How convenient that a Resolution to be voted on Tuesday concerning a program which has serially cheated the required public participation since the days of DPW Superintendent Butterworth cannot be researched today at City Hall.You'd be right to wonder why the city's principal documents for the DEC's "Long Term Control Plan" program aren't online (LTCP). As long ago as 2005, the state informed the city that "development of a public website and bill inserts are also tools that can be used to address public participation requirements." (The "also" referred to the previous paragraph, where the state chewed out Butterworth for failing the basic requirements of public participation.)Remember the failure of the city to take public participation seriously during planning of the LWRP? Today we have no LWRP.Remember the failure of the city to take public participation seriously during planning of the BOA Program? Today we have no BOA grant.Whether LWRP, BOA or the LTCP, it's a failure of leadership every time (and with the exception of Scalera and Butterworth, the same individuals then as now).But at least with the environmental impact statement for the LWRP we have the DEC's public comments which are totally at odds with the Resolution being voted on Tuesday (see that Comment and the city's official Response below).The DEC is now hoping that Hudson will make the inevitable misstep to spare the state agency a dilemma. The city would be wise to step back, but you know the Common Council can't help itself. So this time I'd like to take the opportunity ahead of time to announce why we're not going to get a grant that in certain respects we desperately need: abysmal leadership and a disrespect of the public.Just consider the following b.s. the city attorney came up with in response to the NYS Department of Environmental Conservation. Unlike residents of Hudson, the DEC won't accept Tuesday's Resolution because it cannot.3.7.7 Comment: Redirecting storm water flows into South Bay would likely have a negative impact on the wetland and would be in direct conflict with other priorities within the LWRP that include protecting a restoring South Bay. (Michael T. Higgins, NYS DEC/Research Reserve Staff, March 26, 2010). 3.7.7 Response: Comment noted. Hydrological and ecological studies, among others, would be required as part of the approvals process for any future plan to redirect storm water flows into the South Bay from the City’s CSO system.
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From the EPA's "Combined Sewer Overflows: Guidance for Long Term Control Plan.""3.1 PUBLIC PARTICIPATION AND AGENCY INTERACTION "It is important to develop and maintain avenues for public involvement throughout LTCP development. Opportunities for public involvement in the assessment of existing conditions and the development of system monitoring information were presented in Chapter 2. During the development and evaluation of alternatives, the goal of the public participation program should be to involve citizens in the development of alternative solutions that protect the local waterways ..." [p. 3-1].http://www.epa.gov/npdes/pubs/owm0272.pdf