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HomeMy WebLinkAboutIAWWTP Improvement Project FEIS 2003STUDY BOUNDARIES FOR ENVIRONMENTAL IMPACT STATEMENT LEGEND TOWN OF DRYDEN PROPOSED STUDY AREA ® TOWN OF DRYDEN EXISTING PLANNING SERVICE AREA TOWN OF MIACA EXISTING PLANNING SERVICE AREA TOWN OF LANSING PROPOSED STUDY AREA I I VMLAGE OF LANSING BOUNDARY CITY OF MUCA EXISTING PLANNING SERVICE AREA PARCEL & MUNICIPAL BOUNDARIES MUNICIPAL BOUNDARIES TOWN PLANNED SEWER SERVICE AREA LINES ROAD CENTER LINES Parcel add Road data distributed by: Tompkins County Information Technology Services North American Datum, New York State Plane Central Zone Unified Boundary by City of Ithaca, DPW: Water & Sewer Division 0.7 M35 0 0.7 lA GIV 21 Ss 1:40,000 FT Conceptual d—gaby Larry Fabbrom PE, LS Drawn by CJL Campbell, MRP Last Updated 9/12/02 H--GIS-Prj2002- Sewer -e —p& bndmap:-WUmid Plo— d, landscape (22z34) 116 map is for display puq— a*. CITY OF ITHACA. bil DEPARTMENT OF PUBLIC WORKS y, gun WATER & SEWER DIVISION 510 FIRST ST ITHACA, NY 14850 te1272-1717, fax 277-5028 STUDY BOUNDARIES FOR ENVIRONMENTAL IMPACT STATEMENT LEGEND r TORN OP rJ mm, PP.ROPOSPI7 STUDY ARRA F j TOWN (Ile DRYDEN LeXIRTWO, PLANNING ME:RVICE ARE TOWN OF IT)fACA hR011081;17 y'i'UI Il' 11thA TOIAW OF ITFIACA EXISTING SERVICP AREA T TOWN OF I ANSING PROPO:iRD STUDY All l A t VILLAGE OF LAMMO ROUNDARY , 9 CITY OF ITHAC.V MISTING P] NNNING.MRVICH ARM P-111c" MUNICIPAL BOUNDARMA r { { MUNICIPAL BOUNDARIES f ROAD C ENTER LINES daarecl and Road datu disiribu(cd hy: Tompkins County InlilrrrJalion Technology Scrvicas Nordi AJnericlan Du(un, New fork H(u(o Raw C:011Lra) %one Unified HOundary by c;Ity of Ithaca, DPW: Water Sewer Division 0.6 03 0 0G - -_ 113 1V ml J 1:+0,WO FT �N Comwupl dwipn by p harry Pobbnmi P61, LS g Umm) by C R, C,'uraphrll, A1RP Lau UpdaiM 6/27/01 iJ;•siu•m;,Jrs>bnd)nup:•larry.mxd, plobheA, umheapa (220 q Nap rpr dlopt,y purmo only, CITY OF ITHACA; DEPARTMENT OIL PUBLIC WORKS WATER & SEWER DIVISION 510 FIRST ST ITHAC:A, ANY 1,1850 te1272-1717, lax 277-5028 r .L al I,�WN+vv�l- i9- � rce �-�.t' SUSAN H. ]CROCK Attorney at Law 306 East State Street, Suite 230 Ithaca, New York 14850 Telephone: 607-277-3 995 Facsimile: 607-277-8042 TO: MAYOR ALAN COHEN SUPERVISOR STEPHEN FARKAS MAYOR DONALD HARTILL MAYOR WALTER LYNN SUPERVISOR CATHERINE VALENTINO SUPERVISOR MARK VARVAYANIS FROM: SUSAN BROCK �\-AF) RE: FINAL EIS DATE: NOVEMBER 18, 2003 i ,f. i ATTEST �6 CLEIRK j 3-mailAVkW �F.r}:,�--CAA.wrn Please find enclosed the Final Environmental Impact Statement for the intermunicipal sewer project. Each municipality should make a copy available for public review at its municipal office beginning Wednesday, November 19. The numbers of copies each municipality is receiving, per their requests, are shown below. Village of Cayuga Heights (2) Town of Dryden (3) City of Ithaca (6) Town of Ithaca (3) Town of Lansing (3) Village of Lansing (3) Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project Location: City of Ithaca, Village of Cayuga Heights, Town of Dryden, and Town and Village of Lansing, Tompkins County, New York Lead Agency: NYS Department of Environmental Conservation Region 7 — Cortland Office 1285 Fisher Avenue Cortland, New York 13045-1090 Contact: John Merriman (607) 753-3095 Project Sponsors: City of Ithaca Town of Ithaca Town of Dryden Town of Lansing Village of Lansing Village of Cayuga Heights Contact: Susan Brock, Esq. (607) 277-3995 EIS Prepared By: The Chazen Companies North Country Office 110 Glen Street Glens Falls, New York 12801 Contact: Stuart F. Mesinger, AICP (518) 812-0513 DEIS Accepted: June 20, 2003 DEIS Comments Due: August 11, 2003 DEIS Public Hearing: July 31, 2003 FEIS Accepted: November 13, 2003 i I J EIS Preparers: The Chazen Companies 110 Glen Street Glen Falls, NY 12804 Environmental Consultant Contact: Stuart F. Mesinger, AICP (518) 812-0513 Stearns & Wheler, LLC One Remington Park Drive Cazenovia, New York 13035 Engineering Consultant Contact: Mr. Gerry Hook, P.E. (315) 655-8161 Greenhouse Consultants 40 Exchange Place, 13th Floor New York, NY 10005 Cultural Resources Investigation Contact: Barry Greenhouse/Will Roberts (212) 514-9520 Ithaca -Tompkins County Transportation Council 121 East Court Street Ithaca, NY 14850 Transportation Studies Contact: Fernando de Aragon, P.E. (607) 274-5570 Creighton Manning Engineering, LLP 4 Automation Lane Albany, New York 12205 Transportation Studies Contact: Chuck Manning, P.E. (518) 446-0397 ii Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project TABLE OF CONTENTS Page Table of Contents iii List of Tables and Figures in Section III iv Glossary of Acronyms v I. Introduction 1 II. Responses to Public Comments 3 • Completeness 3 • Documentation of Need for the Project 4 • Southern Cayuga Lake Condition & Impacts 7 • DEC Actions Regarding Other Projects Affecting Cayuga Lake 12 • Segmentation 12 • IAWWTP SPDES Permit Modification 16 • Phosphorus Upgrade & Loadings 18 • Construction 20 • Unique Natural Areas 21 • Wetlands 23 Water Resources 25 • Growth -Inducing Impacts 26 • Alternatives 27 • Project Schedule 30 • Dryden Planning Area 31 • Mapping Issues 32 • General 33 • Comments in Support of Project 35 III. Tables and Figures (see list on next page) 39 IV. Written Comments Received on the DEIS 40 V. Distribution List 41 iii Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project LIST OF TABLES AND FIGURES IN SECTION III Table F-1: WWTP Total Phosphorus (TP) Loading Discharged to South End � of Cayuga Lake Fil FEIS Figure 1: Wetlands in Relation to Proposed Service Area Sewers FEIS Figure 2: Wetlands in Relation to Potential Planning Area Sewers FEIS Figure 3: Existing Well Points in Relation to Proposed Sewers Revised DEIS Figures DEIS Figure 4: Existing Wastewater Collection Facilities DEIS Figure 14a: Water Resources in the Town of Lansing and Village of Lansing Portion of the Study Area DEIS Figure 14b: Water Resources in the Town of Dryden Portion of the Study Area DEIS Figure 19: Unique Natural Areas DEIS Figure 33: Unique Natural Areas and Proposed Town of Lansing Service Area Sewers iv Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project IGLOSSARY OF ACRONYMS BTT — Best Treatment Technology CFR — Code of Federal Regulations DEC — New York State Department of Environmental Conservation DEIS — Draft Environmental Impact Statement EIS — Environmental Impact Statement FEIS — Final Environmental Impact Statement gpd — Gallons Per Day r IAWWTP — Ithaca Area Wastewater Treatment Plant lbs/day — Pounds Per Day mgd— Million Gallons Per Day mg/L — Milligrams Per Liter NYCRR — New York Code, Rules & Regulations ppm — Parts Per Million SEQRA — State Environmental Quality Review Act SPDES — State Pollutant Elimination Discharge System 1 i TCHD — Tompkins County Health Department TMDL — Total Maximum Daily Load TOGS — Technical and Operation Guidance Series UNA — Unique Natural Area VCHWTP — Village of Cayuga Heights Wastewater Treatment Plant WWFP — Wastewater Facilities Plan WWTP — Wastewater Treatment Plant I� v I. INTRODUCTION This document is a Final Environmental Impact Statement (FEIS) for the proposed Ithaca Area Municipal Wastewater Collection Improvement Project (the project). This document, together with the Draft Environmental Impact Statement (herein incorporated by reference, previously distributed for public comment), form the Environmental Impact Statement (EIS) for the project. The EIS has been prepared in accordance with the requirements of the New York State Environmental Quality Review Act (SEQRA) and implementing regulations at 6 NYCRR Part 617. The EIS presents an evaluation of the potentially significant adverse impacts of constructing new public sewer lines in the Town of Lansing and a sewer transmission main in the Town of Lansing and the Villages of Lansing and Cayuga Heights. The Draft i Environmental Impact Statement (DEIS) also evaluates the impacts of potential sewer lines in the Town of Lansing. Finally, the DEIS evaluates the potential impacts of growth induced in the Towns of Lansing and Dryden and the Village of Lansing as a result of the proposed project, as well as from sewers that may be constructed at some time in the future. The reader is referred to the DEIS document for a complete description of the project and its associated impacts and proposed mitigation measures, as well as a discussion of alternatives to the project. The DEIS is hereby amended by the information contained in the FEIS. IEIS Process The New York State Department of Environmental Conservation (DEC) accepted the DEIS on June 20, 2003 and made it available for public comment. DEC held a public hearing on the DEIS on July 31, 2003. The DEC accepted comments on the DEIS until August 11, 2003. This FEIS was accepted by DEC on November 13, 2003. 1 Organization of the FEIS This FEIS is organized as follows. Comments on the FEIS have been organized into topic areas. The Lead Agency's response to each substantive comment is provided after the comment. Comments that are substantively similar have been combined and a single response is given to such comments. Oral comments made at the public hearing are also summarized here. References are made after each comment as to who made the comment and how it was received. Copies of written comments are reproduced in Section IV. The oral comments made at the July 31, 2003 public hearing were recorded on an audio tape, and that tape is part of the public record and is located at the DEC office listed on the cover sheet. Any comments that are not addressed here are not deemed to be substantive. 1 Summary of Additional Information in FEIS This FEIS contains additional information on several subjects, including the following. 1. Several commenters raised the issue of DEIS completeness and suggested that it was not complete and did not adequately address all issues, specifically those related to phosphorous discharges at the Ithaca Area Wastewater Treatment Plant (IAWWTP) and Cayuga Lake water quality. It is the Lead Agency's position that these issues are completely independent of this project and have already been addressed through a separate SEQRA review of the IAWWTP SPDES permit. Nevertheless, this FEIS contains data demonstrating that with planned phosphorous upgrades to the IAWWTP and Village of Cayuga Heights Wastewater Treatment Plant, there will be a net reduction in phosphorous discharge, even with the addition of the Town of Lansing flows. 2. Several commenters questioned the need for the project, specifically whether y failing in -ground sanitary waste disposal systems had been adequately documented. This FEIS contains additional data and information documenting need for the project. 3. One commenter raised the issue of segmentation, specifically whether the SEQRA review of this project and the IAWWTP SPDES permit had been segmented. It is the Lead Agency's position that segmentation has not occurred. The project had not been developed and was not under consideration when the environmental review was performed in 1996 on the SPDES permit modification request. The impacts of a 13.1 mgd flow were properly considered during the SEQRA review of the IAWWTP's permit modification. 4. This FEIS includes additional information about the level of detail that will be included in construction plans, including plans for crossing streams and Unique Natural Areas, and how routes will be evaluated during the construction plan development process. 5. This FEIS includes an evaluation of the use of the Norfolk Southern Railroad right-of-way for the sewer trunk line. The evaluation concludes that this right-of- way is not feasible because of construction issues. 6. This FEIS contains additional information about why a separate wastewater treatment plant for the Town of Lansing is not a preferred alternative. 2 II. RESPONSES TO PUBLIC COMMENTS COMPLETENESS 1. Comment: The New York State Department of Environmental Conservation (DEC) should reject the Draft Environmental Impact Statement (DEIS) as incomplete. The DEIS should contain a full range of water quality data for southern Cayuga Lake, including the effects of individual septic systems in the Lansing area, historical and projected effluent analyses for the Ithaca Area Wastewater Treatment Plant (IAWWTP) and the Village of Cayuga Heights Wastewater Treatment Plant (VCHWTP), an IAWWTP SPDES permit analysis including the effects of projected flow increases and tertiary phosphorus treatment, and a complete analysis of the current regulatory backdrop against which the project is proposed, including Total Maximum Daily Load (TMDL) development. (R. DePaolo in 8111103 letter) Response: For determinations of completion, SEQRA requires that the DEIS be adequate with respect to its scope and content for the purpose of commencing public review. This standard was met, as the DEIS contains the information required by the scoping document. To the extent this comment requests additional information relevant to the project, such information is provided in response to specific comments below. Much of the information the commenter requests, however, is outside the scope of this project. During the scoping process, this commenter raised a number of water quality and SPDES permit issues related to IAWWTP discharges. As the Scoping Responsiveness Summary explained, such issues are completely independent of this project and have been addressed through a separate and independent process for the IAWWTP permit. The Final Scoping Document does not include such issues. Several other commenters have nonetheless asked for similar information, especially about IAWWTP SPDES permit issues and phosphorus discharges from the two wastewater treatment plants (WWTPs). Some of the comments contain inaccurate assertions about these topics that are repeated by more than one commenter. To correct these inaccuracies, this FEIS provides information on the IAWWTP SPDES permit and WWTP phosphorus discharges, even though such information is relevant to SPDES permit issues and not this project. 2. Comment: The DEIS needs major supplementation; missing information and analysis should be provided, and the DEIS re -issued for comment. The DEIS is not ready to be moved to the Final Environmental Impact Statement (FEIS) stage. (D. Kiefer in 8111103 letter) I Response: See Response to Comment 1. P p 3. Comment: The DEIS appears to be very complete. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. DOCUMENTATION OF NEED FOR THE PROJECT 4. Comment: There is no or insufficient data to support the assertions in the DEIS that water quality impacts are occurring as a result of inadequate on -site sewage disposal systems. There is no water quality data to support the need for an $11 million expenditure ($7 million funded locally) and 26 miles of pipe that will result in discharges into the impaired southern part of Cayuga Lake. Any pollution reductions in the project area are likely to be far outweighed by increased water quality problems in southern Cayuga Lake. The EIS should contain water quality data on the effects of Lansing -area on -site systems on Cayuga Lake and performance characteristics for these systems. Data should include wastewater flow, pollution loading studies and a delineation of wastewater entering the Lake from the on -site systems. The EIS should also contain Cayuga Lake ambient water quality data for the proposed service area and for the IAWWTP-VCHWTP discharge area. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in undated written copy of public comment received by DEC on 816103) Response: Septic system failures have posed a threat to surface and ground waters in the Lansing area for decades. Upwards of 30 septic systems in Ladoga Park are inundated by the Lake whenever water elevations exceed 384.0 feet. When waters recede, they can draw untreated sewage into the Lake from the septic systems. Local knowledge indicates these septic systems have flooded on a relatively frequent basis over the past 10 years. (See Comment 79.) The Tompkins County Health Department (TCHD) has noted that 1. severe limitations for on -site systems exist in Ladoga Park due to flooding and inadequate separation distances to surface waters. Concerns are not limited to flooding conditions. During periods of heavy rain, poorly operating systems can contribute inadequately treated sewage into the Lake and its tributaries. Ladoga Park is located on the Lake next to Myers Park, which has a public swimming beach. The TCHD sampled the Lake at this beach on July 23, 2003, after three inches of rain fell in two days and the Lake level rose six inches. This sampling showed elevated levels of total coliform (3200/100ml) and fecal coliform (2400/100ml). Failing septic systems could be a source of these coliform counts. The Town of Lansing Study Area has a number of creeks that drain into Cayuga Lake. (See DEIS Figure 14a.) Failing systems near Lake tributaries can contaminate the tributaries and ultimately the Lake. TCHD records indicate that on the average 5 failed In septic stems are replaced ever year per 1,000 people in the Town of Lansing Sewer P Y P YY P P P g Study Area. This is a higher per capita replacement rate than the replacement rates in any of the towns in Tompkins County. Actual numbers of failed systems are likely higher, since homeowners often are unaware that their systems have failed until sewage backs -up into their residences or untreated sewage surfaces on the ground. As unsewered populations in the Lansing area increase, it is reasonable to presume that the number of failed systems per year will also increase. Problems with failing septic systems are not new. The November 1983 Wastewater Facilities Plan for the Town of Lansing includes a summary of findings from a sewage disposal system survey questionnaire that was mailed to 933 parcels within a geographic area nearly identical to the EIS Town of Lansing Planning Area. Of the 318 returns, 40% F' indicated some type of failure of their wastewater disposal system. In 1982, the TCHD surveyed 80 homes in the Asbury Road area on a house -to -house basis. Asbury Road runs immediately parallel to Gulf Creek, a tributary to Cayuga Lake. Many of the septic systems along Asbury Road are located just above the steep slopes of Gulf Creek. Of the 80 homes, 10 septic systems were in unsatisfactory or questionable condition and an additional 22 were expected to fail within 5 years. This meant a total of 40% of the systems had failed or were expected to fail soon. Another survey conducted by the TCHD in 1981 of well water systems in the hamlet of Ludlowville found that a significant number of wells were contaminated with sewage. Of 30 wells tested, 18 exhibited some degree of contamination. The TCHD has also expressed concerns about the four on -site sand filter systems at the Lansing Central School District that serve the elementary school, middle school, high school and District Office (approximately 1,380 students, plus teachers and staff, total design flow of 35,300 gallons per day). These systems discharge to surface waters and either drain directly to Cayuga Lake through tributary P296-58 or to Salmon Creek (and ultimately the Lake) via ditches. " "the The TCHD noted in a May 1996 letter that soil in much of the planning area is marginal to poor for on -site sewage systems. Many homes and businesses rely on alternative sand filter/dispersion trench sewage systems which may affect ditches and streams especially if lots are not large enough to keep the dispersion trenches at least 50' from property lines (lots under 100' in the lesser dimension)." In addition to the positive impacts on Cayuga Lake and its tributary streams in the Lansing area, the project will benefit public health. The ability to eliminate failed or inadequate on -site systems, flooded on -site systems, and individual package treatment plants will reduce the potential for groundwater and surface water contamination, which will reduce the risk to both public and private water supplies and to public health in general. 5 The DEIS also spells out other project benefits that are not mentioned by the commenters. These benefits are listed in Section 1.2 of the DEIS and include the elimination of SPDES permit flow exceedances at the VCHWTP, promotion of infill in the Town of Lansing rather than conversion of open space and agricultural lands, and the provision of additional public sewage capacity for the Town and Village of Lansing, which currently is extremely limited. The commenters are concerned about the impact of additional flow into the southernmost end of Cayuga Lake. Their additional comments (set forth in numbered comments below) focus on the amount of phosphorus that will be added to this part of the Lake. As stated in Response to Comment 1 above, this issue is not relevant to the project since both the IAWWTP and VCHWTP will maintain their discharges within permitted limits. However, to correct inaccurate statements made by some commenters about the amount of phosphorus this project will generate, phosphorus information is presented here and in response to specific comments below. It is anticipated initially that an average sewage flow of 144,000 gallons per day (gpd) will be collected annually from the Town of Lansing as a result of this project. It is estimated that this flow will increase to 441,000 gpd in 20 years. All of this sewage will be conveyed to public wastewater treatment plants where it will receive treatment to reduce the phosphorus content to below 0.2 mg/L once planned phosphorus upgrades are completed at the IAWWTP and VCHWTP. The amount of phosphorus this represents is less than one-fourth (1/4) of a pound per day initially, and less three -fourths (3/4) of a pound per day over 20 years. j Table F-1 in Section III shows the impact that this small amount of flow will have on the phosphorus loading from the WWTPs to the south end of the Lake. Data presented is actual operating data for the IAWWTP and VCHWTP for the last four full years of record and the current year through August 2003. With the planned phosphorus upgrades, an overall reduction in the amount of phosphorus currently discharged from these plants to the south end of Cayuga Lake of approximately 65 percent will be achieved, even with the flows from the Town of Lansing. The five-year analysis shows that from 1999 through August of 2003, the historical combined annual average discharge of total phosphorus from the IAWWTP and I VCHWTP has ranged from 33.5 to 44.8 pounds per day. Once the plants install tertiary _ phosphorus treatment, it is anticipated that their combined total phosphorus discharge will not exceed 11.9 to 14.8 pounds per day for flows in the historic five-year range shown in Table F-1. Addition of the initial flows from the proposed Lansing service area will add another 0.24 pounds per day. The initial percent reduction in phosphorus discharged to the Lake from the two WWTPs (including the initial flows from the Town of Lansing) is estimated to range from 57% to 70%. The projected numbers assume that the two WWTPs will discharge phosphorus at a concentration of 0.2 mg/L at all times (see below). This is the highest likely concentration and actual concentrations will probably be lower much of the time, which will result in even greater initial reductions in phosphorus to the Lake. Over the 20-year planning period, as flows increase from all six P municipalities due to growth, the amount of phosphorus loading to the Lake at 0.2 mg/L is not expected to exceed 16.6 pounds per day. S. Comment: The EIS should include data on the number, frequency, location, timing, method and extent of septic system and small package plant failures in the project area, and on whether on -site waste treatment is adversely impacting Cayuga Lake, other waterways, or general public health. One commenter who asks for this information also recognizes that certain developed shoreline areas on both the east and west shores have septic systems that occasionally get flooded by the Lake and need to be dealt with. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter) Response: See Response to Comment 4 above. 6. Comment: To document need for the project and to compare impacts of any existing problems with project impacts, the EIS should contain more information about rates of discharge and frequency and amount of overflow/bypass from the two wastewater treatment plants (WWTPs). One commenter said the EIS should also address whether any of the overflow/bypass problems are being addressed outside this project. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter) Response. Section 2.1 and Tables 1 and 2 in the DEIS summarize the operating conditions of the two WWTPs. No overflows/bypasses have occurred, with the exception of one 2-hour diversion from the IAWWTP headworks in the 1990s during an extreme flooding event. Exceedances of the VCHWTP's permitted flow (all of which is treated) would be addressed by diverting excess flow to the IAWWTP, which has permitted reserve capacity. SOUTHERN CAYUGA LAKE CONDITION & IMPACTS WWTP LOADINGS 7. Comment: The EIS should include historical and projected performance analyses for both the IAWWTP and the VCHWTP, including a projected phosphorus loading analysis that takes into account planned tertiary phosphorus treatment at the IAWWTP and the increased flows from the project. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: Refer to Table F-1 and Response to Comment 4 above. 7 JUSTIFICATION FOR PUTTING FLOW IN SOUTH END OF LAKE AND ANALYSIS OF IMPACTS 8. Comment: The EIS needs tojustify why wastewater will be transported from a relatively deep part of Cayuga Lake to its shallow, impaired southern basin and compare the environmental pros and cons of doing so. Two commenters said the DEC's phosphorus guidance value of 20 micrograms per liter (indicating excessive i eutrophication) is regularly exceeded on the Lake's shallow southern shelf. One commenter said the following as part of this comment: Cayuga Lake's southern S, 000 acres have turbidity and phosphorus levels that impair the Lake's best use. Public bathing is prohibited because of turbidity. High phosphorus levels cause vast algal blooms. These problems threaten drinking water drawn from the Lake. The southern part of the Lake receives phosphorus from IAWWTP and VCHWTP effluent, which is discharged into waters less than 12 feet deep, and phosphorus and turbidity discharged by Cayuga Inlet, Cascadilla Creek, and Fall Creek. Cayuga Lake in the proposed service area is deeper, receives far less pollution and does not suffer from widespread impairments. (R. DePaolo in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter; D. Kiefer in 8111103 letter) Response: See Response to Comment 4 above. The southern shelf does have more issues with phosphorus than the larger, deeper part of the Lake. However, the focus of this project must weigh the overall benefits achieved by providing a regionalized approach to wastewater treatment at larger facilities to the introduction of a new discharge point from a small facility serving only the Town of Lansing. In DEC's experience, larger facilities tend to operate more efficiently and economically with fewer permit excursions. The opportunity posed to provide better treatment and address high flow problems at the VCHWTP is one mitigating factor. Also, the reduction in overall phosphorus loading to the Lake from point sources is a positive for the Lake. By receiving treatment at the VCHWTP, the wastewater from the Town of Lansing will be treated to remove nutrients to a degree that would not be the case if it were discharged to the deeper portion of the Lake. The amount of phosphorus that would enter the Lake from the Town of Lansing flows is far less than the reduction in phosphorus that will be achieved with the planned phosphorus treatment upgrades at the WWTPs. Thus the total loading of phosphorus to Cayuga Lake will be greatly reduced. See Response to Comment 27 below for more information on'phosphorus loadings. 9. Comment. The DEIS lacks documentation of the critical state of the southern end of Cayuga Lake. The addition of more phosphorus to this shallow end will only increase the problems to the Lake. (F. Gougakis in 8111103 letter) Response: See Response to Comment 4 above. 10. Comment: The EIS should analyze the impact of reallocating wastewater to, and concentrating treated effluent in, point discharges to the southern, impaired end of Cayuga Lake. One commenter said this analysis should include how additional loading might impact aquatic biota and algal and weed growth and influence levels of dissolved oxygen. Another commenter noted the Lake's 303(d) listing and said the EIS should discuss the extent to which the project would mitigate water quality problems at the southern end of the Lake. Another commenter said the DEIS does not make a convincing case that implementation of this project will improve water quality problems in the southern end of the Lake. Absent documentation of what the project will mean in the way of addition of nutrients and chemicals to the impaired waters of southern Cayuga Lake, it is impossible to conclude that the project is the best one can do. (D. Kiefer in 8111103 letter; E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Table F-1 and Response to Comment 4 above. 11. Comment: The EIS should acknowledge and discuss the possible biological impacts of the increased WWTP effluent in the impaired waters of the Lake, especially with respect to its reactive -chlorine content and the further concentration of human -excreted drugs. Science is just learning about how, for example, hormones in sewage effluent affect reproduction and the sex of aquatic organisms. As yet, there are no known ways for WWTPs to handle this. This is another reason not to combine/increase effluent streams. (D. Kiefer in 8111103 letter) Response: This comment is not relevant to the project because the WWTPs will be operating within their permitted limits. Impacts of increased amounts of flows were considered when the IAWWTP's SPDES permit underwent environmental review. That said, the amount of chlorine residual entering the southern part of the Lake will not change significantly from current conditions. The IAWWTP dechlorinates its effluent prior to discharge into the Lake, and its SPDES permit limits total residual chlorine to 0. mg/L, which is equivalent to one -tenth of a part per million. The VCHWTP does not dechlorinate its effluent, but the flow treated at that plant will not increase. WWTPs currently do not have special treatment for human -excreted drugs. The increase in flow attributed to the Town of Lansing (annual average of 0.144 mgd initially and 0.441 gpd in 20 years) is a relatively minor fraction of the average combined flows to the two WWTPs (9.19 mgd initially; 9.49 mgd in 20 years.) The Town of Lansing flows will - make up only 1.6% of the annual average flows to the two plants initially and 4.6% after 20 years. The concern raised over concentration of human -excreted drugs in the Z southern Lake is not significantly affected by the relatively low levels of flow projected from the Town of Lansing. LEGALITY OF INCREASED FLOW 12. Comment. Southern Cayuga Lake violates New York State's narrative water quality standard for phosphorus. Algal blooms and rotting and floating weeds cause aesthetic impairments and odors and hinder navigation. Additional phosphorus must not be allowed into the Lake's impaired area from new or expanded point sources. Any increased flow through the IAWWTP into the impaired part of Cayuga Lake on the 303(d) list would constitute a "new or expanded discharge" as prohibited by 40 CFR § 122.4(i). (R. DePaolo in 8111103 letter) Response: The listing of Cayuga Lake on New York State's 303(d) list requires that a TMDL be developed that would identify the point and nonpoint source reductions of phosphorus necessary to restore the designated use. DEC does not believe that there is sufficient information to develop a TMDL at this time. Since the WWTPs will be operating within the limits set by their respective SPDES permits, flows from the project are not considered flows from a "new source or a new discharger," as those terms are defined in the regulations. (Note that this is the regulatory standard, not "new or expanded discharge" as the commenter states.) The increased flows through the IAWWTP will come from the current VCHWTP service area. These are flows that are currently discharged into the south end of the Lake through the VCHWTP outfall. This diversion will free up capacity at the VCHWTP for new Town of Lansing flows. The total loadings of phosphorus from the WWTPs are expected to be far less after the proposed project and phosphorus upgrades are completed than current conditions. See Responses to Comments 4 above and 27 below for more information on phosphorus loadings. 13. Comment: Wastewater collected in the proposed service area was originally intended to be treated by a new facility requiring a discharge permit. Such a permit would have been prohibited by the federal moratorium in 40 CFR § 122.4(i), which prohibits the issuance of discharge permits to "a new source or a new discharger, if the discharge from its construction or operation will cause or contribute to violation of water quality standards. " Conveying the wastewater to the permitted M WWTP by-passes this critical non -degradation standard. (W.. Hang at 7131103 Public Hearing and in 816103 letter) Response: See Response to Comment 12 above. 10 EFFECTS OF 303(d) LISTING AND TMDL PROCESS 14. Comment: Despite the fact the southern 5, 000 acres of Cayuga Lake is on the federal 303(d) list and is designated as high priority for TMDL development, DEC has not investigated the problems nor taken action to eliminate them. The EIS should analyze the current regulatory backdrop against which the project is proposed, including proposed TMDL development. DEC should analyze project impacts in connection with a TMDL study and should define the regulatory backstop that guarantees the project will not contribute to existing water quality standards violations in southern Cayuga Lake. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: As noted in Response to Comment 12, the WWTPs will be operating within their permitted limits and total point source loading to the Lake will be significantly reduced. Regarding the TMDL process, the DEC has agreed to perform an evaluation of the phosphorus loadings to the southern shelf of the lake. The EIS does not supplant the DEC's regulatory responsibilities, nor should it be delayed pending DEC's evaluation. If as a result of the TMDL process further reductions in phosphorus point source loadings are required, DEC will require such reductions through all necessary means, including WWTP SPDES permit modifications if required. 15. Comment: DEC has made no tangible progress to institute a TMDL pollution control program, even though southern Cayuga Lake is a high priority for such a program. One commenter said DEC rejected the Environmental Protection Agency's offer in 2001 to help fund a water quality study and DEC has not developed or adopted any TMDLs since Cayuga Lake was listed on the 303(d) list in 2002. The project should be approved only after the TMDL is implemented or other regulatory safeguards are imposed to assure no further degradation of water quality. Another commenter said a TMDL should be in place before this project or any new wastewater treatment plant is constructed. (W.. Hang at 7131103 Public Hearing and in 816103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 14 above. 16. Comment. The southern end of the Lake is on the national 303(d) listing and is a priority for TMDL development. DEC should be extremely careful about adding any discharges to this area. ' (D. Kiefer in 8111103 letter) Response: See Response to Comment 14 above. 11 DEC ACTIONS REGARDING OTHER PROJECTS AFFECTING CAYUGA LAKE 17. Comment: DEC has failed to enforce the federal moratorium provision by granting a discharge permit to the Lake Source Cooling Project. One commenter said Lake Source Cooling contributes nearly 10% of the phosphorus entering southern Cayuga Lake. Another commenter said despite a recommendation by a Town of Ithaca consultant, there is no monitoring near Lake Source Cooling s outfall, and the commenter is very concerned about DEC's standards and ethics. Other projects are not allowed in shallow waters, and Lake Source Cooling should not have been allowed. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter) Response: This comment is not relevant to the project. The Lake Source Cooling permit was legally issued after extensive review by the public and DEC. i 18. Comment: The commenter asks why DEC has failed for years to address problems at the VCHWTP and expresses concern about the possibility that Cornell University's veterinary school waste might be discharged to the IAWWTP. This commenter wants DEC to address these and other impairments before allowing more waste into the southern basin. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) i Response: The project includes a diversion to eliminate VCHWTP exceedances of permitted flows. In addition, DEC is funding improvements (independent from the project) to the VCHWTP. The improvements include effluent filtration and chemical addition for enhanced phosphorus removal; the addition of baffle wall within one of the two final settling tanks to improve performance; and replacement of trickling filter media for improved wastewater treatment reliability. The discharge of Cornell University's veterinary school waste into the IAWWTP is independent from the project and is still in the discussion stage. Should that plant agree to accept such waste, it would have to be treated so that all of the parameters and limits in the plant's SPDES permit are met. SEGMENTATION 19. Comment: The IAWWTP SPDES permit modification and the project are illegally segmented. As a result, it is impossible to quantify the water quality impacts from the project. (R. DePaolo at 7131103 Public Hearing) 12 Response: There is no illegal segmentation, the water quality impacts are quantifiable, and the impacts of a 13.1 mgd flow were considered during the SEQRA review of the plant's permit modification. As the Scoping Responsiveness Summary noted, the IAWWTP owners requested an increase in capacity in 1995 because the 10 mgd flow limit had been reached (and actually exceeded on at least two occasions). The plant owners asked for the additional capacity to keep the plant in compliance. Their request for 13.1 mgd was based on an engineering study, which indicated the plant capacity could be increased to 13.1 mgd with minor improvements and modifications, which were made in 1997. The City of Ithaca conducted a SEQRA review on the permit modification in 1996 and issued a Negative Declaration. The project that is the subject of this EIS had not been developed and was not under consideration at that time. The Town of Lansing instead was pursuing its own wastewater treatment plant at Portland Point in Lansing. It applied for Clean Water/Clean Air Bond Act funding for a stand-alone plant in 1997. The current project was developed only after Bond Act funding was denied to the local municipalities for their individual projects, and the DEC urged them to come up with a regional solution for wastewater treatment needs. Segmentation has not occurred. The SPDES permit modifications are not dependent on or driven by the project. The IAWWTP needed the increased capacity regardless of whether service areas are added, and it applied for the increased capacity well before the municipalities started developing the project that is the subject of this EIS. In addition, the DEC's approval of the increased capacity does not commit the municipalities and agencies to approving the various elements of the project, nor have environmental impacts evaded review (which is the concern about segmentation). The environmental effects of an increase in capacity to 13.1 mgd were considered in the City's SEQRA review. The effects of a 13.1 mgd discharge on Cayuga Lake are the same regardless of whether the flow comes from within or outside the current service area. 20. Comment. Application of DEC's 8-part test shows segmentation has occurred. There is: a common purpose or goal for each segment; a common reason for each segment being completed at or about the same time; a common geographic location; a common impact that may result in a potentially significant adverse impact if the activities are reviewed as one project; and common ownership or control of the different segments. A given segment is a component of an identifiable overall plan and the initial phase directs the development of subsequent phases; the phases are functionally dependent on each other; and DEC undertook concurrent review of funding and permit modification requests for both segments. Without the project, there would be little need for increased capacity at the IAWWTP. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See Response to Comment 19 above. In addition, application of DEC's 8-part test shows the following. 13 • Is there a common goal? In 1994, the IAWWTP owners identified an opportunity to have DEC increase the plant's permitted capacity at very low cost if they made final settling weir and baffle improvements and increased influent pumping capabilities. The fact the 10 mgd flow limit had been exceeded on two occasions, coupled with the fact the permitted capacity could be increased through implementation of low cost improvements, led to the request in 1995 for an increase in capacity. The IAWWTP owners' consistent goal was to get this low- cost increased capacity, regardless of what happened with the project that is the subject of this EIS. • Is there a common reason for completing each segment at or about the same time? While it is true the flow diversion from the VCHWTP could not occur before an increase in capacity at the IAWWTP, there is no reason to have the increase in capacity occur "at or about the same time" as the flow diversion. The IAWWTP permitted capacity expansion could and did occur without the flow diversion. • Is there a common geographic location? The answer to this depends on how one defines each project's location. Obviously, the IAWWTP is involved in both the permit modification and the project. But many elements of the project are located in the Town and Village of Lansing and the Village of Cayuga Heights as well. The actual flows from the Town of Lansing will flow to and be treated at the VCHWTP, with other flows diverted to the IAWWTP. • Is there a common impact that may result in a potentially significant adverse impact if the activities are reviewed as one project? This query seeks to determine whether impacts from two or more projects, which may be insignificant when reviewed separately, become significant when the projects are reviewed together. As stated in Response to Comment 19, the effects of a 13.1 mgd discharge on Cayuga Lake were reviewed in 1996 when the City of Ithaca issued a Negative Declaration. The impacts are the same regardless of whether the flow comes from within or outside the current service area. There are no additional impacts to the south end of the Lake from the addition of flows diverted from the VCHWTP because the total discharge will be less than 13.1 mgd. No different or more significant impacts to the southern Lake could possibly have been identified if the projects had been reviewed together. • Is there common ownership or control of the different segments? The IAWWTP is owned and operated by the City of Ithaca, Town of Ithaca, and Town of Dryden. This ownership and control is expected to remain the same regardless of whether the diversion and/or service area expansions occur. The VCHWTP is owned and operated by the Village of Cayuga Heights. Pump stations and public sewers in the Town of Lansing will be owned and operated by the Town of Lansing. The Town of Lansing will also own and operate a transmission main that is proposed to cross the Village of Lansing and a portion of the Village of Cayuga Heights. Public sewers in the Village of Lansing will be owned and operated by the Village of Lansing. • Is a given segment a component of an identifiable overall plan? At the time of the City's SEQRA review of the 13.1 mgd discharge, the plan that is the subject 14 of this DEIS had not been developed. In fact, the project sponsors undertook a lengthy planning process to arrive at the plan which is the subject of this EIS. This process did not begin until long after the City's SEQRA review was completed. Are the phases functionally dependent on each other? Flows could not be diverted from the VCHWTP without the IAWWTP capacity expansion. However, the IAWWTP capacity expansion is not dependent in any way on the flow diversion. • Does the approval of one phase commit the agency to approval of other phases? (Note that this last test in the SEQR Handbook is different from that set forth in the commenter's letter.) The answer to this query is no. Approval of IAWWTP's increased capacity request does not commit the project sponsors, DEC, nor other agencies to approval of the various components of the project. 21. Comment: Although the initial application to modify the IAWWTP's SPDESpermit was made before the project materialized, DEC continued to review the application for four years after rejecting separate funding applications and suggesting a regional wastewater management approach, for three years after accepting joint grant applications, and for two years after becoming Lead Agency on the project. A DEC SPDES permit writer told this commenter the length of the review period was due to the fact the permit limit for phosphorus was "revisited several times " during the review process. Review of the permit modification should have been joined with review of the project. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19 and 20 above. There were a number of reasons the period between permit modification application and permit issuance was so long, including personnel changes at DEC. 22. Comment: To remedy the segmentation, the EIS should include IAWWTP historical and projected phosphorus loading analyses, and DEC should revoke or suspend the IAWWTP's SPDES permit and rewrite it to reflect the effects of the planned tertiary phosphorus treatment and the increased effluent posed by the project. The rewritten permit should adhere to Technical and Operation Guidance Series (TOGS) 1.2.1 and 1.3.6, which govern the processes by which phosphorus limits are calculated for expanded discharges into lakes. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19-21 regarding the segmentation comment. Because there was no segmentation, there is no need to revoke or suspend the IAWWTP permit. Historical and projected phosphorus loading analyses for the IAWWTP and VCHWTP are presented in Table F-1. The IAWWTP SPDES permit contains a Fact Sheet that 15 establishes the procedure for the establishment of new limits to reflect the effects of the planned tertiary phosphorus treatment, which is expected to begin operation in the early Fall of 2004. The new limit will be based on actual performance of the plant once the new phosphorus treatment has been in operation for eighteen (18) months. Based on the technology and manufacturer's warranty for the equipment that is being installed, the new limit is not expected to exceed 0.2 mg/L. IAWWTP SPDES PERMIT MODIFICATION 23. Comment: The IAWWTP's modified SPDESpermit allows a 37% increase in mass loading of phosphorus over historical performance in contravention of the "no net increase " provision in TOGS 1.3.6 and TOGS 1.2.1. It appears the permit limit for phosphorus was artificially inflated to allow the capacity needed for the project. (R. DePaolo in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. We believe the commenter intended to reference TOGS 1.3.6 and 1.3.1 (not 1.2.1), so this response is based on information and guidance contained in TOGS 1.3.6 and 1.3.1. Before the IAWWTP permit modification, its then -existing permit required reduction of phosphorus to 1.0 mg/L on a 30-day average basis. This concentration -based limit and the 10.0 mgd flow limit for the plant established a maximum phosphorus loading of 83.4 lbs/day. TOGS 1.3.6 establishes phosphorus removal requirements for new and expanded discharges to lakes or in lake watersheds. The process used by the DEC for the new permit limit is based on TOGS 1.3.6 and statistical analysis of plant performance data from January 1996 through September 2000. Guidance criteria stated in TOGS 1.3.6 requires that: "...any proposed expansion of an existing discharge within a lake watershed, which would require a modification of an existing SPDES permit, should provide BTT [Best Treatment Technology] for phosphorus removal to a degree that the annual quantity (mass loading, flow multiplied by concentration) of phosphorus discharge after the modification does not exceed the phosphorus discharge prior to the modification." The DEC has interpreted this to mean that the discharge of phosphorus after the modification cannot exceed the current (historical) level of phosphorus, not the permitted allowable level of phosphorus. In order to determine the current level of phosphorus being discharged, the DEC completed a statistical analysis of plant data from January 1996 through September 2000, to calculate the 95th percentile effluent phosphorus mass loading. This statistical analysis yielded a limit for phosphorus of 40 lbs/day. The limit was set at 40 lbs/day because, in 16 accordance with DEC's standard methodology, 95% of the 46 twelve-month rolling average data points fell below 401bs/day. Note that the data in Table F-1 cannot be used to calculate the limit, because the Table F-1 data are actual annual averages (not 12- month rolling averages) which are intended to show the average reduction in phosphorus discharged to the Lake. Table F-1 does not represent a statistical analysis of the data. It is important to note that the modified phosphorus effluent limit of 401bs/day represents a greater than 50 percent reduction in mass loading of phosphorus versus the plant's previous permit limit of 1.0 mg/L or 83.4 lbs/day. In setting the new limit, the DEC recognized that the facility actually discharged significantly less phosphorus than what was permitted. The purpose of the modification was to set a no net increase limit on an annualized basis. It should also be pointed out that the modified limit does not reflect advanced phosphorus removal technology. As mentioned in Response to Comment 22, a project is currently underway to provide for an advanced phosphorus removal facility. The SPDES Permit Fact Sheet recognizes that the existing phosphorus limit will be further decreased once the construction is completed and operation of the new facility is underway. 24. Comment: DEC issued a revised SPDES permit for the IAWWTP that allows an increase in phosphorus discharge from less than 30 pounds per day to up to 40 pounds per day. Two commenters state that DEC ignored its own regulatory policy (TOGS 1.3.6) by approving this revision. (W.. Hang at 7131103 Public Hearing and in 816103 letter; R. DePaolo at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 23 above. 25. Comment. If wastewater flows are higher than projected, phosphorus loadings could increase beyond the historical 30 pounds per day, and the sponsors would be within their legal rights. This commenter asked DEC two years ago to revoke or modify the SPDES permit on the grounds ofgrave material falsehoods and the 37% increase in phosphorus loadings. The commenter provided DEC with a detailed statistical analysis performed by a Cornell University statistics professor that showed the 37% increase. DEC has never responded, even though this commenter was promised an answer 18 months ago. It seems likely DEC did not respond in order to allow the SEQRA process for the project to proceed without the benefit of technical insight into the creation of the IAWWTP permit. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. The technical basis for the creation of the IAWWTP permit is explained in the permit's Fact Sheet. As stated in Responses to Comments 23 and 24, the 95 percent statistical recurrence of effluent phosphorus loads (as determined by the DEC) from the IAWWTP 17 is 40 lbs/day, not 301bs/day as stated by the commenter. Therefore, the permit establishes a "no net increase" in allowable phosphorus load discharged from the IAWWTP. The statistical analysis by the Cornell University statistics professor relied on only two years of historical plant flow data, whereas the DEC analysis relied on nearly five years of historical data. (The SPDES Permit Fact Sheet contains a typographical error that says DEC used 3 years of data.) The two years of data used by the professor generates a data set of 12 data points, which DEC believes is not a large enough data set to perform the statistical analysis because it is not a good representation of fluctuations in climatic changes. In comparison, DEC's data set between January 1996 and September 2000 yields 46 data points. Although the commenter has stated the older data is not representative because of subsequent improvements to the IAWWTP and its collection system, those improvements were not done to increase phosphorus removal and did not impact phosphorus loadings or reductions. PHOSPHORUS UPGRADE & LOADINGS 26. Comment: The DEIS contains no information on the phosphorus removal project that is currently out for bid at the IAWWTP. The scoping documents mentioned this project. This commenter thinks the phosphorus removal elements were taken out of the DEIS to avoid a focus on water quality issues. The FEIS should reference the phosphorus removal component. (R. DePaolo at 7131103 Public Hearing) Response: Contrary to the commenter's assertion, the phosphorus removal project was not included in the Scoping Document. The Overview Document previously released to the public states that the IAWWTP phosphorus removal project is independent from the diversion project and would not be part of the EIS. The Overview Document further states that the IAWWTP phosphorus removal project was a Type II action under SEQRA and further SEQRA review was not required for it. 27. Comment: The project would undercut or eliminate the benefits of a proposed phosphorus removal upgrade to the IAWWTP. That facility currently removes phosphorus to less than 0.7 milligrams per liter (parts per millions (ppm)) on a 12-month rolling basis. Approximately 27.5 pounds of phosphorus are discharged daily into the Lake. After the upgrade, phosphorus would be reportedly removed to less than 0.2 ppm on a 12-month rolling average. The project will generate wastewater containing 25 to 36 pounds per day of phosphorus, or 11 % to 16% of the 220 pounds of phosphorus now received by the IAWWTP. That contribution would off -set improved phosphorus removal at the upgraded plant. If wastewater generated by the proposed project exceeds DEC's estimate, there could be a net increase in phosphorus discharged into the Lake, because the IAWWTP's revised SPDES permit allows up to 40 pounds per day of phosphorus discharge. (W. Hang at 7131103 Public Hearing and in 816103 letter) In Response: See the last paragraph of Response to Comment 1. This comment uses incorrect numbers and double -counts existing VCHWTP flows that will be diverted to the IAWWTP. Even with the addition of flows from the Town of Lansing, the amount of phosphorus discharged to the south end of Cayuga Lake will be reduced by between 57 and 70 percent. The discussion presented is flawed in that it states, "The proposed project is estimated to generate wastewater containing 25 to 36 pounds per day of phosphorus" when actually only 11 lbs/day initially and 31 lbs/day in 20 years will be collected by the Town of Lansing sewers installed as part of this project. These amounts will be treated by the VCHWTP and reduced to less than one-fourth lbs/day of phosphorus initially and less than three -fourths lbs/day in 20 years before it is discharged to Cayuga Lake. The flows diverted to the IAWWTP are existing flows from the VCHWTP service area, and, therefore, they do not add an additional phosphorus load to the Lake because they are currently discharged to the south end of the Lake through the VCHWTP outfall. With the phosphorus treatment upgrades at the two plants, the total amount of phosphorus being discharged to the south end of Cayuga Lake will be reduced from a current annual average load ranging from 33.5 to 44.8 pounds per day (combined discharges from the IAWWTP and the VCHWTP) to approximately 15 lbs/day initially (including the additional initial flow collected in the Town of Lansing). 28. Comment: If DEC continues to support the project, then it should be redesigned to prevent further degradation of Cayuga Lake. The phosphorus pollution generated by the project should be measured as it flows into the VCHWTP and the sponsors should clean UP at least twice that amount elsewhere in the Lake's watershed. For example, artificial wetlands at the mouth of Cayuga Inlet could control phosphorus from stormwater runoff, and buffer zones could be established along agricultural areas to prevent fertilizer runoff into Lake tributaries. A study could be undertaken to determine if Lake Source Cooling water could be used as potable drinking water and be treated before discharge back to the Lake. The main polluted area of the Lake flows away from Lake Source Cooling s intake and directly towards Bolton Point's intake, which is directly downgradient from wastewater discharged into the Lake. (W.. Hang at 7131103 Public Hearing and in 816103 letter) Response: The WWTP owners will accomplish far more than what this commenter has requested. Flows from the Town of Lansing sewers will result in one-fourth of a pound per day of phosphorus initially and less than three -fourths of a pound per day in 20 years discharged to the Lake. With the installation of phosphorus treatment, the WWTPs' loadings of phosphorus will decrease in the range of 20 to 31 pounds per day. 29. Comment: The VCHWTP is outmoded and lacks state-of-the-art phosphorus removal. That facility lags behind the IAWWTP's efforts to upgrade its phosphorus removal 19 capability. That problem should be rectified. (W.. Hang at 7131103 Public Hearing and in 816103 letter) Response: The VCHWTP will be upgraded for advanced phosphorus removal and it is expected to remove phosphorus to a level of 0.2 mg/L or better. Money has been awarded from the Clean Water/Clean Air Bond Act for this upgrade. CONSTRUCTION 30. Comment. The EIS should include details about the actual construction and installation of sewer lines in the Lansing Service Area, such as the size of the construction right-of-way, how deep lines will be buried, and what the area of disturbance will be. The FEIS should use this information to analyze construction impacts on stream corridors, instream habitat, wetlands, and Unique Natural Areas (UNAs) in the Lansing Service Area, and the construction plans for the Lansing Planning Area should address these impacts. (E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Traditional sewer pipe installation using open -cut methods of trenching can typically be accomplished within a footprint of 30 feet. Permanent easements are normally 20 feet wide. The depth of construction is variable and will not be known until final design profiles are prepared. At a minimum the depth of cover on small diameter gravity or forcemain sewers will be approximately 4-5 feet. Field verification of construction impacts will be made at the time construction routes are finalized. 31. Comment: The FEIS should detail what is to be included in each construction plan. Construction plans should address minimization of sedimentation and erosion; describe in the blasting plan how construction and pipe locations might impact private drinking water sources from bedrock wells and describe mitigation measures for such impacts; and analyze impacts from potential staging areas. Construction staging areas should be located outside of any UNAs. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The DEIS indicates that appropriate measures will be implemented to mitigate these construction related impacts. These measures will be detailed on construction plans and in the specifications. Construction documents for the'pipeline and pump station projects will include requirements for erosion and sediment control (i.e. silt fence, dewatering of excavations, stabilizing exposed soils); rock removal by blasting with appropriate monitoring; and approved areas for establishing materials and equipment storage. Such plan details and specifications will be tailored to the specific work sites once final sewer main routes are determined. Construction staging areas will be located outside of UNAs wherever possible. 20 UNIOUE NATURAL AREAS 32. Comment: The existing maps of UNA boundaries are not exact. Placement of a sewer line on a boundary does not necessarily mean that there will be no impacts to the flora and fauna, geological structures, habitat, etc. that are found in the area. The FEIS should explore alternative transmission routes along road beds or routes further away from UNAs. The FEIS should also consider trenchless digging as an alternative in the UNAs. Alternate locations should be considered for the two pump stations that are proposed in the UNAs in the Lansing Service Area. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: To the extent practicable, preliminary sewer main routes in the Town of Lansing Service Area have been selected to avoid the general extents of the UNAs. The proposed gravity transmission main along the former Ithaca -Auburn railroad bed will traverse UNA-89, UNA-102 and UNA-103 and an alternative forcemain design has been evaluated along Cayuga Heights Road. A subsequent forcemain design along the Norfolk Southern railroad right-of-way is described in Response to Comment 33. Trenchless technology for installing sewer mains has been identified in the DEIS as a mitigation measure to be implemented for avoiding disturbance of specific surveyed natural features within the UNAs. The proposed Myers Road pump station lies within UNA-55 and will be sited in the vicinity of the Myers Road and Lakeshore Road intersections. The majority of the land in this area was once utilized for gravel mining. The Portland Point pump station will be located west of UNA-63 within the extents of the former industrial disturbance. 33. Comment: The EIS should examine the possibility of running the Town of Lansing- VCHTf TP transmission line along the existing Norfolk Southern railroad line, which is already a highly and frequently disturbed area. This would eliminate the need for pumping stations and habitat destruction that would be necessary with the other routes discussed in the EIS and there would be easy access to the rail bed, which would decrease the cost of maintenance and repair. (L. Leopold in 8111103 letter) Response: T.G. Miller, P.C. has explored the permit requirements and physical constraints of a "longitudinal occupation" within the Norfolk Southern Railroad right-of- way. The Norfolk Southern pipeline offset requirements dictate that a sewer main must be installed roughly 24 feet from the rail centerline. Occupation along the west side of the rail places the main in the waters of Cayuga Lake for a majority of the 5 mile route. Land availability east of the rails varies considerably. At several locations the extensive rock cliffs are within 5 to 6 feet of the eastern rail. To conform to the offset requirements it will be necessary to remove substantial faces of the rock cliff. This removal would negatively impact the steep slopes east of the present cliff edge. 21 Due to the physical constraints noted above, access to and along the railroad bed is not sufficient for either initial construction or future maintenance as long as the rail remains in use. Further, the construction cost for this alternative as estimated in the T.G. Miller analysis will minimally be 2-2.5 times the cost of the Cayuga Heights forcemain alternative. Based on these factors the Norfolk Southern Railroad alternative is not viable at this time. 34. Comment: These commenters strongly support the alternative transmission route along Cayuga Heights Road proposed for the Twin Glens and Esty's Glen UNAs. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Comment received and noted. 35. Comment. As recommended in the DEIS, a biological survey should be conducted of the proposed interceptor route in UNA 103, McKinney's Twin Glens and Lake Cliffs. One commenter wants this survey to inform a decision as to whether trenchless construction should be used (as recommended in the DEIS), and requested this survey be done before the end of the SEQRA process. Another commenter suggested the survey be used to decide whether the sewer route should be diverted away from the UNA, and requested the survey be conducted during the appropriate time of year to reveal the potential plants or animals impacted. (E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Prior to any final selection of the Ithaca -Auburn railroad transmission route a survey will be conducted by qualified professionals to identify the important natural communities and rare/scarce plants or animals within close proximity to the route. The identification of rare or scarce plants will be conducted during the appropriate season(s). The width of the survey corridor will be determined after consultation with the professionals. The approximate limit of the corridor within UNA-89 and UNA-103 is between the south end of Cayuga Hills Road and the existing Village of Lansing sewer transmission main below Cedar Lane. A land survey will then be performed to map the identified communities and plants in order to assess the feasibility of using trenchless technology or to completely avoid the corridor. 36. Comment: The construction of a pipeline through UNAs 103 and 89 would necessitate the removal of a large number of medium-sized and mature hemlocks in the Twin Glens area, which are irreplaceable and create a beautiful visual scene. These areas have had 75 years to grow into forest and many local residents enjoy them year- round. No amount of mitigation can restore these areas in our lifetime if this pipeline is 22 built through this area. The EIS is meant to deal with and prevent preventable environmental impacts. (L. Leopold in 8111103 letter) Response: See Response to Comment 35 above. 37. Comment: The commenter is concerned about the environmental impacts of digging in UNAs and asks how often connectors would be built in forested escarpment areas to reach the transmission interceptor. (J. Dennis at 7131103 Public Hearing) Response: The proposed Ithaca -Auburn railroad transmission main does not include or anticipate the construction of additional connectors through forested escarpment areas. 38. Comment: The Existing Conditions section of the DEIS should note that UNA 103, McKinney's Twin Glens and Lake Cliffs, contains a section of the old Ithaca Auburn Shortline that crosses the glen. If sewer lines will run close to remaining abutments and a trestle from the old Ithaca -Auburn Shortline, the FEIS should assess the impacts of the sewer lines on these features, which may have historic or cultural significance. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: With modifications, the abutments of the Ithaca -Auburn Shortline railroad at the southerly glen could support a pipe bridge. The Stage I Cultural Resources Survey did not identify these abutments as having historical or cultural significance. Further, there is no remnant of a "trestle." There are two existing pipe bridges south of Cedar Lane that support the Village of Lansing sewer transmission main. 39. Comment. The EIS has very little information about mitigation of impacts in UNAs. (J. Dennis at 7131103 Public Hearing) Response: Mitigation for impacts to UNAs is adequately discussed in DEIS Section 4.4.2 and the sections referenced therein. Additional mitigation measures are discussed in Responses to Comments 31 and 35. WETLANDS 40. Comment. The EIS should consider an alternate route for the sewer lines that are proposed to cross UNA 65 (Head Corners Wetland), and DEC should be consulted prior to any disruption of the area. The commenter supports the DEIS suggestion that a 23 wetland scientist should survey the area and make recommendations for limiting impacts to this wetland. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The potential for crossing the Head Corners wetland exists in a future phase for which no definite plans have yet been formulated. Based on the assessment in this EIS, an alternate route for a sewer line in the vicinity of this wetland will be analyzed if and when future sewer extension plans are developed. 41. Comment: Care should be taken to preserve and protect wetlands throughout the study area. In addition to the impacts noted in the DEIS, loss of wetland function can have negative impacts on surrounding lands due to flooding, and can cause problems associated with water quantity and quality in stream corridors and eventually in Cayuga Lake. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Comment noted. The proposed project will not have any direct impact to wetlands, as stated in the DEIS and confirmed by FEIS Figures 1 and 2 in Section III. See also Response to Comment 43. 42. Comment: When the location of sewer lines is determined, a wetlands scientist should conduct a more complete analysis of potential wetlands impacts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Field verification of the EIS conclusion that no wetlands will be impacted will be made at the time construction routes are finalized. 43. Comment: The EIS should contain a map showing all wetlands overlaid with the proposed sewer lines at a finer scale (for example, 1: 24, 000) than that used in Figures 17 and 18. The EIS should also combine the information in Figures 44 and 45 into one map shown in an additional figure. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: More detailed maps of wetlands in relation to proposed sewer routes are found in FEIS Figures 1 and 2. These figures confirm the DEIS conclusion that the proposed Service Area sewers will not impact wetland areas. The potential impacts of Planning Area sewers are accurately discussed in the DEIS. 24 WATER RESOURCES i 44. Comment. Sewer line routes should be designed to reduce impacts to known private wells and public drinking water supplies (such as those at Myers Point, Ludgate's, and the Plantations Inn). (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: FEIS Figure 3 in Section III illustrates the proximity of proposed sewer lines to known public drinking water supply sources. No such sources are located in close proximity to proposed sewer lines such that they would be impacted by the project, with the possible exception of the well point on Burdick Hill. Mitigation for potential impacts to this supply is discussed in Response 46. 45. Comment. There is no discussion of how to mitigate the impact that trenching activities would cause on a residential drinking water supply that exists in the form of a ' large cistern at 1203 East Shore Drive that lies directly below the former Short Line railroad bed. This was brought up during the scoping session but is not mentioned in the DEIS. (L. Leopold in 8111103 letter) Response: This supply is discussed at DEIS page 70. Mitigation of impacts from potential leaks or a break in the line is discussed at DEIS page 74. It is proposed that the transmission line be double sleeved within 100 feet of this water supply. To the extent there may be potential construction impacts from trenching activities, during construction the location of the cistern will be marked in the field and all construction activities will be maintained at a safe distance from the cistern to avoid adverse impacts. The safe distance will be determined in the field based on soils characteristics. 46. Comment. The DEIS states at page 31 that there are numerous private wells located throughout the Study Area that have not been comprehensively mapped. Some of these well points are regulated public water systems, and these have been mapped. The data for these wellheads is available through the Tompkins County Planning Department. There are few, if any, regulated public water systems in the service area, as most of the service area is already served by municipal water. If the final plans do indicate impacts ( on a regulated water system from sewer construction, the system may need to be abandoned and the municipal water systems used if available. (J Andersson, Tompkins County Health Department in 6125103 letter) Response: Known public water supplies are mapped in FEIS Figure 3. The Tompkins County Planning Department supplied the data about these wellheads. There is no available mapping of private wells. No wells for which information is known are found in proximity to proposed sewer lines, with the exception of the private source discussed in Response to Comment 45, and possibly the Burdick Hill well point. Mitigation for the 25 former is discussed in the DEIS and in Response to Comment 45. With respect to the latter, similar mitigation (such as double sleeving of the sewer line within 100 feet of the well point) will be implemented if the line is found to pass within 100 feet after construction plans are developed. 47. Comment: Section 4.5.1 (Impacts to Water Resources) should acknowledge that there could be negative impacts to well heads and mitigation should be recommended, where possible. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 44. GROWTH -INDUCING IMPACTS 48. Comment: The sponsors should consider the following growth -inducing impacts in addition to those identified in the DEIS: The adequacy of public water supplies and private drinking water wells (since induced growth may increase the demand for public and private drinking water supplies). Increased congestion of specific transportation corridors that could result from the density and intensity of land uses allowed in a particular area and the timing of sewer line extensions. Local comprehensive plans should carefully evaluate these relationships between infrastructure and land use. The transportation demand model used in the DEIS dilutes the traffic impacts by spreading them throughout the study area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment noted. The relevant municipalities will need to determine whether adequate drinking water supplies exist in the locations of proposed sewers. Adequate supplies currently exist in the proposed Lansing Service Area; decisions about water supply adequacy in the Lansing Planning Area and Dryden Study Area will need to be made if and when sewers are proposed in those areas. The relevant municipalities should also consider the potential transportation impacts of proposed land use patterns and traffic mitigation. Mitigation could include, among other things, mixed use development patterns that take advantage of or enhance transit connections, and links and facilities for pedestrians and bicycles. The use of the word "dilutes" is not completely accurate in the comment about the transportation model. Volumes of traffic for specific links and intersections are projected with a dynamic model that assumes people will shift their patterns if a specific link or intersection becomes too congested. So the model makes traffic assignments using the entire road network. As a result, one may find that development spread out over an area 061 may show insignificant traffic impacts (such as no system failures at specific links or intersections), particularly if the area has a dense road network. If there are few roads, they tend to capture all the traffic and the model starts to report capacity problems. 49. Comment. The project will trigger a large amount of building. The EIS has very little information about induced housing growth in new areas. (J. Dennis at 7131103 Public Hearing) Response: The DEIS contains an extensive discussion of induced growth in Section 6. Table 31 on page 100 specifically estimates the number of dwelling units which may be constructed in the Study Area under three scenarios. The remainder of Section 6 analyzes the impact of such development. 50. Comment: Sewers will induce growth, which will lead to non point source impacts on the Lake caused by lawn fertilization and stormwater runoff. How do we know there will be a positive offset in taking septic systems off-line? (R. DePaolo at 7131103 Public Hearing) Response: See Response to Comment 4 above. Among other things, the project will correct a significant problem with respect to failing septic systems. It is true that growth may have other impacts. The purpose of the induced growth analysis in DEIS Section 6 is to provide the affected municipalities with information about the amount of growth that may occur in order that they may formulate land use policies to avoid adverse impacts. ALTERNATIVES 51. Comment. DEC has made it clear throughout this planning process that it would only support an intermunicipal solution. The DEIS does not show that the project is better than the alternative of constructing a state-of-the-art satellite treatment plant for the Town of Lansing that would release effluent into a deeper, more northern, and less impaired portion of the Lake. Although DEC did not approve funding for this alternative, it is still a real alternative, and the EIS should discuss this alternative in more detail. One commenter requested that another map/figure be added to the EIS showing possible location and depth of discharge for a new WWTP, as well as the Lake depths in that area. One commenter believes DECpushed the intermunicipal solution for fiscal reasons as much as for environmental reasons. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; L. Leopold in 8111103 letter; D. Kiefer in 8111103 letter; F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: DEC prefers an intermunicipal solution that addresses the problems in the region comprehensively. The phosphorus loadings from Town of Lansing flows are very small and overall phosphorus loadings to the Lake will be greatly reduced with the 27 planned WWTP phosphorus upgrades. It is difficult to interpret the meaning of "state-of- the-art satellite treatment plant" in the comment since no proposal went through to a design phase. In DEC's experience, small municipal plants generally have more operational and compliance problems than regional facilities. Smaller municipal plants are seldom "state-of-the-art" because of the inability to spread higher costs over a small tax base. 52. Comment. The EIS contains no evidence that centralization of wastewater treatment infrastructure in this instance would be more cost-effective or technically superior than a decentralized approach using an additional treatment plant in the Town of Lansing. One commenter said new technologies are available that treat wastewater efficiently and properly. Another commenter suggested consideration of the use of ozone- and ultra- violet based treatment rather than chlorine. Another commenter said that higher risks of malfunction and pollution that come with decentralization are insufficient to reject an additional WWTP in this case because of the impairment in the southern Lake. S (F. Gougakis in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter; L. Leopold in 8111103 letter) Response: See Response to Comment 51 above. We disagree with the comment that the higher risks of malfunction and pollution that come with decentralization are worth incurring because of the impairment in the southern Lake. The additional amount of phosphorus to be discharged in the southern Lake is in itself very small and is less than one-fourth lbs/day initially and less than three -fourths lbs/day in 20 years. Even with the added Town of Lansing flows, the total amount of phosphorus discharged to the Lake will decrease in the range of 20 to 31 pounds per day on an annual average basis. 53. Comment. The EIS should mention the post 9-11 recognition that centralization increases vulnerability. The EIS should acknowledge that the alternative of relying on efficient, smaller -scale distributed infrastructure would promote the maintenance of greater region -wide functionality during times of natural or man -induced calamity. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) i, Response: Vulnerability is certainly a concern today and it is true centralization can increase vulnerability. However, concerns about infrastructure vulnerability are not always cured by relying on decentralized infrastructure. A new smaller plant could be more vulnerable under some scenarios since small plants are not staffed as often as larger plants. 54. Comment. The EIS should examine an upgrade to the Town of Lansing s facility and a discharge into the Lake at that point. (J Dennis at 7131103 Public Hearing) Response: The Town of Lansing does not currently have a wastewater treatment facility. 55. Comment: The EIS should better explore the alternative of expanding the VCHWTP. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: The alternative of expanding the VCHWTP to treat 2.9 mgd (currently permitted at 2.0 mgd) was evaluated in the Town of Lansing Wastewater Facilities Plan prepared in October 1998. That report concluded that expanding the VCHWTP to treat projected flows from the Town of Lansing would cost approximately $3,600,000 more than the alternative to divert equivalent flows to the IAWWTP, where capacity already exists. 56. Comment: The total proposed diversion to IAWWTP is only 1.3 million gallons per day. For a fraction of the $11.2 million capital cost, each of the Lansing on -site septic systems and SPDES permitted discharges referred to in the DEIS could be equipped with state-of-the-art on -site phosphorus removal systems without constructing a 26-mile long wastewater collection system. (W Hang at 7131103 Public Hearing and in 816103 letter) Response: This comment does not take into account the fact that hundreds of septic systems are located in areas that are not well suited for subsurface discharge because of steep slopes, shallow depth to bedrock, shallow groundwater tables, and seasonal flooding. No amount of retrofitting would address the fact that these systems fail at a high rate. As for existing package plants with surface discharges, the Town of Lansing's 1998 Facilities Plan evaluated small satellite treatment plants as an alternative to regional treatment. However, this alternative was more expensive than the selected alternative to treat flow from the Town of Lansing at the VCHWTP. 57. Comment: A study should be conducted to see if the discharge pipes for the IAWWTP, VCHWTP and the Lake Source Coolingfacility could be merged and moved to discharge the combined effluent into deeper waters below the photic zone far from existing drinking water intakes. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The need for such a study has not been demonstrated, and in any event, falls outside the scope of this EIS. Currently there are no water quality issues affecting drinking water. As for issues affecting the Lake, as stated in Response to Comment 12, DEC does not believe that currently there is sufficient information to develop a more stringent limit on phosphorus through the TMDL process. As stated in Response to Comment 14, if further reductions in phosphorus are required in the future, a modification to the WWTPs' permits may be required. If this occurs, the owners of the IAWWTP and VCHWTP will consider alternatives, including extending their outfalls into deeper water. 29 58. Comment: Studies should be conducted to assess the technical feasibility as well as the costs and benefits of managing the project's wastewater without any discharges to Cayuga Lake (discharge into a nearby receiving water body; spray irrigation). (W.. Hang in 816103 letter) Response: Section 6.7.7 of the 1983 Wastewater Facilities Plan completed for the Town of Lansing evaluated the use of small diameter sewers with land application of raw sewage. The evaluation concluded that land spreading is cost -prohibitive, a conclusion that is still valid today. The conclusion reached is published in its entirety: "This alternative considers the areawide collection of sewage by small diameter sewers. The sewage would be transported to a suitable location and then applied to the land. As pointed out earlier, the most suitable location of central collection is at Portland Point. Three potential landsites are considered for the application of raw sewage. These are illustrated in Appendix 6-4. A number of evaluations must be made in considering the application of sewage to land. These are: (1) health considerations to adjoining residential community (2) groundwater pollution (3) soil pollution, (4) air pollution (5) future use of land and many other considerations since the temperature in the Study Area is very low during winter season. The sewage would have to be stored during winter season before it is applied in summer/spring to the land. An economic evaluation of the alternative is made before giving consideration to various health and environmental concerns. The total estimated project cost using this alternative is $15,224,100. The annual cost of Operation and Maintenance is $43, 000. Since this alternative is more costly than the majority of other alternatives, no further consideration is given to this alternative. " Discharges into a nearby receiving water body are not a realistic alternative, either. Discharges from a Town of Lansing plant to receiving waters such as Salmon Creek or Gulf Creek (both of which are tributaries to Cayuga Lake) are not considered feasible by DEC, given the low base flows in the Creeks during the summers. PROJECT SCHEDULE 59. Comment. Section 2.7 says survey and stakeout of sewer line alignments will occur one week ahead of the construction schedule. This short timeframe will likely not be sufficient to deal with any problems that may arise. One commenter asked the time between survey/stakeout and construction be lengthened to two to four weeks to provide the ability to make rerouting decisions that may be necessary due to site conditions. Another commenter asked the time be lengthened to at least four weeks, for the same reason. (J Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) 30 Response: The survey and stakeout referred to in Section 2.7, which will be conducted one week ahead of the construction schedule, is to provide control points for the contractor's use. A detailed design survey is conducted to determine the final alignment of the proposed sewer. The design survey is used to make routing decisions due to site conditions. 60. Comment: The EIS should discuss how analysis, planning and engineering for the 26 proposed stream crossings will be conducted before construction starts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: There are no DEC protected streams to be crossed by the construction of sewer mains in the Town of Lansing Service Area. Certain practices and controls to minimize stream disturbance will still be incorporated in the contract documents and depending on the characteristics of a particular stream may include all of the following: 1. Directional boring beneath the stream or trenching with appropriately constructed coffer dams. 2. Discharges from trench dewatering activities will pass through a sedimentation control practice. 3. Not allowing equipment in flowing streams. 4. Restoring the stream bottom cross-section and profile. 5. Replacing significant trees removed within 50 feet of a stream bank. DRYDEN PLANNING AREA 61. Comment: The Dryden Planning Area in the DEIS is significantly larger than those areas identified for expanding sewer service and accommodating future density in the Town of Dryden 's Draft Comprehensive Plan. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The Dryden Planning Area is a 20-year projection of areas where public sewers might go, whereas the Comprehensive Plan is expected to be updated every 5 to 10 years. The EIS's study of environmental effects within the Planning Area will be used to help inform decisions in the future on where sewer districts might be formed. 62. Comment: The commenter understands that the location of the sewer lines in the Dryden Planning Area is still in the conceptual stages and the DEIS does not discuss the environmental impacts in this area. Additional environmental reviews will need to address the full range of impacts in the Dryden Planning Area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment received and noted. 31 MAPPING ISSUES 63. Comment: The DEIS relied on Soil Association mapping for an assessment of soil conditions in the study area. Tompkins County has a digital version of the more detailed soil series map for Tompkins County, which may be obtained from the Tompkins County Information Technology Services Division. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: At the time of preparation of those portions of the DEIS which utilized soils mapping, the more detailed soil series mapping was not available. The association level mapping used in the DEIS is sufficient to identify the potential for construction impacts such as high groundwater tables or erosion, as well as for use in the growth inducement analysis. Given that the DEIS identified the potential for impacts related to soil conditions and recommended appropriate mitigation measures, no further analysis is required. 64. Comment: The VCHWTP and IAWWTP locations and existing pipe connections should be included for reference on at least Figure 4. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: A revised Figure 4 is included in this FEIS in Section III. 65. Comment. The EIS should include a figure showing the location and depth of the existing WWTP discharge points as well as the depth of the Lake throughout the southern end. (D. Kiefer in 8111103 letter) Response: The location and depth of existing WWTP discharge points are not germane to the discussion of impacts from the proposed sewer construction project. The project does not involve any modifications or changes to these discharges. 66. Comment: In Figure 19, Unioue Natural Areas, the pink color for UNA 102 (Renwick Slope) is on the map, but the number 102 is not printed on the map. The same is true for Figure 33, where the color for the Newman Tract appears, but not its title on the map. (L. Leopold in 8111103 letter) Response: Revised Figures 19 and 33 are included in this FEIS in Section III. The Newman Tract is not located within the area shown on Figure 33. 67. Comment: The DEIS states at page 30 that all water bodies are Class C in the DEIS Study Area. Actually, many are classified as "D" and "A" as shown on Figures 14a and 32 14b. The Figures have a column labeled "Protected Status Code " so only C(T) and higher streams are listed. The column should be labeled "Standards Class " and show all classes. This point is only for clarification, as the Stormwater Permit will protect the "D " streams and unclassified watercourses. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. Revised Figures 14a and 14b are included in this FEIS in Section III. GENERAL 68. Comment: Section MI of the Executive Summary, pages xxviii and xxix, which contains the list of involved agencies and their authority for the project, should state the DEC will also be responsible for review and approval of plans for the new construction, given the scope of the project, that most construction is in a new service area, and that State funds are involved. The TCHD will assist in review and approval if DEC so desires, as the TCHD does for most collector sewers. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: The DEC will be responsible for review and approval of plans and specifications (contract documents) for new construction of sewers and pump stations for the project. The TCHD will assist in the approval, if the DEC so desires. 69. Comment: Please clarify the statement in the DEIS in Section 2.2.2, Town ofLansinz Service Area Proposed Improvements, that "the Village of Lansing s existing 15-inch railroad interceptor sewer intersects the railroad grade below Twin Glens Road and terminates at the existing VCHWTP. " At present, there is no Village of Lansing sewer interceptor below Twin Glens Road, unless the reference means 'farther south " along the railroad bed, instead of downhill, i.e., west, of Twin Glens Road. (L. Leopold in 8111103 letter) Response: The Village of Lansing 15-inch interceptor sewer is located on the former Ithaca -Auburn railroad bed south of Twin Glens Road and immediately west of Cedar Lane. 70. Comment. The commenter was pleased to see there are plans to investigate the possibility of using the former railroad right -of -way -'as a recreation trail in conjunction with this project. This is an excellent opportunity to create trails that link the Lansing community and the larger community. (E. Marx, Tompkins County Planning Department in 8111103 letter) 33 Response: Comment noted. The former railroad right-of-way is on private property. The project sponsors have discussed with the landowners the possible use of this right-of- way as a recreation trail. The affected landowners oppose creation of a public pedestrian right-of-way along the former railroad right-of-way. 71. Comment. The commenter asked what would happen to an elevated septic system that is built on the old railroad bed. Would the sponsors dig under that or remove it and put it back after construction? (J. Dennis at 7131103 Public Hearing) Response: Directional boring beneath the septic system is possible. Conventional trenching is also possible with necessary repairs made in the distribution/collection laterals, filter media and subsoil. Alternatively, the building sewer could be connected to the sewer main and the septic system ultimately abandoned. 72. Comment: One commenter said DEC s job is to protect the environment, not pay attention to how many homes are available. Another commenter said representatives of real estate agencies attended meetings on the project, and this commenter expressed ti concern that development expansion could end up playing a large role in the project. (R. DePaolo at 7131103 Public Hearing; F. Gougakis in 8111103 letter) Response: Comment noted. Section 6 of the DEIS contains an extensive assessment of potential growth induced as a result of the project. The affected municipalities now have the opportunity to review their planning policies with respect to such potential growth. Other sections of the DEIS deal with other environmental impacts and mitigation, and the involved agencies and municipalities likewise will consider this information as they make their decisions. 73. Comment: This commenter expressed concern over impacts to sensitive/unique natural areas, unavoidable habitat loss, erosion, noise issues, odors, and pump station impacts that are raised in the DEIS. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: Comment noted. Each of these potential impacts is adequately addressed in the EIS. Absent a specific comment or concern, no further response is possible. 74. Comment: Local government off cials should have held a public information forum on this project, preferably at night in the City of Ithaca. They made no effort to make sure the public understands this massive project. The ElSprocess should not continue until such a forum is held. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) 34 Response: Comment noted, and the municipalities have the opportunity to take this comment into consideration for future projects. The official SEQRA public hearing and the informal public information session run by DEC were agreed to between DEC and the involved municipalities. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. 75. Comment: One commenter requests an extension of the comment period into September 2003 or well into the Fall of 2003. Another commenter requests an extension of the comment period into the Fall of 2003. (J. Dennis at 7131103 Public Hearing; F. Gougakis at 7131103 Public Hearing) Response: The length of the public comment period meets (and exceeded) the requirements of SEQRA. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. COMMENTS IN SUPPORT OF PROJECT The following comments were received and noted. 76. Comment. The commenter states that overall, it is supportive of the project. The project will eliminate nonpoint source pollution currently caused by inadequate on -site sewage disposal systems in the project area. This will help maintain the public health and welfare of Tompkins County residents and those who use Cayuga Lake as a drinking water and recreational resource. This reduction, combined with an increase in the overall level of treatment for wastewater generated in the Cayuga Lake watershed, will help protect the economic vitality and well-being of Tompkins County. (E. Marx, Tompkins County Planning Department in 8111103 letter) 77. Comment. The commenter looks forward to the FEIS and the development of engineering plans and specifications to solve the identified problems in the service area. (J. Andersson, Tompkins County Health Department in 6125103 letter) 78. Comment. The commenter supports the project, which will eliminate ground and surface water pollution caused by inadequate on -site sewage disposal systems and will provide a higher level of sewage treatment than presently available within the service area. The project will better utilize existing treatment capacity and infrastructure, and phosphorus treatment *will be added in both WWTPs, which will help improve Cayuga Lake's water quality. Members of the Tompkins County Chamber of Commerce and of Tompkins County Area Development funded facilitation of the project because the project is critically important to protect the Lake and it will allow for development in areas designated by each of the municipalities. Those funding the facilitation did not propose any particular solution but rather provided facilitation so the participants could come to a solution beneficial to all. The project's positive impacts far outweigh any potential adverse impacts. (J. McPheeters, Tompkins County Chamber of Commerce at 7131103 Public Hearing and in written copy of public comment received by DEC on 7131103) 79. Comment. The DEIS is well -written and thoroughly reviews the project's impacts. The project will improve the quality of Cayuga Lake by taking septic systems off-line and treating waste. The south end of the Lake is responsible for a majority of septic systems on the Lake. Over the past 8110 years, the commenter's house and septic system on Ladoga Point Road have flooded S times, which created additional discharge into the Lake and prevented occupancy of the house. The project will not necessarily create more growth, as the municipalities will control growth. (R. Cutting at 7131103 Public Hearing and in 816103 letter) 80. Comment. The project will provide an opportunity for expanded sewer service in the watershed and a higher level of treatment than what is provided by septic systems and package plants. The growth inducing impacts are relatively minor. The project will provide for better environmental protection for Cayuga Lake. (M. May in 811103 letter) 81. Comment: The project sensibly deals with the current inadequacies of the VCHWTP by utilizing the available capacity of the IAWWTP. The project will allow some growth in areas where sewers are present but sewer permits are not available due to VCHWTP limitations. The project will also make possible additional growth of homes and businesses without needing large areas of land to accommodate new septic systems. Some homes currently located on the lake shore have questionable septic systems, and no authority checks them on a regular basis. A controlled municipal system which could be upgraded in the future would insure that the waste from these homes is treated properly and meets established guidelines. (E. Quaroni in 811103 letter) 82. Comment: The project is a sound plan and a good solution to a very difficult infrastructure problem. A study initiated by the Tompkins County Planning Department and the Planning Advisory Board in 1994 concluded that limited water and sewer facilities, particularly in the northeast urbanized region, were a limiting factor to economic development. An Economic Development Strategy completed by Tompkins County Area Development (TCAD) in 1999 emphasized the importance of improved water and sewer service to attain the goal of building the economic foundations of Tompkins County. The Strategy noted that issues of concern related to the expansion of sewer services (generally related to the potential for development in suburban areas as opposed to the urban core) are balanced by the following counterpoints: extended sewer service improves environmental quality in already developed areas that use on -site 01 disposal systems; sewer service allows small -lot and high -density development that lowers the developed area on a per capita basis; and the dynamics of development fluctuate among urban centers, suburban rings and rural areas. One of the top 10 action steps (out of 58) identified by the Strategy was an integrated system of water and sewer services for the urbanized and growing areas of the County to improve supply, efficiency of delivery and environmental quality. This is the reason TCAD helped fund facilitation activities to bring the project to this stage. (B. Blanchard, Tompkins County Area Development at 7131103 Public Hearing and in written copy of public comment received by DEC on 7131103) 83. Comment. The proposed regional solution offers by far the best solution to meet the immediate and long term wastewater collection, transmission and treatment needs of the proposed service area. Upland pollution will be eliminated in areas not currently sewered. The entire region will benefit from the substantial improvement in the water quality in the Southern Cayuga Lake Basin. The project is consistent with land use policies already in place in all six municipalities. In addition, the owners of the IAWWTP have voluntarily agreed to more stringent permit levels for the discharge of phosphorus, and phosphorus removal and other improvements at the VCHWTP will also take place. Sufficient spare capacity will be available well beyond the 20 year planning l period, especially with continuation of an aggressive program to eliminate inflow and infiltration. The Town and Village of Lansing service areas can be severed without the need to construct additional treatment capacity, resulting in substantial savings to all users. Improvements to the water quality in the southern basin of the Lake will require more than the commitment of those responsible for the operation of the WWTPs. Stream erosion and agricultural runoff are being addressed in the Town of Caroline, and the Tompkins County Water Resources Council, the Cayuga Lake Watershed Network and Intermunicipal Organization are actively pursuing and coordinating monitoring efforts throughout the region. (N. Desch in 819103 letter) 84. Comment: The DEIS is adequate. Village of Lansing history shows growth in malls, subdivisions and offices will occur with or without sewers. Adequate sewage facilities will only benefit Cayuga Lake. The project is a good use of resources and a cost effective plan. Self-government is preserved, with each municipality defining costs, growth and location of future sewers. The need for this project started in 1987 with a temporary moratorium by the VCHWTP. There has been much effort and discussion since then, and there is no need for further study. (J. Majeroni, Cornell University, Real Estate at 7131103 Public Hearing) 85. Comment: The project should go forward. Home prices are very high because of low inventory. New construction resulting from the project would lead to more moderate prices. In the 23 years this commenter has been in the real estate business, this commenter has never seen a problem with public sewer systems but has seen many Y 37 problems with septic systems come up at real estate closings. The added cost of a septic system is about $10, 000. This adds a lot to the price of a home. Public sewers would make it better for everyone. (A. Edelman, Audrey Edelman & Associates Real Estate at 7131103 Public Hearing) 86. Comment. This commenter stated he echoes Ms. Edleman 's comments about the need for housing. This commenter built a house on Horizon Drive and extended the municipal sewer pipe to his home because he was close enough to do so. One of his neighbors paid $10, 000 for a septic system. Neighbors have had problems with septic systems, including septic systems backing up and flooding their basements. There are current proposals for two subdivisions with more than 180 houses in Lansing. There is a need for housing, and more sewage will be created. With the amount of local vacant land, there could be more than 1, 000 homes built with septic systems, with untreated waste just injected into the ground. There is a need to move forward with public sewers and treat the sewage. (G. Sloan at 7131103 Public Hearing) III. TABLES AND FIGURES 39 Stearns & Wheler, LLC Environmental Engineers and Scientists WWTP TOTAL PHOSPHORUS (TP) LOADING DISCHARGED TO SOUTH END OF CAYUGA LAKE Ir)-.. LUET,T(VA : ` TP.W/- ANSING' T AY .;wwrk:ETFPLGONBINEDWW., '> • .�: x.: 4G'1'LttYli ; ACT.UA ACTUAL- .......: r.P'TJTURE:.; .... � ,. q .....:.� � .: ;•.F.UTURE, , ...: ..; . + � ; - ........ ; ..: .. :..FUTURE,.::- :'.•^;e,s r :: ^: : •:. :. •...:.;.:., .:.- c.:,•: , , ,TT " ,:*:, ERMITTED. -ANNUAL: PERML.T.TED . :ANNUAL'.': v LANSING T -' COMBINED.TP::. s PERMITTED, ANNUALxr ...:_ 3 , ,.,P , .. (�, (.) ;(. �.. PERMIT :. -: PERMIT 1 t R RMI., _ .. s . .> . ...,y,>, .. ,. , , -. ,. a ... , , .,...-.,.:.� i .,s.::. ;" � ; .; ..; , .:... , s . , y AD NG AVERAGE. - 1999 83.4 27 9.3 16.7 6.5 2.6 100.1 33.5 11.9 0.24 12.14 2000 83.4 32 11.6 16.7 10.7 3.1 100.1 42.7 14.7 0.24 14.94 TABLE F-1 REDUCTION" PERCENT.; IN TP LOAD` _� R6&L , ION IN " ,TO.LAICE.1z): ,TP,,TQ`AKE(13),: 21.36 64 l 27.76 65 1 2001 65.3 33 10.2 16.7 11.8 3.1 82.0 44.8 13.3 0.24 13.54 31.26 70 2002 40.0 26 10.8 16.7 8.1 2.6 56.7 34.1 13.4 0.24 13.64 20.46 60 2003* 40.0 23 11.6 16.7 11.9 3.2 56.7 34.9 14.8 0.24 15.04 19.86 57 * Through August 2003. 1, 4, & 7. Allowable phosphorus loading under SPDES permit in effect during each year. 2, 5, & 8. Actual phosphorus loading based on effluent sampling at each plant. 3, 6, & 9. Amount of phosphorus loading that would have been discharged if future permit conditions of 0.2 mg/L for phosphorus were in effect. 10. Amount of phosphorus loading as a result of collecting sewage in the Town of Lansing and treating it to a 0.2 mg/L effluent total phosphorus concentration at the VCHWTP. 11. Sum of columns 9 and 10, which represents the total phosphorus loading to the Lake from the region (including the Town of Lansing) proposed to be served by the IAWWTP and VCHWTP under future permit conditions of 0.2 mg/L effluent phosphorus concentrations. 12. Column 8 minus column 11, which represents the reduction in phosphorus loads to the Lake, if all the flow is treated to a 0.2 mg/L effluent total phosphorus concentration. 13. Column 12 divided by column 8 and expressed as a percentage. Represents the overall actual reduction in phosphorus loading to Cayuga Lake (approximately 65%). Note: The data contained in this table cannot be used to calculate the interim phosphorus limit for the IAWWTP. The data contained herein are actual annual averages (not 12-month rolling averages), intended to show the average reduction in phosphorus discharged to the Lake. L6 Stearns & Wheler . Companies Town of Lansing N /f�� w� pE a 1:55,000 Miles 0 0.5 1 2 Municipal Boundary 0 Sewer Planning Area 0 Sewer Service Area O Proposed Pumpstations • Public Well Points Potential Sewer Lines for Planning Area Proposed Sewer Lines for Service Area Ro s 13 State Highway County Highway Local Road THE CWTUGA LAKE L R� ERUVIL t o o To n of Lansi 222 _� ran L 34 m - C 46 Town. f Groton ASBURN � Do 4 T� f u!y 89 Villa - e of Lansing 13 I_ TEE IRS, _ 96 34 n 13 z vinage R ATERWAGON.,RR y �(� Cayuga N gh L-` K 79 366 Town of Dryd n City of1`7a 327 To ! t h a 34 __0 - 45 ri i-- �'o i 1r Town o f ., � 79 J D r _ RO c > rn �----- I 6B - z VEER ROAD 2 13 Town of Carotin Li t µ W ° RFZQ!� u�, o \{� SNY own o f 1 URDCHILL RI - r NI _ �7O OFR RCAD T wn of Newfie,' 34 :{ Municipal Boundary 0 2 4 8 L� 0 Study Area Boundary 046ES; I,j IR Miles 0 Area shown on large-scale map State Highway Village of Lansing tj„ n Index map of Tompkins County, NY showing the study area CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Ra eve Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue 21 Fox Street 263 Route 17K Stratls Business Centers 110 Glen Street MA I ES Troy, New York 12182 Poughkeepsie, New York 12601 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Phone:(518) 235-SO50 Phone:(845) 454-3980 Phone:(845) 567-1133 Hingham, MA 02043 Phone:(518) 812-0513 Engineers / Surveyors Phone: (781) 556.1037 Planners Environmental Scientists This map Is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. GIs Consultants The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than Its Intended use. oeaced W. Final Environmental Impact Statement: Carol Conolly Ithaca Area Municipal Wastewater Collection Improvement Project o"' September 29, 2003 Figure 3. Existing Well Points In Relation To Proposed Sewers. various; see maps Figure 3 Cayuga Heights 'VastewaterTreatment'Plant VI_ \\ _\ -Ithaca,Area I Treatment Plant I Study Area Wastewater Treatment Facilities r ® Village of Cayuga Heights Wastewater Treatment Plant Ithaca Area Wastewater Treatment Plant Municipal Boundary Existing Sewer Lines i' 0 Existing Pumpstations Roads : 90,000 State Highway Miles County Highway 0 0.5 1 2 Local Road THE CORa eve PANIE M PATE ES / Surveyors Planners Environmental Scientists GIs Consultants CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Straus Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Phone: (518) 235-8050 Phone: (645) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone:(781) 556-1037 This map is a product of The Chazen Campania. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. Town of Lansi of Lansing .. 