Wm. Patrick Madden Steven Strichman Mayor Commissioner of Planning
Monica Kurzejeski Phone: (518) 279-7166 Deputy Mayor [email protected]
Planningn Commission 433 River St., Ste. 5001 Troy, New York 121800
Meeting Minutes December 29th, 2020 @ 6:00 pm
The Planning Commission of the City of Troy, New York conducted a public hearing on Tuesday, 29 December, 2020 at 6:00pm via Zoom Conferencing, in order to hear and decide on proposals for development as follows:
6:05pm – Meeting called to order
Commissioners in Attendance Suzanne Spellen (SS), Barbara Higbee (BH), Anthony Mohen (AM), Sara Wengert (SW)
Commissioners Absent Deirdre Rudolph (DR)
Also in Attendance Andy Brick (Planning and Zoning Attorney), Aaron Vera (Executivve Secretary)
1011 Second Ave. (101.38-9-10) Planning Commission Recommendation to the City Council for Zone Change Kevin Vandenburgh is prroposing a zone change from R-1 (Single-Family Residential Detached, §285-52) to P (Planned Development, §285-57). Pursuant to §285-27 of the City Code a public hhearing is required. The applicant is represented by Jamie Easton, P.E. of M.J. Engineering.
Introduction by Andy Brick and Aaron Vera.
Public comment was provided by the following persons:
(Video timestamp for reference)
(10:50) Andy Arthur - 15A Elm Avenue, Delmar, New York (12:50) Jessica Bennett – 1009 2nd AveDRAFTnue, Troy, New York (20:30) Christianna Bennett – 501 Broadway, Troy, New York
(23:45) Rebecca Martin – Riverkeeper, Kingston, New York
(26:49) Jennifer Schulaner 2161 12th St., Troy, New York
(28:30) Grace Nicohls - 48 Smith Lane, Berne, New York
(32:55) Bethany Yarow – Schoharie County, Waterfall Unity Alliance
(35:10) Bill Studdiford - 311 Richfield Street, Speigletown, New York
(37:45) Christian Grigoraskos - 488 2nd Avenue, Troy, New York
Page 1 of 2 City of Troy Agenda Planning Commission 17 December, 2020
(39:53) Sarah Pezdek - 32 Cobal Avenue, Round Lake, New York
(43:10) Branda Miller - 803 First Avenue, Troy, New York
(45:40) Jenn Baumstein - 114 Pinewoods Avenue, Troy, New York
(47:58) Jessica Holtz – Norwood Avenue, Albany, New York
(50:20) Evangeline Fisher - 9 Cedar Avenue, Troy, New York
(52:50) James Kruegler - 108 3rd Street, Troy, New York
(55:10) Misria Ali - 4th Street, Troy, New York
(57:05) Sheree Cammer - 137 Hedley Road, Wynantskill, New York
(59:05) Stevie Hipwell - 129 4th Street, Troy, New York
(60:50) Keith Hirokawa - 100 Reichards Lane Ext., Wynantskill, New York
(67:15) Waterfall Unity Alliance
(71:00) Adam Fisher - 9 Cedar Avenue, Troy, New York
Open discussion and additional public comments/questions.
BH motion to adjourn public hearing until 28 January, 2021 at 6pm, SS seconded.
Absent Yes No Abstain Recused Deirdre Rudolph X Sara Wengert X Suzanne Spellen X Barbara Higbee X Anthony Mohen X Passed 4-0. DRAFT SS motion to adjourn meeting, AM seconded. Passed 4-0.
Page 2 of 2 Stockbridge-Munsee Tribal Historic Preservation Main Office Extension Office W13447 Camp 14 Rd 65 First Street Bowler, WI 54416 Troy, NY 12180
December 28, 2020
City of Troy C/O Planning Commission 433 River St Troy, NY 12180
Re: Rezoning Riverfront Parcel 1011 2nd St Troy, NY
Troy Planning Commission,
The Stockbridge-Munsee Community Tribal Historic Preservation Office wishes to address the proposed rezoning of the Riverfront Parcel at 1011 2nd St in Troy, NY. The Stockbridge-Munsee Community Tribal Historic Preservation Office operates from its offices here in Troy, NY. We conduct Section 106 and NEPA reviews on Federal undertakings along with all state and local consultation projects. As a sovereign nation, our efforts in Historic Preservation maintain government-to-government relationships and ensure Tribal interests in the Tribe’s ancestral homelands throughout the Hudson River Valley are represented. We wish to address the Tribe’s concerns with the proposed rezoning of the Riverfront Parcel in north Lansingburgh, what is 1011 2nd St Troy, NY.
The Lansingburgh Riverfront Parcel has high archaeological sensitivity and cultural significance for the Stockbridge-Munsee Community. Within the boundaries of the Parcel exists a number of National Register of Historic Places (NRHP) eligible archaeological sites. The recorded Chert Quarries Precontact Site represents immense cultural and educational significance. For thousands of years this site was used for the extraction of resources for Mohican people. Materials from the Chert Quarries Precontact Site have been identified miles away and represent a crucial component of past social trade networks that linked this region to distant Native American communities. The site’s location on the River situates it across from the Mohican village sites called “Unawats Castle” in North Troy and “Moenemin’s Castle” at Peebles Island in Waterford. These sites have been at the center of archaeological research studies on the lifeways of past peoples in the area and a focus for our work in site protection as they represent immense cultural significance. The Tribe’s ancestral homelands continue to be crucial to the living cultural heritage of the Stockbridge-Munsee Community today.
Due to the immense cultural sensitivity for the Tribe and known archaeological sites within the Riverfront Parcel, we are concerned with the current rezoning proposal. We want to bring awareness to the Troy City Planning Commission on the cultural
(413) 884-6029 Email: [email protected]
Stockbridge-Munsee Tribal Historic Preservation Main Office Extension Office W13447 Camp 14 Rd 65 First Street Bowler, WI 54416 Troy, NY 12180
significance of this Parcel. We ask that the board consider its decision to recommend the proposed rezoning of this parcel for future development. The Stockbridge-Munsee Community Tribal Historic Preservation Office proposes to work with the City toward NRHP nomination and ultimately protection in perpetuity of these culturally significant archaeological sites and green spaces for its entire community.
Should you have any questions, please contact me at [email protected].
Sincerely,
Nathan Allison Tribal Historic Preservation Officer
(413) 884-6029 Email: [email protected]
December 29, 2020
By email: [email protected]
Ms. Deirdre Rudolph, P.E., Chair and Members of the City Planning Commission City of Troy c/o Planning Commission 433 River Street Troy, NY 12180
Re: Public Hearing on Planning Commission Recommendation to the City Council for Zone Change (1011 Second Avenue) Kevin Vandenburgh is proposing a zone change from R-1 (Single-Family Residential Detached, §285-52) to PDD (Planned Development District, §285-57)
Dear Ms. Rudolph and Members of the Planning Commission:
Riverkeeper and Scenic Hudson are writing to urge the Planning Commission to recommend against the above-referenced rezoning request. If granted by the City Council, the rezoning from R-1 to PDD would not be in accordance with the recently adopted Realize Troy Comprehensive Plan (2018), as required by N.Y. General City Law Section 28-a(12).
Realize Troy—based on robust public input Urban Strategies, Inc., the planning firm hired by the City to draft Realize Troy, describes the Comprehensive Plan as a three-part community planning initiative developed with a “strong focus on public consultation, both in-person and using a variety of social media channels, and aimed to establish a clear vision and set of action strategies to address both the current and future needs of the City.” Urban Strategies’ website states that the Comprehensive Plan established “a clear community-based vision and action plan to guide the city’s overall development over the next 20 years” and Realize Troy identified “short and longer-term community needs, reinforced and confirmed a set of broadly supported community goals and created a blueprint for future government actions.”1
We bring this to your attention as a reminder that the Realize Troy was created in the context of a robust public engagement process that resulted in an explicit statement of the City’s vision for itself, including the land use future for the subject parcel and surrounding neighborhoods. Realize Troy
1 https://www.urbanstrategies.com/project/realize- troy/#:~:text=Realize%20Troy%20is%20a%20three,a%20city%2Dwide%20comprehensive%20plan.&text=It%20will %20establish%20a%20clear,over%20the%20next%2020%20years. envisions the parcel as remaining in Low Rise Residential use and, in fact, identifies another nearby site as appropriate for the scope and scale of development that would be made possible by this rezoning. As a result, if granted, the requested rezoning would permit three, four-story buildings with between 230 and 250 multi-family units. This scale of development would directly conflict with Realize Troy’s recommendations and the community’s vision for low rise development at the site.
Rezonings must be in accordance with Comprehensive Plans N.Y. General City Law requires that “All city land use regulations must be in accordance with a comprehensive plan adopted pursuant to this section.”2 Further, according to the New York State Department of State (NYSDOS) "New York’s zoning enabling statutes (the state statutes which give cities, towns and villages the power to enact local zoning laws) require that zoning laws be adopted in accordance with a comprehensive plan. The comprehensive plan should provide the backbone for the local zoning law."3
Realize Troy’s vision for the subject parcel The Comprehensive Plan’s Map 14 identifies the subject tax parcel as “Low Rise Residential” (see Appendix A attached to this letter). The parcel is currently zoned R-1 (Single Family Residential— Detached), which permits up to 3.6 dwelling units per acre. Currently, the R-1 zoning would permit up to 36 single family homes on the site. The concept plan submitted in association with this rezoning request proposes approximately 240 multi-family units in three, four-story buildings, a density of 666% above permitted levels and with four-story building heights inconsistent with Low Rise Residential uses.
Therefore, Riverkeeper and Scenic Hudson believe that a rezoning from Single Family Residential to Planned Development District in order to accommodate four-story buildings would not be in accordance with the Comprehensive Plan’s designation of Low Rise Residential and would therefore be inconsistent with N.Y. General City Law Section 28-a(12), as well as NYSDOS guidance.
Other nearby sites are identified as Major Reinvestment Areas Realize Troy identifies “action strategies,” including the designation of seven “Major Reinvestment Areas,” defined as places envisioned by the community as priorities for renewal, neighborhood revitalization and large-scale development. According to Realize Troy:
“Major reinvestment areas are locations in the city in most need of renewal and which also have the potential to accommodate most of the population and employment growth planned for Troy. Strategic initiatives in these areas are intended to catalyze neighborhood revitalization, transform derelict portions of the waterfront and spark economic development. They include large-scale redevelopment opportunities that can result in distinct new employment and mixed- use areas, sites appropriate for significant park and other public realm improvements and areas for neighborhood growth and revitalization.”4
In fact, Realize Troy identifies two Major Reinvestment Areas in Lansingburgh, one of which includes the Hannaford’s parcel immediately to the south of the subject parcel. Realize Troy conceptually proposes redeveloping this site with a large building fronting 126th Street, parking behind the building, and mixed-use 1-4 story residential buildings with required ground floor retail fronting 2nd Avenue (see
2 NY City Law Section 28-a(12) 3 https://www.dos.ny.gov/lg/publications/Zoning_and_the_Comprehensive_Plan.pdf 4 Realize Troy, page 68 Revitalize Troy, page 71 and 72; also attached here as Appendices B-1 and B-2). Realize Troy does NOT propose extending this mixed-use development—nor any high-density development, including apartments as proposed in this rezoning, onto the undeveloped, wooded parcel to the north zoned R-1 and identified in Map 14 as appropriate to remain in Low Rise Residential land use.
Environmental Justice Concerns The subject parcel is located in a New York State Department of Environmental Conservation (NYSDEC)- designated “Potential Environmental Justice Area.”5 According to the NYSDEC’s website:
”Environmental Justice is the fair and meaningful treatment of all people, regardless of race, income, national origin or color, with respect to the development, implementation, and enforcement of environmental laws, regulations and policies. Environmental Justice allows for disproportionately impacted residents to access the tools to address environmental concerns across all of DEC's operations.”6
The NYSDEC’s definition of Environmental Justice includes the Indigenous Peoples (Native Americans) who lived here before the coming of the Europeans and who still live in New York today. It is our understanding that representatives of Indigenous Peoples have expressed historic ties to the subject site, which is eligible for listing on the National Register of Historic Places. In fact, the applicant’s Project Narrative indicates there are eight locations of archaeological artifact concentration on the site.7
Given this unique set of circumstances—the parcel’s well-documented archaeological sensitivity, Indigenous peoples’ concern for the site, and its location in a State-designated Potential Environmental Justice Area—Riverkeeper and Scenic Hudson urge the Planning Commission to take seriously comments and concerns expressed by representatives of Indigenous peoples with ties to the site.
Conclusion During the development of the Realize Troy, undertaken with robust public involvement and adopted by the City Council just two years ago, it was not anticipated that the undeveloped, wooded parcel at 1011 2nd Avenue would be an appropriate place for intense development, in this case approximately 240 multi-family units—an increase in density of 666%. In fact, Realize Troy specifically includes this parcel in the “Low Rise Residential” land use category and the rezoning request would permit four-story buildings. In light of the above Riverkeeper and Scenic Hudson urge the Planning Commission to recommend against the application to rezone Tax Parcel Number 70.64-1-1 on 2nd Avenue from R-1 (Single Family Development) to PDD (Planned Development). Such rezoning would not be in accordance with the Comprehensive Plan as required by N.Y. General City Law Section 28-a(12).
Finally, given the well-documented archaeological sensitivity of the site, concerns raised by representatives of Indigenous peoples, and the site’s location in a Potential Environmental Justice Area, we urge the Planning Commission to take seriously comments and concerns expressed by representatives of Indigenous peoples with ties to the site.
Thank you.
5 https://www.dec.ny.gov/docs/permits_ej_operations_pdf/rensselaerej.pdf 6 https://www.dec.ny.gov/public/333.html 7 Project Narrative for Second Avenue; MJ Engineering & Land Surveying, PC; October 28, 2020; Exhibit 5- Archaeological Concentration Plan, C-2 on page 17
Sincerely,
Jeffrey Anzevino, AICP Christopher Bellovary Director of Land Use Advocacy Staff Attorney8 Scenic Hudson Riverkeeper
Attachments Appendix A Appendix B-1 Appendix B-2
8 Christopher Bellovary is in the process of applying for licensure in the State of New York and currently licensed to practice law within Washington State and Wisconsin (WSBA Member 37657, WisBar Member 1052534). From: Christopher Bassett [mailto:[email protected]] Sent: Saturday, December 26, 2020 9:11 PM To: Steven.Strichman Subject: Follow the law re: 1011 2nd Ave development
Dear Planning Commissioner Steven Strichman,
My name is Chris Bassett. I live at 379 4th St. in Troy. I write to you with deep concern over the proposed rezoning and associated development of 1011 2nd Avenue in Lansingburgh. However, what is truly worrisome is that the City of Troy is currently not following the law in assessing the proposed development.
I am writing you in the hopes that you will take action as soon as possible to:
Make it the highest priority to preserve the nationally significant indigenous heritage site at 1011 2nd Avenue. I respect Troy’s need for economic development, but the city must prioritize its role as a steward of a site of unique importance to Mahican peoples. This site is 5,000 years old and has been recognized as eligible for listing on the National Register of Historic Places. Its preservation must be the highest priority. Rezoning the property would be inconsistent with Troy’s 2018 Realize Troy Comprehensive Plan. The Comprehensive Plan was an expression of the community’s vision for the city, and the community did not envision dense multi-unit housing on Troy’s northern waterfront. At a minimum, the City is required to amend its Comprehensive Plan if it intends to change the zoning in a way that is contrary to the plan. Ensure that the law is followed. For a project of this size, rezoning can not be considered separately from the proposed development itself. As required by the State Environmental Quality Review Act (SEQRA), when a developer with a project of this size requests to rezone a property, the rezoning is a reviewable action under SEQRA. The developer must also identify the zoning change it needs as part of the project’s Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified from the start in the EAF so that the potential environmental impacts associated with them can be considered together. Because this zoning change would also require a Comprehensive Plan amendment, that too must be identified in the EAF. To consider these decisions separately would be “segmentation”, contrary to the intent of SEQRA.
In this case, it is clear that all three actions — a Comprehensive Plan amendment, rezoning, and the proposed development itself — would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review by a designated lead agency.
The Commission should recommend against rezoning the property as being premature until the developer has submitted an EAF and the City has made a SEQRA determination.
Thank you for your consideration,
Chris Bassett 12/26/2020 James.Rath
From: Christianna Bennett
Attn: James Rath Assistant Planner City of Troy c/o Planning Department 433 River Street Troy, NY 12180
December 28, 2020
Dear Assistant Planner Rath,
My name is Christianna Bennett. I live at 501 Broadway in Downtown Troy. I am writing to you with concerns about the proposed rezoning and associated development of 1011 2nd Avenue in Lansingburgh. However, what is innumerably more worrisome to me is the idea that the City of Troy is not following the procedure of the law in assessment of the proposed development.
I am writing you to urge you take action as soon as possible to correct the potential missteps associated with this project, most importantly:
Addressing the issue with Rezoning the property, which would be inconsistent with Troy’s 2018 Realize Troy Comprehensive Plan. The Comprehensive Plan was an expression of the community’s vision for the city. The inhabitants of Troy did not envision dense multi‐unit housing on the Hudson’s northern waterfront. At a minimum, the City is required to amend its Comprehensive Plan if it intends to change the zoning in a way that is contrary to the plan. This is incredibly important to adhere to. Call on the Planning Commission and City Council and ensure that the law is followed. For a project of this size, rezoning cannot be considered separately from the proposed development itself. As required by the State Environmental Quality Review Act (SEQRA), when a developer with a project of this size requests to rezone a property, the rezoning is a reviewable action under SEQRA. The developer must also identify the zoning change it needs as part of the project’s Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified from the start in the EAF so that the potential environmental impacts associated with them can be considered together. Because this zoning change would also require a Comprehensive Plan amendment, that too must be identified in the EAF. To consider these decisions separately would be “segmentation”, contrary to the intent of SEQRA. As a professional in Architecture and Landscape Architecture with degrees from Rensselaer Polytechnic Institute and the Harvard Graduate School of Design, as well as extensive experience designing for projects throughout the Capital Region and the Adirondacks, understand that it is imperative that the correct environmental procedures and community 1 engagement are followed in this, and all projects. It would be a massive professional and ethical oversight of the Planning Commission and of the City to not follow proper SEQRA procedures. Furthermore, it is negligent, if not outright dismissive of our shared environmental responsibilities to fail in advancing, or at the very least following‐through, with the City upholding roles and responsibilities in following the law on a parcel of land this integrally connected to the Hudson River; much less at a moment in time when public engagement for the revitalization of our shared resources is both highly supported and much needed. Make it the highest priority to preserve the nationally significant indigenous heritage site at 1011 2nd Avenue. While I can respect Troy’s need for economic diversification, the city must prioritize its role as a steward of a site of unique importance to Mahican people and their heritage. This site is 5,000 years old and has been recognized as eligible for listing on the National Register of Historic Places. Its preservation must be the highest priority. This point is furthermore critical from my perspective as a professional, as I intimately understand the need for stronger ethical and moral alignments. This is something we must all work on making better as a community. As such, this site can serve as an exemplar in the City of Troy and the Capital Region, as well as throughout Upstate New York and cities along the Hudson River, for its recognition of historical recognition, reparations, and meaningful acknowledgement. Perhaps it goes without saying that sometimes it is more important the things we recognize and preserve in their own right, rather than change, that become the most precious with time. This is certainly true for the current status of the 1011 2nd Avenue site, and would be completely devastated with the imprints and impacts of a massive housing block on the landscape here.
From my understanding, it is clear that all three actions — a Comprehensive Plan amendment, rezoning, and the proposed development itself — would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review by a designated lead agency. The Commission should recommend against rezoning the property as being premature until the developer has submitted an EAF and the City has made a SEQRA determination.
The City of Troy must make it the highest priority to preserve this site. I hope that you, as Assistant Planner and a leader in public service to our wonderful city, take immediate action towards protecting and preserving this site by ensuring that the law, and the interests of the citizens here, are respected in this process and in all future scenarios.
With appreciation, Christianna Bennett BARCH Rensselaer Polytechnic Institute MLA Harvard Graduate School of Design
-- Christianna Bennett Rensselaer Polytechnic Institute, B.ARCH Harvard Graduate School of Design, MLA -- Lecturer, Landscapist Landscapes & Ecologies + History|Theory School of Architecture Rensselaer Polytechnic Institute Greene Building Rm 304 110 8th Street
2 Troy New York 12180 ph. 518 364 1580 Webex: https://rensselaer.webex.com/meet/bennec5 http://www.arch.rpi.edu
3 James.Rath
From: sheree c
Dear Planning Commission, and the City of Troy, and others, I live next door to Troy, in Wynantskill. I am blessed to be surrounded by trees. Tree lives matter! What is your vision for the Forest on the banks of The River that Is Never Still/The River that Flows Both Ways/The Mahicantuck/The Hudson? With that vision as a guide, steps could be taken to make it real. Perhaps developer Kevin Vandenburg might propose other ideas to preserve much more of the natural environment. Perhaps the entire area can be preserved, under the care of the original peoples who were, and are, one with this land. Perhaps an indigenous family could live on the land, stewarding it, and managing food forests and forest gardens. Perhaps there could be a small building with educational materials on the history, archaeology, ecology of this land and the indigenous wisdom we need to regain our place in harmony with nature and all life. Perhaps one very tall building could provide many small housing units. Perhaps it could be a green spire, LEED certified, a model of sustainability. Troy can prove once again that it is a center of innovation.
Sheree Cammer 137 Hidley Rd. Wynantskill, NY 12198
1 James.Rath
From: Mickey Dobbin
Good morning,
I am writing today in regard to the proposed development at 1011 2nd avenue that will be discussed at tonights meeting.
I am an archaeologist working professionally in New York State for 15 years who resides here in Troy. Throughout all of 2019 and into 2020 I devoted my Saturdays volunteering up in Lake George where the construction of new duplexes destroyed the cemetery of American Revolutionary War soldiers who had died from smallpox. A large pile of sand, roughly the size of two trailer homes contained the remains of numerous individuals and their stories. However those stories will now be incomplete, without context the bones of these individuals will have limited scientific information to study. In archaeology, context is everything, an individual artifact's story is limited without precise, meticulous study of the ground, soil, and location it resides in. The year we spent combing through the large dirt pile was more to respect those people who had passed fighting to create America, to rescue their remains from being simply dumped into the garbage than anything else.
Context is important, not just in archaeology, but in our lives today, and in our city and it's future. Now as we face this decision to allow the construction of apartments at 1011 2nd Avenue along the Hudson river, we must consider it's context. It is not zoned for these apartments, rezoning for them will be inconsistent with Troy's own 2018 comprehensive plan, and as of now the developer is not properly going through the procedures, with current segmentation of the EAF, rezoning and changes to the comprehensive plan, and there is plenty of housing stock and other already developed parcels in Troy for a development of this type, and that the developer and his engineer has irresponsibly leaked the location of indegenious archaeological site that could encourage looting.
All this context, taken together has made me afraid that if Troy does not follow the law, and does not reject rezoning at this stage, another blunder to New York's archaeological resources will happen, now right in our backyard. Right now you have the ability to make sure these mistakes don't happen and insist the developer follows the proper procedures before he builds at 1011 2nd avenue and destroys both a valuable natural resource and the unique and rich cultural resource of the native american site there is.
Personally, I would prefer no development occur at this site, it would serve our community much better left wild and natural for all of us to enjoy. Even when an archaeological study is allowed to happen, it is a destructive science, and this valuable and important indegengious site, who's future should be left to our indegenious neighbors, but at the very least, the city should take the opportunity to make sure we proceed with caution and within the law to make sure all proper steps to preservation, conservation and community engagement are taken. Listen to our neighbors, listen to our experts, listen to indegenious leaders.
Everything about this process so far, from the segmentation of the Rezoning Request and the EAF, the the lack of concret promises from the developer on the plans, to the timing of this meeting and the lack of communication with the community and indegenious people is a context I have seen many times, one that leads
1 to the destruction of valuable archaeological resources and the disrespect of the peoples of the past over false promises of silver bullet to a better future.
Until the developer has submitted an EAF and the proper SEQRA process has been completed the commision should recommend against rezoning, meanwhile the city and the community should work to find a way to preserve this space for all of us to enjoy.
Thank you, Mickey (Sean) Dobbin 12/29/20
2 James.Rath
From: sidney fleisher
I am adding my voice to the chorus asking that a zoning change not be considered for the group planning to develop this site(1011 2nd Ave) for apartments. This site is the last patch of untouched forest on Troy’s waterfront. In addition it is a sacred site of the Mahican people, the indigenous first inhabitants of the region. In my opinion such a site should be preserved. It is eligible for listing on the National Register of Historic Places. Its preservation must be the city’s highest priority.
The city of Troy is seeing an upswing in renovations of many industrial buildings into apartments. This I believe is a positive development. There are numerous neighborhoods that would be improved if energy was put into renovating the vacant buildings that exist. The river front is already seeing large apartment complexes being built along the shore. The saving of a piece of historic and sacred land would do more for the city communities than another apartment complex.
Please consider the importance of preserving this site and reject the request for a zoning change.
Sid Fleisher 384 2nd Street Troy
1 James.Rath
From: Molly Freiberg
Hello Mr. Rath, I’m standing with Friends of the Mahicantuck to say that I’m against developing this patch of forested land. The way it is being handled is against Troy’s own plan and laws. I think getting into that shady area instead of standing up for Troy’s own ideals will have repercussions for years to come. It’s not the right thing to do now and it is a slippery slope that will pave the way for a future where law makers are out of touch with community and appear corruptible by financial interest. This is an opportunity to stand for something good and pave the way for trust and community. Thank you, Molly Freiberg 17 Gardner Hill Road East Nassau, NY 12062 (978) 239‐8105
Sent from my iPhone
1 James.Rath
From: Friends of the Mahicantuck
Dear Aaron Vera and James Rath,
I am reaching out in the name of the organizing team of the community organization “Friends of the Mahicantuck”, and am writing in regard to the planned development at 1011 2nd Ave in Lansingburgh.
We wanted to inquire about any planned studies that the planning commission will be requesting from the developer. It is our position that certain studies are needed ahead of any hearings with public input, as they are pertinent to ensure that these conversations are grounded in the best available data possible.
Particularly, it is our position, that the following studies are pertinent to a full understanding of the impacts of this development, and wanted to reach out to you to ensure that the commission and public are provided by the developer with these studies in a substantive and comprehensive manner.
We are certain that you already considered most of these studies. However, it is our responsibility to our community members and organizational partners to ensure that these studies are considered extensively in examining this proposal for 1011 2nd Avenue.
STUDIES WE THINK ARE PERTINENT FOR A COMPREHENSIVE EVALUATION: - Traffic impact study - Impact study on the capacities and budget of the local police station and fire station - Parking impact study, including indirect traffic increase - Long-term and short-term impacts on the city’s climate resilience due to tree loss and associated run-off risks, based on updated and current flood, watershed and sea-level rise data - Impacts on the wastewater management system and the potentials for exacerbating the issues of combined sewage overflow - Impacts on local property and rental values - Request a state agency to take the lead on Type 1 SEQRA - A separate, independent archeological survey and examinatio - Public health impacts study regarding air quality in relation to tree loss - A full tree canopy assessment of the property and its impacts on GHG emissions and reduction goals regarding the 2019 NYS CLCPA - An independent legal (non-city and non-developer) assessment and clarification regarding the potentials for a change in zoning code to constitute “spot-zoning” - That the developer actively seek out the input of and bring to the consultancy of representatives of all indigenous peoples with historical connections to this land
Would you mind sharing with us if any of these studies will be requested from the developer, have already been requested, and when they will be expected? Will any of these studies be requested and/or completed prior to any public meetings?
1
With gratitude for any information and we are looking forward to working with you on a successful, comprehensive and equitable processes in evaluating this proposal.
Sincerely, The Organizing Team of the Friends of the Mahicantuck
2 James.Rath
From: Christian Grigoraskos
To whom it may concern,
I think that the City of Troy should not support the development of 1011 Second Avenue. I am a certified arborist and spend alot of my time in trees taking care of them and have a deep understanding of the ecosystem services they provide especially when they form bio-complex groupings we call forests.
In the year 2020 we cannot afford to destroy more forests for human settlement. The city has innumerable vacant properties that should be priority for infill development, and only when all those options are exhausted should we look to expand into virgin territory.
Add to this the cultural significance of the site for the Mohicans, the original inhabitants of this land, and i see even less of a reason to even consider this project. It is well overdue for us to give the Mohicans their credit for being excellent stewards of this place before Europeans arrived.
If a housing project was to move forward on the proposed land at 1011 Second Avenue it should be held to the highest standards of sustainability (net positive energy) and use human creativity and technology to merge with the forest and set an example for all successive developments and put Troy on the map for being a truly progressive leader in the future of urban planning. A development like I have just described would generate all of its own power and process all of its own waste, and have no negative effect on the surrounding ecosystem.
Sincerely, Christian Grigoraskos 488 Second Avenue
1 James.Rath
From: Alex Hanse
Hello,
I'm writing to express my opposition to the development of 1011 2nd Avenue in Lansingburgh in its current form, proposed by Kevin Vandenburgh and associates.
I recently purchased my first home, in South Central Troy, after being a resident of the Capital region my entire life. I chose to settle down in Troy for its vibrant and resilient community, flourishing small businesses, and it's concentrated wealth of history and architecture. I also chose to live here because of how clearly I see the vision of a great Troy-- that of a model city for Upstate New York. That vision consists of preserving and maintaining the heritage of our streets, alleys, neighborhoods, and natural spaces while keeping in mind the needs of small business owners, residents, students.
Developing 1011 2nd Avenue into multi-story complexes of apartments would not achieve the urban-renewal- through-gentrification that the developers and city planners may envision for the space. Developing a standalone apartment complex creates a microcommunity within an already established community, rather than integrating new residents. This serves only to create social and economic imbalances, in the form of artificially inflated rents and increased motor vehicle traffic, in an already struggling community that needs residents to care and contribute to it at large, not simply reside within its boundaries, separated by a gate and a parking lot. Not to mention that the destruction of natural spaces might cause neighboring residents to leave, as their home values are decreased, leaving an underserved area further desolate. Everyone appreciates access and visibility of natural spaces, be it untouched woods, parks, or simply tree-lined streets. Nature serves as a salve to the human mind, and it's importance to the health and vibrancy of a community cannot be overstated.
If the property at 1011 2nd Avenue must be developed, perhaps it should be developed into a public park, integrating the last waterfront wooded area within the boundaries of the City of Troy with walking trails and spaces for residents and visitors to walk, reflect, and relax. That development should inherently reflect the nature of the space as historic, and perhaps ancient, indigenous land through the form of markers and information boards. An understanding of the peoples who walked this land well before even the city of Troy of history was conceptualized is important, as the alternative is to all but physically complete their genocide.
I must also mention that for any development to occur on 1011 2nd Avenue, a NYSDEC review of the plan in line with the State Environmental Quality Review Act must be completed, or the project will be progressing illegally. We should not be encouraging development in Troy that skirts the rule of law, for if we turn a blind eye to the nature of all development and investment it is a slippery slope that only serves to invite nefarious practices into our community.
I wholeheartedly encourage the Planning Commission to consider the desires of immediately local residents and residents of all of Troy, the history of the area, and what real investment in our community should look like, and reject Mr. Vandenburgh's plan outright.
With respect,
1
Alex Hanse
-- Alexander Stephen Hanse
(518)-751-0342
2
James.Rath
From: Jessica Ika
Dear Planning Commissioner Steven Strichman and Assistant Planner James Rath,
My name is Jessica Holtz and I have been living in the Capital Region for about a year, although I am originally from New York state and have spent most of my life in New York. I am writing to you with deep concern over the proposed rezoning and associated development of 1011 2nd Avenue in Lansingburgh. However, what is truly worrisome is that the City of Troy is currently not following the law in assessing the proposed development.
We respect Troy’s need for economic development, but the city must prioritize its role as a steward of a site of unique importance to Mahican peoples. This site is 5,000 years old and has been recognized as eligible for listing on the National Register of Historic Places. Its preservation must be the highest priority. Rezoning the property would be inconsistent with Troy’s 2018 Realize Troy Comprehensive Plan. The Comprehensive Plan was an expression of the community’s vision for the city, and the community did not envision dense multi-unit housing on Troy’s northern waterfront. At a minimum, the City is required to amend its Comprehensive Plan if it intends to change the zoning in a way that is contrary to the plan. Troy must follow the law. For a project of this size, rezoning can not be considered separately from the proposed development itself. As required by the State Environmental Quality Review Act (SEQRA), when a developer with a project of this size requests to rezone a property, the rezoning is a reviewable action under SEQRA. The developer must also identify the zoning change it needs as part of the project’s Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified from the start in the EAF so that the potential environmental impacts associated with them can be considered together. Because this zoning change would also require a Comprehensive Plan amendment, that too must be identified in the EAF. To consider these decisions separately would be “segmentation”, contrary to the intent of SEQRA.
In this case, it is clear that all three actions — a Comprehensive Plan amendment, rezoning, and the proposed development itself — would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review by a designated lead agency.
The Commission should recommend against rezoning the property as being premature until the developer has submitted an EAF and the City has made a SEQRA determination.
As someone who has had the opportunity to learn about the Indigenous peoples of this land and the privilege of getting to hear their perspectives, I know that land rights are often trampled over in the name of profit and development. On a personal level I feel strongly that the very least that we can do is not hand over environmentally sensitive and culturally important areas to developers solely on the basis of the monetary benefits that might be found in doing so. Further, our environment is not in a state where those minor gains are
1 worth it at the expense of a more damaged planet.
Thank you for your consideration,
Jessica Holtz - 12/29/2020
2 TO: Troy City Planning Board. FROM: David Hunt, Ecological Intuition & Medicine Rensselaer County Biodiversity Greenprint Project RE: Golub Parcel. Proposed Apartment Complex Development. Pleasantdale Bluffs, City of Troy. DATE: December 22, 2020
Planning Board Members,
As part of my effort of over 20 years to map and provide information to landowners and conservation organizations about regionally-important ecological/biodiversity sites throughout Rensselaer County, I would like to bring to your attention information on two important sites connected to the 9.93-acre Golub parcel (Tax Parcel 70.64-1-1) in the City of Troy, on which an apartment complex is reportedly being proposed:
"Pleasantdale Bluffs" a county-important rocky summit/slope ecosystem complex containing knolls and cliffs along the Hudson River spanning the Troy/Schaghticoke municipal boundary with associated county-exemplary occurrences of Pitch Pine-Oak-Heath Rocky Summit plus Shale Cliff & Talus Community, as well as 24 known regionally rare plants.
"Hudson River Schaghticoke" a county-important riparian ecosystem complex containing the Hudson River, shoreline communities, and an associated floodplain, stretching from the Washington County line downstream to the Federal Dam in Troy with associated county-exemplary occurrences of Unconfined River plus Riverside Sand/Gravel Bar, as well as many known regionally-rare plants.
These sites were documented and mapped as part of my contributions to the 2017 Rensselaer County Conservation Plan, coordinated by the Rensselaer Land Trust, focusing on 10 ecological features ranging from relatively small scale (e.g., rare plant concentration areas) to relatively large scale (e.g., regionally-important aquatic networks, forest landscapes, and large-scale conservation sites). Maps have reportedly been accessible on-line since that time for all municipalities and citizens of the county to consult.
I provide an attached packet of summary information about these two sites and their biodiversity components with special focus on the Golub parcel, which explains the basic information available online. More detailed information is available upon request. Each site represents multiple overlapping county-important ecological features, 6 at Pleasantdale Bluffs, 8 at Hudson River Schaghticoke. Because both these ecological sites are somewhat large, much of the prior information was based on field surveys and historical records off the Golub parcel. Both sites were mapped remotely from air photo plus associated datalayers on land cover, hydrology, topography, geology, and soils. A recent survey of the Golub parcel (December 20, 2020), conducted under 2 feet of snow in conjunction with a group of concerned local neighbors, confirmed the presence of multiple features of both regionally important sites including multiple characteristic natural communities and county-rare plants. Because herbaceous and graminoid plants are often not detectable under these conditions, I strongly recommend the parcel be studied by a qualified ecologist during the growing season (May to September) to better evaluate the suspected/potential presence of several additional regionally-rare species including 1) the state-rare moth inland barrens buckmoth, known to feed on scrub oak, which was just found on the parcel, and 2) the state-rare plants pleated-leaved knotweed plus bristly rose, both known just to the north in Schaghticoke.
Hopefully, any decision about potential land use changes of the Golub Parcel should consider the regional importance and rarity of multiple ecological features here (especially the Shale Cliff & Talus Community, riverside habitat, and rare plant species like scrub oak). Whether or not the parcel is further evaluated for rare plants and animals, if any structures are to be built on the parcel, I strongly recommend that they are placed as close as possible to Second Avenue, farthest away from the ecologically-important features of the site, and that any impacts to the high knolls, steep W-facing slopes bordering the Hudson River, and the river shoreline are minimized.
Sincerely in Biodiversity Conservation,
David Hunt. Ph.D. Ecologist. Grafton, NY. Rensselaer County Biodiversity Greenprint Project (Designing an Ark for the Native Species of Rensselaer County)
348 Jay Hakes Road; Cropseyville, NY 12052; (518) 279-4124 Site 1. Pleasantdale Bluffs. (See Maps 1-4).
A. County-important Restricted Ecosystem Complex. (Map 1) Complex type: Rocky summit/slope complex, circumneutral, bluff/gorge, Hudson River Valley regional variant, large river escarpment bluff type. Size: 336 acres. County Importance: Importance Tier 1 of 3 (most important). Extent on Golub Parcel: 40% of tract (N half). Contribution of Golub Parcel: 5% of Complex (S edge). Characteristic Community Types: include Pitch Pine-Oak-Heath Rocky Summit, Shale Cliff & Talus Community. (see Exemplary Natural Communities). Associated Rare Species: numerous county-rare plants (see Rare Plant Concentration Area). Description: substrate includes exposed bedrock. contains characteristic open rocky summit/slope community types with associated rare plant species. The known core of this complex, "Pleasantdale Bluffs" in a more strict sense, is represented by knolls/bluffs at the N end of a patch directly along the Hudson River just W of the W end of River Bend Road. More of the site is mapped along gorges to the NE, between Haughney and Brickyard Roads, mostly unexplored to date.
B. Constituent Exemplary Natural Communities. (Map 2)
Shale Cliff & Talus Community (SCTC4) Regional Conservation Importance: County Priority 3 of 4 (near-exemplary). likely "county significant" but not "state significant". Size: 6.3 acres. Location: corrected 2020 from 2017 mapping to bluffs just W of W end of River Bend Road in Schaghticoke plus bluffs along SW edge of Golub tract. Extent on Golub Parcel: 5% of tract (SW edge). presence confirmed during December 2020 field survey. Contribution of Golub Parcel: 40% of community (S patch). Description: steep slope with exposed shale bedrock. open canopy habitat dominated by low shrubs, scattered herbs, graminoids, mosses, and lichens. Site 1. Pleasantdale Bluffs. p. 2.
Pitch Pine-Oak-Heath Rocky Summit. Regional Conservation Importance: County Priority 2 of 4 (co-exemplary). likely "county significant" but not "state significant". Size: 2.7 acres. Location: corrected 2020 from 2017 mapping to knoll just W of W end of River Bend Road in Schaghticoke. Extent on Golub Parcel: not mapped on tract, but both highest knoll and upper crest of cliff resemble this community type based on December 2020 field survey.
C. Rare Plant Concentration Area. (Map 3) County Importance: concentration priority 3 of 7 (highly concentrated). 28th most important rare plant site in county as of 2017; 5th town priority for Schaghticoke as of 2017. Size: 29 acres. originally mapped at 129 acres but in incorrect location. corrected to patch of Pleasantdale Bluffs ecosystem complex bordering Hudson River. Species Composition: with 17 county rare species/1 state rare species (1 state watch list, 7 county active list, 10 county watch list) documented for 2017 county conservation plan; recently expanded to 24 county rare species/3 state rare species (1 state active list, 2 state watch list, 10 county active list, 14 county watch list). Information on individual species shown in Table 1. Several additional rare plant species are expected, associated with historical specimens at the NY State Museum labelled "Lansings Grove", reportedly the local name for this site, that have not yet been attached to this site. Extent on Golub Parcel: 40% of tract (N half); as ecosystem complex. presence confirmed during December 2020 field survey. Contribution of Golub Parcel: 15% of concentration area (S edge). Location: corrected 2020 from 2017 mapping to match corresponding patch of rocky summit/slope ecosystem complex along Hudson River.
Site 1. Pleasantdale Bluffs. p. 3.
D. Rare Animals. No rare animals have yet been identified from Pleasantdale Bluffs, most of the field surveys being focused on natural community types and vascular plant species. The observed presence of several individuals of scrub oak on the rocky summit and cliff community types suggests the potential for the state-rare moth "inland barrens buckmoth", which is known to feed primarily on that shrub. Similarly, no surveys for Karner blue butterfly, a globally rare moth characteristic of pitch pine barrens, are known to date from the site.
E. County-Important Roadless Blocks see Hudson River Northern Rensselaer County Block below, under Site 2 (Hudson River Schaghticoke).
F. County-Priority Conservation Site North Troy Hills & Bluffs. (Map 4) Site type: Level-2 site (mostly moderate-scale local ecosystems). Description: large aggregate of rocky summit/slope complexes. County-Importance: Tier 2 of 4 site (moderate county priority). Size: 1168 acres. Ecosystem Complex Composition: includes complexes associated with Bald Mountain Brunswick, Oakwood Cemetery Troy, Pleasantdale Bluffs, and River Road Schaghticoke. Extent on Golub Parcel: 40% of parcel. Contribution of Golub Parcel: 2% of conservation site. Site 2. Hudson River Schaghticoke (See Maps 5-8).
A. County-important Restricted Ecosystem Complex. (Map 1) Complex type: Riparian complex. non-tidal, confined river, large river type (main channel) in calcareous flats. Size: 1191 acres. County Importance: Importance Tier 1 of 3 (most important). Extent on Golub Parcel: <1% of tract (borders entire W edge of tract, tract influences local quality of site). Contribution of Golub Parcel: <<1% of the complex (inland edge) Characteristic Community Types: include Unconfined River and Riverside Sand/Gravel Bar (see Exemplary Natural Communities). Associated Rare Species: several county-rare plants (see Rare Plants). Description: includes river, shoreline communities and associated floodplain. Location: Stretches along the entire non-tidal portion of the Hudson River from the Washington County line downstream to the Federal Dam in Troy. Only the Rensselaer County part of this complex has been mapped to date. The complete site extends N into Washington County and W into Saratoga County.
B. Constituent Exemplary Natural Communities. (Map 5)
Unconfined River Regional Conservation Importance: County Priority 2 of 4 (co-exemplary). likely "state significant". Size: 949 acres. Location: representing entire non-tidal portion of Hudson River from Washington County line downstream to Federal Dam in Troy; only the Rensselaer County part of this community has been mapped; it extends N into Washington County and W into Saratoga County. Extent on Golub Parcel: <<1% of tract (borders entire W edge of tract; tract influences local quality of large community example). Contribution of Golub Parcel: <<1% of community border. Description: wide, slow flowing, moderately deep river dominated by run and pool microhabitats, relatively confined within shale Site 2. Hudson River Schaghticoke. p. 2.
stream terraces in a moderately wide valley.
Riverside Sand/Gravel Bar A 37-acre county co-exemplary site for this community type has been mapped along the Hudson River 1.8 miles to the north of the Golub parcel in Schaghticoke. One patch of this community is believed to be present on the Golub tract (but was under snow during the December 20, 2020 field survey). If intervening patches are present upstream within 1.0 miles, the Golub patch would be lumped into this exemplary occurrence. The community was mapped using air photos; field surveys allow a much more precise mapping of this community, which typically occurs as narrow, linear bands that are difficult to detect on air photos.
C. Rare Plants. Although no rare plant concentration area has been mapped yet to this aquatic-based site, pending sufficient surveys of its shoreline and nearshore areas, at least one county-rare plant was observed on the Golub tract within this site: cocklebur. Several individuals of this county watch list plant were observed on a shoreline community of the Hudson River, probably Riverside Sand/Gravel Bar (but buried under deep snow during the December 2020 field survey). Other county-rare shoreline plants are suspected from this site and would be most detectable during the growing season.
D. Important Animal Habitats County Importance: Conservation priority 4 of 7 ("concentrated"). Size: 949 acres. (corresponding to Unconfined River) Animal Concentration Area Composition: 1 known probable animal concentration area (odonates). Other potential concentration areas are likely (large river fish, shorebirds, riparian birds), but information is not yet available for analysis. Additional areas would raise the importance level of this site, if confirmed. Rare Species Composition: 3 known state & county-rare animal taxa (odonates), all documented with NY Natural Heritage Program. Location: Boundary follows that for exemplary Unconfined River community. Extent on Golub Parcel: <<1% of tract (borders entire W edge of tract; tract influences Site 2. Hudson River Schaghticoke. p. 3.
local quality of large site). Contribution of Golub Parcel: <<1% of habitat.
E. County-Important Aquatic Network Hudson River Main Channel (Network AN62) (Map 6) Network type: main channel, non-tidal network. Size: 4002 acres/14.5 stream miles. County Importance: Priority Tier 1 of 4 (most important). Extent on Golub Parcel: NW 70% of tract (as coarsely modelled with assistance from RLT). Contribution of Golub Parcel: <<1% of network. Network Composition (on Golub parcel): forested "riparian strips" coarsely mapped based on regional land cover database; a more precise local mapping using air photos and field evaluation would probably extend the forested buffer boundary eastward to cover 80% to 90% of the tract.
F. County-Important Roadless Blocks (Map 7) Although the Golub parcel is not situated within a Level-4 (strictest level) regionally important forest matrix block, it is mapped within a large "aquatic matrix block", the Hudson River Northern Rensselaer County block.
Hudson River Northern Rensselaer County Block. Location: This block includes the Hudson River from the Washington County line south to the Federal Dam in Troy, plus lands eastward to the first public road, constituting a narrow buffer inward of the river. While the concept should ideally include similar land N of the county line in Washington County and W of the river in Saratoga and Albany Counties, only the Rensselaer County "subsite" was precisely mapped. Size: 11089 acres. County-Importance: Priority Tier 1 of 4. Extent on Golub Parcel: 100% of tract. Contribution of Golub Parcel: <<1% of block.
G. County-Important Forest Corridors. Although the parcel is not within a mapped regionally important forest corridor, being situated in the general urban setting of Troy, it is contained within an important "aquatic corridor" (see information on county-important aquatic networks and Site 2. Hudson River Schaghticoke. p. 4.
roadless blocks).
H. County-Priority Conservation Site Hudson River Corridor. (Map 8) Site type: Level-1 site (large regional landscapes). Description: large important aquatic corridor. County-Importance: Tier 1 site (highest county priority). Size: 13662 acres. Site Composition: includes river plus adjacent areas, especially with natural cover, deemed important to maintain the high water quality and native biota of the river. includes a strip throughout the W edge of Troy. Extent on Golub Parcel: 100% of parcel. Contribution of Golub Parcel: <<1% of conservation site.
Feature Concepts and Definitions.
County-Important Restricted Ecosystem Complexes the largest, most intact, and most ecologically-important examples of ecosystem complex types with restricted distribution and total size in Rensselaer County, thought to be the best set of sites necessary to conserve the complete diversity of natural community types and native biota of those complexes in the county. Restricted types include rocky summit/slopes, wetlands, lakes, and riparian areas. Habitats typically delineated based on air photo interpretation of natural community types, hydrology, topography, geology, and soils.
County-Important Natural Communities the largest, most intact, and most ecologically important ("exemplary") examples of every natural community type in Rensselaer County, representing the "benchmark" for its biodiversity composition, condition/quality, and landscape setting relative to all other examples of the community type within the county. Types follows standard state classification of ecological community types (New York Natural Heritage Program).
Rare Plant Concentration Areas the largest concentrations of "rare" plant taxa in Rensselaer County, those that are rare at least at a county level, with sites prioritized by rarity level and abundance of rare species, giving highest priority to global and state rare plants. includes all groups of vascular plants and limited groups of non-vascular plants. Rare plants at 3 levels (global, state, and county) are divided into "active list" species (actively tracked as "very rare" and the highest priority for conservation) plus "watch list" species (others that are "moderately rare" and monitored over time to assess their trends in status, either decreasing, stable, or increasing). Species concepts follow the 2017 New York state flora. Global and state rarity assessments are derived and maintained by the New York Natural Heritage Program. County rarity assessments are derived and maintained by the Rensselaer County Biodiversity Greenprint Project, following standard methods of the natural heritage network.
County-Important Animal Habitats the most ecologically important habitats in Rensselaer County for sets of animals and/or animal behavior types with restricted distribution in the county. Includes rare animal populations, dense animal concentration areas, and important animal behavioral features such as dens and breeding areas.
County-Important Aquatic Networks the largest, most intact, and most ecologically important aquatic landscapes in Rensselaer County, thought to be the best set of sites necessary to conserve the complete diversity of natural aquatic community types (especially river types) and native aquatic biota of the county. Sites include the central waterway of the network ("stream system") plus two key surrounding land features that contribute most to the high water quality and native biota composition of the stream system: 1) riparian corridors [buffer strips] directly along the stream system, typically its mainstem, and 2) wider intact subcatchment areas, typically in headwater positions. Feature Concepts and Definitions. p. 2
County-Important Roadless Blocks the largest, most intact, and most ecologically-important "blocks" in Rensselaer County, thought to be the best set of sites that 1) contain a matrix of natural communities characteristic of the local physiographic area and 2) are necessary to conserve the complete diversity of native biota of the county (especially large forest mammals and species vulnerable to disturbances associated with disturbance corridors such as roads). Roadless blocks, like "city blocks", are bounded by public roads and have no internal public road "bisections". "Aquatic blocks" are bisected by dams rather than roads, specifically those with high bridges over water that do not impede water flow and movement of aquatic biota.
