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TM City Environmental Quality Review ENVIRONMENTAL ASSESSMENT STATEMENT SHORT FORM ● FOR UNLISTED ACTIONS ONLY Please fill out, print and submit to the appropriate agency (see instructions)

PART I: GENERAL INFORMATION 1. Does Action Exceed Any Type I Threshold In 6 NYCRR Part 617.4 or 43 RCNY §6-15(A) (Executive Order 91 of 1977, as amended)? ✔ Yes No If yes, STOP, and complete the FULL EAS

2. Project Name Community Wildfire Protection Plan for the Eastern Shore of 3. Reference Numbers

CEQR REFERENCE NUMBER (To Be Assigned by Lead Agency) BSA REFERENCE NUMBER (If Applicable) 13DPR003R

ULURP REFERENCE NUMBER (If Applicable)) OTHER REFERENCE NUMBER(S) (If Applicable) (e.g. Legislative Intro, CAPA, etc)

4a. Lead Agency Information 4b. Applicant Information NAME OF LEAD AGENCY NAME OF APPLICANT City Department of Parks and Recreation

NAME OF LEAD AGENCY CONTACT PERSON NAME OF APPLICANT’S REPRESENTATIVE OR CONTACT PERSON Joshua Laird ADDRESS 830 Fifth Avenue, Room 401 ADDRESS

CITY New York STATENY ZIP10065 CITY STATE ZIP TELEPHONE 212-360-3402 FAX212-360-3453 TELEPHONE FAX

EMAIL ADDRESS [email protected] EMAIL ADDRESS 5. Project Description: The Department of Parks and Recreation, in partnership with other City, State, and Federal agencies and elected officials on Staten Island, which include the New York City Department of Environmental Protection (DEP), the New York City Fire Department (FDNY), the New York State Department of Environmental Conservation (DEC), the (NPS), and the Staten Island Borough President’s Office, have drafted a Community Wildfire Protection Plan (CWPP) to provide a list of prioritized recommendations and best practices to combat and prevent the prevalence of urban wildfires that occur on the Eastern Shore of Staten Island within the geographically defined boundaries of the CWPP. Please see Attachment A.

6a. Project Location: Single Site (for a project at a single site, complete all the information below)

ADDRESS NEIGHBORHOOD NAME

TAX BLOCK AND LOT BOROUGH COMMUNITY DISTRICT

DESCRIPTION OF PROPERTY BY BOUNDING OR CROSS STREETS

EXISTING ZONING DISTRICT, INCLUDING SPECIAL ZONING DISTRICT DESIGNATION IF ANY: ZONING SECTIONAL MAP NO:

6b. Project Location: Multiple Sites (Provide a description of the size of the project area in both City Blocks and Lots. If the project would apply to the entire city or to areas that are so extensive that a site-specific description is not appropriate or practicable, describe the area of the project, including bounding streets, etc.) The area within the South Shore of Staten Island bounded between and Raritan Bay, from north to .

7. REQUIRED ACTIONS OR APPROVALS (check all that apply) ✔ : ✔ City Planning Commission: YES NO Board of Standards and Appeals YES NO

CITY MAP AMENDMENT ZONING CERTIFICATION SPECIAL PERMIT

EXPIRATION DATE MONTH DAY YEAR ZONING MAP AMENDMENT ZONING AUTHORIZATION

ZONING TEXT AMENDMENT HOUSING PLAN & PROJECT

UNIFORM LAND USE REVIEW SITE SELECTION — PUBLIC FACILITY VARIANCE (USE) PROCEDURE (ULURP)

CONCESSION FRANCHISE

UDAAP DISPOSITION — REAL PROPERTY VARIANCE (BULK)

REVOCABLE CONSENT

ZONING SPECIAL PERMIT, SPECIFY TYPE: SPECIFY AFFECTED SECTION(S) OF THE ZONING RESOLUTION

MODIFICATION OF

RENEWAL OF

OTHER EAS SHORT FORM PAGE 2

Department of Environmental Protection: YES NO ✔ IF YES, IDENTIFY:

: ✔ Other City Approvals YES NO

LEGISLATION RULEMAKING

FUNDING OF CONSTRUCTION; SPECIFY: CONSTRUCTION OF PUBLIC FACILITIES

POLICY OR PLAN; SPECIFY: FUNDING OF PROGRAMS; SPECIFY:

LANDMARKS PRESERVATION COMMISSION APPROVAL (not subject to CEQR) PERMITS; SPECIFY:

384(b)(4) APPROVAL OTHER; EXPLAIN FDNY and DEP review and approval of the CWPP.

PERMITS FROM DOT’S OFFICE OF CONSTRUCTION MITIGATION AND COORDINATION (OCMC) (not subject to CEQR)

✔ State or Federal Actions/Approvals/Funding: YES NO IF “YES,” IDENTIFY: The New York State Department of Environmental Conservation will review and provide agreement on the CWPP. DEC also provides regulatory approval for prescribed burns in New York State.

8. Site Description: Except where otherwise indicated, provide the following information with regard to the directly affected area. The directly affected area consists of the project site and the area subject to any change in regulatory controls. GRAPHICS The following graphics must be attached and each box must be checked off before the EAS is complete. Each map must clearly depict the boundaries of the directly affected area or areas and indicate a 400-foot radius drawn from the outer boundaries of the project site. Maps may not exceed 11×17 inches in size and must be folded to 8.5 ×11 inches for submission ✔ Site location map Zoning map Photographs of the project site taken within 6 months of EAS submission and keyed to the site location map ✔ Sanborn or other land use map Tax map For large areas or multiple sites, a GIS shape file that defines the project sites PHYSICAL SETTING (both developed and undeveloped areas)

Total directly affected area (sq. ft.): Type of Waterbody and surface area (sq. ft.): Roads, building and other paved surfaces (sq. ft.)

Other, describe (sq. ft.):

9. Physical Dimensions and Scale of Project (if the project affects multiple sites, provide the total development below facilitated by the action)

Size of project to be developed: (gross sq. ft.)

✔ Does the proposed project involve changes in zoning on one or more sites? YES NO

If ‘Yes,’ identify the total square feet owned or controlled by the applicant: Total square feet of non-applicant owned development:

✔ ✔ Does the proposed project involve in-ground excavation or subsurface disturbance, including but not limited to foundation work, pilings, utility lines, or grading? YES NO If ‘Yes,’ indicate the estimated area and volume dimensions of subsurface disturbance (if known): Please see Attachment A.

Area: sq. ft. (width × length) Volume: cubic feet (width × length × depth)

DESCRIPTION OF PROPOSED USES (please complete the following information as appropriate)

Residential Commercial Community Facility Industrial/Manufacturing Size (in gross sq. ft.) Type (e.g. retail, office, school) units

Number of additional Number of additional Does the proposed project increase the population of residents and/or on-site workers? YES NO ✔ residents? workers? Provide a brief explanation of how these numbers were determined:

✔ Does the project create new open space? YES NO if Yes (sq. ft)

Using Table 14-1, estimate the project’s projected operational solid waste generation, if applicable: N.A. (pounds per week)

Using energy modeling or Table 15-1, estimate the project’s projected energy use: N.A. (annual BTUs) ✔ Has a No-Action scenario been defined for this project that differs from the existing condition? YES NO If ‘Yes,’ see Chapter 2, “Establishing the Analysis Framework” and describe briefly: EAS SHORT FORM PAGE 3

10. Analysis Year CEQR Technical Manual Chapter 2

ANTICIPATED BUILD YEAR (DATE THE PROJECT WOULD BE COMPLETED AND OPERATIONAL): xxxxxxx?? ANTICIPATED PERIOD OF CONSTRUCTION IN MONTHS:

NO ✔ IF MULTIPLE PHASES, HOW MANY PHASES: WOULD THE PROJECT BE IMPLEMENTED IN A SINGLE PHASE? YES Dependent on funding

BRIEFLY DESCRIBE PHASES AND CONSTRUCTION SCHEDULE:

11. What is the Predominant Land Use in Vicinity of Project? (Check all that apply) Please see page 1a for project description. ✔ ✔ ✔ ✔ Community facilities RESIDENTIAL MANUFACTURING COMMERCIAL PARK/FOREST/OPEN SPACE OTHER, Describe:

