The Yorktown Town Board
Town Hall
363 Underhill Avenue
Yorktown Heights, NY 10598

Re: French Hills Golf Course FEIS dated July 17, 2001

Dear Members of the Yorktown Town Board:

Federated Conservationists of Westchester County, Inc. is a 36-year-old organization founded by many organizations and individuals to create a unified voice on environmental matters of regional concern. For the last 36 years, 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 water supply, we are submitting this comment with regard to the final environmental impact statement ("FEIS") with respect to the French Hill Golf Course in the Town of Yorktown.

The golf course site of 155 acres is sited entirely within the New York City watershed which provides water to 9 million people. The waters from the site feed into the New Croton Reservoir which, as part of the NYC system, supplies unfiltered water to 900,000 people daily or 2,000,000 people in times of drought. It lies within the "60 day travel time" framework which measures time from source to the faucet and is generally viewed as the life span of most pathogens in fresh water. Sediment and erosion caused by construction carry pathogens and interfere with the efficacy of the chlorination process making the disturbance of this watershed land particularly sensitive. Moreover, the New Croton reservoir has been listed by State DEC on its 1998 list of impaired water bodies pursuant to section 303(d) of the Clean Water Act. If the water is to remain potable, phosphorus levels and other pollution of the New Croton must be reduced through further protections and not increased by damaging development.

The 155-acre site is currently heavily wooded and contains a 20-acre state delineated wetland. 63% of this total property will be disturbed by the golf course for the creation of greens, fairways, a clubhouse and other buildings. Up to 70% of the forested buffer that now protects the fragile wetland will be encroached upon; the forest will be removed and grasses substituted with a small area set aside for man-made stormwater management devices to replace that function previously provided by the trees and other vegetation. 5% of the wetland itself will be altered to create a golf driving range.

Westchester County has embarked on a multi-faceted program to protect our drinking water quality. As was said this morning at the introduction of the new County web site on water quality protection, "pollution of our water is an ongoing problem with devastating consequences. We must recognize the problem before we have a calamity and each take responsibility to ensure our future." No single site is necessarily determinative on water quality. However, the pollution of our water is composed of constantly increasing discharges of pollution into an already problematic reservoir. The proposed golf course is a piece of a watershed land puzzle in which every piece counts. Every potential disturbance of land in the Croton watershed must be examined with the most rigorous care, with an eye on the cumulative effects on the watershed, to ensure that it does not produce any further impairment of the New Croton Reservoir.

With this in mind, we must ask ourselves whether the golf course as proposed will produce any impairment of the Croton reservoir and further decide whether we even have adequate information to make that determination:

• Can we really credit the FEIS statement that stormwater treatment will "reduce loads to values lower than prior loads" in light of the skewed values used in the analysis?
• Should we rely on the 1987 pollutant removal efficiency numbers used in the FEIS rather than the 2000 figures available and which are based on the significant progress made in stormwater engineering?
• Should we rely on nationwide data for pollution removal efficiencies as set forth in the FEIS rather than site-specific, on pollutant removal efficiencies?
• Is the precipitation figure critical to determining runoff, as it correlates directly with rainfall, used in the FEIS appropriate when it conflicts and is lower than that set forth by the US Department of Agriculture?
• Should the golf course construction be allowed to proceed as proposed when the FEIS states that the maximum cleared at any one time will not exceed 25 acres while the New York State DEC SPDES permit process does not permit more than 5 acres of unprotected soil at a time just because the acres to be uncovered are not all contiguous in this very sensitive area?
• Should we accept the FEIS statement and the calculations based on that statement that the percent impervious will be zero when the figure of 9% impervious is the one referred to these days by experts for golf courses?
• Should a decision be made without the benefit of a submission by the applicant of a complete and detailed site specific Stormwater Pollution Protection Plan to ensure that pesticides and chemical and other pollutants do not pollute the water?
• Should any alteration of the wetland area be permitted to become a driving range given the critical function wetlands serve and the fact that efforts to restore or re-create them are generally unsuccessful?
• Should any encroachment on the wetland buffer area be permitted in such a sensitive area given the function of such buffers and the difficulties associated with the construction and maintenance of stormwater management basins.
• What assurances do we have that construction will be properly supervised and construction halted if environmental issues arise?
• Does the long term oversight by Audubon International (unrelated to the Audubon Society) give us adequate assurance that there will be appropriate supervision of the stormwater management systems post construction?
• Is the diversion of water from Mohansic Lake, which lies within Mohansic State Park, for the benefit of a privately-owned golf course proper, or indeed even legal in light of the Public Trust Doctrine which does not permit the use of parks for non-park purposes?
• Should the needs of millions of people who rely on the Croton watershed for clean, drinkable water be sacrificed for those of a few lucky hundred select members of a golf course?

FCWC urges that unless we are satisfied that we have the information we need to make a fully informed determination and are further satisfied that there will be no impairment of the New Croton Reservoir, we cannot responsibly proceed to allow the golf course to be constructed as proposed.

We thank you for the opportunity to submit these comments.

Respectfully submitted,

Edna Sussman
Executive Director