MP Enterprises, LLC Project Synopsis

LAKE GEORGE PARK COMMISSION PROJECT SYNOPSIS Meeting Date 10/27/2020

Applicant Facility Parcel MP Enterprises LLC SNUG HARBOR MARINA 150.75-3-3.000 Application # Lakefront Location M20-000006 Marina - Class A 509 92 BLACK POINT ROAD Date Received SEQR Type Comment Period Ends 09/28/2020 Unlisted Action 10/13/2020 Project Relocation of gas dispenser and customer fueling station Background Snug Harbor is an existing Class A Marina offering seasonal berthing, quick launch, boat rentals, sales, service, and fuel. The applicant seeks to modify the fuel service operation by updating and relocating the fuel dispenser equipment and relocating the associated fueling station for vessels on the facility's docks. Specifically, the applicant seeks to remove the existing fuel pump and fuel lines from the middle of the dock complex. The new fuel lines will be located entirely upland, with a flexible fuel line proposed to dispense fuel to customers on the 123' south dock. No modifications to the docks are proposed.

The action will not result in any change to the volume of vessel or vehicular traffic to and from the site. However, the boat traffic relative to fueling and any associated impacts (eg. noise, fumes, etc.) will be brought in closer proximity to neighboring residential lands.

There is no apparent jurisdiction for the APA. The project is subject to review and approval by the Town building department, which administers NYS Fire Code. The facility is subject to DEC's bulk storage jurisdiction. Per Commission regulation, where applicable, an applicant must demonstrate proof of compliance with New York State fire code standards and DEC bulk storage standards for the storage of gasoline and hazardous materials. If applicable, no permit application shall be complete until proof of compliance is submitted to the Commission.Any approval of the subject application will be conditioned on receiving the above-referenced permits/authorizations.

Public comments have been received that cite potential safety and neighborhood impacts.

Regulatory Determinations

SEQRA: A decision under the State Environmental Quality Review Act (SEQRA) is required. The project is unlisted and the SEQRA review is uncoordinated. A draft negative declaration was prepared by staff.

Considerations for Class A Marinas Section 646-1.6 (a) Prior to granting any permit relative to a dock, wharf, mooring or marina, the Commission shall ascertain the probable effect of the proposed facility and the operation thereof on the health, safety and welfare of the public and on the resources of the Park. The Commission shall also ascertain the impact of the proposed facility upon the congestion of Lake George and the probable visual, cultural and audible effects of the proposed facility on the neighborhood in which the facility is proposed and on the Park. Where the Commission determines that the facility will have an undue impact upon the health, safety, or welfare of the public of the resources of the park, lead to overcrowding or congestion, or cause undue visual, cultural or audible impacts on the neighborhood or the Park, a permit shall be denied. 16E

16B

16A 16D

16B

NYS ITS GIS Program Office, Westchester County GIS 0 485 970 Feet Snug Harbor 1 " = 400 feet ¯ 92 Black Point Rd IMPORTANT NOTICE AND DISCLAIMER TM# 150.75-3-3.000

This map and information is provided as is. Town of Ticonderoga We make no warranties or guarantees, expressed or implied. The user assumes all risks and responsibility for determining whether this map is sufficent for purposes intended. The data is deemed reliable but not guaranteed. 2018 Air Photo NYS ITS GIS Program Office, Westchester County GIS 0 120 240 Feet Snug Harbor 1 " = 100 feet ¯ 92 Black Point Rd IMPORTANT NOTICE AND DISCLAIMER TM# 150.75-3-3.000

Proposed Fuel Dock

NYS ITS GIS Program Office, Westchester County GIS 0 80 160 Feet Snug Harbor 1 " = 67 feet ¯ 92 Black Point Rd IMPORTANT NOTICE AND DISCLAIMER TM# 150.75-3-3.000

1A LG Village, west side 11A Harbor Islands area 16E 1B LG Village, east side 11B Mother Bunch Island area State Boat 1C Tea Island 11C Harbor Island Launch 16D 16A 2A Hearthstone Point 11D Huletts Landing 16B 2B Plum Pt / Woods Pt area 12A Sabbath Day / Silver Bay 16C Rogers 2C Hearthstone Campground 12B Bluff Head area Rogers Rock Slide 2D Dunham's Bay 12C Werner's Bay State Campground 15B 3A Cannon Pt area 12D Bass Bay 15A 3B Assembly Pt area 13A Pardo Point area Anthony's Nose 13B Mallory Island area 3C Still Bay 15C 3D Harris Bay 13C Arcady Bay Blairs Bay 3E Sandy Bay 13D Hague Bay 3F Warner Bay 13E Gull Bay Hague 14A 14B 3G Assembly Point Channel 14A Waltonian Islands area 13D 4A Long Island West 14B Rock Bro's Is / Brown's Pt 13E Gull Bay 4B Long Island East 15A Friend's Pt / Roger's Rock 13A 13B 4C Elizabeth Island 15B Brown's Pt / Weed's Bay 13C Mallory Pt 5A Rush Island area 15C Blairs Bay 5B Whipple Island area 16A Ticonderoga area, west side Silver Bay 5C Boon Bay 16B Ticonderoga area, east side 16C Heart Bay 12D 5D Echo Bay 16D Mossy Point 12A 12B 6A Cotton Point area 16E North of natural dam 12C Bluff Head 6B Pilot Knob area Sabbath Day 6C Basin Bay Point 6D Andrews Bay 7A Clay Island - Dome Island 11D 7B Watch Point area Huletts 11C Landing 7C Huddle Bay 11A 11B 8A Northwest Bay, west side Canoe Mother Launch Bunch 8B Northwest Bay, east side (Tongue Mt) Islands 8C Sawmill Bay 10A 10B 8D Shelving Rock Bay Tongue Mt 10D 8E Log Bay Northwest Black Mt 8F Huckleberry Island Bay Point 8B 10C 8G Bolton Bay & east of Green Island The Narrows Paradise Bay 9D 9A Narrows, west side 9A 9B Sawmill Bay 8A 9E 9B Narrows, east side 8C 9C Shelving Rock 9C 14 Mile Island Bolton 8G 8F Landing 8E 9D Red Rock Bay 8D 9E Glen Island 7C 7A 7B Huddle Bay 10A Dollar Island Group area Basin Bay 10B Black Mtn Point area 6C 6A 6B 10C Paradise Bay Cotton Pt 6D Pilot 10D Black Mtn Point 5C Knob Boon Bay 5A Echo 5B Bay 5D 4A 4C 4B Kattskill Diamond Bay Point 3G 3A 3E 3D 3F 3C 3B Sandy Warner Hearthstone State Bay Bay Campground Harris Cleverdale 2C 2B Bay 2A 2D Dunhams Zone Over Capacity 1C Bay 1A 1B 0 1 2 Lake George Miles Village