County-Important Forest Corridors. the widest, most intact, and most ecologically important forest ("wildlife") corridors in Rensselaer County, connecting a related set of county-important forest landscapes to form one connected "forest network".
County-Priority Conservation Sites the most important ("priority") large to moderate-scale biodiversity conservation sites in Rensselaer County, the complete set of which is designed to represent a group with the least amount of sites needed to conserve all native/natural biodiversity and ecological features of the county.
Table 1. Rare Species of Pleasantdale Bluffs Ecosystem Complex site.
Species Name Subsite Presence (# individuals) Scientific Common Schaghticoke Golub Parcel
1. State Rare (3)
Juglans cinerea Butternut 1 not yet found Polygonum tenue Pleated-Leaved Knotweed 8 not evaluated Rosa acicularis Bristly Rose 50 not evaluated
2. County Active List (8)
Carex umbellata Parasol Sedge present not evaluated Crocanthemum canadense Frostweed 10 not evaluated Cyperus lupulinus Eastern Flat Sedge 50 not evaluated Galium pilosum Hairy Bedstraw 40 present Quercus prinoides Dwarf Chinquapin Oak present not yet found Selaginella rupestris Rock Spikemoss present not evaluated Solidago squarrosa Stout Goldenrod 5 probably found Symphyotrichum patens Late Purple Aster present not evaluated
3. County Watch List (13)
Abietinella abietinum Wiry Fern Moss present not evaluated Amelanchier sanguinea Round-Leaved Shadbush present probably found Andropogon gerardi Big Bluestem present not evaluated Arabidopsis lyrata Lyre-Leaf Cress 100 not evaluated Asplenium trichomanes Maidenhair Spleenwort 50 not evaluated Borodinia canadensis Sicklepod present not evaluated Drymocallis arguta Tall Cinquefoil not yet found ~10 Houstonia longifolia Long-Leaved Bluets present not evaluated Lechea intermedia Large-Podded Pinweed 5 not evaluated Lespedeza violacea Wand-Like Bush Clover 5 not evaluated Polygonatum biflorum (commutatum) Large Solomon's-Seal present not evaluated Quercus ilicifolia Scrub Oak present ~5 Woodsia ilvensis Rusty Woodsia 20 not evaluated
Statement of James Kruegler 108 3rd Street, Troy NY 12180
City of Troy Planning Commission
SPECIAL MEETING December 29, 2020
“1011 Second Ave. (101.38-9-10) Planning Commission Recommendation to the City Council for Zone Change. Kevin Vandenburgh is proposing a zone change from R-1 (Single Family Residential Detached, §285-52) to P (Planned Development, §285-57). Pursuant to §285-27 of the City Code a public hearing is required. The applicant is represented by Jamie Easton, P.E. of M.J. Engineering.”
Dear Member of the Planning Commission. My name is James Kruegler, I live at 108 3rd Street and I want to speak today in opposition of the proposed change in zone code. I want to strongly urge the Planning Commission to recommend against the requested zone change.
In general, the negative impacts of rezoning and the associated proposed development project - - on the property, its unique history and ecology, the surrounding communities and neighborhoods, and the City of Troy overall -- are far too great.
In particular, I want to draw attention to how the rezoning and proposed development would destroy the ability of this land to provide considerable ecosystem services to the people of Troy. Currently the land at 1011 Second Avenue is highly forested with over 90% tree canopy cover. These trees filter common harmful air pollutants, intercept rainfall and subsequently avoid stormwater runoff, and act as a vegetative buffer keeping sediment- and water-borne pollutants from entering the Hudson. Severely deforesting this land on the scales proposed in this development plan would necessarily degrade these ecosystem services already being rendered at no cost to anyone. There are provisions in this development plan for negating some (but not all) of these adverse effects of rapid deforestation at the edge of a major river network. For example, it is stated the development “would be designed so that the total site runoff of stormwater will be less than or equal to existing conditions”. However, this is a vague claim that is not supported with any verifiable details anywhere else in the plan. The “Project Narrative” currently before the Planning Commission promises a lot, but provides so little supporting information that these promises cannot hope to be investigated with any rigor. On this point alone, the Planning Commission and the City Council should not consider rezoning until a more detailed, quantitative assessment of the proposed development is put forward.
Considering the potential negative impacts of the proposed rezoning and associated development, I also strongly urge the Planning Commission and the City Council to make a positive SEQRA (State Environmental Quality Review Act) declaration. Per the SEQRA, when a development project of this size requires a property be rezoned, the rezoning is a reviewable action under the SEQRA. The developer must also identify the zoning change they need as part of the project’s Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified from the start in the EAF so that the potential environmental impacts associated with them can be considered together. For a project of this size, rezoning cannot be considered separately from the proposed development itself; this would constitute “segmentation”, contrary to the intent of SEQRA.
It is my opinion that a change in zoning code would be an enormous mistake, and so the Planning Commission should recommend against it. The unique ecology, history, and archeology of this site; its location along the Hudson River; and its ecosystem services all would be degraded or lost by a high-density zoning. For over three hours on September 10th, 2020 the public commented in opposition to this zoning change and the development. There was not one comment by a member of the public in support of this zone change and the associated development. The losses we would incur from rezoning and development are far too high. It is abundantly clear the public is not willing to pay that price, and neither should the city.
Thank you for your consideration.
James Kruegler
Aaron.Vera
From: Steven.Strichman Sent: Monday, December 28, 2020 1:40 PM To: Aaron.Vera Subject: FW: 1011 2nd ave.
From: Denis McCarthy [mailto:[email protected]] Sent: Monday, December 28, 2020 1:39 PM To: Lucy McCarthy Cc: Patrick.Madden; Steven.Strichman; James.Rath Subject: Re: 1011 2nd ave.
Good morning The property is zoned for single unit housing. The burden on Troy taxpayers would be much greater if 36 single family homes were constructed. Trash pickup, snow removal, road maintenance, would be Troy’s responsible. The owner of apartments would be responsible for the above. I would also think that these lands would be disturbed just as much by single family homes.
Happy Holidays Denis On Mon, Dec 28, 2020 at 9:52 AM Lucy McCarthy
Although I do not reside in Troy at this time, having grown up in Troy, I am very interested in the city. As an example, my involvement with Troy led me to watch a film about the Hudson River offered by Media Sanctuary. Through this viewing I learned about 1011 2nd Ave.
Closely reading the material offered by the Friends of the Mahicantuck web site, I am compelled to write suggesting that the planning board take this slowly. There are many aspects of the Troy Comprehensive plan which would support not developing this parcel, and not losing this access to the Hudson. Too, the fact that there is a 5000 year old scared site on the property needs careful consideration.
Will the Federal government need to be involved ? There is in Indian Law this requirement if the tribe is Federally recognized the tribe needs to be involved.
How much will this project either the large apartment complex or the 36 houses cost the city of Troy? The tax issue always comes into consideration and usually it is claimed that the expanded tax base will be a boon. Very rarely, really, does this get considered -- Roads, fire, emergency, increased education costs, police etc.-- This would be worth evaluating. Taxes gained versus real cost to the city.
For much of my work life I have been involved in land transactions and conservation. Think about Troy’s parks. I am familiar with Frear and Prospect. They are well used and loved. Yes, sometimes abused, but think of the enjoyment and chance to be outside they provide the citizens.
1
There are other uses than development for this land. Maybe a conservation group could purchase it and provide this open space to the people without a cost to the town. Maybe the City wants to establish a link to the Hudson - Please take this slowly.
Thank you for reading this letter -
Lucy A. McCarthy PO Box 267 Vinalhaven, Maine 04863
2 From: Lucy McCarthy [mailto:[email protected]] Sent: Monday, December 28, 2020 9:52 AM To: Steven.Strichman; Patrick.Madden Cc: James.Rath Subject: 1011 2nd ave.
Good afternoon Mayor Madden and Mr. Strichman;
Although I do not reside in Troy at this time, having grown up in Troy, I am very interested in the city. As an example, my involvement with Troy led me to watch a film about the Hudson River offered by Media Sanctuary. Through this viewing I learned about 1011 2nd Ave.
Closely reading the material offered by the Friends of the Mahicantuck web site, I am compelled to write suggesting that the planning board take this slowly. There are many aspects of the Troy Comprehensive plan which would support not developing this parcel, and not losing this access to the Hudson. Too, the fact that there is a 5000 year old scared site on the property needs careful consideration.
Will the Federal government need to be involved ? There is in Indian Law this requirement if the tribe is Federally recognized the tribe needs to be involved.
How much will this project either the large apartment complex or the 36 houses cost the city of Troy? The tax issue always comes into consideration and usually it is claimed that the expanded tax base will be a boon. Very rarely, really, does this get considered -- Roads, fire, emergency, increased education costs, police etc.-- This would be worth evaluating. Taxes gained versus real cost to the city.
For much of my work life I have been involved in land transactions and conservation. Think about Troy’s parks. I am familiar with Frear and Prospect. They are well used and loved. Yes, sometimes abused, but think of the enjoyment and chance to be outside they provide the citizens.
There are other uses than development for this land. Maybe a conservation group could purchase it and provide this open space to the people without a cost to the town. Maybe the City wants to establish a link to the Hudson - Please take this slowly.
Thank you for reading this letter -
Lucy A. McCarthy PO Box 267 Vinalhaven, Maine 04863 Equality for Troy 400 Broadway ave #592 Troy, New York 12181 518‐646‐3207
December 28th 20120
TO: Mayor Patrick Madden
SUBJECT: Tell the City Commission and Council to follow the law in considering a development at 1011 2nd Avenue
Dear Mayor Patrick Madden
My name is Tasheca Medina the founder of Equality for Troy. I am writing with a grave disgust for the proposed rezoning and associated development of 1011 2nd Avenue in Lansingburgh. However, what is truly troublesome is that the City of Troy is currently not following the law in assessing the proposed development.
As a sign of good faith to the people. Please consider these factors:
1. We the people request you make your highest priority preserving the nationally significant indigenous heritage site at 1011 2nd Avenue. The city must prioritize its role as a steward of a site of unique importance to Mahican peoples. We understand the city’s need for economic development. However, there is plenty other areas of troy, that is in desperate need for revitalization. For example, North Central troy.
2. We the people notice that rezoning the property would be inconsistent with Troy’s 2018 Realize Troy Comprehensive Plan. One factor that needs to be addressed is, the City is required to amend its Comprehensive Plan if it intends to change the zoning in a way that is contrary to the plan. Furthermore, the indigenous people of this land with other citizens of troy oppose this plan. We cringe at the idea of multi‐unit housing on Troy’s northern waterfront.
In Troy’s 2018 Realize Troy Comprehensive Plan it states: “It is a blueprint for community transformation aimed at enhancing prosperity, community well‐being and the quality of life and opportunity the City of Troy offers its citizens.” Does this not include the natives to this land?
3. We the people insist the City of Troy follow the law!!! According to the State Environmental Quality Review Act (SEQRA), when a developer with a project of this size requests to rezone a property, the rezoning is a reviewable action under SEQRA. The developer must also identify the zoning change it needs as part of the project’s Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified from the start in the EAF so that the potential environmental impacts associated with them can be considered together. Because this zoning change would also require a Comprehensive Plan amendment, that too must be identified in the EAF. To consider these decisions separately would be “segmentation”, contrary to the intent of SEQRA.
If the city proceeds with these actions. This would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review by a designated lead agency.
The Commission should recommend against rezoning the property as being premature until the developer has submitted an EAF and the City has made a SEQRA determination. And the City of Troy should make it the highest priority to preserve this site. I hope that you, as the Mayor of our wonderful city, take immediate action towards protecting and preserving this site and ensuring that the Commission and Council follow the law.
Best Regards
Tasheca Medina
DEPARTMENT OF THE ARTS IEAR STUDIOS
December 25, 2020
Steven Strichman James Rath Planning Commissioner Asst. Planner [email protected] [email protected]
Dear colleagues on the Planning Commission:
I write this as a person who loves Troy, and the Hudson River along its shores. For the past three decades, I have been committed to the cultural and economic development of the City of Troy, in my role as Professor of Media Arts at RPI and as Arts & Education Coordinator at The Sanctuary for Independent Media. I am also a homeowner on the river directly across from the historically and spiritually significant site of Peebles Island, a few blocks south of this significant site. I believe the preservation of 1011 2nd Ave. is critical for the quality of life and future of Troy, and I appreciate your consideration of my words.
• Preservation of the forest at the City of Troy’s historic Northern shores offers valuable opportunities for economic development now and long into the future.
I beseech the City of Troy to keep focus on the long-term development opportunities for all of the citizens of Troy, rather than the short-term gains for a mere few. Preservation of this green space along Troy’s northern shores strengthens the city’s prestige, cultural attraction, quality of life through connection to the river, and unique history. Economic development opportunities range from expanding Tro’sy population through the attraction of increased quality of life, to increasing our local economy through tourism drawn to this historic and natural jewel of our City.
As the Arts & Education Coordinator at Media Sanctuary, our Uptown Summer program is a collaboration with NY State Workforce Development Program. To celebrate our legacy and role as environmental stewards along the Hudson River in Troy, we also brought in economic development support from New York State Council of the Arts, Regional Economic Development support, and funding from the National Endowment of the Arts to honor our treasured heritage and
Rensselaer Polytechnic Institute 110 8th Street | Troy, NY 12180-3590 | Arts Department, 110 West Hall Phone (518) 276-2546 | Fax (518) 276-4370 | www.arts.rpi.edu
2 produce the short documentary film “Echoes from Lock One.” Our Uptown Summer youth researched the exceptional history of Troy’s shores along the Hudson River. They met tribal representatives to learn about the vital importance of the Stockbridge-Munsee Community and the Mahican peoples’ 5000-year history along the shores in North Troy.
This site has high archaeological sensitivity and cultural significance for the Stockbridge-Munsee Community and Mohican peoples, with a number of National Register of Historic Places (NRHP) eligible archaeological sites. The recorded Chert Quarries Precontact Site was used for the extraction of resources for Mohican people and social trade networks linking to distant Native American communities. This natural forest along the Hudson represents immense cultural and educational significance, a great attraction to the community of Troy.
May I note here that many of the youth growing up in the economically disadvantaged neighborhoods of North Troy have little or no relationship to the Hudson just a few blocks from their homes. Nurturing green space along the Hudson for walking and nature observation offers valuable support to the health and welfare of our diverse communities in Troy. The newly constructed Ingalls Ave. Boat Launch in North Troy offers access to boaters but was disappointing in that it lacks access to the shore for pedestrians. Expanding access, especially in the midst of the pandemic and an uncertain future, embraces our natural resources as a development opportunity for all of the citizens of Troy.
I’ve connected with this waterfront treasure many a time from canoe and kayak on the Hudson, connecting to the mystical powers of the landscape and imagining the footsteps ancestral knowledge elders’ presence on this land. Many of our growing new population are attracted by richness of our watershed, and with concerns for climate change, are attracted to Troy as their new home.
I’ve witnessed eagles flying off these shores. The vision of America, right here in our home of Troy! Please, as leaders of the City of Troy, be our stewards to the economic, cultural, historical opportunities that are offered by preservation of this land!
• Let’s follow Troy’s 2018 Realize Troy Comprehensive Plan, envisioned through a community design process!
As an invited participant of the community engagement process, I witnessed unanimous agreement of our waterfront’s deeply intrinsic value the on the quality of life in Troy. Changes in zoning will seriously result in an erosion of trust. Please keep our zoning unchanged, respecting the Comprehensive Plan’s vision. 3 Rather than despoiling Troy’s northern waterfront with dense multi-unit housing, preserving the forests along these ancient historic shores of the Hudson will add a spectacular attraction for those attracted to Native American history. This site is also located right above a spot rich with history for early American/ Erie Canal enthusiasts: the confluence of the Hudson and Mohawk Rivers, “The Waterford Flight” at Lock 2, and the 126th Bridge which succeeds a span built in 1804 considered the first bridge to cross the Hudson River north of New York Harbor.
Environmentalists and scientists from across the Hudson Mohawk Region will be attracted to the site to collectively improve the quality of the water on the Hudson. From our own experience with the exciting development of our NATURE Lab Environmental Education Center, we are transforming a long- abandoned building owned by the Troy Land Bank not far from the River’s Shores into a vibrant community science lab dedicated to people’s health. The economic development opportunities arising from this are impressive, including a new collaboration with Riverkeeper offering job development and scientific training to local at-risk teens. Visitors from across the nation and the world are being attracted to Troy to learn about our historical legacy along the Hudson.
And most important to enhancing the quality of life in Troy, walking trails would enrich Troy with a gorgeous natural location for hikers and cross-country skiers, as well as canoers, kayakers, sailors and boaters.
• Troy must follow the law. For a project of this size, rezoning cannot be considered separately from the proposed development itself.
As required by the State Environmental Quality Review Act (SEQRA), when a developer with a project of this size requests to rezone a property, the rezoning is a reviewable action under SEQRA. The developer must also identify the zoning change it needs as part of the project’s Environmental Assessment Form (EAF and would also require a Comprehensive Plan amendment. To consider these decisions separately would be “segmentation,” contrary to the intent of SEQRA. All three actions — a Comprehensive Plan amendment, rezoning, and the proposed development itself — would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review.
I urge the Commission to recommend against rezoning the property and commit to a leadership role in preserving this environmentally and culturally significant resource for our great City of Troy. 4
Yours truly,
Professor Branda Miller Professor of Media Arts, Arts Department, School of Humanities, Arts and Social Sciences, Rensselaer Arts & Education Coordinator, The Sanctuary for Independent Media [email protected], 518-441-0229
December 28, 2020
Mayor Patrick Madden 433 River Street, Troy, NY 12180
CC: Steve Strichman – Planning Commissioner James Rath – Assistant Planner
Friends of the Mahicantuk
Dear Mayor Patrick Madden,
As a resident of the city of Troy, I’m writing to express opposition to the proposed re-zoning from R1 for the land parcel at 1011 2nd Avenue in Troy NY.
This property is a critical part of the riparian woodland zone as the interface between the riverway and upland forested habitat. Riparian areas are important in ecology and environmental resource management. A report on the riparian zone identified the McDonald Creek-Hudson River catchment basin (where this land parcel is located) as an area of less extreme challenges in terms of overcoming ecological stress and therefore potential candidates for conservation (Conley, 2018). This zone contributes to soil conservation, habitat biodiversity and flora and fauna ecosystems. Riparian zones act as a natural biofilter vital for improving water quality from both surface runoff and excessive sedimentation. Additionally, this parcel plays an active role as a wildlife corridor.
Due to the significant steepness of the slope on this parcel, it is expected that construction will cause significant erosion issues. Contributing factors to significant erosion include the loss of tree cover, scraping of overburden topsoil and dynamite blasting/chemical non-explosive demolition such as a calcium oxide. These are expected to be required to prepare the site to build 240-apartments with underground parking as shown in the newspaper article in (Times Union, 2020). If the re-zoning and development proceeds, irreversible damage to the ecosystem is highly probable.
Many alternate sites exist in Troy for brownfield development – including former industrial and commercial waterfront sites such as the former Price Chopper location 0.4 miles to the south at 865 2nd Avenue in Troy. Brownfield development is currently encouraged by the 2018 Realize
8 Washington Place #2, Troy NY 12180
Troy Comprehensive Plan. In short: a rezoning from R1 should not be permitted as it will discourage brownfield redevelopment.
Additionally, as required by the State Environmental Quality Review Act (SEQR) for a project of the size proposed, a full Environmental Assessment Form (EAF) will be required as this project meets the definition of a Type I action in section 617.4 in SEQR (NYCRR, 2020). The Realize Troy comprehensive plan upholds the commitment from the city to uphold standards under SEQR. Re-zoning this parcel prior to undertaking the full EAF would be contrary to the Realize Troy comprehensive plan.
With the rich history of industry in Troy, few remaining undeveloped land parcels remains in Troy – especially along the waterfront. Many of the existing Troy waterfront is engineered (e.g. vertical sheet wall piling in the Troy seawall). The Realize Troy Comprehensive Plan (City of Troy, 2018) specifically emphasizes Troy’s desire to increase waterfront access for residents through redeveloping the Riverfront Park. Goal #5 in this plan is to “Invest in sustainable infrastructure and protect the environment” through specific actions such as reducing sewer overflows, complying with SEQR, naturalizing the shoreline, detailed construction management plans for river adjacent developments, and preserving, protecting and enhancing existing ecological resources.
As climate change becomes an issue that permeates all levels of government, local municipal government has a role to play in preserving land that acts as a carbon sink to sequester carbon. According to analysis performed using i-Tree Canopy software (USDA Forest Service, 2020) this land parcel is estimated to sequester approximately 14 tons of carbon annually in addition to the 351 tons of carbon currently stored in trees on this parcel. The Realize Troy Comprehensive Plan acknowledges that 3 ft of sea-level rise is estimated to impact downtown Troy by 2080 and that Troy signed the “Climate Smart Communities” pledge to become more resilient and help combat climate change. Presumably, preserving carbon sinks would be part of that pledge.
In summary due to environment concerns with this pristine riparian woodland, the availability of other suitable brownfield sites, the incompatibility with the Realize Troy Comprehensive Plan/SEQR and the climate change impacts of losing this carbon sink, the commission should recommend against rezoning this property and the City of Troy should make it the highest priority to preserve this site from future development.
Thank you for your consideration,
Mike Preiksaitis
8 Washington Place #2, Troy NY 12180
REFERENCES
City of Troy. (2018, 5 1). City of Troy. Retrieved from Realize Troy Comprehensive Plan: https://www.troyny.gov/wp- content/uploads/2019/09/RealizeTroyComprehensivePlanMay2018.pdf
Conley, A. K. (2018). Statewide Riparian Opportunity Assessment. Albany NY: New York Natural Heritage Program. Retrieved from https://nynhp.org/files/TreesForTribs2017/Statewide_riparian_assessment_final_jan20 18.pdf
NYCRR. (2020, 12 28). Retrieved from 617.4 Type I actions: https://govt.westlaw.com/nycrr/Document/I4ec3a764cd1711dda432a117e6e0f345?co ntextData=%28sc.Default%29&transitionType=Default
Times Union. (2020, 8 26). Retrieved from Troy apartment project stirring oposition: https://www.timesunion.com/business/article/Troy-apartment-project-stirring- opposition-15517357.php
USDA Forest Service. (2020, 12 28). Retrieved from i-Tree Canopy: https://canopy.itreetools.org/
8 Washington Place #2, Troy NY 12180
Don Rittner 835 Central Pkwy Schenectady, NY 12309 [email protected]
To members of Troy’s Planning Commission
The proposed development in Lansingburgh/Speigletown at 1011 2nd Avenue is an area of high archaeological potential considering it is near the confluence of two major river valleys, the Hudson and Mohawk. Lansingburgh has been long known to have been settled by Algonquian speaking people (Mohican) and alter Iroquoian (Mohawks) and various names for part of the Burgh have been recorded by early settlers and historians. This territory was recorded as early as 1614 as found on the Adriaen Block map of New Netherland and Cornelius Hendrickson map of 1616, two early Dutch traders of the Hudson Valley and who were responsible for the founding of nearby Albany.
Panhoosick lay north of Troy near the Piscawen Kill (Middleburgh St). Part of the name is retained in the area (Hoosick).
Potquassick was an early name for Lansingburgh and might mean “round stones.” One historian applied the name to a woodland east of the river and “near a small island commonly known as whale fishing island.” Whale Island was in the Hudson directly across from Herman Melville’s home, now the Lansingburgh Historical Society at 2 114th Street. The name of a whale is from pootau, “he blows strongly.” The place name seems to be from petuhqui “it is round” and quassik, means “Stone.” Whale Island is now buried under the raised level of the Hudson River. Whale Island was inspiration for Melville’s writing.
Sheepschack was on the site of Lansingburgh according to a 19th century historian. It may be derived from seip, “a river.”
Taescameasick is also placed on the site of Lansingburgh and suggests a ford.
Nachtenac was used to describe Waterford and the mouth of the Mohawk River. It means “Excellent land.”
Quahemiscos is Mohican for Van Schaick Island.
Tiosaronda is Mohawk for the junction of the Mohawk and Hudson Rivers and means “mingling of two streams,” or “place where streams empty themselves.”
In addition, over the last century and a half, many Native sites have been found in the Burgh.
Just yards from this proposed development site is a well know flint mine, now on the property of the Hannaford shopping market. Flint, or Chert, is a sedimentary cryptocrystalline form of Quartz and is found in rocks such as limestone and chalks and was used extensively for tool making and hunting implements from the first arrivals of indigenous people in the area some 10,000 years ago.
The famous Flint Mine Hill in Coxsacki for example is on the National Register of Historic Places. West Athens Hill, south of us, is a well-known Paleoindian work site that dates back to about 13,000 years ago. These deposits of flint were well known to indigenous peoples of the area and they often lived close by.
Over the last two centuries and particularly in the 19th and early 20th century, amateur archaeologists combed the banks of the Hudson River in the Capital District discovering Native sites of various ages. In 1897 a Native cemetery was uncovered near the intersection of River and Second Avenues; a neighboring camp site was also located. There was an early camping spot of three acres with signs of two occupations on nearby Green Island.
The famous Menomine’s Castle (village) was located on Peebles Island and can be seen on the Van Rensselaer Map of 1631. Chief Menomine was killed in the Mohican war with the Mohawks between 1624-1626.
So is Unawats Castle in South Troy. It is an Algonquin word and may be derived from oosoowneat, meaning “To swim” as a place favorable or bathing, or a customary way of crossing.
In 1922 Arthur C. Parker reported the discovery of “chipped red slate” projectile points at the southeast end of Peebles island. A collector named Albert C. Hurd of Troy found several sites in Troy, the Burgh, and surrounding area and also found sites at the northeast end and on either side of the railroad tracks on the island.
On nearby Van Schaick Island, a burial of a Native woman and her child was uncovered on the golf course and in 1926 Homer Folger of the Burgh, a carpenter at the Matton Shipyard, discovered a Native burial and artifacts near the shipyard, north of the yard.
Folger in 1933 found another well preserve Indian burial and in April 1938 he found two burials that has been exposed by the high water of the river at the north tip of Van Schaick Island. The bodies were buried in a fetal position and a projectile point was embedded in the skull of the one of the burials.
Indian burials were found during WW II when a new frame building was constructed at Matton. North of Peebles Island other Native burials have been found. In 1981 Native bones were uncovered while a sewer connector was being dug at 43 Hudson River Road, about a mile north of Broad Street in Waterford. North of Peebles Island just across the Mohawk River Channel three burials were uncovered in 1995 in Waterford all in fetal position. There was radiocarbon dates to ca. 995 AD. A third burial was dated 1435 AD.
Many other artifacts were found on the Matton Shipyard over the years north of the yards including eight Owasco Indian Burials with large pit features with fragments of Late Woodland Iroquois pots.
Menomine’s village moved around and some believe it once was located on the east bank of the Hudson not far from this proposed development site near a stream. Also, on a 1639 map it shows this possible village on the north side of the Mohawk below the Cohoes Falls and is labeled Vastichuyt meaning stronghold. In 1640 a Dutch visitor of the falls recorded there “are many Indians here, whom they call Maquas [Mohawks].” The Mohawks had driven the Mohicans from the land earlier.
A village site north of the Waterford Bridge along the Hudson was recorded in 1920. The site was extensive and yielded an abundance of stone artifacts. This would have been directly across from the development site and it is highly likely that a settlement was here on the east side of the river and close to the flint mine.
When the Freihofer’s Bakery was being built, several Native skeletons were recovered from it.
At the foot of Glen Avenue in the “Batestown” section of the Burgh, workmen grading the Laureate Athletic grounds in 1890 found two well preserved Native skulls about four feet from the surface. There was more as published in the Troy Daily Times:
An Indian Burial-Ground—Workmen Make an Interesting Discovery.
The workmen grading the Laureate athletic grounds, at the foot of Glen avenue, were surprised yesterday at the discovery of human bones. Two well-preserved skulls were exhumed, about four feet below the surface, on the bank of the river. The men were digging up the loam which is being placed on the baseball diamond. Other bones were uncovered, and this morning another skull was found. The lower jaw was in place and most of the teeth were found. The contractor said this morning that the bones of about a dozen persons had been found. From the location it is believed that a burial-place of the old Mohawk Indians was uncovered. Twenty years ago, when the Waters boat-factory was built several feet north, the bones of several persons were found, and with them arrowheads and other Indian relics were discovered. Troy Daily Times. June 3, 1890: 3 col 6.
As late as 2012, artifacts attributed to Mohican occupation were found in the South Troy industrial park on the east bank.
As you can see prehistoric occupation of the Troy-Lansingburgh area is well documented and considering that many sites have been found near the proposed development and directly north of this site, it is imperative that a well-funded archaeological study must be conducted by the developer before any rezoning or use is made of the land. I feel quite confident that there is evidence of Native occupation on the proposed development site, and I have been told informally that artifacts have been found on the site. Changing the zoning on this site could create adverse harm to subsurface archaeological resources. Allowing any form of structural development could completely destroy a part of Troy’s prehistory which is only now being researched and uncovered for future generations.
The city should require an environmental review under SEQRA before any rezoning is considered. While my remarks are solely geared on historic and archaeological resources there are many other environmental and social issues that need to be addressed and I am sure will be taken by other interested parties.
Don Rittner, Professor of Archaeology, WCC Author and Historian. December 29, 2020
Historically Known Prehistoric Archaeological Sites in Lansingburgh and Surrounding Area
Compiled by Don Rittner James.Rath
From: Gabriel Romero-Quiroz
Hello,
I am writing today to express my discomfort and displeasure at hearing of the plans for rezoning of the beautiful and historic forest, the last forest on the waterfront in Troy, at 1011 2nd Ave.
I respect the city's need for economic development, but one thing that is more important than a couple apartments is Troy's civic duty to steward and represent a site of unique importance to the Native Mahican people. The site at 1011 2nd Ave. is 5,000 years old and has been recognized as eligible for listing on the National Register of Historic Places. Preservation of this site and its unique and diverse wildlife must be the highest priority.
Additionally, rezoning the property would be inconsistent with Troy’s 2018 Realize Troy Comprehensive Plan. The Comprehensive Plan was meant to be an expression of the community’s vision for the city; and the community did not envision clunky, view-blocking, multi-unit housing on Troy’s northern waterfront. At a minimum, the City is required to amend its Comprehensive Plan if it intends to change the zoning in a way that is contrary to the plan.
Finally, Troy must follow the law. For a project of this size, rezoning can not be considered separately from the proposed development itself. As required by the State Environmental Quality Review Act (SEQRA), when a developer with a project of this size requests to rezone a property, the rezoning is a reviewable action under SEQRA. The developer must also identify the zoning change it needs as part of the project’s Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified from the start in the EAF so that the potential environmental impacts associated with them can be considered together. Because this zoning change would also require a Comprehensive Plan amendment, that too must be identified in the EAF. To consider these decisions separately would be “segmentation”, contrary to the intent of SEQRA.
In this case, it is clear that all three actions — a Comprehensive Plan amendment, rezoning, and the proposed development itself — would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review by a designated lead agency.
The Commission should recommend against rezoning the property as being premature until the developer has submitted an EAF and the City has made a SEQRA determination.
Thank you and be well, Gabriel Romero BA in Linguistics, SUNY Albany 518-419-5853 [email protected]
1
To: The City of Troy Planning Commission, Planning Commissioner Steven Strichman, and Mayor Patrick Madden
Regarding: Meeting of the City Council Planning Commission on Tuesday, December 29, 2020
Respectful greetings:
I am Sachem (hereditary chief) Robert HawkStorm Yawanawa of the Schaghticoke First Nations.
The Schaghticoke are an Indigenous Peoples of this region who are opposed to the development and rezoning proposal for 1011 2nd Street due to a number of factors, but among the most important, is the historic significance of this land.
This property has great historic and cultural significance for the Indigenous Peoples of the Mahicantuck River Valley including the Schaghticoke First Nations, as well as the Munsee and Lenape Nations. This land was a permanent and semi-permanent settlement of various groups of Algonquin-speaking indigenous Peoples and included a critical ceremonial ground. The land was also a quarry for the production of tools and weapons, particularly arrowheads and still contains a significant portion of indigenous artifacts. According to the statements made by the developer during the May hearing of the Planning Commission, a majority of test wells produced a significant amount of artifacts. According to the developer’s engineering consultant, as stated at the workshop on November 19th, this site is also National Register eligible.
The property’s historical-archeological significance is reaffirmed by several studies, including historical and cultural assessments connected to the GE remediation (see Decision 2002), a recent study and report conducted by Hartgen Archeological Assoc, a study in 2015 by Ann Morton, and long-running explorations, studies and examinations by Hetty Jo Brumback. All these studies identify the entirety of the property waterfront as bearing key archeological artifacts. There are strong indications that despite the rest of the property not having been
Website: https://www.schaghticoke.info/ Email: [email protected]
1
independently examined, important artifacts and archeological potential remains for the rest of the property and beyond.
Despite these verifiable privately contracted surveys, research in association with these reports indicate inadequate assessment and archeological recovery on this site. The development of the site and space can negatively impact and threaten the cultural and historical heritage, as increased foot traffic, artifact-hunters, and pollution all can contribute to major disturbances and irrevocable loss.
Additionally, we support an alternative vision for this land: to bring it into long term preservation, maintain trails, bring food forestry to this land for the community, and ensure its proper ecological, archeological and cultural preservation. Community groups in Troy, including the Friends of the Mahicantuck and their local, regional and statewide partners are committed to working towards securing the necessary resources to preserve this land, bring it into trust and maintain it for the public good.
We support this vision and urge the city, it’s council and mayor, as well as the planning commission to work with the group, indigenous leaders, the current owner of this land, and the developer to realize it. This is an opportunity for the city to enhance its public spaces and historical and cultural heritage within a potential environmental justice area.
Finally, there are several concerning inconsistencies regarding the current review process for the proposed rezoning.
● Rezoning the property would be inconsistent with Troy’s 2018 Realize Troy The Comprehensive Plan was an expression of the community’s Comprehensive Plan. vision for the city, and the community did not envision dense multi-unit housing on Troy’s northern waterfront. At a minimum, the City is required to amend its Comprehensive Plan if it intends to change the zoning in a way that is contrary to the plan. ● Troy must follow the law. For a project of this size, rezoning can not be considered As required by the State separately from the proposed development itself. Environmental Quality Review Act (SEQRA), when a developer with a project of this size requests to rezone a property, the rezoning is a reviewable action under SEQRA. The developer must also identify the zoning change it needs as part of the project’s Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified from the start in the EAF so that the potential environmental impacts
Website: https://www.schaghticoke.info/ Email: [email protected]
2
associated with them can be considered together. Because this zoning change would also require a Comprehensive Plan amendment, that too must be identified in the EAF. To consider these decisions separately would be “segmentation”, contrary to the intent of SEQRA.
In this case, it is clear that all three actions — a Comprehensive Plan amendment, rezoning, and the proposed development itself — would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review by a designated lead agency.
The Commission should recommend against rezoning the property as being premature until the developer has submitted an EAF and the City has made a SEQRA determination.
Schaghticoke First Nations is aware that there is a wide scope of legal grounds for why the requested change in zoning code cannot be granted. Further, we are also aware that there are other locations in the area that could be better suited to the development being submitted, one of which is currently under the same ownership as the land at 1011 2nd Avenue.
In closing, we call upon this commission to consider that instead of destroying the last tract of forest on the waterfront in Troy, we could work together in collaboration with property owners, and local community groups toward providing a unique opportunity for racial and environmental justice, education, and sustainable tourism in the area. At the very least, however, we urge the city and this commission to follow the proper process as detailed in the New York State Environmental Quality Review Act (SEQRA) and recommend against the rezoning as premature until the developer has submitted an EAF and the City has made a SEQRA determination.
Respectfully submitted,
Sachem Robert HawkStorm Yawanawa
Schaghticoke First Nations, and Schaghticoke First Nations, Inc.
Website: https://www.schaghticoke.info/ Email: [email protected]
3 James.Rath
From: Dara Silbermann
Good evening, Planning Commission! It's been three years since I stood before this panel for my own project, the 2nd Street Farm. My name is Dara Silbermann, and I live on 2nd Street in South Troy. I'm writing today to urge that you recommend against the proposed zoning change Kevin Vandenburgh is requesting.
In the years since my own Planning Commission hearing, I've learned a lot about municipal operations here in Troy, and it's clear to me that a system that demands my little Pay-What-You-Can farm stand go through the same approvals process as this complete neighborhood overthrow that Kevin Vandenburgh is proposing is not only absurd, it's a primary mechanism for preferencing well-capitalized "development" over actual community building and the efforts of average working folks in our City. This is obvious not only from the process itself as I've already explained, but from the very application that the developer himself has submitted. He attests in addition to turning a profit, he hopes to "appease" the community. Note he does not say he wants to contribute to the existing community, he does not mention how he will integrate neighbors. Just that he hopes to "appease" us. That language assumes we the community are an antagonist. How can we, as the community, trust anything in regards to this project when we are already cast as an adversary, merely an entity to be mollified?
The community of Troy has spoken this year about what we need for the "appeasement" Mr. Vandenburgh refers to in his application. We need racial justice. We need political justice. We need a municipal government that works for us, not for developers merely wishing our "appeasement," developers who will hold this city hostage as they stump for tax breaks unavailable to capital-starved community developers like myself. How, Mr. Vandenburgh, can you hope to appease the community when our loudest cry of the year - a cry for racial justice and radical acceptance of the abuses against Black and Indigenous peoples - will be yet again silenced should your project be successful?
When I stood before this Planning Commission three years ago, the Chairperson read my proposal and asked me why I was even there. It was a good question, as there really wasn't a legal requirement for me to have Planning approval. I was there because I, like Kevin Vandenburgh, was working on my own appeasement game: I was aiming to appease the City of Troy. The community - over 30 of whom showed up in-person to support my zoning variance - was already with me. My efforts to act in good faith didn't score me any points with the City though, despite my work being celebrated by community members from every racial, political, economic, and social identity group.
Today I'm asking this commission to follow its own procedure and demand proper protocol be respected. A rezone of this property should be considered in conjunction with the project itself, and the community should have ample time to express their concerns. We deserve a proper environmental impact statement from this developer, and we should have the ability to comment publicly on it. As a highly-skilled farmer, I have much more to say during that period regarding the importance of wild lands for the success of my work and what Mr. Vandenburgh can do to appease me, but I know this Commission will stand with the people and make sure I have that opportunity. Putting this question to a special meeting tucked in between Christmas and New Years seems like the best to ensure the community is shut out of the conversation, so perhaps your votes tonight will indicate that you've heard our demands, not just sided with the developers low expectations of appeasement. I urge you to recommend to the City Council that they reject this call for a rezone of 1011 2nd Avenue.
1
Thank you for your consideration and Happy New Year. In solidarity, dara
2 From: Patrick.Madden Sent: Thursday, December 24, 2020 10:15 AM To: Monica.Kurzejeski; Steven.Strichman Subject: Fwd: Indigenous lands site
Sharing
Sent from my iPhone
Begin forwarded message:
From: Jane Snay
:To Whom It May Concern
There is no need to ruin the last historical forest and indigenous lands for another apartment complex. There have been and are currently many large apartment complexes being built in the City. There are still hugh sites to build already such as monument square, the old Leonard hospital site and the area along the river when the Taylor Apts are taken down. There also are numerous abandoned / run down buildings. Try tearing down and replacing these buildings with owner occupied homes and green spaces. The comprehensive plan called for de- densifying the neighborhoods for a better quality of life.
The City services are already over taxed, parking is a nightmare in this City and the roads are a disgrace. Troy needs to look to the future and follow the comprehensive plan many of us participated in forming. We need green spaces, abandoned buildings, descent roads and quality of life issues addressed. We are being overbuilt with all these large apartment complexes while the neighborhoods are falling apart.
Respectfully submitted, Jane Snay 521 4th Street Troy,N.Y.12180 Email [email protected] James.Rath
From: William Studdiford
Dear Mr. Rath,
I am writing as regards the parcel of land at 1101 2nd Avenue.
I stand in opposition to the move to rezone the land. Developing the land in the manner envisioned by the developer would have numerous negative impacts upon the land, the Hudson River, and the community surrounding the parcel. If the zoning is to be altered, it must be done properly, and legally, via the procedures and mechanisms set forth by the State Environmental Quality Review Act. And, in doing so, many of these impacts will become obvious.
I recommend not changing the zoning.
Regards,
William Studdiford
1
The Economic Value of Riparian Buffers in the Delaware River Basin
August 2018
Prepared for: Delaware Riverkeeper Network
FINAL REPORT
KOIN Center 222 SW Columbia Street Suite 1600 Portland, OR 97201 503.222.6060
ECONorthwest 1 Contact Information
Austin Rempel and Mark Buckley prepared this report with the assistance of a number of other ECONorthwest staff. ECONorthwest is solely responsible for its content. ECONorthwest gratefully acknowledges the data and assistance provided by Doug Norton and Elizabeth Smith of the US EPA.
ECONorthwest specializes in economics, planning, and finance. Established in 1974, ECONorthwest has four decades of experience helping clients make sound decisions based on rigorous economic, planning and financial analysis.
For more information about ECONorthwest, visit our website at www.econw.com.
For more information about this report, please contact:
Dr. Mark Buckley
ECONorthwest 222 SW Columbia Street, Suite 1600 Portland, OR 97201 503-724-8445 [email protected]
ECONorthwest 2 Disclaimer
ECONorthwest completed this project under contract to Delaware Riverkeeper Network.
Throughout the report we have identified our sources of information and assumptions used in the analysis. Within practical limits, ECONW has made every effort to check the reasonableness of the data and assumptions and to test the sensitivity of the results of our analysis to changes in key assumptions.
We gratefully acknowledge the assistance of the many individuals who provided us with information and insight. But we emphasize that we, alone, are responsible for the report's contents. We have prepared this report based on our own knowledge and training and on information derived from government agencies, the reports of others, interviews of individuals, or other sources believed to be reliable. ECONorthwest has not verified the accuracy of such information, however, and makes no representation regarding its accuracy or completeness. Any statements nonfactual in nature constitute the authors' current opinions, which may change as more information becomes available.
ECONorthwest 3 Table of Contents
EXECUTIVE SUMMARY 7
INTRODUCTION 9 BACKGROUND ON ECOSYSTEM SERVICES AND THEIR ECONOMIC VALUE 9 Techniques for Estimating Value of Ecosystem Services 11
RIPARIAN LAND COVER IN THE DELAWARE RIVER BASIN 13 Implications for Buffer Protection 21
RIPARIAN ECOSYSTEM SERVICES IN THE DELAWARE RIVER BASIN 23 Categories of Benefit 23 Buffer Widths and Vegetation Cover 23 Multiple vs. Single Service Provision 24 A. VALUES OF SPECIFIC ECOSYSTEM SERVICES 25 1. WATER QUALITY 25 Nitrogen and Phosphorus Reductions 27 North Carolina Buffer Mitigation Program 30 Sediment Reductions 31 Urban Stormwater Treatment 34 Drinking Water Source Protection 35 2. CARBON STORAGE 36 3. AIR QUALITY 38 4. FLOOD MITIGATION 38 5. PROPERTY VALUES 41 6. FISH AND WILDLIFE HABITAT 42 Riparian Forest Cover and Aquatic Habitat Health 43 Habitat Connectivity 44 Existence Values 46 7. RECREATION 46 B. AGGREGATE VALUE OF RIPARIAN BUFFER SERVICES 49 SUMMARY OF RIPARIAN ECOSYSTEM SERVICES IN THE DELAWARE RIVER BASIN 51
IMPLEMENTING PROTECTION AND RESTORATION OF RIPARIAN AREAS 53 Protection vs. Restoration 53 Urbanization 54 Social Barriers and Constituencies 55 Policy Implications 58
APPENDIX MAPS 60
ECONorthwest 4 List of Figures Figure 1. Components of Total Economic Value ...... 10 Figure 2. Hierarchy of Benefit Analysis ...... 12 Figure 3. Resolution of Satellite Imagery and Buffer Width ...... 13 Figure 4. 350-foot Riparian Buffer Zones in the Delaware River Basin ...... 15 Figure 5. Land Cover Acreages within the Riparian Zone (350-foot Buffer), Delaware River Basin, 2011 ...... 16 Figure 6. Land Cover Composition within the Riparian Zone (350-foot Buffer), Delaware River Basin, 2011 ...... 16 Figure 7. Percent Developed and Undeveloped Cover within the Riparian Zone (350-foot Buffer), Delaware River Basin, 2011 ...... 17 Figure 8. Land Cover Changes in the Riparian Zone (350-foot Buffer) 2001-2011, Delaware River Basin ...... 18 Figure 9. Land Cover Changes in the Riparian Zone (350-foot Buffer) by State, 2001-2011, Delaware River Basin...... 19 Figure 10. Percent Land Cover Change in the Riparian Zone (350-foot Buffer) by State, 2001- 2011, Delaware River Basin ...... 20 Figure 11. Stream Segments Listed as Impaired by the EPA ...... 26 Figure 12. Annual flood peaks recorded on the Delaware River at Trenton, N.J., 1898-2015...... 39 Figure 13. Movement Corridors and Habitat Connection ...... 45 Figure 14. Planned Network of Streams, Trails, and Greenway Connections in the Delaware Valley ...... 48 Figure 15. Urban Development Projections, 2011-2070 ...... 55 Figure A-16. Percent Cover in Riparian Zone, 2011 ...... 61 Figure A-17. Percent Change in Land Cover, 2001-2011 ...... 62
List of Tables Table ES1. Benefits of Protected Riparian Areas ...... 8 Table ES2. Ecosystem Services Provided by Riparian Buffers in the Delaware River Basin, and Per-Unit Values ...... 8 Table 3. Techniques Used to Estimate Economic Value of Ecosystem Services ...... 11 Table 4. Development of Natural Riparian Areas and Net Loss of Riparian Cover in the Delaware River Basin by State and Buffer Width (Acres), 2001-2011 ...... 22 Table 5. Buffer Vegetation and Effectiveness ...... 24 Table 6. Increase in Nutrient Delivery with Land Use Change ...... 27 Table 7. Nutrient Loads and Estimates of Buffer Treatment Capacity ...... 28 Table 8. Increase in Nutrient Delivery with Buffer Losses ...... 29 Table 9. Annual and Projected Nutrient Costs from Riparian Development ...... 30 Table 10. Benefits of Sediment Capture ...... 32 Table 11. Increase in Sediment Delivery with Land Use Change ...... 32 Table 12. Sediment Loads and Estimates of Buffer Treatment Capacity ...... 32 Table 13. Increase in Sediment Delivery with Buffer Losses and Economic Values ...... 33
ECONorthwest 5 Table 14. Annual and Projected Sediment Costs Associated with Riparian Development ...... 34 Table 15. Costs of Stormwater Treatment by Land Cover ...... 35 Table 16. Land Use Change and the Value of Lost Carbon Storage Capacity ...... 37 Table 17. Annual and Projected Values of Lost Carbon Storage ...... 37 Table 18. Annual and Projected Air Pollution Damages from Riparian Development ...... 38 Table 19. Buffer Widths Required by Various Wildlife Species ...... 43 Table 20. Stream Health Rankings and Forested Buffers ...... 44 Table 21. Value of Private Lands for Recreation ...... 47 Table 22. Annual and Projected Recreation Losses Associated with Riparian Development ...... 47 Table 23. Representative Household WTP (Willingness to Pay) for Riparian Protection Measures and Benefits ...... 50 Table 24. Estimated Household Values for Increased Riparian Protection ...... 50 Table 25. Summary of Ecosystem Services Values by Riparian Buffers in the Delaware River Basin ...... 51 Table 26. Summary of Projected Ecosystem Service Losses, by State, 2018-2028 ...... 52 Table 27. Distribution of Benefits and Costs from Buffer Policies ...... 58
ECONorthwest 6 Executive Summary
Riparian buffers are strips of undeveloped land surrounding streams, rivers, ponds and reservoirs. They help to protect water bodies from the impact of adjacent land uses, and provide a suite of crucial ecological services including water purification, flood control, climate regulation, corridors for wildlife movement, and opportunities for outdoor recreation (Table ES1).
Over the past 300 years, nearly half of the Delaware River Basin’s original riparian forests have been cleared. Remaining forests are threatened by expanding suburban development. In this report we value losses in ecosystem services that may result from ongoing trends in riparian development and land clearing in the Basin. Specifically, we assess the loss of ecosystem services associated with a 0.6 percent decline (nearly 1,700 acres) in natural riparian land cover within 100 feet of water bodies across the Basin, as occurred between 2001 and 2011. We then project this same rate of development over a 10-year time frame, 2018 to 2028.
Without more effective protection for riparian buffers, we estimate an annualized loss of approximately $981 thousand to $2.5 million in the value of monetized ecosystem services. Translated to a single acre, buffers provide over $10,000 per acre per year in monetized benefits (Table ES2), with additional non-monetized benefits expected to increase this total. Considering these benefits over time, policies that protect riparian corridors represent one of the most efficient investment opportunities facing communities in the Basin.
Total benefits over time, and with extension to even wider buffers, are clearly in the tens of millions of dollars. These benefits are orders of magnitude greater than the one-time costs of protecting these areas before they are developed. Providing these benefits through conservation rather than restoration is particularly cost-effective. The specific benefit categories addressed in this report are:
• Water Quality • Carbon Storage • Air Quality • Flood Prevention • Property Values • Wildlife Habitat • Outdoor Recreation
The connections that riparian corridors provide between fragmented habitats and land parcels are important for both wildlife (enabling dispersal and migration) and humans (a benefit that is increasingly highlighted in regional park and trail plans). Climate change and urbanization will increase the importance and value of buffer services (e.g., by allowing communities in the Basin to adapt to rising recreation demand, increased wastewater and stormwater discharges, and higher peak temperatures affecting streams). Table ES1 summarizes riparian buffer benefits, and Table ES2 summarizes monetary values for a subset of these benefits.