9 Town of Carolin own o f `baR, q IT,��n of Newfie); 34 L_J Municipal Boundary M Study Area Area shown on large-scale map 0 2 4 8 State Highway Miles Index map of Tompkins County, NY showing the study area Draft Environmental Impact Statement: Ithaca Area Municipal Wastewater Collection Improvement Project Figure 4. Existing Wastewater Collection Facilities. Qr dby: Carol Conolly September 29, 2003 sw. Vnri" IC' CPP mnnc Figure 4 N w-�-E 8 1:55,000 Miles 0 0.5 1 2 1 1 tie -� 4 — �� Town of Lansing 4B u' g 34 / r� 14 21 I S _ '19 TO ^-� 19 % Ln C4MG.1 LAKE Cl) ' 3 \ 26 Study Area 13 34 ® Municipal Boundary 14 35 Roads 15 36 is State Highway 16 37 County Highway 17 38 Local Road 18 39 ---- Streams that do not have a NYSDEC Watershed Index # 19 40 Streams that have a NYSDEC Watershed Index # "® 20 41 Map Symbol Id 21 42 1 22 — 43 2 23 44 3 24 45 4 25 46 5 26 47 6 27 48 7 28 49 8 29 — 50 9 30 51 10 31 52 - ® 11 32 53 12 33 --_ 54 55 t THE Chazen COMPA IES Engineers / Surveyors Planners Environmental Scientists GIS Consultants I I CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. 271 i -1 `L _ ----------- 34 48 r � ; 49- 48 y I t6g— 51 Capital District Office: Dutohess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue 21 Fox Street 263 Route 17K Stratls Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12601 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone: (781) 556-1037 This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than Its Intended use. Village of Lansing Map NYSDEC Watershed Index Status Code Symbol Id # Protected Status_ 55 Ont. 66-12-P 296-69 D Not protected 53 Ont. 66-12-P 296-68 D Not protected 51 Ont. 66-12-P 296-67 D Not protected 47 Ont. 66-12-P 296-66 D Not protected 52 Ont. 66-12-P 296-67-1 D Not protected 46 Ont. 66-12-P 296-65 D Not protected 54 Ont. 66-12-P 296-68-1 D Not protected 48 Ont. 66-12-P 296-66-1 D Not protected 50 Ont. 66-12-P 296-66-2 D Not protected 49 Ont. 66-12-P 296-66-1-1 D Not protected I 44 Ont. 66-12-P 296-64 D Not protected 45 Ont. 66-12-P 296-64-1 D Not protected 43 Ont. 66-12-P 296-63c D Not protected 42 Ont. 66-12-P 296-63b D Not protected I 41 Ont. 66-12-P 296-63a D Not protected 39 Ont. 66-12-P 296-63 D Not protected I 37 Ont. 66-12-P 296-62 D Not protected I 31 Ont. 66-12-P 296-61-2-1 D Not protected 38 Ont. 66-12-P 296-62? D Not protected I. 40 Ont. 66-12-P 296-63? D Not protected 29 Ont. 66-12-P 29&61-2 D I Not protected 33 Ont. 66-12-P 296-61-2-3 D Not protected 34 Ont. 66-12-P 296-61-2-a D Not protected 30 Ont. 66-12-P 296-61-2? D Not protected 32 Ont. 66-12-P 296-61-2-2 D Not protected 27 Ont. 66-12-P 296-61-1a D Not protected 28 Ont. 66-12-P 296-61-1 b D I Not protected 25 Ont. 66-12-P 296-61 D Not protected I 26 Ont. 66-12-P 296-61-1 D Not protected 36 Ont. 66-12-P 296-61-4 D Not protected 35 Ont. 66-12-P 296-61-3 D Not protected 19 Ont. 66-12-P 296-59 D Not protected 23 Ont. 66-12-P 296-60 I D Not protected 24 Ont. 66-12-P 296.60a D Not protected I 20 Ont. 66-12-P 296-59? D Not protected 18 Ont. 66-12-P 296-58-1 D Not protected I 21 Ont. 66-12-P 296-59-1 D Not protected 14 Ont. 66-12-P 296-57-3-4 B Protected 3 Ont. 66-12-P 296.57 C(TS) Protected 22 Ont. 66-12-P 296-59-1-1 D Not protected 5 Ont. 66-12-P 296-57-2 D Not protected 7 Ont. 66-12-P 296-57-2-2 D Not protected 17 Ont. 66-12-P 296-58 D Not protected 1 Ont. 66-12-P 296-56 D Not protected 6 Ont. 66-12-P 296-57-2-1 D Not protected 2 Ont. 66-12-P 296-57 D Not protected 15 Ont. 66-12-P 296-57-3-4 C Not protected 8 Ont. 66-12-P 296-57-3 D Not protected 13 , Ont. 66-12-P 296-57-3-4 D Not protected 9 Ont. 66-12-P 296-57-3 C Not protected 4 Ont. 66-12-P 296-57-1 a D Not protected 11 Ont. 66-12-P 296-57-3-2 D Not protected 16 Ont. 66-12-P 296-57-3a D Not protected 10 Ont. 66-12-P 296-57-3-1 D I Not protected I 12 I Ont. 66-12-P 296-57-3-2-1 D Not protected I o.fteW Draft Environmental'Impact Statement: Carol Conolly Ithaca Area Municipal Wastewater Collection Improvement Project ° September 29, 2003 Figure 14a. Water Resources In The Town of Lansing sd. And Village Of Lansing Portion Of The Study Area. various; see maps Figure 14a Cl 0 ' /ANC W- -E s 1:63,000 Miles 0 0.5 1 2 p Study Area 71 93 Municipal Boundary 72 94 U Roads 73 95 fs State Highway 74 - 96 County Highway 75 97 Local Road 76 98 ---- Streams that do not have a NYSDEC Watershed Index # 77 99 Streams that have a NYSDEC Watershed Index # 78 100 Map Symbol Id 79 101 53 80 102 { 59 81 103 4J! 60 82 104 I I 61 83 105 62 84 106 63 85 107 64 86 108 65 87 109 _ U 66 88 110 67 89 111 68 90 112 69 91 113 70 92 114 115 THE Ownt_. COMPA IES Engineers / Surveyors Planners Environmental Scientists GIs Consultants CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Capital Dlsbict Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue 21 Fox Street 263 Route 17K Straus Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12601 Newburgh, New York 12550 99 Derby Rd., Sulte 200 Glens Falls, New York 12801 Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone: (781) 556-1037 This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibMes, or liabilities from the use of this map for any purpose other than its intended use. Map Symbol Id NYSDEC Watershed Index# 110 Ont. 66-12-P 296-75-5-28 106 Ont. 66-12-P 296-75-5 109 Ont. 66-12-P 296-75-5-22 111 Ont. 66-12-P 296-75-5-32 113 Ont. 66-12-P 296-75-5-34-1 112 Ont. 66-12-P 296-755-34 115 Ont. 66-12-P 296-755-39-2 114 Ont. 66-12-P 296-755-34-3 108 Ont. 66-12-P 296-75-5-17-1 107 Ont. 66-12-P 296-75-5-17 93 Ont. 66-12-P 296-75-3-11 91 Ont. 66-12-P 296-753 98 Ont. 66-12-P 296-753-4 101 Ont. 66-12-P 296-7535-1 97 Ont. 66-12-P 296-7533 105 Ont. 66-12-P 296-75-3-9 95 Ont. 66-12-P 296-75-3-2a 100 Ont. 66-12-P 296-75-3-6 92 Ont. 66-12-P 296-75-3-10 104 Ont. 66-12-P 296-753-8b 94 Ont. 66-12-P 296-75-3-2-8 90 Ont. 66-12-P 296-753 102 Ont. 66-12-P 296-75-3-7 99 Ont. 66-12-P 296-7535 96 Ont. 66-12-P 296-75-3-2b 103 Ont.66-12-P 296-75-3-7-1 61 Ont. 66-12-P 296-74 b 60 Ont. 66-12-P 296-74 62 Ont. 66-12-P 296-74 c 74 Ont. 66-12-P 296-74-3 75 Ont. 66-12-P 296-74-3-1 77 Ont. 66-12-P 296-74-4-1 76 Ont. 66-12-P 296-744 72 Ont. 66-12-P 296-74-2 85 Ont. 66-12-P 296-74-9 78 Ont. 66-12-P 296-745 73 Ont. 66-12-P 296-74-2-1 79 Ont. 66-12-P 296-74-6 80 Ont. 66-12-P 296-74-7 81 Ont. 66-12-P 296-74-8 86 Ont. 66-12-P 296-74-9a 87 Ont. 66-12-P 296-74-9b 53 Ont. 66-12-P 296-68 88 Ont. 66-12-P 296-74-9c 89 Ont. 66-12-P 296-74-9d 63 Ont. 66-12-P 296-74-10 64 Ont. 66-12-P 296-74-10a 65 Ont. 66-12-P 296-74-11 66 IOni. 66-12-P 296-74-12 67 IOni. 66-12-P 296-74-12a 82 IOni. 66-12-P 296-74-8-1 68 IOni. 66-12-P 296-74-14 83 IOni. 66-12-P 296-74-8-2 84 I Ont. 66-12-P 296-74-8-2-1 69 IOnt. 66-12-P 296-74-15a 59 I Ont. 66-12-P 296-74 70 I Ont. 66-12-P 296-74-16 71 I Ont. 66-12-P 296-74-16a Draft Environmental:lmpact Statement: Ithaca Area Municipal Wastewater Collection Improvement Project Figure 14b. Water Resources In The Town of Dryden Portion Of The Study Area. Status Protected Code Status A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected D Not Protected CM Protected D Not Protected D Not Protected D Not Protected D Not Protected D Not Protected D Not Protected C(T) Protected C(T) Protected D Not Protected D Not Protected D Not Protected D Not Protected D Not Protected D Not Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected D Not Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected A Protected D Not Protected C(T) Protected D Not Protected Carol Conolly 00, September 29, 2003 I� Various; see maps Figure 14b F -)` L_l U A- UNA-2 34 N Roads UNA to State Highway 1 County Highway I7 Local Road NA - Municipal Boundary ' Unique Natural Areas A. - To n of Lansi. 222 Site Code, Site Name �- 34 UNA-102, Renwick Slope CA7TIGALAKE 4B UNA-103, McKinneys Twin Glens and Lake C �l U Town f Groton UNA-104, Palmer Woods = 4 s 111 NA-67 T f U f y =e, UNA-106, Sapsucker Woods Bird Sanctuary 34 A 6_ 89 Villa a of Lansing 13 UNA-107, DEC Mapped Wetland (Code TA9) I UN 1 UNA-108, Monkey Run - 96 f � 13 13 I UNA-109, Fall Creek Hemlock Grove -' Village UNA-110, Etna Bird Sanctuary (Etna Marsh) UN .88 U A-8 Cayuga He h 'U -89 `� NA-8 79 366 T, o w n. of D r y d n � UNA-124, Frost Ravine -_ � City of ! is UNA-126, Ellis Hollow Swamp UN -1J1 327 T o 1 t h " ? UNA-127, Poison Preserve and Snyder Hill 13 UNA-102 07 NA-10 Town of". - 79 j ii UNA-130, Fall Creek Valley, Ithaca U A-106 ����TIII UNA-133, Thomas Road Wetlands UNA-157, Cooks Comer Gully 13 6 UNA-24, Lake Cliffs, North of Myers Point UNA-108T o. w n o f C. a r o 1 i n {NA- 4 own of' q _ i 0 UNA-28, Ludlowville Woods UNA-52, DEC Mapped Wetland (Code WG14) T w n of N e w f i e r' 34 `~ UNA-53, Portland Point Quarry Study Area UNA-54, Minnegar Brook Woods ? �� Municipal Boundary UNA-55, Lower Salmon Creek 0 2 4 8 Area shown on large-scale map w Miles r UNA-63, Shurger Glen State Highway 0 UNA-64, Lake Cliffs, South of Portland E Index map of Tompkins County, NY showing the study area UNA-65, Head Corners Wetland UNA-66, Cornell Ponds #1 and DEC Mapped (Code WG21) NA-12 UNA-67, Dryden -Lansing Swamp 1 : 90,000 Disclaimer: UNA-71, Mill Dam Marsh, Freeville - UNA-83, DEC Mapped Wetland (CodeTA4) Miles0 0.5 1 2 � UNA-127 Unique Natural Area boundaries were delineated by field biologists based on a review 0 UNA-85, DEC Mapped Wetland (Codes TA2 and TA3) - 33 of air photographs, digital GIS base map data (roads, building footprints, 20-foot contours and streams) and field visits. Unique Natural Area boundaries are approximate and 0 UNA-86, DEC Mapped Wetland (Code TA5) should be used for general planning purposes only. As a practical matter, Tompkins ' 0 UNA-87, Fringed Gentian Meadow A-1 7 L - County does not warrant the accuracy or completeness of the information portrayed. The end -user of this map agrees to accept the data "as -is" with full knowledge that 0 UNA-88, Airport Ponds, Wetland 79 errors and omissions may exist, and to hold harmless the County for any damages that UNA-89, Lake Cliffs, McKinney's Point to Bolton Point may result from inappropriate use of this map. UNA-90, Estys Glen THE Gbap CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Draft Environmental Impact Statement: Carol Conolly Capital District office: Dutchess County office: orange County office: New England office: North Country Office: Ithaca Area Municipal Wastewater Collection Improvement Project a.. 20 Gurley Avenue 21 Fox Street 263 Route 17K Straus Business Centers 110 Glen Street I September 29, 2003 COMPARES Troy, New York 12182 Poughkeepsie, New York 12601 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 5 Engineers /Surveyors Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Figure 19. Unique Natural Areas. I Various; see maps Phone: (781) 556-1037 Planners Environmental Scientists This map is a product of The Chazen Companies. It should be used for reference purposes only. Reawnable efforts have been made to ensure the accuracy of this map. Figure 19 GIs Consultants The Chazen Companies expressly disclaims any responsiblities or liabilities from the use of this map for eny purpose other than its intended use. 9 I LJ 0 1 Il 4 � fl r I� r i I I 1 1 Town of Lansing 1 : 55,000 Miles 0 0.6 1 2 ® Municipal Boundary �j Sewer Service Area Q Proposed Pumpstations Proposed Sewer Lines for Service Area Unique Natural Areas Site Code, Site Name 0 UNA-102, Renwick Slope 0 UNA-103, McKinneys Twin Glens and Lake C 0 UNA-24, Lake Cliffs, North of Myers Point 0 UNA-28, Ludlowville Woods 0 UNA-52, DEC Mapped Wetland (Code WG14) 0 UNA-53, Portland Point Quarry 0 UNA-54, Minnegar Brook.Woods 0 UNA-55, Lower Salmon Creek 0 UNA-63, Shurger Glen 0 UNA-64, Lake Cliffs, South of Portland 0 UNA-65, Head Comers Wetland 0 UNA-66, Cornell Ponds #1 and DEC Mapped (Code WG21) 0 UNA-67, Dryden -Lansing Swamp 0 U NA-88, Airport Ponds, Wetland 0 UNA-89, Lake Cliffs, McKinney's Point to Bolton Point 0 UNA-90, Esty's Glen Roads �s State Highway County Highway Local Road THE Gap COMPARES Engineers / Surveyors Planners Environmental Scientists GIS Consultants e4 ROAD �- 34B 34 1NA-54o� Z Jy— UNA-53 y`�,fm , ` O R- ROAD l'. 9,x to �P = ASBURY UNA-63 0 p� _ _W v CAYUGAL 4KE E E qO s� 34 \Q�esr -RUN, - rn ,� � WATERWAGON 0 ` L KE co .� 1 o mm Y ;0 UNA-102 c°man o 0N 2gN zA -65 r :5�o UTC — Village of Cayuga Heights CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue 21 Fox Street 263 Route 17K Sbatls Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsle, New York 12601 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone;(781) 556.1037 This map Is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than Its Intended use. a UNA-67 Town of Lans.i f U vtllage Cayuga H ght� 79 City 0 as 327 To Town of - 13 Town of Carolin . )A-88 o w n o f OAD T-wn of Newfiel 34 R Municipal Boundary 0 2 4 8 �� 0 Study Area Boundary Miles 0 Area shown on large-scale map State Highway Index map of Tompkins County, NY showing the study area Disclaimer: Unique Natural Area boundaries were delineated by field biologists based on a review of air photographs, digital GIS base map data (roads, building footprints, 20-foot contours and streams) and field visits. Unique Natural Area boundaries are approximate and should be used for general planning purposes only. As a practical matter, Tompkins County does not warrant the accuracy or completeness of the information portrayed. The end -user of this map agrees to accept the data "as -is" with full knowledge that errors and omissions may exist, and to hold harmless the County for any damages that may result from inappropriate use of this map. oeaxd br: Draft Environmental Impact Statement: Carol Conolly Ithaca Area Municipal Wastewater Collection Improvement Project mt.: September 29, 2003 Figure 33. Unique Natural Areas and Proposed scale: Town of Lansing Service Area Sewers. various; see maps Figure 33 IV. WRITTEN COMMENTS RECEIVED ON THE DEIS m TOMPKINS COUN DIVISION OF E] 25 June 2003 NYS DEC Region 7 — Cortland Office 1285 Fisher Avenue Cortland, NY 13045-1090 Attn: John Merriman "DEPA R.TM VIROl�llIIEN�, 7 arms B:'Oes'brive New _Yorks 485071385 f 667)= 274-6688:!' OF HEALTH AL HEALTH Re: DEIS - Ithaca Area Municipal Wastewater Collection Improvement Project Dear John: Thanks for the opportunity to comment on the DEIS of this important project. The DEIS appears to be very complete and we have very few comments, as follows: a Page xxviii: Section XII List of Involved Agencies and their Authority for the Project; 1.; the DEC will likely also be responsible for approval of plans for the new constriction, given the scope of the project, that most is in a new service area, and that State funds are involved. • Page xxix: Section XII; County Agencies: It is more likely that the DEC, not the Tompkins County Health Department, will review and approve the plans. The TCHD is ready to assist in review and approval if so desired by DEC, as the TCHD does for most collector sewers. a Page 30: first para, states that all water bodies are Class C in the DEIS Study area. Actually, many are classified as "D" and "A" as shown on Figures 14A and 14B. The Figures have a column titled "Protected Status Code" so only C (T) and higher streams are listed. The column should be labeled "Standards Class" and show all classes. This point is only for clarification, as the Stormwater Permit will protect the "D" streams and unclassified watercourses. Page 31: last para states that there are numerous private well points located throughout the DEIS Study area that have not been comprehensively mapped. Some of these well points are regulated public water systems, and these have been mapped; the data is available through the Tompkins County Planning Department. There are few, if any, in the service area as most of the service area is already served by municipal water. If the final plans do indicate impacts on a regulated water system from the sewer construction, it may need to be abandoned and the municipal water systems used if available. We look forward to the Final EIS and development of engineering plans and specifications to solve the identified problems in the service area. Sincerely, eo Jo M. Andersson, P.E. D ector, Division of Environmental Health Services '. � Q a:IthacaAreaDeis.p 19 't,,* Recycled paper Toiiipkins ;C6i i ty DEPAR-TMENTV-0f. PLANNING Edward C. Marx, AICP Commissioner of Planning John Merriman NYS Department of Environmental Conservation Region 7 — Cortland Office 1285 Fisher Avenue Cortland, New York 13045-1090 VIA FACSLMLE AND MAIL °14850 August 11, 2003 Re: DEIS Ithaca Area Municipal Wastewater Collection Improvement Project Dear Mr. Merriman: Telephone (607) 274-5560 Fax (607) 274-5578 Overail, we are supportive of the Ithaca Area Municipal Wastewater Collection Improvement Project, as it will eliminate nonpoint source pollution currently caused by inadequate on -site sewage disposal systems in the project area. The reduction of nonpoint.source pollution is important to maintaining the public health and welfare of Tompkins County residents and those who use Cayuga Lake as a drinking water and recreational resource. From a broad perspective, it appears that this reduction, combined with an increase in the overall level of treatment for wastewater generated in the Cayuga Lake watershed, will help protect the economic vitality and well-being of Tompkins County. One issue that we believe should be addressed and analyzed more fully prior to accepting the FEIS is the specific impact of reallocating wastewater to, and concentrating treated effluent in, point discharges to the southern end of Cayuga Lake. This analysis should include how additional loading might impact aquatic bioat:_, algal and weed growth, and influence levels of dissolved oxygen. The DEIS does include a section assessing the impacts associated with the sewer lines in the Lansing Service Area, however it does not include details about the actual construction and installation of the lines, such as the size of the construction right-of-way, how deep lines will be buried, and what the area of ' disturbance will be. Without this information, it is not possible to accurately assess the environmental impact of construction on stream corridors, instream habitat, wetlands, and Unique Natural Areas (UNAs). This analysis for the Lansing Service Area should be included in the FEIS and be explicitly addressed in the construction plans (referenced below) for the Lansing Planning Area. We understand that the location of the sewer lines in the Dryden Planning Area is still in the conceptual stages and the DEIS does not discuss the environmental impacts in this area. Additional environmental reviews will need to address the full range of impacts in the Dryden Planning Area. Sewer Line Route Location An alternate route should be considered for the sewer lines that are proposed to cross UNA 65. This is the Head Corners Wetland, a large federally designated wetland that the UNA Inventory identified should be added to the New York State Freshwater Wetlands Inventory. Consultation with the DEC should be DEIS Wastewater Improvement Project Page 2 of 3 initiated prior to any disruption of the area. We support the DEIS suggestion (Section 5.4) that a wetland scientist should survey the area and make recommendations for limiting impacts to this wetland. UNA 103, McKinney's Twin Glens and Lake Cliffs, exhibits a high number of rare or scarce plants that could be disturbed. We agree that a biological survey of the proposed sewer line route should be conducted. It should be completed prior to the end of the SEQRA process so it can inform a decision of whether trenchless construction will be used (as recommended in the DEIS). It should be noted in the existing conditions section of the DEIS that UNA 103, McKinney's Twin Glens and Lake Cliffs, contains a section of the old Ithaca -Auburn Shortline that crosses the glen. The UNA Inventory indicated that abutments and one trestle are still intact that may have historic or cultural significance and may be worthy of protection. It is unclear where the sewer lines are in relation to these structures, however, if the sewer lines are in proximity to these features, an assessment of the impacts should be included in the FEIS. Sower fine routeZ should consider known private drinking water wells and wells for public drinking water systems located within the study area (such as Myer's Point, Ludgate's, and the Plantations Inn) and steps taken to reduce potential impacts to those water supplies. Construction Plans The DEIS identifies a number of construction plans that will need to be completed prior to beginning construction. These plans include erosion control, blasting, dewatering, and dust control plans, as well as delineation of construction boundaries. The FEIS should detail what is to be included in each of these construction plans. Following are some of the items that we would like to see taken into account or addressed in the FF,IS: Due to the extremely steep slopes in the Town of Lansing Service and Planning Areas and the potential direct impact on Cayuga Lake, extensive effort should be taken to minimize sedimentation and erosion resulting from construction. The blasting plan should include a description of how construction and pipe locations might impact private drinking water sources from bedrock wells and how these impacts could be mitigated. When the construction staging areas are identified, the potential impacts should be analyzed. We recommend that areas for construction staging be located outside of any UNAs. Secondary (growth inducing) Impacts There are a number of impacts associated with population growth and increased development as a result of the wastewater project. We do not have the resources available to fully evaluate the methodology and assumptions underlying this analysis within the time allotted for comment. The DEIS acknowledges and discusses some of those impacts, and recommends that the affected towns and villages further study these impacts and update local comprehensive plans and zoning ordinances. We agree that these impacts should be further evaluated by the participating municipalities, and without more comprehensive review, would not recommend that those municipal analyses rely upon the information contained in the DEIS. Following are some of the items that towns and villages should look at, in addition to those identified in the DEIS: Induced growth may increase the demand for public and private drinking water supplies. The adequacy of public water supplies and private drinking water wells should be considered. The transportation demand model used to analyze traffic impacts dilutes the impacts by spreading them throughout the entire study area. Local governments should recognize that specific transportation corridors may experience increased congestion depending on the density and intensity of land uses allowed in a particular area and the timing of sewer line extensions. Local comprehensive plans should carefully evaluate these relationships between infrastructure and land use. DEIS Wastewater Improvement Project Page 3 of 3 We also offer the following observations: The Dryden Planning Area that is delineated in the DEIS is not consistent with the Town of Dryden's Draft Comprehensive Plan. The Dryden Planning Area is significantly larger than those areas identified for expanding sewer service and accommodating future density in the Town's Comprehensive Plan. We were pleased to see that there are plans to investigate the possibility of using the former railroad right- of-way as a recreation trail in conjunction with this project. This is an excellent opportunity to create trails that link the Lansing Community and the larger community. The DEIS relied on Soil Association mapping for an assessment of soil conditions in the study area. For your information, Tompkins County has a digital version of the more detailed soil series map for Tompkins County. This data may be obtained from the Tompkins County Information Technology Services Division. Thank you for the opportunity to review this project. Sincerely, LZ Edward C. Marx, AICP Commissioner of Planning cc: Barbara Blanchard, District No. 1 Leslyn McBean, District No. 2 Richard Booth, District No. 3 Nancy Schuler, District No 4 Tom Todd, District No. 5 Frank Proto; District No. 7 George Totman, District No. 9 Dooley Kiefer, District No. 10 Michael Koplinka-Loehr, Distr.*,<:t No. 11 Tim Joseph, District No. 12 Martha Robertson, District No. 13 Michael Lane, District No. 14 TOM]P']KIN55 COUNTY t1•S c�G ]EN VII]KON1\ I ENTA\]L MA NA\GIEl\ RENT COIL NCRIL 10 ' n21 East Court Stireet Ithaca, New 'Yoirlk n4850 Telephone (gory) �i9�"5560 Fax x (60�) �ry9E-55�8 ; �-, (S D ` August 11, 2003 John Merriman NYS Department of Environmental Conservation Region 7 — Cortland Office 1285 Fisher Avenue Cortland, NY 13045 VIA FACSEVIII.E AND MAUL Re: DEIS Ithaca ?Area Wastewater. Collection Improvement Project Dear It h Merrinan: The Tompkins County Environmental Management Council appreciates the opportunity to comment on the Draft EIS for the Ithaca Area Wastewater Collection Improvement Project. We appreciate the idea that this project is intended to be protective of Cayuga Lake. We have several areas concern and request that you consider our comments in the FEIS. Unique Natural Areas The DEIS lacks in-depth information to assess the full range of impacts to the UNAs in the project study area. For example, there is no indication of the depth of placement of the proposed sewer lines, which would help outline a more distinct range of disturbance to these areas and allow for realistic and concrete mitigation measures to be proposed. We would also like to note that the existing maps of UNA boundaries are not exact. Placement of a sewer line on the boundary does not necessarily mean that there will be no impacts to the flora and fauna, geological structures, habitats, etc. that are found in that area. We strongly support the recommended alternative transmission proposed for the Twin Glens and Esty's Glen UNAs and would like to see alternative transmission routes placed along road beds or further away from the other I)NAs in the study area. The UNAs are areas that have been determined to have exceptional examples of habitats, geological formations, etc. While there is no direct authority to regulate these areas, we believe they are worth preserving and hope that DEC would agree. To limit, disruption to such areas, we suggest that the DEIS consider trenchless digging as an alternative. We also request that the DEIS include alternative locations for the two pump stations that are proposed in the LNAs in the Lansing Service Area. The DEIS suggests that a biological survey of the proposed sewer line route should be conducted prior to construction in UNA 103 (McKinney's Twin Glens and Lake Cliffs). We concur with this recommendation and request that the survey be conducted during the appropriate time of year to reveal the potential plants or animals impacted. If any threatened, rare, or endangered species are found along the proposed route, the sewer line should be diverted away from the UNA. Wetlands The DEIS acknowledges that degradation to wetland functions may be caused by the sewer lines in proximity to the federal wetland in UNA 65 and other wetlands primarily associated with stream corridors. Loss of wetland function can have other negative impacts on surrounding lands due to flooding The EMC is a citizen board that advises the County Legislature on matters relating to the environment and does not necessarily express the views of the Tompkins County Legislature. TC EMC Comments DEIS — Wastewater Project Page 2 of 3 as well as problems associated with water quantity and quality in stream corridors and eventually, entering Cayuga Lake. Care should be taken to preserve and protect wetlands throughout the study area. We note that most of the wetland analysis focuses on meeting NYS regulations rather then the Federal regulations that are much more stringent. The impacts to Federal wetlands should be more clearly analyzed. The DEIS states that "The Project Engineer for the proposed project has reviewed the location of proposed sewer lines in the field and determined that no Federally regulated wetlands will be impacted by the project." When the location of the lines is determined, a wetlands scientist should conduct a more complete analysis of potential wetlands impacts. The DIES should address this need. Figures 17 and 18 are useful as is, but the DEIS should contain a map showing all wetlands overlayed with the proposed sewer lines, preferably at a finer scale (for example, 1:24,000). Similarly, figures 44 and 45 are useful as is; could therc be an. additional figure combining their information into one map? Water Resources There are numerous private well points located throughout the DEIS Study Area, but they are not mapped and their locations are not known. Section 4.5.1 (Impacts to Water Resources) should acknowledge that there could be negative impacts to these well heads. Mitigation, wherever possible, should be rccommended. Project Schedule We note that, as presently described in section 2.7, the survey and stakeout of the proposed sewer line alignments will most likely be done one week ahead of the construction schedule. This short timefraine will likely not be sufficient to deal with any problems that may arise. For example, if an area of wetlands soils are recognized, what measures will be taken to confine the existence of wetlands, and if necessary identify alternate routes or other measures to mitigate possible negative impacts to these areas? We suggest lengthening the time between the survey / stakeout and construction to at least four weeks to provide the ability to make rerouting decisions that may be necessary due to site conditions. The project contemplates 26 stream crossings. The analysis, planning, and engineering should be conducted prior to starting construction. This approach should be discussed in the DEIS. General Comments It would be helpful to include the VCHWTP and the UWWTI locations and existing pipe connections for reference on at least Figure 4. "We share DEC's desire to protect and enhance Cayuga Lake waters. Rather than simply committing to building 26 miles of new sewer lines that could conceivably worsen water quality at the southern end of the lake, DEC could again consider the alternative of permitting what could be a less expensive option of building a state of the art satellite treatment plant for the Town of Lansing that would release effluents into a deeper, more northern, and less impaired portion of the lake. This alternative requires fuller discussion in the DEIS. Impacts to the Southern End of Cayuga Lake There should be some discussion in the FEIS of the environmental impacts of concentrating sewage from. a larger area into the shallow, southern end of Cayuga Lake and the reasons for doing so. Following are some of our concerns: 1. Cayuga Lake is listed on the national 303(d) listing of waterbodies and is a candidate for a comprehensive Total Maximum Daily Load CII ML) pollution control program. The DEIS should indicate the extent to which implementation of the proposed wastewater collector system would mitigate water quality problems at the southern end of Cayuga Lake. For example, without TC EMC Comments DEIS — Wastewater Project Page 3 of 3 documentation of projected phosphorus loading into the lake from interconnecting and expanding the service area of the existing two wwtps, it would be prudent to assume that a new treatment plant releasing treated effluent into the Lake from the Town of Lansing (north of Meyers Point?) would have less adverse impact on water quality at the south end of the Lake than would the transport to and treatment of Town of Lansing wastewater at the Ithaca Area Waste Water Treatment Plant. 2. The DEIS should be more specific about the rates of discharge and incidence and amount of overflow from each of the WWTPs on pages 9 and 10. Without this information, it is difficult to assess the impacts on the southern end of the Lake. We are aware that the DEC has approved an increase in allowable phosphorus discharge into the lake from the IAWWTP from 30 to 40 pounds per day. However, as far as we are aware, the DEC has not yet developed a TMDL program for the lake subsequent to southern Cayuga Lake being listed in 2002 as a priority candidate for such a program. A TMDL should be developed prior to permitting any increases in phosphorus loading of the lake and should be in place prior to the approval of any new wastewater treatment piant or construction of this project. 3. While we accept the premise that water quality in the southern end of Cayuga Lake has been impaired for many years, any proposal to reroute present and future waste water from widely distributed septic systems and small package plants to two wastewater treatment plants that discharge into the already impaired waters at the south end of Cayuga Lake should be documented in the FEIS. For example, there are no data as to the frequency and extent to which existing septic systems in the proposed project area are faPing and whether septic system -based waste treatment is adversely impacting Cayuga Lake, other waterways, or general public health. 4. The alternative of using smaller, more widely -distributed treatment plants is ruled out without any citation of technical literature whatsoever. It is simply stated that "..a larger plant is likely to incorporate a higher degree of wastewater treatment, resulting in a higher quality of treated waste discharge, particularly with respect to phosphorus removal." The DEIS contains no evidence to make a case that centralization of waste water treatment infrastructure would in this instance be more cost-effective or technically superior than a more decentralized approach using an additional treatment plant serving the Town of Lansing that would discharge treated effluent into a more northerly part of the Lake. This needs to be discussed in the DEIS. The DEIS should at least mention that the strategy of centralizing wastewater treatment facilities across six municipalities runs counter to the post 9-11 recognition that centralization increases vulnerability. It should also be acknowledged that the alternative of relying on efficient, smaller -scale distributed infrastructure would promote the maintenance of greater region -wide functionality during times of natural or man -induced calamity. Thank you again for the opportunity to comment. Sincerely, J Steve Uzmann Chair, Environmental Review Committee Tompkins County Environmental Management Council t ` sxcsstoR STATE OF NEW YORK DEPARTMENT OF TRANSPORTATION 333 EAST WASHINGTON STREET SYRACUSE, N.Y. 13202 JON P. EDINGER, P.E. REGIONAL DIRECTOR August 5, 2003 Mr. John Merriman N.Y.S. Department of Environmental Conservation Region 7 - Cortland Office 1285 Fisher Avenue Cortland, New York 13045-1090 r Dear Mr. Merriman: JOSEPH H. BOARDMAN COMMISSIONER RE: SEQR-COMMENTS ON DEIS PROPOSED ITHACA AREA MUNICIPAL WASTEWATER COLLECTION IMPROVEMENT PROJECT We have completed our review of the above referenced document and have no substantive comments. As noted in the document, various portions of the proposal will need a State Highway Work Permit for activities within the State Highway right-of-way. The person to contact to begin this process is Stan Birchenough, Acting Resident Engineer of our Cortland/Tompkins Maintenance Residency. He can be reached at (607) 756-7072. If you have any other questions, contact William Egloff, of my staff at (315) 428-4409. Very truly yours, ALBERT S. VETTER, P.E. Regional Planning and Program Manager By ?Associate(Transportation s M. Gross �0 - 7 CO Analyst (!:�',jR1ecejv;d a UG-7 M 1203 East Shore Drive Ithaca. NY 14850 607-273-3457 August 11, 2003 Mr. John Merriman NYS Department of Environmental Conservation Region 7--Cortland Office 1285 Fisher Avenue Cortland NY 13045-1090 Dear Mr. Merriman: Thank you for the opportunity to comment on the DEIS for the Ithaca Area Municipal Wastewater Collection Improvement Project. Below are some issues about which I have serious concerns. 1. Regarding the preferred wastewater transmission line from the Town of Lansing to the Ithaca Area Wastewater Treatment Plant (IAWTP), the engineers looped at a gravity -feed line running along the abandoned Short Line Railroad bed, through several -sensitive Unique Natural Areas in the Village of Lansing; down Cayuga Heights Road (which would require the addition of pumping stations); and possibly down NYS State Highway 34. It seems a great omission that in the DEIS, there was no discussion, not even mention, of the possibility of running the transmission line directly to the existing Norfolk Southern railroad line. Given that this is already a highly disturbed area, and disturbance is frequent, it makes sense to avoid all the expensive pumping stations and habitat destruction "in UNAs by studying this alternative. Access to the rail bed is not difficult, whereas access along the abandoned rail bed would be, increasing the cost of maintenance and repair. Please consider all the ramifications of using the N-S Railroad line as the preferred transmission lisle. There would be little disruption of traffic and far less environmental damage than the other alternatives. Certainly, no final decision should be made about this project until this issue has been investigated with the same thoroughness as the other alternatives. 2. Concerning the discussion of how the impacts to the Unique Natural Areas #103 and #89 would be mitigated, frankly, the construction of a pipeline through those UNAs would necessitate the removal of a large number of medium-sized and mature hemlocks in the Twin Glens area, which are irreplaceable. While care will be taken to protect all trees of 12' dbh or larger, the aggregate of these hemlocks creates a beautiful visual scene that no amount of mitigation can restore in our lifetime, These areas are enjoyed by many local residents who walk them year round. The pipeline would destroy the naturalness of the railroad bed, even though it was once a railroad. Since the Short Line went into receivership in the mid-1920s, the rail bed has had some 75 years to grow back into forest. Since the trend -Jess construction technique for installing pipe in such sensitive areas is four tines as expensive ' as the traditional method, I can expect that cost alone will be the deciding factor. This is an EIS and is meant to deal with and prevent preventable oi\environmental impacts. 3. There is no discussion of how to mitigate the impact on a residential drinking g P g water supply that exists in the form of a large cistern that originally was used by the Short Line Railroad during the steam engine years. This water supply is used by the residence (mine) at 1203 East Shore Drive and would be seriously compromised by any trenching activities, since it lies directly below the rail bed. This was brought up during the scoping session but I could find no discussion of how to protect this crucial resource in the DEIS. 4. In Figure 19, Unique Natural Areas, the pinkk color for #102, Renwick Slope, is on the map, but the #102 is not printed on the map. 5. In Figure 33, the same is true for #102, the Newman Tract. Its color appears, but not its title on the map. .6, On Page 16, 2.2.2 Town of Lansing Service Area Proposed Improvements, the text states that "the Tillage of Lansing's existing 15-finch railroad interceptor sewer intersects the railroad grade below Twin Glens Road and terminates at the VCHWTP." This is confusing. is this stated as fact or as part of the proposed transmission system for the Town of Lansing? At present, there is no Village of Lansing sewer interceptor below Twin Glens Road, unless the reference means "farther south" along the railroad bed, instead of downhill, i.e., west, of Twin Glens Road. Please clarify. 7. Finally, NYS has made it clear throughout this sewer planning process that it would only support some kind of intermunicipal solution to the lack of sewer service in the Town of Lansing and the needs to upgrade both the Cayuga Heights and Ithaca Area wastewater plants. Because Cayuga Lake already has more than its share of pollutants being discharged into the south end of the lake, why wouldn't a well -designed modern, small wastewater treatment plant serve the Town of Lansing well and spread the pollution out in Cayuga Lake, rather than concentrating all the effluent at the south end? Not all small plants are equal. There are new technologies available now that treat wastewater efficiently and properly. This whole project is predicated on the assumption that there be no plant to serve the Town of Lansing, when that seems the obvious solution. Grant money could help the .plants at the south end of the lake achieve their phosphorous removal goals and upgrade them . to meet all new standards. A smaller, efficiently run plant in the Town of Lansing would treat the sewage that presently goes into septic systems, not all of which operate well. The logic does not follow that bigger is better and that more sewage to be treated, more effluent to be discharged, and loss of sensitive habitat are better. Thank you for your attention to these comments. Sincerely, t13. Leopold Xc: Mayor Donald Hartill, Village of Lansing Susan Brock, Esq., attorney 9 OF AM 000 11 August 2003 To: John Merriman NYS Department of Fnvi.ronmcntal Conservation Region 7 - Cortland Office 1285 Fisher Avenue C.ortland,'NY 13045 Fax no. 753-8532 From: Dooley Kiefer '-K>J-� 629 HighlandRd. 'fthaca, NY 14850 Subject: DEIS, Ithaca Arca Wastewater Collection Improvement Project 'Dear Mr. Merriman, I have followed Cayuga. Lake's fortunes for many years, and am always interested in projects des'-ned to protect the lake:_ I do have some concerns about the proposed project and note that the DEIS appears to be incomplete in several respects. 1 recognize that development in the Town and Village ofLwising has in recant years been hampered by lack of available public sewer service. I recall that during the past decade both the i Village of Cayuga Heights and the City of lthaca's IAWWTP ba.ve sought funding to upgrade their waste water treatment Plants (WWTPs), and that the llLC: turned down thu Town of Lansing's applicalloai for its own sewer treatment facility, instead urging the three Tompkins County municipalities to get together to see if they could conic up with a joint intermunicipal plan for wastewater treatment. I believe that this may have been suggested as much for fiscal reasons as for environmental ones. As of today, I understand that the City WWTP hat had a capacity upgrade from DEC and is moving to upgrade treatmient and hopefiYlly lessen phosphorus discharge. = as is the Village of Cayuga 1 TeilTbt.s. i support using bond act monies to upgrade existing treatment and lessen phosphorus discharge:. However, this DF.TS only deals with l.u�ing the.two existing WWTPs and allowing se ,er extension (and consequent growth) in Lansing (and potentially Dryden). My biggest concern is with 11-te Planned concentration of effluents. The need to concentrate effluent loads in the srsuther•n env of Cayuga Lake is nat documented in the DER?. and the environmental dash -ability ofdolniz so is questionable. - To document need, the DEIS should be specific about the water -quality issues the project purports to address. There need to be specifics about how many septic systems and small package plants are failing, where, and -when and if they are how, when, and how much are they discharging, to Cayuga Lake. (T do recognize that there are certain developed shoreline areas where septic systems occasionally get flooded by the lake, and these need to be dealt with. Of course this is also true for the west shore of the lake.) I found no data to document that septic out.;1t •Y 4F AM [a 00.3 t I systems — or snia.11 package plants -- are adversely impacting the lake, any streams, or public health. The DRIS should be revised to include such documentation. - Waters in the southern end of Cayuga Take have been added to the national 303(d) listing and :f believe that they are considered a priority for development of TIViDT.s. DFIC: should be extremely careful .adding; to any discharges in this area. Absent documentation in the DEIS of just what the proposed project will mean in the way o f` addition of nutrients and chemicals to these impaired waters, it is impossible to conclude that the proposed project is the best one can do. • As to "need", the DEiS should be specific about the amount and frequency of overflow/bypass from the existing WW'I"Ps, and whether any of ttiosc Problems arc being addressed outside this proposed project. Without this information, it is not possible; to assess those impacts compared to the impacts of this project on the southern ertd of" the lake, T'he DEIS should include a figure/reap shoving Lhe location turd depth of' Lhe existing WWTP discharge points as well as the depth ofthe lake throughout the southern end. I do not believe the case has been convincingly made: in this DEIS that implementation of this project will improve; water, quality problems in the southern end cif the lake. - EvLn granting need fir such a project, the DEIS does not demonstrate that the proposed project is better Lhan the alternative of cons(.ruct.ing a separate Twom of Lansing WWTP that would discharge into Cayuga Lake in a more northerly, less shallow area. A] though DEC: did not approve funding such several years ago, it is still a real alternative. As part of the discussion of this alternative, another map/f gure should be added showing possible; location and depth of disehaTge (or such a new WWTP as well as the lake depths in that area, Absent analysis of effluent -constituent loadings from the proposed project and their impacts on the southern waters, I can only assunie that a new (state-of—the-art) treatment plant releasing effluent into unimpaired waters is preferable_ Such a new plant could even consider using an ozone- and ultra -violet - based treatment rather than just chlorine. Such an alternative deserves serious discussion and analysis in the'DEIS. - The DEIS should discuss the possible biological impacts of the increased WWTP effluent in these impaired waters especially with respect to its reactive-clilorrine content and the further concentration of human -excreted drugs. This latter is an emerging problem, slowly being iccognized and documented in the scientific literature. We are: just learning about how, for example, hormones in sewage effluent affect reproduction and the sex of aquatic organisms_ As yet I believe there are no known ways fear W WTPs to handle this. However, this is aaiother rea.-on to not combine/increase effluent streams. 7'he DLIS should acknowledge these issues and discuss them. In summary, the: DEIS needs major supplementation, missing information and analysis should be provided, arid the DEIS re -,issued for comracrtt. There should he serious discussion of"the environmenlal yrros and cons o1•cc)ncenh-ating sewage f'am. a larger area in the (alread)) impaired waters of thej .Yhullo--v south end q fC'ayugu Lake. i believe this DEIS and is not ready to be: moved to the PETS Stage. Thwik you for the opportunity to commcnL. Walter Hang 212 Fall Creek Drive Ithaca, NY 14850 7 0 Received AUG - 6 2003 Greetings. My name is Walter Hang, and I am an avid sailor of Laser, 470 and Lightning sailboats. For the last four years, I have been actively involved in investigating water quality impairments in southern Cayuga Lake. My goal is to prevent existing pollution problems from growing worse and to make sure that all identified contamination sources are cleaned up as quickly as feasible to comply with applicable local, state and federal legal requirements. With those interests in mind, I reviewed the Draft Environmental Impact Statement (DEIS) for the Ithaca Area Municipal Wastewater Collection Improvement Project and would like to offer detailed comments for your consideration. t_ With due respect, the DEIS is not an Environmental Impact Assessment. It is a blueprint for development. The DEIS proposes a sewer collection system that would foster residential, commercial and industrial development at public expense. That is not necessarily something which I oppose, but the proposed project would contribute to water quality impairments that have t hampered Cayuga Lake for decades. The DEIS neither identifies those impacts nor suggests how to eliminate them. For that reason, it should not serve as the basis of public decision making. I urge you to oppose the proposed project in its current configuration or to require it to be redesigned to eliminate any impact on our beleaguered lake. Please allow me to elaborate. i• Proposed Project's Premise Is Totally Unsupported by DEIS First and foremost, the DEIS does not make a persuasive argument that the proposed ! project is necessary. The key point of consideration'is on page 128: "...the premise of this project is that the continued environmental impacts associated with in -ground systems in the Town of L Lansing Service Area are greater than those associated with an increase in discharge of treated sewage to Cayuga Lake." The DEIS fails to provide a shred of detailed documentation in support of its premise. It does not demonstrate that either on -site septic systems or wastewater discharges in the project _ area contribute to pollution hazards in Cayuga Lake. The DEIS provides no calculation of wastewater flow, no pollution loading study nor any delineation of wastewater entering the lake. Absent these data, there is no reason to accept the proposed project's central premise. 0 On the contrary, any pollution reductions in the project area are likely to be far outweighed by increased water quality problems in southern Cayuga Lake. Southern Cayuga Lake's Long -Standing Water Quality Impairments Cayuga Lake's southern 5,000 acres have turbidity and phosphorus levels that impair the lake's best use. Public bathing has been banned at Stewart Park since the early 1960s due to turbidity. High phosphorus levels cause vast algal blooms that clog virtually the entire area north of Stewart Park during late summer months. Both of these problems pose serious risks to drinking water drawn from the lake and supplied to tens of thousands of residents. As a result, the lake is listed on the national 303(d) listing of waterbodies requiring comprehensive clean up. Cayuga Lake's main polluted area is the southern basin where effluent discharges from the Ithaca Area and Cayuga Heights wastewater treatment plants and Lake Source Cooling are dumped into waters less than 12 feet deep. Phosphorus released into these shallow waters supports massive algal blooms. See photo. To make matters worse, phosphorus and turbidity discharged by Cayuga Inlet, Cascadilla Creek and Fall Creek pollute the same area. See photo. The result is water quality impairments that have persisted for decades. In stark contrast, Cayuga Lake in the proposed service area is deeper, receives far less pollution and does not suffer from widespread impairments. It make no sense to transport wastewater from the proposed service area in order to dump it precisely where Cayuga Lake's worst pollution impairments exist. The treated wastewater would contain significant amounts of phosphorus and would undoubtedly contribute to existing water quality violations. Key Regulatory Safeguards By -Passed Granting approval for the proposed project would continue a long history of failure to enforce state and federal laws requiring clean up of Cayuga Lake. The U. S. Clean Water Act at 40 CFR § 122.4(i) prohibits the issuance of discharge permits to "a new source or a new discharger, if the discharge from its construction or operation will cause or contribute to violation of water quality standards." Wastewater collected in the proposed service area was originally intended to be treated by a new facility requiring a discharge permit. That permit would have been prohibited by the federal moratorium provision. Conveying the wastewater to the permitted Ithaca Area Wastewater Treatment Plant by-passes this critical non -degradation safeguard. The New York State Department of Environmental Conservation (DEC), the lead agency for the proposed project, failed to enforce this key provision by granting a discharge permit to the Lake Source Cooling project. That effluent now contributes nearly ten percent of the phosphorus entering southern Cayuga Lake. Cornell's own monitoring data illustrate the large area of the lake that exceeds the 20 parts per billion recreational water quality guideline. 4 Phosphorus is the growth -limiting factor in Cayuga Lake and causes increased algal growth. The DEC recently renewed this facility's discharge permit. The DEC also ignored its own regulatory policy (Technical and Operation Guidance Series 1.3.6 document) by approving a revised discharge permit for the Ithaca Area Wastewater Treatment Plant. That revision allows an increase in phosphorus discharge from less than 30 pounds per day up to 40 pounds per day. r Finally, Southern Cayuga Lake is a high priority for a comprehensive Total Maximum Daily Load (TMDL) pollution control program, but the DEC has made no tangible progress toward that goal. The DEC rejected a 2001 offer of Environmental Protection Agency funding support for a study of water quality in the impaired portion of the lake. Moreover, no TMDL has been developed or adopted since the lake was listed in 2002. It is absolutely essential that the TMDL for southern Cayuga Lake is based on: an assessment of the proposed project's water quality impact. There is no justification for approving the proposed project prior to the development of the TMDL. The proposed project should only be approved after the TMDL is proposed, adopted and implemented or other regulatory safeguards are imposed to assure no further degradation of water quality. Proposed Project Would Undercut or Eliminate Benefits of Improved Phosphorus Treatment Most galling of all, the proposed project would undercut or eliminate the benefits: of a proposed phosphorus removal upgrade to the Ithaca Area Wastewater .Treatment Plant. That facility currently removes phosphorus to less than 0.7 milligrams per liter (parts per million (ppm)) on a 12 month rolling average basis. As a result, approximately 27.5 pounds of phosphorus are i discharged daily into Cayuga Lake. If the upgrade is completed in perhaps two years, phosphorus would be reportedly removed to less than 0.2 ppm on a 12 month rolling average. The proposed project is estimated to generate wastewater containing 25 to 36 pounds per day of phosphorus or 11 % to 16% of the 220 pounds of phosphorus now received by'the Ithaca Area Wastewater Treatment Plant. That contribution would off -set improved phosphorus removal at the upgraded plant. If the wastewater generated by the proposed project exceeds the DEIS's estimate, there could actually be a net increase in phosphorus discharged into the lake because the plant's revised permit allows up to 40 pound of phosphorus to be discharged daily. Proposed Project's Goals Could be Achieved Through Cheaper and Better Alternatives I I urge you to think long and hard before supporting the proposed project because its goal of eliminating existing wastewater impacts in the proposed service area could be achieved through technically -superior, lower -cost, on -site treatment alternatives. According to the DEIS: 'Currently, inadequate on -site septic systems are in use within the proposed Town of Lansing Service Area. For example, the Tompkins County Health i Department has identified limitations or inadequacies with systems in the Lagoda Park;area, the mall near the intersection of Atwater Road and Route 34, the tavern at the corner of Drake Road and Route 34 and at the Lansing Central School District. Elimination of these inadequate systems will improve ground and surface water quality." The DEIS also notes: "Currently, individual SPDES discharge permits are held by residential, commercial, industrial and institutional facilities that fall within the proposed Town of i Lansing Service Area. These include the Lansing Central Fire Station, Colonial Cleaners, Hunter Apartments, Lakewatch Inn, New York State Office of Children & Family Services facilities, Cargill, Inc., Woodsedge Apartments, Transonic Systems and UPS. Elimination of the individual sewage discharges at these facilities will improve the water quality of Cayuga Lake because, with the exception of the New York State Office of Children & Family Services facilities, the systems for which these permits have been issued do not incorporate phosphorus removal." It is inconceivable that a $11,210,000.00 capital cost pricetag is justified by purported pollution reductions involving one neighborhood, a tiny mall, a tavern, a firehouse, several schools, two small apartments complexes, three companies, a dry cleaner and a part-time restaurant. The total amount of wastewater estimated to be diverted to the Ithaca Area Wastewater Treatment Plant by the project over the course of the coming 20 years is only 1.3 million gallons per day. For a fraction of the proposed cost, each of the referenced discharges could be equipped with "state -of -the art," on -site phosphorus removal systems that could safeguard Cayuga Lake without constructing a 26-mile long wastewater collection system. The only firm financial commitment to the proposed project is a $4,203,000.00 allocation from the New York State Clean Water/Clean Air Bond Act. That leaves two-thirds of the overall pricetag in question. It would be irresponsible for authorities to assume such a staggering financial liability without completing a more rigorous environmental benefits analysis. _I h How the Proposed Project's Pollution Impact On Cayuga Lake Could Be Eliminated If you wish to support the proposed project despite its environmental and financial shortcomings, I urge you to require it to be redesigned in order to prevent further degradation of Cayuga Lake. Off -set the Proposed Project's Pollution Contributions The report of the EPA's Federal Advisory Committee on the TMDL program recommends that new pollution discharges into impaired waters be off -set by curtailing pollution sources in its drainage basin. In short, the total amount of phosphorus pollution generated by the proposed project should be measured as it flows into the Cayuga Heights Wastewater Treatment , Plant. At least twice that amount should be cleaned elsewhere in Cayuga Lake's watershed to ensure that phosphorus loading in the southern lake continuously goes down instead of up. If more wastewater is generated by development than estimated, more clean up would be required. For example, phosphorus contained in stormwater run-off could be controlled by constructing artificial wetlands, notably at the mouth of Cayuga Inlet. Buffer zones could be established along agricultural areas to prevent fertilizer run-off into tributaries to Cayuga Lake. The Lake Source Cooling Project is a significant phosphorus discharge that could be curtailed. Cold water pumped up from the bottom of the lake near the Ithaca Yacht Club contains phosphorus that accumulates naturally at those depths. Instead of discharging this massive volume of cooling water into the southern lake, a study should be undertaken to determine if the water could be supplied as potable drinking water. Lake Source Cooling water is drawn from a depth of approximately 250 feet at a location upgradient of the impaired portion of Cayuga Lake. Bolton Point, where raw water is drawn from less than 100 feet, is directly downgradient from the wastewater dumped into the southern lake. As a result, the main polluted area of the lake flows away from the Lake Source Cooling intake and directly toward Bolton Point's intake. Supplying Lake Source Cooling water as potable water could significantly reduce phosphorus loading to the lake. Cooling water used as drinking water would be purified before being consumed and treated before being discharged as wastewater. Lake Source Cooling's discharge currently receives no phosphorus removal treatment whatsoever. Much of the water supplied for potable purposes irrigates lawns or washes cars and might not impact the lake. .1 Upgrade Cayuga Heights Wastewater Treatment Plant With due respect, Cayuga Heights Wastewater Treatment Plant is an out-moded facility that lacks state-of-the-art phosphorus removal. The facility also lags behind the Ithaca Area Wastewater Treatment Plant's efforts to upgrade its phosphorus removal capability. That problem should be rectified to help reduce phosphorus discharges into Cayuga Lake. Merge and Extend Existing Discharge Pipes Into Deeper Waters �. Discharge pipes for the Ithaca Area Wastewater Treatment Plant, the Cayuga Heights Wastewater Treatment Plant and the Lake Source Cooling facility all dump phosphorus into shallow waters with abundant sunlight. In warm summer months, the result is algal blooms. A study should be conducted to determine whether the three discharge pipes could be merged and moved to discharge the combined effluent into deeper waters below the photic zone far from existing drinking water intakes. By discharging phosphorus at a depth where there is no sunlight, it might very well be possible to prevent algal blooms and help safeguard drinking water quality. Such a project is technically feasible and might receive regulatory approval because treated sewage is warmer than Lake Source Cooling's effluent. Since Lake Source Cooling's discharge constitutes a much larger volume than the treated sewage, the combined discharge might be cool enough to warrant discharge into the deeper waters of the lake. _i Manage the Proposed Project's Wastewater Without Discharges to Cayuga Lake Studies should be undertaken to assess the technical feasibility as well as the costs and benefits of manaqing the proposed project's wastewater without any discharges to Cayuga Lake. Treated wastewater might be able to be discharged into a nearby receiving body of water that is not listed on 303(d). Such a possibility should only be considered if the discharge would neither cause nor contribute to existing water quality violations in strict compliance with the permitted discharge moratorium at 40 CFR § 122.4(i). Another alternative could utilize spray irrigation systems that disperse treated wastewater at low application rates over forested lands, silvaculture facilities or other appropriate areas. Any beneficial application of wastewater could not threaten groundwater or surface water quality or pose environmental or public health hazards that exceed applicable ti standards. 1 Conclusion The oath sworn by physicians requires that they first do no harm to their patients. That principle should guide all public policy decisions when it comes to protecting Cayuga Lake. I have summarized how local, state and federal governments have failed for decades to return our beautiful lake to its natural state of ecological balance. They have permitted ever increasing amounts of pollution to be dumped into its impaired waters while making meager progress to curtail identified contamination sources. In the last four years, Cayuga Lake's pollution troubles have received extensive national attention. As a result, I am hopeful that the downward spiral of our precious lake can finally be reversed. 1 will strongly oppose all projects that hinder that progress. In conclusion, the proposed project either should not be approved or should be required to ` be redesigned to prevent any further degradation of Cayuga Lake. Approval of the proposed project without additional safeguards would invite a concerted and vigorous citizen response to protect the lake. `` Thank you for your consideration. 41 MIN Y�W Sample Location 6 Total Phosphorus 4/5101 22.7 ppb 6/28101 233 ppb 819101 21.2 ppb 8/23/01 35.5 ppb 25% of samples over 20 ppb guidance value 1 KU-" Sample Location 5 Total Phosphonu 4/5/01 45.4 ppb 6/28/01 20.6 ppb 8/9/01 20.5 ppb 8/23/01 22.7 ppb 25% of samples over 20 ppb guidance value \ V Samplc Location J Total Phosphorus 415101 26.2 ppb 6/28101 29.8 ppb 8/23/01 21.1 ppb 1 18.75% of samples over 20 ppb guidance value Sample Location 2_' _ �'�"-y= '_�^•" Total Pho horns ' 4/5/01 43.8 F . b = ' 4/20/01 66.4 ppb 6114101 21.1 ppb = 6/28/01 34.7 ppb 7/12/01 37.4 ppb- 8/9/01 49.6 ppb 8/23/01 76.7 ppb 9/6101 8-1.5 ppb- 9/20/01 35.0 b PP 1014101 48.0 ppb 't • _ 62.S% of samples over 20 ppb guidance value _ ® Sample Locations LSC Intake " Discharge Pipes w e x Lake Depth in feet s n WWTP Waste Water Treatment Plant 20ppb guiduce valor: Tedudcal Opeutiomt Gai-duce Series 1.1.1: New York State neputmm ofFnvcomnerM Cmuervation I S- C.yvP take Wmer Qaaty btonitoring Related to tl. LSC Facility: 2001 Prepredby: Update Fceshwma hotiape• Spreomd by. Cornea Uni-if 1 0 Lake Source Cooling 2001 Total Phosphorus Monitoring Results Exceeding New York State's Guidance Value of 20 parts per billion Sample Location 3 r Total Phosphorus 4/5/01 39.6 ppb _ (4/20/01 30.9 ppb 513/01 22.9 ppb 7111101 21.2 ppb 8/9/01 28'0 ppb � . 8/73/01 37.5 ppb 37.5% of samples over wu Y 20 ppb guidance value - y + { Sample Location l Toml Phosphorus 4/5101 35.8 ppb 4/20/01 23.9ppb 5/3101 22.1 ppb rN 6128/01 29.4 ppb ' 7/12/01 33.2 ppb f 8/9/Ul 26A ppb 8123101 28.4 ppb `_ 9/6/01 32.6 ppb 50% ofsamples over �- - - 20 ppb guidance value t - - - Sample Location 7 Total Phosphorus 4/5/O1 25.0 ppb 4/20101 31.8 ppb a r 5131101 22.4 ppb 6128/01 333 ppb mY Y i r 7/12/01 39.8ppb 7/26/01 21.8 ppb - 8/9/01 30.6 ppb 8/2-1/01 34.5 ppb 9/6/01 203 ppb 9/20/01 36.6 ppb 10/4/01 31.1 ppb lE - � "! 68.75%ofsamples `F _ over 20 ppb guidance value / V I I _ • Additional total phosphorus sampling conducted 5 miles NNW -* of LSC Intake. t' Guidance value not exceeded. 1. 1 r � Cavyridd 2002 Toxin T.geting l- I Dear DEC, �?- 11-03 I am a concerned citizen and not an expert on scientific matters. I want to make public comment cause I care about the health of Cayuga Lake and my community. I have read the document as best I can. It is very difficult for anybody without much knowledge of the project to completely comprehend what is in the DEIS, especially without adequate backgrounds in the various fields of expertise needed for evaluation. However I have my opinions on the matter which I shared at the public hearing at the Ramada Inn. I have learned a lot from the public hearing itself, and the informational mtg. last month, and have read more on the DEIS and would like to submit my comments in writing as well. I also want to acknowledge the time and years people have put into this project, and that it is difficult for me to be critical when I did not put the same effort into this matter. In reading the DEIS, I find that it is lacking in documentation of the critical state the southern end of Cayuga Lake is in. This critical state of the lake is of great importance to me and many others in our area. The southern end is very shallow and bringing more phosphorous into it will only increase the problems to the lake. Our lake is now on the national 303 listing of impaired bodies of water. I do not feel LSC should have been allowed to be established, with the lake's problems. LSC has no monitoring by the output, which is at a critical spot in the southern basin of the lake. I became very concerned with the DEC's standards and ethics. I was also told how the Cayuga Heights plant has troubles and why hasn't this been addressed by the DEC for years now? I also have serious concerns about the CU vet school waste, possibly going to the Ithaca Area wastewater treatment plant. We need to address how we are going to deal with this impairment first, before we allow more waste into our SOUTHERN BASIN and I do not see this concern with this project in the DEIS. There is need for more discussion on Alternatives to this project. I am deeply concerned about this_ I do not see adequate explanation on why other alternatives cannot work. I feel that we may have other alternatives, yet maybe more expensive, or may take longer to plan but what's important is the long-term health of our lake and our environment which cannot be replaced -I do care about how people feel inconvenienced by the systems they now have in place and how they are also not working effectively. But we cannot afford to make the wrong choicest I find it very hard to comprehend sending all the waste of Lansing downward. I feel Lansing should start to handle its own waste, or the maybe expanding the Cayuga Heights plant. I do not feel we have the right answers yet cause money is in the way, as is I feel the concerns of others parties that want an immediate solution. rlu� 11 U.] U-t UOP 1"I0GOnKey bU'/JU / /55if P- J Z- I noticed at the meetings there were people from CU's LSC project. I can't help but think that they are worried that if something goes wrong with this plan, there addition of LSC in the lake will make matters even worse. This is why LSC should have not been given a permit! Other projects such as these are not in shallow waters! Which brings me to the question why did the DEC let them do this? I noticed also at the mtgs. representatives from real astate agencies. I am concerned that development expansion may end up playing a large part of this plan, despite what is said in the DEIS. Other concerns loom over the sensitive/unique natural areas the project will go threw, and the unavoidable habitat loss, erosion, noise issues, odors, concerns of the pump stations and there potential to cause odors, raised in the DEIS. The NYSDEC wants a regional wastewater solution as stated on page 127 of the DEIS. In the section for Alternatives to this project, NYSDEC states as follows " from an environmental point of view, this alternative would result in another treatment plant requiring proper operation with a resultant higher risk of malfunction and environmental pollution." If the DEC has not confronted the problems of the Cayuga Heights plant than i of course one should worry about more plants. But I do not feel this is an adequate answer. Let me Explain... The southern end of Cayuga Lake is in trouble! We are adding more loads to this SHALLOW end of the lake. This is why in my judgement we should not be consolidating and throwing everything at one end. This why I do not agree with what the NYSDEC says on page 127. In another scenario this makes sense, but given Cayuga lakes surcumstances, the present plan may not be the right way to go. One big concern I have as a lay person is that there was NO public information forum On this issue for the community at large. Our local government.officials made no effort to make sure that the public understands this project, and I am deeply angered by this. In this case it's a ma.,sive project, costing lots of taxpayers money. I hope that DEC can have an influence in how municipalities offer information to the public. Any DEIS is not an easy document to read! If the State, DEC and our local government officials want public input on issues we face, than we need to give them information they can understand in order to facilitate there ability to make "informed judgements and to feel good about making an input on a project. In conclusion, I feel a lot more can be said here. But I'm not an expert, and I hope that r others have submitted concerns on issues I have missed, as well as offering other ideas. I hope that this input is of help to .you and to concerns we face. May these thoughts I share i 1'11.: l: U r I FCC UU !A 0 F ! 0.7C with you help remind us that we must act in the best interests of all concerned and protect our environment that sustains us! Sincerely, Fay Goubakis P.O Box 6764 Ithaca, NY, 148SI # 607 272-7501 cJO t-f N �"22 s m f}"J � �L 3. �1/14/2003 FR1 11:47 FAX 6077538532 NYS DEC CORTLAND Q 002 Richard P. DePaolo PO Box 294 Ithaca, NY 14851 607.275.9054 August 11, 2003 By FAX Mr. John H. Merriman Jr. NYSDEC, Division of'Environmental Permits 1285 Fisher Ave. Cortland, NY 13045-1090 Ithaca Area Wastewater Proiect DEIS: Introduction An analysis of the Draft Environmental Impact Statement (DEIS) for the Ithaca Area Wastewater Project (the Project), reveals vast data gaps which preclude credible environmental ; assessment, and threaten to allow exacerbation of the well -documented pollution problems in southern Cayuga Lake, NYSDEC should reject the DEIS as incomplete, and require that a comprehensive DEIS be prepared which contains a full range of water quality data for southern Cayuga Lake including the Offects of individual septic systems in the Lansing area, a historical and projected effluent analysis for the Ithaca Area Wastewafer Treatment Plant (iAWWTP) and the Village of Cayuga Heights Wastewater Tre.Atment Plant (VCHWWTP), an IAWWTP SPDES permit analysis including the effects of projected flow increases and tertiary phosphorus treatment, and a complete analysis of the current regulatory backdrop against which the Project is proposed, including proposed Total Maximum Daily Load (TMDL) development. Lack of Data to Support Purpose, Need and Viability of Project No On -site or Ambient Water Ouat Data The Project DEIS states that "the common goal of the municipalities is to eliminate ground and surface water pollution currently caused by inadequate on -site sewage disposal systems." The do4ument, however, contains nothing but skimpy anecdotal claims to backup the assertions that impacts are i occurring as a result of such systems. We are asked to assume on faith that on -site septic systems are creating the kind of water quality impacts that require 11 million dollars and 20 miles of pipe to miti+bate, There is no water quality data whatsoever regarding the individual systems identified. There is no Cayuga Lake ambient water data whatsoever for either the proposed service area or for the IAWWTP and VCHWWTP discharge area. It is unconscionable that a DEiS for a project that is hailed by sponsors as a water quality improvement project contains riot one drop of water quality data. No Effluent Anaivses:for IAWWTP and VCHWWTP The Project DEIS maintains in its introduction and in itsone naraaranhregarding impacts orb water resources that the two regional wastewater treatment facilities do a better job of processing ewage than on -site systems. Here, again, we are asked to take this claim at face value, as there is no onlite data and no performance data for IAWWTP or VCHWWTP to support claims that centralized treattinent is 11/14/2003 FRI 11:48 FAX 6077538532 NY•S DEC CORTLAND ra003 Ithaca Area Wastewater Profect, DEIS Comments, Richard DePaolo, page 2. superior. These claims must be substantiated in a vastly expanded EIS which includes historical and Projected performance analyses for both regional plants. f In addition, the tertiary phosphorus treatment reportedly being pursued by iAWWTP partners must be quantified in' a complete projected phosphorus loading analysis. An analysis of pending Changes treatment technology; at lAWWTP should be a central part of the Project environmental review. Ohly with a complete and accurate performance picture of the wastewater treatment plants can a credible environmental assessment be made regarding potential impacts of the Project. Existing Water (duality Standards Violations NYSDEC Narrative Standard for Phosphorus The EPA -approved water quality standard for phosphorus in New York is the narrative standard that provides that phosphorus shall be limited to "[n]one in amounts that will result in alg4e, weeds and slinries that will impair the waters for their best usages." 6 N.Y.C.R.R. §703.2. Southern Cayuga Lake already violates that standard. Algae blooms occur duririge sumrrrer months, rotting weeds pile up on the lake shore creating serious aesthetic impairments and odors,+and huge mats of floating:weeds have hindered the navigation of boats in many areas of the southern ke. Against that backdrop, additional phosphorus must not be allowed into the lake's impaired area from new or expanded point -sources. Until southern Cayuga Lake meets existing water quality standards, any increased flow through IAWWTP into the impaired waterbody segment defined on the 1998 acid 2002 303(d) listings (with or without tertiary phosphorus treatment) would constitute a "new or expanded ASGharge" as prohibited by 40 C R § 122.4(i) NYSDEC Guidance Value for Phosphorus The NYSDEC phosphorus guidance value to indicate excessive eutrophication of a waterbody is 20 micrograms/liter: Monitoring data gathered in conjunction with the Lake Source Cooling project show that value to be, regularly exceeded on the shallow southern shelf of Cayuga Lake. The Project DEIS needs to justify the wisdom of transporting wastewater from a relatively deep part of Cayuga: Lake, to its shallow, impaired southern bas(n. Cavucia Lake PWL. 303(d) Seament. TMDL development NYSDEC included the southern 6,000 acres of Cayuga Lake on the 1998 federal 303(d) lilting of waterbodies where; despite point -source controls, the waters do not attain their designated uses? In 2002 the listed waterbody segment was designated as High -Priority for TMDL development. Southern Cayuga Lake is obviously impaired by nutrients and turtW, but, despite its high-1 priority 303(d) listing, NYSDEC has neither investigated the problems nor taken action to eliminate them. To the contrary, NYSDEC has allowed and even encouraged new sources of pollution to the impaired area of Cayuga Lake since..its impairments were identified. Public bathing is banned due to turbidity andlhigh bacteria counts. Algal blooms and aquatic weed infestations have created widespread aesthetic impairments. Uncontrolled toxic contamination sources are located at the lake's edge and along its' tributaries. The chronic pollution problems identified by NYSDEC and suffered by Ithaca residents must be quantified in a TIML study.The potential impacts of the nr000sed Project must be analvzed jri conucection with a coinorehensive'TlNpL study The Project provides the perfect opportunity for NYSDEC to coordinate review of a major development project within the famework of the TMDL study originaiQ called for by NYSDEC in 1998. It is time for NYSDEC to abandon its failed approach of micro -managing point - source discharges and, finally, embrace the watershed -wide approach to pollution control required Oy federal law. r 11 11/14/2003 FR1 11:49 FAX 6077538532 YS DEC CORTLAND Ithaca Area Wastewater Project, DEIS Comments, Richard DePaolo, page 3. State Environmental Quality Review (SEQR) Segmentation Permit modifications to IAWWTP and the proposed Project are being illegally segmented according to NYSDEC criteria for determining when separate environmental review of related segmented is allowable. NYSDEC utterly failed to address the segmentation issues 1 raised during the EIS Scoping Phase public comment period. The flimsy justification for allowing the IAWWTP SPDES review to proceed fora vears after it began to review funding reauests for the Proiec1that the initial SPDES i application was filed before the Project materialized) does not release NYSDEC from its obligatiobs, nor from its oportunity, to coordinate SEQR review of the inter -dependent components of the current proposal. tthout specifically answering each element of its own segmentation test (outlined below), NYSDEC can not escape the unavoidable conclusion that it is continuing to circumvent the comprehensive environmental analysis called for by the current proposaThe test must be answered. SEQR, 6 NYCRR Part 617.2(ag), defines "segmentation" as °the division of the environmental review of an action such that various activities or staves are addressed under this Part as thoughithey were independent, unrelated activities, needing individual determinations of significance." Page 2. of the Project overview document ppreppaared by Stearns & Wheler, dated 8/8/2001, stated that "Previous construction modifications to the IAWWTP have been made (independent of this ptoject) which increased the flow capacity from 10 to 13.1 mgd." The document further states that a new SPDES permit has been issued by NYSDEC to allow increased flow at IAWIIUTP. The Project DEIS makes reference to "existing;,capacity" at IAWWTP, as though that capacity materialized in a vacuum, without prior knowledge of the pending Project. Though scoping documents mention the initial permit modification application date as 3/1/95, the IAWWTP SPDES Permit Fact Sheet reveals that a review of the plane's performance (to determine new discharge limits) did not begin until at least July, 2000. Hence, the performance reviedidn't even bbain until tiro vears after the first ioirlt arant anolicatjon for sewer improvements was made to NYSDEC by the Citv of Ithaca. the Town of Lansina and the Villaoe of Cayuoa Heiahts for what has evolved into the curreptproaosal.Furthermore, NYSDEC permit writer William Schaff revealed upon inquiry that the permit limit for phosphorus was "revisited several times" during the review process, which accounted for the length of the review period. NYSDEC had ample opportunity to join the IAWWTP SPDES review with its review of the Project. In fact, it now appears in retrospect that the SPDES permit was specific4lly fashioned to accommodate the Project. Despite its :concurrent reviews of funding requests for future sewer projects and the SPDES permit application, NYSDEC failed to require joint SEQR review and issued a new SPDES permit for IAWWTP on 8/1/01, two years after becoming Lead Aaencv for the proposed Proiect. three yearslafter acceotina ioint grant applications, four vears after reiectina separate funding applications and suadtestinq G regional wastewater rmanaaement anDtoach. Scoping and;overview documents for the Prol'ect are dated 8/8/01 and were made availa le for public review at a Draft Scoping Session on 8128101. The NYSDEC issuance of the SPDES perMiit just one week before the commencement of formal SEQR review of the Project raises serious questidns of intent regarding the avoidance of joint review under SEQR. , The NYSDEC Test for SEQR Seamentation To understand conclusively that segmentation has illegally occurred in this case; cons Idet how the following NYSDEC criteria for segmentation (reprinted from the NYSDEC SEQR Handbook) r1plate to the specific facts at hand. NYSDEC must answer these tests separately and completely. in order to conclusively show that segmentation has not occurred. 1& 004 11/14/2003 FRl 11:50 FAX 6077538532 NYS DEC CORTLAND IM005 Ithaca Area Wastewater Project, DEIS Comments. Richard DePaolo, page 4. 1. Purpose: is there a common purpose or goal for each segment? Yes. The goal of the recently -issued IAWWTP SPDES permit is to increase flow limitation s from 10 to 13.1 million gallons per day (mgd). The goal of the Project is to expand sewer service areas in the Town and Village of Lansing and Dryden, and to divert flows from VCHWWTP to IAWWTP. Project Engineers ex ct to utilize the expanded permitted capacity of IAWWTP. Estimaties are that an initial .95 mgd and an eventual 1.33 mgd diversion to IAWWTP will be needed forithe Project alone. Since engineers state that this will create initial total maximum daily flows to IAWWTP of -10.9 mgd and eventual flows of 11.3 mgd, it becomes apparent that the pprev ous permitted flow limit at IAWWTP of 10 mgd would have been insufficient to allow the Proj*t to proceed. Expansion of sewer service to the Town of Lansing and the diversion of flows from VCHWWTP are denendenton the increased capacity granted to IAWWTP in its new perntu. 2. Time: Is; there a common reason for each segment being completed at or about the same time? Yes. As indicated above, it is imperative for the development of the Project that increase4 capacity at IAWWTP be available. Since the additional permitted capacity will be unused luntil the completion of the Project, it can be argued that the increased influent, and the increased Capacity to treat it, become active at the same time. Furthermore, there would be little need for increased capacity at IAWWTP without the Project or some similar source of additional influent. 3. Location: Is there a common geographic location involved? Yes. The proposed Project effects flows at the VCHWWTP and, ultimately, IAWWTP. Th6 current and proposed service areas are tied together at VCHWWTP. 4. Impacts: Do any of the activities being considered for segmentation (while not necessarily significant by themselves) share a common impact that may, If the actlWtles are reviewed as one project, result In a potentially significant adverse impact? Yes. The proposed Project would facilitate major changes in land use and result in negative impacts to surface water quality in the impaired basin of southern Cayuga Lake. The IAWWTP permit essentially enables the water quality impacts posed by the Project to occur, Theseltwo components'are major pieces of the same infrastructure. The lead agency in the IAWWI SPDES review, the Ithaca Common Council, issued a Negative Declaration for expansion of the treatment component- while NYSDEC is requiring broader environmental review for the d®livery component. The inconsistency is completely unsupportable. 5. Ownership: Are the different segments under the same ownership or control? t Yes. According to iAWWTP SPDES permit, the pemutttees ("owners") are the City of Ithaca, the Town of Ithaca, and the Town of Dryden. On 8/17/99 (two years prior to the issuance bf the new IAWWTP SPDES perrrd), the City of Ithaca, the Town of Ithaca, and the Town of Dryden as well as new potential partners Village of Cayuga Heights, Town and Village of Lansing i�ointly endorsed the unified approach to wastewater management which would depend on increai;ing capacity at IAWWTP. 6. Planning: is a given segment a component of an Identifiable overall plan? Witl he initial phase direct the development of subsequent phases or will it preclude or IdIt the consideration of alternatives in subsequent phases? Absolutely. As explained above, the Project is dependent upon increased capacity at IA P. To answer the test spec'rficalfy, the "initial phase" (the consideration of expanded permute flows at IAWWTP) had a direct and potentially limiting effect on the viability and scale of the Pr iect- 11/14/2003 FR1 11:51 FAX 6077538532 NIS DEC CORTLAND R1006 Ithaca Area Wastewater Project, DEIS Comments, Richard DePaolo, page 5. just as the width of a roadway has a limiting effect on the volume and speed of traffic. Denial of the IAWWTP flow expansion would have precluded the current Project proposal. 7. Utility: Can any of the interrelated phases of various projects be consider functionally dependent on each other. Yes. Given the regional approach favored by NYSDEC, expanded service areas could not be considered without expanded treatment capacity. i. 8. Inducement: Does the approval of one phase or segment commit the agency to approve other phases? NYSDEC is the permitting agency for both major segments of this project. And, considering the concurrent review by NYSDEC of funding and permit modification requests for both segonts, the agency was induced to grant expanded capacity to IAWWTP by virtue of knowing that it was simultaneously involved in the development of expanded service areas that would affect operation of the facility. Proposed Remedv for .SEAR Seamentation Given the obvious segmentation of the two major components of the regional wastewater management strategy; NYSDEC should include IAWWTP historical and projected phosphorus loa ing analyses in the Project DEIS and rewrite the IAWWTP SPDES permit to reflect both the effects o tertiary phosphorus treatment (reportedly under development), and the increased effluent posed b} the Project. Detailed statistical methodology should be included to show adherence to TOGS 1.2.1 and 1.3.6, which govern the processes by which phosphorus limits are calculated for expanded discharges irtlo lakes. Almost two years ago, i submitted a detailed statistical analysis prepared by Cornell Professor of advanced statistics, Joseph. Francis, which underscored the urgency of an Immediate review of the: IAWWTP SPDES permit. At that time, i requested a NYSDEC-initiated permit revocation or modification on the grounds that pemnit SEOR documents contained grave material falsehoods and the pemnit 'itself actually allows fora 37% increase in mass loading of ohosghorus)ver IAWWTP's historical performance in direct contravention, of the "no net increase" provision in TOGS 1.3.6 and the EPA -approved stat istical methodology in TOGS 1.2.1. Despite numerous reminders to various NYSDEC officials. I have not; received a reniv to my analvsis and request. NYSDEC must answer not only to the segmentation of the iAWWTP permit review, but alto to the technical review of the permit itself. it now appears that the permit limit for phosphorus was artificially inflated to allow the capacity needed for the proposed Project. it also seems likely that an answer trig my analysis and request has been stalled to allow the SEOR process for the current Project to proceed in its own vacuum- without the benefit of technical insight into the creation of the IAWWTP permit. Conclusion a 1) Reject t the current DEIS as incomplete. Require a DEiS which includes comprehensive water quality data for on -site systems in the proposed service areas, and ambient water quality data In the proposed service area and in the IAWWTP and VCHWWTP discharge areas. 2) include complete historical and projected discharge data for IAWWTP and VCHWWTP'L Include analysis of the pendingg IAWWTP tertiary phosphorus removal project. 3) Revoke or suspend the iA= SPDES permit and review a new application as part 6f a proper joint SEAR review with the Project. Ensure that the new permit application rot e' is the actual historical performance of the plant and the pending tertiary phosphorus trea ent upgrade. 11/14/2003 FR1 11:52 FAX 6077538532 NTS DEC COR7FLAND 0 007 Ithaca Area Wastewater Project, DEIS Comments, Richard DePaolo, page 6. 4) Provide the complete state and federal regulatory backdrop against which the Project{ is proposed. Define the regulatory backstop that guarantees that the Project will not contribute to existing water quality standards violations in southern Cayuga Lake's impaired basin. 5) Review the Project in conjunction with the TMDL study originally called for in 1998. Sincerely, n New York State Department o � ,. ental Conservation 1285 Fisher Avenue Cortland, New York 13045 o Ij �0Q Re: Public Comment DEIS tonal . ewater Collection System Towns of Lansing, Dryden, It 'ages of Cayuga Heights and Lansing and the City of Ithaca I am writing to express support for contents and findings of the DEIS on the above referenced project. The proposed regional solution offers, by far, the best solution to meet the immediate and long term wastewater collection ,transmission and treatment needs of the proposed service area within the six municipalities. Without question the quality of life for.present and future property owners, businesses and residents will be greatly enhanced through elimination of upland pollution in areas currently not sewered. The entire region will benefit from the substantial improvement in the water quality in the Southern Cayuga Lake Basin. I have had the good fortune of being extensively involved with Cayuga Lake water quality issues for the past 30 years. I was one of the founding fathers of the Southern Cayuga Lake Intermunicipal Water Commission (Bolton Point). Many of the same community leaders who have formed the regional wastewater partnership also are responsible for the quality of our drinking water through the governance of Bolton Point. Present and future leaders of both partnerships will be able to integrate the best practices needed to protect the health of the entire service area. - I have participated in the often bi-weekly inter -municipal negotiations for the past two years and can attest to the commitment that these community leaders have had to find the best wastewater collection and treatment solution for our region. Furthermore the governing bodies of the six municipalities have wholeheartedly supported this effort through the expenditure of hundreds of thousands of dollars for engineering and environmental studies, legal support and financial analyses. During the early 1980's I also had the good fortune being one of the leaders in the effort to plan, finance and build the Ithaca Area Wastewater Facility when I served as Town Supervisor of the Town of Ithaca. The joint effort by the City and Town of Ithaca and the Town of Dryden, our State (particularly DEC) and federal officials was instrumental in bringing to Ithaca the $30M Clean Water Act award. This enabled us to build a state of the art facility to meet the long-term future needs of a large service area. Without this support and action the community could not locally afford to build a new facility. We still would be struggling with an antiquated wastewater plant, parts of which were constructed in 1905, and with an outfall that discharged into the Inlet with its very limited ability to provide adequate dilution. Subsequently, coniniunity leaders have continually further improved the quality of treatment at IAWTF. Most recently, the owners have voluntarily agreed to much more stringent permit levels for the discharge of phosphorous. These improvements are underway with the assistance of a State Environmental Bond Act Award. These improvements, coupled with phosphorous removal and other improvements at the Village of Cayuga Heights Wastewater Treatment Plant, make it possible to add the Town and Village of Lansing service area without the necessity of constructing additional treatment capacity thereupon resulting in substantial savings to all users. The municipal and consulting engineers for the six municipalities have carefully . projected the service area needs for treatment capacity. It is clear that sufficient spare capacity will be available well beyond the 20 year planning period. This is further assured by the commitment to continue an aggressive program to eliminate inflow and infiltration within the currently sewered portion of the service area. The proposed intermunicipal agreements provide for the evaluation of the UI program as well as the quality of overall service. It is recognized that improvements to the water quality in the Southern Basin of Cayuga Lake will require more than the commitment of those responsible for the operation of our wastewater plants. Town officials in the outlying areas such as the Town of Caroline have taken action to reduce stream erosion and agricultiiral runoff. The Tompkins County Water Resources Committee, the Cayuga Lake Watershed Network and Intermunicipal Organization are actively pursing and coordinating monitoring efforts throughout the region. These are just a few of the examples of the commitment of both elected officials and volunteers to assure an effective stewardship for the vital natural resource that Cayuga Lake will provide for many generations to come. It is clear that the wastewater collection and diversion proposal encompassed in the DEIS will offer our region the best solution to our immediate and long term needs.It is consistent with land use ploicies already in place in all six municipalities. Our community leaders deserve our thanks for sticking with these efforts through many, often difficult, discussion sessions on one of the most complex local matters imaginable. I have no doubt that the intermunicipal cooperation that has resulted from these efforts will serve as a foundation for similar cooperation in many other areas. Very Sincerely, Noel Desch 132 Updike Road Ithaca, New York - �91 J Testimony at Public Hearing 7/31/03 Ithaca Wastewater Treatment DEIS My name is Barbara Blanchard. I live on Brookfield Road in the City of Ithaca and am a member of the Tompkins County Legislature representing District 1 in the City and Town of Ithaca. I am here tonight speaking as Chair of Tompkins County Area Development's Board of Directors. I have a fair amount of history with this project and am happy to speak in favor the plan which is the subject of the DEIS. In 1994, the County Planning Department and the Planning Advisory Board initiated a study conducted by Planning/Environmental Research Associates and Novelli & Company Engineers that analyzed the county's water and sewer infrastructure from the smallest village system to the Ithaca Wastewater Treatment facility. A major conclusion of this report was that limited water and sewer services, particularly in the northeast urbanized area, were a limiting factor to economic development. The report also noted that integrating and improving existing systems to correct these deficiencies was feasible but would require strong municipal leadership. In 1997, TCAD was charged by the County Board with the responsibility of preparing a Strategic Plan to serve as the principle guide for economic development in the County. This process involved over a hundred citizens from all parts of the County and took almost two years of research and analysis to complete. The final product was an Economic Development Strategy presented in 1999 to the County Board and to the community at large. This Strategy document was organized around the following three goals: • Building the economic foundations of Tompkins County o Creating employment and business opportunities • Reflecting community values in the economic development process The first goal - building the economic foundations - emphasized the importance of improved physical infrastructure citing specifically, water and sewer service. The Strategy noted that issues of concern related to the expansion of sewer services - generally related to the potential for development in suburban areas as opposed to the urban core - are balanced by the following counterpoints: e Extended sewer service improves environmental quality in already developed areas that use on -site disposal systems. • Sewer service allows small -lot and high -density development that lowers the developed area on a per capita basis. Areas that lack sewer can require a minimum of two -acres for residential lots to accommodate on -site septic systems. • The dynamics of development fluctuate among urban centers, suburban rings and rural areas and many factors, besides sewer extensions, affect the economic cycles of the Ithaca -Tompkins County region. The Strategy contained fifty-eight specific action steps of which ten were identified as the Top Priorities for implementation. One of these top ten, was an integrated system of water and sewer services for the urbanized and growing areas of the County to improve supply, efficiency of delivery and environmental quality. The status of plans to integrate these systems has been the subject of discussion at almost every TCAD Board meeting over the last four years. It is the reason TCAD was happy to help fund the facilitation activities that have helped bring the wastewater management component of these systems to this stage. In summary, this is a sound plan and a good solution to a very difficult infrastructure problem. It will be immensely beneficial to the entire community and should proceed without further delay. We urge all the community leaders who have spent so much time and effort getting to this point to move as quickly as possible to take the required actions to implement the plan Thank you. Testimony at Public Hearing on July 31, 2003 Ithaca Area Wastewater DEIS Good evening. My name is Jean McPheeters. I live on Bailor Road in Brooktondale and I serve as the president of the Tompkins County Chamber of Commerce, which is located at 904 East Shore Drive, Ithaca 14850. The Tompkins Chamber supports the plan that has been developed by the group of six municipalities to coordinate operations at the Ithaca Area Wastewater Treatment Plant and the Village of Cayuga Heights Wastewater Treatment Plant. This project will eliminate ground and surface water pollution caused by inadequate on -site sewage disposal systems and will provide a higher level of sewage treatment than presently available within the service area. The plan will also better utilize existing treatment capacity and infrastructure and phosphorus treatment will be added in both plants, which will help improve Cayuga Lake's water quality. The Chamber wants to congratulate and thank the elected officials from the six municipalities and Susan Brock, their attorney, who have all worked diligently on this plan. We also want to thank Noel Desch and Mike Hall, who have worked as facilitators with the elected officials and the technical staff from the six municipalities. Members of the Chamber and of Tompkins County Area Development provided financial support for the facilitation of this project because we believe that the project is critically important to protect the lake and to allow for development in areas designated by each of the municipalities. From the beginning, the Chamber and TCAD made it clear that it was not our intention, to propose any particular solution but rather to provide facilitation so that the participants could come to a solution that would be beneficial to all concerned. The Chamber's Board of Directors thinks that this is a thoughtful plan and an excellent solution. We have read the report, considered the growth inducing impacts and the regional impacts and think that the positive impacts far outweigh any potential adverse impacts. We urge the DEC to consider the comments and to move to a final DEIS quickly so that the six municipalities will be able to take the necessary actions to implement the plan later this year. Thank you for your attention and for your work on this plan. Sincerely, AancPheeters President 904 East Shore Drive • Ithaca, NY 14850 • Phone: (607) 273-7080 • Fax: (607) 272-7617 August 6, 2003 NYS Dept of Environmental Conservation 1285 fisher Ave. Cortland, NY 13045 Dear Mr. Merriman; The DEIS for the Ithaca Area Municipal Wastewater Collection Improvement Project should be accepted. It's well written and thorough review of the impacts. This project is a wonderful opportunity to improve the quality of our lake. Anytime septic systems can be taken off line and the waste treated, that's a win for the lake. With -the south end of the lake responsible for a majority of septic systems on the lake, this project must go forward. The local municipalities have been working on this project for many years. Over the past 10 years our house at Ladoga Point Rd. has been flooded 5 times. Our septic system flooded and our house could not be occupied. Please continue to lead and approve this document so the common sense solutions to waste can go forward. Sincerely, R. Davis CUtting New York State Department of Environmental August 1, 2003 Conservation Region 7 Cortland Office 1285 Fisher Avenue Cortland, New York 13045-1090 Dear Sir: As a resident of Cayuga Heights, an imbiber of Cayuga Lake water, an avid fisherman, and a real estate broker, I am writing in support of the proposed "Regional Wastewater Treatment" plan. It is important to keep the quality of the lake water as high as possible. The proposed plan sensibly deals with the current inadequacies of the Cayuga Heights Wastewater Treatment Plant by utilizing the available capacity of the Ithaca Area Wastewater Treatment Plant. The proposal will also allow some growth in areas where sewers are already present, but serer er permits are not available due to the Cayuga Heights plant limitations. If the "Region Plan" is implemented and the sewer systems were expanded, additional growth of homes and businesses would be possible without needing large areas of land to accommodate new septic systems. There are homes currently located on the lake shore which have questionable septic systems. No authority checks these systems on a regular basis. A controlled municipal system, which could also be upgraded in the future, would insure that the waste from these homes is' treated properly and meets established guidelines. Thank you for ;your consideration of the health of Cayuga Lake and the Tompkins County area. Sincerely, Elaine Quaroni 115 Cayuga Park Circle Ithaca, New York 14850 Received AUG "4 N4]C1-IAI L R. MAY nr I'I:RJ. MIIL M UfAI-1, A. YN-11. ADAMS, `FIREIiSI N, MAY, MILLER & 'YE1<- L \'I-I'<)I.,NI_a'S AI�Q� (.:C)UNSLiI.C7RS A'1' 7,AW 103 WES1 SINI C:A-M'PJTF FI'HACA, Nt:WYORK 14850 607-272-3442 - FAX 2724514 e-mail atm@clarityconnect.com Internet: http:llwww.atmlaw.com New York State Department of Environmental Conservation Region 7 — Cortland Office 1285 Fisher Avenue Cortland, NY 13045-1090 RE: Ithaca Area Wastewater DEIS To whom it may concern: AR,NIAND L. ADAMS 1911-1993 19 NRY W. "FItI ISE-N 1939-2001 August 1,2003 I am writing in support of the regional plan for wastewater treatment in the southern Cayuga watershed and the findings of the draft environmental impact statement. The proposed regional solution will provide the opportunity for expanded sewer service in the watershed and a higher level of treatment than what is provided by septic systems and package plants. The draft EIS finds that the growth inducing impacts are relatively minor and that "local plans encourage the patterns and densities of growth analyzed in this DEIS. " Most importantly, this plan will provide for better environmental protection for Cayuga Lake, Thank you for the opportunity to comment. I hope that the DEC will move forward to a final Environmental Impact Statement quickly so that the six municipalities will be able to vote for this project by the end of 2003. Sincerely, V. DISTRIBUTION LIST Copies of the FEIS have been distributed as required by 6 NYCRR §617.12(b) and to additional recipients: Environmental Notice Bulletin DEC Division of Environmental Permits, Albany, NY DEC Regional Office City of Ithaca Town of Dryden Town of Ithaca Town of Lansing Village of Cayuga Heights Village of Lansing Tompkins County Planning Department Tompkins County Health Department Tompkins County Department of Public Works City of Ithaca Conservation Advisory Council NYS Department of Agriculture and Markets NYS Department of Transportation NYS Environmental Facilities Corporation Cayuga Nation US Army Corps of Engineers 41 I p i I I 1 I J, t p R . 0' v . E NOV I ATTEST ITHA (?Wh CLEW ,� t M Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project Location: City of Ithaca, Village of Cayuga Heights, Town' of Dryden, and Town and Village of Lansing, Tompkins County, New York Lead Agency: NYS Department of Environmental Conservation Region 7 — Cortland Office 1285 Fisher Avenue Cortland, New York 13045-1090 Contact: John Merriman (607) 753-3095 Project Sponsors: City of Ithaca Town of Ithaca Town of Dryden Town of Lansing Village of Lansing Village of Cayuga Heights Contact: Susan Brock, Esq. (607) 277-3995 EIS Prepared By:; The Chazen Companies North Country Office 110 Glen Street Glens Falls, New York 12801 Contact: Stuart F. Mesinger, AICP (518) 812-0513 DEIS Accepted: June 20, 2003 DEIS Comments Due: August 11, 2003 DEIS Public Hearing: July 31, 2003 FEIS Accepted: November 13, 2003 i w EIS Preparers: The Chazen Companies 110 Glen Street Glen Falls, NY 12804 Environmental Consultant Contact: Stuart F. Mesinger, AICP (518) 812-0513 Stearns & Wheler, LLC One Remington Park Drive Cazenovia, New York 13035 Engineering Consultant Contact: Mr. Gerry Hook, P.E. (315) 655-8161 Greenhouse Consultants 40 Exchange Place, 13th Floor New York, NY 10005 Cultural Resources Investigation Contact: Barry Greenhouse/Will Roberts (212) 514-9520 Ithaca -Tompkins County Transportation Council 121 East Court Street Ithaca, NY 14850 Transportation Studies Contact: Fernando de Aragon, P.E. (607) 274-5570 Creighton Manning Engineering, LLP 4 Automation Lane Albany, New York 12205 Transportation Studies Contact: Chuck Manning, P.E. (518) 446-0397 ii a Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project TABLE OF CONTENTS Page Table of Contents iii List of Tables and Figures in Section III iv Glossary of Acronyms v I. Introduction 1 II. Responses to Public Comments 3 • Completeness 3 • Documentation of Need for the Project 4 • Southern Cayuga Lake Condition & Impacts 7 • DEC Actions Regarding Other Projects Affecting Cayuga Lake 12 • Segmentation 12 • IAWWTP SPDES Permit Modification 16 • Phosphorus Upgrade & Loadings 18 • Construction 20 • Unique Natural Areas 21 • Wetlands 23 • Water Resources 25 • Growth -Inducing Impacts 26 • Alternatives 27 • Project Schedule 30 • Dryden Planning Area 31 • Mapping Issues 32 . General 33 • Comments in Support of Project 35 III. Tables and Figures (see list on next page) 39 IV. Written Comments Received on the DEIS 40 V. Distribution List 41 iii Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project LIST OF TABLES AND FIGURES IN SECTION III Table F-1: WWTP Total Phosphorus (TP) Loading Discharged to South End of Cayuga Lake FEIS Figure 1: Wetlands in Relation to Proposed Service Area Sewers FEIS Figure 2: Wetlands in Relation to Potential Planning Area Sewers FEIS Figure 3: Existing Well Points in Relation to Proposed Sewers Revised DEIS Figures DEIS Figure 4: Existing Wastewater Collection Facilities DEIS Figure 14a: Water Resources in the Town of Lansing and Village of Lansing Portion of the Study Area DEIS Figure 14b: Water Resources in the Town of Dryden Portion of the Study Area DEIS Figure 19: Unique Natural Areas DEIS Figure 33: Unique Natural Areas and Proposed Town of Lansing Service Area Sewers IV Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project GLOSSARY OF ACRONYMS BTT — Best Treatment Technology CFR — Code of Federal Regulations DEC — New York State Department of Environmental Conservation DEIS — Draft Environmental Impact Statement EIS — Environmental Impact Statement FEIS — Final Environmental Impact Statement gpd — Gallons Per Day IAWWTP — Ithaca Area Wastewater Treatment Plant lbs/day — Pounds Per Day mgd— Million Gallons Per Day mg/L — Milligrams Per Liter NYCRR — New York Code, Rules & Regulations ppm — Parts Per Million SEQRA — State Environmental Quality Review Act SPDES — State Pollutant Elimination Discharge System TCHD — Tompkins County Health Department TMDL — Total Maximum Daily Load TOGS — Technical and Operation Guidance Series UNA — Unique Natural Area VCHWTP — Village of Cayuga Heights Wastewater Treatment Plant WWFP — Wastewater Facilities Plan WWTP — Wastewater Treatment Plant v • I. INTRODUCTION This document is a Final Environmental Impact Statement (FEIS) for the proposed Ithaca Area Municipal Wastewater Collection Improvement Project (the project). This document, together with the Draft Environmental lmpact Statement (herein incorporated by reference, previously distributed for public comment), form the Environmental Impact Statement (EIS) for the project. The EIS has been prepared in accordance with the requirements of the New York State Environmental Quality Review Act (SEQRA) and implementing regulations at 6 NYCRR Part 617. The EIS presents an evaluation of the potentially significant adverse impacts of constructing new public sewer lines in the Town of Lansing and a sewer transmission main in the Town of Lansing and the Villages of Lansing and Cayuga Heights. The Draft Environmental Impact Statement (DEIS) also evaluates the impacts of potential sewer lines in the Town of Lansing. Finally, the DEIS evaluates the potential impacts of growth induced in the Towns of Lansing and Dryden and the Village of Lansing as a result of the proposed project, as well as from sewers that may be constructed at some time in the future. The reader is referred to the DEIS document for a complete description of the project and its associated impacts and proposed mitigation measures, as well as a discussion of alternatives to the project. The DEIS is hereby amended by the information contained in the FEIS. EIS Process The New York State Department of Environmental Conservation (DEC) accepted the DEIS on June 20, 2003 and made it available for public comment. DEC held a public hearing on the DEIS on July 31, 2003. The DEC accepted comments on the DEIS until August 11, 2003. This FEIS was accepted by DEC on November 13, 2003. Organization of the FEIS This FEIS is organized as follows. Comments on the FEIS have been organized into topic areas. The Lead Agency's response to each substantive comment is provided after the comment. Comments that are substantively similar have been combined and a single response is given to such comments. Oral comments made at the public hearing are also summarized here. References are made after each comment as to who made the comment and how it was received. Copies of written comments are reproduced in Section IV. The oral comments made at the July 31, 2003 public hearing were recorded on an audio tape, and that tape is part of the public record and is located at the DEC office listed on the cover sheet. Any comments that are not addressed here are not deemed to be substantive. Summary of Additional Information in FEIS This FEIS contains additional information on several subjects, including the following. 