Lake George 2015 Recreation Study Lake Zones Map May, 2016 LA Group Lake George Recreation Survey 2015 977 Lake George Boaters, Dock Owners Recreation Visitors Where, if anywhere, did you feel there was boat congestion on the Lake? (Check all that apply). Use of Lake George Gender Age Association with Lake George Home Community 65 and Year-round Seasonal Visitor/Day- Under 5,000 5,000 to 24,999 25,000 to Over 100,000 Total Dock Boat Recreation Male Female Under 40 40 to 49 50 to 64 older resident visitor user Rural people people 99,999 people people 1A: LG Village, east side 15% 13% 14% 15% 14% 18% 25% 11% 15% 14% 19% 13% 15% 17% 14% 15% 12% 15% 1B: LG Village, west side 19% 19% 18% 21% 18% 21% 21% 13% 19% 20% 24% 17% 17% 19% 18% 18% 19% 24% 1C: Tea Island Channel 4% 4% 4% 5% 4% 4% 2% 1% 4% 6% 7% 4% 1% 4% 5% 4% 0% 7% 2A: Hearthstone Point 3% 2% 3% 2% 2% 3% 1% 3% 3% 2% 5% 2% 2% 2% 5% 2% 0% 3% 2B: Plum Pt / Woods Pt area 2% 2% 2% 1% 2% 2% 2% 1% 2% 2% 3% 1% 1% 1% 4% 1% 2% 2% 2D: Dunham's Bay 6% 8% 6% 5% 5% 6% 6% 1% 5% 8% 9% 5% 4% 6% 5% 5% 5% 5% 3A: Cannon Pt area 2% 2% 2% 2% 1% 3% 3% 3% 2% 1% 2% 1% 3% 1% 4% 1% 1% 4% 3B: Assembly Pt area 6% 7% 6% 7% 5% 9% 11% 7% 6% 4% 9% 6% 4% 5% 6% 8% 3% 5% 3C: Still Bay 1% 1% 1% 0% 1% 1% 1% 0% 1% 1% 2% 0% 0% 0% 3% 1% 0% 0% 3D: Harris Bay 6% 10% 6% 6% 6% 7% 4% 3% 7% 8% 10% 6% 4% 6% 11% 5% 3% 5% 3E: Sandy Bay 14% 20% 15% 14% 13% 18% 13% 15% 14% 14% 22% 13% 8% 13% 17% 15% 14% 10% 3F: Warner Bay 4% 7% 4% 4% 4% 4% 2% 3% 5% 4% 9% 2% 2% 3% 8% 3% 2% 4% 3G: Assembly Pt Channel 7% 11% 7% 5% 7% 8% 7% 1% 7% 9% 10% 7% 3% 7% 7% 8% 5% 5% 4A: Hayden Point area 1% 1% 1% 1% 0% 2% 2% 1% 1% 1% 1% 1% 0% 0% 1% 1% 0% 2% 4B: Long Is / Van Warmer Bay 4% 5% 4% 4% 4% 5% 5% 7% 4% 2% 6% 3% 4% 5% 4% 3% 5% 7% 4C: Elizabeth Is Channel 1% 2% 1% 2% 1% 2% 0% 0% 1% 2% 1% 2% 0% 1% 2% 1% 0% 2% 5A: Rush Island area 1% 1% 1% 1% 1% 2% 2% 1% 1% 1% 1% 1% 0% 0% 2% 1% 1% 2% 5B: Whipple Island area 1% 1% 1% 1% 1% 0% 0% 1% 1% 1% 0% 1% 0% 0% 1% 1% 0% 2% 5C: Boon Bay 2% 3% 2% 2% 2% 1% 1% 2% 2% 2% 3% 2% 0% 2% 2% 1% 1% 3% 5D: Echo Bay 1% 1% 1% 1% 1% 1% 1% 1% 1% 1% 1% 1% 0% 1% 2% 0% 0% 1% 6A: Cotton Point area 3% 6% 3% 4% 3% 2% 3% 3% 3% 3% 4% 4% 0% 2% 2% 3% 5% 3% 6B: Pilot Knob area 5% 8% 5% 6% 5% 4% 5% 3% 6% 5% 7% 5% 2% 6% 5% 6% 1% 5% 6C: Basin Bay 9% 15% 9% 8% 10% 6% 7% 6% 11% 8% 16% 9% 2% 8% 13% 7% 12% 5% 6D: Andrews Bay 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 1% 0% 1% 1% 0% 0% 7A: Clay - Dome Islands 4% 5% 5% 5% 5% 3% 5% 6% 4% 3% 4% 4% 4% 5% 4% 4% 2% 4% 7B: Watch Point area 2% 2% 2% 2% 2% 1% 2% 3% 2% 1% 2% 2% 2% 1% 2% 3% 0% 2% 7C: Huddle Bay 5% 7% 5% 7% 5% 5% 4% 3% 5% 7% 6% 5% 4% 4% 8% 5% 4% 4% 8A: NW Bay - West side 2% 2% 1% 2% 1% 2% 1% 0% 2% 2% 2% 1% 1% 3% 1% 1% 2% 0% 8B: NW Bay - East side (Tongue) 2% 2% 1% 2% 1% 2% 1% 1% 2% 2% 2% 2% 1% 3% 0% 1% 0% 4% 8C: Sawmill Bay 2% 3% 3% 2% 3% 2% 6% 3% 2% 2% 4% 2% 1% 3% 2% 2% 1% 4% 8D: Shelving Rock Bay 8% 11% 9% 9% 7% 11% 11% 6% 8% 9% 14% 7% 6% 9% 10% 8% 4% 10% 8E: Log Bay 20% 25% 21% 20% 19% 22% 21% 20% 17% 22% 28% 18% 13% 22% 21% 20% 15% 16% 8F: Huckleberry Is. area 3% 4% 3% 2% 3% 2% 4% 4% 3% 1% 3% 4% 1% 2% 2% 4% 2% 2% 8G: Bolton Bay & E of Grn. Is. 10% 12% 10% 10% 10% 10% 10% 10% 10% 10% 8% 12% 7% 12% 7% 11% 9% 10% 9A: Narrows - west side 5% 5% 5% 5% 4% 5% 6% 3% 5% 4% 4% 5% 4% 7% 3% 4% 4% 5% 9B: Narrows - east side 8% 8% 8% 9% 8% 8% 8% 8% 8% 8% 11% 7% 7% 9% 8% 9% 5% 8% 9C: 14 Mile Island Channel 2% 3% 2% 3% 2% 2% 5% 0% 2% 3% 3% 2% 2% 2% 2% 3% 1% 2% 9D: Red Rock Bay 5% 6% 6% 4% 6% 5% 3% 3% 7% 5% 8% 5% 4% 6% 8% 5% 2% 5% 9E: Glen Island 6% 7% 6% 5% 6% 5% 7% 4% 5% 7% 7% 6% 4% 7% 9% 4% 5% 4% 9F: Paradise Bay 8% 11% 8% 7% 8% 6% 4% 4% 7% 12% 9% 9% 4% 7% 10% 8% 5% 8% 10A: Dollar Island Group area 1% 1% 1% 1% 1% 1% 3% 1% 1% 1% 2% 1% 1% 1% 1% 1% 2% 0% 10B: Black Mtn Point area 2% 2% 2% 3% 2% 2% 4% 2% 2% 2% 4% 2% 2% 2% 4% 2% 2% 1% 10D: Black Mtn Point 2% 1% 2% 2% 2% 2% 3% 1% 2% 2% 2% 2% 1% 2% 3% 2% 1% 0% 11A: Harbor Islands area 0% 1% 0% 0% 0% 0% 2% 0% 0% 0% 1% 0% 0% 0% 1% 0% 0% 0% 11B: Mother Bunch Island area 2% 2% 2% 2% 2% 3% 2% 1% 2% 2% 2% 2% 2% 2% 4% 1% 2% 5% 11C: Harbor Island 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 11D: Hulett's Landing 1% 1% 1% 1% 1% 1% 1% 0% 1% 1% 1% 1% 0% 1% 2% 0% 1% 0%

Copy of LAGroup Crosstabs 8 of 13 LA Group Lake George Recreation Survey 2015 977 Lake George Boaters, Dock Owners Recreation Visitors

12A: Sabbath Day / Silver Bay 1% 1% 1% 1% 0% 2% 0% 1% 1% 1% 0% 1% 0% 1% 1% 0% 1% 3% 12B: Bluff Head area 0% 1% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 1% 1% 12C: Werner's Bay 1% 2% 1% 1% 1% 1% 1% 0% 1% 2% 0% 2% 1% 0% 1% 2% 2% 0% 12D: Bass Bay 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 13A: Pardo Point area 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 13B: Mallory Island area 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 13D: Arcady Bay 0% 1% 0% 0% 0% 1% 0% 1% 0% 0% 0% 1% 0% 0% 0% 0% 2% 0% 13E: Hague Bay 2% 3% 2% 2% 2% 1% 2% 1% 1% 3% 1% 3% 0% 1% 2% 2% 2% 1% 13F: Gull Bay 0% 1% 0% 1% 1% 0% 0% 0% 1% 0% 1% 0% 0% 0% 1% 1% 0% 0% 14A: Walltonian Islands area 2% 2% 2% 2% 1% 2% 2% 2% 2% 1% 1% 2% 1% 2% 2% 1% 1% 3% 14B: Rock Bro's Is / Brown's Pt 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 15A: Friend's Pt / Roger's Rock 1% 2% 1% 2% 1% 1% 1% 1% 1% 1% 1% 1% 1% 2% 2% 1% 1% 0% 15B: Brown's Pt / Weed's Bay 1% 2% 1% 1% 1% 1% 2% 0% 1% 0% 0% 1% 0% 1% 0% 1% 1% 1% 15C: Blairs Bay 0% 1% 0% 0% 0% 0% 1% 0% 0% 0% 1% 0% 0% 0% 1% 0% 0% 0% 16A: Ticonderoga area - West side 1% 2% 1% 0% 1% 1% 2% 0% 1% 2% 2% 1% 0% 2% 1% 1% 1% 2% 16B: Ticonderoga area - East side 1% 3% 1% 1% 1% 1% 1% 0% 1% 2% 2% 1% 0% 2% 2% 1% 1% 2% 16C: Heart Bay 0% 1% 0% 0% 1% 0% 1% 1% 0% 0% 0% 1% 0% 0% 0% 1% 0% 1% 16D: Mossy Point 1% 2% 1% 0% 1% 0% 1% 1% 1% 1% 3% 0% 0% 2% 1% 0% 0% 0% 16E: N. of natural dam 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Did not feel there was boat congestion on 35% 24% 35% 37% 37% 30% 31% 35% 36% 36% 24% 35% 48% 37% 29% 37% 35% 35% the Lake

Did you change your plans or modify your behavior in any of the following ways because of problems you experienced on your recent visit to Lake George? (Check all that apply). Use of Lake George Gender Age Association with Lake George Home Community 65 and Year-round Seasonal Visitor/Day- Under 5,000 5,000 to 24,999 25,000 to Over 100,000 Total Dock Boat Recreation Male Female Under 40 40 to 49 50 to 64 older resident visitor user Rural people people 99,999 people people Boated earlier or later in the day 29% 34% 29% 30% 27% 36% 21% 32% 31% 28% 37% 28% 23% 26% 36% 26% 31% 32% Boated more often earlier or later in the 17% 20% 17% 15% 16% 18% 12% 15% 19% 15% 31% 12% 13% 21% 20% 15% 18% 8% season Boated more on weekdays than weekends 40% 49% 40% 42% 36% 49% 30% 25% 38% 53% 55% 37% 28% 42% 51% 35% 36% 36% or holidays Boated other areas of the lake than where 11% 10% 11% 14% 10% 13% 23% 11% 11% 7% 11% 11% 11% 9% 10% 10% 16% 13% I prefer Canceled certain boating activities (e.g., 9% 15% 9% 12% 8% 12% 20% 11% 9% 5% 11% 11% 4% 6% 12% 8% 11% 12% water-skiing) Boated on other water bodies 5% 2% 5% 6% 5% 3% 8% 5% 5% 3% 6% 3% 8% 6% 6% 5% 2% 1% None of the above 44% 40% 44% 43% 47% 36% 46% 51% 43% 41% 27% 49% 50% 41% 33% 48% 45% 48%

Are you aware of the special Rules and Regulations on Lake George for governing speed, engine noise, anchoring, PWC use, parasailing, etc.? Use of Lake George Gender Age Association with Lake George Home Community 65 and Year-round Seasonal Visitor/Day- Under 5,000 5,000 to 24,999 25,000 to Over 100,000 Total Dock Boat Recreation Male Female Under 40 40 to 49 50 to 64 older resident visitor user Rural people people 99,999 people people Yes 88% 92% 88% 88% 88% 88% 80% 88% 89% 91% 93% 89% 81% 91% 89% 88% 83% 91% No 12% 8% 12% 12% 12% 12% 20% 12% 11% 9% 7% 11% 19% 9% 11% 12% 17% 9%

Copy of LAGroup Crosstabs 9 of 13 October 13, 2020

Memo

To: File From: J. Thouin Re: Recreational Boating Analysis

The applicant seeks to remove the existing fuel pump and fuel lines from the middle of the dock complex. The new fuel lines will be located entirely upland, with a flexible fuel line proposed to dispense fuel to customers on the south side of the most southern, 123' dock. No modifications to the docks are proposed.

Existing Southern Dock Use: The Snug Harbor facility plan indicates the most southern dock is 20’± north of and parallel with the property line. The neighboring residential property to the south has a dock authorized 11’8” south of the common property line. Presently, the south side of Snug Harbor’s most southern dock is utilized by 3 seasonal berthing customers. The 2006 Lake George Recreation Study indicates that seasonal berthing customers use their vessels 10 per month, or 0.357x per day. As such, the current boat activity immediately adjacent to the southern neighbor is roughly 1 boat trip per day to/from the south side of the southern pier.

