Friends of Stanford Home and preservationists:
For people who are going to make statements at the Tuesday Public
Hearing, below are some points to consider in your statements. They
are offered by one of our researchers.
For those who just are going to join us to support our preservation
efforts, we certainly welcome everyone to come and cheer us on. It
is very critical to show these five Town Board Members that there
indeed is a lot of support to keep the land and mansion as it is.
Your body counts. We will make a body count for the record. Bring
it and your good mind to help. 7 p.m. on Tuesday, January 23.
Send this on to people whom you think might want some activity other
than watching the US President's State of the Union presentation.
We all have a right to state opinions on something so beautiful and
so a part of what we like to see in our communities of upstate New
York.
Linda Champagne
346-8316
----- Original Message -----
Sent: Saturday, January 20, 2007 9:48 PM
Subject: Ingersoll Suggestions and Observations
Hi all,
Highbridge’s revised Environmental Assessment Form (EAF) shows that they
will need the following New York State Permits: NYSDOT for curb-cuts and NYSDEC
for a SPDES permit for Stormwater Discharge.
For the proposed project, DEC considers it a minor project. Nevertheless, the
SPDES website would seem to indicate that it would trigger a review by SHPO.
The website states:
“If a project may have a significant impact on historical structures or
archaeological sites protected by the State Historic Preservation Act (SHPA),
the DEC must evaluate this impact.” I believe that this is to satisfy SHPO’s
Environmental Review program. The objective of this program is help protect New
York's historic cultural resources from the potential impacts of projects that
are funded, licensed or approved by state or federal agencies.
SHPO describes its role as:
“Under Section 106 of the National Historic Preservation Act
and Section 14.09 of the New York State Historic Preservation Act,
the SHPO's role in the review process is to ensure that effects or
impacts on eligible or listed properties are considered and avoided
or mitigated during the project planning process.”
The problem I see is that, because the DEC as far as the SPDES
permit is concerned, considers it a minor project, the applicant
is not required to send a Structural and Archaeological Assessment
Form (SAAF) with their application. Hence, how will the DEC know
that this is a historic site? If the DEC relies on the EAF they
will not make the referral. The EAF form only asks if the site
contains a building on the State or National Register of Historic
Places.
The EAF does state that the site includes a view known to be important
to the community.
On a DEC Program Policy report titled Assessing and Mitigating
Visual Impacts, it states that in the review of an application
for a permit, Department staff must evaluate the potential for
adverse visual and aesthetic impacts. The policy paper also states
that unlisted aesthetic resources include a property on or eligible
for inclusion in the National or State Register of Historic Places.
I think we should push for such an assessment. One concern is that
this white paper states that in 1999 the Legislature eliminated
the requirement that DEC staff testify with regard to local jurisdiction
needs. This change was related to the placement of power plants.
I am not sure what this means to our situation, but it should be
checked out. Alex do you know an expert in this area.
On a related matter, SHPO will advise local communities on local
preservation environmental reviews, upon request, under the provisions
of the State Environmental Quality Review Act. This review would
be a help to Niskayuna.
I would like to suggest a few action items:
1) Notify the DOT and the DEC as to the historic nature of the
Ingersoll site, and push the state agencies to bring in SHPO to
perform a site review. More than one person may have to write a
letter. I would hate to see a permit approved without the proper
referral. I fear that Ingersoll will fall through the cracks.
2) Find out if the DEC will due a Visual Assessment of the proposed
shopping center on the historic Stanford Home. Such an analysis
is quite involved. I am sure that the current plan would have an
adverse impact on the current site’s aesthetics.
3) As part of the SEQRA and the EIS, residents should press the
town to due a visual assessment study. There is actual a set procedure
for conducting such a study. The advantage of bring it up now is
that it will pressure the town to conduct this study even if the
state won’t.
The argument to conduct a study is clear. Highbridge has proposed
leaving the house and building around it, and the question is,
how much harm the proposed project will have on the historic building.
The visual assessment will provide one measure of the shopping
centers impact. It will also show the town board that more studies
must be done and an EIS should be required.
4) Finally residents should suggest that SHPO be asked by the town
to due an analysis of the property. Such a request is appropriate
given the nature of the project and the goal of SEQRA.
For steps 3 and 4, the more residents that request such actions
on Tuesday, the better.