1. Several commenters raised the issue of DEIS completeness and suggested that it was not complete and did not adequately address all issues, specifically those related to phosphorous discharges at the Ithaca Area Wastewater Treatment Plant (IAWWTP) and Cayuga Lake water quality. It is the Lead Agency's position that these issues are completely independent of this project and have already been addressed through a separate SEQRA review of the IAWWTP SPDES permit. Nevertheless, this FEIS contains data demonstrating that with planned phosphorous upgrades to the IAWWTP and Village of Cayuga Heights Wastewater Treatment Plant, there will be a net reduction in phosphorous discharge, even with the addition of the Town of Lansing flows. 2. Several commenters questioned the need for the project, specifically whether failing in -ground sanitary waste disposal systems had been adequately documented. This FEIS contains additional data and information documenting need for the project. 3. One commenter raised the issue of segmentation, specifically whether the SEQRA review of this project and the IAWWTP SPDES permit had been segmented. It is the Lead Agency's position that segmentation has not occurred. The project had not been developed and was not under consideration when the environmental review was performed in 1996 on the SPDES permit modification request. The impacts of a 13.1 mgd flow were properly considered during the SEQRA review of the IAWWTP's pen -nit modification. 4. This FEIS includes additional information about the level of detail that will be included in construction plans, including plans for crossing streams and Unique Natural Areas, and how routes will be evaluated during the construction plan development process. 5. This FEIS includes an evaluation of the use of the Norfolk Southern Railroad right-of-way for the sewer trunk line. The evaluation concludes that this right-of- way is not feasible because of construction issues. 6. This FEIS contains additional information about why a separate wastewater treatment plant for the Town of Lansing is not a preferred alternative. 2 V II. RESPONSES TO PUBLIC COMMENTS COMPLETENESS 1. Comment: The New York State Department of Environmental Conservation (DEC) should reject the Draft Environmental Impact Statement (DEIS) as incomplete. The DEIS should contain a full range of water quality data for southern Cayuga Lake, including the effects of individual septic systems in the Lansing area, historical and projected effluent analyses for the Ithaca Area Wastewater Treatment Plant (IAWWTP) and the Village of Cayuga Heights Wastewater Treatment Plant (VCHWTP), an IAWWTP SPDES permit analysis including the effects of projected flow increases and tertia y phosphorus treatment, and a complete analysis of the current regulatory backdrop against which the project is proposed, including Total Maximum Daily Load (TMDL) development. (R. DePaolo in 8111103 letter) Response: For determinations of completion, SEQRA requires that the DEIS be adequate with respect to its scope and content for the purpose of commencing public review. This standard was met, as the DEIS contains the information required by the scoping document. To the extent this comment requests additional information relevant to the project, such information is provided in response to specific comments below. Much of the information the commenter requests, however, is outside the scope of this project. During the scoping process, this commenter raised a number of water quality and SPDES permit issues related to IAWWTP discharges. As the Scoping Responsiveness Summary explained, such issues are completely independent of this project and have been addressed through a separate and independent process for the IAWWTP permit. The Final Scoping Document does not include such issues. Several other commenters have nonetheless asked for similar information, especially about IAWWTP SPDES permit issues and phosphorus discharges from the two wastewater treatment plants (WWTPs). Some of the comments contain inaccurate assertions about these topics that are repeated by more than one commenter. To correct these inaccuracies, this FEIS provides information on the IAWWTP SPDES permit and WWTP phosphorus discharges, even though such information is relevant to SPDES permit issues and not this project. 2. Comment: The DEIS needs major supplementation; missing information and analysis should be provided, and the DEIS re -issued. for comment. The DEIS is not ready to be moved to the Final Environmental hnpact Statement (FEIS) stage. (D. Kiefer in 8111103 letter) f Response: See Response to Comment 1. 3. Comment: The DEIS appears to be very complete. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. DOCUMENTATION OF NEED FOR THE PROJECT 4. Comment: There is no or insufficient data to support the assertions in the DEIS that water quality impacts are occurring as a result of inadequate on -site sewage disposal systems. There is no water quality data to support the need for an $11 million expenditure ($7 million funded locally) and 26 miles ofpipe that will result in discharges into the impaired southern part of Cayuga Lake. Any pollution reductions in the project area are likely to be far outweighed by increased water quality problems in southern Cayuga Lake. The EIS should contain water quality data on the effects of Lansing -area on -site systems on Cayuga Lake and performance characteristics for these systems. Data should include wastewater flow, pollution loading studies and a delineation of wastewater entering the Lake from the on -site systems. The EIS should also contain Cayuga Lake ambient water quality data for the proposed service area and.for the IA WWTP- VCHWTP discharge area. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in undated written copy of public comment received by DEC on 816103) Response: Septic system failures have posed a threat to surface and ground waters in the Lansing area for decades. Upwards of 30 septic systems in Ladoga Park are inundated by the Lake whenever water elevations exceed 384.0 feet. When waters recede, they can draw untreated sewage into the Lake from the septic systems. Local knowledge indicates these septic systems have flooded on a relatively frequent basis over the past 10 years. (See Comment 79.) The Tompkins County Health Department (TCHD) has noted that severe limitations for on -site systems exist in Ladoga Park due to flooding and inadequate separation distances to surface waters. Concerns are not limited to flooding conditions. During periods of heavy rain, poorly operating systems can contribute inadequately treated sewage into the Lake and its tributaries. Ladoga Park is located on the Lake next to Myers Park, which has a public swimming beach. The TCHD sampled the Lake at this beach on July 23, 2003, after three inches of rain fell in two days and the Lake level rose six inches. This sampling showed elevated levels of total coliform (3200/100ml) and fecal coliform (2400/100ml). Failing septic systems could be a source of these coliform counts. The Town of Lansing Study Area has a number of creeks that drain into Cayuga Lake. (See DEIS Figure 14a.) Failing systems near Lake tributaries can contaminate the tributaries and ultimately the Lake. TCHD records indicate that on the average 5 failed 11 E septic systems are replaced every year per 1,000 people in the Town of Lansing Sewer Study Area. This is a higher per capita replacement rate than the replacement rates in any of the towns in Tompkins County. Actual numbers of failed systems are likely higher, since homeowners often are unaware that their systems have failed until sewage backs -up into their residences or untreated sewage surfaces on the ground. As unsewered populations in the Lansing area increase, it is reasonable to presume that the number of failed systems per year will also increase. Problems with failing septic systems are not new. The November 1983 Wastewater Facilities Plan for the Town of Lansing includes a summary of findings from a sewage disposal system survey questionnaire that was mailed to 933 parcels within a geographic area nearly identical to the EIS Town of Lansing Planning Area. Of the 318 returns, 40% indicated some type of failure of their wastewater disposal system. In 1982, the TCHD surveyed 80 homes in the Asbury Road area on a house -to -house basis. Asbury Road runs immediately parallel to Gulf Creek, a tributary to Cayuga Lake. Many of the septic systems along Asbury Road are located just above the steep slopes of Gulf Creek. Of the 80 homes, 10 septic systems were in unsatisfactory or questionable condition and an additional 22 were expected to fail within 5 years. This meant a total of 40% of the systems had failed or were expected to fail soon. Another survey conducted by the TCHD in 1981 of well water systems in the hamlet of Ludlowville found that a significant number of wells were contaminated with sewage. Of 30 wells tested, 18 exhibited some degree of contamination. The TCHD has also expressed concerns about the four on -site sand filter systems at the Lansing Central School District that serve the elementary school, middle school, high school and District Office (approximately 1,380 students, plus teachers and staff; total design flow of 35,300 gallons per day). These systems discharge to surface waters and either drain directly to Cayuga Lake through tributary P296-58 or to Salmon Creek (and ultimately the Lake) via ditches. The TCHD noted in a May 1996 letter that "the soil in much of the planning area is marginal to poor for on -site sewage systems. Many homes and businesses rely on alternative sand filter/dispersion trench sewage systems which may affect ditches and streams especially if lots are not large enough to keep the dispersion trenches at least 50' from property lines (lots under 100' in the lesser dimension)." In addition to the positive impacts on Cayuga Lake and its tributary streams in the Lansing area, the project will benefit public health. The ability to eliminate failed or inadequate on -site systems, flooded on -site systems, and individual package treatment plants will reduce the potential for groundwater and surface water contamination, which will reduce the risk to both public and private water supplies and to public health in general. The DEIS also spells out other project benefits that are not mentioned by the commenters. These benefits are listed in Section 1.2 of the DEIS and include the elimination of SPDES permit flow exceedances at the VCHWTP, promotion of infill in the Town of Lansing rather than conversion of open space and agricultural lands, and the provision of additional public sewage capacity for the Town and Village of Lansing, which currently is extremely limited. The commenters are concerned about the impact of additional flow into the southernmost end of Cayuga Lake. Their additional comments (set forth in numbered comments below) focus on the amount of phosphorus that will be added to this part of the Lake. As stated in Response to Comment 1 above, this issue is not relevant to the project since both the IAWWTP and VCHWTP will maintain their discharges within permitted limits. However, to correct inaccurate statements made by some commenters about the amount of phosphorus this project will generate, phosphorus information is presented here and in response to specific comments below. It is anticipated initially that an average sewage flow of 144,000 gallons per day (gpd) will be collected annually from the Town of Lansing as a result of this project. It is estimated that this flow will increase to 441,000 gpd in 20 years. All of this sewage will be conveyed to public wastewater treatment plants where it will receive treatment to reduce the phosphorus content to below 0.2 mg/L once planned phosphorus upgrades are completed at the IAWWTP and VCHWTP. The amount of phosphorus this represents is less than one-fourth (1/4) of a pound per day initially, and less three -fourths (3/4) of a pound per day over 20 years. Table F-1 in Section III shows the impact that this small amount of flow will have on the phosphorus loading from the WWTPs to the south end of the Lake. Data presented is actual operating data for the IAWWTP and VCHWTP for the last four full years of record and the current year through August 2003. With the planned phosphorus upgrades, an overall reduction in the amount of phosphorus currently discharged from these plants to the south end of Cayuga Lake of approximately 65 percent will be achieved, even with the flows from the Town of Lansing. The five-year analysis shows that from 1999 through August of 2003, the historical combined annual average discharge of total phosphorus from the IAWWTP and VCHWTP has ranged from 33.5 to 44.8 pounds per day. Once the plants install tertiary phosphorus treatment, it is anticipated that their combined total phosphorus discharge will not exceed 11.9 to 14.8 pounds per day for flows in the historic five-year range shown in Table F-1. Addition of the initial flows from the proposed Lansing service area will add another 0.24 pounds per day. The initial percent reduction in phosphorus discharged to the Lake from the two WWTPs (including the initial flows from the Town of Lansing) is estimated to range from 57% to 70%. The projected numbers assume that the two WWTPs will discharge phosphorus at a concentration of 0.2 mg/L at all times (see below). This is the highest likely concentration and actual concentrations will probably be lower much of the time, which will result in even greater initial reductions in phosphorus to the Lake. Over the 20-year planning period, as flows increase from all six rel municipalities due to growth, the amount of phosphorus loading to the Lake at 0.2 mg/L is not expected to exceed 16.6 pounds per day. 5. Comment: The EIS should include data on the number, frequency, location, timing, method and extent of septic system and small package plant failures in the project area, and on whether on -site waste treatment is adversely impacting Cayuga Lake, other waterways, or general public health. One commenter who asks for this information also recognizes that certain developed shoreline areas on both the east and west shores have septic systems that occasionally get flooded by the Lake and need to be dealt with. (S. Uzinann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter) Response: See Response to Comment 4 above. 6. Comment: To document need .for the project and to compare impacts of any existing problems with project impacts, the EIS should contain more information about rates of discharge and firequency and amount of oveJflow/bypass from the two wastewater treatment plants (WWTPs). One commenter said the EIS should also address whether any of the overflow/bypass problems are being addressed outside this project. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter) Response. Section 2.1 and Tables I and 2 in the DEIS summarize the operating conditions of the two WWTPs. No overflows/bypasses have occurred, with the exception of one 2-hour diversion from the IAWWTP headworks in the 1990s during an extreme flooding event. Exceedances of the VCHWTP's permitted flow (all of which is treated) would be addressed by diverting excess flow to the IAWWTP, which has permitted reserve capacity. SOUTHERN CAYUGA LAKE CONDITION & IMPACTS WWTP LOADINGS 7. Comment: The EIS should include historical and projected performance analyses for both the IAWWTP and the VCHWTP, including a projected phosphorus loading analysis that takes into account planned tertiary phosphorus treatment at the IAWWTP and the increased flows from the project. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: Refer to Table F-1 and Response to Comment 4 above. 7 JUSTIFICATION FOR PUTTING FLO W IN SO UTH END OF LAKE AND ANALYSIS OF IMPACTS 8. Comment: The EIS needs to justify why wastewater will be transported front a relatively deep part of Cayuga Lake to its shallow, impaired southern basin and compare the enviromnental pros and cons of doing so. Two commenters said the DEC's phosphorus guidance value of 20 micrograms per liter (indicating excessive eutrophication) is regularly exceeded on the Lake's shallow southern shelf. One commenter said the following as part of this comment: Cayuga Lake's southern S, 000 acres have turbidity and phosphorus levels that impair the Lake's best use. Public bathing is prohibited because of turbidity. High phosphorus levels cause vast algal blooins. These problems threaten drinking water drawn fi-oni the Lake. The southern part of the Lake receives phosphorus from IAWWTP and VCHWTP effluent, which is discharged into waters less than 12 feet deep, and phosphorus and turbidity discharged by Cayuga Inlet, Cascadilla Creek, and Fall Creek. Cayuga Lake in the proposed service area is deeper, receives far less pollution and does not suffer from widespread impairments. (R. DePaolo in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter; D. Kiefer in 8111103 letter) Response: See Response to Comment 4 above. The southern shelf does have more issues with phosphorus than the larger, deeper part of the Lake. However, the focus of this project must weigh the overall benefits achieved by providing a regionalized approach to wastewater treatment at larger facilities to the introduction of a new discharge point from a small facility serving only the Town of Lansing. In DEC's experience, larger facilities tend to operate more efficiently and economically with fewer permit excursions. The opportunity posed to provide better treatment and address high flow problems at the VCHWTP is one mitigating factor. Also, the reduction in overall phosphorus loading to the Lake from point sources is a positive for the Lake. By receiving treatment at the VCHWTP, the wastewater from the Town of Lansing will be treated to remove nutrients to a degree that would not be the case if it were discharged to the deeper portion of the Lake. The amount of phosphorus that would enter the Lake from the Town of Lansing flows is far less than the reduction in phosphorus that will be achieved with the planned phosphorus treatment upgrades at the WWTPs. Thus the total loading of phosphorus to Cayuga Lake will be greatly reduced. See Response to Comment 27 below for more information on phosphorus loadings. 9. Comment: The DEIS lacks documentation of the critical state of the southern end of Cayuga Lake. The addition of more phosphorus to this shallow end will only increase the problems to the Lake. (F. Gougakis in 8111103 letter) Response: See Response to Comment 4 above. 10. Comment: The EIS should analyze the impact of reallocating wastewater to, and concentrating treated effluent in, point discharges to the southern, impaired end of Cayuga Lake. One commenter said this analysis should include how additional loading might impact aquatic biota and algal and weed growth and influence levels of dissolved oxygen. Another commenter noted the Lake's 303(d) listing and said the EIS should discuss the extent to which the project would mitigate water quality problems at the southern end of the Lake. Another commenter said the DEIS does not make a convincing case that implementation of this project will improve water quality problems in the southern end of the Lake. Absent documentation of what the project will mean in the way of addition of nutrients and chemicals to the impaired waters of southern Cayuga Lake, it is impossible to conclude that the project is the best one can do. (D. Kiefer in 8111103 letter; E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Table F-1 and Response to Comment 4 above. 11. Comment: The EIS should acknowledge and discuss the possible biological impacts of the increased WWTP effluent in the impaired waters of the Lake, especially with respect to its reactive -chlorine content and the.further concentration of human -excreted drugs. Science is just learning about how, for example, hormones in sewage effluent affect reproduction and the sex of aquatic organisms. As yet, there are no known ways for WWTPs to handle this. This is another reason not to combine/increase effluent streams. (D. Kiefer in 8111103 letter) Response: This comment is not relevant to the project because the WWTPs will be operating within their permitted limits. Impacts of increased amounts of flows were considered when the IAWWTP's SPDES permit underwent environmental review. That said, the amount of chlorine residual entering the southern part of the Lake will not change significantly from current conditions. The IAWWTP dechlorinates its effluent prior to discharge into the Lake, and its SPDES permit limits total residual chlorine to 0.1 mg/L, which is equivalent to one -tenth of a part per million. The VCHWTP does not dechlorinate its effluent, but the flow treated at that plant will not increase. WWTPs currently do not have special treatment for human -excreted drugs. The increase in flow attributed to the Town of Lansing (annual average of 0.144 mgd initially and 0.441 gpd in 20 years) is a relatively minor fraction of the average combined flows to the two WWTPs (9.19 mgd initially; 9.49 mgd in 20 years.) The Town of Lansing flows will make up only 1.6% of the annual average flows to the two plants initially and 4.6% after 20 years. The concern raised over concentration of human -excreted drugs in the 7 'i southern Lake is not significantly affected by the relatively low levels of flow projected from the Town of Lansing. LEGALITY OF INCREASED FLOW 12. Comment: Southern Cayuga Lake violates New York State's narrative water quality standard for phosphorus. Algal blooms and rotting and floating weeds cause aesthetic impairments and odors and hinder navigation. Additional phosphorus inust not be allowed into the Lake's impaired area from new or expanded point sources. Any increased flow through the IAWWTP into the impaired part of Cayuga Lake on the 303(d) list would constitute a "new or expanded discharge" as prohibited by 40 CFR § 122.4(i). (R. DePaolo in 8111103 letter) Response: The listing of Cayuga Lake on New York State's 303(d) list requires that a TMDL be developed that would identify the point and nonpoint source reductions of phosphorus necessary to restore the designated use. DEC does not believe that there is sufficient information to develop a TMDL at this time. Since the WWTPs will be operating within the limits set by their respective SPDES permits, flows from the project are not considered flows from a "new source or a new discharger," as those terms are defined in the regulations. (Note that this is the regulatory standard, not "new or expanded discharge" as the commenter states.) The increased flows through the IAWWTP will come from the current VCHWTP service area. These are flows that are currently discharged into the south end of the Lake through the VCHWTP outfall. This diversion will free up capacity at the VCHWTP for new Town of Lansing flows. The total loadings of phosphorus from the WWTPs are expected to be far less after the proposed project and phosphorus upgrades are completed than current conditions. See Responses to Comments 4 above and 27 below for more information on phosphorus loadings. 13. Comment: Wastewater collected in the proposed service area was originally intended to be treated by a new_facility requiriizg a discharge permit. Such a permit would have been prohibited by the federal moratorium in 40 CFR § 122.4(i), which prohibits the issuance of discharge permits to "a new source or a new discharger, if the discharge fi-om its construction or operation will cause or contribute to violation of water quality standards. " Conveying the wastewater to the permitted IAWWTP by-passes this critical non -degradation standard. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: See Response to Comment 12 above. 10 EFFECTS OF 303(d) LISTING AND TMDL PROCESS 14. Comment: Despite the fact the southern S, 000 acres of Cayuga Lake is on the federal 303(d) list and is designated as high priority for TMDL development, DEC has not investigated the problems nor taken action to eliminate them. The EIS should analyze the current regulatory backdrop against which the project is proposed, including proposed TMDL development. DEC should analyze project impacts in connection with a TMDL study and should define the regulatory backstop that guarantees the project will not contribute to existing water quality standards violations in southern Cayuga Lake. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: As noted in Response to Comment 12, the WWTPs will be operating within their permitted limits and total point source loading to the Lake will be significantly reduced. Regarding the TMDL process, the DEC has agreed to perform an evaluation of the phosphorus loadings to the southern shelf of the lake. The EIS does not supplant the DEC's regulatory responsibilities, nor should it be delayed pending DEC's evaluation. If as a result of the TMDL process further reductions in phosphorus point source loadings are required, DEC will require such reductions through all necessary means, including WWTP SPDES permit modifications if required. 15. Comment: DEC has made no tangible progress to institute a TMDL pollution control program, even though southern Cayuga Lake is a high priority for such a program. One commenter said DEC rejected the Environmental Protection Agency's offer in 2001 to help fund a water quality study and DEC has not developed or adopted any TMDLs since Cayuga Lake was listed on the 303(d) list in 2002. The project should be approved only after the TMDL is implemented or other regulatory safeguards are imposed to assure no further degradation of water quality. Another commenter said a TMDL should be in place before this project or any new wastewater treatment plant is constructed. (W. Hang at 7131103 Public Hearing and in 816103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 14 above. 16. Comment: The southern end of the Lake is on the national 303(d) listing and is a priority.for TMDL development. DEC should be extremely careful about adding any discharges to this area. (D. Kiefer in 8111103 letter) Response: See Response to Comment 14 above. 11 DEC ACTIONS REGARDING OTHER PROJECTS AFFECTING CAYUGA LAKE 17. Comment: DEC has failed to enforce the federal moratorium provision by granting a discharge permit to the Lake Source Cooling Project. One commenter said Lake Source Cooling contributes nearly 10% of the phosphorus entering southern Cayuga Lake. Another commenter said despite a recommendation by a Town of Ithaca consultant, there is no monitoring near Lake Source Cooling's outfall, and the commenter is very concerned about DEC's standards and ethics. Other projects are not allowed in shallow waters, and Lake Source Cooling should not have been allowed. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter) Response: This comment is not relevant to the project. The Lake Source Cooling permit was legally issued after extensive review by the public and DEC. 18. Comment: The commenter asks why DEC has failed for years to address problems at the VCHWTP and expresses concern about the possibility that Cornell University's veterinary school waste might be discharged to the IAWWTP. This commenter wants DEC to address these and other impairments before allowing more waste into the southern basin. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: The project includes a diversion to eliminate VCHWTP exceedances of permitted flows. In addition, DEC is funding improvements (independent from the project) to the VCHWTP. The improvements include effluent filtration and chemical addition for enhanced phosphorus removal; the addition of baffle wall within one of the two final settling tanks to improve performance; and replacement of trickling filter media for improved wastewater treatment reliability. The discharge of Cornell University's veterinary school waste into the IAWWTP is independent from the project and is still in the discussion stage. Should that plant agree to accept such waste, it would have to be treated so that all of the parameters and limits in the plant's SPDES permit are met. SEGMENTATION 19. Comment: The IAWWTP SPDES permit modification and the project are illegally segmented. As a result, it is impossible to quantify the water quality impacts from the project. (R. DePaolo at 7131103 Public Hearing) 12 Response: There is no illegal segmentation, the water quality impacts are quantifiable, and the impacts of a 13.1 mgd flow were considered during the SEQRA review of the plant's permit modification. As the Scoping Responsiveness Summary noted, the IAWWTP owners requested an increase in capacity in 1995 because the 10 mgd flow limit had been reached (and actually exceeded on at least two occasions). The plant owners asked for the additional capacity to keep the plant in compliance. Their request for 13.1 mgd was based on an engineering study, which indicated the plant capacity could be increased to 13.1 mgd with minor improvements and modifications, which were made in 1997. The City of Ithaca conducted a SEQRA review on the permit modification in 1996 and issued a Negative Declaration. The project that is the subject of this EIS had not been developed and was not under consideration at that time. The Town of Lansing instead was pursuing its own wastewater treatment plant at Portland Point in Lansing. It applied for Clean Water/Clean Air Bond Act funding for a stand-alone plant in 1997. The current project was developed only after Bond Act funding was denied to the local municipalities for their individual projects, and the DEC urged them to come up with a regional solution for wastewater treatment needs. Segmentation has not occurred. The SPDES permit modifications are not dependent on or driven by the project. The IAWWTP needed the increased capacity regardless of whether service areas are added, and it applied for the increased capacity well before the municipalities started developing the project that is the subject of this EIS. In addition, the DEC's approval of the increased capacity does not commit the municipalities and agencies to approving the various elements of the project, nor have environmental impacts evaded review (which is the concern about segmentation). The environmental effects of an increase in capacity to 13.1 mgd were considered in the City's SEQRA review. The effects of a 13.1 mgd discharge on Cayuga Lake are the same regardless of whether the flow comes from within or outside the current service area. 20. Comment: Application of DEC's 8-part test shows segmentation has occurred. There is: a common pufpose or goal for each segment; a common reason for each segment being completed at or about the same time; a common geographic location; a common impact that may result in a potentially significant adverse impact if the activities are reviewed as oneproject; and common ownership or control of the different segments. A given segment is a component of an identifiable overall plan and the initial phase directs the development of subsequent phases; the phases are functionally dependent on each other; and DEC undertook concurrent review offunding and permit modification requests for both segments. Without the project, there would be little need for increased capacity at the IAWWTP. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See Response to Comment 19 above. In addition, application of DEC's 8-part test shows the following. 13 • Is there a common goal? In 1994, the IAWWTP owners identified an opportunity to have DEC increase the plant's permitted capacity at very low cost if they made final settling weir and baffle improvements and increased influent pumping capabilities. The fact the 10 mgd flow limit had been exceeded on two occasions, coupled with the fact the permitted capacity could be increased through implementation of low cost improvements, led to the request in 1995 for an increase in capacity. The IAWWTP owners' consistent goal was to get this low- cost increased capacity, regardless of what happened with the project that is the subject of this EIS. • Is there a common reason for completing each segment at or about the same time? While it is true the flow diversion from the VCHWTP could not occur before an increase in capacity at the IAWWTP, there is no reason to have the increase in capacity occur "at or about the same time" as the flow diversion. The IAWWTP permitted capacity expansion could and did occur without the flow diversion. • Is there a common geographic location? The answer to this depends on how one defines each project's location. Obviously, the IAWWTP is involved in both the permit modification and the project. But many elements of the project are located in the Town and Village of Lansing and the Village of Cayuga Heights as well. The actual flows from the Town of Lansing will flow to and be treated at the VCHWTP, with other flows diverted to the IAWWTP. • Is there a common impact that may result in a potentially significant adverse impact if the activities are revie",ed as one project? This query seeks to determine whether impacts from two or more projects, which may be insignificant when reviewed separately, become significant when the projects are reviewed together. As stated in Response to Comment 19, the effects of a 13.1 mgd discharge on Cayuga Lake were reviewed in 1996 when the City of Ithaca issued a Negative Declaration. The impacts are the same regardless of whether the flow comes from within or outside the current service area. There are no additional impacts to the south end of the Lake from the addition of flows diverted from the VCHWTP because the total discharge will be less than 13.1 mgd. No different or more significant impacts to the southern Lake could possibly have been identified if the projects had been reviewed together. • Is there common ownership or control of the different segments? The IAWWTP is owned and operated by the City of Ithaca, Town of Ithaca, and Town of Dryden. This ownership and control is expected to remain the same regardless of whether the diversion and/or service area expansions occur. The VCHWTP is owned and operated by the Village of Cayuga Heights. Pump stations and public sewers in the Town of Lansing will be owned and operated by the Town of Lansing. The Town of Lansing will also own and operate a transmission main that is proposed to cross the Village of Lansing and a portion of the Village of Cayuga Heights. Public sewers in the Village of Lansing will be owned and operated by the Village of Lansing. • Is a given segment a component of an identifiable overall plan? At the time of the City's SEQRA review of the 13.1 mgd discharge, the plan that is the subject 14 of this DEIS had not been developed. In fact, the project sponsors undertook a lengthy planning process to arrive at the plan which is the subject of this EIS. This process did not begin until long after the City's SEQRA review was completed. Are the phases functionally dependent on each other? Flows could not be diverted from the VCHWTP without the IAWWTP capacity expansion. However, the IAWWTP capacity expansion is not dependent in any way on the flow diversion. Does the approval of one phase commit the agency to approval of other phases? (Note that this last test in the SEQR Handbook is different from that set forth in the commenter's letter.) The answer to this query is no. Approval of IAWWTP's increased capacity request does not commit the project sponsors, DEC, nor other agencies to approval of the various components of the project. 21. Comment: Although the initial application to modify the IAWWTP's SPDESpermit was made before the project materialized, DEC continued to review the application for four Years after rejecting separate.fimding applications and suggesting a regional wastewater management approach, _ for three years after accepting joint grant applications, and for two years after becoming Lead Agency on the project. A DEC SPDES permit writer told this commenter the length of the review period was due to the fact the permit limit for phosphorus was "revisited several times " during the review process. Review of the permit modification should have been joined with review of the project. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19 and 20 above. There were a number of reasons the period between permit modification application and permit issuance was so long, including personnel changes at DEC. 22. Comment: To remedy the segmentation, the EIS should include IAWWTP historical and projected phosphorus loading analyses, and DEC should revoke or suspend the IAWWTP's SPDES permit and rewrite it to reflect the effects of the planned tertiary phosphorus treatment and the increased effluent posed by the project. The rewritten permit should adhere to Technical and Operation Guidance Series (TOGS) 1.2.1 and 1.3.6, which govern the processes by which phosphorus limits are calculated for expanded discharges into lakes. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19-21 regarding the segmentation comment. Because there was no segmentation, there is no need to revoke or suspend the IAWWTP permit. Historical and projected phosphorus loading analyses for the IAWWTP and VCHWTP are presented in Table F-1. The IAWWTP SPDES permit contains a Fact Sheet that 15 establishes the procedure for the establishment of new limits to reflect the effects of the planned tertiary phosphorus treatment, which is expected to begin operation in the early Fall of 2004. The new limit will be based on actual performance of the plant once the new phosphorus treatment has been in operation for eighteen (18) months. Based on the technology and manufacturer's warranty for the equipment that is being installed, the new limit is not expected to exceed 0.2 mg/L. IAWWTP SPDES PERMIT MODIFICATION 23. Comment: The IAWWTP's modified SPDESpermit allows a 37% increase in mass loading of phosphorus over historical performance in contravention of the "no net increase " provision in TOGS 1.3. 6 and TOGS 1.2.1. It appears the permit limit for phosphorus was artif cially inflated to allow the capacity needed for the project. (R. DePaolo in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. We believe the commenter intended to reference TOGS 1.3.6 and 1.3.1 (not 1.2.1), so this response is based on inforination and guidance contained in TOGS 1.3.6 and 1.3.1. Before the IAWWTP permit modification, its then -existing permit required reduction of phosphorus to 1.0 mg/L on a 30-day average basis. This concentration -based limit and the 10.0 mgd flow limit for the plant established a maximum phosphorus loading of 83.4 lbs/day. TOGS 1.3.6 establishes phosphorus removal requirements for new and expanded discharges to lakes or in lake watersheds. The process used by the DEC for the new permit limit is based on TOGS 1.3.6 and statistical analysis of plant performance data from January 1996 through September 2000. Guidance criteria stated in TOGS 1.3.6 requires that: "...any proposed expansion of an existing discharge within a lake watershed, which would require a modification of an existing SPDES permit, should provide BTT [Best Treatment Technology] for phosphorus removal to a degree that the annual quantity (mass loading, flow multiplied by concentration) of phosphorus discharge after the modification does not exceed the phosphorus discharge prior to the modification." The DEC has interpreted this to mean that the discharge of phosphorus after the, modification cannot exceed the current (historical) level of phosphorus, not the permitted allowable level of phosphorus. In order to determine the current level of phosphorus being discharged, the DEC completed a statistical analysis of plant data from January 1996 through September 2000, to calculate the 95th percentile effluent phosphorus mass loading. This statistical analysis yielded a limit for phosphorus of 40 lbs/day. The limit was set at 40 lbs/day because, in 16 accordance with DEC's standard methodology, 95% of the 46 twelve-month rolling average data points fell below 40 lbs/day. Note that the data in Table F-1 cannot be used to calculate the limit, because the Table F-1 data are actual annual averages (not 12- month rolling averages) which are intended to show the average reduction in phosphorus discharged to the Lake. Table F-1 does not represent a statistical analysis of the data. It is important to note that the modified phosphorus effluent limit of 40 lbs/day represents a greater than 50 percent reduction in mass loading of phosphorus versus the plant's previous permit limit of 1.0 mg/L or 83.4 lbs/day. In setting the new limit, the DEC recognized that the facility actually discharged significantly less phosphorus than what was permitted. The purpose of the modification was to set a no net increase limit on an annualized basis. It should also be pointed out that the modified limit does not reflect advanced phosphorus removal technology. As mentioned in Response to Comment 22, a project is currently underway to provide for an advanced phosphorus removal facility. The SPDES Permit Fact Sheet recognizes that the existing phosphorus limit will be further decreased once the construction is completed and operation of the new facility is underway. 24. Comment: DEC issued a revised SPDES permit for the IAWWTP that allows an increase in phosphorus discharge from less than 30 pounds per day to up to 40 pounds per day. Two commenters state that DEC ignored its own regulatory policy (TOGS 1.3.6) by approving this revision. (W. Hang at 7131103 Public Hearing and in 816103 letter; R. DePaolo at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 23 above. 25. Comment: ff wastewater flows are higher than projected, phosphorus loadings could increase beyond the historical 30 pounds per day, and the sponsors would be within their legal rights. This commenter asked DEC two years ago to revoke or modify the SPDES permit on the grounds of grave material falsehoods and the 37% increase in phosphorus loadings. The connnenter provided DEC with a detailed statistical analysis performed by a Cornell University statistics professor that showed the 37% increase. DEC has never responded, even though this commenter was promised an answer 18 months ago. It seems likely DEC did not respond in order to allow the SEQRA process for the project to proceed without the benefit of technical insight into the creation of the IAWWTP permit. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. The technical basis for the creation of the IAWWTP permit is explained in the permit's Fact Sheet. As stated in Responses to Comments 23 and 24, the 95 percent statistical recurrence of effluent phosphorus loads (as determined by the DEC) from the IAWWTP 17 is 40 lbs/day, not 30 lbs/day as stated by the commenter. Therefore, the permit establishes a "no net increase" in allowable phosphorus load discharged from the IAWWTP. The statistical analysis by the Cornell University statistics professor relied on only two years of historical plant flow data, whereas the DEC analysis relied on nearly five years of historical data. (The SPDES Permit Fact Sheet contains a typographical error that says DEC used 3 years of data.) The two years of data used by the professor generates a data set of 12 data points, which DEC believes is not a large enough data set to perform the statistical analysis because it is not a good representation of fluctuations in climatic changes. In comparison, DEC's data set between January 1996 and September 2000 yields 46 data points. Although the commenter has stated the older data is not representative because of subsequent improvements to the IAWWTP and its collection system, those improvements were not done to increase phosphorus removal and did not impact phosphorus loadings or reductions. PHOSPHORUS UPGRADE & LOADINGS 26. Comment: The DEIS contains no information on the phosphorus removal project that is currently out for bid at the IAWWTP. The scoping documents mentioned this project. This commenter thinks the phosphorus removal elements were taken out of the DEIS to avoid a focus on water quality issues. The FEIS should reference the phosphorus removal component. (R. DePaolo at 7131103 Public Hearing) Response: Contrary to the commenter's assertion, the phosphorus removal project was not included in the Scoping Document. The Overview Document previously released to the public states that the IAWWTP phosphorus removal project is independent from the diversion project and would not be part of the EIS. The Overview Document further states that the IAWWTP phosphorus removal project was a Type II action under SEQRA and further SEQRA review was not required for it. 27. Comment: The project would undercut or eliminate the benefits of a proposed phosphorus removal upgrade to the ]AWWTP. That facility currently removes phosphorus to less than 0.7 inilligrams per liter (parts per millions (ppm)) on a 12-month rolling basis. Approximately 27.5 pounds ofphosphorus are discharged daily into the Lake. After the upgrade, phosphorus would be reportedly removed to less than 0.2 ppm on a 12-month rolling average. The project will generate wastewater containing 25 to 36 pounds per day of phosphorus, or I1 % to 16% of the 220 pounds of phosphorus now received by the IAWWTP. That contribution would off -set improved phosphorus removal at the upgraded plant. If wastewater generated by the proposed project exceeds DEC's estimate, there could be a net increase in phosphorus discharged into the Lake, because the IAWWTP's revised SPDES permit allows up to 40 pounds per day of phosphorus discharge. (W. Hang at 7131103 Public Hearing and in 816103 letter) F Response: See the last paragraph of Response to Comment 1. This comment uses incorrect numbers and double -counts existing VCHWTP flows that will be diverted to the IAWWTP. Even with the addition of flows from the Town of Lansing, the amount of phosphorus discharged to the south end of Cayuga Lake will be reduced by between 57 and 70 percent. The discussion presented is flawed in that it states, "The proposed project is estimated to generate wastewater containing 25 to 36 pounds per day of phosphorus" when actually only 11 lbs/day initially and 31 lbs/day in 20 years will be collected by the Town of Lansing sewers installed as part of this project. These amounts will be treated by the VCHWTP and reduced to less than one-fourth lbs/day of phosphorus initially and less than three -fourths lbs/day in 20 years before it is discharged to Cayuga Lake. The flows diverted to the IAWWTP are existing flows from the VCHWTP service area, and, therefore, they do not add an additional phosphorus load to the Lake because they are currently discharged to the south end of the Lake through the VCHWTP outfall. With the phosphorus treatment upgrades at the two plants, the total amount of phosphorus being discharged to the south end of Cayuga Lake will be reduced from a current annual average load ranging from 33.5 to 44.8 pounds per day (combined discharges from the IAWWTP and the VCHWTP) to approximately 15 lbs/day initially (including the additional initial flow collected in the Town of Lansing). 28. Comment: If DEC continues to support the project, then it should be redesigned to prevent, further degradation of Cayuga Lake. The phosphorus pollution generated by the project should be measured as it flows into the VCHWTP and the sponsors should clean up at least twice that amount elsewhere in the Lake's watershed. For example, artificial wetlands at the mouth of Cayuga Inlet could control phosphorus. fi-om stormwater runoff, and buffer zones could be established along agricultural areas to prevent fertilizer runoff into Lake tributaries. A study could be undertaken to determine ifLake Source Cooling water could be used as potable drinking water and be treated before discharge back to the Lake. The main polluted area of the Lake flows away from Lake Source Cooling's intake and directly towards Bolton Point's intake, which is directly downgradient from wastewater discharged into the Lake. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The WWTP owners will accomplish far more than what this commenter has requested. Flows from the Town of Lansing sewers will result in one-fourth of a pound per day of phosphorus initially and less than three -fourths of a pound per day in 20 years discharged to the Lake. With the installation of phosphorus treatment, the WWTPs' loadings of phosphorus will decrease in the range of 20 to 31 pounds per day. 29. Connnent: The VCHWTP is outmoded and lacks state-of--the-art phosphorus removal. That facility lags behind the IAWWTP's efforts to upgrade its phosphorus removal 19 capability. That problem should be rectified. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The VCHWTP will be upgraded for advanced phosphorus removal and it is expected to remove phosphorus to a level of 0.2 mg/L or better. Money has been awarded from the Clean Water/Clean Air Bond Act for this upgrade. CONSTRUCTION 30. Comment: The EIS should include details about the actual construction and installation of sewer lines in the Lansing Service Area, such as the size of the construction right-of-way, how deep lines will be buried, and what the area of disturbance will be. The FEIS should use this information to analyze construction impacts on stream corridors, instreann habitat, wetlands, and Unique Natural Areas (UNAs) in the Lansing Service Area, and the construction plans for the Lansing Planning Area should address these impacts. (E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uznnann, Tompkins County Environmental Management Council in 8111103 letter) Response: Traditional sewer pipe installation using open -cut methods of trenching can typically be accomplished within a footprint of 30 feet. Permanent easements are normally 20 feet wide. The depth of construction is variable and will not be known until final design profiles are prepared. At a minimum the depth of cover on small diameter gravity or forcemain sewers will be approximately 4-5 feet. Field verification of construction impacts will be made at the time construction routes are finalized. 31. Comment: The FEIS should detail what is to be included in each construction plan. Construction plans should address minimization of sedimentation and erosion; describe in the blasting plan how construction and pipe locations might impact private drinking water sources from bedrock wells and describe mitigation measures for such impacts; and analyze innpacts from potential staging areas. Construction staging areas should be located outside of any UNAs. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The DEIS indicates that appropriate measures will be implemented to mitigate these construction related impacts. These measures will be detailed on construction plans and in the specifications. Construction documents for the pipeline and pump station projects will include requirements for erosion and sediment control (i.e. silt fence, dewatering of excavations, stabilizing exposed soils); rock removal by blasting with appropriate monitoring; and approved areas for establishing materials and equipment storage. Such plan details and specifications will be tailored to the specific work sites once final sewer main routes are determined. Construction staging areas will be located outside of UNAs wherever possible. 20 UNIQUE NATURAL AREAS 32. Comment: The existing maps of UNA boundaries are not exact. Placement of a sewer line on a boundary does not necessarily mean that there will be no impacts to the flora and fauna, geological structures, habitat, etc. that are found in the area. The FEIS should explore alternative transmission routes along road beds or routes further away from UNAs. The FEIS should also consider trenchless digging as an alternative in the UNAs. Alternate locations should be considered.for the two pump stations that are proposed in the UNAs in the Lansing Service Area. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: To the extent practicable, preliminary sewer main routes in the Town of Lansing Service Area have been selected to avoid the general extents of the UNAs. The proposed gravity transmission main along the former Ithaca -Auburn railroad bed will traverse UNA-89, UNA-102 and UNA-103 and an alternative forcemain design has been evaluated along Cayuga Heights Road. A subsequent forcemain design along the Norfolk Southern railroad right-of-way is described in Response to Comment 33. Trenchless technology for installing sewer mains has been identified in the DEIS as a mitigation measure to be implemented for avoiding disturbance of specific surveyed natural features within the UNAs. The proposed Myers Road pump station lies within UNA-55 and will be sited in the vicinity of the Myers Road and Lakeshore Road intersections. The majority of the land in this area was once utilized for gravel mining. The Portland Point pump station will be located west of UNA-63 within the extents of the former industrial disturbance. 33. Comment: The EIS should examine the possibility of running the Town of Lansing- VCHWTP transmission line along the existing Norfolk Southern railroad line, which is already a highly and frequently disturbed area. This would eliminate the need_for pumping stations and habitat destruction that would be necessary with the other routes discussed in the EIS and there would be easy access to the rail bed, which would decrease the cost of maintenance and repair. (L. Leopold in 8111103 letter) Response: T.G. Miller, P.C. has explored the pen -nit requirements and physical constraints of a "longitudinal occupation" within the Norfolk Southern Railroad right-of- way. The Norfolk Southern pipeline offset requirements dictate that a sewer main must be installed roughly 24 feet from the rail centerline. Occupation along the west side of the rail places the main in the waters of Cayuga Lake for a majority of the 5 mile route. Land availability east of the rails varies considerably. At several locations the extensive rock cliffs are within 5 to 6 feet of the eastern rail. To conform to the offset requirements it will be necessary to remove substantial faces of the rock cliff. This removal would negatively impact the steep slopes east of the present cliff edge. 21 Due to the physical constraints noted above, access to and along the railroad bed is not sufficient for either initial construction or future maintenance as long as the rail remains in use. Further, the construction cost for this alternative as estimated in the T.G. Miller analysis will minimally be 2-2.5 times the cost of the Cayuga Heights forcemain alternative. Based on these factors the Norfolk Southern Railroad alternative is not viable at this time. 34. Comment: These commenters strongly support the alternative transmission route along Cayuga Heights Road proposed for the Twin Glens and Esty's Glen UNAs. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Managerent Council in 8111103 letter) Response: Comment received and noted. 35. Comment: As recommended in the DEIS, a biological survey should be conducted of the proposed interceptor route in UNA 103, McKinney's Twin Glens and Lake Cliffs. One commenter wants this survey to inform a decision as to whether trenchless construction should be used (as recommended in the DEIS), and requested this survey be done before the end of the SEQRA process. Another commenter suggested the survey be used to decide whether the sewer route should be diverted away from the UNA, and requested the survey be conducted during the appropriate time of year to reveal the potential plants or animals impacted. (E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Prior to any final selection of the Ithaca -Auburn railroad'transmission route a survey will be conducted by qualified professionals to identify the important natural communities and rare/scarce plants or animals within close proximity to the route . The identification of rare or scarce plants will be conducted during the appropriate season(s). The width of the survey corridor will be determined after consultation with the professionals. The approximate limit of the corridor within UNA-89 and UNA-103 is between the south end of Cayuga Hills Road and the existing Village of Lansing sewer transmission main below Cedar Lane. A land survey will then be performed to map the identified communities and plants in order to assess the feasibility of using trenchless technology or to completely avoid the corridor. 36. Comment: The construction of a pipeline through UNAs 103 and 89 would necessitate the removal of a large number of medium-sized and mature hemlocks in the Twin Glens area, which are irreplaceable and create a beautiful visual scene. These areas have had 75 years to grow into forest and many local residents enjoy them year- round. No amount of mitigation can restore these areas in our lifetime if this pipeline is 22 built through this area. The EIS is meant to deal with and prevent preventable environmental impacts. (L. Leopold in 8111103 letter) Response: See Response to Comment 35 above. 37. Comment: The commenter is concerned about the environmental impacts of digging in UNAs and asks how often connectors would be built in forested escarpment areas to reach the transnission interceptor. (J. Dennis at 7131103 Public Hearing) Response: The proposed Ithaca -Auburn railroad transmission main does not include or anticipate the construction of additional connectors through forested escarpment areas. 38. Comment: The Existing Conditions section or the DEIS should note that UNA 103, McKinney's Twin Glens and Lake Cliffs, contains a section of the old Ithaca -Auburn Shortline that crosses the glen. If sewer lines will run close to rennaining abutments and a trestle from the old Ithaca -Auburn Shortline, the FEIS should assess the innpacts of the sewer lines on these features, which nnay have historic or cultural significance. (E. Marx, Tonipkins County Planning Department in 8111103 letter) Response: With modifications, the abutments of the Ithaca -Auburn Shortline railroad at the southerly glen could support a pipe bridge. The Stage I Cultural Resources Survey did not identify these abutments as having historical or cultural significance. Further, there is no remnant of a "trestle." There are two existing pipe bridges south of Cedar Lane that support the Village of Lansing sewer transmission main. 39. Comment: The EIS has very little information about mitigation of innpacts in UNAs. (J. Dennis at 7131103 Public Hearing) Response: Mitigation for impacts to UNAs is adequately discussed in DEIS Section 4.4.2 and the sections referenced therein. Additional mitigation measures are discussed in Responses to Comments 31 and 35. WETLANDS 40. Comment: The EIS should consider an alternate route for the sewer lines that are proposed to cross UNA 65 (Head Corners Wetland), and DEC should be consulted prior to any disruption of the area. The connnnenter supports the DEIS suggestion that a 23 wetland scientist should survey the area and make recommendations for limiting impacts to this wetland. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The potential for crossing the Head Corners wetland exists in a future phase for which no definite plans have yet been formulated. Based on the assessment in this EIS, an alternate route for a sewer line in the vicinity of this wetland will be analyzed if and when future sewer extension plans are developed. 41. Comment: Care should be taken to preserve and protect wetlands throughout the study area. In addition to the impacts noted in the DEIS, loss of wetland.function can have negative impacts on surrounding lands due to flooding, and can cause problems associated with water quantity and quality in stream corridors and eventually in Cayuga Lake. (S. Uzmann, Tonpkins County Environmental Management Council in 8111103 letter) Response: Comment noted. The proposed project will not have any direct impact to wetlands, as stated in the DEIS and confirmed by FEIS Figures 1 and 2 in Section III. See also Response to Comment 43. 42. Comment: When the location of sewer lines is determined, a wetlands scientist should conduct a more complete analysis of potential wetlands impacts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Field verification of the EIS conclusion that no wetlands will be impacted will be made at the time construction routes are finalized. 43. Comment: The EIS should contain a map showing all wetlands overlaid with the proposed sewer lines at a finer scale (for example, 1: 24, 000) than that used in Figures 17 and 18. The EIS should also combine the information in Figures 44 and 45 into one niap shown in an additional figure. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: More detailed maps of wetlands in relation to proposed sewer routes are found in FEIS Figures 1 and 2. These figures confirm the DEIS conclusion that the proposed Service Area sewers will not impact wetland areas. The potential impacts of Plaiming Area sewers are accurately discussed in the DEIS. 24 WATER RESOURCES 44. Comment: Sewer line routes should be designed to reduce impacts to known private wells and public drinking water supplies (such as those at Myers Point, Ludgate's, and the Plantations Inn). (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: FEIS Figure 3 in Section III illustrates the proximity of proposed sewer lines to known public drinking water supply sources. No such sources are located in close proximity to proposed sewer lines such that they would be impacted by the project, with the possible exception of the well point on Burdick Hill. Mitigation for potential impacts to this supply is discussed in Response 46. 45. Comment: There is no discussion of how to mitigate the impact that trenching activities would cause on a residential drinking water supply that exists in the form of a large cistern at 1203 East Shore Drive that lies directly below the former Short Line railroad bed. This was brought up during the scoping session but is not mentioned in the DEIS. (L. Leopold in 8111103 letter) Response: This supply is discussed at DEIS page 70. Mitigation of impacts from potential leaks or a break in the line is discussed at DEIS page 74. It is proposed that the transmission line be double sleeved within.100 feet of this water supply. To the extent there may be potential construction impacts from trenching activities, during construction the location of the cistern will be marked in the field and all construction activities will be maintained at a safe distance from the cistern to avoid adverse impacts. The safe distance will be determined in the field based on soils characteristics. 46. Comment: The DEIS states at page 31 that there are numerous private wells located throughout the Study Area that have not been comprehensively mapped. Some of these well points are regulated public water systems, and these have been mapped. The data for these wellheads is available through the Tompkins County Planning Department. There are few, if any, regulated public water systems in the service area, as most of the service area is already served by municipal water. If the final plans do indicate impacts on a regulated water system from sewer construction, the system may need to be abandoned and the municipal water systems used if available. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Known public water supplies are mapped in FEIS Figure 3. The Tompkins County Plamling Department supplied the data about these wellheads. There is no available mapping of private wells. No wells for which information is known are found in proximity to proposed sewer lines, with the exception of the private source discussed in Response to Comment 45, and possibly the Burdick Hill well point. Mitigation for the 25 former is discussed in the DEIS and in Response to Comment 45. With respect to the latter, similar mitigation (such as double sleeving of the sewer line within 100 feet of the well point) will be implemented if the line is found to pass within 100 feet after construction plans are developed. 47. Comment: Section 4.5.1 (Impacts to Water Resources) should acknowledge that there could be negative impacts to well heads and mitigation should be recommended, where possible. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 44. GROWTH -INDUCING IMPACTS 48. Comment: The sponsors should consider the following growth -inducing impacts in addition to those identified in the DEIS: The adequacy of public water supplies and private drinking water wells (since induced growth may increase the demand for public and private drinking water supplies). Increased congestion of specific transportation corridors that could result from the density and intensity Orland uses allowed in a particular area and the timing of sewer line extensions. Local comprehensive plans should carefully evaluate these relationships between infrastructure and land use. The transportation demand model used in the DEIS dilutes the traffic impacts by spreading them throughout the study area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment noted. The relevant municipalities will need to determine whether adequate drinking water supplies exist in the locations of proposed sewers. Adequate supplies currently exist in the proposed Lansing Service Area: decisions about water supply adequacy in the Lansing Planning Area and Dryden Study Area will need to be made if and when sewers are proposed in those areas. The relevant municipalities should also consider the potential transportation impacts of proposed land use patterns and traffic mitigation. Mitigation could include, among other things, mixed use development patterns that take advantage of or enhance transit connections, and links and facilities for pedestrians and bicycles. The use of the word "dilutes" is not completely accurate in the comment about the transportation model. Volumes of traffic for specific links and intersections are projected with a dynamic model that assumes people will shift their patterns if a specific link or intersection becomes too congested. So the model makes traffic assignments using the entire road network. As a result, one may find that development spread out over an area 26 may show insignificant traffic impacts (such as no system failures at specific links or intersections), particularly if the area has a dense road network. If there are few roads, they tend to capture all the traffic and the model starts to report capacity problems. 49. Comment: The project will trigger a large amount of building. The EIS has very little information about induced housing growth in new areas. (J. Dennis at 7131103 Public Hearing) Response: The DEIS contains an extensive discussion of induced growth in Section 6. Table 31 on page 100 specifically estimates the number of dwelling units which may be constructed in the Study Area under three scenarios. The remainder of Section 6 analyzes the impact of such development. 50. Comment: Sewers will induce growth, which will lead to non point source impacts on the Lake caused by lawn fertilization and stormwater runoff. How do we know there will be a positive offset in taking septic systems off-line? (R. DePaolo at 7131103 Public Hearing) Response: See Response to Comment 4 above. Among other things, the project will correct a significant problem with respect to failing septic systems. It is true that growth may have other impacts. The purpose of the induced growth analysis in DEIS Section 6 is to provide the affected municipalities with information about the amount of growth that may occur in order that they may formulate land use policies to avoid adverse impacts. ALTERNATIVES 51. Comment: DEC has made it clear throughout this planning process that it would only support an interinunicipal solution. The DEIS does not show that the project is better than the alternative of constructing a state -of the -art satellite treatment plant.for the Town of Lansing that would release effluent into a deeper, more northern, and less impaired portion of the Lake. Although DEC did not approve funding for this alternative, it is still a real alternative, and the EIS should discuss this alternative in more detail. One commenter requested that another map/figure be added to the EIS showing possible location and depth of discharge for a new WWTP, as well as the Lake depths in that area. One commenter believes DEC pushed the intermunicipal solution for fiscal reasons as much as for environmental reasons. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; L. Leopold in 8111103 letter; D. Kiefer in 8111103 letter; F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: DEC prefers an intermunicipal solution that addresses the problems in the region comprehensively. The phosphorus loadings from Town of Lansing flows are very small and overall phosphorus loadings to the Lake will be greatly reduced with the 27 planned WWTP phosphorus upgrades. It is difficult to interpret the meaning of "state-of- the-art satellite treatment plant" in the comment since no proposal went through to a design phase. In DEC's experience, small municipal plants generally have more operational and compliance problems than regional facilities. Smaller municipal plants are seldom "state-of-the-art" because of the inability to spread higher costs over a small tax base. 52. Comment: The EIS contains no evidence that centralization of wastewater treatment infrastructure in this instance would be more cost-effective or technically superior than a decentralized approach using an additional treatment plant in the Town of Lansing. One commenter said new technologies are available that treat wastewater efficiently and properly. Another commenter suggested consideration of the use of ozone- and ultra- violet based treatment rather than chlorine. Another commenter said that higher risks of malfunction and pollution that come with decentralization are insufficient to reject an additional WWTP in this case because of the impairment in the southern Lake. (F. Gougakis in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter; L. Leopold in 8111103 letter) Response: See Response to Comment 51 above. We disagree with the comment that the higher risks of malfunction and pollution that come with decentralization are worth incurring because of the impairment in the southern Lake. The additional amount of phosphorus to be discharged in the southern Lake is in itself very small and is less than one-fourth lbs/day initially and less than three -fourths lbs/day in 20 years. Even with the added Town of Lansing flows, the total amount of phosphorus discharged to the Lake will decrease in the range of 20 to 31 pounds per day on an annual average basis. 53. Comment: The EIS should mention the post 9-11 recognition that centralization increases vulnerability. The EIS should acknowledge that the alternative of relying on efficient, smaller -scale distributed infrastructure would promote the maintenance of greater region -wide functionality during times of natural or man -induced calamity. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Vulnerability is certainly a concern today and it is true centralization can increase vulnerability. However, concerns about infrastructure vulnerability are not always cured by relying on decentralized infrastructure. A new smaller plant could be more vulnerable under some scenarios since small plants are not staffed as often as larger plants. 54. Comment: The EIS should examine an upgrade to the Town of Lansing's facility and a discharge into the Lake at that point. (J. Dennis at 7131103 Public Hearing) Response: The Town of Lansing does not currently have a wastewater treatment facility. 55. Comment: The EIS should better explore the alternative of expanding the VCHWTP. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: The alternative of expanding the VCHWTP to treat 2.9 mgd (currently permitted at 2.0 mgd) was evaluated in the Town of Lansing Wastewater Facilities Plan prepared in October 1998. That report concluded that expanding the VCHWTP to treat projected flows from the Town of Lansing would cost approximately $3,600,000 more than the alternative to divert equivalent flows to the IAWWTP, where capacity already exists. 56. Comment: The total proposed diversion to IAWWTP is only 1.3 million gallons per day. For a fraction of the $11.2 million capital cost, each of the Lansing on -site septic systems and SPDES permitted discharges referred to in the DEIS could be equipped with state-of-the-art on -site phosphorus removal systems without constructing a 26-7nile long wastewater collection system. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: This comment does not take into account the fact that hundreds of septic systems are located in areas that are not well suited for subsurface discharge because of steep slopes, shallow depth to bedrock, shallow groundwater tables, and seasonal flooding. No amount of retrofitting would address the fact that these systems fail at a high rate. As for existing package plants with surface discharges, the Town of Lansing's 1998 Facilities Plan evaluated small satellite treatment plants as an alternative to regional treatment. However, this alternative was more expensive than the selected alternative to treat flow from the Town of Lansing at the VCHWTP. 57. Comment: A study should be conducted to see if the discharge pipes for the IAWWTP, VCHWTP and the Lake Source Cooling facility could be merged and moved to discharge the combined effluent into deeper waters below the photic zone far from existing drinking water intakes. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The need for such a study has not been demonstrated, and in any event, falls outside the scope of this EIS. Currently there are no water quality issues affecting drinking water. As for issues affecting the Lake, as stated in Response to Comment 12, DEC does not believe that currently there is sufficient information to develop a more stringent limit on phosphorus through the TMDL process. As stated in Response to Comment 14, if further reductions in phosphorus are required in the future, a modification to the WWTPs' permits maybe required. If this occurs, the owners of the IAWWTP and VCHWTP will consider alternatives, including extending their outfalls into deeper water. 29 58. Conintent: Studies should be conducted to assess the technical feasibility as well as the costs and benefits of managing the project's wastewater without any discharges to Cayuga Lake (discharge into a nearby receiving water body; spray irrigation). (W. Hang in 816103 letter) Response: Section 6.7.7 of the 1983 Wastewater Facilities Plan completed for the Town of Lansing evaluated the use of small diameter sewers with land application of raw sewage. The evaluation concluded that land spreading is cost -prohibitive, a conclusion that is still valid today. The conclusion reached is published in its entirety: "This alternative considers the areawide collection of sewage by small diameter sewers. The sewage would be transported to a suitable location and then applied to the land. As pointed out earlier, the Jnost suitable location of central collection is at Portland Point. Three potential landsites are considered for the application of raw sewage. These are illustrated in Appendix 6-4. A number of evaluations must be made in considering the application of sewage to land. These are: (1) health considerations to adjoining residential community (2) groundwater pollution (3) soil pollution, (4) air pollution (5) future use of land and many other considerations since the temperature in the Study Area is very low during winter season. The sewage would have to be stored during winter season before it is applied in summer/spring to the land. An econoinic evaluation of the alternative is made before giving consideration to various health and environmental concerns. The total estimated project cost using this alternative is $15,224,100. The annual cost of Operation and Maintenance is $43, 000. Since this alternative is more costly than the majority of other alternatives, no further consideration is given to this alternative. " Discharges into a nearby receiving water body are not a realistic alternative, either. Discharges from a Town of Lansing plant to receiving waters such as Salmon Creek or Gulf Creek (both of which are tributaries to Cayuga Lake) are not considered feasible by DEC, given the low base flows in the Creeks during the summers. PROJECT SCHEDULE 59. Comment: Section 2.7 says survey and stakeout of sewer line alignments will occur one week ahead of the construction schedule. This short time/rame will likely not be sufficient to deal with any problems that may arise. One commenter asked the time between survey/stakeout and construction be lengthened to two to four weeks to provide the ability to make rerouting decisions that may be necessary due to site conditions. Another commenter asked the time be lengthened to at least four weeks, for the same reason. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: The survey and stakeout referred to in Section 2.7, which will be conducted one week ahead of the construction schedule, is to provide control points for the contractor's use. A detailed design survey is conducted to determine the final alignment of the proposed sewer. The design survey is used to make routing decisions due to site conditions. 60. Comment: The EIS should discuss how analysis, planning and engineering for the 26 proposed stream crossings will be conducted before construction starts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: There are no DEC protected streams to be crossed by the construction of sewer mains in the Town of Lansing Service Area. Certain practices and controls to minimize stream disturbance will still be incorporated in the contract documents and depending on the characteristics of a particular stream may include all of the following: 1. Directional boring beneath the stream or trenching with appropriately constructed coffer dams. 2. Discharges fi-om trench dewatering activities will pass through a sedimentation control practice. 3. Not allowing equipment in flowing streams. 4. Restoring the stream bottom cross-section and profile. 5. Replacing significant trees removed within 50 feet of a stream bank. DRYDEN PLANNING AREA 61. Comment: The Dryden Planning Area in the DEIS is significantly larger than those areas identified for expanding sewer service and accommodaling.future density in the Town of Dryden's Draft Comprehensive Plan. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The Dryden Plarming Area is a 20-year projection of areas where public sewers might go, whereas the Comprehensive Plan is expected to be updated every 5 to 10 years. The EIS's study of environmental effects within the Planning Area will be used to help inform decisions in the future on where sewer districts might be formed. 62. Comment: The commenter understands that the location of the sewer lines in the Ryden Planning Area is still in the conceptual stages and the DEIS does not discuss the environmental impacts in this area. Additional environmental reviews will need to address the full range of impacts in the Dryden Planning Area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment received and noted. 31 MAPPING ISSUES 63. Connnent: The DEIS relied on Soil Association mapping for an assessment of soil conditions in the study area. Tompkins County has a digital version of the more detailed soil series map for Tompkins County, which may be obtained from the Tompkins County Information Technology Services Division. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: At the time of preparation of those portions of the DEIS which utilized soils mapping, the more detailed soil series mapping was not available. The association level mapping used in the DEIS is sufficient to identify the potential for construction impacts such as high groundwater tables or erosion, as well as for use in the growth inducement analysis. Given that the DEIS identified the potential for impacts related to soil conditions and recommended appropriate mitigation measures, no further analysis is required. 64. Connnent: The VCHWTP and IAWWTP locations and existing pipe connections should be included for reference on at least Figure 4. (S. Uznann, Tompkins County Environmental Management Council in 8111103 letter) Response: A revised Figure 4 is included in this FEIS in Section III. 65. Connzent: The EIS should include a figure showing the location and depth of the existing WWTP discharge points as well as the depth of the Lake throughout the southern end. (D. Kiefer in 8111103 letter) Response: The location and depth of existing WWTP discharge points are not germane to the discussion of impacts from the proposed sewer construction project. The project does not involve any modifications or changes to these discharges. 66. Connnent: In Figure 19, Unique Natural Areas, the pink color.for UNA 102 (Renwick Slope) is on the map, but the number 102 is not printed on the map. The sane is true for Figure 33, where the color for the Newnan Tract appears, but not its title on the nap. (L. Leopold in 8111103 letter) Response: Revised Figures 19 and 33 are included in this FEIS in Section III. The Newman Tract is not located within the area shown on Figure 33. 67. Conment: The DEIS states at page 30 that all water bodies are Class C in the DEIS Study Area. Actually, many are classified as "D " and "A " as shown on Figures 14a and 32 14b. The Figures have a column labeled "Protected Status Code" so only C(T) and higher streams are listed. The column should be labeled "Standards Class" and show all classes. This point is only for clarification, as the Stormwater Permit will protect the "D"streams and unclassified watercourses. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. Revised Figures 14a and 14b are included in this FEIS in Section 11I. GENERAL 68. Comment: Section XII of the Executive Summary, pages xxviii and xxix, which contains the list of involved agencies and their authority for the project, should state the DEC will also be responsible for review and approval of plans for the new construction, given the scope of the project, that most construction is in a new service area, and that State funds are involved. The TCHD will assist in review and approval if DEC so desires, as the TCHD does for most collector sewers. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: The DEC will be responsible for review and approval of plans and specifications (contract documents) for new construction of sewers and pump stations for the project. The TCHD will assist in the approval, if the DEC so desires. 69. Convnent: Please clarify the statement in the DEIS in Section 2.2.2, Town ofLansine Service Area Proposed hnvrovements, that "the Village of Lansing's existing 15-inch railroad interceptor sewer intersects the railroad grade below Twin Glens Road and terminates at the existing VCHWTP. " At present, there is no Village of Lansing sewer interceptor below Twin Glens Road, unless the reference means ':farther south" along the railroad bed, instead of downhill, i.e., west, of Twin Glens Road. (L. Leopold in 8111103 letter) Response: The Village of Lansing 15-inch interceptor sewer is located on the former Ithaca -Auburn railroad bed south of Twin Glens Road and immediately west of Cedar Lane. 70. Comment: The commenter was pleased to see there are plans to investigate the possibility of using the former railroad right-of-way as a recreation trail in conjunction with this project. This is an excellent opportunity to create trails that link the Lansing community and the larger community. (E. Marx, Tompkins County Planning Department in 8111103 letter) 33 Response: Comment noted. The former railroad right-of-way is on private property. The project sponsors have discussed with the landowners the possible use of this right-of- way as a recreation trail. The affected landowners oppose creation of a public pedestrian right-of-way along the former railroad right-of-way. 71. Comment: The connnenter asked what would happen to an elevated septic system that is built on the old railroad bed. Would the sponsors dig under that or remove it and put it back after construction? (J. Dennis at 7131103 Public Hearing) Response: Directional boring beneath the septic system is possible. Conventional trenching is also possible with necessary repairs made in the distribution/collection laterals, filter media and subsoil. Alternatively, the building sewer could be connected to the sewer main and the septic system ultimately abandoned. 72. Comment: One commenter said DEC's job is to protect the enviromnent, not pay attention to how many homes are available. Another commenter said representatives of real estate agencies attended meetings on the project, and this commenter expressed concern that development expansion could end up playing a large role in the project. (R. DePaolo at 7131103 Public Hearing; F. Gougakis in 8111103 letter) Response: Comment noted. Section 6 of the DEIS contains an extensive assessment of potential growth induced as a result of the project. The affected municipalities now have the opportunity to review their planning policies with respect to such potential growth. Other sections of the DEIS deal with other environmental impacts and mitigation, and the involved agencies and municipalities likewise will consider this information as they make their decisions. 73. Comment: This commenter expressed concern over impacts to sensitive/unique natural areas, unavoidable habitat loss, erosion, noise issues, odors, and pump station impacts that are raised in the DEIS. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: Comment noted. Each of these potential impacts is adequately addressed in the EIS. Absent a specific comment or concern, no further response is possible. 74. Comment: Local government officials should have held a public information forum on this project, preferably at night in the City of Ithaca. They made no effort to make sure the public understands this massive project. The EIS process should not continue until such a forum is held. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) 34 Response: Comment noted, and the municipalities have the opportunity to take this comment into consideration for future projects. The official SEQRA public hearing and the informal public information session run by DEC were agreed to between DEC and the involved municipalities. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. 75. Comment: One commenter requests an extension of the comment period into September 2003 or well into the Fall of 2003. Another commenter requests an extension of the comment period into the Fall of 2003. (J. Dennis at 7131103 Public Hearing; F. Gougakis at 7131103 Public Hearing) Response: The length of the public comment period meets (and exceeded) the requirements of SEQRA. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. COMMENTS IN SUPPORT OF PROJECT The following comments were received and noted. 76. Comment: The commenter states that overall, it is supportive of the project. The project will eliminate nonpoint source pollution currently caused by inadequate on -site sewage disposal systems in the project area. This will help maintain the public health and welfare of Tompkins County residents and those who use Cayuga Lake as a drinking water and recreational resource. This reduction, combined with an increase in the overall level of treatment for wastewater generated in the Cayuga Lake watershed, will help protect the economic vitality and well-being of Tompkins County. (E. Marx, Tompkins County Planning Department in 8111103 letter) 77. Comment: The commenter looks forward to the FEIS and the development of engineering plans and specifications to solve the identified problems in the service area. (J. Andersson, Tompkins County Health Department in 6125103 letter) 78. Comment: The commenter supports the project, which will eliminate ground and surface water pollution caused by inadequate on -site sewage disposal systems and will provide a higher level of sewage treatment than presently available within the service area. The project will better utilize existing treatment capacity and infrastructure, and phosphorus treatment will be added in both WWTPs, which will help improve Cayuga Lake's water quality. Members of the Tompkins County Chamber of Commerce and of Tompkins County Area Development funded_facilitation of the project because the project is critically important to protect the Lake and it will allow for development in areas designated by each of the municipalities. Those funding the facilitation did not propose any particular- solution but rather provided_ facilitation so the participants could come to 35 a solution beneficial to all. The project's positive impacts far outweigh any potential adverse impacts. (J. McPheeters, Tompkins County Chamber of Commerce at 7131103 Public Hearing and in written copy of public comment received by DEC on 7131103) 79. Comment: The DEIS is well -written and thoroughly reviews the project's impacts. The project will improve the quality of Cayuga Lake by taking septic systems off-line and treating waste. The south end of the Lake is responsible for a majority of septic systems on the Lake. Over the past 8110 years, the commenter's house and septic system on Ladoga Point Road have flooded S times, which created additional discharge into the Lake and prevented occupancy of the house. The project will not necessarily create more growth, as the municipalities will control growth. (R. Cutting at 7131103 Public Hearing and in 816103 letter) 80. Comment: The project will provide an opportunity for expanded sewer service in the watershed and a higher level of treatment than what is provided by septic systems and package plants. The growth inducing impacts are relatively minor. The project will provide for better environmental protection for Cayuga Lake. (M. May in 811103 letter) 81. Comment: The project sensibly deals with the current inadequacies of the VCHWTP by utilizing the available capacity of the IAWWTP. The project will allow some growth in areas where sewers are present but sewer permits are not available due to VCHWTP limitations. The project will also make possible additional growth of homes and businesses without needing large areas of land to accommodate new septic systems. Some homes currently located on the lake shore have questionable septic systems, and no authority checks them on a regular basis. A controlled municipal system which could be upgraded in the future would insure that the waste firom these homes is treated properly and meets established guidelines. (E. Quaroni in 811103 letter) 82. Comment: The project is a sound plan and a good solution to a very difficult infrastructure problem. A study initiated by the Tompkins County Planning Department and the Planning Advisory Board in 1994 concluded that limited water and sewer facilities, particularly in the northeast urbanized region, were a limiting factor to economic development. An Economic Development Strategy completed by Tompkins County Area Development (TOAD) in 1999 emphasized the importance of improved water and sewer service to attain the goal of building the economic foundations of Tompkins County. The Strategy noted that issues of concern related to the expansion of sewer services (generally related to the potential for development in suburban areas as opposed to the urban core) are balanced by the following counterpoints: extended sewer service improves environmental quality in already developed areas that use on -site 9M 41 disposal systems; sewer service allows small -lot and high -density development that lowers the developed area on a per capita basis; and the dynamics of development fluctuate among urban centers, suburban rings and rural areas. One of the top 10 action steps (out of 58) identified by the Strategy was an integrated system of water and sewer services for the urbanized and growing areas of the County to improve supply, efficiency of delivery and environmental quality. This is the reason TCAD helped fund facilitation activities to bring the project to this stage. (B. Blanchard, Tompkins County Area Development at 7131103 Public Hearing and in written copy of public comment received by DEC on 7131103) 83. Comment: The proposed regional solution offers by far the best solution to meet the immediate and long term wastewater collection, transmission and treatment needs of the proposed service area. Upland pollution will be eliminated in areas not currently severed. The entire region will benefit from the substantial improvement in the water quality in the Southern Cayuga Lake Basin. The project is consistent with land use policies already in place in all six municipalities. In addition, the owners of the IAWWTP have voluntarily agreed to more stringent permit levels.for the discharge of phosphorus, and phosphorus removal and other improvements at the VCHWTP will also take place. Sufficient spare capacity will be available well beyond the 20 year planning period, especially with continuation of an aggressive program to eliminate inflow and infiltration. The Town and Village of Lansing service areas can be sewered without the need to construct additional treatment capacity, resulting in substantial savings to all users. Improvements to the water quality in the southern basin of the Lake will require more than the commitment of those responsible for the operation of the WWTPs. Stream erosion and agricultural runoff are being addressed in the Town of Caroline, and the Tompldns County Water Resources Council, the Cayuga Lake Watershed Network and Intermunicipal Organization are actively pursuing and coordinating monitoring efforts throughout the region. (N. Desch in 819103 letter) 84. Comment: The DEIS is adequate. Village of Lansing history shows growth in malls, subdivisions and of will occur with or without sewers. Adequate sewage facilities will only benefit Cayuga Lake. The project is a good use of resources and a cost effective plan. Self-government is preserved, with each municipality defining costs, growth and location offuture sewers. The need for this project started in 1987 with a temporary moratorium by the VCHWTP. There has been much effort and discussion since then, and there is no need.for.further study. (J. Majeroni, Cornell University, Real Estate at 7131103 Public Hearing) 85. Comment: The project should go.forward. Home prices are very high because of low inventory. New construction resulting from the project would lead to more moderate Prices. In the 23 years this commenter has been in the real estate business, this commenter has never seen a problem with public sewer systems but has seen many 37 problems with septic systems come up at real estate closings. The added cost of a septic system is about $10, 000. This adds a lot to the price of a home. Public sewers would make it better for everyone. (A. Edelman, Audrey Edelman & Associates Real Estate at 7131103 Public Hearing) 86. Comment: This commenter stated he echoes Ms. Edlenzan's comments about the need for housing. This commenter built a house on Horizon Drive and extended the municipal sewer pipe to his home because he was close enough to do so. One of his neighbors paid $10,000 for a septic system. Neighbors have had problems with septic systems, including septic systems backing up and flooding their basements. There are current proposals for two subdivisions with more than 180 houses in Lansing. There is a need for housing, and more sewage will be created. With the amount of local vacant land, there could be more than 1,000 homes built with septic systems, with untreated waste just injected into the ground. There is a need to move forward with public sewers and treat the sewage. (G. Sloan at 7131103 Public Hearing) III. TABLES AND FIGURES 39 IV. WRITTEN COMMENTS RECEIVED ON THE DEIS .o V. DISTRIBUTION LIST Copies of the FEIS have been distributed as required by 6 NYCRR §617.12(b) and to additional recipients: Environmental Notice Bulletin DEC Division of Environmental Permits, Albany, NY DEC Regional Office City of Ithaca Town of Dryden Town of Ithaca Town of Lansing Village of Cayuga Heights Village of Lansing Tompkins County Planning Department Tompkins County Health Department Tompkins County Department of Public Works City of Ithaca Conservation Advisory Council NYS Department of Agriculture and Markets NYS Department of Transportation NYS Environmental Facilities Corporation Cayuga Nation US Army Corps of Engineers im i 4 red S/ p r.. S sM tt<-A 'Tb 0 l Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project Location: City of Ithaca, Village of Cayuga Heights, Town of Dryden, and Town and Village of Lansing, Tompkins County, New York Lead Agency: NYS Department of Environmental Conservation Region 7 — Cortland Office 1285 Fisher Avenue Cortland, New York 13045-1090 Contact: John Merriman (607) 753-3095 Project Sponsors: City of Ithaca Town of Ithaca Town of Dryden Town of Lansing Village of Lansing Village of Cayuga Heights Contact: Susan Brock, Esq. (607) 277-3995 EIS Prepared By: The Chazen Companies North Country Office 110 Glen Street Glens Falls, New York 12801 Contact: Stuart F. Mesinger, AICP (518) 812-0513 DEIS Accepted: June 20, 2003 DEIS Comments Due: August 11, 2003 DEIS Public Hearing: July 31, 2003 FEIS Accepted: XXX 1 EIS Preparers: The Chazen Companies 110 Glen Street Glen Falls, NY 12804 Environmental Consultant Contact: Stuart F. Mesinger, AICP (518) 812-0513 Stearns & Wheler, LLC One Remington Park Drive Cazenovia, New York 13035 Engineering Consultant Contact: Mr. Gerry Hook, P.E. (315) 655-8161 Greenhouse Consultants 40 Exchange Place, 13th Floor New York, NY 10005 Cultural Resources Investigation Contact: Barry Greenhouse/Will Roberts (212) 514-9520 Ithaca -Tompkins County Transportation Council 121 East Court Street Ithaca, NY 14850 Transportation Studies Contact: Fernando de Aragon, P.E. (607) 274-5570 Creighton Manning Engineering, LLP 4 Automation Lane Albany, New York 12205 Transportation Studies Contact: Chuck Manning, P.E. (518) 446-0397 11 Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project TABLE OF CONTENTS Table of Contents List of Tables and Figures in Section III Glossary of Acronyms I. Introduction II. Responses to Public Comments Completeness • Documentation of Need for the Project Southern Cayuga Lake Condition & Impacts DEC Actions Regarding Other Projects Affecting Cayuga Lake • Segmentation • IAWWTP SPDES Permit Modification Phosphorus Upgrade & Loadings • Construction Unique Natural Areas Wetlands Water Resources Growth -Inducing Impacts • Alternatives • Project Schedule Dryden Planning Area • Mapping Issues • General • Comments in Support of Project III. Tables and Figures (see list on next page) IV. Written Comments Received on the DEIS V. Distribution List Page iii iv v 1 3 3 4 7 12 12 16 18 20 21 23 25 26 27 30 31 32 33 35 39 40 41 iii Lq I Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project LIST OF TABLES AND FIGURES IN SECTION III Table F-1: FEIS Figure l: FEIS Figure 2: FEIS Figure 3: Revised DEIS Figures WWTP Total Phosphorus (TP) Loading Discharged to South End of Cayuga Lake Wetlands in Relation to Proposed Service Area Sewers Wetlands in Relation to Potential Planning Area Sewers Existing Well Points in Relation to Proposed Sewers DEIS Figure 4: Existing Wastewater Collection Facilities DEIS Figure 14a: Water Resources in the Town of Lansing and Village of Lansing Portion of the Study Area DEIS Figure 14b: Water Resources in the Town of Dryden Portion of the Study Area DEIS Figure 19: Unique Natural Areas DEIS Figure 33: Unique Natural Areas and Proposed Town of Lansing Service Area Sewers 1v c } Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project GLOSSARY OF ACRONYMS BTT — Best Treatment Technology CFR — Code of Federal Regulations DEC — New York State Department of Environmental Conservation DEIS — Draft Environmental Impact Statement EIS — Environmental Impact Statement FEIS — Final Environmental Impact Statement gpd — Gallons Per Day IAWWTP — Ithaca Area Wastewater Treatment Plant lbs/day — Pounds Per Day mgd— Million Gallons Per Day mg/L — Milligrams Per Liter NYCRR — New York Code, Rules & Regulations ppm — Parts Per Million SEQRA — State Environmental Quality Review Act SPDES — State Pollutant Elimination Discharge System TCHD — Tompkins County Health Department TMDL — Total Maximum Daily Load TOGS — Technical and Operation Guidance Series UNA — Unique Natural Area VCHWTP — Village of Cayuga Heights Wastewater Treatment Plant WWFP — Wastewater Facilities Plan WWTP — Wastewater Treatment Plant v I. INTRODUCTION This document is a Final Environmental Impact Statement (FEIS) for the proposed Ithaca Area Municipal Wastewater Collection Improvement Project (the project). This document, together with the Draft Environmental Impact Statement (herein incorporated by reference, previously distributed for public comment), form the Environmental Impact Statement (EIS) for the project. The EIS has been prepared in accordance with the requirements of the New York State Environmental Quality Review Act (SEQRA) and implementing regulations at 6 NYCRR Part 617. The EIS presents an evaluation of the potentially significant adverse impacts of constructing new public sewer lines in the Town of Lansing and a sewer transmission main in the Town of Lansing and the Villages of Lansing and Cayuga Heights. The Draft Environmental Impact Statement (DEIS) also evaluates the impacts of potential sewer lines in the Town of Lansing. Finally, the DEIS evaluates the potential impacts of growth induced in the Towns of Lansing and Dryden and the Village of Lansing as a result of the proposed project, as well as from sewers that may be constructed at some time in the future. The reader is referred to the DEIS document for a complete description of the project and its associated impacts and proposed mitigation measures, as well as a discussion of alternatives to the project. The DEIS is hereby amended by the information contained in the FEIS. EIS Process The New York State Department of Environmental Conservation (DEC) accepted the DEIS on June 20, 2003 and made it available for public comment. DEC held a public hearing on the DEIS on July 31, 2003. The DEC accepted comments on the DEIS until August 11, 2003. This FEIS was accepted by DEC on DEC to insert date. Organization of the FEIS This FEIS is organized as follows. Comments on the FEIS have been organized into topic areas. The Lead Agency's response to each substantive comment is provided after the comment. Comments that are substantively similar have been combined and a single response is given to such comments. Oral comments made at the public hearing are also summarized here. References are made after each comment as to who made the comment and how it was received. Copies of written comments are reproduced in Section IV. The oral comments made at the July 31, 2003 public hearing were recorded on an audio tape, and that tape is part of the public record and is located at the DEC office listed on the cover sheet. Any comments that are not addressed here are not deemed to be substantive. 1 Summary of Additional Information in FEIS This FEIS contains additional information on several subjects, including the following. 1. Several commenters raised the issue of DEIS completeness and suggested that it was not complete and did not adequately address all issues, specifically those related to phosphorous discharges at the Ithaca Area Wastewater Treatment Plant (IAWWTP) and Cayuga Lake water quality. It is the Lead Agency's position that these issues are completely independent of this project and have already been addressed through a separate SEQRA review of the IAWWTP SPDES permit. Nevertheless, this FEIS contains data demonstrating that with planned phosphorous upgrades to the IAWWTP and Village of Cayuga Heights Wastewater Treatment Plant, there will be a net reduction in phosphorous discharge, even with the addition of the Town of Lansing flows. 2. Several commenters questioned the need for the project, specifically whether failing in -ground sanitary waste disposal systems had been adequately documented. This FEIS contains additional data and information documenting need for the project. 3. One commenter raised the issue of segmentation, specifically whether the SEQRA review of this project and the IAWWTP SPDES permit had been segmented. It is the Lead Agency's position that segmentation has not occurred. The project had not been developed and was not under consideration when the environmental review was performed in 1996 on the SPDES permit modification request. The impacts of a 13.1 mgd flow were properly considered during the SEQRA review of the IAWWTP's permit modification. 4. This FEIS includes additional information about the level of detail that will be included in construction plans, including plans for crossing streams and Unique Natural Areas, and how routes will be evaluated during the construction plan development process. 5. This FEIS includes an evaluation of the use of the Norfolk Southern Railroad right-of-way for the sewer trunk line. The evaluation concludes that this right-of- way is not feasible because of construction issues. 6. This FEIS contains additional information about why a separate wastewater treatment plant for the Town of Lansing is not a preferred alternative. 2 II. RESPONSES TO PUBLIC COMMENTS COMPLETENESS 1. Comment: The New York State Department of Environmental Conservation (DEC) should reject the Draft Environmental Impact Statement (DEIS) as incomplete. The DEIS should contain a full range of water quality data for southern Cayuga Lake, including the effects of individual septic systems in the Lansing area, historical and projected effluent analyses for the Ithaca Area Wastewater Treatment Plant (IAWWTP) and the Village of Cayuga Heights Wastewater Treatment Plant (VCHWTP), an IAWWTP SPDESpermit analysis including the effects ofprojected flow increases and tertiary phosphorus treatment, and a complete analysis of the current regulatory backdrop against which the project is proposed, including Total Maximum Daily Load (TMDL) development. (R. DePaolo in 8111103 letter) Response: For determinations of completion, SEQRA requires that the DEIS be adequate with respect to its scope and content for the purpose of commencing public review. This standard was met, as the DEIS contains the information required by the scoping document. To the extent this comment requests additional information relevant to the project, such information is provided in response to specific comments below. Much of the information the commenter requests, however, is outside the scope of this project. During the scoping process, this commenter raised a number of water quality and SPDES permit issues related to IAWWTP discharges. As the Scoping Responsiveness Summary explained, such issues are completely independent of this project and have been addressed through a separate and independent process for the IAWWTP permit. The Final Scoping Document does not include such issues. Several other commenters have nonetheless asked for similar information, especially about IAWWTP SPDES permit issues and phosphorus discharges from the two wastewater treatment plants (WWTPs). Some of the comments contain inaccurate assertions about these topics that are repeated by more than one commenter. To correct these inaccuracies, this FEIS provides information on the IAWWTP SPDES permit and WWTP phosphorus discharges, even though such information is relevant to SPDES permit issues and not this project. 2. Comment: The DEIS needs major supplementation; missing information and analysis should be provided, and the DEIS re -issued for comment. The DEIS is not ready to be moved to the Final Environmental Impact Statement (FEIS) stage. (D. Kiefer in 8111103 letter) Response: See Response to Comment 1. 3. Comment: The DEIS appears to be very complete. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. DOCUMENTATION OF NEED FOR THE PROJECT 4. Comment: There is no or insufficient data to support the assertions in the DEIS that water quality impacts are occurring as a result of inadequate on -site sewage disposal systems. There is no water quality data to support the need for an $11 million expenditure ($7 million funded locally) and 26 miles ofpipe that will result in discharges into the impaired southern part of Cayuga Lake. Any pollution reductions in the project area are likely to be far outweighed by increased water quality problems in southern Cayuga Lake. The EIS should contain water quality data on the effects of Lansing -area on -site systems on Cayuga Lake and performance characteristics for these systems. Data should include wastewater flow, pollution loading studies and a delineation of wastewater entering the Lake from the on -site systems. The EIS should also contain Cayuga Lake ambient water quality data for the proposed service area and for the IA WWTP- VCHWTP discharge area. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in undated written copy of public comment received by DEC on 816103) Response: Septic system failures have posed a threat to surface and ground waters in the Lansing area for decades. Upwards of 30 septic systems in Ladoga Park are inundated by the Lake whenever water elevations exceed 384.0 feet. When waters recede, they can draw untreated sewage into the Lake from the septic systems. Local knowledge indicates these septic systems have flooded on a relatively frequent basis over the past 10 years. (See Comment 79.) The Tompkins County Health Department (TCHD) has noted that severe limitations for on -site systems exist in Ladoga Park due to flooding and inadequate separation distances to surface waters. Concerns are not limited to flooding conditions. During periods of heavy rain, poorly operating systems can contribute inadequately treated sewage into the Lake and its tributaries. Ladoga Park is located on the Lake next to Myers Park, which has a public swimming beach. The TCHD sampled the Lake at this beach on July 23, 2003, after three inches of rain fell in two days and the Lake level rose six inches. This sampling showed elevated levels of total coliform (3200/100ml) and fecal coliform (2400/100ml). Failing septic systems could be a source of these coliform counts. The Town of Lansing Study Area has a number of creeks that drain into Cayuga Lake. (See DEIS Figure 14a.) Failing systems near Lake tributaries can contaminate the tributaries and ultimately the Lake. TCHD records indicate that on the average 5 failed 0 .k septic systems are replaced every year per 1,000 people in the Town of Lansing Sewer Study Area. This is a higher per capita replacement rate than the replacement rates in any of the towns in Tompkins County. Actual numbers of failed systems are likely higher, since homeowners often are unaware that their systems have failed until sewage backs -up into their residences or untreated sewage surfaces on the ground. As unsewered populations in the Lansing area increase, it is reasonable to presume that the number of failed systems per year will also increase. Problems with failing septic systems are not new. The November 1983 Wastewater Facilities Plan for the Town of Lansing includes a summary of findings from a sewage disposal system survey questionnaire that was mailed to 933 parcels within a geographic . area nearly identical to the EIS Town of Lansing Planning Area. Of the 318 returns, 40% indicated some type of failure of their wastewater disposal system. In 1982, the TCHD surveyed 80 homes in the Asbury Road area on a house -to -house basis. Asbury Road runs immediately parallel to Gulf Creek, a tributary to Cayuga Lake. Many of the septic systems along Asbury Road are located just above the steep slopes of Gulf Creek. Of the 80 homes, 10 septic systems were in unsatisfactory or questionable condition and an additional 22 were expected to fail within 5 years. This meant a total of 40% of the systems had failed or were expected to fail soon. Another survey conducted by the TCHD in 1981 of well water systems in the hamlet of Ludlowville found that a significant number of wells were contaminated with sewage. Of 30 wells tested, 18 exhibited some degree of contamination. The TCHD has also expressed concerns about the four on -site sand filter systems at the Lansing Central School District that serve the elementary school, middle school, high school and District Office (approximately 1,380 students, plus teachers and staff; total design flow of 35,300 gallons per day). These systems discharge to surface waters and either drain directly to Cayuga Lake through tributary P296-58 or to Salmon Creek (and ultimately the Lake) via ditches. The TCHD noted in a May 1996 letter that "the soil in much of the planning area is marginal to poor for on -site sewage systems. Many homes and businesses rely on alternative sand filter/dispersion trench sewage systems which may affect ditches and streams especially if lots are not large enough to keep the dispersion trenches at least 50' from property lines (lots under 100' in the lesser dimension)." In addition to the positive impacts on Cayuga Lake and its tributary streams in the Lansing area, the project will benefit public health. The ability to eliminate failed or inadequate on -site systems, flooded on -site systems, and individual package treatment plants will reduce the potential for groundwater and surface water contamination, which will reduce the risk to both public and private water supplies and to public health in general. 5 The DEIS also spells out other project benefits that are not mentioned by the commenters. These benefits are listed in Section 1.2 of the DEIS and include the elimination of SPDES permit flow exceedances at the VCHWTP, promotion of infill in the Town of Lansing rather than conversion of open space and agricultural lands, and the provision of additional public sewage capacity for the Town and Village of Lansing, which currently is extremely limited. The commenters are concerned about the impact of additional flow into the southernmost end of Cayuga Lake. Their additional comments (set forth in numbered comments below) focus on the amount of phosphorus that will be added to this part of the Lake. As stated in Response to Comment 1 above, this issue is not relevant to the project since both the IAWWTP and VCHWTP will maintain their discharges within permitted limits. However, to correct inaccurate statements made by some commenters about the amount of phosphorus this project will generate, phosphorus information is presented here and in response to specific comments below. It is anticipated initially that an average sewage flow of 144,000 gallons per day (gpd) will be collected annually from the Town of Lansing as a result of this project. It is estimated that this flow will increase to 441,000 gpd in 20 years. All of this sewage will be conveyed to public wastewater treatment plants where it will receive treatment to reduce the phosphorus content to below 0.2 mg/L once planned phosphorus upgrades are completed at the IAWWTP and VCHWTP. The amount of phosphorus this represents is less than one-fourth (1/4) of a pound per day initially, and less three -fourths (3/4) of a pound per day over 20 years. Table F-1 in Section III shows the impact that this small amount of flow will have on the phosphorus loading from the WWTPs to the south end of the Lake. Data presented is actual operating data for the IAWWTP and VCHWTP for the last four full years of record and the current year through August 2003. With the planned phosphorus upgrades, an overall reduction in the amount of phosphorus currently discharged from these plants to the south end of Cayuga Lake of approximately 65 percent will be achieved, even with the flows from the Town of Lansing. The five-year analysis shows that from 1999 through August of 2003, the historical combined annual average discharge of total phosphorus from the IAWWTP and VCHWTP has ranged from 33.5 to 44.8 pounds per day. Once the plants install tertiary phosphorus treatment, it is anticipated that their combined total phosphorus discharge will not exceed 11.9 to 14.8 pounds per day for flows in the historic five-year range shown in Table F-1. Addition of the initial flows from the proposed Lansing service area will add another 0.24 pounds per day. The initial percent reduction in phosphorus discharged to the Lake from the two WWTPs (including the initial flows from the Town of Lansing) is estimated to range from 57% to 70%. The projected numbers assume that the two WWTPs will discharge phosphorus at a concentration of 0.2 mg/L at all times (see below). This is the highest likely concentration and actual concentrations will probably be lower much of the time, which will result in even greater initial. reductions in phosphorus to the Lake. Over the 20-year planning period, as flows increase from all six N municipalities due to growth, the amount of phosphorus loading to the Lake at 0.2 mg/L is not expected to exceed 16.6 pounds per day. 5. Comment. The EIS should include data on the number, frequency, location, timing, method and extent of septic system and small package plant failures in the project area, and on whether on -site waste treatment is adversely impacting Cayuga Lake, other waterways, or general public health. One commenter who asks for this information also recognizes that certain developed shoreline areas on both the ,east and west shores have septic systems that occasionally get flooded by the Lake and need to be dealt with. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. . Kiefer in 8111103 letter) Response: See Response to Comment 4 above. 6. Comment: To document need for the project and to compare impacts of any existing problems with project impacts, the EIS should contain more information about rates of discharge and frequency and amount of oveiflow/bypass from the two wastewater treatment plants (WWTPs). One commenter said the EIS should also address whether any of the overflow/bypass problems are being addressed outside this project. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter) Response. Section 2.1 and Tables 1 and 2 in the DEIS summarize the operating conditions of the two WWTPs. No overflows/bypasses have occurred, with the exception of one 2-hour diversion from the IAWWTP headworks in the 1990s during an extreme flooding event. Exceedances of the VCHWTP's permitted flow (all of which is treated) would be addressed by diverting excess flow to the IAWWTP, which has permitted reserve capacity. SOUTHERN CAYUGA LAKE CONDITION & IMPACTS WWTP LOADINGS 7. Comment: The EIS should include historical and projected performance analyses for both the IAWWTP and the VCHWTP, including a projected phosphorus loading analysis that takes into account planned tertiary phosphorus treatment at the IAWWTP and the increased flows from the project. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: Refer to Table F-1 and Response to Comment 4 above. 7 JUSTIFICATION FOR PUTTING FLO W IN SO UTH END OF LAKE AND ANALYSIS OF IMPACTS 8. Contnrent: The EIS needs to justify why wastewater will be transported from a relatively deep part of Cayuga Lake to its shallow, impaired southern basin and compare the environmental pros and cons of doing so. Two commenters said the DEC's phosphorus guidance value of 20 micrograms per liter (indicating excessive eutrophication) is regularly exceeded on the Lake's shallow southern shelf. One commenter said the following as part of this comment: Cayuga Lake's southern S, 000 acres have turbidity and phosphorus levels that impair the Lake's best use. Public bathing is prohibited because of turbidity. High phosphorus levels cause vast algal blooms. These problems threaten drinking water drawn from the Lake. The southern part of the Lake receives phosphorus from IAWWTP and VCHWTP effluent, which is discharged into waters less than 12 feet deep, and phosphorus and turbidity discharged by Cayuga Inlet, Cascadilla Creek, and Fall Creek. Cayuga Lake in the proposed service area is deeper, receives far less pollution and does not suffer from widespread impairments. (R. DePaolo in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter; D. Kiefer in 8111103 letter) Response: See Response to Comment 4 above. The southern shelf does have more issues with phosphorus than the larger, deeper part of the Lake. However, the focus of this project must weigh the overall benefits achieved by providing a regionalized approach to wastewater treatment at larger facilities to the introduction of a new discharge point from a small facility serving only the Town of Lansing. In DEC's experience, larger facilities tend to operate more efficiently and economically with fewer permit excursions. The opportunity posed to provide better treatment and address high flow problems at the VCHWTP is one mitigating factor. Also, the reduction in overall phosphorus loading to the Lake from point sources is a positive for the Lake. By receiving treatment at the VCHWTP, the wastewater from the Town of Lansing will be treated to remove nutrients to a degree that would not be the case if it were discharged to the deeper portion of the Lake. The amount of phosphorus that would enter the Lake from the Town of Lansing flows is far less than the reduction in phosphorus that will be achieved with the planned phosphorus treatment upgrades at the WWTPs. Thus the total loading of phosphorus to Cayuga Lake will be greatly reduced. See Response to Comment 27 below for more information on phosphorus loadings. 9. Comment: The DEIS lacks documentation of the critical state of the southern end of Cayuga Lake. The addition of more phosphorus to this shallow end will only increase the problems to the Lake. (F. Gougakis in 8111103 letter) E:3 Response: See Response to Comment 4 above. 10. Comment: The EIS should analyze the impact of reallocating wastewater to, and concentrating treated effluent in, point discharges to the southern, impaired end of Cayuga Lake. One commenter said this analysis should include how additional loading might impact aquatic biota and algal and weed growth and influence levels of dissolved oxygen. Another commenter noted the Lake's 303(d) listing and said the EIS should discuss the extent to which the project would mitigate water quality problems at the southern end of the Lake. Another commenter said the DEIS does not make a convincing case that implementation of this project will improve water quality problems in the southern end of the Lake. Absent documentation of what the project will mean in the way of addition of nutrients and chemicals to the impaired waters of southern Cayuga Lake, it is impossible to conclude that the project is the best one can do. (D. Kiefer in 8111103 letter; E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Table F-1 and Response to Comment 4 above. 11. Comment: The EIS should acknowledge and discuss the possible biological impacts of the increased WWTP effluent in the impaired waters of the Lake, especially with respect to its reactive -chlorine content and the further concentration of human -excreted drugs. Science is just learning about how, for example, hormones in sewage effluent affect reproduction and the sex of aquatic organisms. As yet, there are no known ways for WWTPs to handle this. This is another reason not to combine/increase effluent streams. (D. Kiefer in 8111103 letter) Response: This comment is not relevant to the project because the WWTPs will be operating within their permitted limits. Impacts of increased amounts of flows were considered when the plants' respective SPDES permits underwent environmental review. That said, the amount of chlorine residual entering the southern part of the Lake will not change significantly from current conditions. The IAWWTP dechlorinates its effluent prior to discharge into the Lake, and its SPDES permit limits total residual chlorine to 0.1 mg/L, which is equivalent to one -tenth of a part per million. The VCHWTP does not dechlorinate its effluent, but the flow treated at that plant will not increase. WWTPs currently do not have special treatment for human -excreted drugs. The increase in flow attributed to the Town of Lansing (annual average of 0.144 mgd initially and 0.441 gpd in 20 years) is a relatively minor fraction of the average combined flows to the two WWTPs (9.19 mgd initially; 9.49 mgd in 20 years.) The Town of Lansing flows will make up only 1.6% of the annual average flows to the two plants initially and 4.6% after 20 years. The concern raised over concentration of human -excreted drugs in the 6 southern Lake is not significantly affected by the relatively low levels of flow projected from the Town of Lansing. LEGALITY OF INCREASED FLOW 12. Comment. Southern Cayuga Lake violates New York State's narrative water quality standard for phosphorus. Algal blooms and rotting and floating weeds cause aesthetic impairments and odors and hinder navigation. Additional phosphorus must not be allowed into the Lake's impaired area from new or expanded point sources. Any increased flow through the IAWWTP into the impaired part of Cayuga Lake on the 303(d) list would constitute a "new or expanded discharge" as prohibited by 40 CFR § 122.4(i). (R. DePaolo in 8111103 letter) Response: The listing of Cayuga Lake on New York State's 303(d) list requires that a TMDL be developed that would identify the point and nonpoint source reductions of phosphorus necessary to restore the designated use. DEC does not believe that there is sufficient information to develop a TMDL at this time. Since the WWTPs will be operating within the limits set by their respective SPDES permits, flows from the project are not considered flows from a "new source or a new discharger," as those terms are defined in the regulations. (Note that this is the regulatory standard, not "new or expanded discharge" as the commenter states.) The increased flows through the IAWWTP will come from the current VCHWTP service area. These are flows that are currently discharged into the south end of the Lake through the VCHWTP outfall. This diversion will free up capacity at the VCHWTP for new Town of Lansing flows. The total loadings of phosphorus from the WWTPs are expected to be far less after the proposed project and phosphorus upgrades are completed than current conditions. See Responses to Comments 4 above and 27 below for more information on phosphorus loadings. 13. Comment: Wastewater collected in the proposed service area was originally intended to be treated by a new facility requiring a discharge permit. Such a permit would have been prohibited by the federal moratorium in 40 CFR § 122.4(i), which prohibits the issuance of discharge permits to "a new source or a new discharger, if the discharge from its construction or operation will cause or contribute to violation of water quality standards. " Conveying the wastewater to the permitted IAWWTP by-passes this critical non -degradation standard. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: See Response to Comment 12 above. 10 EFFECTS OF 303(d) LISTING AND TMDL PROCESS 14. Comment: Despite the fact the southern 5, 000 acres of Cayuga Lake is on the federal 303(d) list and is designated as high priority for TMDL development, DEC has not investigated the problems nor taken action to eliminate them. The EIS should analyze the current regulatory backdrop against which the project is proposed, including proposed TMDL development. DEC should analyze project impacts in connection with a TMDL study and should define the regulatory backstop that guarantees the project will not contribute to existing water quality standards violations in southern Cayuga Lake. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: As noted in Response to Comment 12, the WWTPs will be operating within their permitted limits and total point source loading to the Lake will be significantly reduced. Regarding the TMDL process, the DEC has agreed to perform an evaluation of the phosphorus loadings to the southern shelf of the lake. The EIS does not supplant the DEC's regulatory responsibilities, nor should it be delayed pending DEC's evaluation. If as a result of the TMDL process further reductions in phosphorus point source loadings are required, DEC will require such reductions through all necessary means, including WWTP SPDES permit modifications if required. 15. Comment: DEC has made no tangible progress to institute a TMDL pollution control program, even though southern Cayuga Lake is a high priority for such a program. One commenter said DEC rejected the Environmental Protection Agency's offer in 2001 to help fund a water quality study and DEC has not developed or adopted any TMDLs since Cayuga Lake was listed on the 303(d) list in 2002. The project should be approved only after the TMDL is implemented or other regulatory safeguards are imposed to assure no further degradation of water quality. Another commenter said a TMDL should be in place before this project or any new wastewater treatment plant is constructed. (W. Hang at 7131103 Public Hearing and in 816103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 14 above. 16. Comment. The southern end of the Lake is on the national 303(d) listing and is a priority for TMDL development. DEC should be extremely careful about adding any discharges to this area. (D. Kiefer in 8111103 letter) Response: See Response to Comment 14 above. 11 DEC ACTIONS REGARDING OTHER PROJECTS AFFECTING CAYUGA LAKE 17. Comment: DEC has failed to enforce the federal moratorium provision by granting a discharge permit to the Lake Source Cooling Project. One commenter said Lake Source Cooling contributes nearly 10% of the phosphorus entering southern Cayuga Lake. Another commenter said despite a recommendation by a Town of Ithaca consultant, there is no monitoring near Lake Source Cooling's outfall, and the commenter is very concerned about DEC's standards and ethics. Other projects are not allowed in shallow waters, and Lake Source Cooling should not have been allowed. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter) Response: This comment is not relevant to the project. The Lake Source Cooling permit was legally issued after extensive review by the public and DEC. 18. Comment. The commenter asks why DEC has failed for years to address problems at the VCHWTP and expresses concern about the possibility that Cornell University's veterinary school waste might be discharged to the IAWWTP. This commenter wants DEC to address these and other impairments before allowing more waste into the southern basin. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: The project includes a diversion to eliminate VCHWTP exceedances of permitted flows. In addition, DEC is funding improvements (independent from the project) to the VCHWTP. The improvements include effluent filtration and chemical addition for enhanced phosphorus removal; the addition of baffle wall within one of the two final settling tanks to improve performance; and replacement of trickling filter media for improved wastewater treatment reliability. The discharge of Cornell University's veterinary school waste into the IAWWTP is independent from the project and is still in the discussion stage. Should that plant agree to accept such waste, it would have to be treated so that all of the parameters and limits in the plant's SPDES permit are met. SEGMENTATION 19. Comment. The IAWWTP SPDES permit modification and the project are illegally segmented. As a result, it is impossible to quantify the water quality impacts from the project. (R. DePaolo at 7131103 Public Hearing) 12 Response! There is no illegal segmentation, the water quality impacts are quantifiable, and the impacts of a 13.1 mgd flow were considered during the SEQRA review of the plant's permit modification. As the Scoping Responsiveness Summary noted, the IAWWTP owners requested an increase in capacity in 1995 because the 10 mgd flow limit had been reached (and actually exceeded on at least two occasions). The plant owners asked for the additional capacity to keep the plant in compliance. Their request for 13.1 mgd was based on an engineering study, which indicated the plant capacity could be increased to 13.1 mgd with minor improvements and modifications, which were made in 199T The City of Ithaca conducted a SEQRA review on the,permit modification in 1996 and issued a Negative Declaration. The project that is the subject of this EIS had not been developed and was not under consideration at that time. The Town of Lansing instead was pursuing its own wastewater treatment plant at Portland Point in Lansing. It applied for Clean Water/Clean Air Bond Act funding for a stand-alone plant in 1997. The current project was developed only after Bond Act funding was denied to the local municipalities for their individual projects, and the DEC urged them to come up with a regional solution for wastewater treatment needs. Segmentation has not occurred. The SPDES permit modifications are not dependent on or driven by the project. The IAWWTP needed the increased capacity regardless of whether service areas are added, and it applied for the increased capacity well before the municipalities started developing the project that is the subject of this EIS. In addition, the DEC's approval of the increased capacity does not commit the municipalities and agencies to approving the various elements of the project, nor have environmental impacts evaded review (which is the concern about segmentation). The environmental effects of an increase in capacity to 13.1 mgd were considered in the City's SEQRA review. The effects of a 13.1 mgd discharge on Cayuga Lake are the same regardless of whether the flow comes from within or outside the current service area. 20. Comment. Application of DEC's 8-part test shows segmentation has occurred. There is: a common purpose or goal for each segment; a common reason for each segment being completed at or about the same time; a common geographic location; a common impact that may result in a potentially significant adverse impact if the activities are reviewed as one project; and common ownership or control of the different segments. A given segment is a component of an identifiable overall plan and the initial phase directs the development of subsequent phases; the phases are functionally dependent on each other; and DEC undertook concurrent review of funding and permit modification requests for both segments. Without the project, there would be little need for increased capacity at the IAWWTP. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See Response to Comment 19 above. In addition, application of DEC's 8-part test shows the following. 13 Is there a common goal? In 1994, the IAWWTP owners identified an opportunity to have DEC increase the plant's permitted capacity at very low cost if they made final settling weir and baffle improvements and increased influent pumping capabilities. The fact the 10 mgd flow limit had been exceeded on two occasions, coupled with the fact the permitted capacity could be increased through implementation of low cost improvements, led to the request in 1995 for an increase in capacity. The IAWWTP owners' consistent goal was to get this low- cost increased capacity, regardless of what happened with the project that is the subject of this EIS. Is there a common reason for completing each segment at or about the same time? While it is true the flow diversion from the VCHWTP could not occur before an increase in capacity at the IAWWTP, there is no reason to have the increase in capacity occur "at or about the same time" as the flow diversion. The IAWWTP permitted capacity expansion could and did occur without the flow diversion. Is there a common geographic location? The answer to this depends on how one defines each project's location. Obviously, the IAWWTP is involved in both the permit modification and the project. But many elements of the project are located in the Town and Village of Lansing and the Village of Cayuga Heights as well. The actual flows from the Town of Lansing will flow to and be treated at the VCHWTP, with other flows diverted to the IAWWTP. Is there a common impact that may result in a potentially significant adverse impact if the activities are reviewed as one project? This query seeks to determine whether impacts from two or more projects, which may be insignificant when reviewed separately, become significant when the projects are reviewed together. As stated in Response to Comment 19, the effects of a 13.1 mgd discharge on Cayuga Lake were reviewed in 1996 when the City of Ithaca issued a Negative Declaration. The impacts are the same regardless of whether the flow comes from within or outside the current service area. There are no additional impacts to the south end of the Lake from the addition of flows diverted from the VCHWTP because the total discharge will be less than 13.1 mgd. No different or more significant impacts to the southern Lake could possibly have been identified if the projects had been reviewed together. Is there common ownership or control of the different segments? The IAWWTP is owned and operated by the City of Ithaca, Town of Ithaca, and Town of Dryden. This ownership and control is expected to remain the same regardless of whether the diversion and/or service area expansions occur. The VCHWTP is owned and operated by the Village of Cayuga Heights. Pump stations and public sewers in the Town of Lansing will be owned and operated by the Town of Lansing. The Town of Lansing will also own and operate a transmission main that is proposed to cross the Village of Lansing and a portion of the Village of Cayuga Heights. Public sewers in the Village of Lansing will be owned and operated by the Village of Lansing. Is a given segment a component of an identifiable overall plan? At the time of the City's SEQRA review of the 13.1 mgd discharge, the plan that is the subject 14 of this DEIS had not been developed. In fact, the project sponsors undertook a lengthy planning process to arrive at the plan which is the subject of this EIS. This process did not begin until long after the City's SEQRA review was completed. • Are the phases functionally dependent on each other? Flows could not be diverted from the VCHWTP without the IAWWTP capacity expansion. However, the IAWWTP capacity expansion is not dependent in any way on the flow diversion. • Does the approval of one phase commit the agency to approval of other phases? (Note that this last test in the SEQR Handbook is different from that set forth in the commenter's letter.) The answer to this query is no. Approval of IAWWTP's increased capacity request does not commit the project sponsors, DEC, nor other agencies to approval of the various components of the project. 21. Comment: Although the initial application to modify the IAWWTP's SPDESpermit was made before the project materialized, DEC continued to review the application for four years after rejecting separate funding applications and suggesting a regional wastewater management approach, for three years after accepting joint grant applications, and for two years after becoming Lead Agency on the project. A DEC SPDES permit writer told this commenter the length of the review period was due to the fact the permit limit for phosphorus was "revisited several times " during the review process. Review of the permit modification should have been joined with review of the project. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19 and 20 above. There were a number of reasons the period between permit modification application and permit issuance was so long, including personnel changes at DEC. 22. Comment. To remedy the segmentation, the EIS should include IAWWTP historical and projected phosphorus loading analyses, and DEC should revoke or suspend the IAWWTP's SPDESpermit and rewrite it to reflect the effects of the planned tertiary phosphorus treatment and the increased effluent posed by the project. The rewritten permit should adhere to Technical and Operation Guidance Series (TOGS) 1.2.1 and 1.3.6, which govern the processes by which phosphorus limits are calculated for expanded discharges into lakes. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19-21 regarding the segmentation comment. Because there was no segmentation, there is no need to revoke or suspend the IAWWTP permit. Historical and projected phosphorus loading analyses for the IAWWTP and VCHWTP are presented in Table F-1. The IAWWTP SPDES permit contains a Fact Sheet that 15 establishes the procedure for the establishment of new limits to reflect the effects of the planned tertiary phosphorus treatment, which is expected to begin operation in the early Fall of 2004. The new limit will be based on actual performance of the plant once the new phosphorus treatment has been in operation for eighteen (18) months. Based on the technology and manufacturer's warranty for the equipment that is being installed, the new limit is not expected to exceed 0.2 mg/L. IAWWTP SPDES PERMIT MODIFICATION 23. Comment: The IAWWTP's modified SPDES permit allows a 37% increase in mass loading of phosphorus over historical performance in contravention of the "no net increase "provision in TOGS 1.3.6 and TOGS 1.2.1. It appears the permit limit for phosphorus was artificially inflated to allow the capacity needed for the project. (R. DePaolo in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. We believe the commenter intended to reference TOGS 1.3.6 and 1.3.1 (not 1.2.1), so this response is based on information and guidance contained in TOGS 1.3.6 and 1.3.1. Before the IAWWTP permit modification, its then -existing permit required reduction of phosphorus to 1.0 mg/L on a 30-day average basis. This concentration -based limit and the 10.0 mgd flow limit for the plant established a maximum phosphorus loading of 83.4 lbs/day. TOGS 1.3.6 establishes phosphorus removal requirements for new and expanded discharges to lakes or in lake watersheds. The process used by the DEC for the new permit limit is based on TOGS 1.3.6 and statistical analysis of plant performance data from January 1996 through September 2000. Guidance criteria stated in TOGS 1.3.6 requires that: "...any proposed expansion of an existing discharge within a lake watershed, which would require a modification of an existing SPDES permit, should provide BTT [Best Treatment Technology] for phosphorus removal to a degree that the annual quantity (mass loading, flow multiplied by concentration) of phosphorus discharge after the modification does not exceed the phosphorus discharge prior to the modification." The DEC has interpreted this to mean that the discharge of phosphorus after the modification cannot exceed the current (historical) level of phosphorus, not the permitted allowable level of phosphorus. In order to determine the current level of phosphorus being discharged, the DEC completed a statistical analysis of plant data from January 1996 through September 2000, to calculate the 95th percentile effluent phosphorus mass loading. This statistical analysis yielded a limit for phosphorus of 401bs/day. The limit was set at 401bs/day because, in 16 accordance with DEC's standard methodology, 95% of the 46 twelve-month rolling average data points fell below 40 lbs/day. Note that the data in Table F-1 cannot be used to calculate the limit, because the Table F-1 data are actual annual averages (not 12- month rolling averages) which are intended to show the average reduction in phosphorus discharged to the Lake. Table F-1 does not represent a statistical analysis of the data. It is important to note that the modified phosphorus effluent limit of 40 lbs/day represents a greater than 50 percent reduction in mass loading of phosphorus versus the plant's previous permit limit of 1.0 mg/L or 83.4 lbs/day. In setting the new limit, the DEC recognized that the facility actually discharged significantly less phosphorus than what was permitted. The purpose of the modification was to set a no net increase limit on an annualized basis. It should also be pointed out that the modified limit does not reflect advanced phosphorus removal technology. As mentioned in Response to Comment 22, a project is currently underway to provide for an advanced phosphorus removal facility. The SPDES Permit Fact Sheet recognizes that the existing phosphorus limit will be . further decreased once the construction is completed and operation of the new facility is underway. 24. Comment: DEC issued a revised SPDES permit for the IAWWTP that allows an increase in phosphorus discharge from less than 30 pounds per day to up to 40, pounds per day. Two commenters state that DEC ignored its own regulatory policy (TOGS 1.3.6) by approving this revision. (W. Hang at 7131103 Public Hearing and .in 816103 letter; R. DePaolo at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 23 above. 25. Comment: If wastewater flows are higher than projected, phosphorus loadings could increase beyond the historical 30 pounds per day, and the sponsors would be within their legal rights. This commenter asked DEC two years ago to revoke or modify the SPDES permit on the grounds of grave material falsehoods and the 37% increase in phosphorus loadings. The commenter provided DEC with a detailed statistical analysis performed by a Cornell University statistics professor that showed the 37% increase. DEC has never responded, even though this commenter was promised an answer 18 months ago. It seems likely DEC did not respond in order to allow the SEQRA process for the project to proceed without the benefit of technical insight into the creation of the IAWWTP permit. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. The technical basis for the creation of the IAWWTP permit is explained in the permit's Fact Sheet. As stated in Responses to Comments 23 and 24, the 95 percent statistical recurrence of effluent phosphorus loads (as determined by the DEC) from the IAWWTP 17 is 40 lbs/day, not 30 lbs/day as stated by the commenter. Therefore, the permit establishes . a "no net increase" in allowable phosphorus load discharged from the IAWWTP. The statistical analysis by the Cornell University statistics professor relied on only two years of historical plant flow data, whereas the DEC analysis relied on nearly five years of historical data. (The SPDES Permit Fact Sheet contains a typographical error that says DEC used 3 years of data.) The two years of data used by the professor generates a data set of 12 data points, which DEC believes is not a large enough data set to perform the statistical analysis because it is not a good representation of fluctuations in climatic changes. In comparison, DEC's data set between January 1996 and September 2000 yields 46 data points. Although the commenter has stated the older data is not representative because of subsequent improvements to the IAWWTP and its collection system, those improvements were, not done to increase phosphorus removal and did not impact phosphorus loadings or reductions. PHOSPHORUS UPGRADE & LOADINGS 26. Comment: The DEIS contains no information on the phosphorus removal project that is currently out for bid at the IAWWTP. The scoping documents mentioned this project. This commenter thinks the phosphorus removal elements were taken out of the DEIS to avoid a focus on water quality issues. The FEIS should reference the phosphorus removal component. (R. DePaolo at 7131103 Public Hearing) Response: Contrary to the commenter's assertion, the phosphorus removal project was not included in the Scoping Document. The Overview Document previously released to the public states that the IAWWTP phosphorus removal project is independent from the diversion project and would not be part of the EIS. The Overview Document further states that the IAWWTP phosphorus removal project was a Type II action under SEQRA and further SEQRA review was not required for it. 27. Comment: The project would undercut or eliminate the benefits of a proposed phosphorus removal upgrade to the IAWWTP. That facility currently removes phosphorus to less than 0.7 milligrams per liter (parts per millions (ppm)) on a 12-month rolling basis. Approximately 27.5 pounds ofphosphorus are discharged daily into the Lake. After the upgrade, phosphorus would be reportedly removed to less than 0.2 ppm on a 12-month rolling average. The project will generate wastewater containing 25 to 36 pounds per day of phosphorus, or 11 % to 16% of the 220 pounds of phosphorus now received by the IAWWTP. That contribution would off -set improved phosphorus removal at the upgraded plant. If wastewater generated by the proposed project exceeds DEC's estimate, there could be a net increase in phosphorus discharged into the Lake, because the IAWWTP's revised SPDES permit allows up to 40 pounds per day of phosphorus discharge. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: See the last paragraph of Response to Comment 1. This comment uses incorrect numbers and double -counts existing VCHWTP flows that will be diverted to the IAWWTP. Even with the addition of flows from the Town of Lansing, the amount of phosphorus discharged to the south end of Cayuga Lake will be reduced by between 57 and 70 percent. The discussion presented is flawed in that it states, "The proposed project is estimated to generate wastewater containing 25 to 36 pounds per day of phosphorus" when actually only 11 lbs/day initially and 31 lbs/day in 20 years will be collected by the Town of Lansing sewers installed as part of this project. These amounts will be treated by the VCHWTP and reduced to less than one-fourth lbs/day of phosphorus initially and less than three -fourths lbs/day in 20 years before it is discharged to Cayuga Lake. The flows diverted to the IAWWTP are existing flows from the VCHWTP service area, and, therefore, they do not add an additional phosphorus load to the Lake because they are currently discharged to the south end of the Lake through the VCHWTP outfall. With the phosphorus treatment upgrades at the two plants, the total amount of phosphorus being discharged to the south end of Cayuga Lake will be reduced from a current annual average load ranging from 33.5 to 44.8 pounds per day (combined discharges from the IAWWTP and the VCHWTP) to approximately 15 lbs/day initially (including the additional initial flow collected in the Town of Lansing). 28. Comment: If DEC continues to support the project, then it should be redesigned to prevent further degradation of Cayuga Lake. The phosphorus pollution generated by the project should be measured as it flows into the VCHWTP and the sponsors should clean up at least twice that amount elsewhere in the Lake's watershed. For example, artificial wetlands at the mouth of Cayuga Inlet could control phosphorus from stormwater runoff, and buffer zones could be established along agricultural areas to prevent fertilizer runoff into Lake tributaries. A study could be undertaken to determine if Lake Source Cooling water could be used as potable drinking water and be treated before discharge back to the Lake. The main polluted area of the Lake flows away from Lake Source Cooling s intake and directly towards Bolton Point's intake, which is directly downgradient from wastewater discharged into the Lake. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The WWTP owners will accomplish far more than what this commenter has requested. Flows from the Town of Lansing sewers will result in one-fourth of a pound per day of phosphorus initially and less than three -fourths of a pound per day in 20 years discharged to the Lake. With the installation of phosphorus treatment, the WWTPs' loadings of phosphorus will decrease in the range of 20 to 31 pounds per day. 29. Comment: The VCHWTP is outmoded and lacks state-of-the-art phosphorus removal. That facility lags behind the IAWWTP's efforts to upgrade its phosphorus removal 19 capability. That problem should be rectified. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The VCHWTP will be upgraded for advanced phosphorus removal and it is expected to remove phosphorus to a level of 0.2 mg/L or better. Money has been awarded from the Clean Water/Clean Air Bond Act for this upgrade. CONSTRUCTION 30. Comment. The EIS should include details about the actual construction and installation of sewer lines in the Lansing Service Area, such as the size of the construction right-of-way, how deep lines will be buried, and what the area of disturbance will be. The FEIS should use this information to analyze construction impacts on stream corridors, instream habitat, wetlands, and Unique Natural Areas (UNAs) in the Lansing Service Area, and the construction plans for the Lansing Planning Area should address these impacts. (E. Marx, Tompkins County Planning Department in 8111103 . letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Traditional sewer pipe installation using open -cut methods of trenching can typically be accomplished within a footprint of 30 feet. Permanent easements are normally 20 feet wide. The depth of construction is variable and will not be known until final design profiles are prepared. At a minimum the depth of cover on small diameter gravity or forcemain sewers will be approximately 4-5 feet. Field verification of construction impacts will be made at the time construction routes are finalized. 31. Comment: The FEIS should detail what is to be included in each construction plan. Construction plans should address minimization of sedimentation and erosion; describe in the blasting plan how construction and pipe locations might impact private drinking water sources from bedrock wells and describe mitigation measures for such impacts; and analyze impacts from potential staging areas. Construction staging areas should be located outside of any UNAs. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The DEIS indicates that appropriate measures will be implemented to mitigate these construction related impacts. These measures will be detailed on construction plans and in the specifications. Construction documents for the pipeline and pump station projects will include requirements for erosion and sediment control (i.e. silt fence, dewatering of excavations, stabilizing exposed soils); rock removal by blasting with appropriate monitoring; and approved areas for establishing materials and equipment storage. Such plan details and specifications will be tailored to the specific work sites once final sewer main routes are determined. - Construction staging areas will be located outside of UNAs wherever possible. 20 UNIQUE NATURAL AREAS 32. Comment. The existing maps of UNA boundaries are not exact. Placement of a sewer line on a boundary does not necessarily mean that there will be no impacts to the flora and fauna, geological structures, habitat, etc. that are found in the area. The FEIS should explore alternative transmission routes along road beds or routes further away from UNAs. The FEIS should also consider trenchless digging as an alternative in the UNAs. Alternate locations should be considered for the two pump stations that are proposed in the UNAs in the Lansing Service Area. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: To the extent practicable, preliminary sewer main routes in the Town of Lansing Service Area have been selected to avoid the general extents of the UNAs. The proposed gravity transmission main along the former Ithaca -Auburn railroad bed will traverse UNA-89, UNA-102 and UNA-103 and an alternative forcemain design has been evaluated along Cayuga Heights Road. A subsequent forcemain design along the Norfolk Southern railroad right-of-way is described in Response to Comment 33. Trenchless technology for installing sewer mains has been identified in the DEIS as a mitigation measure to be implemented for avoiding disturbance of specific surveyed natural features within the UNAs. The proposed Myers Road pump station lies within UNA-55 and will be sited in the vicinity of the Myers Road and Lakeshore Road intersections. The majority of the land in this area was once utilized for gravel mining. The Portland Point pump station will be located west of UNA-63 within the extents of the former industrial disturbance. 33. Coninzent: The EIS should examine the possibility of running the Town of Lansing- VCHWTP transmission line along the existing Norfolk Southern railroad line, which is already a highly and frequently disturbed area. This would eliminate the need for pumping stations and habitat destruction that would be necessary with the other routes discussed in the EIS and there would be easy access to the rail bed, which would decrease the cost of maintenance and repair. (L. Leopold in 8111103 letter) Response: T.G. Miller, P.C. has explored the permit requirements and physical constraints of a "longitudinal occupation" within the Norfolk Southern Railroad right-of- way. The Norfolk Southern pipeline offset requirements dictate that a sewer main must be installed roughly 24 feet from the rail centerline. Occupation along the west side of the rail places the main in the waters of Cayuga Lake for a majority of the 5 mile route. Land availability east of the rails varies considerably. At several locations the extensive rock cliffs are within 5 to 6 feet of the eastern rail. To conform to the offset requirements it will be necessary to remove substantial faces of the rock cliff. This removal would negatively impact the steep slopes east of the present cliff edge. 21 Due to the physical constraints noted above, access to and along the railroad bed is not sufficient for either initial construction or future maintenance as long as the rail remains in use. Further, the construction cost for this alternative as estimated in the T.G. Miller analysis will minimally be 2-2.5 times the cost of the Cayuga Heights forcemain alternative. Based on these factors the Norfolk Southern Railroad alternative is not viable at this time. 34. Comment: These commenters strongly support the alternative transmission route along Cayuga Heights Road proposed for the Twin Glens and Esty's Glen UNAs. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Comment received and noted. 35. Comment: As recommended in the DEIS, a biological survey should be conducted of the proposed interceptor route in UNA 103, McKinney's Twin Glens and Lake Cliffs. One commenter wants this survey to inform a decision as to whether trenchless construction should be used (as recommended in the DEIS), and requested this survey be done before the end of the SEQRA process. Another commenter suggested the survey be used to decide whether the sewer route should be diverted away from the UNA, and requested the survey be conducted during the appropriate time of year to reveal the potential plants or animals impacted. (E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Prior to any final selection of the Ithaca -Auburn railroad transmission route a survey will be conducted by qualified professionals to identify the important natural communities and rare/scarce plants or animals within close proximity to the route. The identification of rare or scarce plants will be conducted during the appropriate season(s). The width of the survey corridor will be determined after consultation with the . professionals. The approximate limit of the corridor within UNA-89 and UNA-103 is between the south end of Cayuga Hills Road and the existing Village of Lansing sewer transmission main below Cedar Lane. A land survey will then be performed to map the identified communities and plants in order to assess the feasibility of using trenchless technology or to completely avoid the corridor. 36. Comment: The construction of a pipeline through UNAs 103 and 89 would ' necessitate the removal of a large number of medium-sized and mature hemlocks in the Twin Glens area, which are irreplaceable and create a beautiful visual scene. These areas have had 75 years to grow into forest and many local residents enjoy them year- round. No amount of mitigation can restore these areas in our lifetime if this pipeline is 22 built through this area. The EIS is meant to deal with and prevent preventable environmental impacts. (L. Leopold in 8111103 letter) Response: See Response to Comment 35 above. 37. Comment. The commenter is concerned about the environmental impacts of digging in UNAs and asks how often connectors would be built in forested escarpment areas to reach the transmission interceptor. (J. Dennisat 7131103 Public Hearing) Response: The proposed Ithaca -Auburn railroad transmission main does not include or anticipate the construction of additional connectors through forested escarpment areas. 38. Comment. The Existing Conditions section of the DEIS should note that UNA 103, McKinney's Twin Glens and Lake Cliffs, contains a section of the old Ithaca -Auburn Shortline that crosses the glen. If sewer lines will run close to remaining abutments and a trestle from the old Ithaca -Auburn Shortline, the FEIS should assess the impacts of the sewer lines on these features, which may have historic or cultural significance. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: With modifications, the abutments of the Ithaca -Auburn Shortline railroad at the southerly glen could support a pipe bridge. The Stage I Cultural Resources Survey did not identify these abutments as having historical or cultural significance. Further, there is no remnant of a "trestle." There are two existing pipe bridges south of Cedar Lane that support the Village of Lansing sewer transmission main. 39. Comment. The EIS has very little information about mitigation of impacts in UNAs. (J. Dennis at 7131103 Public Hearing) Response: Mitigation for impacts to UNAs is adequately discussed in DEIS Section 4.4.2 and the sections referenced therein. Additional mitigation measures are discussed in Responses to Comments 31 and 35. WETLANDS 40. Comment. The EIS should consider an alternate route for the sewer lines that are proposed to cross UNA 65 (Head Corners Wetland), and DEC should be consulted prior to any disruption of the area. The commenter supports the DEIS suggestion that a 23 wetland scientist should survey the area and make recommendations for limiting impacts to this wetland. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The potential for crossing the Head Corners wetland exists in a future phase for which no definite plans have yet been formulated. Based on the assessment in this EIS, an alternate route for a sewer line in the vicinity of this wetland will be analyzed if and when future sewer extension plans are developed. 41. Comment: Care should be taken to preserve and protect wetlands throughout the study area. ha addition to the impacts noted in the DEIS, loss of wetland function can have negative impacts on surrounding lands due to flooding, and can cause problems associated with water quantity and quality in stream corridors and eventually in Cayuga Lake. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Comment noted. The proposed project will not have any direct impact to wetlands, as stated in the DEIS and confirmed by FEIS Figures 1 and 2 in Section III. See also Response to Comment 43. 42. Comment: When the location of sewer lines is determined, a wetlands scientist should conduct a more complete analysis of potential wetlands impacts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Field verification of the EIS conclusion that no wetlands will be impacted will be made at the time construction routes are finalized. 43. Comment: The EIS should contain a map showing all wetlands overlaid with the proposed sewer lines at a finer scale (for example, 1: 24, 000) than that used in Figures 17 and 18. The EIS should also combine the information in Figures 44 and 45 into one map shown in an additional figure. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: More detailed maps of wetlands in relation to proposed sewer routes are found in FEIS Figures 1 and 2. These figures confirm the DEIS conclusion that the proposed Service Area sewers will not impact wetland areas. The potential impacts of Planning Area sewers are accurately discussed in the DEIS. Im WATER RESOURCES 44. Comment: Sewer line routes should be designed to reduce impacts to known private wells and public drinking water supplies (such as those at Myers Point, Ludgate's, and the Plantations Inn). (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: FEIS Figure 3 in Section III illustrates the proximity of proposed sewer lines to known public drinking water supply sources. No such sources are located in close proximity to proposed sewer lines such that they would be impacted by the project, with the possible exception of the well point on Burdick Hill. Mitigation for potential impacts to this supply is discussed in Response 46. 45. Comment: There is no discussion of how to mitigate the impact that trenching activities would cause on a residential drinking water supply that exists in the form of a large cistern at 1203 East Shore Drive that lies directly below the former Short Line railroad bed. This was brought up during the scoping session but is not mentioned in the DEIS. (L. Leopold in 8111103 letter) Response: This supply is discussed at DEIS page 70. Mitigation of impacts from potential leaks or a break in the line is discussed at DEIS page 74. It is proposed that, the transmission line be double sleeved within 100 feet of this water supply. To the extent there may be potential construction impacts from trenching activities, during construction the location of the cistern will be marked in the field and all construction activities will be maintained at a safe distance from the cistern to avoid adverse impacts. The safe distance will be determined in the field based on soils characteristics. 46. Comment: The DEIS states at page 31 that there are numerous private wells located throughout the Study Area that have not been comprehensively mapped. Some of these well points are regulated public water systems, and these have been mapped. The data for these wellheads is available through the Tompkins County Planning Department. There are few, if any, regulated public water systems in the service area, as most of the service area is already served by municipal water. If the final plans do indicate impacts on a regulated water system from sewer construction, the system may need to be abandoned and the municipal water systems used if available. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Known public water supplies are mapped in FEIS Figure 3. The Tompkins County Planning Department supplied the data about these wellheads. There is no available mapping of private wells. No wells for which information is known are found in proximity to proposed sewer lines, with the exception of the private source discussed in Response to Comment 45, and possibly the Burdick Hill well point. Mitigation for the 25 former is discussed in the DEIS and in Response to Comment 45. With respect to the latter, similar mitigation (such as double sleeving of the sewer line within 100 feet of the well point) will be implemented if the line is found to pass within 100 feet after construction plans are developed. 47. Comment: Section 4.5.1 (Impacts to Water Resources) should acknowledge that there could be negative impacts to well heads and mitigation should be recommended, where possible. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 44. GROWTH -INDUCING IMPACTS 48. Comment: The sponsors should consider the following growth -inducing impacts in addition to those identified in the DEIS: • The adequacy of public water supplies and private drinking water wells (since induced growth may increase the demand for public and private drinking water supplies). • Increased congestion of specific transportation corridors that could result from the density and intensity of land uses allowed in a particular area and the timing of sewer line extensions. Local comprehensive plans should carefully evaluate these relationships between infrastructure and land use. The transportation demand model used in the DEIS dilutes the traffic impacts by spreading them throughout the study area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment noted. The relevant municipalities will need to determine whether adequate drinking water supplies exist in the locations of proposed sewers. Adequate supplies currently exist in the proposed Lansing Service Area; decisions about water supply adequacy in the Lansing Planning Area and Dryden Study Area will need to be made if and when sewers are proposed in those areas. The relevant municipalities should also consider the potential transportation impacts of proposed land use patterns and traffic mitigation. Mitigation could include, among other things, mixed use development patterns that take advantage of or enhance transit connections, and links and facilities for pedestrians and bicycles. The use of the word "dilutes" is not completely accurate in the comment about the transportation model. Volumes of traffic for specific links and intersections are projected with a dynamic model that assumes people will shift their patterns if a specific link or intersection becomes too congested. So the model makes traffic assignments using the entire road network. As a result, one may find that development spread out over an area 26 may show insignificant traffic impacts (such as no system failures at specific links or intersections), particularly if the area has a dense road network. If there are few roads, they tend to capture all the traffic and the model starts to report capacity problems. 49. Comment: The project will trigger a large amount of building. The EIS has very little information about induced housing growth in new areas. (J. Dennis at 7131103 Public Hearing) Response: The DEIS contains an extensive discussion of induced growth in Section 6. Table 31 on page 100 specifically estimates the number of dwelling units which may be constructed in the Study Area under three scenarios. The remainder of Section 6 analyzes the impact of such development. 50. Comment: Sewers will induce growth, which will lead to non point source impacts on the Lake caused by lawn fertilization and stormwater runoff. How do we know there will be a positive offset in taking septic systems off-line? (R. DePaolo at 7131103 Public Hearing) Response: See Response to Comment 4 above. Among other things, the project will correct a significant problem with respect to failing septic systems. It is true that growth may have other impacts. The purpose of the induced growth analysis in DEIS Section 6 is to provide the affected municipalities with information about the amount of growth that may occur in order that they may formulate land use policies to avoid adverse impacts. ALTERNATIVES 51. Comment: DEC has made it clear throughout this planning process that it would only support an intermunicipal solution. The DEIS does not show that the project is better than the alternative of constructing a state-of-the-art satellite treatment plant for the Town of Lansing that would release effluent into a deeper, more northern, and, less impaired portion of the Lake. Although DEC did not approve funding for this alternative, it is still a real alternative, and the EIS should discuss this alternative in more detail. One commenter requested that another map/figure be added to the EIS showing possible location and depth of discharge for a new WWTP, as well as the Lake depths in that area. One commenter believes DEC pushed the intermunicipal solution for fiscal reasons as much as for environmental reasons. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; L. Leopold in 8111103 letter; D. Kiefer in 8111103 letter; F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: DEC prefers an intermunicipal solution that addresses the problems in the region comprehensively. The phosphorus loadings from Town of Lansing flows are very small and overall phosphorus loadings to the Lake will be greatly reduced with the 27 planned WWTP phosphorus upgrades. It is difficult to interpret the meaning of "state-of- the-art satellite treatment plant" in the comment since no proposal went through to a design phase. In DEC's experience, small municipal plants generally have more operational and compliance problems than regional facilities. Smaller municipal plants are seldom "state-of-the-art" because of the inability to spread higher costs over a small tax base. 52. Comment: The EIS contains no evidence that centralization of wastewater treatment infrastructure in this instance would be more cost-effective or technically superior than a decentralized approach using an additional treatmentplant in the Town of Lansing. One commenter said new technologies are available that treat wastewater efficiently and properly. Another commenter suggested consideration of the use of ozone- and ultra- violet based treatment rather than chlorine. Another commenter said that higher risks of malfunction and pollution that come with decentralization are insufficient to reject an additional WWTP in this case because of the impairment in the southern Lake. (F. Gougakis in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter; L. Leopold in 8111103 letter) Response: See Response to Comment 51 above. We disagree with the comment that the higher risks of malfunction and pollution that come with decentralization are worth incurring because of the impairment in the southern Lake. The additional amount of phosphorus to be discharged in the southern Lake is in itself very small and is less than one-fourth lbs/day initially and less than three -fourths lbs/day in 20 years. Even with the added Town of Lansing flows, the total amount of phosphorus discharged to the Lake will decrease in the range of 20 to 31 pounds per day on an annual average basis. 53. Comment: The EIS should mention the post 9-11 recognition that centralization increases vulnerability. The EIS should acknowledge that the alternative of relying on efficient, smaller -scale distributed infrastructure would promote the maintenance of greater region -wide functionality during times of natural or man -induced calamity. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Vulnerability is certainly a concern today and it is true centralization can increase vulnerability. However, concerns about infrastructure vulnerability are not always cured by relying on decentralized infrastructure. A new smaller plant could be more vulnerable under some scenarios since small plants are not staffed as often as larger plants. 54. Comment: The EIS should examine an upgrade to the Town of Lansing's facility and a discharge into the Lake at that point. (J. Dennis at 7131103 Public Hearing) Response: The Town of Lansing does not currently have a wastewater treatment facility. 55. Comment: The EIS should better explore the alternative of expanding the VCHWTP. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: The alternative of expanding the VCHWTP to treat 2.9 mgd (currently permitted at 2.0 mgd) was evaluated in the Town of Lansing Wastewater Facilities Plan prepared in October 1998. That report concluded that expanding the VCHWTP to treat projected flows from the Town of Lansing would cost approximately $3,600,000 more than the alternative to divert equivalent flows to the IAWWTP, where capacity already exists. 56. Comment: The total proposed diversion to IAWWTP is only 1.3 million gallons per day. For a fraction of the $11.2 million capital cost, each of the Lansing on -site septic systems and SPDES permitted discharges referred to in the DEIS could be equipped with state-of-the-art on -site phosphorus removal systems without constructing a 26-mile long wastewater collection system. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: This comment does not take into account the fact that hundreds of septic systems are located in areas that are not well suited for subsurface discharge because of steep slopes, shallow depth to bedrock, shallow groundwater tables, and seasonal flooding. No amount of retrofitting would address the fact that these systems fail at a high rate. As for existing package plants with surface discharges, the Town of Lansing's 1998 Facilities Plan evaluated small satellite treatment plants as an alternative to regional treatment. However, this alternative was more expensive than the selected alternative to treat flow from the Town of Lansing at the VCHWTP. 57. Comment: A study should be conducted to see if the discharge pipes for the IAWWTP, VCHWTP and the Lake Source Cooling facility could be merged and moved to discharge the combined effluent into deeper waters below the photic zone far from existing drinking water intakes. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The need for such a study has not been demonstrated, and in any event, falls outside the scope of this EIS. Currently there are no water quality issues affecting drinking water. As for issues affecting the Lake, as stated in Response to Comment 12, DEC does not believe that currently there is sufficient information to develop a more stringent limit on phosphorus through the TMDL process. As stated in Response to Comment 14, if further reductions in phosphorus are required in the future, a modification to the WWTPs' permits may be required. If this occurs, the owners of the IAWWTP and VCHWTP will consider alternatives, including extending their outfalls into deeper water. 29 58. Comment: Studies should be conducted to assess the technical feasibility as well as the costs and benefits of managing the project's wastewater without any discharges to Cayuga Lake (discharge into a nearby receiving water body; spray irrigation). (W. Hang in 816103 letter) Response: Section 6.7.7 of the 1983 Wastewater Facilities Plan completed for the Town of Lansing evaluated the use of small diameter sewers with land application of raw sewage. The evaluation concluded that land spreading is cost -prohibitive, a conclusion that is still valid today. The conclusion reached is published in its entirety: "This alternative considers the areawide collection of sewage by small diameter sewers. The sewage would be transported to a suitable location and then applied to the land. As pointed out earlier, the most suitable location of central collection is at Portland Point. Three potential landsites are considered for the application of raw sewage. These are illustrated in Appendix 6-4. A number of evaluations must be made in considering the application of sewage to land. These are: (1) health considerations to adjoining residential community (2) groundwater pollution (3) soil pollution, (4) air pollution (5) future use of land and many other considerations since the temperature in the Study Area is very low during winter season. The sewage would have to be stored during winter season before it is applied in summer/spring to the land. An economic evaluation of the alternative is made before giving consideration to various health and environmental concerns. The total estimated project cost using this alternative is $15,224,100. The, annual cost of Operation and Maintenance is $43, 000. Since this alternative is more costly than the majority of other alternatives, no further consideration is given to this alternative. " Discharges into a nearby receiving water body are not a realistic alternative, either. Discharges from a Town of Lansing plant to receiving waters such as Salmon Creek or Gulf Creek (both of which are tributaries to Cayuga Lake) are not considered feasible by DEC, given the low base flows in the Creeks during the summers. PROJECT SCHEDULE 59. Comment: Section 2.7 says survey and stakeout of sewer line alignments will occur one week ahead of the construction schedule. This short timeframe will likely not be sufficient to deal with any problems that may arise. One commenter asked the time between survey/stakeout and construction be lengthened to two to four weeks to provide the ability to make rerouting decisions that may be necessary due to site conditions. Another commenter asked the time be lengthened to at least four weeks, for the same reason. (J Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) 30 Response: The survey and stakeout referred to in Section 2.7, which will be conducted one week ahead of the construction schedule, is to provide control points for the contractor's use. A detailed design survey is conducted to determine the final alignment of the proposed sewer. The design survey is used to make routing decisions due to site conditions. 60. Comment: The EIS should discuss how analysis, planning and engineering for the 26 proposed stream crossings will be conducted before construction starts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: There are no DEC protected streams to be crossed by the construction of sewer mains in the Town of Lansing Service Area. Certain practices and controls to minimize stream disturbance will still be incorporated in the contract documents and depending on the characteristics of a particular stream may include all of the following: 1. Directional boring beneath the stream or trenching with appropriately constructed coffer dams. 2. Discharges from trench dewatering activities will pass through a sedimentation control practice. 3. Not allowing equipment in flowing streams. 4. Restoring the stream bottom cross-section and profile. 5. Replacing significant trees removed within 50 feet of a stream bank. DRYDEN PLANNING AREA 61. Comment: The Dryden Planning Area in the DEIS is significantly larger than those areas identified for expanding sewer service and accommodating future density in the Town of Dryden 's Draft Comprehensive Plan. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The Dryden Planning Area is a 20-year projection of areas where public sewers might go, whereas the Comprehensive Plan is expected to be updated every 5 to 10 years. The EIS's study of environmental effects within the Planning Area will be used to help inform decisions in the future on where sewer districts might be formed. 62. Comment. The commenter understands that the location of the sewer lines in the Dryden Planning Area is still in the conceptual stages and the DEIS does not discuss the environmental impacts in this area. Additional environmental reviews will need to address the full range of impacts in the Dryden Planning Area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment received and noted. 31 MAPPING ISSUES 63. Comment: The DEIS relied on Soil Association mapping for an assessment of soil conditions in the study area. Tompkins County has a digital version of the more detailed soil series map for Tompkins County, which may be obtained from the Tompkins County Information Technology Services Division. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: At the time of preparation of those portions of the DEIS which utilized soils mapping, the more detailed soil series mapping was not available. The association level mapping used in the DEIS is sufficient to identify the potential for construction impacts such as high groundwater tables or erosion, as well as for use in the growth inducement analysis. Given that the DEIS identified the potential for impacts related to soil conditions and recommended appropriate mitigation measures, no further analysis is required. 64. Comment. The VCHWTP and IA WWTP locations and existing pipe connections should be included for reference on at least Figure 4. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: A revised Figure 4 is included in this FEIS in Section III. 65. Comment: The EIS should include a figure showing the location and depth of the existing WWTP discharge points as well as the depth of the Lake throughout the southern end. (D. Kiefer in 8111103 letter) Response: The location and depth of existing WWTP discharge points are not germane to the discussion of impacts from the proposed sewer construction project. The project does not involve any modifications or changes to these discharges. 66. Comment. In Figure 19, Uniaue Natural Areas. the pink color for UNA 102 (Renwick Slope) is on the map, but the number 102 is not printed on the map. The same is true for Figure 33, where the color for the Newman Tract appears, but not its title on the map. (L. Leopold in 8111103 letter) Response: Revised Figures 19 and 33 are included in this FEIS in Section III. The Newman Tract is not located within the area shown on Figure 33. 67. Comment: The DEIS states at page 30 that all water bodies are Class C in the DEIS Study Area. Actually, many are classified as "D " and `'A " as shown on Figures Ma and 32 14b. The Figures have a column labeled "Protected Status Code" so only C(T) and higher streams are listed. The column should be labeled "Standards Class" and show all classes. This point is only for clarification, as the Stormwater Permit will protect the "D" streams and unclassified watercourses. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. Revised Figures 14a and 14b are included in this FEIS in Section III. GENERAL 68. Comment: Section XII of the Executive Summary, pages xxviii and xxix, which contains the list of involved agencies and their authority for the project, should state the DEC will also be responsible for review and approval of plans for the new construction, given the scope of the project, that most construction is in a new service area, and that State funds are involved. The TCHD will assist in review and approval if DEC so desires, as the TCHD does for most collector sewers. (J Andersson, Tompkins County Health Department in 6125103 letter) Response: The DEC will be responsible for review and approval of plans and specifications (contract documents) for new construction of sewers and pump stations for the project. The TCHD will assist in the approval, if the DEC so desires. 69. Comment: Please clarify the statement in the DEIS in Section 2.2.2, Town ofLansiniz Service Area Proposed Improvements, that "the Village of Lansing s existing 15-inch railroad interceptor sewer intersects the railroad grade below Twin Glens Road and terminates at the existing VCHWTP. " At present, there is no Village of Lansing sewer interceptor below Twin Glens Road, unless the reference means `farther south " along the railroad bed, instead of downhill, i.e., west, of Twin Glens Road. (L. Leopold in 8111103 letter) Response: The Village of Lansing 15-inch interceptor sewer is located on the former Ithaca -Auburn railroad bed south of Twin Glens Road and immediately west of Cedar Lane. 70. Comment: The commenter was pleased to see there are plans to investigate the possibility of using the former railroad right-of-way as a recreation trail in conjunction with this project. This is an excellent opportunity to create trails that link the Lansing community and the larger community. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment received and noted. 33 71. Comment: The commenter asked what would happen to an elevated septic system that is built on the old railroad bed. Would the sponsors dig under that or remove it and put it back after construction? (J. Dennis at 7131103 Public Hearing) Response: Directional boring beneath the septic system is possible. Conventional trenching is also possible with necessary repairs made in the distribution/collection laterals, filter media and subsoil. Alternatively, the building sewer could be connected to the sewer main and the septic system ultimately abandoned. 72. Comment: One commenter said DEC's job is to protect the environment, not pay attention to how many homes are available. Another commenter said representatives of real estate agencies attended meetings on the project, and this commenter expressed concern that development expansion could end up playing a large role in the project. (R. DePaolo at 7131103 Public Hearing, F. Gougakis in 8111103 letter) Response: Comment noted. Section 6 of the DEIS contains an extensive assessment of potential growth induced as a result of the project. The affected municipalities now have the opportunity to review their planning policies with respect to such potential growth. Other sections of the DEIS deal with other environmental impacts and mitigation, and the involved agencies and municipalities likewise will consider this information as they make their decisions. 73. Comment: This commenter expressed concern over impacts to sensitive/unique natural areas, unavoidable habitat loss, erosion, noise issues, odors, and pump station impacts that are raised in the DEIS. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: Comment noted. Each of these potential impacts is adequately addressed in the EIS. Absent a specific comment or concern, no further response is possible. 74. Comment: Local government officials should have held a public information forum on this project, preferably at night in the City of Ithaca. They made no effort to make sure the public understands this massive project. The EIS process should not continue until such a forum is held. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: Comment noted, and the municipalities have the opportunity to take this comment into consideration for future projects. The official SEQRA public hearing and the informal public information session run by DEC were agreed to between DEC and the 34 involved municipalities. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. 75. Comment: One commenter requests an extension of the comment period into September 2003 or well into the Fall of 2003. Another commenter requests an extension of the comment period into the Fall of 2003. (J. Dennis at 7131103 Public Hearing; F. Gougakis at 7131103 Public Hearing) Response: The length of the public comment period meets (and exceeded) the requirements of SEQRA. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. COMMENTS IN SUPPORT OF PROJECT The following comments were received and noted. 76. Comment. The commenter states that overall, it is supportive of the project. The project will eliminate nonpoint source pollution currently caused by inadequate on -site sewage disposal systems in the project area. This will help maintain the public health and welfare of Tompkins County residents and those who use Cayuga Lake as a drinking water and recreational resource. This reduction, combined with an increase in the overall level of treatment for wastewater generated in the Cayuga Lake watershed, will help protect the economic vitality and well-being of Tompkins County. (E. Marx, Tompkins County Planning Department in 8111103 letter) 77. Comment: The commenter looks forward to the FEIS and the development of engineering plans and specifications to solve the identified problems in the service area. (J. Andersson, Tompkins County Health Department in 6125103 letter) 78. Comment: The commenter supports the project, which will eliminate ground and su7jace water pollution caused by inadequate on -site sewage disposal systems and will provide a higher level of sewage treatment than presently available within the service area. The project will better utilize existing treatment capacity and infrastructure, and phosphorus treatment will be added in both WWTPs, which will help improve Cayuga Lake's water quality. Members of the Tompkins County Chamber of Commerce and of Tompkins County Area Development funded facilitation of the project because the project is critically important to protect the Lake and it will allow for development in areas designated by each of the municipalities. Those funding the facilitation did not propose any particular solution but rather provided facilitation so the participants could come to V � 1 a solution beneficial to all. The project's positive impacts far outweigh any potential adverse impacts. (J. McPheeters, Tompkins County Chamber of Conznzerce at 7131103 Public Hearing and in written copy of public comment received by DEC on 7131103) 79. Comment: The DEIS is well -written and thoroughly reviews the project's impacts. The project will improve the quality of Cayuga Lake by taking septic systems off-line and treating waste. The south end of the Lake is responsible for a majority of septic systems on the Lake. Over the past 8110 years, the commenter's house and septic system on Ladoga Point Road have flooded S times, which created additional discharge into the Lake and prevented occupancy of the house. The project will not necessarily create more growth, as the municipalities will control growth. (R. Cutting at 7131103 Public Hearing and in 816103 letter) 80. Comment. The project will provide an opportunity for expanded sewer service in the watershed and a higher level of treatment than what is provided by septic systems and package plants. The growth inducing impacts are relatively minor. The project will provide for better environmental protection for Cayuga Lake. (M. May in 811103 letter) 81. Comment: The project sensibly deals with the current inadequacies of the VCHWTP by utilizing the available capacity of the IAWWTP. The project will allow some growth in areas where sewers are present but sewer permits are not available due to VCHWTP limitations. The project will also make possible additional growth of homes and businesses without needing large areas of land to accommodate new septic systems. Some homes currently located on the lake shore have questionable septic systems, and no authority checks them on a regular basis. A controlled municipal system which could be upgraded in the future would insure that the waste from these homes is treated properly and meets established guidelines. (E. Quaroni in 811103 letter) 82. Comment: The project is a sound plan and a good solution to a very difficult infrastructure problem. A study initiated by the Tompkins County Planning Department and the Planning Advisory Board in 1994 concluded that limited water and sewer facilities, particularly in the northeast urbanized region, were a limiting factor to economic development. An Economic Development Strategy completed by Tompkins County Area Development (TCAD) in 1999 emphasized the importance of improved water and sewer service to attain the goal of building the economic foundations of Tompkins County. The Strategy noted that issues of concern related to the expansion of sewer services (generally related to the potential for development in suburban areas as opposed to the urban core) are balanced by the following counterpoints: extended sewer service improves environmental quality in already developed areas that use on -site 36 disposal systems; sewer service allows small -lot and high -density development that lowers the developed area on a per capita basis; and the dynamics of development fluctuate among urban centers, suburban rings and rural areas. One of the top 10 action steps (out of 58) identified by the Strategy was an integrated system of water and sewer services for the urbanized and growing areas of the County to improve supply, efficiency of delivery and environmental quality. This is the reason TCAD helped fund facilitation activities to bring the project to this stage. (B. Blanchard, Tompkins County Area Development at 7131103 Public Hearing and in, written copy of public comment received by DEC on 7131103) 83. Comment. The proposed regional solution offers by far the best solution to meet the immediate and long term wastewater collection, transmission and treatment needs of the proposed service area. Upland pollution will be eliminated in areas not currently sewered. The entire region will benefit from the substantial improvement in the water quality in the Southern Cayuga Lake Basin. The project is consistent with land use policies already in place in all six municipalities. In addition, the owners of the IAWWTP have voluntarily agreed to more stringent permit levels for the discharge of phosphorus, and phosphorus removal and other improvements at the VCHWTP will also take place. Sufficient spare capacity will be available well beyond the 20 year planning period, especially with continuation of an aggressive program to eliminate inflow and infiltration. The Town and Village of Lansing service areas can be sewered without the need to construct additional treatment capacity, resulting in substantial savings to all users. Improvements to the water quality in the southern basin of the Lake will require more than the commitment of those responsible for the operation of the WWTPs. Stream erosion and agricultural runoff are being addressed in the Town of Caroline, and the Tompkins County Water Resources Council, the Cayuga Lake Watershed Network and Intermunicipal Organization are actively pursuing and coordinating monitoring efforts throughout the region. (N. Desch in 819103 letter) 84. Comment: The DEIS is adequate. Village of Lansing history shows growth in malls, subdivisions and offices will occur with or without sewers. Adequate sewage facilities will only benefit Cayuga Lake. The project is a good use of resources and a cost effective plan. Self-government is preserved, with each municipality defining costs, growth and location offuture sewers. The need for this project started in 1987 with a temporary moratorium by the VCHWTP. There has been much effort and discussion since then, and there is no need for further study. (J. Majeroni, Cornell University, Real Estate at 7131103 Public Hearing) 85. Comment. The project should go forward. Home prices are very high because of low inventory. New construction resulting from the project would lead to more moderate prices. In the 23 years this commenter has been in the real estate business, this commenter has never seen a problem with public sewer systems but has seen many 37 problems with septic systems come up at real estate closings. The added cost of a septic system is about $10, 000. This adds a lot to the price of a home. Public sewers would make it better for everyone. (A. Edelman, Audrey Edelman & Associates Real Estate at 7131103 Public Hearing) 86. Comment: This commenter stated he echoes Ms. Edleman's comments about the need for housing. This commenter built a house on Horizon Drive and extended the municipal sewer pipe to his home because he was close enough to do so. One of his neighbors paid $10, 000 for a septic system. Neighbors have had problems with septic systems, including septic systems backing up and flooding their basements. There are current proposals for. two subdivisions with more than 180 houses in Lansing. There is a need for housing, and more sewage will be created. With the amount of local vacant land, there could be more than 1, 000 homes built with septic systems, with untreated waste just injected into the ground. There is a need to move forward with public sewers and treat the sewage. (G. Sloan at 7131103 Public Hearing) III. TABLES AND FIGURES 39 IV. WRITTEN COMMENTS RECEIVED ON THE DEIS m :h V. DISTRIBUTION LIST 41 Stearns & Wheler, LLC Environmental Engineers and Scientists TABLE F-1 WWTP TOTAL PHOSPHORUS (TP) LOADING DISCHARGED TO SOUTH END OF CAYUGA LAKE IAWWTP EFFLUENT TP (LBS/DAY) VCHWTP EFFLUENT TP (LBS/DAY) COMBINED WWTP W/ LANSING (T) EFFLUENT TP (LBS/DAY) ACTUAL ACTUAL ACTUAL FROM TOTAL REDUCTION PERCENT YEAR PERMITTED (q ANNUAL FUTURE (3) PERMIT (4) PERMITTED ANNUAL FUTURE (6) PERMIT (7) PERMITTED ANNUAL FUTURE (9) LANSING (T) COMBINED TP IN TP LOAD (12) REDUCTION IN (13) AVERAGE(Z) AVERAGE(5) AVERAGE($) PERMIT (10) LOADING(11) TO LAKE TP TO LAKE 1999 83.4 27 9.3 16.7 6.5 2.6 100.1 33.5 I 11.9 I 0.24 12.14 I 21.36 64 2000 83.4 32 11.6 16.7 10.7 3.1 I 100.1 42.7 I 14.7 0.24 I 14.94 27.76 I 65 2001 65.3 33 10.2 16.7 11.8 I 3.1 82.0 44.8 I 13.3 I 0.24 13.54 I 31.26 70 2002 40.0 26 10.8 16.7 8.1 I 2.6 56.7 34.1 I 13.4 0.24 13.64 I 20.46 60 2003* 40.0 23 11.6 16.7 11.9 3.2 56.7 34.9 14.8 0.24 I 15.04 19.86 I 57 * Through August 2003. 1, 4, & 7. Allowable phosphorus loading under SPDES permit in effect during each year. 2, 5, & 8. Actual phosphorus loading based on effluent sampling at each plant. 3, 6, & 9. Amount of phosphorus loading that would have been discharged if future permit conditions of 0.2 mg/L for phosphorus were in effect. 10. Amount of phosphorus loading as a result of collecting sewage in the Town of Lansing and treating it to a 0.2 mg/L effluent total phosphorus concentration at the VCHWTP. 11. Sum of columns 9 and 10, which represents the total phosphorus loading to the Lake from the region (including the Town of Lansing) proposed to be served by the IAWWTP and VCHWTP under future permit conditions of 0.2 mg/L effluent phosphorus concentrations. 12. Column 8 minus column 11, which represents the reduction in phosphorus loads to the Lake, if all the flow is treated to a 0.2 mg/L effluent total phosphorus concentration. 13. Column 12 divided by column 8 and expressed as a percentage. Represents the overall actual reduction in phosphorus loading to Cayuga Lake (approximately 65%). N, &6 Stearns & Wheler r Companies ekvJ� r-c- ts Final Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Project Location: City of Ithaca, Village of Cayuga Heights, Town of Dryden, and Town and Village of Lansing, Tompkins County, New York Lead Agency: NYS Department of Environmental Conservation Region 7 — Cortland Office 1285 Fisher Avenue Cortland, New York 13045-1090 Contact: John Merriman (607) 753-3095 Project Sponsors: City of Ithaca Town of Ithaca Town of Dryden Town of Lansing Village of Lansing Village of Cayuga Heights Contact: Susan Brock, Esq. (607) 277-3995 EIS Prepared By: The Chazen Companies North Country Office 110 Glen Street Glens Falls, New York 12801 Contact: Stuart F. Mesinger, AICP (518) 812-0513 DEIS Accepted: June 20, 2003 DEIS Comments Due: August 11, 2003 DEIS Public Hearing: July 31, 2003 FEIS Accepted: XXX 1 A� EIS Preparers: The Chazen Companies 110 Glen Street Glen Falls, NY 12804 Environmental Consultant Contact: Stuart F. Mesinger, AICP (518) 812-0513 Stearns & Wheler, LLC One Remington Park Drive Cazenovia, New York 13035 Engineering Consultant Contact: Mr. Gerry Hook, P.E. (315) 655-8161 Greenhouse Consultants 40 Exchange Place, 13th Floor New York, NY 10005 Cultural Resources Investigation Contact: Barry Greenhouse/Will Roberts (212) 514-9520 Ithaca -Tompkins County Transportation Council 121 East Court Street Ithaca, NY 14850 Transportation Studies Contact: Fernando de Aragon, P.E. (607) 274-5570 Creighton Manning Engineering, LLP 4 Automation Lane Albany, New York 12205 Transportation Studies Contact: Chuck Manning, P.E. (518) 446-0397 74 TABLE OF CONTENTS [To be provided.] LIST OF TABLES AND FIGURES [To be provided.] 1' GLOSSARY BTT — Best Treatment Technology CFR — Code of Federal Regulations DEC — New York State Department of Environmental Conservation DEIS — Draft Environmental Impact Statement EIS — Environmental Impact Statement FEIS — Final Environmental Impact Statement gpd — Gallons Per Day IAWWTP — Ithaca Area Wastewater Treatment Plant mgd— Million Gallons Per Day NYCRR — New York Code, Rules & Regulations SEQRA — State Environmental Quality Review Act SPDES — State Pollutant Elimination Discharge System TCHD — Tompkins County Health Department TMDL — Total Maximum Daily Load TOGS — Technical and Operation Guidance Series UNA — Unique Natural Area VCHWTP — Village of Cayuga Heights Wastewater Treatment Plant WWFP — Wastewater Facilities Plan WWTP — Wastewater Treatment Plant 2 tk INTRODUCTION This document is a Final Environmental Impact Statement (FEIS) for the proposed Ithaca Area Municipal Wastewater Collection Improvement Project (the project). This document, together with the Draft Environmental Impact Statement (herein incorporated by reference, previously distributed for public comment), form the Environmental Impact Statement (EIS) for the project. The EIS has been prepared in accordance with the requirements of the New York State Environmental Quality Review Act (SEQRA) and implementing regulations at 6 NYCRR Part 617. The EIS presents an evaluation of the potentially significant adverse impacts of constructing new public sewer lines in the Town of Lansing and a sewer transmission main in the Town of Lansing and the Villages of Lansing and Cayuga Heights. The Draft Environmental Impact Statement (DEIS) also evaluates the impacts of potential sewer lines in the Town of Lansing. Finally, the DEIS evaluates the potential impacts of growth induced in the Towns of Lansing and Dryden and the Village of Lansing as a result of the proposed project, as well as from sewers that may be constructed at some time in the future. The reader is referred to the DEIS document for a complete description of the project and its associated impacts and proposed mitigation measures, as well as a discussion of alternatives to the project. The DEIS is hereby amended by the information contained in the FEIS. EIS Process The New York State Department of Environmental Conservation (DEC) accepted the DEIS on June 20, 2003 and made it available for public comment. DEC held a public hearing on the DEIS on July 31, 2003. The DEC accepted comments on the DEIS until August 11, 2003. This FEIS was accepted by DEC on DEC to insert date. Organization of the FEIS This FEIS is organized as follows. Comments on the FEIS have been organized into topic areas. The Lead Agency's response to each substantive comment is provided after the comment. Comments that are substantively similar have been combined and a single response is given to such comments. Oral comments made at the public hearing are also summarized here. References are made after each comment as to who made the comment and how it was received. Copies of written comments are reproduced in Section insert section number. The oral comments made at the July 31, 2003 public hearing were recorded on an audio tape, and that tape is available to the public at the DEC office listed on the cover sheet. Summary of Additional Information in FEIS 5 t, This FEIS contains additional information on several subjects, including the following. 1. Several commenters raised the issue of DEIS completeness and suggested that it was not complete and did not adequately address all issues, specifically those related to phosphorous discharges at the Ithaca Area Wastewater Treatment Plant (IAWWTP) and Cayuga Lake water quality. It is the Lead Agency's position that these issues are completely independent of this project and have already been addressed through a separate SEQRA review of the IAWWTP SPDES permit. Nevertheless, this FEIS contains data demonstrating that with planned phosphorous upgrades to the IAWWTP and Village of Cayuga Heights Wastewater Treatment Plant, there will be a net reduction in phosphorous discharge, even with the addition of the Town of Lansing flows. 2. Several commenters questioned the need for the project, specifically whether failing in -ground sanitary waste disposal systems had been adequately documented. This FEIS contains additional data and information documenting need for the project. 3. One commenter raised the issue of segmentation, specifically whether the SEQRA review of this project and the IAWWTP SPDES permit had been segmented. It is the Lead Agency's position that segmentation has not occurred. The impacts of a 13.1 mgd flow, including flow from the Lansing Service Area, were properly considered during the SEQRA review of the IAWWTP's permit modification. 4. This FEIS includes additional information about the level of detail that will be included in construction plans, including plans for crossing streams and Unique Natural Areas, and how routes will be evaluated during the construction plan development process. 5. This FEIS includes an evaluation of the use of the Norfolk Southern Railroad right-of-way for the sewer trunk line. The evaluation concludes that this right-of- way is not feasible because of construction issues. 6. This FEIS contains additional information about why a separate wastewater treatment plant for the Town of Lansing is not a preferred alternative. on RESPONSES TO PUBLIC COMMENTS COMPLETENESS 1. Comment: The New York State Department of Environmental Conservation (DEC) should reject the Draft Environmental Impact Statement (DEIS) as incomplete. The DEIS should contain a full range of water quality data for southern Cayuga Lake, including the effects of individual septic systems in the Lansing area, historical and projected effluent analyses for the Ithaca Area Wastewater Treatment Plant (IAWWTP) and the Village of Cayuga Heights Wastewater Treatment Plant (VCHWTP), an IAWWTP SPDESpermit analysis including the effects ofprojected flow increases and tertiary phosphorus treatment, and a complete analysis of the current regulatory backdrop against which the project is proposed, including Total Maximum Daily Load (TMDL) development. (R. DePaolo in 8111103 letter) Response: For determinations of completion, SEQRA requires that the DEIS be adequate with respect to its scope and content for the purpose of commencing public review. This standard was met, as the DEIS contains the information required by the scoping document. To the extent this comment requests additional information relevant to the project, such information is provided in response to specific comments below. Much of the information the commenter requests, however, is outside the scope of this project. During the scoping process, this commenter raised a number of water quality and SPDES permit issues related to IAWWTP discharges. As the Scoping Responsiveness Summary explained, such issues are completely independent of this project and have been addressed through a separate and independent process for the IAWWTP permit. The Final Scoping Document does not include such issues. Several other commenters have nonetheless asked for similar information, especially about IAWWTP SPDES permit issues and phosphorus discharges from the two WWTPs. Some of the comments contain inaccurate assertions about these topics that are repeated by more than one commenter. To correct these inaccuracies, this FEIS provides information on the IAWWTP SPDES permit and WWTP phosphorus discharges, even though such information is relevant to SPDES permit issues and not this project. 2. Comment: The DEIS needs major supplementation; missing information and analysis should be provided, and the DEIS re -issued for comment. The DEIS is not ready to be moved to the Final Environmental Impact Statement (FEIS) stage. (D. Kiefer in 8111103 letter) Response: See Response to Comment 1. 7 3. Comment: The DEIS appears to be very complete. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. DOCUMENTATION OF NEED FOR THE PROJECT 4. Comment: There is no or insufficient data to support the assertions in the DEIS that water quality impacts are occurring as a result of inadequate on -site sewage disposal systems. There is no water quality data to support the need for an $11 million expenditure ($7 million funded locally) and 26 miles ofpipe that will result in discharges into the impaired southern part of Cayuga Lake. Any pollution reductions in the project area are likely to be far outweighed by increased water quality problems in southern Cayuga Lake. The EIS should contain water quality data on the effects of Lansing -area on -site systems on Cayuga Lake and performance characteristics for these systems. Data should include wastewater flow, pollution loading studies and a delineation of wastewater entering the Lake from the on -site systems. The EIS should also contain Cayuga Lake ambient water quality data for the proposed service area and for the IA WWTP- VCHWTP discharge area. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in undated written copy of public comment received by DEC on 816103) Response: [Dave Herrick to revise.] Flooded and failing septic systems have posed problems in the Lansing area for years. Septic systems in Ladoga Park are flooded by the Lake on a frequent basis. (See Comment 79.) [Any TCHD or other data on flooding frequency & numbers of houses/systems?] Flooded septic systems contribute raw sewage directly into the Lake. [Does Ladoga Park have public water or do the residents draw drinking water from the Lake?] The TCHD has expressed concerns about these systems. As part of the planning process for public sewers in the Lansing Study Area, John Andersson, Director of the Division of Environmental Health Services, said in a May 31, 1996 letter to the consulting engineers for the Town of Lansing that the Ladoga Park area has "severe limitations for on -site sewage systems due to flooding and inadequate separation distance to surface waters." Concerns are not limited to flooding conditions. During periods of heavy rain, poorly operating systems can contribute inadequately treated sewage into the Lake and its tributaries. Ladoga Park is located on the Lake next to Myers Park, which has a public swimming beach. The Town of Lansing Study Area has A number of creeks that drain into Cayuga Lake. (See DEIS Figure 14A.) Failing systems near Lake tributaries can contaminate the 21 tributaries and ultimately the Lake. Tompkins County Health Department records indicate that on the average 5 failed septic systems are replaced every year per 1,000 people in the Town of Lansing Sewer Study Area. This is a higher per capita replacement rate than the replacement rates in any of the towns in Tompkins County. Actual numbers of failed systems are likely higher, since homeowners often are unaware that their systems have failed until sewage backs -up into their residences or untreated sewage surfaces on the ground. As unsewered populations in the Lansing area increase, it is reasonable to presume that the number of failed systems per year will also increase. Problems with failing septic systems are not new. In 1983, the Town of Lansing mailed a questionnaire to all property owners in an area that is nearly identical to the EIS's Planning Area. [Dave —Do you mean the larger Planning Area, or the smaller Service Area?] Of 933 questionnaires mailed, approximately 34% were returned. Of those returned, 40% indicated some type of failure with the property's wastewater system. Also in 1983 [?], the TCHD surveyed 80 homes in the Asbury Road area on a house -to -house basis. The TCHD found 10 systems were in unsatisfactory condition and an additional 22 were expected to fail within five years. [Dave, a creek —Mill Creek? — runs behind homes on part of Asbury Rd. Do you know if the surveyed homes were along this creek? What is it tributary to? Another creek? The Lake?] John Andersson's May 1996 letter notes that "the soil in much of the planning area is marginal to poor for on -site sewage systems. Many homes and businesses rely on alternative sand filter/dispersion trench sewage systems which may affect ditches and streams especially if lots are not large enough to keep the dispersion trenches at least 50' from property lines (lots under 100' in the lesser dimension)." [Any info on the problem systems listed in the DEIS that we should spell out here? Any info on systems built on bedrock that likely drain into the Lake or a creek?] [Any DEC concerns backed up by data about package plants with SPDES permits?] In addition to the positive impacts on Cayuga Lake and its tributary streams in the Lansing area, the project will benefit public health. The ability to eliminate failed or inadequate on -site systems, flooded on -site systems, and individual package treatment plants will reduce the potential for groundwater and surface water contamination, which will reduce the risk to both public and private water supplies and to public health in general. The TCHD has documented drinking water contamination caused by failing septic systems in the Town of Lansing. In 1983 [?], a Health Department survey of 30 well water systems in the Ludlowville area of Lansing found 18 wells contaminated with sewage. [Any other data on well contamination?] The DEIS also spells out other project benefits that are not mentioned by the commenters. These benefits are listed in Section 1.2 of the DEIS and include the elimination of SPDES permit flow exceedances at the VCHWTP, promotion of infill in 9 the Town of Lansing rather than conversion of open space and agricultural lands, and the provision of additional public sewage capacity for the Town and Village of Lansing, which currently is extremely limited. The commenters are concerned about the impact of additional flow into the southernmost end of Cayuga Lake. Their additional comments (set forth in numbered comments below) focus on the amount of phosphorus that will be added to this part of the Lake. As stated in Response to Comment 1 above, this issue is not relevant to the project since both the IAWWTP and VCHWTP will maintain their discharges within permitted limits. However, to correct inaccurate statements made by some commenters about the amount of phosphorus this project will generate, phosphorus information is presented here and in response to specific comments below. It is anticipated initially that an average sewage flow of 144,000 gallons per day (gpd) will be collected annually from the Town of Lansing as a result of this project. It is estimated that this flow will increase to 441,000 gpd in 20 years. All of this sewage will be conveyed to public wastewater treatment plants where it will receive treatment to reduce the phosphorus content to below 0.2 mg/L once planned phosphorus upgrades are completed at the IAWWTP and VCHWTP. The amount of phosphorus this represents is less than one-fourth (1/4) of a pound per day initially, and lesshree-fourths (3/4) pound per day over 20 years. _ Table F-1 shows the impact that this small amount of flow will have on the phosphorus loading from the WWTPs to the south end of the Lake. Data presented is actual operating data for the IAWWTP and VCHWTP for the last four full years of record and the current year through August 2003. With the planned phosphorus upgrades, an overall reduction in the amount of phosphorus currently discharged from these plants to the south end of Cayuga Lake of approximately 65 percent will be achieved, even with the flows from the Town of Lansing. The five-year analysis shows that from 1999 through August of 2003, the historical combined annual average discharge of total phosphorus from the IAWWTP and VCHWTP has ranged from 33.5 to 44.8 pounds per day. Once the plants install tertiary phosphorus treatment, it is anticipated that their combined total phosphorus discharge will not exceed 11.9 to 14.8 pounds per day for flows in the historic five-year range shown in Table F-1. Addition of the initial flows from the proposed Lansing service area will add another 0.24 pounds per day. The initial percent reduction in phosphorus discharged to the Lake from the two WWTPs (including the initial flows from the Town of Lansing) is estimated to range from 57% to 70%. The projected numbers assume that the two WWTPs will discharge phosphorus at a concentration of 0.2 mg/L at all times (see below). This is the highest likely concentration and actual concentrations will probably be lower much of the time, which will result in even greater initial reductions in phosphorus to the Lake. Over the 20-year planning period, as flows increase from all six municipalities due to growth, the amount of phosphorus loading to the Lake at 0.2 mg/L is not expected to exceed 16.6 pounds per day. 10 L C 5. Comment: The EIS should include data on the number, frequency, location, timing, method and extent of septic system and small package plant failures in the project area, and on whether on -site waste treatment is adversely impacting Cayuga Lake, other waterways, or general public health. One commenter who asks for this information also recognizes that certain developed shoreline areas on both the east and west shores have septic systems that occasionally get flooded by the Lake and need to be dealt with. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter) Response: See Response to Comment 4 above. 6. Comment. To document need for the project and to compare impacts of any existing problems with project impacts, the EIS should contain more information about rates of discharge and frequency and amount of overflow/bypass from the two wastewater treatment plants (WWTPs). One commenter said the EIS should also address whether any of the overflow/bypass problems are being addressed outside this project. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter) Response. Section 2.1 and Tables 1 and 2 in the DEIS summarize the operating conditions of the two WWTPs. No overflows/bypasses have occurred, with the exception of one 2-hour diversion from the IAWWTP headworks in the 1990s during an extreme flooding event. Exceedances of the VCHWTP's permitted flow (all of which is treated) would be addressed by diverting excess flow to the IAWWTP, which has permitted reserve capacity. SOUTHERN CAYUGA LAKE CONDITION & IMPACTS WWTP LOADINGS 7. Comment: The EIS should include historical and projected performance analyses for both the IAWWTP and the VCHWTP, including a projected phosphorus loading analysis that takes into account planned tertiary phosphorus treatment at the IAWWTP and the increased flows from the project. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: Refer to Table F-1 and Response to Comment 4 above. JUSTIFICATION FOR PUTTING FLOW IN SOUTH END OF LAKE AND ANALYSIS OF IMPACTS 8. Comment: The EIS needs to justify why wastewater will be transported from a relatively deep part of Cayuga Lake to its shallow, impaired southern basin and compare 11 L the environmental pros and cons of doing so. Two commenters said the DEC's phosphorus guidance value of 20 micrograms per liter (indicating excessive eutrophication) is regularly exceeded on the Lake's shallow southern shelf. One commenter said the following as part of this comment: Cayuga Lake's southern S, 000 acres have turbidity and phosphorus levels that impair the Lake's best use. Public bathing is prohibited because of turbidity. High phosphorus levels cause vast algal blooms. These problems threaten drinking water drawn from the Lake. The southern part of the Lake receives phosphorus from IAWWTP and VCHWTP effluent, which is discharged into waters less than 12 feet deep, and phosphorus and turbidity discharged by Cayuga Inlet, Cascadilla Creek, and Fall Creek. Cayuga Lake in the proposed service area is deeper, receives far less pollution and does not suffer from widespread impairments. (R. DePaolo in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter; D. Kiefer in 8111103 letter) Response: See Response to Comment 4 above. The southern shelf does have more issues with phosphorus than the larger, deeper part of the Lake. However, the focus of this project must weigh the overall benefits achieved by providing a regionalized approach to wastewater treatment at larger facilities to the introduction of a new discharge point from a small facility serving only the Town.of Lansing. In DEC's experience, larger facilities tend to operate more efficiently and economically with fewer permit excursions. The opportunity posed to provide better treatment and address high flow problems at the VCHWTP is one mitigating factor. Also, the reduction in overall phosphorus loading to the Lake from point sources is a positive for the Lake. By receiving treatment at the VCHWTP, the wastewater from the Town of Lansing will be treated to remove nutrients to a degree that would not be the case if it were discharged to the deeper portion of the Lake. h amount of phosphorus entering the Lake from the Town of Lansing flows is far les tha 'the reduction in phosphorus that will be achieved , bl� with the planned phosphorus trea ment upgrades at the WWTPs. Thus the total loading of phosphorus to Cayuga Lake will be greatly reduced. See Response to Comment 27 below for more information on phosphorus loadings. 9. Comment. The DEIS lacks documentation of the critical state of the southern end of Cayuga Lake. The addition of more phosphorus to this shallow end will only increase the problems to the Lake. (F. Gougakis in 8111103 letter) Response: See Response to Comment 4 above. 10. COmment: The EIS should analyze the impact of reallocating wastewater to, and concentrating treated effluent in, point discharges to the southern, impaired end of 12 ti Cayuga Lake. One commenter said this analysis should include how additional loading might impact aquatic biota and algal and weed growth and influence levels of dissolved oxygen. Another commenter noted the Lake's 303(d) listing and said the EIS should discuss the extent to which the project would mitigate water quality problems at the southern end of the Lake. Another commenter said the DEIS does not make a convincing case that implementation of this project will improve water quality problems in the southern end of the Lake. Absent documentation of what the project will mean in the way of addition of nutrients and chemicals to the impaired waters of southern Cayuga Lake, it is impossible to conclude that the project is the best one can do. (D. Kiefer in 8111103 letter; E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Table F-1 and Response to Comment 4 above. 11. Comment: The EIS should acknowledge and discuss the possible biological impacts of the increased WWTP effluent in the impaired waters of the Lake, especially with respect to its reactive -chlorine content and the further concentration of human -excreted drugs. Science is just learning about how, for example, hormones in sewage effluent affect reproduction and the sex of aquatic organisms. As yet, there are no known ways for WWTPs to handle this. This is another reason not to combine/increase effluent streams. (D. Kiefer in 8111103 letter) Response: This comment is not relevant to the project because the WWTPs will be operating within their permitted limits. Impacts of increased amounts of flows were considered when the plants' respective SPDES permits underwent environmental review. That said, the amount of chlorine residual entering the southern part of the Lake will not change significantly from current conditions. The IAWWTP dechlorinates its effluent prior to discharge into the Lake, and its SPDES permit limits total residual chlorine to 0.1 mg/L, which is equivalent to one -tenth of a part per million. The VCHWTP does not dechlorinate its effluent, but the flow treated at that plant will not increase. WWTPs currently do not have special treatment for human -excreted drugs. The increase in flow attributed to the Town of Lansing,(annual average of 0.144 mgd initially and 0.441 gpd in 20 years) is a relatively minor fraction of the average combined flows to the two WWTPs (9.19 mgd initially; 9.49 mgd in 20 years.) The Town of Lansing flows will make up only 1.6% of the annual average flows to the two plants initially and 4.6% after 20 years. The concern raised over concentration of human -excreted drugs in the southern Lake is not signifcantlffectedl�y the relatively low levels of flow projected � from the Town of Lansing. aft-_� LEGALITY OF INCREASED FLOW 13 "I 12. Comment. Southern Cayuga Lake violates New York State's narrative water quality standard for phosphorus. Algal blooms and rotting and floating weeds cause aesthetic impairments and odors and hinder navigation. Additional phosphorus must not be allowed into the Lake's impaired area from new or expanded point sources. Any increased flow through the IAWWTP into the impaired part of Cayuga Lake on the 303(d) list would constitute a "new or expanded discharge" as prohibited by 40 CFR § 122.4(i). (R. DePaolo in 8111103 letter) Response: The listing of Cayuga Lake on New York State's 303(d) list requires that a TMDL be developed that would identify the point and nonpoint source reductions of phosphorus necessary to restore the designated use. DEC does not believe that there is sufficient information to develop a TMDL at this time. Since the WWTPs will be operating within the limits set by their respective SPDES permits, flows from the project are not considered flows from a "new source or a new discharger," as those terms are defined in the regulations. (Note that this is the regulatory standard, not "new or expanded discharge" as the commenter states.) In addition, the increased flows through the IAWWTP will come from the current VCHWTP service area. These are flows that are currently discharged into the south end of the Lake through the VCHWTP outfall. This diversion will free up capacity at the VCHWTP for new Town of Lansing flows. The total loadings of phosphorus from the WWTPs are expected to be far less after the proposed project and phosphorus upgrades are completed than current conditions. See Responses to Comments 4 above and 27 below for more information on phosphorus loadings. 13. Comment. Wastewater collected in the proposed service area was originally intended to be treated by a new facility requiring a discharge permit. Such a permit would have been prohibited by the federal moratorium in 40 CFR § 122.4(i), which prohibits the issuance of discharge permits to "a new source or a new discharger, if the discharge from its construction or operation will cause or contribute to violation of water quality standards." Conveying the wastewater to the permitted IAWWTP by-passes this critical non -degradation standard. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: See Response to Comment 12 above. EFFECTS OF 303(d) LISTING AND TMDL PROCESS 14. Comment. Despite the fact the southern 5, 000 acres of Cayuga Lake is on the federal 303(d) list and is designated as high priority for TMDL development, DEC has not investigated the problems nor taken action to eliminate them. The EIS should analyze the current regulatory backdrop against which the project is proposed, including proposed 14 TMDL development. DEC should analyze project impacts in connection with a TMDL study and should define the regulatory backstop that guarantees the project will not contribute to existing water quality standards violations in southern Cayuga Lake. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: As noted in Response to Comment 12, the WWTPs will be operating within their permitted limits and total point source loading to the Lake will be significantly reduced. Regarding the TMDL process, the DEC has agreed to perform an evaluation of the phosphorus loadings to the southern shelf of the lake. The EIS does not supplant the DEC's regulatory responsibilities, nor should it be delayed pending DEC's evaluation. If as a result of the TMDL process further reductions in phosphorus point source loadings are required, DEC will require such reductions through all necessary means, including WWTP SPDES permit modifications if required. 15. Comment: DEC has made no tangible progress to institute a TMDL pollution control program, even though southern Cayuga Lake is a high priority for such a program. One commenter said DEC rejected the Environmental Protection Agency's offer in 2001 to help fund a water quality study and DEC has not developed or adopted any TMDLs since Cayuga Lake was listed on the 303(d) list in 2002. The project should be approved only after the TMDL is implemented or other regulatory safeguards are imposed to assure no further degradation of water quality. Another commenter said a TMDL should be in place before this project or any new wastewater treatment plant is constructed. (W. Hang at 7131103 Public Hearing and in 816103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 14 above. 16. Comment: The southern end of the Lake is on the national 303(d) listing and is a priority for TMDL development. DEC should be extremely careful about adding any discharges to this area. (D. Kiefer in 8111103 letter) Response: See Response to Comment 14 above. DEC ACTIONS REGARDING OTHER PROJECTS AFFECTING CAYUGA LAKE 17. Comment. DEC has failed to enforce the federal moratorium provision by granting a discharge permit to the Lake Source Cooling Project. One commenter said Lake Source Cooling contributes nearly 10% of the phosphorus entering southern Cayuga Lake. Another commenter said despite a recommendation by a Town of Ithaca consultant, there is no monitoring near Lake Source Cooling s outfall, and the commenter is very 15 concerned about DEC's standards and ethics. Other projects are not allowed in shallow waters, and Lake Source Cooling should not have been allowed. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter; W. Hang at 7131103 Public Hearing and in 816103 letter) Response: This comment is not relevant to the project. The Lake Source Cooling permit was legally issued after extensive review by the public and DEC. 18. Comment. The commenter asks why DEC has failed for years to address problems at the VCHWTP and expresses concern about the possibility that Cornell University's veterinary school waste might be discharged to the IAWWTP. This commenter wants DEC to address these and other impairments before allowing more waste into the southern basin. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: The project includes a diversion to eliminate VCHWTP exceedances of permitted flows. In addition, DEC is funding improvements (independent from the project) to the VCHWTP. The improvements include effluent filtration and chemical addition for enhanced phosphorus removal; the addition of baffle wall within one of the two final settling tanks to improve performance; and replacement of trickling filter media for improved wastewater treatment reliability. The discharge of Cornell University's veterinary school waste into the IAWWTP is independent from the project and is still in the discussion stage. Should that plant agree to accept such waste, it would have to be treated so that all of the parameters and limits in the plant's SPDES permit are met. SEGMENTATION 19. Comment: The IAWWTP SPDES permit modification and the project are illegally segmented. As a result, it is impossible to quantify the water quality impacts from the project. (R. DePaolo at 7131103 Public Hearing) Response: There is no illegal segmentation, the water quality impacts are quantifiable, and the impacts of a 13.1 mgd flow were considered during the SEQRA review of the plant's permit modification. As the Scoping Responsiveness Summary noted, the IAWWTP owners requested an increase in capacity in 1995 b_ use the 10 mgd flow limit had been reached (and actually exceeded on at leas to occasions). The plant owners asked for the additional capacity o keep the plant in compliance. Their request for 13.1 mgd was based on an X� _ 16 engineering study, which indicated the plant capacity could be increased to 13.1 mgd with minor improvements and modifications, which were made in 1997. The City of Ithaca conducted a SEQRA review on the permit modification in 1996 and issued a Negative Declaration. The project that is the subject of this EIS had not been developed and was not under consideration at that time. The Town of Lansing instead was pursuing its own wastewater treatment plant at Portland Point in Lansing. It applied for Clean Water/Clean Air Bond Act funding for a stand-alone plant in 1997. The current project was developed only after Bond Act funding was denied to the local municipalities for their individual projects, and the DEC urged them to come up with a regional solution for wastewater treatment needs. Segmentation has not occurred. The SPDES permit modifications are not dependent on or driven by the project. The IAWWTP needed the increased capacity regardless of whether service areas are added, and it applied for the increased capacity well before the municipalities started developing the project t "the subject of this EIS. In addition, the DECcit 's approval of the increased capanot commit the municipalities and agencies to approving the various elements of the project, nor have environmental impacts evaded review (which is the concern about segmentation). The environmental effects of an increase in capacity to 13.1 mgd were considered in the City's SEQRA review. The effects of a 13.1 mgd discharge on Cayuga Lake are the same regardless of whether the flow comes from within or outside the current service area. 20. Comment. Application of DEC's 8-part test shows segmentation has occurred. There is: a common purpose or goal for each segment; a common reason for each segment being completed at or about the same time; a common geographic location; a common impact that may result in a potentially significant adverse impact if the activities are reviewed as one project; and common ownership or control of the different segments. A given segment is a component of an identifiable overall plan and the initial phase directs the development of subsequent phases; the phases are functionally dependent on each other; and DEC undertook concurrent review of funding and permit modification requests for both segments. Without the project, there would be little need for increased capacity at the IAWWTP. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See Response to Comment 19 above. In addition, application of DEC's 8-part test shows the following. • Is there a common goal? In 1994, the IAWWTP owners identified an opportunity to have DEC increase the plant's permitted capacity at very low cost if they made final settling weir and baffle improvements and increased influent pumping, capabilities. The fact the 10 mgd flow limit had been exceeded on two occasions, R coupled with the fact the permitted capacity could be increased thro`ug`f implementation of low cost improvements, led to the request in 1995 for an increase in capacity. The IAWWTP owners' consistent goal was to get this low- 14' 6 17 cost increased capacity, regardless of what happened with the project that is the subject of this EIS. • Is there a common reason for completing each segment at or about the same time? While it is true the flow diversion from the VCHWTP could not occur before an increase in capacity at the IAWWTP, there is no reason to have the increase in capacity occur "at or about the same time" as the flow diversion. The IAWWTP permitted capacity expansion could and did occur without the flow diversion. • Is there a common geographic location? The answer to this depends on how one defines each project's location. Obviously, the IAWWTP is involved in both the permit modification and the project. But many elements of the project are located in the Town and Village of Lansing and the Village of Cayuga Heights as well. The actual flows from the Town of Lansing will flow to and be treated at the VCHWTP, with other flows diverted to the IAWWTP. • Is there a common impact that may result in a potentially significant adverse impact if the activities are reviewed as one project? This query seeks to determine whether impacts from two or more projects, which may be insignificant when reviewed separately, become significant when the projects are reviewed together. As stated in Response to Comment 19, the effects of a 13.1 mgd discharge on Cayuga Lake were reviewed in 1996 when the City of Ithaca issued a Negative Declaration. The impacts are the same regardless of whether the flow .comes from within or outside the current service area. There are no additional impacts to the south end of the Lake from the addition of flows diverted from the VCHWTP because the total discharge will be less than 13.1 mgd. No different or more significant impacts to the southern Lake could possibly have been identified if the projects had been reviewed together. • Is there common ownership or control of the different segments? The IAWWTP is owned and operated by the City of Ithaca, Town of Ithaca, and Town of Dryden. This ownership and control is expected to remain the same regardless of whether the diversion and/or service area expansions occur. The VCHWTP is owned and operated by the Village of Cayuga Heights. Pump stations and public sewers in the Town of Lansing will be owned and operated by the Town of Lansing. The Town of Lansing will also own and operate a transmission main that is proposed to cross the Village of Lansing and a portion of the Village of Cayuga Heights. Public sewers in the Village of Lansing will be owned and operated by the Village of Lansing. • Is a given segment a component of an identifiable overall plan? At the time of the City's SEQRA review of the 13.1 mgd discharge, the plan that is the subject of this DEIS had not been developed. In fact, the project sponsors undertook a lengthy planning process to arrive at the plan which is the subject of this EIS. This process did not begin until long after the City's SEQRA review was completed. Are the phases functionally dependent on each other? Flows could not be diverted from the VCHWTP without the IAWWTP capacity expansion. However, the IAWWTP capacity expansion is not dependent in any way on the flow diversion. Does the approval of one phase commit the agency to approval of other phases? (Note that this last test in the SEQR Handbook is different from that set forth in the commenter's letter.) The answer to this query is no. Approval of IAWWTP's increased capacity request does not commit the project sponsors, DEC, nor other agencies to approval of the various components of the project. 21. Comment: Although the initial application to modify the IAWWTP's SPDESpermit was made before the project materialized, DEC continued to review the application for four years after rejecting separate funding applications and suggesting a regional wastewater management approach, for three years after accepting joint grant applications, and for two years after becoming Lead Agency on the project. A DEC SPDES permit writer told this commenter the length of the review period was due to the fact the permit limit for phosphorus was "revisited several times" during the review process. Review of the permit modification should have been joined with review of the project. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19 and 20 above. There were a number of reasons the period between permit modification application and permit issuance was so long, including personnel changes at DEC. 22. Comment: To remedy the segmentation, the EIS should include IAWWTP historical and projected phosphorus loading analyses, and DEC should revoke or suspend the IAWWTP's SPDES permit and rewrite it to reflect the effects of the planned tertiary phosphorus treatment and the increased effluent posed by the project. The rewritten permit should adhere to Technical and Operation Guidance Series (TOGS) 1.2.1 and 1.3.6, which govern the processes by which phosphorus limits are calculated for expanded discharges into lakes. (R. DePaolo in 8111103 letter) Response: See Responses to Comments 19-21 regarding the segmentation comment. Because there was no segmentation, there is no need to revoke or suspend the IAWWTP permit. Historical and projected phosphorus loading analyses for the IAWWTP and VCHWTP are presented in Table F-1. The IAWWTP SPDES permit contains a Fact Sheet that establishes the procedure for the establishment of new limits to reflect the effects of the planned tertiary phosphorus treatment, which is expected to begin operation in the early Fall of 2004. The new limit will be based on actual performance of the plant once the new phosphorus treatment has been in operation for eighteen (18) months. Based on the technology and manufacturer's warranty for the equipment that is being installed, the new limit is not expected to exceed 0.2 mg/L. IAWWTP SPDES PERMIT MODIFICATION 19 23. Continent. The IAWWTP's modified SPDES permit allows a 37% increase in mass loading of phosphorus over historical performance in contravention of the "no net increase" provision in TOGS 1.3.6 and TOGS 1.2.1. It appears the permit limit for phosphorus was artificially inflated to allow the capacity needed for the project. (R. DePaolo in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. We believe the commenter intended to reference TOGS 1.3.6 and 1.3.1 (not 1.2.1), so this response is based on information and guidance contained in TOGS 1.3.6 and 1.3.1. Before the IAWWTP permit modification, its then -existing permit required reduction of phosphorus to 1.0 mg/L on a 30-day average basis. This concentration -based limit and the 10.0 mgd flow limit for the plant established a maximum phosphorus loading of 83.4 lbs/day. TOGS 1.3.6 establishes phosphorus removal requirements for new and expanded discharges to lakes or in lake watersheds. The process used by the DEC for the new permit limit is based on TOGS 1.3.6 and statistical analysis of plant performance data from January 1996 through September 2000. Guidance criteria stated in TOGS 1.3.6 requires that: "...any proposed expansion of an existing discharge within a lake watershed, which would require a modification of an existing SPDES permit, should provide BTT [Best Treatment Technology] for phosphorus removal to a degree that the annual quantity (mass loading, flow multiplied by concentration) of phosphorus discharge after the modification does not exceed the phosphorus discharge prior to the modification." The DEC has interpreted this to mean that the discharge of phosphorus after the modification cannot exceed the current (historical) level of phosphorus, not the permitted allowable level of phosphorus. In order to determine the current level of phosphorus being discharged, the DEC completed a statistical analysis of plant data from January 1996 through September 2000, to calculate the 95th percentile effluent phosphorus mass loading. This statistical analysis yielded a limit for phosphorus of 40 lbs/day. The limit was set at 40 lbs/day because, in accordance with DEC's standard methodology, 95% of the 46 twelve-month rolling average data points fell below 40 lbs/day. Note that the data in Table F-1 cannot be used to calculate the limit, because the Table F-1 data are actual annual averages (not 12- month rolling averages) which are intended to show the average reduction in phosphorus discharged to the Lake. Table F-1 does not represent a statistical analysis of the data. It is important to note that the modified phosphorus effluent limit of 40 lbs/day represents a greater than 50 percent reduction in mass loading of phosphorus versus the plant's previous permit limit of 1.0 mg/L or 83.4 lbs/day. In setting the new limit, the DEC GI recognized that the facility actually discharged significantly less phosphorus than what was permitted. The purpose of the modification was to set a no net increase limit on an annualized basis. It should also be pointed out that the modified limit does not reflect advanced phosphorus removal technology. As mentioned in Response to Comment 22, a project is currently underway to provide for an advanced phosphorus removal facility. The SPDES Permit Fact Sheet recognizes that the existing phosphorus limit will be further decreased once the construction is completed and operation of the new facility is underway. 24. Comment: DEC issued a revised SPDES permit for the IAWWTP that allows an increase in phosphorus discharge from less than 30 pounds per day to up to 40 pounds per day. Two commenters state that DEC ignored its own regulatory policy (TOGS 1.3.6) by approving this revision. (W. Hang at 7131103 Public Hearing and in 816103 letter; R. DePaolo at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: See Response to Comment 23 above. 25. Comment. If wastewater flows are higher than projected, phosphorus loadings could increase beyond the historical 30 pounds per day, and the sponsors would be within their legal rights. This commenter asked DEC two years ago to revoke or modify the SPDES permit on the grounds of grave material falsehoods and the 37% increase in phosphorus loadings. The commenter provided DEC with a detailed statistical analysis performed by a Cornell University statistics professor that showed the 37% increase. DEC has never responded, even though this commenter was promised an answer 18 months ago. It seems likely DEC did not respond in order to allow the SEQRA process for the project to proceed without the benefit of technical insight into the creation of the IAWWTP permit. (R. DePaolo at 7131103 Public Hearing and in 8111103 letter) Response: See the last paragraph of Response to Comment 1 above. The technical basis for the creation of the IAWWTP permit is explained in the permit's Fact Sheet. As stated in Responses to Comments 23 and 24, the 95 percent statistical recurrence of effluent phosphorus loads (as determined by the DEC) from the IAWWTP is 40 lbs/day, not 30 lbs/day as stated by the commenter. Therefore, the permit establishes a "no net increase" in allowable phosphorus load discharged from the Ithaca Area Wastewater Treatment Plant. The statistical analysis by the Cornell University statistics professor relied on only two years of historical plant flow data, whereas the DEC analysis relied on nearly five years of historical data. (The SPDES Permit Fact Sheet contains a typographical error that says DEC used 3 years of data.) The two years of data used by the professor generates a data set of 12 data points, which DEC believes is not a large enough data set to perform the 21 statistical analysis because it is not a good representation of fluctuations in climatic changes. In comparison, DEC's data set between January 1996 and September 2000 yields 46 data points. Although the commenter has stated the older data is not representative because of subsequent improvements to the IAWWTP and its collection system, those improvements were not done to increase phosphorus removal and did not impact phosphorus loadings or reductions. PHOSPHORUS UPGRADE & LOADINGS 26. Comment: The DEIS contains no information on the phosphorus removal project that is currently out for bid at the IAWWTP. The scoping documents mentioned this project. This commenter thinks the phosphorus removal elements were taken out of the DEIS to avoid a focus on water quality issues. The FEIS should reference the phosphorus removal component. (R. DePaolo at 7131103 Public Hearing) Response: Contrary to the commenter's assertion, the phosphorus removal project was not included in the Scoping Document. The Overview Document previously released to the public states that the IAWWTP phosphorus removal project is independent from the diversion project and would not be part of the EIS. The Overview Document further states that the IAWWTP phosphorus removal project was a Type II action under SEQRA and further SEQRA review was not required for it. 27. Comment: The project would undercut or eliminate the benefits of a proposed phosphorus removal upgrade to the IAWWTP. That facility currently removes phosphorus to less than 0.7 milligrams per liter (parts per millions (ppni)) on a 12-month rolling basis. Approximately 27.5 pounds of phosphorus are discharged daily into the Lake. After the upgrade, phosphorus would be reportedly removed to less than 0.2 ppm on a 12-month rolling average. The project will generate wastewater containing 25 to 36 pounds per day of phosphorus, or I % to 16% of the 220 pounds of phosphorus now received by the IAWWTP. That contribution would off -set improved phosphorus removal at the upgraded plant. If wastewater generated by the proposed project exceeds DEC's estimate, there could be a net increase in phosphorus discharged into the Lake, because the IAWWTP's revised SPDES permit allows up to 40 pounds per day of phosphorus discharge. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: See the last paragraph of Response to Comment 1. This comment uses incorrect numbers and double -counts existing VCHWTP flows that will be diverted to the IAWWTP. Even with the addition of flows from the Town of Lansing, the amount of phosphorus discharged to the south end of Cayuga Lake will be reduced by between 57 and 70 percent. 22 The discussion presented is flawed in that it states, "The proposed project is estimated to generate wastewater containing 25 to 36 pounds per day of phosphorus" when actually only 11 lbs/day initially and 31 lbs/day in 20 years will be collected by the Town of Lansing sewers installed as part of this project. [Jerry, why are the average annual and max month numbers the same for T. Lansing P contributions in Table 1?] [Jerry is checking on this.] These amounts will be treated by the VCHWTP and reduced to less than one-fourth lbs/day of phosphorus initially and less than three -fourths lbs/day in 20 years before it is discharged to Cayuga Lake. The flows diverted to the IAWWTP are existing flows from the VCHWTP service area, and, therefore, they do not add an additional phosphorus load to the Lake because they are currently discharged to the south end of the Lake through the VCHWTP outfall. With the phosphorus treatment upgrades at the two plants, the total amount of phosphorus being discharged to the south end of Cayuga Lake will be reduced from a current annual average load ranging from 33.5 to 44.8 pounds per day (combined discharges from the IAWWTP and the VCHWTP) to approximately 15 lbs/day initially (including the additional initial flow collected in the Town of Lansing). 28. Comment: If DEC continues to support the project, then it should be redesigned to prevent further degradation of Cayuga Lake. The phosphorus pollution generated by the project should be measured as it flows into the VCHWTP and the sponsors should clean up at least twice that amount elsewhere in the Lake's watershed. For example, artificial wetlands at the mouth of Cayuga Inlet could control phosphorus from stormwater runoff, and buffer zones could be established along agricultural areas to prevent fertilizer runoff into Lake tributaries. A study could be undertaken to determine if Lake Source Cooling water could be used as potable drinking water and be treated before discharge back to the Lake. The main polluted area of the Lake flows away from Lake Source Cooling's intake and directly towards Bolton Point's intake, which is directly downgradient from wastewater discharged into the Lake. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The WWTP owners will accomplish far more than what this commenter has requested. Flows from the Town of Lansing sewers will result in one-fourth of a pound per day of phosphorus initially and less than three -fourths of a pound per day in 20 years discharged to the Lake. With the installation of phosphorus treatment, the WWTPs' loadings of phosphorus will decrease in the range of 20 to 31 pounds per day. 29. Comment: The VCHWTP is outmoded and lacks state-of-the-art phosphorus removal. That facility lags behind the IAWWTP's efforts to upgrade its phosphorus removal capability. That problem should be rectified. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The VCHWTP will be upgraded for advanced phosphorus removal and it is expected to remove phosphorus to a level of 0.2 mg/L or better. Money has been awarded from the Clean Water/Clean Air Bond Act for this upgrade. 23 CONSTRUCTION 30. Comment: The EIS should include details about the actual construction and installation of sewer lines in the Lansing Service Area, such as the size. of the construction right-of-way, how deep lines will be buried, and what the area of disturbance will be. The FEIS should use this information to analyze construction impacts on stream corridors, instream habitat, wetlands, and Unique Natural Areas (UNAs) in the Lansing Service Area, and the construction plans for the Lansing Planning Area should address these impacts. (E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Traditional sewer pipe installation using open -cut methods of trenching can typically be accomplished within a footprint of 30 feet. Permanent easements are normally 20 feet wide. The depth of construction is variable and will not be known until final design profiles are prepared. At a minimum the depth of cover on small diameter gravity or forcemain sewers will be approximately 4-5 feet. Field verification of construction impacts will be made at the time construction routes are finalized. 31. Comment: The FEIS should detail what is to be included in each construction plan. Construction plans should address minimization of sedimentation and erosion; describe in the blasting plan how construction and pipe locations might impact private drinking water sources from bedrock wells and describe mitigation measures for such impacts; and analyze impacts from potential staging areas. Construction staging areas should be located outside of any UNAs. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The DEIS indicates that appropriate measures will be implemented to mitigate these construction related impacts. These measures will be detailed on construction plans and in the specifications. Construction documents for the pipeline and pump station projects will include requirements for erosion and sediment control (i.e. silt fence, dewatering of excavations, stabilizing exposed soils); rock removal by blasting with appropriate monitoring; and approved areas for establishing materials and equipment storage. Such plan details and specifications will be tailored to the specific work sites once final sewer main routes are determined. Construction staging areas will be located outside of LTNAs wherever possible. UNIQUE NATURAL AREAS 32. Comment. The existing maps of UNA boundaries are not exact. Placement of a sewer line on a boundary does not necessarily mean that there will be no impacts to the flora and fauna, geological structures, habitat, etc. that are found in the area. The FEIS should explore alternative transmission routes along road beds or routes further away 24 from UNAs. The FEIS should also consider trenchless digging as an alternative in the UNAs. Alternate locations should be considered for the two pump stations that are proposed in the UNAs in the Lansing Service Area. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: To the extent practicable, preliminary sewer main routes in the Town of Lansing Service Area have been selected to avoid the general extents of the UNAs. The proposed gravity transmission main along the former Ithaca -Auburn railroad bed will traverse UNA-89, UNA-102 and UNA-103 and an alternative forcemain design has been evaluated along Cayuga Heights Road. A subsequent forcemain design along the Norfolk Southern railroad right-of-way is described in Response to Comment 33. Trenchless technology for installing sewer mains has been identified in the DEIS as a mitigation measure to be implemented for avoiding disturbance of specific surveyed natural features within the UNAs. The proposed Myers Road pump station lies within UNA-55 and will be sited in the vicinity of the Myers Road and Lakeshore Road intersections. The majority of the land in this area was once utilized for gravel mining. The Portland Point pump station will be located west of UNA-63 within the extents of the former industrial disturbance. 33. Comment: The EIS should examine the possibility of running the Town of Lansing- VCHWTP transmission line along the existing Norfolk Southern railroad line, which is already a highly and frequently disturbed area. This would eliminate the need for pumping stations and habitat destruction that would be necessary with the other routes discussed in the EIS and there would be easy access to the rail bed, which would decrease the cost of maintenance and repair. (L. Leopold in 8111103 letter) Response: T.G. Miller, P.C. has explored the permit requirements and physical constraints of a "longitudinal occupation" within the Norfolk Southern Railroad right-of- way. The Norfolk Southern pipeline offset requirements dictate that a sewer main must be installed roughly 24 feet from the rail centerline. Occupation along the west side of the rail places the main in the waters of Cayuga Lake for a majority of the 5 mile route. Land availability east of the rails varies considerably. At several locations the extensive rock cliffs are within 5 to 6 feet of the eastern rail. To conform to the offset requirements it will be necessary to remove substantial faces of the rock cliff. This removal would negatively impact the steep slopes east of the present cliff edge. Due to the physical constraints noted above, access to and along the railroad bed is not sufficient for either initial construction or future maintenance as long as the rail remains in use. Further, the construction cost for this alternative as estimated in the T.G. Miller analysis will minimally be 2-2.5 times the cost of the Cayuga Heights forcemain alternative. Based on these factors the Norfolk Southern Railroad alternative is not viable at this time. 25 34. Comment: These commenters strongly support the alternative transmission route along Cayuga Heights Road proposed for the Twin Glens and Esty s Glen UNAs. (J Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Comment received and noted. 35. Comment: As recommended in the DEIS, a biological survey should be conducted of the proposed interceptor route in UNA 103, McKinney's Twin Glens and Lake Cliffs. One commenter wants this survey to inform a decision as to whether trenchless construction should be used (as recommended in the DEIS), and requested this survey be done before the end of the SEQRA process. Another commenter suggested the survey be used to decide whether the sewer route should be diverted away from the UNA, and requested the survey be conducted during the appropriate time of year to reveal the potential plants or animals impacted. (E. Marx, Tompkins County Planning Department in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Prior to any final selection of the Ithaca -Auburn railroad transmission route a survey will be conducted by qualified professionals to identify the important natural communities and rare/scarce plants or animals within close proximity to the route. The identification of rare or scarce plants will be conducted during the appropriate season(s). The width of the survey corridor will be determined after consultation with the professionals. The approximate limit of the corridor within UNA-89 and UNA-103 is between the south end of Cayuga Hills Road and the existing Village of Lansing sewer transmission main below Cedar Lane. A land survey will then be performed to map the identified communities and plants in order to assess the feasibility of using trenchless technology or to completely avoid the corridor. 36. Comment: The construction of a pipeline through UNAs 103 and 89 would necessitate the removal of a large number of medium-sized and mature hemlocks in the Twin Glens area, which are irreplaceable and create a beautiful visual scene. These areas have had 75 years to grow into forest and many local residents enjoy them year- round. No amount of mitigation can restore these areas in our lifetime if this pipeline is built through this area. The EIS is meant to deal with and prevent preventable environmental impacts. (L. Leopold in 8111103 letter) Response: See Response to Comment 35 above. 37. Comment: The commenter is concerned about the environmental impacts of digging in UNAs and asks how often connectors would be built in forested escarpment areas to reach the transmission interceptor. 110 (J. Dennis at 7131103 Public Hearing) Response: The proposed Ithaca -Auburn railroad transmission main does not include or anticipate the construction of additional connectors through "forested escarpment areas". 38. Comment. The Existing Conditions section of the DEIS should note that UNA 103, McKinney's Twin Glens and Lake Cliffs, contains a section of the old Ithaca -Auburn Shortline that crosses the glen. If sewer lines will run close to remaining abutments and a trestle from the old Ithaca -Auburn Shortline, the FEIS should assess the impacts of the sewer lines on these features, which may have historic or cultural significance. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: With modifications, the abutments of the Ithaca -Auburn Shortline railroad at the southerly glen could support a pipe bridge. The Stage 1 A Cultural Resources Survey did not identify these abutments as having historical or cultural significance. Further, there is no remnant of a "trestle". There are two existing pipe bridges south of Cedar Lane that support the Village of Lansing sewer transmission main. 39. Comment: The EIS has very little information about mitigation of impacts in UNAs. (J. Dennis at 7131103 Public Hearing) Response: Mitigation for impacts to UNAs is adequately discussed in DEIS Section 4.4.2 and the sections referenced therein. Additional mitigation measures are discussed in Responses to Comments 31 and 35. WETLANDS 40. Comment: The EIS should consider an alternate route for the sewer lines that are proposed to cross UNA 65 (Head Corners Wetland), and DEC should be consulted prior to any disruption of the area. The commenter supports the DEIS suggestion that a wetland scientist should survey the area and make recommendations for limiting impacts to this wetland. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The potential for crossing the Head Corners wetland exists in a future phase for which no definite plans have yet been formulated. Based on the assessment in this EIS, an alternate route for a sewer line in the vicinity of this wetland will be analyzed if and when future sewer extension plans are developed. 41. Comment: Care should be taken to preserve and protect wetlands throughout the study area. In addition to the impacts noted in the DEIS, loss of wetland function can have negative impacts on surrounding lands due to flooding, and can cause problems 27 associated with water quantity and quality in stream corridors and eventually in Cayuga Lake. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Comment noted. The proposed project will not have any direct impact to wetlands, as stated in the DEIS and confirmed by FEIS Figures I and 2. See also Response to Comment 43. 42. Comment. When the location of sewer lines is determined, a wetlands scientist should conduct a more complete analysis of potential wetlands impacts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Field verification of the EIS conclusion that no wetlands will be impacted will be made at the time construction routes are finalized. 43. Comment: The EIS should contain a map showing all wetlands overlaid with the proposed sewer lines at a finer scale (for example, 1: 24, 000) than that used in Figures 17 and 18. The EIS should also combine the information in Figures 44 and 45 into one map shown in an additional figure. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: More detailed maps of wetlands in relation to proposed sewer routes are found in FEIS Figures 1 and 2. These figures confirm the DEIS conclusion that the proposed Service Area sewers will not impact wetland areas. The potential impacts of Planning Area sewers are accurately discussed in the DEIS. WATER RESOURCES 44. Comment: Sewer line routes should be designed to reduce impacts to known private wells and public drinking water supplies (such as those at Myers Point, Ludgate's, and the Plantations Inn). (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: FEIS Figure 3 illustrates the proximity of proposed sewer lines to known public drinking water supply sources. No such sources are located in close proximity to proposed sewer lines such that they would be impacted by the project, with the possible exception of the well point on Burdick Hill. Mitigation for potential impacts to this supply is discussed in Response 46. 45. Comment: There is no discussion of how to mitigate the impact that trenching activities would cause on a residential drinking water supply that exists in the form of a large cistern at 1203 East Shore Drive that lies directly below the former Short Line railroad bed. This was brought up during the scoping session but is not mentioned in the DEIS. (L. Leopold in 8111103 letter) Response: This supply is discussed at DEIS page 70. Mitigation of impacts from potential leaks or a break in the line is discussed at DEIS page 74. It is proposed that the transmission line be double sleeved within 100 feet of this water supply. To the extent there may be potential construction impacts from trenching activities, during construction the location of the cistern will be marked in the field and all construction activities will be maintained at a safe distance from the cistern to avoid adverse impacts. The safe distance will be determined in the field based on soils characteristics. 46. Comment: The DEIS states at page 31 that there are numerous private wells located throughout the Study Area that have not been comprehensively mapped. Some of these well points are regulated public water systems, and these have been mapped. The data for these wellheads is available through the Tompkins County Planning Department. There are few, if any, regulated public water systems in the service area, as most of the service area is already served by municipal water. If the final plans do indicate impacts on a regulated water system from sewer construction, the system may need to be abandoned and the municipal water systems used if available. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Known public water supplies are mapped in FEIS Figure 3. The Tompkins County Planning Department supplied the data about these wellheads. There is no available mapping of private wells. No wells for which information is known are found in proximity to proposed sewer lines, with the exception of the private source discussed in Response to Comment 45, and possibly the Burdick Hill well point. Mitigation for the former is discussed in the DEIS and in Response to Comment 45. With respect to the latter, similar mitigation (such as double sleeving of the sewer line within 100 feet of the well point) will be implemented if the line is found to pass within 100 feet after construction plans are developed. 47. Comment: Section 4.5.1 (Impacts to Water Resources) should acknowledge that there could be negative impacts to well heads and mitigation should be recommended, where possible. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 lettef) Response: See Response to Comment 44. GROWTH -INDUCING IMPACTS 29 48. Comment: The sponsors should consider the following growth -inducing impacts in addition to those identified in the DEIS: • The adequacy of public water supplies and private drinking water wells (since induced growth may increase the demand for public and private drinking water supplies). • Increased congestion of specific transportation corridors that could result from the density and intensity of land uses allowed in a particular area and the timing of sewer line extensions. Local comprehensive plans should carefully evaluate these relationships between infrastructure and land use. The transportation demand model used in the DEIS dilutes the traffic impacts by spreading them throughout the study area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment noted. The relevant municipalities will need to determine whether adequate drinking water supplies exist in the locations of proposed sewers. Adequate supplies currently exist in the proposed Lansing Service Area; decisions about water supply adequacy in the Lansing Planning Area and Dryden Study Area will need to be made if and when sewers are proposed in those areas. The relevant municipalities should also consider the potential transportation impacts of proposed land use patterns and traffic mitigation. Mitigation could include, among other things, mixed use development patterns that take advantage of or enhance transit connections, and links and facilities for pedestrians and bicycles. The use of the word "dilutes" is not completely accurate in the comment about the transportation model. Volumes of traffic for specific links and intersections are projected with a dynamic model that assumes people will shift their patterns if a specific link or intersection becomes too congested. So the model makes traffic assignments using the entire road network. As a result, one may find that development spread out over an area may show insignificant traffic impacts (such as no system failures at specific links or intersections), particularly if the area has a dense road network. If there are few roads, they tend to capture all the traffic and the model starts to report capacity problems. 49. Comment: The project will trigger a large amount of building. The EIS has very little information about induced housing growth in new areas. (J. Dennis at 7131103 Public Hearing) Response: The DEIS contains an extensive discussion of induced growth in Section 6. Table 31 on page 100 specifically estimates the number of dwelling units which may be constructed in the Study Area under three scenarios. The remainder of Section 6 analyzes the impact of such development. 50. Comment: Sewers will induce growth, which will lead to non point source. impacts on the Lake caused by lawn fertilization and stormwater runoff. How do we know there will 30 be a positive offset in taking septic systems off-line? (R. DePaolo at 7131103 Public Hearing) Response: See Response to Comment 4 above. Among other things, the project will correct a significant problem with respect to failing septic systems. It is true that growth may have other impacts. The purpose of the induced growth analysis in DEIS Section 6 is to provide the affected municipalities with information about the amount of growth that may occur in order that they may formulate land use policies to avoid adverse impacts. ALTERNATIVES 51. Comment: DEC has made it clear throughout this planning process that it would only support an intermunicipal solution. The DEIS does not show that the project is better than the alternative of constructing a state-of-the-art satellite treatment plant for the Town of Lansing that would release effluent into a deeper, more northern, and less impaired portion of the Lake. Although DEC did not approve funding for this alternative, it is still a real alternative, and the EIS should discuss this alternative in more detail. One commenter requested that another map/figure be added to the EIS showing possible location and depth of discharge for a new WWTP, as well as the Lake depths in that area. One commenter believes DEC pushed the intermunicipal solution for fiscal reasons as much as for environmental reasons. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; L. Leopold in 8111103 letter; D. Kiefer in 8111103 letter; F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: DEC prefers an intermunicipal solution that addresses the problems in the region comprehensively. The phosphorus loadings from Town of Lansing flows are very small and overall phosphorus loadings to the Lake will be greatly reduced with the planned WWTP phosphorus upgrades. It is difficult to interpret the meaning of "state-of- the-art satellite treatment plant" in the comment since no proposal went through to a design phase. In DEC's experience, small municipal plants generally have more operational and compliance problems than regional facilities. Smaller municipal plants are seldom "state-of-the-art" because of the inability to spread higher costs over a small tax base. Also see Response to Comment 52. 52. Comment: The EIS contains no evidence that centralization of wastewater treatment infrastructure in this instance would be more cost-effective or technically superior than a decentralized approach using an additional treatment plant in the Town of Lansing. One commenter said new technologies are available that treat wastewater efficiently and properly. Another commenter suggested consideration of the use of ozone- and ultra- violet based treatment rather than chlorine. Another commenter said that higher risks of malfunction and pollution that come with decentralization are insufficient to reject an additional WWTP in this case because of the impairment in the southern Lake. 31 (F. Gougakis in 8111103 letter; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter; D. Kiefer in 8111103 letter; L. Leopold in 8111103 letter) Response: See Response to Comment 51 above. The October 1998 Wastewater Facilities Plan prepared for the Town of Lansing evaluated treatment alternatives including localized treatment systems, a conventional Town -owned treatment facility, and a regional wastewater treatment facility. That report recommended conveyance of sewage flows from the proposed Town of Lansing sewer service area to the VCHWTP, coupled with the partial diversion of sewage flow from the Cayuga Heights sewer service area to the IAWWTP. [What were the reasons for that recommendation? We need to spell them out here.] A new plant serving the Town of Lansing would have used ultra- violet treatment as the disinfection system. We disagree with the comment that that the higher risks of malfunction and pollution that come with decentralization are insufficient to reject an additional wastewater treatment plant in this case because of the impairment in the southern lake. The additional amount of phosphorus to be discharged in the southern lake is in itself very small and is less than one-fourth lbs/day initially and less than three -fourths lbs/day in 20 years. Even with the added Town of Lansing flows, the total amount of phosphorus discharged to the Lake will decrease in the range of 20 to 31 pounds per day on an annual average basis. 53. Comment: The EIS should mention the post 9-11 recognition that centralization increases vulnerability. The EIS should acknowledge that the alternative of relying on efficient, smaller -scale distributed infrastructure would promote the maintenance of greater region -wide functionality during times of natural or man -induced calamity. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: Vulnerability is certainly a concern today and it is true centralization can increase vulnerability. However, concerns about infrastructure vulnerability are not always cured by relying on decentralized infrastructure. A new smaller plant could be more vulnerable under some scenarios since small plants are not staffed as often as larger plants. 54. Comment: The EIS should examine an upgrade to the Town of Lansing's facility and a discharge into the Lake at that point. (J. Dennis at 7131103 Public Hearing) Response: The Town of Lansing does not currently have a wastewater treatment facility. 55. Comment: The EIS should better explore the alternative of expanding the VCHWTP. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) 32 M Response: The alternative of expanding the VCHWTP to treat 2.9 mgd (currently permitted at 2.0 mgd) was evaluated in the Town of Lansing Wastewater Facilities Plan prepared in October 1998. That report concluded that expanding the VCHWTP to treat projected flows from the Town of Lansing would cost approximately $3,500,000 - more than the alternative to divert equivalent flows to the IAWWTP, where capacity already exists. 56. Comment: The total proposed diversion to IAWWTP is only 1.3 million gallons per day. For a fraction of the $11.2 million capital cost, each of the Lansing on -site septic systems and SPDES permitted discharges referred to in the DEIS could be equipped with state-of--the-art on -site phosphorus removal systems without constructing a 26-mile long wastewater collection system. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: [To be developed.] 57. Comment: A study should be conducted to see if the discharge pipes for the IAWWTP, VCHWTP and the Lake Source Cooling facility could be merged and moved to discharge the combined effluent into deeper waters below the photic zone far from existing drinking water intakes. (W. Hang at 7131103 Public Hearing and in 816103 letter) Response: The need for such a study has not been demonstrated, and in any event, falls outside the scope of this EIS. Currently there are no water quality issues affecting drinking water. As for issues affecting the Lake, as stated in Response to Comment 12, DEC does not believe that currently there is sufficient information to develop a more stringent limit on phosphorus through the TMDL process. As stated in Response to Comment 14, if further reductions in phosphorus are required in the future, a modification to the WWTPs' permits may be required. If this occurs, the owners of the IAWWTP and VCHWTP will consider alternatives, including extending their outfalls into deeper water. 58. Comment: Studies should be conducted to assess the technical feasibility as well as the costs and benefits of managing the project's wastewater without any discharges to Cayuga Lake (discharge into a nearby receiving water body; spray irrigation). (W. Hang in 816103 letter) Response: Section 6.7.7 of the 1983 Wastewater Facilities Plan completed for the Town of Lansing evaluated the use of small diameter sewers with land application of raw sewage. The conclusion reached is published in its entirety: "This alternative considers the areawide collection of sewage by small diameter sewers. The sewage would be transported to a suitable location and then applied to the land. As pointed out earlier, the most suitable location of central collection is at Portland Point. 33 Three potential landsites are considered for the application of raw sewage. These are illustrated in Appendix 6-4. A number of evaluations must be made in considering the application of sewage to land. These are: (1) health considerations to adjoining residential community (2) groundwater pollution (3) soil pollution, (4) air pollution (5) future use of land and many other considerations since the temperature in the Study Area is very low during winter season. The sewage would have to be stored during winter season before it is applied in summer/spring to the land. An economic evaluation of the alternative is made before giving consideration to various health and environmental concerns. The total estimated project cost using this alternative is $15,224,100. The annual cost of Operation and Maintenance is $43, 000. Since this alternative is more costly than the majority of other alternatives, no further consideration is given to this alternative. " PROJECT SCHEDULE 59. Comment: Section 2.7 says survey and stakeout of sewer line alignments will occur one week ahead of the construction schedule. This short timeframe will likely not be sufficient to deal with any problems that may arise. One commenter asked the time between survey/stakeout and construction be lengthened to two to four weeks to provide the ability to make rerouting decisions that may be necessary due to site conditions. Another commenter asked the time be lengthened to at least four weeks, for the same reason. (J. Dennis at 7131103 Public Hearing; S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: The survey and stakeout referred to in Section 2.7, which will be conducted one week ahead of the construction schedule, is to provide control points for the contractor's use. A detailed design survey is conducted to determine the final alignment of the proposed sewer. The design survey is used to make routing decisions due to site conditions. 60. Comment: The EIS should discuss how analysis, planning and engineering for the 26 proposed stream crossings will be conducted before construction starts. (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: There are no DEC protected streams to be crossed by the construction of sewer mains in the Town of Lansing Service Area. Certain practices and controls to minimize stream disturbance will still be incorporated in the contract documents and depending on the characteristics of a particular stream may include all of the following: 1. Directional boring beneath the stream or trenching with appropriately constructed coffer dams. 2. Discharges from trench dewatering activities will pass through a sedimentation control practice. I Ile 3. Not allowing equipment in flowing streams. 4. Restoring the stream bottom cross-section and profile. 5. Replacing significant trees removed within 50 feet of a stream bank. DRYDEN PLANNING AREA 61. Comment: The Dryden Planning Area in the DEIS is significantly larger than those areas identified for expanding sewer service and accommodating future density in the Town of Dryden's Draft Comprehensive Plan. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: The Dryden Planning Area is a 20-year projection of areas where public sewers might go, whereas the Comprehensive Plan is expected to be updated every 5 to 10 years. The EIS's study of environmental effects within the Planning Area will be used to help inform decisions in the future on where sewer districts might be formed. 62. Comment: The commenter understands that the location of the sewer lines in the Dryden Planning Area is still in the conceptual stages and the DEIS does not discuss the environmental impacts in this area. Additional environmental reviews will need to address the full range of impacts in the Dryden Planning Area. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment received and noted. MAPPING ISSUES 63. Comment. The DEIS relied on Soil Association mapping for an assessment of soil conditions in the study area. Tompkins County has a digital version of the more detailed soil series map for Tompkins County, which may be obtained from the Tompkins County Information Technology Services Division. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: At the time of preparation of those portions of the DEIS which utilized soils mapping, the more detailed soil series mapping was not available. The association level mapping used in the DEIS is sufficient to identify the potential for construction impacts such as high groundwater tables or erosion, as well as for use in the growth inducement analysis. Given that the DEIS identified the potential for impacts related to soil conditions and recommended appropriate mitigation measures, no further analysis is required. 64. Comment: The VCHWTP and IAWWTP locations and existing pipe connections should be included for reference on at least Figure 4. 35 M (S. Uzmann, Tompkins County Environmental Management Council in 8111103 letter) Response: A revised Figure 4 is included in this FEIS. 65. Comment: The EIS should include a figure showing the location and depth of the existing WWTP discharge points as well as the depth of the Lake throughout the southern end. (D. Kiefer in 8111103 letter) Response: The location and depth of existing WWTP discharge points are not germane to the discussion of impacts from the proposed sewer construction project. The project does not involve any modifications or changes to these discharges. 66. Comment: In Figure 19, Uniaue Natural Areas. the pink color for UNA 102 (Renwick Slope) is on the map, but the number 102 is not printed on the map. The same is true for Figure 33, where the color for the Newman Tract appears, but not its title on the map. (L. Leopold in 8111103 letter) Response: Revised Figures 19 and 33 are included in this FEIS. 67. Comment: The DEIS states at page 30 that all water bodies are Class C in the DEIS Study Area. Actually, many are classified as "D" and `A " as shown on Figures 14A and 14B. The Figures have acolumn labeled "Protected Status Code" so only C(T) and higher streams are listed. The column should be labeled "Standards Class" and show all classes. This point is only for clarification, as the Stormwater Permit will protect the "D" streams and unclassified watercourses. (J. Andersson, Tompkins County Health Department in 6125103 letter) Response: Comment noted. Revised Figures 14A and 14B are included in this FEIS. GENERAL 68. Comment. Section XII of the Executive Summary, pages xxviii and xxix, which contains the list of involved agencies and their authority for the project, should state the DEC will also be responsible for review and approval of plans for the new construction, given the scope of the project, that most construction is in a new service area, and that State funds are involved. The Tompkins County Health Department (TCHD) will assist in review and approval if DEC so desires, as the TCHD does for most collector sewers. (J. Andersson, Tompkins County Health Department in 6125103 letter) 36 M Response: The DEC will be responsible for review and approval of plans and specifications (contract documents) for new construction of sewers and pump stations for the project. The Tompkins County Health Department will assist in the approval, if the DEC so desires. 69. Comment: Please clarify the statement in the DEIS in Section 2.2.2, Town ofLansin,z Service Area Proposed Improvements. that "the Village of Lansing's existing 15-inch railroad interceptor sewer intersects the railroad grade below Twin Glens Road and terminates at the existing VCHWTP. " At present, there is no Village of Lansing sewer interceptor below Twin Glens Road, unless the reference means 'farther south " along the railroad bed, instead of downhill, i.e., west, of Twin Glens Road. (L. Leopold in 8111103 letter) Response: The Village of Lansing 15-inch interceptor sewer is located on the former Ithaca -Auburn railroad bed south of Twin Glens Road and immediately west of Cedar Lane. 70. Comment: The commenter was pleased to see there are plans to investigate the possibility of using the former railroad right-of-way as a recreation trail in conjunction with this project. This is an excellent opportunity to create trails that link the Lansing community and the larger community. (E. Marx, Tompkins County Planning Department in 8111103 letter) Response: Comment received and noted. 71. Comment. The commenter asked what would happen to an elevated septic system that is built on the old railroad bed. Would the sponsors dig under that or remove it and put it back after construction? (J. Dennis at 7131103 Public Hearing) Response: Directional boring beneath the septic system is possible. Conventional trenching is also possible with necessary repairs made in the distribution/collection laterals, filter media and subsoil. Alternatively, the building sewer could be connected to the sewer main and the septic system ultimately abandoned. 72. Comment: One commenter said DEC's job is to protect the environment, not pay attention to how many homes are available. Another commenter said representatives of real estate agencies attended meetings on the project, and this commenter expressed concern that development expansion could end up playing a large role in the project. (R. DePaolo at 7131103 Public Hearing; F. Gougakis in 8111103 letter) 37 Response: Comment noted. Section 6 of the DEIS contains an extensive assessment of potential growth induced as a result of the project. The affected municipalities now have the opportunity to review their planning policies with respect to such potential growth. Other sections of the DEIS deal with other environmental impacts and mitigation, and the involved agencies and municipalities likewise will consider this information as they make their decisions. 73. Comment: This commenter expressed concern over impacts to sensitive/unique natural areas, unavoidable habitat loss, erosion, noise issues, odors, and pump station impacts that are raised in the DEIS. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: Comment noted. Each of these potential impacts is adequately addressed in the EIS. Absent a specific comment or concern, no further response is possible. 74. Comment. Local government officials should have held a public information forum on this project, preferably at night in the City of Ithaca. They made no effort to make sure the public understands this massive project. The EIS process should not continue until such a forum is held. (F. Gougakis at 7131103 Public Hearing and in 8111103 letter) Response: Comment noted, and the municipalities have the opportunity to take this comment into consideration for future projects. The official SEQRA public hearing and the informal public information session run by DEC were agreed to between DEC and the involved municipalities. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. 75. Comment: One commenter requests an extension of the comment period into September 2003 or well into the Fall of 2003. Another commenter requests an extension of the comment period into the Fall of 2003. (J. Dennis at 7131103 Public Hearing; F. Gougakis at 7131103 Public Hearing) Response: The length of the public comment period meets (and exceeded) the requirements of SEQRA. It is DEC's opinion as Lead Agency that adequate opportunity for public review and comment has been provided. COMMENTS IN SUPPORT OF PROJECT The following comments were received and noted. 76. Comment. The commenter states that overall, it is supportive of the project. The project will eliminate nonpoint source pollution currently caused by inadequate on -site sewage disposal systems in the project area. This will help maintain the public health &: and welfare of Tompkins County residents and those who use Cayuga Lake as a drinking water and recreational resource. This reduction, combined with an increase in the overall level of treatment for wastewater generated in the Cayuga Lake watershed, will help protect the economic vitality and well-being of Tompkins County. (E. Marx, Tompkins County Planning Department in 8111103 letter) 77. Comment. The commenter looks forward to the FEIS and the development of engineering plans and specifications to solve the identified problems in the service area. (J. Andersson, Tompkins County Health Department in 6125103 letter) 78. Comment: The commenter supports the project, which will eliminate ground and surface water pollution caused by inadequate on -site sewage disposal systems and will provide a higher level of sewage treatment than presently available within the service area. The project will better utilize existing treatment capacity and infrastructure, and phosphorus treatment will be added in both WWTPs, which will help improve Cayuga Lake's water quality. Members of the Tompkins County Chamber of Commerce and of Tompkins County Area Development funded facilitation of the project because the project is critically important to protect the Lake and it will allow for development in areas designated by each of the municipalities. Those funding the facilitation did not propose any particular solution but rather provided facilitation so the participants could come to a solution beneficial to all. The project's positive impacts far outweigh any potential adverse impacts. (J. McPheeters, Tompkins County Chamber of Commerce at 7131103 Public Hearing and in written copy of public comment received by DEC on 7131103) 79. Comment: The DEIS is well -written and thoroughly reviews the project's impacts. The project will improve the quality of Cayuga Lake by taking septic systems off-line and treating waste. The south end of the Lake is responsible for a majority of septic systems on the Lake. Over the past 8110 years, the commenter's house and septic system on Ladoga Point Road have flooded S times, which created additional discharge into the Lake and prevented occupancy of the house. The project will not necessarily create more growth, as the municipalities will control growth. (R. Cutting at 7131103 Public Hearing and in 816103 letter) 80. Comment: The project will provide an opportunity for expanded sewer service in the watershed and a higher level of treatment than what is provided by septic systems and package plants. The growth inducing impacts are relatively minor. The project will provide for better environmental protection for Cayuga Lake. (M. May in 811103 letter) 39 81. Comment: The project sensibly deals with the current inadequacies of the VCHWTP by utilizing the available capacity of the IAWWTP. The project will allow some growth in areas where sewers are present but sewer permits are not available due to VCHWTP limitations. The project will also make possible additional growth of homes and businesses without needing large areas of land to accommodate new septic systems. Some homes currently located on the lake shore have questionable septic systems, and no authority checks them on a regular basis. A controlled municipal system which could be upgraded in the future would insure that the waste from these homes is treated properly and meets established guidelines. (E. Quaroni in 811103 letter) 82. Comment. The project is a sound plan and a good solution to a very difficult infrastructure problem. A study initiated by the Tompkins County Planning Department and the Planning Advisory Board in 1994 concluded that limited water and sewer facilities, particularly in the northeast urbanized region, were a limiting factor to economic development. An Economic Development Strategy completed by Tompkins County Area Development (TCAD) in 1999 emphasized the importance of improved water and sewer service to attain the goal of building the economic foundations of Tompkins County. The Strategy noted that issues of concern related to the expansion of sewer services (generally related to the potential for development in suburban areas as opposed to the urban core) are balanced by the following counterpoints: extended sewer service improves environmental quality in already developed areas that use on -site disposal systems; sewer service allows small -lot and high -density development that lowers the developed area on a per capita basis; and the dynamics of development fluctuate among urban centers, suburban rings and rural areas. One of the top 10 action steps (out of 58) identified by the Strategy was an integrated system of water and sewer services for the urbanized and growing areas of the County to improve supply, efficiency of delivery and environmental quality. This is the reason TCAD helped fund facilitation activities to bring the project to this stage. (B. Blanchard, Tompkins County Area Development at 7131103 Public Hearing and in written copy ofpublic comment received by DEC on 7131103) 83. Comment: The proposed regional solution offers by far the best solution to meet the immediate and long term wastewater collection, transmission and treatment needs of the proposed service area. Upland pollution will be eliminated in areas not currently sewered. The entire region will benefit from the substantial improvement in the water quality in the Southern Cayuga Lake Basin. The project is consistent with land use policies already in place in all six municipalities. In addition, the owners of the IAWWTP have voluntarily agreed to more stringent permit levels for the discharge of phosphorus, and phosphorus removal and other improvements at the VCHWTP will also take place. Sufficient spare capacity will be available well beyond the 20 year planning period, especially with continuation of an aggressive program to eliminate inflow and infiltration. The Town and Village of Lansing service areas can be sewered without the need to construct additional treatment capacity, resulting in substantial savings to all M users. Improvements to the water quality in the southern basin of the Lake will require more than the commitment of those responsible for the operation of the WWTPs. Stream erosion and agricultural runoff are being addressed in the Town of Caroline, and the Tompkins County Water Resources Council, the Cayuga Lake Watershed Network and Intermunicipal Organization are actively pursuing and coordinating monitoring efforts throughout the region. (N. Desch in 819103 letter) 84. Comment: The DEIS is adequate. Village of Lansing history shows growth in malls, subdivisions and offices will occur with or without sewers. Adequate sewage facilities will only benefit Cayuga Lake. The project is a good use of resources and a cost effective plan. Self-government is preserved, with each municipality defining costs, growth and location of future sewers. The need for this project started in 1987 with a temporary moratorium by the VCHWTP. There has been much effort and discussion since then, and there is no need for further study. (J. Majeroni, Cornell University, Real Estate at 7131103 Public Hearing) 85. Comment: The project should go forward. Home prices are very high because of low inventory. New construction resulting from the project would lead to more moderate prices. In the 23 years this commenter has been in the real estate business, this commenter has never seen a problem with public sewer systems but has seen many problems with septic systems come up at real estate closings. The added cost of a septic system is about $10, 000. This adds a lot to the price of a home. Public sewers would make it better for everyone. (A. Edelman, Audrey Edelman & Associates Real Estate at 7131103 Public Hearing) 86. Comment: This commenter stated he echoes Ms. Edleman's comments about the need for housing. This commenter built a house on Horizon Drive and extended the municipal sewer pipe to his home because he was close enough to do so. One of his neighbors paid $10, 000 for a septic system. Neighbors have had problems with septic systems, including septic systems backing up and flooding their basements. There are current proposals for two subdivisions with more than 180 houses in Lansing. There is a need for housing, and more sewage will be created. With the amount of local vacant land, there could be more than 1,000 homes built with septic systems, with untreated waste just injected into the ground. There is a need to move forward with public sewers and treat the sewage. (G. Sloan at 7131103 Public Hearing) 41 Stearns & Wheler, LLC TABLE F-1 Environmental Engineers and Scientists WWTP TOTAL PHOSPHORUS (TP) LOADING DISCHARGED TO SOUTH END OF CAYUGA LAKE IAWWTP EFFLUENT TP (LBS/DAY) VCHWTP EFFLUENT TP (LBS/DAY) COMBINED WWTP W/ LANSING (T) EFFLUENT TP (LBS/DAY) REDUCTION PERCENT YEAR (1) ACTUAL FUTURE (4) ACTUAL FUTURE (7) ACTUAL FUTURE FROM TOTAL IN TP LOAD REDUCTION IN PERMITTED ANNUAL (3) PERMIT PERMITTED ANNUAL (6) PERMIT PERMITTED ANNUAL (9) PERMIT LANSING (T) COMBINED TP (12) TO LAKE (13) TP TO LAKE AVERAGE(2) AVERAGE(5) AVERAGEM (10) LOADINd") 1999 83.4 27 9.3 16.7 6.5 2.6 100.1 33.5 11.9 0.24 12.14 21.36 64 2000 83.4 32 11.6 16.7 10.7 3.1 100.1 42.7 14.7 0.24 14.94 27.76 65 2001 65.3 33 10.2 16.7 11.8 3.1 82.0 44.8 13.3 0.24 13.54 31.26 70 2002 40.0 26 10.8 16.7 8.1 2.6 56.7 34.1 13.4 0.24 13.64 20.46 60 2003* 40.0 23 11.6 16.7 11.9 3.2 56.7 34.9 14.8 0.24 15.04 19.86 57 * Through August 2003. 1, 4, & 7. Allowable phosphorus loading under SPDES permit in effect during each year. 2, 5, & 8. Actual phosphorus loading based on effluent sampling at each plant. 3, 6, & 9. Amount of phosphorus loading that would have been discharged if future permit conditions of 0.2 mg/L for phosphorus were in effect. 10. Amount of phosphorus loading as a result of collecting sewage in the Town of Lansing and treating it to a 0.2 mg/L effluent total phosphorus concentration at the VCHWTP. 11. Sum of columns 9 and 10, which represents the total phosphorus loading to the Lake from the region (including the Town of Lansing) proposed to be served by the IAWWTP and VCHWTP under future permit conditions of 0.2 mg/L effluent phosphorus concentrations. 12. Column 8 minus column 11, which represents the reduction in phosphorus loads to the Lake, if all the flow is treated to a 0.2 mg/L effluent total phosphorus concentration. 13. Column 12 divided by column 8 and expressed as a percentage. Represents the overall actual reduction in phosphorus loading to Cayuga Lake (approximately 65%). ♦.C:\DOCUME-I\mmssell\LOCALS-l\Temp\FEIS Table F-I Ldoc /`06 Stearns& Wheler Companies t 1 WATER QUALITY IMPROVEMENT PROJECTS - CLEAN WATER/CLEAN AIR BOND ACT APPLICATION FOR STATE ASSISTANCE PAYMENTS FOR SFY 2000/01 Part A - A licant Information , .. PP .. . ,.,... .. ...... ,: :ems', . , ..... ..... •:� 1. Applicant Municipality: 4. Contact Person: IDominick Cafferillo/Larry Fabbroni OCityOTownO VillageDOther (specify) I Iof lIthaca, New York 5. Phone:1(607) 274-6577 �ax:1607-272-7348 2. Municipal Federal Id Number 1156000407 116. Contact Mailing Address (if different from applicant): 3. Applicant Mailing Address: (no. & street)1510 First Street (no. & street) 1 108 East Green Street I I (citY]Ithaca Kstate) 0 (Zip)I 14850 (citY)JIthaca IN-Y. (Zip)I PartB General Project.Informatioin . 1. Project Name: IMunicipal WW Collection & Treatment System Additions & Improv. for the Ithaca Area 2. Project Location(s) And Zip Codes: 0✓ City [Town QVillage of 1Ithaca (C), Ithaca (T), Dryden (T), Lansing (T), County of: ITompkins OCity OTown QVillage of Cayuga Heights (V), Lansing (V) Zip Code(s) : 114850, 13053, 14882 �IUSGS 7.5' Quad Map (or copy) Attached Ov i latitude and longitude : (see attached) 11iydrologic Unit Code (HUC):104140201 3. Project Type: Select ONE of the following five (5) Project Types ONLY Wastewater Treatment Improvement E) Nonpoint Source Pollution - Nonagricultural (NPS) ®Aquatic Habitat Restoration (AHR) Pollution Prevention ®AHR/NPS (see instructions, page ii) 4. Management Program, Plan or Project Area(s): 7-Hudson River Onondaga Lake ✓❑Finger Lakes pLong Island Sound ONY-NJ Harbor Estuary OPeconic Estuary Program OLake Champlain F1 Great Lakes 0 South Shore Estuary Reserve i QPopulations <75,000 (WWT Proiects Only) E Statewide Nonagricultural NPS (EPF, PPG) 5. Existing Clean Water State Revolving Loan Fund Project # IC7-6382; C7-6387; 6-6392 .11 Bond Act/EPF/PPG August 2000 2 Application for State Assistance Payments for Water Quality Improvement Projects Part C - Pro ect"Tiiniri "And Costs 3 g 1. Proposed Start Date: (November 6, 1996 1 ^3. State Funds Requested** 1$ 6,384,500.001 2. Expected Completion Date:'*see schedule I * Refer to project schedule (attached) for 4. Local Match*** 1 $ 8,788,000.001 completion dates of each project component. - ** Does not include $2,417,500 Bond Act 5. Total Project Costs $ 1 17,590,000.001 funding previously committed to this project, refer to Project Finance Summary Table for details of previously committed funds. ^ State Funds RequestedforWastewater Treatment (attached) NOTE: The dollar amounts you enter for questions 3-5 should be the same as those entered on page 6 of this application Improvement Projects May Not Exceed 85% of the Total form (Part G, Funding Sources) Construction Costs *** Includes $1.5 million private grant for Tom o Part D - Project"Siimmarv.`: Provide a brief summary statement (1-2 sentences ) that describes the following': • the name and value 2 of the affected waterbody(ies) • the water quality and/or aquatic habitat impairment (i.e., fish consumption advisories, beach closures, habitat impairment from land use and hardening of shorelines, etc.) • the name of the priority pollutant(s)or disturbance(s) causing the impairments • the source(s) of priority pollutants or disturbances causing the impairment • what will be constructed the expected environmental benefit In a cooperative effort by the City of Ithaca, Villages of Cayuga Heights and Lansing, and the Towns of Dryden, Ithaca, and Lansing, wastewater collection and treatment facilities will be constructed to minimize public health concerns due to failing on -site systems, to reduce non -point source pollution in the watershed and to reduce the amount of phosphorus discharged into Cayuga Lake , a Class A (southerly tip) and Class AA water, which provide drinking water to over 25,000 residents and institutions and industry in Tompkins County. The project includes extending sewer service to the Town of Lansing (to eliminate failing septic systems) and providing needed capacity for the Village of Lansing, construction of trunk sewers to direct flows to regional treatment plants, installation of intercepting sewers to eliminate wet weather overflows and construction of j advanced treatment facilities for phosphorus removal, the most significant cause of algal blooms in the south end of Cayuga Lake. ' Example: The City of Kingston will construct a wastewater pretreatment and diversion chamber to minimize the amount of wastewater diverted to Rondout Creek, a tidal tributary of the Hudson River. The project will reduce the amount of pathogen -laden discharges from combined sewer overflows that enter the creek, a nursery for many species of fish. Z For a state -designated wetland, provide the designation number. For surface water. describe classified best use (i.e., high quality drinking water, shellfish waters, contact recreation, trout or trout propagation waters, etc.). For a groundwater resource, indicate if it is a primary water supply aquifer and/or supplying private wells. For aquatic habitat, provide the names of specific fish and wildlife species and how they could use the habitat (i.e., spawning, nursery, migratory, etc.). Bond Act/EPF/PPG August 2000 Application for State Assistance Payments for Water Quality Improvement Projects J , r. i- ' ,—, a .. - PartE Certrficahon. ,�s I hereby affirm under penalty of perjury that information provided on this form and attached statements and exhibits is true to the best of my knowledge and belief. False statements made herein are punishable as a Class A misdemeanor pursuant to Section 210.45 of the Penal Law. (title) I City Controller lof (entity) JCity of Ithaca (date) (signature) (print name) IDominick R. Cafferillo h Part F - Project De tails Describe the location of the project' (street address, proximity to the affected waterbody, and identifiable landmarks), what will be constructed to improve water quality4 or restore aquatic habitats (include dimensions, specifications, etc.) , and the approved Best Management Practices (BMPs) and/or Best Available Technologies to be used For point source projects involving distinct components or multiple locations, name each and describe each phase or component separately. For nonpoint source and aquatic habitat restoration projects covering separate waterbodies or watersheds, fill out a separate application form for each. Please see attached "Part F - Project Details," consisting of four (4) pages. Refer to Project Location and Summary Table (attached). 'For point source projects, provide the location(s)of the discharge(s). J 4 For salt storage sheds, include the dimensions of the building, the amount of salt/sand that will be stored, and any other intended uses of the building. f 'Example: The project site is 2.1 acres on which 1.75 acres of tidal marsh will be restored by removing 25,000 cubic yards of dredge spoil and planted with Spartina alterniflora - 3 per square foot.) 9 PART F - PROJECT DETAILS The project consists of wastewater treatment improvements to the two regional treatment plants (Cayuga Heights WWTP and Ithaca Area WWTP) and the collection systems as described below: • Town of Lansing Municipal Sewer Collection System - The purpose of this phase of the overall project is to collect sanitary sewage from the Town of Lansing service area (all unsewered area currently) for treatment at the VCHWWTP and IAWWTP. This project will eliminate ground and surface water contamination caused by inadequate septic systems and poor soils. In addition, it will eliminate individual point source discharges by residential, commercial, industrial, and institutional facilities that currently hold SPDES permits in the Town of Lansing sewer service area. The individual phases are described below. Transmission Main to Cayuga Heights Wastewater Treatment Plant - Construction of approximately 12,000 linear feet of 21-inch diameter PVC piping and 7,700 linear feet of 24-inch diameter PVC piping southward along State Route 34 (East Shore Drive) from the Town of Lansing service area to the VCHWTP. The construction work is proposed to be completed in September 2002. The estimated construction costs are $2,350,000. Bond Act committed is $1,020,000. An additional $680,000 is required to implement this portion of the project. • Collector Sewers - 10" and 12" Mains - South Lansing Service Area - Construction of approximately 3,300 linear feet of 10-inch PVC interceptor sewer and approximately 4,900 linear feet of 12-inch PVC interceptor sewer. The construction work is proposed to be completed by the end of 2002. The estimated construction costs are $1,880,000. No Bond Act funding has been awarded or committed, $1,360,000 of funding is critical for this portion of the project to proceed. • Collectors and Lateral Sewers - South Lansing Area. Construction of approximately 3,900 linear feet of 4-inch PVC sewer laterals, and 52,000 linear feet of 8-inch PVC collector sewers. The construction work is proposed to be completed by the end of 2002. The estimated construction costs are $3,200,000. Bond Act funding has not been requested for this project element. Need for Wastewater Collection and Treatment in the Town of Lansing. Physical Aspects — Cayuga Lake is the western boundary for the Town of Lansing, and the steep slopes rising from the lakeshore and much(?) [all?] of the rest of the Town drains into Cayuga Lake. Ground surface topography within the Planning Area is very i steep, the depth to bedrock is very shallow and soil drainage characteristics are very poor. Raised systems are often necessary where soil drainage is poor and there is a shallow bedrock depth. Poor soil drainage characteristics necessitate larger systems with higher construction cost and lead to potential system problems, which result in �I premature system failure. Such failures contaminate Cayuga Lake, which provides drinking water for a large number of County residents. I Application for State Assistance Payments City of Ithaca, New York Prepared by: Steams & Wheler 1:\8000\8031811\Wonlpnoc\Misc\Bond Act ApplicationTART F of Bond Aa Applimtion.doc Benefited properties in the new Town sewer district will repay the annual debt for the SRF loan plus treatment, operation and maintenance charges. To achieve for a single- family residence a total annual target service charge of $553, inclusive of debt and treatment charges, it is imperative the Town succeeds in securing at least $1.2 million in additional grant funds from the Clean Water/Clean Air Bond Act. • Village of Cayuga Heights Wastewater Treatment Plant - The purpose of the improvements to the Cayuga Heights Wastewater Treatment Plant described below is to significantly reduce the amount of phosphorus discharged from the plant to Cayuga Lake. �- Cayuga Heights Wastewater Treatment Plant, Filtration - Installation of an innovative high rate flocculated settling process (BAT) for enhanced phosphorus removal. Total phosphorus concentrations in the final effluent discharged from the plant is anticipated to be reduced to 0.2 mg/l on a 12-month, 30-day rolling average, an 80 percent reduction of the current permitted limit of 1.0 mg/l. The proposed C completion date for the construction work is December 2002. The estimated construction costs are $1,500,000. The amount of Bond Act funding required is $1,020,000 to implement this portion of the project. No funding has been received. This project element is dependent on funding to proceed. • Ithaca Area Wastewater Collection System and WWTP Improvements - The purpose of this element of the overall project is to improve wastewater collection and treatment at the IAWWTP. Two interceptor and collector sewer improvement phases have already been completed. Construction of a new wastewater treatment plant grit removal system will occur if funding becomes available, since it will reduce grit loading and improve facility operations by reducing equipment maintenance. Construction of a new phosphorus removal system using the innovative high rate flocculated settling technology (BAT) will occur if funding becomes available. The third collector and interceptor sewer phase will be implemented if funding becomes i available, since it will improve conveyance of wastewater to the IAWWTP and eliminates wet weather overflow. The various phases are described in more detail below. ➢ Wastewater treatment plant upgrade consisting of a new grit removal system. ➢ Installation of a high rate chemically enhanced flocculated settling system within 1 one of the two existing 60-foot diameter unused tanks at the Ithaca Area WWTP. This innovative process will be capable of treating up to 13.1 mgd (average annual) and 30 mgd of wastewater flow on a peak hourly basis to significantly reduce effluent phosphorus concentrations. Total phosphorus concentrations in the final effluent discharged from the plant are anticipated to be less than 0.2 mg/l on a 12-month, 30-day rolling average basis, an 80 percent reduction of the current permitted limit of 1.0 mg/l. Rehabilitation of existing collector and interceptor sewers to reduce sewer overflows resulting from excessive infiltration and inflow. Application for State Assistance Payments City of Ithaca. New York Prepared by: Steams & Wheler 1:\8000\8031811\WordpmcUtisc\3ond Act Applic tionNAAT F of Bond Am Applitation.doc diversion to North Titus Avenue overflow structure, pump station rehabilitation and 3,500 linear feet of sewer lining interceptor sewer lining, Third Street to Cayuga Street, 6,000 linear feet of 24-inch sewer lining new siphon at old inlet, 24-inch to 30-inch siphon reline siphon under flood channel, 3,000 linear feet South Hill interceptor, Cayuga Street to Renbetti Street, 3,000 linear feet of sewer • State Street interceptor, Mitchell Street to Cayuga Street, 3,400 linear feet of sewer • miscellaneous improvements. The proposed completion date for the construction work is December 2001 for the phosphorus removal project, December 2002 for the grit removal project, and �- February 2002 for the interceptor improvement project. The total estimated - project costs are $8,660,000. The amount of Bond Act funding that has been committed is $1,397,500 for the phosphorus removal project. Additional funding required is $612,000 for grit removal, $1,152,500 for phosphorus removal filtration, and $1,560,000 for Phase 3 interceptor and collector sewer improvements. This level of funding is required if these project elements are to proceed. Application for State Assistance Payments City of Ithaca, New York Prepared by: Steams & Wheler P\80001803181 I\Wordpmc\Miscc\Bond Act ApplirationTART F of Bond Ad Applimtion.doc On -Site Septic Systems - The physical characteristics of the Planning Area are not conducive for on -site septic systems, and, together with the availability of public water in large portions of the Planning Area, septic systems are stressed. According to the Tompkins County Health Department there have been over 60 septic system replacements in the last 8 years just within the initial service area in Lansing. The Health Department states the Ladoga Park area, which has numerous homes on the east shore of Cayuga Lake, has "severe limitations for on -site systems due to flooding and inadequate separation distance to surface waters." The successful completion of Collector and Lateral Sewers in the Myers Road Area will ensure these severe conditions are eliminated. Other problematic conditions (failed septic systems) known by the Health Department include the Atwater Road Mall, the Lansing Inn, the Rogues Harbor Inn, the Lansing Pizza Restaurant and Colonial Cleaners. The Elementary, Junior High and Senior High schools of the Lansing Central School District altogether discharge nearly 17,000 gallons of septic effluent per day to adjacent surface waters [Salmon Creek Class C (TS)] using four sand filters of varying sizes built between 1958 and 1973. The Health Department states, "These systems are getting old, and may need significant work in the near future. If they are not served by a municipal sewer system, we advise that the School District apply for the SPDES permits." The completion of the South Lansing Collector Sewers will facilitate the abandonment of the School District systems. Other permitted septic systems that will be abandoned once the South Lansing Area Collector Sewers are available include: Facility System Size Discharging To ` Lansing Central Fire Station 2,000 gpd Raised System Groundwater Colonial Cleaners 2,000 gpd Raised System Groundwater Hunter Apartments 3,000 gpd Raised System Groundwater Lakewatch Inn 4,000 gpd Sand Filter/Trench Groundwater _ NYS Division for Youth 50,000 gpd RBC, settling, Bowers Creek filtration Cargill, Inc. 6,000 gpd Aeration package plant Cayuga Lake Woodsedge Apartments 6,000 gpd Unnamed Surface Water Financing Project Cost - The project cost for the necessary components of the Town of Lansing sewer system is approximately $11.3 million. This figure represents nearly half of the entire regional project budget. To be economically viable the Town's project must secure at least $7.0 million in grant funds from various sources. Having received a commitment to date of $3.5 million from the Environmental Bond Act the Town is well on its way to achieving the goal. Additionally, the Town will be able to leverage a $1.5 million grant from the private sector should the regional project be approved and the Town sewer district established. Therefore, the balance of grant funds needed from the i Bond Act in order for the Town to proceed with the regional project is approximately $2.0 million. The remaining local share of $4.3 million ($5.8 million less $1.5 private sector grant) would be financed through the Clean Water State Revolving Fund. Application for State Assistance Payments City of Ithaca, New York Prepared by: Steams & Wheler 7:\8000\8071811\Wotdpmc\Misc\Bond Act Applim ionNART F of Band Act Appliotion.doc A-5 Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS PROJECT LOCATION AND SUMMARY BOND ACT APPLICATION MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA PROJECT`COW,ONENT ,: ' ., : LOCATION "" AFFECTED FACILITIES TO IMPROVE WATER f -. , , %WATERBODY QUALITY .' 10" and 12" Sewer Mains Lansing (T) Salmon Creek, 8,200 feet of 10" and 12" - South Lansing Cayuga Lake interceptor sewers Collector Sewers - South Lansing (T) Salmon Creek, 52,000 feet of 8" collector sewers Lansing Cayuga Lake and 3,900 feet of 4" laterals VCHWWTP Phosphorus Cayuga Heights Cayuga Lake I High rate flocculated settling for Removal (V) effluent phosphorus removal IAWWTP Grit Removal Ithaca (C) Cayuga Lake Vortex type grit removal facilities IAWWTP Phosphorus Ithaca (C) Cayuga Lake + High rate flocculated settling for Removal I effluent phosphorus removal IAWWTP - Phase 3 Ithaca (C) Cayuga Lake, 6,400 feet of new interceptor, Interceptor Improvements Six Mile Creek, 12,500 feet of interceptor and Cayuga Inlet siphon lining, and pump station rehabilitation J:\8000\803181 I\ WordprocWisc\Bond Act ApplicationTroject Location and Su=ary.doc 1A-\ Stearns &Wheler ^'ponies 4 Part G -.Project Budget And Funding Sources - Use, Only For Wastewater,, Treatmenthnprovenient,Projects • Proiect Budget: Fill in the proposed budget sheet below. In cases where a project involves multiple components, use a conv of this budget sheet to provide a budget breakdown for each component, or for each geographic area where work will be performed. Name of Project Component from Part F - Project Description(if applicable): (Lansing Sewers (10"&12" mains) (Critical) Expenditure Category Requested @ Sources Tota • ^State Funds Local Match Other Funding1 1. Construction Costs $1,360,000.00� $240,000.00 I I $1,600,000.001 2. Personal Services - for construction portion of the project (i.e., Municipal Personnel) a. Salaries, Wages & Fringe Benefits Total 3. Nonpersonal Services- for construction portion of the project a. Travel b. Equipment c. Supplies & Materials d. Other (please specify) �Eng., Fiscal &Legal Cost I I $280,000.00� ' $280,000.00 Total� 4. Total - All Categories $1 1,360,000.001 $1 520,000.001 • $1 1 $ I 1,880,000.001 I State Funds refers to assistance from Water Quality Improvement Project Bond Act, Environmental Protection Fund, or PPG implementation ^ For Wastewater Treatment Improvement Projects, the state funds requested may not exceed 85% of the total construction costs * The Bond Act prohibits using other state or federal grant dollars received for the project for the local match of the project @ Includes previous Bond Act funding committed for this project • If the project will receive funding from another source, fill out the table on page 6 r 4 Part G : Project Budget And Funding Sources -,Use Only, For .Wastewater=Treattnent,bnprovement Projects',' • Proiect Budeet : Fill in the proposed budget sheet below. In cases where a project involves multiple components, use a cony_ of this budget sheet to provide a budcet breakdown for each component, or for each geographic area where work will be performed. Name of Project Component from Part F - Project Description(if applicable): Lansing Collector Sewers-S.Lansing Area - ^State Funds * Local Match @Other Funding Total Expenditure Category Requested Sources (�rivata 1 1. Construction Costs I I $1,220,000.001 1 $1,500,000.001 1 $2,720,000.001 2. Personal Services - for construction portion of the project (i.e., Municipal Personnel) a. Salaries, Wages & Fringe Benefits Total I - 3. Nonpersonal Services- for construction portion of the project a. Travel b. Equipment c. Supplies & Materials d. Other (please specify) �Eng., Fiscal&Legal Fees Total 4. Total - All Categories $1 I I I I $480,000.001 1 1 I $480,000.001 $' 1,700,000.001 - $1 1,500,000.001 $ I 3,200,000.001 , State Funds refers to assistance from Water Quality Improvement Project Bond Act, Environmental Protection Fund, or PPG implementation ^ For Wastewater Treatment Improvement Projects, the state funds requested may not exceed 85% of the total construction costs * The Bond Act prohibits using other state or federal grant dollars received for the project for the local match of the project @ Includes previous Bond Act funding committed for this project . If the project will receive funding from another source, fill out the table on page 6 0 Part G - Project Budget And Funding Sources -Use, Only For.Wastewater Treatment Irnprovement Projects • Proiect Budget: Fill in the proposed budget sheet below. In cases where a project involves multiple components, use a conv of this bude_ et sheet to provide a budget breakdown for each component, or for each geographic area where work will be performed. Name of Project Component from Part F - Project Description(if applicable): ILansing Trans. Main to CHWWTF Critical Component Expenditure Category - ^State Funds Requested * Local Match @Other Funding Sources Total 1. Construction Costs 1 $680,000.001 1 $300,000.001 1 $1,020,000.001 ' $2,000,000.00� 2. Personal Services - for construction portion of the project (i.e., Municipal Personnel) a. Salaries, Wages & Fringe Benefits Total I I I I 3. Nonpersonal Services- for construction portion of the project a. Travel b. Equipment c. Supplies & Materials d. Other (please specify) 'Eng., Fiscal &Legal Cost Total� $350,000.00� (' $350,000.00 4. Total - All Categories $ 680,000.001 $ I 650,000.001 $1 1,020,000.001 $ 1 2,350,000.001 State Funds refers to assistance from Water Quality Improvement Project Bond Act, Environmental Protection Fund, or PPG implementation ^ For Wastewater Treatment Improvement Projects, the state funds requested may not exceed 85% of the total construction costs * The Bond Act prohibits using other state or federal grant dollars received for the project for the local match of the project @ Includes previous Bond Act funding committed for this project • If the project will receive funding from another source, fill out the table on page 6 4 Part G - Project Budget And Funding Sources r. Use Only For Wastewater Tredtmentlmprovenzent Projects • Proiect Budget: Fill in the proposed budget sheet below. In cases where a project involves multiple components, use a conv of this budge et sheet to provide a budget breakdown for each component, or for each geographic area where work will be performed. Name of Project Component from Part F - Project Description(if applicable): (Cayuga Heights WWTP Advanced Phosphorus Removal - ^State Funds * Local Match @Other Funding Total Expenditure Category Requested Sources 1. Construction Costs I $1,020,000.001 I $180,000.001 I ( $1,200,000.00 2. Personal Services -for construction portion of the project (i.e., Municipal Personnel) a. Salaries, Wages & Fringe Benefits Total I I I I I I I 3. Nonpersonal Services- for construction portion of the project a. Travel b. Equipment c. Supplies & Materials d. Other (please specify) Eng., Fiscal &Legal Cost Total $300,000.00I $300,000.00 1 4. Total - All Categories $ I 1,020,000.001 $1 480,000.001 $1 1 $' 1,500,000.001 State Funds refers to assistance from Water Quality Improvement Project Bond Act, Environmental Protection Fund, or PPG implementation ^ For Wastewater Treatment Improvement Projects, the state funds requested may not exceed 85% of the total construction costs * The Bond Act prohibits using other state or federal grant dollars received for the project for the local match of the project @ Includes previous Bond Act funding committed for this project • If the project will receive funding from another source, fill out the table on page 6 .19 Part G - Project Budget And Funding Sources - Use Only For Wastewater -Treatment Improvement Projects • Proiect Budget: Fill in the proposed budget sheet below. In cases where a project involves multiple components, use a con_ v of this bude_ et sheet to provide a budget breakdown for each component, or for each geographic area where work will be performed. Name of Project Component from Part F - Project Description(if applicable): Ithaca Area WWTP Grit Removal System - ^State Funds * Local Match @Other Funding Total Expenditure Category Requested Sources 1. Construction Costs $612,000.001 1 $108,000.001 1 1 $720,000.001 2. Personal Services - for construction portion of the project (i.e., Municipal Personnel) a. Salaries, Wages & Fringe Benefits Total I I I I 3. Nonpersonal Services- for construction portion of the project a. Travel b. Equipment c. Supplies & Materials d. Other (please specify) IEng., Fiscal &Legal Cost Total ' I $280,000.00� $280,000.001 4. Total - All Categories $ I 612,000.001 $1 388,000.001 $1 1 $ I 1,000,000.001 • State Funds refers to assistance from Water Quality Improvement Project Bond Act, Environmental Protection Fund, or PPG implementation ^ For Wastewater Treatment Improvement Projects, the state funds requested may not exceed 85% of the total construction costs * The Bond Act prohibits using other state or federal grant dollars received for the project for the local match of the project @ Includes previous Bond Act funding committed for this project • If the project will receive funding from another source, fill out the table on page 6 Part G - Project Budget And Funding Sources Use Ohly'For'Wastewater TreonentlrnprovetnentProjects • Proiect Budget: Fill in the proposed budget sheet below. In cases where a project involves multiple components, use a cony of this budget sheet to provide a budget breakdown for each component, or for each geographic area where work will be performed. Name of Project Component from Part F - Project Description(if applicable): Ithaca Area WWTP - Phosphorus Removal - ^State Funds * Local Match @Other Funding Total Expenditure Category Requested Sources 1. Construction Costs I $1,152,500.001 I $450,000.001 1 $1,397,500.001 1 $3,060,000.001 2. Personal Services - for construction portion of the project (i.e., Municipal Personnel) a. Salaries, Wages & Fringe Benefits Total I I I I 3. Nonpersonal Services- for construction portion of the project a. Travel b. Equipment c. Supplies & Materials d. Other (please specify) Eng., Fiscal & Legal Cost $750,000.00 Total� 4. Total - All Categories $ I 1,152,500.001 $ I 1,200,000.001 ' $1 1,397,500.001 $' 3,750,000.001 • State Funds refers to assistance from Water Quality Improvement Project Bond Act, Environmental Protection Fund, or PPG implementation ^ For Wastewater Treatment Improvement Projects, the state funds requested may not exceed 85% of the total construction costs * The Bond Act prohibits using other state or federal grant dollars received for the project for the local match of the project @ Includes previous Bond Act funding committed for this project • If the project will receive funding from another source, fill out the table on page 6 4 Part G - Project Budget And Funding Sources.