Green energy is good. Green jobs are good. But, destroying precious habitats, endangering the River, and putting quality of life issues at risk is bad! Let’s not sacrifice one for the other.
Other port candidates in the Capital Region are far better positioned for offshore wind manufacturing than the proposal being pushed forth by the owners of the Port of Coeymans.
Use your voice on December 27th at 7p to convince the Town of Coeymans Planning and Zoning Board that “carving up” residential-zoned land, especially without proper due process and environmental review, is more harmful than good.
Members of the CAC Steering Committee sent the following letter to Chairman Nolan and members of the PBZBA (Planning Board/Zoning Board of Appeals) regarding what needs to be done to slow the process down. We also cc-ed several state congressmen, senators, and legislators with this letter. Additional officers at the NYSDEC, Albany County DPW, NYS DOT, and the Albany County Planning Board have been looped in as well.
Timing is important, we only have until the end of this year to make this right. Please help us take a stand against a company intent on gobbling up every square inch of land in our town for industrial use.
Dear Chairman Nolan and members of the Town of Coeymans Planning Board/Zoning Board of Appeals:
We are writing in regard to the “GE / LM Wind” proposal submitted by the applicant Carver Companies. As a Type 1 Action requiring coordinated review, we have several concerns about the Lead Agency process. We also request a Positive Declaration of Significance (“Pos Dec”) under the State Environmental Quality Review Act (“SEQR”) and a 90-day comment period for scoping.
The Clean Air Coalition of Coeymans and Greater Ravena (CAC) is a community group with a mission to address the environmental and public health concerns of waste management, incineration, tire burning, and port expansion in the Town of Coeymans, New York. We are concerned about the impact that all this will have on the Capital District and the Hudson River, specifically on the Greater Ravena-Coeymans area. The CAC aims to build a stronger community able to create a cleaner and more equitable future for the environment, the river, and the people who live here.
First, the “Project Location” is described as being located on Bronk Road and NYS Route 144 in the Town of Coeymans. The “Proposed Action” is described as “GM/LM Wind Blade Manufacturing Facility is an 80+/- acre campus to support the manufacturing and transportation of OSW blades for use in the development of green energy projects in New York State. The facility includes approximately 515,000 SF of manufacturing buildings for the 400 FT long wind blades. Additional structures include office space for employees and 392 parking spaces. The portion of the campus area located within the R1 zone, approximately half of the 80 acres, will be used for an outdoor blade storage year. Tax map ID #s 156.-1-1.11, 156.-3-1-1, and 156.-4-8.1 reference the project site.”
Lead Agency
The purpose of the Lead Agency is to “coordinate the SEQR process from start to finish so that when an action is to be carried out, funded or approved by two or more agencies, a single integrated environmental review is conducted.” The Lead Agency is also “responsible for making key SEQR determinations during the review process.”
In 617.6 (B) (2) For Type I actions, a “full Environmental Assessment Form (“EAF”) must be used to determine the significance of such actions. The project sponsor must complete Part 1 of the full EAF, including a list of all other involved agencies that the project sponsor has been able to identify, exercising all due diligence.”
Upon reviewing the applicant’s Environmental Assessment Form (EAF) as a record before the Town of Coeymans Planning Board/Zoning Board of Appeals, we noticed that at least the Village of Ravena is missing from Section B “Government Approvals” in the applicant’s EAF.
This is significant, as on page five (5) of the EAF, the Village of Ravena is identified as providing 10,000 GPD of drinking water and infrastructure to deliver drinking water to the site: “4500 LF of new 8” water main along route 144 (River Road) north towards the project site. Project will be served as an out of district user”. The Village of Ravena will also receive “10,000 GPD of sanitary wastewater generated by employees”. The Village of Ravena should have been identified in Government Approvals in the EAF in order to be included as an “Involved Agency”
For a Type 1 Action and Coordinated Review (Section 617.6 (b) (3) (i) (ii), “When an agency proposed to directly undertake, fund or approve a Type 1 action…with other involved agencies, it must, as soon as possible, transmit Part 1 of the EAF completed by the project sponsor or a draft Environmental Impact Statement (“EIS”) and a copy of any application it has received within 30 calendar days of the date the EAF or draft EIS was transmitted to them.”
