September 14, 2001

Mr. Alexander F. Ciesluk, Jr.
Deputy Regional Permit Administrator
New York State Department of Environmental Conservation
21 South Putt Corners Road
New Paltz, New York 12561-1696

Re: Seven Springs Golf Course

Dear Mr. Ciesluk:

Federated Conservationists of Westchester County, Inc. is a 36-year-old organization founded as a coalition of many organizations and individuals to create a unified voice on environmental matters of regional concern. FCWC has worked on protecting wetlands, habitat and parks, ensuring adherence to environmental regulations, and protecting and enhancing Westchester's natural resources: the Hudson River, Long Island Sound and the New York City watershed.

Because of our concern for a clean and safe drinking water supply we are submitting this comment with respect to the completeness of the application of Seven Springs L.L.C. for a State Pollution Discharge Elimination System (SPDES) permit for the linear absorption system (LAS) proposed for the treatment of pesticides and runoff at the Seven Springs Golf Course in the towns of Bedford and New Castle.

The Seven Springs Golf Course is located on a hill-side above Byram Lake Reservoir, the major source of drinking water for the Village of Mount Kisco. Run off from Seven Springs will also be received by the New Croton Reservoir, part of the New York City watershed. These two sources of drinking water must be protected from pesticides and nutrient contaminated storm water runoff. There is no question that the construction of the golf course will require thousands of trees to be removed, natural wetlands to be destroyed, substantial new impervious surfaces added, and new storm water paths to be created. There is no question that storm water runoff from the golf course will be contaminated with nutrients and pesticides. There is, furthermore, no question that the LAS, as specially designed for the Seven Springs Golf Course, has never been used before and is untested. Thus it is impossible to determine whether or not the LAS will successfully treat pollutant laden runoff. Under these circumstances we urge you to declare the SPDES permit incomplete until evidence in the form of actual performance data is proffered by the Applicant.

Traditional golf course management utilizes pesticides heavily. The Applicant's FEIS itself states that 26 pesticides may be used; the calculations in the FEIS further show that the health advisory levels for five of those pesticides could be exceeded in the storm water runoff. Both Byram Lake and the Croton Reservoir are critically sensitive to increased nutrient loads. The Applicant submitted no empirical data or information to support the claim that the LAS will work to adequately remove pesticide and nutrient contamination.

In light of the threat to two sources of drinking water, it is requisite that new processes and technologies such as those proposed be pilot tested before relying on them. The project sponsor is currently building a golf course in the neighboring community of Briarcliff Manor that does not abut a source of drinking water. This would be an eminently suitable place to test the LAS prior to its use in Seven Springs to ensure the continued quality of the drinking water.

It is the Applicant's obligation to provide information sufficient to enable the DEC to evaluate the efficacy of the proposed treatment measures and determine levels of pollution. Such information has not been provided for Seven Springs. Accordingly, Federated Conservationists urges that the application be deemed incomplete until evidence based on actual performance data sufficient to make that evaluation is submitted.

Sincerely,

Edna Sussman
Executive Director