PART II: TECHNICAL ANALYSES

INSTRUCTIONS: The questions in the following table refer to the thresholds for each analysis area in the respective chapter of the CEQR Technical Manual. • If the proposed project can be demonstrated not to meet or exceed the threshold, check the ‘NO’ box. • If the proposed project will meet or exceed the threshold, or if this cannot be determined, check the ‘YES’ box. • Often, a ‘Yes’ answer will result in a preliminary analysis to determine whether further analysis is needed. For each ‘Yes’ response, consult the relevant chapter of the CEQR Technical Manual for guidance on providing additional analyses (and attach supporting information, if needed) to determine whether detailed analysis is needed. Please note that a ‘Yes’ answer does not mean that an EIS must be prepared—it often only means that more information is required for the lead agency to make a determination of significance. • The lead agency, upon reviewing Part II, may require an applicant either to provide additional information to support this Short EAS Form or complete a Full EAS Form. For example, if a question is answered ‘No,’ an agency may request a short explanation for this response. In addition, if a large number of the questions are marked ‘Yes,’ the lead agency may determine that it is appropriate to require completion of the Full EAS Form. YES NO

1. LAND USE, ZONING AND PUBLIC POLICY: CEQR Technical Manual Chapter 4

(a) Would the proposed project result in a change in land use or zoning that is different from surrounding land uses and/or zoning? ✔ Is there the potential to affect an applicable public policy? If “Yes”, complete a preliminary assessment and attach. (b) Is the project a large, publicly sponsored project? If “Yes”, complete a PlaNYC assessment and attach.See Attachment B ✔ (c) Is any part of the directly affected area within the City’s Waterfront Revitalization Program boundaries? ✔ If “Yes”, complete the Consistency Assessment Form. See Attachment B. 2. SOCIOECONOMIC CONDITIONS: CEQR Technical Manual Chapter 5 (a) Would the proposed project:

• Generate a net increase of 200 or more residential units? ✔

• Generate a net increase of 200,000 or more square feet of commercial space? ✔

• Directly displace more than 500 residents? ✔

• Directly displace more than 100 employees? ✔

• Affect conditions in a specific industry? ✔

3. COMMUNITY FACILITIES: CEQR Technical Manual Chapter 6 ✔ (a) Does the proposed project exceed any of the thresholds outlined in Table 6-1 of Chapter 6?

4. OPEN SPACE: CEQR Technical Manual Chapter 7 ✔ (a) Would the proposed project change or eliminate existing open space?

(b) Is the proposed project within an underserved area in , , , , or Staten Island? If “Yes,” would the proposed project generate 50 or more additional residents? ✔ If “Yes,” would the proposed project generate 125 or more additional employees? (c) Is the proposed project in a well-served area in the Bronx, Brooklyn, Manhattan, Queens, or Staten Island? ✔ If “Yes,” would the proposed project generate 300 or more additional residents? ✔ If “Yes,” would the proposed project generate 750 or more additional employees? ✔ (d) If the proposed project is not located in an underserved or well-served area, would the proposed project generate: ✔ 200 or more additional residents? 500 additional employees? ✔ EAS SHORT FORM PAGE 4 YES NO

5. SHADOWS: CEQR Technical Manual Chapter 8 (a) Would the proposed project result in a net height increase of any structure of 50 feet or more? ✔

(b) Would the proposed project result in any increase in structure height and be located adjacent to or across the street from a ✔ sunlight-sensitive resource? 6. HISTORIC AND CULTURAL RESOURCES: CEQR Technical Manual Chapter 9 (a) Does the proposed project site or an adjacent site contain any architectural and/or archaeological resource that is eligible for, or ✔ has been designated (or is calendared for consideration) as a New York City Landmark, Interior Landmark or Scenic Landmark; is listed or eligible for listing on the New York State or National Register of Historic Places; or is within a designated or eligible New York City, New York State, or National Register Historic District? Please see Attachment B. If “Yes,” list the resources and attach supporting information on whether the project would affect any of these resources. 7. URBAN DESIGN: CEQR Technical Manual Chapter 10 (a) Would the proposed project introduce a new building, a new building height, or result in any substantial physical alteration to the ✔ streetscape or public space in the vicinity of the proposed project that is not currently allowed by existing zoning? (b) Would the proposed project result in obstruction of publicly accessible views to visual resources that is not currently allowed by ✔ existing zoning? 8. NATURAL RESOURCES: CEQR Technical Manual Chapter 11 (a) Is any part of the directly affected area within the Watershed? ✔ If “Yes,” complete the Jamaica Bay Watershed Form.

(b) Does the proposed project site or a site adjacent to the project contain natural resources as defined in section 100 of Chapter 11? If “Yes,” list the resources and attach supporting information on whether the project would affect any of these resources. ✔ Freshwater wetlands and upland resources. See Attachment B. 9. HAZARDOUS MATERIALS: CEQR Technical Manual Chapter 12 Please see Attachment B. (a) Would the project allow commercial or residential use in an area that is currently, or was historically, a manufacturing area that ✔ involved hazardous materials?

(b) Does the project site have existing institutional controls (e.g. (E) designations or a Restrictive Declaration) relating to hazardous ✔ materials that preclude the potential for significant adverse impacts? (c) Would the project require soil disturbance in a manufacturing zone or any development on or near a manufacturing zone or ✔ existing/historic facilities listed in Appendix 1 (including nonconforming uses)? (d) Would the project result in the development of a site where there is reason to suspect the presence of hazardous materials, ✔ contamination, illegal dumping or fill, or fill material of unknown origin? (e) Would the project result in development where underground and/or aboveground storage tanks (e.g. gas stations) are or were ✔ on or near the site? (f) Would the project result in renovation of interior existing space on a site with potential compromised air quality, vapor intrusion ✔ from on-site or off-site sources, asbestos, PCBs or lead-based paint? (g) Would the project result in development on or near a government-listed voluntary cleanup/brownfield site, current or former power ✔ generation/transmission facilities, municipal incinerators, coal gasification or gas storage sites, or railroad tracks and rights-of-way? (h) Has a Phase I Environmental Site Assessment been performed for the site? ✔ If ‘Yes,” were RECs identified? Briefly identify: 10. INFRASTRUCTURE: CEQR Technical Manual Chapter 13 Please see Attachment B. ✔ (a) Would the proposed project result in water demand of more than one million gallons per day?

(b) Is the proposed project located in a combined sewer area and result in at least 1,000 residential units or 250,000 SF or more of commercial space in Manhattan or at least 400 residential units or 150,000 SF or more of commercial space in the Bronx, ✔ Brooklyn, Staten Island or Queens? (c) Is the proposed project located in a separately sewered area and result in the same or greater development than that listed in ✔ Table 13-1 of Chapter 13? (d) Would the project involve development on a site five acres or larger where the amount of impervious surface would increase? ✔

(e) Would the project involve development on a site one acre or larger where the amount of impervious surface would increase and is located within the Jamaica Bay Watershed or in certain specific drainage areas including: Bronx River, Coney Island Creek, ✔ Flushing Bay and Creek, Gowanus Canal, Hutchinson River, Newtown Creek, or ? (f) Is the project located in an area that is partially sewered or currently unsewered? ✔

(g) Is the project proposing an industrial facility or activity that would contribute industrial discharges to a WWTP and/or generate ✔ contaminated stormwater in a separate storm sewer system? (h) Would the project involve construction of a new stormwater outfall that requires federal and/or state permits? ✔ 11. SOLID WASTE AND SANITATION SERVICES: CEQR Technical Manual Chapter 14 ✔ (a) Would the proposed project have the potential to generate 100,000 pounds (50 tons) or more of solid waste per week?

