CRITIQUE AND RECOMMENDATIONS FOR GROUNDWATER SECTION
OF
EAST HAMPTON'S COMPREHENSIVE PLAN

Prepared by Sue Avedon & Cile Downs
in co-operation with the "Environmental Subcommittee" for East Hampton's Comp. Plan


The Environmental Sub-committee commends Dr. Koppelman's recognition of the importance of water protection in the planning for the future of East Hampton. His statement that "future growth has to be controlled within the parameters of maintaining a sustainable(water) supply…" that water is "…the controlling factor in how much growth can occur…" and that water protection is the "…linchpin to the entire comprehensive plan" reflects the strongly held view of this sub-committee. We also agree with some of his specific suggestions such as Town acquisition of woodland to be kept as open space, golf courses as non-permitted uses, mandatory clustering, limitation of commercial and industrial uses, and programs for the removal of underground fuel tanks.

The following comments, however, will address areas and issues which we believe fall short of Dr. Koppelman's charge of planning strategies which will ensure water protection for East Hampton:

  1. November 3, 2000 Town Board Resolution
     This resolution came about following the Town's refusal to place a Groundwater Management Plan as a referendum on the November 2000 ballot, in spite of the fact that 1,417 East Hampton citizens signed petitions to do so. Therefore the expectation of this community was that Dr. Koppelman's much awaited Water Protection report would address each element of the resolution rendering any other Groundwater Management Plan unnecessary.

    The introduction to the resolution reads as follows: "Whereas the Town hired Master Planner, Dr. Lee Koppelman author of the "208 Study" of Long Island's groundwater resources to develop a Groundwater Management Plan ("The Plan" ) for East Hampton as a component of our Comprehensive Plan Update" (emphasis ours)" which will examine innovative measures that can improve groundwater, surface water and forest habitat conservation, including specific attention to zoning, financing, taxation credits, regulatory programs, etc. for example, local golf course management legislation, incentives for residential fuel storage tank removal, enhanced tax credits for gifts of land etc. The Town will analyze the impact of our future maximum build-out population on existing water supplies and address the planning implications of full build-out in terms of long-term water consumption, distribution needs, infrastructure costs, and private well contamination; and

    Whereas The Plan will examine the effectiveness of our present and future land-use tools, which may be used to implement the watershed plan and provide recommendations to mitigate present adverse impacts; and which will identify the actions necessary to enhance contiguous forest habitats, open space conservation, and passive recreational opportunities in the watershed zone. It will offer recommendations to ensure coordination of actions by the Town, County and State in furtherance of the Plan, …"

    We believe that Dr. Koppelman's Water Protection Plan does not fulfill the elements specified in the resolution. Specifically, the following areas were not addressed:
    1. financing- although the report recommends acquisitions, there is no estimated cost of such acquisitions, no methods of financing other than vague reference to partnering with the County or State.
    2. Local legislation to create regulatory programs for golf course management and enhanced tax credits for gifts of land was not addressed,
    3. Impact of future maximum build-out in terms of quantity and quality was not analyzed in detail, distribution needs were not addressed, infrastructure costs were not calculated and reference to private well contamination was very general,
    4. The effectiveness of present and future land use tools was not analyzed. Strengths and weaknesses of SGPA and WRO were not discussed nor were there any new and innovative recommendations made for land preservation.
    5. No recommendations were made to ensure coordination of actions by the Town, County and State in furtherance of the plan.


  2. Other Issues which were not discussed in the Plan.
    1. The toxic plume at the East Hampton landfill and recommendations for dealing with it, i.e. is capping or mining recommended and why?
    2. The proposed Green Hollow Woods project which flies in the face of his recommendations regarding prudent activities in SGPAs. Reactions to the fact that the Town is refusing to allow a SEQRA EIS.
    3. No mention is made of the current land use situation on the groundwater divide in the vicinity of "Stony Hill". There the groundwater divide and the thickest portion of the freshwater aquifer sit beneath a sand mine being used as a transfer station, an old filed subdivision map, an asphalt manufacturing plant, a strip development with several "wet" businesses, a contaminated landfill, a sewage treatment facility and a high density affordable housing project. Further, The B&C Golf course which has recently been developed did so with no SEQRA review.
    4. Recommendations for more effective code enforcement.
    5. Recommendations regarding use of toxic chemicals on school and other municipal properties.
    6. Dr. Koppelman suggests on page 8 that accidents which involve substances that could seep into the ground are presently being mishandled, but does not provide specific remedial recommendations. We do have some thoughts about this issue which are noted in the Recommendation section below.
    7. Boundaries for watershed protection were not revised.
    8. Specific point sources of pollution within the Town of East Hampton were not identified; rather, a general description of point source pollution was provided.


  3. Issues which were addressed but with which we disagree.
    1. Water Quantity
      Recent studies suggest that areas which were presumed to have sufficient quantity may suffer from limitations in the future because of global warming. Rising ocean levels have already caused increased salt water intrusion problems. Further, available quantity will be directly affected by quality as noted below.