Fuel Dock, Estiated Average Daily Use: The application states that average daily gas customers at Snug Harbor total a maximum of 29 vessels (1-2 berthing customers, 10-15 rental customers, and 10-12 public customers). The application also provides that 37,781.7 gallons of fuel gas was delivered to the subject facility in 2019, which is intended to approximate fuel dispensed to vessels at the facility fuel dock. Assuming a 90 day boating season, and 29 vessels fueled per day, this equates to roughly 14.5 gallons per vessel. The fuel tank on most vessels can accommodate 25-50 gallons of fuel. The low estimate for gallons/vessel indicates that 29 vessels per day may be an overestimate for typical daily use June through August. Compared with the current use of the southern dock, the proposed fueling activity at this location would increase boat traffic on this pier by 29 times the current estimated value (1).

Fuel Dock, Estimated Max Daily Use: The facility is authorized 40 boats on the docks and 30 quick launch for use by seasonal berthing customers and rental vessels. The site is allowed a maximum of 40 rental vessels and 40 seasonal berthing customers. The maximum potential number of vessels that may utilize the fuel dock in one day is dependent on the number of times that each rental vessel is utilized in one day. The facility is authorized for up to 40 rental vessels, and offers 2hr, 4hr, and full day rentals. As such, it’s possible that each vessel may be used multiple times per day. For purposes of this analysis, we will assume a maximum number of daily rentals of 40 and that these vessels take 1 boat trip per day. The remaining 30 vessels onsite would be seasonal customers that may be represented by the estimated 0.357 trips per day; collectively 10.7 total boat trips. Using these values, it is estimated that the fuel dock is visited a maximum 51 times per day. Compared with the current use of the southern dock, the proposed fueling activity described above would increase boat traffic on this pier by 51 times the current estimated value (1).

Lines of Boats Waiting for Fuel: On busy boating days it is not uncommon for lines of boaters to develop at facilities that offer fuel. Snug Harbor has approximately 509’ of lakefront. Presently, the fuel dock is located roughly 150’ from its southern boundary in approximately the center of the main docking facilities. Moving the fueling location 130’ south to the most southern location of the facility creates greater potential for lines of boaters that may have once formed entirely in front of the facility, to now expand beyond the facility and into the waters directly in front of nearby residential properties.

Joe Thouin

From: Joe Thouin Sent: Friday, October 16, 2020 9:50 AM To: Joe Thouin Subject: Snug Harbor North

From: Joe Johns Sent: Wednesday, October 14, 2020 12:51 PM To: Joe Thouin Subject: RE: Snug Harbor North

Good Afternoon,

After looking over the plan for Snug Harbor North, I think the new configuration of the gas dock will be safer for the public. By keeping the south dock open for gas, more than one boat can pull in at a time. The area in front of the existing gas dock is in an area that is subject to wind and current from the channel. An inexperienced boater often has difficulty dealing with these conditions while waiting to be pulled into the gas dock. The new gas dock would allow multiple boats to pull straight into the dock and avoid the wind and current.

Joe

1 617.21 State Environmental Quality Review NEGATIVE DECLARATION Notice of Determination of Non-Significance

Project Number: M20-000006 Date:

This notice is issued pursuant to Part 617 of the implementing regulations pertaining to Article 8 (State Environmental Quality Review Act) of the Environmental Conservation Law.

The Lake George Park Commission has determined that the proposed action described below will not have a significant effect on the environment and a Draft Environmental Impact Statement will not be prepared.

Name of Action: Snug Harbor Fuel Service Modification

SEQR Status: Unlisted Action

Description of Action: Relocation of gas dispenser and customer fueling station

Location: Parcel: 150.75-3-3.000, 92 Black Point Road Ticonderoga, NY 12883

Reasons Supporting This Determination: Snug Harbor is an existing Class A Marina offering seasonal berthing, quick launch, boat rentals, sales, service, and fuel. The applicant seeks to modify the fuel service operation by updating and relocating the fuel dispenser equipment and relocating the associated fueling station for vessels on the facility's docks. Specifically, the applicant seeks to remove the existing fuel pump and fuel lines from the middle of the dock complex. The new fuel lines will be located entirely upland, with a flexible fuel line proposed to dispense fuel to customers on the 123' south dock. No modifications to the docks are proposed.

The waters of Lake George, all land lying under such waters and within 500 feet of the mean high-water mark of such waters, and wetlands located adjacent to the waters of Lake George and all land within 500 feet of such wetlands are designated a Critical Environmental Area pursuant to Section 617.4(h) of the State Environmental Quality Review Act regulations (6NYCRR) and 645-3.8 of the Lake George Park Commission regulations (6NYCRR).

The reason for this designation was and is to afford increased protection of a unique resource of state-wide significance and to recognize and protect the exceptional natural beauty, scenicquality, water quality, fish & wildlife habitat, historic significance, recreational resources andecological sensitivity of the Lake.

For Further Information: Contact Person: Joe Thouin Deputy Permit Administrator Lake George Park Commission, PO Box 749, Lake George NY 12845 Telephone Number: 518-681-0934 Fax (518) 668-5001 E-mail: [email protected]

______

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35,17 )250 3DJHRI

LGPC APPLICATION SUPPORTING INFORMATION

1. Updated site plan showing the proposed/ preferred site modifications See Diagram

100’ of new gas line will be run from existing 3,000 gallon fuel tank located in existing cement dike to the new single 2 hose gas dispenser.

2. Updated dock plan showing where fuel customers vs berthing customers will be located. The existing dock sketch is contained within the marina permit attached.

See Diagram

We have multiple dockage slips available for the 2021 season. We are going to relocate 3 boats located on the South dock to open slips next season. We are going to keep the existing gas dock open for rental boats and service customers to keep traffic flowing towards center dock.

First, we are going to relocate a 32’ Carver Cruiser from slip 13S to new location 10S. Second, 21’ Bennington Pontoon from slip 14S will be relocated to 4N. Third, 24’ Bennington Pontoon from slip 15S will be relocated to 5N.

3. A description and copy of specifications for the fuel storage and dispensing equipment

Note: Modification to existing fuel storage tank in dike will include a new submersible pump in the existing 3,000 gallon tank. New pipe attachment from existing 3,000 gallon tank will go into a transition sump with sensors in dike and run underground 100’ to a raised concrete platform. The platform will include a containment sump with alarm sensors. There will be two reels with new gas hose 125’ in length.

Attached is a copy of the new equipment which include, select dispenser will be Twin 1 with price displays,Omntec proteus will have a sensor in the Transition sump at the tank and under the dispenser, Flex pipe will be 1.5 “ inside of duct pipe, etc.

4. An updated spill plan. See requirements at 646-1.2(b)(5) cited below and the existing spill plan attached

Current Spill Prevention Plan Attached

5. A description of the proposed changes to the fueling operation including details on changes to boating patterns (eg. public fuel customers, boat rental fueling, etc.), and how the proposal may be operated so as to minimize any impacts to neighbors (see regulations regarding neighborhood impacts at 646-1.6(a) cited below).

See Diagram

Approximately 3 gas customers at a time on the end of the center dock. Existing customers will now relocate to South Dock.

South Dock will be the new location for public fuel customers. To reduce boat traffic in that area we are going to keep the existing gas dock for the boat rentals. Boat rental safety procedures and reviewing of rental boat contracts will still be conducted on the Center Dock (unchanged). We send out the rental boats from 8:30am to 4:00pm the latest. End of day check-in procedure for fueling rental boats will be located on the South Dock (rental returns are no later than 6:00pm).

6. Related to the above, present alternatives that you have considered, and provide a narrative describing why these alternatives are not preferable

Alternative option was to replace existing fuel dispenser on center dock with 125’ of new pipe run from dispenser to land, additional lines along lakeside of building around south corner, and back to existing 3,000 gallon fuel tank.

Concern for replacing equipment in existing location: (1) Cost prohibitive (2) Potential environmental impacts/hazards with gas lines and dispenser being located 125’ in length over the water. After with consulting with Northeast Petroleum they advised that most equipment in that length is not designed for a permanent solution. Many marina with this setup would be put in as a temporary solution that people are keeping for permanent usage which poses many risks. The proposed plan in the new location will help us to be proactive with expecting regulatory changes in the future with the DEC including containment tanks, leaking sensors, alarm system, etc. (3) The new system will have live monitoring connected to the adjacent building whereas the existing location has no monitoring system.

7. Provide a copy of any existing permits and/or status of applications/jurisdictional inquiries/review for compliance with NYS Fire Code, the DEC (bulk storage), the County, the Town, and the APA (see 646-1.6(f) below)

See Attachments

8. For context regarding boat traffic related to fueling, provide any available information on the average and max number of fuel customers (per day/week/year), and any customer information (eg. general public vs existing onsite Snug customers)

No fueling would begin before 8:30AM

Average for Daily gas of berthing customer ~1-2 boats **Note: all cruisers on the south dock could fuel from their own slips Average for Daily gas of rental customer ~10-15 boats Average for Daily gas of public customer ~10-12 boats

No fueling would occur after 6 PM

Gas Dock would open Memorial Day and would close sometime near Columbus Day

9. Provide an estimate of fuel dispensed during the boating season Completed 2019 Gallons Delivered from Mountain Petroleum

37,781.7

10. Provide hours of operation for customer fueling Before Memorial Day: 5 days a week, Monday-Friday 8:30am to 5:00pm

Memorial Day to Labor Day: 7 days a week, Sunday-Saturday 8:30am to 6:00pm

Labor Day to Columbus Day: 5 days a week, Monday-Friday 8:30am to 5:00pm

11. Clarify if boat renters fuel up themselves onsite, or if this is a service provided by the marina

Boat rental customers pull up to fuel dock, remove personal equipment while a dock hand fuels the boat. General public customers are also fueled by a dock hand.

1. As previously noted, compliance with other local and State codes is required for approval by the Commission. Provide a copy of any existing permits and/or status of applications/jurisdictional inquiries/review for compliance with NYS Fire Code, the County, the Town, and the APA.

