January 13, 2000

To All Residents of Taylor Road, Valhalla

There is a proposal to build a large water treatment plant for the New York City water supply system on the Grasslands Reservation. This filtration plant will occupy New York City owned land that is on the north side of Grasslands Road between the Hammond House and the County Jail, and will go back toward the Medical College. The proposal also includes a separate wastewater residual treatment facility to be constructed on the south side of Grasslands Road, on City-owned property, near the site of a former bank on Clearbrook Road. There will be a passage underneath Grasslands Road connecting the two parcels. Entrance to the entire facility will be from Bee Line Boulevard at the County bus garage.

It is intended for this plant to filter all of the water emanating from the Catskill and Delaware aqueducts. The filtered water will supply the needs of most of New York City and southern Westchester. A copy of the draft scope of the work for the Environmental Impact Statement is attached. New York City’s Department of Environmental Protection is the lead agency coordinating the environmental review. A public meeting to receive comments on the draft scope will be held on Wednesday, January 26^th at 7 PM in the Westchester County Center in White Plains.

There is uncertainty as to whether this plant will be built at all as the final decision to require the filtration of NYC water rests with the Federal EPA. No decision will be made by them until April 15, 2002. In the meantime, plans for the building of this plant must proceed on a dual track because, if such a plant becomes required, it would take too many years to design and construct. As of now, the target for breaking ground is the Spring of 2007. It will take eight years to construct and the goal is to have it fully operational by 2015.

If you have any questions, or comments, I will be happy to provide you with whatever information that I have, and will include your concerns in a written statement from our civic association to the NYC DEP. You may also send your own written comments directly them. They will be accepted until February 25^th (not ten calendar days as stated in the document). Written statements should be addressed to Angela Licata, Deputy Director, Office of Management Assessment, NYC Department of Environmental Protection, 59-17 Junction Blvd. Corona, NY, 11368.

RE: Scoping meeting held on 01/26/2000 at the Westchester County Center for the draft Scope of Work issued during December, 1999.

The Council of Greenburgh Civic Associations is an umbrella organization representing over fifty civic associations within the Town of Greenburgh. The Council has certain concerns with the draft scope of the work for the Environmental Impact Statement and is requesting that the following items be considered for inclusion in the Draft Environmental Impact Statement document that is due to be issued during December, 2000.

Site Plan:

The figure maps in the of the draft scope of the work for the Environmental Impact Statement depicting the land south of Grasslands Road are both out of scale and are inaccurate. Either they show the placement of the Cat/Del aqueduct or they show Taylor Road, but with one exception (Figure 4), do not show both. The figure 4 drawing is incorrect as it implies that there is significant land between the Cat/Del aqueduct and Taylor Road. This is not the case. Figure 4 depicts the Eastview site south of Grasslands Road and east of the aqueduct as New York City property, when in fact the property between Taylor Road and the aqueduct is privately owned. There are six properties here and at least five of them directly abut the aqueduct. Tax maps should be used for both scale and for a more accurate representation of property ownership.

Figure 3 depicts a detention basin (#15) for the wastewater treatment plant south of Grasslands Road. This retention basin does not appear in any of the publicly available drawings prior to this draft scope document. In view of the encephalitis outbreak caused by mosquitoes during this past summer and due the fear of an even greater one for the coming season, we are requesting that this basin be covered or contained. If retention tanks are the substitute, have them placed below grade, as their required height would affect the horizon.

The height of all structures that will be built for this filtration plant on both sides of Grasslands Road is not represented in the figure drawings. When the Westchester County jail was built, it was depicted as a three-story structure adjacent to an existing penitentiary. What was not made clear was the actual height of those three stories. What we have today is a structure that is three gymnasium stories high, affecting the horizon of the entire area. Accordingly, we are asking that the height of the filtration and waste water plant buildings be represented in actual feet so that residents who are concerned that these structures might be in their view have some basis to either negate or validate their concerns. Coupled with this we are asking that the grading plans also be included in the next document so that we can get a more complete picture of the impact of those building heights.