(b) Would the proposed project involve a reduction in capacity at a solid waste management facility used for refuse or recyclables ✔ generated within the City? EAS SHORT FORM PAGE 5 YES NO

12. ENERGY: CEQR Technical Manual Chapter 15 (a) Would the proposed project affect the transmission or generation of energy? ✔

13. TRANSPORTATION: CEQR Technical Manual Chapter 16 ✔ (a) Would the proposed project exceed any threshold identified in Table 16-1 of Chapter 16? (b) If “Yes,” conduct the screening analyses, attach appropriate back up data as needed for each stage, and answer the following questions: (1) Would the proposed project result in 50 or more Passenger Car Equivalents (PCEs) per project peak hour? If “Yes,” would the proposed project result in 50 or more vehicle trips per project peak hour at any given intersection? **It should be noted that the lead agency may require further analysis of intersections of concern even when a project generates fewer than 50 vehicles in the peak hour. See Subsection 313 of Chapter 16, “Transporation,” for information. (2) Would the proposed project result in more than 200 subway/rail or bus trips per project peak hour? If “Yes,” would the proposed project result, per project peak hour, in 50 or more bus trips on a single line (in one direction) or 200 subway trips per station or line?

(3) Would the proposed project result in more than 200 pedestrian trips per project peak hour? If “Yes,” would the proposed project result in more than 200 pedestrian trips per project peak hour to any given pedestrian or transit element, crosswalk, subway stair, or bus stop?

14. AIR QUALITY: CEQR Technical Manual Chapter 17

(a) Mobile Sources: Would the proposed project result in the conditions outlined in Section 210 of Chapter 17? ✔ Stationary Sources: Would the proposed project result in the conditions outlined in Section 220 of Chapter 17? ✔ (b) If ‘Yes,’ would the proposed project exceed the thresholds in the Figure 17-3, Stationary Source Screen Graph? (attach graph as needed) ✔ (c) Does the proposed project involve multiple buildings on the project site? ✔

(d) Does the proposed project require Federal approvals, support, licensing, or permits subject to conformity requirements? ✔ Does the proposed project site have existing institutional controls (e.g. E-designations or a Restrictive Declaration) relating to air (e) ✔ quality that preclude the potential for significant adverse impacts? 15. GREENHOUSE GAS EMISSIONS: CEQR Technical Manual Chapter 18 Is the proposed project a city capital project, a power plant, or would fundamentally change the City’s solid waste management (a) ✔ system? (b) If “Yes,” would the proposed project require a GHG emissions assessment based on the guidance in Chapter 18? ✔

16. NOISE: CEQR Technical Manual Chapter 19 ✔ (a) Would the proposed project generate or reroute vehicular traffic? Would the proposed project introduce new or additional receptors (see Section 124 of Chapter 19) near heavily trafficked (b) roadways, within one horizontal mile of an existing or proposed flight path, or within 1,500 feet of an existing or proposed rail line ✔ with a direct line of site to that rail line? Would the proposed project cause a stationary noise source to operate within 1,500 feet of a receptor with a direct line of sight to (c) ✔ that receptor or introduce receptors into an area with high ambient stationary noise? Does the proposed project site have existing institutional controls (e.g. E-designations or a Restrictive Declaration) relating to (d) ✔ noise that preclude the potential for significant adverse impacts? 17. PUBLIC HEALTH: CEQR Technical Manual Chapter 20 Please see Attachment B. ✔ (a) Would the proposed project warrant a public health assessment based upon the guidance in Chapter 20?

18. NEIGHBORHOOD CHARACTER: CEQR Technical Manual Chapter 21 (a) Based upon the analyses conducted for the following technical areas, check yes if any of the following technical areas required a detailed analysis: Land Use, Zoning, and Public Policy, Socioeconomic Conditions, Open Space, Historic and Cultural Resources, Urban Design and Visu al Resources, Shadows, Transportation, Noise ✔ If “Yes,” explain here why or why not an assessment of neighborhood character is warranted based on the guidance of in Chapter 21, “Neighborhood Character.” Attach a preliminary analysis, if necessary.

EAS SHORT FORM PAGE 7

PART III: DETERMINATION OF SIGNIFICANCE (To Be Completed By Lead Agency)

INSTRUCTIONS: In completing Part III, the lead agency should consult 6 NYCRR 617.7 and 43 RCNY §6-06 (Executive Order 91 of 1977, as amended) which contain the State and City criteria for determining significance.

1. For each of the impact categories listed below, consider whether the project may have a significant effect on the Potential environment. For each of the impact categories listed below, consider whether the project may have a significant Significant adverse effect on the environment, taking into account its (a) location; (b) probability of occurring; (c) duration; (d) irreversibility; (e) geographic scope; and (f) magnitude. Adverse Impact

IMPACT CATEGORY YES NO

Land Use, Zoning, and Public Policy

Socioeconomic Conditions

Community Facilities and Services

Open Space

Shadows

Historic and Cultural Resources

Urban Design/Visual Resources

Natural Resources

Hazardous Materials

Water and Sewer Infrastructure

Solid Waste and Sanitation Services

Energy

Transportation

Air Quality

Greenhouse Gas Emissions

Noise

Public Health

Neighborhood Character

Construction Impacts 2. Are there any aspects of the project relevant to the determination whether the project may have a significant impact on the environment, such as combined or cumulative impacts, that were not fully covered by other responses and supporting materials? If there are such impacts, explain them and state where, as a result of them, the project may have a significant impact on the environment.

3. LEAD AGENCY CERTIFICATION

TITLE LEAD AGENCY

NAME SIGNATURE EAS SHORT FORM PAGE 8

Check this box if the lead agency has identified one or more potentially significant adverse impacts that MAY occur.

Issue Conditional Negative Declaration

A Conditional Negative Declaration (CND) may be appropriate if there is a private applicant for an Unlisted action AND when conditions imposed by the lead agency will modify the proposed project so that no significant adverse environmental impacts would result. The CND is prepared as a separate document and is subject to the requirements in 6 NYCRR 617.

Issue Positive Declaration and proceed to a draft scope of work for the Environmental Impact Statement. If the lead agency has determined that the project may have a significant impact on the environment, and if a conditional negative declaration is not appropriate, then the lead agency issues a Positive Declaration.

NEGATIVE DECLARATION (To Be Completed By Lead Agency)

Statement of No Significant Effect Pursuant to Executive Order 91 of 1977, as amended, and the Rules of Procedure for City Environmental Quality Review, found at Title 62, Chapter 5 of the Rules of the City of New York and 6NYCRR, Part 617, State Environmental Quality Review, the [ ] assumed the role of lead agency for the environmental review of the proposed project. Based on a review of information about the project contained in this environmental assessment statement and any attachments hereto, which are incorporated by reference herein, the [ ] has determined that the proposed project would not have a significant adverse impact on the environment.

Reasons Supporting this Determination

The above determination is based on information contained in this EAS that finds, because the proposed project:

No other signficant effects upon the environment that would require the preparation of a Draft Environmental Impact Statement are foreseeable. This Negative Declaration has been prepared in accordance with Article 8 of the New York State Environmental Conservation Law (SEQRA).

TITLE LEAD AGENCY

NAME SIGNATURE ATTACHMENT A

Community Wildfire Protection Plan for the Eastern Shore of Staten Island Environmental Assessment Statement Part I, Question #5

The New York City Department of Parks and Recreation, in partnership with other City, State, and Federal agencies and elected officials on Staten Island, which include the New York City Department of Environmental Protection (DEP), the New York City Fire Department (FDNY), the New York State Department of Environmental Conservation (DEC), the National Park Service (NPS), and the Staten Island Borough President’s Office, have drafted a Community Wildfire Protection Plan (CWPP) to provide a list of prioritized recommendations and best practices to combat and prevent the prevalence of urban wildfires that occur on the Eastern Shore of Staten Island within the geographically defined boundaries of the draft CWPP. The draft CWPP is attached as Appendix 1.

In the last fifteen years, 103 serious Phragmites brush fires have occurred within the draft CWPP communities, all risking destruction to residential, commercial and historic properties and having the potential to cause harm and death to residents, workers, and firefighters. The source of virtually all these urban wildfires is the stands of the invasive grass Common Reed (Phragmites australis) that exist on both privately–owned and public properties within the project area, bounded by Lower New York Bay to the north and east, the southern boundary of Great Kills Park to the south, and Hylan Blvd and Maryland Avenue to the west. The draft CWPP contains approximately 3500 acres, with approximately a third of this coverage area encompassing publicly owned open space, wetlands, and beach areas. Please see the attached map. The draft CWPP provides three strategies, one short term, one intermediate, and one long term to manage hazardous fuel loads in such a way as to sustainably create a safe buffer between humans and their property and the source of these urban wildfires. This environmental review is for the adoption of the plan, in general, and to specifically address actions anticipated in the short term to address urban wildfires on the eastern shore of Staten Island.

