Letter to the Editor: League of Women Voters Concerned about Omissions in Firehouse Final Scope
March 21, 2008
LWV concerned about significant omissions in Millwood firehouse final scoping document
March 10, 2008
Re: Final Scope for Environmental Review
Firehouse #1, Millwood Fire District
To the Board of Fire Commissioners:
As an interested agency for the construction of a new Firehouse #1 in the Millwood Fire District, the League of Women Voters of New Castle has reviewed the Final Scope dated November 12, 2007 that was adopted for this project. We are concerned by significant omissions in this document.
Section (7) of the Final Scope refers to “prominent issues that were raised during scoping and determined to be not relevant or not environmentally significant or that have been adequately addressed in a prior environmental review.” This section specifically excludes “statistical, facility and equipment comparisons to other Districts; financing and desire of taxpayers; lifetime cost analysis; future financial needs beyond the firehouse; District and Company organization and governance; and five-year operating costs of the Fire Company” from the Final Scope.
New York’s State Environmental Quality Review Act broadly construes the range of issues for consideration in a project’s Environmental Impact Statement (EIS). As noted by the NYS Department of Environmental Conservation, “It was the intention of the Legislature that the protection and enhancement of the environment, human and community resources should be given appropriate weight with social and economic considerations in determining public policy… Accordingly, it is the intention…that a suitable balance of social, economic and environmental factors be incorporated into the planning and decision-making processes of state, regional and local agencies. It is not the intention of SEQR that environmental factors be the sole consideration in decision-making” (http://www.dec.ny.gov/regs/4490.html).
Thus, the issues that were excluded in Section (7) of the Final Scope are all relevant – and indeed critical – questions that should be addressed in the EIS. The League of Women Voters of New Castle highlighted a number of these issues, as well as others, in comments submitted during the
public scoping process for this project in January 2007. A copy of the League’s comments is enclosed for your reference.
Further, the Environmental Impact Statement is meant to be a comprehensive document that brings together all significant information about a project for consideration and review. It is not sufficient, as stated in Section (7), to refer to issues that have been addressed “in a prior
environmental review.” All significant issues must be addressed, again if necessary, in the EIS for the current proposed action – the construction of a new firehouse on the preferred site (Realis Property) and the three alternate sites selected (Rotta, Vesce and the existing location of Firehouse #1).
We urge the Millwood Fire Commissioners to reconsider the Final Scope document, and to expand the scope of issues to be addressed in the Environmental Impact Statement for this project to reflect the true intent of the SEQR process.
Sincerely,
Sheila Crespi, Co-President and
Chair, Local Planning Committee
League of Women Voters of New Castle
Questions for Millwood Fire House Scoping Document: Realis Property
January 24, 2007
INTRODUCTION
The League of Women Voters of New Castle is a nonpartisan civic organization whose mission is to promote informed and active participation in government. Through activities such as our Candidates’ Nights; forums and informational meetings; public questioning and comment before relevant town boards; and coverage in our newsletter, The Voter, the League provides public education and outreach on a broad array of issues with impact on our local community,
As part of our ongoing involvement with significant community issues, the League’s Local Planning Committee has been following developments related to the proposed construction of a new fire house in the Millwood Fire District to replace the existing Station #1 on Route 120. The following are our comments to be considered for the Final Scoping Document for the Draft Environmental Impact Statement (DEIS) on the Realis Property as a potential site for the new Station #1:
Size and Cost of the Proposed Fire Station
In the DEIS, please provide a full justification for the size and cost of the fire station. This should include a comparison of the Millwood Fire District with other districts of similar size in surrounding areas. For each district including the Millwood Fire District, the comparison should include, but not be limited to, the following factors: the number of households each serves; the size of the business community each serves; the total assessed tax value of each district; the number of fire stations and number of bays in each district; the square footage of the fire stations; other facilities offered in each of the stations, such as offices and public meeting rooms; and other relevant factors.
Ability of the Fire District to Pay for the New Fire Station
The DEIS should discuss the anticipated cost and financing of the project and all proposed alternatives, along with projected impacts on the tax rate. The desire and the ability of the District’s tax payers to pay for such additional taxes should be evaluated.
Watershed Impact
The DEIS should discuss in detail the plans for waste management and environmental controls, and the approvals that will be required to maintain the integrity of the watershed. Sewering options for the site and alternatives should be considered.
Neighborhood Covenants
The DEIS should include a full discussion of any covenants restricting the use of the Realis Property. If any have to be overturned, the DEIS should describe the process for so doing and the costs involved.
Unsuitability of Existing Fire Station
The DEIS should address the specifics of why the current location is unsuitable for a new fire station. It should also consider how the old site would be used after the construction of a new fire station on a new site. If the intention is to sell the property, an estimate of the sale price should be included.
Compliance with Town Zoning
The DEIS should address whether the proposed fire station is compliant with the regulations of current Town Zoning Code and those of the Millwood Overlay District. If not, it should discuss the zoning changes necessary to accommodate the proposed building and alternatives.
Outdoor Activities
The DEIS should address any outdoor activities, including training, that would take place on the site and at alternative sites.
Editor’s Note: A copy of this letter to the Millwood Fire Commissioners was supplied to all interested agencies as well as news outlets including NewCastleNOW.org
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