Comments on the Final Environmental Impact Study
for the Proposed Stadium
Robert I. Rhodes   June 25, 2010

I. The Board of the RLDC is illegally constituted.

I believe this public hearing is illegal, and I would like to explain why this is so.

Preserve Ramapo has been trying to obtain all LDC papers since April 16th. We have also been trying to get the required financial reports (FOILed May 26^th. Why are they unavailable? Under the circumstances it is reasonable to assume that, contrary to state law, this requirement has been ignored and these documents do NOT exist. We also presume that in the absence of contrary information there is no resolution by the RLDC authorizing this project. Can the town of Ramapo approve of a project purportedly proposed by the RLDC when we have no documentation demonstrating that the RLDC actually did make the proposal. Consequently, I wonder what legal authority the Ramapo Town Board has to approve of this project.

There is also a conflict of interest that is so severe that it suggests these proceedings are illegal. First we have the question: Can an elected official both sponsor a project and then sit on the board which has to approve of it. But what makes this conflict of interest even more outrageous is the fact that St. Lawrence is one of three lifetime members of the board of the RLDC. Under state law a member of the board of directors of a local development corporation is not allowed to exert political influence over elected officials. But St. Lawrence IS an elected official. It would seem to me that this makes St. Lawrence’s board membership illegal. Since this board is illegally constituted, any decisions made by the RLDC, or this board, are also illegal.

What is worse is that St. Lawrence has a financial interest in the affairs of the RLDC that is worth several million dollars. He is in a position where he can approve of his salary as a member of the board of directors of the RLDC for his entire life. This is a multi-million dollar decision. How can he pretend that he can objectively evaluate the environmental impact of this project?

II. The FEIS is in reality just a second DEIS.

Every critical question raised in response to the DEIS either remains unanswered, or the response to the question is so tentative that it remains essentially unanswered. The remainder of this commentary deals with these issues.

Why, we must ask, has the response of the town been so weak? Is it that these questions cannot be answered; that St. Lawrence is in such a rush to push this thing through that he doesn’t want to take the time to deal with major issues; or is it that if an attempt were made to address these issues, it would become obvious that satisfactory answers cannot be made?

III. Parking

Parking is a critical issue. The proposal expects a maximum attendance of 5,000 persons with an average of 4 persons per car. This is clearly overly optimistic. The plan calls for 900 parking spaces with an overflow of 300 cars on grass fields. This yields a total capacity of 1200 cars. But if we assume, MUCH more realistically, that we will have an average of 3 persons per car, we will need 1,666 parking spaces. The authors of the FEIS apparently have no experience parking folks on grass. Even moderate rain will render this parking area unusable. Moreover, if it starts raining during an event, this area will become a sea of mud

In response to comments by KLD engineering the plan argues that more parking would constitute "overdesign." This is not a satisfactory response. A maximum attendance of 2,700 would be far more realistic. Unfortunately, since Ramapo never bothered to create a business plan, we have no idea what the economic impact of such a limitation would be.

Will there be parking fees and what impact will the collection of these fees have upon traffic on Route 45 and Pomona road? The plan simple says:

This too is not an adequate response to a critical question.

IV. Exiting

The plan assumes that 3500 persons can exit in one hour. Where is the mathematical model demonstrating this is realistic? What would happen if an emergency evacuation were necessary? This issue is raised more fully below.

V. Emergencies

What would happen if there were an unexpected hurricane or tornado warning? What would happen if emergency personnel had to rush to the Emergency Operations Center in the Fire Training Center at the same time that there would be a need to evacuate the stadium? Why hasn’t the possibility of panic been considered?

The FEIS concedes that emergency issues have not been addressed. Instead, on page 6 of the comments section we find:

An agreement between the Town and the County will address emergency traffic and accommodate the needs of the Fire Training Center in case of an emergency.

This is a most inadequate response to an absolutely critical issue. The FEIS should have presented a series of possible scenarios and an adequate response to each of these!

VI. Environmental Issues

Many important environmental issues are raised in the five page letter sent by Allan Beers, Rockland County’s Coordinator of Environmental Resources, to Ramapo in response to the DEIS. Most of these issues are simply ignored in the FEIS response. For that reason I am resubmitting his letter this as part of my FEIS comment.

Mr. Beers notes that "the plans are unclear as to the drainage pattern on the site and should be more clearly defined." They remain unclear.

He suggests that drainage storage systems should be installed under the parking area. This suggestion is ignored.

Parking lots are contaminated by oil leaking from cars, the overflow of anti-freeze, and possibly other fluids. How will this contamination be handled? This is an important question that becomes especially critical if there are heavy rains, yet the FEIS simply suggests:

A storm water treatment system will be provided for the building, parking lot, and

What are the specification for this system? This is not a serious response to a critical issue.

Mr. Beers recommends that "bio-retention storm water systems be utilized" and that rain gardens be constructed on the perimeter of impervious surface areas. Is this an acceptable proposal? Why isn’t this discussed in what pretends to be a FINAL environmental impact study?

Mr. Beers strongly recommends that "pesticides, fertilizers and salt should be prohibited for use on the grounds and parking areas." This suggestion is ignored. When one considers that most of this site drains into Rockland County’s largest wetland this is an inexcusable failure.

The DEIS states that "Detention facilities will be located outside of all wetland and floodplains." Mr. Beers notes that there is a need for an overlay to verify this claim. Where is this overlay?

The FEIS assures us:

Although the slopes will be altered for the project, compliance with soil

And further:

What are these soil erosion, mitigation, and control procedures? Once again, when one considers that most of the grounds of this proposed stadium drain into Rockland’s largest wetland this a most serious question. They should have been included in the FEIS.

Last, and most importantly, the FEIS claims:

Like Mr. Beers I would also like to see an overlay showing the plan with the located stream. I doubt this is an honest claim. Any displacement or interference with the stream would constitute a serious violation of New York environmental law.

VII. Noise

The authors observe that maximum noise during the eight times during the season when there are fireworks will be momentary. Try telling this to an autistic child who reacts badly to noise, a normal child who is afraid of thunder, or a nervous dog. We should remember that the folks who bought single family homes that are immediately adjacent to the ball field on the other side of Pomona road did not buy their homes expecting to hear fireworks, the roar of a crowd, or an outdoor public address system that operates for hours at a time.

Respectfully submitted.

Robert I. Rhodes, Ph.D.

Chairman, Preserve Ramapo

[Click here for the full text of Allan Beers' letter, Beers is Rockland County’s Coordinator of Environmental Resources]