The CWPP process is detailed in the Healthy Forest Restoration Act (HFRA), enacted by Congress in 2003, and is intended to encourage local communities to develop a plan that sets forth remedies to mitigate wildfires at what is termed the wildland-urban interface (WUI). A CWPP is required to qualify for specific federal funds designated to reduce hazardous fuel loads at the WUI only. These funds are not available to combat wildfires that are not a threat to communities. As such, the proposed remedies are to be deployed as narrow buffers between 50 and 150 feet wide and do not seek to wholesale eradicate or alter large stands of Phragmites within the CWPP. As required through HFRA, a community engagement and input process has been carried out to develop the draft plan and has involved all areas of Staten Island, including and beyond the communities within the project area.

The goals and objectives of the draft CWPP are to eliminate destruction and harm to property, natural resources and to the existing residential and work population. The objectives of the draft CWPP are to provide strategies to improve community implementation of wildfire prevention techniques, improve FDNY’s ability to contain and extinguish wildfires, manage the fuel load of natural vegetation occurring on open space and undeveloped land adjacent to residential and other properties, alter the dominant plant community to a more fire resistant native plant community, and to increase and maintain the community’s understanding of wildfire risks in their community. The specific short, medium, and long term strategies identified in the draft CWPP followed an assessment of the existing community landscape, population, land use profile, utilities, emergency response capabilities, existing State resources, and emergency medical facilities. A community risk assessment for urban wildfires was conducted by evaluating the number of fire occurrences within proximity to human habitation and other property and the fire behavior based on fuel type, flame length, and rate of spread, to develop an overall risk level rating. Subareas within the overall draft CWPP boundaries were identified, with high risk areas located in 4 distinct geographical subareas. As a planning document, the draft CWPP seeks only to identify three risk categories- high, medium, and low. It does not designate specific future projects which will be dependent on the level of funding available at any given time to stage projects, but will guide the selection of those projects through its recommendations.

The short term strategies identified in the draft CWPP include recommendations and suggestions to homeowners to reduce the potential for structural ignitability using home construction methods and landscaping design and maintenance. Mechanical fuels reduction is a short term tool identified in the draft CWPP and involves the cutting of phragmites to provide an immediate solution for the removal of a highly flammable resource and replacement with a more fire resistant native plant community. The intermediate term solution calls for a multi-step, multi- year protocol to provide eradication of the flammable source. This procedure would require multiple applications of herbicide and revegetation of the area with native plantings. This procedure could also include the prescribed burn of phragmites stubble and re-sprouts (not standing stalks). Although not currently planned, any such proposal would require additional review to assess potential effects on public health, safety and natural resources, As noted below, a prescribed burn would also need to comply with Part 194 of the New York State Environmental Conservation Law (ECL). The DEP Bluebelt program, a program carried out through DEP to create wetland areas for natural stormwater retention in watersheds, is an independent project, but has planned work within the boundaries of the draft CWPP over a twenty-year period and constitutes the long-term strategy outlined in the draft CWPP. Drainage sheds that coincide with the draft CWPP limits and with planned Bluebelt program improvements are the Oakwood Beach, New Creek and South Beach watersheds. The Bluebelt program involves the removal of phragmites through the excavation of existing fill soils, which would include the root zone areas of phragmites, and the conversion of the area to standing water. The Bluebelt projects will not necessarily treat every risk area delineated in the draft CWPP, as they are designed primarily for stormwater management within distinct drainage sheds, but Phragmites eradication is one of the necessary steps in their development and coincides with a draft CWPP recommendation. This environmental assessment for the draft CWPP has not been conducted in support of the Bluebelt projects, which are undergoing their own, independent environmental review process by DEP as lead agency (CEQR# 07DEP063R).

Additional suggestions and recommendations described in the draft CWPP to assist in the effort to prevent and eradicate urban wildfires include conducting outreach and education to the general public on wildfire prevention awareness, emergency equipment enhancement, emergency response planning enhancements, adjustments to utilities and infrastructure to assure that such facilities have adequate defense against wildfires, and the formation of an East Shore Fire Council to support and facilitate recommendations detailed in the draft CWPP.

NPS is in the process of implementing a short term remedy identified in the draft CWPP, specifically the mechanical removal of Phragmites, with an initial set of mowing activities that took place May 2012. A Memorandum of Agreement in effect for the timeframe of March 30, 2012 and September 30, 2012 between NPS, DPR, DEP and the Staten Island Borough President’s Office, enables NPS to perform the mechanical removal of Phragmites on land under the ownership of either the federal government, State or City. For any removal actions within DEC regulated freshwater wetland areas, the work is being carried out under approval from an existing DEC Permit (Number 2-6400-00009), which allows for Phragmites removal in such areas. Possible future permits and approvals required to carry out the various actions described in the draft CWPP include: DEC wetland permits and compliance with DEC regulations for prescribed burns as detailed in DEC regulations Part 194. Any areas in which prescribed fires will occur will be required to comply with Part 194 of the New York State Environmental Conservation Law (ECL). The regulatory measures of the ECL require approval of a prescribed burn plan and its execution by the DEC. A prescribed burn plan is required to contain the timing and weather conditions for the initiation of a prescribed burn, qualifications of the burn manager, a logistics plan to assure that the burn is restricted to the area identified for prescribed burn management, fire suppression measures, smoke management, and a communications plan. This Environmental Assessment Statement (EAS) has been conducted to consider the ideas presented in the draft CWPP and to detail the short term remedies in areas of high risk as identified in the draft CWPP for the eastern shore of Staten Island. The environmental review for the intermediate recommendations will undergo their own environmental review or reviews, as appropriate, once funding and detailed actions are established.

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Community Wildfire Protection Plan for the Eastern Shore of Staten Island Environmental Assessment Statement Part II: Technical Analyses

1. Land Use Zoning and Public Policy

The CEQR Technical Manual, January 2012 Edition explains that a land use analysis characterizes the uses and development trends in the area that may be affected by a proposed project, and determines whether a proposed project is either compatible with those conditions or whether it may affect them. Similarly, the analysis considers the project's compliance with, and effect on, the area's zoning and other applicable public policies, considered as officially adopted and promulgated public policies that describe the intended use applicable to an area or particular site(s) in the City. Based on the information and considerations as described below, the proposed action will not result in any significant impacts related to land use, zoning, or public policies.

Land Use and Zoning The area covered by the Community Wildfire Protection Plan is along the eastern shore of Richmond County (Staten Island), New York and includes all or portions of the communities of Oakwood Beach, , Midland Beach, South Beach, Old Town, Grasmere, Arrochar and Shore Acres. These communities consist mainly of one and two family residential housing with commercial areas (primarily retail) along Hylan Boulevard. Interspersed within these neighborhoods are over 1,350 acres of publicly owned open space, wetlands, and beach, mostly in large parcels. Open space in the community is owned and managed by several different entities, including private ownership, the National Park Service (NPS), and the New York City Departments of Environmental Protection (DEP) and Parks & Recreation (DEP). Indicative of the area is the Oakwood Beach Watershed area that is comprised of residential (about 47 percent), open space (8.5 percent), commercial (about 5 percent) and developed roadbed (about 21 percent) uses.

Zoning designations within the CWPP boundaries include lower-density residential zoning districts including R3-1, R3-2, R3X and R2, a commercial zoning district (C4-1) and a manufacturing zoning district (M3-1). R3-1 zoning districts are mapped throughout the CWPP area. The C4-1commercial district allows for larger buildings and specialty stores such as furniture retailers and shopping centers. This zoning district is on the south side of Hylan Boulevard, at the intersection with New Dorp Lane. M3-1 manufacturing typically allow large manufacturing buildings. The Oakwood Beach wastewater treatment plant is located within the southwest corner of the CWPP boundaries and is zoned M3-1.

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The proposed project does not involve a change in land use or zoning as the CWPP is a plan with recommendations for combatting the prevalence of wildfires that occur within the plan’s designated boundaries. Plan recommendations, including phragmites removal, revegetation of existing landscaped areas, suggested measures for securing private property, and policy recommendations for communication improvements of fire-prone conditions all aim to protect the existing land uses and development within the CWPP boundaries.