    2. Reliance on public water supply.
      1. Public wells are periodically closed because of poor or imprudent groundwater management policies; pollution of public wells will limit the source of public water supply which is felt, in the report, to be adequate. Further, several of the locations listed in the report as proposed public well fields (p.3) are in areas that we believe could be in danger of pollution: these include one at the airport (on page 11 the airport is noted as a potentially hazardous (SPDES/Superfund) site and the one at Red Dirt Road which may well be in the path of the plume at the Town landfill.
      2. Dr. Koppelman indicates (on page 4) that the… "SCWA can successfully remove many of the common contaminants." We question the definition of "successfully" and even if the level of contamination is within "acceptable" levels, what about cumulative and/or synergistic effects of small amounts of contaminants. Further, public water contains chlorine which is a carcinogen and which also may potentially interact with other chemical substances in the water.
      3. We believe that public water does in fact encourage development (in spite of Dr. K's suggestions to the contrary on p.26). An example is the Green Hollow Woods project sponsored by the Town Board. The use of public water is the rationale for moving forward on this project even though potential groundwater contamination (in an SGPA) is acknowledged based on the size of the project.
      4. The existence of private wells requires adequate distance between wells and septic systems thus limiting population density.


    3. Montauk
      This section is very surprising in that it is contrary to the experience of most Montauk residents who have lived through water shortages. In fact, salt water intrusion has necessitated piping of water to Montauk. We would like further explanation of the conclusion that Montauk has sufficient fresh water to meet the needs of the residents.,

    4. Management Practices
      We disagree with Dr. K's recommendation that IPM be used in agriculture and golf course management. IPM allows considerable leeway as to when pesticides can be used and decisions may be based on subjective and variable criteria. Equally, if not more important is that IPM is not verifiable. Further, the Plan calls for "stringent efforts" rather than mandating the use of BMPs on existing golf courses. We believe that this very important document, which will be used as a guide for the next 10 to 20 years, should strongly argue for fully organic management practices.

    5. The Ross School
      Dr. K's discussion of the Ross School deals only with the need for an STP. He makes no comments or recommendations regarding the size of the original project and other issues related to the project such as the leveling or breaking up of the contiguous forest that presently exists. Since it seems likely that a new DEIS for this project will be forthcoming, his input regarding those issues is appropriate and important.


  4. Recommendations
    1. It is our opinion that the SGPA map needs to be redone.
      [ A map delineating the location of the groundwater resource should be drawn up based on the best hydrological information we have, and should reflect the location of the resource (e.g. the location of the thickest freshwater portions of the aquifer and the location of the groundwater divide). Current or future land uses should not be considered in developing this base map.
      Based on this groundwater resource map, a second map should be drawn up identifying several groundwater recharge protection areas. These areas should be identified by overlaying the groundwater resource map over the existing land use map and a map identifying known and potential groundwater contamination areas. The goal of this that have the best potential for long term protection of the underlying groundwater resource; in other words, these are the Town¹s best defensible areas. Most of these should straddle the groundwater divide so that contaminated groundwater plumes from offsite are unlikely to migrate into these core areas. They should also have a high potential for preservation or extremely low development. The most stringent land use, zoning and other regulations should be enacted in these core areas to best ensure long term groundwater protection. (All criteria for mapping should be clearly stated.)
    2. There should be a long term plan for protecting the groundwater resources in specific, highly sensitive areas such as "Stony Hill" (see section 2, no.3).
    3. In regard to zoning, the major recommendation made in the plan is 5 acre zoning in the SGPA. We believe that this does not go far enough. We would recommend up-zoning old file maps in sensitive watershed areas, and change of zoning in specific problem areas, all of which need to be identified. One example is one of the most important deep recharge aquifer areas which is off Rt.114 and zoned Commercial/Industrial. At the present time, inappropriate uses such as the airport and gun club threaten the groundwater. If we are to accept the fact that those facilities cannot be moved to other locations, we should have strict guidelines and enforcement regarding management. The Plan does not mention how the airport fuel is currently stored or how to mitigate the impact of lead from gunshot. Recommendations regarding these issues should be made. We feel strongly that non-toxic management of these areas be stressed, and when possible mandated.
    4. In regard to financing, estimated costs of recommended acquisitions should be determined and specific methods of financing discussed. These figures should be compared to additional infrastructure costs of projected build-out. A multi-year project implementation budget, including a long-term funding plan for landfill remediation, land acquisitions, pollution mediation and other projects should be developed.
    5. We believe that the Plan should formally encourage Town sponsored education campaigns and lobbying for the passage of laws (State, County and local) banning or limiting the use of toxic chemicals in designated areas.
    6. In order to keep complete records of all pollution sites and monitor their remediation, we recommend that the position of "Pollution Czar" be created. Ideally, this official should work closely with someone in a parallel position in Southampton to ensure coordination and consistency.
    7. Regarding spill management, we recommend a "neighbor notification" program to be applied to all pollution spills.
    8. The Town should be encouraged to purchase small intervening lots in densely populated areas such as Springs. This would help ensure adequate distance between wells and septic systems and would also provide better recharge in shallow aquifer areas.




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South Fork Groundwater Task Force
PO BOX 2360    Sag Harbor, NY 11963
Phone/Fax: 631 - 725 - 6200

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