Well done, John...THANK YOU!!
-Eileen Keenan
Shawangunk Grasslands National Wildlife Refuge.
-----Original Message-----
From: redknot <redk...@optonline.net>
To: Murray, Joseph <r3...@gw.dec.state.ny.us>
Cc: NYSBIRDS-L <NYSBIRDS-L@cornell.edu>
Sent: Thu, Sep 6, 2012 12:11 am
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.
Sincerely,
John Turner
President
Alula Birding & Natural History Tours
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