Public Policies Public policies can help define the existing and future context of the land use and zoning of an area. Public policies include Urban Renewal Plans, 197a Plans, Industrial Business Zones, and Business Improvement Districts. Two other citywide policies, the Waterfront Revitalization Program (WRP) and Sustainability, as defined by PlaNYC, are also considered within the context of CEQR. No designated Empire Zones, Industrial Business Zones, nor 197a Plans exist within the CWPP boundaries. Staten Island has two designated Empire Zones, the North Shore and West Shore Empire Zones, but they are not within the CWPP boundaries.

The CWPP is within the designated coastal zone of New York City. The coastal zone is the geographic area of New York City's coastal waters and adjacent shorelands that have a direct and significant effect on coastal waters. Proposed projects that are situated within the designated boundaries of New York City's Coastal Zone must be assessed for their consistency with the City's Waterfront Revitalization Program, adopted by the City of New York in 1999, and subsequently approved by the New York State Department of State with the concurrence of the United States Department of Commerce pursuant to applicable state and federal law, including the Waterfront Revitalization of Coastal Areas and Inland Waterways Act. The WRP establishes the City's Coastal Zone and includes 10 policies dealing with: (1) residential and commercial redevelopment; (2) water-dependent and industrial uses; (3) commercial and recreational boating; (4) coastal ecological systems; (5) water quality; (6) flooding and erosion; (7) solid waste and hazardous substances; (8) public access; (9) scenic resources; and (10) historical and cultural re- sources. The coastal zone consistency form is attached.

Vision 2020: New York City’s Comprehensive Waterfront Plan (Vision 2020) developed by the New York City Department of City Planning builds on these policies and sets the stage for expanded use of the waterfront for parks, housing and economic development, and the waterways for transportation, recreation and natural habitats. A 10-year vision for the future of city's 520 miles of shoreline, Vision 2020 provides a sustainable framework for more water transport, increased public access to the waterfront and economic opportunities that will help make the water part of New Yorkers' everyday lives. The CWPP boundaries include two reaches outlined in Vision 2020: Reach 18 and 19 for Staten Island North and South Shores. Twenty two reaches were established along the City’s shoreline based on their continuous expanses of waterfront and land use, natural features, and physical and political boundaries. Specific to each reach and based on a comprehensive community engagement process, Vision 2020 outlines neighborhood strategies to enhance the waterfront goals of public access, maritime industry, water

2 recreation, the natural environment, new development, and other activities. Strategies for Reach 18 and 19 that correlate with the CWPP boundaries include:

Support NPS’ General Management Plan process for Gateway National Recreation Area to provide additional opportunities for waterfront access, recreational use and cultural exploration. (Reaches 18 and 19) Maximize public use and activation of Miller Field (Reach 19) Support completion of Midland Beach Children’s park and public amenities on the boardwalk (Reach 19) Complete improvements to Ocean Breeze Park including new regional athletic facility and indoor horseback-riding arena. (Reach 19) Restore and improve public access to Cedar Grove Beach. (Reach 19)

The strategies and recommendations outlined in the CWPP do not conflict with the strategies outlined in Vision: 2020. The CWPP recommendations enable a managed approach to prevent wildfires. By implementation of such actions as outlined in the CWPP, existing open spaces within the Gateway National Recreation Area, Midland Beach, Ocean Breeze Park, and Cedar Grove Beach will not be affected. Any areas in which prescribed fires will occur will be required to comply with Part 194 of the New York State Environmental Conservation Law (ECL). The regulatory measures of the ECL require approval of a prescribed burn plan and its execution by the New York State Department of Environmental Conservation (SDEC). A prescribed burn plan is required to contain the timing and weather conditions for the initiation of a prescribed burn, qualifications of the burn manager, a logistics plan to assure that the burn is restricted to the area identified for prescribed burn management, fire suppression measures, smoke management, and a communications plan.

In 2007, the City adopted wide-ranging sustainability policies through PlaNYC, the City’s long-term sustainability plan, that apply to the city’s land use, open space, brownfields, energy use and infrastructure, transportation systems, water quality and infrastructure, and air quality, and also make the city more resilient to projected climate change impacts. The CWPP meets policies initiatives of PlaNYC, which include sustainability measures for parks, open space and waterways.

PlaNYC’s Initiative 12 details the intention to conserve natural areas to protect open spaces. Wetlands and other natural areas dominate much of the area along the eastern shore of Staten Island included in the CWPP coverage area. The draft plan provides strategies for sustainable management of these spaces to conserve natural resources and prevent the destruction of open space. Protection of these natural areas and the various species of wildlife that depend upon them is emphasized in the draft wildfire plan and is pursuant to the goals of PlaNYC. PlaNYC’s Initiative 15 seeks to ensure the long-term health of parks and public space through maintenance of public space. The draft CWPP includes short, intermediate, and long term strategies to increase sustainability in the design and management of public space and infrastructure. The strategies identified in the CWPP include mechanical

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removal of Phragmites, an invasive and highly flammable plant, by mowing, prescribed burns accompanied by immediate revegetation with native plants, and outreach and education to the general public. These actions incorporate sustainable management practices in the maintenance and protection of natural resources and public space to prevent wildfires from occurring and the potential closure of public recreational facilities to be destroyed or temporarily closed. Initiative 12 of PlaNYC calls for the enhancement of wetlands to protect and restore wetlands, aquatic systems, and ecological habitat. The CWPP encompasses large areas of wetlands and includes strategies to protect existing wetland areas through prevention of future destruction by wildfires and mitigation of wetland loss through revegetation of these areas with native plants. Currently, these wetland areas are in a degraded state and would be positively affected with revegetation and enhancement of the wetland ha+bitat by restoration activities. The strategies presented in the draft CWPP aim to prevent the loss of wetlands through sustainable management of natural resources and invasive species.

6. Historic and Cultural Resources

The CEQR Technical Manual outlines an assessment of archaeological resources for projects that would result in any in ground disturbance. The CEQR Technical Manual also outlines that architectural resources should be surveyed as assessed if a proposed project would result in: new construction, demolition, or significant physical alteration to any building or structure; a change in scale, visual prominence, visual context of any building, structure or object or landscape feature; screening or elimination of publicly accessible views; additions to or significant removal, grading or replanting of significant historic landscape features; or the introduction of significant new shadows or duration of existing shadows on a historic structure or landscape if they are dependent on sunlight.

Within the CWPP boundaries are historic structures and districts. The designated or eligible historic structures and districts within the CWPP boundaries include:

FDR Boardwalk & Beach Gateway National Recreation Area – Great Kills Park, Fort Wadsworth, Miller Field, Fort Tompkins, Battery Weed St. John Villa Academy, High School and Convent – 57 Cleveland Place St. Joseph Hill Academy – 850 Hylan Boulevard H.H.Richardson House – 45 Mclean Avenue Geller House School – 77 Chicago Avenue Our Lady of Lourdes Church – Cedar Grove Avenue Alice Austen House – 2 Hylan Boulevard McFarland-Bredt House- 30 Hylan Boulevard Woodland Cottage- 33-37 Belaire Road St. John’s Episcopal Church Parish House – 1331 Bay Street St. John’s Rectory- 1331 Bay Street 4

St. John’s Church Complex – 1334 Bay Street King House- 29 McClean Avenue Von Briesen Park – School Road and Bay Street Cedar Grove Historic District- eligible 23-25 Belair Road House 30 Belair Road House

The CWPP does not involve the development, alteration, or demolition of any historic structures. A CWPP recommendation does involve the possibility for prescribed burns and revegetation of areas that currently contain stands of Phragmites. Care will be taken to develop a prescribed burn plan that will ensure that no historical structure or district is at risk for any adverse effects. Any areas in which prescribed fires will occur will be required to comply with Part 194 of the New York State Environmental Conservation Law (ECL). The regulatory measures of the ECL require approval of a prescribed burn plan and its execution by the New York State Department of Environmental Conservation (SDEC). A prescribed burn plan is required to contain the timing and weather conditions for the initiation of a prescribed burn, qualifications of the burn manager, a logistics plan to assure that the burn is restricted to the area identified for prescribed burn management, fire suppression measures, smoke management, and a communications plan. If any historic structures or districts are in near proximity to the area planned for a prescribed burn, part of the communications plan will include informing the owner of any historic property.