Ticonderoga Town Codes Officer (Bill Ball) **Still waiting on a response

Region 5 NYSDEC- Ben Hankins, Assistant Engineer (Environmental), Division of Remediation. I have attached our current Petroleum Bulk Storage Certificate. PBS Number: 5-488178 which is valid until 6/15/2023. We had an inspection and are fully compliant as is. As required, if we get approval from the LGPC, we will need to fill out a New York State Department of Environmental Conservation Pre-Work Notification for Bulk Storage (PBS or CBS) Tank Installation or Closure. This will be done 30 days before the work begins. All of the equipment provided from Northeast Petroleum Technologies, Inc. complies with the 613-4.1 requirements.

According to Region5 NYSDEC- Ben Hawkins, Assistant Engineer (Environmental), Division of Remediation: “attached is the tank notification to notify the Department of the piping upgrade. The piping will need to be installed according to 613-4.1(b)(2) as shown below. Once the piping is complete, the application will need to be updated to reflect site conditions”.

(2) Piping. Piping that routinely contains petroleum and is in contact with the ground must be properly designed, constructed, and protected from corrosion in accordance with subparagraph (i) or (ii) of this paragraph.

(i) Piping made of a non-corrodible material must meet the following conditions.

(a) The materials, joints, and joint adhesives must be compatible with petroleum, petroleum additives, and corrosive soils.

(b) All underground piping must be designed, constructed, and installed with access ports to permit tightness testing without the need for extensive excavation.

(d) All underground piping must be tested for tightness before being covered, enclosed or placed in use.

(e) All piping installed after October 11, 2015 must be designed and constructed according to one of the following codes of practice (refer to section 613-1.10 of this Part for complete citation of references):

(1) UL 971, February 2006; or (2) ULC-S660-08, 2008.

(ii) Piping made of steel that is cathodically protected must meet the following conditions:

(a) The cathodic protection system must provide a minimum of 30 years of protection in corrosive soils.

(b) Cathodic protection must be provided by the use of sacrificial anodes or impressed current.

(c) Where sacrificial anodes or impressed current systems are used, monitors to check on the adequacy of the system must be installed and kept in proper working condition. If at any time the monitor shows that the electrical current necessary to prevent corrosion is not being maintained, the system must be repaired or the piping will be considered unprotected and must be tested for tightness in accordance with section 613-4.3(d)(2) of this Subpart.

(d) Except where cathodic protection is provided by impressed current, underground piping must have dielectric bushings, washers, sleeves, or gaskets installed at the end to electrically isolate the piping from the AST and the dispenser. These dielectric connectors must be compatible with petroleum, petroleum additives, and corrosive soils.

(e) All underground piping must be designed, constructed, and installed with access ports to permit tightness testing without the need for extensive excavation.

(f) All joints must be liquid and air tight.

(g) All underground piping must be tested for tightness in accordance with section 613-4.3(d)(2) of this Subpart before being covered, enclosed, or placed in use.

(h) All piping installed after October 11, 2015 must meet the following conditions:

(1) The piping must be designed and constructed according to UL 971A, October 2006 (refer to section 613-1.10 of this Part for complete citation of references);

(2) The piping must be coated with a suitable dielectric material;

(3) The cathodic protection system must be designed, fabricated, and installed according to one of the following codes of practice (refer to section 613-1.10 of this Part for complete citation of references):

(i) API RP 1632, January 1996 (revised 2002);

(ii) STI R892, January 2006;

(iii) NACE SP0169-2013, 2013; or

(iv) NACE SP0285-2011, 2011. (4) Every field-installed cathodic protection system must be designed by a corrosion expert;

(5) Every impressed current system must be designed to allow determination of current operating status as required in section 613-4.2(b)(2) of this Subpart.

(6) Every cathodic protection system must be operated and maintained in accordance with section 613-4.2(b) of this Subpart.

2. As you know, the neighbor has expressed some concern regarding the proximity of the fueling station to his property. In the Town of Ticonderoga, how close can a structure be placed to the property boundary?

Are there any special provisions related to fuel stations?

Ticonderoga Town Codes Officer (Bill Ball) **Still waiting on a response.

What is the distance between the proposed fueling station and the property line?

Attached is a few pictures for clarification as to where the dispenser will be located. The distance between our Main Marina Building and the Neighbors Property is 31’ 4” . The dispenser will be placed approximately 15 foot 7 inches from the neighbors property, leaving the same distance between the dispenser and our building.

3. The south dock is proposed for fueling. This dock is 123’ long. The flexible fuel line is proposed to start on land. The fuel pump information provided does not appear to include a reel to house the 123+’ fuel hose. From a practical perspective, please clarify how this flexible fuel hose will be handled and stored.

I have attached the spec sheet on the marine grade reel. The flexible fuel hose will be stored on this reel attached to the dispenser. This reel is rated to hold up to a 125’ of 1” hose. The fuel hose we will be using and storing on this reel will be a ¾” hose marine grade hose.

a. Will the hose be coiled up on the grass, and walked out over the dock for each customer?

This hose can easily be pulled out and reeled back up in between gas customers. We are using a ¾” hose which will reel much easier than the allowed 1” hose. b. Will the hose and nozzle remain extended and laying on the dock all day, and be brought upland at the close of business?

We would like to avoid having the hose just laying on the dock when not in use. The hose will be pulled to fill up any boats that are at the dock at the time or coming in to be fueled. The hose will then be reeled up.

At the end of the night the hose will also be brought into the reel and locked.

c. May dragging the hose up and down the wood dock lead to potential damage of the hose line?

The hose that we are using with the dispenser is a marine grade fuel hose and reel assembly, the reel is a covered unit that will help preserve the hose from weather. The hose itself is a heavy duty material called PTFE. That stands for polytetrafluoroethylene—a plastic material that is best known as Teflon in one specific variation. This material is impervious to the degenerative effects. d. How will the hose be utilized on the dock so as to minimize tripping hazards to customers and staff?

We will be purchasing the green fuel hose (not black) so it will stand out while on the dock to minimize tripping hazards. This system will actually be safer than our current situation where the black gas hose is just laid on the dock. We will not be leaving the gas hose laying on the dock when not in use.

4. The application states that the proposed fueling system may not duplicated at the middle dock, because replacing the existing upland fuel line is cost prohibitive. Can you please quantify and/or elaborate on this?

The cost of this project is already overwhelmingly expensive. We knew our situation with the antiquated gas dispenser and piping would eventually need to be addressed, we did not know it would require replacing the entire piping to be compliant with all of the upcoming regulations. It would cost thousands of dollars to replace the current dispenser in its current location or even modifying the middle pier dock to have a dispenser on that.

Having only 100’ of piping and the dispenser sitting on land, with a sump containment dispenser pan under it. We feel this is the safest to place on the property. For every amount of underground/under-dock fuel line creates an added cost and added risk.

PUMP MEASURE CONTROL Fuel Dispensing and Metering Solutions HR8 / HR9 Hose Reel Cabinet

The HR8/9 External Hose Reel provides an attractive solution when a hose reel is required to accommo-  75ft of 1” hose capacity date longer lengths of hose. Our hose reel cabinet

will effectively reduce ground clutter while at the  50ft of 1 1/2” hose capacity same time providing hose protection from harmful UV rays.  Stainless steel welded frame

The cabinet is  Brushed stainless steel panels supported by a stainless steel in-  Left or right side outlets ternal frame, which is welded  Corrosion Resistant together, not  Protects hose from UV dam- bolted. The 316 age stainless steel panels will remain  Attractive design like-new for a very long time, even in the harshest salt- water environments. Hose is managed by a Hanney spring re- wind reel and is available in left or right side inlet configurations.

We built the HR series hose reel cabinet to be tough, and to perform as expected after many years of heavy use. Stainless steel can still rust when sub- jected to highly corrosive environments like marinas, that is why we use high grade stainless for all of our marine units. We pride our marine products for their excellent resistance to rust and corrosion.

www.pmc-ga.com

HR8 / HR9 Hose Reel Cabinet SPECIFICATIONS

Transition & Special Application Sumps X End

BELOW GROUND PRODUCTS www.opwglobal.com

Transition Sumps TRANSITION SUMP ASSEMBLY Model PTS-4021 Transition Sump INSPECTION HATCH SCH. 40 (OPEN POSITION) STEEL PIPE (2 Piece - Polyethylene Sump/ Polyethylene Top)

PTS-4021 TRANSITION u SUMP Non-corroding, polyethylene 21BV SERIES sump container FULL-PORT BALL VALVE u Weatherproof lockable cover OPW FMS u Exterior anchoring system LEAK SENSOR JUNCTION AST Application: Provides secondary TEST TUBE containment and accessibility to the ENTRY ASSEMBLY FITTING fittings that connect the underground supply piping to the rigid supply piping SWIVEL ELBOW that leads from an above ground storage tank.

AXP SERIES DOUBLE-WALL DOUBLE-WALL Vent Stack Application: Transition sump is ACCESS PIPE FLEXIBLE PIPE COUPLING used for containment and accessibility to the fittings. At the vent stack, where the underground vent piping connects to the AST Vent Stack rigid vent stack piping. Application Application

41" 30" (1,041 mm) (762 mm)

16-1/2" (406 mm)

46-1/2" (1,168 mm) 30" (762 mm) FRONT VIEW SIDE VIEW

24" 38-1/2" (609 mm) (965 mm)

The complete Environmental System for underground fuel transfer and containment for the 21st century.

51 Polyethylene Pans

BELOW GROUND PRODUCTS www.opwglobal.com

FlexWorks Polyethylene Dispenser Pans FlexWorks Dispenser Pans are installed beneath fuel dispensers to provide secondary containment of dispenser plumbing and emergency shear valves. Dispenser pans are commonly used with rigid fuel pipe and to retroft existing dispensers.

Ordering Specifcations B FlexWorks Polyethylene Dispenser Pan Dimensions Weight Model * A B C D E in. cm in. cm in. cm in. cm in. cm lbs. kg

1 1 1 1 E DP-1117F 14 /2 37 10 /2 27 20 /2 52 16 /2 42 11 28 20 9

DP-1123 15 38 11 28 27 69 23 58 11 28 23 10

DP-1123F 15 38 11 28 27 69 23 58 11 28 23 10

C DP-1543 19 48 15 38 43 109 38.8 99 11 28 44 20

DP-1630 20 51 16 41 34 86 30 76 11 28 38 17

DP-1836 211/2 55 171/2 44 40 102 36 91 11 28 50 23

* Flush Mount Model (F) Supplied without Rain Lip Due to Dispenser Frame Clearance Limitations; Supplied with Frame Gasket. Anchor Bolts Provided, Stabilizer Bar Kits Ordered Separately; One Kit Required for each Emergency Shut-Off Valve.

