crty OFALBANY OFFICE OF THE MAYOR 24 enue STREET upaivy, NeW YORK 12207 TeLePHOMe (16) a36-5100 arity Sieeuan Naor December 7, 2015 ‘Mr. Robert L. Megna, Executive Director New York State Thruway Authority 200 Southern Boulevard P.O. Box 189) Albany, NY 12201-0189 Me. Basil Seggos, Acting Commissioner "New York State Department of Environmental Conservation 625 Broadway ‘Albany, NY 12233-0001 Re: Lead Agency status on Pilgrim Pipeline proposal Dear Mr. Megna & Commissioner Seggos, ‘The City of Albany isin receipt of the New York State Thruway Authority (“Thruwey Authority") letter dated November 16, 2015 declaring intent of the Thruway Authority to assume lead agency status onthe Pilgrim Pipeline proposal, within the meaning of New York's State Environmental Quality Review Act (“SEQRA"). As your letter indicate, the City of Albany is an involved agency for this proposal. After reviewing the preliminary draft environmental impact statement ("EIS") dated August 2015, prepared by the project sponsor, Pilgrim ‘Transportation of New York, Inc. ("Pilgrim New York”), the City of Albany respectfully requests designation ofthe New York State Department of Environmental Conservation CDEC") as lead agency fortis project.In support of this request, the involved agencies and their respective jurisdictions as {destitied in section 1.5 ofthe preliminary draft EIS, on table 1.5-1, pages 1-15 to I-17, and ‘maps presented in figures 1-2 through 1-S (attached), are hereby incorporated by reference. All relevant information forthe DEC Commissioner's consideration of lead agency is contained within the preliminary draft EIS, which is being provided to DEC with this letter. This request for DEC to assume lead agency status is supported by several factors, including but not limited to the following: (1) While the majority of the pipelines” path would be located on Thruway Authority ‘property the anticipated impacts of the action under consideration are primarily Statewide. The preliminary draft EIS identifies many environmental areas of concern that are not located on Thruway Authority property, including but not limited to construction and operation within “sites of concern” (EIS pages 3-29 to 3-31), clean water aquifers (EIS pages 3-36 to 3-48, including table 3.1.3-3, identifying public water supply wells within approximately one mile of project mainline), endangered species, agricultural resources (EIS pages 3-187 to 3-193), and DEC designated state visual resources (EIS page 3-222). Significant environmental impacts are presented at length in section 4 of the preliminary draft EIS. (2) DEC has the broadest governmental powers for investigation ofthe impacts of the proposed actions,notably, the identification of environmental justice areas (EIS pages 3- 209 t0 3-214, with maps presented as figures 3.2.4, 3.24-2 and 3.24-3), including one inthe City of Albany, which requires public notice and hearings associated with ‘mandatory scoping under current DEC poly. Iti our understanding that scoping would ‘not be mandatory were the Thruway Authority to assume the role as lead agency. Based ‘on past experience inthe City, we believe itis imperative o include the environmental justice process in the scoping (@) DEC has greater experience for providing the most thorough environmental assessment of the proposed action. Lead agency determination should not be made ‘merely on the basis that much of the proposed work will be on Thruway Authority property, as indicated inthe Thruway Authority etter dated November 16, 2015. For these reasons, we believe it State, to designate DEC as lead agency. in Albany's bes interest, and the best interest ofthe All comments regarding the request of DEC to assume lead agency status must be ‘submitted to the DEC commissioner within ten (10) calendar days after receipt ofthis request Furthermore, @ review of the preliminary draft EIS supports a positive declaration within the ‘meaning of SEQRA at this stage. Sincerely, Kathy M, Sheehan Mayor, City of AlbanyFederal Highway Admiistation FHWA) USS. Army Corps of Engincers (USACE) USS. Fish and Wildlife Service (USEWS) US. Department of Treasury ~ Buea of Alcool, Tobacco and Firearms US. Department of Transportation (USDOT), Pipeline & Haz. Materials Safety Admin, (PSHMA), Office of Pipeline Safety (OPS) ‘New York State Department of Transportation (NYSDOT) ‘New York State Department of State (NYSDOS), Division of Coastal Resources (DCR) New York Office of Parks, Recrestion and Historie Preservation (OPRHPYPalisades Interstate Park Commission (PIPC) ‘New York State Office of General Services (NYSOGS) New York State Department of Agriculture & Markets ‘New Jersey Department of Environmental Protection (NIDEP) ‘New Jersey Department of Transporation (NJDOT) Pilgrim Transportation of New York Ine Hon, John Clarkson. Supervisor, Town of Bethlehem Hon, Stephen D. Flach Supervisor, Town of Coeymans Hon. William Misuraca Mayor, Village of Ravena Hon. Daniel J. Dwyer ‘Mayor, City of Rensselaer Hon, Keith A. Langley Supervisor, Town of East Greenbush Hon. Nick Dellisanti Supervisor, Town of New Baltimore Hon, Richard K. Hanse ‘Supervisor, Town of CoxsackieHon. Christian Pfister ‘Mayor, Village of Athens Hon, Joseph M Leggio Supevisr, Town of Catskill Hon, Greg Helsmoortel ‘Supervisor, Town of Saugerties Hon, James E. Quigley Supervisor, Town of Ulster Hon. Shayne Gallo ‘Mayor, Cty of Kingston Hon, Jeanne Walsh Supervisor, Town of Rosendale Hon. Paul Hansut Supervisor, Town of Lloyd Hon. Kyle Bamett Supervisor, Town of Esopus Hon. Susan Zimet Supervisor, Town of New Paltz Hon, Joseph G. Croce ‘Supervisor, Town of Plattekill, Hon, Stephen Osborn Supervisor, Town of Marlboro Hon, Gil Piaquadio ‘Supervisor, Town of Newburgh Hon, Judy Kennedy Mayor, City of Newburgh Hon. George A. Green Supervisor, Town of New Windsor Hon, Randy Clack Supervisor, Town of Cornwall Hon. Ralph Caruso Supervisor, Town of Woodbury Hon. Stephen H, Welle ‘Mayor, Village of Harriman,Hon, Michael Rost ‘Supervisor, Town of Tuxedo Hon, Mary Jo Guinchard Mayor, Village of Tuxedo Park Hon, Christopher P. St, Lawrence Supervisor, Town of Ramapo Hon, Craig M. Flanagan, J. Mayor, Village of Hillburn