Karen Shultz, Airport Co-Chair
Julius Shultz, Airport Co-Chair
Westchester county airport non-expansion
Below is a reprint of a petition sent from DEP Commissioner Christopher O. Ward to Michael Kaplowitz, Chair of the Westchester County Legislature. The letter points out the potential impacts on the NYC water supply if the de-icing facility and tree clearing proposals were to be accepted. Please help us stop airport expansion by contacting your County Legislator, Michael B. Kaplowitz, 26 Lalli Drive, Katonah, NY 10536. Office #: 995-2848.
October 4, 2002
Michael Kaplowitz, Chair
Westchester County Legislature
Michaelian Office Building
148 Martine Avenue
White Plains, NY 10601
Re: Westchester County Airport
Buffer Zone Tree Clearing and Proposed De-icing Facility
Dear Mr. Kaplowitz:
In past years, the New York City DEP and Westchester County have worked cooperatively to ensure that operations at Westchester County Airport are conducted in a manner that fosters protection of the nearby Kensico Reservoir. We appreciate the county’s efforts in this regard. However, I am writing to you now to express our concern about two pending projects at the airport that appear to effectively expand capacity of facilities at the airport and point towards an expansion of flight operations. As such, they may threaten the reservoir and run counter to the work we have done together in the past.
1. Proposed Clearing of Five Acres in the Kensico Reservoir Buffer Zone
We believe that the proposed clearing of nearly five acres in the proposed “Water Quality Buffer” to create a sight path between the Airport control tower and new taxi ways is a project that has both potential direct and secondary impacts on the New York City water supply that have not been adequately assessed, and on that basis, DEP is not prepared at this time to issue approvals or permits for such work to proceed.
This specific action has not received adequate environmental review, either in the 1987 Environmental Assessment/Generic Environmental Impact Statement (EA/GEIS) of the Westchester County Airport Master Plan Update, to which the Westchester DOT referred in the September 4, 2002 letter of Robert J. Bracchitta, nor in the more recent 1996 Draft EIS on the Master Plan Update. Environmental review of the impacts of the taxiway itself was not completed in the 1986 DEIS, and to the extent those impacts were addressed in the 1987 EA/GEIS, we are concerned that such reviews are no longer timely. In the last 15 years there have been significant changes in the structure of the New York City water supply, regulatory requirements, land uses in the Kensico Basin, and in regional air traffic patterns. We believe that a new Environmental Impact Statement is necessary to properly analyze, assess and address the impacts, both direct and indirect that may stem from the proposed project.
Since the first EPA Filtration Avoidance Determination (FAD) in 1993, the Kensico Reservoir has assumed greater importance as the terminal holding reservoir for two unfiltered water supply systems. As the final link in the unfiltered systems which serves dozens of Westchester communities along with New York City, the Kensico is subject to the requirements of the FAD, under which more vigilant environmental impact review is explicitly mandated. The quality of water in the Kensico is crucial to the City’s ability to continue to operate the Delaware and Catskill systems as unfiltered systems. Second, since 1987, and even since the 1996 Draft EIS on the Master Plan Update, under the 1997 New York City Watershed Memorandum Agreement, the New York City Department of Environmental Protection has acquired new regulatory responsibility. DEP must now review and grant approval of a stormwater pollution prevention plan (SPPP) before any land clearing or land grading project involving two or more acres located at least in part within 300 feet of a reservoir or within 100 feet of a water course may proceed. See 15 RCNY§ 18.39(b)(3)(iv). Third, in the last decade there has been extensive development in the Kensico basin, putting additional stress on the basin and reducing the Reservoir’s capacity to assimilate pollutants from the airport. Fourth, there has been a growing recognition of the importance of pollutants carried in runoff as a substantial contributor to water quality degradation. As a result, EPA has required and the State has implemented comprehensive stormwater management and control programs under the federal Clean Water Act and New York State law. This increased focus on and understanding of problems caused by stormwater runoff postdates the assessment performed in the EA/GEIS, or even in the 1996 DEIS. In light of the increased sensitivity of the resource, the increased stress already upon it, and the new regulatory responsibilities with which we are entrusted, we believe the direct impacts of the proposed land clearing on the Reservoir from stormwater runoff, erosion, and other pollutants must be thoroughly reevaluated.
Of equal, if not greater concern, are the secondary impacts of such an action from increased airport operations. These secondary impacts on water quality in the Kensico Reservoir include increases in automobile and commercial traffic to and from the airport, increased demand for parking and road widening to accommodate such ground traffic, with attendant increases in impervious surface and stormwater runoff, and impacts from aircraft and aircraft handling, including fuel and other chemical spills and emissions from aircraft over the Reservoir and its watershed, as well as increased risk of aviation accidents in or around the resevoir. Increased airport operations may also lead to further expansion of corporate headquarters and office parks in the Kensico basin, and along with that, increased commercial and residential development, each of which in turn will create more impervious surface, increased run off and contamination and increased loads on waste water systems. All of these potential secondary impacts must be thoroughly assessed in light of current knowledge, concerns and regulatory requirements.
