Attached are the comments provided by Graham Trelstad, Senior Vice President and Director of Environmental Planning of AKRF, FASNY’s environmental and planning consultant, at Monday’s Site Plan Hearing. He comments first in response to questions about the validity of FASNY’s traffic data collection and then regarding FASNY’s interaction with United States Army Corps of Engineers.  I believe this addresses your questions regarding FASNY’s ongoing interaction with the Army Corps of Engineers that began in 2011 when work on the plan for the property commenced.

“With respect to wetlands, FASNY contacted the United States Army Corps of Engineers (USACE) in early 2011 at the very start of the environmental review and shared all relevant information with them at that time for the environmental impact assessment.

Wetland experts from AKRF used both the 1987 USACE methodology and the 1989 Inter-Agency methodology required by the City of White Plains to identify wetlands.

Using both the three parameter approach requiring presence of hydrophytic vegetation, hydric soils, and presence/evidence of wetland hydrology …

… and the more subjective and flexible standards that allow other factors to be considered…

…we identified all potential Waters of the United States (or wetlands) on the Property.

In addition to the large forested wetland area that is also a NYSDEC wetland, there is one small pocket wetland on Parcel D and one stream corridor on Parcel C.

The project will not affect any of these wetlands or their City and State 100-foot buffers. There is no required USACE buffer.

FASNY has always identified the property as being located in the Mamaroneck River watershed.

As is typical and customary during the site plan process, we have reached out to NYSDEC and USACE for their final review and concurrence.

Contrary to previous suggestions that FASNY is seeking to hide from the USACE, we are actively engaged with them as we knew we had to and is customary at this point in the process.

We are confident that FASNY has met and will continue to meet all City, State, and Federal regulations regarding wetlands, stormwater, and all other issues.

(Editor’s Note: Anne Bobroff-Hajal exposed  that the French American School had not passed its actual plans to the Army Corps of Engineers Monday evening according to the Army Corps of Engineers. She provided her notes to WPCNR of what she said in response to Mr. Trelstad’s statement on the Army Corps of Engineers situation:)

Bobroff-Hajal:

“Trelstead said FASNY had always adhered to Army Corps regulations and contacted them immediately after they bought the land in 2011.

My remarks:  YES, FASNY got in touch with ACE 3 years ago after buying the land, but that was before they had created any of their building plans.  They never contacted ACE after 2011.  They never sent ACE any of their building plans. 

When we contacted Stephen Ryba ( Army Corps of Engineers regulatory program manager in charge of FASNY review), he was grateful.  He told us that they often have to rely on citizen activists contacting them about what’s happening in local areas because otherwise they don’t have any way of knowing what developers are up to under their radar.

Trelstead denied FASNY ever tried to cover up their link to the Mamaroneck River, that they “always identified themselves as part of the Mamaroneck River watershed.”

“Watershed” is a general term that means nothing and doesn’t bring anyone under the Army Corps’ jurisdiction.  The entire city of White Plains is part of the watershed, but we’re not all under ACE’s jurisdiction. So FASNY identifying themselves that way omits the crucial element of their property.

What potentially brings FASNY under ACE jurisdiction is that one branch of the Mamaroneck River literally starts on and crosses their land (one stream begins in the pond, the other is the buried stream on the left side of the property). 

Yet FASNY has subtracted that branch of the river from all their maps that they circulate widely (buried deep within the EIS docs are one or two accurate maps, so they aren’t unaware of them).  FASNY seems to have consciously chosen to omit from their widely-publicized maps the single crucial fact that potentially brings them under Army Corps jurisdiction. 

I spoke again about the big US GIS map I brought (which I gave Mayor and Council individual copies of) which very clearly shows the river-branch accurately.  Why did FASNY eliminate this from their maps if they’re not trying to hide it?  They show all other wetland features clearly.

(Editor’s Note, 6 P.M. E.D.T.:The Mayor’s Office has not responded to the WPCNR query as to why city SEQRA consutants and Planning Department, Public Works Departments, and Legal Counsel did not suggest to The French American School that they run their plans past the Army Corps of Engineers to see if the Corps had jurisdiction .

On the subject of  protests  from speakers that Traffic issues had not been adequately studied.. Trelstad made these comments at the hearing Monday evening

“A number of issues raised at previous hearings on the Special Permit, as well as tonight, address the accuracy and sufficiency of traffic data collection and analysis have already been addressed in the FEIS.

That document contains detailed technical studies carefully reviewed by City staff and consultants. All data and analyses were determined, by City staff and consultants, to accurately and completely evaluate existing traffic conditions and potential future traffic. All data were collected on days when school was in session. While observations may have been made on days when school was out, no data collected on those days was used in the analysis. To repeat, we did not use any data collected during days when school was not in session.”