For any areas on City-owned property where soil disturbance will occur for replanting of native plantings following Phragmites removal, the entity performing the work will consult with the New York City Landmarks Preservation Commission (LPC) to determine if any areas of archaeological concern are present. Information to be submitted to the LPC includes a site plan showing existing and proposed conditions, block and lot numbers for the proposed work, and a 400 foot radius measured from the edge of the lot on a Sanborn map or equivalent. Recommended archaeological protection measures will be incorporated into planning the activities involving soil disturbance as outlined in the draft CWPP.

The proposed action will not result in a significant impact on historic or cultural resources as it does not involve the construction, demolition, or alteration of any structure, will comply with ECL regulations and protections required for any future prescribed burn to ensure the protection of any nearby historic structures, and consultation with LPC and/or SHPO will occur to take into account potentially archaeological sensitive areas with soil disturbance required for any areas to be revegetated following a prescribed burn.

8. Natural Resources

The CEQR Technical Manual advises that a natural resources assessment is conducted when such resources are present on or nearby a project site, and when an action involves disturbance to natural resources. Natural areas make up a significant portion of the

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CWPP area, primarily hundreds of acres of City-owned parkland and Federal parkland. Of these parkland acres, 450 of the City park acres and 473 of the Federal park acres can be classified as natural areas. In addition, NYCDEP owns or is in the process of acquiring 195 acres of wetland areas for future Bluebelt projects. A substantial portion of this acreage within the CWPP boundaries and which contain natural areas is subject to periodic wildland fire due to the prevalence of phragmites. The recommendations of the CWPP include mowing the Phragmites as a short term measure, with the chemical treatment of phragmites, prescribed burns and revegetation of areas as a longer term solution to prevent wildfires. Possible future permits and approvals required to carry out the various actions described in the CWPP include: DEC wetland permits and compliance with DEC regulations for prescribed burns as detailed in DEC regulations Part 194.

Although the natural resources of the entire CWPP area are herein addressed, it should be restated that the actual areas proposed for actions under the draft CWPP are narrow bands of vegetation from 50 to 150 feet in width adjacent to areas of human occupancy. In most instances, the confined nature of these activities will in and of itself mitigate any impacts to natural resources.

An intermediate measure for Phragmites eradication as described in the CWPP includes chemical treatment. Targeted, careful application of herbicides such as glyphosate would be applied to phragmites by SDEC licensed applicators, and would be done following proper application procedures to ensure no harm to natural resources or to the personnel conducting the chemical application.

Wetlands The natural area along the Staten Island eastern shore addressed by the CWPP is dominated by New York State-regulated freshwater wetlands. These habitats are protected under New York State Environmental Conservation Law (ECL Article 24) and activities within these wetlands are controlled pursuant to Freshwater Wetlands Regulations (NYCRR Part 663), as administered by the New York State Department of Environmental Conservation (SDEC).

NPS is in the process of implementing a short term remedy identified in the CWPP, specifically the mechanical removal of Phragmites, with an initial set of mowing activities that took place May 2012. A Memorandum of Agreement in effect for the timeframe of March 30, 2012 and September 30, 2012 between NPS, DPR, DEP and the Staten Island Borough President’s Office, enables NPS to perform the mechanical removal of Phragmites on land under the ownership of either the federal government, State or City. For any removal actions within DEC regulated freshwater wetland areas, the work is being carried out under approval from an existing DEC Permit (Number 2- 6400-00009), which allows for Phragmites removal in such areas.

Plants The majority of several parcels, most notably Great Kills, Cedar Grove/Oakwood Beach, and New Creek, are virtually pure stands of non-native, highly invasive common reed

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(Phragmites australis). This plant also occurs in several other parcels where it is present in significant amounts, but is mixed with other wetland vegetation. Some of these stands have patches of groundsel bush (Baccharis halimifolia) or sumacs (Rhus spp.) along the wetland boundaries. The previous year‘s stalks of this tall perennial grass are the major fuel source for wildland fires in the area. Additionally, many of these wet parcels have upland plant communities on elevated hummocks within the wetlands. These hummocks support a variety of species such as oaks (Quercus spp.), hickories (Carya spp.), rose (Rosa spp.), and raspberry (Rubus spp.). Several locally uncommon species, including Starry campion (Silene stellata), Canadian burnet (Sanguisorba Canadensis), Starry false lily of the valley (Maianthemum stellatum), Wood-anemone (Anemone quinquefolia), and Dwarf chestnut oak (Quercus prinoides) can be found here as well. Parcels such as Great Kills and portions of Ocean Breeze have forest patches of various sizes. Stands of pin oak (Quercus palustris), gray birch (Betula populifolia), sassafras (Sassafras albidum), silver maple (Acer saccharinum), black locust (Robinia pseudoacacia), black cherry (Prunus serotina), willow (Salix spp.), and cottonwood (Populus deltoides) can be found on hummocks, on higher elevations, and on the perimeter of many of the wetlands throughout the area. Many of these patches have a significant amount of invasive plant species including Japanese knotweed (Polygonum cuspidatum), porcelainberry (Ampelopsis brevipedunculata) or multiflora rose (Rosa multiflora) in the understory or on their edges. Significant amounts of invasive mugwort (Artemesia vulgaris) and native seaside goldenrod (Solidago sempivirens) exist on the edges and perimeters of most of these areas. Ocean Breeze differs from the other areas as it contains a mixture of scrubby forest patches as above, interspersed with a significant acreage of warm season grassland, mostly switchgrass (Panicum virgatum), little blue stem (Schizachyrium scoparum), and weeping love-grass (Eragrostis curvula), a non-native grass. While the dried stems of these grasses are flammable, their short stature limits the duration, intensity, and spread of the fires that occur here.

Birds The natural areas within the CWPP host significant diversity of resident and migrant bird species. Mallard (Anas platyrhynchos), gadwall (Anas strepera), and Canada goose (Branta canadensis) can commonly be found in open water and channel areas. The coastal areas and wetland edges host waders such as killdeer (Charadrius vociferous), spotted sandpiper (Actitis macularius), and black crowned night heron (Nycticorax nycticorax). Breeding and full-time resident upland species include red-winged blackbird (Agelaius phoeniceus), yellow warbler (Dendroica petechia), swamp sparrow (Melospiza georgiana), song sparrow (Melospiza melodia), Carolina wren (Thryothorus ludovicianus), and red-eyed vireo (Vireo gilvus). The areas surrounding Ocean Breeze Park host a population of wild turkey (Meleagris gallopavo).

Mammals There are several mammalian species present in the CWPP area, broadly distributed throughout. They are mostly common generalist species including but not limited to raccoon (Procyon lotor), white-footed mouse (Peromyscus leucopus), opossum (Didelphis virginiana), muskrat (Ondatra zibethicus), eastern gray squirrel (Sciurus carolinensis), and eastern cottontail (Sylvilagus floridanus).

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Reptiles and Amphibians A number of habitat generalists such as Eastern red-backed salamander (Plethodon cinerus), and common garter snake (Thamnophis sirtalis) can be expected in the Phragmites dominated wetlands, and spring peepers (Pseudacris crucifer) have been heard in several locations. Several additional species including green frog (Lithobates clamitans) and Fowler‘s toad (Anaxyrus fowleri) may be found in the wetlands of Ocean Breeze.

Threatened and Endangered Species A review of existing available records, environmental assessments, and reports covering the area was conducted. These documents were reviewed for information on species listed as endangered, threatened, of special concern, or rare by the U. S. Fish and Wildlife Service (USFWS) and the New York Natural Heritage Program (NYNHP).

A table listing the potential Federal and State listed protected species within the CWPP boundary is found below.

None of the wildlife species are known to nest in the fire prone areas of the CWPP area, however, fire may impact the abundance and availability of their prey. Data is scarce on the effect of fire on many of the plant species, though removal of the Phragmites will have the temporary effect of reducing competition for sunlight and opening new areas for seed germination. Regeneration of native vegetationhas been observed in these areas following wildfire occurrences.

