Chapter 18B: Project Design Alternatives

18B.1. INTRODUCTION In accordance with the State Environmental Quality Review Act (SEQRA), Chapter 18 of this Draft Environmental Impact Statement (DEIS) presents and analyzes alternatives to the Proposed Project. The analysis of alternatives in this DEIS is presented in four parts that, following an introduction, together make up Chapter 18: • Chapter 18A, which analyzes process and operational alternatives to the Proposed Project; • Chapter 18B (this chapter), which evaluates design alternatives for the Proposed Project; • Chapter 18C, which assesses the Ambrey Pond Reservoir Alternative; and • Chapter 18D, which assesses the Wastewater Reuse Alternative. To comply with SEQRA, environmental impact statements (EISs) must include an evaluation of alternatives that seeks to identify “reasonable alternatives available.” As set forth in the SEQRA regulations, EISs must include “a description and evaluation of the range of reasonable alternatives to the action that are feasible, considering the objectives and capabilities of the project sponsor.”1 The SEQRA regulations call for analysis of a No Action Alternative—in which the Proposed Project is not implemented—as well as a range of alternatives, that “may also include, as appropriate, alternative: (a) sites; (b) technology; (c) scale or magnitude; (d) design; (e) timing; (f) use; and (g) types of action.”2 Chapters 18A, 18C, and 18D consider alternative technologies, uses, and types of actions. This chapter considers alternative sites and designs for the Proposed Project.

18B.1.1. CHAPTER ORGANIZATION After this introduction, this chapter of the DEIS includes the following sections: Section 18B.2: Alternative Sites for the Proposed Project. Section 18B.3: Alternative Energy Sources for the Proposed Project. Section 18B.4: Alternative Uses for Brine and Wastewater.

18B.1.2. SUMMARY OF PROJECT DESIGN ALTERNATIVES CONSIDERED AND PRINCIPAL CONCLUSIONS The analyses presented in this chapter discuss a range of project design alternatives considered during the development and design of the Proposed Project. Upon the analysis of numerous alternatives regarding location of the Proposed Project components, energy sources, and

1 6 NYCRR § 617.9(b)(5)(v) 2 Ibid.

18B-1 Haverstraw Water Supply Project DEIS alternative uses of treatment process byproducts, this chapter concludes that the Proposed Project meets the purpose and need for the project in the most effective and feasible manner. United Water New York Inc. (United Water) conducted a rigorous site selection process to identify suitable locations for the Proposed Project’s water treatment plant and intake pumping station. A total of 13 sites in the Towns of Clarkstown, Haverstraw, and Stony Point were identified and evaluated. The site selection process focused on the eastern portion of United Water’s Rockland County service area, close to the proposed Hudson River water source, to facilitate withdrawal of water from the river for treatment with limited need for pumping, and to take advantage of land in existing industrial or utility areas (i.e., brownfield land). Project designs to locate the Intake Structure outside the Haverstraw Bay Significant Coastal Fish and Wildlife Habitat (SCFWH) area were also considered, yet were deemed infeasible due to a variety of factors, including engineering obstacles and parkland alienation. The proposed Water Treatment Plant Site and site for the intake pumping station and intake structure, at the former Town of Haverstraw Landfill Site and on an industrial parcel adjacent to the U.S. Gypsum plant, respectively, are deemed to be the most suitable sites for the Proposed Project. United Water is committed to reducing greenhouse gas emissions, improving energy efficiency, and increasing and promoting renewable energy generation. This chapter discusses alternative energy generation options for the Proposed Project that could reduce its demand for power from the existing electrical grid. On-site and off-site wind power generation was evaluated, as well as the potential for on-site solar power generation and the use of off-site renewable energy sources. The analyses conclude that on-site wind turbines would have a marginal ability to offset the Proposed Project’s energy demands, whereas the off-site construction of a 2.5 megawatt (MW) wind turbine at United Water’s Lake DeForest Reservoir could provide up to 22 percent of the projected energy use of the Proposed Project. This option, however, would result in several environmental impacts. Solar power generation options were shown to provide between 2 and 7.8 percent of the projected energy demand. The incorporation of potential alternative energy sources for the Proposed Project will be further evaluated as design advances. This chapter also discusses possible alternative uses for the wastewater, solid wastes, and brine generated as byproducts of the proposed water treatment processes. Wastewater generated by the water treatment process potentially could be reused for irrigation, in the manner described in some detail in Chapters 18A and 18D. This chapter concludes that the volumes of wastewater anticipated to be produced by the Proposed Project are not large enough to warrant the investment needed to further treat and transport the wastewater for reuse. Alternative uses of solid waste generated by the Proposed Project indicate that solid wastes, in the form of sludge, following dewatering, could be recycled and used as compost, provided that the salinity levels of the materials were suitable for such use. No other feasible reuse of the solid waste was identified. Finally, alternative reuse options for the brine that is a byproduct of the Proposed Project were explored. The assessment of reusing brine as a road de-icing solution concluded that the salinity of the brine would be too low, and the sulfate concentration too high. The low salinity of the brine could actually contribute to further road icing, and the expense and energy consumption necessary to increase its salinity and decrease its sulfate concentration renders its reuse infeasible and uneconomical. Other uses, including the use of diluted brine for irrigation purposes, or to produce sodium hypochlorite, a chemical used in the water treatment process, were also evaluated. Neither reuse was deemed economically feasible due to anticipated cost of implementation.

18B-2 Chapter 18B: Project Design Alternatives

18B.2. ALTERNATIVE SITES FOR THE PROPOSED PROJECT

18B.2.1. DESCRIPTION OF THE ALTERNATIVE This alternative describes the site selection process undertaken for the Proposed Project and evaluates alternative sites for the Proposed Project that would locate the raw water intake outside of the boundaries of the Haverstraw Bay Significant Coastal Fish and Wildlife Habitat (SCFWH), either to the south or north of Haverstraw Bay. As discussed in this DEIS in Chapter 9A, “Aquatic Natural Resources,” the area of the Hudson River where the Proposed Project’s river water intake is proposed to be located is within the Haverstraw Bay SCFWH. As shown in Figure 9A-2 in that chapter, the SCFWH occupies the full width of the Hudson River, from Rockland County to Westchester County. It extends approximately six miles on the Hudson River, from Hook Mountain State Park in Rockland County and Croton Point in Westchester County on the south, to Stony Point in Rockland County and Verplanck in Westchester County on the north. According to the New York State Department of State (NYSDOS), the following qualify Haverstraw Bay as a SCFWH under New York State’s Coastal Management Program: the extensive shallow estuarine habitat areas; the occurrence of commercial and recreational fisheries; the use of Haverstraw Bay as a nursery, feeding and/or overwintering area for marine and anadromous species; and the presence of vulnerable or sensitive species (i.e., endangered or threatened). The Haverstraw Bay SCFWH encompasses the entire river over this approximate six- mile reach, which is the widest section of the Hudson River. This brackish water portion of the river is highly productive and comprises a substantial part of the nursery area for striped bass, American shad, white perch, tomcod, and Atlantic sturgeon. Other anadromous species, including blueback herring and alewife, spawn in upstream freshwater areas but concentrate here before moving downriver in the fall. The bay is also a major nursery and feeding area for bay anchovy, Atlantic menhaden, and blue crab. Depending on the location of the salt front, a majority of the spawning and wintering populations of Atlantic sturgeon in the Hudson River may reside here. The endangered shortnose sturgeon also overwinters here. Large numbers of waterfowl use the area for feeding and resting during spring and fall migrations. As noted in the NYSDOS’s coastal fish and wildlife habitat rating form for the Haverstraw Bay SCFWH, “Despite various habitat disturbances, Haverstraw Bay possesses a combination of physical and biological characteristics that make it one of the most important fish and wildlife habitats in the Hudson River estuary.”1 As discussed in Chapter 17, “Coastal Zone Consistency,” in the discussion of coastal zone management Policy 7, NYSDOS has established guidance for assessing whether a proposed activity would protect, preserve, and, where practical, restore SCFWHs, which is the intent of Policy 7. Guidance documents state that (1) “[a] habitat impairment test must be met for any activity that is subject to consistency review;” (2) the “test that must be met is as follows – In order to protect and preserve a significant habitat, land and water uses or development shall not be undertaken if such action would: destroy the habitat; or, significantly impair the viability of the habitat.” As discussed in detail in Chapter 17 (Policy 7) and in Chapter 9A, “Aquatic Natural Resources,” the Proposed Project would be consistent with Policy 7 and would not result in significant adverse impacts on water quality, nor to the species identified as important for the Haverstraw Bay SCFWH. The

1 http://www.nyswaterfronts.com/downloads/pdfs/sig_hab/hudsonriver/Haverstraw_Bay.pdf

18B-3 Haverstraw Water Supply Project DEIS

Proposed Project would not result in significant adverse impacts on regional target species populations, or to regional populations of other fish, plankton or macroinvertebrates.

18B.2.2. SITE SELECTION PROCESS During development of the conceptual design for the Proposed Project, United Water conducted a rigorous site selection process to identify suitable locations for the Proposed Project’s water treatment plant and intake pumping station. Sites were evaluated in the Towns of Clarkstown, Haverstraw, and Stony Point as potential locations for the water treatment plant. The site selection focused on the eastern portion of United Water’s Rockland County service area, close to the Hudson River, ideally locating the water treatment plant in proximity to the water source (the Hudson River) to facilitate withdrawal of water from the river for treatment with limited need for pumping. Sites with direct waterfront access are preferable to those without waterfront access, because they provide certain riparian rights. The site selection focused on the northern portion of the service area, in Clarkstown, Haverstraw, and Stony Point, to take advantage of land in industrial or utility areas (i.e., brownfield land) that could be reused for the water treatment plant. Most of the remaining service area in relatively close proximity to the river is in residential or parkland use and was considered not to be ideal for a water treatment plant location. In addition, south of Clarkstown, the land closest to the river is located in the Village of Nyack, which is not within United Water’s service area and presents other challenges in finding a suitable site, as discussed below in section 18B.2.3.1. Potential sites were then evaluated for their suitability and compared to identify the most suitable site for the Proposed Project. The evaluation considered the following factors: • Site size. Sites of at least 10 acres were considered preferable, because those would provide enough space for the structures and raw water storage tanks associated with the water treatment plant. Sites smaller than 9 acres would not be large enough to accommodate the project. • Proximity to potential intake locations for river water. Sites should be located near the Hudson River, to facilitate transmission of raw water to the water treatment plant. At the same time, sites located outside of the designated Coastal Zone were considered preferable to those in the Coastal Zone, to avoid potential conflicts related to visual impacts and other Coastal Zone Management policies. • Proximity to existing United Water large-diameter finished (potable) water mains that could receive the potable water produced by the Project. Sites should be close to a water transmission main of at least 12 inches in diameter, to receive the potable water produced by the water treatment plant. • Roadway access. Access to roadways that would be suitable for heavy construction equipment and post-construction deliveries was sought. • Proximity to a wastewater treatment plant. Sites located near a wastewater treatment plant or major wastewater transmission line were considered preferable, because this would facilitate the discharge of wastewater from the water treatment process. • Constructability. The potential difficulty of construction was evaluated, including the need for grading and clearing, the need for extra foundation support because of poor soils, the presence of bedrock, and the need for special engineering considerations or remediation due to the presence of hazardous materials. In addition, the presence of wetlands was considered since it would limit the amount of land available for construction, and the presence of

18B-4 Chapter 18B: Project Design Alternatives

floodplains was considered because it would require additional grading to raise building foundations above the flood elevation. • Environmental issues. This included the possible hazardous materials, the presence of wetlands and other natural resources, potential protected species (based on a literature review), and the potential for issues related to consistency with New York State’s coastal zone management policies, such as the presence of SCFWH habitat areas and the potential for adverse visual effects along the Hudson River waterfront. This evaluation was intended to eliminate sites for which obtaining the required approvals and permits appeared unduly difficult, and to rank sites according to their suitability for a water treatment plant from an environmental perspective. • Community concerns. This included an evaluation of the suitability of the site in terms of adjacent land uses and the presence of appropriate zoning for water treatment facilities. Sites in industrial areas that are not proximate to residential uses were considered preferable. • Availability. The sites’ availability for purchase was assessed. Some of the sites were determined not to be available and were therefore eliminated from further consideration. • Potential intake locations. While no design was conducted at this stage, potential locations for the raw water intake were evaluated for each site. These include locations in the open river both in and out of the SCFWH and locations in Bowline Pond (which is not part of the Haverstraw SCFWH). A total of 13 sites in the Towns of Clarkstown, Haverstraw, and Stony Point were identified and evaluated. These sites are shown in Figure 18B-1. The relative impacts and benefits of each site are summarized in Table 18B-1. The proposed Water Treatment Plant Site, which comprises a portion of the Town of Haverstraw’s former landfill, was the site selected as a result of this process. Major advantages of the Water Treatment Plant Site include the following: • The site is a brownfield site that can be put to productive reuse, reclaiming a site that otherwise would likely remain vacant. Moreover, both the proposed Water Treatment Plant Site and the proposed Intake Site are currently industrial in nature and located in generally industrial areas, so that the Proposed Project would not adversely affect community character. • Although located close to the river and within the coastal zone, the site is buffered from the river and coastal zone by the former Haverstraw Landfill and by the Site’s topography. • The Intake Site selected for the Project’s intake pumping station is in an industrial area, which minimizes any potential visual effects in the coastal zone. • Both Project Sites are available for purchase. • The site is currently owned by a municipality, so converting it to private ownership will generate new property tax revenue for the municipality, the county, and the school district. • The site’s location close to the Hudson River minimizes the distance that raw water must be pumped to the treatment plant (thereby also minimizing the associated energy demands for pumping). • The site is adjacent to the Haverstraw Joint Regional Sewage Treatment Plant (JRSTP), allowing for efficient disposal of wastewater and reverse osmosis concentrate (i.e., brine) produced during the water treatment process. • Both proposed Project Sites have roadway access that would be suitable for heavy construction equipment and post-construction deliveries.

18B-5 10.1.10 UNITED WATER Haverstraw Water Supply Project 1 Potential Alternative SItes 13 12 Alternative Water Treatment 6 11 0 SCALE Plant Sites Evaluated 1 4 3 7 2 10 5 1 8 9 Figure 18B-1 2 MILES Haverstraw Water Supply Project DEIS

Table 18B-1 Site Description and Evaluation Results Site / Location / Description Site Evaluation Results 1. Town of Haverstraw Former Selected as preferred site for Proposed Project’s water treatment plant. Landfill, Town of Haverstraw Availability: Site available for purchase. (proposed Water Treatment Plant Siting: Suitable roadway access during and after construction. Access to large- Site) diameter water main for potable water connections. Close proximity to Portion of former landfill JRSTP for wastewater treatment. Good proximity to river for intake. 15.4 acres. Constructability: Minimal clearing and easy roadway access; varied topography and would need to raise portions of site above water table; poor soils may require piles or other foundation support. Environmental: Portions in floodplain and some wetland areas. Not on waterfront, but within coastal zone adjacent to portion of Hudson River in SCFWH. Review of Phase I and Phase II environmental site assessment reports indicates that hazardous materials are not a major concern at this site; the site provides an opportunity to redevelop a brownfield. Community: Industrial zoning appropriate for water treatment plant; buffer to nearest residential uses. 2. Bowline North, Town of Not selected, because site was unavailable for purchase. Haverstraw Availability: Site unavailable for acquisition. Industrial land immediately north of Siting: Suitable roadway access. Access to large-diameter water main for Bowline power generating station potable water connections. Close proximity to JRSTP for wastewater on Rte. 109. treatment. Access for intake in Bowline Pond. 19.5 acres. Constructability: Level topography and minimal clearing needed. However, significant site dewatering likely to be needed during construction and poor soils may require piles or other foundation support. Environmental: Portions in floodplain. Not on waterfront, but within coastal zone adjacent to portion of Hudson River in SCFWH. Community: Industrial zoning appropriate for water treatment plant. No residential uses nearby. 3. Keahon Auto Salvage Site, Town Not selected because of limited size, difficult constructability, and potential of Haverstraw environmental issues. Active auto salvage business on Availability: Unknown but occupied by an active business. west side of Beach Rd. north of Siting: Site size would constrain development. Suitable roadway access, access Railroad Ave. to large-diameter water main for potable water connections, and good 9.2 acres. proximity to JRSTP for wastewater treatment. Proximity to river or Bowline Pond for intake. Constructability: Difficult because of limited site area, need for demolition of existing structures, potential for contamination from auto salvage activities and need for remediation. Significant site dewatering likely to be needed during construction and poor soils may require piles or other foundation support Environmental: More than half the site in floodplain. Not on waterfront, but within coastal zone adjacent to portion of Hudson River in SCFWH. Community: Industrial zoning appropriate for water treatment plant; no residential uses nearby.

