Written Comments for FBC Wetlands Permit Due 8/13/15!

This is an urgent call to action: we have a deadline approaching to submit written comments regarding the Faith Bible Church Department of Environmental Conservation permit application to--among other things--lay a sewer pipe through Mohegan Lake.  Here's link to the DEC Notice and here's what we need you to do.Email the DEC engineer reviewing the application with your concerns.  Her name is Rebecca Crist and you can email her at rebecca.crist@dec.ny.gov (again, we're coming up on a hard deadline this Thursday). Let her know all of your concerns regarding the environmental impacts.  For example:


Rebecca Crist
DEC Region 3
Division of Environmental Permits

Re: Faith Bible Church DEC Application #3-5554-00298/00001

Ms. Crist,

I am writing to you to express my concerns and raise questions about the subject application.  The development site is immediately adjacent to our 110 acre lake and 20 acre wetland outflow which are both Class 1 wetlands.  The lake has chronic blue-green algae problems and this particular site is prone to severe flooding.  There are several environmental issues I believe need to be addressed.  Before I begin, I would like to note that the description of the project on the DEC notice is different than the Planning Board application.  The DEC notice  says the applicant's proposed disturbances are for the "the reconstruction and expansion of an existing church and its associated parking and utilities."  In fact the existing church will be demolished, along with two single family homes, to build an approximately 8,000sf new building; this project is a new development, for the record.  That said, I have the following comments and questions:  

1. The project proposes running a sewer pipe under Mohegan Avenue from the church to route six, it will have to sit below the water table.  It appears that DEC regulation 663.4(d) prohibits a new sewer utility as permitted activity within a Fresh Water Wetland (see line item 37 in the activities chart in said section).
2. Where the pipe has to go up and over the culvert, it will be in PVC pipe-within-a-pipe with heat-trace (think a little wire that tries to keep the pipe from freezing during our long, cold winters).  This is a disaster waiting to happen.  Is there redundancy and alarm monitoring in this system?  Do the DEC regulations really allow a new sewer pipe vulnerable to freezing and physical damage through a Class I wetland?
3. That section of Mohegan Lake (where the sewer is proposed to run) is literally the only thing that separates the 110 acre lake from a 20 acre wetland/pond.  Those bodies of water are hydro-logically connected and the sewer will have to be placed within that system.  There is an alternative route to a sewer tie-ins that avoids the wetland buffer down Sagamore Ave, albeit a slightly longer run, but it routes it away from the lake and wetland buffer. 
4. The impervious area increases in this proposal.  There are serious drainage issues in this corner of the lake, literally right in front of the church as it stands.  Will the increase in impervious area compound this problem?
5. Complete elimination of the 100 foot wetland buffer is unacceptable.  The parking lot across the street provides no (0') buffer from the adjacent 20 acre wetland.  Providing even a few feet 20-30' would better protect and screen the wetland from both the parking lot and lighting.  The class I wetland outflow is a sensitive ecological area with blue heron and turtle nests, among many other flora and fauna.  Surely complete and total elimination of the required wetland buffer is not in the best interest of the health of our lake and wetland.  I respectfully request that the largest buffer possible be maintained to respect our sensitive wetland.  Considering that 100' is the minimum, zero feet is a very, very hard pill to swallow.

I thank you for your careful review of the application and thoughtful consideration of my concerns and questions in light of the beautiful lake our community cares deeply about and is desperate to conserve for future generations.

Kind Regards,

[Mohegan Lake Resident]
[Address]
[Phone]