Traffic:

The traffic study proposed for this project does not include the intersection of Route 100A/Route 100 (Knollwood Road) at Route 100C (Grasslands Road) as one of the ten shown in Figure 5. This intersection is already classified as being in "failure" by State DOT during peak hours due to the concentration of institutions and corporate parks within this radius. The impact of traffic on this particular needs to be addressed.

The effect of traffic generated by both the operations staff and by other vehicles such as trucks needs to be projected. The number of trucks or other heavy equipment vehicles that will be involved with the operation of the plant for any and all reasons needs to be documented. For example, there is no statement as to amount of de-watered cake and the estimated tonnage with the accompanying number of vehicles that will be required to carry it away in any of the documentation.

Noise:

The issue of stationary source noise needs greater study than what is proposed in this document. It states:

"Sensitive receptors generally within a 2,000-foot radius and in direct line of sight of the noise source will be considered for analysis if noise generating equipment associated with the proposed project has the likelihood of producing greater than a 3 dBA increase in noise levels at the property boundary." (p. 18)

This is a formula for doing nothing. The wording precludes that if any of the conditions are not present, a more detailed analysis is not required. Soon after the opening of the Sprain Brook Parkway almost twenty years ago, the noise level at Route 100C at the Sprain Brook Parkway exit was 85 decibels. An increase of 3-to-5 dBA represents a doubling of noise, not merely an incremental increase. According we are asking that a detailed analysis be done within a half-mile of the perimeter all of the plant boundaries particularly for those times not associated with peak traffic hours, when the increased noise will be noticed.

Air Quality:

We request that DEC perform a wind-rose study as previous research for a proposed county incinerator that was never built indicated that the prevailing winds from the Grasslands Reservation carry particulates toward the south east. There are many homes in this direction and hundreds of families will be affected. Also the addition of numerous heavy equipment vehicles into the traffic stream will affect air emissions and also needs to be addressed. The potential air quality impact from both the plant facility and the traffic that it generates needs to be fully studied.

Other Issues not addressed in the draft scope study:

• Fire Departments

The fire departments that cover the Grasslands Reservation are strictly volunteer. Valhalla covers the Mount Pleasant side, while Elmsford protects the Greenburgh section. Some of the chemicals that will be used in the operation of this plant require fire safety management procedures that exceed the capabilities of these volunteers. What provision has been made to both train personnel and fund their operations due their foreseeable and inevitable expansion?

• Septic Tanks

All of the homes on Taylor Road have septic tanks and leaching fields that are significantly above the grade of the Cat/Del aqueduct. During the building of the Sprain Brook Parkway, when the rest of North Greenburgh was connected to the County Trunk line, no provision for the connection of these homes was made due to significant cost factors. This resulted in Taylor Road being isolated and without recourse. Since the wastewater treatment plant will be on the south side of Grasslands Road and since it will itself be directly connected into the County sewer line, can arrangements be made to study the feasibility of now connecting these homes into that line?

• Screening

Since the homes on Taylor Road are considerably above the grade of the Cat/Del aqueduct, adequate tree screening should be placed so that there is no view of the wastewater treatment plant and its ancillary facilities.

• Residual Land

We are requesting that the New York City land that is south of Grasslands Road in the Town of Greenburgh, not utilized for this filtration project, remain undeveloped, and that it never be sold. This property which will become landlocked after construction completion is vital for screening and noise mitigation. It should remain as open space. We request that a deed restriction to this effect be put on this land so that it remains as open space forever wild.

• Cell Towers

Address the issue of possible placement of cell towers on these structures in the future. We are asking that you prohibit their placement.

• Topsoil

The topsoil on this property is valuable as the land was once farmed. Not only should Its economic value be addressed, but also the truck traffic that its relocation and removal will generate during plant construction.

