Public Meeting, March 27, 2019

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Environmental Impact Statement (EIS) Scope Meeting at Camp Cass

First Impressions


During this well attended meeting, PARKS provided high level information about the EIS Scope for the shooting range, shoot house and facility expansion.  The presentations were on neatly printed posterboards, but for the most part were aspirational not informational.  About ten staff from Ecology and Environment (E&E) were manning the posterboards and sign-in, indicating they all recognize the high level of public interest.  (E&E is a large, well respected, environmental consulting firm with experience in Environmental Impact Statements.)


Exploratory questions of a technical nature were accepted with understanding and concern, but consistently answered with "put that in your comments".  Unhelpful, but we do understand. 


EIS Scope Thoughts


We'll publicly publish our EIS Scope Comments here later in the week.  Our comments may be helpful to you for your comments, for their points, format, or bureaucratic jargon.


Especially disappointing in PARKS EIS Scope and presentation was the complete lack of studies and models they plan to use in their EIS. For example, they're currently conducting a noise modeling study outside of the formal approved EIS workplan.


  • They have a contractor working on noise computer modeling.  
  • They are using existing noise information they collected in 2017 just before the range use was ended.


During this phase of work, we should be reviewing and commenting on their intended computer models and calibration methodology, their plans to conduct testing at the affected properties, as well as, the previous studies they're relying on. This is  listed in the DEC SEQR handbook, and PARKS has much of this information in hand.


PARKS is denying us  a chance to comment on these key elements of the EIS Scope, and this is issue extends across all of the EIS study areas.  Because of PARKS previous evasion of public comment and input, this lack of transparency is highly concerning.


Budget and Cost thoughts


In the News 10 interview, Captain Schedel said they needed the range because training outside was costing $52,000 per year. That works out to about $2,000/recruit.  Since the need for this range is financial, as taxpayers we want to see the details of the financial justification.


We asked in a Dec 2018 FOIL request for their budget to build and operate this range.  Any surprise the response has been slowrolled?


By the way,  we estimate PARKS shooting range destroys $17,000,000 in property values (435 affected homeowners, average $40,000 loss in value).    


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This page includes:

Our Concerns

What is an EIS Scope - A quick overview of the EIS Scope

The DEC SEQR Handbook - The DEC handbook on SEQR and EIS

PARKS EIS  -The entire EIS Scope document is available to read


For the official meeting notice, click below and scroll down to

Positive Declaration, Availability of Draft Scope and Public Scoping Session

DEC Meeting Notice



Our Concerns

Lead contamination

We do not want lead contamination of the state land, our land, our groundwater, or surface water.

Period. 

Noise pollution

PARKS wants a multi-agency shooting facility for year round and night use.  Hunting and local plinking are common, but the barrage from the range is intolerable.  Because of the sharp bowls and valleys, the sound travels for miles.

Stormwater control

The new EIS for stormwater should start with remediation of the existing issues. The existing construction was performed without complying with SEQR, and those areas are subjects for demolition and site remediation.

Property values

The devastating impact to property values by this range not only affects the landowners, but also the Town and County, due to the downstream drastic reduction of property taxes.  

This is an unconstitutional taking under the 5th amendment and if that's where we end up, so be it. 

Use of the State Forest

When the range is hot with shooting, the entire surrounding mile of Rensselaerville State Forest sounds like a bad day in Fallujah. No horseback riding, no hiking, no hunting; it's unusable.

Light pollution

Did you know astronomers call the very low  level of light pollution found in Rensselaerville a "black hole"?  Because of that HESA is looking to site an observatory here. Camp Cass should be reducing their existing light pollution not adding to the problem.

What is the EIS Scope?

The EIS scope is a written document that outlines the topics and the potential environmental impacts of the range project that will be addressed in the actual EIS.
The purpose of scoping is to narrow issues and ensure that the draft EIS will be a concise, accurate and complete document that is adequate for public review. The scoping process is intended to:

  • Ensure public participation in the EIS development process
  • Allow open discussion of issues of public concern
  • Permit inclusion of relevant, substantive public issues in the final written scope


The EIS Scope objectives include;

  • Identify the significant environmental conditions which may be affected by the project
  • Describe the extent and quality of information needed
  • Specify study methods or models to be used to generate new information, including criteria or assumptions underlying any models, and define nature and presentation of the data to be generated by those studies and models. 
  • Define reasonable alternatives for avoiding specific impacts which must be included in the EIS, either as individual scenarios or a range of alternatives. 
  • Specify possible measures for mitigating potential impacts which must be discussed in the EIS, to the extent that they can be identified at the time of scoping.


The next critical date is April 12, 2018 when our public comments on the EIS Scope are due. 


Email your comments by April 12, 2019 to: 

Janet.Zuckerman@parks.ny.gov 


or mail, with delivery by April 12, 2019, to:

Janet Zuckerman

OPRHP

625 Broadway

Albany, NY 12238


Below is a link the DEC SEQR Handbook, which was updated in January, 2019.  The EIS Scope description starts on Page 108.  We find this handbook to be very readable, and the first 5 pages of the Scope section provide an excellent outline of the EIS scope.
 

DEC SEQR Handook

PARKS EIS Scope Document

 Below is a link to the complete PARKS EIS Scope document, released March 12, 2019 

PARKS EIS scope

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