ECONorthwest 7 Table ES1. Benefits of Protected Riparian Areas Source: ECONorthwest with data from multiple sources (see report) Effect Category Riparian Buffer Effects Ecosystem Services
ê Water treatment costs é Sediment capture é Drinking water quality é Nutrient uptake and filtration é Water clarity Water Quality ê Sediment, nitrogen and phosphorus delivered é Quality and quantity of water-based recreation to waterways ê Fish kills and algae blooms ê Summer water temperatures ê Reservoir and channel dredging é Aesthetic conditions surrounding nearby é Residential property values homes (shade, flood protection, noise reduction, Community Appeal é Property tax base privacy) and Livability é Quality and quantity of land- and water-based é Visual appeal of riparian recreation areas and recreation water trails é Aquatic inputs (e.g., leaves, fallen trees, insects) for food and cover é Recreational fishing opportunities é Bank stability é Commercial fish harvests Aquatic Habitat é Stream shading é Abundance of sensitive aquatic species ê Summer stream temperatures ê Habitat enhancement/replacement costs é Dissolved oxygen levels é Habitat for wildlife foraging and breeding é Hunting and wildlife viewing opportunities é Connections between isolated habitats Terrestrial Habitat é Abundance of sensitive wildlife species é Conduits for daily movement to annual ê Habitat enhancement/replacement costs migrations ê Damage to downstream property and crops ê Runoff speed ê Flood insurance premiums Flood Control ê Downstream flood peaks ê Flood infrastructure and control costs ê Sediment loads ê Risk to human life
é Improved human health ê Healthcare costs Carbon Storage é Capture and storage of carbon, airborne ê Climate Change effects and extreme weather and Air Quality particulates, nitrogen and sulfur dioxides events é Climate resiliency
Table ES2. Ecosystem Services Provided by Riparian Buffers in the Delaware River Basin, and Per- Unit Values Source: ECONorthwest with data from multiple sources (see report) Ecosystem Service Provided Per-unit Value for Services Nutrient Retention $87 to $4,789 per acre per year Carbon Storage $4,762 to $8,477 per acre per year Air Quality $3 to $132 per acre per year Aesthetic Values +1% to +26% Property Price Premium Flood Mitigation Qualitative Description Recreation $63 per acre per year (lower bound) Wildlife Habitat Qualitative Description Combined Buffer Services $14/Household/Year
ECONorthwest 8 Introduction
Riparian areas occupy only three percent of the landscape but they provide a disproportionately diverse and important set of ecological services to society, and conservation benefits throughout the watershed (Table ES1).1 These benefits are particularly important when much of the remainder of the watershed is developed, as in the Delaware River Basin.
In this analysis, we consider the potential benefits of protecting and restoring riparian areas across the Delaware River Basin. We begin by providing the economic framework for evaluating the value of ecosystem services provided by riparian zones. Next, we describe the status and recent trends of land cover within the Basin’s riparian zones. We then consider the ecological functions of riparian areas and draw on peer-reviewed literature and governmental reports to assign economic values to these services.
The steps in this analysis are: 1. Provide an economic framework based on ecosystem services to assess riparian buffer benefits in the Delaware River Basin. 2. Quantify the existing area of riparian buffers and rates of loss across the Basin 3. Review existing literature on the economic benefits of riparian buffers relevant to the Basin and compile monetary values. 4. Estimate the monetary and non-monetary benefits associated with avoiding further loss of riparian buffers. 5. Consider policy design implications of economic findings, including urgency associated with urbanization trends.
The final results of this analysis are: • A series of maps detailing the status and trends of riparian buffers in the Delaware River Basin • A literature review of economic benefits of riparian buffers relevant to the Basin • Monetary values of ecosystem services of riparian buffers in the Basin by relevant spatial and household units • Net benefits over time for avoiding continued loss of riparian vegetation Background on Ecosystem Services and their Economic Value
Ecosystem services are the benefits that humans derive from functional ecosystems. Identifying and accounting for ecosystem services in a systematic way provides a methodical approach for describing the numerous benefits provided by ecosystems. It can also ensure proper
1 Jones, K.B., Slonecker, E.T., Nash, M.S., Neale, A.C., Wade, T.G. and Hamann, S., 2010. Riparian habitat changes across the continental United States (1972–2003) and potential implications for sustaining ecosystem services. Landscape Ecology, 25(8), pp.1261-1275.
ECONorthwest 9 incorporation of demand into the valuation process, recognizing where a particular service is scarce and where it is not. Ecosystem service approaches strive to align valuation with market- based values to reduce criticism and translate benefits into cost-savings terms that will be relevant even to those for whom ecological protection is not an ethical priority. In this section we describe the conceptual framework for ecosystem services, and the techniques used to value them.
Ecosystem services exist only insofar as there is human demand for their supply. Furthermore, the value of ecosystem services is derived from the ways in which humans demand them. Figure 1 demonstrates the various types of economic value for ecosystem services. Total economic value is made up of several components. Direct use value describes the value associated with direct use of an ecosystem service such as breathing clean air or drinking clean water. Indirect use value describes the ecosystem services that precede direct services. Soil fertilization, for example, promotes tree growth, which in turn, plays a role in air purification.
Figure 1. Components of Total Economic Value Source: ECONorthwest
Total Economic Value
Use Value Passive Use Value
Option Value
Direct Use Indirect Use Existence Bequest Value Value Value Value
Passive use values are less obvious but are, in some instances, greater than use values. Existence value describes an individual’s demand for the existence of a particular object. Bequest value describes an individual’s demand for the future existence of a particular object. Typically, these values are described in terms of an individual’s willingness to pay for an object’s current or future existence. For example, if an individual is willing to pay a positive sum of money to prevent bald eagle extinction, then she likely is placing existence value on the species. Similarly, if she would be willing to donate a positive sum of money to a conservation fund aimed at maintaining bald eagle health into the future, she likely is placing bequest value on the species.
Option value can fall into either the use or passive use categories. It describes the value of keeping the option open to use a resource or service in the future. For example, some residents of the Basin might feel that the region already has enough riparian habitat, but that there would still be value to additional habitat for the contingency that existing habitat declines, or science reveals a greater need for habitat.
ECONorthwest 10 Techniques for Estimating Value of Ecosystem Services In the absence of well-formed markets, economists have developed techniques for estimating the value of ecosystem services based on the characteristics of the services and the benefiting population. Table 3 summarizes some of the primary techniques for valuing ecosystem services.2
Table 3. Techniques Used to Estimate Economic Value of Ecosystem Services Source: ECONorthwest based on EPA (2009) Estimate the value of a service by identifying and estimating the cost of Avoided Cost future projects or programs that would be needed but for the current existence of the service. Estimate the value of a service at a particular site based on analyses Benefit Transfer estimating the value of a similar service in another geographic location. Estimate the value of a service with questionnaires asking respondents Contingent Valuation how much they would be willing to pay to protect the service, or how much they would be willing to accept to forego the service. Estimate the value of a service by comparing property values of multiple Hedonic Analysis households, controlling for several factors, and determining the impact of changes in quantity or quality of the service on property value. Estimate the value of a service by identifying and estimating the cost for Replacement Cost projects or programs required to replace the service. Estimate the value of a service by calculating the time and money spent by Travel Cost individuals traveling to enjoy or experience the service
Benefit analysis typically progresses from identification of benefits to estimating their monetary value. It is not feasible or appropriate to use dollar values for all potential benefits of riparian areas. Sufficient information is available to assign a dollar value to only a small subset of the total universe of ecosystem goods and services provided by riparian areas in the Basin (Figure 2). Other ecosystem goods and services, such as nutrient cycling, food production, and spiritual fulfillment, provide society with additional benefits, but resist quantification in physical and monetary terms. Other benefits might be theorized to exist, but cannot be identified and verified. Finally, there are potentially other valuable ecosystem goods and services that science does not currently allow us to recognize.
2 U.S. Environmental Protection Agency. 2009. Valuing the Protection of Ecological Systems and Services: A Report of the EPA Science Advisory Board. Report No. EPA-SAB-09-012.
ECONorthwest 11 Figure 2. Hierarchy of Benefit Analysis Source: ECONorthwest
Table ES1 (pg. 7) shows the ecosystem effects and services provided by riparian buffers. Some of these benefits can be reliably measured using market prices, while others are best described by other means. The remainder of this report details the analyses necessary to value these services in the Delaware River Basin.
ECONorthwest 12 Riparian Land Cover in the Delaware River Basin
In this section we assess the current extent of intact riparian vegetation and trends in loss and recovery. We use data from the U.S. Environmental Protection Agency’s (EPA) Watershed Index Online (WSIO) to describe riparian land cover composition, and trends between 2001 and 2011. The EPA data rely on LANDSAT remote sensing data that classify land cover within 30x30 meter cells. We exclude all watersheds that fall outside the Delaware River Basin.
The WSIO data include information on land covers and land uses within the riparian zone, defined as a 108-meter (~ 350 feet) buffer around all surface waters and wetlands. The riparian zone includes the following land cover types:
Riparian Zone = Surface Water + Wetlands + Forest (including evergreen forest, deciduous forest, and mixed forests) + Shrub/Scrub + Grassland/Herbaceous + Urban (including high/medium/low intensity development and open space) + Agriculture (including pasture/hay and cultivated crops) + Barren Land
Given the 30-meter (~100 feet) minimum cell size, LANDSAT data are “… not of sufficient spatial resolution to adequately map riparian buffer vegetation within the widely accepted 100-ft (30 m) buffer width used as a common reference for buffer effectiveness”.3 EPA chose 108 meters (~ 350 feet) as the most accurate width to describe riparian land cover in their dataset.
Figure 3. Resolution of Satellite Imagery and Buffer Width Source: Center for Land Use Education and Research, 2008. The Status of Connecticut’s Coastal Riparian Corridors. University of Connecticut. http://clear.uconn.edu/projects/riparian_buffer/results/CLEAR_%20Summary_021508.pdf
3 Goetz, S.J., Wright, R.K., Smith, A.J., Zinecker, E. and Schaub, E., 2003. IKONOS imagery for resource management: Tree cover, impervious surfaces, and riparian buffer analyses in the mid-Atlantic region. Remote sensing of environment, 88(1), pp.195-208.
ECONorthwest 13 To estimate annual rates of land cover change, we divide the ten-year (2001-2011) change totals by ten. To approximate change in land cover at the policy relevant scale of 100 feet, we assume that land cover composition is the same in the 350- and 100-foot (30 meter) buffer zones and that roughly a third (30m/108m = 27 percent) of the annual/decadal change in the 350-foot zone occurs within the 100-foot zone. Previous analyses have confirmed that trends at 350 feet are representative of trends at 100 feet. For example, a previous study that had access to data at multiple scales (Figure 3) reported similar land cover composition and rates of change in the two buffer widths. The rate of development within in the 100-foot zone was slightly lower than that in the 300-foot zone, which the authors suggest may be a result of recently implemented 100-foot buffer protection policies.4
Figure 4 provides a map of the current distribution of riparian buffers in the Delaware River Basin. The data in this map are the basis for the results summarized in Figures 5, 6 and 7. Figure 5 shows the total riparian area within each state in the Basin. Pennsylvania has the most riparian land area in the Basin, and Delaware the least. New York has the highest proportion of natural and forested land within the riparian zone, while Delaware has the lowest (Figure 6 and Figure 7). Almost half of the Basin’s historic riparian cover has been lost to agriculture, shopping malls, housing developments, and highways (Figure 7).
4 Center for Land Use Education and Research, 2008. The Status of Connecticut’s Coastal Riparian Corridors. University of Connecticut.
ECONorthwest 14 Figure 4. 350-foot Riparian Buffer Zones in the Delaware River Basin Source: ECONorthwest with data from the US EPA’s Watershed Index Online
ECONorthwest 15 Figure 5. Land Cover Acreages within the Riparian Zone (350-foot Buffer), Delaware River Basin, 2011 Source: ECONorthwest with data from the US EPA’s Watershed Index Online
PA 795,000
NY 246,000
NJ 501,000
DE 155,000
- 200,000 400,000 600,000 800,000 1,000,000 Riparian Acres
Forest Other Natural Cover Urban Agricultural
Figure 6. Land Cover Composition within the Riparian Zone (350-foot Buffer), Delaware River Basin, 2011 Source: ECONorthwest with data from the US EPA’s Watershed Index Online
DRB 53% 3% 22% 23%
PA 59% 3% 22% 16%
NY 75% 1% 10% 14%
NJ 41% 4% 27% 29%
DE 24% 3% 24% 48%
0% 20% 40% 60% 80% 100% % Cover in Riparian Zone
Forest Other Natural Cover Urban Agricultural
ECONorthwest 16 Figure 7. Percent Developed and Undeveloped Cover within the Riparian Zone (350-foot Buffer), Delaware River Basin, 2011 Source: ECONorthwest with data from the US EPA’s Watershed Index Online
DRB 55% 45%
PA 62% 38%
NY 76% 24%
NJ 44% 56%
DE 27% 73%
0% 20% 40% 60% 80% 100% % of Riparian Zone
Natural Land Cover Human Use Land Cover
Trends in riparian land cover are summarized in Figures 8, 9, and 10, as well as Table 4. Urban development (defined on page 18 of this report) in the riparian zone increased between 2001 and 2011, while forests and agriculture declined. Studies of riparian land cover composition and change conducted elsewhere have reported similar trends.5
Forested cover and natural cover generally declined in all Basin states, while agricultural use declined in three out of four states (increasing slightly in New York State). WSIO data include watershed-scale totals in 2001 and 2011, but not which land uses replaced others. For example, a watershed may have lost forest on the whole between 2001 and 2011, but the data do not
5 See, for example: - Center for Land Use Education and Research, 2008. The Status of Connecticut’s Coastal Riparian Corridors. University of Connecticut. - Jones, K.B., Slonecker, E.T., Nash, M.S., Neale, A.C., Wade, T.G. and Hamann, S., 2010. Riparian habitat changes across the continental United States (1972–2003) and potential implications for sustaining ecosystem services. Landscape Ecology, 25(8), pp.1261-1275. - Newcomb, D.J., Hale, K., Phillipuk, C.R., Schleifer, D. and Stanuikynas, T.J., 2002. Surface Water and Riparian Areas of the Raritan River Basin: A technical report for the Raritan Basin Watershed Management Project. - Price, W. and Sprague, E., 2011. Pennsylvania's Forests: How They are Changing and Why We Should Care. Pinchot Institute for Conservation. - Wickham, J.D., Wade, T.G. and Riitters, K.H., 2011. An environmental assessment of United States drinking water watersheds. Landscape Ecology, 26(5), p.605.
ECONorthwest 17 specifically report whether those acres transitioned to urban, agriculture, or another natural land cover.
Figure 8. Land Cover Changes in the Riparian Zone (350-foot Buffer) 2001-2011, Delaware River Basin Source: ECONorthwest with data from the US EPA’s Watershed Index Online 15,000 12,996
10,000
6,028
5,000 3,280 Total Developed Agricultural Land
- Urban Land Total Natural Land Cover Other Natural Land cover Riparian Forest
Change in Acreage 2001-2011 Acreage in Change -5,000
-6,028 -6,968
-10,000 -9,308
-15,000 1
Urban land cover includes multiple kinds of human development:6
• Developed, Open Space - areas with a mixture of some constructed materials, but mostly vegetation in the form of lawn grasses. Impervious surfaces account for less than 20% of total cover. These areas most commonly include large-lot single-family housing units, parks, golf courses, and vegetation planted in developed settings for recreation, erosion control, or aesthetic purposes. • Developed, Low Intensity - areas with a mixture of constructed materials and vegetation. Impervious surfaces account for 20% to 49% percent of total cover. These areas most commonly include single-family housing units, residential yards and lawns.
6 Homer, C.G., Dewitz, J.A., Yang, L., Jin, S., Danielson, P., Xian, G., Coulston, J., Herold, N.D., Wickham, J.D., and Megown, K., 2015, Completion of the 2011 National Land Cover Database for the conterminous United States- Representing a decade of land cover change information. Photogrammetric Engineering and Remote Sensing, v. 81, no. 5, p. 345-354
ECONorthwest 18 • Developed, Medium Intensity - areas with a mixture of constructed materials and vegetation. Impervious surfaces account for 50% to 79% of the total cover. These areas most commonly include single-family housing units. • Developed High Intensity - highly developed areas where people reside or work in high numbers. Examples include apartment complexes, row houses and commercial/industrial. Impervious surfaces account for 80% to 100% of the total cover. Urban cover therefore includes both urban and suburban development, as well as roads, utility lines, and lawnscapes. Each of these land cover types has different effects on the environment but the limitations of the land cover data do not allow for us to account for these differences.
Figure 9. Land Cover Changes in the Riparian Zone (350-foot Buffer) by State, 2001-2011, Delaware River Basin Source: ECONorthwest with data from the US EPA’s Watershed Index Online
-1,079 -334 DE 2,465 -2,131 334
-2,423 -1,912 NJ 4,504 -2,591 1,912
-1,040 -454 NY 346 108 454
-4,766 -3,328 PA 5,681 -2,354 3,328
-6,000 -4,000 -2,000 - 2,000 4,000 6,000 8,000 Change in Acreage 2001-2011 Riparian Forest Total Natural Land Cover Urban Land Agricultural Land Total Developed
It’s also important to note that not all of the lost riparian forest area was necessarily developed for human uses. Natural land cover types often transition to other natural land cover types. For example, in Pennsylvania nearly 4,800 acres of riparian forest were lost between 2001 and 2011 (Figure 10), but fewer acres of natural land cover were lost overall (-4,800 acres of riparian forest vs. -2,900 acres of natural land cover, overall). Some of these forest acres shifted to shrub/scrub and grasslands.7
7 These trends can be explored with NOAA’s Land Cover Atlas (choose watersheds, then the forests tab to see an accounting of which land covers replaced forest cover): https://coast.noaa.gov/ccapatlas/.
ECONorthwest 19 • Shrub/Scrub - areas dominated by shrubs; less than 5 meters tall with shrub canopy typically greater than 20% of total vegetation. This class includes true shrubs, young trees in an early successional stage or trees stunted from environmental conditions. • Grassland/Herbaceous - areas dominated by graminoid or herbaceous vegetation, generally greater than 80% of total vegetation. These areas are not subject to intensive management such as tilling (in which case they would classified as agricultural land), but can be used for grazing. The grassland/herbaceous category also does not include residential yards and lawns – these are included in either the ‘low intensity urban development’ or the ‘developed open space’ categories. Non-forest categories of natural land cover – shrub/scrub and grasslands – increased on the whole during between 2001 and 2011.
Trends in land cover change can be understood in absolute (i.e., total acres of forest lost) and relative to total stock (i.e., acres of forest lost compared to total acres of forest). For example, Pennsylvania lost over four times as many acres of riparian forest as Delaware (Figure 9), but Delaware lost a larger share of its total riparian forest than Pennsylvania (2.8% loss in DE vs. 0.6% in PA; Figure 10).
Figure 10. Percent Land Cover Change in the Riparian Zone (350-foot Buffer) by State, 2001-2011, Delaware River Basin Source: ECONorthwest with data from the US EPA’s Watershed Index Online
-2.8% -0.2% DE 7.32% -2.8% 0.6%
-1.2% -0.3% NJ 3.62% -1.7% 1.3%
-0.6% -0.2% NY 1.61% 0.3% 0.7%
-1.0% -0.5% PA 3.48% -1.8% 1.0%
-4.0% -2.0% 0.0% 2.0% 4.0% 6.0% 8.0% % Change 2001-2011 Riparian Forest Total Natural Land Cover Urban Land Agricultural Land Total Developed
These change estimates include the effects of existing protection policies, such as buffer protection ordinances in Pennsylvania and New Jersey and protection through public ownership generally. For reference, 18 percent of the Delaware River Basin is protected by
ECONorthwest 20 federal, state, and local governments or as private conservation easements through land trusts accessible to the public.8 Implications for Buffer Protection Information about development trends in the riparian zone allows us to estimate the amount of undeveloped riparian land that could be preserved with policy changes and community protection. As described in the next section (‘Buffer Widths and Vegetation Cover’), studies suggest 100 feet is the minimum functional buffer width for most objectives, while 350 feet of width are needed for habitat benefits.
Based on the net change in natural land cover within 100 feet of streams between 2001 and 2011, buffer ordinances adopted throughout the Basin would protect nearly 1,700 acres over ten years, or 167 acres a year. For a 350-foot buffer, over 6,000 acres of natural land cover would be protected over 10 years (Table 4).9 This assumes constant development rates in the future matching those of the period 2001 to 2011 and does not account for potential variances or development exceptions, which would decrease the number of acres on which development is prevented. We also chose to use the net loss of natural land cover as the basis for policy modeling instead of lost forestland.10 Forested buffers provide the greatest diversity and amount of ecosystem services, so transition to a grass or shrub dominated state will still result in a net loss of services. Our estimates of ecosystem services lost to development are likely underestimates to the extent they omit loss of conversion from forested buffers to other natural land cover.
8 Kauffman, G., Belden, A. and Homsey, A., 2009. Technical Summary: State of the Delaware Basin Report. 9 See earlier discussion for buffer width basis. 10 Some of the decline in riparian forest observed between 2001 and 2011 was due to natural disturbances and processes (e.g., flooding, windthrow), and some could be due to prior misclassification of forest land cover. An unknown portion of the transition from forest to shrub/scrub and grassland could also conceivably be due to human clearing (for grazing, for example), but might not be detected and/or categorized as one of the urban uses defined above. Only transition to land covers classified as ‘urban’ can be reliably linked to human development.
ECONorthwest 21 Table 4. Development of Natural Riparian Areas and Net Loss of Riparian Cover in the Delaware River Basin by State and Buffer Width (Acres), 2001-2011 Source: ECONorthwest with data from the US EPA’s Watershed Index Online 350-ft Buffer Zone 100-ft Buffer Zone State Net Loss of Net Loss of Natural Net Loss of Net Loss of Natural Riparian Forest Land Cover Riparian Forest Land Cover 2001 - 2011 DE -1,079 -334 -300 -93 NJ -2,423 -1,912 -673 -531 NY -1,040 -454 -289 -126 PA -4,766 -3,328 -1,324 -924 DRB -9,308 -6,028 -2,585 -1,674 Annual Average DE -108 -33 -30 -9 NJ -242 -191 -67 -53 NY -104 -45 -29 -13 PA -477 -333 -132 -92 DRB -931 -603 -259 -167
ECONorthwest 22 Riparian Ecosystem Services in the Delaware River Basin
The Chesapeake Bay Program identifies riparian forest buffers as being perhaps the single best practice to maintain and improve the quality of downstream waters and habitats:
“Riparian forest buffers provide critical barriers between polluting landscapes and receiving waterways using relatively little land. Forest buffers reduce the adverse effect of excessive nitrogen, phosphorus, and suspended sediment inputs. Per acre, they likely provide more benefits and are more cost-effective than any other [management practice], especially when considering the added high value habitat at the critical juncture of land and water.”11 Categories of Benefit We focus our analysis on these identified functions and benefits of riparian areas in the Delaware River Basin:
• Water Quality Protection (specifically, treatment and prevention of nutrient and sediment pollution, interception of urban stormwater runoff, and drinking water provision) • Carbon Sequestration • Mitigation of Air Pollution • Provision of Habitat and Movement Corridors for Fish and Wildlife • Flood Prevention • Improvements in Property Values • Outdoor Recreation Opportunities Buffer Widths and Vegetation Cover The size (width and area) and vegetative cover type determine a buffer’s capacity to provide ecosystem services and benefits. Generally speaking, wider buffers provide greater benefits. Each of the ecosystem services above also requires a certain minimum area or size of land area surrounding water bodies to be fully realized. Many reviews suggest that 100 feet is the minimum width at which all of the relevant services are provided.12 Some services are realized relatively quickly (e.g., bank stabilization), while other services require much larger widths to
11 Chesapeake Bay Program. 2014. Buffering the Bay: A Report on the Progress and Challenges of Restoring Riparian Forest Buffers in the Chesapeake Bay Watershed. 12 Sweeney, B.W. and Newbold, J.D., 2014. Streamside forest buffer width needed to protect stream water quality, habitat, and organisms: a literature review. JAWRA Journal of the American Water Resources Association, 50(3), pp.560- 584.
ECONorthwest 23 provide efficient services (e.g., 300 feet for wildlife habitat). Depending on a water body’s position in the watershed, the type of vegetation present, adjacent land uses and slope, some buffers may require thousands of feet to provide ecological functions and benefits.13 Forested riparian buffers, as opposed to grass or shrub dominated buffers, deliver the greatest range of environmental benefits (Table 5).14
Table 5. Buffer Vegetation and Effectiveness Source: NRCS. 1999. Managing Streamside Areas with Buffers. Benefit Grass Shrub Tree Stabilize Bank Erosion Low High High Filter Sediment High Low Low Filter Nutrients, Pesticides, Bacteria Sediment-bound Particle Removal High Low Low Soluble Particle Removal Medium Low Medium Aquatic Habitat Low Medium High Wildlife Habitat Range/Pasture/Prairie Wildlife High Medium Low Forest Wildlife Low Medium High Flood Protection Low Medium High Water Temperature Low Low High
Multiple vs. Single Service Provision Some of the environmental services provided by forested riparian areas might be partially provided by human-built structures and technologies, such as reservoirs for flood control and wastewater treatment plants for pollutant removal. However, these substitutions are directed at single functions rather than the multiple functions that riparian areas carry out simultaneously, including functions not easily replicated. Unlike built alternatives, riparian buffers support multiple habitat benefits while also improving water quality, aesthetics, etc.15
This also highlights the importance of recognizing the complementary benefits of riparian buffers for other natural and built assets in a watershed. Buffers can make other resources, such as downstream water bodies and adjacent forests, more functional and valuable. They are also complementary within their own system, in that upstream buffers can make downstream buffers more beneficial and vice versa.
13 Schueler, T., Site Planning for Urban Stream Protection, Metropolitan Washington Council of Governments 111 (1995), at 3. 14 Lowrance, R. R. 1997. Water quality functions of riparian forest buffer systems in the Chesapeake Bay watershed. Environmental Management 21(5): 687-712. 15 Sweeney, B.W. and Newbold, J.D., 2010. Removal of Nonpoint Source Pollutants by Riparian Buffers: A Short Summary of the Scientific Literature.
ECONorthwest 24 A. Values of Specific Ecosystem Services
We provide ranges in service values to account for the fact that marginal benefits will not be constant across the Basin. Ecosystems and individual parcels of land vary considerably in quality and capacity to provide specific services, and the value of these services can also depend on the regional context.16 For example, buffers adjacent to agriculture provide a different mix and magnitude of benefits than those adjacent to forests or residential properties.
The demand curve for most ecosystem services is presumed to be downward sloping, suggesting diminishing returns. The marginal value of benefits provided by riparian buffers should decrease as the portion of a given area constituted by buffers increases. 17 With some ecosystem services, such as carbon sequestration, extrapolating values across large acreages could be relatively accurate because marginal benefits are likely to be nearly constant. Other services, such as habitat provision, may be even more valuable on large acreages.
All values are in 2017 dollars unless noted otherwise. Literature values were updated to current year dollars using the Consumer Price Index. 1. Water Quality
Riparian areas act as natural filtration systems that improve water quality by absorbing excess amounts of sediment, nutrients, and other contaminants from urban and agricultural runoff.18 Streamside vegetation also supports a large number and diversity of aquatic insects that process pollutants and further improve water quality.19
Figure 11 shows stream segments in the Basin that do not meet minimum standards for certain uses (such as fishing and swimming). Beyond their ability to address specific pollutants, forested riparian buffers are also linked to stream health and quality generally (see Table 20, pg. 42).
16 Kauffman, G.J., 2016. Economic Value of Nature and Ecosystems in the Delaware River Basin. Journal of Contemporary Water Research & Education, 158(1), pp.98-119. 17 Ballard, J., J. Pezda and D. Spencer. 2016. An Economic Valuation of Southern California Wetlands. University of California – Santa Barbara. 18 Sweeney, B.W. and Newbold, J.D., 2014. Streamside forest buffer width needed to protect stream water quality, habitat, and organisms: a literature review. JAWRA Journal of the American Water Resources Association, 50(3), pp.560- 584. 19 Sweeney, B.W., Bott, T.L., Jackson, J.K., Kaplan, L.A., Newbold, J.D., Standley, L.J., Hession, W.C. and Horwitz, R.J., 2004. Riparian deforestation, stream narrowing, and loss of stream ecosystem services. Proceedings of the National Academy of Sciences of the United States of America, 101(39), pp.14132-14137.
ECONorthwest 25 Figure 11. Stream Segments Listed as Impaired by the EPA Sources: ECONorthwest with data from the US EPA Water Quality Assessment and TMDL Tracking (ATTAINS) database, EPA 2002 Impaired Waters Baseline National Geospatial Dataset, and the Pennsylvania Department of Environmental Protection 2016 Integrated Water Quality Report. Note: Stream impairments only include categories 4 (polluted streams that do not require a TMDL) and 5 (polluted waters that require a TMDL).
NY
PA Scranton
New York
NJ
Reading
Trenton
Philadelphia
Wilmington
MD Impaired streams
Delaware DE River Basin Surface water and wetlands
ECONorthwest 26 Nitrogen and Phosphorus Reductions High concentrations of nutrients such as nitrogen and phosphorus can fuel excessive plant growth (e.g., nuisance algae) and lower dissolved oxygen levels in streams and lakes. Nutrient concentrations are a commonly used indicator of water quality.
We begin by estimating the amount of nitrogen and phosphorus discharged to the environment with and without riparian buffers. We use a database of nutrient loadings for various land uses and land covers in the Chesapeake Bay in the absence of similar information for the Delaware River Basin.20 Our nutrient accounting methodology is based on that of the Chesapeake Bay Program, the North Carolina Buffer Mitigation Program, and the USDA Conservation Reserve Enhancement Program (CREP).
The value provided by buffer policies is not only for the water filtration services that buffers provide, but also the problems that are avoided when other land uses are excluded (Table 6). The nutrient reduction benefit of riparian buffers includes both the nutrient retention associated with keeping an acre of forest from turning into urban or agricultural uses - measured as the difference in nutrient loadings between forest and developed land uses (Table 6) – and the buffer’s treatment of runoff from upland acres.
Table 6. Increase in Nutrient Delivery with Land Use Change Source: ECONorthwest with data from University of Maryland Center for Environmental Science and Maryland Department of Natural Resources (http://dnr2.maryland.gov/ccs/Documents/trustfund/AgricultureandForestCalculator.xls) 1: The composite value is an average of the developed, crop and pasture land covers. Values may not sum due to rounding Nitrogen Phosphorus Land Use/Land Cover (lb/acre/yr) (lb/acre/yr) Average Range Average Range Developed 7.5 0 - 21.7 0.5 0 - 1.1 Crop 15.5 0 - 44.7 1.1 0 - 3.7 Pasture 5.1 0 - 17.1 0.6 0 - 1.2 Composite Urban/Agricultural1 9.4 - 0.7 - Forest 1.9 0 - 5.8 0.1 0 - 0.1 Increase in nutrient delivery 7.5 - 0.7 - with loss of streamside forest
The values shown in Table 6 are consistent with previously reported estimates.21 Based on guidance from the Chesapeake Bay Commission, we assume that an acre of riparian buffer
20 Data are available online at http://dnr2.maryland.gov/ccs/Documents/trustfund/AgricultureandForestCalculator.xls 21 Stephenson, K., Aultman, S., Metcalfe, T. and Miller, A., 2010. An evaluation of nutrient nonpoint offset trading in Virginia: A role for agricultural nonpoint sources? Water Resources Research, 46(4).
ECONorthwest 27 treats four upland acres with respect to total nitrogen loads and two upland acres with respect to phosphorus and sediment (see next section for sediment calculations).22
To account for varying effectiveness of individual buffer units as well as the range of buffer widths used in the source literature, we use a range of 48 to 95 percent for nitrogen capture/treatment, 36 to 79 percent for phosphorus (Table 7), and 70 to 96 percent for sediment (Table 12, next section).23
Table 7. Nutrient Loads and Estimates of Buffer Treatment Capacity Sources: ECONorthwest with data from sources cited in text. Land Use/Land Cover Nutrient Factors Pasture Developed Crops Loading rate (lb/ac/yr) 5.1 7.5 15.5 Total Discharge to buffer w/ 4:1 upland/buffer ratio 20.5 29.9 62.2 Nitrogen Removal efficiency 48% 95% 48% 95% 48% 95% Nitrogen yield (lb/ac/yr) 9.8 19.4 14.4 28.4 29.8 59.0 Loading rate (lb/ac/yr) 0.6 0.5 1.1 Total Discharge to buffer w/ 2:1 upland/buffer ratio 1.2 1.0 2.1 Phosphorus Removal efficiency 36% 79% 36% 79% 36% 79% Phosphorus yield (lb/ac/yr) 0.4 1.0 0.3 0.8 0.8 1.7
For comparison, the North Carolina mitigation program (described in the next section) assumes that each acre of riparian buffer within 50 feet of streams prevents 75.77 pounds of nitrogen and 4.88 pounds of phosphorus per year from reaching waterways. Buffers in Maryland and Georgia were found to retain 23 to 65 pounds of nitrogen (67 to 89 percent of inputs) and 1.1 to 2.6 pounds of phosphorus (24 to 81 percent of inputs) per acre of buffer per year.24
We value each pound of nitrogen and phosphorus with the cost of removal or prevention using various practices. Loss of riparian buffers will increase the costs of nitrogen and phosphorus removal, while buffer protection will allow society to avoid these control costs. The costs of removing nitrogen are generally between $4 and $58 per pound, while phosphorus removal costs $24 to $399 per pound (Table 8).25 Removal costs vary based on the technology used, the
22 Riparian Buffer Expert Panel, 2014. Recommendations of the Expert Panel to Reassess Removal Rates for Riparian Forest and Grass Buffers Best Management Practices. 23 Hawes and Smith. 2005. Riparian Buffer Zones: Functions and Recommended Widths. Prepared for the Eightmile River Wild and Scenic Study Committee 24 Lowrance, R. R. 1997. Water quality functions of riparian forest buffer systems in the Chesapeake Bay watershed. Environmental Management 21(5): 687-712. 25 Van Houtven, G., Loomis, R., Baker, J., Beach, R. and Casey, S., 2012. Nutrient credit trading for the Chesapeake Bay: An economic study. RTI International, Research Triangle Park, NC. US Environmental Protection Agency. 2002. Economic Analysis of the Final Revisions to the National Pollutant Discharge Elimination System Regulation and the Effluent Guidelines for Concentrated Animal Feeding Operations - Appendix E Cost-Effectiveness Analysis. Washington, DC.: Office of Science and Technology, Pub No. EPA-821-R-03- 002.
ECONorthwest 28 scale of treatment, and landscape setting. The cost to remove or prevent a pound of nitrogen or phosphorus from farm runoff and drainage, for example, is typically 4 or 5 (and as high as 10 or 20) times less than the cost to remove the same amount from municipal wastewater or urban stormwater.26
Table 8. Increase in Nutrient Delivery with Buffer Losses Sources: ECONorthwest with data from sources cited in text. Nitrogen Low High 1) Increase in TN export with land use change (lb/acre/yr) 7.5 2) Loss of TN removal from nonpoint source runoff (lb/acre/yr) 9.8 59.0 Total increase in nitrogen delivery (lb/acre/yr) 17.3 66.6 $4 $63 $241 Treatment cost per pound of nitrogen: $58 $1,012 $3,885 Total Increase in N treatment costs with buffer loss ($/acre/yr) $241 $3,885 Phosphorus Low High 1) Increase in TP export with land use change (lb/acre/yr) 0.7 2) Loss of TP removal from nonpoint source runoff (lb/acre/yr) 0.3 1.7 Total increase in phosphorus delivery (lb/acre/yr) 1.0 2.3 $24 $24 $55 Treatment cost per pound of phosphorus: $389 $394 $905 Total increase in P treatment costs with buffer loss ($/acre/yr) $55 $905 Low prices $87 $296 Combined N+P ($/ac/yr): High prices $1,406 $4,789
Annual service losses repeat year after year, and build cumulatively. For example, in year one we value the losses associated with 167 acres of riparian forest, and in the second year we value losses from 334 acres. In the first year there are not only 167 acres of newly developed lands discharging more nutrients than the forested riparian acreages did previously, but also 668 upland acres that have lost their nitrogen filtration barrier (based on a 1 to 4 treatment ratio), and 334 acres that have lost their phosphorus and sediment filtration barrier (based on a 1 to 2 treatment ratio).
To produce an estimate of potential losses between 2018 and 2028 (Table 9), we apply the mid- range of values (Table 8; $296 to $1,406 per acre, rather than the upper and lower extremes of $87 to $4,789 per acre).
26 National Association of Clean Water Agencies. 2011. Controlling Nutrient Loadings to U.S. Waterways: An Urban Perspective
ECONorthwest 29 Table 9. Annual and Projected Nutrient Costs from Riparian Development DE NJ NY PA Basin Total Net Loss of Natural Land Cover -9 -53 -13 -92 -167 (100-ft buffer, acres/yr) Low Buffer Effectiveness, Low Avoided Treatment Costs -$806 -$4,613 -$1,095 -$8,028 -$14,543 (-$87/acre/yr) Low Buffer Effectiveness, High Avoided Treatment Costs -$13,055 -$74,699 -$17,726 -$129,988 -$235,468 (-$1,406/acre/yr) High Buffer Effectiveness, Low Avoided Treatment Costs -$2,750 -$15,733 -$3,733 -$27,378 -$49,595 (-$296/acre/yr) High Buffer Effectiveness, High Avoided Treatment Costs -$44,459 -$254,390 -$60,365 -$442,675 -$801,889 (-$4,789/acre/yr) Total NPV 2018-2028 Low Range (-$296/acre/yr) -$126,992 -$726,636 -$172,426 -$1,264,450 -$2,290,503 (mid-range values, cumulative effect, 3% discount rate) High Range (-$1,406/acre/yr) -$602,932 -$3,449,930 -$818,646 -$6,003,368 -$10,874,876 Low -$12,699 -$72,664 -$17,243 -$126,445 -$229,050 2018-2028 Annualized High -$60,293 -$344,993 -$81,865 -$600,337 -$1,087,488
The Chesapeake Bay Commission and North Carolina Buffer Mitigation Program value nitrogen and phosphorus treatment costs separately and additively. However, many treatment practices will treat both nutrients simultaneously, so under some treatment scenarios and circumstances there may be double counting when avoided costs are valued separately. North Carolina Buffer Mitigation Program Since 1997, North Carolina has actively managed development within its riparian zones to maintain and improve water quality in the state’s streams and bays. The state has designated 50-foot riparian buffers, and sets “exempt,” “allowable,” “allowable with mitigation,” and “prohibited” uses within this regulated buffer zone.27 Impacts that are “allowable with mitigation” must be offset by the restoration of buffers elsewhere within the same watershed.
Mitigation is based on the nutrient (nitrogen and phosphorus) loading that will result from land use changes over a 30-year period. Compliance options include providing stormwater BMPs at the development site to offset the lost nutrient treatment capacity, or paying to create a new riparian buffer elsewhere in the watershed.
This mitigation approach has effectively created a market for forested riparian buffers. The North Carolina Ecosystem Enhancement Program (NCEEP), a state agency, completes stream, wetland, and riparian buffer mitigation projects and sells credits to other agencies, private companies, or individuals that need to purchase mitigation as part of a development project. NCEEP’s nutrient offset credit rates vary by watershed, but current prices range from $9 to $21 per pound of nitrogen and $167 to $382 per pound of phosphorus.28
NCEEP estimates that over a 30-year period, one acre of forested riparian buffer prevents 2,273 pounds of nitrogen and 146.4 pounds of phosphorus from reaching surface waters. Taking the average of the watershed nutrient prices, one acre of forested riparian buffer has a value of: $14.99/lb. X 2,273 lbs. of nitrogen over 30 years = $34,061 and $274.78/lb. X 146.4 lbs. of
27 Chatham Conservation Partnership. 2011. Chatham Conservation Plan Appendix G - Forest Resources: Economic Analysis for Water Quality 28 North Caroline Department of Environmental Quality. 2016-17 Statewide Stream & Wetland & 2017 Riparian Buffer Rates. https://deq.nc.gov/about/divisions/mitigation-services/dms-customers/fee-schedules
ECONorthwest 30 phosphorus over 30 years = $40,227. This equates to $2,476 per acre year for both nitrogen and phosphorus reductions, which is two to eight times higher than the nutrient values we apply in our analysis.
The combined nutrient removal value for one acre of restored forested riparian buffer over a 30- year period is $74,288. The price for a riparian buffer mitigation credit through NEEP is currently $1.16/square foot, which translates to $50,530/acre. The net benefit of an acre of riparian buffer, in this case, would be about $24,000 over a 30-year period.29 Riparian wetlands are slightly more expensive to offset and produce, at $40,297 to $71,273 per acre. These costs include land purchase (at least $19,000 an acre and often more depending on how urbanized the watershed is), long-term maintenance and monitoring, as well as relatively high transaction costs (e.g., for permitting, planning and program management).30
The values above are meant to illustrate and confirm the magnitude of potential benefits and costs associated with nutrient retention and treatment by buffers. These are essentially one-time payments/losses/benefits, and NCEEP’s nutrient prices are specific to the region’s water quality goals.
Based on mitigation applications to NCEEP between 2005 and 2010, more than half of the costs/benefits associated with the buffer mitigation rule have been incurred by the North Carolina Department of Transportation, and another third by private developers.31 Sediment Reductions Roots, stems and fallen trees in a riparian buffer slow the flow of surface runoff, allowing sediment to settle out and be trapped before reaching streams and lakes. Capturing sediment before it reaches waterways creates a number of benefits for local communities and industries (Table 10).32 For example, excessive sediment loads impose damage and control costs on multiple kinds of infrastructure (e.g., reservoirs, power plants, roads, canals), exacerbate flooding, and lower catch rates for commercial and recreational marine fisheries. The categories and values shown in the table below are based on models that the USDA Economic Research Service uses to assign monetary values to changes in soil erosion and sediment deposition.33 These models provide information on the costs and damages associated with a ton of sediment discharged to regional waterways, with values specific to the northeastern region.
29 Ibid 30 RTI International and the Center for Watershed Protection. 2007. A Study of the Costs Associated with Providing Nutrient Controls that are Adequate to Offset Point Source and Nonpoint Source Discharges of Nitrogen and Other Nutrients. Prepared for the North Carolina General Assembly’s Environmental Review Commission 31 North Carolina Department of Environmental and Natural Resources. 2015. Fiscal and Regulatory Impact Analysis - Buffer Mitigation Rules. 32 Hansen, L. and Ribaudo, M., 2008. Economic Measures of Soil Conservation Benefits: Regional Values for Policy Assessment. USDA Technical Bulletin Number 1922 33 Ibid
ECONorthwest 31 Table 10. Benefits of Sediment Capture Source: ECONorthwest with data from Hansen and Ribaudo 2008 Note: categories without ranges are those for which have values specific to the Northeast region. All cost figures are in 2017$. Categories Description of Benefit Value ($/ton) Reservoir services Avoided cost of dredging reservoirs $0 to $1.86 Navigation Avoided cost of dredging harbors and shipping channels $0 to $6.75 Irrigation ditches and channels Reduced cost of removing sediment and aquatic plants from irrigation channels $0.01 Road drainage ditches Less damage to and flooding of roads $0.27 Municipal water treatment Lower sediment removal costs for water-treatment plants $0.36 Flood damages Reduced flooding and damage from flooding $1.04 Marine fisheries Improved catch rates for marine commercial fisheries $1.25 Marine recreational fishing Increased catch rates for marine recreational fishing $2.12 Municipal & industrial water use Reduced damages from salts and minerals dissolved from sediment $1.96 Steam powerplants Reduced plant growth on heat exchangers $0.89 Total ($/ton) $8 to $17
We use the same accounting method and data sources used for nitrogen and phosphorus to estimate the increase in sediment discharge that occurs when natural buffers are replaced by urban and agricultural development.
Table 11. Increase in Sediment Delivery with Land Use Change ECONorthwest with data from University of Maryland Center for Environmental Science and Maryland Department of Natural Resources (http://dnr2.maryland.gov/ccs/Documents/trustfund/AgricultureandForestCalculator.xls) Sediment (TSS) Land Use/Land Cover (lb/acre/yr) Average Range Developed 359 0 - 1,236 Crop 1,054 0 - 5,178 Pasture 210 0 - 1,401 Composite Urban/Agricultural1 541 - Forest 52 0 - 267 Increase in nutrient delivery 489 - with loss of streamside forest
Table 12. Sediment Loads and Estimates of Buffer Treatment Capacity Sources: ECONorthwest with data from sources cited in text.
Land Use/Land Cover Sediment Loading and Removal Factors Pasture Developed Crops Loading rate (lb/ac/yr) 210 359 1,054 Discharge to buffer w/ 2:1 upland/buffer ratio 420 718 2,109 Removal efficiency 70% 96% 70% 96% 70% 96% Sediment yield (lb/ac/yr) 294 403 502 689 1,476 2,025
We estimate that every acre of riparian buffer lost to development will increase sediment discharge by approximately 800 to 2,500 pounds (0.4 to 1.3 US tons) per year (see Table 13 below). These estimates are consistent with values used in the Conservation Reserve
ECONorthwest 32 Enhancement Program’s (CREP) project accounting, which assumes that 0.5 and 0.1 tons are generated by an acre of row crop and pasture, respectively.34
We use loading estimates from the Chesapeake Bay database for consistency with nitrogen and phosphorus accounting, but these estimates likely do not capture the upper range of possible sediment capture by buffers. For example, over a 100-year period (1880-1979), a riparian zone in a coastal plain agricultural watershed in Georgia accumulated an estimated 190,667 to 283,276 pounds of sediment (95 to 142 US tons) per acre per year.35 Additionally, our accounting likely does not capture the sediment discharges associated with construction projects, which could be an important stressor given the scale of urbanization occurring in the Basin. Estimates of uncontrolled construction-site sediment loadings range from 7.2 to 1,000 tons per acre per year.36
Table 13. Increase in Sediment Delivery with Buffer Losses and Economic Values Sources: ECONorthwest with data from sources cited in text. Sediment Delivery Low High 1) Increase in sediment export with land use change (lb/acre/yr) 489 2) Loss of sediment removal from nonpoint source runoff (lb/acre/yr) 294 2,025 Total increase in sediment delivery (lb/acre/yr) 783 2,513 Low High Benefit Categories ($/acre/yr) ($/acre/yr) Reservoir services $0.00 $2.34 Navigation $0.00 $8.48 Irrigation ditches and channels $0.01 $0.02 Road drainage ditches $0.11 $0.34 Municipal water treatment $0.14 $0.46 Flood damages $0.41 $1.31 Marine fisheries $0.49 $1.58 Marine recreational fishing $0.83 $2.66 Municipal & industrial water use $0.77 $2.46 Steam powerplants $0.35 $1.12 Total Costs/Damages ($/acre/yr) $3.1 $20.8
The value of sediment control by an acre of natural riparian buffer will generally fall between $3 and $21 per acre per year, with the largest potential benefits realized in avoided dredging costs,
34 See, for example, the Wisconsin CREP worksheet at https://datcp.wi.gov/Documents/CREPEnvirBenefitReport.doc 35 Lowrance, R., J.K. Sharpe, and J.M. Sheridan. 1986. Long-term sediment deposition in the riparian zone of a coastal plain watershed. Journal of Soil & Water Conservation 41:266-271. For a review of sedimentation rates, see Lowrance, R., Altier, L.S., Newbold, J.D., Schnabel, R.R., Groffman, P.M., Denver, J.M., Correll, D.L., Gilliam, J.W., Robinson, J.L., Brinsfield, R.B. and Staver, K.W., 1997. Water quality functions of riparian forest buffers in Chesapeake Bay watersheds. Environmental Management, 21(5), pp.687-712. 36 Langland, M. and Cronin, T., 2003. A summary report of sediment processes in Chesapeake Bay and watershed (No. 2003-4123).
ECONorthwest 33 enhanced catches for marine fishing, and reduced damage to municipal and industrial water infrastructure.
Table 14. Annual and Projected Sediment Costs Associated with Riparian Development DE NJ NY PA Basin Total Annual Net Loss of Natural Land Cover -9 -53 -13 -92 -167 (100-ft buffer, acres/yr) Low (-$3/acre) -$29 -$164 -$39 -$286 -$518 High (-$21/acre) -$193 -$1,103 -$262 -$1,919 -$3,475 Total NPV 2018-2028 Low -$1,327 -$7,591 -$1,801 -$13,210 -$23,929 (cumulative effect, 3% discount rate) High -$8,899 -$50,918 -$12,083 -$88,605 -$160,505 Low -$133 -$759 -$180 -$1,321 -$2,393 2018-2028 Annualized High -$890 -$5,092 -$1,208 -$8,861 -$16,051
These costs mount over time, building cumulatively with annual loss of buffer capacity. Over the next ten years we project that total sediment–related costs across the basin due to buffer loss will fall somewhere between $24 and $161 thousand. These impacts are low in comparison to the other categories addressed in this report, which is due in part to the low costs of removing sediment. These values could be substantially greater than these estimates suggest given that much higher rates of sediment capture by buffers have been reported in the literature.
With the exception of damages to marine recreational fishing which are included in the recreation valuation section, we do not include sediment-related costs in the final summation of costs, shown in Table 26. At the local scale, secondary costs such as these might be of more prominent importance. Well-implemented and managed riparian buffers can effectively address site-specific needs. The total cost of sediment pollution caused by riparian habitat loss might be low across the Basin, but the localized value can still be an important factor for assessment. Urban Stormwater Treatment As vegetated areas are replaced, the ability of the land to absorb and filter stormwater runoff is reduced. Flooding, bank erosion, and runoff subsequently increase. Impervious surfaces also reduce groundwater recharge and infiltration for stream base-flows.