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Pursuant to New York State regulation (NYCRR part 182), no person shall take or engage in any activity that is likely to result in a take of any species listed as endangered or threatened in this Part, except as authorized by an incidental take permit issued by SDEC. Any person proposing an activity or any entity with regulatory oversight over a proposed activity may request a determination from the department as to whether the proposed activity is likely to result in the take or taking of any species listed as endangered or threatened in this Part and is therefore subject to regulation under this Part.

In implementing activities under the CWPP, consultation with SDEC will occur to determine if the proposed activity will result in a take. This may require a more careful inspection of the area to determine the extent to which any listed species occupy or utilize the area upon the initiation of a recommendation included in the CWPP, such as a prescribed burn or revegetation of any area. If the department finds the activity is likely to result in a take, an application for an Incidental Take permit will be made to SDEC. The application must include submittal of a mitigation plan providing a net conservation benefit to the species in question, therefore no significant adverse effect to threatened or endangered species will occur.

9. Hazardous Materials

The CEQR Technical Manual details that a hazardous material assessment is conducted when elevated levels of hazardous materials exist on a site, when an action would increase pathways to their exposures, either human or environmental, or when an action would introduce new activities or processes using hazardous materials. For any areas within the CWPP boundaries that would be revegetated, the plan would be to seed and/or add herbaceous plugs or possibly shrubs. No excavation beyond eight inches would be required for such work. There are no properties within the CWPP boundaries that have institutional controls or a Restrictive Declaration relating to hazardous materials. No development is part of the CWPP. The CWPP details management strategies for the curtailment of phragmites to prevent wildfires. Some of the areas within the CWPP boundaries include historic fill, or fill of unknown origin. According to the CEQR Technical Manual it is not uncommon to find elevated levels of hazardous materials in historic fill. Historical fill is typically found in properties adjacent to waterways where, historically, large amounts of fill material have been used as part of urban development. The CEQR Technical Manual details that historic fill and other materials with concentrations typical of urban fill material may be reused on-site, provided that doing so is not in violation of any applicable regulatory requirements and that exposure to such materials is mitigated by installation of a cap, or other appropriate mitigation controls are implemented. In accordance with NYSDEC’s Rules and Regulations on beneficial use, found at 6 NYCRR Part 360, Section 1.15(b)8, nonhazardous, contaminated soil that has been excavated as part of construction projects may be used as backfill for the same excavation or excavations containing similar contaminants at the same site. Any planting scheme to be carried out in the context of the

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CWPP will comply with this guidance and the prescribed regulations, therefore no significant impact related to hazardous materials will result from the proposed action.

10. Infrastructure

The CEQR Technical Manual details that a preliminary analysis of a project’s effects on the water supply system is warranted if a project would result in an exceptionally large demand for water, or would be located in an area that experiences low water pressure. A preliminary analysis of a project’s effects on wastewater or stormwater infrastructure is warranted depending on a project’s proposed density, its location, and its potential to increase impervious surfaces. The CWPP boundaries include partially sewered areas, although the proposed action is not a development project and would not add new flows to the existing sewer network. Therefore, no significant impacts associated with infrastructure are expected from the implementation of recommendations detailed in the CWPP. The DEP Bluebelt program, a program carried out through DEP to create wetland areas for natural stormwater retention in watersheds, is an independent project, but has planned work within the boundaries of the CWPP over a twenty-year period. Drainage sheds that coincide with the CWPP limits and with planned Bluebelt program improvements are the Oakwood Beach, New Creek and South Beach watersheds. The Bluebelt program involves the removal of phragmites through the excavation of existing fill soils, which would include the root zone areas of phragmites, and the conversion of the area to standing water. The Bluebelt projects will not necessarily treat every risk area delineated in the CWPP, as they are designed primarily for stormwater management within distinct drainage sheds, but Phragmites eradication is one of the necessary steps in their development and coincides with a CWPP recommendation. The Bluebelt project is undergoing an independent environmental review process by DEP as lead agency (CEQR# 07DEP063R).

17. Public Health

The CEQR Technical Manual details the goal is to determine whether adverse impacts on public health may occur as a result of a proposed project, and if so, to identify measures to mitigate such effects. Public health is the organized effort of society to protect and improve the health and well-being of the population through monitoring; assessment and surveillance; health promotion; prevention of disease, injury, disorder, disability and premature death; and reducing inequalities in health status.

The goal of the CWPP is to aid at-risk communities for wildfires. The CWPP establishes recommendations and priorities to protect citizens, homes, and essential infrastructure and resources from the destruction of catastrophic wildfire and to safeguard those responsible for fighting and controlling such fires, while preserving and protecting the natural environment. One possible approach suggested is to conduct a prescribed fire to enable the eradication of phragmites stubble and re-sprouts after a cutting and the application of herbicides, prior to revegetation of the area. Any such proposed prescribed

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burn action would be subject to additional review for potential public health effects, particularly since prescribed burn would lead to some levels of smoke. Care would be taken to develop a prescribed burn plan in consultation with public health, environmental and life safety agencies in order to ensure public safety for personnel conducting the prescribed burn and nearby residents and workers. Smoke management would take into account sensitive areas including residential communities, recreation areas, schools, hospitals, and nursing homes. To avoid or minimize effects on sensitive areas a smoke screening evaluation would be conducted for the selected burn area and would become part of the burn plan, which requires review and approval by SDEC as per Part 194 of the New York State Environmental Conservation Law (ECL). A prescribed burn plan is required to contain the timing and weather conditions for the initiation of a prescribed burn, qualifications of the burn manager, a logistics plan to assure that the burn is restricted to the area identified for prescribed burn management, fire suppression measures, smoke management, and a communications plan. If any historic structures or districts are in near proximity to the area planned for a prescribed burn, part of the communications plan will include informing the owner of any historic property.

Prescribed burns are not proposed at this time. Should a proposal for the use of this technique be proposed, it would be subject to additional review. The procedures recommended, at this time, including cutting, the application of herbicides and revegetation would occur as prescribed under currently regulations, therefore no significant impacts to public health will occur as a result of the recommendations outlined in the CWPP.

An intermediate measure for Phragmites eradication as described in the CWPP also includes chemical treatment. Targeted, careful application of herbicides such as glyphosate would be applied to phragmites by SDEC licensed applicators, and would be done following proper application procedures to ensure no harm to natural resources or to the personnel conducting the chemical application.

19. Construction

The CEQR Technical Manual calls for an assessment of construction-related impacts, with a focus on transportation, air quality, noise, as well as consideration of other technical areas such as historic and cultural resources, hazardous materials, and natural resources. The timeframe and duration of activities associated with recommendations in the CWPP is not yet defined, but activities related to the plan will not result in any development. A prescribed burn plan may involve the temporary closure of traffic or pedestrian elements to enable safe access for fire personnel and for the safety of nearby residents and workers. The duration of such activities would be temporary in nature and would be carried out following advance notification and communication to the residents and workers in near proximity of the prescribed burn area.

Although not proposed at this time, any areas in which prescribed fires will occur will be required to comply with Part 194 of the New York State Environmental Conservation

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Law (ECL). The regulatory measures of the ECL require approval of a prescribed burn plan and its execution by the New York State Department of Environmental Conservation (SDEC). A prescribed burn plan is required to contain the timing and weather conditions for the initiation of a prescribed burn, qualifications of the burn manager, a logistics plan to assure that the burn is restricted to the area identified for prescribed burn management, fire suppression measures, smoke management, and a communications plan. If any historic structures or districts are in near proximity to the area planned for a prescribed burn, part of the communications plan will include informing the owner of any historic property. Section 194.8 of ECL provides for the protection of adjoining property, by establishing a minimum distance between the fire and the property of the adjacent landowners to protect such property. The distance required is based on the prescribed fire requirements such as weather and wind conditions, calculated flame spread and the sensitivity of the adjacent property. Typically the minimum distance to adjacent properties is 75 feet with a waiver from the adjacent landowner is required if the distance is to be less.

No significant impacts associated with construction activities are expected from the activities detailed in the CWPP due to the temporary nature of the activities to be undertaken and with the provision of measures for the public’s protection and safety as required by SDEC following their review and approval of a prescribed burn plan.

