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Lester E. Hendrix 245 Main
Street, PO Box 711 Schoharie, NY
12157 26 February 2007 Mr. Kent P. Sanders, Deputy Regional Permit Administrator, NYS Dept. of Environmental Conservation, 65561 State Highway 10, Suite 1, Stamford, N.Y. 12167-9503 Re: Cobleskill Stone Products Inc. DEIS Dear Mr. Sanders: I offer the following comments on “Draft Environmental Impact Statement Cobleskill Stone Products Inc. Schoharie Quarry” (hereafter “DEIS”) dated December 2005 and March 15, 2006, before the New York State Department of Environmental Conservation in the matter of a permit application. I am an amateur historian. I am editor of the Schoharie County Historical Review, the semi-annual publication of the Schoharie County Historical Society, and co-author with my wife of Sloughters’ History of Schoharie County. Project opponents in the Save Our Schoharie organization asked me to review the DEIS from a historical perspective and comment if I felt so inclined. I regret to report that I find the DEIS to be seriously deficient in regards to the historical assets of the village of Schoharie, and that I feel the deficiencies call for comment.
DEIS
CONTENT IN REGARDS TO EXISTING HISTORICAL ASSETS DEIS states that Columbia Heritage LTD identified all historic areas and structures, using OPRHP files, published sources, a pedestrian reconnaissance within the project area. It states that a list of the structures appears in Appendix E. (3.2.5.2.1) It recognizes historic significance of the Palatine House[1] (Appendix E, page 3) and the spring there (4.1.4.2.2); recognizes that historic structures could be impacted by blasting (4.2.2.2); and assesses visual and blasting impact, concluding there is no significant impact (4.2.4.2). It further states (4.2.5.2) that the expansion area is further from the village center than the existing quarry and the primary crusher will be moved farther from the village center. Appendix E parades an array of photographs of houses. It lists structures that have a view of the quarry site, records native American sites and artifacts, and lists one single historic structure, the Palatine House. “The frame residence located adjacent to Warner Hill Road in the western portion of the property meets the minimum age requirement for inclusion on the State and National Register of Historic Places and was documented as a part of this study. Twenty additional structures, all residences, that meet this requirement were noted within the project view shed. They were photodocumented and placed on a keyed project location map included in an appendix to this report. No sites currently listed or determined eligible for listing on the State or National Register lie within or adjacent to the project area or have a view of the proposed action and numerous structures currently listed or determined eligible for inclusion on the State and National Register are located below, within the Village of Schoharie. None of these has a view of the proposed mine modification” (emphasis added). The National Register-listed Old Lutheran Parsonage (90NR2687) lies approximately 0.4 miles (0.6 kilometers) southwest of the study area, and St. Paul’s Cemetery (01NR00839) adjoins the parsonage to the northwest Lasell Park, just to the northwest of the proposed modification parcel, contains the Palatine House museum. (Appendix E, page 3). DEFICIENCIES
IN DEIS ANALYSIS OF HISTORICAL ASSETS Columbia Heritage may have identified all the historic or potentially historic structures but the DEIS fails to list them. The Palatine House, cemetery and twenty residences are the only mentioned historic structures and the twenty are not listed. No historic structures in the village of Schoharie are listed. Among many omitted historic structures are two that are listed on the National Register, the courthouse (NR No. 95001010) and Lasell Hall (NR No. 01001444). Also omitted are these buildings which I believe are all eligible for listing on the Register: Presbyterian Church, Parrott House Inn, Health Department Building, and Reformed Church. Many individual residences are also likely for listing. The DEIS takes the position that the expansion area is farther from the center of the village than the existing quarry (4.2.5.2) and that since blasting is permitted and will continue at the existing quarry, its relocation and the proposed mitigation will benefit the community rather than adversely impact it. (4.2.5.3) The center of the village is not downtown and not near the above listed buildings. The center of the village is at or near the county Highway Department garage approximately 2,500 to 3,000 feet north of the downtown area that many people may consider to be the center of the village. All the downtown historic resources will be closer to the new blasting area than they are to the existing quarry. The center of the existing quarry is about 3,750 feet from the heart of the village and the center of the expansion area is about 2,750 feet from the heart of the village. See Map 1 in the Appendix.
