קרית יואל פייפלייןאפשאצונגפין אינשעניר
January 11, 2005
KJ pipeline needs a thorough environmental review
By Andrew Barone
When created, the intent and purpose of the State Environmental Quality Review Act was for all agencies to conduct their affairs with an awareness that they are stewards of the air, water, land and living resources, and to recognize that they have an obligation to protect the environment for the use and enjoyment of this and all future generations.
The basic purpose of SEQR is to incorporate the consideration of environmental factors into the existing planning, review and decision-making processes of state, regional and local government agencies at the earliest possible time. To accomplish this goal, the act requires that all agencies determine whether the actions they undertake, fund or approve may have a significant impact on the environment, and, if so, prepare or request an environmental impact statement.
For its proposed 13-mile long water pipeline connection to the New York City Aqueduct, the Village of Kiryas Joel is required to obtain the approval of the New York City Department of Environmental Protection Bureau of Water Supply. In so doing, compliance with the act is mandatory and KJ undertook its implementation and declared itself lead agency. Following the procedures of the act, village officials determined that there would not be any detrimental impacts on the environment and arrived at a negative declaration, thus concluding in rapid fashion this phase of the approval process.
However, the New York City Board of Water Supply could just as well have been the lead agency (and perhaps should have challenged the initial declaration by KJ), as that agency is the one granting the approval. The city board is the steward of thousands of upstate watersheds where impoundments of potable water are stored in a vast array of reservoirs connected by underground tunnels. This is to meet the needs and requirements for this natural resource for millions of state residents.
As to the needs of KJ for this additional supply of water, we know that at times of prolonged drought, despite the numerous wells they have drilled, village residents still need water to be trucked in to augment the groundwater supply. Nevertheless, this community continues with its rapid growth without any moratoriums on building of living units. Further, it appears that the village eventually is going to expand its municipal boundaries by annexations of abutting lands, as follows:
- 140 acres of Ace Farm
- 79.5 acres Lands of Vaad Hakiryah
- 87 acres from Woodbury
- 97 acres from Monroe
In addition, village officials are permitting commercial uses that require significant amounts of water on a daily basis, e.g. a poultry processing plant that, when operating at full capacity, requires about 75,000 gallons per day.
All of these actions are subject to SEQR and should have been included in their pipeline approval application. Not to do so constitutes "segmentation." Segmentation by SEQR definition means the division of the environmental review of an action such that various activities or stages are addressed as though they were independent, unrelated activities, needing individual determinations of significance. Considering only a part or segment of an action is contrary to the intent of the act.
Village officials must clearly state in their determination of significance, and any subsequent environmental impact statement, the supporting reasons and must demonstrate that such review is clearly no less protective of the environment. Related actions should be identified and discussed to the fullest extent possible.
During periods of severe drought, New York City is required to maintain minimum flows in the various rivers and streams downstream of their reservoirs. Excess drawdowns during these periods might restrict the flows that they can deliver to their other users.
In addition, excess drawdown will indirectly create high wastewater flows to the existing treatment plants. Their capacities can be overextended, violating their permits.
For all of these reasons, a more thorough review of a complete environmental impact statement is in order and called for before KJ is given any approvals to proceed with this project.
Andrew Barone of Monroe is a civil engineer.
הטקסט שלך כאן
 |
|
|