- Use, Only For-, Wastewater,�TreatmentTmprovement Projects • Proiect Budget: Fill in the proposed budget sheet below. In cases where a project involves multiple components, use a con_ v_ of this budget sheet to provide a budaet breakdown for each component, or for each geographic area where work will be performed. Name of Project Component from Part F - Project Description(if applicable): Ithaca Phase 3 Inter./Collect. System Improvements - ^State Funds * Local Match @Other Funding Total 1 Expenditure Category Requested Sources 1. Construction Costs $1,560,000.001 I $1,855,000.001 I 1 $3,415,000.001 2. Personal Services - for construction portion of the project (i.e., Municipal Personnel) a. Salaries, Wages & Fringe Benefits Total $195,000.001 1 I I $195,000.00 3. Nonpersonal Services- for construction portion of the project a. Travel b. Equipment c. Supplies & Materials d. Other (please specify) �Eng., Fiscal &Legal Cost $30,000.00I I $30,000.00 Total� 4. Total - All Categories $ 1,560,000.001 $1 ' $ I $' 3,910,000.001 • State Funds refers to assistance from Water Quality Improvement Project Bond Act, Environmental Protection Fund, or PPG implementation ^ For Wastewater Treatment Improvement Projects, the state funds requested may not exceed 85% of the total construction costs * The Bond Act prohibits using other state or federal grant dollars received for the project for the local match of the project @ Includes previous Bond Act funding committed for this project - If the project will receive funding from another source, fill out the table on page 6 Bond Act/EPF/PPG August 2000 6 Application for State Assistance Payments for Water Quality Improvement Projects Funding Sources: Funding Source, ' Granit/L6an V Type •' `Status of Pimount (1}ederai; State; T;ocgl` Fillldln Private} Rural Development Housing and Urban Development Clean Water SRF Long -Term Loan JLoan State $7,288,000.001 Other Bond Act Funds (e.g. Parks and Recreation, Brownfields) JGrant State A . *$6,384,500.001 Other Sources -Private Grant Grant I Private 1 JA 1 1 $1,500,000.001_ TOTAL $1 17,590,000.0011 • Use the following to indicate status: I- Intend to apply to the supplemental or alternative funding source P -Have applied to the supplemental or alternative funding source, but have not received a commitment A - Have received a commitment from the supplemental or alternative funding source. * Does not include $2,417,500 Bond Act funds previously committed to this project. Part H-aDocumentation of.Water. Quality or Aquatic Habitat Impairment. Cite documentation of a water quality impairment such as NYS DEC Priority Waterbodies List (PWL) listing, County Health Department violations, a report or study indicating a violation of water quality standards, assessments in wildlife management plans, wildlife and/or habitat restoration plans, etc. where applicable. See attached "Part H - Documentation of Water Quality or Aquatic Habitat Impairment," consisting of one (1) page. If the waterbody is listed on the NYS DEC Priority Waterbodies List (PWL), write the identification number below and include the one page Waterbodv Data Sheet from the PWL. (The PWL is available at all County Soil and Water Conservation District and DEC Regional offices). PWL Segment #: 10705-0040 1 PART H - Documentation of Water Quality or Aquatic Habitat Impairment I Southern Cayuga Lake is classified as Class A, with a designated best (and actual) use for water supply following coagulation, sedimentation, and filtration. This region of Cayuga Lake is heavily used for boating and other water contact recreation. The Allen H. Treman State Marine Park is located in the water segment affected by the proposed project. Cayuga Lake supports two distinct fish communities: a littoral zone warm water community and a cold water community dominated by lake trout, rainbow trout, brown trout, and landlocked Atlantic salmon. Rainbow trout and salmon travel through shallow southern Cayuga Lake on their annual spawning migrations to the southern tributaries. Currently, the southern end of Cayuga Lake receives the bulk of the pollution entering the lake. However, according to the Upstate Freshwater Institute (July 2000), water retention in the southern end of the lake is about two weeks versus approximately 15 years for the lake as a whole. Therefore, discharges to the southern end of the lake have a lengthy, prolonged impact on the entire lake. See attached PWL datasheets for information on impairments to swimming, fisheries, and water supply. Application for State Assistance Payments Page 1 of 1 Pages City of Ithaca, New York Prepared by: Steams & Wheler M8000\8031811\wordpmdMis6Bond An AppUm ionTART H of Bond An Appliodomdoc Bond Act/EPF/PPG August 2000 Application for State Assistance Payments for Water Quality Improvement Projects Pa# I-, C oordinated Approach 1. Indicate the priority in a Management Plan or Program that the project will address (Refer to Appendix 2 in the Updated Information for Applicants pages A-S thru A-26) No specific priorities have been identified for the Finger Lakes since there is no Management Plan for this area. However, the Cayuga Lake Watershed Intermunicipal Organization (IO), which represents 26 municipalities and is the group responsible for overseeing the development of the Cayuga Lake Watershed Management Plan, has ranked this project as the highest priority in the watershed. The IO supports this project and acknowledges its potential to benefit Cayuga Lake (see attached). 2. Explain how the project contributes to a comprehensive and coordinated approach to solving water quality impairments and/or restoring aquatic habitat. Include a brief description of how the project is consistent with water quality policies or recommendations in other plans (i.e., County Water Quality Strategy; an approved Watershed Management Plan; Local Waterfront Revitalization Program; NYS Coastal Nonpoint Pollution Control Program; DEC approved species or habitat management plan or project, and/or New York State's Open Space Conservation Plan). See attached "Part I - Coordinated Approach" item 2 attached consisting of one (1) page. I Part J•-:Fr-oject.Readiness, 7 1. State Environmental Quality Review (SEQR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? 0 Type I ®Unlisted ®Type H • Has the environmental review/SEQR process been commenced? ® Y () N ® N/A (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement I • Has a lead agency been designated? ®Y ON ®N/A If YES, provide the name of the lead agency: and the date the agency was designated: • Has a detemiination of significance been made by the lead agency? ® Y ON ®N/A If YES, circle the appropriate response to the following: Negative Declaration? ® Y ® N Positive Declaration? ® Y ® N Has the draft Environmental Impact Statement been accepted? ® Y ® N Has the final Environmental Impact Statement been accepted? ®Y ON C] Bond Act/EPF/PPG August 2000 7 Application for State Assistance Payments for Water Quality Improvement Projects P -, Coordinated,Approach 1. dicate the priority in a Management Plan or Program that the project ddress (Refer to App ix 2 in the Updated Information for Applicants pages A-S thru A- 2. Explain how the project contributes omprehensive and coordinated approach to solving water quality impairments and/or bring aqua ' bitat. Include a brief description of how the project is consistent with w er quality policies or commendations in other plans (i.e., County Water Quality Strate , an approved Watershed Mana ent Plan; Local Waterfront Revitalization Pr ram; NYS Coastal Nonpoint Pollution of Program; DEC approved species or h itat management plan or project; and/or New Yor ate's Open Space Conse tion Plan). Part J; -Project Readiness: Collector Sewers Tq"-12" Mains, S.� Lansing Service Area (T of Lansing) 1. State Environmental Quality Review (SEQR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? ® Type I Unlisted OType H • Has the environmental review/SEQR process been commenced? S Y ®N O N/A (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement' • Has a lead agency been designated? G Y ®N ®N/A If YES, provide the name of the lead agency: INYSDEC and the date the agency was designated: • Has a determination of significance been made by the lead agency? ® Y G) N ®N/A If YES, circle the appropriate response to the following: Negative Declaration? 0 Y ® N Positive Declaration? ® Y 0 N Has the draft Environmental Impact Statement been accepted? ® Y ® N Has the final Environmental Impact Statement been accepted? 0 Y ON Bond Act/EPF/PPG August 2000 Application for State Assistance Payments for Water Quality Improvement Projects Coordinate- P' d A roach Imo- pp. ... ,. .... ... 1. dicate the priority in a Management Plan or Program that the project address (Refer to App ix 2 in the Updated Information for Applicants pages A-5 thru 6 2. Explain how the project contribute comprehensive and coordinated approach to solving water quality impairments and/or toning aq ' habitat. Include a brief description of how the project is consistent with er quality policies o ecommendations in other plans (i.e., County Water Quality Strate , an approved Watershed Man ment Plan; Local Waterfront Revitalization P am; NYS Coastal Nonpoint Pollution trol Program; DEC approved species or itat management plan or project; and/or New Yo tate's Open Space Conse tion Plan). Part'J - Project Readiness: Collectors and Lateral Sewers South Lansing Area (Town of Lansing) 7 1. State Environmental Quality Review (SEQR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? ® Type I Unlisted ®Type H • Has the environmental review/SEQR process been commenced? e Y ®N ®N/A (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement I I • Has a lead agency been designated? E) Y ®N C)N/A If YES, provide the name of the lead agency: INYSDEC and the date the agency was designated: • Has a determination of significance been made by the lead agency? ®Y G N ®N/A If YES, circle the appropriate response to the following: Negative Declaration? ® Y ® N Positive Declaration? Y ® N Has the draft Environmental Impact Statement been accepted? ®Y o N Has the final Environmental Impact Statement been accepted? ® Y ® N 1 Bond Act/EPF/PPG August 2000 Application for State Assistance Payments for Water Quality Improvement Projects r i"'Is P`a � .Goordinated`A roach 1. 'cate the priority in a Management Plan or Program that the pro�,4 ct ddress (Refer to Appe 2 in the Updated Information for Applicants pages A-S thru 2.Explain how the project contributes a mprehensive and coordinated approach to solving water quality impairments and/or ring aqua6NIjabitat. Include a brief description of how the project is consistent with w er quality policies or ommendations in other plans (i.e., County Water Quality Strate , an approved Watershed Manakment Plan; Local Waterfront Revitalization Pr am; NYS Coastal Nonpoint Pollution C of Program; DEC approved species or h itat management plan or project, and/or New Yor te's Open Space Conse tion Plan). TPart J l Project Readiness: Transmission 1Vlain to Cayuga Heights WWTP. (Town of Lansing); 7 State Environmental Quality Review (SEAR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? ()Type I Unlisted ®Type H • Has the environmental review/SEQR process been commenced? e Y ®N ®N/A (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement • Has a lead agency been designated? GY ON ®N/A If YES, provide the name of the lead agency: JNYSDEC and the date the agency was designated: • Has a determination of significance been made by the lead agency? ® Y (j) N ®N/A If YES, circle the appropriate response to the following: Negative Declaration? 0 Y ® N Positive Declaration? © Y ® N Has the draft Environmental Impact Statement been accepted? ® Y ® N Has the final Environmental Impact Statement been accepted? 0 Y 0 N Bond Act/EPF/PPG August 2000 7 Application for State Assistance Payments for Water Quality Improvement Projects �P- r Coordinated.Approaeh' 1. �dicatethe priority in a Management Plan or Program that the project ddress (Refer to x 2 in the Updated Information for Applicants pages A-5 thru A- 2. Explain how the project contributes comprehensive and coordinated approach to solving water quality impairments and/or oring aqua habitat. Include a brief description of how the project is consistent wither quality policies' o commendations in other plans (i.e., County Water Quality Strate , an approved Watershed Man ment Plan; Local Waterfront Revitalization Pr am; NYS Coastal Nonpoint Pollution trol Program; DEC approved species or h itat management plan or project; and/or New Yor tate's Open Space Conse tion Plan). Tart J -Project Readiness: Cayuga Heights.WWTP Filtration..(Phosphorus Removal) 1. State Environmental Quality Review (SEQR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? ® Type I eUnlisted ®Type H • Has the environmental review/SEQR process been commenced? e Y ®N ®N/A (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement • Has a lead agency been designated? If YES, provide the name of the lead agency: and the date the agency was designated: ®Y (DN ®N/A • Has a determination of significance been made by the lead agency? ® Y E)N ®N/A If YES, circle the appropriate response to the following: Negative Declaration? ® Y ® N Positive Declaration? ® Y ® N Has the draft Environmental Impact Statement been accepted? ® Y ® N Has the final Environmental Impact Statement been accepted? ® Y ® N Bond Act/EPF/PPG August 2000 Application for State Assistance Payments for Water Quality Improvement Projects ` Pa -Coordinated Approach /1 1. P Cate the priority in a Management Plan or Program that the project ' address (Refer to Ape ix 2 in the Updated Information for Applicants pages A-S thru 2. Explain how the project contribute omprehensive and coordinated approach to solving water quality impairments and/or oring aqua��b'itat. Include a brief description of how the project is consistent with er quality policcommendations in otherplans (i.e., County Water Quality Strate an approved WaterseMana ment Plan; Local Waterfront Revitalization Pr am; NYS Coastal Nonpoint Pollution trol Program; DEC approved species or h itat management plan or project; and/or New Yor tate's Open Space Conse tion Plan). Part J -Project Readiness: Ithaca Area WWTP: New Grit Removal. Facilities 7 1. State Environmental Quality Review (SEQR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? ® Type I eUnlisted ®Type H • Has the environmental review/SEQR process been commenced? (�) Y ®N O N/A (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement I I • Has a lead agency been designated? ®Y (j)N ®N/A If YES, provide the name of the lead agency: and the date the agency was designated: • Has a determination of significance been made by the lead agency? ® Y G)N ON/A If YES, circle the appropriate response to the following: Negative Declaration? ® Y ® N Positive Declaration? ® Y ® N Has the draft Environmental Impact Statement been accepted? ® Y ® N Has the final Environmental Impact Statement been accepted? ® Y ® N Bond Act/EPF/PPG August 2000 Application for State Assistance Payments for Water Quality Improvement Projects P - Coordinated Approach 1. 'Cate the priority in a Management Plan or Program that the project dress (Refer to Appe ix 2 in the Updated Information for Applicants pages A-S thru A- 2. Explain how the project contributes omprehensive and coordinated approach to solving water quality impairments 7weer or ring aqua bitat. Include a brief description of how the project is consistent with quality policies or commendations in other plans (i. e., County Water Quality Strate , an approved Watershed Manaketnent Plan; Local Waterfront Revitalization Pr am; NYS Coastal Nonpoint Pollution rol Program; DEC approved species or h itat management plan or project; and/or New Yor at' Open Space Conse tion Plan). Part J - Project Readiness: Ithaca Area WWTP: Filtration (Plhosphorus.Removal) I 7 1. State Environmental Quality Review (SEQR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? ® Type I ®Unlisted Type H • Has the environmental review/SEQR process been commenced? ®Y ®N G N/A (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement • Has a lead agency been designated? If YES, provide the name of the lead agency: and the date the agency was designated: ® Y ®N GN/A • Has a determination of significance been made by the lead agency? ® Y ® N (j)N/A If YES, circle the appropriate response to the following: Negative Declaration? ® Y ® N Positive Declaration? © Y ® N Has the draft Environmental Impact Statement been accepted? ® Y ® N Has the final Environmental Impact Statement been accepted? ® Y ® N Bond Act/EPF/PPG August 2000 Application for State Assistance Payments for Water Quality Improvement Projects - Coordinated Agproach 1. dicate the priority in a Management Plan or Program that the project ddress (Refer to App ix 2 in the Updated Information for Applicants pages A-S thru A- 2. Explain how the project contributes omprehensive and coordinated approach to solving water quality impairments and/or,oring aqua ' bitat. Include a brief description of how the project is consistent with w er quality policies o commendations in other plans (i.e., County Water Quality Strate , an approved Watershed Mana ent Plan; Local Waterfront Revitalization Pr am; NYS Coastal Nonpoint Pollution of Program; DEC approved species or h itat management plan or project; and/or New Yor ate's Open Space Conse tion Plan). Part J-Project Readiness: Ithaca' Area.WWTP: Phase 3 Interceptor &.Collector Sewer Improvement 7 State Environmental Quality Review (SEQR) - For each question below, circle the appropriate response - See attached sheets and summary for SEQR classification of each project element. • What is the SEQR classification for the project? 0 Type I ®Unlisted GType II • Has the environmental review/SEQR process been commenced? (e.g. has an Environmental Assessment Form been completed?) If YES, provide the date of SEQR commencement I • Has a lead agency been designated? If YES, provide the name of the lead agency: and the date the agency was designated: • Has a determination of significance been made by the lead agency? If YES, circle the appropriate response to the following: Negative Declaration? Positive Declaration? ®Y ®N(F)N/A ®Y ON (j)N/A ® Y ON ON/A ®Y ®N ©Y ON Has the draft Environmental Impact Statement been accepted? ® Y ® N Has the final Environmental Impact Statement been accepted? 0 Y ON PART I - Coordinated Approach This proposed project presents a unique opportunity to demonstrate the over -reaching benefits of intermunicipal coordination to solve water quality problems. Phosphorus loading and ambient water quality of Southern Cayuga Lake are the focus of community concern through the Ithaca area. The project addresses the top priorities of the Tompkins County Water Resources Council (WRC), which was established in August 1997, by the County Board of Representatives, to identify issues, recommend strategies, and promote coordination of water resources related issues. A water quality strategy for Tompkins County was accepted in June 1992; a revised draft of August 1999, is awaiting adoption by the WRC. The revised draft lists "lack of intermunicipal coordination and cooperation in reviewing projects affecting whole watersheds" as the number 1 priority (county -wide concerns), "surface and groundwater contamination by excess introduction of nutrients from non -point sources..." as the number 2 priority and "discharge of on -site septage where it may impact ground or surface waters..." as the number 3 priority (county -wide concerns). For specific watersheds and water bodies, Cayuga Lake is listed as the number 3 priority, "high levels of turbidity from storm events and algal blooms..." Recently, the Intermunicipal Organization (via the Town of Ledyard) received a grant from the New York Department of State to develop a watershed management plan for Cayuga Lake. This organization is comprised of representatives from 26 municipalities from throughout the Cayuga Lake Watershed, all applicants are currently members of this organization. The goal of the organization is to identify measurable goals and strategies for water quality improvement and protection. The intermunicipal organization has ranked this proposed project first out of all the watershed projects it considered (see attached letter from the intermunicipal organization). A grass -roots organization, the Cayuga Watershed Network, has also recently formed to promote watershed -wide community organizing for education, communication, and leadership. The six municipal applicants have formed a Regional Planning Group, which is composed of elected officials from each municipality and their respective technical staffs. This group has met numerous times to discuss all of the items that must be accomplished to make the joint project a reality. Among other things, this group is coordinating the work for the Environmental Impact Statement ("EIS") that will be prepared for the joint project pursuant to SEQRA. The group has agreed on proposed new service area boundaries for the Ithaca Area Wastewater Treatment Facility, including proposed expansions into the Village and Town of Lansing as one of the joint project's components. These boundaries will be examined in the EIS, and final decisions on boundaries will be based on data generated during the SEQRA process. The Ithaca Area Wastewater Treatment Facility owners (City of Ithaca, Town of Ithaca, and Town of Dryden) will be negotiating an intermunicipal agreement with the Village and Town of Lansing to make them new owners of the Ithaca Area plant. Under the proposed agreement, the Village and Town of Lansing will purchase capacity at the Ithaca Area plant and participate in the plant's governance. Relevant portions of this agreement will be reviewed in the EIS that will be prepared for the joint proj ect. The six municipalities (5 above plus Cayuga Heights) will also be negotiating an intermunicipal agreement to accomplish flow diversion from Cayuga Heights to the Ithaca Area plant. Application for State Assistance Payments City of Ithaca, New York Prepared by: Stearns & Wheler 1:\8000\9011811\WordpmcWisc\Bond Act Applim ionTART I of Bond Am Appli=ion.doc Page 1 of 1 Page Bond Act/EPF/PPG August 2000 g Application for State Assistance Payments for Water Quality Improvement Projects 1 L' _ 2. List the approvals and uermits reouired for the uroiect List the type of approval/permit; the responsible agency; the date the permit application was submitted; whether or not the ' permits/approvals have been issued; and the date issued. • State Permits or Approvals (e.g., SPDES, freshwater or tidal wetlands, stream disturbance, solid waste) SPDES Discharge Permit Modification - Ithaca Area - NYSDEC SPDES Discharge Permit Modification - Cayuga Heights WWTP - NYSDEC Application for Approval of Plans for a Wastewater Disposal System - NYSDEC Highway Work Permit for Utility Work - NYSDEC • Federal or Local Permits or Approvals Highway Work Permit - Tompkins County Highway Department Street Work Permits - City of Ithaca Street Tree Permits - City of Ithaca 3. Provide information about land ownership including the status of easements or permission to use or restore the site. Lansing collection sewers will be located in road right-of-ways or adjacent easements. Easements have not been obtained at this time. Improvements at the Cayuga Heights and Ithaca Area Wastewater Treatment Plants will be constructed on the existing plant sites and improvements to Ithaca interceptor and collector sewers are occurring on existing sewers. 4. Describe what work. if anv. has been comnleted in sunnort of the project. Include, as appropriate, the status of technical reports, conceptual design and construction drawings, plans and specifications, requests for bids, etc. See attached sheet "Part J - Project Readiness, Item 4" PART J - PROJECT READINESS, ITEM 4 Technical Reports . Unified Engineering Report. Municipal Wastewater Collection and Treatment System Improvements, Ithaca, Cayuga Heights and Lansing, New York has been submitted to NYSDEC for review and approval. Wastewater Facilities Plan. Town of Lansing, nary Jan 1998 has been submitted to the NYSDEC for review and approval. Engineering report for re -rating of the Ithaca Area Wastewater Treatment Plant has been reviewed and approved by the NYSDEC. Infiltration/Inflow and sewer system evaluation study reports for Ithaca Area wastewater collection system have been reviewed and approved by the NYSDEC. Design Drawings, Plans and Specifications Design drawings, plans and specifications for additions and modifications to the Ithaca Area Wastewater Treatment Plant for expansion of flow capacity have been reviewed and approved by the NYSDEC. Other (e.g., bidding) Construction of additions and modifications to the Ithaca Area Wastewater Treatment Plant for expansion of flow capacity has been completed. Construction of approximately 12,500 feet of new interceptor sewers in the Ithaca service area has been completed since December 1996. Construction of upgrades of three pump stations in Ithaca service area have been completed. Application for State Assistance Payments Page 1 of 1 Page City of Ithaca. New York Prepared by: Stearns & Wheler I:\8000\8031811\Worrpmc\Mis6Bond An Applia0i..TART I. Item 4 ofB..d Am Appliation.doc i Bond Act/EPF/PPG August 2000 9 Application for State Assistance Payments for Water Quality Improvement Projects Part;;K`=;for Nonpoint;S64c, ;andA untie;Habitat"Rest#tir t[tm-P ro'ec .O 1. Proiect Personnel - Identify the key personnel for the project, including the name, title and qualifications of the Project Manager, the parties responsible for project oversight, the parties responsible for operation and maintenance, and their experience with a similar type of project. 2. Operation and Maintenance -Briefly describe the following: • How the project will be maintained (i.e., inspections, scheduled monitoring and repair) • How the project will be redesigned if the original project does not meet the project goals after five years. Part - Enforcement Status • Is the municipality under enforcem nt (e.g., consent order) to construct the project? E) yes 9no • If YES, attach a copy of the enforcement instrument AZ Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS SEQR SUMMARY BOND ACT APPLICATION MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA A summary table of the project elements, their SEQRA classification, and status is summarized below. A detailed description of each community project and phase is provided in the next section. Town of Lansing Municipal Sewer X NYSDEC as lead agency Collection System (new service to determine significance. area) Diversion from VCHWWTP to I I X I I NYSDEC as lead agency IAWWTP to determine significance. IAWWTP Phosphorus Removal I X I Further SEQRA review I I not required. Cayuga Heights Wastewater X Cayuga Heights to Treatment Plant Filtration complete EAF and (Phosphorus Removal) determine significance. IAWWTP Grit Removal X City of Ithaca Board of Public Works to complete EAF and determine significance. IAWWTP Phase 3 Interceptor and I X Further SEQRA review Collector Sewer Improvements I not required. 1:\8000\8031811\Wordproc\Misc\Bond Act Application\SEQR Summary for Bond Act Application.doc L&Steams &Wheler "mpanies Steams &Wheler,LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS PROJECT SCHEDULE MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS FOR THE ITHACA AREA Town of Lansing Collector Sewers - South Lansing Area • 10" and 12" Mains • Collectors and Laterals Transmission - South Lansing Area Collector Sewers - Myers Road Area Pump Stations Transmission to Cayuga Heights WWTF Diversion of Cayuga Heights Wastewater to IAWWTF • Kline Road • Remington Road Village of Cayuga Heights WWTP Improvements Effluent Filtration for Phosphorus Removal City of Ithaca Interceptor Improvements* (Phases 1 and 2) WWTP Improvements - Plant Re -rating* WWTP Grit Removal Facilities WWTP Phosphorus Removal Facilities Interceptor Improvements - Phase 3 *Projects completed. October 27, 2000 1:\8000\803 1811\Wordproc\Misc\13ond Act ApplicationTroject Schedule.doc 1/l/01 511101 11/1/01 11/1/01 2/l/02 1/31/03 1 / 1 /01 511101 11 / 1 /01 12/31 /01 2/ 1 /02 1 /31 /03 1 / 1 /01 511101 7/ 1 /01 9/ 1 /01 9/15/01 9/ 15/02 1/l /01 5/l /01 7/l /01 9/l/01 9/15/01 5/13/03 1 / 1 /01 511101 7/ 1 /01 9/ 1 /01 9/15/01 9/ 15/02 1 / 1 /01 511101 7/ 1 /01 9/l/01 9/15/01 9/ 15/02 Completed 9/15/01 10/15/00 11/1/00 511101 Completed 7/1/01 9/l/01 9/15/01 9/15/02 ll/l/00 2/l/01 4/1/01 6/1/01 6/15/01 12/15/01 3/l/01 9/l/01 1/11/01 1/15/02 2/15/02 12/31/02 Completed Completed 3/l/01 9/l/01 11/1/01 1/15/02 2/15/02 12/31/02 9/1/00 2/l/01 4/1/01 6/l/01 6/15/01 12/15/01 7/ 1 /0 0 10/ 1 /01 2/ 1 /01 3 / 15/01 4/ 1 /01 2/31 /02 Stearns &%eler "panies �I , A-Z Stearns&Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS PROJECT FINANCE SUMMARY REQUESTED BOND ACT FUNDING Y.�k'bza,`t 'rf$r;'«r.'vim",gy;Y":;.r,,;:.i"`'%��i.F•;'�v,'�;� TOWN OF LANSING ➢ Collector Sewers - 1011 and 12" Mains, South Lansing Area ➢ Collector Sewers - South Lansing Area I ➢ Transmission - South Lansing Area ➢ Collector and Lateral Sewers - Myers Road Area ➢ Pump Stations ➢ Transmission to Cayuga Heights WWTF ➢ Diversion of from VCHWWTP to IAWWTP • Kline Road • Remington Road VILLAGE OF CAYUGA HEIGHTS ➢ Wastewater Treatment Plant Improvements ➢ VCHWTP Filtration ITHACA AREA OWNERS ➢ WWTP/Interceptor Improvements (Phase 1) ➢ WWTP Improvements - Plant Re -rating* ➢ WWTP Grit Removal*** (3) ➢ r Effluent Filtration (P Removal) * * * ➢ Interceptor and Collector Sewer Improvements $1,880,000 $0 $1,360,000 ` . $520,000. $3,200,000 $0 $0 $3,200,000 $550,000 $370,000 I $0 $180,000 $1,630,000 I $1,080,000 $0 $550,000 $1,360,000 $900,000 $0 $460,000 $2,350,000 I $1,020,000I $680,000I $650,000 $100,000 $63,750 $0 $36,250 $140,000 $89,250 $0 $50,750 $1,000,000 I $569,000 $0 $431,000 $1,500,000 $0 $1,020,000 $480,000 $1,660,000 I $1,220,000 $0 $440,000 $340,000 $289,000 $0 $51,000 $1,000,000 $0 $612,000 $388,000 $3,750,000 $1,397,500 $1,152,500 $1,200,000 • Phase 2 (') $1,090,000 $515,420 $0 $574,580 • Phase 3 (3) $3,910,000 $0 $1,560,000 $2,350,000 TOTALS 1 $25,460,000 $7,513,920 $6,384,500 1 $11,561,580 (1) Projects completed. Critical Project Component (7) Sum of two previous Bond Act Applications. (3) Includes leveraged $1.5 million private grant for sewers in the Town of Lansing. (4) Funding -dependent component. October 27, 2000 J:\8000\803181 I\Wordproc\Misc\Bond Act Application\Froject Finance Summary.doc ZA.� Stearns &Wheler Companies I, Jodi Dake, Clerk of the Village of Lansing, New York, do hereby certify that the attached resolution is a true and exact copy of the whole of such resolution on file in the Village Clerk's Office at 2405 N. Triphammer Road, Ithaca, NY from a regular Board of Trustees meeting held on the 2nd day of October, 2000. IN WITNESS WHEREOF, I HAVE HEREUNTO SET MY HAND AND THE Corporate seal of the Village of Lansing, New York this 4th day of October 2000. Jodi L. Dake Clerk, Village of Lansing -SEAL- Resolution #3714- Municipal Resolution Resolution authorizing the items listed below pursuant to the Clean Water/ Clean Air Bond Act of 1996. WHEREAS, the Village of Lansing herein called the "Municipality", after thorough consideration of the various aspects of the problem and study of available data, has hereby determined that certain work, as described in its application and attachments, herein called the "Project", is desirable, is in the public interest, and is required in order to implement the Project; and WHEREAS, Article 56 of the Environmental Conservation Law authorizes State assistance to municipalities for water quality improvement projects by means of a contract and the municipality deems it to be in the public interest and benefit under this law to enter into a contract therewith; NOW, THEREFORE, BE IT RESOLVED BY the Village of Lansing 1. That Mayor Donald Hartill is the representative authorized to act in behalf of the Municipality's governing body in all matters relating to State assistance under ECL Article 56, Title 3. The representative is also authorized to make application, execute the State Assistance Contract, submit Project documentation, and otherwise act for the Municipality's governing body in all matters related to the Project and to State Assistance; 2. That the Municipality agrees that it will fund its portion of the cost of the Project and that funds will be available to initiate the Project's field work within twelve (12) months of written approval of its application by the Department of Environmental Conservation; 3. That one (1) certified copy of this resolution be prepared and sent to the Albany office of the New York State Department of Environmental Conservation together with the Application for State Assistance Payments; 4. That this resolution take effect immediately. Trustee Larry Fresinski moved to accept this resolution and Trustee Lynn Leopold seconded the motion. A vote was taken: Mayor Donald Hartill - Aye Trustee Lynn Leopold- Aye Trustee Larry Fresinski- Aye Trustee Frank Moore -Aye OF 1 y�N- $ , 'iezi % TOWN CLERK 273-1721 TOWN OF ITHACA 215 NORTH TIOGA STREET, ITHACA, N.Y. 14850 HIGHWAY 273-1656 PARKS 273-8035 ENGINEERING 273-1747 PLANNING 273-1747 . ZONING 273-1783 FAX (607) 273-1704 Town Board Meeting-1012/00 v Agenda Item No.18 1996 Clean Water i Clean Air Bond Act — Title 3 Section 56-0303 Water Quality Improvement Projects and Environmental Protection Fund Article 17-14 Environmental Conservation Law; Performance Partnership Grants Public Law 104-134 Nonagricultural Nonpoint Source Projects Municipal Resolution Resolution No. 157 Resolution authorizing the items listed below pursuant to the Clean Water / Clean Air Bond Act of 1996. WHEREAS, the governing Town Board of the Town of Ithaca herein called the "Municipality", after thorough consideration of the various aspects of the problem and study of available data, has hereby determined that certain work, as described in its application and attachments, herein called the "Project?', is desirable, is in the public interest, and is required in order to implement the Project; and WHEREAS, Article 56 of the Environmental Conservation Law authorizes State assistance to municipalities for water quality improvement projects by means of a contract and the Municipality deems it to be in the public interest and benefits under this law to enter into a contract therewith; NOW, THEREFORE, BE IT RESOLVED, that the governing Town Board of the Town of Ithaca: 1. That the Town of Ithaca Town Supervisor, Catherine Valentino, or such person's successor in office, is the representative authorized to act in behalf of the Municipality's governing body in all matters related to State assistance under ECL Article 56, Title 3. The representative is also authorized to make application, execute the State Assistance Contract, submit Project documentation, and otherwise act for the Municipality's governing body in all matters related to the Project and to State assistance; 2. That the Municipality agrees that it will fund its portion of the cost of the Project and that funds will be available to initiate the Project's field work within twelve (12) months of written approval of its application by the Department of Environmental Conservation; 3. That one (1) certified copy of this Resolution be prepared and sent to the Albany office of the New York State Department of Environmental Conservation together with the Application for State Assistance Programs; Page 2 Resolution No.167 Agenda Item No.18 Town Board Meeting 10/2100 4. That this Resolution take effect immediately. MOVED: Councilman Conley SECONDED: Councilwoman Russell Supervisor Valentino, aye; Councilwoman Russell, aye; Councilwoman Grigorov, aye; Councilman Klein, aye; Councilman Conley, aye; Councilman Niederkorn, aye. Motion carried unanimously. 616701, Deborah Kelley, Deputy Town Clerk ,/ of 1' � �' \\. :�,,y�q. TOWN OF ITHACA ITHACA, N.Y. 14850 �- 215 NORTH T10GA STREET, ITH , TOWN CLERK 273-1721 HIGHWAY 273-1656 PARKS 273-8035 ENGINEERING 273-1747 PLANNING 273-1747 ZONING 273-1783 FAX (607) 273-1704 - STATE OF NEW YORK ) COUNTY OF TOMPKINS) SS: TOWN OF ITHACA ) I, Deborah Kelley, Deputy Town Clerk of the Town of Ithaca, New York, does hereby certify that the attached resolution is a true and exact copy of a resolution duly adopted by the Town Board of said Town of Ithaca at a regular meeting held on the 2nd day of October 2000, and that the same is a complete copy of the whole 'of such resolution. IN WITNESS WHEREOF, I have hereunto set my hand and the Corporate seal of the Town of Ithaca, New York this 4th day of October 2000. oioa , oijif-4 Deborah Kelley /f Deputy Town Clerk VV Town of Ithaca (SEAL) 17.1 DPW -Water & Sewer - Approval of Bond Application By Alderperson Vaughan: Seconded by Alderperson Hershey WHEREAS, the City of Ithaca herein called the "Municipality", after thorough consideration of the various aspects relating to wastewater treatment and study of available data, has hereby determined that certain work, as described in its application and attachments, herein called the "Project" is desirable, is in the public interest, and is required in order to implement the Project; and WHEREAS, Article 56 of the Environmental Conservation Law authorizes State assistance to municipalities for water quality improvement projects by means of a contract and the Municipality deems it to be in the public interest and benefit under this law to enter into a contract therewith; now, therefore, be it RESOLVED, by the Common Council of the City of Ithaca that 1. The City Controller is the representative authorized to act in behalf of the Municipality's governing body in all matters related to the State assistance under ECL Article 56, Title 3. The representative is also authorized to make application, execute the State Assistance Contract, submit Project documentation, and otherwise act for the Municipality's governing body in all matters related to the Project and to State assistance; 2. That the Municipality agrees that it will fund its portion of the cost of the Project and that funds will be available to initiate the Project's field work within twelve (12) months of written approval of its application by the Department of Environmental Conservation; 3. That one (1) certified copy of this Resolution be prepared and sent to the Albany office of the New York State Department of Environmental Conservation together with the Application of State Assistance Payments; 4. That this Resolution take effect immediately. Carried Unanimously STATE OF NEW YORK COUNTY OF TOMPKINS SS: CITY OF ITHACA I, Julie Conley Holcomb, City Clerk of the City of Ithaca, do hereby certify that the foregoing resolution is a true and exact copy of a resolution duly adopted by the Common Council of said City of Ithaca at a regular meeting held on the 4th day of October, 2000, and that the same is a complete.copy of the whole of such resolution. IN WITNESS WHEREOF, I have hereunto set my hand and the Corporate Seal of the City of Ithaca, this loth' day of October, 2000. .. �. ............ Ju ie Conley Holc k'CMC City Clerk City of Ithaca, New York —_ I To Seneca Falls To Auburn TOWN of LANS ING "Home of Industry, Agriculture and Scenic Beauty" To Ithaca October 23, 2000 The following Resolution was adopted by the Town Board of the Town of Lansing at a Regular Meeting held by said Board on October 18, 2000. 1996 Clean Water/Clean Air Bond Act - Title 3 Section 56-0303 Water Quality Improvement Projects and Environmental Protections Fund Article 17-14 Environmental Conservation Law; Performance Partnership Grants Public Law 104-134 Nonagricultural Nonpoint Source Projects Municipal Resolution RESOLUTION authorizing the items listed below pursuant to the Clean Water/Clean Air Bond Act of 1996. WHEREAS, the Town of Lansing herein called the "Municipality", after thorough consideration of the various aspects of the problem and study of available data, has hereby determined that certain work, as described in its application and attachments, herein called the "Project", is desirable, is in the public interest, and is required in order to implement the Project; and WHEREAS, Article 56 of the Environmental Conservation Law authorizes State assistance to municipalities for water quality improvement projects by means of a contract and the Municipality deems it to be in the public interest and benefit under this law to enter into a contract therewith; NOW, THEREFORE, BE IT RESOLVED, by the Lansing Town Board That Stephen Farkas, Town Supervisor or such person's successor in office, is the representative authorized to act in behalf of the Municipality's governing body in all matters related to State assistance under ECL Article 56, Title 3. The representative is also authorized to make application, execute the State Assistance Contract, submit Project documentation, and otherwise act for the Municipality's governing body in all matters related to the Project and to State assistance; 1 2. That the Municipality agrees that it will fund its portion of the cost of the Project and that funds will be available to initiate the Project's field work within twelve (12) months of written approval of its application by the Department of Environmental Conservation; That one (1) certified copy of the Resolution be prepared and sent to the Albany office of the New York State Department of Environmental Conservation; 3. That one (1) certified copy of this Resolution be prepared and sent to the Albany office of the New York State Department of Environmental Conservation together with the Application for State Assistance Payments; 4. That this Resolution take effect immediately. Vote of the Town Board ... (Aye) Meg Overstrom, Councilperson Vote of the Town Board ... (Aye) Francis Shattuck, Councilperson Vote of the Town Board ... (Aye) Stephen Farkas, Supervisor STATE OF NEW YORK ) COUNTY OF TOMPKINS ) ss TOWN OF LANSING ) I, Debbie S. Crandall, Deputy Town Clerk of the Town of Lansing, Tompkins County, New York, do hereby certify that I have compared the preceding Resolution with the original thereof filed in the Town Clerk's Office at the Town Hall, Lansing, Tompkins County, New York on the 23rd day of October 2000 and that the same is a true and correct copy of said original in the whole thereof. In testimony whereof, I have hereunto set my hand and affixed the seal of said Town this 23rd day of October. IL � _. A Debbie S. Crandall Deputy Town Clerk Town of Lansing Tompkins County, New York Cayuga County Aurelius (r) Aurora M Cayuga M Fleming M Genoa M Ledyard (r) Scipio M Springport M' Summerhill M Union Springs M Venice M Seneca County Covert (T) Fayette (r) Interlaken M Romulus (r) Cayuga Lake Watershed INTERMUNICIPAL ORGANIZATION Intermunicipal cooperation promoting protection of the watershed 18 September 2000 Mr. Lawrence Fabbroni City of Ithaca DPW Water and Sewer Division 510 first Street Ithaca, NY 14850 Dear Mr. Fabbroni: The Cayuga Lake Watershed Intermunicipal Organization (IO) is pleased to announce their endorsement of the Ithaca/Cayuga Heights/Lansing Area Wastewater Collection and Treatment System Improvements project as proposed by the City of Ithaca, NY: Ithaca. The IO is a municipal, watershed group responsible for overseeing the development of the Cayuga Lake Watershed Management Plan. In this, the IO serves as a clearinghouse for, and helps to prioritize projects that are proposed in the watershed. In April 2000, the IO sought proposals for watershed projects that help to address water resource problems in the watershed. A total of eleven projects were submitted. The IO and its Technical Committee evaluated and ranked the projects per a set of nine Evaluation Criteria, each having equal weight. Each project was also evaluated using only five of the nine criteria. The five criteria used in the second evaluation are the same as those used by funding agencies to evaluate proposed projects for Bond Act, EPF and 319 funding. Seneca Falls (T) This proposal ranked number 1 out of 11 proposed projects using the full set of Varick (r) _ evaluation criteria. The total quantitative score for this proposal was 193 (average deviation 1.57) out of a possible high score of 225. Tompkins County This water system improvement proposal ranked number 1 out of 11 proposed Cayuga Heights M projects using the Bond Act, EPF and 319 funding criteria. The total quantitative sum for this proposal was 110 (average deviation 1.13) out of a possible high FreeviIle (� score of 125. Dryden (r) Groton (T) The IO supports this project and acknowledges its potential to have a positive Ithaca (C) impact on the overall health of the Cayuga Lake watershed. We hope that the targeted funding agency shares this view and funds the proposed project as Ithaca (T) requested. Lansing M Lansing (T) Sincerely, Ulysses (r) Sylvia Hurlbut Town of Ledyard Supervisor 1099 Poplar Ridge Rd • Aurora, NY 13026 • Phone 315-364-5707 • Fax 315-364-5711 • E-mail IedyardGaubcom-com CAYUGA LAKE WATERSHED MANAGEMENT PLAN 2ND YEAR INTERIM RECOMMENDATIONS RANKING MATRIX PROJECT IDENTIFICATION KEY Project Number Project Title 1 Biomonitoring of Four Major Tributaries of Northern Cayuga Lake: Yawger Creek, Great Gully, Paine's Creek and salmon Creek 2 Water Remediation, Village of Union I Springs 3 Cayuga Lake Roadbank Stabilization I Project 4 Ithaca/Cayuga Heights/Lansing Area Wastewater Collection and Treatment System Improvements 5 Agricultural Nutrient Management in I Seneca County 6 Water System Improvement Village of I Interlaken 7 High Resolution-Multispectral Remote - I Sensing Chlorophyll -a Quantitation 8 Six -Mile Creek riparian Buffer Restoration I Program 9 The Trophic State of Cayuga Lake as Affected by a Reduction of Phosphorus and Silt Loading 10 Defining a Source Water Assessment Program (SWAP for the Cayuga Lake Watershed and the Hydrological, Ecological and Environmental Conditions of Watersheds Undergoing Socio- Economic Changes Affecting Land and Water Use 11 Stream Restoration at the Barrile Site in the Town of Caroline an M M Cayuga Lake Watershed Management Plan 2nd Year Interim Recommendations Ranking Matrix Scaring 1 through 5 (1 low, 5 high) Quantitative Scoring criteria I Criteria 2 Criteria 3 Criteria 4 Criteria S* Criteria 6 Criteria 7 Criteria 8 Criteria 9* Existing Means of Idenfified Address I Address Senefitl Use Quantitative Average NNOverall irimcf- SD Sot-1ion - SO E-al-,ahon- SO O&V SD Jmpailmsnt- SD H,,manUsej SD Ecology SD D-gradeWa SD Consiferatf07** SD Sum Deviation 4 5 4 5 5 0.55 5 5 3 5 5 0,89 5 5 3 5 3 1.10 3 5 5 5 5 0.89 5 5 0 5 5 2.24 4 5 0 5 512-17 4 5 0 5 4 2.07 4 5 4 5 5 0.55 5 5 3 5 5 0.89 1 5 5 4 4 1.64 3 5 5 4 5 0,89 3 4 5 5 5 0.89 1 3 5 4 2 1.58 4 5 5 4 5 0.55 3 5 5 4 510.89 3 5 5 5 5 0.89 3 4 5 5 3 1.00 3 5 5 5 5 0,89 3 4- 5 4 5 0.84 4 5 5 4 5 0.55 1 5 5 5 3 1.79 1 2 3 5 2 1.52 4 55 4 5 0.55 4 5 5 4 4 0.55 4 5 5 4 5 0.55 4 5 5 4 5 0.55 3 5 5 4 5 0.89 1 5 3 4 5 1.67 3 5 5 4 5 0.89 2 5 0 4 5 2.17 3 5 3 4 3 0.89 4 5 5 4 5 0.55 4 5 3 4 5 0.84 4 5 3 4 5 0.84 4 5 5 4 5 0.55 3 5 3 4 5 1.00 E£z?<??%�:# 3 4 5 4 5 0.84 3 2 5 2 5 1.52 5 4 5 3 5 0.89 3 5 3 4 5 1.14 4 5 5 4 5 0.55 4 4 5 4 31 0.71 4 4 5 3 5 0.84 3 3 5 3 3 0.89 4 4 5 3 5 0.84 3 4 5 4 30.84 3 4 5 4 5 0.84 3 4 5 4 4 0.71 3 4 3 4 3 0.67 4 4 5 4 5 0.55 3 5 5 4 51 0.89 3 5 5 4 5 0.89 3 3 5 4 3 0.89 3 3 5 4 5 1.00 4 5 5 3 5 0.89 5 5 4 3 5 0.89 3 3 0 3 2 1.30 3 3 5 3 1 1.41 5 5 5 3 5 0.89 4 5 5 3 31 1.00 4 5 5 3 3 1.00 4 5 3 3 5 1.00 5 5 5 3 5 0.89 1 5 1 4 3 1.79 4 5 4 4 5 0.55 1 3 0 4 3 1.64 4 4 3 4 5 0.89 4 5 5 4 5 0.55 3 5 4 4 0.82 4 5 4 4 0.50 4 5 4 4 5 0.55 4 5 0 4 5 2.07 1 4 0 5 2 2.07 4 5 4 4 5 0.55 1 5 5 4 3 1.67 4 5 5 4 2 1.22 4 5 0 5 4 2.07 4 5 5 5 5 0.45 3 3 0 3 3 1.34 3 3 0 4 5 1.87 4 5 0 4 2 2.00 2 5 3 5 1 1.79 2 5 2 5 1 1.87 4 4 2 5 1 1.64 2 1 5 1 1.89 3 4 5 5 3 1.00 3 5 5 5 3 1.10 3 4 5 5 3 1.00 3 4 5 5 3 1.00 3 4 5 5 1 1.67 1 1 0 1 1 0.45 2 5 4 1 5 1.82 1 1 1 3 1 0.89 1 1 5 4 1 1.95 1 1 0 2 1 0.71 4 5 5 3 3 1.00 1 1 0 1 1 0.45 1 1 0 2 3 1.14 1 1 0 2 2 0.84 For explanation of all criteria refer to Evaluation Criteria Refer to PWL for Cayuga Lake and Cayuga Lake Tributaries - Scores will be both aggregated with all criteria and shown separately for Bond Act EPF and Section 319 related projects 193.0 1.57 189.0 1.52 189.0 1.36 KA:*i 18Z 0 1 .54 181.5 1.41 180.5 1.30 176.0 1.49 162.5 1.53 155.0 1.69 155.0 1.66 82.0 1.06 M M i M Ml � rr Cayuga Lake Watershed Management Plan 2nd Year Interim Recommendations Clean Water/Clean Air Bond Act (Criteria 1, 2, 3, 5, 9) Ranking Matrix Scoring 1 through 5 (1 low, 5 high) Quantitative Scoring r# Criteria 1 Criteria 2 Criteria 3 Criteria 5* Criteria 9* Existing Means of Identified Use Quantitative Average overalllnnact** SD Solution*" SD Evaluation** SD Impairment** SD Consideration** SD Sum Deviation 4 5 4 5 5 0.55 5 5 3 5 5 0.89 515 3 5 3 1.10 5 5 0 5 5 2.24 5 5 31 5 5 0.89 1 5 5 4 4 1.64 3 5 5 4 5 0.89 3 4 5 5 5 0.89 4 5 5 4 5 0.55 3 5 5 5 5 0.89 3 4 5 4 5 0.84 4 5 5 4 5 0.55 1 5 5 5 3 1.79 4 5 5 4 5 0.55 3 5 5 4 5 0.89 '<'`'' 3 4 5 4 5 0.84 3 2 5 2 5 1.52 5 4 5 3 5 0.89 4 5 5 4 5 0.55 4 4 5 3 5 0.84 V' v' 3 4 5 4 -3 0.84 3 4 5 4 5 0.84 3 4 5 4 4 0.71 4 4 5 4 5 0.55 3 3 5 4 5 1.00 4 5 5 3 5 0.89 5 5 4 3 5 0.89 3 3 0 3 2 1.30 5 5 5 3 5 0.89 5 5 5 3 5 0.89 u>>_ 1 5 3 4 5 1.67 3 5 5 4 5 0.89 2 5 0 4 5 2.17 4 5 5 4 5 0.55 3 5 3 4 5 1.00 1 5 1 4 3 1.79 4 5 4 4 5 0.55 1 3 0 4 3 1.64 4 5 5 4 5 0.55 4 5 0 4 5 2.07 ...... 1 4 0 5 2 2.07 4 5 4 4 5 0.55 1 5 5 4 3 1.67 4 5 0 5 4 2.07 4 5 0 4 2 2.00 2 5 3 5 1 1.79 2 5 2 5 1 1.87 4 4 2 5 1 1.64 3 4 5 5 3 1.00 3 4 5 5 1 1.67 1 1 0 1 1 0.45 2 5 4 1 5 1.82 1 1 1 3 1 0.891 1 1 0 2 1 0.71 1 1 0 2 2 0.84 NFor explanation of all criteria refer to Evaluation Criteria * Refer to PWL for Cayuga Lake and Cayuga Lake Tributaries ** 1�rnrps will be both aqqreqated with all criteria and shown separately for Bond Act, EPF and Section 319 related projects 110.0 1.13 109.0 0.97 108.0 0.92 104.0 0.93 102.0 101.0 99.0 88.0 85.0 85.0 39.0 0.79 0.98 1.26 1.32 2.06 2.00 1.00 i i 5-28_98_- 15 _44 LSCADILLA CREEK t unitation Informatlon main: Oswego-Scnecs-Oneida (07) Basin: Upper Seneca R./Finger Lakes (05) Type: River ;glCounty: 71 Tompkins (55) 5 Quid: r1HACA EAST (L-15.1) Size: 4.0 Miks ascription: Lower section 4lern- Information Imp%h=ent(s) Severity ish Propagation Tlsrestened cs * Stressed of Pollutant(s)llt (Sediment) * Nutrients so (s).of fthdant(s) Waumbank Erosion * AgricuIture Urban -Runoff Roadbank Erosion llvabjllty issue Nods Study and Managtment Plan, -'--ter Details 315 t-26 7402- - -1 -- -- - Resohmon Potentle : 6trtaun Chat 7Q10 Flow: FFM 315 65•- 4180 : #! 8 070.9-M5 C.CM < 20 es (* iedic ates the PRUNARY Use Impairmeat/PollutsntlSource) Doenmentatioa Sane Poor irment - Aftcr heavy rainfalls, the stream b=mes very mmicy with saspended sediment. Fish propagation is .r ered due to filling of gravel beds with silt. This creek is the best of the three (Cayuga Inlet. Shmile. Cascadit) has wild brown trout spawning in it. Aesthetkm are stireaaed due to the muddineu of the creek after rainfall._ bank and roadbank erosion contribute ranch of the silt, Cropland, urban mess and land development am oaa tficant• scurcm. The rapid development taking place in the wasershad is increasing the amount of runoff and. ucntly, the amount of erosion. caal pile at Cornell Um%ersity is close to this strum and there is cancers over it as a possible so= of toxim 1 [J 157 J BY: 5-28-98 15:44 315 4--G 740:2— 315 CZ5 4180:# 7 CAYUGA INLET Location Information ()3we9D-SCneC2-Owjda (07) Sub -Basin: Upper Seneca P.JFinger Lakes (05) Se. Type: Reg/County.- River 7 / Tompkins (SS) USGS Quad., ITHACA WESTIWEST DANBy(L14-3) (L.14_2) Seg Size.- 10.0 miles Description: :jj d Lower Cayuga jWct Ab.— IRV-6%h1Itif 0705-oo4i It"Oham patentw: * High Strum Class: CICM- 7010 Flow: < 20 efs I I 111W 10n - (* IndlcMs the PRMURY Use 1mp3jr==fPoIlu=USOurCe) .!.-Use Lupairroem(s) Fab Propagation sevaty Doamientation Strewed Type of Poffutant(s) Silt (Sediment) Unknown Toxicity Nutrients um(s) of Pollutant(s) Agriculture Land Disposal Construction On -site Systems Urban Runoff SUMMbank Erosion Roadbank Erosion ,fesolvabiliq Isaac Needs Study and ?quagement plan urther DeWls se ImPirment - Heavy sedin= loads stress fish PropqAtim in the stream. 3YU92 Inlet Is a primary spawning and nursery .area for lake rainbow MOM Erosion sad sedimentation stresses the hery by filling the gravel beds 2W Creating VXtId cowitions. reambaak and roadbank erosion, land develcomcmC urban runoff 2W some 4HCukure Ve major sour= of sedh�. significant sediment plume is visible in lajcz from this trib after & k4vy rainW. lrrambznlc stabilization efforts sbould be =blered. I I I 138 ,CAYUGA .LAKE ILocation Information Basin: Sub -Basin: Seg Type: Reg/County: �USGS Quad: Seg She: Description: 5-223-yH 15:43 Oswego -Seneca -Oneida (07) Upper Seneca R./F'utger Lakes (05) Lake 7 / Tompkins (SS) ITHACA WEST/LUDLOWVILLE(K-I4-3 5000.0 Acres Southern end of Cayuga Lake Iftoblem Information Ire Impairments) Water Supply Bathing Fish Propagation Aesthetics ype of Pollutant(s) Silt (Sadiment) ' urea(s) of Pollutant(s) Sur ambank Erosion Urban Runoff :315 4-26 7402 315 _655 4180: # 6 V ! 0r7-/{I'!N Resolution Poteaft : Medium Stream Clare: AAT, A 7QI0 Flows N/A (I.,14-2) (* indiutes the PRIMARY Use Impairment/Pollutant/Source) Severity Documentation Threatened Some Stressed Good Stressed Some Stressed Some Nutrients Agdculni re Construction Rosdbank Erosion lvabillty Issue Needs Study and Management Plan Pother Deialls se Impairment - High levels of turbidity cause bathing to be strued. Water supply =- is threatened by the turbidity. e � , r heavy rainfall events, the south end of Cayuga Lake Is brown with suspended m4mestt that is trmisported from the :rounding watershed by several major tributaries. These trio: include Salmon Creek, Fail Creek, Caseadilla Creelt, 61 aile Creek. and Cayuga Inlet. -c high levels of turbidity stress .tbe bathing use: the beach rA Stewart Park has been closed for 20 yeas because :ogdity was too high for safe swimming. After herainfall, the low uvxpsreacy of the water cmna unmfe avy itions at other beaches. The watrsawater fishery is strmaed because the water is too turbid to support rooted aquatics icb provide habitat for the fish. Ithaca takes Its weer from the lake near Bolton Point (south of Salmon Creek mouth) doesn't appearto be presently affected by the silt problem. However, water supply 1s threatened if the turbidity arc em gets worse. Most of the problems ate at the extreme southern end., although Selman Crock is a sigWfiratnt source ►edlment and autrients where it enters the lake. onpoint sources in the watershed are many. Salmon Creek is most affected .by agriculture; it is a prime area for production in both Cayuga and Tompkins County. These are many big farms, considerable cash cropping and l waste; there are some poultry farms as wen. Cayuga Inlet, Cascadilla Creek and Siunik Creek suffer primarily .0 ambank and roadbank erosion, erosion from construc don, and land development, and urban mrsot% with some 159 cropland erosion. Fall Creek has sourm of erosion in its watershed including eaman, roadbank, develoPmeut, and agricultural am. strbk' 1 160 u -315 426 7402 315 655 4180 : ff • 4 FALL CREEK Location Inforrualion 0705-0036 Basin: Oswego -Seneca -Oneida (07) Resolution Pateotialt High Sub -Basin: Upper Seneca R./Finger Lakes (05) Set B. A 'RegtCoar#} . 7 / Tompkins (SS) 7Q10 Flow: < 20 cfs USGS d: ITHACA EAST, GROTON(K-15-3) (Ir15-1) Seg Size: 5.0 Miles Description: From Mouth at Cayuga Lake to S miles upstream Problem Infot•matlon {e indieam the PRIMARY Use Impair=:WPollututtfSo=) Use Impairment(s) Severity Domimentatlon Water Supply Threatened Some Bathing Threatened Poor Fish Propagation • Stressed Some Fish Survival - Stressed Some ppe of Pollutant(s) Silt (sediment) * Nutrients 7bermal Changes ' Pathonus Source(s) of Pollutant(s) Streambank Erosion * Agriculture Construction �On-site Systems Roadbank Erosion oivability asue Needs Study and Management Plan _ �rther lielaiis - Impairment - Fish propagation and survival is stressed' in this reach due to heavy silt loads and thermal changes. rinking water supply and bathing are threatened by pathogs. -s creek is impacted primarily by sediment and nutrients and is i source of these pollutants to Cayuga Lake as well. vbe Lake, an impoundment along the creek on the Cornell Univ. campus, was Iosing capacity and recently was dredged to move large sediment accumulations. 'The lower 2-mile section is classified B; this section inciudez Beebe Lake and Rock. People do swim in those areas, but bathing is threatened by pathogens from c n4lte systems in the numerous niets (Etna, Var=, Frceville) along the creek. Beebe Lake is impacted by murieats is well. portion upstream of the B section is classified A and is the water supply for Cornell University. This supply is tatened by sediment and pathogens. 't-turvival and propagation era stressed by siltation of the bottom, organic enrichment and thermal changes in areas xe there has been riparian vegetation removal and overgrazing (particularly In Groton and along major trim). .21 freek was nominated in Cayuga County, but there appeared to be no significant impacts on the stream in the upper i ons. In Cayugs County. the stream supports an excellent trout fishery with natural reproduction. However, nutrients 162 and sediment from agriculture (more in this county than In Tompkins), lake Cumo, and bank erosion in Cayuga County h1rly contribute to the cff cts seen downstream. upstream segment from Froeville to Dryden was on the 1989 PWP llst(M No. "7) due to raw sewage discharges in the . hamlets along the stream. Municipal u=umnt plants should have corrected these problem by this time. v 1 f t 163 I SIX MILE CREEK It Location Information Basin: Oswego -Seneca -Oneida (07) Sub -Basin: • Upper Seneca, RJFwger Lakes (OS) Seg Type: River Reg/County: 9/ Tompkins (53) USGS Quad: ITHACA EAST (Sf15-1) ISeg Sim: 19.0 Miles WDescriptioa: Entire length of crack, including all major tributaries Irmblem Information Use Impairnient(s) Severity Water Supply * Stressed Fish Propagation Streued JIMN of pollutant(s) Silt (Sediment) * Pesticides Aestbctics wurce(s) of PolhiUwt(p) Streambank Erosion * industrial Private Agriculture Scam Sewers On -alto Systems Roadbank Errosion solvability Issue Necds Study and Managtuneat Plan Ver Details O705-W3 Added: I I104193 Resolution Potential: High Stream Claw: A ' . 7Q1O Flow: < 20 cfs (* indicates tine PRIMARY Use Impairmatt/Pollutant/Sowce) Documentation Good Some Nutrients Municipal Urban Runoff Hydromodification ,-later supply is stressed due to the high conrcatratims of sediment entering (and filling) the City of Ithaca's reservoir. f h pragagatim is stressed due to the instability of the cndc's str+eambed. According to the DEC office in Cortiand, NY. ._ effom of local municipalities to remove gravel in the tircambed have furtber destabilized the streambed, thus creating .,:rives deterioration of f b habitat. Fish often do not have adequate cover in Six Mile Creek, sad therefore fish o.1ducrion has declined. Ciureatly, the stocking rate of brown trout yeaziings (8' long) is 2,300lyear. _ -)a= of information: Tompkins County Planning Department r ZI Im VMH Sir Z Z ooz--- IA G' Page ii TABLE OF CONTENTS 1.0 PURPOSE 1 2.0 METHODOLOGY 1 3.0 DATA 4 3.1 Population Data and.Projections 4 3.2 Household Size 4 3.3 Commercial Building Permit Data 4 3.4 School -age Children 5 3.5 Municipal Fiscal Data 5 3.6 School District Fiscal Data .5 3.7 Property Utilization 5 3.8 Soils 6 3.9 Construction Values 7 3.10 Zoning 8 4.0 ASSUMPTIONS 9 4.1 Assignment of New Growth 9 4.2 Commercial Growth Assumptions 9 4.3 TAZ Assumptions 10 4.4 Sales Tax Assumptions 10 5.0 RESULTS 11 5.1 Total Build -out 11 5.2 Buildable Areas By Zoning District 11 5.3 Buildable Areas By School District 5.4 Buildable Areas By TAZ 5.5 Projected Development Density By Zoning District 5.6 Projected Development Density By School District 5.7 Projected Development Density By TAZ 5.8 Projected School -age Children Generation 5.9 Projected Employee Generation 5.10 Projected Land Conversion 5.11 Sales Tax Generation 5.12 Projected Municipal Fiscal Impacts 5.13 Projected School District Fiscal Impacts Page Hi 12 13 15 15 16 19 19 19 x 20 411 Page 1v LIST OF TABLES Table 4-1 Scenario Assumptions Table 4-2 Population Data Table 4-3 Household Size Table 4-4 Commercial Building permit data Table 4-5 School -age Children Age Percentage By Table 4-6 Municipal Fiscal Data Table 4-7 School District Fiscal Data Table 4-8 Property Class Code Characterizations Table 4-9 Soil Associations By Buildable status Table 4-10 New Residential Construction Values Table 4-11 New Commercial Construction Values Table 4-12 Zoning Summary Municipality Table 4-13 Village of Lansing Commercial Growth Assumptions Table 4-14 Town of Lansing Commercial Growth Assumptions Table 4-15 Town of Dryden Commercial Growth Assumptions Table 4-16 Commercial Employee Generation Assumptions Table 4-17 Sales Tax Distribution Table 4-18 Town of Lansing Study Area Total Theoretical Build -out Table 4-19 Village of Lansing Study Area Total Theoretical Build -out Table 4-20 Town of Dryden Study Area Total theoretical Build -out Table 4-21 Town of Lansing Buildable Acreage By Zoning District Table 4-22 Village of Lansing Buildable Acreage By Zoning District Table 4-23 Town of Dryden Buildable Acreage By Zoning District Table 4-24 Town of Lansing Buildable Acreage By School District Table 4-25 Village of Lansing Buildable Acreage By School District Table 4-26 Town of Dryden Buildable Acreage By Zoning District Table 4-27 Town of Lansing Buildable Acreage By TAZ Table 4-28 Village of Lansing Buildable Acreage By TAZ Table 4-29 Town of Dryden Buildable Acreage By TAZ Table 4-30 Summary of Projected Residential Development By Municipality Table 4-31 Summary of Projected Commercial Development By Municipality Table 4-32 Summary of Projected Residential Development By School District Table 4-33 Summary of Projected Commercial Development By School District Table 4-34 Summary of Projected Residential Development By TAZ Table 4-35 Summary of Projected Commercial Development By TAZ Table 4-36 Projected School -age Children Generation Table 4-37 Projected Employee Generation By Scenario Table 4-38 Projected Land Conversion By Scenario Table 4-39 Projected Sales Tax Revenue By Scenario Table 4-40 Projected Municipal Fiscal Impacts Page v Table 4-41 Projected School District Fiscal Impacts LIST OF FIGURES Figure 4-1 Town of Lansing Buildable Areas by Zoning District Figure 4-2 Village of Lansing Buildable Areas by Zoning District Figure 4-3 Town of Dryden Buildable Areas by Zoning District Figure 4-4 Town of Lansing Buildable Areas by School District Figure 4-5 Village of Lansing Buildable Areas by School District Figure 4-6 Town of Dryden Buildable Areas by School District Figure 4-7 Town of Lansing Buildable Areas by TAZ Figure 4-8 Village of Lansing Buildable Areas by TAZ Figure 4-9 Town of Dryden Buildable Areas by TAZ 1 1.0 PURPOSE The purpose of this report is to summarize the methodology and assumptions used to estimate the amount of new development which may occur in the communities included in the Ithaca Area Municipal Wastewater Collection Improvement Project (IAMWCIP) Planning Area. The purpose of undertaking this analysis was to estimate the amount of development that could occur under several future development scenarios and to compare the impacts of each development scenario. The Planning Area for which the analysis was conducted consists of the Village of Lansing and portions of the Towns of Lansing and Dryden. The results of these analyses have been incorporated into the impact assessment portion of the DEIS for the project. 2.0 METHODOLOGY The study was conducted using a geographic information system (GIS). GIS coverages were used to calculate areas of developable land and to integrate information such as natural resource constraints and zoning that affects the amount of land that can be developed. The study was conducted according to the following steps. 1. GIS coverages were assembled for the Planning Area. The following were assembled: Tax parcels with associated real property data, existing and proposed sewer mains, sewer planning area boundaries, traffic analysis zones (TAZs), school district boundaries, zoning, soil survey at the association level, slopes (derived from USGS digital elevation models), topography, floodplains and wetlands. These datasets were combined to create a single GIS dataset. The dataset was then "clipped" to the study area boundary of each municipality to create one dataset per municipality. 2. GIS data were queried to determine those lands that were potentially buildable, based on natural resource constraints, and that contained the potential for additional development, based on real property data. The classifications for natural resources constraints were as follows. • Areas with slopes greater than 15% were considered unbuildable. • All wetlands were considered unbuildable. • All areas within the 100-year floodplain were considered unbuildable. z • All hydric and organic soil associations and soil associations where the depth to bedrock is less than 26 inches were considered unbuildable. 3. Tax parcel data was classified at either "buildable", "underutilized" or "not buildable" based upon the parcel's property class code. Zoning regulations were applied to the buildable area calculated for each parcel in step 2. The application of zoning regulations resulted in a calculation of the amount of development that could potentially occur if all available land were built upon in accordance with the zoning regulations. 4. Building permit and census data were reviewed to determine the amount of residential growth that occurred in the Planning Area between 1990 and 2000. These data were also reviewed to determine the amount of growth in each municipality that occurred in areas served by sewers. 5. Three scenarios were constructed for analysis. a. Scenario 1. Growth will continue at current rates for the 20 year planning period. b. Scenario 2. Growth will continue at current rates, but a greater percentage of the growth will occur within the Planning Area. c. Scenario 3. Growth will occur at higher rates and a greater percentage of growth will occur within the Planning Area. 6. Population growth was converted to residential dwelling units using the average household size as reported by the U.S. census for each municipality. 7. Dwelling units were assigned to each municipality. The number of dwelling units assigned to the Planning Area in each municipality was assumed to occur in the same proportion as has historically occurred for Case 1, and was increased by 15% in Cases 2 and 3. Note that since all of the Village of Lansing lies within the Planning Area, 100% of development in all cases was assumed to occur within the Planning Area. The percentages are summarized in Table 4-1 below. 3 Village of Lansing Town of Lansing Town of Dryden Table 4-1. Scenario Assumptions Percentage of Total Residential Growth to Occur in Study Area For Case 1 100% 50% 75% Percentage of Total Residential Growth to Occur in Study Area For Case 2 100% 65% 90% Percentage of Total Residential Growth to Occur in Study Area for Case 3 100% 65% 90% 8. Residential development for each scenario calculated in Step 7 was distributed among the buildable parcels calculated in Step 2. This distribution formed the basis for the analysis in the DEIS. 9. Residential development calculated in Step 7 was distributed proportionally among the Traffic Analysis Zones (TAZ's) provided by the Ithaca Tompkins County Area Traffic Council as mapped in Step 2. The results were provided to the ITCATC for incorporation into the T-Model for Tompkins County. 10. Residential development calculated in Step 7 was distributed proportionally among the School Districts mapped in Step 2. The results were used in the DEIS impact analysis. 11. Future commercial development for Case 1 was calculated by averaging the total commercial development square footage in each municipality, as derived from building permit data, over the last ten years and then applying that yearly average over the 20 year study period. For Cases 2 and 3 the total square footage was increased by 0.5%/year. All commercial development was assumed to occur within the Study Area, as the Study Area contains nearly all of the significant commercially zoned lands in each municipality. Commercial development was apportioned among the TAZs and school districts in the same manner as for residential development in Steps 9 and 10. 4 1 3.0 DATA The following summarizes the raw data relevant to this analysis. 3.1 Population Data and Projections Table 4-2 summarizes 1990 and 2000 populations by municipality, the rate of population growth, and the estimated 2020 population, assuming that the rate of growth remains unchanged. In calculating the 2020 population, growth was compounded in 2010. Table 4-2. Population Data 1990 Pop. 2000 Pop. Percentage Increase Scenario 1 Population Increase Scenario 2 Population Increase Scenario 3 Population Increase Town of Lansing 9,296 10,521 13.18% 1,478 1,921 2,712 Village of Lansing 3,281 3,417 4.15"/ 289 289 654 Town of Dryden 13,251 13,532 2,12% 435 522 1,796 3.2 Household Size Average household size in each municipality is summarized in Table 4-3 below. Table 4-3. Household Size f Average Household Size Town of Lansing 2.33 persons Village of Lansing 2.06 persons Town of Dryden 2.43 persons 3.3 Commercial Building Permit Data Commercial Building Permit data for each municipality are summarized in Table 4-4 below.' Table 4-4. Commercial Building Permit Data 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Total Annual Average 8,888 14,885 20,220 30,577 0 34,988 10,792 25,658 45,000 23,054 214,062 21,40E sing (T) No Data No Data 1,600 1,200 31,000 5,736 18,600 10,770 15,228 0 84,134 10,51 i sing M 71,750 12,844 33,962 18,000 10,728 84,270 30,900 84,220 77,669 88,554 512,897 51,29( 1 The following non-commercial structures were not included in the Village of Lansing data. Montessori School (1993); CU Ornithology (2000). The following structures were considered re -builds and so were not included in the data: Hoyts Theaters (1995); Tops (1999); Applebees (2000). 5 3.4 School -age Children The percentage of the population that is school age children in each municipality was derived from the census using the 5-17 age bracket. These data are summarized in Table 4-5 below. Table 4-5. School -age Children Percentage by Municipality Percentage of Population Who Are School -age Children Town of Lansing 18.70% Village of Lansing 12.70% Town of Dryden 18.40% 3.5 Municipal Fiscal Data Data relevant to the fiscal analysis for each municipality are presented in Table 4-6 below. Table 4-6. Municipal Fiscal Data Total Municipal Expenditu Total Real Property Val Average Real Property ValTotal Non -Residential Property VaAverage Non -Residential Property VahWax Rate Town of Lansing $5,408,603 $669,019,261 $201,694 $381,941,560 $428,186 $1.53/$1,000 Village ofLansin $3,610,480 $314,984,638 $345,000 $229,527,538 $655,793 $1.701$1,000 Town of Dryden $4,739,822 $529,856,867 $117,903 $214,129,667 $130,170 $1.701$1,000 3.6 School District Fiscal Data Data relevant to the fiscal analysis for each school district are presented in Table 4-7 below. Table 4-7. School District Fiscal Data Total Budget Total Enrollment Expenditure/Student Tax Rate Ithaca City S.D. $68,242,650 5,599 $12,188 $19.94/$1,000 Lansing Central S.D. $17,362,209 1,341 $12,947 $19.50/$1,000 Dryden S.D. $22,957,415 2,031 $11,126 $22.00/$1,000 3.7 Property Utilization Table 4-8 sets forth the division of property class codes into buildable, ' unbuildable and underutilized categories. For underutilized categories, an amount of land equal to the amount of development on the parcel (if given in square feet) was subtracted from the parcel size to obtain the buildable acreage. G Table 4-8. Property Class Code Characterizations Property Property Class Definition Assigned Value Class Codes All100's Agricultural Buildable All 240's Rural residence with acreage Buildable All 300's Vacant land Buildable All 910's Private wild and forest lands Buildable 250 Residential property not less than 5 acres Underutilized All400's Commercial Underutilized that are > 1 acre in size All 500's Recreation and entertainment Underutilized that are > 1 acre in size All700's Industrial Underutilized that are > 1 acre in size All other Not buildable property class codes not listed above and all 400's, 500's and 700's that are < 1 acre in size 3.8 Soils Table 4-9 lists each soil type and whether it was considered buildable for purposes of this analysis. 0 7 Table 4-9. Soil Associations by Buildable Status Soil Association Aurora -Angola Aurora -Farmington -Manlius Benson-Wassaic ICazenovia-Ovid IEllery-Erie-Alden Erie -Langford Hamlin, fan -Palmyra +Hamlin -Teel Howard-Arkport Howard-Chenango Howard -Palmyra Howard -Phelps Hudson -Dunkirk Hudson -Rhinebeck IKendaia-Lyons Langford -Erie Langford -Howard Lansing-Conesus ILordstown-Arnot ILordstown-Langford ILordstown-Mardin ILordstown-Mardin-Langford IMardin-Langford IMardin-Volusia Ovid -Ilion Palmyra Rhinebeck -Niagara Sloan-Madalin-Fonda Sloan -Teel, alluvial land IVolusia-Mardin 3.9 Construction Values Restriction Class No Restriction to Development No Restriction to Development Shallow Bedrock No Restriction to Development Wet Soil No Restriction to Development No Restriction to Development No Restriction to Development No Restriction to Development No Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development Wet Soil Wo Restriction to Development Wo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development INo Restriction to Development Table 4-10 summarizes new residential construction values, as received from the assessor in each municipality. Table 4-10. New Residential Construction Values Average Residential Construction Value Town of Lansing $177,517 Village of Lansing $155,097 Town of Dryden $119,816 8 Table 4-11 summarizes new commercial construction values, as derived from building permit data. For the Towns of Lansing and Dryden, the figures were rounded to $40/s.f. for use in the analyses. Table 4-11. New Commercial Construction Values Average Commercial Construction Va Town of Lansing $40/s.f. Village of Lansing $55/s.f. Town of Dryden $40/s.f. 3.10 Zoning Table 4-12 on the following page summarize allowed uses and densities by district and municipality. I-:-,tlwelling'unitslacre���'')- square feettacre W--vlth water •-" .Sirigle;fami4v "` I� _ 't'=`Duple"ses"s= ' "''"`� ""•'TriAleses ° ; =Multiunit IItvellirig' I NW=without water (10 units)::::,.; S=withsewer pi '•: I c.;.... :•., 1`s i.;.' is<i s I NS=no sewer . °) `•��>_ ..:z.^" � s:9... .. :,r �'.c. .� '^.,py,�. {,l a:a-�g ,'.;�};w'�a: ::-..A.36- ';,.i; is? ^". 2.tS ,•-'-" 2lS_ : 28;889:00-:; 062ic: c Town of Lansing Bl Commercial. General and MixedUae •?'': �'�=.�2:i8'::�: :: `--� °,:'� I IR Industrial/Research I Ll Lakeshore a,09<'.:..,'..) :,.1.09"-:...;",.I;.::.;'. Notperinitted<'':': ;:,'' .•:'. 26:$83:OII'. ;;:':M=062 ': `>:;; I I LI Lake Frontage ".2.18.::.. --. '.- 2.18 ? I''%'3' " 2.18 ,. 2.ISi j I R1 Residential Low Density L09 I-.- 1.09 :=:'': Netperinittod` nos3yni6cmtteonrrtiereishisesz<='cyk.._. or.(W):2:IS;s:18.15(S)Gr(45')::2.18,';;':' R2 Residential Moderate Density "- "'-z i '2.i8:,' ':;,aud (N4Y) : " ' (NS)and. (N4SA : ' (13S) and (Nt :� • ' qG 8.OD;`l .': 4 fiZ I I R3 Residential. Mixed -Use •1:09" 1.09:.::: '.., a : '. o Notpormitted" c _ 0.62:' -; I RA Rural Agriculture 1A9::. 1:09"."?t 1.09. 1.09 2G,889:00G ,' :.: :-0.6? „ 24.829.20 �0.57 I I CHT Commercial High Traffic :..- .; ...:a:i= _ .:.: ,-:.: •. No:rosrdential.' ::: ...✓; .'.:: '�•'; .:'.::_ -. ':.:;.:':�.;:..., : 22926.31 (S) I 0:53 I I CLT Commercial Low Traffic Z26''... 7.26., 22926.31 (S) I 0.53 ',,�.2§(S)ttot:al]dwed:=7:26;CS):x}okaliowed;. HDR HighDensitvResidential=.;,3.63(0,76(NS)-'t "!' S.80(S);'U6�(N§Y,:.',.:;:•;°ivithmwsewer. ",<; ;.witl no sower-:'; 17,424(S);8,712(S) 0.40(S);0.20(NS)" No significant LDR Low Density Residential ✓ d-45(S)0:78(NS):��sl:' 2:i'8(S);0;97(NS) ''i `-•':nofpertuitted�•t��j ;'--pot permitted:'.•:: commercial " No significant MDR Medium Density Residential - -"2.`1&(Sk0.73(NS)i` ,I7}' 3:18(S):0.57(NS)' :" nolpermttted>,w' i ,= ;: notpormittedVi' ' commercial I RSH Research District >_: i. +i.::::.. ?:� :. No:ieaidenti8l:'.. .:.- . '' " .. 32.669.76 I 0.75 HHSD Human Health Services District -No iesidential' 22,926.31 I ,t 0.53 Town of Dryden M-A Manufacturing andAssembly • ',' ;.`.�-''= %a'.` . - "� �'•iioresidential- : 10,459.32 0.26 I M-AA Adult l.)ses(seernningmnwuimantfor desi: ":,;."'.`�' - ..:-":. ":���: �:.. .- ttoresidential•-'- :c�<:.: �. �; i �:; �:� 10,954.32 1:45(NWl (NS),. ;5 2,90(NW)or(NS)4:36(W!! ;..5>' no significant RB Low Density Residential J 2:18(W)and(S).s:'. )and(S)'.=t6.";1_'::`.;'"riot permitted-'✓ ",:.notperinittad•:commercial :!-,'2.90,(NW)or{NS);- ;. no significant R-B-1 LowDensitvAgricultural- Residential3G(VV)aiid(S}= .not06rrriittkd•�: �notQgrmitted- •<: commercial i;45(NW)oi(NS),2:90'.2,90(Wr; (NS)j' 3:i2(NW)or(N$)" R-C Moderate Density Agricultural - Residentir` WMo'r (S). ".:`•:: " 5.12M1 and(S) ;. " �G 87(iV)and(S) ' ' =:'. " I3 2(VV)and(S)': ';1.;'r: , 13,068.00 0.30 1:95(NtV)ana(KS)_8,G3(: 2,90(N,S?J)&r(NS);6.22<W 3:12(NV4)Or,(NS)".;$_37( 5,2(NW)%'(NS)";14:5( R•D Higher Density Agriclutural •Commercial 8nd(Sry }aud W)and(S) W)aad(S), 13,068.00 0.30 r a a % a'«i ' i(': k"'2 34,1 9 Village Cayuga Heights C -Commercial District .. �.. - ,.. 3,067.90 0.30 ntnosignificant Rl Residence District '';'2-32;.' i ;; ` ("' S':••.."A.65:';< I:: ootpi rmitted :::,f+;i.:enoilim fitted;'.,: e. commercial no significant RM Multiple Housing District 5 2.32; commercial<'4.G5. - `�-�'f-, •-"G:96 ;'.""-�-- '23,20';V:.''.::i �rt-. mmercial : •Town of Lansing. No value available for when sewer is available _""_ , ,•,,,,,_.,„„„,, „ _ . < ." .„...-__, _,„,„".",". ". _„„_,,,, „._..._ " ..-, . , .,.",_",...�_,. I •*Assume two -bedroom house. 9 4.0 ASSUMPTIONS Several assumptions were made in order to complete the analysis. These assumptions are summarized as follows. 4.1 Assignment of New Growth The total amount of new residential and commercial growth anticipated to occur in each municipality was assigned to the zoning districts, school districts and transportation analysis zones (TAZs) in proportion to the percentage of developable land lying within that zoning or school district or TAZ. That is, if 50% of the total developable land within a municipality lies within a given zoning district, than 50% of the projected future growth was assigned to that district. The districts were reviewed to ensure that the amount of growth so estimated did not exceed the maximum allowed under the zoning ordinance. 4.2 Commercial Growth Assumptions For purposes of the TAZ model it was necessary to divide commercial growth into retail, non -retail and industrial components. The assumptions in this regard are summarized in Tables 4-13-4-15. Table 4-13. Village of Lansing Commercial Growth Assumptions District Retail % Non -Retail °/Wanufacturing % Business and Technology 0% 100% 0% Commercial High Traffic 75% 25% 0% Commercial Low Traffic 0% 100% 0% Human Health Services 0% 100% 0% Table 4-14 Town of Lansing Commercial Growth Assumptions District Retail % Non -Retail %Manufacturing % Commercial, General and Mixed Use 50% 50% 0% Industrial/Research 0% 0% 100% Residential Mixed -Use 50% 50% 0% ' Residentail Moderate Density 75% 25% 0% i Rural Agricultural 75% 25% 0% 10 Table 4-15 Town of Dryden Commercial Growth Assumptions District Retail % Non -Retail %Manufacturing % High DensityAg/Commercial/Residential 75% 25% 0% Manufacturing and Assembly 0% 0% 100% Moderate Density Agriculture/Residential 75% 25% 0% 4.3 TAZ Assumptions F, In assigning new development to TAZ's, it was necessary to differentiate household size and number of automobiles in each household. All households were assumed to have two automobiles. Half of all households were assumed - to have two persons. Half were assumed to have more than two persons. The number of automobiles for each type of commercial development were derived using ratios identical to those for employment estimates. These are presented in Table 4-16. Table 4-16. TAZ Commercial Employee Generation Assumptions l Ratio Retail 1:650 s.f. Non -Retail 1:350 s.f. Manufacturing 1:600 s.f. 4.4 Sales Tax Assumptions Based on data contained in the recently completed Southwest Area Environmental Impact Statement, new retail uses were assumed to generate $190/s.f. in sales. Sales taxes were assumed to be distributed using the same formula as present. That is, 1% of the sales tax revenue is distributed to (� Tompkins County towns in proportion to each town's percentage of the total _ county population. The distribution to each of the municipalities is summarized in Table 4-17. f� Table 4-17. Sales Tax Distribution ' 2000 Population Percentage for Sales Tax Distribution Tompkins County 95,501 Town.of Lansing 10,521 11.02% Village of Lansing 3,417 3.58% Town of Dryden 13,532 14.17% 11 5.0 RESULTS 5.1 Total Build -out Tables 4-18 — 4-20 presents the total build -out for the Planning Area in each municipality. It is emphasized that this is a theoretical number and assumes that all land that is not already built upon and does not have development constraints is developed in accordance with current zoning regulations. Table 4-18. Town of Lansing Study Area Maximum Theoretical Build - out Type of Development Commercial Residential Duplex Residential Multi -Family Residential Single Family Residential Triplex Amount of Development 72,408,434 s.f. 8,494 d.u. 19,844 d.u. 5,441 d.u. 7,041 d.u. Table 449 Village of Lansing Study Area Maximum Theoretical Build -out Type of Development Commercial Residential Duplex - no sewer Residential Duplex - sewer Residential Multi -Family Residential single family - no sewer Residential single family - sewer Residential triplex Amount of Development 917,313 s.f. 2,431 d.u. 2,670 d.u. 236 d.u. 1,461 d.u. 1,726 d.u. 236 d.u. Table 4-20 Town of Dryden Study Area Maximum Theoretical Build - out Type of Development Commercial Residential Duplex Residential Multi -Family Residential Single Family Residential Triplex Amount of Development 5,229,477 s.f. 14,783 d.u. 2,932 d.u. 7,592 d.u. 1,609 d.u. 5.2 Buildable Areas By Zoning District Buildable areas by zoning district are illustrated by Figures 4-1 - 4-3. Buildable acres are summarized in Tables 4-21 - 4-23. 0 0.5 ® Buildable 1 Zoning Districl ® Commercii 0 Industrial / ® Lakeshore Residential, Low Density 0 Residential, Moderate Density 0 Residential, Mixed -Use Rural Agricultural Roads to State Highway County Highway Local Road THE ba e,'_ COMPHN�lES Engineers / Surveyors Planners Environmental Scientists GIS Consultants Town, of 0 Town of G,aroli wn. of New.fi,el Municipal Boundary — State Highway 2 4 8 Study Area Miles Town of Lansing (study area) Index map of Tompkins County, NY showing the study area CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Draft Environmental Impact Statement: Ithaca Area Municipal Wastewater Collection Improvement Project Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Count Office: n 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Figure 4-1. Town of Lansing Buildable Areas Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: 556-1037 Phone: (518) 812-0513 by Zoning District. (781) This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. C m.d by: Carol Conolly one: March 19, 2002 scde: Various; see maps R'_1: 90122.00 I — -i ^N1 s 0 0.25 0.5 1 : 30,000 1 1 Miles M Buildable Areas Zoning District Business and Technology Commercial High Traffic 0 Commercial Low Traffic 0 Human Health Services District 0 Low Density Residential 0 Medium Density Residential 0 High Density Residential 0 Research District hway ighway ad To n of. Lansirf 34 48 T f UI s - 89 Villa 96 Town of Town, kJlf Groton of Lansing 1 )366C �_ToWn- of Dry Tod,f lth, BURoiclN---M 13 \ Town of Caro 1 i n. � t , o.wn of �n�Tq LANE ` lTwn of Newfi,el 34 �. �� OK W ' ' Municipal Boundary �` - State Highway 0 2 4 8 Village of nT Mlles Stud Areaansing ��'-fj• O zl AX DRIVE z' LPN Y I SyALE C ar z pis W <• O ' -- Index map of Tompkins County, NY showing the study area 70 "O "m' _ 1 O - O FIN — mx Y firs BROW- 'P l N a P � 'PO ' D CA HE W� • Dy Op�jy[yDOp � ' tJ BROW - w m I RD -EXT o'� x v> r o ;,d _ Px M?.'� EN:s,.TM1ri;,Y RO m LC Om[ed by: THE CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Draft Environmental Impact Statement: I carol Conolly C�i7l e�ln Ithaca Area Municipal Wastewater Collection Improvement Proiect I DI_ Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: N ES 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street March 19, 2002 COMPA Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Figure 4-2. Village of Lansing Buildable Areas scde1 Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 by Zoning District. Engineers I Surveyors Phone: (781) 556-1037 Various; see maps Planners Environmental Scientists This map is a product of The chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. GIS Consultants The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. 90122.00 0 0.5 1 2 Miles 1 : 65,000 ® Buildable Areas Zoning District 0 Manufacturing and Assembly Adult Uses Low Density Agricultural - Residential 0 Low Density Residential Moderate Density Agricultural - Residential ® Higher Density Agricultural -Commercial -Residential Roads �a State Highway County Highway Local Road THE CyJGZ �G,72 COMP �SN�ES Engineers / Surveyors Planners Environmental Scientists GIS Consultants CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Capital District Office: Dutchess County Office: Orange County office: New England Office: North Country Office: 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Phone: (518) 235-8050 Phone: (845) 4S4-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone: (781) 556-1037 This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. To n of. Lansirt 34 4B T f UI 89 Villa; 96 - 13 Cayuga HEyh 79 City of tlac 327 T o, I t h. Town. of Town, 1f Groton. of Lansing Town of Dry,. 13 Town o.f' Carolin own. of 1.w, . of New,fie1 34 MMunicipal Boundary - State Highway 0 2 4 8 Study Area Miles Town of Dryden Index map of Tompkins County, NY showing the study area Omhd by: Draft Environmental Impact Statement: carol Conolly Ithaca Area Municipal Wastewater Collection Improvement Proiect C—: March 19, 2002 Figure 4-3. Town of Dryden Buildable Areas s.,�: by Zoning District. Various; see maps ROKR a: 90122.00 iI 12 Table 4-21. Town of Lansing Buildable Acreage By Zoning District Acreage Commercial, General and Mixed Use 389.7 Industrial/Research 195.3 Lake Frontage 126.8 Lakeshore 72.3 Residential Low Density 852.3 Residnetial Mixed use 629.7 Residential Moderate Density 1,010.40 Rural Agriculture 383.6 Totals 3,660.10 r- Table 4-22 Village of Lansing Buildable Acreage By Zoning District Acreage - Business and Technology 2.6 Commercial High Traffic 3 Commercial Low Traffic 28.5 ' High Density Residential 4 Human Helath Services District 2.5 Low Density Residential 702.1 Medium Density Residential 261.00 Totals 3,660.10 Table 4-23 Town of Dryden Buildable Acreage By Zoning District j h Acreage Higher Density Ag/Comm/Residential 66.4 Low Density Ag/Residential 942.9 Low Density Residential 3,545.20 Manufacturing and Assembly 141.9 Moderate density Ag/Residential 210.8 Totals 4,907.20 5.3 Buildable Areas By School District Buildable areas by school district are illustrated by Figures 4-4 - 4-6. Buildable acreages are summarized in Tables 4-24 - 4-26. Table 4-24. Town of Lansing Buildable Acreage By School District Buildable Acreage Ithaca City School District 209.2 Lansing Central School District 3,450.90 ��i♦'`�♦�°i!i�-poi ,;�'� :.y ►•. -71 _ • �1►_� 1 0.5 1 2• �`: Miles W-WX, - �♦ .0 School Districts 0 Ithaca City School District 0 Lansing Central School District Roads is State Highway County Highway Local Road ® Buildable Areas THE�1�////yi P CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Capital District ice: Dutchess County Office: Orange County Office: New England Office: North Country Office: COMPf1ES 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Engineers / Surveyors Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 9 Y Phone: (781)556-1037 Planners Environmental Scientists This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. GIS Consultants The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. - T q*,n, of L a n, s i T o vsffFd f I t h. Town, of 1 � To:w*222 nf 0ro.ton. of Lansing Town of D.ry 13 Town o..f Carolin, oWn, of :qq wn, o-f Ne wfi.el 34 (I Municipal Boundary i State Highway 0 2 4 8 Study Area Miles Town of Lansing (study area) Index map of Tompkins County, NY showing the study area by: Draft Environmental Impact Statement: carol Conolly Ithaca Area Municipal Wastewater Collection ImDrovement Proiect March 19, 2002 Figure 4-4. Town of Lansing Buildable Areas tee: by School District. various; see maps mo�ea a: 90122.00 0 0.25 0.5 1 Miles THE CLJGZjG72COMPiES Engineers / Surveyors Planners Environmental Scientists GIS Consultants 1 : 30,000 ® Buildable Areas School Districts 0 Ithaca City School District Lansing Central School District Is P State Highway County Highway - Local Road in yoo oa• O , BROW RD. EXTin _ in cr Town of Carolin Twn. of Newfiel 34 1 j =1 Municipal Boundary I- State Highway 0 2 4 8 0 Village of Lansing Miles C3 Study Area Index map of Tompkins County, NY showing the study area CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Draft Environmental Impact Statement Ithaca Area Municipal Wastewater Collection Improvement Proiect Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Figure 4-5. Village of Lansing Buildable Areas Phone: (518) 23S-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 by .School District. Phone: (781) 556-1037 This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. treated by: Carol Conolly D�: March 19, 2002 smc: Various; see maps Rv}ea e: 90122.00 N w-�—E s 0 0.5 1 2 Miles 1 : 65,000 ® Buildable Areas �i School Districts 0 Dryden Central School District Ithaca City School District Lansing Central School District Roads to State Highway County Highway Local Road THE 2ajen COMPANIES Engineers / Surveyors Planners Environmental Scientists GIS Consultants To -n; af..Lan,s:i:_rf .. 222 34 4 Toiwn•,. f::Grot.oa: j. � J _ 4B Villa e. of Lansing_, ; 96 _ 13 Cayuga Hc- Xh .. 79 366 }jTo,.w»: of D-ry, d City of 1 'lac 327 - T, o. t th, .era Towne. o.f \ 79 i 613 13 - Town. 6,f- Cl.' .aroin o w,. n: o f, T wn;. o fi: 01 34 Municipal Boundary i State Highway 0 2 4 8 ® Study Area Mlles Town of Dryden Index map of Tompkins County, NY showing the study area CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Draft Environmental Impact Statement: Ithaca Area MuniCiDal Wastewater Collection Improvement Proiect Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue Troy, New York 12182 Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 110 Glen Street Glens Falls, New York 12801 Figure 4-6. Town of Dryden Buildable Areas Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 by School District. Phone: (781) 556-1037 This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. Q-Md bv: Carol Conolly o-: March 19, 2002 sm�: Various; see maps ao - a: 90122.00 13 1 1 1 1 1 1 1 Table 4-25. Village of Lansing Buildable Acreage By School District Buildable Acreage Ithaca City School District 739 Lansing Central School District 265.00 Table 4-26. Town of Dryden Buildable Acreage By School District Buildable Acreage Ithaca City School District 3,737.40 Lansing Central School District 11.00 Dryden Central School District 1,158.20 5.4 Buildable Areas By TAZ Buildable areas by TAZ are illustrated by Figures 4-7 - 4-9. Buildable acreages are summarized in Tables 4-27 - 4-29. Table 27. Town of Lansing Buildable Acreage By TAZ TAZ Acreage 9 1.3 11 281 12 362.4 13 65.9 15 128.6 16 428.6 17 100.2 18 274.7 19 387.5 20 232.8 21 194.5 22 443.7 23 622.2 24 50.3 25 41.4 26 8.6 27 0.2 28 33.7 39 2.4 s 0 0.5 1 2 Miles 1 : 50,000 PERUVIL ® Buildable Areas Transportation Analysis Zone = 21 Roads 0 0 0 22 �a State Highway 0 9 0 23 County Highway 11 0 24 Local Road 12 0 25 0 13 0 26 0 15 28 0 16 29 0 17 0 30 0 18 0 32 0 19 0 64 0 20 74 0 75 24 THE CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Chie�_ Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: ('Oh /tPANE 4 N�C(' 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street f V 11 A LJ Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Engineers /Surveyors Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone: (781) 556-1037 Planners Environmental Scientists This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. GIS Consultants The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. Town, of Town of Carol.i w..n of Newfiel Municipal Boundary i State Highway 0 2 4 8 Study Area Miles Town of Lansing (study area) Index map of Tompkins County, NY showing the study area Q—.d w: Draft Environmental Impact Statement: Carol Conolly Ithaca Area Municipal Wastewater Collection Improvement Protect: March 19, 2002 Figure 4-7. Town of Lansing Buildable Areas sde: by Transportation Analysis Zone. various; see maps moxc e: 90122.00 N w�E ass 0 0.25 0.5 1 Miles 1 : 30,000 THE Chazen COMWIES Engineers / Surveyors Planners Environmental Scientists GIS Consultants ® Buildable Areas Transportation Analysis Zone 0 34 Roads 0 C] 35 is State Highway 0 20 0 36 County Highway 23 37 Local Road 24 0 38 0 25 0 39 26 0 40 �27 041 28 42 0 29 43 30 75 0 31 0 181 32 237 0 33 238 ;N ;:32 1 n' 75 33 0.0 POOR 13 - _- O • '�BROw ru z, 43 .f RD EXr. CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone:(781) 556-1037 This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its intended use. I To\iyn of, La,nsi Town f Groton B T f W ,, 89 Villa e of Lansing 96 13 t 13 Cayuga H h 366 To w n, of D,r 327% ITqWirdI : 1 th,� a. ,T-awn, o.f \ c� 0 Town of Carotin, own. of`D: q— T ,wn of. N,ew,fiel' 34 l� Municipal Boundary - State Highway 0 2 4 8 Village of Lansing Miles Study Area Index map of Tompkins County, NY showing the study area o—e by: Draft Environmental Impact Statement: Carol Conolly Ithaca Area Municipal Wastewater Collection Improvement Proiect D-: Figure 4-8. Village of Lansing Buildable Areas March 19, 2002 srde: by Transportation Analysis Zone. various; see maps noxc.: 90122.00 N w—A^-E s 0 0.5 1 2 Miles 1 : 65,000 ® Buildable Areas Transportation Analysis Zone = 95 Roads 72 13 State Highway 0 73 0 96 0 97 County Highway 74 103 Local Road 75 0 104 0 76 105 0 77 106 0 78 0 112 79 113 80 a' r"; 114 91 0 115 92 0 116 0 93 126 94 230 THE RCOMajen_ PAN ES Engineers / Surveyors Planners Environmental Scientists GIS Consultants CHAZEN ENGINEERING & LAND SURVEYING CO., P.C. Capital District Office: Dutchess County Office: Orange County Office: New England Office: North Country Office: 20 Gurley Avenue Manchester Rd. PO Box 3479 263 Route 17K Stratis Business Centers 110 Glen Street Troy, New York 12182 Poughkeepsie, New York 12603 Newburgh, New York 12550 99 Derby Rd., Suite 200 Glens Falls, New York 12801 Phone: (518) 235-8050 Phone: (845) 454-3980 Phone: (845) 567-1133 Hingham, MA 02043 Phone: (518) 812-0513 Phone: (781) 556-1037 This map is a product of The Chazen Companies. It should be used for reference purposes only. Reasonable efforts have been made to ensure the accuracy of this map. The Chazen Companies expressly disclaims any responsibilities or liabilities from the use of this map for any purpose other than its Intended use. Cayuga,He 79 City of l 327, Municipal Boundary - State Highway 0 2 4 8 StudyArea Miles MW Town of Dryden Index map of Tompldns County, NY showing the study area o and by: Draft Environmental Impact Statement Carol Conolly Ithaca Area Municipal Wastewater Collection Improvement Proiect o—: Figure 4-9. Town of Dryden Buildable Areas March 19, 2002 srd.: by Transportation Analysis Zone. various; see maps aoFa.: 90122.00 14 Table 28. Village of Lansing Buildable Acreage By TAZ TAZ Acreage 20 0.4 23 0.5 25 0.2 26 130.1 27 55.5 28 471.1 29 28.1 30 123.9 32 2 34 65.3 35 4.2 36 -13.3 38 44.1 39 25.8 40 4.8 41 2.5 42 31.5 75 0.5 Table 29. Town of Dryden Buildable Acreage By TAZ TAZ Acreage 72 107.8 73 70.8 74 15.1 75 156.3 76 68.3 77 332.1 78 215.9 79 72.7 80 5.2 91 31.7 92 12.1 93 106.5 94 127.4 95 74.4 96 231.8 97 146.6 103 388.50 104 1,084.50 105 614.30 106 1,042.40 113 0.7 115 0.8 116 1.1 15 5.5 Projected Development Density By Municipality Density of projected residential and commercial development by zoning district is summarized in Tables 4-30 and 4-31. Table 4-30. Summary of Projected Residential Density By Municipality Scenario 1 Population Increase Scenario 1 Dwelling Units Scenario 2 Population Increase Scenario 2 Dwelling Units Scenario 3 Population Increase Scenario 3 Dwelling Units Town of Lansing Village of Lansing Town of Dryden 1,478 289 435 635 140 .179 1,921 289 522 825 140 215 2,712 654 1,796 - 1,164 317 739 Table 4-31. Projected Summary of Commercial Density By Municipality Town of Lansing Village of Lansing Town of Dryden Scenarios 1 and 2 Retail Commercial 125,390 s.f. 55,658 s.f. 212,370 s.f. Non -Retail Commercial 69,196 s.f. 861,655 s.f. 70,789 s.f. Manufacturing 15,754 s.f. 144,961 s.f. Scenario 3 Retail Commercial 134,952s.f. 55,658 s.f. 228,562 s.f. Non -Retail Commercial 74,471 s.f. 861,655 s.f. 76,187 s.f. Manufacturing 16,956 s.f. 156,015 s.f. 5.6 Projected Development Density By School District Tables 32 and 33 summarize projected development density projections by School District. Table 32. Summary of Projected Residential Projections By School District Ithaca City S.D. Lansing Central S.D. Dryden Central S.D. Scenario 1 477 639 94 Scenario 2 556 818 113 Scenario 3 870 1,190 160 16 Table 33. Summary of Projected Commercial Projections By School District - Scenario 1 Retail Commercial Non -Retail Commercial Manufacturing Scenario 2 Retail Commercial Non -Retail Commercial Manufacturing Scenario 3 Retail Commercial Non -Retail Commercial Manufacturing Ithaca City S.D. Lansing Central S.D. Dryden Central S.D. 552,299 s.f. 113,209 s.f. 90,580 s.f. 429,603 s.f. 179,002 s.f. 30,193 s.f. 14,672 s.f. 15,039 s.f. 131,005 s.f. 552,299 s.f. 113,209 s.f. 90,580 s.f. 429,603 s.f. 179,002 s.f: 30,193 s.f. 14,672 s.f. 15,039 s.f. 131,005 s.f. 562,508 s.f. 121,928 s.f. 97,486 s.f. - 433,007 s.f. 183,969 s.f. 32,495 s.f. 15,791 s.f. 16,186 s.f. 140,994 s.f. 5.7 Projected Development Density By TAZ Tables 34 and 35 summarize projected development density by TAZ. 17 Table 34. Summary of Projected Residential Projections By TAZ TAZ Scenario 1 Scenario 2 Scenario 3 11 52 66 94 - 12 66 86 122 13 12 16 22 15 11 15 22 16 77 99 141 17 9 13 18 18 51 66 91 19 71 92 128 20 43 56 77 21 35 47 64 22 82 106 148 23 109 139 194 24 4 5 7 25 6 8 11 26 19 20 44 27 8 8 18 28 73 75 161 29 4 4 9 30 30 17 39 34 9 9 21 35 0 0 1 36 2 2 4 38 7 7 14 39 4 5 9 41 0 0 1 42 4 4 9 72 4 12 16 73 3 8 11 74 1 2 2 75 4 11 16 76 3 7 11 77 10 28 40 78 8 24 33 79 3 8 11 80 0 0 1 91 1 3 5 92 0 1 2 93 4 11 16 94 4 14 19 95 2 7 10 96 8 25 36 97 5 16 23 103 15 43 60 104 42 120 168 105 23 67 95 106 39 115 163 18 ITable 35. Summary of Projected Commercial Projections By TAZ 1 .. TAZ Scenario 1 Scenario 1 Scenario 1 Scenario 2 Scenario 2 Scenario 2 Scenario 3 Scenario 3 Scenario 3 Retail Non -retail. Manufact Retail Non -retail Manufact Retail Non -retail Manufact 11 63 31 63 12 68 14 12 74 41 74 41 80 45 13 14 7 14 7 16 8 15 3 2 8 3 2 8 3 2 9 ' 16 88 46 1 88 46 1 96 50 2 17 15 4 6 15 4 6 16 5 7 18 47 25 47 25 51 26 19 41 8 41 8 44 8 ' 20 15 3 15 3 16 3 21 40 8 40 8 43 8 22 48 9 48 9 52 10 ' 23 153 29 5 153 29 5 165 41 5 24 6 1 4 6 1 4 7 1 4 25 10 2 1 10 2 1 10 2 1 28 8 367 8 367 9 385 30 524 524 524 32 145 145 145 35 227 227 227 36 931 931 931 39 1 1 1 41 233 44 233 44 233 44 42 45 186 45 186 45 186 72 356 68 356 68 383 73 74 76 39 90 39 90 39 96 76 77 128 128 137 80 15 3 15 3 16 3 93 359 68 359 68 359 73 94 299 48 6 299 48 6 323 61 6 95 13 2 19 13 2 19 13 3 20 103 2 2 2 106 15 3 15 3 16 3 113 r 3 3 3 1 19 5.8 Projected School Age Children Generation Table 4-36 summarizes the projected generation of school -age children by school district and scenario. Table 4-36. Projected School -age Children Generation Ithaca City S.D. Lansing Central S.D. Dryden Central S.D. ' Scenario 1 82 117 17 Scenario 2 97 151 21 Scenario 3 147 217 29 5.9 Projected Employee Generation Table 4-37 summarizes the projected generation of employment by scenario. Table 4-37. Projected Employee Generation By Scenario Scenario 1 Scenario 2 Scenario 8 Town of Lansing 417 jobs 417 jobs 449 jobs Village of Lansing 2,548 jobs 2,548 jobs 2,548 jobs Town of Dryden 771 jobs 771 jobs 830 jobs 5.10 Land Conversion Table 4-38 summarizes the projected conversion of land from undeveloped to developed condition by scenario. Table 4-38. Projected Land Conversion By Scenario Scenario 1 Scenario 2 Scenario 3 Town of Lansing 645 acres 835 acres 1,174 acres Village of Lansing 112 acres 112 acres 201 acres Town of Dryden 199 acres 235 acres 760 acres 5.11 Projected Sales Tax Generation Table 4-39 summarizes projected sales tax generation by municipality and scenario. 20 Table 4-39. Projected Sales Tax Revenue By Scenario Scenario 1 Scenario 2 Scenario 3 ' Town of Lansing $26,254 $3,786 $57,176 Village of Lansing $26,254 $3,786 $57,176 ' Town of Dryden #28,256 $3,786 $61,536 5.12 Projected Municipal Fiscal Impacts Projected municipal fiscal impacts are summarized in Table 4-40. ' 5.13 Projected School District Fiscal Impacts Projected school district fiscal impacts are summarized in Table 4-41. M M MMMMM TABLE X. Fiscal Impact Assessment of Municipal Finances PROJECTED EXPENDITURES V Lansing 1 V Lansing 2 V Lansing 3 T _Lansing 1 TLanstng 2 T Lansing 3 T Dryden 1 T Dryden 2 T Dryden 3 Total Municipal Expenditure 3.610,460 3.610,480 3,610.480 5.408,603 5,408,603 5,408,603 4.739,822 4.739,822 4,739,822 Municipal Population' 3,417 3,417 3.417 10,521 10,521 10.521 13,532 13,532 13,532 County Population' 95,501 95,501 95,501 95,501 95,501 95,501 95,601 95,501 95,501 Existing total Local Nonresidential Real Property Value 229.527,538 229,527,538 229,527,538 381,941.560 381,941,560 381,941.560 214,129.667 214,129,667 214,129,667 Total Local Real Property Value 314,984,638 314,984,638 314,984,638 669,019.261 669.019,261 669,019,261 529,856,867 529.856.867 529,856,667 Average Value Nonresidential Parcels 655,793 655.793 655.793 428,186 428.186 428.186 130,170 130,170 130.170 Average Value of Ali Parcels 345,000 345.000 345,000 201.694 201,694 201,694 117,903 117.903 117.903 Projected Population Increase 289 289 654 1,478 1,921 2,712 435 522 1.796 Projected SF of Commercial Development 917.313 917,313 917,313 210.340 210,340 226.379 428.120 428,120 460,764 Average Cost of Commercial Development per SF 55 55 55 40 40 40 40 40 40 Refinement Coefficient #1 Input to use in look -up table 1.90 1.90 1.90 2.12 2.12 2.12 1.10 1.10 1.10 Value from look -up table 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 Refinement Coefficient #2 Input to use in look -up table 76.93 76.93 76.93 19.65 19.65 21.15 131.56 131.56 141.59 Value from look -up table 0.17 0.17 0.17 0.27 0.27 0.26 0.09 0.09 0.08 Total Municipal Expenditures Attributable to Nonresidential Uses 2.630.937 2,630,937 2.630,937 3,087.759 3,087,759 3.087,759 1,915.492 1.915.492 1,915.492 Residential Induced Expenditures 979,543 979.643 979.543 2,320.844 2,320,844 2,320,844 2,824,330 2.824,330 2,824.330 MunK;gict a�I Costs per Capita 287 ._#287 287 221 1, 1 2� 209 209 ri Re�derdia�Iv.lndueedAnhuai"MuiricinafF�cilcridkurelnctease....4..,.,..,_ . , ,; °sF .02,847..... ...82847'>' N ` � 187:48tA :,3 :03gq ,;:ia: : ,. 26 ..., ... , "..y" .. >.. •; .a. S9$'2 f ;: <<- . t0 949 .;c,:.s . ,, ,. .,.,42 .7 sM , 4g791' ; ^. :s„ -" _$ 374852 Incoming Facility Nonresidential Property Value_ 50.452,215 50.452215 50,452,215 8.413.600 8.413,600 9,055,160 17,124,800 17,124,800 18.430,560 Munciaal�Co�/lil•oCatedtts.No��e'�Fa (p�r,;„q . . . a:.in.,:::t c � >s " „ ::98:332•�.°z•, �,98'3 Zz°:�*,:�:a�3:ie�,,;�12�•fa,ass:-, «'aFm�•awa�.'d:.;.s'� - a..,� ;-a�;rzs..�e:3`F�5'"'""":;<r9033':.,-?"�;r�"��___. .. _ i3:787'..,.. -:�,.. ..,...3:190 'Based on 2000 U.S. Census. PROJECTED REVENUES V Lansing 1 V Lansing 2 V Lansing 3 T Lansing 1 T_Lansing 2 T Lansing 3 T Dryden 1 T Dryden 2 T_Dryden 3 COMMERCIAL Total Value of Projected Commercial Development 50,452,216 50,452.215 60.452,215 8,413,600 8,413,600 9.055.160 17,124,800 17,124,800 18,430,560 Tax Rate 1.70 1.70 1.70 1.53 1.53 1.53 1.70 1.70 1.70 _".__ ._ .. _... , ,.. „a" . R ue ro'F[oTiGted'GottrmerciaT.Devebnmeni?7 z- �bo ��'�.�:�:w".::.�....M::-..e.-...':.:mr".�.d5�i ,.iL�...L'ei.:d.. bb bpi 6.7 r 6 ._.,... ':ma`s:.=.::k�.. 32 $7s• ' s ' -: n ,., t o :J;s.;�:::3�tSZ... w;,�,r��e:a.r»:: :�,s:`i�:...�^Ra' �,...:,:.,`�.. v " 2:, 33 _ _ • RESIDENTIAL Average Household Size 2.06 206 2.06 2.33 2.33 2.33 2.43 2.43 2.43 Projected Population Increase 289 289 654 1,478 1,921 2,712 435 522 1,796 # Households 140 140 317 634 824 1,164 179 215 739 AverageHouseCost 155,097 165,097 155,097 177,517„ 177,517 119.816 119,816 119.816 w^" sx-Wx ,177,517 r'r. ","7 Reveue{(arirPiajeotef3rRes7deirtial De�efnpinencr: r=+:: T .„ Ec - ,.: Rs v s 36 990 36j990 83,707 172,286,.. . 223:925:. . ; ar 31$.130,` K V` � ,� ; 36.483;: ° e , A3�755�m 'p P O 'PRO:IEG D'C06A tALDEV;rM -! 1' fi43':^` - 1 :'j'NEj:G�UN/L..SS,F .M, FE, M„„ ..2.• - :E.2 '843 •a' -;�.= 6' 92".,: .'at„a;::-SB.• 2.: 2 : °K, "::=5103773�'e`:'- 'c55'179 k•: ";Sifi• 26', o-.,•"--'r'4C;-"516"32 '�`: '518"142 « � e-'"�NE9`.'GAINIL`bSS:FRd'MIPROJEGTEDRE$IDENTIA"DE1t;;'<="'" ;`.r.-$45°857''::��..�S4S867.'•."N. r5153748`-'°..:,,i• °Si9883t:. ai...'„'r.;.$2'1.15`E:`:'-,```'«-5:-:$54RJ28 :., _ _....:565:194".. ...,....-$224i3U8 CALCULATION OF SALES TAX REVENUE Proportion of County Population 0.04 0.04 0.04 0.11 0.11 0.11 0.14 0.14 0.14 Sales Tax per SF* 190 190 190 190 190 190 190 190 190 Proportion of Sales Tax that Municipality Receives 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 Projected SF of Retail Development $55,658 $55,658 $55.668 $125.390 $125,390 $134,952 $212.370 $212.370 $228.562 Projected Sales Tax Revenue $3.784 $3.784 $3,784 $26.246 $26.246 $28.248 $57,174 $57,174 $61.534 • Based on Southwest Area DGEIS :`a�:. . "r: 'e" ��,: �"OVERAI:I,NETfaAltdll:OSS.r�':> 400'r9' '.=00:5 6$'4,.`�a" i:i: t,>;�,�..,,,-.!;<;^,5.:,.•c•�>.. OVERALL>NE'fiGA1N1LOSS+SAI:.E57AX'fiE{fENUEs��",:�:.,?.�54;ir't6„:5�"=54.695F,`=i,.,s.1�2rS33'�='s``.rv,-132;ee4:*,,.,. g g;, z169241.at . 118`31 .*a #', .:.i¢,t ';"^ r�".205`32itr.;�i--'vt;<„ 294`:°• u ,:� 90 Y;tt°:<"M >-x ,; "`�t 4 z;,n<;r�' o s , r., . `•'�!i, . < 2.;,_ f:»`:': �: , �x . 3 µ w.. . 9,869.1 �':; � , z,-2 6;16 'Y :i7.Y kM<'e ,, �>'fi9:1117•r"::,:z.,.-;-.%=258;ti46..• .�.F:e.-?:'j:w>'18:171.:�;&,`i'•^;144'fi37, F z , } - B � 4 ^3m n N Ii 8d 9 r � xdoo eae o0o Bee 8oe S8e oee vae aoe i i Pnw€' d x W V^ o 0 0 a P � 5 e^^� =g 800 Bad Sao eg8 egg; og; a 'a-_m 4: aao� � lss.3 wa4 ungamxt ril ri, €9 ms mq m i - 4��E � a��N k)�� g'gyyS 55� C�^gyyE Sz5z. ''@�N gW yy6, g�$yE.53E$f� ggy$E,55H111111 �5y55E$�y.�E�WgEE 'Sh a8�j d8'3i ipz 33�8ij� 3Ei6fi a3 di5� $}', yy °�d�$$ 85a$p Soltg' I'�S vL rr�> ~Hill OCI al l .still toGr'~I82 S^1S���=11 ^S7iY $ Hill Hi villa E€6'ap EE�iy 'illsIll E1� Hi �a �V EFL' E Eia EDC F E� EE.BEa { $�C Ee Hill A11139 5pgµs11boaaad- aana LL on 1ia�r an�6a�Eb� a a a S a � � Aa Steams &Wheler,LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS AGENDA REVIEW OF DEIS SCOPE OF WORK MUNICIPAL COLLECTION SYSTEM IMPROVEMENTS ITHACA, CAYUGA HEIGHTS, DRYDEN AND LANSING, NEW YORK January 11, 2001 S&W No. 80318.9 I. Use of Existing Draft Scoping Document10 ,o • Update for revised scope j°�°` `" • Update with Committee comments (S. Blumenthal) Ll.� �� W w..t..oc.�•t-�-s II. Draft EIS - Chapter 1 - Project Description, Chapter 2 - Existing Environ. Setting w -J- • Refocus away from WWTP issues r� • Existing Environmental Setting - No stream crossings - s� ��^'. - �� t,Cf �GV - C� III. Draft EIS - Chapter 3 - Impacts and Mitigation Measures / • Delete impacts and mitigation related to WWTP and Sewage Discharge / 15, IV. Draft EIS - Chapter 4 - Growth Inducing Impacts • Conduct Two Growth Scenarios compared to No Action - "Only Water Service" - Current Growth Rate -1q_ - Moderate Growth Rate f5 - Only evaluate Growth Induced by "Sewers" • Articulate Impacts of Effects on Countywide services • Reuse of Existing County Data & Related Cost Savings Lk k` • Elimination of Traffic Model C- A/,�, F F) 'C-- V. Final EIS Cost Estimate a 1J.r .. t C�-- p a f/r v S&W Form 197 (08/00) �D�"� ���Stearns&Wheler WASNOTayuga Hgts Agenda TWF 01-11-0Ldoc Companies h✓U� Plat, w `5 �"' . w �. j .('1,,,,, p. y.,..�cs.S a r-� v--cLlc � � SG/Q �` di'`�"'�✓ .ti. c �.Jr' �•^--a (JJ � �. 6 �c e ry t cT JvI c ,� �ce�� Z ci C� - -Z vl� w� you ✓ ✓ g S RC 16 S 6-,1 V .