[CT Birds] FW: [nysbirds-l] Application ID: 3-5152-00233/00002 - Article 11, Incidental take of Endangered and Threatened Species - Galeville Park & Shawangunk NWR
Leslie.Meredith at simonandschuster.com
Thu Sep 6 09:35:45 EDT 2012
In case you don't know about this unnecessary proposed development of the Grasslands, here is an eloquent and impassioned letter against it. Letters opposing the development should be sent today.
From: bounce-64112130-12941460 at list.cornell.edu [mailto:bounce-64112130-12941460 at list.cornell.edu] On Behalf Of redknot at optonline.net
Sent: Thursday, September 06, 2012 1:12 AM
To: Murray, Joseph
Subject: [nysbirds-l] Application ID: 3-5152-00233/00002 - Article 11, Incidental take of Endangered and Threatened Species - Galeville Park & Shawangunk NWR
Dear Mr. Murray: I would like to take this opportunity to express my strong opposition to the issuance of a permit, pursuant to the above-referenced application, by the Department of Environmental Conservation so the Town of Shawangunk may move forward to construct a large, regional recreational facility at Galeville Park, a town-owned parcel situated adjacent to the nationally significant Shawangunk Grasslands National Wildlife Refuge.
As the application references, the construction of this facility will result in the destruction of approximately 10 acres of grassland habitat critical for a variety of rare and declining bird species including short-eared owls, northern harriers, potentially henslow's sparrows, upland sandpipers, and a host of other grassland dependent bird species. The owl is a state endangered species while the other three are state threatened.
These habitat impacts are proposed to be mitigated by several measures detailed in the notice, as laid out below:
* The Town will convert and maintain approximately 10 acres of the Galeville Park property as designated grassland habitat area;
* Construction activities for the development of the park will be prohibited during nesting and overwintering periods;
* Lighting of the four athletic fields will be prohibited;
* Dogs will be prohibited;
* The Town has served as the facilitator for the acquisition of an adjacent 31 acre parcel of land by the USFWS for the creation of an off-site grassland habitat area;
* The Town will conduct environmental education or interpretive outreach programs and will develop enhanced wildlife observation areas;
* The Town will construct an interpretative walking trail system at Galeville Park with linkage to the adjoining refuge.
I do not believe these mitigation measures sufficiently offset the environmental impacts caused by the proposed project - the outright destruction of habitat adjacent to one of the most significant grassland areas in the northeastern United States. Perhaps this is partially due to the fact that given the information presented in the ENB notice it is impossible to judge the full extent of the mitigating effect of the proposed measures. For example, one of the mitigating measures is the "facilitation by the town of the acquisition of an adjacent 31 acre property in which a grassland habitat will be created". Without knowing the proximity of this property to the refuge, and the details of the proposed grassland creation there is no way to judge its merits and thus the extent to which it truly qualifies as a mitigating measure. The same is true with the proposed creation of 10 acres of "newly designated grassland habitat area" by the town to replace the grassland acreage lost due to the construction of the recreational facility. Ecological restoration dictates that in almost all situations a better and more prudent approach is to preserve and maintain an existing natural community type rather than to allow for it to be destroyed and attempt to re-create it nearby.
A local article indicates that the proposed football field will be equipped with lights. If the other four fields are to remain unlit I strongly urge that this field remain unlit as well.
How will some of the other proposed mitigation measures be enforced? For example, will there be some way to ensure enforcement of the dog ban? Generally, mitigation measures which rely on public compliance or cooperation typically have less value than measures which don't.
I don't understand how the last proposed measure - construction of an interpretive walking trail with linkage to the refuge - serves to mitigate the environmental damage to the grassland habitat.
Furthermore, I was extremely surprised to read that the SEQR determination for this action was a Type 1, Negative Declaration. Given its adjacency to the refuge, pursuant to Part 617 NYCRR, the Type 1 threshold (the threshold which presumes a Positive Declaration) would be lowered to an action affecting a mere 2.5 acres of land, one fourth the amount of grassland proposed to be destroyed by one element of the proposed action and about one twentieth the size of the overall action. Given this, and the exceptional value of the habitat for demonstrably rare birds, it is inconceivable that the lead agency for this action would issue a Negative Declaration. One of the benefits of a Positive Declaration, resulting in the preparation of an EIS, would have been a requirement to discuss reasonable alternatives to the proposed project, including alternative layouts, scope, and most importantly sites. It is highly unfortunate that the full value of SEQR will be unavailable to assess this project.
In conclusion, as an individual who has visited the refuge many times both individually and with groups on bird tours through my company, I oppose the project as proposed and urge the Department to deny the issuance of the requested endangered and threatened species "take" permits. I urge the Department to work with the Town to fully mitigate the impacts of the project with the central goal of leaving the grassland portions of the park intact and by establishing a sufficient buffer between the active portions of the proposed park facility and the refuge.
Alula Birding & Natural History Tours
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