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C. Coastal Assessment Policy Question Supplemental Responses for “Yes” Answered Questions

1. Is the project site on the waterfront or at the water’s edge?

The area covered by the proposed project is along the eastern shore of Staten Island, and includes all or portions of the communities of Oakwood Beach, New Dorp Beach, Midland Beach, South Beach, Old Town, Grasmere, Arrochar and Shore Acres.

9. Are there any waterfront structures, such as piers, docks, bulkheads or wharves, located on the project site(s)?

Yes (details to be provided). The project does not propose any work or changes to any existing piers, docks, bulkheads or wharves, located on the project site.

14. Would the action be located in a commercial or recreational boating center, such as City Island, Sheepshead Bay or Great Kills or an area devoted to water-dependent transportation?

While the project site was previously operated as a marina and is located in a Significant Maritime and Industrial Area, which has a history of commercial marine activity, the proposed improvements do not conflict with future use of the site for boating related use. The proposed improvements are above the Elevation 10 contour and do not impact the existing bulkhead and pier area(s). The proposed improvements do allow public access to view the waterfront.

20. Is the site located within or adjacent to a Recognized Ecological Complex: South Shore of Staten Island or Riverdale Natural Area District?

Details to be provided

21. Would the action involve any activity in or near a tidal or freshwater wetland?

The natural area along the Staten Island eastern shore addressed by the proposed project is dominated by New York State-regulated freshwater wetlands. These habitats are protected under New York State Environmental Conservation Law (ECL Article 24) and activities within these wetlands are controlled pursuant to Freshwater Wetlands Regulations (NYCRR Part 663), as administered by the New York State Department of Environmental Conservation (SDEC).

The National Park Service (NPS) is in the process of implementing a short term remedy identified in the CWPP, specifically the mechanical removal of Phragmites, with an initial set of mowing activities that took place May 2012. A Memorandum of Agreement in effect for the timeframe of March 30, 2012 and September 30, 2012 between NPS, DPR, DEP and the Staten Island Borough President’s Office, enables NPS to perform the mechanical removal of Phragmites on land under the ownership of either the federal government, State or City. For any removal actions within DEC regulated freshwater wetland areas, the work is being carried out under approval from an existing DEC Permit (Number 2-6400-00009), which allows for Phragmites removal in such areas.

22. Does the project site contain a rare ecological community or would the proposed project affect a vulnerable plant, fish, or wildlife species?

The project site does contain species listed as endangered, threatened, of special concern, or rare by the U.S. Fish and Wildlife Service (USFWS) and the New York Natural Heritage Program (NYNHP) found within the table below. .

None of these wildlife species are known to nest in the fire prone areas of the project site , however, fire may impact the abundance and availability of their prey. Data is scarce on the effect of fire on many plant species, though removal of the Phragmites will have the temporary effect of reducing competition for sunlight and opening new areas for seed germination. Regeneration of native vegetation has been observed in these areas following wildfire occurrences.

Although the natural resources of the entire CWPP area are herein addressed, it should be restated that the actual areas proposed for actions under the CWPP are narrow bands of vegetation from 50 to 150 feet in width adjacent to areas of human occupancy. In most instances, the confined nature of these activities will in and of itself mitigate any impacts to natural resources.

Pursuant to New York State regulation (NYCRR part 182): No person shall take or engage in any activity that is likely to result in a take of any species listed as endangered or threatened in this Part, except as authorized by an incidental take permit issued by the department (NYSDEC). Any person proposing an activity or any entity with regulatory oversight over a proposed activity may request a determination from the department as to whether the proposed activity is likely to result in the take or taking of any species listed as endangered or threatened in this Part and is therefore subject to regulation under this Part.

In implementing activities under the proposed project, a determination must be made concerning the potential for the proposed activity to result in a take. This may require a more careful inspection of the area to determine the extent to which any listed species occupy or utilize the area. If NYSDEC finds the activity is likely to result in a take, an application for an Incidental Take permit will be submitted. The application will include submittal of a mitigation plan providing a net conservation benefit to the species in question.

32. Would the action result in any activities within a federally designated flood hazard area or state designated erosion hazards area?

Federal Emergency Management Agency (FEMA) flood maps indicate the project area as being within Zone information to be added. No structures are included in the proposed project nor is any regarding planned. If Phragmites are removed, the affected area will be revegetated and permits will be obtained for any activities located within a federally designated flood hazard area or state-designated erosion hazards area.

35. Would the action involve any new or increased activity on or near any beach, dune, barrier island, or bluff?

Details to be provided

39. Would the action affect any sites that have been used as landfills?

The area covered by the proposed project includes Great Kills Park. Primary development work was performed between 1934 and 1951. The total land area of Great Kills Park is 488 acres. Of that total, approximately 223 acres are landfill that was created by filling the area’s wetlands with “sanitation controlled fill.” Small sources of radium have been found in discrete areas at Great Kills Park. These radium sources, found buried more than a foot below the ground surface, have been removed. It is believed that the radium came from discarded medical treatment sources brought to the site. Radium present in these items has probably leaked over time, resulting in contamination of soil surrounding the sources.

Additional areas exhibiting above-background radiation readings have been identified within the footprint of the historic landfill at Great Kills Park. The National Park Service (NPS) is pursuing cleanup of Great Kills Park as prescribed under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as the “Superfund” law. NPS is currently working through an Inter-Agency Agreement with the U.S. Army Corps of Engineers and their contractor to prepare the work plans necessary to fully investigate and clean up radioactive contamination at Great Kills Park. As a precaution, visitor access to the affected areas is still closed.

Additional information to be added

43. Will the proposed project affect or be located in, on, or adjacent to any federal, state or city park or other land in public ownership protected for open space preservation.

Federal and City parkland comprises a significant portion of the project area. There are over 600 acres of City-owned parkland, and an additional 790 acres of Federal parkland within the project area. In addition, New York City Department of Environmental Protection (NYC DEP) owns or is in the process of acquiring 195 acres of wetland areas for future Bluebelt projects. The proposed project will reduce the risk of wildfire and associated damage to these properties.

47. Does the proposed project involve publicly owned or acquired land that could accommodate waterfront open space or recreation?

Yes. See answer to Question No. 43 above.

48. Does the project site involve lands or waters held in public trust by the state or city?

Yes, see answer to Question 43 above.

49. Would the action affect natural or built resources that contribute to the scenic quality of a coastal area?

Details to be provided

ENVIRONMENTAL REVIEW

Project number: NYC DEPT. OF PARKS AND RECREAT / 77DPR013R Project: COMMUNITY WILDFIRE PROTECTION PLAN EASTERN SHORE Date received: 6/12/2012

Comments: The LPC is in receipt of the draft project materials of 6/12/12. Comments are as follows.

Architecture

Properties within the project and study areas:

Miller Army Air Field Historic District, New Dorp Lane, S/NR listed. Ft. Wadsworth Historic District, S/NR listed. Ft. Tompkins Quadrangle, Building 137, Ft. Wadsworth, LPC and S/NR listed. Battery Weed, Ft. Wadsworth, LPC and S/NR listed.

23-25 Belair Rd. House, 33-37 Belair Rd. House, 30 Belair Rd. House, all LPC listed.

St. John’s Church Complex, 1334 Bay St., LPC and S/NR listed. St. John’s Parish House, 1331 Bay St., LPC listed. St. John’s Rectory, 1331 Bay St., LPC listed.

H.H. Richardson House, 45 McClean Ave., LPC listed. King House, 29 McClean Ave; LPC listed.

Archaeology

Upon identification of project location(s) within this Plan that are City lots which will include in-ground disturbance as a result of the action, the lead agency will contact LPC for an archaeological review on a site specific, lot by lot basis. Project locations within Federally owned property shall be reviewed by the National Park Service.

Information needed by LPC to conduct a review is as follows:

1. A site plan and sections showing existing and proposed conditions. 2. Block and lot numbers. 3. A 400’ radius map measured from the edge of the lot on a Sanborn map or equivalent.

6/21/2012

SIGNATURE DATE Gina Santucci, Environmental Review Coordinator

File Name: 27982_FSO_GS_06192012.doc