing the water study as part of the Final Environmental Impact Statement, CRGD noted that would be impermissible under SEQRA.
Handler goes on to discuss additional omissions in the DEIS which should have been addressed as indicated in the Final Scoping Document. On the economic front, “the DEIS does not address the need for additional facilities due to increased [school] enrollment. As the projected increase in school enrollment is likely to push the existing school facilities over current capacity, this appears to be a significant omission in the DEIS.” Handler then lists specifics, including the observation that “the DEIS makes no attempt to discuss mitigation measures or the costs of those measures, required for over-capacity schools” and requests the submission of expected fiscal impacts of Phase II and at full build out.
CRGD respectfully requested “that the Town Board not accept the Applicant’s Draft Environmental Impact Statement (DEIS) as complete.” CRGD acknowledges and thanks our experts and counsel in the preparation of this submission.
– Please go to CRGD Letter to the Dover Town Board February 11, 209
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