If the Village of Ravena is not listed in Government Approvals, and therefore, not acknowledged as an “Involved Agency”, then Ravena may not have received a communication from the Town of Coeymans Planning Board/Zoning Board of Appeals about their intent to become Lead Agency, leaving the Village at risk to miss the 30-day window to participate.Furthermore, as this is likely one of the largest projects ever proposed in the Town of Coeymans, and, as the NYS Department of Environmental Conservation (“NYSDEC”) is an Involved Agency in SEQR, we request that the NYSDEC, and not the Town of Coeymans Planning Board/Zoning Board of appeals, take on the role of Lead Agency for this complicated project.
Positive Declaration and 90-Day Public Scoping Process
Because of the size, scope and scale of this proposal, there is the potential for significant environmental impacts and in SEQR, all that is required is ONE POTENTIAL significant adverse environmental impact to trigger a Positive Declaration (“Pos Dec”) and EIS. As required by New York Codes, Rules and Regulations (NYCRR) (617.7 (a)) and based on our non-exhaustive list from the applicant’s full EAF, the Lead Agency should issue a Pos Dec and the preparation of an EIS for this project:
617.7 (c) (1) and (i): “A substantial adverse change in existing air quality, ground or surface water quality or quantity, traffic or noise levels; a substantial increase in solid waste production; a substantial increase in potential for erosion, flooding, leaching or drainage problems.”
- ● The project is sited over or immediately adjoining to a principal aquifer.
- ● The project will create a demand for 10,000 GPD of drinking water from the neighboring town of the Village of Ravena, requiring water mains to be built along Route 144 north towards the project site.
- ● The project will generate 10,000 GPD of liquid sanitary waste managed by a line extension to the Village of Ravena; The project will disturb more than one acre of runoff, with “stormwater runoff to new outfalls along the Hudson River”. Stormwater runoff flow will flow to adjacent properties.
- ● The project includes one or more sources of air emissions.
- ● The hours of operation during construction are 6a – 6p, and during operations: 24 hours a day.
- ● An increase in noise levels will occur during construction.
- ● There will be outdoor lighting that may contribute to light pollution.
- ● Traffic for all routes related to this project should be studied comprehensively.
- ● The project is located in a 100 and 500-year floodplain.
617.7 (c) (1) (vi) “A major change in the use of either the quantity or type of energy”
- There will be a new demand for energy, requiring a new or upgrade to an existing substation.
617.7 (c) and (1) (ii): “The removal or destruction of large quantities of vegetation or fauna; substantial interference with the movement of any resident or migratory fish or wildlife species; impacts on a significant habitat area; substantial adverse impacts on a threatened or endangered species of animal or plant, or the habitat of such a species; or other significant adverse impacts to natural resources”
- There are federal wetlands on-site and Class C streams and lakes/ponds with waterbodies that NYS has deemed water quality impaired for pollutants into the Hudson River and priority organics – fish consumption; The predominant wildlife species that occupy or use the project site are white-tailed deer and Canada goose. The project site contains a designated natural community with a floodplain forest, freshwater tidal marsh, and freshwater intertidal mudflats. Endangered species on-site include shortnose sturgeon, Bald Eagle, Davis’ Sedge, and American Waterwort.
617.7 (c) (1) (v): “The impairment of the character or quality of important historical, archeological, architectural, or aesthetic resources or of existing community or neighborhood character”
- The project is located in a sensitive archaeological site; This project is within five miles of designated scenic or aesthetic resources Schodack Island State Park for its state-protected wetlands, bird sanctuary, and recreational park is located 0.25 miles from the site.
617.7 (c) (1) (vii) “The creation of a hazard to human health.”
- The project will have 6600 gallons of Epoxy Resin onsite.
617.7 (c) (1) (xi). “Changes in 2 or more elements of the environment”(xi) changes in two or more elements of the environment, no one of which has a significant impact on the environment, but when considered together result in a substantial adverse impact on the environment.”
- On January 23, 2023, the CAC with support from Riverkeeper, Scenic Hudson, and Hudson River Sloop Clearwater requested that the Department of Environmental Conservation conduct a comprehensive cumulative impact analysis of Coeymans and associated industrial park.
We urge Lead Agency, once identified, to recognize these impacts and issue a Pos Dec, require the preparation of an EIS, provide 90-days for the public to review and provide written comments on a draft Scope for the EIS, and hold a public scoping meeting to allow for greater public participation.
In conclusion, as this project has already elicited strong reactions from the community, a transparent and inclusive SEQR process is an opportunity to address important concerns in a comprehensive manner.Thank you,
The Steering group of the Clean Air Coalition of Greater Ravena-Coeymans