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Table 18B-1 (cont’d) Site Evaluation Results Site / Location / Description Site Evaluation Results 4. North Rockland Associates Site, Not selected, because of issues related to constructability and potential Village of West Haverstraw environmental issues. Former construction and Availability: Site availability unknown. demolition debris landfill along Siting: Suitable roadway access. Access to large-diameter water main for Beach Rd. between Ecology Ln. potable water connections. Proximity to JRSTP for wastewater treatment. and Railroad Ave. Proximity to river or Bowline Pond for intake. 34.5 acres Constructability: Level topography and minimal clearing needed. However, significant site dewatering likely to be needed during construction and poor soils may require piles or other foundation support. Use as former landfill may require advanced engineering controls. Remediation required for hazardous materials. Issues related to unresolved NYSDEC consent orders and required remediation. Environmental: Portions in floodplain and near wetland areas. Potential hazardous materials related to former use as landfill. Not on waterfront, but within coastal zone adjacent to portion of Hudson River in SCFWH. Community: Industrial zoning appropriate for water treatment plant. Some residential uses nearby. 5. Stony Point Wastewater Treatment Not selected because of inadequate site size and impacts to existing Plant, Stony Point wastewater treatment plant site. Property occupied by the Stony Availability: Unlikely to be available. Point wastewater treatment plant Siting: Site not large enough (less than 9 acres) and would require closure and west of River Rd./Grassy Point Rd. demolition of existing wastewater treatment plant and new force main to 5.0 acres (or larger with addition of divert wastewater to JRSTP. Not near large-diameter water main for a portion of the adjacent U.S. potable water connections. Access to river for intake. If this site is Gypsum plant site). combined with the adjacent U.S. Gypsum plant site, it would be large enough, but would still most likely be unavailable and still require extensive demolition. Constructability: Need to demolish extensive buildings and related infrastructure. Environmental: Close to waterfront, and within coastal zone adjacent to portion of Hudson River in SCFWH. Proximity to Hudson River waterfront raises visual effects concerns in coastal zone. Extensive floodplains on the adjacent U.S. Gypsum property. Community: Residential waterfront zoning and location in close proximity to residential neighborhood. 6. Kay-Fries Site, Town of Stony Not selected because of significant hazardous materials concerns related to Point site’s listing on New York State’s Hazardous Waste Site List and its small size. Former chemical plant site on Kay Availability: Unknown. Fries Dr. (east of Rte. 9W). Siting: Site size would constrain development. Suitable roadway access. Access 9.5 acres. to large-diameter water main for potable water connections. Moderately good proximity to JRSTP for wastewater treatment. Moderately good proximity to river for intake. Constructability: Difficult, due to limited construction staging area, soil contamination, and level of remedial effort involved. Environmental: Portions in floodplain. Site listed on New York State’s Hazardous Waste Site List as significant threat to public health. Not on waterfront, but within coastal zone adjacent to portion of Hudson River in SCFWH and within boundaries of Town of Stony Point local waterfront revitalization program. Community: Industrial zoning suitable for a water treatment plant site, but residential area to north of site.

18B-7 Haverstraw Water Supply Project DEIS

Table 18B-1 (cont’d) Site Evaluation Results Site / Location / Description Site Evaluation Results 7. Hornicks Site, Village of Not selected because site not available and potential issues related to Haverstraw constructability. Industrial site immediately south of Availablity: Site unavailable for acquisition. Bowline power generating station. Siting: Suitable roadway access. Access to large-diameter water main for 25.3 acres. potable water connections. Access to Bowline Pond for intake. Constructability: Level topography and minimal clearing needed. However, significant site dewatering likely to be needed during construction and poor soils may require piles or other foundation support. Potential to require remediation of hazardous materials. Proximity to Minisceongo Creek, wetlands on site, and potential wet soils may limit area of site that can be used for construction. Environmental: Potential hazardous materials related to previous use. Wetlands on-site. Some residential uses nearby. Not on waterfront, but within coastal zone adjacent to portion of Hudson River in SCFWH. Within boundaries of Village of Haverstraw’s local waterfront revitalization program. Community: Industrial zoning appropriate for water treatment plant, but residential neighborhood nearby. 8. Empire Chair Factory Site, Village Not selected because waterfront location raises issues of coastal zone of Haverstraw consistency and visual impacts and because Village of Haverstraw has plans for Industrial site at south end of use of this site. Bowline Pond (Liberty St.) along Availability: Unlikely to be available for purchase. Hudson River waterfront. Siting: Site size would constrain development. Site does not have suitable 9.7 acres. roadway access, does not have large-diameter water transmission main nearby for potable water connections. Not in close proximity to JRSTP. Access to river or Bowline Pond for intake. Environmental: In coastal zone and adjacent to portion of Hudson River in SCFWH. Within boundaries of Village of Haverstraw’s local waterfront revitalization program. Location along Hudson River waterfront raises concerns regarding visual effects on in coastal zone. Community: Village of Haverstraw has plans to build a ferry terminal and parking on site; located within Village of Haverstraw Urban Renewal Area boundary. 9. Congers–West Haverstraw Quarry Not selected due to inadequate developable land within site, difficult North, Village of Haverstraw construction conditions, and public policy setting site aside for future waterfront Vacant land along Hudson River (residential) development. waterfront north of active quarry. Availability: Not available. 14.5 acres Siting: Suitable roadway access. Access to large-diameter water main for potable water connections. However, because of wetlands, the amount of land available for development is not large enough (less than 10 acres). Access to river for intake. Constructability: Difficult, because large area precluded from development due to wetlands; remaining land with wet subsurface conditions. Environmental: Extensive wetlands on-site. In coastal zone and adjacent to portion of Hudson River in SCFWH. Within boundaries of Village of Haverstraw’s local waterfront revitalization program. Location along Hudson River waterfront raises concerns regarding visual effects in coastal zone Community: No residential uses nearby. However, site is zoned for waterfront development, and located within Village of Haverstraw Urban Renewal Area boundary.

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Table 18B-1 (cont’d) Site Evaluation Results Site / Location / Description Site Evaluation Results 10. Lake DeForest, Clarkstown Not selected because not available, constructability issues, and long distance Vacant land formerly owned by from river. United Water north of existing Availability: Land originally owned by United Water was sold and is no longer reservoir along Rte. 304. available. 42.9 acres. Siting: Unsuitable for use due to proximity to reservoir and long distance to river for intake. Constructability: Difficult because of topography, extensive wetland areas. Environmental: Extensive natural resources and wetland areas. Community: Residential area nearby. 11. Lovett power generating station, Not selected because site not available for purchase. Stony Point Availability: Not available for purchase. Vacant land and land formerly Siting: Roadway access difficult due to presence of railroad tracks and need for occupied by power generating crossings. Not in close proximity to large-diameter water main or station. wastewater treatment facilities. Access to river for intake. 55.6 acres. Constructability: The portion of the site along the river (east of the railroad right- of-way) is level and cleared, but significant site dewatering likely to be needed during construction and poor soils may require piles or other foundation support. This portion of the site would also likely require substantial remediation for hazardous materials. Construction at the portion of the site west of the railroad right-of-way would be difficult due to steep topography, significant land clearing, and potential for rock. Environmental: Portions in floodplain. In coastal zone adjacent to Hudson River. Waterfront location raises coastal zone issues related to visual impacts. Not adjacent to SCFWH. Potential for hazardous materials related to previous use as coal-fired power plant. Community: Zoned for industrial and utilities, but residential neighborhood to the west. 12. Cedar Pond Brook, Stony Point Not selected, because of difficult constructability, sensitive environmental area, Vacant land owned by United and proximity to residences. Water at site of former Stony Point Availability: Owned by United Water. water treatment plant, north of Rte. Siting: Site constraints related to brook, slopes, wetlands. 106 and east of Reservoir Rd. Constructability: Difficult, because of proximity to brook, steep topography, 15.4 acres. significant wetland impacts, large areas of floodplain, and potential for rock. Environmental: Not in coastal zone or adjacent to SCFWH. Wetlands and natural resources impacts likely. Community: Residential zoning and residences nearby. 13. Letchworth Reservoirs water Not selected because of location in park and long distance to Hudson River. treatment plant, Town of Siting: Long distance to Hudson River (5 miles). Change in elevation from river Haverstraw requires lift stations to deliver raw water to plant. Brine disposal difficult at Site of existing water treatment this location. plant operated by United Water, Availability: Water treatment plant is leased by United Water from the Palisades with land owned by Palisades Interstate Park Commission. Any additional land needed for a larger water Interstate Park. treatment plant site would require an additional agreement and would Acreage to be determined, require alienation of parkland by the New York State legislature, which is depending on site layout. outside of United Water’s capabilities. Environmental: Not in coastal zone or adjacent to SCFWH and no floodplains. However, location in park with natural resources and potential for protected species to be present. Community: No residential uses nearby, but site is located within parkland. Permitting for a new large-scale water treatment plant within a state park would be very difficult. Note: See also Figure 18B-1.

18B-9 Haverstraw Water Supply Project DEIS

18B.2.3. ALTERNATIVE SITES WITH RIVER INTAKES LOCATED OUTSIDE THE HAVERSTRAW BAY SCFWH In addition to the site selection analysis described above, a comprehensive review was conducted to identify potential alternative sites for the Project’s intake pumping station, and potentially the water treatment plant, so that the river water intake would be located outside of the Haverstraw Bay SCFWH. As discussed below, this evaluation considered alternative sites south and north of the SCFWH, and it considered alternative technologies with no in-river intake. The analysis of alternative sites for the intake pumping station sought alternative sites within 1,000 feet of the Hudson River shoreline. Preference was given to sites bordering the Hudson River for purposes of riparian rights, and since pumping stations at a greater distance from the river would require substantially higher energy usage to pump water from the river. Further, along much of the Hudson River shoreline in Rockland County, the shoreline rises steeply moving inland from the river, so that significant additional pumping would be required for an intake pumping station (and water treatment plant) located farther inland. Sites with direct waterfront access are preferable to those without waterfront access, because they provide certain riparian rights.

18B.2.3.1. ALTERNATIVE SITES CONSIDERED SOUTH OF THE HAVERSTRAW BAY SCFWH The southern boundary of the Haverstraw Bay SCFWH is close to the northern boundary of Hook Mountain State Park, more than four miles south of the Project Sites (see Figure 18B-2). Based on a review of land uses and topography of sites within 1,000 feet of the Hudson River shoreline, no sites are available for the Proposed Project’s intake pumping station to the south of that boundary. As shown in Figure 18B-2, Rockland County’s Hudson River shoreline south of the Haverstraw Bay SCFWH is occupied by New York State parkland (primarily Hook Mountain State Park, Nyack Beach State Park, and Tallman Mountain State Park) or residential land (including the Villages of Nyack and Piermont, which are both located along the Hudson River shoreline). Locating the Proposed Project’s intake pumping station in state parkland would require an alienation of parkland approval by the New York State Legislature, and such approval is not within United Water’s capabilities. Two other SCFWHs are located along this stretch of shoreline as well: the Hook Mountain SCFWH and the Piermont Marsh SCFWH. The only sites that are not in residential or park use are located in the middle of residential neighborhoods or are located in the Village of Nyack. The potential sites in the Village of Nyack were further investigated to determine whether they would be feasible for use as an intake pumping station. A review of aerial photographs identified four potential vacant or underutilized parcels in the downtown area of the Village of Nyack that are within 1,000 feet of the shoreline, but each of these was determined to be unsuitable, as follows: • The so-called Main Street “superblock” site is several blocks inland from the river in downtown Nyack. In June 2011, the Village of Nyack issued a Request for Expression of Interest (RFEI) for the redevelopment of this site, which the Village identified as a “priority reinvestment area of the Village.” The RFEI states that the Village is seeking redevelopment of this site with a cultural arts facility, ground floor retail and other commercial uses, upper floor residential uses, and new open space. The Village intends that the selected

18B-10 7.8.11

Hook Mountain State Park Haverstraw Bay SCFWH

Nyack Beach State Park

Hook Mountain SCFWH

HUDSON RIVER

Tappan Zee Bridge

Tallman Piermont Marsh SCFWH Mountain State Park

New York State Significant Coastal Fish and Wildlife Habitats (SCFWH) Land Use Park/Open Space Private Recreation Residential 0 2,000 5,000 FEET

SCALE

Figure 18B-2 Southern Rockland County Area Reviewed for Alternative Sites UNITED WATER Haverstraw Water Supply Project Outside Significant Coastal Fish and Wildlife Habitats Chapter 18B: Project Design Alternatives

development proposal for the full site “will complement and strengthen an already vibrant Village mixed-use neighborhood. As exhibited by Nyack’s vibrant downtown retail and healthy housing market, there is an opportunity for developers of the Superblock site to benefit from the town’s economic activity and its unique Hudson River vantage point. The Project will also strengthen Nyack’s position as a regional destination for the arts, shopping, dining and entertainment.” Therefore, use of this site as a water intake pumping station would be inconsistent with local plans for the property and was considered infeasible. • A large waterfront site, consisting of two privately owned tax parcels, located along Gedney Street in downtown Nyack, between the Nyack Boat Club on the north and the condominium development known as Clermont on the south. These parcels are identified in the Village of Nyack’s 2006 Comprehensive Plan as critical waterfront sites. Both of these parcels were once occupied by a former manufactured gas plant and are currently undergoing an extensive remediation effort by Orange & Rockland Utilities, Inc. (O&R).In addition, the southern portion of this site is planned for redevelopment as part of the Clermont condominium. The 2006 Comprehensive Plan specifically identifies these as key waterfront parcels in downtown Nyack. The Plan also lists goals for the waterfront that include potential acquisition of these two parcels to create new public parkland. • The fourth waterfront parcel identified is adjacent to the north side of Memorial Park, the Village’s major waterfront park along the Hudson River shoreline. This small parcel was identified in the Village’s 1992 Local Waterfront Revitalization Plan as an important site for public access to the waterfront, and it is now used for parking related to the adjacent park and marina. Overall, therefore, the four sites in downtown Nyack that appear potentially suitable in aerial photographs are in fact not feasible for redevelopment with a water intake pumping station. In general, these sites are not available and because of the proximity to the Village’s downtown, this use would be incompatible with the Village of Nyack’s Local Waterfront Revitalization Plan and Comprehensive Plan. Further, the Village of Nyack is not part of United Water’s service area. Placing the Proposed Project’s intake pumping station in an area that is not part of United Water’s service area would require constructing raw water transmission mains through an area where United Water does not have easements, which could add complexity, delay, and cost to the project. Finally, the area of the Hudson River as far south as Nyack is subject to greater salinity levels than Haverstraw Bay, so water drawn from this portion of the river would require higher energy usage for the reverse osmosis (RO) process than water drawn from the Proposed Project’s intake location. For these reasons, locating the intake pumping station in Nyack was not considered feasible. Since a feasible intake pumping station location was not identified south of the SCFWH, it would not be feasible to locate the Proposed Project outside of the boundaries of the SCFWH south of the Project Sites.