In addition to thorough analysis of these secondary and growth inducing impacts, environmental review of the proposed land clearing must also properly situate this project in the context of other related projects that may also tend to increase Airport capacity and flight operations, such as the proposed de-icing facility, so that their cumulative impact may be properly assessed and avoided or mitigated.
Without an updated environmental review addressing both the direct and secondary impacts, that fully examines all possible alternatives and identifies full and adequate reasonable mitigation for secondary as well as direct impacts, we can not at this time approve the land clearing.
2. Proposed De-icing Facility
The proposed de-icing facility is also a cause of concern for us. While we appreciate the County’s proposal to locate it at the southern end of the airport, outside the Kensico basin, we are nonetheless concerned with both the potential direct and secondary impacts of this project.
With regard to direct impacts, despite whatever is done to collect over-spray and route stormwater out of the watershed, we are nonetheless concerned about the potential for deicing fluids shed by planes taking off over the reservoir basin entering the Reservoir. While we appreciate the environmental advantages of infrared heating of aircraft enabling some decrease in the volume of de-icing chemicals per plane, we are still concerned about the total number of planes treated. If the four bay facility planned enables increases in flight operations it may well result in no reduction in chemical use and may even result in a net increase.
We are also concerned about groundwater contamination from the de-icing facility, which even if sited at the southern location could still, under low water level conditions, bring contaminants into the Reservoir through groundwater. We urge Westchester County to continue its effort to determine groundwater flow patterns and fully identify and remediate all groundwater contamination at the airport.
As with the buffer zone land clearing, we are equally concerned with the secondary impacts. The four bay facility proposed would appear to enable a significant expansion of airport operations beyond the current number of flights. As discussed above, such an expansion of operations could have detrimental direct impacts on the watershed and in turn induce infrastructure development and other development that would have further impacts beyond that. At its present proposed scale the de-icing facility appears to represent part of a larger plan to expand Westchester County Airport that has not been adequately reviewed for environmental and public health impacts. We are further concerned that the de-icing facility as proposed may be located off the original footprint authorized in the 1987 review of the original master plan. This in itself is a cause of concern as it would establish a precedent for further development outside of previously approved bounds.
Because of its unique location and the impacts it already has on the surrounding environment, including the water supply, we have serious reservations regarding any proposal that would result in an expansion of the Airport, or an increase in its level of operations. Any expansion of the airport or its operations may have a significant impact on the water supply and therefore raises the prospects of an unacceptable risk to public health.
We therefore ask that the County’s Environmental Impact Statement clearly identify any way the clearing of trees and subsequent use of the taxiway, together with the proposed deicing facility, will contribute to an increase in airport flight operations capacity. If these projects are found to contribute to an increase in Airport capacity, it is important that alternatives be offered that will either avoid or mitigate subsequent increases in the number of flights, gates, hangar capacity, parking or use of heavier planes induced by the new taxiway and deicing capacity. If no increase in capacity is found, we would expect to see measures incorporated in design and operation that will insure that capacity will remain limited. Permits could incorporate conditions and limitations consistent with that principle.
We also request that at this stage you provide us with clear maps, exact plans, specifications and architectural drawings for both projects as proposed, so that we may have time to properly analyze them before responding to a DEIS on either or both. We also request the opportunity to conduct a site walk with County staff so that we can better understand the information we have been provided.
And finally, we ask for the County’s support in asking the Federal Aviation Administration for an exemption of Westchester County Airport from any present or future federally mandated airport expansion programs on the basis of its unique location next to critical drinking water supplies.
I very much appreciate your time and consideration. While we are sensitive to the economic role played by the Airport, we are concerned that the environmental impacts associated with the projects as currently proposed not outweigh the benefits they might otherwise yield. We would be more than willing to meet with you to explain our concerns in detail, and to explore other options that might help the County improve management of the airport while at the same time avoiding such impacts. I look forward to hearing from you.
Christopher O. Ward
cc. Andrew J. Spano, Westchester County Executive
Joel Russel, Airport Manager, Westchester County Airport
Gina D’Agrossa, Director of Environmental Planning, County of Westchester
Erin M. Crotty, Commissioner, New York State Department of Environmental Conservation
Ron Tramontano, Director, Center for Environmental Health, New York State Department of Health
Jane Kenny, Director, U.S. Environmental Protection Agency, Region II