Sunday, February 05, 2006
The Hidden Forest "Draft Final" EIS Scoping Document appears to be deficient in several areas. While SEQR permits considerable flexibility in the format of the Draft and Final EIS; the organization of the Hidden Forest "Draft Final" scoping document is such that essential components of an EIS are missing or obscured. For example, rather than present project alternatives early in the document, as would be done for a Federal (NEPA) EIS, the project alternatives are located at the back of the document, and are not the focus of the study. Mitigation and monitoring for each proposed alternative (which seem to focus on traffic design and the number of housing units, rather than the overall project spatial footprint) are not specified. A summary of impacts by alternative is not included. The scoping document does not indicate that an alternatives matrix (an important EIS component) will be developed for the draft EIS. According to NYSDEC, one of the purposes of the SEQR scoping process is to provide an initial identification of mitigation measures for antipated project impacts. This is not provided in the scoping document, and normally would be a component of the alternatives analysis, had the document been organized such that the project alternatives were highlighted. Finally, the emphasis of the scoping document is heavily weighted towards traffic and socio-economic impacts. These two categories of impacts are presented in considerable detail, relative to impacts to natural resources (wetlands, wildlife, soils, hydrology, etc.).If this is because information on these study components is lacking and requires further data collection/environmental studies, it should have been stated in the scoping document, as identification of the extent and quality of information required to complete the EIS is also specified by NYSDEC as a primary objective of the SEQR scoping process.