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City of Hudson Proposed LWRP-DGEIS

FoH and LWRP Task Force Submit Separate But Compatible Comments to Hudson Common Council and DOS At the close of the Public Comment period on March 15, 2010 FoH board president Christopher Reed submitted FoH's formal comments on the proposed LWRP-DGEIS. An FoH-initiated LWRP Task Force, comprised of area residents, also submitted its own statement. Both statements praised the proposed zoning and call for its immediate adoption apart from consideration of the LWRP and DGEIS. Both then emphasize problem areas with the LWRP and DGEIS documents and reflect a similar perspective on the issues. The FoH statement identifies key areas in the documents where there are inconsistencies with state policies and community consensus. These inconsistencies include the omission of a critically important Harbor Management Plan, the absence of a consensus-building process for dealing with conflicting points of view, and a lack of specific recommended actions for the restoration of the South Bay. Instead, the documents display an undue deference to O&G and Holcim, most notably in the recommendation to turn a railroad right-of-way through the South Bay into a trucking route. The statement then draws the following conclusions: The Proposed zoning map is one of the advances in this latest cycle to complete an LWRP. It should be adopted regardless of the fate of the draft LWRP and DGEIS.A missing component that will support the Zoning is a Harbor Management Plan and Map. The LWRP is incomplete without such a Plan.The DGEIS is seriously flawed because it lacks internal consistency with its own premise that the South Bay is “one of the fifteen high priority areas for restoration along the Hudson River.”The DGEIS is incomplete because it fails to include all the proposed trucking alternatives. The omission of Alternative 3D “The South Bay Public Road” delegitimizes the DGEIS.The LWRP lacks a credible plan of action for the incremental restoration of the South Bay starting with wetland and hydrological studies completed before any proposed action is undertaken.Without such studies, there is no basis on which to make a general determination that no mitigation is required for the DGEIS’s Proposed Action as well as the various Alternatives (including Alternative 3D) that impact the South Bay wetland.In the event that significant sections of the LWRP and DGEIS must be redrafted, we strongly recommend that the City form task specific sub-committees. The highest priority areas for community consensus building would be harbor management, South Bay restoration, and transportation. The Task Force Comment deals with many of the same issues as the FoH statement including harbor management, wetlands, transportation, the Broad Street crossing and zoning. Threaded throughout the comments on these issues are found the same observations on the lack of public consensus. The Comment documents a history of revisions to the current LWRP without benefit of public input, and in certain cases, in absolute disregard of expressed public wishes. The Task Force Comment goes on to enumerate various fundamental inconsistencies of the documents particularly with regard to State laws and guidelines. Taken as a whole the comments expose critical omissions as well as unjustifiable conclusions or recommendations made within the documents and describes the ways in which the various issues relate to one another. For example in discussing the highly controversial and widely rejected "Proposed Action" for a new and private truck route that will bisect the South Bay Class I wetland, the Task Force has shown it to be inconsistent with State and Federal laws with regard to such wetlands. The Task Force Comments make an important distinction between a plan (the LWRP) and a specific project (Holcim/O&G Truck Road Development Project or HTR). The statement points out that "the inclusion of a specific project (HTR) in the LWRP and DGEIS is inappropriate and incongruous with the manner in which the SEQRA process is done. The HRT project should be removed from consideration as a sub-set of the Plan and considered on its own merits, leaving the LWRP process to proceed to it’s logical conclusion without the confusion caused by the Plan vs. Project dissonance." The Task Force repeatedly demonstrates the need for significant revisions to both documents. Similarly the FoH comments stress the need for additional due diligence by the public as well as State and Federal agencies and provides examples of professional planners and designers with strong track records in community-based consensus building: "Because a local LWRP when voted into law preempts state and federal regulatory authority, it is critically important that the documents satisfy the criteria of alignment with state policies and establishment of community consensus. It has been 23 years since the first efforts to create an LWRP began. That length of time testifies to two conditions: a unique mix of conflicting interests at work within the waterfront domain and a historical pattern of avoiding consensus building approaches in favor of more traditional top-down short cuts to decision-making." In this context Christopher Reed noted that "Every day of studying these documents and researching the issues has turned up important new information. These discoveries confirm that the documents need substantial revision in key areas before they can be adopted." "Friends of Hudson stands ready to work in good faith with the DOS, the City government and all interested constituencies and individuals," Reed said. "Our goal is to see the creation of a set of documents that will enhance this incomparable waterfront and protect it for the use and enjoyment of future generations." ###For a map showing the South Bay Road (the preferred alternative that was lamentably not considered by the authors of the proposed LWRP.) For more information or to get involved with ongoing activities: Christopher Reed, FoH,, 518-672-7743 Michael O'Hara, LWRP Task Force,, 518-828-4369