18B.2.3.2. ALTERNATIVE SITES CONSIDERED NORTH OF THE HAVERSTRAW BAY SCFWH The northern boundary of the SCFWH is at the point of land where the Stony Point State Park is located (see Figure 18B-3). North of the SCFWH, the land within 1,000 feet of the Hudson River shoreline within Rockland County is predominantly state parkland (including Stony Point

18B-11 7.12.11

Proposed Manitou Marsh SCFWH

Iona Marsh SCFWH

Hudson River Mile 44-56 SCFWH

Bear Mountain State Park

Harriman State Park

Proposed Expansion: Hudson River Mile 40-60 SCFWH

Former Lovett Site

Tomkins Cove Quarry

Stony Point Park

HUDSON RIVER Intake Site

Water Treatment Plant Site

Town of Haverstraw

Haverstraw Bay SCFWH

Hook Mountain State Park Project Sites New York State Significant Coastal Fish and Wildlife Habitats Proposed Areas of New/Expanded Significant Coastal Fish and Wildlife Habitats

Land Use Park/Open Space Private Recreation Residential 0 2,000 5,000 FEET

SCALE

Figure 18B-3 Northern Rockland County Area Reviewed for Alternative Sites UNITED WATER Haverstraw Water Supply Project Outside Significant Coastal Fish and Wildlife Habitats Haverstraw Water Supply Project DEIS

Park, Harriman State Park, and Bear Mountain State Park) and residential land. Two additional SCFWHs are at the northern end of the portion of the shoreline in Rockland County: Hudson River Mile 44–56 SCFWH, and Iona Marsh SCFWH. The Hudson River Mile 44–56 SCFWH extends north from Jones Point in Bear Mountain State Park (see Figure 18B-3) to Storm King Mountain near Cornwall-on-Hudson in Orange County. The Iona Marsh SCFWH is on the western shore of the river near Bear Mountain. In addition, the NYSDOS has proposed an expansion to the Hudson River Mile 44–56 SCFWH, so that it encompasses River Miles 40–60. The expanded SCFWH would extend from the northern boundary of the Haverstraw Bay SCFWH at Stony Point northward to New Windsor in Orange County. In the area north of the existing Haverstraw Bay SCFWH, railroad tracks used by CSX for freight operations run alongside the Hudson River throughout this stretch of shoreline. Immediately inland of the tracks, the shoreline has a steep slope rising sharply above the tracks. As shown in Figure 18B-3, two large sites north of the Haverstraw Bay SCFWH are not parkland or residential land. These two sites are the Tomkins Cove Quarry and the site of the former Lovett power generating station. However, as discussed below, neither site is feasible for an intake pumping station or a water treatment plant, and both in any case would be located in the expanded Hudson River Mile 40–60 SCFWH proposed by the NYSDOS. In addition to these sites, the possibility of tunneling north from the Proposed Project’s Intake Site on Beach Road to a location in the river north of the Haverstraw SCFWH was also considered, as discussed below. 18B.2.3.2.1. Intake Site at Tomkins Cove Quarry The Tomkins Cove Quarry is located alongside the Hudson River in the Town of Stony Point. Quarrying activities are still ongoing at this location. The total area controlled by the quarry’s owner, Tilcon New York, Inc., is approximately 200 acres, with approximately 185 acres of total approved mining area. The reported minimum remaining life of this quarry is 50 years. To use the Tomkins Cove Quarry for an intake pumping station and potentially a water treatment plant, United Water would either have to acquire all or a portion of the land from its current owner, Tilcon New York, Inc., or wait until mining is complete at the quarry (approximately 50 years). However, the quarry is not available for purchase, and ceasing mining activities at the quarry is directly counter to New York State’s policy to support the mining industry. New York State’s Environmental Conservation Law (ECL) § 23-2703 states, “The legislature hereby declares that it is the policy of this state to foster and encourage the development of an economically sound and stable mining industry, and the orderly development of domestic mineral resources and reserves necessary to assure satisfaction of economic needs compatible with sound environmental management practices.” Moreover, the New York State Department of Environmental Conservation’s (NYSDEC) website notes that New York’s mineral resources make a substantial contribution to the state’s total economy.1 Further, purchase of all or a portion of the quarry from Tilcon New York, Inc. would be cost-prohibitive, given the value of the remaining mineral rights there. For these reasons, use of the Tomkins Cove Quarry as an alternative site for the Proposed Project was not considered feasible. It does not meet the purpose and need for the project and is not within the objectives or capabilities of United Water.

1 http://www.dec.ny.gov/lands/5020.html.

18B-12 Chapter 18B: Project Design Alternatives

18B.2.3.2.2. Intake Site at Former Lovett Power Generating Station The Lovett power generating station was located along the Hudson River shoreline in Tomkins Cove from 1955 until it was demolished in 2008. The Lovett plant was a coal-fired power station that fully occupied a large, flat site between the Hudson River and the CSX railroad right-of- way. Facilities on the site included a railroad siding for delivery of coal, a large coal storage pile, and multiple structures, including electrical substations, the main generating station building, and a large exhaust stack. The Lovett plant had a large intake in the Hudson River that had permitted capacity to withdraw 491 million gallons per day (mgd) of raw water from the river for use as cooling water. The 15.4-acre site is now vacant. However, based on inquiries made by United Water to GenOn (the site’s current owner), this site is not available for purchase by United Water and therefore an alternative that uses this site for a water treatment plant and/or intake pumping station is not feasible or within the capabilities of United Water.

18B.2.3.2.3. Tunneled Intake in River North of Stony Point In this alternative, the intake pumping station would continue to be located at the Intake Site on Beach Road in the Town of Haverstraw. The water intake line would be installed via tunnel beneath the Hudson River, as with the Proposed Project. However, instead of a tunnel running approximately 900 to 1,500 feet from the shoreline of the Intake Site, the tunnel would instead run north from the Intake Site for a distance of approximately 9,000 feet, or about 1.7 miles, to a point in the river north of the northern boundary of the Haverstraw SCFWH. This alternative considers two methods of installing the pipeline: microtunneling, using a micro- tunnel boring machine (MTBM); and horizontal directional drilling (HDD). As described in Chapter 15, “Construction Impacts,” the Proposed Project’s intake pipe would be installed beneath the Hudson River using microtunneling. This construction technique involves the use of a MTBM operated by remote-control in combination with a pipe jacking technique that installs the pipeline. Typical microtunneling equipment consists of a pressurized earth balance or slurry shield tunnel boring machine that is at the front of a jacked pipeline of steel, concrete, or fiberglass pipe. A hydraulic jacking system is established and maintained at the launch shaft to push the pipes at the same rate as the MTBM advances. The tunnel excavated spoil is extracted from the front of the MTBM by means of screw conveyor which maintains the face pressure. The screw conveyor removes the cuttings back to the launch shaft. The muck is lifted out of the shaft and loaded onto trucks for disposal and/or reuse. Directional and positional controls are carried out through the combination of a laser guidance system and steering cylinders in the shield. For the Proposed Project, a 7- to 8-foot diameter tunnel would be installed via MTBM for the water intake pipeline and associated chemical and air supply lines. For this alternative, however, due to the length of the pipeline (1.7 miles), it is likely that a larger diameter pipe would be needed so that adequate pressures are maintained at the intake pump station once the project is operational under this alternative. Microtunneling is an effective installation technique when subsurface conditions are moderately variable across the length of drive. A variety of cutting heads can be used, and can be fitted with blades for soft soil, picks for hard soil/soft rock, and disc cutters for hard rock. However, microtunneling is vulnerable to significant changes in subsurface conditions including obstructions such as timber piles and boulders encountered during a drive. Should the need arise to clear obstructions that cannot be handled by the MTBM, unlike conventional tunneling with an open face, it is very difficult to gain sufficient access through the cutterhead to perform

18B-13 Haverstraw Water Supply Project DEIS clearing work from within the plenum chamber. Depending on the nature of the obstruction, it may be necessary to sink a recovery shaft to clear the obstruction. As with the Proposed Project, this alternative would require in-river work at the site of the intake structure, including the installation of a cofferdam. Section 15.2.2.1 of Chapter 15, “Construction Impacts,” describes the in-river construction activities and sequence associated with microtunneling, including construction activities related to the cofferdam and installation of the intake structure. Alternatively, the water intake line could be installed using horizontal directional drilling (HDD). HDD involves construction of a borehole through which the piping is pulled using a multi-step drilling process. An initial pilot bore is made using HDD equipment from a launch shaft to a termination shaft, following the tunnel route. This pilot bore is followed by additional drilling (reaming and back-reaming) of the pilot bore with increasingly larger drill bits to create a sufficient size opening to allow the carrier pipe to be installed. During this process, the borehole opening is maintained through the use of stabilizing drill fluids (typically water mixed with bentonite, a natural clay material). Once the opening is large enough, the pipe is attached to the drilling rod and pulled back through the borehole by the HDD machine. HDD is generally initiated from near the ground surface from shallow pits. From the initiation pit at the Intake Site, the HDD alignment would angle down to a depth sufficient to extend about 20 feet below the lowest ground surface or mud line level before angling upwards to the HDD termination point in the Hudson River, north of the northern boundary of the SCFWH. Since the termination point would be in the river, it would be necessary to construct a coffer dam within which the pipeline exit would be located. Entry angles at the initiation point are typically between 10 and 15 degrees, and exit angles are usually less than 10 degrees. Pipe curvature along the HDD alignment is a function of the pipe material and the drill rods. An HDD staging area at the Intake Site would require a minimum of 0.5 to 1 acre. At the termination where the intake structure would be installed, an area of sufficient length, up to approximately 500 feet, would be required where the long lengths of carrier pipe would be pulled through the borehole by the HDD machine. To establish a termination area of sufficient length, it would be necessary to temporarily locate a series of barges adjacent to the coffer dam. The in-river construction activities associated with the cofferdam and installation of the intake structure is further described in Chapter 15, “Construction Impacts,” cited above. The length of an HDD installation is dependent on pipe size, soil conditions and available staging area. As the pipeline gets larger in diameter, the shorter the distance that it can be installed using HDD. Typically HDD installations have been less than 5,000 feet, with the longest HDD installation being 5,400 feet for a 24-inch pipe. For the Proposed Project, however, the length of tunnel needed to locate the water intake outside the Haverstraw Bay SCFWH is 1.7 miles, or approximately 9,000 feet. Due to this length, using the HDD approach is not a viable alternative for the installation of the intake structure at this alternative location. The 1.7-mile-long tunnel required for this alternative could not be constructed using an MTBM. To construct a tunnel of this length, a full tunnel boring machine (TBM) would be required. Typically, tunnel boring machines have much larger diameters than micro tunnel boring machines—10- to 12-foot minimum diameter for a TBM for this project rather than the 5-foot diameter for an MTBM. The larger diameter tunnel can accommodate the equipment, power lines, muck lines, and ventilation that would be needed for the longer tunnel run. Construction of this long tunnel using the larger machine would be a more complex endeavor, requiring deeper

18B-14 Chapter 18B: Project Design Alternatives construction to provide adequate cover above the tunnel to maintain the tunnel’s stability, and involving much greater volume of materials removed from the tunnel. This would increase the cost of the project by as much as $140 million and lengthen the construction schedule by up to 18 months. The route of the tunneled intake line would run under the Town of Stony Point’s Riverfront Park, a public waterfront park that is located on the point of land where River Road bends to become Grassy Point Road. Implementing this alternative would therefore require the alienation of parkland by the New York State Legislature, and such approval is not within United Water’s capabilities.

18B.2.3.3. ALTERNATIVE INTAKE METHODS—INFILTRATION GALLERY Two types of infiltration galleries—subsurface intake structures and on-shore infiltration galleries—were evaluated to determine the feasibility of these types of intake structures as an alternative to the proposed open surface water intake structure. Infiltration galleries can be designed to capture groundwater as it discharges to a surface water body (i.e., the Hudson River) and/or induce infiltration from the surface water body. Infiltration gallery systems utilize natural filtration that occurs as water is drawn through a permeable layer surrounding the intake. As a result, both types of infiltration galleries could significantly reduce and possibly eliminate impingement and entrainment of aquatic organisms. However, as discussed below, both types of infiltration galleries have been determined to be infeasible for use with the Proposed Project. The feasibility of utilizing an infiltration gallery system as an alternative to the proposed intake structure is discussed below (see Appendix 18B.1 for additional information).

18B.2.3.3.1. Subsurface Intake Structure There are several types of subsurface intake structures. Most commonly, these consist of a well or wells (e.g., vertical wells, slant wells, or radial wells) which are installed along the coastline or river bank and connected to an on-shore pumping facility. With this alternative, a well or wells would be constructed along the embankment of the Hudson River (western shoreline) in an area where groundwater is tidally influenced and an on-shore pumping facility would be located nearby. Well-type intake structures must have a suitable geologic unit (i.e., subsurface layer) of permeable sand and gravel and significant areal extent and hydraulic connectivity to the water body. A hydrogeologic study was undertaken by Leggette, Brashears & Graham, Inc. (2008) to determine the feasibility of utilizing a subsurface intake as an alternative to the proposed open surface water intake structure for the Proposed Project. This study sought to identify locations where hydrogeologic conditions would be suitable for subsurface withdrawal of river water. A total of 17 borings were drilled in 2008 at locations in Haverstraw and Stony Point near the river, from Bowline Point Town Park on the south to Riverfront Park on Grassy Point Road in Stony Point on the north. At most of the boring locations, subsurface conditions were not suitable for a well-type intake. Rather, fine-grained, low permeable sediments were generally encountered, with only minor amounts of sand and gravel. The only shoreline area identified in the vicinity of the Water Treatment Plant site that had a potentially suitable amount of sand and gravel was Riverfront Park in Stony Point. Placement of a subsurface intake well or wells at this upland location would require acquisition and alienation of the parkland and would either entirely or substantially displace this waterfront park, which would result in an adverse impact to this open space resource.

