ANDREW M. CUOMO ERIK KULLESEID Governor Commissioner April 08, 2020 Carol Weed Principal Independent Contractor 50 Saw Mill Rd. Unit 15326 Danbury, CT 06810 Re: FAA Randall Airport (06N) Off-Airport Obstruction Removal (Runway 26) 20PR02217 AIP Grant 3-36-0224-28-12 Dear Carol Weed: Thank you for requesting the comments of the State Historic Preservation Office (SHPO). We have reviewed the project in accordance with Section 106 of the National Historic Preservation Act of 1966. These comments are those of the SHPO and relate only to Historic/Cultural resources. They do not include potential environmental impacts to New York State Parkland that may be involved in or near your project. Such impacts must be considered as part of the environmental review of the project pursuant to the National Environmental Policy Act and/or the State Environmental Quality Review Act (New York Environmental Conservation Law Article 8). Based upon this review, it is the opinion of the New York SHPO that no historic properties, including archaeological and/or historic resources, will be affected by this undertaking. If further correspondence is required regarding this project, please be sure to refer to the OPRHP Project Review (PR) number noted above. Sincerely, R. Daniel Mackay Deputy State Historic Preservation Officer Division for Historic Preservation Division for Historic Preservation P.O. Box 189, Waterford, New York 12188-0189 parks.ny.gov CRIS PROJECT NOTIFICATION, ATTACHMENT 01, PHASE IA MEMORANDUM TO: NEW YORK OFFICE OF PARKS, RECREATION AND HISTORIC PRESERVATION, FIELD SERVICES BUREAU FROM: CAROL S. WEED, M.A. (RPA #989090) SUBJECT: RANDALL AIRPORT, TOWN OF WALKILL, ORANGE COUNTRY, NY, REVISIONS OF FAA SHORT FORM EA FOR AIRPORT DEVELOPMENT, PHASE IA DUE DILIGENCE REVIEW DATE: MARCH 31, 2020 CC: FILE CSW13108, 2019-009_KGO_RANDALL Randall Airport (06N), 100 Airport Road, Town of Wallkill, Orange County, New York (NY), is proposing to conduct off-airport obstruction removal for Runway 26 (the Project; Figures 1 and 2). Specifically, pursuant to the Federal Aviation Administration (FAA) Part 77 regulations, there are vegetative obstructions (i.e., trees; Figures 3 and 4) in the approach to Runway 26 which are required to be removed for safe and unobstructed navigation to the runway. This action is subject to review by the FAA. The proposed Project is currently being reviewed by the FAA Eastern Region. A Short Environmental Assessment Form for Airport Development (Draft EA) for the Project was filed by TSPE Planning Engineering & Land Surveying, P.C. on April 8, 2019. That Draft EA is being revised by P.W. Grosser Consulting, Inc., pursuant to FAA comments dated August 21, 2019. Those comments also included coordination with all landowners as well as undertaking consultations. The FAA Eastern Region, by comment #16 (August 21, 2019), noted that the cultural resources information presented in the Draft EA was dated and needed updating. FAA commented that a “[n]ew determination [from NYOPRPHP] is required because properties not eligible for listing then or that have been deemed eligible for listing or listed since then may be in or adjacent to project area.” To that end, this memorandum and accompanying materials are being submitted electronically for review to the New York State Office of Parks, Recreation, and Historic Preservation (NYOPRHP) using the NYOPRHP Cultural Resources Information System (CRIS). The cultural resources Phase IA due diligence assessment for the Project is prepared by Carol S. Weed, MA (RPA #989090) under contract to Ms. Shavawn M. Lockhart (P.E.), TriState Planning Engineering & Land Surveying (TSPE TriState), Hauppauge, NY, as project engineer to Mr. Charles Brodie, Owner, Aerodrome Development Corporation, 100 Airport Road. The FAA filing is being managed and prepared by the Project environmental consultant, Ms. Kim Gennaro-Oancea (AICP CEP), P.W. Grosser Consulting, Inc. (PWGC), Bohemia, NY. 1 CSW 2019-009_KGO_Randall This memorandum is divided into four parts: Project Description, Existing Conditions, Background and Literature Review, and Conclusions and Recommendations. Project Description The Project, totally + 14 acres, is focused solely on the removal of trees within the approach slopes for Runway 26. Figures 3 (Runway 26 Obstructions) and 4 (Enlarged View of Area 3) illustrate the locations of tree clusters that occur within the three project subdivisions (Areas 1, 2, and 3). Figure 5 offers additional information about perceived surface disturbance. Each ‘cluster’ contains one or more trees and the clusters are based on observed conditions recorded in 2016. The areas that contain the Project tree clusters are • Area 1: This area is north of Interstate (I)-84, adjacent to the Randall Airport property and located on New York State Department of Transportation (NYDOT) property (I-84 