Based on municipal stormwater treatment costs in the Basin, protecting or restoring one acre of forested riparian buffer could save $540 to $1,898 per year (Table 15). Urban treatment costs are based on stormwater volume, as opposed to the concentration of specific nutrients. The full replacement costs associated with stormwater treatment (e.g., for construction of retention ponds), as opposed to the marginal treatment costs, are much higher at $2.03 per cubic foot.37
37 New Jersey Department of Environmental Protection, 2007. Valuing New Jersey’s Natural Capital: An Assessment of the Economic Value of the State’s Natural Resources.
ECONorthwest 34 Streamside property owners in communities with stormwater crediting programs can lower monthly stormwater bills by decreasing impervious cover on their property.38
Table 15. Costs of Stormwater Treatment by Land Cover Sources: ECONorthwest with data from the Trust for Public Land.39 We apply lower runoff values for all categories; forest runoff can be as high as 20 percent, suburban can be as high as 60 percent, dense urban as high as 70 percent, and city commercial as high as 80 percent.40 The runoff coefficient is the proportion of rainfall that is converted to storm water runoff. Stormwater Treatment Cost Annual Savings Average Rainfall/ac/yr = 150,000 cu. ft./acre ($/cu. ft.) Per Acre of Philadelphia, PA Wilmington, DE Riparian Forest Runoff Runoff/ac/yr Land Cover $0.012 $0.023 Low High Generation (cu. ft./acre) Forest 5% 7,500 $90 $173 -- Suburban Residential 35% 52,500 $630 $1,208 $540 $1,035 Dense Urban Residential 50% 75,000 $900 $1,725 $810 $1,553 City Commercial 60% 90,000 $1,080 $2,070 $990 $1,898
The Problem of Channelized Flow: Buffers can be less effective at treating water pollution in urban environments. Models concerning the effectiveness of riparian buffers typically assume that water flows evenly across the landscape and interacts with the buffer equally at all points. In nature and particularly in urban environments this is rarely the case and certain areas will receive more runoff than others, which can quickly overwhelm a buffer’s filtering capacity. Because of channelization and pipes, stormwater in urban environments often goes straight from impervious areas to receiving water bodies, passing through pipes and bypassing riparian buffer treatment zones altogether. An urban buffer’s ability to treat stormwater depends on how much the flow has become channelized before it enters, and how long it is detained in the buffer. However urban buffers also provide many other unique benefits in an urban setting including reduction of heat island effect, reduced concentrations of air pollutants (Section 3) and increased property values (Section 5). Drinking Water Source Protection The Delaware River Basin provides water for roughly five percent of the US population. Most of the drinking water entering the streams in the Basin initially passes through riparian buffers in headwater regions. Headwaters account for approximately 75 percent of the total waterway length in watersheds.41 Riparian buffers will often be more effective along small or low-order
38 http://www.phillywatersheds.org/whats_in_it_for_you/reduce-your-stormwater-fees 39 Trust for Public Land. 2008. How Much Value Does the City of Philadelphia Receive from its Park and Recreation System? Trust for Public Land. 2009. How Much Value Does the City of Wilmington Receive from Its Park and Recreation System? 40 Pennsylvania Department of Environmental Protection. 2012. Erosion and Sediment Pollution Control Program Manual. Pennsylvania Department of Transportation. 2015. PennDOT Drainage Manual. 41 Meyer, JL. 2003. Where Rivers Are Born: The Scientific Imperative for Defending Small Streams and Wetlands. Washington (DC): American Rivers, Sierra Club.
ECONorthwest 35 streams than larger or high-order streams since most water delivered to channels from uplands enters along low-order streams.
Forested areas (including riparian buffers) decrease costs by reducing the need to clean and filter public drinking water:
• Portland, Oregon avoided purchasing a $200 million filtration treatment system for its water supply by protecting 102 square miles of its watershed. This avoided cost constitutes an economic benefit of just under $3,000 per acre for water filtration services. • New York City draws half of its drinking water from three reservoirs located in the Catskill Mountains in the headwaters of the Delaware River. By spending $1.5 billion on watershed protections, New York City has avoided spending at least $6 to $8 billion in capital costs for the construction of a water filtration plant, as well as the $300 million it would cost every year to operate that plant.
In both examples, building a treatment plant would not have generated the wide array of ancillary ecosystem services provided by the conservation alternative, such as carbon sequestration, wildlife habitat, and recreational opportunities.
Water quality is also reflected in elevated property prices (Section 5) and increased number and quality of recreational trips (Section 6). 2. Carbon Storage
Riparian areas contribute to climate regulation by storing carbon in biomass (e.g., vegetation and soils). When riparian areas are replaced by other land cover types, such as agriculture or residential development, the stored carbon is released into the atmosphere as greenhouse gases that contribute to climate change.
We collected information on the amount of carbon stored above ground, below ground and in the soil in various kinds of riparian forests as well as alternative land uses, and estimate the net loss in carbon storage that occurs when an acre of streamside forest is developed.42 To quantify the economic value of carbon sequestration, we use an estimate of the social cost of carbon in the atmosphere ($31 per ton of CO2 in $2010, or $127 per metric ton of CO2 equivalent in $2017).43 The social cost of carbon estimates the present value of the stream of annual costs and
42 Based on the overall accounting method outlined in the InVEST package (Carbon Storage and Sequestration: Climate Regulation), as well as regional values reported in: Industrial Economics. 2011. Economic Valuation Of Wetland Ecosystem Services In Delaware. Prepared for the Delaware Department Of Natural Resources And Environmental Control. Smith, J.E., Heath, L.S. and Hoover, C.M., 2013. Carbon factors and models for forest carbon estimates for the 2005– 2011 National Greenhouse Gas Inventories of the United States. Forest Ecology and Management, 307, pp.7-19. 43 Nordhaus, W.D., 2017. Revisiting the social cost of carbon. Proceedings of the National Academy of Sciences, p.201609244. Estimates of the social cost of carbon vary widely, and ours can be considered a conservative value.
ECONorthwest 36 damages (e.g., changes in agricultural production, flooding, wildfire, human health, drought etc.) expected to result from the emission of one metric ton of CO2.
Table 16. Land Use Change and the Value of Lost Carbon Storage Capacity Sources: ECONorthwest with data from the InVEST package, IeC 2011 and Smith et. al 2013. Carbon Storage (metric tons/acre) Land Use/Land Cover Aboveground Belowground Soil Total Developed - - 16 16 Agriculture 4 2 22 28 Rangeland 1 1 30 32 Oak/Hickory 41 6 21 69 Elm/Ash/Cottonwood 31 4 45 81 Maple/Beech/Birch 48 6 28 82 Change in Carbon Storage with Land Cover Change (metric tons/acre) Oak/Hickory -41 -6 -6 -53 Elm/Ash/Cottonwood To Developed -31 -4 -30 -65 Maple/Beech/Birch -48 -6 -13 -66 Oak/Hickory -37 -4 1 -41 Elm/Ash/Cottonwood To Agriculture -27 -2 -23 -52 Maple/Beech/Birch -44 -4 -6 -54 Oak/Hickory -40 -5 8 -37 Elm/Ash/Cottonwood To Rangeland -30 -4 -16 -49 Maple/Beech/Birch -47 -5 1 -51 Value of Change in Carbon Storage ($/acre) Oak/Hickory -$5,258 -$795 -$722 -$6,775 Elm/Ash/Cottonwood To Developed -$3,937 -$573 -$3,766 -$8,276 Maple/Beech/Birch -$6,114 -$764 -$1,599 -$8,477 Oak/Hickory -$4,742 -$537 $103 -$5,175 Elm/Ash/Cottonwood To Agriculture -$3,421 -$315 -$2,941 -$6,676 Maple/Beech/Birch -$5,598 -$506 -$774 -$6,878 Oak/Hickory -$5,103 -$691 $1,032 -$4,762 Elm/Ash/Cottonwood To Rangeland -$3,782 -$470 -$2,012 -$6,264 Maple/Beech/Birch -$5,959 -$660 $155 -$6,465
Table 17. Annual and Projected Values of Lost Carbon Storage DE NJ NY PA Basin Total Net Loss of Natural Land Cover -9 -53 -13 -92 -167 (100-ft buffer, acres/yr) Low (-$4,762/acre) -$44,210 -$252,967 -$60,028 -$440,199 -$797,405 High (-$8,477/acre) -$78,697 -$450,299 -$106,853 -$783,584 -$1,419,432 Total NPV 2018-2028 Low -$388,436 -$2,222,600 -$527,409 -$3,867,640 -$7,006,084 3% Discount Rate High -$691,441 -$3,956,372 -$938,822 -$6,884,650 -$12,471,285 Low -$38,844 -$222,260 -$52,741 -$386,764 -$700,608 2018-2028 Annualized High -$69,144 -$395,637 -$93,882 -$688,465 -$1,247,128
ECONorthwest 37 In contrast to the water quality and air pollution mitigation value, which repeat every year, we value losses in carbon storage as one-time events. 3. Air Quality
Streamside forests improve regional air quality. Forest Service researchers have quantified the capacity of trees to capture air particulates and how this translates into reduced healthcare costs.44 The economic benefit of trees is highest in urban areas where human populations and the health effects of air pollution are concentrated.
Table 18. Annual and Projected Air Pollution Damages from Riparian Development Source: ECONorthwest with data from EPA and Nowak et. al. 2004 DE NJ NY PA Basin Total Net Loss of Natural Land Cover -9 -53 -13 -92 -167 (100-ft buffer, acres/yr) Low Value: Rural ($3 to $7/ac/yr) -$51 -$276 -$42 -$652 -$1,021 High Value: Urban ($42 to $132/ac/yr) -$584 -$2,312 -$1,722 -$11,728 -$16,346 Total NPV 2018-2028 Low -$1,371 -$7,843 -$1,861 -$13,648 -$24,723 (cumulative effect, 3% discount rate) High -$56,477 -$323,155 -$76,683 -$562,336 -$1,018,651 Low -$137 -$784 -$186 -$1,365 -$2,472 2018-2028 Annualized High -$5,648 -$32,316 -$7,668 -$56,234 -$101,865
Similar to water quality effects, we assume that air pollution losses from forest conversion repeat year after year, and build cumulatively. For example, in year one we value the losses associated with 167 acres of riparian forest, and in the second year we value losses from 334 acres. 4. Flood Mitigation
Riparian areas with undeveloped floodplains provide overbank storage for floodwaters and help attenuate large magnitude floods by reducing the height, velocity and destructive power of floodwaters downstream. Trees and other riparian vegetation help slow the speed and power of floodwaters.45 For example, forest vegetation was shown to lower stream water elevations from 32 feet to 17.3 feet for a 100-year flood.46 Buffers also ensure that structures are set back a safe distance from the water’s edge. Reducing a property’s proximity to waterways and floodwaters reduces the potential for flooding and damages.
The costs of floodplain protection and the benefits of avoided damages are realized by different groups. For instance, the costs of flooding are often spread among many downstream property
44 Nowak, D.J., Hirabayashi, S., Bodine, A. and Greenfield, E., 2014. Tree and forest effects on air quality and human health in the United States. Environmental Pollution, 193, pp.119-129. 45 U.S. Environmental Protection Agency, 2006. Economic Benefits of Wetlands. EPA843-F-06-004.
46 Castelle et al. (1994) Wetland and stream buffer size requirements - a review. Journal of Environmental Quality, 23(5): 878-882.
ECONorthwest 38 owners and insurance agencies, whereas the opportunity costs of conserving riparian areas must be borne by relatively few upstream landowners and municipalities.47
A riparian protection program that prohibits development in both the floodway and the flood fringe preserves natural areas for absorption of flood sized flows and protects structures from flood damage. The potential for flood damages associated with various flood stages has been characterized for many specific communities in the Basin.48
Figure 12. Annual flood peaks recorded on the Delaware River at Trenton, N.J., 1898-2015 Source: USGS, https://nwis.waterdata.usgs.gov/nj/nwis/peak/?site_no=01463500&agency_cd=USGS Note: From September 2004 to June 2006, the Delaware River in New Jersey, New York, and Pennsylvania experienced three major floods that caused extensive damage.
In 2009, the DRBC Flood Advisory Committee recommended that communities “incorporate the buffer concept as part of a comprehensive floodplain management program to protect communities from flood damage”, and identified fixed 100-foot buffers and variable width buffers as appropriate policies. The New Jersey Flood Mitigation Task Force and the Association of State Floodplain Managers echoed these recommendations in separate reports.49
Flood risk and flood damages are highly site and event-specific. For example, avoided damage depends on the type, value and density of buildings in the floodplain, as well as flood heights.
47 Watson, K.B., Ricketts, T., Galford, G., Polasky, S. and O'Niel-Dunne, J., 2016. Quantifying flood mitigation services: The economic value of Otter Creek wetlands and floodplains to Middlebury, VT. Ecological Economics, 130, pp.16-24.
48 Delaware River Basin Commission. No Date. Flood Impacts by Location. 49 New Jersey Flood Mitigation Task Force, 2006. Report on Delaware River Flood Mitigation. Association of State Floodplain Managers. 2013. How-To Guide for No Adverse Impact – Infrastructure.
ECONorthwest 39 Few studies have addressed the topic of riparian cover and flood damages in a way that might be directly transferrable to and quantifiable in the context of the Delaware River Basin.
Suspended sediment in streams increases the frequency and severity of flooding. We estimate that every acre of riparian buffer lost to development increases flood damages by $0.4 to $1.3 due to sediment effects alone (see Section 1). Based on sediment erosion and deposition locations, under some circumstances this value might be considerably higher.
The largest flood-related benefit of a buffer policy would likely be that of preventing further development in floodplains. Not building in floodplains in the Chicago metropolitan area, for example, was estimated to save an average of $900 per acre per year in flood damages.50
Many regions in the Delaware River Basin face repetitive flood loss claims.51 To help avoid flood damages, the state of Pennsylvania has voluntarily ‘bought out’ and demolished nearly 1,400 homes and removed 3,500 people from dangerous flood areas since 1996.52
Riparian buffers are creditable under the Federal Emergency Management Agency’s Community Rating System (CRS).53 Mitigation activities (like buffer ordinances and other floodplain management activities) can improve a community’s rating and earn 5 percent incremental discounts on flood insurance premiums.
A number of other studies document the flood mitigation effects of, and economic justification for, protecting natural floodplains:
• In 1976 the Army Corps of Engineers used an avoided-cost approach to estimate the economic costs and benefits of wetland and floodplain preservation in the Charles River Basin, Massachusetts.54 The Corps estimated that the loss of 8,442 acres of wetlands within the Charles River system would have resulted in annual flood damages of over $17 million, and chose to purchase and protect the floodplain parcels from development rather than constructing expensive flood control structures. This translates into roughly $2,000 per acre in avoided damages ($8,621 in $2017 dollars). • A recent study conducted in Vermont reported an annual flood damage reduction of $459,000 from conserving 17,989 acres ($25.50/acre) of woody wetlands and floodplain forests. This is substantially lower than other values reported in the literature, and the
50 Johnston, D.M., Braden, J.B. and Price, T.H., 2006. Downstream economic benefits of conservation development. Journal of water resources planning and management, 132(1), pp.35-43. 51 Delaware River Basin Commission. No Date. Flood Insurance Claims In The Delaware River Basin. 52 Pennsylvania Emergency Management Agency. What is Hazard Mitigation. 53 FEMA. 2015. Fact Sheet - The Community Rating System 2015 Works to Protect Natural Floodplains. Delaware Riverkeeper Network. 2015. Appendix A - Sample Riparian Ordinance. 54 Thibodeau, F.R. and B.D. Ostro. 1981. An Economic Analysis of Wetland Preservation. Journal of Environmental Management, 12:19-30.
ECONorthwest 40 authors suggest that this is because the benefits accrue to a relatively small population of downstream beneficiaries.55 • A widely applied meta-analysis of wetland studies found that flood attenuation benefits provided by wetlands were between $166 and $3,256 per acre per year, with a mean value of $732 (2017$).56 • Allen et al. (2003) concluded that the existence of woody corridors along the Missouri River during a large flood in 1993 prevented and reduced levee damage by almost half. Areas with wider woody corridors had less levee damage, and buffer widths of 300 to 500 feet were the most protective.57 5. Property Values
For amenity reasons, landowners tend to prefer forested buffers to barren streambanks.58 Forested riparian buffers were widely preferred in a photo-based survey of rural and suburban landowners, with 90 percent of suburban landowners preferring forested riparian buffers to non-vegetated corridors.59 Additionally, in a recent study of nearly 12,000 American adults and children, seven out of 10 children surveyed said they “would rather explore woods and trees than play on neat-looking grass.”60
A review of academic research papers on the amenity values and resulting property price effects of riparian areas concluded that the presence and quality of riparian buffers can enhance property values by less than 1 percent to upwards of 26 percent.61 Home prices generally increase with proximity to a stream or buffer zone.
Of particular relevance to the policy context in the Delaware River Basin is a 2009 study by Bin et. al, which examined housing prices after several counties in North Carolina established a mandatory buffer rule. The authors concluded that limiting streamside development and tree removal did not have a significant impact on the value of riparian properties. They suggest that
55 Watson, K.B., Ricketts, T., Galford, G., Polasky, S. and O'Niel-Dunne, J., 2016. Quantifying flood mitigation services: The economic value of Otter Creek wetlands and floodplains to Middlebury, VT. Ecological Economics, 130, pp.16- 24. 56 Woodward, R.T. and Wui, Y.S., 2001. The economic value of wetland services: a meta-analysis. Ecological economics, 37(2), pp.257-270. 57 Allen, S.B., Dwyer, J.P., Wallace, D.C. and Cook, E.A., 2003, Missouri River flood of 1993: role of woody corridor width in levee protection. Journal of the American Water Resource Association, 39(4), pp.923-933. 58 Sullivan, W.C., Anderson, O.M., Lovell, S.T., 2004. Agricultural buffers at the rural-urban fringe: an examination of approval by farmers, residents, and academics in the Midwestern United States. Landscape and Urban Planning. 69, 299–313. 59 Kenwick, R. a., Shammin, M. R., & Sullivan, W. C. 2009. Preferences for riparian buffers. Landscape and Urban Planning, 91, 88–96. 60 Kellert, S. and DJ Case and Associates. 2017. The Nature of Americans National Report: Disconnection and Recommendations for Reconnection. 61 American Rivers. 2016. The Economic Value of Riparian Buffers.
ECONorthwest 41 the policy may not have changed how property owners would have used or managed the land in the absence of the rule and/or that the environmental amenities protected by the buffer policy (e.g., visual aesthetics, water quality of adjacent streams, wildlife watching values) raised property values enough to offset any negative impacts.
In practice, it is difficult to isolate the effect of improved aesthetics while avoiding double- counting of benefits -- such as air quality, water quality, and flood control -- that also impact property values. For example:
§ Heightened flood risk can lower property values. Qui (2006) found that homes in the FEMA floodplain were worth 4.7 to 5.6 percent less than similar homes outside of the floodplain. Other studies have shown that homes in the floodplain tend to have 4 to 12 percent lower prices.62 § Improvements in water quality often elevate housing prices. A study conducted by the EPA found that clean water can increase the value of single family homes within 4,000 feet of the water’s edge by up to 25 percent.63 The City of Philadelphia estimates that installation of green stormwater infrastructure in the city will raise property values two to five percent, generating $390 million over the next 40 years in increased values for homes near green spaces.64 6. Fish and Wildlife Habitat
Riparian corridors are some of the most diverse, dynamic and complex habitats on Earth.65
• As part of the Atlantic flyway, the riparian habitats of the Delaware River Basin are used by hundreds of resident and migratory bird species for feeding, nesting, and/or breeding. Bird abundances in floodplain forests can be twice as high as upland forests. • Recreationally and commercially important fish species like trout, shad, herring, alewife, and striped bass use forested streams and rivers to spawn.66 • Riparian areas are especially important to amphibians and reptiles due to the fact that their lifecycle requires access to water.
62 Qiu, Z., Prato, T. and Boehrn, G., 2006. Economic Valuation of Riparian Buffer and Open Space in a Suburban Watershed. JAWRA Journal of the American Water Resources Association, 42(6), pp.1583-1596. 63 U.S. Environmental Protection Agency. 1973. Benefit of Water Pollution Control on Property Values. EPA-600/5-73- 005. 64 Philadelphia Water Department. 2009. Green City, Clean Waters: The City of Philadelphia’s Program for Combined Sewer Overflow Control—A Long Term Control Plan Update. Summary Report. 65 Naiman, R.J., Decamps, H. and Pollock, M., 1993. The role of riparian corridors in maintaining regional biodiversity. Ecological applications, 3(2), pp.209-212. 66 CBP (Chesapeake Bay Program), 1997. Riparian Forest Buffer Panel Report: Technical Support Document. (CBP ⁄ TRS 167 ⁄ 97)(EPA903-R-97-007)
ECONorthwest 42 Table 19 shows the preferred buffer widths for various wildlife species. Wildlife habitat needs in general greatly exceed the 100-foot area protected by buffer policies.
Table 19. Buffer Widths Required by Various Wildlife Species Source: Ellis, J.H. 2008. Scientific Recommendations on the Size of Stream Vegetated Buffers Needed to Protect Wildlife and Wildlife Habitat, Part Three, The Need for Stream Vegetated Buffers: What Does the Science Say? Report to Montana Department of Environmental Quality, EPA/DEQ Wetland Development Grant. Montana Audubon, Helena, MT. Desired Buffer Width Species (feet) Great Blue Heron nest 820–985 Cavity nesting ducks 600 Bald Eagle nests 400–1,320 Pileated Woodpecker, fisher, mink 330–600 Large mammals, bobcat, red fox, otter, muskrat, dabbling ducks 330 Wood Duck 250–600 Osprey, pine marten 200–330 Amphibians and reptiles, Belted Kingfisher, beaver 100–330 Small mammals 40–300 Hairy Woodpecker 130 Deer, Ring-necked Pheasant 75 Mourning Dove, Downy Woodpecker 50 Songbirds 50–660 American Redstart, Spotted Towhee 660 Warbling Vireo 300 Brown Creeper, Ruby-crowned Kinglet, Swainson’s Thrush 200 Red-eyed Vireo, Brown Thrasher 130 Black-capped Chickadee, White-breasted Nuthatch 50 Cold water fisheries 100-300
Riparian Forest Cover and Aquatic Habitat Health A stream’s ability to provide ecosystem services depends on the quality and quantity of surrounding tree cover. Studies evaluating the effectiveness of forested riparian buffers suggest that where natural riparian habitats are protected, fish diversity can be maintained with up to 15 percent impervious cover in the watershed, and aquatic insect diversity can be maintained with as much as 30 percent impervious cover.67
In 2001, the State Legislature of Georgia reduced the minimum width of mandatory-forested riparian buffers along designated trout streams from 100 feet to 50 feet. Researchers examined the importance of forested buffers to trout populations in the Appalachian Mountains in Georgia. They concluded that streams with 50-foot wide buffers had higher temperatures than
67 Schueler, T. R. 2003. Impacts of impervious cover on aquatic systems. Center for Watershed Protection, Ellicott, MD, Monograph No. 1 , 140p.
ECONorthwest 43 those with 100-foot wide buffers, with a predicted 66 to 97 percent reduction in trout reproductive success in streams with narrower buffers.68
Another study examining the influence of riparian buffers and impervious cover on stream health rankings found that watersheds with the best overall stream conditions had, on average, greater than 65 percent tree cover within the 100-foot riparian buffer zone and less than six percent impervious cover distributed throughout the watershed (Table 20). The other rankings (‘good’, ‘fair’, ‘poor’) had progressively lower levels of riparian tree cover and greater impervious cover.69
Table 20. Stream Health Rankings and Forested Buffers Source: Goetz et. al. 2003 Stream Health Forested Impervious Cover in Ranking Buffer Local Catchment Excellent 76.8% 3.6% Good 71.3% 4.9% Fair 63.2% 13.9% Poor 56.3% 19.5%
Habitat Connectivity Riparian vegetation along river channels functions as a primary regional migration corridor for most wildlife species. Woody vegetation must be present for many terrestrial species to find needed cover while traveling across otherwise open areas.70
Fragmentation results in the loss of wildlife habitat and movement corridors, which in turn results in wildlife decline and extirpation. Habitats that become isolated islands surrounded by development lose much of their ecological value even though the habitat may not be directly
68 Jones. K.L., G.C. Poole, J.L. Meyer, W. Bumback and E.A. Kramer. 2006. Quantifying expected ecological response to natural resource legislation: a case study of riparian buffers, aquatic habitat and trout populations. Ecology and Society 11(2):15 69 Goetz, S.J., Wright, R.K., Smith, A.J., Zinecker, E. and Schaub, E., 2003. IKONOS imagery for resource management: Tree cover, impervious surfaces, and riparian buffer analyses in the mid-Atlantic region. Remote sensing of environment, 88(1), pp.195-208. Goetz, S.J., 2006. Remote sensing of riparian buffers: past progress and future prospects. JAWRA Journal of the American Water Resources Association, 42(1), pp.133-143. Snyder, M.N., Goetz, S.J. and Wright, R.K., 2005. Stream health rankings predicted by satellite derived land cover metrics. JAWRA Journal of the American Water Resources Association, 41(3), pp.659-677. 70 USDA NRCS. 1996. Riparian Areas Reservoirs of Diversity.
ECONorthwest 44 affected (Figure 13).71 Researchers have suggested a nation-wide network of wildlife corridors along rivers to facilitate wildlife migration and enable adaptation to climate change.72
Figure 13. Movement Corridors and Habitat Connection Source: http://conservationcorridor.org/wp-content/uploads/riparian_diagram.jpg
Increased riparian habitat can also benefit commercial operations by protecting wildlife populations. In addition to sediment-related benefits for marine fisheries (see Section 1), other examples include:
• Pollination by native pollinators: The Nature Conservancy estimates that protecting and restoring habitat for native pollinators can boost agricultural earnings on New Jersey tomatoes farms by $30 to $222 per acre.73 • Pest control by forest birds: birds control many insect pest species. The cost to replace the biological control provided by forest birds with pesticides or genetic engineering has been estimated to be at least $7.34 per acre.74
71 Newcomb et. al.. 2002. Surface Water and Riparian Areas of the Raritan River Basin - A Technical Report for the Raritan Basin Watershed Management Project.
72 Fremier, A.K., Kiparsky, M., Gmur, S., Aycrigg, J., Craig, R.K., Svancara, L.K., Goble, D.D., Cosens, B., Davis, F.W. and Scott, J.M., 2015. A riparian conservation network for ecological resilience. Biological Conservation, 191, pp.29-37. 73 The Nature Conservancy. No Date. Analysis of Native Pollinator Benefits to New Jersey Farms. 74 Moskowitz, K. and Talberth, J., 1998. The economic case against logging our national forests. Santa Fe, New Mexico: Forest Guardians.
ECONorthwest 45 Existence Values About half of the animal species of concern in the Mid-Atlantic Region are dependent on wetlands, streams, rivers, and riparian areas.75 Riparian protection and restoration efforts could improve conditions for federally-listed endangered species such as the Atlantic sturgeon, as well as more common species such as blueback herring and alewife that have experienced widespread declines from historical levels. Economic research on passive-use values suggests particularly high value for rare species. 7. Recreation
Loss of riparian forest can affect both land and water-based recreational opportunities. For example, development can reduce the total area of forest available for certain types of recreational activities, or it can reduce enjoyment by altering the visual appeal of streamside recreation areas. In a study of nearly 12,000 American adults and children, seven out of 10 children surveyed said they “would rather explore woods and trees than play on neat-looking grass.”76 The quantity and quality of riparian habitats also strongly influences the availability of wildlife populations that in turn support a variety of recreational activities. Insofar as riparian buffers provide habitat and improve wildlife populations, the quality of hunting, fishing, wildlife viewing, nature photography, and other wildlife-dependent activities will be improved. Riparian corridors can provide important opportunities for trail development along waterways, maintaining public access.
Recreational effects can be measured in a variety of ways, including number of trips taken, consumer spending on travel and equipment, as well as ‘consumer surplus’, which refers to a person’s enjoyment of a recreation activity above and beyond what they actually pay for it. Economists at the USDA Economic Research Service have developed models to describe the recreation benefits of the U.S. Department of Agriculture’s Conservation Reserve Enhancement Program (CREP).77 This program pays private landowners to retire agricultural lands from production and convert them to forests and grasslands, with a particular emphasis on planting in riparian areas. Based on nation-wide recreation participation data and information about regional land cover, the models estimate the gain in recreational use and consumer surplus that occurs when an acre of land is converted from cropland to natural cover. This is essentially the process of buffer loss and development in reverse and therefore represents an appropriate and useful set of values to assess incremental changes in recreation due to land use change.
75 Brooks, R.P. and Serfass, T.L., 2013. Wetland-Riparian Wildlife of the Mid-Atlantic Region: An Overview. In Mid- Atlantic Freshwater Wetlands: Advances in Wetlands Science, Management, Policy, and Practice (pp. 259-268). Springer New York. 76 Kellert, S. and DJ Case and Associates. 2017. The Nature of Americans National Report: Disconnection and Recommendations for Reconnection. 77 Feather, P., Hellerstein, D. and Hansen, L., 1999. Economic valuation of environmental benefits and the targeting of conservation programs: the case of the CRP. USDA Economic Research Service. Agricultural Economic Report No. 778.
ECONorthwest 46 Table 21 shows per-acre consumer surplus values for various recreational activities in the Northeastern region. Every acre of natural riparian land converted to alternative uses results in a loss of $62.8 in recreational use and enjoyment, on average. This loss in use and enjoyment could be due to a number of factors including lower recreation participation, less access, or reduced wildlife populations that reduce the quality of hunting and viewing.
Table 21. Value of Private Lands for Recreation Source: ECONorthwest with data from Feather and Hansen 1999 and Hansen and Ribaudo 2008 Note: the per-acre estimate for marine recreational fishing is transferred from sediment related impacts described in Section 1. Value Recreation Type (consumer surplus/ac/yr) Wildlife viewing $49.0 Pheasant hunting $8.6 Freshwater recreation $3.4 Marine recreational fishing $1.7 Total $62.8
Cumulative losses amount to approximately $48.5 thousand per year, summing to a projected $485 thousand over the course of the next ten years (Table 22).
Table 22. Annual and Projected Recreation Losses Associated with Riparian Development DE NJ NY PA Basin Total Annual Net Loss of Natural Land Cover -9 -53 -13 -92 -167 (100-ft buffer, acres/yr) Annual Loss in Consumer Surplus ($63/acre) -$583 -$3,334 -$791 -$5,802 -$10,509 Total NPV 2018-2028 -$26,910 -$153,975 -$36,537 -$267,938 -$485,359 2018-2028 Annualized -$2,691 -$15,397 -$3,654 -$26,794 -$48,536
A study in Philadelphia estimated that restoring riparian vegetation and developing streamside parks would increase recreational trips by almost 350 million over 40 years, translating to roughly $950/ac/year in additional consumer surplus (2009$).78 Riparian corridors are an important part of Philadelphia’s GreenPlan, regional riverfront access initiatives, and other planning efforts.79 For example, in 2009 the Delaware Valley Regional Planning Commission (DVRPC) developed an open space plan which links the region’s watersheds and parks to a two-state, nine-county network of streams, trails, and greenways (Figure 14).
78 The Conservation Fund. 2014. Ecosystem Services Literature Review. Prepared for the Chicago Metropolitan Agency for Planning. 79 Wallace Roberts & Todd. 2010. GreenPlan Philadelphia.
ECONorthwest 47 Figure 14. Planned Network of Streams, Trails, and Greenway Connections in the Delaware Valley Source: Delaware Valley Regional Planning Commission and GreenPlan Philadelphia
Other studies demonstrate the close link between water quality, habitat restoration, and spending on outdoor recreation. For example:
• In the central Appalachian region, restoring streams to support fish could generate an additional $239 million in freshwater fishing expenditures across the region.80 • Research has demonstrated that, for every extra meter of visibility in a lake, recreationists are willing to travel 56 minutes farther (equivalent to US$22 in travel costs).81
80 Jackson, L.E., Rashleigh, B. and McDonald, M.E., 2012. Economic value of stream degradation across the central Appalachians. Journal of Regional Analysis & Policy, 42(3), p.188. 81 Keeler, B.L., Wood, S.A., Polasky, S., Kling, C., Filstrup, C.T. and Downing, J.A., 2015. Recreational demand for clean water: evidence from geotagged photographs by visitors to lakes. Frontiers in Ecology and the Environment, 13(2), pp.76-81.
ECONorthwest 48 • The improvements in water quality achieved in the Chesapeake Bay by 1996 alone increased the value of recreational use (beach use, boating, and striped bass sport fishing) by $357.9 million to $1.8 billion (1996$).82 Collectively, riparian buffers improve conditions for outdoor recreation on-site and elsewhere in the watershed. Outdoor recreation importance to quality of life, public health, and general regional attractiveness to businesses and skilled workers make it an important contributor to regional economy stability and growth. B. Aggregate Value of Riparian Buffer Services
People appreciate and value riparian buffers directly and with recognition of the collective suite of amenity and ecological services they provide. Johnston et al. (2015) published a valuation study estimating Maine residents’ Willingness to Pay (WTP) for protecting and restoring riparian habitat (Table 23).83 Based on a general population survey of three towns in south coastal Maine, the authors estimated that households in the study watershed were willing to pay an average of $0.140/year/additional foot of riparian development setbacks (the survey question specifically asked about WTP to increase the currently protected buffer area of 100 feet to 200 feet).
82 Morgan, C. and Owens, N., 2001. Benefits of water quality policies: the Chesapeake Bay. Ecological Economics, 39(2), pp.271-284.
83 Johnston, R.J., C. Feurt and B. Holland. 2015. Ecosystem Services and Riparian Land Management in the Merriland, Branch Brook and Little River Watershed: Quantifying Values and Tradeoffs. George Perkins Marsh Institute, Clark University, Worcester, MA and the Wells National Estuarine Research Reserve, Wells, ME. These annual household values are supported by a previous study that examined New York residents’ willingness to pay for different types of coastal habitat restoration in the Peconic Estuary system: Johnston, R.J., Grigalunas, T.A., Opaluch, J.J., Mazzotta, M. and Diamantedes, J., 2002. Valuing estuarine resource services using economic and ecological models: the Peconic Estuary System study. Coastal Management, 30(1), pp.47-65.
ECONorthwest 49
Table 23. Representative Household WTP (Willingness to Pay) for Riparian Protection Measures and Benefits Source: Johnston et al. 2015
Table 24. Estimated Household Values for Increased Riparian Protection Source: U.S. Census 2010; Johnston et. al. 2015 Number of Households Total Annual WTP for 100-foot State in Basin (2010) Development Setback Delaware 330,944 $4,633,215 New Jersey 1,070,859 $14,992,027 New York 48,585 $680,184 Pennsylvania 2,188,921 $30,644,894 Delaware River Basin 3,639,309 $50,950,320
We can apply these values to the Delaware River Basin in multiple ways. Using 2010 Census data on the number of people living in the Basin, we estimate the number of households by dividing the population by average family size (2.5). A 100-foot development setback program (or an increase to 200 feet in states that already have 100 foot buffers, for example) would be worth $14 to households every year, summing to nearly $51 million every year across the Basin.
These per household values align well with those reported elsewhere in the literature. For example, Holmes et al. (2004) report that annual household WTP for a riparian restoration program in North Carolina ranged from $0.95 – $74, depending on the spatial scale of restoration.84 Similarly, a meta-analysis examining household willingness to pay to protect farmland from development found that mean annual household WTP per acre ranges from
84 Holmes, T.P., Bergstrom, J.C., Huszar, E., Kask, S.B. and Orr, F., 2004. Contingent valuation, net marginal benefits, and the scale of riparian ecosystem restoration. Ecological Economics, 49(1), pp.19-30.
ECONorthwest 50 $0.0001 in Colorado and Wyoming to $21.90 in Massachusetts, with an average across all studies of $1.80.85 Summary of Riparian Ecosystem Services in the Delaware River Basin
In summary, riparian buffers in the Delaware River Basin provide tens of thousands of dollars in benefits per acre annually, with evidence that additional non-monetized benefits would substantially increase these totals (Table 25). Furthermore, households and homeowners benefit from riparian buffers in multiple ways, including aesthetics, recreation access and quality, and appreciation for habitat and wildlife. With greater population density, more potential beneficiaries also increase the total economic value provided per segment of riparian buffer.
Table 25. Summary of Ecosystem Services Values by Riparian Buffers in the Delaware River Basin Source: ECONorthwest with data from a number of sources (see report) Ecosystem Service Provided Per-unit Value for Services Nutrient Retention $87 to $4,789 per acre per year Carbon Storage $4,762 to $8,477 per acre per year Air Quality $3 to $132 per acre per year Aesthetic Values +1% to +26% Property Price Premium Flood Mitigation Qualitative Description Recreation $63 per acre per year (lower bound) Wildlife Habitat Qualitative Description Combined Buffer Services $14/Household/Year
Extrapolating the rate of riparian land development observed in the Delaware River Basin between 2001 and 2011, and applying ecosystem service values monetized at a per acre scale, the net present value of future losses will be in the tens of millions of dollars (Table 26). Looking at only the narrower of the two buffer widths considered (100 foot width) the discounted benefit over the next ten years of avoiding additional loss of riparian buffer would likely be worth greater than $25 million.
85 Bergstrom, J.C. and Ready, R.C., 2009. What have we learned from over 20 years of farmland amenity valuation research in North America?. Applied Economic Perspectives and Policy, 31(1), pp.21-49.
ECONorthwest 51 Table 26. Summary of Projected Ecosystem Service Losses, by State, 2018-2028 Source: ECONorthwest with data from a number of sources (see report) Note: Net Present Value calculations apply a 3 percent discount rate. Water pollution refers only to nitrogen and phosphorus effects, and does not include sediment benefits; see Table 9, Section 1. Carbon storage effects are detailed in Table 17, Section 2 Air pollution effects are detailed in Table 18, Section 3 Recreation effects are detailed in Table 22, Section 7. State Delaware New Jersey New York Pennsylvania Basin Total Net Loss of Natural Land Cover Annual -9 -53 -13 -92 -167 (100-ft buffer, acres) Decadal -93 -531 -126 -924 -1,674 NPV 2018-2028 Low -$388,436 -$2,222,600 -$527,409 -$3,867,640 -$7,006,084 Water Pollution Removal High -$691,441 -$3,956,372 -$938,822 -$6,884,650 -$12,471,285 Low -$126,992 -$726,636 -$172,426 -$1,264,450 -$2,290,503 Carbon Storage High -$602,932 -$3,449,930 -$818,646 -$6,003,368 -$10,874,876 Low -$1,371 -$7,843 -$1,861 -$13,648 -$24,723 Air Pollutant Removal High -$56,477 -$323,155 -$76,683 -$562,336 -$1,018,651 Outdoor Recreation - -$26,910 -$153,975 -$36,537 -$267,938 -$485,359 Low -$543,708 -$3,111,053 -$738,233 -$5,413,675 -$9,806,669 Total Quantified Services High -$1,377,759 -$7,883,432 -$1,870,688 -$13,718,293 -$24,850,172 Annualized Value Low -$38,844 -$222,260 -$52,741 -$386,764 -$700,608 Water Pollution Removal High -$69,144 -$395,637 -$93,882 -$688,465 -$1,247,128 Low -$12,699 -$72,664 -$17,243 -$126,445 -$229,050 Carbon Storage High -$60,293 -$344,993 -$81,865 -$600,337 -$1,087,488 Low -$137 -$784 -$186 -$1,365 -$2,472 Air Pollutant Removal High -$5,648 -$32,316 -$7,668 -$56,234 -$101,865 Outdoor Recreation - -$2,691 -$15,397 -$3,654 -$26,794 -$48,536 Low -$54,371 -$311,105 -$73,823 -$541,368 -$980,667 Total Quantified Services High -$137,776 -$788,343 -$187,069 -$1,371,829 -$2,485,017
ECONorthwest 52 Implementing Protection and Restoration of Riparian Areas
Providing these economic benefits of riparian buffers is not a particularly costly endeavor. Per- acre, agricultural land costs $8,400 in Delaware, $12,800 in New Jersey, $2,980 in New York, and $5,500 in Pennsylvania.86 The price of an easement is generally 60 to 80 percent of the land price.87 These prices suggest that the one-time burden of riparian buffer costs in areas not yet urbanized would generally be less than the annual benefit. Prices in urban and suburban areas are much higher. For example, in 2016 urban land in Philadelphia cost $52,187 per acre.88 Retrofitting riparian buffers back into urbanized areas can be particularly costly. These figures establish a clear urgency for protecting the Basin’s remaining riparian forests. See the Appendix Maps for more information on this issue. Protection vs. Restoration Buffer rules offer the opportunity to keep existing riparian forests in place. Protecting forests will protect water bodies from further declines and could avert much larger costs to fix the Basin’s impaired habitats and waters in the future. Restoration is much more expensive than protection. In work we have completed in the Puget Sound Basin reviewing habitat restoration and conservation projects, restoration projects tended to cost at least ten times more than equivalent conservation projects.89
Furthermore, restoration can be challenging, and success rates are well below 100 percent. A review of wetland mitigation projects in Washington State found less than a 50 percent success rate.90 Programs based on restoration have often had a difficult time meeting restoration goals.91 For example, the Chesapeake Bay program has consistently failed to meet planting objectives: “A goal of 900 miles/year was a goal first set by the states in 2007. Since that time, this goal has never been reached. … Average annual mileage [between 2012 and 2014] was 220 miles. In a 10-year period, from 2001-2010, average annual mileage was 650 miles.”92 The report cites a variety of barriers that have slowed progress.
86 USDA National Agricultural Statistics Service. 2016. Land Values 2016 Summary. 87 New Jersey Transfer of Development Rights Program. 1999. Appraisal Guidelines For Determining Development Potential. 88 Lincoln Institute of Land Policy. 2016. Land and Property Values in the U.S. - Land Prices for 46 Metro Areas. 89 See, for example ECONorthwest. 2008. Puget Sound Partnership Action Agenda: Financing Strategy Task 1: Cost Analysis. 90 Washington State Department of Ecology. 2000. Washington State Wetland Mitigation Evaluation Study. 91 Chesapeake Bay Program. Track the Progress – Planting Forest Buffers. Online at: http://www.chesapeakebay.net/indicators/indicator/planting_forest_buffers 92 Chesapeake Bay Program. 2015. Riparian Forest Buffer Outcome Management Strategy 2015–2025, v.1
ECONorthwest 53 Restoration not only costs more than protection, but also provides lower service levels during recovery. For example, when planted, a riparian forest buffer composed of saplings will not be very effective in reducing nutrient runoff, but its effectiveness will increase as the trees mature. A recent study of riparian buffer age and its effects on stream aquatic function supports the idea that restoration may require significantly longer time periods to display restored ecological functions and values. Orzetti et. al. (2010):
“…collected data on water quality, habitat, and macroinvertebrates from 30 Piedmont streams with buffers ranging from zero to greater than 50 years of age in the Chesapeake Bay watershed. Overall, buffer age was positively related to improved stream habitat, water quality, and a suite of macroinvertebrate metrics. The data collected showed marked improvements occurring within 5–10 years postrestoration, with conditions approaching those of streams with long established buffers within 10–15 years postrestoration”.93 Urbanization Riparian buffers are “uniquely capable of producing high levels of multiple ecosystem services in otherwise nonforested landscapes”.94 For example, in a model assessing the impacts of urbanization on Chesapeake Bay water quality between 2000 and 2030, researchers demonstrated that, if implemented throughout the Basin, riparian buffers could reduce overall nitrogen and phosphorus loads even as urban point sources increase.95
Federal and state policies have traditionally prioritized agricultural properties for technical and financial support and participation in incentivized riparian buffer programs, such as the U.S. Department of Agriculture’s Conservation Reserve Enhancement Program (CREP). In contrast, part-time farmers (and/or amenity owners) and residential landowners have received much less programmatic attention (information and incentives) for buffer implementation. Based on the increase in urban cover in the riparian zone and the decline in forest and agricultural cover throughout the Basin, federal and state policy might shift from its present agricultural emphasis to better address residential riparian conditions and loss. Urbanization is projected to increase throughout the Basin in the coming decades (Figure 15).
93 Orzetti LL, Jones RC, Murphy RF (2010) Stream condition in Piedmont streams with restored riparian buffers in the Chesapeake Bay watershed. J Am Water Resour Assoc 46:473–485 94 Stanturf, J., Lamb, D. and Madsen, P. eds., 2012. Forest landscape restoration: Integrating natural and social sciences (Vol. 15). Springer Science & Business Media. 95 Roberts, A.D., and S.D. Prince. (2010). Effects of urban and non-urban land cover on nitrogen and phosphorus runoff to Chesapeake Bay. Ecological Indicators 10: 459-474
ECONorthwest 54 Figure 15. Urban Development Projections, 2011-2070 Source: The Delaware River Basin Project, Presentation by Dr. Jantz, Shippensburg University
Researchers studying riparian buffer implementation in urban environments observed “that residential landowners without buffers often were not familiar with riparian functions or conservation organizations; nor did they find the practices promoted by buffer programs applicable for their backyards”.96 They concluded that:
“Residential riparian landowners are dramatically less willing to implement buffers on their property than agricultural landowners … In the eyes of residential riparian landowners, the current size and demands of buffers are not acceptable; however, neighborhood cohesion may play an encouraging or discouraging role depending on the prevailing normative standards. As buffers become more common on residential properties, potentially through experimentation and education that emphasizes local outcomes, backyard buffers may more effectively adhere to aesthetic and property management norms”97 Social Barriers and Constituencies The Technical Advisory Committee for Pennsylvania’s Riparian Buffer Initiative Implementation Plan issued a comprehensive report based on the input of more than 100
96 Armstrong, A. and Stedman, R.C., 2012. Landowner willingness to implement riparian buffers in a transitioning watershed. Landscape and Urban Planning, 105(3), pp.211-220. 97 Armstrong, A. and Stedman, R.C., 2012. Riparian landowner efficacy in an urbanizing watershed. Society & Natural Resources, 25(11), pp.1193-1203.
ECONorthwest 55 individuals and representatives of Pennsylvania groups that represented a range of interests in the Chesapeake Bay watershed. 98 The report identified six categories of barriers to riparian forest buffers in Pennsylvania:99
• Economic barriers include the need for farmers to maximize production, the fact that smaller farms may suffer more than larger farms from loss of riparian land from production, and the costs of planting and maintenance. • Education and awareness: fear of government control, failure to consider buffers in site designs, and failure to understand the need for or function of buffers. • Marketing: landowners may not know where to go for help. • Policy, planning and legislative barriers: engineered flood control projects do not take buffers into account; transportation, utility, and other corridors are often located along streams; landowners lack incentives, and; Pennsylvania has no driving legislation. • Physical, chemical, or biological barriers: Lack of space in urban areas and the use of streamside lands for active recreation.
• Attitudes: landowners think that buffers harbor invasive plants or undesirable wildlife; a desire for access to streams; the value of tidiness; the importance of traditional appearances and habits; lack time to establish or manage riparian forests; interference with viewsheds; and landowner-rights issues. Based on landowner surveys, Dutcher et. al. (2004) report that these barriers must be addressed in order for successful policy implementation:
“An effective approach to conserving and maintaining riparian forests needs to emphasize the role of riparian forests, respect concerns and dignity of individual landowners, and use credible advisors who understand landowner needs. Initially, it might be more effective for planners and policy makers to encourage riparian landowners to develop and execute personal management plans that incorporate landowner interests than to expect landowners to buy into abstract, arbitrary goals for buffer widths and stream reaches. … To be successful, any effort to create and maintain riparian forests on private lands should address landowner concerns about flooding, the reluctance of many landowners to abandon the ordered landscapes to which they are accustomed, and the economic interests of farmers. Centrally administered, coercive regulations will not be well received, although a broad, flexible regulatory framework that accounts for the interests of individual landowners may be acceptable once
98 Dutcher, D.D., Finley, J.C., Luloff, A.E. and Johnson, J., 2004. Landowner perceptions of protecting and establishing riparian forests: a qualitative analysis. Society and Natural Resources, 17(4), pp.319-332. 99 Pennsylvania Department of Environmental Protection. 1998. Pennsylvania Riparian Buffer Initiative Implementation Plan, Report of the Technical Advisory Committees, Final Draft.
ECONorthwest 56 more democratic approaches have been tried and landowners have learned more about the importance of streamside reforestation”.100
Residential and commercial landowners are more likely to approve of riparian buffers when their ecosystem services are recognized.101 Similarly, agricultural landowners are more likely to support riparian conservation if they believe that these areas are important for the community.102
Constituencies that will benefit from protecting riparian areas include angling and boating groups, hunters, outdoor recreationists, commercial fishermen, public water utilities, dam operators, tourism bureaus, businesses needing clean water, and local landowners. Buffer management policies must be designed to address the concerns of groups who may perceive losses, including agriculture, industry, residential owners, utilities, realtors, homebuilders, and landowner associations.
In a paper reviewing the implications of climate change and other large-scale trends in the Basin, researchers at the Pinchot Institute highlighted the importance of buffers and the role of local governments:
“In considering the findings of the risk assessments, analysis and prioritization, it is clear that risks to the region could be reduced significantly through implementing land use policies that maintain existing forest cover, reduce forest fragmentation, maintain impervious cover at reasonable levels (e.g., < 10 percent), and take full advantage of the ecosystem services provided by floodplains and riparian corridors. Local governments have primary responsibility for the land use decisions that can ultimately make communities less vulnerable and more economically resilient to environmental changes. Although it is a challenge to coordinate land use policy in a region that includes three states, seven counties and hundreds of municipalities, it has great potential for far-reaching climate resiliency benefits”103
100 Dutcher, D.D., Finley, J.C., Luloff, A.E. and Johnson, J., 2004. Landowner perceptions of protecting and establishing riparian forests: a qualitative analysis. Society and Natural Resources, 17(4), pp.319-332. 101 Wagner, M.M., 2008. Acceptance by knowing? The social context of urban riparian buffers as a stormwater best management practice. Society and Natural Resources, 21(10), pp.908-920. 102 Schrader C (1995) Rural greenway planning: the role of streamland perception in landowner acceptance of land management strategies. Landsc Urban Plan 33:375–390 103 Price, W. and Beecher, S., 2014. Climate change effects on forests, water resources, and communities of the Delaware River Basin.