18B-15 Haverstraw Water Supply Project DEIS

Another type of subsurface intake structure is an engineered subsurface intake. This type of intake may be used where no natural materials exist to support subsurface intake wells, and involves construction of an artificial permeable layer (i.e., a filter bed) and a series of perforated intake pipes laid within this layer. With an engineered subsurface intake system alternative, at least six to eight feet of the Hudson River bottom would be excavated and replaced with coarser, more permeable sand and gravel to create a filter bed. A system of intake pipes would be laid within the filter bed, and the raw water would be pumped to the water treatment plant, which would be located at the Water Treatment Plant Site. There are several factors that pose a challenge to the use of a subsurface infiltration gallery system in this area of the Hudson River. First, Haverstraw Bay is a depositional environment with high sedimentation rates (up to 8 millimeters per year at some locations). High concentrations of suspended sediments are deposited and resuspended throughout the bay. With an engineered subsurface intake, the continued deposition of mud and sandy mud would be expected to clog the filter bed, requiring frequent dredging or cleaning such as replacing the filter bed or daily back flushing of water or air through the system. Water that would be pumped from a subsurface intake structure would include both groundwater and river water, although approximately 85 to 95 percent of the pumped water would likely be river water. The infiltration system would draw water from the river bottom where the salinity concentration is the highest. Therefore, the raw water salinity levels would be higher with a subsurface intake structure than currently anticipated with the Proposed Project. Groundwater may also pose a challenge to the subsurface intake structure should the groundwater contain elevated iron. Upon discharging into the infiltration gallery, dissolved iron would oxidize and produce ferric iron, which would clog the infiltration gallery and require increased maintenance. The issue of iron fouling became problematic at an on-shore infiltration gallery installed in the Town of Bethlehem, New York, in 1996. This infiltration gallery, which was constructed to provide a source of raw water for industrial purposes, was designed to capture groundwater prior to discharging to the Hudson River as well as to capture flow from the river through infiltration. While the infiltration gallery was intended to produce 6 mgd, the average capacity over the first year of operation was 2.3 mgd and the current average capacity is approximately 0.8 - 1.0 mgd. The two main reasons for the reduced capacity of the system are siltation within the Hudson River and iron fouling of the infiltration gallery. (Further discussion is provided in Appendix 18B.1.) To allow for intermittent pumping during low tides, when salinity is lower, and assuming a water flow rate of 0.05 gallons per minute per square foot1, such as system within the Hudson River would require an extensive footprint, comprising between three and six acres of the river bottom. As discussed in Chapter 9A, “Aquatic Natural Resources,” the use of Haverstraw Bay as a nursery, feeding and/or overwintering area for marine and anadromous species and the presence of vulnerable or sensitive species (i.e., endangered or threatened) qualifies Haverstraw Bay as a SCFWH. The installation of such an extensive filter bed, as well as routine maintenance associated with the operation of an engineered subsurface intake, would affect a much larger

1 This surface loading rate is consistent with guidance published by the American Water Works Association (AWWA), Reverse Osmosis and Nanofiltration. AWWA Manual of Water Supply Practices – M46, Second Edition. 2007. Low surface loading rates are intended to mimic slow sand filtration; this rate is at the low end of the range recommended by AWWA to account for the silty nature of the sediments in the Hudson River.

18B-16 Chapter 18B: Project Design Alternatives area of the river than the Proposed Project (three to six acres vs. up to 2,000 square feet with the Proposed Project) and this large area would be expected to adversely impact aquatic resources in Haverstraw Bay. Therefore, for the reasons described above, the use of an engineered subsurface intake structure is not considered a feasible alternative.

18B.2.3.4. ON-SHORE INFILTRATION GALLERY With an on-shore infiltration gallery system alternative, a trench would be constructed parallel to the riverbank. A perforated pipe or well screen would be installed at the bottom of the trench and backfilled with gravel. The screen would connect to intake piping and either submersible pumps or a pump station. With this alternative, the raw water drawn via the on-shore infiltration gallery would be pumped to the water treatment plant, which would be located at the Water Treatment Plant Site. This type of intake system was installed on the Hudson River in Bethlehem, NY, as discussed above (further discussion is provided in Appendix 18B.1). Using the Bethlehem system as a template, it is expected that an intake system occupying approximately 10,000 to 20,000 linear feet of shoreline would be needed to produce the amount of water required for the proposed water treatment plant (approximately 10,000 linear feet of shoreline to produce a flow rate of 10 mgd with continuous pumping, or 20,000 feet to produce a flow rate of 20,000 mgd to allow for intermittent pumping).1 The depositional environment of Haverstraw Bay would be problematic to an on-shore infiltration gallery in this location, as it would limit flow to the system. In addition, the hydrogeologic investigation described above revealed extensive sedimentary deposits of silt and clay, which would also limit flow. Further, a much larger area—extending two to four miles along the shoreline—would be required to produce the amount of water needed to meet the Project’s purpose and need. Due to the extensive amount of shoreline that would be required and the potential problems associated with sedimentary deposits and siltation, the use of an on-shore infiltration gallery is not considered a feasible alternative.

18B.3. ALTERNATIVE ENERGY SOURCES FOR THE PROPOSED PROJECT United Water is committed to providing sustainable projects. As noted on United Water’s website,2 this includes a commitment to reduce greenhouse gas emissions; improve energy efficiency; and increase and promote renewable energy generation. To meet that commitment, United Water continues to investigate the provision of alternative energy sources for the Proposed Project that could reduce or eliminate its demand for power from the existing electrical grid. The potential for use of alternative, renewable energy sources is constrained by a number of factors, including regulations associated with O&R’s tariffs, availability of sites for power infrastructure, solar and wind conditions in Rockland County, and the cost of these options and associated effect on customer rates. Nonetheless, even given these constraints, there may be opportunities for use of alternative energy in connection with the Proposed Project. This section

1 The infiltration rate and reported effectiveness of the system in Bethlehem, NY was used to determine the estimated length of shoreline required to maintain 10 mgd raw water flow required for the proposed water treatment plant. 2 http://www.unitedwater.com/sustainable-development.aspx.

18B-17 Haverstraw Water Supply Project DEIS describes the potential alternative energy sources for the Proposed Project that will be further evaluated as design advances.

18B.3.1. FACTORS AFFECTING USE OF SUSTAINABLE ENERGY

18B.3.1.1. POWER NEEDS OF THE PROPOSED PROJECT The energy demand for the Proposed Project would vary on a daily, monthly, seasonal, and even annual basis, depending on the amount of water being produced as well as on the temperature and salinity levels of the raw water. As discussed in Chapter 11 of this DEIS, “Infrastructure and Energy” (section 11.4.4.2.3), based on the current level of design completed, the Proposed Project’s average annual energy demand at full build-out (when the plant would produce 7.5 mgd of water) has been estimated at approximately 17,370 megawatt hours (MWh), or 18,256 MWh assuming warmer ambient temperatures and higher salinity as might occur with global climate change. The peak load (also known as the maximum operating load) for the Proposed Project is estimated at 4.47 MW. As also discussed in Chapter 11, the energy utility serving the Project Sites, O&R, has indicated that it has the capacity to supply the Proposed Project’s energy needs via the existing electrical grid.

18B.3.1.2. FACTORS AFFECTING USE OF “OFF-THE-GRID” POWER For the Proposed Project to meet its power demands without using O&R’s power grid, the Project must be able to produce enough energy on its own to meet its peak period demands. This would mean that a fully off-the-grid alternative would have to be able to produce a maximum operating load of 4.47 MW at full build-out. Any energy supplied to the Proposed Project from a source that is off of the grid must, of course, be reliable and able to meet the demands for the Project during peak and off-peak periods. The Proposed Project could also generate supplemental power off the grid to meet some, but not all, of its energy needs. This is referred to as “distributed generation.” In accordance with the Public Service Law, O&R’s tariff (i.e., approved rates, charges, rules and regulations for electric service), which is approved by the New York State Public Service Commission (PSC), has requirements regarding distributed generation provided by commercial customers. O&R’s tariff also limits the amount of power that can be produced by commercial customers who remain connected to the grid and want to sell power back to O&R. In total, up to 2 MW of distributed generation electricity may be produced by a single commercial customer. In addition, over O&R’s entire distribution system, no more than 3.1 MW in wind power and 10.4 MW in solar power may be generated as distributed generation.1 These limits are intended to protect O&R’s ability to adequately provide power for their entire distribution system, since the utility must have adequate capacity to meet the needs of commercial customers who are producing their own power in case those off-the-grid systems fail. O&R’s tariff rules also govern procedures for “net metering,” also referred to as “reverse metering,” in which a customer generates power that can be sold back to O&R when it is excess of the customer’s needs. Customers may also produce power on-site without generating a surplus that is sold back to the utility. This is sometimes referred to as “behind the meter” power, because it reduces the need for metered power. There is no limit to the amount of power that a customer can produce “behind the meter.”

1 O&R Tariff, 6th Revised Leaf No. 22L-23, Service Classification Riders, Rider N.

18B-18 Chapter 18B: Project Design Alternatives

18B.3.2. POTENTIAL ALTERNATIVE ENERGY SOURCES FOR THE PROPOSED PROJECT This section describes the potential alternative energy sources for the Proposed Project that will be further evaluated as design advances. These include the use of wind power at or near the Project Sites, and the use of solar power at the Project Sites, and purchase of renewable energy from an energy provider. The analyses presented below were informed by the NYSDEC guidance on the review and consideration of the environmental effects of wind power projects.1

18B.3.2.1. ON-SITE WIND POWER

18B.3.2.1.1. Description of Alternative United Water is evaluating the use of wind power at the Water Treatment Plant Site. Data for the Haverstraw area indicates that wind in this area may be suitable for use of wind turbines. The National Renewable Energy Laboratory, which is under the jurisdiction of the U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, has created maps classifying the wind resources of the U.S. in seven wind power classes, ranging from Class 1 to Class 7, with 7 being the windiest. Each class represents a range of “wind power density” or equivalent mean speed, at specified heights above the ground. For each geographical area, the assigned wind power class represents the range of wind power densities likely to occur at locations free of obstruction, such as hilltops and large clearings. Using this system, areas designated as Class 4 or greater are suitable for utility-scale wind power generation using technologies currently available. Class 3 may be suitable for smaller wind power generation. The wind power class for Haverstraw is 4, indicating that wind power generation may be effective there.2 Wind turbines are most effective when they are several hundred feet above the ground, where the wind is faster and less turbulent than at ground level. For the Proposed Project, small wind turbines mounted on masts 140 feet above ground surface could be used to produce power. At the top of the mast the blades would be 10 feet long. To maximize the amount of power that could be generated on the Water Treatment Plant Site, this alternative assumes that eight small wind turbine masts would be located on the Water Treatment Plant Site. These would be located between the water treatment plant buildings and the landfill (see Figure 18B-4). Even with eight turbines on the Site, the effectiveness of small wind turbines at the Water Treatment Plant Site would be limited. Considering the size of the turbines and the varying wind speeds at the Water Treatment Plant Site, the use of wind turbines on the Project Sites would generate only a small amount of power, ranging from 4,000 to 16,000 kWh per year, which is less than 1 percent of the predicted average annual energy consumption for the Proposed Project. By comparison, the national average energy consumption for a single-family house is estimated to be 12,773kWh per year.3 Larger wind turbines cannot be accommodated on the Water Treatment Plant Site because of the need to maintain a buffer zone around such turbines that is large enough so that in the unlikely event that the turbine should fall, it would fall only within the buffer zone. Buffer zones consist

1 http://www.dec.ny.gov/energy/40966.html 2 Wind power classifications are available from the National Renewable Energy Laboratory at www.nrel.gov/gis/wind.htm. 3 http://www.epa.gov/greenpower/pubs/calcmeth.htm

18B-19 1.13.12

Potential Wind Turbine Locations 0 100 200 FEET SCALE

Figure 18B-4 Potential Location of Wind Turbines UNITED WATER Haverstraw Water Supply Project at Water Treatment Plant Haverstraw Water Supply Project DEIS of circular areas around each wind turbine that are at least 110 percent the height of the mast plus the turbine blade when it is extended straight upward. Large wind turbines are typically several hundred feet tall; for example, depending on the specific manufacturer and type of equipment, wind turbines rated for 0.5 to 1 MW are generally 250 to 300 feet tall and therefore require buffer areas of 270 to 330 feet. Larger wind turbines, rated for 2 to 2.5 MW, are generally 390 to 410 feet in height, and therefore require buffer areas of 430 to 450 feet. No locations on the Water Treatment Plant Site, including the property owned by DSB Realty Associates, LLC (referred to as the “DSB property”) or the Intake Site, are large enough to accommodate the buffer zone (of 270 to 450 feet). In addition, no feasible site is available at the former Haverstraw Landfill, since large wind turbines require substantial foundations, and such a foundation would interfere with the landfill cap. The 140-foot-tall wind turbines that would be located at the Water Treatment Plant Site in this alternative would have an appropriate buffer between the mast and adjacent properties, but would not have a buffer between the mast and the water treatment buildings. The environmental issues associated with small mast-mounted wind turbines at the Water Treatment Plant Site are discussed below.

18B.3.2.1.2. Effects on Greenhouse Gas Emissions To the extent that wind power generated at the Project Sites can offset some of the Project’s energy demand, this would have a positive effect in terms of greenhouse gases. However, as noted above, small wind turbines at the Water Treatment Plant Site would generate only a minimal amount of energy. 18B.3.2.1.3. Visual Effects Small mast-mounted wind turbines would have relatively small-diameter rotors, but because of their height, would be visible from around the Project Site. To consider the visual effects of the Proposed Project with wind turbines on the Water Treatment Plant Site, a visual impact analysis was prepared consistent with the methodologies for the Proposed Project applied in Chapter 4, “Visual Resources.” The visual impact analysis for the wind turbine alternative considered the incremental additional height and mass of the eight wind turbines at the Water Treatment Plant Site and followed the same general framework that was presented in Chapter 4. Besides the addition of the wind turbines, all other aspects of the visual character of the Proposed Project under the wind turbine alternative would remain the same as presented in Chapter 4. The five-mile study area around the Project Sites that is described and mapped in Chapter 4 was also used for the evaluation of the Proposed Project with wind turbines. The inventory of resources considered (described in section 4.3.2.3 of Chapter 4) is therefore also unchanged. However, the viewshed for the Proposed Project would be slightly larger, because of the tall wind turbine masts. Figure 18B-5 illustrates the viewshed for the Water Treatment Plant Site with wind turbines (the viewshed for the Intake Site would be unchanged from that described in Chapter 4 and therefore is not discussed in this chapter). Of the 81 historic resources considered in Chapter 4, 29 would fall within the viewshed for the Water Treatment Plant Site with wind turbines, as discussed below. The visual effects of the Proposed Project related to the addition of wind turbines on the Water Treatment Plant Site are summarized below and in Table 18B-2. Figures 18B-6, 18B-7, and 18B-8 provide photosimulations of the wind turbines from several locations in the surrounding area.