39 Dispenser Sump Selection Chart

Ordering Specifcations - FlexWorks Dispenser Sump Selection Chart Dispenser Footprint Dispenser Manufacturer & Model FlexWorks FlexWorks FlexWorks FlexWorks FlexWorks Dimensions One-Piece Wide-Access One-Piece One-Piece Wide-Access Stabilizer Polyethylene Polyethylene Polyethylene Fiberglass Fiberglass Bar Kit GILBARCO in. cm Sump Sump Pan Sump Sump Commercial 625, 650, 684 Series 1511/16" x 21" 40 x 53 DS-1117F --- DP-1117F ------SBK-1100J (21" / 53" cm Frame)

Salesmaker-2 Series (21" / 53 cm Frame) 1511/16" x 21" 40 x 53 DS-1117F --- DP-1117F ------SBK-1100J

Highline 11B Series (21" Frame / 53 mm) 1511/16" x 21" 40 x 53 DS-1117F ------SBK-1100J

Highline 111B Series (27" / 69 cm Frame) 1511/16" x 27" 40 x 53 DS-1123F DSW-1123F DP-1123F ------SBK-1100J Trimline 251, 252, 261, 262 1511/16" x 27" 40 x 69 DS-1123F DSW-1123F DP-1123F --- DSF-1123F SBK-1100J (27" / 69 cm Frame) Trimline 154, 164, 251, 262 1511/16" x 21" 40 x 69 DS-1117F ------SBK-1100J (27" / 69 cm Frame) Commercial 650 Series 1511/16" x 27" 40 x 69 DS-1123F DSW-1123F DP-1123F --- DSF-1123F SBK-1100J (27" / 69 cm Frame)

Highline Salesmaker Series 1511/16" x 21" 40 x 69 DS-1117F --- DP-1117F ------SBK-1100J

Highline Salesmaker Series (27" / 69 cm 1511/16" x 27" 40 x 69 DS-1123F DSW-1123F DP-1123F --- DSF-1123F SBK-1100J Frame)

Salesmaker-4 Series (27" / 69 cm Frame) 1511/16" x 27" 40 x 69 DS-1123F DSW-1123F DP-1123F --- DSF-1123F SBK-1100J

Legacy Series 1511/16" x 27" 40 x 69 DS-1123F DSW-1123F DP-1123F --- DSF-1123F SBK-1100J

231/2" x DSW-1836 DSF-1836 Encore Series LOOP SYSTEM- 60 x 103 DS-1836 DP-1836 FDS-4021 SBK-1800* READY 409/16" DSW-1836CL DSF-1836C

Advantage (36" / 91 cm Frame Models) 211/2" x 36" 55 x 91 DS-1630 DSW-1630 DP-1630 --- DSF-1630 SBK-1600 Quad or Dual ------

Blender X + O (36" / 91 cm) ------

Advantage (48" / 122 cm Frame Models) 211/2" x 48" 55 x 122 DS-1642 ------SBK-1600*

Blender Six-Hose ------

Blender Single-Hose ------Blender X + O (48" / 122 cm) or X + 1 ------(48" / 122 cm) MPD-1, MPD-2, MPD-3 16" x 48" 41 x 122 DS-1036 ------SBK-1000J

MPD Fixed Blender 16" x 48" 41 x 122 DS-1036 ------SBK-1000J

------

BENNETT

LOOP SYSTEM- 1 1 Bennett Pacific READY 19 /2" x 43 /2" 49 x 110 DS-1543A ------SBK-1500

Bennett 3000 Series 20" x 30" 51 x 76 DS-1123B ------SBK-1100J

PD MCLAREN

RDR HSx (Single Product, Single Hose) 21” x 17.75” 53 x 45 --- DSW-1922 ------SBK-1900

RDR HSx-D1 (Single Product, Dual Hose) 21” x 17.75” 53 x 45 --- DSW-1922 ------SBK-1900

RDR HSx-D2 (Dual Product, Dual Hose) 21” x 17.75” 53 x 45 --- DSW-1922 ------SBK-1900

RDR HSx-SAT (Master Unit and Satellites) 21” x 17.75” 53 x 45 --- DSW-1922 ------SBK-1900 RDR HSx-X2 (Single Product, Dual Hose, 21” x 17.75” 53 x 45 --- DSW-1922 ------SBK-1900 One at a Time)

* For FDS-4021 Models, use Stabilizer Bar SBK-1800.

42 9393 Princeton-Glendale Road Hamilton, Ohio USA 45011 Phone: (800) 422-2525 Fax: (800) 421-3297 BELOW GROUND PRODUCTS www.opwglobal.com

0215A, 216A (197/8" Frame / 50.5 mm) 171⁄4" x 197⁄8" 49 x 50.5 DS-1117F --- DP-1117F ------SBK-1100J

52 and 53 Series 17" x 197⁄8" 44 x 50.5 DS-1117F --- DP-1117F ------SBK-1100J

8700, 8800, 9100, 9800 Series 171⁄4" x 25" 44 x 63.5 DS-1120 ------SBK-1100J

25" Frame 63.5 mm 171⁄4" x 25" 44 x 63.5 ------

8700, 8800, 9100, 9800 Series (281⁄4" 171⁄4" x 28" 44 x 71 DS-1123 DSW-1123 DP-1123 ---- DSF-1123F SBK-1100J Frame / 72 mm)

9850A 1511⁄16" x 21" 40 x 69 DS-1120 DSW-1120 ------DSF-1120 SBK-1100J

* Stabilizer bar is installed widthwise in dispenser sump

DRESSER / WAYNE

350, 357, 358, 360, 370 Series 15" x 257⁄8" 30 x 66 DS-1123F DSW-1123F DP-1123F ---- DSF-1123F SBK-1100J

Vista 380 Series (387, 389) 20" x 35" 51 x 89 DS-1229 ------SBK-1200J

Vista 590 Series (590, 595) 20" x 48" 51 x 122 DS-1242 ------SBK-1200J

Vista 390 Series (395, 399) 20" x 48" 51 x 122 DS-1242 ------SBK-1200J

Vista 490 Series 20" x 48" 51 x 122 DS-1242 ------SBK-1200J

DL390, 395, 399 Series 20" x 48" 51 x 122 DS-1242 ------SBK-1200J

HS1 Satellite / 287 Series 20" x 35" 51 x 89 DS-1229 ------SBK-1200J

LOOP SYSTEM- DSW-1543 DSF-1543 Ovation 191⁄2" x 431⁄2" 50 x 110 DS-1543A** DP-1543 FDS-4319* SBK-1500 READY DSW-1543C DSF-1543C

Select 193⁄8" x 325⁄16" 49 x 82 DS-1928 ------DSF-1630 SBK-1500

Global Century 193⁄8" x 325⁄16" 49 x 82 DS-1928 ------DSF-1630 SBK-1500

Reliance 193⁄8" x 325⁄16" 49 x 82 DS-1928 ------DSF-1630 SBK-1500

HS4 / HS3 / Vista 193⁄8" x 325⁄16" 49 x 82 DS-1630 DSW-1630*** DP-1630 ---- DSF-1630*** SBK-1600

Narrow Frame Helix (2000, 4000) 20" x 33" 51 x 84 DS-1630 ------SBK-1600

LOOP SYSTEM- Wide Frame Helix (5000) READY 26" x 44" 51 x 112 DS-1741 ------SBK-1700

TOKHEIM

1200, 1248, 1250 Series 171⁄4" x 25" 44 x 64 DS-1120 DSW-1120 ------DSF-1120 SBK-1100J

330B, 333B Series 171⁄4" x 44" 44 x 112 DS-1642 ------SBK-1600

* For FDS-4319 Model use Stabilizer Bar SBO-0250.

Dispenser Sump Selection Dispenser Sumps/Pans Chart Piping & Containment • FlexWorks Supply Systems Piping

FlexWorks Supply Piping Why flex pipe? OPW developed FlexWorks Pipe in response to customer feedback. You asked and we delivered! The pipe is more flexible, lighter and has reduced memory. Celebrating Over 20 Years of Pipe can also be replaced without breaking concrete. Success Through Piping Excellence

Elimination of potential underground leak points

u No underground fittings or joints u No hand-built field joints u All termination points are contained safely inside sumps u Termination joints precision swaged to simulate factory made assemblies

Primary Pipe Light, Flexible, & Easy Outer Barrier to Install. ULC Approved Kynar® PVDF Fully Bonded Coaxial for All Fuels Thermalplastic Construction featuring Kynar® ULC APPROVAL Primary Pipe Inner Barrier Kynar® PVDF Motor Vehicle Fuels

High Blend Fuels

Concentrated Fuels What Makes This Pipe Different? Lower installation costs

Aviation and Marine u Eliminates the hassles – installation u No adhesives – heat assists, time and potential leak points of rigid curing problems or electrofusion pipe installations welding of joints u Fast and easy installation – results u Easy to bend – no special fittings to 3rd PARTY in less installation labor, time and cost install in order to make bends APPROVED u Eliminates burdensome cutting, fitting, FOR DEF and cleaning

See pages 141 - 144 for details on the OPW DEF System

8 9393 Princeton-Glendale Road Hamilton, Ohio USA 45011 Phone: (800) 422-2525 Fax: (800) 421-3297 BELOW GROUND PRODUCTS www.opwglobal.com

Ordering Specifications - Sizing Matrix FlexWorks Supply Piping New Pipe ID Description OPW's FlexWorks Pipe is more Part # flexible, lighter and has reduced C075A-250 Double Wall Primary Pipe, 250' memory to aid installation and is C075A-1000 Double Wall Primary Pipe, 1000' UL approved for all fuels.

