New York State Department of Environmental Conservation.
Ray Brook, NY 12977
Re: Draft Program Report for Adirondack Rail Trail April 2017
Dear Mr. Guglielmi,
Electronic Review for the Environment Inc. has reviewed the document and has the following comments:
Page 3 Adverse Impacts – the document discusses that “minor pollution” of surface water will occur. This document should describe what those pollutants will be and what mitigation measures can be implemented under a management plan. Storm Water Pollution Prevention Plans (SWPPP) should be developed and included in an appendix of this document.
Page 3 Adverse Impacts – the document discusses that “minor impacts” to fish and wildlife will occur. This document should describe what those anticipated impact will be. The level of impacts to all species should be included. Are there endangered or protected species along the 34-mile trail corridor which need further study? Have mitigation measures been considered to mitigate the anticipated impacts? Is the development of the trail anticipated to increase the level of service (LOS) such that cumulative impacts to the fish and wildlife should be evaluated?
Page 14 Bridges and major culverts (and roadway crossings)– please discuss whether these structures shown on photographs have any hazardous materials associated with them that would require testing (e.g. lead from lead-based paint or metals from chemically treated railroad ties onto soils or into creek sediments below the bridges).
Page 22 section 3 B/ Concept Plan Map Pages 2, 10, 12, 14, 16, 24, 25, 28, 29, 31, 34, 38, 39, 40, 41, 44, 48, 52, 56, 59, 61, 62, 64. Please consider adding a renewable energy section to the building architecture plans (e.g. solar panel roofs and wind turbine powered rest stops).
Page 23 Section 4 D, Snowmobile parking areas. Parking capacity listed for the first proposed snowmobile parking area is predicted for 70 trucks with trailers. Could this lot size have a significantly greater impact on wildlife and water quality? Please conduct a study on this environmental impact. Please make changes based on findings. Consider changes that would mitigate environmental impact like reducing the parking capacity proportionately.
Page 25 section 4 C. Since this is a travel corridor directly adjacent to wilderness, it should be properly signed (e.g “carry in-carry out” in trail areas where receptacles are absent and "do not litter signs"). Additional regulatory signage on snowmobile speed limits, minimal ground snow levels, and importantance to stay on trail should be written in detail in this section.
Page 25 section 4 D. Signs for unique and diverse Adirondack Ecology should include the rare plant Calamagrostis Pickeringii (Pickerings Grass) with identifiable information. Posted: leave untouched and report information to the New York State DEC office. *1) _bibliography
Page 25 section 4 E / Concept Map Plan pages 1-64. The trail maps should show emergency telephone access points at equidistant intervals along the trail and at the rest stops.
Page 26 section 7 – Removal of railroad ties is discussed in this section however there is no mention of a testing program or plans for disposal. Since railroad ties can contain hazardous substances (e.g. metals, creosote, semi-volatile organic compounds…), this document should include a testing program for those compounds and plans for the railroad ties disposal. If testing results of soil sampling efforts along the proposed trail corridor are available, those should be included in tables and laboratory reports should be included in an appendix. Soils underneath the railroad ties should also be tested (a work plan for that activity should be included in an appendix) and depending on the contaminant concentrations, in the event they exceed screening levels (whether New York screening levels or USEPA Regional Screening Levels “RSLs”) those soils should be removed and disposed of in a permitted landfill. If contaminated soils are planned to remain in place, those should be capped and a land use covenant should be placed on the land along the trail corridor to safeguard against future human health and environmental exposures. Any land use covenant should require that any future breaching of the cap or work along the trail corridor be properly managed under a Soil Management Plan which should also be prepared and included in an appendix which includes provisions for worker Health and Safety Plans, proper soil handling procedures, and required testing and disposal procedures.
Page 28 section 11 – Maintenance along the trail should include provisions for following a soil management plan including health and safety provisions related to hazardous substances.
Page 28 section 11 paragraph 3 – The maintenance of undesired or invasive plant species could be monitored with help of the IMAP Invasive Species Database. Users can view sightings and this can track the number of plants and area contained through GIS.
Absent from this document are discussions of contaminant concentrations along historical railroad corridors and a testing program should be proposed to address concerns including:
a. Toxic combustion products including polynuclear aromatic hydrocarbons (PAHs) which are aerially deposited onto soils, this document should include provisions for testing for those compounds. The extent of the PAH plume along the entire 34-mile corridor should be investigated. Once the contaminant concentrations are known and presented on isopleth maps, then mitigation approaches should be evaluated.
b. Pesticides including lead arsenate and organochlorine pesticides should be tested for.
c. Polychlorinated biphenyls (PCBs) are known to have been used in railroad equipment so biased sampling toward locations of known electrical equipment should be proposed as well as a limited number of random sampling locations along the corridor since PCBs are also known to be used in other equipment such as hydraulic fluids for braking systems.
d. Since locomotives run on diesel fuel, a random sampling program to adequately cover the proposed trail corridor should be proposed to inform the project as to background concentrations along the corridor as well as in areas of obvious soil staining.
Absent from this document is discussion of what the plans are to address if cultural resources are encountered during this project (artifacts, whether anthropomorphic or paleo-). Plans for bringing an expert to the field to make an assessment in the event those resources are encountered.
Concept Plan Map Book. Please include a habitat map for the animals located adjacent to the corridor. Please add that with special attention to endangered or protected species if present
We would like to see citations for assessments and biological reports to control and mitigate the environmental impact(s) effectively. We would like to also see a listing of these documents in a bibliography.
ELECTRONIC REVIEW FOR THE ENVIRONMENT INC.
P.O. BOX 2756
BERKELEY, CA 94702
1) United States. New York State Department of Environmental Conservation. Division of Lands and Forests. Remsen -Lake Placid Travel Corridor Final Management Plan / Environmental Impact Statement. By Richard T. Fenton and David V. Gray. March: n.p., 1996. Print.