ECONorthwest 57 Table 27. Distribution of Benefits and Costs from Buffer Policies Source: Huron River Watershed Council104 Entity Costs Benefits Staff time Increased property values Staff Training Reduced water treatment costs Local Technical Assistance to Developers and landowners Stormwater management Governments Public education efforts Reductions in flood damage Habitat preservation and increased wildlife populations Technical surveys and reports Increased property values Buffer delineation Stormwater management Developers Loss of developable land Bank stabilization and erosion control and Property Buffer restoration Increased diversity of wildlife Owners Buffer protection during construction Recreation opportunites Potential economic uses of buffer (e.g., logging)
Programs must be designed carefully to avoid unintended consequences that work against the objectives of riparian buffer protection efforts. For example, farmers and other landowners might preemptively reduce riparian areas in natural vegetation on their property with potential limits under consideration. The North Carolina Environmental Management Commission introduced North Carolina’s buffer rule as an immediate rule in July 1997 to minimize such activity.
In conclusion, efforts to protect existing riparian buffers can provide benefits well in excess of the costs associated with protecting such remaining areas. And policy should be designed and implemented with expediency as a primary objective. Policy Implications The key findings relevant to policy from this study are:
1. Benefits of well-functioning riparian buffers in the Delaware River Basin are high in economic value, particularly in comparison to typical costs. 2. Investments should prioritize protection of existing buffers. Preservation is generally much more cost-effective than restoration. 3. Beneficiaries of riparian buffers are numerous, widespread and geographically diffuse. The widespread distribution of benefits suggests that individual private investment alone will generally lead to underinvestment in riparian buffers. Benefits to others will typically play a negligible role in individual private investment decisions. Even when riparian landowners recognize their benefits from riparian buffers, it will be most advantageous, all else equal, to free-ride on buffers provided by others upstream and downstream. The free-riding approach leads to little private investment overall, with a heavy reliance on public contributions where feasible.
The benefits of riparian buffers in the Basin compared to the costs are particularly favorable, to an extent rarely observed in the scope of potential public investments. Opportunities to invest
104 Huron River Watershed Council. 2008. Riparian Corridor Protection in the Huron River Watershed.
ECONorthwest 58 thousands of dollars per acre to see that return or more every subsequent year are uncommon. The challenge is that the costs are not well-aligned with a narrow set of beneficiaries, but rather a diverse set of upstream and downstream beneficiaries, and society at large.
Collectively these results dictate that government involvement is needed to coordinate and maintain investment in riparian buffers for the Delaware River Basin. By requiring protection and in some cases restoration of riparian buffers, those who benefit also contribute, while the society as a whole experiences the broader benefits. There is a fairness to this approach as well, in that riparian landowners have disproportionately benefitted from society-wide investments to improve water quality and aquatic habitat conditions in the Basin.
ECONorthwest 59 Appendix Maps
Maps in Figure A-16 and Figure A-17 show land coverage and changes in land coverage by type from 2001 to 2011. Of particular note are the declines in agricultural lands and corresponding increases in urban lands. Urban land generally has higher prices than agricultural land, suggesting that the sooner riparian buffer protections can be established, the less costly they will be. Furthermore, urban areas have more people to benefit from the presence of riparian buffers, so the value of riparian buffers will increase over time as well.
ECONorthwest 60 Figure A-16. Percent Cover in Riparian Zone, 2011
Forest Urban Agriculture
NY NY NY
Scranton Scranton Scranton " " "
PA PA PA
Reading Reading Reading " " "
Trenton " Trenton " Trenton "
Philadelphia Philadelphia Philadelphia " " "
Wilmington Wilmington Wilmington " NJ " " NJ NJ
PercentBaltimore Forest PercentBaltimore Urban PercentBaltimore " " " in Riparian in Riparian Agriculture in Zone Zone Riparian Zone 0% - 20% 0% - 20% 0% - 20% 20% - 40% DE 20% - 40% DE 20% - 40% DE MD 40% - MD60% 40% - 60% 40% - MD60% 60% - 80% 60% - 80% 60% - 80% 80% - 100% 80% - 100% 80% - 100% Surface water Surface water Surface water and wetlands and wetlands and wetlands
ECONorthwest 61 Figure A-17. Percent Change in Land Cover, 2001-2011
ECONorthwest 62 Aaron.Vera
From: Steven.Strichman Sent: Monday, December 21, 2020 9:00 PM To: Friends of the Mahicantuck; Aaron.Vera; James.Rath Subject: RE: Urgent: EAF and application/error message on emails
There is no EAF. There is no action at this point. The Planning Commission is making a recommendation to the Council.
Sent from my Verizon, Samsung Galaxy smartphone
------Original message ------From: Friends of the Mahicantuck
Dear Steven, Aaron and James, we are reaching out, as we sent a while ago a message with several questions we had.
We wanted to follow up on that, but more importantly we wanted to inquire about the application associated with the requested change in zoning code for 1011 2nd Avenue. We were wondering if you were able to share with us the application and any EAF that might be associated with the application, if existing. Or, if the EAF was not yet submitted by the developer or any of his representatives, when it is expected that the EAF will be submitted?
Also, at our last email to James Rath, we got an error message in return and were wondering if that email address works again, so we can ensure we can submit statements ahead of the hearing on December 29.
Thank you again so much for your tireless work, the entire Friends of the Mahicantuck team.
1 The Friends of the Mahicantuck
Recipient: Carmella Mantello, Anasha Cummings
Letter: Greetings,
We, the undersigned residents of the City of Troy, do hereby protest against any change of the Zoning Code which would zone the property at 1011 2nd Avenue to any classification other than R1, residential single family, detached. The development of the property at 1011 2nd Avenue in Troy, NY, would disrupt the neighborhood, irrevocably change the character of the neighborhood, destroy the city’s last undeveloped forest along the Hudson River, and put an historically, archeologically and culturally significant indigenous site at jeopardy. We therefore urge the Troy City Council as well as the Planning Commission to not grant any change in the zoning of 1011 2nd Avenue. Signatures
Name Location Date
Leo Bachinger Catskill, NY 2020-08-22
KD McTeigue Albany, NY 2020-08-23
Emily Musial Philadelphia, PA 2020-08-23
Victoria Marcario Troy, NY 2020-08-23
Catherine Regitano Troy, NY 2020-08-23
Heather Kennish Castleton On Hudson, NY 2020-08-23
Madelyn Degler Troy, NY 2020-08-23
Molly Freiberg East Nassau, NY 2020-08-23
Annie Jacobs Troy, NY 2020-08-23
Zachary DeVilleneuve Troy, NY 2020-08-23
Donna Simms Troy, NY 2020-08-23
Christopher Bassett Troy, NY 2020-08-23
Rhea Drysdale Troy, NY 2020-08-23
Sarah Pezdek-Bachinger Ballston Spa, NY 2020-08-23
Jason Meyre Troy, NY 2020-08-23
Rags Ragliacci Troy, NY 2020-08-23
dan bolam Schenectady, NY 2020-08-24
Abigail Harris Wynantskill, NY 2020-08-24
Lauren Goewey Watervliet, NY 2020-08-24
Adam Retzlaff Mohawk, NY 2020-08-24 Name Location Date
Michelle Driscoll Pennellville, NY 2020-08-24
Michelle McCarthy Rensselaer, NY 2020-08-24
Kizzianne Casale Troy, NY 2020-08-24
Timothy Sarver Rensselaer, NY 2020-08-24
Eric Patton Troy, NY 2020-08-24
Beth Doris troy, NY 2020-08-24
Deirdre Matthews Sebastian, FL 2020-08-24
Jess Bennett Troy, NY 2020-08-24
Omar Williams Troy, NY 2020-08-24
Jay Deierlein East Greenbush, NY 2020-08-24
Jay Deierlein Troy, NY 2020-08-24
Celena Scherfner Liverpool, NY 2020-08-24
Ivy Hest Troy, NY 2020-08-24 richard herrick Troy, NY 2020-08-24
Shannon Contento Cohoes, NY 2020-08-24
Elizabeth Maloney Troy, NY 2020-08-24
Lauren Boardman Milton, NY 2020-08-24
Brendan Freiler River Vale, NJ 2020-08-24
Rachael Gardner Ravena, NY 2020-08-24
Patricia Jones Binghamton, NY 2020-08-24
Brandon Costelloe-Kuehn rensselaer, NY 2020-08-24
Paula Hebert Troy, NY 2020-08-24 Name Location Date
John Cruickshank Troy, NY 2020-08-24
Leander Fenton Troy, NY 2020-08-24
Stephanie Levay Albany, NY 2020-08-24
Dylan Keenan Cohoes, NY 2020-08-24
Ashleigh Ellis Troy, NY 2020-08-24
Zach Carhide Troy, NY 2020-08-24
Shawna Norton Troy, NY 2020-08-24
Louis Sanders jr Troy, NY 2020-08-24
Jan Hoffman Sebastian, FL 2020-08-24
LYNN JUDKINS TROY, NY 2020-08-24
Jean Debboli Greenville, NY 2020-08-24 steven shashok albany, NY 2020-08-24
Christine Powers Loudonville, NY 2020-08-24
Dia Osgood Slingerlands, NY 2020-08-24
Kristen Renee Rensselaer, NY 2020-08-24
Meagan Gallagher Albany, NY 2020-08-24
Elizabeth Ohler troy, NY 2020-08-24
Patricia Derocher Cohoes, NY 2020-08-24
Wendy Zeigler Troy, NY 2020-08-24
Laura Priscott Troy, NY 2020-08-24
Justin Tyrrell Troy, NY 2020-08-24
Maggie Noel Troy, NY 2020-08-24 Name Location Date
Melissa Ashdown Troy, NY 2020-08-24
Kathleen Miller Pleaseantdale, NY 2020-08-24
Jessica Bruce Troy, NY 2020-08-24
Cassandra Baker Endicott, NY 2020-08-24
Sara Culliton Troy, NY 2020-08-24
Kerri Dornicik New Paltz, NY 2020-08-24
Joshua Maxson Troy, NY 2020-08-24
Sharee Dunham Troy, NY 2020-08-24
Craig Craven pleasantdale, NY 2020-08-24
Mary D'Amico Wynantskill, NY 2020-08-24
Sharon Shaughnessy Albany, NY 2020-08-24
MICHAEL ZEHNER TROY, NY 2020-08-24
Jane Snay Troy, NY 2020-08-24
Makenzie Henault Albany, NY 2020-08-24
Meghan Menard Troy, NY 2020-08-24
Corrine Winnie-Obzud Troy, NY 2020-08-24
Bryana Campbell Troy, NY 2020-08-24
Manuel Perez Troy, NY 2020-08-24
Kyle Obzud Troy, NY 2020-08-24 rosemary clark TROY, NY 2020-08-24
Brittany Luke Troy, NY 2020-08-24
Anthony Powers Troy, NY 2020-08-24 Name Location Date
Taylor Elting Troy, NY 2020-08-24
Guillermo Chacon Albany, NY 2020-08-24
Ashley Delmonico Whitesboro, NY 2020-08-24
Brenda Ford Troy, NY 2020-08-24
Myra Johnson Albany, NY 2020-08-24 christine lucey Troy, NY 2020-08-24
Harold Previtali Troy, NY 2020-08-24
Christopher Caulfield Albany, NY 2020-08-24
Samantha Elting Waterford, NY 2020-08-24
Caroline ferris Troy, NY 2020-08-24
Renee Sambets Troy, NY 2020-08-24
Alex Helmar Troy, NY 2020-08-24
Jacob Osgood Cohoes, NY 2020-08-24
Laura ford Watervliet, NY 2020-08-24
Heather Moran Cohoes, NY 2020-08-24
Breanna Jordan Troy, NY 2020-08-24
Jessy Valentine Troy, NY 2020-08-24 michael lavigne Troy, NY 2020-08-24
Colleen Skiff Delmar, NY 2020-08-24
John Wolbeck Troy, NY 2020-08-24
Michael Nash Whitesbo, NY 2020-08-24
Araceli Herrera Queensbury, NY 2020-08-24 Name Location Date
Makayla Baldwin Delmar, NY 2020-08-24
Cait Denny Albany, NY 2020-08-24
Stephanie Weigelt Hudson, US 2020-08-24
Allison Conley Troy, NY 2020-08-24
Charleen Bushey Cohoes, NY 2020-08-24
Emily Clute Troy, NY 2020-08-24
James & Bonnie Devoe Troy, NY 2020-08-24
Crystal Riddell Troy, NY 2020-08-24
Joan Ciccarelli Troy, NY 2020-08-24
Rosella Riddell Troy, NY 2020-08-24
Karen Bellamy Clifton Park, NY 2020-08-24
Dana Williams Cohoes, NY 2020-08-24 wayne foy Troy, NY 2020-08-24
Linda Houle Troy, NY 2020-08-24
David Palmo Troy, NY 2020-08-24
Elaina Halse Troy, NY 2020-08-24
Samantha Johnson Albany, NY 2020-08-24
Treven Santicola Albany, NY 2020-08-24
John Baranowski North Las Vegas, NV 2020-08-24
Cassie Tran Wilmington, DE 2020-08-24
Stuart Ford Homestead, FL 2020-08-24
David Osgood Troy, NY 2020-08-24 Name Location Date
Carl Jourdanais Cohoes, NY 2020-08-24
Daniel Benoit Troy, NY 2020-08-24
Julie Prey Media, PA 2020-08-24
Debra Evans Troy, NY 2020-08-24
Meghan Keenan New York, NY 2020-08-25
Kristine Henneberry Kennebunk, ME 2020-08-25
Suzanne Ayer Schodack, NY 2020-08-25
Jo Medve Norfolk, NY 2020-08-25
Christina Galagarza Philadelphia, PA 2020-08-25
Kim Chabot Troy, NY 2020-08-25
Kelly Benoit Troy, NY 2020-08-25
Molly McDonnell Troy, NY 2020-08-25
Jacob Kuklick Philadelphia, PA 2020-08-25
Amy Sciortino Philadelphia, PA 2020-08-25
Grace Ashley Schenectady, NY 2020-08-25
Niah Tobarri Latham, NY 2020-08-25
John Connors Troy, NY 2020-08-25
Abby Swick Blue Springs, MO 2020-08-25
Kaylee Laflamme San Juan Capistrano, US 2020-08-25 alicia anaya Floresville, US 2020-08-25
Autumn Koen Sylvania, US 2020-08-25
AnnMarie Broussard Lafayette, US 2020-08-25 Name Location Date celys tials US 2020-08-25 egrah audil Minneapolis, US 2020-08-25
Hope Ryan South San Francisco, US 2020-08-25
Elizabeth Salvador Lahaina, US 2020-08-25
Kelly Brown Reno, US 2020-08-25
Janice Hall Tampa, US 2020-08-25
Caiden Kemp Baton Rouge, US 2020-08-25
Jeremy Peel San Diego, CA 2020-08-25
Nicole Keb San Francisco, US 2020-08-25
Liana Snow US 2020-08-25
Parker Brown Chevy Chase, US 2020-08-25 unknown 1212 US 2020-08-25
Jae Long Las Vegas, US 2020-08-25
Yajaira Garcia Prescott, US 2020-08-25
Ella Rosenthal Port Washington, US 2020-08-25
Brooke Sorensen Redmond, US 2020-08-25 christa chan Seattle, US 2020-08-25 nikki whitehead dallas, US 2020-08-25
Nakara Johnson Montclair, US 2020-08-25 mireya flores Harlingen, US 2020-08-25
Lily Huerta Portland, US 2020-08-25
Anarely Santana Houston, US 2020-08-25 Name Location Date
Blake Cohen Washington, US 2020-08-25
Shiloh Jones Troy, NY 2020-08-25
Eduardo Barbero Redding, US 2020-08-25
Mike Flores Escondido, US 2020-08-25
Fatima N Phoenix, US 2020-08-25
Ellis Coleman Waxhaw, US 2020-08-25
Jaylen Chua Covina, US 2020-08-25
Iroshi Perera Reading, US 2020-08-25 denise asadorian Troy, NY 2020-08-25
Kate Lovering US 2020-08-25 andria Munroe Baerga Troy, NY 2020-08-25
Shannon S East Greenbush, NY 2020-08-25
Richard Freiberg Philadelphia, PA 2020-08-25
Jennifer Cardinal Troy, NY 2020-08-25
Rebekah Hogan Harrison, NJ 2020-08-25
Kelly Fellenzer Troy, NY 2020-08-25
Judy Anderson Kinderhook, NY 2020-08-25
Summer Myers Troy, NY 2020-08-25
Alyssa Rodriguez Wynantskill, NY 2020-08-25
Jessilyn Hartman Troy, NY 2020-08-25
Tara Simmons Troy, NY 2020-08-25
Austen Zeh Rensselaerville, NY 2020-08-25 Name Location Date
Patrick McLaughlin Troy, NY 2020-08-25
Paul D'Arcy New York, NY 2020-08-25
Justin Rogers Schenectady, NY 2020-08-25
Joan Gingeresky Troy, NY 2020-08-25
Mark Sarnacki Troy, NY 2020-08-25
Lynn Conway Troy, US 2020-08-25
Elizabeth Heller Troy, NY 2020-08-25
Sarah Thompson Stephentown, NY 2020-08-25
Jennifer Schulaner Troy, NY 2020-08-25
Stacey Civello Portland, OR 2020-08-25
Matheus Arnellas Santa Clara, CA 2020-08-25 kathy spillane Troy, NY 2020-08-25
Leonora Maroli Troy, NY 2020-08-25
Michele Valenti Troy, NY 2020-08-25
Kiersten McDermott Troy, NY 2020-08-25
Lila Denning San Diego, CA 2020-08-25
Kainat Faizi Albany, NY 2020-08-25
Aarom Morris Round Lake, NY 2020-08-26
Allison Fleck Waltham, MA 2020-08-26
Elizabeth Barker Troy, NY 2020-08-26
Dylan miller Troy, NY 2020-08-26
Rachel B irvington, NY 2020-08-26 Name Location Date
Christy Mercer Troy, NY 2020-08-26
SUZANNE BUTLER Troy, NY 2020-08-26
Jillian Naveh Troy, NY 2020-08-26
Adam Heggen Schenectady, NY 2020-08-26
Zan S Troy, NY 2020-08-26
Matthew Plummer Troy, NY 2020-08-26 margaret Davey Troy, NY 2020-08-26
Tracy Kennedy Troy, NY 2020-08-26
Geoffrey Raymond Troy, NY 2020-08-26
Laudelina martinez troy, NY 2020-08-26
Mark Shipley Troy, NY 2020-08-26
Danielle Sanzone Troy, NY 2020-08-26
Michele DeLair Troy, NY 2020-08-26
Jim Deseve Ny, NY 2020-08-26
Kimberly Connors Troy, NY 2020-08-26
Brendan Kennedy Troy, NY 2020-08-26
Kevin Lovelady Troy, NY 2020-08-26
Sara Emmert Troy, NY 2020-08-26
James Van Duyne Albany, NY 2020-08-26
Theresa Hovish Albany, NY 2020-08-26
Terri Metchick Troy, NY 2020-08-26
Christine Dowd Cohoes, NY 2020-08-26 Name Location Date
Michael Burgess Petersburg, NY 2020-08-26
D Rossbach Troy, NY 2020-08-26
Stephen Smith Troy, NY 2020-08-26
Katherine Snively Schenectady, NY 2020-08-26
Patty Stanford Delmar, NY 2020-08-26
Kathryn Adams Troy, NY 2020-08-26
Julie Summersquash Providence, RI 2020-08-27
Mary Otero Liverpool, NY 2020-08-27
T.J. Kennedy Troy, NY 2020-08-27
Raymond Essiembre Troy, NY 2020-08-27
Sambit Ghosh Troy, NY 2020-08-27
David Villagomez Troy, NY 2020-08-27
Haley Williams Troy, NY 2020-08-27
Maya Navabi Tucson, AZ 2020-08-27
Audrey Palma Troy, NY 2020-08-27
Richard Hichman Saratoga Springs, NY 2020-08-27
Kathryn Sheehan Troy, NY 2020-08-27
Trinity Paradis Troy, NY 2020-08-27
Crystal Buckley Cohoes, NY 2020-08-27
Steve Anderson Troy, NY 2020-08-27
Tim MacSweeney Woodbury, CT 2020-08-27
Marion Ross Troy, NY 2020-08-27 Name Location Date
Marina Capp Troy, NY 2020-08-27
Guy Schaffer Troy, NY 2020-08-27
Phoenix Oaks Portland, OR 2020-08-27
Annette Strope Troy, NY 2020-08-27
Michelle Ausman Cohoes, NY 2020-08-27
Carol Hyldelund Troy, NY 2020-08-27
Kierstan Ryan Troy, NY 2020-08-27
Grayce Brown Troy, NY 2020-08-27
Charlotte Bosworth Pembroke, MA 2020-08-27
Peg Aloi Albany, NY 2020-08-27
Bradley Matheus Troy, NY 2020-08-27
William Brown Troy, NY 2020-08-27
Wyatt Brown Troy, NY 2020-08-27
Gregory Baxter Stratford, CT 2020-08-27
Andy StGermain Troy, NY 2020-08-27
Sally St.Germain Troy, NY 2020-08-27
Makayla Wahaus Troy, NY 2020-08-28
Elizabeth press Troy, NY 2020-08-28
Mary Kahl Delmar, NY 2020-08-28
Pam Kniskern Johnsonville, NY 2020-08-28
Sheila Poole Albany, US 2020-08-28
Kathy Colman Cohoes, NY 2020-08-28 Name Location Date
Mark Oliver Rensselaer, NY 2020-08-28
Nolin Borrero Rensselaer, NY 2020-08-28
Donna Hays Saratoga Springs, NY 2020-08-28
Shane Senecal Kissimmee, FL 2020-08-28
Drew Demers Troy, NY 2020-08-28
Surya Padinjarekutt Troy, NY 2020-08-28
Indroneil Roy Troy, NY 2020-08-28
Vicki Griffin Gloversville, NY 2020-08-28
Sharon Bruce Troy, NY 2020-08-28
Lisa Covey Craryville, NY 2020-08-28
Margaret Callahan Cohoes, NY 2020-08-29
Michael Oatman Troy, NY 2020-08-29
Michael Lawes Chesapeake, VA 2020-08-29
Miahrose Ross new york, NY 2020-08-29
Brooke Degener Albany, NY 2020-08-29
Cathryn Dwyre Hudson, US 2020-08-29
Tara Ingersoll Albany, NY 2020-08-29
Anna Taranenko San Francisco, CA 2020-08-29
I S Troy, NY 2020-08-29
Lindsey miller Santa Cruz, CA 2020-08-29 yolonda landry troy, NY 2020-08-29
Jennifer Lepper US 2020-08-29 Name Location Date
Joseph Fell Buffalo, NY 2020-08-29 dante digiulio Buffalo, NY 2020-08-29
Jennifer Bartels Troy, NY 2020-08-29
Robert Hilts Troy, NY 2020-08-29 dorothy collins buffalo, NY 2020-08-29
Galaya Wong Pittsburg, US 2020-08-29
Lily Watne Orlando, US 2020-08-29
John Kramer Marshfield, US 2020-08-29
Abbygail Adriano Germantown, US 2020-08-29
Emily Frank East Hampton, US 2020-08-29
Jessica Stillman Upper Lake, US 2020-08-29
Matthew Harding Concord, US 2020-08-29
Angelina Alvarado Austin, US 2020-08-29 danna renteria Santa Teresa, US 2020-08-29
Emue G Cambridge, US 2020-08-29
Mariah Marquez Menifee, US 2020-08-29 chris farmer califofnia, US 2020-08-29
Guido Gabriel Troy, NY 2020-08-29
LILA STROMBERG TUXEDO, NY 2020-08-30 alyssa johnson Vacaville, CA 2020-08-30
Shannon Curran-Trzepacz Troy, NY 2020-08-30
Denise Losoya Las Vegas, NV 2020-08-30 Name Location Date
Randy Herrington Troy, NY 2020-08-30
Nicole Collen Troy, NY 2020-08-30
Lewis Snearly Albany, NY 2020-08-30
Carla Leitao Florida, NY 2020-08-30 olivia krewer Bronx, NY 2020-08-30
Cynthia Slavens Alameda, CA 2020-08-30
Mara Dicenta Buenos Aires, Argentina 2020-08-30
Christy Thomas Williamstown, MA 2020-08-31
Jillian Crandall Rensselaer, NY 2020-08-31
Pearl Higgins Troy, NY 2020-08-31
Margaret Corrigan Troy, NY 2020-09-01
Elaine Broiles Troy, NY 2020-09-01
Jacob Broadhead Troy, NY 2020-09-02
Karen Molinares Troy, NY 2020-09-02
Tammie Broadhead Troy, NY 2020-09-02
Victoria Ramos Troy, NY 2020-09-02
Marissa Peck Troy, NY 2020-09-02
Robin Donato Cortland, NY 2020-09-02
Katrina Belcher Troy, NY 2020-09-02
Aidan Bardos Washington, US 2020-09-02
Gary Nelson Hudson, NY 2020-09-03
Dale Nelson Hudson, NY 2020-09-03 Name Location Date
Sandra Hutchison Troy, NY 2020-09-03
Gail Terp Queensbury, NY 2020-09-03
INGRID Madelayne Troy, NY 2020-09-03
Rebecca Hein Albany, NY 2020-09-03
Shari Gibbs Wynantskill, NY 2020-09-03
Dan Phiffer Troy, NY 2020-09-03
Kevin Carpenter US 2020-09-03
Darlene Simpson Troy, NY 2020-09-03
Jac Cohn Troy, NY 2020-09-04
Angie morley Troy, NY 2020-09-04
Christopher Eastman Troy, NY 2020-09-04
Patricia Burke Troy, NY 2020-09-04
Zachary Metzger Brunswick, NY 2020-09-04
Beth Finkle Troy, NY 2020-09-05 geri de seve troy, NY 2020-09-05
Frank Visco Troy, NY 2020-09-05
Albert Marble Knoxville, TN 2020-09-05 michael esposito Troy, NY 2020-09-05
Spencer Schmitt Redondo Beach, US 2020-09-06
Victoria Ramirez El Paso, US 2020-09-06 lilli ramos US 2020-09-06
Elizabeth Green Enfield, US 2020-09-06 Name Location Date
Sarah Grahamer Frankfort, US 2020-09-06 emili-jade luna Norwich, US 2020-09-06
Amiyah Barber Harrisburg, US 2020-09-06 sandra olivos Jackson Heights, US 2020-09-06
Shauntea Black Lewistown, US 2020-09-06
Kyla Rhyann Brooklyn, US 2020-09-06
Giselle Ibarra Las Vegas, US 2020-09-06 kelly weldon suleski Springfield, US 2020-09-06
Christine Bernard Schenectady, US 2020-09-06 antonelle russell Atlanta, US 2020-09-06
Imtiaz Ahmed Ozone Park, US 2020-09-06
Rafal Wisniewski Brooklyn, US 2020-09-06 joanna morris Washington, US 2020-09-06
Mik I Little Neck, US 2020-09-06
Alicia Swanson West Fargo, US 2020-09-06
Fatima Aldava Pharr, US 2020-09-06
Tiara Howard East Lyme, US 2020-09-06
Sarah Vallejo Pinehurst, US 2020-09-06
Stefan Krueger Troy, NY 2020-09-06
Britney Gil Troy, NY 2020-09-06
Daniel Marble Mohawk, NY 2020-09-06
Kayla marble Troy, NY 2020-09-06 Name Location Date
Frank Porter Troy, NY 2020-09-06
Dennis McDermott Troy, NY 2020-09-06 rosella riddell Troy, NY 2020-09-06
Holly DeVoe Saratoga Springs, NY 2020-09-06
Sonya Farrell Troy, NY 2020-09-06
Daniel Morrissey Albany, NY 2020-09-06
Amanda Groves Lansingburgh, NY 2020-09-07
Adam Tinkle Saratoga Springs, NY 2020-09-07
Jennifer Smith Templeton, U.S. Outlying Islands 2020-09-07
Jesse Hancock Troy, NY 2020-09-07
Mary Pezdek Melrose, NY 2020-09-07
Victoria Lee Chicago, IL 2020-09-07
Jack O’Brien Mount Pleasant, MI 2020-09-07
Hunter Schuur Dowagiac, MI 2020-09-07 kerri munn troy, NY 2020-09-08
Rafael Varela Troy, NY 2020-09-08
David Klak Mount Pleasant, MI 2020-09-08 sierra dattilo Mount Pleasant, MI 2020-09-08
Michel Foucault Denver, CO 2020-09-08
Annelise Ellars Hartford, US 2020-09-08
Sonja Baiin Pittsburgh, PA 2020-09-08
Jennifer Reid Troy, NY 2020-09-08 Name Location Date
Ellie Irons Brooklyn, NY 2020-09-08
Mallory Hallstead Albany, NY 2020-09-08
Joyce Domingo Kitchener, Canada 2020-09-08
Rachel Hegeman Syracuse, NY 2020-09-08
Kiara Rivera Chicago, IL 2020-09-08
Tracy Frisch Greenwich, NY 2020-09-08
CHRISTOPHER SCULLY Troy, NY 2020-09-09
Kathryn Beisner Reston, VA 2020-09-09
Siegfried Isidro-Cloudas Troy, NY 2020-09-09
Anthony Olivares Troy, NY 2020-09-09
Andrea Williams Troy, NY 2020-09-09
Jennifer Baumstein Troy, NY 2020-09-09
Sean Mickey Dobbin Troy, NY 2020-09-09
Kimberley Preiksaitis Troy, NY 2020-09-09
Laura Hynes Troy, NY 2020-09-09
Nathalie Gibeau Troy, NY 2020-09-10
Laura Cullen Troy, NY 2020-09-10
John Raup Troy, NY 2020-09-10
Alex Simon Haverstraw, NY 2020-09-10
Leo Harben Ithaca, US 2020-09-10 piper bernstein New York, US 2020-09-10
Stephanie Zhang New York, US 2020-09-10 Name Location Date
Christopher Stimson Akron, US 2020-09-10
Emily Petrovic Miami, US 2020-09-10
Janet Chow Brooklyn, US 2020-09-10
Jesse Brown Stoughton, US 2020-09-10
Lucas Arias Long Beach, US 2020-09-10
Olivia Adkison Queens, US 2020-09-10
Kristine Heaton Skokie, US 2020-09-10
Slayton Thompson Eufaula, US 2020-09-10
Titus Jefferson Olive Branch, US 2020-09-10
Anaiza Cortez Foothill Ranch, US 2020-09-10
Edgar Hernandez Chicago, US 2020-09-10
Marilyn Spencer Tunkhannock, US 2020-09-10
Nexon Greenwood Village, US 2020-09-10 (JamesBartholomewthe3rd) Chau
Lauren Tait Roosevelt, US 2020-09-10
Matsui Yoko ohio, US 2020-09-10
Johanna Shinn Omaha, US 2020-09-10
Ray Gamble Knoxville, US 2020-09-10
Summer Ward US 2020-09-10
Debby Willette Greencastle, US 2020-09-10
Lance Kammerud US 2020-09-10
Dana Drozynski New York, US 2020-09-10 Name Location Date
Helen Parker Gaithersburg, US 2020-09-10
Crystal Sanderson Saint Louis, US 2020-09-10
Osmara Castaneda Fontana, US 2020-09-10
Angel Arias Long Beach, US 2020-09-10
Erin Sipos Cleveland, US 2020-09-10
Jordan Stiltoner Virginia Beach, US 2020-09-10
Andrew Murtha Guilford, US 2020-09-10
Bailyn Johnson Elgin, US 2020-09-10
Kayla Jackson Fayetteville, US 2020-09-10
Zachary Hayes Troy, NY 2020-09-10
Aileen Javier Halfmoon, NY 2020-09-10
Molly McCormick St. Petersburg, FL 2020-09-10
Richard Sleeper Troy, NY 2020-09-10
Mariam Samara Tinley Park, US 2020-09-10
Brittney Spaulding Shepherdsville, US 2020-09-10
Elizabeth E Lake City, US 2020-09-10
JJ Keitz Long Beach, US 2020-09-10
Jat Jimenez Miami, US 2020-09-10
Mia Galloway Pompano Beach, US 2020-09-10
Matthew Davis Seattle, US 2020-09-10 adriana betsuie Albuquerque, US 2020-09-10 ankitha chintala Jacksonville, US 2020-09-10 Name Location Date
Natalie :) San Antonio, US 2020-09-10
Kiara Pena Bronx, US 2020-09-10
Tillie Cohen Denver, US 2020-09-10
Samuel Kunowski Garden Grove, US 2020-09-10
Timothy Paich Loveladies, US 2020-09-10
Ashley Wefel Oak Park, US 2020-09-10
Cate Wise Beverly Hills, US 2020-09-10 ximena garcia US 2020-09-10
Peyton McCoy Dexter, US 2020-09-10
Aly Comer Tulsa, US 2020-09-10
Alyssa Barrios Whittier, US 2020-09-10
Amy Ochoa Charlotte, US 2020-09-10
Madison Delaney Price, US 2020-09-10
Tarah Holcombe Royston, US 2020-09-10
Jeshua Oviedo New York, US 2020-09-10
Jeremy Gomez Long Beach, US 2020-09-10
Geanie Barfield US 2020-09-10
Angel D Miller Place, US 2020-09-10
Kevin 0 Murrieta, US 2020-09-10 ethan t Pasadena, US 2020-09-10
Ernesto Castro Riverside, US 2020-09-10
Kamryn Kamryn US 2020-09-10 Name Location Date
Nathaly Bermejo Minneapolis, US 2020-09-10
Madison Inzunza Lorton, US 2020-09-10
Lauren Lima New Bedford, US 2020-09-10
Laa Laa Ocean City, US 2020-09-10
Skylah Marra Howell, US 2020-09-10
Marika Bjornsen Marion, US 2020-09-10
Abby Lusk Chattanooga, US 2020-09-10
Evelyn Buenrostro Irving, US 2020-09-10
Cole Purnell Ruskin, US 2020-09-10 aiden miller Lansdale, US 2020-09-10
Carla Yofzitdztud Bronx, US 2020-09-10
Christian Ayon Porterville, US 2020-09-10
Nicholas Petrovich New York, US 2020-09-10
Erik Ramos Columbia, US 2020-09-10
Tanya Veronica Phoenix, US 2020-09-10
Zoey Decker Carlisle, US 2020-09-10
Adriann Monahan-DaSilva Malden, US 2020-09-10
Holly Rankin West Des Moines, US 2020-09-10
Ricardo Carbajal Segura San Francisco, US 2020-09-10
Alex Barazotti Howell, US 2020-09-10
Gabriel Whitworth Phoenix, US 2020-09-10 reymond jimenez Bronx, US 2020-09-10 Name Location Date
Abby Anson Harrisburg, US 2020-09-10 oliver perez Anaheim, US 2020-09-10
Madison Smith Belleville, US 2020-09-10 natalia rodriguez St. Paul, US 2020-09-10
Emily Van Ness Lowell, US 2020-09-10
Ethan McGinty Houston, US 2020-09-10
Tagan Ortega Topeka, US 2020-09-10 tanner gorsuch Pittsburgh, US 2020-09-10
Chrissy Dav Rolling Meadows, US 2020-09-10
Ali F Chicago, US 2020-09-10
Luisa Isayev US 2020-09-10
Addison Gibson Greencastle, US 2020-09-10
Alicia Keaveney lincroft, US 2020-09-10 melissa truberg commack, US 2020-09-10
Hayley cloud Nixa, US 2020-09-10
Kathy Filkins Clifton Park, US 2020-09-10
Penny Oslin Celeste, US 2020-09-10
Noralee Santana Bronx, US 2020-09-10
Kimberly Luna Moreno Valley, US 2020-09-10
Madison Collins Erie, US 2020-09-10
J Stanley Morgan Hill, US 2020-09-10
Haibert Barfian Glendale, US 2020-09-10 Name Location Date
Sarah Herc Clarkston, US 2020-09-10 cheyenne tingen Richmond, US 2020-09-10
Ann Z Shirley, US 2020-09-10
Cassy King Lake Forest, US 2020-09-10
Amanda Richardson Hibbing, US 2020-09-10
D’Vante Yoshikawa Rohnert Park, US 2020-09-10
Kyla Booker Los Angeles, US 2020-09-10
Stefhan Luctamar Miami Gardens, US 2020-09-10
Dave Saint simon Costa Mesa, US 2020-09-10
Nick Champagne Atlanta, US 2020-09-10
Anindita Halder Valleystream, US 2020-09-10
Adriane Marcelle Miami, US 2020-09-10
Kathryn Tuttle New York 2020-09-10
Nestor Nieto Arlington, TX 2020-09-10
Nicolette Boyd Palm Harbor, US 2020-09-10
Simon Reynolds Pensacola, US 2020-09-10
Olivia Marquiis Boston, US 2020-09-10
Carlos Hernandez Santa Ana, US 2020-09-10
Geroge Ogle Atlanta, US 2020-09-10
Kike Velasco Foothill Ranch, US 2020-09-10
Noddy Maldinero Jersey City, US 2020-09-10
Sahana Prakash Concord, US 2020-09-10 Name Location Date
Kristiana Corona Chandler, US 2020-09-10
Elliot Velasquez Hollywood, US 2020-09-10
Adriel Casas Davenport, US 2020-09-10
Eva Chen Racine, US 2020-09-10
Dana Carbajal Long Beach, US 2020-09-10
Lisa Allarde Green Lane, US 2020-09-10
Linh Leonard Reno, US 2020-09-10
Jaedyn Gerhardt Fort Worth, US 2020-09-10
Meaghan Lockwood US 2020-09-10
Shannon Neville Mount Vernon, US 2020-09-10 donna kennedy flanders, US 2020-09-10 jennifer valentine Massapequa, US 2020-09-10
Samuel nashed Fontana, US 2020-09-10
Tatyana Mayberry Dyersburg, US 2020-09-10
Baba Booey Sparta, US 2020-09-10
Panchali Dipankar Bellevue, US 2020-09-10
Keven Gamez Burbank, US 2020-09-10
James lupu Hazleton, US 2020-09-10
Juliana Bianchi Harrisburg, US 2020-09-10
Julie Mceldowney Cayce, SC 2020-09-10
Anissa perez Portland, US 2020-09-10
Khuzaima Ahmed Falls Church, US 2020-09-10 Name Location Date
Chris V Oceanside, US 2020-09-10
Chloe Andrea Javier Long Beach, US 2020-09-10
Maddie Ulmer Alexandria, US 2020-09-10
None of your Business Jellyana Bronx, US 2020-09-10
Diana Toader Greenville, US 2020-09-10
Guillermo Ramirez Seattle, US 2020-09-10
Rachel Frascella Albany, NY 2020-09-10
Christian Archuletta Groton, US 2020-09-10
Margaret Alarcon Los Angeles, US 2020-09-10
Jayden Mann Charlotte, US 2020-09-10
Owen Dominguez Silver Spring, US 2020-09-10 suri ortega Miami, US 2020-09-10
Hannia Colon Paterson, US 2020-09-10 shemica johnson Worcester, US 2020-09-10
Dominica Singleton Las Vegas, US 2020-09-10
Dennis Strainge Saratoga Springs, NY 2020-09-10
Katherine Mules New York 2020-09-10
Denise Meyers Clifton Park, NY 2020-09-10
Robert Pezdek Troy, NY 2020-09-10
Danielle Charlestin Troy, NY 2020-09-10
Cliff Kalinowski New York, NY 2020-09-10
James Davey Troy, NY 2020-09-10 Name Location Date
Anderson B Charlotte, US 2020-09-10
Bianey Cuevas Anaheim, US 2020-09-10 samantha chavez Elmhurst, US 2020-09-10
Keverlynn Knight Seffner, US 2020-09-10
Shivani B Framingham, US 2020-09-10
.F. W. Knoxville, US 2020-09-10
Emma Stelly Round Rock, US 2020-09-10
Bryan Haedy New York, NY 2020-09-10
Sashs Dubodel Troy, NY 2020-09-10
Jan O'Malley Troy, NY 2020-09-10
Rachel Ruller Troy, NY 2020-09-11
Mike Preiksaitis Troy, NY 2020-09-11
Audrey Vallee Troy, NY 2020-09-11
Dara Silbermann Troy, NY 2020-09-11
Colleen Phoenix Troy, NY 2020-09-11
Michael Roll Troy, NY 2020-09-11
Katharine Corp Troy, NY 2020-09-11
Kelly Artis Albany, NY 2020-09-11
Fran ODonnell Troy, NY 2020-09-11
Mary Patterson Watervliet, NY 2020-09-11
Natalie Bowen Guilderland, NY 2020-09-12
Kathy Puffer Tillson, NY 2020-09-12 Name Location Date
JoAnne Ruddy Wynantskill, NY 2020-09-12
Wanda Johnson Troy, NY 2020-09-12
Cara Helfer Charlotte, NC 2020-09-12
Wendi s Ballston Spa, NY 2020-09-12
Michael Hart Troy, NY 2020-09-12
Desiree DiCristoforo Fort Lee, NJ 2020-09-12
Gwen Sislowski Troy, NY 2020-09-12
Don Sislowski Troy, NY 2020-09-12
Evan Couture Troy, NY 2020-09-12
Anna Moodgill Gloversville, NY 2020-09-13
Elanor zierhut Aliso Viejo, CA 2020-09-13
Jade Rodriguez Bronx, NY 2020-09-14
Amanda DeWald Delhi, NY 2020-09-21
Jeremy Barnes Valley Falls, NY 2020-09-21
Joshua Eason Troy, NY 2020-09-21
Miriam Cantor-Stone Troy, NY 2020-09-21
Francis Magai Troy, NY 2020-09-23
Armond Gray Troy, NY 2020-09-23
Margaret Pearce Sanford, ME 2020-09-30
Zach Schwartz-Weinstein Albany, NY 2020-10-02
C. Wesley Dingman Queensbury, NY 2020-10-09
Yoehan Oh Troy, NY 2020-10-13 Name Location Date
Ava Diener Muskego, US 2020-10-13
Ruzanna Babayan Flushing, US 2020-10-13
Victoria Emmitt Ontario, US 2020-10-13
Aracylis Rampersad South Ozone Park, US 2020-10-13
Triton McDonald Virginia Beach, VA 2020-10-13
Robert Rossi New York, NY 2020-10-14
Thomas Connor Fayetteville, NY 2020-10-19 erin altadonna hayward, US 2020-10-20
Naomi Hood Temecula, US 2020-10-20
Khambia Clarkson Marshalltown, US 2020-10-20
Rieana Ferreira Orlando, US 2020-10-21
Joseph A Papale Jr Troy, NY 2020-10-21
Faiyaj Khan Albany, NY 2020-10-30
Maggie McAuliffe Brockport, US 2020-10-30
Jamel Mosely Troy, NY 2020-11-02
James Barker Troy, NY 2020-11-02
Hannah Carr Troy, NY 2020-11-02
Scott Womer Troy, NY 2020-11-02
Hana van der Kolk Troy, NY 2020-11-02
Jared Williams Jamaica Plain, MA 2020-11-02
Julia Gladstone Waban, MA 2020-11-02
Liz N Brooklyn, NY 2020-11-02 Name Location Date
Shaina Cantino Athens, OH 2020-11-02
Joshua Potter Troy, NY 2020-11-02
Katie Centanni Troy, NY 2020-11-02
Kiara Marra Troy, NY 2020-11-02
Carolyn Bardos Troy, NY 2020-11-02
Mari Brennan Saratoga Springs, NY 2020-11-02 yasmine perez Ballston Spa, NY 2020-11-02
Jimmy Taylor Albany, NY 2020-11-02
Alex Elliott Albany, NY 2020-11-02
Mary Helen Collen Defreestville, NY 2020-11-02
Olivia Dunn Albany, NY 2020-11-02
Elizabeth FIGLIOMENI Troy, NY 2020-11-02
Brooke Murray Hudson, NY 2020-11-02
Daniel Coxson Olney, US 2020-11-02 julia champagne Troy, NY 2020-11-02
Brooke Bernstein Saint Louis, US 2020-11-02
Sachi Cappo East Chatham, US 2020-11-02
Avery Childreds Statesville, US 2020-11-02
Richard McConnell Crown Point, US 2020-11-02
Jordan Salas Paterson, US 2020-11-02
Tori Rodriguez Troy, NY 2020-11-02
Tiffany Marr Stafford, US 2020-11-02 Name Location Date
Nessie Cuevas Paramus, US 2020-11-02
Aniece Middleton Sumter, US 2020-11-02
Ryan Jay Bronx, US 2020-11-02 m h austin, US 2020-11-02 charlene parker Kingstree, US 2020-11-02
Avin Helseth denver, US 2020-11-02
Megan Hackett West Orange, US 2020-11-02
Karen Debiase Chester, VA 2020-11-02
Courtney Shepherd Mount Juliet, US 2020-11-02 elena nehring gahanna, US 2020-11-02
Kiwi Yuugi Winter Haven, US 2020-11-02
Ava Seilhamer Boonsboro, US 2020-11-02
Candice Brockman Stone Mountain, US 2020-11-02
Stephanie Rodas Jersey City, US 2020-11-02
Elaine Mitchell Vadito, US 2020-11-02
Steve jobs real Parkersburg, US 2020-11-02
Samuel Goodwin Chapel Hill, US 2020-11-02
Michael Davis Utica, US 2020-11-02
Jordan Smotzer Cincinnati, US 2020-11-02
McFadden McFadden Beaver Falls, US 2020-11-02
Trinity Rosas Connersville, US 2020-11-02
Darlene Reese Batavia, US 2020-11-02 Name Location Date theyeetgod 12 q Peoria, US 2020-11-02
Swag Phia Lake Worth, US 2020-11-02 sherri thompson Little Rock, US 2020-11-02
Aliyah garcia Galveston, US 2020-11-02
Esbeydi Diaz Martinez Saint Paul, US 2020-11-02
Claudia Clerveaux Mattapan, US 2020-11-02
Jessica Mendoza Troy, NY 2020-11-02
Christina Wu Atlantic City, US 2020-11-02
Sean McCaughtry Montgomery, US 2020-11-02
Alisa Goldsman Pomona, US 2020-11-02
Ehva Corbin Lincoln, US 2020-11-02 coffee pro Los Angeles, US 2020-11-02
T Tuck Covington, US 2020-11-02
Tomas Ramirez San Antonio, US 2020-11-02
Katie Alsback Lebanon, US 2020-11-02 grace mulhall Brooklyn, US 2020-11-02
Rebecca Romano West Hartford, US 2020-11-02
Kendra Gernaey Orlando, US 2020-11-02 iyanna whipple Blacklick, US 2020-11-02 paige paige Los Angeles, US 2020-11-02
Jdjdjjdd Ndndndndjs Bronx, US 2020-11-02
Stephanie Collins Albany, NY 2020-11-02 Name Location Date
Judith Romero Anaheim, US 2020-11-02
Mercedes Roussos US 2020-11-02
Selena Hughes Bristol, US 2020-11-02
Myriam Stern Saint Louis, US 2020-11-02
Lauren Harte Lebanon, US 2020-11-02
Sydney Quick Rock Hill, SC 2020-11-02
Stan Piper Jacksonville Beach, US 2020-11-02
Brian Anderson Denver, US 2020-11-02
William Shotwell Smithville, US 2020-11-02
Carol Collins Dover, US 2020-11-02 madison scrivner Maryville, US 2020-11-02
Brianna M Ann Arbor, US 2020-11-02
Rachel Waldrip Tucson, US 2020-11-02
Marielle Quibilan Bergenfield, US 2020-11-02
Delynn Parker Sf, US 2020-11-02
Autumn Carron Wichita, US 2020-11-02
Connie Richters Singapore, US 2020-11-02 michelle b Kansas City, US 2020-11-02
Mia is Ibitoye Chicago, US 2020-11-02
Melissa Masters Newfane, VT 2020-11-02
Ashley Dorris Chicago, US 2020-11-02 nathaniel felix cardenas Phoenix, US 2020-11-02 Name Location Date
Christian Joyce Reidsville, US 2020-11-02
Katie Bunch Dallas, US 2020-11-02
Destiny Campos Hoboken, US 2020-11-02
Deidra Rivera Worcester, US 2020-11-02
Aliyah Arellano Laredo, US 2020-11-02 emily miras Detroit, US 2020-11-02 karlie kyelberg Wilmington, US 2020-11-02
Ingrid Benitez Burke, US 2020-11-02
Sofia Rhodes Cary, US 2020-11-02
Patricia AFERHOLT-EDDINGS Nashville, TN 2020-11-02
Mary Cox Virginia Beach, US 2020-11-02
Greta Bonvini Oregon House, US 2020-11-02
Timothy Stirling Manheim, US 2020-11-02
Darien Verdun Houma, US 2020-11-02
Emma Baumgartner Antigo, US 2020-11-02
Anna Marie Winder Philadelphia, US 2020-11-02
Morgaen Hansen Albany, NY 2020-11-02
Elizabeth Liranzo Larchmont, US 2020-11-02
Andrea Kehoe Putney, VT 2020-11-02
Jemma Kaczanowicz ballston spa, NY 2020-11-02
Ann Giguere Green Island, NY 2020-11-02
Christina Toppin Clifton Park, NY 2020-11-02 Name Location Date
Grace Boyan Long Island City, NY 2020-11-02
Sean Boyan Arlington, VA 2020-11-02
John Pjontek Albany, NY 2020-11-02
Andrew Sullivan Albany, NY 2020-11-02
Kaitlyn Mazza Newburgh, NY 2020-11-02
Heather Maranville Rensselaer, NY 2020-11-02
Megan Prokorym Albany, NY 2020-11-02
Paige Allen Albany, NY 2020-11-02
Stephen Rosia Ballston Spa, NY 2020-11-02
Allison Giguere Cohoes, NY 2020-11-02
Rachel Baxter Albany, NY 2020-11-02
Pamela Boyan Allentown, PA 2020-11-02
Hannah Boyan South Orange, NJ 2020-11-02
Kaitlin Resler Albany, NY 2020-11-02
Kelly Bromm Albany, NY 2020-11-02 michelle noonan Averill Park, NY 2020-11-02
Amanda Irle Trenton, NJ 2020-11-02
Dorothy Davila Rensselaer, NY 2020-11-02
Stephanie June Troy, NY 2020-11-02
Jacklynn Blanchard Littleton, CO 2020-11-02
Kerrie Vincent Albany, NY 2020-11-02
Amelia Allen Troy, NY 2020-11-02 Name Location Date
Allison Greene Delmar, NY 2020-11-02
Eden Loeffel Detroit, MI 2020-11-02
Luke Bateman Troy, NY 2020-11-02
Samira Iravani Astoria, NY 2020-11-02
Samantha Dobin Watervliet, NY 2020-11-02
Rebekah Desjardins Troy, NY 2020-11-02
Catherine McTague Troy, NY 2020-11-02 allison watson troy, NY 2020-11-02
Emilee Brunette Troy, NY 2020-11-02
Laura Harrison Saratoga Springs, NY 2020-11-02
Oliver HOLECEK Troy, NY 2020-11-02 leepa poulose Congers, NY 2020-11-02
Sarah Haze Chatham, NY 2020-11-02
Lila Flanagan Troy, NY 2020-11-02
Emily Cain Sarasota, FL 2020-11-02
Stephanie Leahy Centreville, VA 2020-11-02
Jayna Patel New Braunfels, TX 2020-11-02
Alex Divanyan Buffalo Grove, IL 2020-11-02
John Bowden Sandy, UT 2020-11-02