C075A-SB 3/4" Double Wall Primary Pipe 3/4" I.D. Short Box, 1' - 249'

3 C075A-SR Double Wall Primary Pipe /4" I.D. Short Reel, 260' - 490' FlexWorks Supply Piping CO75A-MR Double Wall Primary Pipe, Mega Reel, 2000'

C10A-250 Double Wall Primary Pipe, 250' C10A-1000 Double Wall Primary Pipe, 1000' C10A-SB 1" Double Wall Primary Pipe 1.0" I.D. Short Box, 1' - 249' C10A-SR Double Wall Primary Pipe 1.0" Short Reel, 20' - 990' C10A-MR Double Wall Primary Pipe, Mega Reel, 2000'

C15A-250 Double Wall Primary Pipe, 250' C15A-500 Double Wall Primary Pipe, 500' C15A-1000 Double Wall Primary Pipe, 1000'

C15A-1225 Stick Pipe* 11/2" 12 Pieces At 25', 12 per box

C15A-1233 11/2" Stick Pipe* 11/2" 12 Pieces At 33', 12 per box

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12 9393 Princeton-Glendale Road Hamilton, Ohio USA 45011 Phone: (800) 422-2525 Fax: (800) 421-3297

Joe Thouin

From: dec.sm.DEP.R5 Sent: Monday, September 28, 2020 2:45 PM To: Joe Thouin Cc: Duval, Kelly A (DEC) Subject: RE: Snug Harbor North Attachments: image005.jpg; image006.png; image007.png; image008.jpg

Good Afternoon,

Please complete a No Exposure form (https://www.dec.ny.gov/docs/water_pdf/noexposure.pdf) for your permit and provide documentation to the Department that requirement was met. If you have questions regarding this, please contact Steve McCague in División of Water in Albany at 518-402- 8111.

Thank you,

Bethany Kress Program Aide, Division of Environmental Permits

New York State Department of Environmental Conservation 1115 State Rte 86, Ray Brook, NY 12977 P: (518) 897-1234 | F: (518) 897-1394 | [email protected] www.dec.ny.gov | | |

From: Joe Thouin Sent: Monday, September 28, 2020 12:25 PM To: [email protected]; 'Chris Navitsky' ; apa.sm.Referrals ; dec.sm.DEP.R5 ; [email protected]; [email protected] Subject: NAR: Snug Harbor North

ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.

Dear folks,

Please find attached a notice of availability of review for a marina modification at Snug Harbor North. The marina proposes to modify the fueling services by changing fuel docks and fueling equipment. No other modifications to the marina are proposed.

Please let me know if you have any concerns or related jurisdiction.

Respectfully yours, 1 Joe Thouin

From: Joe Thouin Sent: Monday, October 19, 2020 10:51 AM To: Joe Thouin ([email protected]) Subject: Snug Harbor

From: Huyck, Brian (DEC) Sent: Monday, October 19, 2020 8:38 AM To: Burns, Erin (DEC) Subject: RE: October 2020: LGPC Site Visits

Erin, FYI

Ben Hankins has been in contact with Michelle Palandrani from Snug Harbor. They plan to move the dispenser from the dock, back to shore. In doing so, they will be replacing the line from the tank to the dispenser. The piping will be double- walled and the dispenser will have containment under it. On our side, this is an environmental improvement and they will just have to update the application when it is completed.

Should be all set. Thank You.

1 Joe Thouin

From: Mark DiChiara, Gateway Limousines Sent: Tuesday, October 13, 2020 12:27 PM To: Joe Thouin Cc: Dave Wick; [email protected] Subject: Re: Snug Harbor Marina M20-000006 Attachments: Snug Harbor_n.jpg; View from back porch 1 .jpg; View from back porch 2.jpg; View from back yard 1.jpg; View from back yard 2.jpg; View from dock 1.jpg; View from dock 2.jpg; View from dock 3.jpg; View of fire pit.jpeg

Good Morning Joe,

Thank you for contacting me for comments. Currently I have engaged representation in opposition to this application with Mark Schachner of Miller, Mannix, Schachner & Hafner, LLC along with Jo Ann McArdle of 104 & 106 Black Point Rd. and Nadia and Val Ranguelov of 77 Sagamore Dr. Mark will be submitting our full opposition letter today.

In addition to our collective opposition, I submit that my property will be the most impacted by this application and submit the following additional comments to be presented to the commission.

Attached are several pictures that are unique to my circumstance given the close proximity to the proposed pump location, and fuel dock.

1. The picture captioned Snug Harbor shows an aerial view of Snugs more than 500 feet of available shoreline demonstrating multiple alternative locations that will not cause harm to the neighborhood as described in our full opposition letter. 2. Photo's View from back porch 1& 2 show a bird's eye view of the proposed location which demonstrate the visual effect of this location from inside my home. 3. Photo's view from back yard 1& 2 show the negative effects, and visual disruption I would encounter from the ground in my back yard. 4. Photo's view from dock 1‐ 2 & 3 further illustrate the close proximity on land of this proposed location to my property , and the very narrow amount of space between my dock, and the proposed fueling location. Berthing of a boat on the northern side of my northern dock would create almost impossible access to the proposed fuel dock, and substantially increase the probability of damage to either my dock, or berthed boat. Additionally, the danger created when swimming off the end of my dock would further impact the safety of my waterfront. 5. Photo view of fire pit shows the close proximity of my fire pit, along with the tiki torches I use in my backyard. The dangers associated with open flames, embers, and sparks in such close proximity to a fuel pump, and air borne fuel vapors would again impose a safety hazard which does not exist today.

For these reasons, and the reasons stated in our formal opposition letter I feel this application must be denied. I will be available when the application is heard before the board to add any verbal comments on the impacts of this application and ask if appropriate for the opportunity to address the board.

Please confirm receipt of this email, and acknowledge it meets the requirements of the public comment.

Respectfully

Mark DiChiara President Gateway Limousine Inc. 74 Mattatuck Heights Waterbury,CT. 06705 Tel. 203‐753‐5466 Fax 203‐757‐2622 E‐mail [email protected] Web www.gatewaylimos.com

From: Joe Thouin Sent: Tuesday, October 13, 2020 7:36 AM To: Mark DiChiara, Gateway Limousines Cc: Dave Wick Subject: Snug Harbor Marina

Dear Mr. DiChiara,

I hope this finds you well.

Today is the last day of the public comment period for the proposed Snug Harbor modification. If you have any comments you would like to make for the record, please submit them to me via email by close of business today.

Best regards as always, Joe

MILLER, MANNIX, SCHACHNER & HAFNER, LLC ATTORNEYS AT LAW

15 WEST NOTRE DAME STREET GLENS FALLS, NEW YORK 12801 Mark Schachner Telephone: (518) 793-6611 John W. Miller (1908-1968) Robert H. Hafner Facsimile: (518) 793-6690 John C. Mannix (1931-2006) Leah Everhart Jacquelyn P. White Thomas W. Peterson 49 BURLINGTON AVE., 2ND FLOOR Toll Free: 1-800-421-6166 PO BOX 578 ROUND LAKE, NEW YORK 12151 Michael J. Hill, Of Counsel Telephone: (518) 899-1518 Web Site: millermannix.com Brian S. Reichenbach, Of Counsel Facsimile: (518) 899-1561 E-Mail: [email protected]

October 13, 2020

Lake George Park Commission Via Email – [email protected] Fort George Road and US Mail Lake George, New York 12845

Re: Snug Harbor Marina Application No.: M20-000006

Dear Commissioners:

We represent Mark DiChiara, Jo Ann McArdle, Nadejda Ranguelova and Vladimir Ranguelov in opposition to the proposed relocation of the gas dispenser and fuel dock at Snug Harbor Marina. Mr. DiChiara owns 100 Black Point Road, the immediately adjacent property to the south, Ms. McArdle owns the next two southern properties at 104 and 106 Black Point Road and the Ranguelovs own property located at 77 Sagamore Drive directly across on the other side of this narrow portion of Lake George. We respectfully submit that the Marina Permit Modification Application must be denied.

Among the considerations for issuance of a marina permit are the probable effect of the proposed facility and its operation on the health, safety and welfare of the public and on the resources of the Lake George Park, the impact of the proposed facility on congestion of Lake George and the probable visual, cultural and audible effects of the proposed project on the neighborhood in which the project is proposed and on the Park. As discussed below, it appears that the Applicant’s proposal would have significant negative impacts on all of these factors.

Preliminarily, the application does not clearly indicate whether the intention is to terminate fuel dispensing at the currently existing location and relocate the existing gas pump to the Applicant’s southernmost dock or continue to dispense fuel at the existing central dock and add a new gas pump to the southern dock. Regardless, there is no justifiable reason to locate a gas pump at the proposed southernmost location of the 500 foot commercial property only approximately 20 feet from the neighboring property line. However, the Application is ambiguous in referencing relocation, but also stating: “We are

PRINTED ON RECYCLED PAPER Lake George Park Commission Re: Snug Harbor Marina Application No.: M20-000006 October 13, 2020 Page 2 of 4 ______

going to keep the existing gas dock open for rental boats and service customers to keep traffic flowing towards center dock.“ In addition, there are several factual misstatements on the Application and numerous photographs appear to show that the Applicant may be storing, berthing and/or servicing more boats at the Marina than allowed under the current permit. The Permit Modification Application should not be processed further if the Applicant is already violating the existing Marina Permit.

1. The current gas pump is located approximately in the center of the Marina’s docking area near the far end of a 125’ long dock. This triangulated distance provides a buffer for adjacent properties that would be completely eliminated if the gas pump were moved to the proposed location directly adjacent to Mr. DiChiara’s property. Not only would the pump be located only a short distance from Mr. DiChiara’s property, but it would be on the same axis as his backyard. The effects of noise, fumes and visual intrusions on the DiChiara and neighboring properties would be significant and inescapable. The southernmost dock currently typically has 3 to 4 berthed boats per day coming and going, whereas relocation of the gas pump would cause the alarming boat traffic increase of at least 50 to 60 boats per day. The rerouting of commercial boat traffic to use the gas pump in front of the neighbors’ homes would create substantial danger to their families and friends engaged in boating, swimming, rafting, wading and the like and would have devastating impacts on their use and enjoyment of Lake George.

