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October 22, 2005

Riverkeeper, Water Quality

Good evening. My name is Eric Hager and I am from the Columbia Environmental Law Clinic.

I am here on behalf of Riverkeeper, a not-for-profit environmental organization working to protect the ecological integrity of the Hudson River, its tributaries, and the New York City watershed.

Given the size and scope of the proposed Atlantic Yards redevelopment, there will be numerous environmental impacts, many of which are named in the scoping document. However, the scoping document fails to clearly identify and define a significant impact: namely, the impacts to surface water quality – specifically to the East River – as a result of increased combined sewer overflow discharges, or “CSOs”. A CSO is the discharge of untreated sanitary sewage and polluted stormwater during wet-weather events.

The Atlantic Yards redevelopment project will add more than 2 million gallons of sewage per day to the City’s combined sewage system, a system which is already so overburdened that it discharges raw sewage to the East River (as well as other local waterways) approximately once per week during wet weather. The additional sewage generated from this project will increase the volume (and perhaps the frequency) of these polluted – and illegal – discharges, resulting in additional pathogens and oxygen demand in the East River, which harms aquatic life and threatens the health and safety of a growing number of recreational users.

The significant impact from additional CSO discharges should have been clearly delineated in the scoping document, and must be appropriately evaluated and mitigated in the DEIS. This is the fourth project where Riverkeeper has commented on the significant impacts from CSO discharges, an issue that, given the longstanding City-wide problem of CSOs, should be thoroughly assessed in any SEQRA, CEQR, or other environmental review.

Atlantic Yards is an opportunity to address CSOs in a manner that sets a standard for green and responsible development in the City, rather than being a project that contributes to and worsens a serious, longstanding environmental and public health problem.

I would like to make four other brief points:

First, The Increase in Combined Sewer Overflows (“CSOs”) is a Significant Adverse Impact of the Atlantic Yards Project that Must Be Analyzed in the DEIS.

Notably, the DEIS should examine how the proposal will affect water quality of the East River, but with spatial and temporal parameters that are more attuned to this project’s impacts.

Second, The Increase in CSOs is a Significant Adverse Cumulative Impact of the Atlantic Yards Project that Must Also Be Analyzed in the DEIS,

taking into account other present and future developments.

Third, Low Impact or “Green” Development Technologies are Available to Mitigate and Eliminate the Increase in CSOs and Must be Evaluated in the DEIS.

Fourth and finally, A “No Net CSO Increase” Requirement Should Be Imposed on the Atlantic Yards Development.

Imposing such a requirement would really show a commitment to doing something about the CSO problem in this City.

Posted by lumi at October 22, 2005 12:18 AM