-c r U-1 w. 1 S �W_ a 0 bu j4-x to r )- I I r s u IL_ Kol I I v o &,A bc-,I- - col e. --b C-o iai ✓�s b�� k� w,, A, ,X , ,ram �6 bLIr7dk o�x � Steams &Wheler, LLc DRAFT SCOPING DOCUMENT ENVIRONMENTAL ENGINEERS & SCIENTISTS Revised January 11, 2001 ITHACA AREA MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS The following is a list of required items and topics to be included and discussed in the Environmental Impact Statement for the Municipal Wastewater Collection System Improvements. A. Cover Sheet. The EIS shall have a cover sheet that includes the following information: whether the document is a "draft" or "final" EIS. the title of the project. location of the project. • name and address of the lead agency and the name and telephone number of a contact at the lead agency. name and address of persons who prepared the statement and contact names and telephone numbers. date of acceptance of the draft EIS. the deadline for review comments (when in draft form). B. Table of Contents and Summary. A Table of Contents is required to be included for both the draft and final EIS. A summary is also required and should include: • a brief description of the action. • significant, beneficial, and adverse impacts (identify issues of controversy). identify mitigating measures. • identify alternatives. • identify permits, approvals, or funding to be decided. C. Description of the Proposed Action. 1. Project Purpose and Need. Discuss the background and history of the proposed project. Discuss the public need for the project and the objectives of the involved municipalities based on adopted community development plans, and indicate the joint owner's objectives. 2. Location. Establish geographic boundaries of the project (use regional and local scale maps). Describe access to the proposed project site and existing zoning. Revised January 11, 2001 1:\8000\803181 MVordproc\N1isc\Lansing Scoping Documen[.doc Lei Stearns &Nheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS DRAFT SCOPING DOCUMENT PAGE Design and Layout. Provide a description and separate figure of the following: a. Total site area including: • proposed impervious surface area (e.g., roofs, parking lots, roads). • amount of land to be cleared. open space. b. Structures including: • sewers and pump stations. • site plans and profile views. 4. Construction and Operation. a. Construction. Indicate the anticipated length of construction and provide a proposed construction schedule. Discuss possible future development both on -site and within adjoining properties. Also, discuss the costs within each municipality with and without the proposed sewer infrastructure. b. Operation and Maintenance. Discuss the type of operation and maintenance involved in the proposed project. Discuss growth -induced impacts on fiscal costs of operation and maintenance. 5. Approvals. Changes or variances to the zoning regulations required for the proposed project shall be indicated as well as other permit or funding requirements. D. Environmental Setting and Significant Environmental Impacts. The following are topics that shall be discussed in detail in the Environmental Impact Statement. Also, identify and discuss aspects of the environmental setting within and surrounding the proposed project area that may be significantly adversely or beneficially impacted by the proposed action. 1. Natural Resources. a. Geology. • Subsurface. Discuss composition and thickness of subsurface material (e.g., depth to and nature of bedrock formations and impermeable layers, occurrences of an extractive mineral source, usefulness as a construction material). • Surface. List the types of soils and discuss their characteristics such as physical and engineering properties. Indicate how these soils are distributed within the project area and discuss their appropriate use in agriculture, and other uses related to the proposed project. Revised January 11, 2001 J:\8000\8071811\Wordproc\Misc\Lansing Scoping Document.doc Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS DRAFT SCOPING DOCUMENT PAGE 3 Topography. Describe the topography of the proposed project area noting prominent or unique features. Also, describe the topography of the areas surrounding the proposed project area. Discuss proposed modifications to existing hydrologic features (e.g., streambeds or embankments, drainage ditches, culverts) and possible impacts on flooding and drainage caused by the proposed project. b. Water Resources. • Groundwater. Describe aquifers and recharge areas (e.g., depth to water table, seasonal variation, quality, quantity, and flow). Indicate the present uses and level of use of groundwater, such as location of existing wells, public/private water supplies, industrial uses, agricultural uses, and positive and negative impacts on these resources by proposed project. Surface Water. Provide the location and description (including NYSDEC surface water classifications) for surface waters located within the project area or those that may be influenced by the proposed project (e.g., seasonal variation, water quality, and classification according to the New York State Department of Health). Also, identify the use and level of use of surface waters such as public/private water supply, industrial uses, agricultural uses, recreation, and positive and negative impacts on these resources by proposed project. C. Air Resources. • Climate. Discuss seasonal variations and extremes in temperature, humidity, precipitation, wind, and impacts they have on proposed project. Air Quality. Describe air quality levels within the proposed project area. List the National and State Air Quality Standards for the project area and the compliance status for each standard. Identify existing sources or pollutants, both fixed and mobile, and identify sensitive receptors in the area such as hospitals, schools, nursing homes, parks, etc. Describe existing monitoring program within the project area. • Odors. Discuss potential for odor generation from new collection system and pump stations in relation to surrounding areas and neighborhoods. d. Terrestrial and Aquatic Ecology. Vegetation. Identify types of vegetation within both the proposed project and surrounding areas. Also, discuss the characteristics of each type such as presence and abundance of species, age, size, distribution, dominance, community types, unique, rare and endangered species, value as a habitat for wildlife, and productivity. Revised January 11, 2001 1:\8000\8031811\Wordproc\Misc\Lansing Scoping Document.doc A_� Stearns &Wheler, L.L.c ENVIRONMENTAL ENGINEERS & SCIENTISTS DRAFT SCOPING DOCUMENT PAGE Fish and Wildlife. Identify species of fish and wildlife within the proposed project and surrounding areas, including migratory and resident species. Discuss their population and characteristics such as presence and abundance, distribution, dominance, unique or rare and endangered species, and productivity. Wetlands. Identify wetland areas within or adjacent to the proposed project area. Also, discuss the characteristics including acreage, vegetative cover, classification, and benefits of the wetland such as flood and erosion control, and recreation. Preserves and Natural Areas. Identify public or privately owned preserves or natural areas within the proposed project area. Unique Natural Areas (UNA). Identify any UNA within the proposed project area and discuss the characteristics (acreage, features, etc.) and benefits to the area. 2. Growth -Inducing Impacts. a. Demography. • Population Characteristics. Describe the current population's characteristics within the proposed project area. Indicate the population's distribution, density, and household size and composition. Also, discuss projections for population growth with and without the changes caused by the proposed project.. b. Cultural Resources. Visual Resources. Describe the physical characteristics of the community (urban versus rural) and the natural areas of significant scenic value. Historic and Archaeological Resources. Perform a literature search and describe the location of historic areas or structures listed on State or National Register or designated by the community. Identify sites having potential significant archaeological value within the proposed project area. C. Land Use and Zoning. Existing Land Use and Zoning. Describe and analyze existing land use and zoning for each municipality within the proposed project area including commercial, residential, agricultural, business, retail, industrial, and vacant areas. Note if potential growth -induced impacts are consistent with the community's existing zoning and comprehensive plans. Calculate the "historic growth quotient" in the study area to measure the change in urbanized land relative to the growth in households for the past 20 years. Describe zoning ordinances and how they contribute to regional growth patterns. Revised January 11, 2001 J:\8000\8031811\Wordproc\Misc\Lansing Scoping Docwnent.doc L& Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS d. Future Development Patterns and Induced Growth. DRAFT SCOPING DOCUMENT PAGE 5 1� Land Use Plans. Discuss potential land use plans under current zoning and potential land use as a result of expanded service along with any proposed zoning changes. Describe changes in development costs within each municipality with and without sewer infrastructure. Calculate a "future growth quotient" in the study area to measure the change in urbanized land relative to the growth in households as a result of the induced growth. Describe the impact of induced growth on the preservation of the region's unique physical character — the historic city and villages, and the region's farms, forests, rural character, and open spaces. e. Transportation. Transportation Services. Describe the size, capacity, and condition of transportation services, such as roads, canals, railroads, bridges, parking facilities, and traffic control. Describe the current level of use of these services such as morning and evening peak hour traffic flow, vehicle mix, and existing sources of traffic volume. Discuss overall impacts of the project on existing key roads, intersections, neighborhoods, and the potential construction of any new roads. Also, discuss fiscal impacts on transportation services due to potential growth, including operation and maintenance costs. • Public Transportation. Describe the current availability of public transportation services and their present level of use. Also, identify potential growth -induced impacts on public transportation services. Pedestrian Environment. Briefly describe the pedestrian environment within the proposed project area and potential growth induced impacts on this environment. Land Use Plans. Describe plans for land use and/or the status of comprehensive plans in the proposed project area, such as the possibility that the proposed project may encourage non-agricultural development. Discuss future development trends or pressures in progress (i.e., Northeast Subarea Transportation Study, Cayuga Lake Waterfront Revitalization Plan, etc.). Describe the interrelationships of these land use or comprehensive plans and how they contribute to regional growth patterns. f. Community Services. Public Services. Provide a list of existing facilities and discuss their current and projected use, as well as potential growth -induced impacts, including schools, police protection, fire protection, recreational facilities, and utilities. Discuss fiscal impacts on services including costs and benefits from changes in growth patterns that would result, including operation and maintenance costs. Revised January 11, 2001 3:\8000\8031811\\Vordproc\N1isc\Lansing Scoping Document.doc � M Stearns &Wheler, LLc DRAFT SCOPING DOCUMENT ENVIRONMENTAL ENGINEERS & SCIENTISTS PAGE 6 g. Budget Analysis. Analyze affordability of the sewer projects for each municipality. E. Mitigation Measures to Minimize Environmental Impact. Discuss measures to reduce or avoid potential adverse impacts previously identified. F. Adverse Environmental Impacts. Identify adverse environmental effects that cannot be avoided if the proposed project is implemented regardless of mitigating measures considered. G. Alternatives. Discuss alternatives to the project as currently proposed. Potential alternatives include no action and reduced sewer service areas. Other alternatives to be considered will be identified and assessed during preparation of the DEIS. Include a comparative assessment of costs, benefits and environmental risks for each alternative. H. Appendices. The following backup materials shall be used as supporting documents to the Environmental Impact Statement: 1. List of underlying studies, reports, and information considered and relied upon in preparing the statement. 2. List all federal, state, regional, or local agencies, organizations, consultants and private persons consulted in preparing the statement. J. Technical exhibits at a legible scale. 4. Relevant correspondence regarding the projects. Revised January 11, 2001 1:\8000\8031811\Wordproc\btisc\Lansing Scoping Document.doc 1AN Stearns &Wheler, LLc MEETING ENVIRONMENTAL ENGINEERS & SCIENTISTS ANNOUNCEMENT MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA WHAT: EIS - Traffic Study & Data Collection, Cost Review & Approval WHERE: Town of Ithaca, Town Hall WHEN: March 22, 2001 TIME: 9:00 a.m. The cost for Chazen Associates to obtain the intersection turn movement counts and the SUMMARY: link directional counts for use by ITCTC for the traffic study is as follows: ITEM COST Intersection -Turn Movement Counts $220 per intersection Roadway - Link Directional Counts $455 per Link Directional Count As indicated by ITCTC, there are 15 intersections requiring turn movement counts, and 11 roadways requiring link directional counts. The City of Ithaca has turn movement counts required for 2 of the 5 intersections at Fulton Meadows area, which would reduce the total cost accordingly. The estimated total cost is as follows: • 13 Intersections, Turn Movement Counts • 11 Roadways, Link Counts Total $2,860 - �� � 1 h, (-,I i 5,000 - 4- by c� � $7,860 As discussed at the last meeting, the outstanding traffic data needs to be collected during the month of April, while students are still in attendance. Please attend this meeting prepared to discuss approval of this phase of work, and to discuss approval of the overall EIS scope of work to allow the EIS work to move forward. y"c-sh6'- - (tvik � r- : Mwindows\TEMPWeeting Announcement 3-22-01.doc Z& Stearns &Wheler r'ompanies 1-*--\ Stearns &Wheler, = ENVIRONMENTAL ENGINEERS & SCIENTISTS AGENDA EIS SCOPE REVIEW ITHACA AREA MUNICIPAL COLLECTION SYSTEM IMPROVEMENTS March 22, 2001 S&W No. 80318.9 A. Data Collection — Traffic Study 1. Proposed Cost 2. Approval to Move Forward and Collect Data in April B. Other EIS Scope Issues sf✓ h'r ",-I l 1. Development Potential Analysis �', I A-" f o Methodology for Growth rate Determination 2. Fiscal Impact Analysis • Cost Breakdown • Proportional Valuation Methodology C. Draft EIS 1. Scope Modification and Approval S., S ", - C-1,�) ()S".S y/o J 0 n o - 4, -� wl c�-,-"-6AI` — ""sue S+-" / V S Lc� S P \J / u If 61, 'e v i/! Lam,//-- ) / j - T,lt. o f ( 14_ ✓ c IN S&W Form 197 (08/00) J:\8000\8031811\Wordproc\Agendas\03-22-Ol.doc u'. y by ��StearIlS&Wheler r,)mpanies S�—�oIS f b L—j t'v , vo u—u;e i U- zL c b S 17 G i L // 1 L T G /0 4J- Sa Li,� i --v w i Vc-t4 5< vo �oF 3 -Ilzt s &--S Stearns &Wheler, nc ENVIRONMENTAL ENGINEERS & SCIENTISTS LIST OF FIRMS REQUEST FOR QUALIFICATIONS PREPARATION OF AN ENVIRONMENTAL IMPACT STATEMENT FOR MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA W ri' adway Saratoga Springs, NY 12866 Phone: (518) 587-2550 Fax: (518) 587-2564 Response: Left a voice mail message on 8128100, no response to date. 14U Route 9, Building I " Clifton Park, NY 12065 Phone: (518) 371-0929 Fax: (518) 371-0623 Response: RFQ received. 40 Long Alley Saratoga Springs, NY 12866 Phone: (518) 587-8100 Fax: (518) 587-0180 Response: Left a voice mail message on 8128100, no response to date. Y 11Y1L+ E iHRS : ," 136`Sims ury Road Riverdale Farm Avon, CT 06001 Phone: (860) 677-5267 Response: Left a voice mail message on 8128100, no response to date. 2T5�1vTain Street White Plains, NY 10601 Phone: (914) 761-3582 Fax: (914) 761-3759 Response: RFQ received. "Et4rKt%L `Computer Drive Albany, NY 12205-1623 Phone: (518) 458-7112 Fax: (518) 458-1879 Response: Will not be submitting a Statement of Qualifications. C Ul1E H'k VLJ i�iL A Vt;JA act . �e:S� a+` r.� k `� r `: �,':...". _> i Winners Circ e, Box 5269 Albany, NY 12205 Phone: (518) 453-4500 Fax: (518) 458-1735 Response: Left a voice mail message on 8128100, no response to date. JA8000\803 181 1\Wordproc\Misc\RFQ List.doc Stearns &Wheler _. Companies June 21, 2001 Mr. John Merriman NYSDEC 1285 Fisher Avenue Cortland, NY 13045-1090 Re: Review Meeting and Determination of Significance Ithaca Area Municipal Collection System Improvement Project S&W No. 80318.5 Dear Mr. Merriman: Enclosed with this letter is the updated Overview Document, Draft Scoping Document, and Project Timeline for the Ithaca Area Collection- System Improvement Project for NYSDEC review and comment. Also enclosed is an agenda for our scheduled meeting at the Cortland office of NYSDEC on Tuesday, June 26, 2001 at 9:30 a.m. to update NYSDEC on the project status, and to discuss any outstanding issues or questions that NYSDEC may have to allow a "Determination of Significance" for this project. Following the June 26, 2001 meeting, the Overview and Draft Scoping Documents will be finalized and submitted to NYSDEC with a formal request for NYSDEC to make its "Determination of Significance." If you have any questions, please do not hesitate to contact me. Very truly yours, Thomas W. Friedrich, P.E. Senior Project Manager TWF/jm Enclosures cc: Ralph Manna, NYSDEC (w/enc.) Steve Eidt, NYSDEC (w/enc.) EIS Committee Members (w/enc.) !.\8000\803181 1 \ Wordproc\1cttm W ERT W F01.doc Stearns & Wheler, LLC • S&W Services, Inc. • S&W Redevelopment, LLC One Remington Park Drive • Cazenovia, New York 13035 • (315) 655-8161 • tax: (315) 655-4180 it S Stearns &Wheler, LLc AGENDA ENVIRONMENTAL ENGINEERS & SCIENTISTS NYSDEC REVIEW MEETING MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA NYSDEC — Cortland Office Tuesday — June 26, 2001— 9:30 a.m. S&W No. 80318.9 A. Update NYSDEC on Project Status 1. Redefined Elements of Base Project - Overview Document 2. Status of Intermunicipal Agreements 3. EIS Consultant (Chazen Associates) 4. Conducted Traffic Counts for Traffic Portion of Draft EIS 5. Proceeding with Draft EIS Work B. NYSDEC - Discussion on "Determination of Significance" 1. Documents for "Determination:" • Long Form EAF - Completed and Submitted to NYSDEC • Overview Document - Updated and Submitted to NYSDEC 2. Draft Scoping Document - Completed and Submitted to NYSDEC C.. Project Schedule 1. NYSDEC - Proposed Date of Official "Determination of Significance" 2. Project Timeline S&W Forth 197 (08/00) 1AWO\807181 I\ Wordproc\Agendas\06-26-01.doc ZZ Stearns &Wheler companies 4--� Stearns &Wheler, LLc DRAFT AND FINAL EIS TIMELINE ENVIRONMENTAL ENGINEERS & SCIENTISTS June 21, 2001 MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA Note: Italics represent actions the municipalities must take Action Item I Completed 1. Chazen to Perform Traffic Study Data Collection Required per ITCTC Request I ✓ 2. Finalize Wording of New Contract with Stearns & Wheler (S&W) and I ✓ Subconsultan.t, Chazen Associates 3. Revise Draft Scoping Document-(Chazen Task) ✓ Municipalities approve revised draft Scope. 4. Sign Contract with Stearns & Wheler • Need municipal resolutions authorizing each Mayor/Supervisor to sign S. Give Stearns & Wheler and Chazen Notice to Proceed ✓ 6. Update Overview Document (Stearns & Wheler) ✓ • Municipalities approve revised Overview Document 7. Kickoff Meeting with NYSDEC, Stearns & Wheler, Chazen, and Municipalities • Give NYSDEC the draft Scope and Overview Document before or at the meeting 8. NYSDEC makes determination of significance (positive declaration) • This can happen anytime before or after kickoff meeting 9. NYSDEC Conducts Scoping • NYSDEC circulates draft scope to involved and interested agencies and individuals • Agencies and public review and comment on draft scope • Possible public meeting (municipalities should have representatives attend) 10. NYSDEC Issues Final Scope Within 60 days of its receipt of draft scope 11. DEIS Prepared (by Chazen and Stearns & Wheler, with Traffic Study by ITCTC) • Target date of four months from notice to proceed to submission to NYSDEC • Draft Joint Sewer Agreement and any other intermunicipal agreements must be ready for public release in DEIS • Municipalities approve submission to NYSDEC 12. Municipalities Submit DEIS to NYSDEC Revised June 21, 2001 1:\8000\803181 I\ WordprocWiscUthaca 06-21-01 doc\EIS Timeline.doc ,Stearns&Wheler lbmpanics &.� Stearns &Wheler, LI.c- ENVIRONMENTAL ENGINEERS & SCIENTISTS DRAFT AND FINAL EIS TIMELINE PAGE 2 Action Item 13. NYSDEC Determines Adequacy of DEIS • Within 45 days of receipt of DEIS 14. NYSDEC Files and Publishes Notice of Completion of DEIS, Starting Public Comment Period • Minimum public comment period is 30 days from notice of completion, or 10 days following public hearing, whichever is later • Probable public hearing (need 14 day advance notice by publication; hearing to be held no less than 15 days nor more than 60 days after notice of completion) • Municipalities should have representatives attend hearing 15. NYSDEC Files FEIS and Notice of Completion • Chazen prepares FEIS • Possible changes to intermunicipal agreements as a result ofpublic comment • Municipalities approve submission of FEIS to NYSDEC • NYSDEC must file FEIS within 45 days after close of public hearing. 16. Municipalities and Other Involved Agencies Prepare Findings Statements • 10-day waiting period after filing of FEIS 17. Municipalities Decide Whether to Sign Joint Sewer Agreement and Any Other Intermunicipal Agreements 18. Municipalities Make Other Decisions Related to Bond Act Projects • Timing and actions dependent on NYS decision on Round 3 Bond Act application 19. Modify SPDES Permit(s) for New Municipalities (Owners) of Wastewater Treatment Plant(s) Completed Revised June 21, 2001 :\8000\803181I\Wordproc\Misc\Ithaca 06-21-Ol.doc\EIS Timeline.doc ANStearns&Wheler ,nmpanies &--� Stearns &Wheler, LLc OVERVIEW DOCUMENT ENVIRONMENTAL ENGINEERS & SCIENTISTS June 21, 2001 MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA Purpose The purpose of this overview document is to provide a summary of the proposed wastewater collection and treatment system improvements for the communities of Ithaca (City and Town), the Village of Cayuga Heights, the Town of Dryden, and the Town and Village of Lansing, New York. The overall project represents a regional approach for wastewater collection and treatment, as well as protection of the Cayuga Lake watershed for the six involved municipalities. This document identifies the schedule and status of each project (by community); and summarizes the proposed intermunicipal agreements to convey and treat flows that are required for these projects. Some of the community projects have been completed independent of the overall regional approach. The completed projects have already undergone the environmental review process (State Environmental Quality Review Act, SEQRA), and therefore are not included in the SEQRA process for the new community projects. An overall summary of the environmental review process for each community project is provided as part of this document. This document describes the regional approach for wastewater collection and treatment in the following sections: • Background and Overview • Environmental Review and Involved Agencies • Project Descriptions • Projected Sewage Flows and Loadings • Total Estimated Project Costs • Intermunicipal Agreements. • Summary of Previous Technical Reports and Funding Applications Background and Overview of Overall Project On October 20, 1997, the City of Ithaca, Village of Cayuga Heights, and Town of Lansing submitted individual applications for funding under the New York State Clean Water/Clean Air Bond Act process. The City of Ithaca submitted an application largely for major interceptor improvements to eliminate infiltration and inflow and to fund wastewater plant improvements. under construction to achieve a 13.1 mgd rating. The Village of Cayuga Heights applied for a modest amount to upgrade specific plant process elements. The Town of Lansing applied for monies to build collector sewers and a new wastewater treatment plant. All applications were denied under the first round with the New York State Department of Environmental Conservation (NYSDEC) citing low benefit to the environment. After extensive conversations with the NYSDEC, a regional approach to wastewater collection and treatment, which provided more environmental improvement, was proposed. On June 3, 1998, the City of Ithaca submitted a joint application, along with the Town of Lansing and the Village of Cayuga Heights, for state grant funding available for wastewater treatment and collection systems improvements under the New York State Clean Water/Clean Air Bond Act. Partial funding was awarded. Revised June 21, 2001 1:\8000\8031911\Wordproc\D1isc\1thaca 06-21-01.doc\Overview Document doc &\Stearn$&` eler r'�mpanies 1-t Stearns &Wheler, LLC ENVIRONMENTAL ENGINEERS & SCIENTISTS OVERVIEW DOCUMENT PAGE 2 An evaluation of regional solutions to the wastewater collection and treatment needs of the six member communities was undertaken to satisfy the conditions of the original grant award, as well as to support additional or amended grant funding requests. Representatives of the member communities, including the City and Town of Ithaca, the Village of Cayuga Heights, the Town and Village of Lansing, and the Town of Dryden, met to review the results of the detailed evaluation of alternatives presented in the Unified Engineering Report, August 1999, prepared by Stearns & Wheler, LLC, and T.G. Miller, P.C. On the basis of the review of the total project costs and estimated operation and maintenance costs for each of these alternatives, the member communities selected the Cayuga Heights partial diversion alternative as the recommended plan. A second application was prepared and submitted on August 17, 1999 to include additional projects within the Town of Lansing, Village of Lansing, Village of Cayuga Heights, and City of Ithaca. The joint grant applications represent a cooperative effort to provide municipal wastewater collection and treatment to unsewered. areas in the Town of Lansing and to improve water quality in Cayuga Lake. On October 27, 2000, a third Bond Act application was prepared and submitted by the six municipalities. The project scope and costs requested for funding in the 1999 Bond Act were revised to reflect only those elements necessary for the regional solution (Partial Diversion Alternative) for wastewater c1 o� ll ction and treatment for the six municipalities. 41 laD1�� JS Under the partial diversion alternative, some of the wastewater generated within the Towns of Lansin, Ithaca, and Dryden will be conveyed to the Cayuga Heights wastewater treatment plant. Because the Cayuga Heights plant is operated at near -design capacity, some wastewater will be diverted from the Cayuga Heights sewer system to the Ithaca area wastewater collection system for treatment. This flow diversion will be accomplished by installing interceptor sewers to connect the Cayuga Heights and Ithaca service areas. Modifications will be made at the Cayuga Heights wastewater treatment plant to improve wastewater treatment reliability. Capacity for treatment of the wastewater generated from the City of Ithaca, the Town of Ithaca, the Town of Lansing, and the Town of Dryden, as well as wastewater diverted from the Village of Cayuga Heights wastewater treatment plant (VCHWTP), is available at the Ithaca Area Wastewater Treatment Plant (IAWWTP). Previous construction modifications to the IAWWTP have been made (independent of this project), which increased the flow capacity from 10 to 13.1 mgd. The existing owners of the IAWWTP (City of Ithaca, Town of Ithaca, and Town of Dryden) submitted an application to the NYSDEC on March 1, 1995, to permit the plant for 13.1 mgd. Positive benefits of the proposed project include the following: • Beneficial impact on groundwater quality by eliminating inadequate on -site septic systems within the proposed Town of Lansing sewer service area. • Rehabilitation of existing sewers will eliminate wastewater overflows into Cayuga Lake tributaries that occur during extreme wet -weather conditions. Revised June 21, 2001 1:\8000\8031811\Wordproc\Misc\1thaca 06-21-01.doc\Overview Document.doc AStearns&Wheler rbmpanies &--S Steams &iVheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS OVERVIEW DOCUMENT PAGE 3 • Beneficial impacts on water quality from the elimination of individual SPDES discharge permits held by residential, commercial, industrial, and institutional facilities within the proposed Town of Lansing sewer service area. The partial diversion alternative was selected as it provides a regional solution to the wastewater collection and treatment needs of the area and maximizes the overall benefits to the environment. Environmental Review and Involved Agencies Some of these projects are subject to environmental review under the State Environmental Quality Review Act (SEQRA), which requires all state and local government agencies to consider environmental impacts and factors when funding, approving or directly undertaking an action. The environmental reviews in this case will be used to guide the direct actions of the local agencies, and to satisfy funding requirements under the State Revolving Fund and Bond Act. Actions are subject to review under SEQRA if any state or local agency has the authority to issue a discretionary permit, license, funding, or other type of approval, or adopts a rule, policy, or plan that may affect the environment. The steps required for the SEQRA process are indicated on the enclosed SEQRA flow path chart. The six municipalities submitted a full Environmental Assessment Form (full EAF) for this project on June 18, 1999, to the NYSDEC. The involved agencies for this project include the following: • Village of Cayuga Heights • City of Ithaca • Town of Lansing • NYSDEC • NYSDOT • Tompkins County Department of Public Works • Town of Dryden • Town of Ithaca • Village of Lansing • NYSEFC • Tompkins County Planning Department • Tompkins County Health Department As previously stated, some individual community projects have already been completed, along with the environmental review under SEQRA. Some phases will not require SEQRA (i.e., Type II projects). The remaining projects are classified as either "Type I" or "Unlisted Actions" that require preparation of environmental assessment forms and a "Determination of Significance:" The municipalities have requested that the NYSDEC be the lead agency for the SEQRA process for the portions of the Unified Project involving the creation of new service areas in the Town of Lansing, extension of existing sewer service areas in the Towns of Ithaca and Dryden, and for the connection of additional sewer units in the Village of Lansing. It is anticipated that the Village of Cayuga Heights will be the lead agency for the Cayuga Heights Wastewater Treatment Plant Filtration Project for phosphorus removal, and the City of Ithaca Board of Public Works will be lead agency for the IAWWTP Grit Removal Project. The environmental reviews for the filtration and grit removal projects at the area wastewater treatment plants are not being included in the review for the other projects, because they are independent projects. Construction of the filtration and/or grit removal projects can proceed independently of the project to extend and provide new sewer service. Revised June 21, 2001 1:\8000\8031811\%Vordproc\Misc\Ithaca 06-21-01.doc\Overview Document.doc AN Stearns &Wheler Companies r t A_N Steams &Wheler,= ENVIRONMENTAL ENGINEERS & SCIENTISTS OVERVIEW DOCUMENT PAGE 4 The relevant agency must determine the significance of the projects classified as Type I or unlisted actions, as shown on the enclosed SEQRA flow chart. A positive declaration of significance requires the preparation of a draft Environmental Impact Statement (DEIS); a Negative Declaration would end the SEQRA process. A summary table of the base project elements, their SEQRA classification, and status is summarized below. A detailed description of each community project and phase is provided in the next section. Municipality and Project Phases Town of Lansing Municipal Sewer Collection System (New Service Area) Diversion from VCHWWTP to IAWWTP Extension of Existing Service Areas (Towns of Ithaca and Dryden) and Inclusion of Additional Units (Village of Lansing) IAWWTP Interceptor Improvements (Phase 1) (Project Completed) IAWWTP Plant Re -Rating (Project Completed) IAWWTP Interceptor and Collector Sewer Improvements (Phase 2) (Project Completed) Cayuga Heights Wastewater r Treatment Plant Improvements IAWWTP Phosphorus Removal Cayuga Heights Wastewater Treatment Plant Filtration (Phosphorus Removal) IAWWTP Grit Removal IAWWTP Phase 3 Interceptor and Collector Sewer Improvements Revised June 21, 2001 1:\8000\803181 I\Wordproc'Misc\Ithaca 06-21-01.doc\Overview Document.doc SEQRA Classification Type I Unlisted Type II Action Action Action SEQRA Status X NYSDEC as lead agency to determine significance. X INYSDEC as lead agency to determine significance. X NYSDEC as lead agency to determine significance. X I SEQRA completed. X I I SEQRA — Public comment period. X SEQRA completed. X I I Further SEQRA review not >( required. X IFurther SEQRA review not required. 947 X _Vj' Cayuga Heights to complete EAF and determine significance. City of Ithaca Board of Public Works to complete EAF and determine significance. X Further SEQRA review not required. L_\ Stearns&Wheler ,panies AStearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS Project Descriptions OVERVIEW DOCUMENT PAGE On April 4, 2000, the joint municipalities received notification via a Governor's press release that the Ithaca/Cayuga Heights/Lansing Bond Act Projects would only receive an additional $515,420 over that previously awarded and committed, bringing the total level of Bond Act funding for the Unified Project to $7,513,920 out of $21,480,250 requested. As a result, the municipalities have had to scale back the overall project to a Base Project, which is financially affordable while protecting the water quality of the Cayuga Lake Watershed through a regional approach to wastewater collection and treatment. Implementation of this Base Project, however, will require additional funding, as requested in the October 27, 2000 Bond Act Application. The following describes the various projects and phases of a Base Project broken down by municipality. A Project Phase Timeline table summarizing each phase, the projected dates for final design, advertisement and bidding, and construction is attached. More detailed descriptions indicating proposed service areas can be found in the Unified Engineering Report, August 1999, and the Wastewater Facilities Report, Town of Lansing, October 1998. A map of the proposed service areas and municipal sewer collection systems is attached to this document. The geographic boundaries agreed to for the SEQRA study are specific to this study and do not imply agreement by the member communities as the ultimate boundaries of the future service area of the IAWWTP. That decision will be made as part of the current negotiation of the Intermunicipal Agreement process and will be based on data generated during the SEQRA process. A Budget Summary of the Base Project is also attached, which summarizes the various overall project phases, the base project total costs, committed Bond Act funding, and additional Bond Act funding required for the base project. Some phases of the base project are funding dependent and will not be completed without additional funding. A description of funding -dependent additions to the base project is included for the purpose of presenting the overall project. None of the wastewater treatment plant improvements at the IAWWTP and VCHWWTP are necessary for the treatment of diverted wastewater flows from the Town of Lansing and the VCHWWTP, but were included as funding -dependent additions to the base project since they will improve performance and operation at these treatment facilities. These project components will be constructed if funding becomes available. The four base project components that are funding -dependent include: • VCHWWTP Effluent Filtration. • IAWWTP Grit Removal • IAWWTP Effluent Phosphorus Removal • IAWWTP - Phase 3 Interceptor and Collector Sewer Improvements A. Town of Lansing Municipal Sewer Collection System. The purpose of this phase of the overall project is to collect sanitary sewage from the Town of Lansing service area (all unsewered area currently) for treatment at the VCHWWTP and IAWWTP. Revised June 21, 2001 1:180001803181 I MordproedMisc\lthaca 06-=1-01.doc\0verview Document.doc Le, Stearn$ & YY l leler companies A-S Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS OVERVIEW DOCUMENT PAGE 6 This project will eliminate ground and surface water contamination caused by inadequate septic systems and poor soils. In addition, it will eliminate individual point source discharges by residential, commercial, industrial, and institutional facilities that currently hold SPDES permits in the Town of Lansing sewer service area. The individual phases are described below: 1. Phase 1. None. 2. Phase 2. a. Transmission Main to Cayuga Heights WWTP. Construction of approximately 12,000linear feet of 21-inch diameter PVC piping and 7,700 linear feet of 24-inch diameter PVC'piping southward along State Route 34 (East Shore Drive) from the Town of Lansing service area to the VCHWTP. The construction work is proposed to be completed in September 2003. The estimated construction costs are $2,350,000. Committed Bond Act funding is $1,020,000. An additional $680,000 is required to implement this portion of the project. b. Pump Stations. Construction of three pump stations, approximately 7,200 linear feet of parallel 10-inch diameter PVC force mains, and approximately 1,000 linear feet of 18-inch diameter PVC interceptor sewer. Pump Station No. 1 will be located at the intersection of Myers Road and Lakeshore Road and will pump wastewater to Pump Station No. 2, located on Portland Point Road near the outlet of Gulf Creek. Pump Station No. 2 will pump wastewater to Pump Station No. 3, located at the west end of Reach Run Road. Pump Station No. 3 pumps wastewater to a manhole located at the intersection of Smugglers Path and Reach Run Road, and at this manhole, begins the 21-inch transmission main. The construction work is proposed to be completed in September 2003. The estimated construction costs are $1,360,000. Bond Act funding of $900,000 has been committed for this work. C. Cayuga Heights Diversion to IAWWTP. Construction of approximately 2,960 linear feet of 12-inch PVC interceptor -sewer for connection of Cayuga Heights sewer system to Ithaca Area sewer system at two locations. The construction work is proposed to be completed in September 2002 for the Kline Road diversion, and September 2003 for the Remington Road diversion. The estimated construction costs are $240,000. Bond Act funding of $153,000 has been committed to construct the diversion interceptor. 3. Phase 3. a. Collection System for Myers Road Service Area. Construction of approximately 1,200 linear feet of 4-inch PVC sewer laterals, 9,100 linear feet of 8-inch PVC collector sewers, 4,900 linear feet of 6-inch PVC force main, 4,900 linear feet of 4-inch PVC vacuum main, vacuum collection station, and low head sewage pump station. Revised June 21, 2001 1:\8000\8071811\WordproC\Misc\Ithaca 06-21-01.doc\Overview Document doc ��, Stearns& heler ..... t-ompanies 1A.1 Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS OVERVIEW DOCUMENT PAGE 7 The construction work is proposed to be completed in May 2004. The estimated construction costs are $1,630,000. Bond Act funding of $1,080,000 has been committed to sewers for the Myers Road service area b. Transmission Main for South Lansing Service Area. Construction of approximately 6,200 linear feet of 12-inch PVC interceptor sewer. The construction work is proposed to be completed in September 2003. The estimated construction costs are $550,000. Bond Act funding of $370,000 has been committed for the South Lansing service area. 4. Phase 41. a. Collector Sewers — 10-Inch and 12-Inch Mains — South Lansing Service Area. Construction -of approximately 39300 linear feet of 10-inch-PVC interceptor sewer and approximately 4,900 linear feet of 12-inch PVC interceptor sewer. The construction work is proposed to be completed in January 2004. The estimated construction costs are $1,880,000. No Bond Act funding has been awarded or committed, $1,360,000 of funding is required for this portion of the project. b. Collectors and Lateral Sewers — South Lansing Area. Construction of approximately 3,900 linear feet of 4-inch PVC sewer laterals, and 52,000 linear feet of 8-inch PVC collector sewers. The construction work is proposed to be completed in January 2004. The estimated construction costs are $3,200,000. No Bond Act is required or committed for this project. B. Village of Cayuga Heights Wastewater Treatment Plant. The purpose of the Phase 2 improvements described below is to improve wastewater treatment quality and reliability at the VCHWWTP. These improvements are not necessary under the Base Project for the "Partial Flow Diversion" alternative to be constructed. The Phase 3 improvements (effluent filtration for phosphorus removal) are not necessary under the base project for the "Partial Flow Diversion" alternative, but may be constructed if funding becomes available. 1. Phase 1. None. 2. Phase 2 — Cayuga Heights Wastewater Treatment Plant Improvements. This work includes the addition of baffle wall within one of the two final settling tanks to improve performance, and replacement of trickling filter media and rotary arm distributor for improved wastewater treatment reliability. The proposed completion date for the construction work is December 2002. The estimated construction costs are $1,000,000. The total requested Bond Act funding was $842,500. The Bond Act funding awarded is $569,000. 3. Phase 3 — Cayuga Heights Wastewater Treatment Plant — Filtration. This project component is funding dependent and includes installation of effluent filtration and chemical addition for enhanced phosphorus removal. Total phosphorus concentrations in the final effluent discharged from the plant are anticipated to be less than 0.5 mg/l. The proposed construction date for the construction work is December 2003. The estimated construction Revised June 21, 2001 f:\80o0\8031811\Wordproe Mis61thaca 06-21-01.doc\0verview Document.doc &Z Stearns &Wheler companies I-E Stearns &Wheler, i_L.c ENVIRONMENTAL ENGINEERS & SCIENTISTS OVERVIEW DOCUMENT PAGE 8 costs are $1,500,000. The amount of Bond Act funding required is $1,020,000 to implement this portion of the project. No Bond Act funding has been awarded. C. Ithaca Area Wastewater Collection System and WWTP Improvements. The purpose of this phase of the overall project is to improve wastewater collection and treatment at the IAWWTP. The Phase 1 and Phase 2 interceptor and collector sewer improvements are already complete, as well as the wastewater treatment plant additions and modifications to increase plant flow capacity (plant flow re -rating). Construction of a new wastewater treatment plant grit removal system may occur if funding becomes available, since it will reduce grit loading and improve facility operations by reducing equipment maintenance. Construction of a new phosphorus removal system will occur if funding becomes available. Existing collector and interceptor sewers (Phase 3) will be rehabilitated if funding becomes available, since it will improve conveyance of wastewater to the -IAWWTP.- The Phase 3 improvements and grit and phosphorus -removal systems are not required for the "Partial Flow Diversion" alternative. The various phases are described in more detail below: 1. Phase 1. Completed projects are not part of the upcoming SEQRA and are listed here for informational purposes. a. Wastewater Treatment Plant Additions and Modifications. Installation of baffle walls and additional effluent weirs and launders in existing final settling tanks, installation of new raw wastewater pump, and construction of yard. piping modifications to increase plant flow capacity and reduce the potential for overflows at the main influent pumping station. b. Interceptor Improvements. Installation of approximately 5,200 linear feet of interceptor sewer to eliminate `overflows resulting from excessive infiltration and inflow. • Fall Creek interceptor from First Street to Fall Creek (completed 1997) 2,200 feet of 36-inch sewer • SW interceptor wastewater treatment plant to Cascadilla Street (completed 1997) 3,000 feet of 36-inch sewer. 2. Phase 2. Completed projects are not part of the upcoming SEQR review and are listed here for informational purposes. a. Interceptor Improvements. Installation of over 5,000 linear feet of 18-inch and 24-inch diameter interceptor sewers to eliminate sewer overflows resulting from excessive infiltration and inflow. • Interceptor sewer north of Ithaca High School (completed 1998) 700 feet of 24-inch sewer Revised June 21, 2001 J:\8000\803181 MordprocWiscUthaca 06.21-01.doc\0verview Document.doc AD Stearns &Wheler companies A--� Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS OVERVIEW DOCUMENT PAGE 9 • Interceptor sewer south of Ithaca High School (completed 1998) 1,487 feet of 24-inch sewer • Interceptor sewer, Fall Street/Lake Street - Lower Section (completed 1998) 24-inch sewer • Interceptor sewer, Lake Street (completed 1999) 915 feet of 24-inch sewer • Interceptor Sewer, Fall Street/Lake Street - Upper Section (completed 1999) 24-inch sewer • Interceptor sewer, University Avenue Lake Street to West Side Avenue (completed 1999) 2,100 feet of 18-inch sewer. 3. Phase 3. a. Wastewater treatment plant upgrade consisting of a new grit removal system. b. Installation of a high rate effluent filtration system within one of the two 60-foot diameter Phostrip tanks at the Ithaca Area wastewater treatment plant. The process will be capable of treating up to 13.1 mgd (average annual) and 30 mgd of wastewater flow on a peak hourly basis for further reduction of effluent phosphorus concentrations. Total phosphorus concentrations in the final effluent discharged from the plant are anticipated to be less than 0.40 mg/1. C. Rehabilitation of existing collector and interceptor sewers to reduce sewer overflows resulting from excessive infiltration and inflow. • Diversion to North Titus Avenue overflow structure, pump station rehabilitation and 3,500 linear feet of sewer lining • Interceptor sewer Iining, Third Street to Cayuga Street 6,000 linear feet at 24-inch sewer lining • New siphon at old inlet 24-inch to 30-inch siphon • Reline siphon under flood channel 3,000 linear feet • South Hill interceptor, Cayuga Street to Renbetti Street 3,000 linear feet of sewer Revised June 21, 2001 J:\80001803181 MordprodMiscUthaca 06-:I-0Ldoc\0verview Document doc ��� Stearns Maeler companies A-N Stearns &Wheler, LLC OVERVIEW DOCUMENT ENVIRONMENTAL ENGINEERS & SCIENTISTS PAGE 10 State Street interceptor, Mitchell Street to Cayuga Street 3,400 linear feet of sewer • Miscellaneous improvements The proposed completion date for the construction work is December 2002 for the phosphorus removal project, December 2003 for the grit removal project, and February 2003 for the interceptor improvement project. The total estimated project costs are $11,750,000. The amount of Bond Act funding that has been committed is $1,686,500 for the plant expansion and upgrade and $1,735,420 for the collection system. Additional funding required is $612,000 for grit removal, $1,152,500 for phosphorus removal filtration, and $1,560,000 for Phase 3 interceptor and collector sewer improvements. Projected Sewage Flows and Loadings The current maximum monthly flow from the Cayuga Heights service area is 2.76 mgd. The initial maximum monthly flow from the proposed Town of Lansing sewer service area is estimated to be 0.187 mgd. The 20-year design maximum monthly flow from this area is estimated to be 0.573 mgd. In order to limit the maximum monthly flow to the VCHWTP to 2 mgd, an initial total diversion of 0.95 mgd, and 1.33 mgd for the 20-year design period must be made to the IAWWTP. The current maximum monthly flow rate from the IAWWTP service area is approximately 9.96 mgd. The maximum monthly diversion of the flows from the Cayuga Heights service area will be 0.95 mgd initially, and 1.33 mgd during the 20-year design period. Thus, the total projected maximum monthly flows to the IAWWTP will be 10.9 mgd initially and 11.3 mgd on a 20-year design basis. The upgraded design capacity of the IAWWTP is 13.1 mgd. Therefore, the available maximum monthly flow rate capacity will be 2.2 mgd initially and 1.8 mgd during the 20-year design period. Tables summarizing wastewater flow and loading projections for Cayuga Heights and the Ithaca area wastewater treatment plants are included with this document. Total Estimated Project Costs The total estimated cost for the projects for which funding was sought in 1999 is $36,390,000. Applications were submitted for the maximum Bond Act funding possible for this project, which is $21,480,250. As of the April 4, 2000 press release, the project will receive funding of $7,513,920. The total estimated cost for the Base Project, including funding -dependent components described above is $25,460,000. Additional Bond Act funding of $6,384,500 is required to implement this project. Based on the requested level of Bond Act funding, the remaining cost of approximately $11,561,580 would have to be funded locally. A budget summary table lists project costs and Bond Act funding and local funding by project phase and municipality. Revised June 21, 2001 1:\8000\803181 Mordproc\.'fisc\Ithaca 06-21-01.doc\0Wview Document.doc L M Stearns & YY heler ,ompanies 1-k Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS Intermunicipal Agreements OVERVIEW DOCUMENT PAGE 11 On August 17, 1999, officials representing the City of Ithaca, Town of Ithaca, Town of Dryden, Village of Cayuga Heights, Town of Lansing, and Village of Lansing all endorsed the unified approach for municipal wastewater collection and treatment to serve the area. This endorsement (which is conditioned upon the receipt of the funding levels requested in the Joint Bond Act application) includes a commitment to enter into intermunicipal agreements regarding the unified approach. The following issues will be addressed in one or more intermunicipal agreements: • Ownership and governance of the IAWWTP's and VCHWTP's joint services • Relationship between the Ithaca Area and Cayuga Heights facilities • Flow volumes to be diverted from the Cayuga Heights facility to the Ithaca Area facility • Addition of new owners • Service areas (boundaries and extensions) Purchase and sale of plant capacities • Expansion of plant capacities • O&M rates paid by the municipalities • Financing of capital projects and jointly owned interceptors • Employment and oversight of treatment facility personnel • Industrial Pretreatment Program oversight • Liability issues • Growth and planning issues The Ithaca Area facility owners (City of Ithaca, Town of Ithaca, and Town of Dryden) currently operate their wastewater treatment facility pursuant to a Joint Sewer Agreement that was last revised in 1984. That agreement is being updated and revised by the Ithaca Area owners and the potential new owners (Town and Village of Lansing and Village of Cayuga Heights). Relevant provisions of the draft revised Joint Sewer Agreement will be reviewed in the DEIS. If the Village of Cayuga Heights becomes a partner with the other municipalities, then the Ithaca Area and Cayuga Heights plants would be jointly owned and operated by all six municipalities. If Cayuga Heights does not become a partner, then the Ithaca Area facility owners and Cayuga Heights will negotiate an agreement governing the relationship between the two facilities and their respective owners for the following issues: the diversion of flows from Cayuga Heights to the Ithaca Area facility, and the rates paid by Cayuga Heights. If such an agreement is needed, then it will also be reviewed in the DEIS. Finally, the Cayuga Heights facility currently provides service to portions of the Town of Lansing, Village of Lansing, Town of Ithaca, and Town of Dryden. Depending on the outcome of negotiations between the Ithaca Area and Cayuga Heights owners, changes may be proposed to the current agreements for the Cayuga Heights service, or the Joint Sewer Agreement may supercede these agreements. If either of these occurs, the relevant changes will be reviewed in the DEIS. The entire text of all proposed intermunicipal agreements will be included in the DEIS and be made available for public review when the DEIS is completed. Revised June 21, 2001 J:\8000\803181Mordproc\ld isc\Ithaca 06-21-01.doc\0verview Document.doc I-& Stearns&YYheler "'n panies A-1 Stearns &Wheler•, LLC OVERVIEW DOCUMENT ENVIRONMENTAL ENGINEERS & SCIENTISTS PAGE 12 Summary of Previous Technical Reports and Funding Applications Numerous technical reports, studies, and grant and loan applications have been completed for the various communities and phases involved with this project. A list of those documents available for review and reference is as follows: Technical Reports: "Unified Engineering Report, Municipal Wastewater Collection and Treatment System Improvements, Ithaca, Cayuga Heights, Dryden, and Lansing, NY," August 1999, by Stearns & Wheler, LLC and T. G. Miller, P.C. "Wastewater Facilities Plan, Town of Lansing, Tompkins County," October 1998, by T. G. Miller, P.C., and Stearns & Wheler, LLC. "Draft Engineering Report, Cayuga Heights Wastewater Treatment Plant Improvements, Cayuga Heights, New York," July 1999, by Stearns & Wheler, LLC. Draft letter report, Effluent Filtration for Enhanced Phosphorus Removal, Cayuga Heights Municipal Wastewater Treatment Plant, July 1999, by Stearns & Wheler, LLC. "Draft Engineering Report, Capital Improvements Plan, Ithaca Area Wastewater Treatment Plant, City of Ithaca, NY," May 1999, by Stearns & Wheler, LLC. "Engineering Report for Discharge Permit Modification and Plant Capacity Analysis, Ithaca Area Wastewater Treatment Plant," May 1994, by Stearns & Wheler, LLC. "Infiltration and Inflow Study," February 1983, by Stearns & Wheler, LLC. "Interim Report on Sewer System Evaluation Survey," February 1981, by Stearns & Wheler, LLC. Bond Act Funding Applications: Clean Water/Clean Air Bond Application, City of Ithaca/Town of Ithaca/Town of Dryden/Village of Cayuga HeightsNillage of Lansing/Town of Lansing, Wastewater Collection System Improvements, October 27, 2000. Clean Water/Clean Air Bond Act Funding Application, City of Ithaca/Town of Ithaca/Town of Dryden/Village of Cayuga Heights/Village of ,Lansing/Town of Lansing, Wastewater Collection and Treatment System Improvements, August 17, 1999. Clean Water/Clean Air Bond Act Funding Application, Ithaca/Cayuga Heights/Lansing Area Wastewater Collection and Treatment System Improvements, June 3, 1998. Revised June 21, 2001 J:\8000\8031911\Wordproc\Misc\Ithaca 06-21-01.doc\0vMiew Document.doc 4 B Stearns &Wheler companies St ep 1: Step 2 : Step 3: Step 4 : N Q'�8an�fxcnt:. tvr s , � -. ��_; e •-?;=gat: Wit•: x:� �;,,J'�,r� Cl assify C;ompl et a an C oor dinat e Determine the Envir onmerit al Significance tif>iatztT m L iF_Ylew Action Assessment of Action on )1,' e Form?'ossr _. Environment Issue C)ptional Step Issue Positive_ Negative Scope E.I. Declaration Declaration or Issue Condit Negative Declaration' Step 5: Step 6: Ik:aft�is -At abl'� Prep ar ation of Det ermm' a °r r.,:Y� ; r q c,:..' Draft E.I.S. Ade uayof e� � -' `� � ��°�;�_> .� °tltiSiStl�7rt1� Draft E.I.S s�;�.'�;=::i -: . r� ..I.�k;." "sue �+�,6ki�,. ,ae •.fiE w . _ .. Stet? 7 Publish Notice that E.I.S is Accepted for Public BRview Step 8: Step 9: Receive Deade Whether Public to Hold a Public CrOr unent Hearing St ep 10: Prepare Final E I S Step 11: SEQR Findings are made by all involved agenaes AStearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS BUDGET SUMMARY June 21, 2001 BASE PROJECT AND FUNDING-DEPDENDENT COMPONENTS Town of Lansing Collector Sewers — 10-Inch and 12-Inch Mains, South Lansing Area Collector Sewers - South Lansing Area Transmission - South Lansing Area Collector and Lateral Sewers - Myers Road Area Pump Stations Transmission to Cayuga Heights WWTF Diversion of Cayuga Heights Wastewater to IAWWTF Village of Cayuga Heights Additional Committed Funding Base Project Bond Act Required For Local Share If Total Cost Funding** Base Project Fully Funded $1,880,000 $0 $1,360,000 $520,000 $3,200,000 $0 I $0 $3,200,00 $550,000 $370,000 $0 I $180,000 $1,630,000 I $1,080,000 I $0 I $550,000 $1,360,000 I $900,000 I $0 I $460,000 $2,350,000 $1,020,000 I $680,000 I $650,000 $240,000 $153,000 I - $0 I $87,000 Wastewater Treatment Plant Improvements $1,000,000 I $569,000 $0 I $431,000 VCHWTP Filtration.. ;:..< ;. .;' :`$:1';SOO;OQO': ''::; $0:. $I,020 000 -,: $480;000 Ithaca Area Owners WWTP/Interceptor Improvements (Phase 1)* $1,660,000 I $1,220,000 I $0 I $440,000 WWTP Improvements - Plant Re -Rating* $340,000 $289,000 $0 $51,000 WWTP Grit:Removal ;'. .: ;:=:: `:i=::; :. ; ":' $:1,000,000 :.; :.... .: , e ;: `'' `:.:$Os;:.:.: ,..:;` .: $6.12 000 ... $388 000 Effluent Filtration P Removal ( ) $3,75 0,000 $1397,500,; ' ` $1,152500 ... $1,200,000 Interceptor and Collector Sewer Improvements • Phase 2* $1,090,000 $515,420 $0 $574,580 • Phase 3 $33910,0001. $0 $1,560,000 I $2,350,000 Total $25,460.000 S7,513,920 $6,384.500 $11,561,580 * Projects completed. Funding -Dependent Component Sum of two previous Bond Act Applications. Revised June 21, 2001 L�,Stearns&Wheler J:\5000\8031 S I I1WorordprxVdisc\Ithaca 06-21-01 doc\Budger Summary.doc rnmpanies &__� Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS St SCIENTISTS PROJECT PHASE TIMELINE June 21, 2001 MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA Project Component Town of Lansing Collector Sewers - South Lansing Area • 10-Inch and 12-Inch Mains • Collectors and Laterals Transmission - South Lansing Area Collector Sewers - Myers Road Area Pump Stations Transmission to Cayuga Heights WWTP Diversion of Cayuga Heights Wastewater to IAWWTP • Kline Road • Remington Road Village of Cayuga Heights WWTP Improvements Effluent Filtration for Phosphorus Removal City of Ithaca Interceptor Improvements* (Phases I and 2) WWTP Improvements - Plant Re -Rating* WWTP Grit Removal Facilities WWTP Phosphorus Removal Facilities Interceptor Improvements - Phase 3 * Projects completed. Final Design Start Finish Date Date Advertisement and Bidding Start Finish Date Date Construction Start Finish Date Date 01/01/02 05/01/02 11 /01 /02 11 /01/02 02/01 /03 01 /31 /04 01/01/02 05/01/02 11 /01 /02 12/31 /02 02/01 /03 01 /31 /04 01/01/02 05/01/02 07/01/02 09/01/02 09/15/02 09/15/03 01/01/02 05/01/02 07/01/02 09/01/02 09/15/02 05/13/04 01/01/02 05/01/02 07/01/02 09/01/02 09/15/02 09/15/03 01/01/02 05/01/02 07/01/02 09/01/02 09/15/02 09/15/03 Completed 01/01/02 03/01/02 03/15/02 09/15/02 Completed 07/01/02 09/01/02 09/15/02 09/15/03 10/01 /01 02/01 /02 04/01 /02 06/01 /02 06/ 15/02 12/ 15/02 03/01/02 09/01/02 01/11/02 01/15/03 02/15/03 12/13/03 Completed Completed 03/01/02 09/01/02 11 /01 /02 01 / 15/03 .02/ 15/03 12/31 /03 10/01/01 02/01/02 04/01/02 06/01/02 06/15/02 12/15/02 07/01/02 10/01 /02 02/01 /02 03/ 15/02 04/01 /02 02/31 /03 3 \8000\803181 I\ WordprmWisc\Ithaca 06-21-01 docTroject Phase Timeline doc Stearns &Wheler C mp-le, &__� Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS Parameter/Averaging Period Sewage Flow PROJECTIONS -SUMMARY Village of Cayuga Heights SUMMARY OF WASTEWATER FLOW AND LOADING PROJECTIONS CAYUGA HEIGHTS WASTEWATER TREATMENT PLANT Current Cayuga Proposed Lansing (T) Heights Sewer Service Areal) Service 20-Year Area Initial Design Total Combined Cayuga Heights and Lansing (T) Service Areas (2) 20-Year Initial Design Total Flow Diversion to IAWWTPI'1 20-Year Initial Design Annual average, mgd 2.17 0.144 0.441 2.31 2.61 0.74 1.05 Maximum month, mgd 2.76 0.187 0.573 2.95 3.33 0.95 1.33 Peak hourly, mgd 8.60 0.475 1.455 9.08 10.06 4.08 5.06 BOD5 Annual average, mg/1 155 250 237 -- -- 155 155 Annual average, lb/day 2,800 300 870 3,100 3,670 961 1,352 Maximum month, lb/day 3,500 390 1,130 3,890 4,630 1,201 1,690 Suspended Solids Annual average, mg/l 182 266 266 -- -- 182. 182 Annual average, lb/day 3,300 320 980 3,620 4,280 1,132 1,594 Maximum month, lb/day 5,000 420 1,280 5,420 6,280 1,716 2,415 Phosphorus Annual average, mg/1 4.6 9.2 8.4 -- -- 4.6 4.6 Annual average, lb/day 83 11 31 94 114 28 40 Maximum month, lb/day 110 11 31 121 141 38 53 tU Source: "Wastewater Facilities Plan, Town of Lansing, Tompkins County, New York, " October 1998 (Final). (2) Flow diversion calculations based on offset of annual average BOD5 loading from proposed Town of Lansing sewer service area. (') Flow diversion necessary to limit maximum month and peak hourly flows influent to the VCHWTP to 2 mgd and S mgd, respectively. Revised June 21, 2001 J \8000\803181 I\ Wordproc\hlisc\lihaca 06-21-01 docTrojections Summary -Cayuga Heights.doc Future VCHWTP Influent 20-Year Initial Design 1.57 1.56 2.00 2.00 5.00 5.00 163 178 2,139 2,318 3,689 2,940 190 206 2,488 2,686 3,704 3,865 5.0 5.7 66 74 83 88 AB Stearns &Wheler Companies &--� Stearns &Wheler, >_.l.,c ENVIRONMENTAL ENGINEERS & SCIENTISTS Sewage Flow PROJECTIONS SUMMARY Ithaca Area WWTP SUMMARY OF WASTEWATER FLOWS AND LOADING PROJECTIONS ITHACA AREA WASTEWATER TREATMENT PLANT Current Cayuga Heights IAWWTP Diversion(2) Service 20-Year Area(l) Initial Design Projected Capacity Needs(3) Upgraded 20-Year Design nitial Design Capacity Available Capacity 20-Year Initial Design Annual average, mgd 7.27 0.74 1.05 8.01 8.30 9.8 1.8 1.5 Maximum month, mgd 9.96 0.95 1.33 10.9 11.3 13.1 2.2 1.8 Peak hourly, mgd 25.0 4.08 5.06 29.1 30.1 32.0 2.9 1.9 BOD5 Annual average, mg/1 131 155 155 134 134 150 240 240 Annual average, lb/day 7,948 961 1,352 8,910 9,300 12,200 3,290 2,900 Maximum month, lb/day 11,068 1,201 1,690 12,270 12,800 15,130 2,860 2,330 Suspended Solids Annual average, mg/1 132 182 182 139 139 199 546 546 Annual average, lb/day 7,975 1,132 1,594 9,110 9,600 16,200 7,090 6,600 Maximum month, lb/day 9,770 1,716 2,415 11,490 12,200 21,620 10,130 9,420 Phosphorus Annual average, mg/1 3.3 4.6 4.6 3.5 3.5 4.2 8.1 8.1 Annual average, lb/day 202 28 40 230 242 340 110 98 Maximum month, lb/day 260 38 53 300 313 453 153 140 t1i Based on analysis of IA {VWTP influent monitoring data for Jamtmy 1996-April 1999. t2i Partial diversion of sewage flow from the VCHWTP to offset additional BOD5 loading from proposed Town of Lansing sewer service area and limit influent sewage flows and loadings to current design capacity of 2.0 mgd (maximum monthly average flow). (3) Values rounded Revised June 21, 2001 J \80011\8031811%%Vuidproc\h is01thaca 00-21-01 docTrojections Summary - ❑haca Area doc 80--� Stearns &YYl leler Cwnpanies I 1 & Stearns &Wheler, LLc DRAFT SCOPING DOCUMENT ENVIRONMENTAL ENGINEERS & SCIENTISTS June 21, 2001 MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA The following is a list of required items and topics to be included and discussed in the Environmental Impact Statement for the Municipal Wastewater Collection System Improvements. A. Cover Sheet. The EIS shall have a cover sheet that includes the following information: whether the document is a "draft" or "final" EIS. the title of the project.' location of the project. name and address of the lead agency and the name and telephone number of a contact at the lead agency. name and address of persons who prepared the statement and contact names and telephone numbers. i date of acceptance of the draft EIS. the deadline for review comments (when in draft form). B. Table of Contents and Summary. A Table of Contents is required to be included for both the draft and final EIS. A summary is also required and should include: • a brief description of the action. • significant, beneficial, and adverse impacts (identify issues of controversy). • identify mitigating measures. • identify alternatives. • identify permits, approvals, or funding to be decided. C. Description of the Proposed Action. 1. Project Purpose and Need. Discuss the background and history of the proposed project. Discuss the public need for the project and the objectives of the involved municipalities based on adopted community development plans, and indicate the joint owner's objectives. 2. Location. Establish geographic boundaries of the project (use regional and local scale maps). Describe access to the proposed project site and existing zoning. Revised June 21, 2001 J:180001803181 Mordproc:Mis61thaca 06-21-01.doc\Laming Scoping Docurmnt.doc 1-C Stearns &Wheler, I.Lc DRAFr SCOPING DOCUMENT ENVIRONMENTAL ENGINEERS & SCIENTISTS PAGE 2 3. Design and Layout. Provide a description and separate figure of the following: a. Total site area including: proposed impervious surface area (e.g., roofs, parking lots, roads) amount of land to be cleared open space b. Structures including: sewers and"pump stations site plans and profile views 4. Construction and Operation. a. Construction. Indicate the anticipated length of construction and provide a proposed construction schedule. Discuss possible future development both on -site and within adjoining properties. Also, discuss the costs within each municipality with and without the proposed sewer infrastructure. b. Operation and Maintenance. Discuss the type of operation and maintenance involved in the proposed project. Discuss growth -induced impacts on fiscal costs of operation and maintenance. 5. Approvals. Changes or variances to the zoning regulations required for the proposed project shall be indicated as well as other permit or funding requirements. D. Environmental Setting and Significant Environmental Impacts. The following are topics that shall be discussed in detail in the Environmental Impact Statement. Also, identify and discuss aspects of the environmental setting within and surrounding the proposed project area that may be significantly adversely or beneficially impacted by the proposed action. This section' will rely on existing published data and reports whenever possible. 1. Natural Resources. a. Geology. Subsurface. Discuss composition and thickness of subsurface material (e.g., depth to and nature of bedrock formations and impermeable layers, occurrences of an extractive mineral source, usefulness as a construction material). Surface. List the types of soils and discuss their characteristics such as physical and engineering properties. Indicate how these soils are distributed within the project Revised June 21, 2001 1\8000\803I81 MordproMisc\Ithaca 06-21-01.doc\Lansing Scoping Document.doc Stearns &Wheler, LI..,C ENVIRONMENTAL ENGINEERS & SCIENTISTS DRAFT SCOPING DOCUMENT PAGES area and discuss their appropriate use in agriculture, and other uses related to the proposed project. Topography. Describe the topography of the proposed project area noting prominent or unique features. Also, describe the topography of the areas surrounding the proposed project area. Discuss proposed modifications to existing hydrologic features (e.g., streambeds or embankments, drainage ditches, culverts) and possible impacts on flooding and drainage caused by the proposed project. b. Water Resources. Groundwater. Describe aquifers and recharge areas (e.g., depth to water table, seasonal variation, quality, quantity, and flow). Indicate the present uses and level of use of groundwater, such as location of existing wells, public/private water supplies, industrial uses, agricultural uses, and positive and negative impacts on these resources by proposed project. Surface Water. Provide the location and description (including NYSDEC surface water classifications) for surface waters located within the project area or those that may be influenced by the proposed project (e.g., seasonal variation, water quality, and classification according to the New York State Department of Health). Also, identify the use and level of use of surface waters such as public/private water supply, industrial uses, agricultural uses, recreation, and positive and negative impacts on these resources by proposed project. C. Air Resources. Climate. Discuss seasonal variations and extremes in temperature, humidity, precipitation, wind, and impacts they have on proposed project. Air Quality. Describe air quality levels within the proposed project area. List the National and State Air Quality Standards for the project area and the compliance status for each standard. Identify existing sources or pollutants, both fixed and mobile, and identify sensitive receptors in the area such as hospitals, schools, nursing homes, parks, etc. Describe existing monitoring program within the project area. Odors. Discuss potential for odor generation from new collection system and pump stations in relation to surrounding areas and neighborhoods. d. Terrestrial and Aquatic Ecology. Vegetation. Identify types of vegetation within both the proposed project and surrounding areas. Also, discuss the characteristics of each type such as presence Revised June 21, 2001 J:\8000\803181I\Wordproc\Misc\Ithaca 06-21-0I.doc\Laming Scoping Document.doc Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS DRAFT SCOPING DOCUMENT PAGE and abundance of species, age, size, distribution, dominance, community types, unique, rare and endangered species, value as a habitat for wildlife, and productivity. Fish and Wildlife. Identify species of fish and wildlife within the proposed project and surrounding areas, including migratory and resident species. Discuss their population and characteristics such as presence and abundance, distribution, dominance, unique or rare and endangered species, and productivity. Wetlands. Identify wetland areas within or adjacent to the proposed project area. Also, discuss the characteristics including _acreage, vegetative cover, classification, and benefits of the wetland such as flood and erosion control, and recreation. Preserves and Natural Areas. Identify public or privately owned preserves or natural areas within the proposed project area. Unique Natural Areas (UNA). Identify any UNA within the proposed project area and discuss the characteristics (acreage, features, etc.) and benefits to the area. 2. Growth -Inducing Impacts. a. Demography. Population Characteristics. Describe the current population's characteristics within the proposed project area. Indicate the population's distribution, density, and household size and composition. Also, discuss projections for population growth with and without the changes caused by the proposed project. b. Cultural Resources. Visual Resources. Describe the physical characteristics of the community (urban versus rural) and the natural areas of significant scenic value. Historic and Archaeological Resources. Perform a literature search and describe the location of historic areas or structures listed on State or National Register or designated by the community. Identify sites having potential significant archaeological value within the proposed project area. C. Land Use and Zoning. Existing Land Use and Zoning. Describe and analyze existing land use and zoning for each municipality within the proposed project area including commercial, residential, agricultural, business, retail, industrial, and vacant areas. Note if potential growth -induced impacts are consistent with the community's existing Revised June 21, 2001 J:\8000\803181 Mordproc\Miscllthaca 06-21-0i.doc\Lansing Scoping Document. doc Stearns &A%eler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS DRAFT SCOPING DOCUMENT PAGE zoning and comprehensive plans. Calculate the "historic growth quotient" in the study area to measure the change in urbanized land relative to the growth in households for the past 20 years. Describe zoning ordinances and how they contribute to regional growth patterns. d. Future Development Patterns and Induced Growth. Land Use Plans. Discuss potential land use plans under current zoning and potential land use as a result of expanded service along with any proposed zoning changes. Describe changes in development costs within each municipality with and without sewer infrastructure. Analyze the potential impacts of current growth and growth that may be induced as a result of the project. Analyze three growth scenarios: (1) existing conditions — current growth rates with no sewer project; (2) current growth rates with sewer project; and (3) moderate growth rates with sewer project. Analyze the effect of each scenario, including the change in urbanized land relative to the growth in households as a result of the induced growth. Describe the impact of induced growth on the preservation of the region's unique physical character — the historic city and villages, and the region's farms, forests, rural character, and open spaces. e. Transportation. Transportation Services. Describe the size, capacity, and condition of transportation services, such as roads, canals, railroads, bridges, parking facilities, and traffic control. Describe the current level of use of these services such as morning and evening peak hour traffic flow, vehicle mix, and existing sources of traffic volume. Discuss overall impacts of the project on existing key roads, intersections, neighborhoods, and the potential construction of any new roads. Also, discuss fiscal impacts on transportation services due to potential growth, including operation and maintenance costs. Public Transportation. Describe the current availability of public transportation services and their present level of use. Also, identify potential growth -induced impacts on public transportation services. Pedestrian Environment. Briefly describe the pedestrian environment within the proposed project area and potential growth induced impacts on this environment. Land Use Plans. Describe plans for land use and/or the status of comprehensive plans in the proposed project area, such as the possibility that the proposed project may encourage non-agricultural development. Discuss future development trends or pressures in progress (i.e., Northeast Subarea Transportation Study, Cayuga Lake Waterfront Revitalization Plan, etc.). Describe the interrelationships of these land use or comprehensive plans and how they contribute to regional growth patterns. Revised June 21, 2001 1:\8000\8031811\Wordproc\Misc\Ithaca 06-21.01.doc\Lansing Scoping Document.doc IA_S Stearns &Wheler, = ENVIRONMENTAL ENGINEERS & SCIENTISTS f. Community Services. DRAFT SCOPING DOCUMENT PAGE 6 Public Services. Provide a list of existing facilities and discuss their current and projected use, as well as potential growth -induced impacts, including schools, police protection, fire protection, recreational facilities, and utilities. Discuss fiscal impacts on services including costs and benefits from changes in growth patterns that would result, including operation and maintenance costs. g. Budget Analysis. Analyze affordability of the sewer projects for each municipality. E. Mitigation Measures to Minimize Environmental Impact. Discuss measures to reduce or avoid potential adverse impacts previously identified. F. Adverse Environmental Impacts. Identify adverse environmental effects that cannot be avoided if the proposed project is implemented regardless of mitigating measures considered. G. Alternatives. Discuss alternatives to the project as currently proposed. Potential -alternatives include no action and reduced sewer service areas. Other alternatives to be considered will be identified and assessed during preparation of the DEIS. Include a comparative assessment of costs, benefits and environmental risks for each alternative. H. Appendices. The following backup materials shall be used as supporting documents to the Environmental Impact Statement: 1. List of underlying studies, reports, and information considered and relied upon in preparing the statement. 2. List all federal, state, regional, or local agencies, organizations, consultants and private persons consulted in preparing the statement. 3. Technical exhibits at a legible scale. 4. Relevant correspondence regarding the projects. Revised June 21, 2001 JA8000\80318I 1\Wordproc\Misc\Ithaca 06-21-0I.doc\Lansing Scoping Docum nt.doc A--� Stearns &Wheler, LLc ENVIRONMENTAL ENGINEERS & SCIENTISTS MEETING MINUTES PROJECT REVIEW MEETING ITHACA AREA WASTEWATER TREATMENT PLANT IMPROVEMENTS CITY OF ITHACA, NEW YORK June 26, 2001 S&W No. 80318.9 Attendees: Distribution: Cathy Valentino - Town of Ithaca All Attendees Mary Russell - Town of Ithaca Susan Blumenthal - City of Ithaca Jon Kanter - Town of Ithaca Alan Cohen - City of Ithaca Steve Farkas - Town of Lansing Paulette Manos - City of Ithaca Don Hartill - Village of Lansing Tracy Farrell - City of Ithaca Frank Moore - Village of Lansing Joan Spielholtz - City of Ithaca Brent Cross - Village of Cayuga Heights Patricia Vaughn - City of Ithaca James Burke - NYSDEC Larry Fabbroni - City of Ithaca DPW Ralph Manna - NYSDEC - Environmental Permits Bill Gray - City of Ithaca DPW John Merriman - NYSDEC - Environmental Permits Daniel Walker - Town of Ithaca Stuart Mesinger - Chazen Associates Larry Fresinski - Village of Cayuga Heights Dave Herrick - T.G. Miller, P.C. Walter Lynn - Village of Cayuga Heights Susan Brock - IAWWTF Bud Shattuck - Town of Lansing Jerry Hook, P.E. - Stearns & Wheler, LLC Mark Varvayanis - Town of Dryden Tom Friedrich, P.E. - Stearns & Wheler, LLC Steve Eidt - NYSDEC - Water A. Purpose. To review status of Ithaca Area Municipal Collection System Improvement project with NYSDEC and review required steps to have NYSDEC make their "Determination of Significance." B. Project Status. 1. Overview Document finalized with input from all six municipalities and submitted to NYSDEC for their use for Determination of Significance. 2. EIS subconsultant selected and has begun preliminary work. Chazen Associates is the subconsultant and Stuart Mesinger is their project manager. 3. Intermunicipal agreements are continuing to progress and will be included in draft EIS. 4. Scoping Document prepared and finalized with input from all six municipalities and provided to NYSDEC for their use. S&w Form 196 (02/00) C1-0�Stearns &Wheler :\TEMP\06-26-OLdoc Companies Stearns &Wheler, nc MEETING MINUTES ENVIRONMENTAL ENGINEERS & SCIENTISTS PAGE 2 C. NYSDEC "Determination of Significance" 1. NYSDEC requires a letter from six municipalities designating the action(s) that require NYSDEC to act as lead agency and provide a "Determination of Significance." The actions include the following: • SPDES permit modification to list new owners of WWTP. • Approval of plan for sewer service area extension for Town of Lansing and connection to the Village of Cayuga Heights and Ithaca Area WWTP. 2. Submit a draft "Positive Declaration" to NYSDEC and include the following attachments: • Overview Document • Scoping Document • Reduced size maps of service area, planning area, and proposed sewers 3. Establish location, date, and time for Public Scoping Session. The group agreed that the meeting should be held in September 2001; however, the notice for that meeting could be sent out in August to allow sufficient public review of background information. 4. NYSDEC requested that all reports referenced be made available at one or two locations (i.e., Tompkins County library). 5. Scoping Session - NYSDEC indicated that meeting minutes should be recorded for permanent record by use of tape recorder or stenographer. D. Plan of Action. Plan of Action Letter to NYSDEC designating action(s) and requesting "Determination of Significance." Submit draft "Positive Declaration" to NYSDEC. Reduce mapping of service and planning areas and proposed sewer service to 11" x 17". Determine date, time, and location for Public Scoping Session. Prepare extra copies of past reports referenced in Overview Document for public review at Tompkins County library. Set up meeting in August with NYSDEC to discuss plans for Public Scoping Session. Responsible Person Susan Brock Jon Kanter/Susan Brock Tom Friedrich SJS Committee/Susan Brock Tom Friedrich Tom Friedrich S&W Form 196 (02/00) CATEMP\06-26-01.doc 1-& Stearns &Wheler "ompanies AStearns &Wheler, nc ENVIRONMENTAL ENGINEERS & SCIENTISTS MEETING MINUTES SCOPING REVIEW MEETING MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA August 22, 2001 S&W No. 80318.9 Attendees: Distribution: John Merriman — NYSDEC — Environmental Permits All Attendees Stuart Mesinger — Chazen Associates Susan Brock — IAWWTF Tom Friedrich, P.E. — Stearns & Wheler, LLC 1. Agenda. A proposed agenda for the public scoping session was discussed. A draft of the proposed agenda is attached. 2. Presenters. The proposed presenters for the meeting are listed on the attached agenda. 3. Minutes for Meeting. John Merriman indicated someone should be responsible for taking notes related to comments to the scoping document. These will be utilized to prepare a response to the public scoping comments. Susan Brock will discuss who should be responsible for taking notes with the six municipalities. 4. Public Comments. Tom Friedrich will be responsible for recording public comments on an easel during the meeting to account for each .issue raised. _ 5. Miscellaneous Items. a. Tom Friedrich indicated he would provide the following items for the meeting: • 20 reduced copies of each of the 11 x 17-inch maps for public distribution at the meeting • blown up copies of the maps and an easel for review of overview document • sign -in sheet to include name, address, phone number, and affiliation • white board to write down public comments b. Susan Brock indicated she would take care of arranging audio/visual with county personnel, including microphones and videotaping of the meeting. TWF/jm S&W Fonn 196 (02/00) CAW NDOWMEN008-22-01.doc &__�Stearns&%eler ��mpanies AN Stearns &Wheler, i T .C: AGENDA ENVIRONMENTAL ENGINEERS & SCIENTISTS PUBLIC SCOPING SESSION MUNICIPAL WASTEWATER COLLECTION SYSTEM IMPROVEMENTS AND INTERMUNICIPAL AGREEMENTS FOR THE ITHACA AREA Lansing Town Hall Thursday — September 6, 2001 — 7:00 p.m. S&W No. 80318.9 1. Introduction (5 Minutes)................................................................................ John Merriman 2. Review of Overview Document (10 to 15 Minutes) ....................................... Tom Friedrich Dave Herrick Assistance From....................................................................................................... Bill Gray Mark Varvayanis Larry Fabbroni 3. Questions (10 to 15 Minutes)........................................................................................Public 4. Review of Scoping Document (10 to 15 Minutes)........................................Stuart Mesinger 5. Receipt of Public Comments....................................................................................... Public 6. Closing (5 Minutes).........................................................................................John Merriman S&W Form 197 (08/00) CAVnND0WS\TEMP\09-06-01.doc L&, Stearns &Wheler companies z � LU �. =Uo LLD It--\ Steams &Wheler, ENVIRONMENTAL ENGINEERS & SCIENTI MEMORANDUM To: Proposal Review Committee (Larry Fabbroni, Susan Blumenthal,' M 4 , "' �4s§011,4Von Kanter, Dave Herrick) ah"y From: G.C. Hook Date: December 1, 2000 Re: DEIS Proposal We only received one proposal (copy enclosed), from The Chazen Companies, in ,response to our Request for Proposals. Please review the proposal and the attached summary memorandum. We would like to meet on Monday, December 11, 2000, at 10:30 a.m., at the Ithaca Area Wastewater Treatment Plant to discuss our next steps. Please respond to Joanne Bartell at (315) 655-8161, ext. 311, regarding your availability to meet on December 11 th. GCH/jlb S&W Form 195 (02/00) JA80001803 181 1NWordpmd\Memos\DE1S Proposal.doc IANSWarm&Wheler !---npanies A-N Stearns &Wheler, L,c ENVIRONMENTAL ENGINEERS & SCIENTISTS To: G.C. Hook, File 80318.2 From: T.W. Friedrich Date: December 1, 2000 Re: RFP Response for DEIS Ithaca Area Wastewater Treatment Improvement Project MEMORANDUM The Chazen Companies is the only firm that responded to the Request for Proposals for preparation of a draft Environmental Impact Statement (DEIS) for the Ithaca Area Wastewater Treatment Improvement Project. - Chazen's project understanding and approach was well prepared and complete. Their proposed schedule indicated that they could have a DEIS prepared in four months (per RFP request) from notice to proceed. However, following submission of the DEIS to the lead agency (NYSDEC), Chazen is estimating another six months of comments, revisions, final EIS preparation, and preparation of findings. A total project time of 10 months is estimated. The Chazen Companies has a lot of experience working in the Ithaca area, as indicated by their qualifications. Their proposal includes all of the requested tasks. A major emphasis of their proposal is addressing "Growth Inducing Impacts." They have a very detailed approach, which includes the following elements: • Establish planning horizon (10 to 20 years) • Establish development scenarios (current growth rates, moderate growth increase, rapid growth increase) • Establish development potential (based on proximity to water and sewer) k{ • Construct compost suitability map • Establish existing zoning and development potential • Establish development potential of vacant and partially developed parcels ' t, • Calculate impacts of induced growth based on fiscal and traffic impacts • Develop mitigation measures. In addition, Chazen's proposal includes wetlands delineation reports, flora and fauna reports, Stage 1A and 1B cultural resources survey, fiscal impact analysis, build -out study, engineering report, letters of records, records of contact, scoping document, and a bibliography. S&W Form 195 (02/00) JAB000\8031811\Wordproc\Memos\RFPResponse for DEIS.doc A Stearns&Wheler ,.panes .A b 1-t-N Stearns &Wheler, IJI.,c ENVIRONMENTAL ENGINEERS & SCIENTISTS FEE PROPOSAL SUMMARY The estimated cost of Chazen's proposal is shown below. Task 1 - Kickoff Meeting Task 2 - Prepare Scoping Document Task 3 - Public Scoping Session Task 4 - Finalize Scoping Document Task 5 - Prepare DEIS Task 6 - DEIS Comment Period Support MEMORANDUM PAGE 2 Lump Sum $180,000 (plus expenses) * * Includes one set of revisions to DEIS based on lead agency comments. -_ Phase 1B - Cultural Resources Survey $2,500/7inear mile plus expenses Task 7 - Supplemental DEIS Task 8 - FEIS Task 9 - Findings Statement Task 10 - Meetings Estimated Subtotal (as proposed) Expenses (5% of total) Estimated Total Negotiate Fee if Supplemental DEIS Required Negotiate Fee After Review of all Comments Not to Exceed $5,000 (hourly basis) $10,000 estimated (hourly) $198, 000 $10,000 **$208,000 * * Does not include any negotiated fees for preparation of supplemental EIS (if required) or FEIS. Stearns & Wheler discussed the costs of the proposal with the project manager for Chazen, Stewart Mesinger. Stewart indicated the following cost savings could be obtained: Sit $50,000 savings if the "Traffic Model" by subconsultant, SRF & Associates and Robert M. Shull of T Model Corporation, is deleted. • $20,000 savings if only one "Development Scenario" is evaluated versus three. The most likely scenario is to select the use of current steady state growth rate determined by evaluating existing information. Further discussions indicated that the lowest cost that the DEIS could be completed for would be in the range of $80,000 to $100,000. This would have to be discussed and negotiated with Stearns & Wheler and the Planning Committee. S&W Farm 195 (02/00) JA8000\807181 MordprodWemosTR Response for DEIS.doc Stearns &heler !'^mpanies e�yf/S 6� r act ,ter --t �� 4 of-((- Irv°fLr "A- l4(!oIDEc ;,qe ct, 2 S& Q b1["�`t w1iA- /"LSTS Sh,1� Proposal for Preparation of the Environmental Impact Statement for the Ithaca Area Wastewater Improvement Project November 9, 2000 Prepared for: Mr. Thomas Friedrich, P.E. Stearns & Wheler, LLC One Remington Park Drive Cazenovia, New York 13035 © 2000 The Chazen Companies Proposal for Preparation of the Environmental Impact Statement for the Ithaca Area Wastewater Improvement Project November 9, 2000 THE ChaKen .0 COMPANIES Prepared by: The Chazen Companies 110 Glen Street Glens Falls, New York 12801 Prepared for: Stearns & Wheler, LLC One Remington Park Drive Cazenovia, New York 13035 Orange County Poughkeepsie Capital District (914) 567-1133 (914) 454.3980 (518) 371-0929 © 2000 The Chazen Companies Ithaca Area Wastewater Improvement Project EIS Proposal i TABLE OF CONTENTS SECTION 1 STATEMENT OF UNDERSTANDING SECTION 2 PROJECT APPROACH SECTION 3 PROJECT SCHEDULE SECTION 4 STAFFING AND ORGANIZATIONAL CHART SECTION 5 FEE PROPOSAL APPENDIX A APPENDIX B APPENDIX C APPENDIX D CHAZEN RESUMES SRF & ASSOCIATES QUALIFICATIONS CITY/SCAPE QUALIFICATIONS TRAFFIC STUDY SCOPE 2 4 Ithaca Area Wastewater Improvement Project EIS Proposal 2 I SECTION 1 STATEMENT OF UNDERSTANDING The Chazen Companies has followed the Ithaca Area Wastewater Improvement Project for several years. We believe the EIS and this project to be about primarily two things: the straightforward physical aspects -of constructing new sewer facilities and discharging treated wastewater and, more importantly, growth which may be induced as a result. It is the secondary impacts of induced growth that are likely to ' be of most concern to the public. We have worked extensively in the greater Ithaca area over the years, and we therefore understand the level of scrutiny to which the project will be subject. Therefore, it is imperative that the EIS be based on a sound and defendable methodology. Our experience includes using GIS tools to conduct build -out studies, and we have learned how to properly perform such studies. A build -out study that considers new development potential should ideally address a range of scenarios in order to serve as a planning tool. Having identified a range of potential growth scenarios, a competent study will then assess impacts from each scenario: number of cars generated, water used, etc. Properly applied, the results become planning tools for ' the affected municipalities. Our approach therefore emphasizes the planning as well as the environmental aspects of the project. A properly constructed planning and evaluation team that includes policy -making members of the affected municipalities will result in a document whose conclusions are accepted and implemented. Given the sometimes fractious nature of decision making in the Ithaca community, we believe this understanding and approach are of the greatest importance. As a matter of routine, we understand the need for timely delivery of work products. Chazen prides itself on on -time delivery. We previously supplied you with our references, and we hope you have had an opportunity to contact our references at the City of Ithaca for an evaluation in this regard. The proposed four month schedule for completion of the DEIS is easily obtainable. ` Project management is simplified when there are few subcontractors and a single ._.' point of contact. Chazen proposes to provide all services for this project in-house, with the exception of traffic analysis and cultural resources. With respect to traffic analysis, Chazen proposes to collaborate with SRF and Associates, a Rochester based firm. SRF has extensive experience in the greater Ithaca area, including most recently collaborating with Chazen on the Southwest Area GEIS. SRF will bring an innovative approach to assessing the traffic impacts of induced growth from the project. With respect to cultural resources, Chazen will use the services of City/Scape, a WBE firm with whom Chazen frequently collaborates. Chazen's 3 Ithaca Area Wastewater Improvement Project EIS Proposal established relationships with these firms will minimize the communications difficulties that sometimes arise when multiple sub -contractors are used. Chazen proposes that Mr. Stuart Mesinger, AICP, serve as Project Manager. Mr. Mesinger has been an environmental planner in New York for 18 years. He manages the firms GIS division and has extensive experience preparing large-scale EIS'. His recent experience includes major EIS' projects for the City, and he previously prepared several EIS' for projects in the Town of Ithaca. Mr. Mesinger ' will be assisted by a team with extensive experience in all of the disciplines required for this project. In particular, Chazen's GIS analysis will be headed by Mr. _ David Wycliffe. Mr. Wycliffe recently joined Chazen from a regional planning agency in New Hampshire where he spent nine years working on a variety of projects. In particular, Mr. Wycliffe_ conducted build -out analyses= for several communities during his tenure. Also notable on our team is the inclusion of Mr. Steven Ferranti, SRF's principal. Mr. Ferranti is well known in the Ithaca - community for making complex analyses understandable and accessible to the public, a skill that will certainly be required for this project. Again, we invite you to ' make inquiry of City planning staff in this regard. FI L Ithaca Area Wastewater Improvement Project EIS Proposal SECTION 2 PROJECT APPROACH The following sets forth our approach to this project. Given the complexity of the project, we believe it is appropriate to suggest that the approach be discussed and refined with you after you have a chance to review it. For example, and as discussed in our cover letter, the Planning Team may choose to analyze a single growth scenario instead of three scenarios as we have suggested. All work products will be submitted as drafts to Stearns & Wheler for review and 15 comment. We recommend that drafts also be circulated among the Planning Team as appropriate. Note the importance of having the Planning Team conduct reviews in a timely fashion to stay on schedule. Task 1 Kick-off Meeting The Consulting Team (The Consultant) will attend a kick-off meeting with Stearns & Wheler, DEC and the owner's representatives. As discussed in our qualifications submittal, we suggest that the owner's representatives consist of an internal ' Planning Team consisting of representatives of each affected municipality. By so doing, buy -in and agreement with decisions can be obtained at an early project point. At this meeting the Consultant and team will discuss responsibilities, project schedule and coordination of the project with the DEC. The Consultant will prepare and distribute minutes within seven days of the meeting. A-J" ITask 2 Prepare Scoping Document The Consultant will review and revise the existing draft Scoping Document in consultation with Sterns & Wheler. The Consultant will present the draft Scoping Document to the DEC for review and comment, and will meet with the DEC if ' necessary to review the draft. The Consultant will revise the draft in response to comments. In preparing the document, the Consultant will endeavor to focus the EIS on those issues that are potentially relevant, eliminate non -significant and non - relevant issues, identify mitigation measures to the extent practicable, and identify the extent and quality of information required. Task 3 Public Scoping Session ' The Consultant will conduct a public scoping session in cooperation and consultation with DEC and the Planning Team. The exact time and format of the Scoping session will be determined at the initial kick-off meeting, however it can be anticipated to include a comment period of approximately 30 days and potentially a �; public meeting. IIthaca Area Wastewater Improvement Project EIS Proposal 1 Task 4 Finalize Scoping Document The Consultant will finalize the Scoping Document in response to comments and in �} consultation with the DEC and the Planning Team. As with all work products for this project, drafts will be submitted to Stearns & Wheler for review prior to submittal. ' Task 5 Prepare Draft Environmental Impact Statement n U The Consultant will prepare a Draft Environmental Impact Statement meeting the procedural and substantive comments of NYCRR Part 617.9. Our fee for this task includes review of the draft document by the Lead Agency and revisions in response to such review. It is understood that multiple submissions may be required, although we will of course endeavor to be as responsive as possible to comments on the initial submission in order to complete the project as expeditiously as possible. We anticipate the following approach to the major subject areas of this draft. The draft will of course include the appropriate cover sheet, table of contents, executive summary and supporting figures and tables. Chanter 1 Proiect Description. This chapter will describe the purpose and justification for the project, including the benefits and objectives to be achieved. It will generally describe existing sewage service provisions in and around the study area. It will describe the conceptual designs and routes for the sewer lines and the physical location and conceptual design and layout of associated facilities such as pump stations. It will describe proposed upgrades to the sewage treatment plant. It will provide site plans and profile views as well as basic development statistics. It will describe existing and proposed design flows. It will describe the effluent standards to be met. It will describe the regulatory environment affecting the plant. It will describe the decision to be made and approvals needed and how the project will be funded, including the potential tax burden on each affected municipality. It will describe the schedule and timing of the action, including the construction schedule. It will describe operation and maintenance of the proposed facilities. Chapter 2 Existina Environmental Setting. This chapter will describe the existing environmental setting of the project area. Major areas to be covered include: Physical description of the sewer line paths, pump station locations, and sewage treatment plant expansion areas, including flora and fauna, rare and endangered species, preserves and unique natural areas, wetlands (ACOE and DEC), stream crossings and classifications, cultural resources, Ithaca Area Wastewater Improvement Project EIS Proposal 6 soils, subsurface geology, groundwater, topography and surrounding land use. This chapter will also describe potentially affected resources outside of the immediate pipeline path to be analyzed with respect to induced growth. These will include land use and zoning of affected communities, comprehensive plan recommendations of affected communities, water and sewer resources of affected communities, development suitability of affected communities (see discussion of Chapter 4 below), traffic and transportation characteristics of affected municipalities, demographic and housing characteristics of affected communities, fiscal, economic and school enrollment and taxation characteristics of affected communities and school districts, stormwater management facilities of affected communities, private utility characteristics of affected communities, and community service characteristics (e.g. fire, police, etc.) of affected communities. Depending on the results of the Scoping process, noise, visual and air resource characteristics of affected communities may or may not be included. Chanter 3 Impacts and Mitieration Measures. This chapter will describe the major potential impacts of the project and proposed mitigation measures. Impacts and mitigation will be divided into three categories: 1) Construction related impacts and mitigation; 2) Operations related impacts and mitigation; and ,)j Secondary and induced growth impacts and mitigation. Major construction impacts and mitigation are likely to include methods and mitigation for stream and wetland crossings; methods and mitigation for dealing with high groundwater, shallow bedrock depth or other subsurface conditions; cultural resource considerations (if any); impacts from noise and dust, including mitigation such as limitations on hours of construction in areas identified as sensitive (e.g. those near population concentrations) or notification methods for blasting. Major operations impacts are likely to relate to the impacts of treated s6wage discharge as well as -odor and noise=fr-om=the-sewage-t-reat t plant and pump stations. This section will also discuss the existing and future treatment capacity of the plant, particularly in light of flows resulting from induced growth analyzed in Chapter 4. Secondary and growth impacts form a major portion of this project and will be treated in a separate chapter below. L Ithaca Area Wastewater Improvement Project EIS Proposal 7 p ' Chanter 4 Growth Inducine (Aspect )� Our ap proach to this task will be to integrate GIS land use an& parcel coverages with zoning data, natural ' resources data and infrastructure information to conduct a build -out analysis of lands within the sewer service area. The build -out analysis will be used to project impacts. Mitigation measures will be developed in response to such ' impacts in close consultation with the Planning Team. Recognizing the complexity of this task, we believe it will be important for all team members to fully understand the methodology and assumptions that will be used. ' Task 4 s .1 Establish Planning Horizon. It is important to establish a planning ' horizon for assessment of growth related impacts. A horizon of between 10 and years is typical. We will determine the appropriate horizon in consultation- with the Planning Team. Task 4.2 Establish Development Scenarios. In each affected community, Y, we will analyze existing building permit data and interview land use and zoning officials to obtain an understanding of current growth rates and how such rates may be affected by the presence of sewage capacity. Where appropriate, the analysis will consider proposed or potential 'zoning changes. The results of these tasks will be integrated to present three possible scenarios: 1) Steady state growth (i.e. current growth rates), 2) Moderate growth increase, and 3) Ragid4rowth increase. �_a --L-a- ' Task 4.3 Establish Development Potential Based on Proximity to Water and Sewer. Each development scenario will be considered with respect to proximity to water and sewer infrastructure. We propose the following mechanism, with the expectation that it will need to be reviewed and refined in consultation with the Planning Team. Lands within Y2 mile of both existing or proposed water and sewer lines will be considered to have the highest ' development potential. Lands within Y2 mile of either existing or proposed water and sewer lines (i.e. within the distance of one or the other, but not both) will be considered to have the next highest development potential. Lands within between Y2 and one mile of both water and sewer lines (again existing or proposed) will be considered to have the third highest development potential. Lands within between Y2 and one mile of either a water or sewer line (again, existing or proposed) will be considered to have the fourth highest development potential. Finally, lands in excess of one mile from both water and sewer lines (existing or proposed) will be considered to have the fifth highest development potential. We will develop a growth factor to determine the percentage of lands for which there is likely to be a demand ' for development within each of these areas. That is, within an area of highest development potential, we may assume that 80% of the lands that are able to Ithaca Area Wastewater Improvement Project EIS Proposal 8 be developed will be developed, while the figure may be 20% in the areas of lowest potential. We anticipate developing these factors based on discussion ' with the Planning Team. Task 4.4 Construct Composite Suitability Map. Within each area of ' development potential, we will construct a composite suitability map. The composite suitability map will be constructed using standard overlay techniques. Areas to be included will be soils suitability for development ' (including both surface and subsurface characteristics and considering development with and without on -site septic systems), slope, wetlands and ' floodplains. We anticipate developing the specific breakdowns of what constitute slight, medium and severe constraints to development for each resource category in consultation with the Planning Team. Task 4.5 Establish Existing Development and Zoning Potential. Existing development within each area of development potential will be queried using real property data files and zoning coverages. We will create a digital zoning layer for the study area and populate the layer with maximum allowed density. Parcels will then be queried to determine the amount of development already existing. Parcels that are completely developed will be dropped from further consideration. Task 4.6 Establish Development Potential of Vacant and Partially Developed Parcels. Vacant parcels and parcels that are partly developed will be compared to the results of the resource constraints analysis to determine the percentage of the parcel that should be considered buildable. All results will be verified through field and property data research. In our experience, field verification is critical to establishing the true development potential of vacant and partially developable parcels. Failure to verify is the main reason that build -out studies typically produce unreasonably high development estimates. Verification will include a check of ownership status. (For example, a large vacant -parcel may be owned by a land trust and thus have no actual development potential). All buildable parcel areas will then be analyzed using existing zoning for each of the, development scenarios (and applying development potential factors for the planning horizon) discussed above. Task 4.7 Calculate Impacts of Induced Growth. For each scenario, impacts in terms of traffic generation, wastewater generation, water use, population growth, school children generation, fiscal impact and other relevant impacts will be summarized. Such other relevant impacts may include the need for police and fire protection, and the demand for recreation and other IIthaca Area Wastewater Improvement Project EIS Proposal 9 1 community services. The following outlines our approach to the two areas we believe will be of greatest importance. Task 4.7.1 Fiscal Impacts. With respect to fiscal impact, we anticipate preparing fiscal impact analyses for each scenario for each municipality to determine whether the development scenarios will have positive or negative impacts. These analyses will include both the municipal and the various school system budgets. The analyses will be prepared using the proportional valuation method, which is the standard method routinely employed for such analyses. The proportional valuation method divides the cost of municipal services into residential, commercial and industrial components. It assumes that future demand for municipal services will occur in the same proportion as current demand. This method will allow the Planning Team to forecast whether induced growth in each community will generate school and tax revenues greater or less than the cost of the services provided. This analysis will be an important factor in the consideration of mitigation measures (see Task 4.8 below). Task 4.7.2 Traffic Impacts. We propose an innovative approach to assessing traffic impacts, one that employs a collaborative team effort and state -of -the art modeling for determining both future traffic forecasts and traffic impacts associated with future development scenarios. The team of people constructing the evaluation models are hey to its ultimate quality and usefulness. This team consists of two parts: 1) the consultant team and the staff of ITCTC, with in-depth understanding of the data, i.e. the area, the transportation network (opportunities and constraints), the traffic, the land use, the growth elements to be modeled, and evaluation tools; and 2) travel demand forecasting staff (Tmodel Corp. — see resume in Appendix B) with in- depth understanding of the traffic modeling process and the forecasting tools being used. The goal of model development is simple. Once constructed and calibrated, the model is a predictive tool which can be modified to simulate changes in land use, the roadway network, and/or traveler behavior characteristics under the alternative growth scenarios. It is then able to project traffic volumes and, in many cases, turn counts. It will be used for evaluating a multitude of performance measures for the three growth scenarios, such as volume/capacity ratios, vehicle L Ithaca Area Wastewater Improvement Project EIS Proposal 10 miles of travel, vehicle hours of travel, level -of -service, cost -benefit analyses, emissions modeling, etc. The evaluation procedures for selected intersections will also include a straight forward method to calculate an intersections volume related to capacity. Another key element included in the DEIS traffic element is the establishment of Traffic Performance Districts (TPDs). The purpose of the TPDs is to allow analysis of traffic performance on the subarea study roadway network. The TPD descriptions explain the land use and transportation characteristics of each district, and how the various development scenarios and potential mitigation strategies are applied in these subareas. They provide a rationale for allowing an appropriate level of development to continue, even in those instances where roadway levels of service may vary somewhat from those recommended by the NYSDOT or by local communities. This technique helps insure greater consistency with state, regional, and local goals. A detailed description of our approach to this task is provided in Appendix D. Task 4.8 Develop Mitigation Measures. The results of the build -out study will be a valuable tool for zoning and planning purposes in the affected municipalities. We anticipate reviewing the findings of this task in draft form with each municipality. Based on this review, we will develop recommendations for proposed mitigation measures for each community. Such measures could include recommendations for changes to comprehensive plans and zoning ordinances; recommendations for growth management measures such as phasing development or concurrency (i.e. requiring that development occur concurrent with specified physical improvements); recommendations for establishment of mitigation fees or other funding mechanisms such as improvement districts for traffic, water or other infrastructure improvements; and recommendations for specific infrastructure improvements, for example improvements related to transportation facilities. Chanter 5 Unavoidable Adverse Impacts. This chapter will summarize all of the unavoidable adverse impacts associated with the project. Chapter 6 Alternatives to the Action. This chapter will present and evaluate alternatives to the action. Alternatives to be evaluated will be determined in consultation with the Planning Team, and may include alternative service Ithaca Area Wastewater Improvement Project EIS Proposal 11 area(s); alternative routing; alternative pipe size/capacity; alternative stream and wetland crossing mechanisms; alternative capacity of the treatment plant; alternative treatment methods/discharge standards and the no -action alternative. Alternatives will be evaluated at a level of detail sufficient to allow comparison of the relevant impact to the environment. We do not anticipate conducting full growth inducing and secondary impact analyses for each alternative service area and routing option. The inclusion of alternative growth scenarios in the build -out study will satisfy SEQRA requirements with respect to alternative rates and types of growth. �Chanter 7 Irreversible and Irretrievable Resource Commitments., This i chapter will summarize irreversible and irretrievable resource commitm The discussion will center on the commitment of water resources to th IBM facility. Appendices. We anticipate the inclusion of the following appendices Appendix 1 Wetlands Delineation Reports. This appendix will contain formal ' delineation reports prepared according to approved USACOE and DEC methodologies (whichever may be applicable) for all wetlands (if any) directly affected by the project. The boundaries of such wetlands as they are affected by the project will be field located by survey. �i Appendix 2 Flora and Fauna Report. This appendix will contain flora and fauna surveys of the areas for which construction is proposed. The survey will identify rare, threatened and endangered species as well as unique natural communities and habitats. Appendix 3 Stage lA and 1B Cultural Resources Survey. This appendix will contain a Stage 1A Cultural Resources Survey for areas affected by project construction. A Stage 1B survey will be conducted for those areas identified as having the potential to contain cultural resources. The Stage 1B survey will consist of shovel tests, generally at 50 foot intervals along proposed construction routes, or on a 50 foot grid for the pump station and sewage treatment plant facilities. Appendix 4 Traffic Study. This appendix will contain the results of the traffic study assessing the results of the build -out study. See Appendix D for a detailed description of the scope of this study. Ithaca Area Wastewater Improvement Project EIS Proposal 12 Appendix 5 Fiscal Impact Analyses. This appendix will contain the fiscal impact analyses for each scenario in each municipality and school district. Fiscal impact analyses will be conducted utilizing the proportional valuation method developed by Burchell, Listokin and Dolphin and presented in the standard reference, The New Practitioner's Guide to Fiscal Impact Analysis. Appendix 6 Build -out Study. This appendix will contain the detailed results of the build -out study performed as the basis for the growth inducing/secondary impacts section, including all assumptions, data used and showing calculations (e.g. water use calculations, demographic multipliers, i- etc.). Appendix 7 Engineering Report. This appendix will contain engineering information relevant to discharge standards, noise and odor control. The purpose of this appendix will be to provide sufficient information to demonstrate compliance with appropriate standards and to address concerns ' typically associated with wastewater pumping and treatment facilities. ' Appendix 8 Letters of Record. This appendix will contain copies of all relevant correspondence with agencies and personnel involved with the r project, such as the New York State Natural Heritage Program Significant Habitats Unit, The New York State Office of Parks, Recreation and Historic Preservation, local service providers, etc. Appendix 9 Records of Contact. This appendix will document all interviews, contacts, information sources, etc. Appendix 10 Scoping Document. This appendix will contain a copy of the Scoping Document. Appendix 11 Bibliography. This appendix will document all resources consulted. I Task 6 DEIS Comment Period Support This task includes project support during the DEIS comment period, including attendance at the hearing, making presentations and answering questions as required. Ithaca Area Wastewater Improvement Project EIS Proposal 13 Task 7 Optional Task: Supplemental DEIS We believe that if the DEIS is properly prepared, there will be no need for a supplemental DEIS. However, recognizing the possibility that one may be required, and to demonstrate our understanding of the SEQRA process, we have included the preparation of a supplemental DEIS as an optional task. At this time it is not possible to provide a scope or fee for this task, should it be required. Task 8 Prepare Final Environmental Impact Statement (FEIS) The Consultant will prepare a FEIS for the project. The DEIS and FEIS will collectively form -the EIS upon which the agencies will make their decisions. The Consultant will work closely with Stearns & Wheler and the project team to ensure that the document reflects the collective thinking of the entire project team. In particular, it will be important that conclusions and recommendations with respect to local zoning and land use plans and traffic improvements be agreed upon, especially where there are funding implications. The FEIS will consist of the following parts. Project Description. The Project Description will summarize any changes or revisions to the project that have been found to be desirable as a result of the ' SEQRA process or other considerations. CSummary of and Responses to Substantive Comments. This section of the FEIS will summarize substantive comments and provide responses to such comments. Substantive comments will generally be grouped by subject and a single response provided to all similar comments. .Additional Studies/Analyses. Additional studies or analyses may be required to respond to certain substantive comments or because of changes to the project. This section will present such studies and analyses. Errata. Errata to the DEIS will be presented here. 1 Task 9 Prepare Findings Statements ' The Consultant will are re Draft Findings Statements for each of the involved prepare g agencies for the project, reflecting those agencies decisions for their respective ' 14 Ithaca Area Wastewater Improvement Project EIS Proposal jurisdictions. Draft Statements will be circulated for review and comment. We will attend meetings as required to review and refine the Statements. Task 10 Meetings g The Consultant will attend meetings in support of the project as required. We have assumed ten meetings in Ithaca in support of the project (Seven Planning Team Meetings, plus Kick-off, Scoping and Public Hearing meetings). We are of course available to attend additional meetings as required. 