 

Cumulative Impacts:

There are significant cumulative impacts in three major areas for this project: drainage, noise and traffic.

• Drainage

The covering of such a large area with impervious surfaces can only serve to further degrade the flood conditions with which North Greenburgh and the village of Elmsford must cope. The filtration plant site sits significantly higher than both areas and drains directly into the Saw Mill River Valley flood plain where they are located. This filtration plant will occupy an area that is significantly larger than a Home Depot big box store, proposed for Route 9A at Dana Road. The effects of that project on the Saw Mill River Valley flood plain are considerable, to the point that the project was initially rejected by the Mount Pleasant Planning Board for this reason, among others. The amount of surface area that will become impervious from the filtration plant construction needs to be delineated, so that its effects can be fully evaluated.

• Traffic

There is a cumulative impact for all of the vehicular traffic now using Grasslands Road. The immediate neighborhood (.05 mile radius) is impacted by the arriving and departing of vehicles in order to reach the following facilities, all of which must use Grasslands Road (Route 100C) for their entrance and egress:

• Westchester County Bus Depot

• Westchester County Jail

• Westchester County Penitentiary

• Westchester County Medical Center

• Westchester County Psychiatric Center

• Ruth Taylor Institute

• Blythedale Children’s Hospital

• 503 Grasslands Road Medical Building

• Westchester Community College

• BOCES of Southern Westchester

• Hebrew Hospital/Home

• Westchester Meadows Continuing Care Retirement Community

• Kensico Cemetery

• Robert-Martin Executive Park

• 100 Grasslands Road Office Complex

 

In addition to the above, there are other facilities not directly on Grasslands Road but within the .05 mile radius impacting local traffic:

• NYS Department of Transportation Maintenance yard (Route 9A @ Dana Road)

• Home Depot (proposed for Route 9A @ Dana Road)

• Tops Appliances (Big–box store) (Route 9A)

• Greenburgh Multi-Plex Cinemas (Route 9A @ Old Country Road)

• Fairview Corporate Park (Coca Cola bottling et al @ Route 9A)

• Westchester Ice Rink (Route 9A)

• Executive Park (Route 9A @ Skyline Drive)

• Gate of Heaven Cemetery @ Bradhurst Avenue

• 19 Bradhurst Ave. (former County Office Building)

We are asking that the NYC DEC obtain written commitments from the New York State Department of Transportation on what traffic improvements on both Route 9A and on Grasslands Road, with associated timetables, will be forthcoming prior to the development of this project.

• Noise

The draft scope of the work for the DEIS does not adequately address the issue of the cumulative effect of noise, both stationary and that generated by vehicular traffic. Increased traffic brings increased noise. This project will bring us above the acceptable EPA threshold for permissible noise decibels. The problem of noise in this area was extensively studied during the building of the Sprain Brook Parkway in 1976-80, and again when some noise barriers were installed on the parkway’s eastern flank during the early 1980s. North Greenburgh endures county beneficial projects that the rest of the cities and towns in Westchester would not tolerate. The County Bus Depot generates buses pouring onto the Sprain Brook Parkway commencing at 5:00 AM. The County Jail generates innumerable fire calls, particularly at night. The Medical Center gets ambulance sirens and helicopters landing and taking off at all hours. This is coupled with the endless noise from the Sprain Brook Parkway that literally bisects our town. The traffic generated by this project can only exacerbate the cacophony. We are asking what mitigating factors can be brought into this equation to ameliorate this noise.

In conclusion, with each new application for development in the Grasslands area, the advisory Boards for the County or the Towns acquiesce to the building of each new facility on an individual basis, as each one may be have valid merits and each could add to regional viability. But each facility and institution generates its own impacts and the Boards do not adequately consider their cumulative impact on the total picture. For all of the above reasons, our Association would ask that the DEIS address these collective effects and define what goals they plan to achieve toward their alleviation. Thank you.