2. The application appears to indicate that two boats are intended to be served at the same time at the new location. In light of the very small area of Marina shoreline in the vicinity of the new pump, fueling boats at this location would be impossible without significantly encroaching well beyond the neighbors’ extended property lines. Especially as Mr. DiChiara’s dock is located in close proximity to the extended property line, it is unclear how boats could safely maneuver to access the fuel pump. Inexperienced boaters would be especially challenged by the effects of waves, current and wind in this tight configuration and more likely to collide with either other boats or the Marina’s or Mr. DiChiara’ dock. The application should be denied due to the navigational danger of ingress and egress to the new pump, especially in light of the proximity to Mr. DiChiara’s dock and the likelihood of inexperienced boaters struggling to navigate in such a small area.

3. The proposed location also poses a significant threat to neighbors’ water supplies. The water supply line that serves the DiChiara property is located near the Marina dock adjacent to the proposed new pump, with other nearby water lines as well. Increased boat traffic would continually disturb the silty lakebed which would allow particulates to enter nearby water supplies. Some amount of fuel inevitably enters the water during the fueling process and would be mixed into the water which would also contaminate neighbors’ water supplies. Needless to say, the effect of an actual fuel spill this close to a water supply could be disastrous.

PRINTED ON RECYCLED PAPER Lake George Park Commission Re: Snug Harbor Marina Application No.: M20-000006 October 13, 2020 Page 3 of 4 ______

4. This area of Lake George is also quite narrow. The current location of the fuel pump is across from an uninhabited wooded area so the effects of boat traffic are less consequential. Boats waiting to use the current gas dock are stacking in the best available location at the site. Moving the pump location and thereby shifting the boat traffic to the South would affect additional properties on both sides of Lake George that draw water from the Lake and have individual docks accessing the Lake. The greater concentration of boats would stir up the silty Lake bottom to affect drinking water quality. Stacking of boats waiting to access the fuel pump would also interfere with access to nearby private docks, as increased density of boats waiting or boat stacking at the new location would be inevitable due to the rock outcropping in the channel and would cause navigational hazards in this narrow area. All of these problems would be particularly exacerbated when larger boats are berthed at or visit the marina leaving a silt bloom in their wake due to the shallowness and silty bottom of the area. The resulting impacts would include additional negative effects on the drinking water quality of the neighbors, as well as erosion under the seawalls and around the stakes supporting the neighbors‘ docks. The additional wave action caused by increased boat traffic would likely cause erosion especially under Mr. DiChiara’s seawall and dock support structures, forcing him to repair damage actually caused by Marina activities and creating an undue burden on him as the adjacent property owner.

5. Noise and odor impacts from the proposed fuel dispenser would be especially detrimental due to its close proximity to the DiChiara and McArdle docks and yards. The continual sound of numerous boat engines, gas pumps and people directing access or simply boisterously enjoying themselves at this location would destroy any semblance of the neighbors’ privacy and substantially deprive them of use and enjoyment of their property. We believe that, unlike gas stations, marina fuel pumps do not typically include vapor recovery systems and gasoline odors abound at all gas lines regardless of care of operation. These gasoline smells spread to nearby properties and are readily detectable and offensive prior to dissipating.

6. The Short Environmental Assessment form submitted by the Applicant includes several factual inaccuracies. More importantly, however, if the Commission has any inclination to favorably review this application, then it will have to carefully consider its responsibilities under the State Environmental Quality Review Act. We recognize that many Commission applications are SEQRA Type II actions which do not require SEQRA review and the vast majority of others do not present potentially significant adverse environmental impacts and therefore properly result in SEQRA Negative Declarations. However, diligent review of a properly completed Environmental Assessment Form for this application would recognize that it actually would result in significant adverse environmental impacts and therefore require a Positive Declaration and preparation of an Environmental Impact Statement. We do not believe that the Commission could lawfully approve this Application without this required level of scrutiny.

PRINTED ON RECYCLED PAPER Lake George Park Commission Re: Snug Harbor Marina Application No.: M20-000006 October 13, 2020 Page 4 of 4 ______

Finally, as you know, before issuing a permit that involves commercial use of a dock, the Commission must require an applicant to certify that the facilities and associated land uses are in compliance with applicable provisions of State and local laws, ordinances, rules and regulations. As far as we know, the Applicant has not provided any such evidence of compliance. Given the fact that the proposed project would involve the installation and possible removal and remediation of fuel lines and the placement of a new fuel pump in close proximity to an adjoining residential property, we anticipate that several other approvals would be required including, but not necessarily limited to, authorizations from the Town of Ticonderoga and the New York State Department of Environmental Conservation.

We do not believe that the Commission can lawfully approve an application that imposes such onerous burdens on neighboring property owners, the public and the resources of Lake George Park. The Commission cannot possibly ensure that it is mitigating the visual, cultural and audible effects of the proposal and protecting the health, safety and welfare of the public and the resources of the Park. The application falls far short of these standards and must be denied.

Thank you for your consideration of these comments and your tireless efforts to protect the resources of Lake George.

Very truly yours,

MILLER, MANNIX, SCHACHNER & HAFNER, LLC

Mark Schachner

cc: Town of Ticonderoga Zoning Office New York State Department of Conservation Region 5 Office Karla Williams Buettner, Esq., Commission Counsel Mark DiChiara (via e-mail) Jo Ann McArdle (via e-mail) Nadejda Ranguelova and Vladimir Ranguelov (via e-mail)

N:\Clients\DiCHIARA, MARK\LGPC ltr 10-13-20.docx

PRINTED ON RECYCLED PAPER Joe Thouin

From: Mark DiChiara, Gateway Limousines Sent: Tuesday, October 20, 2020 3:25 PM To: Joe Thouin Cc: [email protected] Subject: M20-000006 MP Enterprises LLC Attachments: Outlook-1516822745.jpg; View from South dock facing marina.jpg; View from north dock facing marina.jpg; View of swimming area from north dock.jpg

Dear Joe,

I had the opportunity to make it up to Ticonderoga this past weekend and take a few more pictures which I feel will be helpful in the application review.

Please find three pictures taken from each of my docks showing the close proximity of the proposed fueling dock, along with the swimming area that we use that will be affected by this application.

I would respectfully request these photos be added to the record.

Thank you for your consideration.

Yours truly

Mark DiChiara President Gateway Limousine Inc. 74 Mattatuck Heights Waterbury,CT. 06705 Tel. 203‐753‐5466 Fax 203‐757‐2622 E‐mail [email protected] Web www.gatewaylimos.com

Joe Thouin

From: Mark DiChiara, Gateway Limousines Sent: Monday, October 26, 2020 12:33 PM To: Joe Thouin Cc: '[email protected]'; Mark Schachner; '[email protected]' Subject: Re: Snug Harbor Marina Application No.: M20-000006 Attachments: Outlook-1516822745.jpg; 20201026113328701.pdf; LGPC ltr 10-26-20.pdf; Mark Schachner Items for Discussion.docx

Dear Joe,

Please find attached a letter from Miller, Mannix, Schachner & Hafner, additional notes and information offered for the commission's review of this application, and NYC Fire code regulations that were received this morning from the Town of Ticonderoga zoning enforcement office.

As requested in the letter the additional information that was not present or available should be made part of the public comment period and be reviewed by the commission to insure a complete and comprehensive review of this application, and its impacts.

Respectfully Mark DiChiara President Gateway Limousine Inc. 74 Mattatuck Heights Waterbury,CT. 06705 Tel. 203‐753‐5466 Fax 203‐757‐2622 E‐mail [email protected] Web www.gatewaylimos.com

MILLER, MANNIX, SCHACHNER & HAFNER, LLC ATTORNEYS AT LAW

October 26, 2020

Lake George Park Commission Via Email – [email protected] Fort George Road and US Mail Lake George, New York 12845

Re: Snug Harbor Marina Application No.: M20-000006

Dear Commissioners:

As you know, we are representing a number of the neighbors of Snug Harbor Marina in opposition to the fuel line relocation/expansion proposal. Our principal comments were submitted on October 13th during the public comment period.

The purpose of this letter is to request your allowance and acceptance of the separate comment letter being submitted directly by Mark DiChiara on behalf of our clients today. Mr. DiChiara’s letter includes important information and comments that deserve your careful review and that should be included in your Record for this Application. Some of his comments relate to communications and/or information which had not yet occurred or was not yet even in existence on October 13th and which therefore could not possibly have been commented on by that date.

It is not our intention to adjourn or delay Commission review of this Application, but we recognize and acknowledge potential difficulty in transmitting, receiving and digesting this information prior to the Commission meeting tomorrow morning. Therefore, while again this is not the purpose of the submission, we have no objection if the Commission chooses to postpone its review to the November meeting in order to make the most informed decision possible.

PRINTED ON RECYCLED PAPER Lake George Park Commission Re: Snug Harbor Marina Application No.: M20-000006 October 26, 2020 Page 2 of 2 ______

Thank you for your consideration of all of the comments from and on behalf of the neighbors of this proposed action.

Very truly yours,

MILLER, MANNIX, SCHACHNER & HAFNER, LLC

Mark Schachner

N:\Clients\DiCHIARA, MARK\LGPC ltr 10-26-20.docx

PRINTED ON RECYCLED PAPER Items for Discussion

Permit Violations of Special Conditions

1. Exceeding number of boats permitted, photo sent to LGPC with opposition shows 52 boats at docks with 2 open berths (#32 on permit) 2. No pump out facility has been installed after the Black Point Rd. Sewer district was deployed. (#31) 3. No white Navigational lights at lakeward most point of each wharf structure (#30)

Permit Violations of General Conditions

1. No person shall clean any vessel with chemicals or detergents where runoff into or contamination of the waters of the park occurs or is likely to occur. (#24)Snug routinely does bottom washing of boats as part of winterization services directly next to their boat launch. 2. This permit shall not be construed as conveying to the permittee any right to trespass on the lands or interfere with the riparian rights of others in order to perform the permitted action as authorizing the impairment of any rights, title, or interest in real personal property held or vested in a person not a party to this permit (# 9). Would our statement in the opposition letter address this as boats will constantly be crossing my extended property lines when arriving or departing.