15 Ithaca Area Wastewater Improvement Project EIS Proposal C! SECTION 3 PROJECT SCHEDULE We propose to complete the DEIS for submittal within four months of Notice to Proceed. This schedule assumes completion of the public Scoping session by approximately the second month of the project and issuance of a final Scoping document by approximately the third month of the project. (We will of course be preparing the DEIS beginning from Notice to Proceed). After submission of the DEIS, the schedule will be somewhat dependent on actions by the Lead Agency. In general, we would expect the following after submission of the DEIS. DEC Completeness Review 30 days Revisions and Resubmission 30 days Comment Period 45 Days Prepare FEIS 45 Days Prepare Findings 30 Days Thus, with four months to prepare and submit the DEIS, we anticipate a total project time of ten months. Again, let us emphasize our commitment to work with the Planning Team to respond to information requests and otherwise complete the project in as timely a fashion as possible. We anticipate monthly meetings with the project team during the ten month schedule, of which three meetings will consist of the kick-off meeting, the Scoping meeting and the DEIS public hearing. IIthaca Area Wastewater Improvement Project EIS Proposal 16 SECTION 4 STAFFING AND ORGANIZATIONAL CHART Staffing for the project team was presented in our qualifications submittal. Since that time we have made several additions, which we believe strengthen our team. These additions are summarized as follows. ' SRF & Associates has joined our team to conduct traffic and transportation analysis. Mr. Steven Ferranti, Principal, will lead the SRF team. He will be assisted by Mr. Robert M. Shull of the Tmodel Corporation, who will assit with the traffic modeling tasks. Resumes and qualifications for SRF are found in Appendix B. We have added Mr. David Wycliffe to the Chazen team as principal GIS analyst. Mr. Wycliffe recently joined Chazen from a regional planning agency in New Hampshire where he spent nine years. During his tenure Mr. Wycliffe used GIS to perform build -out analyses for several towns using methods nearly identical o those ' proposed to be employed here. Chazen has also added Ms. Barbara Beall to our team in the role of senior environmental/wetland scientist. A former employee of the US Army Corps of Engineers, Ms. Beall has an unmatched knowledge of wetlands ' rules and regulations. Inasmuch as the physical extensions of sewer lines are likely to involve multiple crossings of streams and Federally regulated wetlands, her knowledge will be invaluable. With these additions, the organization of our team is presented in chart on the following page. 1 Ithaca Area Wastewater Improvement Project EIS Proposal 17 NYSDEC lead Agency Baca WATP EIS Organization Chad Steams AWhelet Planning Team aie l - Representativesd InvowdMunicipalities - 1 Richard Chown, RE The Chazen Companies Warm, AICP Principal in Charge SWd F. Mesnger, AICP _ QAZ Review Project Manager SRF&Associales ChyilSape TraflicAma�ses Cullural Resources Assessmenis Steve Ferranti, RE Gail Guild Mr. Robed Shul Trina Fmey,AICP Jane Marshal David woo Barbara Beall, CWS MikeNowida Joe lanaro, P.E. PrincipalManner Junior Manner GISManager EnvironmedalSderr g j EnvironmentaiSden6st Managing Engineer Dala Analysis, RepodWiting Data Colddesearch GIS Anaty es Wetlands and Stream Flora and Fauna Idendcalion Wadewaler Impad Aaa�es Idendation and Permitting Ithoca Area Wastewater Improvement Project EIS Proposal 18 1 SECTION 5 FEE PROPOSAL We propose to complete Tasks 1-6 exclusive of the Phase 1B Cultural Resources Survey for a lump sum professional fee of $180,000. This fee includes the completion of one set of revisions to the DEIS based on Lead Agency comments. Expenses such as travel, printing and lodging shall be in addition to the professional fee. We to complete the Phase 1B Cultural Resources propose P es ces Survey for a fee of $2,500Ainear mile of testing, (or equivalent for non -linear areas) inclusive of expenses. [i With respect to Task 7, we propose to review the Scope of any Supplemental DEIS � that may be requested and negotiate a fee with you after such review. As previously stated, we believe that if the DEIS is properly scoped and prepared, a Supplemental DEIS will not be required. With respect to Task 8, we propose to negotiate a fee for preparation of the FEIS F. after review of all comments. L-1 With respect to Task 9, we propose to complete the Findings Statements on an j hourly basis with a Not to Exceed fee of $5,000. L,' With respect to Task 10, we propose that all meetings be reimbursed on an hourly basis. We recommend that you budget $10,000 for meetings. Expenses shall include travel, lodging and printing. We recommend you budget 5% of the project fee for expenses. C' n 1 IthacaArea Wastewater Improvement Project EIS Proposal APPENDIX A 1 CHAZEN RESUMES 11 I� -' The Chazen Companies Ithaca Area Wastewater Improvement Project MESINGER STUART F. MESINGER AICP Pro'ecf:ites C Senior Planner ProjectRole Project,Manager, Education BS Geology/Environmental Studies Project°Respdnsibilities::_ Projecf Management., St. Lawrence University, magna cum laude Highest Degree: B$ Geoiogy.;l.: ' Phi Beta Kappa Envir`onr"riental:Sfudies�:°: _ _ _ . Licensure/Certification . Certification: Professional_-``.' Certified Planner -American Institute of Certified Planners Planner-"_ � - `- • Years:�.Experience:.4�8,"�=- • Affiliations American Planning Association St_ rengths:','': New York State Planning Federation Broad SEQiZA;:,Plannirig, and:=CIS:_Ezperience;:< . �Kiloitiledge:�of:'Fi�oject{area; Experience [ff f Mr. Mesinger has over 18 years experience in land use planning, environmental impact review and geographic information systems and is a former town and county planner in upstate New York. As a planning consultant he has successfully assisted planning and C town boards with the SEQRA review of complex and controversial commercial and industrial projects. He has particular expertise in municipal, regional and recreational (�I planning, in the management of complex, large-scale projects, and in planning in the U unique regulatory environment of the Adirondack Park. Mr. Mesinger is responsible for managing planning, environmental and GIS projects from Uthe firm's Glens Falls office. He performs site analyses and technical studies, prepares ordinances, regulations, environmental impact statements as well as other planning and �l zoning documents, and supervises staff involved in such projects. Mr. Mesinger represents Uclients at meetings with regulatory and review agencies, the public and advocacy groups and has served as consulting planner for numerous municipalities throughout New York. Mr. Mesinger has managed and served as the principal planner for numerous municipal planning projects and master plans, including the Eastern Gateway Canal Regional Plan, the Adirondack Loj Master Plan, and the City of Ithaca West End Redevelopment Plan. Mr. Mesinger has also prepared municipal master plans and implementation ordinances for communities such as Stockbridge, Massachusetts, Saratoga Springs, New York, Lake Placid, New York and Lake George, New York. Mr. Mesinger has managed the environmental review process for numerous public and private sector clients. Projects for which he has prepared environmental impact statements include 1,000,000+ square foot shopping malls, ski centers, mixed use developments and campus expansions. Mr. Mesinger teaches courses and has written about planning, environmental review and Shovel Ready development. 11 The Chazen Companies Qualifications for Ithaca Area Wastewater Improvement Project RICHARD H. CHAZEN, P.E. Principal Education BS Civil Engineering, Syracuse University Licensure Licensed Professional Engineer — New York State New Jersey Affiliations National Society of Professional Engineers American Society of Civil Engineers National Association of Environmental Professionals Vassar Brothers Hospital Board of Trustees Dutchess County Economic Development Corporation Development Committee Mid -Hudson Consulting Engineers Society Experience Project, Responsibilities Project Role:`Principsl=in-Charge Project .Respons itiilities:. Advisor Highest Degree: BS Civil. . Engineering- Registratlon :.Professional Engin"e'er , . Years'.Experiencb..: over 30 Strengths: •:_: Broad civil'engirieering an"-d-.. planning experience • Excellent c6mmunication: sk Ifs Mr. Chazen has over 30 years experience in consulting. His earliest assignments with his father's company, Milton Chazen Associates, were to the survey and construction inspection crews. During his University years, Mr. Chazen broadened his engineering and land development experience. Following graduation, Mr. Chazen accepted a full-time appointment to Milton Chazen Associates and gained technical experience under the direction of the senior engineer of the company and administrative skills under the direction of Milton Chazen. ' Today, Richard Chazen directs the day-to-day operations of the Chazen Companies. He has developed extensive expertise in assisting municipalities with comprehensive plans, zoning ' ordinances and the local review and approval process. Mr. Chazen has planned and supervised numerous urban renewal and community ' development projects including rehabilitation and redesign of water supply, wastewater and stormwater facilities, streetscape improvements and road and sidewalk. systems. ' He has developed extensive SEQRA experience and has a complete and thorough understanding of the statute and accompanying rules and regulations. He has presented projects to many planning, zoning, and municipal boards including residential, commercial, ' and industrial development in the lower Hudson Valley as well as SEQRA activities for municipalities including the City and Town of Poughkeepsie, the Village of Millbrook, and the Towns of Washington, Clinton and Ulster. _J D D C� 1 11 The Chazen Companies Ithaca Area Wastewater Improvement Project JEFF KANE, AICP Director of Environmental Planning Services Poughkeepsie Office Education BA, Economics, College of William and Mary, Williamsburg, Virginia Reg istration/Certification American Institute of Certified Planners Affiliations American Institute of Certified Planners American Planning Association New York Planning Federation Design Experience KANE Project Regponstblities Project Role:1Planning Reviewev. Project R_ esporisibilities: QAIQC Review Hghest'Degree:_BA Economic Certification: AmericanInstitute of Certified=Planners:. ; . Years Ezperlerice:...13, Strengths:. • Planning..Analysis. • Broad- SEQRA Expefth6e,'.1. Mr. Kane directs the firms environmental planning division. As such, he is responsible for the overall management of a wide range of planning and environmental projects. He analyzes, prepares and comments on zoning, planning and environmental documents, studies and regulations, land use plans and environmental impact statements. Prior to joining Chazen, Mr. Kane worked for a not -for -profit organization on Long Island where he was appointed by the U. S. Environmental Protection Agency to the Land Use Planning Work Group for the Long Island Sound Study. C Mr. Kane serves as a consulting planner for municipalities throughout New York's Hudson Valley. He prepares comprehensive plans, zoning ordinances and subdivision regulations. He prepares SEQRA review documents and coordinates the review process for municipalities. Mr. Kane also assists Board's with the review of projects, providing C� comments and advice. Mr. Kane directed the preparation of the City of Poughkeepsie's l Comprehensive Plan, completed by Chazen in 1998. [I For the private sector, Mr. Kane manages the preparation of environmental impact statements. Recent projects include Westchester County's long-term sludge management ' program and the review of New York City's Watershed Rules and Regulations for private clients. City of Poughkeepsie Zoning Ordinance Update D The Chazen Companies Qualifications for Ithaca Area Wastewater Improvement Project CHARLES DAVID WICKLIFFE GIS Manager Education BA Geography, University of New Hampshire Affiliations Pi Gamma Mu Honor Society Experience WICKLIFFE . ProjecfResponsbiltles Project Role.: GIS Analyst ProjecfR' esponsibilities: Perform all GIS Analyses Highest Degree:,BA:Geograph- . Registration: 'Professional Engineer Years Experience: 11 Strengths: • groad GIS,experience in a planning context • Extensive•experience using GIS to. conduct build -out studies Mr. Wickliffe has more 11 years of progressively responsible experience in the GIS field. Prior to joining Chazen he was the GIS Director for the Strafford, New Hampshire Regional Planning Agency, in which capacity he managed GIS projects for 17 municipalities in southeast New Hampshire. Mr. Wickliffe previously held positions with the Complex Systems Research Center in Durham, New Hampshire where he performed progressively responsible technical GIS tasks. Mr. Wickliffe has performed build -out studies for a number of municipalities. He has developed methodologies to apply natural resource limitations to build -out analyses. He has additionally prepared maps and analyses relating to land use and zoning, tax parcel mapping, conservation planning, transportation planning, stormwater planning and census geography design. Mr. Wickliffe manages staff and budgets for GIS projects. He trains clients in the ESRI tool suite. He possesses exceptional communication skills, especially in explaining GIS concepts and analyses to the lay public. Mr. Wickliffe is skilled in using SML, AML and Avenue languages to create GIS t applications. He is experienced in using GPS to capture data for inclusion in GIS, engineering and surveying projects. The Chazen Companies Qualifications for Ithaca Area Wastewater Improvement Project BARBARA B. BEALL, PWS Senior Environmental/Wetland Scientist Education BA Environmental Chemistry, Long Island University Cum Laude MS Environmental Studies, SUNY Environmental Science and Forestry Affiliations Certified Professional Wetland Scientist #267, Society of Wetland Scientists Board of Directors, New York State Wetlands Forum Mid -Atlantic Chapter, Society of Wetland Scientists Member, The Association of State Wetland Managers Advisory Member, Golf Course Superintendents Association Government Relations Committee Experience BEALL Project Responsibilities Project Role:' EnvironmentaiNVetland Scientist Project Responsibilities c Evaluate Impacts, Mitigation and Permitting: Issues for -Streams and. Wetlands Highest Degree: MS Environmental Studies - Registrations Professional' Wetlands=Scientist Years Experience: 19 Strengths: . Extensive Wetlands= and Stream Permitting Experience ' Ms. Beall has 19 years experience in all facets of environmental analysis, specializing in stream and wetland identification, permitting and wetland design. Prior to joining Chazen, Ms. Beall was an environmental scientist with the regulatory branch of the US Army Corps t of Engineers. Ms. Beall's experience as a regulator makes her uniquely suited to assist clients with permitting and mitigation issues involving wetlands and stream disturbance. Ms. Beall's prior experience includes designing wetlands mitigation plans for a number of complex, high profile projects, including a major shopping center in New Hartford, new York and a cogeneration plant in Plattsburgh. She has particular expertise in wetlands issues involving golf courses and has consulted on a number of such projects. In addition to her wetlands and stream specialties, Ms. Beall is an experienced environmental analyst familiar with a wide range of projects and analysis techniques. She has extensive experience preparing environmental assessment forms and environmental impact statements for a wide range of projects. She has managed the approval process for diverse projects including housing subdivisions, retial developments and cell towers. Ms. Beall has published and spoken extensively on environmental topics, especially those related to wetlands disturbance and mitigation. She is active in all of the major organizations involved with wetlands issues in New York State. The Chazen Companies Ithaca Area Wastewater Improvement Project TRINA FINNEY, AICP Senior Planner Poughkeepsie Office Education BS Urban and Regional Planning Eastern Washington University MS Urban and Regional Planning University of Texas Lice ns u re/Certification Certified Planner -American Institute of Certified Planners Affiliations American Planning Association Chair, International Department of Texas APA National Arbor Day Foundation u Experience Finney ProjectResponsbllties . Project:Role:_Principal Planner. Project -Responsibilities:. Research and;. preparation of-DEIS Highest Degree:: MS. Urbaw4hd' planning:... ; Certification:Professional:-Planner Years::Ezperience: 8 Strengths. •:. -Broad :Plan 6ing,;Experien6e ::. Excellent ceComnmunicator; • .Experencwith Growth. Management Issues= L� Ms. Finney has over eight of increasingly responsible experience with city planning departments, most recently in Texas and Washington State. Ms. Finney also previously operated a planning consulting business in which capacity she was the principal planner for comprehensive plans for municipal clients. Ms. Finney's assignments have included conducting neighborhood planning processes, housing plans, streetscape plans and revitalization plans. ' Ms. Finney's previously helped develop a neighborhood revitalization policy for the City of San Antonio, Texas. She developed neighborhood and housing revitalization plans for the ' City of Lewisville, Washington. Ms. Finney's responsibilities for Chazen include all aspects of comprehensive planning. Her background in revitalization planning makes her particularly suited to carry out economic and housing related planning tasks. She has experience working in growing suburban communities and is familiar with growth management issues and techniques. She is an ' excellent meeting facilitator and regularly participates in community based planning projects. She has drafted zoning ordinances for a number of communities and is familiar with current issues and techniques. Ms. Finney also prepares SEQRA documents, including EAF's and EIS'. She is an excellent researcher and writer. The Chazen Companies CIthaca Area Wastewater Improvement Project J JANE E. MARSHALL Assistant Planner Education B.Sc. Urban and Environmental Studies/Biology Brock University, Ontario, Canada M.A. Urban and Regional Planning University of Waterloo, Ontario, Canada Affiliations American Planning Association Experience MARSHALL :Project Responsbiilities Project Role: _Assistant Planner'. ProjecfRespornsjbilit es: Resear 16ollectionch and- Data_ _ _ Highest Degree: M:A_. Urban -and '.; Regional Rlanning - Years Experience: 4 ; Strengths: tJ verse. Planning.:'Experience'.. ' •. � Outstanding itesearch..Skills.. : Build=out Study Experience, Ms. Marshall has been involved in the planning and environmental field as a county planner, private consultant, and assistant biologist. Ms. Marshall has prepared numerous planning reports on a wide range of topics and has participated in several multi - stakeholder initiatives involving watershed management and air quality. She has also participated in waterfront planning initiatives for several communities For The Chazen Companies, Ms. Marshall is responsible for the preparation and presentation of municipal planning and environmental documents. Current projects include the preparation of comprehensive plans and zoning ordinances for the Villages of Hunter and Stamford and the Town of Windham, located in the Catskills, and the Town of Lake George in the Adirondacks. Ms. Marshall is also helping Putnam County communities evaluate the effects of the New York City Watershed Agreement on their future growth and development. Ms. Marshall is providing research assistance for the update of the Queensbury zoning ordinance, and she has proven to be a skillful facilitator at stakeholder meetings. Ms. Marshall is an outstanding grants writer. She recently assisted the Village of South (�I Glens Falls in obtaining $86,000 in State funding for acquisition of watershed property. �J Within the last six months she has helped the Town of Stillwater obtain $12,000 for pedestrian improvements, the Town of Lagrange $10,000 for records management and the ' Village of Canton $3 million for water system improvements. She maintains a computerized database of municipal funding opportunities that is available to Chazen's clients. Ms. Marshall is an excellent researcher. She won numerous academic awards in College and has a strong knowledge of how to use technologies such as the Internet to conduct research for planning and zoning projects. ' The Chazen Companies Ithaca Area Wastewater Improvement Project NOWICKI OMICHAEL NOWICKI Pro ect R ` ` -"`'` '` 6- � -, , esponsibiirties Wildlife/Wetland Biologist _ - n Project Role: Environme_ ntaf . lJ Scientist Education ' BS Environmental and Forest Biology, SUNY Project.Responsibilities Wetlantls . College of Environmental Science and Forestry deliheations; flo'ra/fauna'surveys . _ Environmental . ' and FoHighest:Degree;BS: rest Biology-. Licensure/Certification Certified Wetland Scientist Registration: -.Certified. Wethnd :,_ Scientist ... _ ..._ ..: Years". Eicperience:.9 Affiliations :- .. Society of Wetland Scientists .. _Brosd�'wetianddelii�eat®n�and ,.. ,. ;.: flora/fauna siirv0 lexperience Experience Mr. Nowicki has prepared documentation for a range P P g of projects under the New P J York State Environmental Quality Review Act (SEQRA), including the preparation ' of environmental impact statements. Mr. Nowicki has experience classifying and mapping soils according to the Unified CSoil Classification System. Mr. Nowicki is experienced at mapping using aerial photography and remote sensing data. CIMr. Nowicki routinely performs wetlands delineations applying local, state and federal criteria. He prepares delineation reports, prepares permit applications and n develops mitigation and restoration plans. Li Mr. Nowicki is an experienced wildlife biologist. He routinely performs flora and (`� fauna surveys for rare, threatened and endangered species. The Chazen Companies Ithaca Area Wastewater Improvement Project JOSEPH A LANARO, P.E. ClManaging Engineer Education BS Civil Engineering, Union College, cum laude AAS Civil Engineering Technology, Architectural Emphasis ' Hudson Valley Community College Licensure/Certification Licensed Professional Engineer — New York, Vermont, New Hampshire, Maine, Indiana ClNew York State Class C Water Treatment Plant Operator J Hazardous Waste Site Operations, Certification per 29CFR 1910.120 n c LANARO Project ,psponsibil ties Project Role: seniorEngineer Project' Responsibilities: Odor; Eng�neer�rig;:Wastewater.,and; .:;. ilUater,QualityAssessment� ",'' Highest Degree: BS Civil Engineering. � _ Registrafion:. Professional: -_ _ Engneer _ - Years:"Experience:��12" Strengths::.. Affiliations •.::Broad�:INastewa#er:Engineerfng - erid:Environrrental;Analysis . American Society of Civil Engineers ExpecienCe _ National Society of Professional Engineers Chairman, Scholarship Program, 1994-1999 Home Builders Association of Northern New York, Board of Directors:1994, 1997 Secretary/Treasurer: 1995, 1996 Adjunct Professor, Union College, Civil Engineering Department: 1996-2000 Experience I Mr. Lanaro is Managing Engineer for coordinating and overseeing civil and structural engineering operations from Chazen's Capital District office. He is responsible for overseeing project development -including: planning, design, construction documentation, construction administration and quality control; and project detailing, specification, estimating, permitting, bidding and construction review. CMr. Lanaro has extensive experience in project management, public presentation and is a seasoned construction administrator. Mr. Lanaro has completed site development plans for a wide range of residential, commercial, industrial, institutional, and municipal projects. This experience includes ' development of highway work permit plans, applications and reports, design and development of water and sanitary systems, erosion control plans, and traffic impact analysis and design. He has particular expertise in water and sewer design and has prepared odor control systems and assessed water quality impacts of numerous sewage treatment plants. Notable recent experience includes development of, the Lake George Stormwater Management Plan, Sewer Improvements along Church Street, City of Saratoga Springs, and development of new sewage disposal facilities at Gore Mountain. Mr. Lanaro is also on the engineering faculty of Union College. Ithaca Area Wastewater Improvement Project EIS Proposal APPENDIX B SRF &ASSOCIATES QUALIFICATIONS Our Philosophy - "The larger purpose is not simply to move traffic safely and efficiently, to help create a sense ofplace, to enhance livability - to help shape a community.Me 6 " ' `.-X : ;•'.�."+x='Sc rat` ,�'sYi' �` %i' ""� �a�JIR r t SRF & Associates provides professional traffic engineering and transportation planning consult- ing services to communities and private clients throughout New York State. The staff of SRF & Associates provides a full range of community traffic engineering and transportation planning re- lated services for a wide range of projects. The firm, started in 1985, was organized in recognition of the need for those specialized services. Services offered include Land Use and Arterial Management Planning, Traffic Impact Analyses, Traffic Operations & Safety, Transportation Planning, Congestion System Management & Moni- toring, Traffic Calming, Parking, Traffic Signal Services and Municipal Technical Review Serv- ices. 1 1 Li 1 uatim; satcty, udusporration planning, Lana use planning, and urban design. 5 Transportation Planning The planning of transportation facilities to accommodate the needs of today . ,- _ - ` =RopEo g04;Ciieridor Study-% and for the future is becoming increasingly difficult due to the complexities involved. The availability of land, money, and energy, as well as the socio- economic and environmental considerations make it mandatory to develop innovative solutions for solving problems. SRF & Associates provides transportation planning capabilities in the following areas: Corridor Planning, Sub -area Planning, Town Master Plan - Transportation Element ' s _ Planning, and Alternatives Analysis. GIS technology is used as a vital tool in the transportation planning process. I ' Traffic Impact Analysis The preparation of an traffic impact study is often an essential element required as part of the development review process. SRF & Associates has conducted hundreds of traffic impact analyses for a variety of land uses ranging from small scale residential developments to regional shopping centers. These studies include analysis of the adjacent public roadways and intersections, as well as on -site parking, and circulation for both motorists and pedestrians. SRF & Associates also routinely presents concepts of traffic flow and transportation issues to municipal agencies and the public. i j Traffic Engineering & Safety Traffic Engineers have always sought to provide for the safe and efficient movement of people and goods. The staff at SRF & Associates has conducted many studies for the purpose of reaching that goal. The potential conflict that exists between the various modes of transportation requires careful attention in the planning and design process. Our services can be categorized to include Site Traffic Engineering, Traffic Operations Studies, Safety Studies, Accident Analysis and P.I.L. investigations, Roadway & Intersection Design, and Traffic Surveys. d Transportation Systems Management During the past ten years, much more attention has been given to maximizing the existing transportation system efficiency by utilizing low cost and/or short term efforts. These types of solutions called Transportation Systems Management (TSM) can include such items as ride -sharing, staggered work hours, flex -time, and parking management, as well as traditional traffic engineering measures. SRF & Associates has provided recommendations such as those stated above in may studies for both private and public clients alike. Parking The need to provide sufficient parking in an effective and safe manner has become increasingly important. SRF & Associates provides parking consultation in the areas of Central Area Studies, Site Specific/Location Studies, Parking Supply & Demand Analysis, and Parking Lot Layout. Traffic Signal Design Services The impacts of new developments can often warrant a new signal or require the development of an integrated traffic signal system. Other times, simple modifications in phasing or timing of existing traffic signals can accomodate changes in travel patterns. SRF & Associates provides various traffic signal analysis and design services including Traffic Signal Justification, Traffic Signal Design, Signal Timing Analysis, and system- wide progression and interconnection analysis / design. Municipal Services Many municipalities that do not employ a full-time traffic engineer/transportation planner often find themselves confronted with traffic problems generated by growth or dynamic travel patterns. The services of trained traffic engineers are frequently required. SRF & Associates has been retained by several municipalities to review development site plans, traffic impact analyses, analysis of traffic operations, and safety related matters. 1. Southwest Area Land Use Study, Town of Ithaca, New York F The firm assessed the traffic/transportation issues of a Generic Environmental Impact Statement. The study established :'the existing conditions on -site and adjacent to a vacant land parcel in the City of Ithaca. Various land use scenarios, ( i ranging in size from 500,000 s.f. to 1.2 million s.f were investigated as viable alternatives. The intent was to identify — the best combination of land use on -site, and the phased improvements required to mitigate impact to the surrounding transportation network. Comprehensive traffic models were established and super imposed on a G.I.S. background util- izing SYNCHRO traffic software. The existing and future alternative models assess the vehicular operating conditions ;E at 27 separate intersections throughout the City, and incorporate 4 new access points to the infrastructure surrounding the site. I Contacts: H. Matthys VanCort, Planning Department Director Allen Cohen, Mayor r City of Ithaca City of Ithaca 108 E. Green Street 108 E. Green Street Ithaca, New York 14850 Ithaca, New York 14850 (607)274-6550 (607)274-6526 2. North Campus Residential Initiative, Cornell University, Cornell, New York SRF & Associates was retained to prepare a traffic study to support the transportation issues related to site modifica- tions on Cornell's Campus. The plan includes the construction of new residence halls, a central dining facility, and relo- cated athletic fields to be situated around a central Quad Area adjacent to the dining facility. The study involved the investigation of the transportation network in and around the site, including 12 intersections and 6 centers of major pe- = '- J destrian activity. Existing vehicular and pedestrian traffic flow was established and future conditions projected to assess safety, operational and capacity impact. Mitigation requirements were recommended to offset the impact attributed to the proposal. Two final products were produced; a Traffic Impact Study to be included as a technical appendix of the ^ DEIS/FEIS, and a separate Technical Traffic Memo addressing safety and review of the overall site plan. Contacts: Eric F. Dicke, Director of Facilities Planning Kathryn Wolf, Principal s Cornell University Trowbridge & Wolf (607) 255-1126 1345 Mecklenburg Road i (607)277-1440 =i -f I I I I 11 0 I D I --­13. City-wide Traffic Calming Program, Town of Ithaca, New York Traffic engineering sub -consultant assisting in the identification, rating and evaluation, neighborhood consensus build- ing process, design and implementation plan for one of the first city-wide traffic calming plans in New York State. Pro- 1 gram process involved development of priority rating system, data collection and analyses of alternative sites, considera Lions for selection of one or more devices and the relationship to the M­UTCD, AASHTO, and NYSDOT's Highway De- 4 sign Manual — Chapter 25 on Traffic Calming. Assisted in technical advisory committee involvement and neighborhood charette in a highly educated and environmentally sensitive setting. Contacts: 'I William Grey, Director of Public Works Leslie Chatterton, Program Director City of Ithaca City of Ithaca 108 E. Green Street 108 E. Green Street Ithaca, New York 14850 Ithaca, New York 14850 (607) 274-6530 (607) 274-6550 4. Museum of The Earth, PRI, Town of Ithaca, New York The firm was resonsible for preparing a Traffic Impact Analysis to evaluate the projected traffic demands on the surrounding roadway network for the Paleontological Research Institution's (PRI) proposed Museum of The Earth. The project consisted of approximately 18,000 s.f expansion of the existing PRI exhibit hall located on the 6.35 acre site. The project involved collection of existing data, including review of visitors logs to determine origin and quantity and - ._;time of day for trip distribution and generation purposes. -A Warren D. Allmon, The Paleontological Research Institute 1259 Trumansburg Road Ithaca, NY 14850 J J607) 273-6623 VICINITY MAP MUSEUM OF THE EARTH P.LEONTOLOGICAL RESEARCH INSTITUTION NY,S Route 96. Trumomsbuig Rood TM TC^ V,' 111AACA. TCL,PVr COUMV. 41-.a '�X I 11 u 5. Town -wide & Sub -Area Transportation Studies .i Town of Victor, Ontario County, New York The Town of Victor is one of New York's fastest growing towns, located at the crossroads of the NYS Thruway and Interstate I-490. It's tremendous transportation assets have accelerated growth in regional retail, and light industry development. SRF & Associates — also the Town's Traffic Consultant, assisted the Town in developing both a town - wide and sub -area transportation study, focusing on the future land use demands on the available transportation system. " `Each study documented existing and forecasted 2015 traffic conditions. Alternative improvements related to new expressway ramps, collector roads, Victor TrasisportntianStudy intersection operational and safety improvements, traffic and land use Gcucsee Trnnsportetimi Cmmril -`:' demand, and arterial management strategies were developed. Fare share cost f Town of Victor a allocation formulae for funding transportation improvements were developed. Contacts: Mr. Jack Richter, Town of Victor Supervisor jV�.� Ms. Jane Luce, Director of Development 8 North Main Street N Victor, New York 14526 "' ^�^ •� w; ' �� (716) 742-5040 s 'r. 6. Transportation Master Plan, Town of Irondequoit, New York The Town of Irondequoit, bordered on three sides by water, has a relatively steady population partially due to the Town being over 90% developed. As a consultant on this project, SRF & Associates brought local knowledge and 'Transportation Planning Experience to primarily focus on redevelopment and revitalization. The Transportation Master Plan serves as a guide for traffic and transportation system decisions for the next 15 years and will influence many public and private decisions that will create and shape the future of Irondequoit. The Master Plan will also assist the - _-= Town to progress projects with the assistance of county, state, and federal agencies. �s Contacts: David Schantz, Supervisor Krishan Mago, Planner Town of Irondequoit 1280 Titus Avenue Rochester, New York 14617 (716) 336-6034 7. Highway Monitoring System, Town of Penfield, New York ..... =� SRF & Associates developed for town staff use, a geographic information system (GIS) based information management system used to monitor the i transportation system performance and trends in the Town of Penfield. s The project employed state-of-the-art GIS technology that provides town staff with a dynamic information system for decision -making. The system development included updating traffic volume counts, and highway and = : + intersection level of service at all the major intersections within the town. ;Analysis of land use trends and resulting traffic changes were quantified as part of the project. Chan Philbrick, Town of Penfield Supervisor Jim Costello, Penfield Director of Planning & Development 3100 Atlantic Avenue :. Penfield, New York 14526 1(716)377-8600 Development of Arterial/Access Management Studies (on -going) Various Locations and Counties, NYSIDOT Regions 1-7, 9, New York Totten Of Penfield Highway Monitoring System Report =„rt PrtparcA b,: SI2F R,1mu�lr� .: SRF & Associates was selected to assist the Department in developing multiple project studies which demonstrate practical ways to realize the potential of arterial/access management to enhance highway capacity, promote safety, and support economic development. The studies are developed in cooperation with localities and are primarily concerned with State arterial corridors. Traffic and growth management issues are addressed. The studies facilitate revised or new il land use ordinances, circulation improvements, and other access management enhancements. The goal of the studies is to develop prototype arterial management applications that utilize a variety of approaches to implement arterial and access management concepts. The range of applications include Corridor Access Mangagement Plans, Area Wide Circulation Plans, Corridor Capacity Preservation, Project Design Input, and Local Network Improvements. - I Contacts: Mr. Ken Carlson, Planning Division New York State Department of Transportation 1220 Washington Avenue I Albany, NY 12232 (518) 457-3429 .s 4` �i 9. NYS Route 17/Chambers Road/Colonial Drive Ramp Evaluations } Town of Big Flats, Chemung County, New York SRF & Associates, as the Project team's traffic consultant, performed extensive traffic engineering and transportation planning evaluations related to new ramp and interchange propopals at Route 17/Chambers Road interchange. Existing conditions, and twenty year forecast conditions were determined and analyzed using travel demand, operations, and simulation models. Area -wide intersection analyses and traffic simulation runs were performed to assess the future operating conditions and travel benefits associated with alternative interchange and intersection improvement plans. - Contacts: Mr. Thomas Tranter, Chemung Co. Executive Elmira, New York : Mr. Paul McAnany, Regional Design Engineer _ NYSDOT Region 6 (Hornell) (607)324-8438 10. Land Use and Access Management Plan, NYS Routes 441/250, Town of Penfield, Monroe County, NY SRF & Associates, as project Traffic Consultant, provided traffic engineering and transportation planning services for the development of a land use and access management plan on two NYSDOT corridors in the Town of Penfield, New York. Existing, and future 20 Year traffic scenarios were analyzed based on existing land use plans. Alternate land use plans were analyzed and recommendations for access outlined. A comprehensive 4 = i package of arterial management strategies was developed; an Access Management "ice ' Plan and Access Management Corridor Overlay Zone were crafted, and adopted. Roadway and geometric recommendations for design conditions were also developed. s- This highly sensitive project required extensive public, Planning Board, and Town Board interaction and orientation. Significant interaction with a corridor task group and NYSDOT was also necessary. a •j This project was designated by the NYSDOT Corridor Management Group as a case study in the publication Best Practices in Arterial Management, November, - 1996. The project case study was also chosen by the USDOT-FHWA, and Transportation Research Board(TRB) Committee on Access Management as a "Selected Paper from the Second National Conference on Access Management, Vail, Colorado, August, 1996, for presentation at the TRB 1997 Annual Meeting, Washington, D.C. Contacts: Chan Philbrick, Town of Penfield Supervisor . s Jim Costello, Penfield Director of Planning & Development 3100 Atlantic Avenue Penfield, New York 14526 (716)377-8600 Stephen Ferranti Title: Principal Technical Responsibility: Principal Traffic Engineer Areas of Specialization: ♦ Traffic Simulation / Visualization ♦ Access Management • Traffic Calming ♦ Land Use Planning (transportation related) ♦ Traffic Modeling • Traffic Impact Analysis ♦ Parking Demand / Circulation ♦ Traffic Operations Richard IDiCesare Title: Associate Technical Responsibility: Transportation Manager, Senior Traffic Engineer Areas of Specialization: • Traffic Forecasting ♦ Systemic/Isolated Capacity Analysis ♦ Safety Investigation and Accident Analysis ♦ Signal System Progression/Coordination/Optimization • Signal System Operation and Design ♦ Maintenance and Protection of Traffic • Traffic Impact Analysis ♦ Traffic Modeling Amv Dake Title: Traffic Engineer Technical Responsibility: Traffic Engineer Areas of Specialization: ♦ Data Collection and System Inventories ♦ Traffic Impact Analysis ♦ Traffic Signal Warrant Analysis ♦ Capacity Analysis ♦ Gap -Analysis ♦ Site Review Cory Greene Title: Traffic Engineer Technical Responsibility: Traffic Engineer Areas of Specialization: ♦ Isolated Traffic Signal Design ♦ Accident Analysis / Investigations ♦ Internal Circulation Analysis ♦ Data Collection and System Inventories ♦ Traffic Impact Analysis ♦ Capacity Analysis ♦ Speed/Delay Analysis F L :-PROFESSIONAL = : - ..BACKGROUND :EDUCATION ♦ Master of Business_ = . - Administratiop;Rochester:-- destitute -of Technology; .; Rochester, -New York = . i' '. Bachelor_ofScience; Civil Engineer_ing:Arizona State University;` -Tempe; Arizona -♦=."Associate of Applied -Science, _ Civil Technology; Broome Commimity College, - Binghamton, New:York. ,YEARS OF EXPERIENCE ♦ 25. REGISTRATION . 'Professionaf Engineer,_NY, License No.-57481-1, -Professional-Traffic, Operations "Engineer, Reg:-No.-488 ,,AFFILIATIONS',_` Institute of Transportation-.- _ Engineers; Member Grad_ e National -Transportation Re search Board Access Manage- ment Committee Member ♦ American Planning Associa- tion, Member American Consulting Engi- -.. neers Council Genesee Transportation Coun- '.cil, Planning Committee lVlem-.1 ber Mr. Ferranti has over 25 years experience specializing in traffic engineering and transportation planning. His professional experience has encompassed a wide range of private and municipal projects. As principal traffic engineer with SRF & Associates, he has developed land use and arterial management plans and strategies that have gained both national and state-wide recognition as "Best Practices" in the field of arterial management. He presently serves on the national Transportation Research Board Committee on Access Management, working on development of a national access management manual. He has provided complete traffic engineering consultant services for major projects and developments which require extensive highway and traffic control improvements. He has managed and conducted traffic impact studies for several hundred proposed or existing land use developments involving commercial, retail, medical and industrial facilities. He has designed numerous traffic signal systems and intersection geometric improvements for many municipalities throughout New York State. As a Senior Engineer with the Monroe County Division of Traffic Engineering, Mr. Ferranti was responsible for the direct supervision and management of the Traffic Engineering and Design Division staff. Prior to that he was an Assistant Engineer -Traffic with the Broome County DOT, Binghamton, New York for over three years. He was responsible for traffic safety and operational studies for Broome County. For over seven years with Monroe County Traffic Engineering, Mr. Ferranti was involved in the development of plans for streets and intersections, traffic signal systems, municipal parking facilities, traffic circulation studies, highway safety programs, land use development reviews and planning, neighborhood traffic management programs, and development and implementation of traffic engineering software applications. He has consulted, and provided technical assistance to municipalities, planning agencies, police, consultants, lawyers and the public on traffic engineering, planning and safety matters. Representative projects include: TOWN -WIDE & SUB -AREA TRANSPORTATION STUDIES, VICTOR, NY: The Town of Victor is one of New York's fastest growing towns, located at the crossroads of the NYS Thruway and Interstate I-490. It's tremendous transportation assets have accelerated growth in regional retail, and light industry development. SRF & Associates — also the Town's Traffic Consultant, assisted the Town in developing both a town -wide and sub -area transportation study, focusing on the future land use demands on the available transportation system. Each study documented existing and forecasted 2015 traffic conditions. Alternative improvements related to new expressway ramps, collector roads, intersection operational and safety improvements, traffic and land use demand, and arterial management strategies were developed. Fare share cost allocation formulaes for funding transportation improvements were developed. NYS ROUTE 332 CORRIDOR IMPROVEMENTS, TOWNS OF CANANDAIGUA & FARMINGTON,ONTARIO COUNTY, NEW YORK: As part of the NYSDOT rehabilitation and widening of a seven mile long principal arterial highway, assisted the NYSDOT and project consultant team in developing, understanding and advancing the application of land use and arterial management tools in support of the Towns's master plan goals and NYSDOT project objectives. Achievement of the full traffic, safety and local development benefits of the project depended upon state and local agreement over median treatment, circulation and C ' access issues and design guidelines, and enactment of access management ordinances. Key assistance was provided to NYSDOT in development and presentation of the arterial management concepts to the town boards and involved residents and businesses. This project was also selected for NYSDOT's handbook of Best Practices in Arterial Management. TOWNWIDE STRATEGIC TRAFFIC STUDY, TOWN OF PENFIELD, NEW YORK: Developed short term and long range transportation plan, and traffic forecasting model for entire town. Analyzed major intersections within town Ci under existing and ten year design conditions. Developed as part of the study, Generalized Level of Service Tables for the study roadways for use by town staff to assess the implications of various land use decisions. Proposed recommendations _ included roadway and geometric improvements, as well as recommendations regarding future ROW widths needed to accommodate future traffic conditions. PUBLICATIONS ' The Challenges and (Early Successes) of a Town Initiated Access Management "Retrofit" Program on Two State Highways, with Geoff Benway; Proceedings of the Second National Conference of Access Management, Vail, Co., 1996. Median Opening Decisions During Design Phase - Opportunity or Not? Co-authored with Donald Nims; Proceedings of the Third National Conference of Access Management, Ft.Lauderdale, Fla., 1998 SPEAKING ENGAGEMENTS l - Mr. Ferranti is regularly invited to speak at national and regional conferences. Recent speaking engagements have focused on transportation/land use relationship topics at: - 4`h National Conference on Access Management, Portland, Ore., Aug. 2000; "What Would You Do With This Street" — Panel Discussion l - APA National Planning Conference, New York, NY, April, 2000; "Access Manangement Plans... Customized to Fit Community Needs for Urban, Suburban and Rural Settings" - ITE Annual Upstate District Meeting, Rochester, NY, October, 1999, "Traffic Impact Studies" r - 3rd National Conference on Access Management, Ft. Laurderdale, Fla., (Oct., 1998), "Working with the Public, Media, and Corridor Businesseses During Access Management Improvement Planning" - APA National Planning Conference, Boston, Mass., April, 1998; ' "Coordinating Land Use & Transportation Through Access Management" - Transportation Research Board-1997 Annual Meeting, Washington, D.C.; "Experiences Managing Access" '- - 2nd National Conference on Access Management,Vail, Co., 1996; "The Challenges and (Early Successes) of a Town Initiated Access Management "Retrofit" Program on Two State Highways" - SUNY- ESF, Syracuse, New York., 1996; "Site Plan Analysis and Review" r- American Planning Association, Buffalo, NY; 1995 - Instititue of Transportation Engineers Upstate Meeting, Rochester, NY, 1995 "Access Management- No More Business As Usual", - New York State Association of Towns Annual Meeting, 1995; - New York State Planning Federation Annual Meeting, 1995; PROFESSIONAL . _ ' ;,BACKGROUND - :EDUCATION, ' ♦ A:A.S:-.Civil Engineering Technology, Mohawk--Valley- Community College,-1978 - YEARS OF EXPERIENCE AFFILIATIONS j Institute of Tra_nsportatiop En-, giiieers:. New York' State-Associatio_n of ,Transportation.Erigineers - Professional Services - Management Association. _ Mr. DiCesare has over twenty years of traffic analysis and design experience, including analysis of traffic flow, urban highway corridors, preparation of isolated and intercon- nected traffic signal timing plans, collection of assorted traffic data, signing design, sig- nal modifications/design, design of geometric improvements and preparation of related Design, Impact and Justification Reports. Representative projects include: SOUTHWEST AREA LAND USE STUDY, ITHACA, N.Y. Project Manager for a traffic study to assess the traffic/transportation issues of a Generic Environmental Impact Statement. The study establishes the existing conditions on -site and adjacent to a vacant land parcel in the City of Ithaca. Various land use scenarios, ranging in size from 500,000 s.f. to 1.2 million s.f were investigated as viable alternatives. The intent is to identify the best combination of land use on -site, and the phased improvements required to mitigate impact to the surrounding transportation network. Comprehensive traffic models were established and super imposed on a G.I.S. background utilizing SYNCHRO traffic soft- ware. The existing and future alternative models assess the vehicular operating conditions at 27 separate intersections throughout the City, and incorporate 4 new access points to the infrastructure surrounding the site. NORTH CAMPUS RESIDENTIAL INITIATIVE, CORNELL UNIVERSITY, CORNELL, N.Y.: Project Manager for a traffic study to support the transportation is- sues related to site modifications on Cornell=s Campus. The plan includes the construc- tion of new residence halls, a central dining facility, and relocated athletic fields to be situated around a central Quad Area adjacent to the dining facility. The study involves the investigation of the transportation network in and around the site, including 12 inter- sections and 6 centers of major pedestrian activity. Existing vehicular and pedestrian traf- fic flow was established and future conditions projected to assess safety, operational and capacity impact. Mitigation requirements were recommended to offset the impact attrib- uted to the proposal. Two final products were produced; a Traffic Impact Study to be in- cluded as a technical appendix of the DEIS/FEIS, and a separate Technical Traffic Memo addressing safety and review of the overall site plan. CRC TRANSLOAD FACILITY, CALEDONIA, N.Y.: Project Manager responsible for the assessment of potential traffic impacts incurred by a Transportation/Loading Cen- ter, collectively serviced by rail and long range interstate semi -tractor trailers. The center is targeted to receive and distribute bulk grain and fertilizer commodities. The site con- tained a 4,400 s.f. office with truck scales, a 21,000 s.f. staging and loading/unloading area, a 54,000 s.f feed containment area, and a 39,000 s.f. fertilizer containment area. An internal circulation roadway system was designed to service each of the areas, and accom- modate the proposed design vehicle (WB-67). PETRO STOPPING CENTER, FARMINGTON, N.Y.: Project Manager responsible for the assessment of traffic impacts and infrastructure improvements required for a re- gional trucking facility situated on a 22 acre parcel. The facility will provide regional service to long distance freight hauling and includes a 35,000 s.f. multi -purpose building, 8 bay gasoline fueling area for cars, 10 bay diesel fueling area for trucks, and 12,500 s.f. truck service area. Prepared a Site Impact Traffic Evaluation that addressed the antici- pated traffic impacts at adjacent intersections and provided design recommendations for required geometric improvements (auxiliary lanes) and isolated traffic signal modifica- tions. RETAIL DEVELOPMENT, ERWIN, N.Y.: Project Manager for the traffic and transportation issues related to a multi- use site, situated on a 32 acre parcel. The mixed retail use totals 345,000 st and consists of a 155,000 st free standing discount super -store (Wahnart), a 160,000 s.f home improvement store, a 25,000 st office supply store, and a 5,000 s.f. restaurant. Prepared a Site Impact Traffic Evaluation that addressed the anticipated traffic impacts at four isolated inter- sections, as well as ramp surface terminals in the immediate vicinity of the project. Two Addenda were produced to deal with unique features of the local network, and addressed specific issues related to queuing, merging and weaving. The fi- nal document included an implementation plan designed to provide corridor wide mitigation, and user benefits equal to the projected economic impact. Also responsible for an isolated traffic signal design at the main access point to the site, modi- fications to an adjacent traffic signal, and interconnection and progression of the signals using time base coordination. SOUTHEAST LOOP GARAGE — PHASE II, ROCHESTER, N.Y.: Project Manager responsible for identifying the collective net traffic impacts of the implementation of the second phase of a parking garage structure. The study assessed the existing operation of a 1,000 vehicle, multi -level structure and adjoining 150 vehicle surface lot. The proposed struc- tural footprint would replace the surface lot with a new structure immediately adjacent to the existing garage -structure, and combine both to provide one contiguous structure operating as one garage with a combined capacity of 2,000 vehicles. The traffic impact report included isolated analyses at 9 intersections and 4 garage access points. Since the garage pro- vided access points leading to/from area expressways, extensive weave/merge and queue analyses were conducted, and SYNCHRO simulation models were created to visually simulate operations and effects on expressway components. WEBSTER CENTRAL SCHOOLS, WEBSTER, N.Y.: Project Manger for a traffic evaluation and study, included as a Technical Appendix to an Environmental Impact Statement. The impact study assessed the effects of construction of a new Middle School, and retention of the current R.L. Thomas School west of the site as an additional High School. Exist- ing and projected operating conditions at 11 intersections within the surrounding highway grid were evaluated to assess the impacts of traffic newly created and diverted from existing facilities within the district. An Addendum was prepared which assessed and addressed the isolated benefits/impacts of relocating the School District Transportation Department (bus terminal) to an alternative site. RETAIL DEVELOPMENT, ROCHESTER, N.Y.: Project Manager responsible for identifying the collective net traffic impacts of an overall retrofit of the existing Westgate shopping plaza site. The project involved the redevelopment of the existing retail area by razing portions of the site and constructing a new 5,000 s.f. high turn -over restaurant, a 59,000 s.f. specialty retail center, a 9,000 s.f. drugstore, and a 203,700 s.f. Wahnart Super -center. The resulting traffic impact report assessed future operations and required improvements on the surrounding infrastructure, a new traffic signal installation, and interconnection within a progressed traffic signal system. MORMON TEMPLE, MANCHESTER/PALMYRA, N.Y.: Project Manager responsible for two traffic studies related to the construction of a 10,300 s.f. regional Temple situated on an eight acre site. The first study assessed the traffic im- pact of the new facility on area roadways surrounding the site. The second study assessed the net traffic impacts of provid- ing direct access to a newly constructed road, which would connect two north/south routes bordering the site. Both studies collectively identified site generated traffic, network traffic diversions, sight distance and safety evaluations at the critical interface points of the connector road with the existing north/south routes, auxiliary turn lane warrant investigations, and provided recommendations for network mitigation. JOSEPH C. WILSON CENTER FOR TECHNOLOGY, WEBSTER, N.Y.: Prepared traffic report as part of a Ge- neric Impact Study which addressed possible development scenarios that could be integrated within the existing facility. The affected network included 10 intersections along Phillips Road, Salt Road, Route 404 and ramp surface terminals to Route 104. Existing traffic operations on the highway system were investigated to assess current capacity levels and to ' identify deficiencies related to capacity or safety. Initial and full build -out alternatives were offered and traffic was gener- ated for each scenario. The related traffic operation for each alternative was investigated, systemic deficiencies identified, and mitigation recommended. AMES MOORINGS; CONESUS, N.Y.: Project Engineer responsible for a traffic study which identified the impacts of a residential development on the adjacent highway system. Recommended mitigation for site access and capacity con- cems. Also participated in a Department of Environmental Conservation Judicatory proceeding and gave expert testimony in defense of the project based on the findings of the report. ROUTE 17 SHOPPING CENTER, VESTAL, N.Y.: Traffic Engineer responsible for two separate reports for a new ' 225,000 s.f. shopping center to be located on a 105 acre site off Route 17. The first report specifically addressed the in- terconnection of traffic signals at each access and their operation through coordinated signal phasing plans. As Project Engineer, responsibilities for the second report (an interchange justification report) included all transportation traffic as- C pects as well as an extensive economic analysis identifying present and future cost/benefit values and ratios. DEPAUL MENTAL HEALTH FACILITY, GATES, NEW YORK.: Traffic Engineer responsible for a traffic study for a facility which combined administrative offices and recreational and day treatment facilities. The study evaluated ex- isting conditions, projected traffic operations along the immediate highway network, established site traffic and flow, and investigated site access. The results were provided in a traffic impact report that provided recommendations for facility access and network improvements. CENTER PLACE DEVELOPMENT, ROCHESTER, N.Y.: Traffic Engineer responsible for trip generation analysis and intersection capacity analysis. Prepared traffic report analyzing existing traffic and projected the impact of future site developed traffic. Prepared a supplemental report to study the progression of six adjacent interconnected signalized inter- sections to select an optimum cycle length and corridor phasing plan. I ROSEPARK DEVELOPMENT OFF -SITE HIGHWAY IMPROVEMENTS, CANANDAIGUA, N.Y.: Project ' Manager for the design of two intersection improvements, two new access road intersections, mainline roadway improve- ments, a new fully traffic actuated signal system and related interconnection and coordination with two adjacent traffic sig- nals. ' PROFESSIONAL DEVELOPMENT Harmonizing Transportation and Community Goals; ITE Conference, California (1998) Project Management; ACEC Continuing Education, California (1997) Advanced TEAPAC Application Techniques; University of Wisconsin (1996) Timing Traffic Signals / PASSER, TRANSYT, NETSIM; University of Wisconsin (1995) 1994 Highway Capacity Manual - Interrupted Flow Procedures; FHWA (1995) Managerial Skills For Transportation Engineers; Northwestern University (1994) ' Modeling of Mobile Source Air Quality; University of Central Florida (1994) Traffic Signal Timing; University of Central Florida (1992) Highway Capacity Workshop; The Traffic Institute, Northwestern University (1985) Using The ITE Trip Generation Report; Institute of Transportation Engineers (1985) Capacity Analysis Workshop; The Traffic Institute, Northwestern University (1982) Effective Traffic Signal Performance; University of Wisconsin (1982) r- PROFESSIONAL L, BACKGROUND EDUCATION 4 Syracuse"University,-B.S., Civil Engineering; 1994= DYEARS OF EXPERIENCE : 5 : REGISTRATION :AFFILIATIONS ' Institute of Transportation En- gineers ♦ American. Society of Civil En- gmeers Ms. Dake has five years of traffic analysis and design experience including determination of transportation impacts and required mitigating measures for the sponsoring organiza- tion or the reviewing governmental agency. Proposals analyzed include: retail, commer- cial, residential, industrial, medical, educational, and recreational forms of site develop- ment of various sizes. This work has included the assessment of existing and proposed traffic conditions, ingress/egress location and design, traffic circulation and parking de- sign, and the determination of site and roadway capacities. Other responsibilities have included organization and supervision of the accumulation of engineering field data; analysis and evaluation of highway conditions including Level of Service analyses and other operational characteristics, volumes, speeds, geometric features, and safety; and analysis and simulation of traffic movement and flow using various software programs including Synchro, Sim Traffic, Traf-Netsim and the Highway Capacity Software (HCS). FOREST GLEN SUBDIVISION, GREECE, NY: Prepared traffic impact study re- lated to a residential subdivision in Greece, NY. The related responsibilities included analysis of existing and projected traffic conditions and preparation of a report address- ing the impacts and any recommended mitigation measures. MARSHALL STREET, SYRACUSE, NY: Prepared traffic impact study related to reversal of a one-way street in the University Hill area of Syracuse, NY. The related responsibilities included organization of collection of data, analysis of existing and pro- jected traffic conditions, and preparation of a technical letter addressing the impacts and any recommended mitigation measures. PHELPS/CLIFTON SPRINGS CENTRAL SCHOOL DISTRICT, PHELPS, NY: Worked on a team preparing a traffic impact study related to consolidation and reloca- tion of grades Pre-K through 5 in Phelps, NY. The related responsibilities included collection of data and preparation of a report addressing the impacts and any recom- mended mitigation measures. DELTA SONIC CAR WASH, PENFIELD, NY: Prepared traffic impact study re- lated to a large car -wash facility with a convenience store and gasoline sales in Pen- field, NY. The related responsibilities included analysis of existing and projected traffic conditions and preparation of a report addressing the impacts and any recommended mitigation measures. SPENCER STREET STUDY, ITHACA, NY: Prepared traffic impact study related to reconfiguration of an existing intersection and rerouting of traffic due to change in directionality of one-way/two-way roadways in Ithaca, NY. The related responsibilities included identification of the anticipated impacts to the roadway system surrounding the intersection, analysis of changes in traffic volumes and preparation of a report address- ing the impacts and any recommended mitigation measures including traffic calming options. ITHACA SOUTHWEST AREA GEIS, ITHACA, NY: Worked on a team preparing a generic traffic impact study related to a large scale, mixed use development in Ithaca, NY. The related responsibilities included analysis of data, identification of the antici- pated impacts to the roadway network throughout the City of Ithaca, determination of appropriate mitigation measures and preparation of a report addressing the impacts and any recommended mitigation measures. [J MONROE-WAYNE INDUSTRIAL PARK, MACEDON, NY: Prepared traffic impact study related to expansion of an existing industrial park in Macedon, NY. The related responsibilities included analysis of existing and projected traffic conditions and preparation of a report addressing the impacts and any recommended mitigation measures. SOUTHEAST LOOP GARAGE PHASE II, ROCHESTER, NY: Worked on a team preparing a traffic impact study related to expansion of a downtown parking garage in Rochester, NY. The related responsibilities included organization of collection of data, analysis of existing data, projection of future trip generation based on existing data, identification of the anticipated impacts to the roadway network adjacent to the project site including weaving areas and expressway ramps, determination of appropriate mitigation measures and preparation of a report addressing the impacts and any rec- ommended mitigation measures. WALMART, CENTRAL SQUARE, NY: Prepared traffic impact study related to a retail development in Central Square, NY. The related responsibilities included supervision of collection of data, identification of the anticipated im- pacts to the roadway system surrounding the site and preparation of a report addressing the impacts and any recom- mended mitigation measures. WALMART/WESTGATE PLAZA, GATES, NY: Prepared traffic impact study related to an extensive revitalization of a retail development and relocation of an existing town park in Gates, NY. The related responsibilities included super- vision of collection of data, identification of the anticipated impacts to the roadway system surrounding the site and preparation of a report addressing the impacts and any recommended mitigation measures. WALMART, HALFMOON, NY: Prepared traffic impact study related to a retail development in Halfinoon, NY. The related responsibilities included supervision of collection of data, identification of the anticipated impacts to the roadway system surrounding the site and preparation of a report addressing the impacts and any recommended mitigation meas- ures. l CALKINS ROAD BUSINESS PARK DEVELOPMENT PROJECT, HENRIETTA, NY: Prepared traffic impact study related to a large scale, mixed use light industrial/office park development in Henrietta, NY. The related responsi- bilities included collection of data, identification of the anticipated impacts to the roadway system surrounding the site LJand preparation of a report addressing the impacts and any recommended mitigation measures. KONAR INDUSTRIAL PARK DEVELOPMENT PROJECT, HENRIETTA, NY: Prepared traffic impact study F: related to a large scale, mixed use industrial/office park development in Henrietta, NY. The related responsibilities in- cluded collection of data, identification of the anticipated impacts to the roadway system surrounding the site and prepa- ration of a report addressing the impacts and recommended mitigation measures. WALMART, POTSDAM, NY: Prepared traffic impact study related to a retail development in Potsdam, NY. The re- lated responsibilities included preparation of a report addressing the impacts and any recommended mitigation measures. ' WEBSTER SCHOOL DISTRICT, WEBSTER, NY: Prepared traffic impact study related to the installation of a new driveway providing access to Schroeder High School along Shoecraft Road in Webster, NY. The related responsibilities included collection of data, identification of the anticipated impacts to the roadway system surrounding the site and preparation of a report addressing the impacts and any recommended mitigation measures. A driveway design was also ' prepared. PROFESSIONAL- _ Mr. Greene has over 4 years of experience in traffic impact analysis an design experi- BACKGROUND ence, including analysis of traj�c flow, on -site /internal circulation patterns, accident investigations, collection of traffic data, which includes turning movement counts, delay, EDUCATION gap, speed and conflict studies, intersection geometric design, and traffic signal design. Rochester Institute ;of Technol- Knowledgeable with a wide variety of software packages, such as Highway Capacity Fogy, B.S. Civil Engineering, Software (HCS), AutoCad, Synchro, Sim Traffic, Arcview GIS, and Microsoft Products 1996 _. used for design and analysis purposes. ;.'SUNY College of Technology at Alfred; A.A.S. Architectural RENO WAREHOUSES, FARMINGTON, N.Y.: Traffic Engineer responsible for the -Engineering Technology,.-1993 preparation of a Traffic Impact Analysis for a 70f acre "Build New York" site in the Town of Hopewell, New York. The project was divided into two different sites, with five YEARS OF EXPERIENCE different proposed access points on two county and one state owned roadway. The first site contains a 215,000 square foot warehousing facility, and the second, and larger of the two sites, contained a combined 750,000 square foot warehousing and 10,000 square foot REGISTRATION office type facility. Careful design consideration was given to the proposed recommenda- = tions due to the operating speeds of each roadway, sight distances, and WB-62 design ve- ♦. „ E.LT: _ . - hicle that would utilizing the facility. AFFILIATIONS of Transportation GREECE CENTRAL SCHOOL DISTRICT, TOWN OF GREECE, N.Y.: Traffic ,Institute . Engineer responsible for the data collection of turning movements, on -site circulation, Engineers pedestrian safety, and analysis of existing operations for three major public high/middle schools within the school district. Each location / campus was unique in internal site characteristics and existing operational deficiencies. The successful completion of the project involved completion of written recommendations and concept plans for each loca- tion. CRYSTAL. RIDGE PLANNED UNIT DEVELOPMENT, SWEDEN, N.Y.: Traffic Engineer responsible for the preparation of a Traffic Impact Analysis for a 295 acre de- velopment consisting of apartments, single family residential, and townhouse units. The proposed development was analyzed at two separate phases of completion, and signal and left turn lane warrants were investigated. Overall, the project included analysis of eight intersections within the project vicinity, field observations, correspondence with local consultants, NYSDOT and MCDOT officials, and Town of Sweden officials. ROCHESTER HOUSING AUTHORITY, CENTRAL MAINTENANCE FACIL- ITY, ROCHESTER, N.Y.: Traffic Engineer responsible for the preparation of a traffic assessment for the proposed Central Maintenance Facility expansion. The project in- cluded gathering existing turning movement volumes, two-way gap data, and analysis of existing, background, and future conditions within the central business district surround- ing the facility. } ALDI STORE, LYONS N.Y.: Traffic Engineer responsible for the preparation of a Traffic Impact Study Analysis update for the project located on NYS Route 31. The proj- _ ect included turning movement count volume collection, conflict analysis study for west- bound vehicles turning left into the site driveway, accident information review and calcu- lation, and left turn lane warrant analysis. Preparation of study involved communications - with NYSDOT, site design engineers, and Town of Lyons officials. HOLT RIDGE CENTER, WEBSTER, N.Y.: Traffic Engineer responsible for the preparation of a Site Impact Traffic Evaluation for a 784,000 square foot multi -use development, situated on 92.4 acres. The development was comprised of retail, residential, and office type uses. This project was unique in that an internal capture rate was applied to the trip gen- eration calculations due to the proposed land uses and site layout. The study involved data collection, observation, analysis, and improvement recommendations for seven intersections under the jurisdiction of MCDOT and NYSDOT. IMMEDIATE CARE CENTER, GENESEO, N.Y.: Traffic Engineer responsible for preparation of a Traffic Impact Analysis for the project located on NYS Route 20A. Duties included data collection, field delay studies, on -site observa- tion, analysis of existing, background, and future conditions, and recommendations for intersection modifications to im- prove operations. Other aspects of the project included studying local, similar type facilities for trip generation purposes, and a signal warrant investigation was completed as part of this project. MILLER ESTATES MOBILE HOME PARK, ARCADIA, N.Y.: Traffic Engineer responsible for preparation of a Traffic Impact Study. The 99-lot mobile home park project involved data collection, site visits, sight distance evaluations, and analysis of existing, background, and future operating conditions. The project also included recommendations and co- ordination with the site engineer to improve and provide safe access onto the roadways. ONTARIO COUNTY CORRECTIONS FACILITY, TOWN OF HOPEWELL,N.Y.: Prepared a Traffic Impact Analysis that entailed analyzing four different scenarios. The first scenario involved a possible 300 and additional 200 bed facility on an existing county owned site, and the second involved a 300 and additional 200 bed facility at a different loca- tion within the Town of Hopewell. Ontario county officials and the project engineers were involved to generate trip distri- bution. and generation information. Responsibilities also included presentation of findings before the public and the Correc- tions Facility Board members. WILSON FARMS CONVENIENCE MARKET, IRONDEQUOIT, NY: Traffic Engineer responsible for the prepara- tion of a Traffic Impact Study for a 2,800 s.f. convenience market which included four vehicle fueling positions. The proj- ect entailed data collection, delay and license plate studies, analysis of existing, background, and future conditions. The future conditions were also analyzed with proposed nearby expressway ramps in place. KONAR INDUSTRIAL PARK, ROCHESTER, N.Y.: — Traffic Engineer responsible for the design of two traffic signals and preparation of a pavement marking and signage plan for Thruway Park Drive. Both new signals are under the jurisdic- tion of NYSDOT. One is located on NYS Route 253, Erie Station Road, and Route 15 West Henrietta Road for the Indus- ' 1 trial subdivision which included realignment of Erie Station Road with Thruway Park Drive. ATLANTIC/WHALEN/SCRIBNER SIGNAL, PENFIELD, N.Y.: —Traffic Engineer responsible for design and plan j preparation for removal of the existing signal and design of a new signal. The signal design was a part of the overall inter- section improvement project on NYS Route 286. Duties also included recommendations for the Project Engineer regarding lane storage and taper lengths for optimal intersection operation. [� OLYMPIA SCHOOL, SIGNAL DESIGN, GREECE, N.Y: Project Engineer responsible for the design and plan prepa- ration of a two-phase actuated signal for the new school driveway entrance. The project also involved meeting with MCDOT officials to review signal design and to optimize intersection geometry. BAILEY ROAD, HENRIETTA, N.Y: Traffic Engineer/Engineering Technician responsible for data collection and analysis of existing, background, and future operating conditions for a 2.2 mile stretch of road under the jurisdiction of (� MCDOT. Duties also included evaluation and preparation of a detailed accident history analysis. s Charles Moynihan (Region 4) Regional Director New York State Department of Transportation 1530 Jefferson Avenue Rochester, New York 14623 Larry Sherman Regional Traffic Engineer (Region 4) New York State Department of Transportation 1530 Jefferson Avenue Rochester, New York 14623 i Richard Twardokus (Region 4) Assistant Regional Design Engineer ' New York State Department of Transportation =` 1530 Jefferson Avenue Rochester, New York 14623 ' Gary Funk (Region 6) Regional Traffic Engineer New York State Department of Transportation 107 Broadway Hornell, New York 14843 Barry Stevens Regional Traffic Engineer (Region 3) New York State Department of Transportation 333 E. Washington Street Syracuse, New York 13202 Brad Oswald ? Planning Bureau (Main Office) New York State Department of Transportation 1220 Washington Avenue Albany, New York 12232 Frank L. Dolan t Director of Transportation Monroe County Department of Transportation City Place, 6th Floor 50 West Main Street Rochester, NY 14614 - n George Stam City of Rochester Engineer City Hall, Department of Environmental Services 30 Church Street Rochester, New York 14614 Bill Grey Director of Public Works City of Ithaca, Department of Public Works 108 E. Green Street Ithaca, New York 14850 H. Matthys VanCort Planning Department Director City of Ithaca 108 E. Green Street Ithaca, New York 14850 Don Robinson Vice President Benderson Development 570 Delaware Avenue Buffalo, New York 14202 Ted Spall President Spall Homes Corporation 30 Grove Street Pittsford, New York 14534 William Wendt Director of Transportation Cornell University 116 Maple Avenue Ithaca, New York 14580 Steve Gleason Director Genesee Transportation Council 65 West Broad Street Rochester, New York 14614 1 1 EXPERIENCE Systems Simulation, Analysis & Development: Responsible for the systems research and development of software products with emphasis on traffic and transportation engineering and planning computer software. Original author of the TMODEL Transportation Modeling System. Project leader and programmer for TMODEL, NCAP Intersection Capacity Analysis Package, TGAP Traffic Gap Analysis Package, and LPlate License Plats Matching program, computer simulation of mobile source emissions for Western Oregon, and others. Transportation Modeling: Primarily responsible for or assisted with the development and applications of ,models for Anacortes, Arlington, Auburn, Black Diamond, Blaine, C1eElum, Ephrata, Everett, Issaquah, Kent, Marysville, Richland, Sedro-Woolley, Shelton, Skagit County, Smokey Point, Snoqualmie Pass, Spokane, Whatcom County, Wenatchee Area Transportation Study, Yakima, and Yakima County, Washington; BART, Cambria, Chico, Goleta, Orcutt, Oroville, Paradise, Paso Robles, San Luis Obispo, Santa Maria, and Shafter, California; Beaverton, Portland, Washington County and Wilsonville, Oregon; Ketchikan, Alaska; Alamogordo, Gallup, Hobbs, Roswell, Santa Fe, Silver City, and Taos, New Mexico; DuPage County, Gurnee, Hoffman Estates, Naperville, Park Ridge, and Rockford, Illinois, Ciudad Guayana, Venezuela. Assisted with many other models through providing support services. ' Transportation Planning: Project manager of Transportation Modeling effort for rapidly growing suburban Washington County, Oregon. Directed technical personnel in computer analysis of county transportation system for preparation of Comprehensive Plan Transportation Element. Developed transportation/urban redevelopment plans for Sherwood, Oregon City, and Gladstone, Oregon. Provided transportation planing guidance for models listed above. Traffic Engineering: Responsible for design, installation, and maintenance of traffic control devices as acting Traffic Engineer for Washington County, OR. Developed Roadway and Traffic Safety ' Management Plans for Coos Bay, Milwaukie, Beaverton, Washington County and Coos County, Oregon. Designed traffic signals, Impact Studies: Responsible for review of traffic impact statements and development of impact assessment fee structure. Developed traffic impact review requirements for Washington County, Oregon. Conducted impact studies for Office, Commercial, Light Industrial, Residential, and ' Retirement Community developments in Oregon and Washington. Traffic Studies: Traffic studies include spot speed, speed and delay, license plate, origin and destination, sign inventories, capacity analyses ' and parking duration and supply. Teaching: Developed and instructed TMODEL2 transportation modeling training workshops in New York, Washington, Illinois, New Mexico, California, Oregon, New Hampshire, British Columbia, Saskatchewan, ' South Dakota, Maryland, New South Wales, and Venezuela. Guest Lecturer at the Northwestern University Traffic Institute, and the University of Washington Transportation Center. Robert M. Shull President PROFESSIONAL POSITIONS TModel Corporation 1991 - Metro Transportation Group, Inc. Professional Solutions Division Vice President 1988 - 1991 Professional Solutions, Inc. President and Founder 1982 - 1988 Washington County (Oregon) Department of Public Works Senior Traffic Analyst, Traffic Engineer 1979 - 1982 Transportation Planning and Management, Inc. Project Engineer 1977 - 1979 Oregon State University Research Assistant, Teaching Assistant 1973 - 1977 EDUCATION Oregon State University Corvallis, Oregon Bachelor of Science in Civil Engineering Oregon State University Corvallis, Oregon Graduate Study in Transportation Engineering LICENSES Registered Professional Engineer, Oregon AFFILIATIONS Institute of Transportation Engineers Transportation Research Board Association of Pedestrian & Bicycle Professionals American Planning Association Ithaca Area Wastewater Improvement Project EIS Proposal APPENDIX C CITY/SCAPE QUALIFICATIONS 1 CITY / SCAPE: Cultural Resource Consultants 726 Carroll Street Brooklyn, NY 11215 (718) 965-3860 Fax: (718) 788-4024 CITY/SCAPE was founded to provide a variety of services to organizations requiring cultural and environmental analyses, open space planning, preservation surveys of historic sites, including landscapes and architectural elements, lectures, tinterpretive programs and exhibitions. Current contracts include environmental impact analyses, cultural resource studies ' (Stage IA and IB), Stage 2 archaeological investigations, mitigation programs, and archaeological research for a number of projects currently underway in eastern New York State, including New York City, Long Island and the Hudson Valley. A partial list of current projects is'attached. The principals of CITY/SCAPE also teach, lecture and guide tours of historic and archaeological sites in North America and South America. CITY/SCAPE works regularly with the New York City Landmarks Preservation i Commission and the New York State Office of Parks, Recreation and Historic Preservation. CITY/SCAPE is listed with the Society of Professional Archaeologists (SOPA/ROPA). CITY/SCAPE has been certified by the State of New York as a Woman Owned Business. 1 1 CITY / SCAPE: Cultural Resource Consultants 726 Carroll Street Brooklyn, NY 11215 (718) 965-3860 Fax: (718) 788-4024 PARTIAL LIST OF PROJECTS 2000 Stage lA Literature Review and Sensitivity Assessment and Stage 1B Archaeological Field Reconnaissance Survey for Frank Farms Subdivision. Town of LaGrange. Dutchess County, New York. 2000 Stage I Literature Review and Sensitivity Assessment for the Concord Convention Center. Town of Thompson. Sullivan County, New York. ' 2000 Stage I Literature Review and Sensitivity Assessment for Hunter Highlands. Town of Hunter. Greene County, New York. 2000 Stage 1B Archaeological Field Reconnaissance Survey for Block 2317. Williamsburg. Borough of Brooklyn. Kings County, New York. 2000 Stage 1B Archaeological Field Reconnaissance Survey for the Graham -Brush House. Village of Pine Plains. Dutchess County, New York. 2000 Stage IA Literature Review and Sensitivity Assessment and Stage 1B Archaeological Field Reconnaissance Survey for Stone Barns. Town of Mount Pleasant. Westchester County, New York. 2000 Stage 1B Archaeological Field Reconnaissance Survey for County House Road LLC. Village of Tarrytown. Westchester County, New York. 1999 Stage lA & Stage 1B Letter Report for Project in Canton, New York. Saint Lawrence County, New York. 1999 Stage I Cultural Resource Report for County House Road LLC. Village of ' Tarrytown. Westchester County, New York. 1999 Stage I & Stage 1B Cultural Resource Report for Veterans Field Site. City of Glens Falls & Town of Queensbury. Warren County, New York. 1999 Stage 1 A Cultural Resource Report for County House Road LLC. Village of ' Sleepy Hollow. Westchester County, New York. 1999 Stage lA & Stage 1B Cultural Resource Report for Laurel Links Residential Development and Golf Course. Town of Southold. Suffolk County, New York. 1999 Stage I Literature Review and Assessment of Archaeological Potential for Block 2260 (760-768 Kent Avenue). Borough of Brooklyn. Kings County, New York. CITY/SCAPE: Cultural Resource Consultants Partial List of Proiects 1 1999 Stage IA Literature Review and Assessment of Archaeological Potential for Supersonic Aviation. Brooklyn Navy Yard. Borough of Brooklyn. Kings County, New York. 1999 Stage IA Literature Review & Stage 113 Archaeological Field Investigation of 45/49, 53. 57 & 59 Taaffe Place and 796 Kent Avenue (Block 1883). Borough of Brooklyn. Kings County, New York. 1999 Stage 1B Archaeological Field Investigation for KF Rye Brook Site (formerly Summerfield Suites). Village of Rye Brook. Westchester County, New York. 1999 Stage IA Literature Review and Stage 1B Archaeological Field Investigation for Hunterbrook Ridge. Town of Yorktown. Westchester County, New York. 1999 Stage IA Literature Review and Stage 1B Archaeological Field Investigation for Beacon City School District. City of Beacon. Dutchess County, New York. 1999 Analysis of Impact of Proposed Assisted Living Facility on National Register Historic Landscape located on Academy Street in City of Poughkeepsie. Dutchess County, New York. 1999 Stage IA Literature Review and Stage 1B Archaeological Field Investigation for Ardsley Senior Citizen Development Site. Village of Ardsley. Westchester County, New York. 1999 Stage I Literature Review for New York Medical College. Grasslands. Town of Mount Pleasant. Westchester County, New York. 1998 Stage I Cultural Resource Report and Stage I Archaeological Field Reconnaissance Survey for Friar's Head Farm. Town of Riverhead. Suffolk County, New York. 1998 Analysis of Impact of RiteAid Drug Store on Hooker Avenue. City of Poughkeepsie. Dutchess County, New York. 1998 Stage IA Cultural Resource Report for Spanish Camp. Borough of Staten Island. Richmond County, New York. 1998 Stage IA Cultural Resource Report for Block 1881 and 1883. Borough of Brooklyn. Kings County, New York. 1998 Stage IA Cultural Resource Report for Stone Hill Estates. Town of Harrison. Westchester County, New York. 1998 Stage I Cultural Resource Report for Summerfield Suites. Town of Harrison. Westchester County, New York. 1998 Stage I Cultural Resource Report for Kings College. Village of Briarcliff Manor. Westchester County, New York. 1998 Stage IA Cultural Resource Report and Stage 1B Archaeological Field Reconnaissance Survey for Kendal -on -Hudson. Village of Sleepy Hollow. Town of Mount Pleasant. Westchester County, New York. CITY/SCAPE: Cultural Resource Consultants Partial List of Proiects 3 1998 Archaeological Assessment for The Meadows -Stephens Green. Town of Somers. Westchester County, New York. 1998 Archaeological Assessment and Field Investigation for Springside. City of Poughkeepsie. Dutchess County, New York. 1998 Preparation of Historic Designation Report for Bonbright Bathhouse and Boathouse. Fisher's Island. Suffolk County, New York. 1997 Stage IA Cultural Resource Report. Block 3132.. Borough of Brooklyn. Kings County, NY. 1997 Stage I Cultural Resource Report. SAP America, Inc. Newtown Square. Newtown Township. Delaware County, Pennsylvania. 1997 Stage 1A and 1B Cultural Resource Report. Block 3070. Williamsburgh. Borough of Brooklyn. Kings County, NY. 1997 Stage IA and 1B Cultural Resource Report. Village of Goshen. Orange County, NY. 1997 Assessment of Impacts of Tower Construction on Historic Resources. Vail's Gate. Orange County, NY. 1997 Stage 1B Archaeological Investigation. Block 405. Borough of Manhattan. New York County, NY. 1997 Stage IA Cultural Resource Report. Block 3330. Borough of Brooklyn. Kings County, NY. 1996 Stage 1B Archaeological Investigation. Block 3995. East New York Youth Corp. Borough of Brooklyn. Kings County, NY. 1996 Stage 1A and 1B Cultural Resource Report. Harrison Temple Project. Town of Harrison. Westchester County, NY. 1996 Stage 2 Archaeological Investigation. Hess MiniMart. Town of Fishkill. Dutchess County, NY. 1996 Stage 1B Archaeological Investigation. The Meadows -Stephens Green. Town of Somers.` Westchester County, NY. 1996 Stage IA and 1B Cultural Resource Report. Hess MiniMart. Town of Fishkill. Dutchess County, NY. 1996 Stage 2 Archaeological Investigation. Chiselhurst Estates. Town of New Castle. Westchester County, NY. 1996 Stage I Literature Review and Archaeological Sensitivity Evaluation. Brooklyn Hospital. Borough of Brooklyn. Kings County, NY. 1996 Stage I Literature Review. Chiselhurst Estates. Town of New Castle. Westchester County, NY. CITY/SCAPE: Cultural Resource Consultants Partial List of Proiects 4 i 1995 Stage IA Literature Review and Stage 1B Archaeological Investigation. Vineyard Estates. Town of Lloyd. Ulster County, NY. 1995 Environmental Review of Proposed Project. Pugsley Hill Road. Town of Stanford. Dutchess County, NY. 1995 Stage IA Cultural Resource Report. White's Corners. Town of Wappingers. Dutchess County, NY. 1995 Stage IA Literature Review. Block 405. Lot 1. Borough of Manhattan. New York County, NY. 1995 Stage IA Literature Review. 140 Johnson Street. Williamsburgh. Borough of Brooklyn, Kings County, NY. 1995 Stage IA -Literature Review. 341- Hendrix Street. East New York. Borough of Brooklyn, Kings County, NY. 1995 Stage IA Literature Review. Bedford-Stuyvesant Health Center. Borough of Brooklyn, Kings County, NY. 1995 Stage IA Literature Review. Block 2208. Lot 2 & 16. Williamsburgh. Borough of Brooklyn, Kings County, NY. 1995 Stage 2 Investigation of Historic Site. Ferrovecchio Subdivision. Town of New Castle. Westchester County, NY. 1995 Stage 1B Archaeological Investigation. 278 Edgegrove Avenue. Staten Island. Richmond County, NY. 1995 Stage 1B Archaeological Investigation. 180 Edgegrove Avenue. Staten Island. Richmond County, NY. 1995 Stage 1B Archaeological Investigation. 517 Sheldon Avenue. Staten Island. Richmond County, NY. 1995 Stage 1B Archaeological Investigation. 94 Finlay Street. Staten Island. Richmond County, NY. 1995 Stage 113 Archaeological Investigation. 278 Edgegrove Avenue. Staten Island. Richmond County, NY. 1995 Stage 1 A Cultural Resource Report. MidHudson Business Park. Poughkeepsie. Dutchess County, NY. 1995 Stage 1 A Cultural Resource Report. Kastel Property. Town of Yonkers & Town of Mamaroneck. Westchester County, NY. 1995 Stage I and Stage 1B Archaeological Investigation. Cerf Estates at Chappaqua. Westchester County, NY. Additional information on specific projects and projects prior to 1995 will be provided upon request. CITY/SCAPE: Cultural Resource Consultants 1 CITY / SCAPE: Cultural Resource Consultants 726 Carroll Street Brooklyn, NY 11215 (718) 965-3860 Fax: (718) 788-4024 GAIL TRAVIS GUILLET EXPERIENCE Jan. 1982 CITY/SCAPE: Cultural Resource Consultants to present 726 Carroll Street, Brooklyn, NY 11215 Principal of CITY/SCAPE, a firm that provides a variety of services to organizations requiring cultural and environmental analyses, open space planning, preservation surveys of historic sites, including landscapes and architectural elements, lectures, interpretive programs and exhibitions. Sept. 1978- Director, Olmsted Project Dec. 1981 NYC Landmarks Preservation Commission �i Director of Olmsted Project -- exhibition "Art of the Olmsted Landscape," premiered at The Metropolitan Museum of Art, Fall 1981. EDUCATION Graduate Center. City University. New York, NY. Course work towards M.A. Anthropology begun in 1995. Columbia University, Graduate School of Architecture and Planning, NY. M.S. Arch. Historic Preservation. (Thesis completion pending). New York University, New York, NY. 1968-70. Course work completed for Ph.D. Medieval and Renaissance History. University of Rochester, Rochester, NY. 1965-68. Ph.D. Program, ' European History. Course work completed for M.A. Partial completion of Ph.D. course work. Wheaton College, Norton, MA 1957-61. B.A. European History. Minor: Biology. Dean's List, 1958-61. Honor's Program. CITY / SCAPE: Cultural Resource Consultants 726 Carroll Street Brooklyn, NY 11215 (718) 965-3860 Fax: (718) 788-4024 STEPHANIE ROBERG-LOPEZ EXPERIENCE 1990 to CITY/SCAPE: Cultural Resource Consultants present 726 Carroll Street, Brooklyn, NY 11215 As Field Archaeologist of CITY/SCAPE has provided archaeological management for environmental impact analyses, cultural resource studies (Stage lA and 1B), Stage 2 cultural resource studies, and archaeological research. Society of Professional Archaeologists (S.O.P.A./R.O.P.A) qualified (1992). 1993 to Lecturer in Anthropology/Archaeology present Dutchess Community College Poughkeepsie, NY. 1982 to Lecturer in Archaeology, 1996 Northwestern Connecticut Community College Winsted, CT. 1994 to Lecturer in Anthropology and Latin American Studies. 1996 SUNY New Paltz, New Paltz, NY. 1995 to Lecturer in Anthropology and Archaeology 1996 Marist College, Poughkeepsie, NY. 1997 to Vice President, Society for Anthropology in present Community Colleges Field Research conducted in Europe, North America & South America EDUCATION Yale University. New Haven, CT. M.A. Archaeology. Honors. Barnard College, Columbia University, New York, NY B.A. Archaeology. Phi Beta Kappa. Magna Cum Laude.. F m '$.ortc#gOf Upr feeis'anal �.rrhmiog*eits 7`iis is fo cerffty leaf GOES 445 L"GAN U.S.A. 1 Ithaca Area Wastewater Improvement Project EIS Proposal ' APPENDIX D TRAFFIC STUDY SCOPE J 1 1 u L TRAFFIC STUDY SCOPE OF SERVICES The study evaluation includes the following work elements: 1. Project Initiation/ Data -Report Review The Consultant will obtain and review all traffic study data and reports ' performed to -date pertinent to the study roadway and intersections. Data will be collected from NYSDOT and any other transportation agencies with information pertinent to this study. 2. Traffic Performance Districts The Consultant Team, with input from the Planning Team, shall establish subareas of the study services areas, classified as Traffic Performance Districts(TPDs). The districts are composed of existing traffic analysis zones (TAZ's) as delineated by ITCTC in their regional forecasting model. The purpose of the TPDs is to allow analysis of land use and traffic performance on the subarea roadway network. Future trip generation estimates, trip allocations over time, and mitigation strategies and improvements can be assigned to the TPDs in a more targeted fashion, thus providing greater effectiveness and efficiencies with future plans. 2.1 Existing Baseline Traffic Conditions In addition to the existing studies, there are many other data sources which are either already in possession of the study team or will be obtained, including Local traffic counts NYSDOT traffic counts f ITCTC and Tompkins County GIS databases Roadway functional classification Number of lanes Ownership Trail system Average daily traffic volumes CATS bus routes, park and ride lots, bus stops & shelters All existing data sources will be obtained and utilized as necessary for use in the study. The Consultant Team has a significant amount of existing information related to the transportation network. 2.2 Intersection and Roadway Operational and Physical Feature Data Collection A field reconnaissance of the existing transportation system within the study boundaries and established TPDs will be performed. This includes data collection on the physical elements of the study roadways and intersections, and the collection of the operational characteristics of the existing fintersection traffic control features. 2.3 Traffic Volumes The Consultant will obtain where available, current average _ daily traffic ' volumes and weekday PM peak hour turning movement counts for roadways and intersections within the study area. Existing data will be utilized if available from 1998 and later, and if not available, the Consultant will perform PM peak hour counts at twelve [121 selected study locations. 2.4 Link and Intersection Capacity Utilization — Existing Conditions The Consultant shall perform select study principal link and rinci al intersection capacity utilization to determine the existing weekday PM peak hour performance. The existing ITCTC regional forecasting model will be employed, and link and intersection capacity utilization (ICU) procedures will ' be utilized. The model procedures are currently used and accepted by NYSDOT. The evaluation procedures are based on the nationally accepted Highway Capacity Manual procedures. For locations with improvements underway or planned, analysis of the traffic conditions shall include the proposed improvements. 3.0 Traffic Forecasting This is the ultimate use of the model and purpose for its creation. The study iteam will use the model to forecast future traffic using the projected land use growth scenarios derived through the detailed land use analyses completed in ' previous study tasks. We will also perform some preliminary forecast runs during calibration so that anomalies in the calibration can be found and to assure that the calibration is right for the right reasons. The calibrated model will be used to test the effects of land use growth and of network change. Network changes may simulate either permanent street construction or closures or temporary changes such as reduced capacity and/or speed during maintenance. I 1 The calibrated model can project absolute volumes or changes in volumes on streets or turn counts. It can also analyze traffic flows to and from specific developments or cumulative developments or help to schedule improvements in an area of cumulative development. The model can allocate responsibility for traffic on a specific street to its zones of origin and/or destination. Future traffic volumes will be forecast for link volumes and for turning movements at selected locations using three alternative projected future land ' use scenarios. Growth rates for the external zones will be supplied by ITCTC for these forecasts. The steps involved in the forecasts are as follows: ' Revise network for programmed transportation improvements (new links, widenings, intersection_ improvements). Code revised (build -out) land use. Generate trips for forecast land use and revise through trip table. Run model for each forecast scenario. IDevelop forecast plots for volumes, link LOS. Review forecasts with ITCTC. Review model rules to insure that base calibration rules are appropriate. If necessary, revise model rules and re -validate calibration. ' Revise network assumptions and land use forecasts as necessary and rerun forecasts (steps 2 through 5). 4. Evaluate Future Conditions 4.1 For each Traffic Performance District involving the study areas, the Consultant will identify screenlines where additional link capacity, transit service, ridesharing, pedestrian linkages, and/or transportation land iuse/demand management actions are needed to process the development demand. The future analysis year traffic volumes under each growth ' scenario will be analyzed for select links and at each principal study intersections. Subsequent study locations may be identified for each scenario, where the overall performance measure (i.e. v/c ratio, LOS, ICU,) ' drops in terms of one level of service. 5. Identify Issues/Mitigation and Needs ' 5.1 An examination of mobility needs will be performed. The Consultant will prepare a rank ordered list of future issues associated with each alternative base condition. The effects of time and increased traffic volumes on the areas identified will also be incorporated into the future issues ranking. 5.2 The Consultant will prepare a technical memorandum summarizing the findings of Tasks 1-5 . Subsequent comments received will be reflected in subsequent study products. 6. Identification and Evaluation of Traffic Mitigation 6.1 The consultant team will identify for each development scenario, a list of mitigation applicable to Traffic Performance Districts in each community, using quantitative performance measure output obtained from the refined regional demand model, intersection capacity analyses, and other prior Iactivities. The anticipated performance and expected benefits of traditional and nontraditional alternatives that contribute to the more efficient use of I existing and future transportation systems shall be identified. Emphasis will be on the identification of management strategies as well as capital projects. I While there are numerous ways to categorize alternatives, a starting point for the alternative mitigation will focus on, but not be limited the following general categories: changes to land use plans and zoning ordinances, phasing recommnedations, traffic operational and infrastructure improvements. The findings of the alternative identification will be summarized. 6.2 The results of Task 6.1 will consist of remedial mitigation action for each development scenario. Differences among these, such as significant ' roadway widening, or construction of new roadway alignments may warrant revisiting the travel demand forecasts prepared in Task 4 to reflect potential trip reductions or diversions. ' The Consultant expects up to 2 model runs will be made in this Subtask to reflect such significant differences between alternative development and ' mitigation alternatives. 7. Proposed Mitigation Plans ' The of this Task is to reach final consensus on alternative remedial purpose action scenarios and document the recommended Mitigation Plans. 7.1 Using the results from Task 6, the Consultant will work with the I Planning team to develop consensus for the appropriate mitigation package for each development scenario. 7.2 It is anticipated minor adjustments will be made to the recommended package of improvements as part of the consensus -building process in Task ' 6.1. The Project Team will document the minor adjustments to the selected package of improvements, including conceptual level impacts on estimated costs and benefits. It is anticipated that the refinements will not warrant preparation of additional travel demand forecasts. The recommended package of mitigation will be documented for each ' development scenario. 8. Cost Estimates 8.1 Cost estimates for one mitigation plan will be provided b the Project g P _ P- Y J Team. Additional cost estimates for each growth scenario can be provided if ' necessary, as a work extra. 8.2 The Consultant will prepare a draft report that summarizes existing conditions and conditions forecast for the three growth scenarios with the recommended improvement scenarios. References will be made to the Technical Memorandum for Task 5 for further details on study process and alternative scenarios. 8.3 The Consultant will prepare a final report to address any minor comments, format and layout.