18B-20 7.6.11

R3-R12 Long Path W24 W2

Hudson Highlands SASS W8 W3 W10 W18 W7 W23 W5-W6 W9 A 3 W12 W1 pp ala W19 W4 chian Trail W11 W22 W25 W13-W16 W26 W20-W21 Bear Mountain State Park 2 W27 W28 R2 W29 Harriman 1 State Park 1 W17

W31

W32

4 21 23 R o u W30 te 5 W33 9 R14-16 22 W34 R13 R18 15 13 24 R17 14 R26 26 12 30 R22 31 20 W39 15 R24 29 W41 R23 28 W40 R25 27 9W W35 W36

16 17 18 W37 High Tor R19 R20 R21 State 6 Park 7 R28 19 South Mountain 25 R27 County Park Croton W38 1010 Point Park O l R37 R39 d C

R32-R36 r

o t

o Watern Treatment Plant Site R40 Long Path A

R1R9 q

u e

9W

Intake d Site

u c

8,9 t 5-Mile Study Area R30 R31 R29 Rockland Lake R38 State Visual Resources Park, Historic Resources Hook Mountain Analyzed Roadways State Park 1 Visual Resources (see Table 18B-2)

Hudson Highlands SASS

Viewshed - Potential Wind Turbines 0 1 2 MILES

SCALE Figure 18B-5 UNITED WATER Haverstraw Water Supply Project Alternative Viewshed Analysis 7.27.11

Existing Conditions: 1a View looking southwest toward Water Treatment Plant Site from Town of Haverstraw Canoe and Kayak Launch

Proposed Water Treatment Plant

Proposed Conditions: 1b View looking southwest toward Water Treatment Plant Site from Town of Haverstraw Canoe and Kayak Launch

Figure 18B-6 Photosimulation, Water Treatment Plant UNITED WATER Haverstraw Water Supply Project with Wind Turbines 7.8.11

Existing Conditions: 2a View looking north along Railroad Avenue

Proposed Water Treatment Plant

Proposed Conditions: 2b View looking north along Railroad Avenue

Figure 18B-7 Photosimulation, Water Treatment Plant UNITED WATER Haverstraw Water Supply Project with Wind Turbines 7.27.11

Existing Conditions: 3a View from Helen Hayes Hospital looking east toward Water Treatment Plant Site

Proposed Water Treatment Plant

Proposed Conditions: 3b View from Helen Hayes Hospital looking east toward Water Treatment Plant Site

Figure 18B-8 Photosimulation, Water Treatment Plant UNITED WATER Haverstraw Water Supply Project with Wind Turbines Chapter 18B: Project Design Alternatives

Table 18B-2 Effects of Wind Turbines on the Water Treatment Plant Site on Visual Resources in the 5-Mile Study Area Map No. Resource Effect of Project with Wind Turbines 1 Harriman State Park Wind turbines might be visible from Harriman State Park and Bear Mountain State Park, particularly from open ridgetops. However, because of distance to the Project Site and the narrow profile of the masts, the wind 2 Bear Mountain State Park turbines would be difficult to see. With the screening effect of vegetation and the context set by surrounding industrial uses in Haverstraw, the wind turbines would 3 Hudson Highlands Scenic Area of Statewide not result in a significant visual impact on Harriman Significance (SASS) State Park, Bear Mountain State Park, or the Hudson Highlands SASS. 4 Palisades Interstate Parkway The Palisades Interstate Parkway is not within the viewshed of the Project Site and the wind turbines would not be visible from the parkway. 5 Stony Point Battlefield State Historic Site The wind turbines would be visible from the southern portion of the Stony Point Battlefield site, but would be partially screened by vegetation, obscured by distance, and set within an industrial context that includes the U.S. Gypsum facility and conveyor and the Bowline Power Plant, among other structures. The Proposed Project with the wind turbines would not alter the overall character of the sweeping Hudson River views available from the Battlefield and would not impair this resource. 6 High Tor State Park From areas along the ridgeline in these parks, views of the wind turbines would be visible. These would be set within the context of numerous structures and industrial buildings that surround the Water Treatment Plant Site. 7 South Mountain County Park The overall context and character of views from High Tor and South Mountain would not be adversely affected. 8 Hook Mountain State Park Similar to views from High Tor State Park and South Mountain County Park, views toward the north from these State Parks could include views of the wind turbines. Overall, views from these parks are dominated by wide vistas of the Hudson River and over the entire 9 Rockland Lake State Park Haverstraw area (including a number of large industrial structures) and this character would not change with the addition of the wind turbines. 10 Haverstraw Beach State Park Although this park falls within the viewshed of the Water Treatment Plant Site with wind turbines, views toward the Project Site are largely blocked by topography. The character of the park is largely associated with its views of the Hudson River, which would not be affected by the wind turbines. 11 Historic Sites Within Viewshed R1 Palisades Interstate Parkway See No. 4 above. R2 Bear Mountain State Park Historic District See No. 2 above. R14 Stony Point Battlefield See No. 5 above R15 Stony Point Battlefield Museum See No. 5 above R16 Stony Point Lighthouse See No. 5 above R17 House at 88-90 East Main Street, Stony Point Views of the wind turbines would be completely R18 House at 92 East Main Street, Stony Point screened by topography and intervening buildings and vegetation.

18B-21 Haverstraw Water Supply Project DEIS

Table 18B-2 (cont’d) Effects of Wind Turbines on the Water Treatment Plant Site on Visual Resources in the 5-Mile Study Area Map No. Resource Effect of Project with Wind Turbines R19 US Post Office–Haverstraw Views of the wind turbines would be completely R20 Kings Daughters Public Library, Haverstraw screened by topography and intervening buildings and vegetation. R21 House at 143 Hudson Avenue, Haverstraw Views of the wind turbines would be completely screened by topography and intervening buildings and vegetation. R22 M/V Commander, Haverstraw Marina The top of the wind turbines would be visible over the mound of the Haverstraw Landfill. With their narrow masts and small rotors, the turbines would not adversely affect views from this location. See Figure 18B-8. R23 Fraser-Hoyer House, Treason Hill off Route See No. 31 below. 9W, West Haverstraw R24 Henry M. Peck House (Helen Hayes Hospital) R25 Railroad Avenue School (Cosgrove Avenue) Views of the wind turbines would be screened by topography and intervening buildings and vegetation. If visible from limited locations, the turbines would be in the context of other buildings and utility poles and would not be dominant features in the landscape. W1 Ford Administration Building, Peekskill Due to the distance between the turbines and these W4 Drum Hill High School, Peekskill resources (5 miles or greater), views would be screened by intervening structures and vegetation and obscured W5 US Post Office, Peekskill as a result of atmospheric perspective. The turbines are W8 Nelson Avenue-Fort Hill Historic District unlikely to be noticeable from these locations. W17 School, 1024 McKinley Street, Peekskill W24 Pump House, Camp Smith, Peekskill W26 Funeral Home, 344 Washington Street, Peekskill W27 Tomassio Residence, Peekskill W28 Peekskill Armory W29 Augustowski Residence, Peekskill W31 Church of St. Patrick, Peekskill W33 Veterans Administration Medical Center, Views of the wind turbines would be completely Montrose screened by topography and intervening buildings and vegetation. W35 Croton North Railroad Station, Croton-on- Views of the wind turbines would be available from the Hudson railroad station, but given the distance (4 miles), the effects of atmospheric perspective, and the other buildings near the Water Treatment Plant Site that would also be visible in the same view, the turbines would not be a notable element in the landscape from this vantage. W36 Asbury United Methodist Church and Bethel Due to the distance between the turbines and these Chapel and Cemetery, Croton-on-Hudson resources (5 miles or greater), views would be screened W37 Van Cortlandt Manor, Croton-on-Hudson by intervening structures and vegetation and obscured as a result of atmospheric perspective. The turbines are W38 Old Croton Aqueduct, Croton and Yonkers unlikely to be noticeable from these resources. 12 Minisceongo State Tidal Wetlands Area The top of the wind turbines would be visible over the mound of the Haverstraw Landfill. With their narrow masts and small rotors, the turbines would not adversely affect views from this location. See Figure 18B-8.

18B-22 Chapter 18B: Project Design Alternatives

Table 18B-2 (cont’d) Effects of Wind Turbines on the Water Treatment Plant Site on Visual Resources in the 5-Mile Study Area Map No. Resource Effect of Project with Wind Turbines 13 Lowland Park Views of the wind turbines would be completely screened by topography and intervening buildings and vegetation. 14 Riverfront Park Views of the tops of the wind turbines may be possible from this location, but most if not all views would be screened by intervening buildings and vegetation. The visual character of this park, which is related to its wide vistas of the Hudson River, would not be affected. 15 Haverstraw Bay County Park Views of the tops of the wind turbines may be possible from this location, but most if not all views would be screened by intervening buildings and vegetation. The visual character of this park, which is related to its wide vistas of the Hudson River, would not be affected. 16 Babe Ruth Field Views of the tops of the wind turbines may be possible from this location, although most views would be screened by vegetation. The character of this park is related to its recreational features, and this character would not be adversely affected by the addition of views of wind turbines. 17 Bowline Point Town Park Views of the tops of the wind turbines may be possible from this location, but most if not all views would be screened by intervening buildings and vegetation. The visual character of this park, which is related to its wide vistas of the Hudson River, would not be affected. 18 Emeline Park Views of the wind turbines would be completely screened by topography and intervening buildings and vegetation. 19 Route 9W Scenic Overlook The wind turbines would be visible from the Route 9W Scenic Overlook. They would be set within the context of the dense development of the Villages of Haverstraw and West Haverstraw, including other much larger industrial structures such as the Bowline Point power facility. The addition of wind turbines would not detract from this view. 20 Hudson River The wind turbines would be visible from the Hudson River above the mound of the Haverstraw Landfill or behind other buildings. They would be set within the context of the dense development of the surrounding area, including other much larger industrial structures such as the Bowline Point power facility. The wind turbines would not be a dominant feature and would not detract from this view. 21 Montrose Point State Forest From these locations, views of the wind turbines may be possible, but due to the distance between the turbines 22 George’s Island County Park and these resources (1 to 5 miles or greater), views would be screened by intervening structures and 23 Sunset Park vegetation and obscured as a result of atmospheric perspective. Views of and across the Hudson River 24 Oscawana County Park include the developed area of Haverstraw and the natural features of the wooded hills, and in this context, 25 Croton Point Park the turbines would not be a dominant feature.

18B-23 Haverstraw Water Supply Project DEIS

Table 18B-2 (cont’d) Effects of Wind Turbines on the Water Treatment Plant Site on Visual Resources in the 5-Mile Study Area Map No. Resource Effect of Project with Wind Turbines 26 Beach Road / River Road The top of the wind turbines would be visible over the mound of the Haverstraw Landfill. With their narrow masts and small rotors, the turbines would not adversely affect views from this location. See Figure 18B-8. 27 Railroad Avenue The wind turbines would be visible down the view corridors created by north–south streets (e.g., Carol Avenue, the CSX railroad-right-of-way, and North 28 North Wayne Avenue Wayne Avenue). From these vantages, the narrow profile of the wind turbine masts are not readily noticeable, as illustrated in Figure 18B-7. 29 Benson Street The wind turbines would be clearly visible from the residences along Benson Street and, on the public street, in gaps between buildings. The turbines would be set within the context of the Water Treatment Plant Site’s industrial setting, which includes other industrial uses. They would not change that setting or adversely affect the visual character of views from Benson Street. 30 Kay Fries Drive The wind turbines may be visible from many locations on Kay Fries Drive, but this street is industrial in character and views of the turbines would not change that setting. 31 Helen Hayes Hospital From the Helen Hayes Hospital campus (and from other locations west of Route 9W nearby), views of the Hudson River area available above existing structures, particularly during the winter. From these locations, the wind turbines would be visible, but because of their narrow masts and small rotors, they would generally blend into the background setting and not dominate views. Views of the Hudson River would continue to be available above the turbines. Figure 18B-6 provides a photosimulation of views of the wind turbines from the campus. Note: Numbering corresponds to Figure 18B-5.

As noted in Table 18B-2, the addition of wind turbines at the Water Treatment Plant Site would not result in significant adverse visual impacts. From most locations, views would be obscured by topography and intervening buildings and vegetation. When the turbines are visible, they would be set within the existing, developed context of an industrial area of Haverstraw. The Water Treatment Plant Site’s topography, which is lower than the surrounding area, and its location beside the mound of the Haverstraw Landfill, would reduce the perceived height of the turbines. The narrow masts and small rotors would further limit the visibility of the turbines. 18B.3.2.1.4. Effects on Natural Resources Wind turbines can have adverse effects on two groups of wildlife, birds and bats, which can be disturbed by the presence of the turbines or injured or killed by collisions with the rotating blades. Disturbance impacts include construction-related disturbances such as habitat loss or degradation due to clearing and grading activities, and avoidance of certain habitat areas due to increased human activity, visual disturbance, and noise during construction and operation of the turbines (Drewitt et al. 2006, Kunz et al. 2007, Leddy et al. 1999, Madders and Whitfield 2006).

18B-24 Chapter 18B: Project Design Alternatives

Collision impacts represent the direct losses of individuals due to collisions with turbines. The following sections assess the potential for the wind turbines at the Project Site to adversely affect wildlife. Disturbance Impacts The wind turbines would be located on the east side of the proposed water treatment plant buildings and the access road that encircles the building (see Figure 18B-4), within a portion of the Site that would be disturbed in any case through clearing and grading for the construction of the treatment plant buildings and structures. Therefore, construction of the turbines would not result in habitat loss or disturbance of adjacent habitats due to noise, visual disturbance, or increased human activity during construction beyond the disturbances resulting from construction of the water treatment plant. Because the turbines would be located within the portion of the Water Treatment Plant Site that would be developed for the water treatment plant, would be distant from Grassy Point Marsh and the majority of the grassland habitat present within the Haverstraw Landfill, and would be adjacent to existing developed areas with high levels of human activity (e.g., train tracks, residential and commercial areas west and north of the Site), there is minimal potential for the operation of the turbines to result in significant adverse impacts to wildlife from increased human activity, visual changes, or noise. The group of birds most likely to occur in the habitat closest to the potential turbine locations is grassland birds, which may be located at the Haverstraw Landfill. This group of birds has been shown to avoid areas with operating turbines, but these displacement effects generally do not extend more than approximately 500 feet from a turbine (reviewed in Johnson and Stephens 2011). For these reasons, disturbance potential of the turbines is considered low, and any potential impacts of the turbines to birds and bats are expected to be primarily limited to collisions, as discussed below. Collision Impacts Bats Collisions with rotors, towers, nacelles (tower hub), and other associated structures result in the majority of the direct loss of bird and bat individuals resulting from wind turbines (Drewitt and Langston 2008, Cryan and Barclay 2009). Additional losses of bats have also been attributed to fatal internal bleeding resulting from the vortex created by spinning rotors (Baerwald et al. 2008). Bird and bat mortality at turbines is highly variable and influenced by a complex interaction of a species’ ecology and behavior, turbine characteristics (i.e., height, rotor size, lighting), weather, season, geographic location, and site features (Drewitt and Langston 2008, de Lucas et al. 2008, Cryan and Barclay 2009, Smallwood et al. 2009). Why birds and bats do not avoid turbines remain unclear and remains a subject of continued study (Cryan and Barclay 2009, Rydell et al. 2010a, Martin 2011). Although the causes of bat mortality at wind turbines are uncertain, the following patterns in bat mortality have been apparent: • The overwhelming majority of bats killed by turbines in North America and Europe are insectivores that belong to the group of long-distance migratory species that roost in trees throughout the year, known as “tree bats,” as opposed to other bat species that occupy caves or mines (Kunz et al. 2007, Arnett et al. 2008, Rydell et al. 2010b). • Bat mortality at wind power facilities peaks dramatically during autumn migration (August through October; Kunz et al. 2007, Arnett et al. 2008, Cryan and Barclay 2009, Rydell

18B-25 Haverstraw Water Supply Project DEIS

2010b, Jain et al. 2011). Autumn fatalities alone account for more than 90 percent of the annual turbine mortality in the United States (Johnson 2005). There is also often a small rise in bat fatalities towards late summer, possibly due to the boost in local population sizes from juvenile recruitment, and the increased feeding activity of bats at this time in preparation for upcoming migration or hibernation (Cryan and Barclay 2009, Jain et al. 2011). • Bat mortalities are strongly related to turbine height. Collisions with turbines shorter than 164 feet (50 meters) are almost nonexistent, whereas turbines that are 213 feet (65 meters) and taller account for nearly all documented fatalities (Barclay et al. 2007, Arnett et al. 2008, Baerwald and Barclay 2009). In the eastern United States, the hoary bat, eastern red bat (Lasiurus borealis), silver-haired bat (Lasionycteris noctivagans), and eastern pipistrelle (Pipistrelles subflavus) together account for approximately three-quarters of all bat fatalities at wind energy facilities. Hoary bats (Lasiurus cinereus) account for nearly half of all turbine fatalities in North America (Arnett et al. 2008). Small wind turbines at the Water Treatment Plant Site would not result in significant adverse impacts to bats due to collision with turbines. Suitable habitat for migratory tree bats, the group of bat species that most commonly collide with turbines, is limited in the vicinity of the Water Treatment Plant Site. Tree cover in the area is limited to a narrow strip along the northern and western boundary of the Site. Any bat activity in the vicinity of the Water Treatment Plant Site is expected to be largely concentrated to the north and east where larger forest fragments and open water in the Grassy Point Marsh provide far more suitable roosting and foraging opportunities, respectively, for migratory tree bats. Additionally, the height of the potential wind turbines (140 feet) is within the range of heights found to result in little to no mortality for bats (approximately 164 feet [50 meters]), and is also below the height that would require nighttime obstruction lighting. Lighting can attract insects to turbines and, in turn, possibly draw more bats into the rotor zone (Horn et al. 2008, Cryan and Barclay 2009, Rydell et al. 2010a). Birds Relative to bats, bird collisions with turbines occur more steadily throughout the year and affect numerous groups of species, including birds of prey, songbirds, waterfowl, and waterbirds (Kuvlesky et al. 2007, Drewitt and Langston 2008). While the potential impacts to birds from the development and operation of wind turbines is influenced by many factors, turbine placement is perhaps the greatest determinant of bird collision risk (Drewitt and Langston 2008, WTGAC 2010). For example, wind energy facilities in forested sites, particularly along ridgelines, cause far greater bird mortality in the northeastern United States than facilities in non-forested areas and areas with little topography (Johnson and Stephens 2011). Given that the Water Treatment Plant Site and surrounding area are not forested or on a ridgeline, potential for bird mortality may be relatively low. However, wind energy facilities that may generally be expected to have low impacts on most birds may nonetheless have significant impacts on an individual species or disproportionately high impacts on a particular group of species (Johnson and Stephens 2011). Therefore, assessing the potential for the wind turbines to impact birds requires full consideration of the area’s birdlife and the species’ ecology. On the basis of the surrounding landscape and the habitats within and near the Water Treatment Plant Site, the following birds are considered to have the greatest potential to occur nearby: waterbirds and waterfowl occurring in Grassy Point Marsh, nocturnally migrating songbirds passing through the area during spring and fall, grassland birds breeding or overwintering on the Haverstraw Landfill, and birds of prey. As discussed below, none of these groups would be adversely affected by small turbines at the Water Treatment Plant Site:

18B-26 Chapter 18B: Project Design Alternatives

• Waterfowl and Waterbirds: The Water Treatment Plant Site offers extremely limited habitat for waterfowl and waterbirds, and activity of these birds near the turbines would be unlikely. Occurrence of these birds in the area is expected to be primarily limited to the wetlands well north and east of the site in Grassy Point Marsh. In general, waterfowl and waterbird collisions with turbines are uncommon, usually representing fewer than 5 percent of total bird fatalities (Johnson and Stephens 2011), and these birds are expected to be at low risk for collisions with the turbines. • Migrating Songbirds: Many songbirds are migratory and migrate at night. While collisions of night migrants with man-made structures such as communication towers and tall buildings have been well-documented and can be numerous (e.g., Gehring et al. 2009), nocturnal migrant songbirds typically fly at altitudes well above the reach of even the tallest turbines and far fewer birds appear to collide with wind turbines. A recent study of collisions at 30 wind farms across North America concluded that night migrant fatalities were minimal, particularly in comparison to communications towers and other structures that typically have obstruction lighting and guy wires (Kerlinger et al. 2010). Individual songbirds may pass through rotor zones during stopover descent and ascent (WTGAC 2010), and songbirds are often the bird group with the greatest number of fatalities at wind energy facilities (Smallwood and Karas 2009, Johnson and Stephens 2011). However, relative to their abundance, songbirds collide with wind turbines far less frequently than other groups of birds such as birds of prey (Johnson and Stephens 2011), and collisions of songbirds with wind turbines are considered too infrequent to have significant effects at the population level (Drewitt and Langston 2008, Kerlinger et al. 2010, Johnson and Stephens 2011). The potential for wind turbines to contribute significantly to songbird losses during migration may increase with increased wind turbine development. The Water Treatment Plant Site and adjacent areas lack suitable stopover habitat to attract large numbers of migratory songbirds (most of which occur in mature and early successional forests) close to the location of the turbines. Moreover, because the turbines would not be tall enough to require obstruction lighting, this would also minimize the likelihood that migrating songbirds would occur near the proposed turbines. Therefore, migratory songbirds are expected to be at low risk for collisions with wind turbines at the Water Treatment Plant Site. • Grassland Birds: Former landfills can provide breeding and overwintering habitat for grassland birds. While many grassland birds, such as sparrow species, have been documented colliding with wind turbines, these collisions have been a low frequency relative to other birds (e.g., Smallwood and Karas 2009). Collision mortality overall is often low in grassland habitats (Drewitt and Langston 2008). Grassland birds generally appear to be sensitive to the presence of turbines and avoid getting too close (Johnson and Stephens 2011), which may explain why they seldom collide with turbines. A notable exception is the horned lark, a New York State Species of Special Concern, which commonly collides with wind turbines (Young et al. 1999, Smallwood et al. 2009, Smallwood and Karas 2009, Johnson and Stephens 2011) possibly due to their elaborate aerial courtship displays during the breeding season (Drewitt and Langston 2008). Horned larks have the potential to occur near the Water Treatment Plant Site at the Haverstraw Landfill during the winter but would not be expected to breed near the Site. Outside of the breeding season, when aerial courtship displays do not occur, horned larks are not at an increased risk of colliding with turbines. • Birds of Prey: Generally, birds of prey and other large-bodied species collide with turbines at greater frequency relative to their abundance than smaller birds (although absolute

18B-27 Haverstraw Water Supply Project DEIS

numbers of songbird fatalities are generally highest) (Drewitt and Langston 2008, Johnson and Stephens 2011). It is likely the flight behaviors of birds of prey, such as riding hillside and ridgeline updrafts in the very same windy areas where wind farms are often located, that place them at increased risk of collisions relative to other bird groups (Hoover and Morrison 2005, Smallwood et al. 2009). Ridgelines and hillsides, in particular, are popular locations for wind turbines, and birds of prey often concentrate near such areas to use deflection updrafts to gain soaring altitude. Losses of individual raptors due to collision with turbines has the potential to adversely impact populations of species with observed mortality due to wind turbines because raptor species generally take longer to mature and reproduce (Drewitt and Langston 2008). The Water Treatment Plant Site lacks topographical features to create strong updrafts that would be attractive to migrating or foraging birds of prey. Nevertheless, many birds of prey are expected to occur in the vicinity of the Site, particularly on the landfill, and these are the birds at greatest risk for collisions with turbines at the Site. Birds of prey observed or likely to occur on the landfill either during winter, the breeding season, or migration include Northern harrier (New York State Threatened), sharp-shinned hawk (New York State Special Concern), Cooper’s hawk (New York State Special concern), red-tailed hawk, American kestrel, and peregrine falcon (New York State Endangered). (For more information on these species, see Chapter 9B, “Terrestrial Natural Resources.”) Although hunting and other flight behaviors of Northern harriers generally occur very close to the ground (Bildstein and Collopy 1985, Collopy and Bildstein 1987), harriers have frequently been observed passing through the rotor zones of wind turbines (Smallwood et al. 2009). Despite this, collisions of harriers with turbines are noticeably uncommon (Drewitt and Langston 2008, Smallwood and Karas 2009), and harriers occurring on the Haverstraw Landfill are not expected to be at high risk for collisions with the proposed turbines. In contrast, red-tailed hawks, American kestrels, Cooper’s hawks, and sharp-shinned hawks each appear to be somewhat common turbine strike victims (Hoover and Morrison 2005, Smallwood and Karas 2009, Johnson and Stephens 2011). Most of these birds would not be expected to occur close to wind turbines at the Water Treatment Plant Site and would have minimal risk for collision given the location of the turbines and their proximity to other areas of high human activity and disturbance. An exception is the red-tailed hawk, which is common in urban areas and tolerant of disturbance, and would have the potential to occur close to the wind turbines at the Water Treatment Plant Site. Therefore, this species would possibly be at greater risk for collisions with the proposed turbines than other birds of prey. Similarly, peregrine falcons are tolerant of high levels of human activity and may also be more likely to occur close to the Project Site than most other birds of prey. For reasons that are unclear, however, collisions of peregrine falcons with wind turbines are extremely rare (e.g., Smallwood and Karas 2009) despite their broad range across North America and Europe. Peregrine falcons would not be expected to be at high risk for collisions with the proposed turbines. Birds of prey that are not associated with grassland habitats but occur in the vicinity of the project area are the bald eagle (New York State Threatened) and osprey (New York State Special Concern). Both species would be at low risk for collisions with turbines at the Water Treatment Plant Site because there are no reported fatalities of these species at wind energy facilities in North America. However, it is possible that this is because wind turbines in the United States are not commonly located in the types of areas inhabited by these species, rather than these species being invulnerable to collisions. The bald eagle’s closest relative,

18B-28 Chapter 18B: Project Design Alternatives

the white-tailed fish eagle (Haliaeetus albicilla), is a common victim of wind turbine collisions in Europe, suggesting bald eagles could be prone to collisions with turbines if they mutually occurred (Drewitt and Langston 2008). NYSDEC’s guidance document for commercial-scale wind farms, Guidelines for Conducting Bird and Bat Studies at Commercial Wind Energy Projects (2009), recommends approaches to estimate and document bird and bat mortality due to collision with turbines and displacement from critical habitat. The document calls for pre- and post-construction analyses so that a state- wide database can be compiled regarding the effects of commercial wind projects on birds and bats. No specific guidance currently exists for smaller-scale projects. However, any wind power project with the potential to impact threatened or endangered species, or their critical habitat, may require an incidental take permit from NYSDEC in accordance with Article 11 of the ECL.

18B.3.2.1.5. Noise Effects Noise generated by wind turbines has caused community concern in a number of locations where turbines have been installed. Typically, a buffer of at least 1,200 feet is maintained between turbines and the nearest residence so as to address the noise concern. A screening-level noise analysis was performed to identify the potential for significant adverse noise impacts related to wind turbines at the Water Treatment Plant Site. The predicted noise levels due to the wind turbines were combined with the predicted noise levels due to the other equipment associated with the water treatment plant, as described in Chapter 13, “Noise.” The analysis of wind turbines focused on Site 1, the noise receptor on the east side of Benson Street near Adler Court, the closest residences to the Water Treatment Plant Site (for more information, see Chapter 13). The analysis considered the effects of eight turbines, each of which was assumed based on a review of manufacturers’ specifications to emit a sound power level (Lw) of 96.1 dBA. It also considered the attenuation due to the distance between the turbines and the receptor, and the attenuation provided by ground absorption. Accounting for these factors, the wind turbines are expected to result in an Leq(1) noise level of 59.8 dBA at Site 1.

This noise level would produce increases in Leq(1) noise levels at Site 1 of up to 10.3 dBA during the daytime and up to 23.1 dBA during the night. These increases would be substantially greater than the noise level increases predicted without the wind turbines, and substantially greater than NYSDEC’s 6 dBA impact guidance threshold (see Chapter 13 for more information on NYSDEC’s guidance for noise analyses). The total Leq(1) noise levels at Site 1 would be 61.7 dBA during the day and 61.3 dBA during the night, which are below NYSDEC’s recommended level of 65 dBA for a residential use. The total Ldn noise level at Site 1 with the wind turbines at the Water Treatment Plant Site would be 69.8 dBA, an increase in Ldn noise level of 4.2 dBA, which would be considered perceptible.

The only mitigation with the potential to decrease the significant increases in Leq(1) noise level resulting from the wind turbines at the Water Treatment Plant Site would be to relocate the turbines farther to the east, to increase the distance between the turbines and the receptors on Benson Street. However, as shown in Figure 18B-4, there is no space to shift the receptors eastward. Consequently, the proposed wind turbines would result in a significant adverse noise impact during the daytime and nighttime.

18B-29 Haverstraw Water Supply Project DEIS

18B.3.2.2. OFF-SITE WIND POWER—WIND TURBINE AT LAKE DEFOREST

18B.3.2.2.1. Description of Alternative As noted above, wind turbines are most effective when they are several hundred feet above the ground, where the wind is faster and less turbulent. Large wind turbines consist of a tall mast with two to three blades mounted to a unit, called a nacelle, at the top of the mast. This type of turbine can have capacities of between 0.5 MW and 3 MW or higher, depending on the mast height, rotor (blade) size, and wind speeds where it is placed. United Water is exploring the possibility of placing a wind turbine rated for 2.5 MW on the small island at the southern end of Lake DeForest. This turbine would be approximately 410 feet tall, with a 290-foot-tall mast and 120-foot-tall blades. Figure 18B-9 shows the potential location of a wind turbine in Lake DeForest. The location in Lake DeForest would provide an adequate buffer in the unlikely event that the turbine fell. The amount of energy that can be generated by a wind turbine depends not only on its rating, but also on the winds at its location. Based on the New York State wind map published by the U.S. Department of Energy, National Renewable Energy Laboratory, the annual average wind speed at 80 meters (264 feet) is expected to be 6.05 meters per second at Lake DeForest (latitude 41° 6’ 17”, longitude 73° 58’ 11”).1 Accounting for the variability in wind speed at Lake DeForest, a 22 to 24 percent capacity factor is likely to be achieved, which accounts for those times when no wind is blowing as well as the various speeds of wind. For a 2 MW wind turbine, a 22 percent utilization factor results in annual generation of 3,854 MWh. As shown in Table 18B-3, production of 3,854 MWh per year on average by a large wind turbine would be equivalent to 21 to 22 percent of the predicted average annual energy consumption (depending on future salinity levels) of the Proposed Project at full build-out. Only one wind turbine could be constructed at Lake DeForest, because of the small size of the island on which it would be constructed and because of the need to comply with O&R’s tariff rules related to the maximum amount of distributed generation that can be provided (see section 18B.3.1.2 above), since the power at this wind turbine would be fed into the O&R grid and would be considered distributed generation. Table 18B-3 Energy Demand of the Proposed Project vs. Energy Generated by Wind Turbine With Current Water Quality With Climate Change Proposed Project Average Annual Energy Demand 17,400 MWh 18,300 MWh Wind Turbine Output Energy Produced 3,854 MWh 3,854 MWh Energy Produced as a Percent of Project’s Average Annual Energy Demand 22% 21%

1 http://www.windpoweringamerica.gov/wind_resource_maps.asp?stateab=ny

18B-30 UNITED WATER Haverstraw Water Supply Project 7.12.11 Potential Locationof410-FootTall Wind Turbine DeForest inLake DeForest Lake Wind Turbine inLakeDeForest Potential Locationof 0 SCALE 1 Figure 18B-9 2 MILES Chapter 18B: Project Design Alternatives

18B.3.2.2.2. Effects on Greenhouse Gas Emissions With the production of up to 3,854 MWh per year on average, a 2.5 MW wind turbine in Lake DeForest would reduce the amount of greenhouse gases emitted by the Proposed Project by some 19 percent.