Right- of-Way) within the Town of Wallkill. • Area 2: This area includes the median of I-84, separating the eastbound and westbound traffic, which is also NYSDOT-owned property (I-84 Right-of-Way). • Area 3: This area is located on the south side of I-84 and is subdivided into three subareas (A, B, and C) based on landowner. The three landowners are: o NYSDOT-owned I-84 Right-of-Way; o private property identified as Tax Number 105-2-1.2 which is a residential subdivision known as Fairways Wallkill, LLC; and o private property identified as Tax Number 73-1-32. The airport owner proposes to remove the vegetative obstructions in Areas 1, 2 and 3 and reseed with native grasses that will not impact the FAA surfaces. This will maintain the approaches for the foreseeable future and is therefore of a high priority safety project under review by the FAA. The individual trees will be cut and stumped. The logs and stumps will be removed by truck and the areas re-seeded after preparation. The subsurface disturbance resulting from these actions will be dependent on the stump sizes, which will vary by tree species and age, and truck tire sizes. It is expected that the stumping will impact to depths corresponding to at least B-horizon soils. Table 1 characterizes the tree heights but not their circumference. Also noted on the table are a small subset of knolls and trees that are on-airport and which will be dealt with separately by the airport owner. The ground and tree obstructions on-Airport are not part of the proposed action. Existing Conditions A drive-by of Area 1, NYDOT ROW adjacent to the Airport, from the Airport side was conducted on December 10, 2019, by the author, Mr. Brodie, Ms. Lockhart, and Ms. Gennaro-Oancea. There was snow cover (Photographs 1-2) but the trees in Area 1 were readily apparent as was the relationship of Area 1 to Area 2, the 1-84 median. No stone walls or depressions were observed 2 CSW 2019-009_KGO_Randall in Area 1. In Area 2, possible depressions that might be stormwater features were observed and this was subsequently confirmed in February, 2020. On February 21, 2020, Ms. Gennaro-Oancea and Ms. Tammy Cunha (LEED AP BD+C), PWGC, who is dealing with Project stormwater issues, conducted drive-bys of Areas 2 and 3A, in addition to a walkover of Area 3B (Photographs 3-6). At the time of the walkover, Area 3C was posted “no trespassing” and conditions in the area were observed from Area 3B. Ms. Cunha made the following observations and also provided some of the photographs that are attached to this memorandum. “…drainage swales were observed alongside Route 84 in the highway shoulders and along the central median dividing the northern and southern traffic lanes, within Areas [2] and [3A]. The centerlines of swales are at a lower elevation than the surrounding roadways and the vegetated areas beyond the highway shoulders. The swales are assumed to have been built as part of the roadway drainage system and are considered to be previously disturbed areas. The drainage swales are approximately 8-10 feet wide, with open grates in various locations. This leads to the belief that these grates are part of an underground stormwater collection system. Much of the median along Route 84 consists of a grass- covered area with intermittent vegetated intervals composed of mature trees and shrubs.” Areas 1, 3B, and 3C also are tree covered with shrub and grass undergrowth. Of the five areas and subareas (1, 2, 3A, 3B, and 3C), none are undisturbed as that term is used archaeologically. A comparison of the 1942 and 1969 USGS Middletown quadrangles shows the contours impacted by the construction of the Airport, I-84, and re-routing of McManus Road/Airport Road to create the existing I-84 overpass (Figures 6 and 7). USGS aerial photographs of the area show the presence of a probable farmstead in the southwest corner of Area 3B. Background Review and Literature Review Buildings and Structures: There are no buildings within the tree-cutting areas. There are structures, however, and these consist of chain link fences (Areas 1 and 3A) and stormwater features (Areas 1, 2, and 3A). Push piles with large rock are present in both Areas 3B and 3C. These are adjacent to the Area 3A chain link fence or in its vicinity. None of the cultural features noted are potentially significant though at least the stormwater features may date to the 1-84 construction period. No buildings or structures are shown in any of the project areas on the 1908 USGS quadrangle (Figure 8). Archaeology: Based on the CRIS search, there has been no previous archaeological survey of any Project areas or subareas though archaeological investigations have been conducted within one- mile of the Project boundaries and on both side of I-84. The adjacent studies account for the assignment of archaeological sensitivity to parts of Areas 1, 2, and 3.