Monday, May 27, 2013

Big Tupper Resort Amphibian Study: Science After The Fact

Michael Klemens sampling for amphibiansWhile it has not attracted much attention yet, Preserve Associates has hired some biologists to conduct an amphibian study this spring to determine the presence of amphibians on some, but by no means all, of the lands proposed for subdivision and development at the permitted Adirondack Club and Resort (ACR) site in Tupper Lake.

According to APA correspondence, this survey is taking place or has recently taken place within 800 feet of all wetlands on seven of the small eastern great camp lots, and along Lake Simond Road Extension and the proposed but not yet developed Bypass Road.

This expenditure of money by ACR reflects a condition in the Adirondack Park Agency permit issued in January 2012 that after-the-fact biological surveys for amphibians only must be approved by APA prior to commencement of the development, with a goal of locating the presence of salamanders and frogs and their habitats, determining migratory pathways, and then planning for possible mitigation measures for the housing, driveways and roads to be developed within the Resource Management lands- so that these vulnerable animals and their habitats are not simply run over, literally and figuratively.

When other surveys for amphibians will take place on the many other lots intersecting 800 feet away from wetlands on Resource Management across the ACR’s 6200 acres is not clear, but it appears that this work will be done according to the phases of development approved by APA in 2012.

Why the amphibian study? In Adirondack Wild’s opinion, there would be no permit condition to perform any wildlife studies at all were it not for the testimony of expert witness Dr. Michael Klemens, who is a herpetologist (specializing in the study of amphibians and reptiles). The abysmal failure to conduct a broadly scoped wildlife study on the property before final project design and the hearing is still playing itself out.

After the fact biological surveys are useless for re-designing ACR to avoid or minimize significant biological impacts – contrasted with mitigation measures through expensive re-engineering of roads, culverts, curbs and drains which pose a virtual obstacle course for small amphibians. That is because the subdivision design of ACR (over 700 dwelling units, miles of roads and driveways, etc) that went to public hearing in 2011 was bereft of any serious biological survey information despite passage of seven years of pre-hearing discussions with APA and “mediation” with stakeholders. The applicant provided no biological information because for seven years they never seriously looked for birds, mammals, amphibians, plants…for anything at all. The only wildlife information in the application came, according to ACR’s own lead witness, as a result of casual observations incidental to other consultant work taking place.

This lack of information was made painfully obvious at the Ray Brook and Tupper Lake hearings, and is fully corroborated in the hearing record. The lack of serious biological data should have been the basis for APA’s denial of the application because without such data how could the APA determine there were no “undue adverse impacts”? But that is a question for the courts. As many readers know, there is a lawsuit pending which challenges the permit on these legal grounds and others. ACR must also obtain a lot of other permits from NYS DEC (at least four DEC permits are needed), from the U.S. Army Corps of Engineers and from NYS Dept. of Health. All of these applications remain incomplete according to APA documents.

So, regarding the ongoing amphibian study, documents suggest that two biologists were hired this spring in a plan approved by APA – one supervisory, and one in the field – to conduct an amphibian survey over a ten day period on just a limited number of lots and roads in Resource Management during late April to mid May.

It remains to be seen if these biologists are up to the task in terms of their competence, the integrity of their work, the amount of effort expended, and over what seasons or of what time duration. It also remains to be seen if the “mitigation” measures the consultants and developer come up with at the behest of the APA– again, assuming ACR moves forward at all – are meaningful in terms of the survival requirements of these creatures. However, as noted herpetologist (amphibian and reptile specialist) and Adirondack Wild expert witness Dr. Michael Klemens noted at the ACR hearing, obtaining some biological information is better than obtaining no information. We wish this survey work well and hope the information it uncovers will be accessible to the public.

Dr. Klemens in one day and rainy night of investigation on just a few miles of the public roads at ACR documented eleven species of amphibians migrating to their breeding ponds on April 25, 2011. This information was entered into the hearing record. Even with the minimum pre-ACR traffic existing in 2011, many were found DOR (dead on road). I do not believe that the areas Dr. Klemens and Adirondack Wild investigated over a 12 hour period in 2011 are even part of the APA’s after-the-fact requirement for a formal and comprehensive survey because they fall within the Moderate Intensity Use land use classification. Needless to say, the wetlands and amphibians do not care what land use classification they inhabit.

I felt it might interest readers to include some of the testimony related to biological studies during the ACR public hearing. Adirondack Wild’s expert is not only a herpetologist and conservation biologist, but also a landscape planner and chair of his town’s planning board outside of the Park. His testimony and responses to cross examination were central to APA’s understanding of basic criteria for conducting a biological survey of Adirondack Club and Resort – whether before the fact of permit issuance or after.

