September 8, 2013
Dear Mayor Roach and Common Council Members:
We understand that the French American School of New York (FASNY) has submitted a DFEIS in connection with its plans to develop the former Ridgeway Country Club property. We have reviewed the DFEIS, and believe that it contains very significant changes to the original DFEIS thatwas the subject of public comment and hearing. Accordingly, we request that the Council require FASNY to submit a supplemental EIS and allow the public the right to a public hearing on these new plans.
We note that FASNY proposed two new alternatives to property access from Ridgeway, from North Street and from Bryant Avenue. These two new alternatives constitute drastic changes from the access plans contained in the original DFEIS, and, we submit, the revised DFEIS should be the subject ofa supplemental EIS and further public comment and hearing.
The two new alternative access points present significantly different traffic, environmental, and other impacts not only upon the directly contiguous Gedney Farm neighborhood, but upon the Bryant Avenue and North Street communities, including White Plains High School, the YWCA and residences, businesses, and houses of worship in the Bryant Avenue and North Street areas.
The new plans also call for massive amounts of impervious surfaces by reason of extensive roadways. These roads are planned for areas containing streams, and the storm water run off routes from Hathaway Lane across the golf course to the wetlands and beyond. FASNY must submit for public review and comment a statement of the environmental impacts of these changes and allow the public to review and comment upon them.
We further note that the North Street access route, and possibly the Bryant Avenue route, eliminates a significant purported benefit of the Conservancy because the area is no longer fit for use as a bird habitat:
However, a driveway bisecting Parcel D would negate the potential improvement to nesting habitat and one of the potential benefits of the proposed Conservancy. Several species of birds that might be attracted to restored meadow habitat require a minimum of 25 contiguous acres of meadow habitat for breeding. The introduction of a driveway in the middle of this area would negate opportunities to attract breeding birds to the Conservancy. Chapter 2.2, Environmental Analysis Modified Proposal, Subdivision E (emphasis added).
We have always felt that the Conservancy was nothing more than a ruse to divert attention from the massive school project. This latest proposal confirms our suspicions as FASNY has now eliminated much of the property from use as a Conservancy.
Further, FASNY admits that the North Street access route violates the City of White Plains 50-foot restrictive wetlands buffer. Chapter 2.2, Environmental Analysis Modified Proposal, Subdivision D.
The above are but a few examples of the impacts that the new FASNY plans will have on the City. It is tremendously unfair for the Council to considerthe new plan without affording the thousands of individuals affected by the new plan the right to be heard. Indeed, it would constitute a total abdication of the Council’s obligation to protect the City if it considers this developer’s purported FEIS to be final.
The New York Department of Environmental Conservation (DEC) authorizes a Supplemental EIS (SEIS) when “…the project sponsor proposes project changes which may result in one or more significant adverse environmental impacts not addressed in the original EIS.” See:http://www.dec.ny.gov/permits/56546.html. The significant changes that FSNY proposes unequivocally meet the DEC criteria for a SEIS, and we submit that you should require FSNY to adhere to this process.
Joseph L. DeMarzo, Esq.
Denise L. DeMarzo, Esq.
41 Hathaway Lane
White Plains, NY 10605