September 18, 2003

John Piazza, Chairman & Members of the Town of Mamakating Planning Board
2948 Rt. 209
Wurtsboro, NY 12790

Chairman Piazza and Members of the Mamakating Planning Board:

My name is Maryallison Farley, the current President of the Basha Kill Area Association, a local environmental group with about 500 members that is alert to threats to the Basha Kill and surrounding environs. We appreciate very much the opportunity to comment on the scope document for the Yukiguni Maitaike Mushroom application which is now before the Planning Board. And based on our working relationship with the Planning Board, we are confident that the Board will consider and weigh all of the environmental impacts before approving the project in any form.

Our comments address those issues in the scoping document that we feel have not been adequately discussed. First, in the site plan and operations discussion, Yukiguni Maitaike needs to explain why a height variance is required for this mushroom production facility. According to other Maitake mushroom producers that we have contacted, it is not necessary for a mushroom facility of this kind to have four floors. The suggestion by the applicant that this design is being used to reduce construction costs presents a poor cost/benefit ratio when that design is weighed next to the negative effect of a four story facility of this size would have on the valley and ridge viewshed.

Regarding the benefits of the proposed action, the applicant should present a full economic analysis which justifies a production facility of this size. Particularly since Yukiguni Maitaike will be benefiting from the tax breaks of an Empire Zone, the community deserves to see the figures that would justify a plant operating at this scale. The citizens of Mamakating and the surrounding region need to see figures that would allay our concerns that within a year of its opening, Yugikuni might be closed down, an empty building because the market is not there for these products.

Regarding operations specifically, in order to understand the environmental impact of this project, detailed plans for the water and wastewater operations are required. The plan for the wastewater facilities should clearly indicate how the wastewater will be treated, what materials (both biological and chemical constituents) will be in the discharge and the temperature of the discharge. Similarly, when looking at potential surface water impacts, this same, detailed information about sewage discharge is required. Without this information, the Planning Board will not be able to fairly evaluate the impact of this project.

Of great concern is the discussion about the groundwater resources which will be impacted by this project. At a minimum, the applicant needs to supply those pump studies which have been done, clarifying how many wells were monitored, over how long a period of time and whether or not 621,000 gallons per day was pulled out of the aquifer. That information is clearly minimal according to experts in hydrogeology that we have consulted. According to these experts, the applicant needs to explain how the use of groundwater by their facility will impact the hydrologic budget for the area (621,000 gallons per day pulled out of the aquifer and 50,000 gallons per day put back). And the experts say that this hydrologic impact can ONLY be adequately explained if a comprehensive water study is completed. To quote Allan Randall at USGS in Troy, NY:

"The magnitude of water-level declines due to particular proposed withdrawals from the valley reach near Wurtsboro could not be estimated with any confidence unless a comprehensive study of that valley reach were undertaken, adequate in scope to calibrate an aquifer model".

To acquire information on the groundwater resources that is as accurate and reliable as possible, the Planning Board needs to select an independent contractor or agency to carry out a comprehensive water study which would then be paid for by the escrow account of the applicant.

Impacts upon the fauna or animals of the area should include the potential impact of drying up of the upper reaches of the Basha Kill, as well as the effect of a general decrease in flow upon the animal life.

Regarding the impact of the project on cultural resources, the applicant should address the impact of its proposed 62' and 82' high structures on users of the historic D& H Canal trail. That canal trail is now being actively promoted and developed by the Town as an important recreational resource which will bring visitors to the Village businesses.

Visual impacts are key effects of this project which have been addressed earlier in this discussion.

Noise impacts to be evaluated include the sound of the ventilation equipment which we understand will be running 24 hours a day, 7 days a week. Because of the scale of the project, the applicant needs to provide an analysis of the noise level from this equipment and from other equipment and explain how it will be ameliorated.

Regarding the impacts of odors associated with the project, the applicant needs to present this information within the context of the inversion which effects the Wurtsboro valley. Questions to be considered are whether in spite of mitigation measures, certain odors dominating the air would be acceptable in this community. We have been advised by experts that in the sterilization or pasteurization of the sawdust which is used as a substrate for the mushrooms, the sawdust is essentially "cooked." This generates odors that are objectionable to some people.

Regarding traffic impacts, Yukiguni Maitaike should also include an analysis of the trucking that will be required to move their products and waste products.

Other issues of importance include how this project will impact some of the goals of the NYS Open Space Plan which has prioritized land purchase on the Shawangunk Ridge.

And finally, with such enormous production of waste materials, the applicant is responsible to clarify where these materials will be disposed of and the impact that the materials will have on landfill(s).

In conclusion, the Basha Kill Area Association as an Interested Party to these proceedings, strongly suggests that the Planning Board require complete and full information from Yukiguni Maitaike Mushroom about the potential environmental impacts of this major industrial proposal before deciding to accept or reject the proposal in any form.

Thank you very much,

Maryallison Farley,
President

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