Marla Anson Woodbridge, VA 2020-11-02
Katie Walker Los Angeles, CA 2020-11-02
Brian Davenport Schenectady, NY 2020-11-02 Name Location Date
Aisling Sive Troy, NY 2020-11-02
Kristen Kiley East Lansing, MI 2020-11-02
Janna Rudler Endicott, NY 2020-11-02
Ethan Carmody Troy, NY 2020-11-02
Laura Hynes Wynantskill, NY 2020-11-02
Lydia Kelley Troy, NY 2020-11-02
Behnaz Haddadi Washington, DC 2020-11-02
Maria Vincent Troy, NY 2020-11-02
Emily Brooks Troy, NY 2020-11-02
Silv Dant Rockville Centre, NY 2020-11-02
Erin O’Keefe Slingerlands, NY 2020-11-02
Kathryn Secor Castleton On Hudson, US 2020-11-02
Lea Rutherford Latham, NY 2020-11-03
William Wesner Glens Falls, NY 2020-11-03
Steven Johnson Delmar, NY 2020-11-03
Erin Meaney Valley Stream, NY 2020-11-03
Sarah Goldman Nyack, NY 2020-11-03
Amelia Stickelmyer Troy, NY 2020-11-03
Ashley Christiano Brooklyn, NY 2020-11-03
Ingrid Staats Toronto, Ontario, Canada 2020-11-03
Bridget Gettys Selkirk, NY 2020-11-03
Tina Rodriguez Schenectady, NY 2020-11-03 Name Location Date niko šveikauskas Woodstock, NY 2020-11-03
Mercy Weiss Brooklyn, NY 2020-11-03
Kendall Gardner Albany, NY 2020-11-03
Buzz Slutzky Brooklyn, NY 2020-11-03
Molly McCumber Troy, NY 2020-11-03
Emily Manning-Mingle Brighton, MA 2020-11-03
Kyra Siegel Nelson, New Zealand 2020-11-03
Stephanie cavoli Schenectady, NY 2020-11-03
Henry Cooley Troy, NY 2020-11-03
Robyn Eames Oneonta, NY 2020-11-03
Sophie Gell Brooklyn, NY 2020-11-03
Caroline Wexler Hartsdale, NY 2020-11-03 erica sparrow Averill Park, NY 2020-11-03
Hannah Musial Rosendale, NY 2020-11-03
Caroline Boyan Troy, NY 2020-11-04
Olivia Quillio Troy, NY 2020-11-04
Kelsey Sloane Troy, NY 2020-11-06
Ben Gorman Troy, NY 2020-11-06
Melanie LaBarge Waterford, NY 2020-11-07
Angela Bartlett Melrose, NY 2020-11-07
Zhenelle Fish Rensselaer, NY 2020-11-07 nora Gallardo Chicago, US 2020-11-07 Name Location Date
Kavinda De Alwis Plano, US 2020-11-07
Christina Bishop Waterford Township, US 2020-11-07
Serafina Coombe US 2020-11-07 willy nonable Plainfield, US 2020-11-07
Chloe Ruiz Oklahoma city, US 2020-11-07
Julia Cadieux Troy, NY 2020-11-07
Stephanie Loveless albany, NY 2020-11-07
Elizabeth Comitale Albany, NY 2020-11-07 colleen single Atlanta, GA 2020-11-07
Michael Valiquette Clifton Park, NY 2020-11-07
Becky Kendall Troy, NY 2020-11-07
Jacob Brady Albany, NY 2020-11-07
Sophia Vastek Troy, NY 2020-11-07
Kaela Knoth Guilderland, NY 2020-11-07
Jessica Ryle Queensbury, NY 2020-11-07
Rose Mitchell Albany, NY 2020-11-07
Kathy Gottsleben Rapid City, US 2020-11-07
Allyson Gamboa US 2020-11-07
Felix Sensley Houston, US 2020-11-07
Dylan Pruitt Laurens, US 2020-11-07
Jacob LaBouliere Doylestown, US 2020-11-07
Myra Loyd Shreveport, US 2020-11-07 Name Location Date
Honey Nalu Honolulu, US 2020-11-07
Sona Juharyan Bakersfield, US 2020-11-07
Judy Dunsford US 2020-11-07
Brayden Rock Duluth, US 2020-11-07
Gabrielle Kamaker Albany, NY 2020-11-07
Danielle Mallon miller place, NY 2020-11-07
Donna Baird Schaghticoke, NY 2020-11-07
Lorelei Wagner Troy, NY 2020-11-07
Greg Farley Hudson, NY 2020-11-07
Zhanna Akopyan Brooklyn, US 2020-11-07
Axel blackholder Lake Mary, US 2020-11-07
Its Moge Modesto, US 2020-11-07
Heather Pelz Hot Springs National Park, US 2020-11-07
Robert Johnson Fairmont, US 2020-11-07
Victoria Kereszi troy, NY 2020-11-08
Cordon Joseph US 2020-11-08
Samantha Moraitou Albany, NY 2020-11-08
Nina Moraitou-Politzi Albany, NY 2020-11-08 alicia stark Castleton, NY 2020-11-08
Julia Posin Oceanside, NY 2020-11-08
Grace Knight Topsfield, MA 2020-11-08
Brittany Phillips Cobleskill, NY 2020-11-08 Name Location Date
Sam Torres Troy, NY 2020-11-08
Sierra Hipwell Troy, NY 2020-11-08
Jessica Hayek Albany, NY 2020-11-08
Brandi Chenette Troy, NY 2020-11-08
Christina Vasil Troy, NY 2020-11-08
Duncan Gamble Burlington, VT 2020-11-08
Samantha Sonnier Troy, NY 2020-11-08
Holly Feit Hannacroix, NY 2020-11-08
Steven Hipwell II US 2020-11-08
Dawnn Antoon Lodi, CA 2020-11-08
Jessica Tanguay Slingerlands, NY 2020-11-09
Isabella Aspiotis Toronto, Canada 2020-11-09
Christy Douglas Menands, NY 2020-11-09
Vanessa Van Zandt Albany, NY 2020-11-09
Laura Pascuzzo Albany, NY 2020-11-09
Sarah Heikkinen Troy, NY 2020-11-09
Caiti Callaghan Troy, NY 2020-11-09
Tara Tucker Williamsburg, MA 2020-11-09
Alissa Roca Coral Gables, FL 2020-11-09
Sarah Schultz New York, NY 2020-11-09
Caleb Bradley Baltimore, MD 2020-11-09
Grave Ma Vancouver, British Columbia, Canada 2020-11-09 Name Location Date
Vijay Gupta Pasadena, CA 2020-11-09
Katja Vanfretti Troy, NY 2020-11-10
Jonah Moberg Troy, NY 2020-11-10 joshua marre scotia, NY 2020-11-10
Alex Noble-Brooks Troy, NY 2020-11-10
Julian Brezon Bronx, NY 2020-11-10
Elizabeth Young Troy, NY 2020-11-10
Katie Cusack New York, NY 2020-11-10
Alexander Hanse Albany, NY 2020-11-10
Brandon Cahrenger Troy, NY 2020-11-10
DeAnna Sutherland Saratoga Springs, NY 2020-11-10
Deirdre Young Troy, NY 2020-11-10
Patricia Cerniglia Troy, NY 2020-11-10
Margaret Young Troy, NY 2020-11-10
Raurri Jennings Troy, NY 2020-11-10
Molly Eadie Troy, NY 2020-11-10
Benjamin Jacques Albany, NY 2020-11-10
Nathan Cole Homer, NY 2020-11-10
Anna D Troy, NY 2020-11-10
Jonathan Cantiello Queensbury, NY 2020-11-10
Jennifer Skoog Monroe, CT 2020-11-10
Chris Hanse Coxsackie, NY 2020-11-10 Name Location Date
Connor Riley Salisbury, CT 2020-11-10
Caity Gallagher Albany, NY 2020-11-10
Mariah Smith Cohoes, NY 2020-11-10
Sharon Hanehan Troy, NY 2020-11-10
Erin Sullivan Troy, NY 2020-11-10
Sarah Morehouse Ballston Lake, NY 2020-11-10
Eliza Chappell Albany, NY 2020-11-10
Rudd Young Troy, NY 2020-11-10
Kelsie Costello Cornwall-on-Hudson, NY 2020-11-10
Erin Baright Bronx, NY 2020-11-10
Chris Rohlman Troy, NY 2020-11-10
Alicia McDonough Troy, NY 2020-11-11
Sarah Alaimo Albany, NY 2020-11-11
Annie Raksasa Hamden, CT 2020-11-11
Jeffery Dingler 02/25/1987 Roanoke, VA 2020-11-12
Kenneth Hummel US 2020-11-14
Elfaeya Phoenix Poestenkill, NY 2020-11-16
Cecelia Reilly Troy, NY 2020-11-17
Cecelia REILLY Troy, NY 2020-11-17
Christopher Jean-Louis Pompano Beach, FL 2020-11-17
George Quine Troy, NY 2020-11-17
Bridget O'Connor New York, NY 2020-11-18 Name Location Date
Jessica Maxwell Delmar, NY 2020-11-20
Adrianna Mathis Albany, NY 2020-11-20
Aashni Shah Albany, NY 2020-11-20
Tia Reis Troy, NY 2020-11-22
Kathryn Davis Troy, NY 2020-11-23
Michael Tario Troy, NY 2020-11-23
Judy cunningham New York, NY 2020-11-23
Rose Orourke Troy, NY 2020-11-23
Christine Marceline Troy, NY 2020-11-23
Ashley mysliwiec Troy, NY 2020-11-23
Dawn Phelps Troy, NY 2020-11-23
Rob Parker Schenectady, NY 2020-11-23
Nicole Manupella Rensselaer, NY 2020-11-23
Ken Mirocki JR Troy, NY 2020-11-23
Terri Craven Louisville, KY 2020-11-23
Tatiana Frolova Troy, NY 2020-11-23 damaris miller Troy, NY 2020-11-23
Debra Lashwa Troy, NY 2020-11-23
Lee Ann Welch Troy, NY 2020-11-23
Mary Peat Troy, NY 2020-11-23
George Mattey Troy, NY 2020-11-23
Shelby Spall Cohoes, NY 2020-11-24 Name Location Date
Dia Beshara Troy, NY 2020-11-24
Rebecca Orrison Albany, NY 2020-11-24
Lynn Hyde Rensselaer, NY 2020-11-24
Beverly Davis Troy, NY 2020-11-24
Irina Naumenkova Brooklyn, NY 2020-11-24
Olivia Vonfricken Cohoes, NY 2020-11-24
Kelsey Renko Troy, NY 2020-11-24
Tracy smith Troy, NY 2020-11-24
Madison LaVallee Schenectady, NY 2020-11-24
Jenny Kemp Troy, NY 2020-11-24
Sophie Heath Malta, NY 2020-11-24
Ian Mahoney-Hoover Troy, NY 2020-11-24
Jean Tschanz-Egger Troy, NY 2020-11-24
Sebastian Guerrero Fontana, US 2020-11-24
Skylar Godwin Middlesex, US 2020-11-24
Shakayla Thomas Compton, US 2020-11-24 kelyse rose Sacramento, US 2020-11-24
Sarah Narkum Everett, US 2020-11-24
Kara Jefts Schuylerville, NY 2020-11-24
Thinh Ngo Arlington, US 2020-11-24
Holly Rippon-Butler Schuylerville, NY 2020-11-25
Royah Marie Troy, NY 2020-11-25 Name Location Date
Il-Young Son Troy, NY 2020-11-25
William Studdiford Troy, NY 2020-11-27
Deborah Levensailor Troy, NY 2020-11-28
Lauri Cartwright Troy, NY 2020-11-29
Guy Pucci Cohoes, NY 2020-11-29
Carmen perrotti Perrotti Clifton Park, NY 2020-11-30
Judith Strong Goshen, US 2020-12-01
Shikara Rollf Goshen, US 2020-12-01
Eli Howard Vail, US 2020-12-03
Jose De la rosa Ligonier, US 2020-12-05
Giovanni Aguayo Goshen, US 2020-12-06
Matthew Leon Amsterdam, NY 2020-12-07
Katherine Wolfram Schenectady, NY 2020-12-07
Alex Brownstein Schenectady, NY 2020-12-07
Andrew Kulmatiski Schenectady, NY 2020-12-07
Margaret Brown Schenectady, NY 2020-12-08
Paula Shaw Schenectady, NY 2020-12-08
Peggy Grot Schenectady, NY 2020-12-08
Jacob Borth Albany, US 2020-12-08
Trish Lynn Taylor US 2020-12-08
Sheila Martin Hawthorne, US 2020-12-08 catie fay New york, US 2020-12-08 Name Location Date
ArtByRinaBun . US 2020-12-08
Penis Face Hastings, US 2020-12-08 angelina ruiz Wayne, US 2020-12-08
Micah Key Washington, US 2020-12-08
Katy Sonnier Austin, US 2020-12-08
Marisol Solano Lodi, US 2020-12-08 h S New Baltimore, US 2020-12-08
Izzie Bartlett Omaha, US 2020-12-08
Spencer Pearce Stillwater, US 2020-12-08 caitlin callahan Redondo Beach, US 2020-12-08
Michael Marts Warsaw, US 2020-12-08
Tessa Seidler Naples, US 2020-12-08
Tienna Edwards Englewood, US 2020-12-08
Judit Mendoza Othello, US 2020-12-08
Jasper Woodward San Diego, US 2020-12-08 praloy saha queens, US 2020-12-08
Katherine Fajardo Ridgewood, US 2020-12-08 natalie dietz Houston, US 2020-12-08
Brianna Nason Turner, US 2020-12-08 kyle gonzalez Algonquin, US 2020-12-08
Peter Fontaine West Warwick, US 2020-12-08
Genevieve Ireland Alexandria, US 2020-12-08 Name Location Date
Zamya Bryant Bethlehem, US 2020-12-08
Keisha Coakley Orlando, US 2020-12-08
William Seyse Scotia, NY 2020-12-08
Kenny Vaher Troy, NY 2020-12-10
Annie Finn Albany, NY 2020-12-10
Steven Janowski Troy, NY 2020-12-10
Isaac Silberman-Gorn Latham, NY 2020-12-12
Cheryl Gorn New York, NY 2020-12-12
Margaret Irwin Troy, NY 2020-12-12
Sara Ibrahim Philadelphia, US 2020-12-12
Ashante Paw Lood Carmel, US 2020-12-12
Anna Duraney New Waterford, US 2020-12-12
Kiori Johnson Buford, US 2020-12-12 emily santana Anaheim, US 2020-12-12 morrissa dunn Warwick, US 2020-12-12 chris edwards Chicago, US 2020-12-12 jax the axe Springfield, US 2020-12-12
Fernanda Tejeda Sacramento, US 2020-12-12 damion lester Las Vegas, US 2020-12-12 maddy dumas Portland, US 2020-12-12
Regina Reyes Salisbury, US 2020-12-12
Nikko Johnson Lexington, US 2020-12-12 Name Location Date kali lopez Swampscott, US 2020-12-12 gracie glotfelty oakland, US 2020-12-12
Jacob Figueroa Fresno, US 2020-12-12 chelsea gonzalez South Gate, US 2020-12-12
Luis Ortiz San Diego, US 2020-12-12
Kayley Argerbright Berea, US 2020-12-12
Chasity Infante Houston, US 2020-12-12
Suzy Flower Evansville, US 2020-12-12
Marissa Hicks Aiken, US 2020-12-12
Mikayla Mclaurin New Orleans, US 2020-12-12
Najma Moalin Nashville, US 2020-12-12
Jonelis Ojeda Perez Philadelphia, US 2020-12-12
Nabayit Fassil Mission Hill, US 2020-12-12
Natalie epperson Modesto, US 2020-12-12
Stephanie Toscano Norwalk, US 2020-12-12
Alejandra Zaragoza Oxnard, US 2020-12-12
Jeymy Santos Glen Head, US 2020-12-12
Sammy Bravo Rolling Meadows, US 2020-12-12
Tessa Noelle US 2020-12-12
Jeida Barron Dubois, US 2020-12-12 lucy gellman Walnut Creek, US 2020-12-12
Edithe Starr Oglala, US 2020-12-12 Name Location Date mahidah shahzad Flushing, US 2020-12-12
Zakiya White Valdosta, US 2020-12-12
Anastasia Lindquist River Falls, US 2020-12-12 valerie brenes Madera, US 2020-12-12
Ronnie Richards Payette, US 2020-12-12
Meghan Scotti Minneapolis, US 2020-12-12
Amelia Belle Omaha, US 2020-12-12 evelyn Annoys Elk Grove, US 2020-12-12 lilly swert Toledo, US 2020-12-12
Denise Michelle San Antonio, US 2020-12-12
Samara Green Las Vegas, US 2020-12-12
Makena Meyer Evanston, US 2020-12-12
Katherine Agreda Hialeah, US 2020-12-12
Rachel Cuzco Woodhaven, US 2020-12-12
Rose Manton Southfield, US 2020-12-12
Try Cheatham Washington, US 2020-12-12
Angie Ahmed Philadelphia, US 2020-12-12
Karen Illescas Los Angeles, US 2020-12-12
Kayden Hale Pompano Beach, US 2020-12-12
Adriana Miranda Albuquerque, US 2020-12-12
Kayla Johnson Freeland, US 2020-12-12 lily marshall Hollywood, US 2020-12-12 Name Location Date lori alcantara Fresno, US 2020-12-12
Adriana Brazzell Pensacola, US 2020-12-12
Blake Abdalla Grand Rapids, US 2020-12-12
Makalia Jackson Coram, US 2020-12-12
Andrea Jackson Saint Paul, US 2020-12-12
Julia Miller Carlsbad, US 2020-12-12
Matthew Misho Niles, US 2020-12-12 bella carr Everett, US 2020-12-12
Eohd Owjdjw US 2020-12-12
Itzel Hernandez Elmhurst, US 2020-12-12
Rutaja Nadgauda Grand Rapids, US 2020-12-12
Alexia Martínez Cincinnati, US 2020-12-12 mehak s New York City, US 2020-12-12
Karla copard Dorchester, US 2020-12-12
Carissa Montes Valencia, US 2020-12-12
Gwynnie Kermorris San Diego, US 2020-12-12
Kimberly Hernandez San Jacinto, US 2020-12-12
Leonor Sandoval Lexington, US 2020-12-12 isabella hoffmann Clermont, US 2020-12-12
Simone Nied Virginia Beach, US 2020-12-12
Alondra Angel Salt Lake City, US 2020-12-12 airmauri davis York, US 2020-12-12 Name Location Date
Keisha Sampson Darby, US 2020-12-12
Gabrielle Arreglo Glendale, US 2020-12-12
Priscilla Adebambo Watertown, US 2020-12-12
Ana Vazquez Myrtle Beach, US 2020-12-12
Ray Rodriguez III Bronx, US 2020-12-12
Sahara Abdi Springfield, US 2020-12-12
Daniella Canjura Clovis, US 2020-12-12
Melanie Arango Tampa, US 2020-12-12
Jazmin Chavez Fresno, US 2020-12-12
Lizbeth Lopez Oceanside, US 2020-12-12
Brendan B Carbondale, US 2020-12-12
Kennedy Sweet Albany, US 2020-12-12
Riley Sar Forest Hills, US 2020-12-12
Avolon Santiago New York, US 2020-12-12
Melody Takahashi Antioch, US 2020-12-12
Sophia Bendix Monroe, US 2020-12-12
Shart f Cloverdale, US 2020-12-12 valerie Mulato Northridge, US 2020-12-12
Hawo Shoble Rochester, US 2020-12-12
Emmanuella Chirac Roxbury, US 2020-12-12
RJ Jackson Elmwood Park, US 2020-12-12
Anna DeOlindo Franklin, US 2020-12-12 Name Location Date
Keren Rodríguez Tampa, US 2020-12-12 elyse studer Austin, US 2020-12-12
Alyssa Jordan North Baltimore, US 2020-12-12
Zyd Coy Three Rivers, US 2020-12-12
Hola Comesta Valdosta, US 2020-12-12
Timur Ismagilov Longview, US 2020-12-12
Ixchell Diaz Patterson, US 2020-12-12 daisy ramirez Pawtucket, US 2020-12-12
Samira Pelegrine Denver, US 2020-12-12
Cactys Jack Los Angeles, US 2020-12-12
Hannah Milot New Milford, US 2020-12-12 ahona alam Houston, US 2020-12-12
Savannah Aguilar Los Angeles, US 2020-12-12
Alyvia Cornett Davison, US 2020-12-12
Travis B Winchester, US 2020-12-12
Fabian Huerta Porterville, US 2020-12-12
Janise Conley Detroit, US 2020-12-12 brooke davis Belleville, US 2020-12-12
Jihsu Ryu Edgewater, US 2020-12-12 emily will Blairsville, US 2020-12-12 brooke sexton Lansing, US 2020-12-12
Jasmine Balboa Crookston, US 2020-12-12 Name Location Date
Jesika Mendoza San Antonio, US 2020-12-12
Lillian Dahl Wichita, US 2020-12-12
Victoria Bazan Bessemer, US 2020-12-12
Violet Asenio Victorville, US 2020-12-12 devas roper Owensville, US 2020-12-12
Yelixa Hidrogo Middleton, US 2020-12-12
Zohra Hashimi Tucson, US 2020-12-12
Alaisha Williams Austin, US 2020-12-12
Ella Pankonin Louisville, US 2020-12-12
Hana Ahmed Fredericksburg, US 2020-12-12
Drew Lefebvre Concord, US 2020-12-12
Lola Linserly Fredonia, US 2020-12-12
Erika Rodriguez Acebedo Woodburn, US 2020-12-12
Maria Fuentes Orlando, US 2020-12-12 salma kwizera Manchester, US 2020-12-12
Juliana T Novi, US 2020-12-12
Bobby Ray Woods Bellflower, CA 2020-12-12
Serenity Russell Brooklyn, US 2020-12-12
Taylor Roddy Wichita, US 2020-12-12
Camreana Williams Chattanooga, US 2020-12-12
Sam Bustamante Minneapolis, US 2020-12-12
Allysha Lorraine Fairbanks, US 2020-12-12 Name Location Date
Carly Sanchez Union City, US 2020-12-12
Nora Dufresne Plano, US 2020-12-12
Anna Antilla Sherman, US 2020-12-12 jada martin Denham Springs, US 2020-12-12
Elyse McMillan Monticello, US 2020-12-12
Ellyana Pfeiffer Neosho, US 2020-12-12
Addison Nunes Olivehurst, US 2020-12-12
Ashley Hernandez Alhambra, US 2020-12-12
Mariela Mares Alameda, US 2020-12-12
Anahi Orozco Bakersfield, US 2020-12-12
Madison Dodson Brooklyn, US 2020-12-12
Lucy Drechsel Mankato, US 2020-12-12
Zoe Medina Minneapolis, US 2020-12-12
Isabel Colin Desert Hot Springs, US 2020-12-12
Angelica Puente Houston, US 2020-12-12 andrea Lopez Goodyear, US 2020-12-12
Marie Rose Sterling, US 2020-12-12
Dasan Shaw Boca Raton, US 2020-12-12
Adriana Hernandez Chicago, US 2020-12-12
Amia Simmons Baltimore, US 2020-12-12
Sarah Murphy Grovetown, US 2020-12-12 ta’lijah frazier sparta, US 2020-12-12 Name Location Date
Natalia Bellido Hollywood, US 2020-12-12
Angelina Gonzalez Turlock, US 2020-12-12
Brooklyn Koesters Indianapolis, US 2020-12-12
Neida Perales Laredo, US 2020-12-12
Julianne Cervantes Carson, US 2020-12-12
Giordyn R Fort Lauderdale, US 2020-12-12 brooklin phillips vinita, US 2020-12-12
EllaMai Queen Sapulpa, US 2020-12-12
Julianna Macias Santa Ana, US 2020-12-12
Carmen Torres Houston, US 2020-12-12
Madaline Lauener Joplin, US 2020-12-12
Toni Rossetti Poulsbo, WA 2020-12-12
Mira Tueller Garden City, US 2020-12-12
Courtney Robinson Anna, US 2020-12-12
Jillian Daire Riverview, US 2020-12-12
Safiya Rhea Arvada, US 2020-12-12
Jesminda Darmanie Brooklyn, US 2020-12-12
Destiny Castellanos El Paso, TX 2020-12-12
Mercedes Del Denver, US 2020-12-12
Trinity Nguyen Glastonbury, US 2020-12-12
April He Rosemead, US 2020-12-12
Molly LaBar Clifton Park, US 2020-12-12 Name Location Date
Andrea Marin Las Vegas, US 2020-12-12
Miana Jeancharles New York, US 2020-12-12
Innocence Johnson Atlanti, US 2020-12-12 alex osborne Harrisonville, US 2020-12-12
Kyla Pina Pawtucket, US 2020-12-12
Delaney Anderson Chicago, US 2020-12-12
Janelly Torres Rockville, US 2020-12-12
Raine Vent Mckees Rocks, US 2020-12-12 katie bartylla Duluth, MN 2020-12-12
Jasmine Candelaria Tehachapi, US 2020-12-12
Katlen Kren Los Angeles, US 2020-12-12
Alicia Gollas Las Vegas, US 2020-12-12
Matt Frederick Asbury Park, US 2020-12-12
Ximena Flores Corona, US 2020-12-12
Maleah Marcum Des Moines, US 2020-12-12
Darianna Weston Chicago, US 2020-12-12
Veronica Davis Bastrop, US 2020-12-12 kendall ramsey Bentonville, US 2020-12-12 kevin a North Bergen, US 2020-12-12 nyah obey Houston, US 2020-12-12
Galilea To a Denver, US 2020-12-12
Marlee Morgan Manchester, US 2020-12-12 Name Location Date
Rosalyn Solorio Sylmar, US 2020-12-12
Lorena Pacheco Dinuba, US 2020-12-12
Zakie Drame Rockville, US 2020-12-12 free gypsy Medford, US 2020-12-12
Colin Watson Glassboro, US 2020-12-12
Faythe Perez Manteca, US 2020-12-12
Brynna Bowen Indianapolis, US 2020-12-12
Emme Augustia Cedar Park, US 2020-12-12
Sandra Vizcaino Las Vegas, US 2020-12-12
Haidyn Brooks Greenwood, US 2020-12-12
Teagen Jensen Thief River Falls, US 2020-12-12
Maria Bennett indianapolis, US 2020-12-12
Corbin Leathers Las Vegas, US 2020-12-12
Juleivy Salgado Clarion, US 2020-12-12
Van Chhuaha West Des Moines, US 2020-12-12 tre’jour salters Elkridge, US 2020-12-12
Diamilatou Diallo New York, US 2020-12-12
Lilly Oli El Paso, US 2020-12-12 audrey mittrucker Wentzville, US 2020-12-12
Evalyn Vires Westland, US 2020-12-12 prisilah rose Danville, US 2020-12-12
Amora Valentine Fort Lauderdale, US 2020-12-12 Name Location Date
Cassandra Kelley Old Forge, US 2020-12-12
Eh Hser Omaha, US 2020-12-12
Mia Buenrostro Baldwin Park, US 2020-12-12
Paige Anatol Short Hills, US 2020-12-12
Brionne McFarlane Bronx, US 2020-12-12
Shamya Taylor Battle Creek, US 2020-12-12
Elizabeth Looez Salinas, US 2020-12-12 estela huddleston Rohnert Park, US 2020-12-12
Alexis Burns Pittsburgh, US 2020-12-12
Kadajah Johnson Louisville, US 2020-12-12 sheidy velez Spring, US 2020-12-12
Id Hassan Reynoldsburg, US 2020-12-12
Brandon Calobeer Cedar City, US 2020-12-12
Mia Bates DuPont, US 2020-12-12
Payton Young Imperial, US 2020-12-12
Clint Boggio US 2020-12-12
Skye Phung Sacramento, US 2020-12-12
Cali Scarpaci Vacaville, US 2020-12-12
Ethan Newitt Coatesville, US 2020-12-12
Violeta Lara New York, US 2020-12-12 zariah mcclure Santa Ana, US 2020-12-12
Cole Francis Buffalo, US 2020-12-12 Name Location Date
Laila Romero Fresno, US 2020-12-12
Michael Gutierrez Dallas, US 2020-12-12
Leilani Zuniga Bakersfield, US 2020-12-12
Karen Walker Kansas, US 2020-12-12
Neeve Walters New Hartford, US 2020-12-12
Felisity Padilla Albuquerque, US 2020-12-12 safrina henk Minneapolis, US 2020-12-12
Abby Frankfurth Westminster, US 2020-12-12
Camilla German Hollywood, US 2020-12-12 k c Las Vegas, US 2020-12-12 bella riepe Paducah, US 2020-12-12
Karis Jones Westlake, US 2020-12-12
Stella Bertoli Piermont, US 2020-12-12
Sarah Cantu Tyrone, US 2020-12-12
Riley Kelis San Antonio, US 2020-12-12
Mayukha Sirineni San Ramon, US 2020-12-12
Aderice Wheeler Texarkana, US 2020-12-12
Phyllisia Rosen Los Alamitos, US 2020-12-12
Deja Wilson Norcross, US 2020-12-12
Janilyn Toyng Fontana, US 2020-12-12
Denise Carrillo Avondale, US 2020-12-12
Audrey Cantor Delaware, US 2020-12-12 Name Location Date
Arisha Rasid Los Angeles, US 2020-12-12
Olivia Vega San Mateo, US 2020-12-12
Madelyn Taylor Surprise, US 2020-12-12
Alaska Morgan Zanesville, US 2020-12-12
Jay Nieves Plainville, US 2020-12-12
Camilla Gaeta Gilroy, US 2020-12-12
Leyah Jackson Cleveland, US 2020-12-12
James Pickett West Bloomfield, US 2020-12-12
Thomas Brewer Lexington Park, US 2020-12-12
Pamela Johnson Fitzgerald, US 2020-12-12
Daisy Favela Las Vegas, US 2020-12-12 leticia G Crowley, US 2020-12-12
Erica O’Donnell Erie, US 2020-12-12
Brooke Fults Mankato, US 2020-12-12
Tajahney Garland Zanesville, US 2020-12-12 l a buena park, US 2020-12-12
Serenity Phillips Saint Clair Shores, US 2020-12-12
Adiba Adrita Los Angeles, US 2020-12-12
Alyssa Rodriguez Miramar, US 2020-12-12 ceona lewis Houston, US 2020-12-12
Bella Sanchezz Phoenix, US 2020-12-12
Remmy Saepharn Rodeo, US 2020-12-12 Name Location Date
Ash Bushby Myrtle Beach, US 2020-12-12
Makenna Pickett Seattle, US 2020-12-12
Nayeli B E Napa, US 2020-12-12
Abbigail Benson Bartlett, US 2020-12-12
Rashiyah Cummings Lad Vegas, US 2020-12-12
Sophia Phillips-Dar Eureka, US 2020-12-12
Veronica Smith Dallas, US 2020-12-12
Sierra Dean Shreveport, US 2020-12-12
Darlynne Garza Edinburg, US 2020-12-12
Eva Araujo Rancho Cordova, US 2020-12-12
Sienna Solis Ventura, US 2020-12-12
Kami Wade Brighton, US 2020-12-12
Julia Pena San Antonio, US 2020-12-12
Deepali Gawade Dublin, US 2020-12-12
Qunoot Al-sultani Saint Louis, US 2020-12-12
Annabelle Quick Charlotte, US 2020-12-12
Emma Van Hall Ballston Spa, US 2020-12-12
Heshshajahfs Gehetehehege Bronx, US 2020-12-12
Nick O’Malley Westbrook, US 2020-12-12
Ike Chinye Hollywood, US 2020-12-12
Ke’Naya Jones Essex, US 2020-12-12
Julians Rivera North Dartmouth, US 2020-12-12 Name Location Date
Emma Lang Salem, US 2020-12-12
Katlyn Cornett Iowa Park, US 2020-12-12 krystal cota El Paso, US 2020-12-12
Allison Lucas Manning, US 2020-12-12
Brooklyn Williams Bainbridge Island, US 2020-12-12
Maya Green Philadelphia, US 2020-12-12
Neftis Prieto Inglewood, US 2020-12-12 ella tobias West Chester, US 2020-12-12 haylie hong Saint Louis, US 2020-12-12
Ella Dyal Orange Park, US 2020-12-12 nariya lang Utica, US 2020-12-12
Eliana Bautista Castro Valley, US 2020-12-12
Y S Arlington, US 2020-12-12 isabelle chaves Lakewood, US 2020-12-12 ezra peiter Ann Arbor, US 2020-12-12
Adrienne Rist Clifton Park, US 2020-12-12
Karen Hams Hines, US 2020-12-12
Karoline Larsen Mount Juliet, US 2020-12-12
Norah Minka Sherbrooke, US 2020-12-12
Fatou Sow Reynoldsburg, US 2020-12-12
Bailey Wong Moriguchi Hayward, US 2020-12-12
Ronald Carter jr Newark, US 2020-12-12 Name Location Date
Mia Bjorn San Jose, US 2020-12-12
Haleigh Mosser Decatur, US 2020-12-12
Eliceht Diaz West Babylon, US 2020-12-12
Nahomi Munoz Parachute, US 2020-12-12
Lili Hanley Colorado Springs, US 2020-12-12 ally ellis Council Bluffs, US 2020-12-12
Beatriz Rush none, US 2020-12-12 sammie santos Waterford, US 2020-12-12
Melw Skajs Spring, US 2020-12-12
Alana Mills Sacramento, US 2020-12-12
Salem Lowell Nashua, US 2020-12-12 tina bourgeois Bloomington, US 2020-12-12
Corinne F Metairie, US 2020-12-12
Erin Weikert Livonia, US 2020-12-12
Sophia Urias South Gate, US 2020-12-12
Allie Behnke Chicago, US 2020-12-12
Elon Dixon Charlotte, US 2020-12-12
Trinity Lewis Four Oaks, US 2020-12-12 chayse horning North Canton, US 2020-12-12
Jisselle King Coral Springs, US 2020-12-12
Brackzen Swips Greer, US 2020-12-12
Denni Simmons Independence, US 2020-12-12 Name Location Date
Cassie Lanham Saint Peters, US 2020-12-12
Lauren Smith Spartanburg, US 2020-12-12 harmony heys Puyallup, US 2020-12-12
Gianna McKinney Chicago, US 2020-12-12
Noelani Soares Kaneohe, US 2020-12-12
Haley Saythideth Providence, US 2020-12-12
Paige MacKenney Abingdon, US 2020-12-12
Sofia Espinosa Fort Lauderdale, US 2020-12-12
Carolina Lopez Fontana, US 2020-12-12
Jada Cook Murfreesboro, US 2020-12-12
Emma Ortlieb Susanville, US 2020-12-12 dylan singer Chesterland, US 2020-12-12
Tatyana Moore Buford, US 2020-12-12
Elisa Pain-Cook Hillsboro, US 2020-12-12
Joy Opare-Ameyaw Rancho Cucamonga, US 2020-12-12
Wangu Magua Silver Spring, US 2020-12-12
Lydia Carter Lubbock, US 2020-12-12
Natalie O Perkasie, US 2020-12-12 sarah is the nice one US 2020-12-12 change now US 2020-12-12
Jordy Jefferies Lincolnton, US 2020-12-12
K C Solvang, US 2020-12-12 Name Location Date
Mya Beaver Westminster, US 2020-12-12
Phoebe Mendiola Manteca, US 2020-12-12
Abby Ugochukwu Braintree, US 2020-12-12 monkichiii poop Stafford, US 2020-12-12
Morgan Spruill Lithonia, US 2020-12-12
Desiree Castro Philadelphia, US 2020-12-12
Katie Collins Baldwinsville, US 2020-12-12
Minah Wango’olo San Diego, US 2020-12-12
Maria Villar Nashville, US 2020-12-12
Alondra Dominguez US 2020-12-12
Amanda Mao US 2020-12-12
Joseph Wickham Schenectady, US 2020-12-12
Frances Chai Carlsbad, US 2020-12-12
Michaela Mlakar Albuquerque, US 2020-12-12
Emily Fasano Fort Lauderdale, US 2020-12-12
Harley Tribble Baltimore, US 2020-12-12
Janasia Haynes Portsmouth, US 2020-12-12
Alexa Herrera Tulsa, US 2020-12-12
Miranda Mendoza Columbus, US 2020-12-12
Gabriella Badon Browns Mills, US 2020-12-12
Carolina Duval Bend, US 2020-12-12 olivia smith Gate City, US 2020-12-12 Name Location Date taylor adams Georgetown, US 2020-12-12
Dawn Christakis South Yarmouth, US 2020-12-12 jadalyn wardell Casper, US 2020-12-12
Miki Ashaye Meridian, US 2020-12-12
Alex Lindgren Fair haven, US 2020-12-12 ella childress Ballwin, US 2020-12-12 jessica taylor hudson, US 2020-12-12 julie webb Wheaton, US 2020-12-12 neya rajkumar Burlington, US 2020-12-12
Josh Kirore Madison, US 2020-12-12
Lauren reiann Richmond, US 2020-12-12
Mikaela Diana Palm Harbor, US 2020-12-12
Montrell Bragg Louisville, US 2020-12-12
Serena Santiago Hollister, US 2020-12-12
Terri Pickett Rosemead, US 2020-12-12
Dalycia Ortega Vineland, US 2020-12-12
Valeria Madrid Rifle, US 2020-12-12
Kalie Butler Northumberland, US 2020-12-12
Trey Mikell Deptford, US 2020-12-12
Melanie Abarca Chicago, US 2020-12-12 zaria brooks Paramus, US 2020-12-12 antoinette granados Sacramento, US 2020-12-12 Name Location Date
Alida Sanders Minneapolis, US 2020-12-12
Charlene Darwen Fresno, US 2020-12-12
Danielle Hernandez Rome, US 2020-12-12
Joselin Perez Sag harbor, US 2020-12-12
Geraldine Rodriguez Mayagüez, US 2020-12-12
Kamron Dunnah Tucker, US 2020-12-12
Mackenzie Dial Atlanta, US 2020-12-12
Younis Abdaljawad Chicago, US 2020-12-12
Viola Veliu Orlando, US 2020-12-12
Gianna Hi Malden, US 2020-12-12
Daryl H Penfield, US 2020-12-12
Gabi D Prosper, US 2020-12-12
Arianna Langstein Montgomery Village, US 2020-12-12
Danielle Fisher Aurora, US 2020-12-12
Janiqua Wright Bronx, US 2020-12-12
Skylar Anthony Clinton, US 2020-12-12
Camryn Mirenna Huntington Beach, US 2020-12-12
Arooj A Fairfax Station, US 2020-12-12
Karen Enciso Fresno, US 2020-12-12
Sarah Elconin Somers, US 2020-12-12
Janelle Tillman Chicago, US 2020-12-12 makiah kelley cape coral, US 2020-12-12 Name Location Date
Leilani Operana Las Vegas, US 2020-12-12
Sujana Kakarla Glen Mills, US 2020-12-12
Hannah Roberts Wilmette, US 2020-12-12
Tatyana Richardson Houston, US 2020-12-12 ralph a Roswell, US 2020-12-12
Yoon Bum Houston, US 2020-12-12
Rihanna Meddings Sewell, US 2020-12-12
Emily Irizarry Brooklyn, US 2020-12-12
Louise Peregrina Boise, US 2020-12-12
Allie Fortmayer Marrero, US 2020-12-12
Pao Terrazas Lincoln, US 2020-12-12
Tionna Means Atlanta, US 2020-12-12
Hailey Masengarb Davenport, US 2020-12-12
Kourtney Hawkins Greenville, US 2020-12-12
Savannah Bentley Sandwich, US 2020-12-12
Xyla Correa Montebello, US 2020-12-12
Addison Thompson Chesterfield, US 2020-12-12
Nadia Winbush Hampton, US 2020-12-12
Ruby Bustamanate Chicago, US 2020-12-12
Cadence Schultz Munising, US 2020-12-12
Laleh Youssefieh Mercer Island, US 2020-12-12
Evelyn Minjares Portland, US 2020-12-12 Name Location Date
Jay Suero Bronx, US 2020-12-12
Dana S. Sanford, US 2020-12-12
Aubrey Finley Pontotoc, US 2020-12-12
Grace Norris Venice, US 2020-12-12
Jonathan Golden Hammond, US 2020-12-12
Arianna Alvatorre Flushing, US 2020-12-12
Eseye Mebrat Brandon, US 2020-12-12
Akira Miller Dublin, US 2020-12-12
Ella Swank Lincoln, US 2020-12-12
Grayson Brown Taylorsville, US 2020-12-12 julia cami Barrington, US 2020-12-12
David Harrington Laurinburg, US 2020-12-12
Emily Davis Orangevale, US 2020-12-12
Stacey Pierre Bridgeport, US 2020-12-12
Serenyty Crus El Paso, US 2020-12-12 juliana s Frederick, US 2020-12-12
Aniyah Kassimu Charlotte, US 2020-12-12
Nayari Mcclymont Belchertown, US 2020-12-12
Daivik Escobar Mount Pleasant, US 2020-12-12
Kiara Day Brooklyn, US 2020-12-12
Morgan Young Linthicum, US 2020-12-12
Avery Jones Oak Park, US 2020-12-12 Name Location Date
Mia Reichardt Queen Creek, US 2020-12-12
Evelyn Malvestuto Chicago Heights, US 2020-12-12
Katherine Brandel Mankato, US 2020-12-12
Asia Chatman Milwaukee, US 2020-12-12
Alyssa D Pasadena, US 2020-12-12
Angelina Pedro Decatur, US 2020-12-12
Darrian :) Kenner, US 2020-12-12
Gracie Garza Euless, US 2020-12-12
Shawn Hernandez Grover Beach, US 2020-12-12
Valeria Valle Dallas, US 2020-12-12
Yasmin Furtado Wilmington, US 2020-12-12
Miya Brooks Ashland, US 2020-12-12
Adelaide Mckinney Clearwater, US 2020-12-12
Clara Stromberg Lincoln, US 2020-12-12
McKenna Osborne Minneapolis, US 2020-12-12
Melanie Rodriguez Lynwood, US 2020-12-12
Emma Davis Summerville, US 2020-12-12
Christian Farber Paiz Bosque Farms, US 2020-12-12
Grace Knoke Ogallala, US 2020-12-12
Jaliyah Johnson Oklahoma City, US 2020-12-12
Christy Maldonado Kansas City, US 2020-12-12
Kaitlyn Collins Cleveland, US 2020-12-12 Name Location Date cynthia lezama Foothill Ranch, US 2020-12-12
Dafne Rivera Fairview, US 2020-12-12
Emma Almeida Justin, US 2020-12-12
Parishi Parekh Dallas, US 2020-12-12
Leanne Tibayan Brentwood, US 2020-12-12
Ariana Gutierrez Cincinnati, US 2020-12-12 sarah devine Phoenix, US 2020-12-12
Caileih Ledbetter Versailles, US 2020-12-12
Emma Randal Fishers, US 2020-12-12
George Lindsey Jr Providence, US 2020-12-12
Maizah Johnson US 2020-12-12
Audrey Pussy flap Orlando, US 2020-12-12 gabby . San Juan, US 2020-12-12
Isabella Alvarez Whittier, US 2020-12-12
Jade Hover Tallahassee, US 2020-12-12
Lydia Murphy Melrose, US 2020-12-12
Carrie Malone Shepherdsville, US 2020-12-12
Coach Ukai Burley, US 2020-12-12
Elliana Williams-Mwaro Los Angeles, US 2020-12-12 jackie valencia Tucson, US 2020-12-12
Hana Lauter Chicago, US 2020-12-12
Shanelle Allwood Harker Heights, US 2020-12-12 Name Location Date
Alyna Kelley Indianapolis, IN 2020-12-12
Mya Whitman Hughes es Philadelphia, US 2020-12-12
Destinee Jacob Cherry Hill, US 2020-12-12
Katherine Molina Weslaco, US 2020-12-12
Z W Denver, US 2020-12-12
Camila Pulex Indianapolis, US 2020-12-12 jillie tirado Merrillville, US 2020-12-12
Sanjay Nair US 2020-12-12 danika lloyd Renton, US 2020-12-12
Marlene Gill Newport, US 2020-12-12
Melody Chai Daly City, US 2020-12-12
Olivia Brenes Laguna Beach, US 2020-12-12
Rosalynn Heite Woodbridge, US 2020-12-12 diego guerrero Dallas, US 2020-12-12
Susanna Rivera Fresno, US 2020-12-12
Akua Swift Canby, US 2020-12-12
Braelyn Fennych Ramona, US 2020-12-12
De'Arieus Hughes Oakland, US 2020-12-12 niaya chisolm Maywood, US 2020-12-12 sam t roseville, US 2020-12-12
Zamyah Holmes Lansing, US 2020-12-12
Eve Ani Colorado Springs CO, US 2020-12-12 Name Location Date allie niesen Chaska, US 2020-12-12
Ismayling Perez Feliz Paterson, US 2020-12-12 hailee cid Richmond, US 2020-12-12
Sha-Nia Perrin Mooresville, US 2020-12-12
Grace Moore Yorktown, US 2020-12-12
Haily Lepe Penaloza El Monte, US 2020-12-12
Neveah Schwartz Henderson, US 2020-12-12
Emily Farmer Elkhorn, US 2020-12-12
Maren Davis Bridgeville, US 2020-12-12
Lexi Shepherd Rockwall, US 2020-12-12 tahdmidf jairjzxjv Goodyear, US 2020-12-12
Saphora Joseph Miami, US 2020-12-12
Carina Leyva Wasco, US 2020-12-12
Victoria Willis Brooklyn, US 2020-12-12
Isabella Silva Chula Vista, US 2020-12-12
Estrella Romulo Laredo, US 2020-12-12
Kalie McLain East Syracuse, US 2020-12-12
Analeeze Quintanilla Grand Prairie, US 2020-12-12
Siyanni Horton High Point, US 2020-12-12 ivette jimenez Boca Raton, US 2020-12-12
Alice Talker Fremont, US 2020-12-12
Maya Chandurkar Sunnyvale, US 2020-12-12 Name Location Date
Kermina Rateb Jersey City, US 2020-12-12 caitlynn k westbury, US 2020-12-12
Lucy annis-bercier Saint Paul, US 2020-12-12
Marissa Ramirez san diego, US 2020-12-12 summer lowder Lexington, US 2020-12-12
Marwah Alami Hamilton, US 2020-12-12
Jacqueline Delgado Prado Palmdale, US 2020-12-12
Ally Gallardo San Diego, US 2020-12-12
Octavia Allen Ballston Spa, US 2020-12-12
Jessica Brainerd Lincoln, US 2020-12-12
Jonathan Martinez Lenexa, US 2020-12-12 anon anon Las Vegas, US 2020-12-12
Christopher Crandall Lenoir City, US 2020-12-12
Robert Cervantes Arroyo Grande, US 2020-12-12
Celsea Buchheit Maryland heights, US 2020-12-12
Victoria Cremeans Orem, US 2020-12-12
Anna Johnston Evansville, US 2020-12-12
Narya Dulaney Atlanta, US 2020-12-12
Evelyn Tran Milpitas, US 2020-12-12
Kaley Fantini Wilmington, US 2020-12-12
Ava Cooper Rutledge, US 2020-12-12
M B New York, US 2020-12-12 Name Location Date
Janice San Martín East Hartford, US 2020-12-12
Shefara Jaman Dacula, US 2020-12-12
Alexandra Hoerle Osprey, US 2020-12-12
Ava Morretta Huntingtown, US 2020-12-12 a b Encinitas, US 2020-12-12
Beck Willis Chicago, US 2020-12-12
Kira Lee Honolulu, US 2020-12-12
K’yah Lanier Plainfield, US 2020-12-12
Allilyn Aberle Brick, US 2020-12-12
Rahi Patel Greensboro, US 2020-12-12
Cathrine May New York City, US 2020-12-12
Lizbeth Gutierrez Corona, US 2020-12-12
Marissa Smith Glendora, US 2020-12-12
Sabina Rossomano Smithtown, US 2020-12-12
Madeline McIntosh Colorado Springs, US 2020-12-12
Isabela Bodoso US 2020-12-12
Savannah Peterson Minneapolis, US 2020-12-12
Rebecca Gray Frankfort, US 2020-12-12
Stevi Groves Menifee, US 2020-12-12
Brigitte Cabrera Des Moines, US 2020-12-12
Sadie Fleming Bettendorf, US 2020-12-12
Naisha Momplaisir Miami, US 2020-12-12 Name Location Date
Nia Kirina Silver Spring, US 2020-12-12
Paulina Romero Basalt, US 2020-12-12
Maddie Biven crestwood, US 2020-12-12
Anthony Saucedo Ogden, US 2020-12-12
Lynne Keim Harrisburg, US 2020-12-12
Andre Freeman Providence, US 2020-12-12
Jennifer Louis Miami, US 2020-12-12
Julie Smith Portland, US 2020-12-12
Ari H Houston, US 2020-12-12
Austin Michaels Austin, US 2020-12-12
Can’t Say Las Vegas, US 2020-12-12
Brisa Lopez Oregon City, US 2020-12-12
Zamari Moore West Des Moines, US 2020-12-12
Pug Doggo Pittsburgh, US 2020-12-12
Amelia Gardner Grand Bay, US 2020-12-12
Jazmyn Stevens Port Orange, US 2020-12-12
Kimberly Mireles Chicago, US 2020-12-12 ella mae markowski downingtown, US 2020-12-12
Luis Hunlock Monroe, US 2020-12-12
Minra Random Last name Worcester, US 2020-12-12
Keyla Reyes Truckee, US 2020-12-12
Kelsey Geister Blanchard, US 2020-12-12 Name Location Date
Cody Mitchell US 2020-12-12
Chloe Lett Beltsville, US 2020-12-12
Maria Colmenares Tioga, US 2020-12-12
Willow Perry Statesboro, US 2020-12-12
Parker Sandoval Palm Springs, US 2020-12-12
Avery Cummings Flint, US 2020-12-12
Frank Vargas San Diego, US 2020-12-12
Lluvia Cervantes Mocksville, US 2020-12-12
Theodore Lee Buffalo, US 2020-12-12
Addison Becker Centennial, US 2020-12-12
Bella Izzy Gilroy, US 2020-12-12
Ben Dover New York, US 2020-12-12
Carter Barnhouse Indian Trail, US 2020-12-12
Anaya Jackson Anaheim, US 2020-12-12
Julliana Ibarra Fontana, US 2020-12-12
Rebecca Cai Saratoga, US 2020-12-12
Chaniah Gayten Oakland, US 2020-12-12
Desiree Lopez Reseda, US 2020-12-12
Victoria Head Irving, US 2020-12-12
Xiomarrah Sisco Dallas, US 2020-12-12
Ria Amin Forest Hills, US 2020-12-12
Mayrin Rosales Beaverton, US 2020-12-12 Name Location Date
Mia Purdy Stone Mountain, US 2020-12-12
Janez Perren Bethlehem, US 2020-12-12
Kaelyn Clown Lewisville, US 2020-12-12
Julianna Perez Belleview, US 2020-12-12
Chloe Stephens Queen Creek, US 2020-12-12
Sydney Ottman Everett, US 2020-12-12
Kaliyah Register Panama City, US 2020-12-12
Alexis Pierre Los Angeles, US 2020-12-12
Amya Riley Saint Paul, US 2020-12-12
Daphne Acosta Phoenix, US 2020-12-12
Bre Riser Arlington, US 2020-12-12
I don’t Wanna Hi, US 2020-12-12 cupcakeboom :3 US 2020-12-12
Ronnell Gilmore Toledo, US 2020-12-12 nicole primavera Bayport, US 2020-12-12
Everett Levine Iowa City, US 2020-12-12 aidyn caraballo Addison, US 2020-12-12
Jasmine Potenza Sterling, US 2020-12-12
Dana Deluca Doylestown, US 2020-12-12
Andrea Martinez Winchester, US 2020-12-12
Kendalyn Logsdon Kalamazoo, US 2020-12-12
Olivia Kurtz Cherry Hill, US 2020-12-12 Name Location Date
Nathalie Rodriguez Houston, US 2020-12-12
Trinity Troncoso Bronx, US 2020-12-12
Francesca Zodel Princeton Junction, US 2020-12-12
Lexi Kingrey West, US 2020-12-12
Emmi Pena Windsor, US 2020-12-12 haylie figueroa whittier, US 2020-12-12
Millie Gomez Los Angeles, US 2020-12-12
Alaysha Pulliam Prairie, US 2020-12-12
Ascheley Louidor Orlando, US 2020-12-12 vanessa ferrer Seattle, US 2020-12-12
Makayla Collier Bloomfield, US 2020-12-12
Annalize Cortes Charlotte, US 2020-12-12
Makayla Davis New Bern, US 2020-12-12
Brooka Robertson Vilonia, US 2020-12-12
Evie Webster Reading, US 2020-12-12
Adryan Aquino Carolina, US 2020-12-12
Maria Gomez Downey, US 2020-12-12
Nayelie Perez Cape Coral, US 2020-12-12
Chase Allen Englewood, US 2020-12-12
Tiffany Pereira Pompano Beach, US 2020-12-12
Arabella DeBow Tyngsboro, US 2020-12-12
Janae Wilson Rockville Centre, US 2020-12-12 Name Location Date
Jayneera Hickerson Dayton, US 2020-12-12
Raquel Royster Sterling, US 2020-12-12
Maya Juarez Framingham, US 2020-12-12
Arianna Alcaraz San Mateo, US 2020-12-12
Khia Wade Cambridge, US 2020-12-12 nicole menjivar Brooklyn, US 2020-12-12
Anya Iyer San Jose, US 2020-12-12 heathey sigy Laguna Beach, US 2020-12-12
Allison Martinez Apple valley, US 2020-12-12
Louisa Perryman Fort Smith, US 2020-12-12
Ana Fuster Carolina, US 2020-12-12
Gabrielle Bradley Carmel, US 2020-12-12
Kerijan Nattoo Orange Park, US 2020-12-12
Karina Corral-Rodriguez Altadena, US 2020-12-12
Salma Shuhayb Louisville, US 2020-12-12
Avery Vainoris San Clemente, US 2020-12-12 big DADDY Saint Louis, US 2020-12-12
Maggie Smith Orlando, US 2020-12-12
Sarah Zapisochnaya Lanham, US 2020-12-12