Table 1. Distances, in feet, of historic resources from the
existing quarry (Old) and the expansion area (New). The blast area will move
900 to 1,500 feet closer to the resources – 46 percent (Palatine House) to 23
percent closer (Reformed Church). I am confident that the consultant was not trying to slant the report by omitting these historic resources; rather, it is apparent to me that the work was not very thorough. The newest sources cited are the consultant’s own 1992 study and a 1972 State Museum bulletin. Other outdated publications cited are the 1950 “Groundwater Resources of Schoharie County” and the 1967 USDA Soil Survey. These are standard references that a consultant would be likely to have at desk side. While it is important in science to have current information, in history we often must consult older works. The consultant apparently did not consult Brown’s, Simms’s, Roscoe’s, Sias’s, Noyes’s or Hendrix’s histories; or the Schoharie County Historical Review which has been published continuously since 1937; all available in a variety of libraries. Nor were the town historian, nor the county historian consulted. Instead, it appears that the consultant did a desk-side literature review and visited the applicant’s subject property, calling the visit a “pedestrian reconnaissance.” A pedestrian reconnaissance down Main Street would have revealed the presence of the aforementioned buildings. DEIS
COMMENTS IN REGARDS TO IMPACT ON HISTORICAL ASSETS DEIS maintains repeatedly that there will be no significant impact on the community. “The Schoharie Quarry is a significant, well-established part of the community. No significant potential impacts to the community can occur. Overall, the modification area will be located further from the village center than existing operations…. the proposed mitigation measures adopted as part of this application will insure that the operation of the modification area will reduce the potential impacts of the existing operation even further. The modification area will, thus, be better screened, produce less noise, less dust and will be less visible than the existing quarry.” (4.2.5.2) “No measures beyond those planned to mitigate the other potential impacts are required. The Schoharie Quarry is an integral part of the community. . . .The relocation of the primary crusher and the use of field conveyors in place of haul trucks will serve to further reduce the impact of the operation.” (4.2.5.3) “No significant impacts can occur since the Schoharie Quarry is part of the community and all aspects of the planned modification area is equal to or superior to that of the existing operation.” (4.2.5.4) QUARRY
EXPANSION PROJECT IMPACT ON HISTORICAL ASSETS The DEIS claims are humorous in light of what DEIS admits, and ludicrous in light of the facts not addressed in the DEIS. The DEIS admits there are historic structures in the village and that historic buildings could be impacted by blasting and visual changes (4.2.2.2). It addresses them in sections 4.2.2.1 and 4.2.4.2 claiming no significant impacts. DEIS admits that blasting impacts air overpressure, ground vibration and causes fly rock (4.2.4.2.2). It admits blasting will cause noticeable vibration at the Palatine House and other structures (4.2.4.2.2.1.1). It admits that air overpressure can crack glass (4.2.4.2.2.2). It says blasting has been done at the Schoharie quarry for decades with “no significant adverse impacts to any of the off-site structures” (4.2.4.2.1) and so the DEIS concludes that the planned mitigation measures for ground vibration, air overpressure and flyrock “will prevent significant blasting impacts from occurring… No further mitigation is needed” (4.2.4.2.4). DEIS is void of any engineering analysis demonstrating that the impact of blast through the existing rock types will be no different at the proposed 2,000-feet distance than at the present 3,000-feet distance. Is that because there is a difference? The document also fails to address cumulative incremental damage.
