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-Croton Watershed Clean Water Coalition, Inc.
Federated
Conservationists of Westchester County
Natural Resources Defense Council
New York Public Interest Research Group, Inc.
Riverkeeper, Inc.
Sierra Club - Lower Hudson Group
October 12, 2005
Via First Class Mail and Facsimile
(518) 402-9016
Denise M. Sheehan
Acting Commissioner
NYS Department of Environmental Conservation
625 Broadway
Albany, New York 12233-1011
Re: Conservation of Granite Pointe Parcel / 2004 Highlands Conservation Act
Dear Commissioner Sheehan:
We, the undersigned community,
civic and environmental organizations, write to urge the NYS Department of
Environmental Conservation (DEC) to use the provisions of the 2004 Highlands
Conservation Act to permanently protect the Granite Pointe parcel, which is in
the Town of Somers, situated alongside and jutting into the Amawalk Reservoir,
and within the Hudson Highlands. Currently, this parcel is threatened by the proposed Granite Pointe
residential development project and its attendant environmental impacts from
increased impervious surfaces, septic systems, stormwater runoff, and
phosphorous loads.
As you may know, the sensitive Amawalk Reservoir is part of a critical natural resource that provides unfiltered drinking water for millions of residents in New York City, parts of Westchester County and the Town of Somers. The Amawalk Reservoir already is water quality impaired and cannot withstand additional development pressures. Total Maximum Daily Loads (TMDLs) for phosphorous have been established for the Amawalk Reservoir, and at present, actual phosphorous loads are above the set limits and phosphorous reductions are required – phosphorous loads to the Amawalk Reservoir must be reduced by 122 kilograms per year to meet its 1,196 kilograms per year limit. [1] In addition, recent research indicates that watersheds are demonstrably and irreversibly degraded when as little as 10% of their surface area is covered by impervious surfaces. [2] The Amawalk basin already is more than 7% impervious (with the reservoir sub-basin approximately 8% impervious). [3] Preservation of this 29-acre forested parcel, which juts into the heart of the phosphorous-impaired Amawalk, should be a leading priority of DEC’s land conservation and water resources protection efforts.
DEC maintains a file on Granite
Pointe documenting the site’s prior and possibly continuing groundwater
contamination caused by a gasoline tank leak and by residual lead from a
recreational shooting range. Gasoline
constituents, including the carcinogen naphthalene, were confirmed in a test
well on the site.
[4]
In addition, the site was used as a
skeet shooting range from the mid-1930s through the mid-1960s.
[5]
Recent testing confirmed very high
levels of lead – 27 times EPA standards for residentially-zoned areas
– at several parcel locations.
[6]
Given the gasoline contamination, the
continuing high presence of lead, and the significant threats both forms of
contamination pose to human health and the environment, it is imperative that DEC
move to prevent ill-conceived development and permanently preserve the Granite
Pointe in its natural, forested state.
Notwithstanding its history of
contamination and scenic, environmental, and public health significance, the
Granite Pointe parcel was almost lost to development two years ago. The above material contamination issues
were not incorporated into the project’s initial review by the Somers Planning
Board for a proposed housing project of 23 housing units, a review period that
dates back for more than 10 years. The site’s owner/developer had acquired final subdivision approvals and
was ready to begin clear-cutting and road construction in the fall of
2003. However, a group of
citizens, with our active involvement, guidance, and support, were able to
persuade the Planning Board to require a Supplemental Environmental Impact
Statement, which has not yet been submitted. Over the course of this review process, the project’s final
approvals have expired and the Granite Pointe project now rests on preliminary
subdivision approval. Thus, it
continues to be severely threatened by the development goals of the current owner/developer.
Protecting this
environmentally-sensitive peninsula and the drinking water reservoir that
surrounds it is the best way to preserve open space and the public health of
those who rely on these critical drinking water supplies. We urge you to use DEC’s land
acquisition and watershed protection expertise and to seek funding under the
2004 Highlands Conservation Act to purchase and protect the important Granite
Pointe parcel in perpetuity.
Thank you for your
consideration. We look forward to
your response.
Sincerely,
Oreon Sandler Marian
Rose, Ph.D.
President President
FCWC CWCWC
78North Broadway 9
Old Bedford Corners
White Plains, NY 10603 Bedford,
NY 10509
Eric Goldstein Cathleen
Breen
Senior Attorney Watershed Coordinator
NRDC NYPIRG
40 West 20th Street 9
Murray Street
New York, NY 10011 New
York, NY 10007
Leila Goldmark George
Klein
Watershed Attorney Chair
Riverkeeper Sierra
Club Lower Hudson
E-House 5
Algonquin Drive
78 North Broadway Chappaqua,
NY 10514
White Plains, NY 10603
cc: Governor
George E. Pataki
Senator
Hillary Rodham Clinton
Senator
Charles Schumer
Congresswoman
Sue Kelly
Town of Somers Supervisor Mary Beth
Murphy
& Hon. Members
of the Town Board
Dave Tobias, Director, Land Acquisition & Stewardship Program,
New York City
Department of Environmental Protection