Section 1.0 Introduction, Section 1.1 History - The second and third paragraphs of this section are confusing. It is not entirely clear why a discussion has been included which attempts tot ake away the history of the Albany Interim Landfill (AIL). The discussion has dropped the individual names for subsequent expansions then calling the collective area AIL. The orginal 1991 Part 360 Permit had intended for the "AIL" to only have 5 cells tha twould cease accepting wate by December 31, 1995. If this discussion is titled "History", then it should describe an accurate history of the landfill with each expanded operation distinctly described and identified by their respective names.
Section 1.0 Introduction, 1.3 Description - Second paragraph, need to be careful when discussing use of the Rapp Road Landfill, this facility not only serve the ANSWERS Planning Unit capactiy, discussions should not give this impression, the current operation is a merchant facility...
A review of the Albany Landfill secondary lectache collection and removal system 30-day average leakage rates from the period 11/23/06 through 10/02/07 reveals only 13 days when those values for cell 10 were equal to or below the 20 gallons per acre per day required by 360-2.7(b)(9)(iv)...
<u>Section 4.0 Unavoidable Adverse Impacts</u>
The proposed landfill expansion is north and norteast/east of the existing active landfill. This expansion project will locate the new active landfill closer to the Fox Run mobile home park and businesses which are situated off Whitestone Rd and Licoln Ave.
Section 4.8 (Air Quality & Ordor Control) states "The odor results show that odor concentrations decrease as distance increases from the active landfilling area." This statement appears to support that there will be noticably be more odor issues to the mobile home park and businesses located north and northeast of the proposed expansion.
1. Department property maps show there is an easement held by the DEC across City lands within the area of the elandfill expansion. This easement was established during the last expansion in order to provide a connection bewteen the Ice Age parcel and Albany Pine Bush Preserve lands to the west. The current DEIS does not discusst he presence of the easement except to show an area labeled: "pedestrain easement". Needed is a discussion of this easement and plans to clearly label NYS as the easement holder as well as assessment of the impact on public users of the easement.
2. The mitigation plan suggests that mitigation work will occur on undecided DEC lands to the east of the landfill, specifically the Ice Age parcel. Further a porition of the porposed mitigation work includes 2.4 acres of Forested Wetland Restoration. This parcel has already been the site of wetland creation work that was done in consideration to federal wetlands located on the State Campus parcel involved in this land swap. Therefore any proposal to modify or alter the wetland mitigation area established would have to also be coordinated with the US Army Corps of Engineers.
3. Figure 2-6 lays out the proposed phasing plans for Habitat Restoration work. The area currently occupied by the trailer is proposed for restoration in Year 2-3 (see p. 2-28). However, 11 remaining residences are found at the site. It is understood that most of these tenant area able to remain until ~2015, while one resident has a life estate. This situation needs to be factored into the restoration timetable and addressed in the DEIS.
Additionally, on p 2-26, the DEIS states the phasing (and pretty much the whole timetable) will be dictated by the availablity of sand. Based on the consultant's presentation at City Hall, sand represents a significant cost factor for the restoration. It is not clear what the City will do to acquire the sands it needs, in the quanities it needs, in order to the complete the habitat restoration as proposed within the time frame specified.
4. The proposed eastern expansion will insert a very high and steep feature into the current and future preserve that is completely unnatural in appearance. In the Wetland Avoidance Scenario (Fig 5-1) the avoidance measures employeed greatly soften the impact. A similiar approach is needed in the preferred eastern expansion alternative discussion and a design which would lessen or naturalize teh appearance of this feature.
8. P 3-46 contains the statement that "all habitats in the expansion area are overgrown and degraded environments". This statement is very misleading as while do not represent the best and most pristine examples of these habitats, they are fully and ecologically fucntion. The forest red maple swamp is a fully function wetland habitat, despite its location in the shadow of the landfill, and despite being continually negatively impacted with windblown trash. The existing wooded north slope of the landfill currently provides a naturally wooded buffer that has habitat value and cannot be quickly replaced if destroyed.
12. P 3-73 Visual impacts - the DEIS needs to present discussion and mapping of specific viewpoint impacts from ajor vantage points in the Preserve. In particular, the views from Blueberry Hill and the Overlook Dune east of the Discovery Center needed to be included in this analysis.
15. The DEIS states on p. 5-27 that without the proposed expansion "a fixed revenue stream would not be guaranteed to the City of Albany". As part of the evaluation of alternatives in the DEIS, the City needs to discuss alternative revenue sources that could replace the landfill revenue and/or reduce the footprint of the expansion area and/or assure that Albany would find a future need to consider any additional expansion proposals to be fully mooted.
