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Drafting a Scoping Comment LetterDear?Commissioner Seggos and Acting Executive Director Bill Finch:?Please find below my comments on the?Draft?Scope?for?the Pilgrim Pipeline project?which you released for public comment on??______, 2016.? I strongly urge that DEC and the Thruway Authority, as Lead Agencies, require the following environmental impacts of most concern to me to be fully evaluated?in the Draft?Environmental?Impact?Statement?(“DEIS”)?that must be prepared for this project?to ensure that?all agencies from whom Pilgrim seeks a permit to allow its project to go forward meet their obligations under state SEQR law to fully consider all relevant environmental factors in their decision-making. Which impact area(s) are of most concern to you? Select two or three and explain your specific concerns.2) Evaluation of Alternatives - The DEIS must evaluate a “reasonable range” of alternatives to the proposed project, including the “no action” alternative (which must always be included in a DEIS).Thank you for your consideration of these comments.List of Potential Significant Impacts of the Pilgrim Pipelines – Which are of Greatest Concern to You Locally or Globally?1) Impacts on LandThe proposed action entails construction on steep slopes, exposed bedrock, and on land where the depth to water table is less than 3 feet. Impacts on Geological FeaturesThe NYS Unique Geologic Landforms project has identified unique geological features along the proposed pipeline route. Impacts on Surface WaterThe proposed action will traverse surface water at 257 locations, including two crossings of the Hudson River, and more than 9.2 linear miles of wetlands which would temporarily impact more than 80 acres of wetlands, including 25 freshwater wetlands under the jurisdiction of NYSDEC. Impacts on GroundwaterThe proposed action involves the conveyance of petroleum products across several groundwater and drinking water resources including the Ramapo River Basin Aquifer Systems Sole Source Aquifer, and the crossing of two New York City public water supply system aqueducts, the Catskill Aqueduct and the Delaware Aqueduct. Impacts on FloodingThe proposed action traverses several floodplains and floodways along the proposed route. Impacts on AirThe proposed action has the potential to result in direct and indirect air quality impacts, including the generation of fugitive dust during construction and emissions from construction equipment. Moreover, the electricity used to power pump stations has the potential to result in additional air quality impacts. The proposed action has the potential to exacerbate climate change due to emissions of greenhouse gas. Impacts on Plants and AnimalsSeveral federally and state listed threatened and endangered species and their habitats are located along the proposed pipeline route and may be indirectly or directly impacted by the proposed action. Additionally, the proposed action involves the removal or destruction of large quantities of vegetation or fauna, including approximately 611 acres of forest that would be impacted, which has the potential to increase surface water runoff and erosion, among other things.Impacts on Agricultural ResourcesThe proposed action traverses more than 20 acres of agricultural land including approximately 5.82 miles of prime farmland and 7.63 miles of farmland of statewide importance. During construction, there may be significant impacts from the disruption of crop production compaction as well as potential loss of crop land along the permanently maintained portions of the ROW.Impacts on Aesthetic ResourcesThe proposed action passes through or is in close proximity to at least eight public parks, including the Sterling Forest State Park and Schunnemunk Mountain State Park and two privately owned golf courses. Impacts on Historic and Archeological ResourcesThe proposed action will cross 45 archeological resources and three properties listed on the National Register of Historic Places, and may have a potentially significant impact on these properties. In addition, the proposed project may transect and disturb Native American archeological sites belonging to the Delaware Tribe of Indians, Delaware Nation, Stockbridge-Munsee Band, and the St. Regis Mohawk Tribe.Impacts on Open Space and RecreationThe proposed action may result in a loss of recreational opportunities or a reduction of an open space resource within local communities. Impacts on Critical Environmental AreasImpacts on TransportationThe unprecedented use of the NYS Thruway ROW for a crude oil pipeline has the potential to significantly impact the traveling public and commerce that this important transportation corridor services. The proposed action could disrupt a major transportation corridor that spans from Albany County to Rockland County and result in a substantial and possibly permanent change in the use, or intensity of use, of land including Thruway Authority property and NYS Thruway ROW for construction and long- term operations and maintenance of the pipelines. Additionally, traffic impacts may occur associated with construction and operation of the pipelines, including blasting and possible spill response. A spill from the pipeline could also disrupt a major transportation corridor and divert a large volume of traffic to local and county roads. Impacts on EnergyThe proposed action may utilize more than 2,500 Mwh per year of electricity to run the pump stations.Impacts on Noise, Odor, and LightThe proposed action may result in construction related traffic and noise impacts during the duration of the proposed action, which is estimated at 10 months, and will include the blasting of bedrock along the NYS Thruway ROW.Impacts on Human HealthThe proposed action potentially risks creating a hazard to human health and the environment in the event of a pipeline rupture, possibly due to malfunction, natural disaster or security breach. The longitudinal occupation of the NYS Thruway ROW for more than 90 miles by an oil pipeline carrying a flammable gases or liquids under pressure within limited access highway ROW has the potential to adversely affect the safety and security of the traveling public.The proposed action may result in potential adverse impacts to nine potential Environmental Justice (EJ) areas that the proposed construction, operation and maintenance of the mainline pipelines will traverse, including an EJ community near the Port of Albany where the pipeline is proposed to originate.Consistency with Community PlansThe proposed action may result in the creation of a material conflict with the current plans or goals as officially approved or adopted of the 29 municipalities traversed by the proposed action and may be inconsistent with those officially adopted community plans.Consistency with Community CharacterThe proposed action may interfere with the use or enjoyment of officially recognized or designated public resources, including several public parks and recreational areas that are located along the pipeline route. 19) Cumulative ImpactsA cumulative assessment of impacts is necessary to determine whether the proposed action can designed and constructed in a manner to avoid, minimize or mitigate potential impacts. In addition, the proposed longitudinal occupation of the pipeline within the Thruway corridor has the potential to interfere with the future growth and expansion of the Thruway. 20) Coastal ConsistencyAs part of the EIS process, the LAs will also need to consider if the proposed action is consistent with State Coastal Policies that promote the beneficial use of coastal resources, prevent their impairment, and evaluate major activities that substantially affect numerous resources. ................
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