ALBANY: The Final Environmental Impact Statement submitted
by the developer for the proposed Residence Inn is so inadequate,
it is appalling. The Albany Common Council must reject
this document as incomplete. In analyzing this document,
it is difficult to choose which area of inadequacy to attack
first.
Disappearing Letters
First, the FEIS omits
two of the most damning letters, one form the US Fish and
Wildlife Service and the other from Dr. Kurt Johnson, a lepidopterist
who commented on the project at the request of Save the Pine
Bush. Where did these letters go? Why was it these two particular
letters that were left out? Save the Pine Bush finds it very
suspicious that the two most critical letters were missing
from the FEIS.
The US Fish and Wildlife Service letter concludes that
Karner Blue butterflies are likely to use the site and the
US Fish and Wildlife Service asks to be allowed to visit
the site in order to make a determination (see related article).
Karner Blue
The other missing letter is from Dr. Kurt Johnson, who wrote
an extensive letter explaining why this particular site is
so important to the survival of the Karner Blue. Unlike the
developer’s expert, Dr. Futyma, who is a vegetation
ecologist, Dr. Johnson is an expert in lepidoptera, with
a particular interest in the Karner Blue butterfly. Dr. Johnson
is recognized as the lepidopterist who completed the unfinished
scientific work of Valdimir Nabokov (who named the Karner
Blue) in the book Nabokov’s Blues: The Scientific Odyssey
of a Literary Genius.
The developer’s contention is that there is a linear
corridor for the butterflies to use between the Crossgates
butterfly hill and the main part of the Preserve, and that
it would be a bad idea to encourage the butterflies to use
the parcel where the hotel is proposed.
Dr. Johnson believes this parcel of land is very important
to the survival of the butterfly and discusses at length
the science behind his opinion. Dr. Johnson explains that
Karner Blues are “patrolling species”, meaning
that individual butterflies actively move away from their
larval foodplants, sometimes a significant distance in order
to find nectar sources and to find mates. In addition, the
blue lupine, the larval foodplant of the Karner Blue is a
nomadic invader species, which requires ample and random
space to move around and colonize new locations.
Dr. Johnson questions the linear corridor concept discussed
in the FEIS. In the native habitat, random dispersal, especially
wind driven dispersal are more common. That is why, wide-open
areas are better for the Karner Blue than linear corridors.
This parcel is important to the butterflies.
Dr. Johnson concludes by stating, “This further increases
my view that extreme caution must be used with regard to
any kind of argument for further development, in this case
particularly in the constricted area around the Residence
Inn parcel . . .”
The FEIS does not make any substantial reply to Dr. Johnson’s
science.
Water Pollution
The developer goes to great length to minimize the importance
of the Pine Bush aquifer, which is a principal aquifer. A
principal aquifer is one that has enough volume and flow
to be used as a municipal water supply. The Pine Bush Formation
(as the aquifer under the Pine Bush is called) was designated
a principal aquifer by the New York State Department of Environmental
Conservation in 1986 in accordance with regulations written
to comply with the Clean Water Act.
The developer responded to Save the Pine Bush’s concerns
about polluting the aquifer, by stating that principal aquifers
are “not intensively used at present for municipal
water supply” and that the Pine Bush is not a “sole
source“ or “primary” aquifer. The developer
points out that principal aquifers underlie 11.2% of New
York land. With these statements, the developer is attempting
to minimize the importance of the Pine Bush aquifer. Just
because the aquifer at this time is not used for a municipal
water supply, does not mean that its OK to pollute it. There
may very well come a day when the Pine Bush aquifer will
be needed, and at that time, we will have wished we kept
it clean!
Two types of pollution can be expected from the parking
lot of the proposed hotel: salt and pollutants from cars.
The plan calls for using two or three recharge basins (depending
on whether you are reading the map or the appendix) to take
care of the water.
According to the NYS Department of Environmental Stormwater
Management Design Manual, recharge basins are not adequate
to treat the run-off from the parking lots and building roofs.
Recharge basins are only effective when used for managing
water volume; they are not effective for removing pollutants.
Because of the importance of protecting the Pine Bush aquifer
from pollutants, the FEIS should not be accepted as complete
until the developer establishes how pollutants will be removed
from the water.
Air Pollution
The proposed hotel will be located in a “nonattainment
area”, meaning that the air does not meet federal clean
air standards. The FEIS states that because the proposed
hotel is located in a nonattainment area, more traffic won’t
make the air any worse. In other words, the air is already
polluted, so it doesn‘t matter that more cars will
make it more polluted.
Walking or bicycling . . . should be discouraged
Perhaps the most outrageous statement (in a document full
of outrageous statements) is that “walking or bicycling
. . . should be discouraged” As Claire Nolan, Save
the Pine Bush member and bicyclist extraordinare, pointed
out at the Common Council committee meeting on this issue,
that she belongs on the streets on her bicycle and that means
all streets.
The developer be required to improve the public safety
of a road, rather than try to restrict public access to a
public road.
Conclusion
The Pine Bush is no place to build a hotel. Hotels should
be built downtown.
Save the Pine Bush asks that the Albany Common Council
reject this FEIS for the proposed Residence Inn hotel as
incomplete. The Common Council should require the developer
to invite the US Fish and Wildlife Service onto the site
to determine whether the Karner Blue Butterfly occupy the
site.
Published November/December 2005