Statements of Applicant on application to contest

1. 6. Related to the above, present alternatives that you have considered, and provide a narrative describing why these alternatives are not preferable Alternative option was to replace existing fuel dispenser on center dock with 125’ of new pipe run from dispenser to land, additional lines along lakeside of building around south corner, and back to existing 3,000 gallon fuel tank. Concern for replacing equipment in existing location: (1) Cost prohibitive (2) Potential environmental impacts/hazards with gas lines and dispenser being located 125’ in length over the water. After with consulting with Northeast Petroleum they advised that most equipment in that length is not designed for a permanent solution. Many marinas with this setup would be put in as a temporary solution that people are keeping for permanent usage which poses many risks. The proposed plan in the new location will help us to be proactive with expecting regulatory changes in the future with the DEC including containment tanks, leaking sensors, alarm system, etc. (3) The new system will have live monitoring connected to the adjacent building whereas the existing location has no monitoring system. The cost should not be a factor in reviewing this application. When I needed to replace my seawall and docks at no time did LGPC, or DEC give any consideration to cost, their sole concern was meeting all requirements regarding my project. I consulted with Wildco Petroleum Equipment sales a distributor of the identical products Snug is planning to use, and contrary to the statement that many marinas with this setup would be used as a temporary solution; the Flexworks pipe has a life expectancy of 30 years, and is approved by the EPA for this type of application. It can be ordered in a continuous length of 1000 feet so no joints would be required, but if additional linear feet are required for the project it can be installed with sumps, so it remains a very viable and safe application. They also offer a 4 inch ducting material which can house the Flexworks pipe and add additional protection. The brochure Snug made part of their application touts the safety and benefits of the product, and the reference to it being a temporary solution is deliberately misleading. All other benefits Snug mentions of the products and improvements can still exist at an alternate on shore location if this pleases regulators. 2. Shug has stated they will sue a Twin 1 dispenser pump. The brochure provided my manufacturer states that pumps can high flow rates of 22, 36 or 60 gallons per minute. This draws concerns as rapid fueling of boats unlike automobiles increases the risk of fuel spills. From personal experience my boat must be fueled at a low rate of it will cause a funnel effect and back up and spill. This is addressed in our letter referencing the potential for fuel spills close to my waterline. This risk should be confined to the current center dock location at Snug’s facility. 3. Emails between DEC staff and Joe Thouin n From: Joe Thouin Sent: Monday, October 19, 2020 10:51 AM To: Joe Thouin ([email protected]) Subject: Snug Harbor From: Huyck, Brian (DEC) Sent: Monday, October 19, 2020 8:38 AM To: Burns, Erin (DEC) Subject: RE: October 2020: LGPC Site Visits Erin, FYI Ben Hankins has been in contact with Michelle Palandrani from Snug Harbor. They plan to move the dispenser from the dock, back to shore. In doing so, they will be replacing the line from the tank to the dispenser. The piping will be double walled and the dispenser will have containment under it. On our side, this is an environmental improvement and they will just have to update the application when it is completed. Should be all set. Thank You. The very same environmental improvement can be achieved by relocation the fuel dispenser to the land side of the existing fuel dock. 4. From: Joe Thouin Sent: Friday, October 16, 2020 9:50 AM To: Joe Thouin Subject: Snug Harbor North From: Joe Johns Sent: Wednesday, October 14, 2020 12:51 PM To: Joe Thouin Subject: RE: Snug Harbor North Good Afternoon, After looking over the plan for Snug Harbor North, I think the new Configuration of the gas dock will be safer for the public. By keeping the south dock open for gas, more than one boat can pull in at a time. The area in front of the existing gas dock is in an area that is subject to wind and current from the channel. An inexperienced boater often has difficulty dealing with these conditions while waiting to be pulled into the gas dock. The new gas dock would allow multiple boats to pull straight into the dock and avoid the wind and current. I counter this analysis. The current fueling location can have 3 boats at the dock simultaneously, two on the lakeward surface, and one on the southern facing dock surface just behind the current fuel building. I have done this myself numerous times over the past 13 years. As far as wind and current there is no difference in the wind or current between the current fuel dock, and the proposed fuel dock. If Joe Johns prefers boats pulling directly onto a southern facing dock this can be accomplished by using the existing fuel dock’s southern facing surface as it is currently used for rental departure and returns. The rental activity can be altered so that rental boats leaving do so from the lakeward side of the fuel dock, as marina employees stage the boats for customer departures, then all returning boats whether rental, or fuel customers would land on the same southern facing surface of the existing fuel dock. This eliminates any intrusion in front of our residential properties, and keeps concerns with inexperienced boaters, and navigational challenges confined to Snugs commercial waterfront as opposed to our residential waterfronts The present location also provides enough room to have five boats at the dock simultaneously thus improving any congestion caused by waiting boats. This configuration would satisfy his statement that multiple boats would be able to pull straight into the dock. Lacking from his observation is how boats will get off the proposed dock without crossing over my extended property line, and encroaching into my swimming area. My dock is 11feet 8 inches off the property line, and his dock is 20 feet off the property line creating a total of 31 feet 8 inches between the docks. Boats are typically 8.5 feet wide which would only leave about 14 feet of space between boats on boat docks. How is this safer? If 3 boats were on this south dock, how would the boat closest to shore leave this dock without extreme difficulty given the narrow space between the fuel dock, and my dock? Using existing gas dock as shown in diagram with application would show this available area, and is the most appropriate location for this activity. What is the turning radius of an average boat of 20 feet? 5. 4. The application states that the proposed fueling system may not duplicated at the middle dock, because replacing the existing upland fuel line is cost prohibitive. Can you please quantify and/or elaborate on this? The cost of this project is already overwhelmingly expensive. We knew our situation with the antiquated gas dispenser and piping would eventually need to be addressed, we did not know it would require replacing the entire piping to be compliant with all of the upcoming regulations. It would cost thousands of dollars to replace the current dispenser in its current location or even modifying the middle pier dock to have a dispenser on that. Having only 100’ of piping and the dispenser sitting on land, with a sump containment dispenser pan under it. We feel this is the safest to place on the property. For every amount of underground/under-dock fuel line creates an added cost and added risk. I respectfully disagree; the sole driving force behind this application is cost savings. The applicant states that they did not know it would be this expensive to remain compliant with upcoming regulations. This should not be a consideration in this application at all. The operator bears the burden of remaining compliant, and should have been aware and planned accordingly. This is not the safest solution simply the most cost effective much to my detriment. 6. It would appear from the sketch added to the application titled proposed plan shows the underground line extending along our common property lines. So far in conversation with zoning official Bill Ball from Ticonderoga there is a 10 foot set back requirement. Does this apply to underground piping? 7. 11. Clarify if boat renters fuel up themselves onsite, or if this is a service provided by the marina Boat rental customers pull up to fuel dock, remove personal equipment while a dock hand fuels the boat. General public customers are also fueled by a dock hand. This further enforces my fear of inexperienced boaters trying to navigate back to a dock in close proximity to mine. Additionally how many dock hands would be working on the fuel dock shouting instructions to customers on where to dock, and running up and down the docks. 8. 8. For context regarding boat traffic related to fueling, provide any available information on the average and max number of fuel customers (per day/week/year), and any customer information (eg. general public vs existing onsite Snug customers) No fueling would begin before 8:30AM Average for Daily gas of berthing customer ~1-2 boats **Note: all cruisers on the south dock could fuel from their own slips Average for Daily gas of rental customer ~10-15 boats Average for Daily gas of public customer ~10-12 boats No fueling would occur after 6 PM Gas Dock would open Memorial Day and would close sometime near Columbus Day. This would subject me to all traffic (29 boats per day based on marina estimate up to 51 boats per day based on LGPC estimate.)and operational impacts seven days a week from Memorial Day to Columbus Day from 8:30AM to 6:00PM. Statement about cruisers on the south dock fueling from their berths only represents 5 boats that are on this dock. The remaining cruisers berthed on the other docks at the marina will still need to physically visit this dock, and create the large silt blooms mentioned in our opposition letter. 9. Jo Ann did research yesterday looking at all marinas with gas service, and reviewed aerial views of all properties. Based on this we do not believe there is presently any marina with their fuel pumps located so close to adjacent residential properties. We feel this displays a standard of reasonable commercial operations that would not exist if this application were approved. 10. Statements about project cost seem to be misleading. The Flex pipe he plans on using cost roughly $20.00 to $25.00/foot. It would seem the major expenses will be the associated equipment I.e. pumps sensors, alarms, sumps etc. That would be required regardless. The excavation cost should also be moot, sine he will need to excavate the area to remove the exiting underground pipes. 11. LGPC Overview the Commission’s regulations define marinas to include traditional boatyards and launches, tour boat terminals, resorts and restaurants that rent slips, neighborhood marinas offering boat berthing only, as well as homeowners who let friends or relatives berth their boat for the season.

Regulatory standards address a wide range of issues for the traditional full service marinas including; expansion, quick launching, PWC rentals, fuel handling, boat cleaning, pump outs and waste management. Marinas must provide services to their customers including parking, access to rest rooms and garbage disposal.

The most significant goals of the marina program are to ensure that there is a comprehensive environmental review and opportunity for public comment on any plan to build or expand a marina; to ensure that marinas operate with care for resources, especially as that relates to such factors as waste management, wastewater and storm water management, fuel handling, and boat cleaning; and to reduce the potential impacts of intensive uses on nearby residential neighborhoods. 12. The application is incomplete and should not be accepted. Required is a facility plan( to scale and with all pertinent dimensions) showing entire parcel , all buildings, wharfs, moorings, rental berthing slips, parking areas, trailer storage areas, boat storage areas, fuel storage and pumps, launch ramps, trash dumpsters, sewage management facilities, rest rooms and adjacent wharfs within 50 feet of property lines. The plan submitted is a grading plan and does not meet any of these requirements. 13. Document received 10-26-2020 from Ticonderoga zoning. Please review FC2310.3.1 speaking to wharves, piers or floats at marine motor fuel dispensing facilities. It is our opinion that this section would prevent the fueling activity requested in the application as it restricts operations to solely dispensing of fuel, and the applicant seeks to also berth boats at this pier 14. Section FC2310.5.4 would prevent any boat from being fast to the dock, as there will be vessels of crafts occupying berths at a marine motor fuel dispensing facility. This would create a high safety risk. 15. FC2130.5..5.1 Smoking. NYCS fire code prohibits open flames, and smoking within 50 feet of fueling operations. Installing this fueling location would infringe on my rights to have a fire in my fire pit, use my tikki torches in my back yard, or enjoy a cigar on my dock while watching a sunset.