Emily Compo Salisbury, US 2020-12-12
Samantha Cross Marlow, US 2020-12-12
Zahylee Cox Keego Harbor, US 2020-12-12 Name Location Date
Rachel Polimeni New York, NY, US 2020-12-12 madison Stewart Titusville, US 2020-12-12 melissa field Portland, US 2020-12-12
Amy Magalhaes Niantic, US 2020-12-12
Donna L West Babylon, US 2020-12-12
Emma Lindroth Pico Rivera, US 2020-12-12 elle marshall Clover, US 2020-12-12
Rose Askren South Jordan, US 2020-12-12
Izzy Pierson North East, US 2020-12-12
Yeramis Subera New York, US 2020-12-12
Emma Malloy Shreveport, US 2020-12-12 aishi ghosh Shrewsbury, US 2020-12-12
Ayeeee Yooo Stockbridge, US 2020-12-12
Benjamin Tarkenton Charlotte, US 2020-12-12
Sara Geis Clover, US 2020-12-12
Reina Lee Queens, US 2020-12-12 gabriela echeverria Miami, US 2020-12-12
Taniya Dyson Houston, US 2020-12-12
Paris Jackson Anaheim, US 2020-12-12
Sofia Garza Pacifica, US 2020-12-12
Andrew Perez Dallas, US 2020-12-12 sophia mares Sanger, US 2020-12-12 Name Location Date
Quinn M Austin, US 2020-12-12 estela blanton Royal Oak, US 2020-12-12
Ella DeLaCruz Tacoma, US 2020-12-12
Leonardo Castello Gaithersburg, US 2020-12-12
Jasper Morris San Francisco, US 2020-12-12
Kennedi Johnson Lithonia, US 2020-12-12
Bill Miller Beverly Hills, US 2020-12-12 ivy tran Duluth, US 2020-12-12
Erica John Gainesville, US 2020-12-12
Josie Flanagan US 2020-12-12
Ayla Gomez Ventura, US 2020-12-12
Catherine Kulcavage Corning, US 2020-12-12
Nicole Dizon Virginia Beach, US 2020-12-12 brookelynn riser Arlington, US 2020-12-12
Toni Hamilton Detroit, US 2020-12-12
Cassidy Pesek Austin, US 2020-12-12
Gina Cordero Pittsburg, US 2020-12-12 carolina villaverde Lake Worth, US 2020-12-12 matthew ikini Roslindale, US 2020-12-12
James Timmons Topeka, US 2020-12-12
Raylynn Moralez Albuquerque, US 2020-12-12
Julie Gomez Dallas, US 2020-12-12 Name Location Date sophie stanford Cleveland, US 2020-12-12
. .. Russellville, US 2020-12-12
Keirra Kyler Houston, US 2020-12-12
Laura Luis Houston, US 2020-12-12
Mya Reyes Watertown, US 2020-12-12
Nathaniel pichardo Newark, US 2020-12-12
April Ochoa Orange, US 2020-12-12
Carmen Taylor Fayetteville, US 2020-12-12 caroline gale Dallas, US 2020-12-12 alannah greig Ilion, US 2020-12-12 mariana a Selma, US 2020-12-12
Delilah Belmontes El Paso, US 2020-12-12 valeria quim Fountain Valley, US 2020-12-12
Destiny Fuller Eddyville, US 2020-12-12
Trisheena Harris Hammond, US 2020-12-12
Yulissa Galan Bronx, US 2020-12-12 daniela arce lynn, US 2020-12-12
Ji Owens New Hartford, US 2020-12-12
Leah Pham San Diego, US 2020-12-12 jesus jesus Bronx, US 2020-12-12 hailey hutchens Stevensville, US 2020-12-12 shawn warren Columbia, US 2020-12-12 Name Location Date kay will Avon, US 2020-12-12
Stacy Lotinker Sparta, US 2020-12-12
Wenda McLaurin Kernersville, US 2020-12-12 maggie clifford Wayland, US 2020-12-12
Atika Timmmons Philadelphia, US 2020-12-12
Loli Lol Somewhere, US 2020-12-12 dakota brown Clementon, US 2020-12-12
Lauren Watterson Anderson, US 2020-12-12
Emily Ryan Quincy, US 2020-12-12
Amielyah Rahim Clermont, US 2020-12-12
Liana Guillen Pompano Beach, US 2020-12-12
Marissa McLellan Seattle, US 2020-12-12
Muslimo Farah Miami, US 2020-12-12
Paola Campos Merrick, US 2020-12-12
Sacha Chunn Atlanta, US 2020-12-12 zaina Naneesh San Francisco, US 2020-12-12
Ashlee Evans Merrillville, US 2020-12-12 ruby lainez Los Angeles, US 2020-12-12
Brenna Daugherty Clinton, US 2020-12-12
Andrew Lewis Atlanta, US 2020-12-12
Anthony Pierce Fond Du Lac, US 2020-12-12
Chico Faes Modesto, US 2020-12-12 Name Location Date
Kimberly Patzer Stevensville, US 2020-12-12 niko defeo fosterburg, US 2020-12-12
Crystal Brackett Worcester, US 2020-12-12
Pratima Neopaney Syracuse, US 2020-12-12
Christashia Thomas Houston, US 2020-12-12
London Hill Dallas, US 2020-12-12
Faith Blondin Westfield, US 2020-12-12
Cherie Fernandez Galveston, US 2020-12-12
Cindy Barlow Staunton, US 2020-12-12 daphne wang San Ramon, US 2020-12-12
Eli Campbell Bath, US 2020-12-12
Maggie McClinton Greensboro, US 2020-12-12
David Salas Hobbs, US 2020-12-12
Sam Mendez Pacoima, US 2020-12-12
Yuleni Luna Dallas, US 2020-12-12
Allwyn Henry Charlottesville, US 2020-12-12
Chi Allen Maple Heights, US 2020-12-12
Aaliyah newell West Des Moines, US 2020-12-12 alyssa arsenal Aiea, US 2020-12-12
Olivia Smith St. John's, US 2020-12-12
Ella Martinez Corpus Christi, US 2020-12-12
Enrique Ramos Bronx, US 2020-12-12 Name Location Date
Yasmin Gay Pompano Beach, US 2020-12-12
Adam Pearcy Fredericksburg, US 2020-12-12
Krislyn King Huntsville, US 2020-12-12
Isabella Paravate West Islip, US 2020-12-12
Kaia Elfarkh Mobile, US 2020-12-12
Leah Scofield Secaucus, US 2020-12-12
Desinya Brown Houston, US 2020-12-12
Nyla Campbell Hyattsville, US 2020-12-12
Leah Mills Seaside Heights, US 2020-12-12
Melannie Ochoa Chicago, US 2020-12-12
Madeline Arellanes Mabelvale, US 2020-12-12
Trinity Williams Mount Prospect, US 2020-12-12 maddy hopkins Stillwater, US 2020-12-12
Celeste Gonzalez Miami, US 2020-12-12
Luri Villatoro Oakland Park, US 2020-12-12
Jordan S Chesapeake, US 2020-12-12
Kylie Guerrero Haysville, US 2020-12-12
Lesly Alcantara Staten Island, US 2020-12-12
Adriana Blanco Trenton, US 2020-12-12
Bella Desquitado Las Vegas, US 2020-12-12
Marish Mills Oswego, US 2020-12-12
Sara Cordova Ibarra Federal Way, US 2020-12-12 Name Location Date delaney o’connor Phoenix, US 2020-12-12
Mardic madison Steubenville, US 2020-12-12
Hannah Gustafson Coeur D'alene, US 2020-12-12
Emma Harrison new York city, US 2020-12-12 nevaeh todd Raeford, US 2020-12-12
Astrid Guerrero Boston, US 2020-12-12
Joseph Johnson Beaufort, US 2020-12-12
Kyla Stalker Centerville, US 2020-12-12
Maribel Marulanda New York, US 2020-12-12 shaylah brown Charles Town, US 2020-12-12
Felipe Rodas Potsdam, US 2020-12-12
Amaji Morales Rialto, US 2020-12-12
Kalynn Holt Washington, US 2020-12-12 poop bdhkaebq San Marcos, US 2020-12-12
Aeman Fatima Midlothian, US 2020-12-12
Arianny Matos Newark, US 2020-12-12
Kiki Lia Jamaica, US 2020-12-12
Amber Ward Franklin, US 2020-12-12
Chloe Riche Woodhaven, US 2020-12-12
Kenzie Haigler Charlotte, US 2020-12-12
Lia Terraza Granada Hills, US 2020-12-12
Nicolasa Cervantes Porterville, US 2020-12-12 Name Location Date
Angel Ward-Johnson San Bernardino, US 2020-12-12
Faith Faamitai Las Vegas, US 2020-12-12
Sanem Atik El Dorado Hills, US 2020-12-12
Cadence Cordova Albuquerque, US 2020-12-12
Tracy mclaren Wright City, US 2020-12-12
Asalah Ali Orlando, US 2020-12-12
Nastajia Hamilton Manning, US 2020-12-12
Caroline Curtin Macungie, US 2020-12-12
Cassie Marshall Chesterfield, US 2020-12-12 kalon sanchez Anaheim, US 2020-12-12
Cameryn Greenough Eugene, US 2020-12-12
Monalisa Singh Austin, US 2020-12-12
Lilliana Ramirez-Smith Snellville, US 2020-12-12
Mylee Fitch Erie, US 2020-12-12
Danielle Baker Houston, US 2020-12-12
Emma Halik Whiting, US 2020-12-12
Saige Franklin Vance, US 2020-12-12
Ashley L Houston, US 2020-12-12
Alexandra Tapia Loganville, US 2020-12-12 sara naveh mason, US 2020-12-12 ava tung Westford, US 2020-12-12
Elliotte Clemente Beverly Hills, US 2020-12-12 Name Location Date clarr c Redwood City, US 2020-12-12
Ezekiel Dula High Point, US 2020-12-12
Anabel Moreland Seattle, US 2020-12-12
Jessica Pastor Linden, US 2020-12-12
Emily Huerta Whittier, US 2020-12-12
Alex Asztalos Boca Raton, US 2020-12-12
Alex Puente Mcallen, US 2020-12-12
Chloe NO Davenport, US 2020-12-12
Jimena Gonzalez Houston, US 2020-12-12 yo mama Unalaska, US 2020-12-12
Natalie Maldonado Yonkers, US 2020-12-12
Black lives Matter Berkeley, US 2020-12-12
Tre’sure Lott Detroit, US 2020-12-12
Cedar Garvin Myrtle Beach, US 2020-12-12
Lexi Garcia Stockton, US 2020-12-12 abbi royandoyan Union, US 2020-12-12
Lana Nguyen Gretna, US 2020-12-12
Soliana Mesfin Aurora, US 2020-12-12
Danielle Sheridan Elkridge, US 2020-12-12
Maddie Crum Barnesville, US 2020-12-12
Andrea Landeros Spring, US 2020-12-12
Chelsea Nunley Queen creek, US 2020-12-12 Name Location Date ginna thome Chicago, US 2020-12-12
Sheyla Gonzalez Nuevo, US 2020-12-12
Khyila Mccall Philadelphia, US 2020-12-12
Kimberly Ruiz Fayetteville, US 2020-12-12 jaylin santos South Jordan, US 2020-12-12
Natiya Natal Bethlehem, US 2020-12-12
Bailey Foster Trimble, US 2020-12-12
Kendra Juarez Los Angeles, US 2020-12-12 harley smith carmel, US 2020-12-12 jada i- Point Pleasant Beach, US 2020-12-12
Kayla Samedy Fayetteville, US 2020-12-12
Brenda Guzman Navasota, US 2020-12-12 denise jaimes Atlanta, US 2020-12-12
Aden Omane Portland, US 2020-12-12
Lexi Davidson San Francisco, US 2020-12-12
Gabby Sobczak Scottsdale, US 2020-12-12
Bella Seraydarian Newtown, US 2020-12-12
Aaliyah George Bronx, US 2020-12-12
Adriana Brazzell Valparaiso, US 2020-12-12
Jocelyn Rojo Glendale, US 2020-12-12
Keke johnson Woodbridge, US 2020-12-12 ainsley martin noneofyourbusiness, US 2020-12-12 Name Location Date
Kaylee Wills Trenton, US 2020-12-12
Aria O’Sullivan Loganville, US 2020-12-12
Julianna Perez Omaha, US 2020-12-12 myron jasper bethesda, US 2020-12-12
Veronica Gabra Huntington Beach, US 2020-12-12 maggie s Winchester, US 2020-12-12
Catie Palus Mandeville, US 2020-12-12
Alexandra Nowak Brooklyn, US 2020-12-12
Autumn Diemert Sacramento, US 2020-12-12
Esmeralda González Springdale, US 2020-12-12 azzy O Greer, US 2020-12-12
Maddie H Vancouver, US 2020-12-12
Addyson Finley Arvada, US 2020-12-12
Cassidy Truesdale Silver Spring, US 2020-12-12
Leah Newlin Gainesville, US 2020-12-12
David Vanroekel Alexandria, US 2020-12-12
Brianna Bellamy Jersey City, US 2020-12-12
Danny Graham Goleta, US 2020-12-12
Hannah Osman Denver, US 2020-12-12
Jazmin Silva Walhalla, US 2020-12-12 olivia contreras Colorado Springs, US 2020-12-12
Will Malkie Bridgeport, US 2020-12-12 Name Location Date
Bailey Linden Oakland, US 2020-12-12
Ben Fisher Boulder, US 2020-12-12
Grace Diviny Nanuet, US 2020-12-12
Kylah Cooper New Kensington, US 2020-12-12
Mirka Sanchez Grand Rapids, MI 2020-12-12
Rosi Ortega Salinas, US 2020-12-12
Sydney Branch Matteson, US 2020-12-12
Jaiden Parrish Cary, US 2020-12-12
Dayanis Zenon Paterson, US 2020-12-12 lizzie green Lake Villa, US 2020-12-12
Nicky Diaconu Roanoke, US 2020-12-12 allison recinos Port Chester, US 2020-12-12
Kayla Davis Charlotte, US 2020-12-12
Sophie Creer Fayetteville, US 2020-12-12
Karely Aguilar-Torres Sparks, US 2020-12-12 anabelle novak Oceanside, US 2020-12-12
Mariann Rojas Bronx, US 2020-12-12
C T Clayton, US 2020-12-12 phyllis muse ar, US 2020-12-12 b d Delray Beach, US 2020-12-12
Rory McConnell Pittsburgh, US 2020-12-12 lesly velasquez Bay Shore, US 2020-12-12 Name Location Date lindsay mercado Las Vegas, US 2020-12-12 alyssa bubaris Chicago, US 2020-12-12
Nariah Woods Danville, US 2020-12-12
Melanie Rose Brooklyn, US 2020-12-12
Melannie Ramírez Lynnwood, US 2020-12-12
Laura A Madison, US 2020-12-12
Jennifer Wallace Country Club Hills, US 2020-12-12 allie novy Chicago, US 2020-12-12
Daily Evans Moreno Valley, US 2020-12-12
Monserrat Peredo Renton, US 2020-12-12
Susana Ruiz Los Ángeles, US 2020-12-12
Jasmine Deabler Waldoboro, US 2020-12-12
Rihanna Orosco Brooklyn, US 2020-12-12
Hennessy Macias Surprise, US 2020-12-12 ciara no Brooklyn, US 2020-12-12
Tracy Cannon Buford, US 2020-12-12 j r dallas, US 2020-12-12
Payton Gorman Louisville, US 2020-12-12
Jahfari Francis Portland, US 2020-12-12
Kaitlyn Rainey Douglasville, US 2020-12-12
Gabby Margulies Wayne, US 2020-12-12 niyah husbands Los Angeles, US 2020-12-12 Name Location Date
Leela Williams Nashville, US 2020-12-12
Antonius Bogan Harker Heights, US 2020-12-12
Malachi Gumbs Brooklyn, US 2020-12-12
Nia Thomas Odenton, US 2020-12-12
Katie Cox Arlington, US 2020-12-12
Hayden Bedell Austin, US 2020-12-12
Sarah LaSalvia Belcamp, US 2020-12-12
Rosa Taylor Naples, US 2020-12-12
Lukas Petroski Newton, US 2020-12-12 liyah donkor Parrish, US 2020-12-12
Alexander Butcher Rochester, NY 2020-12-12
Jean Powell Lynchburg, US 2020-12-12
Lyn Smith Troy, NY 2020-12-14
Kathleen Brennan Green Island, NY 2020-12-14
Caroline Nagy Troy, NY 2020-12-14
Robert Forgett Queensbury, NY 2020-12-14
Brooklinn Britt Goodyear, US 2020-12-15 bry lack Circle Pines, US 2020-12-15
Harjap Badesha Carson, US 2020-12-15
Andrea Macias Houston, US 2020-12-15
Tamie Sheppard Albany, US 2020-12-15
Pamela Slater-Price Del Mar, US 2020-12-15 Name Location Date
Rey Mar Negrete Laguna Hills, US 2020-12-15 mya dooley Bridgeport, US 2020-12-15
Diana Grob Gresham, US 2020-12-15
Andrew Taubr Grants Pass, US 2020-12-15
Maybella Pelayo Houston, US 2020-12-15 laura roane Virginia Beach, US 2020-12-15
Talia Quady Sacramento, US 2020-12-15
Lydia Guajardo Boca Raton, US 2020-12-15
Cherina Kim Buena Park, US 2020-12-15
Austin Meinshausen US 2020-12-15
Brenda Juarez San Diego, US 2020-12-15
Nya Pine Austin, US 2020-12-15
Holly Herrera Albuquerque, US 2020-12-15
Ashley Rojas Sacramento, US 2020-12-15
Saige Scott Buckhannon, US 2020-12-15
Amelfis Zorrilla Peekskill, US 2020-12-15
Jennie Tea Long Beach, US 2020-12-15
Brittany Watler los angles, US 2020-12-15
Jessica Oreus Orlando, US 2020-12-15 alyssa munoz El paso, US 2020-12-15
Marissa G Harvey, US 2020-12-15
Destiny Capunay Elmont, US 2020-12-15 Name Location Date alexa Wohlwinder Alamogordo, US 2020-12-15
Mickey Parker Stevensville, US 2020-12-15
Joseph Schmidt Southampton, US 2020-12-15
Kristin Green Los Angeles, US 2020-12-15
Destiny Silva Los Lunas, US 2020-12-15
Lucy Rae Berthoud, US 2020-12-15
Evelyn Alejo Redwood City, US 2020-12-15
Aditi Joshi Dublin, US 2020-12-15
Liana Kinder Fort Lauderdale, US 2020-12-15
Grace Gozal Warren, US 2020-12-15
Jenna Thompson Menifee, US 2020-12-15
Shawn McNeil Roanoke, US 2020-12-15 laura raforth rochester, US 2020-12-15
Faith Levasseur Hudson Falls, US 2020-12-15
Annabelle Hardy Cottage Grove, US 2020-12-15
David Thorpe Liverpool, US 2020-12-15
Celeste Williams Brandon, US 2020-12-15
Brianna Prieto Pacoima, US 2020-12-15
Kim Conolly Marietta, US 2020-12-15
Mary Belieu Santa Rosa, US 2020-12-15
Jacob Steinberg Petaluma, US 2020-12-15 get james Arlington, US 2020-12-15 Name Location Date icy girl San Pedro, US 2020-12-15
Shaun Borges Sacramento, US 2020-12-15
Mat Bridgington Milford, US 2020-12-15
Samantha Cabrera Valencia, US 2020-12-15
Percival Rodriguez South Gate, US 2020-12-15
Logan McCarl Minneapolis, US 2020-12-15 valerie harmon Woonsocket, US 2020-12-15
Joshua Valdez Riverside, US 2020-12-15
Alejandta Melgoza Los Angeles, US 2020-12-15
Ryanne Cunningham Boise, US 2020-12-15 yulie torres Newport News, US 2020-12-15 patrick grace Torrance, US 2020-12-15
Kirsten Mills Fowlerville, US 2020-12-15
Samantha Nettles Hernando, US 2020-12-15
Faith shishkin US 2020-12-15
NOT TELLING Reston, US 2020-12-15
Sophia Jacobson South Orange, US 2020-12-15
Emily Compas Omaha, US 2020-12-15
Samantha Torres Red Oak, US 2020-12-15
Alyssa Jacobsen Buffalo, US 2020-12-15
Michelle Dalton Pikesville, US 2020-12-15
Ally Albarran Chicago, US 2020-12-15 Name Location Date
Evan Vandenbossche Port Huron, US 2020-12-15
Sara Miguel Clovis, US 2020-12-15
Ariana Hobbs Dearborn Heights, US 2020-12-15
Vanelyn Guzman Methuen, US 2020-12-15
Madyson Beaver Harrison, US 2020-12-15
Maeve Warme Waterville, US 2020-12-15
Christina Johnson Bakersfield, US 2020-12-15
Brooke Cortus Raymore, US 2020-12-15
Margaret Malejko Westampton, US 2020-12-15
Krystal delgado El Paso, US 2020-12-15
Jamie Roush Spring Hill, US 2020-12-15 hailey nguyen Santa Ana, US 2020-12-15
Olivia Bill Buffalo, US 2020-12-15
A. Carcellar Los Angeles, US 2020-12-15
Brady Daye Brentwood, US 2020-12-15
Lily Barton Post Falls, US 2020-12-15
Ruby Cervantez Burbank, US 2020-12-15
Nubia Garcia Los Angeles, US 2020-12-15
Kalei Kealoha Honolulu, US 2020-12-15
Keegan Patton Trenton, US 2020-12-15
Bridget Whalen Avon, US 2020-12-15
Monica Rodriguez Canyon Lake, US 2020-12-15 Name Location Date
Kari Michaels Kingman, US 2020-12-15 denisse chaires Fort Worth, US 2020-12-15
Ariana Heffington Edmond, US 2020-12-15
Erin Case La Center, US 2020-12-15
Aryanna Price Springfield, US 2020-12-15 sarahi villa san mateo, US 2020-12-15 isabella brodeur Temecula, US 2020-12-15
Maddie Lange Brenham, US 2020-12-15
Kylee Deavers Goshen, US 2020-12-15
Vivia n Honolulu, US 2020-12-15 america lister Amarillo, US 2020-12-15
Myla Dayanghirang Bakersfield, US 2020-12-15
Hwhw Hshshe Las Vegas, US 2020-12-15
Alysa Wooton Russell Springs, US 2020-12-15
Diane Espejel Santa Ana, US 2020-12-15
Courtney Sanco Santa Ana, US 2020-12-15
Devon Stanback Alpharetta, US 2020-12-15
Soffie Gabriel Tacoma, US 2020-12-15
Carla Perez Owings Mills, US 2020-12-15
Riley Plumley Coffeyville, US 2020-12-15
Rachel Loui Mountain View, US 2020-12-15
Jonathan Deikman San Carlos, US 2020-12-15 Name Location Date
Jasmine Meyer Houston, US 2020-12-15
Aaliyah Eguia Athens, US 2020-12-15
Megan Mahoney Denver, US 2020-12-15
Michaela Maier Anaheim, US 2020-12-15
Priscilla Sanchez Anaheim, US 2020-12-15
Alexandra Bouselli Alexandria, US 2020-12-15
Michelle Gutierrez Garland, US 2020-12-15
Kevin Lam El Monte, US 2020-12-15
Carla Villa North Las Vegas, US 2020-12-15
Ava Kiefel Walla Walla, US 2020-12-15
Abbie Mastromanno Phoenix, US 2020-12-15
Dina Kulybchuk Kent, US 2020-12-15
Amelia Francis Juneau, US 2020-12-15
Rowyn Phillips Culpeper, US 2020-12-15
Eric Barger Belleville, US 2020-12-15
Yukti Sharma Somerville, US 2020-12-15
Katherine Valdivieso Marysville, US 2020-12-15
Aniyah Blum Lehigh Acres, US 2020-12-15
Regan Clayton Buffalo, US 2020-12-15
Jamison Walstrum Baltimore, US 2020-12-15
Jackie Ms Oregon, US 2020-12-15
Reonna McCoy Beloit, US 2020-12-15 Name Location Date
Laura Escudero El Paso, US 2020-12-15
Mia Galvan San Jose, US 2020-12-15
Emma Goldman Troy, NY 2020-12-15
Jaydy Ramirez Norcross, US 2020-12-15
Alissa Conant Victoria, US 2020-12-15
Joseph DiMaggio Highfield-Cascade, MD 2020-12-15
Leatha Jimerson Delray Beach, FL 2020-12-15
William Denny Delray Beach, FL 2020-12-16
Sara DiLeo US 2020-12-16
Richard Murdock BALLSTON LAKE, NY 2020-12-16
Gracie Alms New Orleans, US 2020-12-16 river bolyard Fairmont, US 2020-12-16
Hollie Sisemore King George, US 2020-12-16
Emma Hickman South Point, US 2020-12-16
Kathryn Mueller Loveland, US 2020-12-16
Wade Potato La La Land, US 2020-12-16
Luna Hernandez Coachella, US 2020-12-16
Emilia Herrera New Caney, US 2020-12-16 kimora santos Sacramento, US 2020-12-16
Amy Brown California, US 2020-12-16
C S Malvern, US 2020-12-16
Kim jiwoo Kimjiwoo Los Ángeles, US 2020-12-16 Name Location Date
Teresa Van Aernam Irving, NY 2020-12-16
Erin Buxton Atlanta, GA 2020-12-16
Sabra Mullins Chapmanville, WV 2020-12-16
Deborah Matheson Troy, NY 2020-12-16
Brenda Haskell Malta, NY 2020-12-16
Tami Watt Salamanca, NY 2020-12-16
Laura Mullins Hartland, MI 2020-12-16
Heidi Brower Troy, NY 2020-12-17
Anya Lever Troy, NY 2020-12-17
Shawn Pollack Troy, NY 2020-12-18
Tasheca Medina Troy, NY 2020-12-19
Don Rittner Schenectady, NY 2020-12-20
Lambert Jimerson Versailles, NY 2020-12-21
Kay Hebert Schenectady, NY 2020-12-21 m f New York, NY 2020-12-22
Christianna Bennett Troy, NY 2020-12-22 katelyn del rosario Cypress, US 2020-12-22
Melissa Spiegel New York 2020-12-23
Jessica Jenkins Berkeley, CA 2020-12-23
Haley Morgan Greenfield, MA 2020-12-23
Jen Kutler Hudson, NY 2020-12-23
Sherie Ruppersberger Philadelphia, PA 2020-12-23 Name Location Date
Brylee Schroder Albany, NY 2020-12-24
Erin Sickler Troy, NY 2020-12-24
Emily Mendelsohn Brooklyn, NY 2020-12-24 lisa schonberg Troy, NY 2020-12-24
Allison Joseph Troy, NY 2020-12-24
Christina Gesualdi Philadelphia, PA 2020-12-24
Brian Gilchrist Rensselaer, NY 2020-12-24
Michelle Wenderlich Canandaigua, NY 2020-12-24
Julia Cavicchi Brattleboro, VT 2020-12-24
Tina Toma Troy, NY 2020-12-24
Melissa Morgan Westminster, US 2020-12-24
Rachelle Smith-Stallman Albany, NY 2020-12-24
Jay Zimmerman Wichita, US 2020-12-24
Mouse � Brooklyn, US 2020-12-24
Michelle Dail Hampton, US 2020-12-24
Leyna Wittl Shakopee, US 2020-12-24
Alysa Corbin Greenwood, US 2020-12-24
Justin Kaufman Fort Wayne, US 2020-12-24
Ayla Noller Phoenix, US 2020-12-24
Nicolle Singh Wentzville, US 2020-12-24
Steve Kennedy Smith Schenectady, NY 2020-12-24
Hamilton Craig Shushan, NY 2020-12-24 Name Location Date
Emelia Martinez Brumbaugh fairhaven, MD 2020-12-24
Dashiell Chrisner New York, NY 2020-12-27
Alex Briggs Queensbury, NY 2020-12-28
Kim Parker Albany, NY 2020-12-28
Jessica Holtz Albany, NY 2020-12-28
Ashley Saupp Troy, NY 2020-12-28 SUBMISSION OF SUPPLEMENTARY EVIDENCE REGARDING PROPOSED DEVELOPMENT OF TAX PARCEL 70.64-1-1 AT 1011 2ND AVE AND THE ASSOCIATED REQUEST FOR CHANGE OF ZONING CODE
RESUBMISSION FOR CITY COUNCIL MEETING ON SEPTEMBER 10
TO: The Members of the Troy City Council Planning Committee, The Troy Planning Commissioner The Members of the Troy City Council at large.
This letter is submitted in the name of: The Friends of the Mahicantuck The Center for Climate Communities The Schaghticoke First Nations
REGARDING: RES91 - Resolution Referring Lansingburgh Zoning Change Request to Planning Commission for Review and Recommendation — SUBMISSION OF SUPPLEMENTARY EVIDENCE
Dear Members of the Troy City Council Planning Committee, Dear Planning Commissioner and members of the Planning Commission Dear Members of the Troy City Council at large.
In this letter we lay out for your consideration critical evidence that clearly shows that a change in zoning code from R-1 to P for Tax Parcel 70.64-1-1 is not compatible with the law, regulations, city code, comprehensive plan, as well as the responsibilities of the council in considering a change in zoning code.
As you are aware, any consideration of a change in zoning code must incorporate that such a change has to be: ● consistent with the comprehensive plan, which it is inot ● in the interest of the current residents of the city, and not the developer or imagined future residents ● consistent with the surrounding use and zoning
The attached evidence, discussed in this letter, shows explicitly how a change in rezoning is inadmissible on six critical grounds, and therefore a change in zoning code is incompatible with the law.
Therefore we strongly urge you to VOTE AGAINST the unnecessary referral of this matter to the Planning Commission and stop this development now.
With best wishes The Friends of Mahicantuck on behalf of a broad coalition of concerned residents The Schaghticoke First Nations The Center for Climate Communities
1
TABLE OF CONTENT AND OVERVIEW OF SUPPLEMENTAL EVIDENCE, ORGANIZED IN SIX SECTIONS
This letter provides an overview of supplemental evidence submitted along with this letter in the name of the above mentioned organizations. It provides the Troy City Council Planning Committee, the Planning Commissioner and the members of the Troy City Council at large with supplemental evidence for consideration of RES91, for consideration of the request for change in zoning code for Tax Parcel 70.64-1-1 from R-1 to P, and for consideration regarding the development on this parcel, as proposed by Kevin Vandenburgh.
This letter, and the supplemental evidence included with this letter, are organized in SIX (6) major sections, each constituting a respective grounds for denying the request for zoning. The collection of this evidence makes explicit that the rezoning request must not be granted, and therefore a referral to the Planning Commission becomes obsolete.
Overview Of Sections ……………………………………………………………….... p. 3 1. Historical and Archeological Grounds ………………………………………………. p. 5 2. Environmental and Public Health Grounds ……………………………………….... p. 7 3. Inconsistency with Troy 2018 Comprehensive Plan ..……………………………... p. 11 4. Economic Grounds ………………………………………………………………….... p. 14 5. Community Impacts, Public Service Impacts, Infrastructure Impacts ……...... P. 17 6. Legal Grounds ………………………………………………………………………... p. 20 7. Summary Alternative Use Proposal ……………………………………………….. p. 22 Appendix: List of Supplemental Evidence …………………………………………. P. 23
This letter discusses the supplemental evidence for each section, providing specific supplemental evidence for consideration regarding RES91 and the requested change in zoning code for Tax Parcel 70.64-1-1 from R-1 to P.
The letter and the presented evidence — individually and in conjunction — clearly show that: - There are significant and exhaustive grounds to DENY changing the zoning code for Tax Parcel 70.64-1-1 from R-1 to P; - That therefore there is NO JUSTIFICATION AND NO NECESSITY to refer the request for zone change to the Troy Planning Commission - And that therefore RES91 should NOT BE PASSED.
2 OVERVIEW OF MAJOR GROUNDS FOR DENYING THE REQUEST FOR CHANGE IN ZONING CODE, FOR EACH OF THE SIX SECTIONS
SECTION 01: Historical and Archeological Grounds This letter and supplementary evidence discusses the historical and archeological grounds for denying the change in zoning code for Tax Parcel 70.64-1-1.
It highlights the historical-cultural and archeological significance of the property in question. - It provides supplemental evidence that shows insufficient due diligence regarding the assessment of the cultural relevance of the site, - It highlights the currently undergoing review of the site for its eligibility to be included in the National Register - It shows the necessity of a DEC SPEDES permit as well as the requirement for additional archeological surveys - And it highlights the risk for loss of an important historical site to the community of Troy.
Based on the provided evidence, a change in zoning code must be denied due to the negative impact on the historical and archeological heritage of the City of Troy.
SECTION 02: Environmental and Public Health Grounds This letter and supplementary evidence discusses the environmental and public health grounds for denying the change in zoning code for Tax Parcel 70.64-1-1.
It highlights the environmental and public health impacts associated with a rezoning and the proposed development of the site in question. - It shows significant environmental and ecological harm associated with the destruction of the last riverfront forest in Troy, NY. - It clearly identifies inconsistencies regarding environmental preservation and waterfront development priorities laid out in the Comprehensive Plan - It highlights the public health risks associated with runoff-pollution, impacts on the Hudson River, and the loss of the forest as a natural resilience asset.
Based on the provided evidence, a change in zoning code must be denied due to adverse impact on public and environment as well as due to inconsistencies with the Comprehensive Plan.
SECTION 03: Inconsistency with Comprehensive Plan This letter and supplementary evidence discusses critical inconsistencies with the 2018 comprehensive plan, constituting critical grounds for denying the change in zoning code for Tax Parcel 70.64-1-1.
It also points to critical legal decisions underscoring the requirement for any change in zoning code to be consistent with the comprehensive plan.
It discusses the issue of spot zoning as a major legal grounds for denying a rezoning that directly relates to inconsistencies with the comprehensive plan.
Based on the provided evidence in this letter, a change in zoning code must be denied due to explicit inconsistencies with the 2018 comprehensive plan.
3 SECTION 04: Economic Grounds This letter and supplementary evidence discusses the negative economic impacts of the proposal as grounds for denying the change in zoning code for Tax Parcel 70.64-1-1.
It highlights the direct and indirect as well as short- and long-term economic costs associated with the proposed development. It explicitly shows that the proposed development will NOT provide the promised increase in tax revenue and instead significantly increase the economic costs for the City of Troy and its tax paying residents.
In particular, costs associated with increased pressures on the public school system, road maintenance, emergency services, garbage collection and the already dramatically strained sewage system, will increase the costs for the city far above the expected short-term revenue associated with the development of this site.
We calculate that this development will lead to an increased combined REVENUE LOSS for the city and school district of AT LEAST $500,000 ANNUALLY
Based on the provided evidence in this letter, a change in zoning code must be denied, as 1) the Economic Viability and Burden Criteria is not met, as 3) the development will negatively impact local property values, and as 2) there is no clear economic benefit to the current residents of the City of Troy.
SECTION 05: Community Impacts, Public Service Impacts and Infrastructure Impacts According to NYS law, a change in zoning code must be in the interest of the public: the CURRENT (and not imagined future) residents. A change in zoning must not be solely for the benefit of the developer. Finally, according to NYS law, a change in zoning code must also be consistent with the comprehensive plan and consistent with current use and character of the neighborhood. This is also explicitly stated as such in Troy’s comprehensive plan.
This section explains how this development and the proposed change in zoning code is violation of all the above mentioned criteria. The section shows how it will NEGATIVELY impact the local neighborhood and community, how it will increase costs and negatively affect public services and infrastructure and how it will be against the interest of the residents of Troy.
SECTION 06: Legal Grounds This letter and supplementary evidence discusses the legal grounds for denying the change in zoning code for Tax Parcel 70.64-1-1.
It summarizes the legal implications of the evidence provided in the letters number 02 to 07 and foregrounds the legal grounds that make the proposed change in zoning code inconsistent with existing federal, state and city law. This includes: Spot Zoning, Economic Burden Criteria, Public Interest Criteria, Inconsistency with the 2018 Comprehensive Plan, Lack of Evident Need for Zoning Change, Inconsistency with Existing Zoning and Surrounding Uses, Inconsistency with the Orderly Development of Public Service and Infrastructure
Based on the provided evidence in this letter, a change in zoning code must be denied as it is incompatible with existing federal, state and municipal legal regulations, statutes and codes.
4 SECTION 1: HISTORICAL AND ARCHEOLOGICAL GROUNDS
SECTION 1 — A: Historical Significance of Parcel 70.64-1-1
The historical and archeological analysis provided in the submitted evidence (see Section 1-C) reveals a consistent academic consensus about the historical, archeological and cultural significance of this site, particularly regarding the Mahican peoples but also pre-historic communities that utilized this site as early as 1600-3000 B.C. [S1-4]
Several archeological studies have been conducted on this land, with one of the first most significant studies dating back to the 1980ies [S1-1] [S1-2]. The existing reports, studies and academic publications all consistently conclude that the land in question is of high historical and archeological significance, and that the found artifacts justify the registration of this land in the national registry.
This has also been confirmed in personal correspondence with a lead archeologist involved in the recent 2020 survey provided as part of the SEQRA analysis. The report was not yet made available to the public.
According to these studies, the sites contain significant amounts of prehistoric and historic archeological artifacts. The scientific consensus agrees that this site is of high historic, archeological and cultural significance.
Amongst the artifacts are countless significant ones of members of the Mahican peoples, but also important finds ranging back to prehistoric times. The site was used by the Mahican people as a quarry and tool making site. The site was also identified as the location of semi-permanent and potentially permanent settlements. Some of the studies also mention strong indications for burial sites [S1-3].
The EPA cultural resource survey associated with the 2002 Record of Decision relating the Hudson River remediation [S1-3] also emphasizes the historical-cultural and archeological significance of this site and notes the need for further study of this site for the future — which has not been independently conducted to this date. This report also states the high likelihood of unrecovered extensive archeological resources on this site.
Finally, two previously unrecovered reports associated with the site as well as a second in immediate proximity — both referred together as the Pleasantdale Quarry — explicitly identify the sites as historically and archeologically critical and positively review the archeological record associated with these sites as eligible for the National Register [S1-4].
One of these reports, referenced and thereby submitted as evidence in the record [S1-4] was authored by Hetty Jo Brumbach, Paula Zitzler, the Public Archeology Facility and Rensselaer Polytechnic Institute and discusses the “potential eligibility for nomination to the National Registry of Historic Places” ([S1-4], p 1).
On S1-4, page 81, the authors explicitly state that: “Stage II survey recovered adequate data to determine that the prehistoric site … appears to meet the criteria for eligibility to the National Register of Historic Places. [...] disturbance to the site has been minimal. Very little artifact collection has taken place and few of the residents are aware of the
5 presence of the prehistoric material. Thus, unlike some quarry locations of the Hudson Valley, the site has not been depleted by collectors”
And continue: “The site also has the potential for providing unique information pertaining to regional prehistory since it is one of the few professionally reported and investigated archaeological sites in Rensselaer County. Thus, the site is capable of yielding information important in prehistory.”
Based on these reports, the site's unique importance becomes explicit and it becomes clear that the preservation of this site is critical. It also makes clear that its development would lastingly destroy this site and rob the city and its people of a major aspect of its history.
An application for review regarding the eligibility of this site for the National Register is currently in the beginning steps, with first evidence filed on August 24, 2020 with NYS SHPO . Additional supplemental evidence is being sent to SHPO over the course of the next weeks.
SECTION 1-B: Legal Implications According to state and federal law, a DEC SPEDES permit is necessary associated with the ground disturbance of this project exceeding one acre. Other state and federal agency permits or funding may also trigger SHPO involvement.
A coordinator of the SHPO Archeology Unit Program confirms this, stating in official correspondence from August 12, 2020 regarding the site:
“Given the archaeological sensitivity of 1011 2nd Street, the SHPO will likely request an archeological survey to document archaeological sites that are located within this project area, if a survey has not already been undertaken.”
The requirement of Section 106 of the National Historic Preservation Act [S1-5] and Section 14.09 of the State Historic Act [S1-6] is that project impacts to National Register eligible or listed sites are avoided, reduced or mitigated. Mitigation may involve additional archaeological surveys.
SECTION 1 — C: List of Supplemental Evidence for Section 1: ● [S1-1] Brumbach, H.J. (1987) “A Quarry/Workshop And Processing Station On The Hudson River In Pleasantdale, New York”. Archeology of Eastern North America, 15(1987), 59-83. ● [S1-2] Lothrop, J. C., Burke, A. L., Winchell-Sweeney, S., and G. Gauthier (2018). Coupling Lithic Sourcing with Least Cost Path Analysis to Model Paleoindian Pathways in Northeastern North America. American Antiquity, 83(3), 462-484. ● [S1-3] US EPA (2002). Responsiveness Summary Hudson River PCBs Site Record of Decision. Appendix C Stage 1A Cultural Resource Survey. ● [S1-4] Brumbach, Hetty Jo, Zitzler, Paula (1993) Stage II Archeological Investigation Of the Turnpike/River Bend Road Area. Pleasantdale Wastewater Facility Plan. Town Of Schaghticoke, Rensselaer County, New York (C-36-1270-01). Public Archaeology Facility, Rensselaer Polytechnic Institute. [Hard Copy Available]. ● [S1-5] National Historic Preservation Act ● [S1-6] State Historic Act
6 SECTION 2: ENVIRONMENTAL AND PUBLIC HEALTH GROUNDS
There are several environmental impacts that constitute direct and indirect public harm associated with the proposed rezoning of Parcel 70.64-1-1 — and the proposed development of the site. These will also have significant consequences for public health, the city’s climate and extreme weather resilience, and the city’s revenue.
Critically, this development and the associated change in zoning code will: - lead to increased floor sealment with concrete and hence increased run-off pressures - increase pressures on the already strained sewage system - lead to further channelization of the Hudson, already leading to increased flood risks, will be further increased with this development — leading to increased flood hazards for downstream properties across the city. The location of this property in particular will severely increase flood risks for the entire city. - cause significant loss of forest and natural waterfront will increase other critical hazards, including urban heat, runoff pollution, air pollution and their severe impacts on public health
These consequences and impacts stand in direct conflict with the 2018 Comprehensive Plan [A], with critical efforts underway through the city’s participation in the Climate Smart Communities Program, and with legal provisions constituted in state and city law and code.
Additionally, the development does not adhere to critical provisions for waterfront protection and renaturalization established in existing code as well as in the additional zoning logics established in the comprehensive plan (which a change in zoning code must adhere to). Particularly, this regards setback and new waterfront shoreline provisions associated with the comprehensive plan.
SECTION 2 — A: Environmental Impacts of Change of Code for Parcel 70.64-1-1
1) SEWAGE OVERFLOW The city’s sewage and water management infrastructure is already at capacity. In the last years, Troy was in violation of state reporting laws in association with massive sewage overflows [S2-1] leading to significant cost for the community. In fact, Troy is the worst polluter in regards to overflows in the region.
The city itself acknowledged that “Unfortunately, sewer overflow events are fairly routine for shoreline communities like Troy.” [S2-2]
It is in this context that the proposed development and its impacts on the loss of this land will significantly escalate this already urgent emergency. The location of the site at the very north of the city, combined with its size and its impact on the city’s sewer system will lead to significant environmental and monetary costs for the city and all its residents.