18B.3.2.2.3. Visual Effects With a mast height of 290 feet and rotor diameter of 240 feet (for a total height of 410 feet), the new wind turbine under this alternative would be visible from many locations around Lake DeForest. The mast of this size turbine would be approximately 13 feet wide at the bottom, tapering to approximately 8 feet wide at the top, so that it would be visible from a distance away. Figure 18B-10 shows the estimated viewshed for a wind turbine located on the island in Lake DeForest. As shown in the figure, the viewshed includes much of the area within five miles of the turbine location, to the extent views are not blocked by intervening vegetation or structures. Key locations from which the turbine would be visible would include: • Any location from which the water of Lake DeForest is visible, including the roads around the reservoir and the two causeways that cross the reservoir at the north end. • High points with views toward the lake, including the parks around the lake that are part of the Palisades Mountains—High Tor State Park, South Mountain County Park, Hook Mountain State Park, Rockland Lake State Park, and Blauvelt State Park—as well as Mountainview Nature Park in Nyack and Congers Lake Memorial Park in Congers. From farther away, such as from Bear Mountain State Park and Harriman State Park (which are part of a designated SASS), views of the wind turbine may be possible but because of the distance between the parks and the turbine location (approximately 10 miles at the closest point to Harriman State Park and 15 miles at the closest point to Bear Mountain State Park), the turbine would be quite small. From most locations in the Hudson River, views of the wind turbine would be blocked by the rise of the Palisades Mountains, but some views may be available from across the river in Tarrytown and Croton-on-Hudson. From any of these locations, a view of a large wind turbine would be incongruous and inconsistent with the surrounding visual setting. These views are generally of the natural landscape, open water, and wooded hills, with few large-scale structures visible. NYSDEC’s guidance on performing visual assessments (DEP-00-2, “Assessing and Mitigating Visual Impacts,” July 31, 2000) defines significant adverse visual impacts as follows: “Aesthetic impact occurs when there is a detrimental effect on the perceived beauty of a place or structure. Significant aesthetic impacts are those that may cause a diminishment of the public enjoyment and appreciation of an inventoried resource, or one that impairs the character or quality of such a place.”1 DEP-00-2 also provides additional guidance with respect to the definition of an aesthetic impact: “Mere visibility, even startling visibility of a project proposal, should not be a threshold for decision making. Instead a project, by virtue of its visibility, must clearly interfere with or reduce the public’s enjoyment and/or appreciation of the appearance of an inventoried resource.”2

1 DEP-00-2, “Assessing and Mitigating Visual Impacts,” July 31, 2000, p. 5. Accessible at www.dec.ny.gov/ docs/ permits_ej_operations_pdf/visual2000.pdf. 2 DEP-00-2, p. 9.

18B-31 UNITED WATER Haverstraw Water Supply Project 7.12.11 Viewshed forWind Turbine Potential 410-FootTall Wind Turbine inLakeDeforest Viewshed Analysis forPotential Wind Turbine inLakeDeForest 0 SCALE Figure 18B-10 1 2 MILES Haverstraw Water Supply Project DEIS

Depending on the specific location affected, the addition of a large wind turbine at Lake DeForest may cause changes to the natural visual landscape that reduce the public’s enjoyment of that landscape, and therefore may result in significant adverse visual impacts. 18B.3.2.2.4. Effects on Natural Resources In contrast to the small wind turbines on the Water Treatment Plant Site, a large turbine at Lake DeForest has the potential to represent a significant collision hazard to birds and bats due to its height and the habitat characteristics of the lake shoreline. Several studies have shown bat mortality from wind turbines to be strongly related to turbine height (Barclay et al. 2007, Arnett et al. 2008, Baerwald and Barclay 2009). At 410 feet, the turbine in Lake DeForest would be well above the height at which turbines often lead to significant bat fatalities (200 feet). In addition, turbines of this height require nighttime obstruction lighting, which would further increase collision potential by attracting birds and bats towards the turbine (Horn et al. 2008, Cryan and Barclay 2009, Gehring et al. 2009, Rydell et al. 2010a). Bird and bat fatalities at wind farms are a strong function of the abundance of birds and bats in the surrounding area. The shorter turbines being considered for the Water Treatment Plant Site would be distant from quality bird and bat habitat, and thus bird and bat activity in the vicinity of those turbines would be expected to be limited. The location of the potential turbine in Lake DeForest, however, is likely to have high levels of bird and bat activity. Lake DeForest is likely utilized by numerous groups of birds including waterfowl, osprey, and waterbirds such as herons and egrets. In addition, the riparian habitat surrounding the lake is likely to be attractive stopover habitat for numerous species of migratory landbirds passing through the area during spring and autumn. Non-breeding bald eagles occurring along the nearby Hudson River may also use the lake for foraging whenever it is not frozen. Each of these birds would be at risk of colliding with a turbine located within Lake DeForest. Therefore, the wind turbine at Lake DeForest would have the potential to result in significant adverse impacts to certain species of birds. Most bat species that occur in the Rockland County vicinity during migration and/or the breeding season are insectivorous. Fresh water bodies such as lakes are often areas of high bat activity, as bats forage for insects over the open water. Foraging activity is particularly high during late summer and autumn, and in turn, bat mortality at wind turbines peaks substantially during these periods (Kunz et al. 2007, Arnett et al. 2008, Cryan and Barclay 2009, Rydell 2010b, Jain et al. 2011). A wind turbine located within Lake DeForest would likely present a significant hazard to bats, particularly the hoary bat, eastern red bat, silver-haired bat, and eastern pipistrelle, which are the species most commonly killed by turbines in the northeastern United States (Arnett et al. 2008). Therefore, the wind turbine at Lake DeForest would have the potential to result in significant adverse impacts to bats. As noted above, NYSDEC’s guidance document for commercial-scale wind farms, Guidelines for Conducting Bird and Bat Studies at Commercial Wind Energy Projects (2009), recommends approaches to estimate and document bird and bat mortality due to collision with turbines and displacement from critical habitat. The document calls for pre- and post-construction analyses so that a state-wide database can be compiled regarding the effects of commercial wind projects on birds and bats. Although no specific guidance currently exists for single-turbine projects, any wind power project with the potential to impact threatened or endangered species, or their critical habitat, may require an incidental take permit from NYSDEC in accordance with Article 11 of the ECL.

18B-32 Chapter 18B: Project Design Alternatives

18B.3.2.2.5. Noise Effects As noted earlier, noise generated by wind turbines has caused community concern in a number of locations where turbines have been installed. A screening-level noise analysis was performed in order to determine whether a 2.5 MW wind turbine at Lake DeForest would have the potential to result in significant noise impacts at nearby sensitive receptors. The analysis of the wind turbine focused on residences on the east side of Lake DeForest along Old Mill Road in Valley Cottage, which are the closest residences to the potential site of the turbine on the island in the reservoir. While existing noise levels were not measured at any of these residences, the nearest residence is assumed to have similar baseline noise levels to those of Site 2 described in Chapter 13, “Noise,” which is located at the corner of Ecology Lane and River Road. This assumption was made because both sites have similar proximity to a freight rail line (the same rail line that passes through West Haverstraw adjacent to the Water Treatment Plant Site) and to local streets rather than major highways. The analysis considered the effects of a single turbine, which was assumed based on a review of manufacturers’ specifications to emit a sound power level (Lw) of 109.0 dBA. The analysis also considered the attenuation due to the distance between the turbine and the receptor (1,440 feet), and the attenuation provided by ground absorption. Taking into consideration these factors, the wind turbine in Like DeForest would be expected to result in an Leq(1) noise level of 58.4 dBA at the nearest residence.

This noise level would produce increases in Leq(1) noise levels at the Old Mill Road receptor location of up to 1.8 dBA during the daytime and up to 12.4 dBA during the night. The predicted increase during the nighttime would be substantially greater than NYSDEC’s 6 dBA impact guidance threshold. The total Leq(1) noise levels at Old Mill Road would be 64.5 dBA during the day and 60.1 dBA during the night, which are below NYSDEC’s recommended level of 65 dBA for a residential use. The total Ldn noise level at Old Mill Road would be 69.3 dBA, an increase in Ldn noise level of only 3.0 dBA, which would be considered barely perceptible.

The only mitigation with the potential to decrease the significant increase in Leq(1) nighttime noise level resulting from the wind turbine would be to relocate the turbine farther from the residences, such that there would be a sufficient buffer area between the turbine and residences to attenuate the noise levels produced by the turbine. This is not practical or feasible, since the turbine would be on a small island in the reservoir. Consequently, the wind turbine in Lake DeForest would result in a significant adverse noise impact during nighttime hours.

18B.3.2.2.6. Construction Impacts Installation of a wind turbine in Lake DeForest would have to be managed carefully, to avoid adverse effects to water quality of this important water supply source. A wind turbine in Lake Deforest could be sited either on the existing island, or at a location in the water, preferably north (upstream) of the Lake DeForest water intake location. Under either scenario, the construction requirements would be similar. A designated work zone within the reservoir would be surrounded by silt curtains to control turbidity and protect the water quality of the reservoir. The foundation requirements for a wind turbine are substantial, and would require excavation, and whether located on the island or in an open water site, the excavation would require the placement of a cofferdam within which the excavation and foundation construction would occur. The cofferdam would extend above the water surface and the work would be performed from barges. Excavated material would be removed from the construction site by barge, and

18B-33 Haverstraw Water Supply Project DEIS transported to the shore of the reservoir for off-site disposal. Dewatering operations at the excavation area would require that water be treated with filters to control the discharge of any sediment. The work zone would also include booms to contain any floatable material and as a safety precaution against any accidental spills of oils. Access to the work zone would be by boat.

18B.3.2.3. ON-SITE SOLAR POWER

18B.3.2.3.1. Description of Alternative United Water is evaluating the use of solar photovoltaic systems on the water treatment plant buildings and intake pumping station building. Solar photovoltaic systems use flat panels that produce electricity directly from sunlight. The amount of solar energy available varies from day to day and season to season, and therefore the amount of power generated from the solar photovoltaic panels would also vary. If the entire roof area of the water treatment plant and intake pumping station were used, up to 35,000 square feet of space could be occupied by solar panels. Assuming the use of the most common solar photovoltaic panels, which are monocrystalline silicon panels, fixed in place, this would produce up to 328 MWh per year on average, which is less than 2 percent of the Project’s estimated maximum annual energy demand at full build-out (7.5 mgd). United Water is also evaluating installation of free-standing solar photovoltaic panels on the southern portion of the Water Treatment Plant Site (the DSB property). If 2.5 acres of the 5-acre site were filled with solar photovoltaic panels, this would produce up to 1,032 MWh per year on average, or 5.6 to 5.9 percent of the Project’s predicted average annual energy demand at full build-out. The panels would face south, with the panels tilted at a fixed 35-degree angle to maximize exposure to the sun.

18B.3.2.3.2. Potential Environmental Impacts Associated with On-Site Solar Power Solar photovoltaic panels mounted on the roof of the water treatment plant would not result in any significant adverse environmental impacts. These panels would not be readily visible from off-site areas, particularly given the buffered location of the Water Treatment Plant Site. To the extent that solar power generated at the Project Sites can offset some of the Project’s energy demand, this would have a positive effect in terms of greenhouse gases. However, ground-mounted panels at the DSB property have some potential environmental effects, as follows: • Visual effects. Solar photovoltaic panels mounted on the ground would be visible from locations in the immediate vicinity and could result in adverse visual impacts, particularly for the residential neighborhood immediately to the south of the property on North Wayne Avenue. This would not result in adverse effects on any of the visual resources evaluated for the Proposed Project in Chapter 4, but would change the character of the area in immediate proximity to the Water Treatment Plant Site. • Effects on natural resources. The DSB property currently has a small drainage channel and small wetland area near its southwest corner. Depending on the layout of the solar panels, these wetland areas could be affected. In addition, approximately two acres of this portion of the Water Treatment Plant Site is currently wooded and would have to be cleared to facilitate development with solar panels.

18B-34 Chapter 18B: Project Design Alternatives

18B.3.2.4. OFF-SITE RENEWABLE ENERGY ALTERNATIVES Other potential options for producing renewable energy that would partially offset the Proposed Project’s energy demand include wind turbines or solar photovoltaic panels elsewhere in Rockland County. These could either produce power that is sold back to O&R, subject to O&R’s tariff limits for its distribution system (discussed earlier in this section), or they could be used to produce power used only by United Water in its own operations. Development of wind turbines or solar panels at locations away from the Project Sites elsewhere in Rockland County would raise the same environmental issues as those on the Project Sites or at Lake DeForest, described above. In addition, depending on the sites selected, other environmental issues could also be a concern. These projects would be subject to their own environmental review under SEQRA. Alternatively, United Water could take equity in an off-site wind farm project being constructed elsewhere that would feed power into the grid to offset the energy demand of the Proposed Project. As of August 2010, there are 47 commercial wind farms projects under development in New York State—generally in rural areas in the northern or western parts of the state—that have made the necessary application to the New York Independent System Operator for connection to the grid. However, as a waterworks corporation regulated by the PSC, United Water could not use its operating revenues to invest in a wind energy project without first obtaining the consent and approval of the PSC, and the PSC could also prohibit United Water from recouping the cost of any such investment in rates.1 Finally, United Water could also purchase energy from a renewable energy provider. For example, O&R and its parent company, Consolidated Edison, offer a renewable energy option to commercial customers that can include wind power or hydro power. However, given that these renewable energy options cost more than the standard energy provided by O&R, extensive use of renewable energy by United Water could result in increases to customer rates. United Water could not purchase energy from a renewable energy provider without first obtaining the consent and approval of the PSC.2

18B.3.2.5. OTHER RENEWABLE ENERGY ALTERNATIVES CONSIDERED BUT NOT ADVANCED A number of other renewable energy options were also considered during development of this alternative but found to be infeasible. These included the following: • Hydropower: The possibility of using a submerged river turbine in the Hudson River close to the water intake was evaluated, but the current strength in the area (approximately 1 knot) is not large enough to support this technology, which requires 3 to 4 knots or greater. The possibility of using hydropower at other United Water facilities to generate power was also considered. This included hydropower at the Lake DeForest Dam, at the Letchworth Reservoirs, and in the Ramapo River at the weir near O&R’s substation number 17 (near Suffern). However, each of these options was found to be infeasible or impracticable, and capable of producing only a small amount of power on a reliable basis.

1 See New York Public Service Law §§ 89-b, 107. 2 See, e.g., Cases 28896, 28897, 28898 – Proceeding of Rochester Gas and Electric Corp., Recommended Decision, 1985 WL 25821,*19, 25 N.Y.P.S.C. 2867 (NYSPSC Apr. 11, 1985) (regulated utilities “should, of course, be required to minimize costs that ratepayers must bear…”).

18B-35 Haverstraw Water Supply Project DEIS

• Gas from Landfill: The Town of Haverstraw Landfill began operation in the 1970s and was closed in 1996. A landfill’s gas production significantly declines after the first 10 years of closure. Although there is limited information available on gas production for the landfill, sampling of gas monitoring wells at the landfill has indicated low to no methane gas being emitted. Based on the sampling data, the methane concentrations being produced are not capable of supporting either a gas-fired generator or other gas-fired equipment. • Gas from Haverstraw Joint Regional Sewage Treatment Plant. Using methane emitted from the JRSTP is not currently feasible, because the sewage treatment plant does not have digesters that produce methane. While the JRSTP has put in an application for funding to design and construct anaerobic digesters, it is unknown when or if the funding would become available and when or if digesters would be in operation. If anaerobic digesters were constructed, they would produce methane. Typically, the methane produced by the digester is used to reheat the recycled sludge within the digester to maintain a temperature of 95 degrees Fahrenheit, which allows the digester to operate properly. Based on the future sludge production of approximately 6,887 pounds per day at an average flow of 8 mgd at the JRSTP, it is estimated that approximately 38,500 cubic feet of digester gas would be produced. During the colder months of the year, approximately 37,800 cubic feet of gas would be used to heat the sludge to allow the digester to operate properly. During the warmer months, the amount of gas required for heating is reduced. To use excess digester gas for heating of buildings, there must be a constant flow of gas. Because of the limited amount of excess gas that would be available from the JRSTP digesters for approximately six months a year, the use of digester gas for heating at the Proposed Project is not considered feasible. Moreover, given the uncertainty of the timing of this option, it was not considered a feasible option for the Proposed Project.

