Today, The Valley Alliance followed up the ten-point brief submitted by the group's attorney, Warren Replansky, with twenty-four pages of supplementary comments. Here is the executive summary of that document:
I. RAIL ALTERNATIVE: The Plan has yet to consider a rail alternative for aggregate transport which bypasses the Waterfront altogether, making the Hudson dock area available for more compatible, beneficial uses.
II. SEGMENTATION: Paid for by O&G, this Generic Environmental Impact Statement is not 'generic' at all, but tailored instead to a single, site-specific project, whose review has been illegally segmented under SEQRA.
III. 'MAKING THE MOST OF YOUR WATERFRONT': The clear lack of community consensus and public acceptance of this Plan endangers its future implementation and success, a problem which needs urgent correction, with State assistance.
IV. ABANDONED RAILROAD BED: Holcim itself has repeatedly described the 'causeway' as an abandoned, demolished, dismantled and/or inactive 'railbed'; yet the GEIS insists that it's always been a road.
V. MOORE LETTER: The head of the lead agency for this review has arbitrarily and capriciously discarded his own prior laundry list of problems with this Plan, pushing it forward without resolving those concerns.
Click here to view the complete document.
This comment is from the South Bay Task Force:
ReplyDeleteHere's an example of an excellent question from the formerly curious Moore which met with the lamest of answers, at least from an honest feasibility standpoint.
3.14.12 Comment: ... The complete absence in the DGEIS of comparative cost data is a major deficiency from the standpoint of decision making. (Donald Moore, City of Hudson Common Council President, March 15, 2010).
[FGEIS, Sept. 2011; p. 3-131]
3.14.12 Response: ... [W]here available, the DGEIS did provide some basic comparative cost information associated with the various O&G Alternatives. However, pure economic considerations are beyond the purview of the SEQR review process.
[FGEIS, Sept. 2011; p. 3-132]
Here is a quick selection from the DEC"s "SEQR Handbook" on the matter of what is expected of alternatives, and why alternatives for a government sponsored action (like Hudson's sort of is) are held to a different standard than those of a private sponsor:
"An analysis of alternative project configurations or designs will enable the lead agency to determine if there are reasonable, feasible alternatives which would allow some or all of the adverse impacts to be avoided ...."
"The goal of the alternatives discussion in an EIS is to investigate means to avoid or reduce one or more identified potentially adverse environmental impacts. Part 617 further requires that the alternatives discussion include a range of reasonable alternatives which are feasible considering the objectives and capabilities of the project sponsor. In general, the need to discuss alternatives will depend on the significance of the environmental impacts associated with the proposed action. The greater the impacts, the greater the need to discuss alternatives. The discussion of each alternative should specifically include an assessment of its likely effectiveness in reducing or avoiding specific impacts.
"What constitutes a "reasonable" alternative will depend on the nature of the proposed action, the nature and range of potential adverse impacts, the sponsor of the action, and the general nature or class of the possible alternative. For example, government sponsors have a greater obligation to consider alternative locations than do private sponsors ...."
"Consideration of alternative project designs may be reasonable under the following circumstances ... [t]he alternative design may increase the overall project costs but the increase is not prohibitive."
http://www.dec.ny.gov/permits/55215.html
Good points Valley Alliance. It sounds as if we need to fill the warchest.
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