RE: Final Environmental Impact Statement for The Farm, Somers, NY Dtd 2/11/98

Dear Members of the Planning Board,

I am writing on behalf of the 1,200 members of the Bedford Audubon Society which has 62 concerned members in the Town of Somers. We are the oldest Audubon Society chapter in New York State, and a chapter of National Audubon Society.

Bedford Audubon strongly encourages land use schemes that are designed to preserve and protect the dwindling area of and quality of valuable wetlands in our region, in keeping with the policy of National Audubon and of New York State Audubon. These wetlands function as filters for natural pollutants and naturally occurring sediments, water recharge of our drinking water, and important habitat for wildlife in our region.

The wetland functions are seasonal in nature, often ebbing and flowing during winter water discharge and spring recharge cycles. No theoretical calculations can be relied upon without accurate seasonal field studies of the water recharge cycles and hydrology of a given wetland. Seasonal cycles vary greatly in the amount of water flowing into and flowing out of the wetland and its aquifer, according to the subsurface hydrology of the particular wetland.

When considering wetland impacts, an average inflow/outflow value does not reflect the true critical inflows and outflows of a wetland. Accumulation of water during the winter discharge cycle can vary according to the underlying geology and topography of the wetland, along with other water flow beneath the surface of the ground. Release of water from snow and from seasonal rains during the spring and early summer recharge can drastically alter these flows. This important hydroperiod can not be characterized without seasonal subsurface studies of the wetland's hydrology. 

After careful consideration of the subject FEIS, Bedford Audubon Society finds a number of fundamental problems with, and flaws in, the proposed plan. Among these problems and flaws: a lack of seasonal hydrologic studies, serious potential adverse impacts to the A-14 DEC Class II wetland (Class II is the second most important wetland class on a scale of I to IV) as indicated by the material and data supplied by the applicant, and inadequate treatment of wetland mitigation's required to offset the potential significant adverse impacts.

We have serious reservations about use of biofilters without further detailed study of their capacity relative to the wetland K-14. Average Expected Pollutant Removal Efficiency ("Anticipated Performance of Stormwater Management Measures" of the "Stormwater Management Plan") can not be determined without the requisite seasonal hydrologic studies, as explained above, for subsurface water quality would be part of such a study.

The theoretical data presented by the applicant (Tables 5 and 6 of the Stormwater Management Measures) indicates an increase of Nitrogen and Phosphorus of 74%/21% in Sub-catchment Area B1C, 183%/67% in sub-catchment Area B2C and an increase of 93%/27% overall. Without a seasonal subsurface hydrologic and hydroperiod study, the impact on adjacent wetlands will be impossible to predict during the water recharge and water discharge cycle. Moreover, this would present an unacceptable degradation of this DEC-Regulated Wetland.

We see no reason why seasonal subsurface hydrologic studies could not have been completed (as suggested in our prior comment), for the applicant has been planning this subdivision since 1994, according to the FEIS.

Finally, we object strenuously to the change in plans which moves the access road into the NY State DEC-regulated Class II wetland A-14. No data is indicated regarding the impact of sediment runoff and/or runoff of road de-icers which will inevitably be used here. Additionally, the overall impact of constructing the road through the wetland and through the wetland buffer has not been fully documented in terms of the underlying hydrology.

In view of the foregoing objections, Bedford Audubon Society, Inc. strongly recommends that a supplemental FEIS be required of the applicant to detail the impacts of the stormwater management, septic effluent and access road construction on the A-14 wetland.

Respectfully Yours,