18B.3.3. SUMMARY OF ALTERNATIVE ENERGY GENERATION Several potential alternative energy sources for the Proposed Project will be further evaluated as design advances. These include the following: • Small mast-mounted wind turbines at the Water Treatment Plant Site. These would produce a limited amount of power and would be subject to local wind conditions. • Potential 2.5 MW wind turbine in Lake DeForest, which would be capable of producing up to 3,854 MWh per year on average, which is approximately 21 to 22 percent (depending on future salinity levels) of the predicted average annual energy demand of the Proposed Project at full build-out (7.5 mgd). • Roof-mounted solar panels installed on the water treatment plant and intake pump station buildings. Based on available roof space, this could produce up to 328 MWh per year on average, which is less than 2 percent of the Project’s estimated maximum annual energy demand at full build-out. • Ground-level fixed solar panels installed over the DSB property. Using half the site, this could produce up to 1,032 MWh per year on average, which is equivalent to 7.4 to 7.8 percent of the Project’s predicted average annual energy demand at full build-out. • Purchase of energy from a renewable energy provider. To the extent that renewable energy can be used to offset some of the Proposed Project’s demand for energy from the grid, this would result in reductions to the greenhouse gas emissions associated with the Proposed Project. More information on the greenhouse gas reductions

18B-36 Chapter 18B: Project Design Alternatives associated with these renewable energy options is provided in Chapter 16 of this DEIS, “Global Climate Change,” section 16.6.

18B.4. ALTERNATIVE USES FOR BRINE AND WASTEWATER This alternative considers possible alternative uses for the wastewater, solid wastes, and brine produced by the proposed water treatment plant.

18B.4.1. WASTEWATER PRODUCED BY THE PROJECT As discussed in Chapter 2, “Project Description,” and Chapter 11, “Infrastructure and Energy,” the Proposed Project’s water treatment process would produce some wastewater (not including the brine produced by the reverse-osmosis (RO) process) every day that would be conveyed to the JRSTP for treatment. During daily operations, the water treatment process would produce wastewater from the routine backwashing of equipment and other routine operations. At full build-out (7.5 mgd production capacity), the Proposed Project would produce an average of 92,000 gallons per day (gpd) of wastewater discharge to the JRSTP in the maximum month. This would consist of an estimated 1,000 gpd of wastewater from sanitary flows and plant washdowns, 15,000 gpd of wastewater from the Clean-in-Place (CIP) neutralization tank if CIP operations on the microfiltration/ultrafiltration (MF/UF) and RO equipment occur at the same time, and 76,000 gpd of filtrate generated by the belt filter press of the solids processing system. These waste streams would include some pollutants removed from the raw water and some neutralized cleaning solutions from CIP operations. For this reason, conveying of the wastewater to the JRSTP for further treatment is appropriate. Potential alternative uses for wastewater produced by the plant could include reuse for irrigation, such as at local farms and nurseries or parks, and for industrial process or power plant cooling water. Any such reuse would be similar to the reuse of “gray water” analyzed in Chapter 18A of this DEIS in section 18A.5.2, “Wastewater and Stormwater Reuse Alternatives.” As discussed there, the wastewater would likely require a high level of treatment before it could be reused. It would also require additional infrastructure—whether trucks or piping—to transmit the wastewater to its destination and a destination where the end user was willing to accept and use the water. The volumes of wastewater anticipated to be produced by the Proposed Project are not large enough to warrant the additional investment required for further treatment and transportation to a reuse destination.

18B.4.2. SOLID WASTE PRODUCED BY THE PROJECT The Proposed Project’s water treatment process, like all water treatment plants, would also produce sludge, consisting of solids removed from the water and chemicals used to remove those pollutants. As discussed in Chapter 2, “Project Description” (section 2.4.6.1), the sludge would be thickened and dewatered at the Water Treatment Plant Site. The resulting sludge “cake” would be taken by truck to a landfill or licensed composting facility, similar to the way sludge from the Lake DeForest water treatment plant is handled today. This material may be suitable for recycling into compost at the landfill, depending on the concentration of soluble salts in the solid waste. As an alternative, thickened sludge from the water treatment process may be sent to the JRSTP for handling with the sludge produced by the JRSTP’s wastewater treatment process. In this case, the sludge would be combined with the JRSTP’s thickened sludge, dewatered, and trucked

18B-37 Haverstraw Water Supply Project DEIS to the Rockland County Solid Waste Management Authority’s co-composting facility. The Solid Waste Management Authority uses the sludge produced by the JRSTP as well as by the other wastewater treatment plants in Rockland and Orange Counties to produce compost, which is then redistributed to landscapers, municipalities, and residents for land applications. In this scenario, it is expected that the water treatment plant’s sludge in combination with the JRSTP’s sludge would be suitable for composting by the Rockland County Solid Waste Management Authority. For more information, see Chapter 11, “Infrastructure and Energy,” section 11.4.5. Thus, in either case, sludge from the Project may be recycled through composting. In the event that the sludge is not suitable for use in composting, no other alternative uses for the solid waste produced by the Project have been identified.

18B.4.3. BRINE PRODUCED BY THE PROJECT As discussed in Chapter 2, “Project Description,” the water treatment plant’s desalination function would remove salts from the water during treatment. At full build-out, when the plant is producing 7.5 mgd of potable water, the treatment process would produce an estimated 1.4 mgd of reverse-osmosis concentrate, or brine. The Project proposes to discharge the brine back to the Hudson River as part of the effluent stream discharged by the JRSTP. The combined effluent from the Proposed Project and the JRSTP would not substantially raise salinity levels at the discharge point (this is discussed in Chapter 9A, “Aquatic Natural Resources”). The brine is anticipated to have approximately 22,400 mg/L of total dissolved solids (TDS), comprised primarily of a mix of ions including calcium, magnesium, sodium, potassium, carbonate, bicarbonate, sulfate, chlorides, and nitrate. The total salt concentration is expected to be 2 to 3 percent and the total sodium concentration is expected to be 1.9 to 2.6 percent. The primary possible alternative use for the brine would be in road de-icing, although, as discussed below, this use is not feasible given the composition of the brine. Other possible alternative uses for the brine would be for irrigation or for generation of sodium hypochlorite (a chemical used in the water treatment process), but these alternative uses also would not be practicable for the Proposed Project for the reasons discussed below.

18B.4.3.1. ROAD DE-ICING One possible alternative use for brine would be as a solution to be used for road de-icing. If practicable, this alternative would only provide an alternative use during wintertime, and more specifically, during winter storm events. Brine produced at most times of the year—and particularly, during the summer, when water demand is greater and therefore water production and resultant brine production would also be greater—could not be used for this purpose. In Rockland County, responsibility for salting and snow plowing roads in response to winter storm events is divided between the State of New York, the county, and local municipalities, depending on which has maintenance responsibility and jurisdiction for the roadway. For example, in the Town of Haverstraw, the Town’s Highway Department is responsible for maintenance of most roadways, but the Rockland County Highway Department is responsible for Thiells Mount Ivy Road, Hammond Road, Suffern Lane, Central Highway, Willow Grove Road, and Call Hollow Road; and the State Department of Transportation is responsible for maintaining Route 202 and Route 9W. To determine the appropriateness of the brine from the Proposed Project as a de-icing agent, the Rockland County Highway Department’s de-icing practices were reviewed. Although practices

18B-38 Chapter 18B: Project Design Alternatives may vary among local municipalities, the county’s practices are considered representative of practices used throughout Rockland County. These practices are set forth in the Rockland County’s Snow and Ice Removal Policy, December 2002.1 Under its policy, Rockland County has established a set of standards to assure the application of environmentally sound practices for the use of de-icing chemicals. Prior to the onset of any precipitation, Rockland County pre-treats its road surfaces with anti-icing chemicals (pre- wetting agents) to prevent ice from forming on road surfaces, which in turn increases the effectiveness of road salt being applied later. All equipment is calibrated to assure the proper amount of chemicals and salt are applied. Throughout a storm event, the application of de- icing/salt is made on an as-needed basis. Rockland County currently uses Clearlane® Treated Salt, a granular sodium chloride treated with liquid magnesium chloride with organic-based performance enhancer, as its primary snow/ice control agent.2 Based on the manufacturer’s technical information sheet, this de-icing substance consists of 95.9 percent sodium chloride deicing salt and 4.1 percent pre-wetting agent. The freezing point for this type of rock salt substance is approximately 15 degrees Fahrenheit. In contrast, the brine from the Proposed Project is anticipated to have much lower salinity, with total salt concentration of approximately 2 to 3 percent. With such low salinity, the freezing point would be reduced by between 2 and 4 degrees (freezing point between 28 and 30 degrees Fahrenheit). Therefore, the brine would not be an effective de-icing agent and might instead contribute to additional ice formation. Moreover, typical road salt has less than 1 percent sulfate content, whereas the sulfate content from the brine produced by the Proposed Project is anticipated to be substantially higher. Sulfates add no benefit to the melting effect of road salt below very modest temperatures, and they are deleterious to cement and pavement. Therefore, for the brine effluent from the Proposed Project to be used as road salt for deicing, the sulfates would first have to be extracted. The brine solution could be transported to an off-site facility to be treated for this application; however, no such facility is currently known to exist in the area. Furthermore, the process required to remove the sulfates and concentrate the brine is very power-intensive.

18B.4.3.2. OTHER USES The brine produced by the water treatment plant could potentially be used as irrigation water for horticultural land, commercial crops, recreational spaces such as golf courses, or parks. However, the brine would need to be diluted with non-saline water to reduce its salinity to a level that could be tolerated by plants. For example, Bermuda grass is a relatively salt-tolerant turf species used in golf courses throughout the United States, and there are several golf courses in the water treatment plant area. The brine would most likely have to be pre-treated to remove potential pollutants present in the substance and it would have to be transported to the end user. This application would only be available seasonally, when irrigation is needed. Given the cost for pre-treatment and transport, and the dilution and water quality requirements, reuse of brine for irrigation is not considered practicable. Another potential use for the brine would be to produce sodium hypochlorite, a chemical used in the water treatment process, thereby eliminating the need for tanker truck deliveries of purchased

1 Available on the internet at: www.co.rockland.ny.us/Highway/construct.htm. 2 Source: NYSOGS Procurement Services Group.

18B-39 Haverstraw Water Supply Project DEIS commercial-grade sodium hypochlorite. However, this is not a recommended procedure by the manufacturer for on-site sodium hypochlorite generation equipment. The drawbacks with use of RO concentrate for this purpose include the fact that the brine is too dilute to be used for this purpose (as noted above, the RO concentrate would have a total dissolved solids concentration of approximately 2 to 3 percent, whereas onsite generation of sodium hypochlorite requires a saturated sodium chloride solution of 26 percent). Therefore, additional salt would have to be added through the use of a brine saturator. In addition, the RO concentrate will contain concentrated salts and other constituents that can foul the on-site generation electrolytic cells and can produce disinfection byproducts. Moreover, this procedure would be more costly than either onsite hypochlorite generation using food grade salt or purchase of commercial-grade sodium hypochlorite off-site. In addition, the amount of saturated brine solution required for onsite hypochlorite generation for the Proposed Project is much smaller than the amount of RO concentrate that would be produced by the water treatment plant, so disposal of excess brine would still be required.

18B.5. REFERENCES Arnett, E.B., K. Brown, W.P. Erickson, J. Fiedler, T.H. Henry, G.D. Johnson, J. Kerns, R.R. Kolford, C.P. Nicholson, T. O’Connell, M. Piorkowski, and J.R. Tankersly. 2008. Patterns of fatality of bats at wind energy facilities in North America. Journal of Wildlife Management 72:61–78. Arnett, E.B., M.P. Huso, M.R. Schirmacher, J.P. Hayes. 2011. Altering turbine speed reduces bat mortality at wind-energy facilities. Frontiers in Ecology and the Environment 9: 209-214. Baerwald, E.F., G.H. D’Amours, B.J. Klug, R.M. Barclay. 2008. Barotrauma is a significant cause of bat fatalities at wind turbines. Current Biology 18:695-696. Baerwald, E.F. and R.M. Barclay. 2009. Geographic variation in activity and fatality of migratory bats at wind energy facilities. Journal of Mammalogy 90:1341-1349. Baerwald, E.F., J. Edworthy, M. Holder, R.M. Barclay. 2009. A large-scale mitigation experiment to reduce bat fatalities at wind energy facilities. Journal of Wildlife Management 73:1077–1081. Barclay, R.M., E.F. Baerwald, and J.C. Gruver. 2007. Variation in bat and bird fatalities at wind energy facilities: assessing the effects of rotor size and tower height. Canadian Journal of Zoology 85:381–387. Collopy, M.W. and K.L. Bildstein. 1987. Foraging behaviors of northern harriers wintering in southeastern salt and freshwater marshes. Auk 104:11-16. Cryan, P.M. and R.M. Barclay. 2009. Causes of bat fatalities at wind turbines: hypotheses and predictions. Journal of Mammalogy 90:1130-1340. Drewitt, A.L. and H.W. Langston. 2008. Collision effects of wind-power generators and other obstacles on birds. Annals of the New York Academy of Sciences 1134: 233-266. Gehring, J.L., P. Kerlinger, A.M. Manville II. 2009. Communication towers, lights, and birds: successful methods of reducing the frequency of avian collisions. Ecological Applications 19: 505-514.

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Hoover, S.L. and M.L. Morrison. 2005. Behavior of red-tailed hawks in a wind turbine development. Journal of Wildlife Management 69:150-159. Horn, J.W., E.B. Arnett, T.H. Kunz. 2008. Behavioral responses of bats to operating wind turbines. Journal of Wildlife Management 72:123-132. Jain, A.A., R.R. Koford, A.W. Hancock, G.G. Zenner. 2011. Bat mortality and activity at a northern Iowa wind resource area. American Midland Naturalist 165:185-200. Johnson, G.D. 2005. A review of bat mortality at wind energy developments in the United States. Bat Research News 46:45-49. Johnson, G.D. and S.E. Stephens. 2011. Wind power and biofuels: a green dilemma for wildlife conservation. Pp 131-155 in: Energy development and wildlife conservation in western North America. David E. Naugle, Ed. Island Press, Washington DC. Kerlinger, P., J.L. Gehring, W.P. Erickson, R. Curry, A. Jain, and J. Guarnaccia. 2010. Night migrant fatalities and obstruction lighting at wind turbines in North America. Wilson Journal of Ornithology 122:744-754. Kunz, T.H., E.B. Arnett, W.P. Erickson, A.R. Hoar, G.D. Johnson, R.P. Larkin, M.D. Strickland, R.W. Thresher, and M.D. Tuttle. 2007. Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses. Frontiers in Ecology and the Environment 5:315–324. Leddy, K.L., K.F. Higgins, D.E. Naugle. 1999. Effects of wind turbines on upland nesting birds in conservation reserve program grasslands. Wilson Bulletin 111:100-104. Madders, M. and D.P. Whitfield. 2006. Upland raptors and the assessment of wind farm impacts. Ibis 148:43-56. Martin, G.R. 2011. Understanding bird collisions with man-made objects: a sensory ecology approach. Ibis 153:239-254. Rydell, J., L. Bach, M. Dubourg-Savage, M. Green, L. Rodriguez, A. Hedenstrom. 2010a. Mortality of bats at wind turbines: links to nocturnal insect migration? European Journal of Wildlife Research 56:823-827. Rydell, J., L. Bach, M. Dubourg-Savage, M. Green, L. Rodriguez, A. Hedenstrom. 2010b. Bat mortality at wind turbines in northwest Europe. Acta Chiropterologica 12:261-274. Sillet,T.S. and R.T.Holmes. 2002. Variation in survivorship of a migratory songbird throughout its annual cycle. Journal of Animal Ecology 71: 296-308. Smallwood, S.K. and B. Karas. 2009. Avian and bat fatality rates at old-generation and repowered wind turbines in California. Journal of Wildlife Management 73:1062-1071. Smallwood, S.K., L. Rugge, M.L. Morrison. 2009. Influence of behavior on bird mortality in wind energy developments. Journal of Wildlife Management 73:1082-1098. Wind Turbine Guidelines Advisory Committee. 2010. Wind Turbine Guidelines Advisory Committee Recommendations submitted to Department of the Interior, March 4, 2010. 

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