The DEIS, and many other assessments, do not address incremental damage that occurs over the years from repetition of seemingly harmless activities. We have recognized incremental damage in archives and libraries for years. For example in the handling of rare books, the user is generally expected to wear gloves and they are routinely provided. This is to prevent the oils of the skin from despoiling the document. As another example, we are increasingly finding that we are not allowed to photocopy some old documents because repeated exposure to light shortens the document’s lifespan. I propose that incremental damage occurs with every blast, and shortens the lifespan of buildings and other nearby resources. Accumulated incremental damage from blasting, earthquakes and natural ground movement in Schoharie has caused limestone building block to crack. I offer in Appendix 1 a series of photographs of limestone building blocks cracked by cumulative incremental vibration. The blocks are in the historic courthouse less than 1,000 yards from the new blast zone. The cracks were pointed up with a dark mortar or grout during the major renovation and restoration of the building a few years ago and are therefore clearly visible. MITIGATION
OF POTENTIAL DAMAGE Let us address the issue of mitigation. The DEIS states that Cobleskill Stone will use Bureau of Mines guidelines and recommendations, and best practices; and that these will prevent significant impact on structures. I submit that government guidelines and standards, and best practices, often prove to be inadequate if not dead wrong. I cite nautical engineering and best practices which sent the RMS Titanic to sea 14 April 1912 with a wholly inadequate number of lifeboats, not to mention a false sense of security. I cite aeronautical and space engineering which on 27 January 1967 filled the Apollo 1 capsule with oxygen in the training exercise that burned three astronauts to death. I cite nuclear engineering best practices, and federal regulation and oversight that allowed the Three Mile Island accident and near meltdown to occur on 28 March 1979. I cite aeronautical and space engineering, and best practices, which included using O-rings to contain fuel in below-freezing temperatures on the spaceship Challenger, on 28 January 1986. I cite careful government agency scrutiny and regulation as well as best aeronautical and space engineering practices which determined heat shield tiles were securely affixed to the spaceship Columbia on 1 February 2003. I cite Army Corps of Engineers design, maintenance and best practices in the operation of the levee system at New Orleans in August of 2005. I cite the City of New York’s best practices in dam operation and maintenance in the sudden discovery in 2005 that the Gilboa Dam at the Schoharie Reservoir was at the brink of failure and in serious need of emergency repairs due to damage from the major flood of 1996. And I cite the New York State Department of Environmental Conservation for failing to determine the perilous condition of that dam, or to cause the city to determine the extent of damage, during the nine-year period before it actually was discovered. I submit that government guidelines and standards, and best practices, often prove to be inadequate if not dead wrong. FAILURE
TO ASSESS ALTERNATIVE LOCATIONS The Schoharie Valley is lined with a vast amount of limestone. Stone necessary for engineering works can just as well be mined at locations more distant from historic assets instead of closer to historic assets. The DEIS fails to consider obtaining stone from alternate locations in Schoharie Valley. CONCLUSION It is clear that the DEIS is deficient in addressing the historic resources in the village of Schoharie. It is clear that the DEIS misrepresents the proximity of historic resources to the new blast zones by saying the new blasting areas are the same distance from the center of the village as the present, when the center of the village is a red herring far from the historic downtown structures. It is clear that the DEIS admits there will be impacts and fails to identify all the impacts or the severity of the likely impacts. It claims that “best practices” will mitigate the impacts when in fact best practices are often inadequate. FACT: Many historic assets will be adversely impacted by this project. FACT: These assets are irreplaceable. FACT: Miles and miles of limestone line the Schoharie Valley. PROBABLE: The impacts of mining at the proposed location will, in the long run, accelerate the deterioration of significant irreplaceable historical assets. There is only one reasonable alternative: deny the permit. The valley and its stone are dozens of miles long. The quarry can expand at distances farther from, not closer to, the irreplaceable historic assets of the village of Schoharie. The option of mining other locations in the Schoharie Valley is not been addressed in the DEIS. Applicant’s purchase of the site in question was a speculative investment at best. Applicant could sell the parcel and replace it with one more suitable.
Lester E. Hendrix
APPENDIX 1 Photo 1: Schoharie County Courthouse Photos 2-4: Repaired Cracks Schoharie County Courthouse Stone Map 1: Location of Quarry in Regards to Historic Assets
Photo 1. Schoharie County Courthouse. Cracks visible in second from bottom row of stones to left of the tree are also shown in photo 3. Cracks visible to left of the lower door (right) are shown in photo 4. A few years ago the county completed an expansion and restoration of the 1870 courthouse, which is an architecturally significant building. Long-standing cracks in the stone were repaired with a dark mortar or other substance. The photos were taken today, 20 February 2007. All the dark lines are repaired cracks which developed over the years, probably due to earth movement from earthquakes and blasting. I cannot but think that had the building not been impacted by something, the limestone would not have cracked. I propose to you that moving the blasting 1,000 feet closer to this and other historic structures will increase the incremental damage caused by blasting. This building is about 3,750 feet from the center of the existing quarry but about 2,750 feet from the center of the expansion area.
Photo 2. Courthouse, west face near north end.
Photo 3. Courthouse, west face near north end.
Photo 4. Courthouse, west face south of main staircase and entry.
Map 1. Center of the village is distant from historic assets in and near the downtown business block. The green lines run from what may be taken as the extreme corners of the village and intersect to show the approximate geographic center of the village. Red dots locate the courthouse and the approximate centers of the village and the two quarry sites. Blue lines show the distances from the courthouse to the new and existing quarry sites The new quarry site is approximately 3,000 feet from the courthouse and the existing quarry is about 4,000 feet from the courthouse. [1]. The Palatine House is also known as the Lutheran Parsonage; the building has two names.
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