2) SOIL EROSION, RUNOFF AND FLOOD RISKS The property is directly adjacent to the Hudson; This means development impacts on this land will significantly affect the flood resilience of Troy, particularly due to its location upstream of the entire city (last property before the city line); The undeveloped higher elevation provide additional protection against runoff and to the integrity of the areas of the land that comprise a flood zone. Studies show the importance of such natural assets in runoff protection [S2-3]
7
The development will significantly increase runoff pollution [S2-4] through the loss of water absorbing forest and forest soils and the use of impervious material as well as the associated increased traffic and pollution. This only constitutes [S2-5] an increased threat of environmental harm on surrounding communities, downstream communities and the Hudson river itself.
3) CHANNELIZATION, RESILIENCY, FLOODING AND RUNOFF Natural, forested spaces are a critical asset to the city’s environmental and climate resilience [S2-6] [S2-7]. This area, upstream of the entire city, significantly protects the city from flooding directly (as a buffer flood zone for flooding) and indirectly by preventing runoff and maintaining the integrity of the river bank [A, p. 16]. The development of the site in the proposed form would significantly interfere with the ability of this land to absorb runoff and protect the city from river pollution and flooding.
Studies well-establish that developments, such as the proposed, and the associated displacement of natural waterfront and channelization significantly increase river flood risks downstream [S2-8; S2-9; S2-10]. The direct effects of sedimentary flow and associated environmental degradation of the Hudson River additionally exacerbate the increase of flood risks downstream at other areas across the City of Troy and other communities along the Hudson River.
This is also acknowledged in the comparative plan [A], which states
“The majority of the Hudson River shoreline south of the Collar City Bridge has been channelized, which has interrupted or removed natural ecosystems. Due to this activity, sediment from the Hudson River is no longer deposited on the banks, and limited habitat is available for fish and wildlife species” (p. 16)
According to [A] the New York State Department of Environmental Conservation (NYSDEC) estimates that by 2080 the City of Troy could face over 3 feet of sea-level rise on the tidal Hudson River due to global climate change. Rainfall events are also expected to become less predictable, more extreme, and occur in the form of heavy downpours or extended droughts. The elevation of the 100-year floodplain and the city’s history of extreme flooding suggest that the threat of damage to and loss of property is heightened due to anticipated climate change.
4) ECOSYSTEM IMPACTS Biodiversity and Ecological Loss: This is one of the last undeveloped natural waterfronts in Troy. It serves as a major biodiversity refuge in the otherwise urban area; Disturbance or complete destruction would mean the irrevocable loss of the last such space in the City of Troy. Increased traffic, disturbance and pollution: Development of the land will increase the traffic, both to and on the land; Even if the development includes public access to untouched parts of the land, the 200 units alone will significantly increase the use of the land, leading to the disturbance of the ecosystem, increased pollution of the land, as well as the Hudson River;
5) PUBLIC HEALTH IMPACTS Associated with the above mentioned environmental impacts are major impacts on public health associated with the proposed development and the proposed change in zoning code.
8 Urban Heat Island Forested areas serve as “natural air conditioning” for the surrounding communities in urban centers and provide a natural refuge and relief from oppressive summer heat; a climate risk that is anticipated to significantly increase for the city of Troy and already constitutes a major public health threat today.. Development, even if major parts of the forest would not be destroyed, would significantly impact the accessibility and functioning of this critical asset [S2-11]. A recent article published in the New York Times (August 24, 2020) [S2-12] discusses the direct relationship between health, income and racial disparities in relationship to exposures to extreme heat in the urban context.
Air Quality will be negatively impacted, both directly and indirectly. The increased traffic associated with the development will diametrically impact the air quality of this neighborhood. Additionally, the loss of tree and natural space will further exacerbate air quality loss [S2-13].
Noise Pollution — as a R1 zone, the rezoning will significantly increase noise levels due to increased population density, increased traffic and the loss of green space as natural noise shield; this will significantly disrupt the character, but also the health of the otherwise characteristically quiet neighborhood.
SECTION 2 — C: Legal Implications
A rezoning of this parcel would allow for a large scale development of the site that ultimately would destroy the environmental and ecological resource of the last undeveloped forest along the Hudson in the entire city of Troy.
In the current zoning as R-1 single family residential, detached, the environmental impact of potential development — while still extraordinarily adverse — would be significantly limited in comparison to the full-scale development that a rezoning to P Planned Development would make possible.
In the lack of a better protection of the parcel and a lasting environmental and historic preservation, maintaining the current code R-1 is the best bet to avoid negative impacts on this critical ecological and environmental asset and its interactions with the Hudson River.
For these reasons, the proposed rezoning and development stand in direct conflict with legal grounds for a rezoning, including cost-benefit analysis of harm to the public/public benefit. Additionally, it constitutes explicit inconsistency with the 2018 Comprehensive Plan [A] as well as the participation of the City of Troy in the Climate Smart Communities Program and the associated “pledge” passed as resolution by the City of Troy [S2-15].
Inconsistency with Comprehensive Plan and Spot Zoning There are major inconsistencies with the Troy Comprehensive Plan of 2018, rendering the rezoning inconsistent with law. This is particularly in reference to the NYS legal requirement to maintain consistency with the Comprehensive Plan for any proposed change in zoning code.
The comprehensive plan calls explicitly for the renaturalization of the waterfront, the preservation and expansion of the tree canopy, and the protection of natural and open spaces in the city (cp. Section 3).
9 The assessment provided by the developer regarding wetlands and flood zone are incomplete and at times omit critical facts. Map 12 [S2-15] of the Troy Comprehensive plan clearly shows that about 40% of the proposed development area are within 100 year and 500 year flood zones, respectively.
It is important to note that these maps date from 1980 and therefore do not take into consideration the requirements to incorporate climate changes into planning, constituted in NYS law as well as the Climate Smart Communities program participation.
Additionally, the Comprehensive Plan designates the development area as a new coastal boundary, which is associated with additional SEQRA requirements, and is to be classified as a Type I action.
Harm to the Public and the Environment Associated with the Proposed Development The attached supplemental evidence clearly shows negative impacts on the environment and public health. This is significant grounds to NOT grant the sought change of the zoning code.
Additionally, the environmental impacts — particularly in the context of sewage overflow and increased flood risks — will significantly negatively impact the city revenue.
SECTION 2 — D: List of Supplemental Evidence for Section 2: ● [S2-1] Times Union (July 7, 2017) “Massive Albany Troy Sewage Spills in Hudson https://www.timesunion.com/7dayarchive/article/Massive-Albany-Troy-sewage-spills-in-Hudson-1 1273421.php ● [S2-2] Statement of City of Troy: “Understanding Tory’s Combined Sewer Infrastructure System” July 10, 2017 http://www.troyny.gov/understanding-troy-combined-sewer-infrastructure-system/ ● [S2-3] Conservation Tools: Working With Nature to Manage Stormwater https://conservationtools.org/guides/166-working-with-nature-to-manage-stormwater ● [S2-4] DOS: Impacts of Urban Runoff https://www.des.nh.gov/organization/divisions/water/wmb/tmdl/documents/stormwater_chapt1.pdf ● [S2-5] https://pubs.er.usgs.gov/publication/wri014071 ● [S2-6] Urban Forests and Climate Change https://climate-woodlands.extension.org/urban-forests-and-climate-change/#:~:text=Urban%20for ests%20can%20be%20useful,to%20heat%20and%20cool%20buildings. ● [S2-7] USDA Urban Forests and Climate Change https://www.fs.usda.gov/ccrc/topics/urban-forests-and-climate-change ● [S2-8] National Management Measures to Control Nonpoint Source Pollution from Hydromodification https://www.epa.gov/sites/production/files/2015-09/documents/chapter_3_channelization_web.pdf ● [S2-9] Problems Facing Urban Streams http://www.msdlouky.org/insidemsd/wqurban.htm ● [S2-10] From Channelization To Restoration http://scholar.google.com/scholar_url?url=http://www.academia.edu/download/43058958/Chen_et _al-2016-Water_Resources_Research.pdf&hl=en&sa=X&scisig=AAGBfm3QW_VCYsUVIg_vciK WvVRiz7HOaQ&nossl=1&oi=scholarr ● [S2-11] EPA: Reduce Urban Heat Island Effect https://www.epa.gov/green-infrastructure/reduce-urban-heat-island-effect
10 ● [S2-12] NYT: How Decades Of Racist Housing Policy Left Neighborhoods Sweltering https://www.nytimes.com/interactive/2020/08/24/climate/racism-redlining-cities-global-warming.ht ml ● [S2-13] Benefits of Urban Trees https://www.nature.org/content/dam/tnc/nature/en/documents/Public_Health_Benefits_Urban_Tre es_FINAL.pdf ● [S2-14] CSC Certification Troy http://csc-site-persistent-prod.s3.amazonaws.com/fileadmin/cicbase/documents/2017/11/10/1510 3445909908.pdf ● [S2-15] Comprehensive Plan Map 12
SECTION 3: INCONSISTENCIES WITH COMPREHENSIVE PLAN
SECTION 3 — A: Major Inconsistencies with Comprehensive Plan
The proposed development as well as the change in zoning code are inconsistent with Realize Troy 2018 Comprehensive Plan [A]. This is relevant for the consideration of the request for change in zoning code, as such a change cannot occur if it is inconsistent with the comprehensive plan.
New York’s zoning enabling statutes require that zoning laws be adopted in accordance with the comprehensive plan. The comprehensive plan should provide the backbone for the zoning law [S3-1]. Furthermore, the change in zoning code is incompatible with New York State City Code Section 28.a.12 [S3-2]: Effect of Adoption of the City Comprehensive Plan: (a) “All city land use regulations must be in accordance with a comprehensive plan adopted pursuant to this section.”
Developing the land is in explicit inconsistency with the 2018 Troy Comprehensive Plan AND THEREFORE CANNOT QUALIFY FOR REZONING
Listed are only some of the most striking conflicts with major sections and goals of the comprehensive plan: 1) Requirement to protect green spaces and environmental assets The Comprehensive Plan explicitly states that green spaces and environmental assets have been impacted by industrial and urban development — and need better protection.
“Troy is endowed with a spectacular natural environment– from magnificent gorges, an expansive riverfront, to a wide array of mature open spaces. In recent years, these areas have been impacted by industrial and urban development and need to be better protected to sustain the environmental health of the city.” ([A], p. 16)
With the REALIZE TROY 2018 Comprehensive Plan, the City of Troy has explicitly designated specific goals to preserve greenspaces, parks, open spaces and natural habitats. These rules were explicitly designed to protect spaces such as the property in question from development. So does the
11 Comprehensive Plan explicitly set out to protect critical natural features of Troy’s waterfront, including this property.
2) Inconsistency with Goal 5 of the Comprehensive Plan
A change in zoning code is inconsistent with GOAL 5 of the Comprehensive plan. The Comprehensive Plan explains: “Existing ecological resources including wetlands and shoreline habitat shall be protected, preserved and enhanced”. However, this development would do the opposite and destroy the last remaining undeveloped natural shoreline of the city.
In this context, the comprehensive plan defines specific requirements, objectives and underlying strategic goals in zoning and developing the City of Troy, its greenspaces, natural habitats and the waterfront. The proposed development and the request for change in zoning code stand in explicit contradiction and therefore are inconsistent with the comprehensive pan.
The plan states that the City of Troy will require implementation of flood protection standards for new buildings within the flood zones that are consistent with the guidelines established by the Federal Emergency Management Agency (FEMA).
A large section of the property lies in flood zones (see Section 2): About 50% of the land is within the waterway and flood area, as displayed in Map 13 of the Comprehensive plan [S3-3]; the plan prohibits major development in that area. Additionally, the land is — with exception of approx. 2 acres — inside the new Landward Coastal Boundary, established in the 2018 Comprehensive plan. Accordingly:
● All development will be set back a minimum of 100 feet from watercourses and wetlands identified on Map 13 in Comprehensive Plan (page 60), to help prevent adverse impacts on these natural assets. ● Only 2 acres can be developed outside this 100ft zone, this only regards R-1 houses. ● The rest of this property is within 100 feet of watercourses and wetlands and is classified as a Type I action pursuant to the StateEnvironmental Quality Review (SEQR) process, increasing the level of environmental review necessary to protect their integrity. ○ The entirety of the land is in the waterfront area (map 13). Any new development in that area that is 500 square feet or greater requires the submission of a construction management plan that demonstrates that the development will not compromise the Hudson riverbank.
The plan also calls for the shoreline to be naturalized to provide greater resiliency during significant flood events — the proposed change in zoning code will result in channelization of the Hudson River and therefore stands in direct conflict with the comprehensive plan.
According to the plan the city’s urban tree canopy will be grown and maintained by expanding tree planting initiatives and incorporating tree planting as part of sidewalk and other streetscape improvements. However, this development would reduce the tree canopy and a unique waterfront habitat that cannot be compensated by re-planting ● Existing mature trees are to be protected during building construction or any alterations to streets or buildings. Tree inventories and management plans are required for all major capital projects and developments.
12 3) Inconsistency with Goal 4 of the Comprehensive Plan
A rezoning is additionally inconsistent with GOAL 4 of the Comprehensive Plan for the historic, archeological and cultural significance of the land for several indigenous peoples and groups (cp. Section 1). The plan demands ○ The preservation of the cultural and historical heritage of the City of Troy ○ A cultural resource investigation will be required for new development planned for archaeological sites or sites within areas identified as archaeologically sensitive by the New York State Office of Parks, Recreation and Historic Preservation (OPRHP). ○ The preservation of the cultural and historical heritage of the City of Troy
4) Inconsistency with Goal 4 of the Comprehensive Plan
A rezoning is additionally inconsistent with GOAL 6, specifically, 6.2 of the Comprehensive Plan, which states: “Development in stable neighborhoods will respect and reinforce the existing neighborhood character and pattern of development”
Our coalition in opposition to the development can and will provide testimony that this neighborhood is a stable neighborhood, and will oppose any suggestions for this being otherwise. A selection of this testimony is provided with supplemental evidence no [S3-4].
SECTION 3 — B: Legal Implications
The proposed development as well as the change in zoning code are inconsistent with Realize Troy 2018 Comprehensive Plan. This is relevant for the consideration of the request for change in zoning code, as such a change cannot occur if it is inconsistent with the comprehensive plan.
New York’s zoning enabling statutes require that zoning laws be adopted in accordance with the comprehensive plan. The comprehensive plan should provide the backbone for the zoning law [S3-1]. Furthermore, the change in zoning code is incompatible with New York State City Code Section 28.a.12: Effect of Adoption of the City Comprehensive Plan: (a) “All city land use regulations must be in accordance with a comprehensive plan adopted pursuant to this section.”
Developing the land is in explicit inconsistency with the 2018 Troy Comprehensive Plan AND THEREFORE CANNOT QUALIFY FOR REZONING
SECTION 3 — C: List of Supplemental Evidence for Section 3: ● [S3-1] NYS Division Of Local Government Services: Zoning and the Comprehensive Plan https://www.dos.ny.gov/lg/publications/Zoning_and_the_Comprehensive_Plan.pdf ● [S3-2] New York State City Code Section 28.a.12 ● [S3-3] Comprehensive Plan MAP 13 ● [S3-4] TESTIMONIES OF RESIDENTS
13 SECTION 4: ECONOMIC GROUNDS
SECTION 4 — A: Negative Economic Impacts of Proposed Development and Code Change for Parcel 70.64-1-1
There are several critical economic impacts that constitute direct and indirect cost to the tax base and the tax paying residents of the city of Troy associated with the proposed rezoning of Parcel 70.64-1-1 and the proposed development of the site.
Based on the attached and here briefly reviewed studies, it is clear that the proposed development will negatively impact the tax revenue of the city of Troy.
Charles Mahron [S4-1] writes that:
“Despite the obfuscation of modern accounting practices, the math equation for a local government is fairly straightforward: a public infrastructure investment must generate enough private wealth to pay for the ongoing replacement and repair of that infrastructure or, if it is to be sustained, it must be subsidized by a more financially productive part of the system.”
The established rule of thumb is that a ratio of 40:1 ($40 private wealth to $1 public investment) is required for a development project to generate and maintain a positive tax revenue [S4-1].
While developers often pay for the initial development and construction cost, the City of Troy will be responsible for critical maintenance and public service costs. This includes - Increased road maintenance and traffic management costs - Increased resource strain for the public school system with the influx of large amounts of new residents in short time - Increased costs for other public services, including the fire department, garbage collection, public safety, etc.
As Mahron [S4-2] writes on the case of development costs, a municipality of similar size and structure:
Rapid growth “[...] provided the local government with the immediate revenues that come from new growth — permit fees, utility fees, property tax increases, sales tax — and, in exchange the city takes on the long term responsibility of servicing and maintaining all the new infrastructure. The money comes in handy in the present while the future obligation is, well … a long time in the future.”
And concludes:
“This thinking is how you end up with two dollars of public infrastructure for every one dollar of private investment. This is how you spend yourself into bankruptcy”. When the full extent of costs are taken into consideration, including maintenance, public infrastructure and public service costs, the proposed development will in fact negatively impact the tax revenue in the city.
14 Instead, leading economists and development experts recommend prioritizing development of existing infrastructure, property and sites, especially vacant sites in economically disadvantaged communities. This has the benefit of minimizing public investment needs and strengthening tax revenue in short- as well as long-term. [S4-3].
This is also made explicit in the 2018 Troy Comprehensive Plan [A], which identifies the need to develop vacancies in Major Investment Areas [S4-4], whereas the parcel in question lies outside the Lansingburgh Investment Area [S4-5] as well as outside the slow development area and is clearly identified as R-1 [S4-6]:
“Troy’s high vacancy rates are also contributing to neighborhood destabilization. There are approximately 23,100 housing units in Troy and approximately 2,100 of these units, or 9%, are vacant and unused. Prospective residents are deterred from purchasing homes in neighborhoods with high vacancy rates as they are perceived as areas with higher crime, and where continued disinvestment may occur. These conditions have resulted in a weak housing market and low housing values compared to the region.” ([A], p.11)
And the plan establishes sites in direct proximity to the parcel for which the rezoning is requested as development focus areas [S4-5 and S4-6] in the spirit of avoiding associated revenue burdens associated with spot zoning developments such as the development proposed for this parcel.
The anticipated short-term economic revenue is anticipated to be outweighed by both, short- and long-term economic costs, based on the expert testimony by economist John Gowdy attached in the evidence [S4-3] and read into the record at the hearing.
The anticipated short-term economic revenue associated with this development proposal is anticipated to be outweighed by both, short- and long-term economic costs.
What is more, studies explicitly and repeatedly show that because of market competition and resource constraint associated with a development of land routinely and structurally prevent the development of other, vacant but already developed sites [S4-7].
In the immediate proximity of the development site proposed by Kevin Vandenburgh there are several vacant properties, including several that have been identified in the Comprehensive Plan as development priority/focus areas.
This means that the proposed development, and the associated rezoning, is incompatible with the responsibilities and legal requirement that must guide the city council committee and planning commission in their decision — and the requested rezoning can only be denied on economic and legal grounds (see below).
SECTION 4 — B: ECONOMIC BASELINE CALCULATION — Public Service Cost
Increased public spending for services outweighs the anticipated revenue.
15 Based on comparative data of similar developments in similar locations in Troy we offer an (generously calculated) anticipated tax revenue for the city around $300,000.00 The anticipated tax revenue for the school district we assess (similarly generously) with $400.000,00. (Based on approximated unit value calculations).
Increase in Cost Spending for Public Schools (TROY SCHOOL DISTRICT): At the same time, in the state of New York, an average of annually $22,366 are spent per pupil on the public education system [S4-8]. In Troy this number is closer to $28,000, but we will use the more conservative average. A conservative estimate would be 40 new pupils entering the Troy School System — an estimate that is very conservative for 240 apartment units. This leads to an increased cost spending of $894,640.
Anticipated Revenue Increase for Troy School District …………. Approx. 400,000 Approximate Cost Increase: Public Service — School ………….. Approx. $894,640 COST TO DISTRICT AS DIRECT RESULT FROM DEVELOPMENT: APPROX. $498,640
This leads to a shortfall of $494,000.00
Increase in Costs For City of Troy On the Example of Public Safety Alone:
Public Safety: Estimates for cost increases for the Fire and Police Services are hard to estimate. One way to estimate this is the per capita spending for police services. According to the 2020 proposed Budget, a total of $40,329,791 will be expended for safety services [S4-9]. This excludes overtime, extraordinary expenditures and other expenditures not listed in the general budget itemization. The population of Troy lies at 49,826 for 2017. This results in a per capita spending of (rounded) $800. With 240 units, and an conservatively estimated 1.75 persons living in each unit, this leads to a total increase of cost of: 240x800x1.75 = $336,000.00
Approximate Revenue for City …………………………………….. Approx. $300,000 Approximate Cost Increase: Public Service — Safety ………….. Approx. $336,000
This leads to an conservatively anticipated increase in cost associated with the development of for public safety alone of $36,000/year.
This does not incorporate other increased public service costs, such as road maintenance, etc.
SECTION 4 — B: Legal Implications
Explicitly, the availability of several other vacant but already infrastructurally developed properties creates an incompatibility with anti-spot-zoning requirements constituted in state law.
Additionally, the above listed reasons create a direct inconsistency with the 2018 Comprehensive Plan and therefore an incompatibility with state law, particularly regarding inconsistencies with soft development, the preservation of the character of the neighborhood, and the requirement of sustainable development.
16 The proposed rezoning and development are also incompatible with New York State Smart Growth Goals.
Finally, the city council is legally required to act in the interest of its current constituents, and not potential future taxpayers — and the shown economic long-term negative impacts stand in direct conflict with this obligation, as they clearly cause economic harm to the city as well as its residents.
SECTION 4 — C: List of Supplemental Evidence for Section 4: ● [S4-1] Charles Marhon Jr. (August 2018) “Building Resilient Communities” https://icma.org/articles/pm-magazine/pm-article-building-resilient-communities ● [S4-2] Charles Marhon Jr. (2017) “The Real Reason Your City Has No Money” https://www.strongtowns.org/journal/2017/1/9/the-real-reason-your-city-has-no-money ● [S4-3] Written Expert Testimony of Dr. of Economy John Gowdy ● [S4-4] Comprehensive Plan Map 2 Investment Areas ● [S4-5] Comprehensive Plan Investment Area Lansingburgh ● [S4-6] Map 14 Land Use ● [S4-7] Resources on Research about Abandoned Properties and Buildings https://journalistsresource.org/studies/government/municipal/abandoned-buildings-revitalization/ ● [S4-8] Annual education spending per state https://www.governing.com/gov-data/education-data/state-education-spending-per-pupil-data.htm l ● [S4-9] Proposed 2020 Budget for Troy NY ● [S4-10] Population Data for Troy NY https://datausa.io/profile/geo/troy-ny
17 SECTION 5: COMMUNITY IMPACTS, PUBLIC SERVICE IMPACTS AND INFRASTRUCTURE IMPACTS
SECTION 5 — A: Neighborhood Impacts of Development and Proposed Code Change for Parcel 70.64-1-1
According to NYS law, a change in zoning code must be in the interest of the public: the CURRENT (and not imagined future) residents. A change in zoning must not be solely for the benefit of the developer. Finally, according to NYS law, a change in zoning code must also be consistent with the comprehensive plan and consistent with current use and character of the neighborhood. This is also explicitly stated as such in Troy’s comprehensive plan [A].
This section explains how this development and the proposed change in zoning code is in direct violation of all above mentioned criteria. The section shows how proposed development and change in zone code will NEGATIVELY impact the local neighborhood and community, will increase costs, and will negatively affect public services and infrastructure, and will be against the interest of the residents of Troy.
Explicitly, a change in zoning code needs to be - consistent with the comprehensive plan - In the interest of the current residents of the City of Troy, not in the interest of the developer or imagined future residents - consistent with surrounding use and zoning
This development and the associated change in zoning code does not meet these criteria. It will impact the neighborhood and the city overall negatively, inconsistently with the comp plan and inconsistently with the surrounding zoning.
This is evidenced in the negative impacts of the proposed development and code change (see Section 5-A), the inconsistencies with the comparative plan implied by these negative impacts (see Section 5-B), and constituted in the increased cost and further strain of public services of the neighborhood (see Section 4). Additional negative impacts for community and city overall, as provided in the entirety of this document, also are the case for the local neighborhood.
LOSS OF FOREST AND WATER ACCESS, AND LOSS OF IMPORTANT NATURAL SPACE The development will destroy the current access to the Hudson River provided with this land. An alternative use proposal, that the current owner is interested in pursuing should the option of sale expire has been submitted in Section 07 of this letter.
In contrast, the proposed development by Kevin Vandenburgh claims to incorporate the public interested in access to the waterfront and natural spaces along the river. However, this statement is clearly misleading.
The developer is creating a dead-end trail and does not create any incentive or attractive park or other features that would invite the public. Additionally, the proposed boat dock is a use-specific water access.
18 The developer is clearly creating amenities for his renters, not for the public and will additionally serve as justification for higher rental prices for departments — with negative effects for surrounding homeowners and renters.
Overall, the proposed development discourages in its design the use of this property, as it is not designed as public use space.
This is inconsistent with the development priorities the city itself has laid out for waterfront properties in its comprehensive plan, which emphasizes public access to water via parks and public space. It also is inconsistent with the comprehensive plan calling for an increase in tree canopy and renaturalization of the waterfront. This speaks to the requirement that a rezoning needs to be for the benefit for the entire public and not for an individual developer.
HEIGHTENED INFRASTRUCTURE AND PUBLIC SERVICE COSTS The residents of 240 newly built apartments will significantly increase pressures on public services and infrastructure.
The proposed development will significantly increase the infrastructure and public service costs, particularly in this R1-zoned residential area. It will in particular negatively impact the local community in terms of infrastructure and public service availability. Several studies have consistently shown the associated increased costs of and strain on critical services associated with developments such as the one proposed here (see evidence for Section 4). Abrupt development growth that does not follow smart and soft growth guidelines and do not utilize existing infrastructure and e.g. vacant properties or buildings, significantly strains services through rapid influx, including amongst others: a) Increased pressure on already strained school services b) Increased pressure on already strained garbage collection c) Increased pressure on already strained emergency services d) Increased need for road maintenance e) Increased pressure on already over-capacity sewage system
LOSS IN PROPERTY VALUE, RESALE VALUE AND RENTAL INCREASES [S5-1] Besides the cost associated with strains on the local infrastructure, this development will also lead to additional direct and indirect costs for the local residents and the overall neighborhood.
The development will lead to significant loss of property value and resale value due to the loss of greenspace and waterfront, which also negatively impacts the city budget f) The tax savings of industrial development may measure a few hundred dollars a year per taxpayer, but the loss in property values measures in the thousands. Typically it takes decades of tax savings to make up for the loss in property value. g) Property value will decline with the loss of a significant greenspace and undeveloped waterfront forest property
Rental increases in surrounding housing are expected to increase due to the amenities at the property, clearly designed for the use of renters at the property.
VACANT PROPERTIES AND LACK OF DEVELOPMENT IN LANSINGBURGH
19 There are priority development areas in the direct vicinity of this property. A vacant price chopper as well as several vacant locations across the local Lansingburgh neighborhood are identified as priority and development nodes in the comprehensive plan.
As the plan states:
“Troy’s high vacancy rates are also contributing to neighborhood destabilization. There are approximately 23,100 housing units in Troy and approximately 2,100 of these units, or 9%, are vacant and unused. Prospective residents are deterred from purchasing homes in neighborhoods with high vacancy rates as they are perceived as areas with higher crime, and where continued disinvestment may occur. These conditions have resulted in a weak housing market and low housing values compared to the region”. ([A], pg.11)
A rezoning discourages and actively prevents the development of already developed vacant areas with existing infrastructure and public services in place.
The development of this property, and the associated rezoning, stand in conflict with these development needs and undermine soft and smart growth and development.
Accordingly, the rezoning would stand in direct conflict with the provisions and priorities laid out in the Comprehensive Plan, the smart growth development principles established in the Comprehensive Plan, and the New York State Smart Growth Criteria. .
SECTION 5 — B: Legal Implications
The development of this property, and the associated rezoning, stand in conflict with these development needs and undermine soft and smart growth and development.
Accordingly, the rezoning would stand in direct conflict with the provisions and priorities laid out in the Comprehensive Plan, the smart growth development principles established in the Comprehensive Plan, and the New York State Smart Growth Criteria.
SECTION 5 — C: List of Supplemental Evidence for Section 5: ● [S4-8] The Impact of Apartment Complexes on Property Value of Single Family Dwellings https://digitalcommons.unomaha.edu/cgi/viewcontent.cgi?article=2150&context=studentwork&fbcl id=IwAR2lCgQJHlRSBKXF68TGCWDoyvmxRbNG0eXIDMzbITX7polbkTClfeul1Iw
20 SECTION 6: LEGAL GROUNDS
SECTION 5 — A: Legal Grounds for Denying Request for Code Change for Parcel 70.64-1-1
This final section highlights some major incompatibilities with existing law, rules and codes.
1) Inconsistency with Comprehensive Plan and Spot Zoning The proposed development as well as the change in zoning code are inconsistent with Realize Troy 2018 Comprehensive Plan (cp. Section 3). New York’s zoning enabling statutes require that zoning laws be adopted in accordance with the comprehensive plan. The comprehensive plan should provide the backbone for the zoning law].
Furthermore, the change in zoning code is incompatible with New York State City Code Section 28.a.12: Effect of Adoption of the City Comprehensive Plan: (a) “All city land use regulations must be in accordance with a comprehensive plan adopted pursuant to this section.”
2) Inconsistent with surrounding uses and zoning and orderly growth and development The law demands the (NYS City Code Section 28.a.12 - o) consistency “with the orderly growth and development of the city. Furthermore, code changes need to be consistent with the surrounding uses and zoning (“SPOT ZONING”).
The comprehensive plan identifies in Map 14 the surrounding area as “low density residential”.
However the parcel in question is NOT located in a major reinvestment area and the surrounding area is R-1 for 10 single family homes. 240 multi-family units do not fit with the character of surrounding land uses. The site is also not located in a Major Reinvestment Area.
3) Spot Zoning According to the NYS Division of Local Government Services, “Spot zoning refers to the rezoning of a parcel of land to a use category different from the surrounding area, usually to benefit a single owner or a single development interest. Size of the parcel is relevant, but not determinative. Illegal spot zoning occurs whenever “the change is other than part of a well-considered and comprehensive plan calculated to serve the general welfare of the community” [S6-1] and [S6-2]
Spot zoning is, in fact, often thought of as the very antithesis of plan zoning. When considering spot zoning, courts will generally determine whether the zoning relates to the compatibility of the zoning of surrounding uses. Other factors may include; the characteristics of the land, the size of the parcel, and the degree of the “public benefit.” Perhaps the most important criteria in determining spot zoning is the extent to which the disputed zoning is consistent with the municipality’s comprehensive plan.
This proposed change in zoning meets the definition of spot zoning on several grounds: ● It is inconsistent with the surrounding zoning (R-1) ● It is inconsistent with the planned zoning detailed in the comprehensive plan ● It constitutes an unreasonably unequal treatment with comparably situated land
21 4) No Evident Need For The Zone Change According to NYS DOS, requests for zone change must show a need for the zone change. This is strictly defined. Specifically, any change must be made for the benefit of the community as a whole, not for an individual property owner or developer [S6-3].
The need for zone change for the benefit of the community as a whole cannot be shown for the parcel in question: The property can be maintained profitable with a single ● Economic Viability/Burden Criteria is not met. family home that can be rented out; Incurred exploration and evaluation costs cannot be included in calculations for economic viability of the property ● Additionally a rezoning will negatively impact the property value and quality of life for neighboring residents and the overall neighborhood’s character ● There was no change in circumstances or mistake made when the original zoning occurred; The developer cannot show the need for change or occurrence of a mistake in the original zoning. ● Additionally, there are sufficient vacant plots elsewhere and in the immediate vicinity that have been identified in the Comprehensive Plan as Major Reinvestment Area and/or Development Priority Areas. ● The code change would be inconsistent with surrounding uses.
The zone change is inconsistent with the orderly development of public services and infrastructure. A rezoning cannot be granted as it necessitates increased infrastructure and public service that can be provided at another vacant lot in immediate proximity (former PriceChopper) that is additionally locate in one of the “node” zones detailed in the Comprehensive Plan, and was identified by the city council and city council president as development priority.
Due to this area being R-1 and inadequate traffic and parking infrastructure, a rezoning and the associated development would create increased infrastructure needs. These infrastructure needs can already be provided at the abandoned and empty, recently closed Price Chopper property in direct vicinity to this property;
Additionally, multiple vacant buildings in the neighborhood, including across the street from the land in question, are also available for redevelopment without the increased infrastructure and public service burden; including several in development priority zones identified in the comprehensive plan.
Hence, part of town already has the services and can support the same type of development the proposed zone change will allow in the direct vicinity of this property; A rezoning cannot legally be granted for this reason.
SECTION 6 — C: List of Supplemental Evidence for Section 6: ● [S6-1] DOS: Zoning and the Comprehensive Plan https://www.dos.ny.gov/lg/publications/Zoning_and_the_Comprehensive_Plan.pdf Gernatt Asphalt Products, Inc. v. Town of Sardinia, supra at 685, citing Udell v. Haas, supra at 472 ● [S6-2] ● [S6-3] Partnership for the Public Good: Land Use and Zoning Law (https://ppgbuffalo.org/files/documents/environment/land_use/environment-_land_use_and_zoning_la w_a_citizens_guide.pdf
22 Section 7: Alternative Land Use Proposal SUMMARY For the Purpose of Protecting the Land as Historically and Culturally Significant Site And for the Purpose of Creating a Community Food Forest and Cultural Center
A preliminary proposal was shared with representatives of the current owner of this land, and they indicated their openness to this alternative use proposal. This section provides a brief summary of this proposal.
We suggest an alternative land-use plan, centered on and in-tune with community needs and with the goal of preserving the property for the community. We suggest the preservation of this important land and its development as a natural recreational space, food resource in the low-access neighborhood, an ecological buffer zone, and a natural protection against flooding.
The Friends of the Mahicantuck commit to collaborating with the community and partner organizations to - protect the lands for its historical, cultural and ecological significance indefinitely - create of a sustainable community food forest (which would be one of the largest of its kind in the nation) - Create educational and cultural outreach programs, and make these accessible to the local school around the corner from the property as well as the local community
A collaboration between nonprofit partners and the local community, already in formation, will create a community food forest, or edible forest garden as well as a preservation of the natural space and historical site. Food forests are an indigenous food production strategy that strengthens the living ecosystem, by focusing on a harmonious natural relationship. This process increases biodiversity and can strengthen food security in sustainable and regenerative ways. The creation of a Community Food Forest will provide the local communities in Troy with a critical food source and address food injustices prevalent in the local communities surrounding this land.
We see every challenge as an opportunity and are working with our partners towards revealing the history that has been hidden and to exemplify how people can be living a sustainable lifestyle that works hard towards mitigating the human impact on the changing climate.
Community Benefits ● The creation of a trail system for better access to the land and the Hudson River ● The creation of a food forest to improve access to food for the local communities of Troy ● The preservation of the land as an important natural recreation space ● The preservation of the site for its historical significance, and the designation as such ● The preservation of one of the last remaining biodiversity niches within Troy ● The preservation of a natural buffer zone against flood risks in a changing climate
23 APPENDIX: LIST OF SUPPLEMENTAL EVIDENCE SUBMITTED WITH THIS LETTER
Evidence not associated with a direct link is provided online for download via this link: https://drive.google.com/drive/folders/1M410j_8CVzDyjIQzzaz_VcNJOLViByH5?usp=shari ng
Evidence can be submitted in hard copy upon request.
LIST OF EVIDENCE
● 2018 Comprehensive Plan [A]
List of Supplemental Evidence for Section 1: ● [S1-1] Brumbach, H.J. (1987) “A Quarry/Workshop And Processing Station On The Hudson River In Pleasentdale, New York”. Archeology of Eastern North America, 15(1987), 59-83. ● [S1-2] Lothrop, J. C., Burke, A. L., Winchell-Sweeney, S., and G. Gauthier (2018). Coupling Lithic Sourcing with Least Cost Path Analysis to Model Paleoindian Pathways in Northeastern North America. American Antiquity, 83(3), 462-484. ● [S1-3] US EPA (2002). Responsiveness Summary Hudson River PCBs Site Record of Decision. Appendix C Stage 1A Cultural Resource Survey. ● [S1-4] Brumbach, Hetty Jo, Zitzler, Paula (1993) Stage II Archeological Investigation Of the Turnpike/River Bend Road Area. Peasentdale Wastewater Facility Plan. Town Of Schaghticoke, Rensselaer County, New York (C-36-1270-01). Public Arecheology Facility, Rensselaer Polytechnic Institute. [Hard Copy Available]. ● [S1-5] National Historic Preservation Act — https://www.nps.gov/history/local-law/nhpa1966.htm ● [S1-6] State Historic Act — https://parks.ny.gov/shpo/environmental-review/preservation-legislation.aspx
List of Supplemental Evidence for Section 2: ● [S2-1] Times Union (July 7, 2017) “Massive Albany Troy Sewage Spills in Hudson https://www.timesunion.com/7dayarchive/article/Massive-Albany-Troy-sewage-spills-in-Hudson-1 1273421.php ● [S2-2] Statement of City of Troy: “Understanding Tory’s Combined Sewer Infrastructure System” July 10, 2017 http://www.troyny.gov/understanding-troy-combined-sewer-infrastructure-system/ ● [S2-3] Conservation Tools: Working With Nature to Manage Stormwater https://conservationtools.org/guides/166-working-with-nature-to-manage-stormwater ● [S2-4] DOS: Impacts of Urban Runoff https://www.des.nh.gov/organization/divisions/water/wmb/tmdl/documents/stormwater_chapt1.pdf ● [S2-5] https://pubs.er.usgs.gov/publication/wri014071 ● [S2-6] Urban Forests and Climate Change https://climate-woodlands.extension.org/urban-forests-and-climate-change/#:~:text=Urban%20for ests%20can%20be%20useful,to%20heat%20and%20cool%20buildings. ● [S2-7] USDA Urban Forests and Climate Change
24 https://www.fs.usda.gov/ccrc/topics/urban-forests-and-climate-change ● [S2-8] National Management Measures to Control Nonpoint Source Pollution from Hydromodification https://www.epa.gov/sites/production/files/2015-09/documents/chapter_3_channelization_web.pdf ● [S2-9] Problems Facing Urban Streams http://www.msdlouky.org/insidemsd/wqurban.htm ● [S2-10] From Channelization To Restoration http://scholar.google.com/scholar_url?url=http://www.academia.edu/download/43058958/Chen_et _al-2016-Water_Resources_Research.pdf&hl=en&sa=X&scisig=AAGBfm3QW_VCYsUVIg_vciK WvVRiz7HOaQ&nossl=1&oi=scholarr ● [S2-11] EPA: Reduce Urban Heat Island Effect https://www.epa.gov/green-infrastructure/reduce-urban-heat-island-effect ● [S2-12] NYT: How Decades Of Racist Housing Policy Left Neighborhoods Sweltering https://www.nytimes.com/interactive/2020/08/24/climate/racism-redlining-cities-global-warming.ht ml ● [S2-13] Benefits of Urban Trees https://www.nature.org/content/dam/tnc/nature/en/documents/Public_Health_Benefits_Urban_Tre es_FINAL.pdf ● [S2-14] CSC Certification Troy http://csc-site-persistent-prod.s3.amazonaws.com/fileadmin/cicbase/documents/2017/11/10/1510 3445909908.pdf ● [S2-15] Comprehensive Plan Map 12
List of Supplemental Evidence for Section 3: ● [S3-1] NYS Division Of Local Government Services: Zoning and the Comprehensive Plan https://www.dos.ny.gov/lg/publications/Zoning_and_the_Comprehensive_Plan.pdf ● [S3-2] New York State City Code Section 28.a.12 ● [S3-3] Comprehensive Plan MAP 13 ● [S3-4] TESTIMONIES OF RESIDENTS
List of Supplemental Evidence for Section 4: ● [S4-1] Charles Marhon Jr. (August 2018) “Building Resilient Communities” https://icma.org/articles/pm-magazine/pm-article-building-resilient-communities ● [S4-2] Charles Marhon Jr. (2017) “The Real Reason Your City Has No Money” https://www.strongtowns.org/journal/2017/1/9/the-real-reason-your-city-has-no-money ● [S4-3] Written Expert Testimony of Dr. of Economy John Gowdy ● [S4-4] Comprehensive Plan Map 2 Investment Areas ● [S4-5] Comprehensive Plan Investment Area Lansingburgh ● [S4-6] Map 14 Land Use ● [S4-7] Resources on Research about Abandoned Properties and Buildings https://journalistsresource.org/studies/government/municipal/abandoned-buildings-revitalization/ ● [S4-8] Annual education spending per state https://www.governing.com/gov-data/education-data/state-education-spending-per-pupil-data.htm l ● [S4-9] Proposed 2020 Budget for Troy NY ● [S4-10] Population Data for Troy NY https://datausa.io/profile/geo/troy-ny
25
List of Supplemental Evidence for Section 5: ● [S4-8] The Impact of Apartment Complexes on Property Value of Single Family Dwellings https://digitalcommons.unomaha.edu/cgi/viewcontent.cgi?article=2150&context=studentwork&fbcl id=IwAR2lCgQJHlRSBKXF68TGCWDoyvmxRbNG0eXIDMzbITX7polbkTClfeul1Iw
List of Supplemental Evidence for Section 6: ● [S6-1] DOS: Zoning and the Comprehensive Plan https://www.dos.ny.gov/lg/publications/Zoning_and_the_Comprehensive_Plan.pdf Gernatt Asphalt Products, Inc. v. Town of Sardinia, supra at 685, citing Udell v. Haas, supra at 472 ● [S6-2] ● [S6-3] Partnership for the Public Good: Land Use and Zoning Law (https://ppgbuffalo.org/files/documents/environment/land_use/environment-_land_use_and_zoning_la w_a_citizens_guide.pdf
26 Dear Members of the Planning Commission,
The Friends of the Mahicantuck submit this statement, as well as attached material, for the consideration of the Planning Commission in their review of a proposed rezoning of 1011 2nd Avenue.
We urge you, as well as the City of Troy Common Council and the Mayor to ensure the following:
1) Prioritize the preservation and stewardship of 1011 2nd Avenue.We urge you to work with us and our partners, leaders of all indigenous groups with ties to this land, the broader community and the current owner of the land to preserve and protect this unique site. This has to be the city’s highest priority.
2) The City of Troy must follow the law! The proposed development and rezoning request must be considered together, according to the State Environmental Quality Review Act (SEQRA). Therefore, the Planning Commission’s recommendation to the common council regarding rezoning should be that the developer submit its Environmental Assessment Form (EAF) that would include the need for rezoning to avoid segmentation and in order for the project and all of the proposed discretionary decisions (such as rezoning) to be studied during a thorough, transparent and inclusive SEQRA review process.
PRIORITIZE THE PRESERVATION OF 1011 2nd AVENUE
Guided by the wisdom of Sachem HawkStorm, hereditary chief of the Schaghticoke First Nations, we’ve built a broad grassroots coalition of community members, local organizations as well as regional and state organizations. The breath of our platform, including over 2300 signatures on our petition, makes unmistakably clear that the public stands behind this vision to bring the land at 1011 2nd Avenue into long-term protection and preservation.
We have been continuously advocating for a win-win solution, and today we call upon the City of Troy to work towards realizing this community vision. As a site that provides evidence of a 5,000 year indigeonous history, it is imperative that our elected and appointed officials commit to working with members of all indigenous peoples with historical ties to this land, our partners from community and collaborating organizations and the broader community to preserve this sacred land for all of Troy and the city’s future generations
We have imagined a clear vision for this land as a public good, and we are prepared to collaborate with our partners to secure the necessary resources to make it real.
We want to bring this land into trust for long term preservation. The Schaghticoke First Nations are willing to invest their wisdom and experience to create a food forest and medicinal garden for the community, in a location that the New York State Department of Environmental Conservation (NYSDEC) has determined a “Potential Environmental Justice” area. We are ready to preserve and protect this land and its unique ecology, history and cultural significance with appropriate programming, regular clean-up events and securing and maintaining trails.
Join us to work toward realizing this vision. The developer does not currently own this land. There are plenty of vacant and abandoned sites in close proximity to repurpose for mixed use housing projects. The former Price Chopper site comes to mind, or the recently cleared Leonard Hospital site. The city has worked with developers before to find sites that are better suited to realize their vision.
THE CITY OF TROY MUST FOLLOW THE LAW
We are deeply concerned about the “out of step” process in which the City of Troy may currently be considering with a rezoning request approval for a project that has yet to undergo its environmental review. That’s segmentation in SEQRA and contrary to its intent. Furthermore, it’s a glaring process flaw that leaves the City of Troy vulnerable to future lawsuits.
According to SEQRA, the developer’s request to rezone 1011 2nd Avenue must be included as part of the whole action for review in its Environmental Assessment Form (EAF). It is critical that all anticipated decisions are identified in the EAF so that the potential environmental impacts associated with them can be considered together. Because this zoning change would also require a Comprehensive Plan amendment, due to being inconsistent with the City of Troy’s Comprehensive Plan, that too must be identified and studied during SEQRA. It is clear that all three actions — rezoning, a Comprehensive Plan amendment and the proposed development itself — would result in adverse environmental impacts to the community and the Hudson River. The Planning Commission has already identified that rezoning for this project was a Type 1 Action under SEQRA, requiring a coordinated review by a designated lead agency.
In the meantime, the developer should be asked to halt any and all studies while the community waits for the EAF to be submitted, a lead agency has been declared and a positive declaration has been made that would initiate the required public scoping process.
The Friends of the Mahicantuck call on the Planning Commission and City Council to ensure a transparent, thorough and inclusive SEQRA process.
Attachments: For your consideration, we included the following documents: - Change.org petition with 1011 2nd Avenue in support of our efforts and opposition to the proposed rezoning and development. - Previously submitted to the City Council: Report by the Friends of the Mahicantuck on the significance of the land, underscoring the necessity of a positive SEQRA declaration - NYSDEC’s Potential Environmental Justice Area that identifies the project site. - 6 N.Y.C.R.R. §617.2(ag), Segmentation definition: SEQRA generally prohibits “segmentation,” which is defined as “the division of the environmental review of an action such that various activities or stages are addressed under this Part as though they were independent, unrelated activities, needing individual determinations of significance.”
Thank you for your consideration,
The Friends of the Mahicantuck www.FriendsOfTheMahicantuck.org [email protected] www.change.org/save1011now To the Troy Planning Commission:
I’m writing to oppose the re-zoning of 1101 2nd Avenue in North Troy, for the “Second Avenue” project. This spot zoning change is myopic in nature, without due consideration for the environmental and cultural impacts that will directly follow from such an action.
It is the charge of the planning Commission promote excellence in site design and among the considerations must be that of the natural environment and protection of public welfare. The rezoning of this site must be considered within the context of the intended construction to follow – high density housing that will radically alter the environment. An affirmative rezoning in the absence of a full review of the environmental impact assessment under the State Environmental Quality Review Board Act is premature and sets a precedent for disregard of impacts to the natural environment. A full understanding of the environmental impacts of this project is all the more important given the unique nature of this site, as the last wooded site along the Hudson River within Troy. Between Troy and Albany, community access to the Hudson should be preserved, for ourselves and for our children.
Access to the river and this site should also be preserved for the sake and stewardship of the Mahican people, the original inhabitants of this site. The rezoning of a sacred site is akin to the desecration of a sacred church, mosque, or temple for private profit. The site has thousands of years of cultural and religious significance. Troy became a city about 200 years ago, but the value of this site had been recognized for an order of magnitude longer – for over 5,000 years. The disregard for this history and cultural significance that a rezoning would signify represents a continuation of the same mentality of manifest destiny that defined the founding of the United States and permitted the genocide of Native communities across this country.
We are what are actions show us to be – and even the small decisions have real meaning.
Thank you for your consideration and I firmly encourage a denial of this zoning permit absent further assessment of the environmental cultural impacts of such a decision.
Dec. 28, 2020
Greetings to the members of the Planning Commission of the City of Troy, NY.
I would like this letter to be added to the record for the Dec. 29th meeting regarding 1011 2nd Ave.
My name is Kanerahtiio Roger Jock. I am Kanien'kehá:ka (Mohawk) Bear Clan from Akwesasne. My great-grandmother is from the Schoharie region of the Mohawk Valley. This is where my DNA comes from, and my ancestors have a long history of relations with the Mahican People that continues to this day.
I am also the project director of the Waterfall Unity Alliance based in West Fulton, NY -- where we are building a traditional longhouse as an initial point of return to our ancestral soils. The mission of the Waterfall Unity Alliance is to protect the Mohawk Watershed and all Earth; and create solutions to the existential challenges of our time.
It’s no longer just the native people of this land who know that we need to respect the Earth, live in reciprocity, and stop destructive development in the name of so-called progress. Our economy should not be based on destroying the Earth. The native trees have a right to be here. Our grandchildren have the right to be able to come and visit this forest, sit by the river, gather medicines. This is a rare place of peace that is senseless to destroy.
Now that it is threatened, the people continue to who love and honor the land are here to say STOP! NO! NO MORE! No more development that destroys the last forests. No more paving over ancestral land. No more short-term gain for long-term destruction.
We join our voice to theirs and say no more to this old story that is leading us to extinction. We need to walk together in a new way. We respect the history of the Mahicans on this land. The land is sacred. The river is sacred. The trees and the breathing life on the riverside are sacred. It is time to protect what is sacred and protect what we love.
We need to stand together and make our old agreements new again. As long as the water flows and the grasses grow, we will respect each other and walk together under the Great Law of Peace, protecting the Earth and all creation.
In Unity, Kanerahtiio Roger Jock
1160 BEAR LADDER ROAD. WEST FULTON, NY 12194 * [email protected]