Dr. Klemens points to how development impacts biologically sensitive sites at ACRIn his testimony, Dr. Klemens repeatedly warned against conducting after-the-fact studies because a fundamental principal of conservation biology is to avoid or minimize ecological impacts before you are forced to attempt to mitigate them. Logic dictates that avoiding or minimizing such impacts can only be done before the fact of final project design and certainly before permit issuance. The improper course APA chose to take in its biased review of the hearing record and in issuing a permit leaves only mitigation as a possibility, a doubtfully effective and possibly expensive option. Yet APA’s permit only allows “non-material” changes to the approved project design, irrespective of what this biological survey comes up with. This restriction certainly hampers amphibian protection.

Anyway, here is the part of the hearing testimony and cross examination of Dr. Klemens and others which is at least relevant to the current amphibian study going on in Tupper Lake, and relevant to other studies the APA should be requiring of applicants elsewhere in the Adirondack Park.

Ms. Tooher asked Dr. Klemens (June 7, 2011, pg.3184, lines 5-22 of the ACR hearing record): “So if you were trying to do a full evaluation of amphibian life on the property, how extensive a timeframe would you need?” He replied: “I think given the size of the property if you had a team of biologists, you probably could get the amphibians wrapped up in one or two seasons. It’s a matter of getting enough people on the ground. It’s pretty labor intensive, but you could use other techniques and really concerted. You could get a really clear picture of a lot of the fauna in about a two-year study of this property. But even a one year would give an awful lot of information. I mean look what I got in a few hours.”

Dr. Michael Klemens wrote in his prefiled testimony, “it is not in the lead agency’s responsibility, nor is it in the public’s interest to condition a defective and data-deficient application in an attempt to make it whole. Rather, the application should be denied without prejudice and the applicant provided with specific directives on what information is missing, and in the manner that it should be collected and submitted with a de novo application to be reconsidered” (page 19, Klemens prefiled testimony).

Paul Van Cott cross-examined Dr. Klemens on June 7 (pages 3141-3142, lines 5-24, and 1-7, ACR hearing record).

Mr. Van Cott:” If the Adirondack Park Agency were to approve the project as proposed, do you have any thoughts about studies and/or mitigative measures that the Agency might consider employing after the fact relative to this project?”

Dr. Klemens replied: “Well, as I’ve testified before and I’ll reiterate again, I mean as you don’t know the critical areas on the site, it’s very hard to approve something and then go out and discover that what you’ve approved is right in the middle of — for example, of amphibian pathways. So the proper prudent way to design the site such as this is to understand the biological resources, beyond the amphibians, all the biological resources where the areas of use are and then design a development that protects that interconnected ecological balance on the site by avoiding. It’s sort of going in backward in a sense. And also if you approve something, you may have to end up redoing half of it based on the biology if not more of it. It just isn’t a prudent way to go about designing a development of any kind, especially a development of this size, without any biological information. You really have to do that first.”

Dr. Klemens was asked by Mr. Plumley (April 27, pgs. 1188-1189, lines 9-24 and 1-15) if conditions should be attached to a permit that would require natural resource assessments to be made after the fact of permit issuance.

Dr. Klemens replied: “So my advice and the advice of attorneys that I’ve worked with- again not here, but further downstate — has been that it’s really not an agency’s obligation — they’re not really serving the public interest to condition a defective application to make it whole. And it’s really kinder to all those involved is rather to deny the application without prejudice and give really clear instruction. And that gets to the other thing — clear instruction to the applicant – about the kind of studies and information, because in the applicant’s perspective, they don’t get a lot of guidance often at the beginning. So that’s the advice I give my municipal clients, the towns I work for is that you can’t make a poor application correct through conditions, but you can deny it without prejudice, and you can provide very, very clear guidelines in all fairness to the developer or the applicant on the kind of studies that are needed to remedy it, and then we hear it again without prejudice.”

Mr. Ulasewicz asked Dr. Klemens on June 7 (pgs 3176-3177, lines 7-23, hearing record): “are you familiar with any fish- and wildlife-friendly construction techniques that might be used to help mitigate wildlife such as the amphibians that you’ve discovered on these roads?”

Dr. Klemens replied: “Well, the first step toward any sort of thought process there is avoidance. You have no information to do any avoidance, so the first — so before I would say yes you can create mitigation, but mitigation comes after avoidance which is based on information, then minimization and then finally mitigation. So, again, yes, you can mitigate certain impacts but one of the primary ways to mitigate the impact is to avoid certain areas. Absent information of where these animals are, the most important part of — is the avoidance part you really can’t do. And that sort of speaks to, I think, when Mr. Van Cott was asking me also about post — post-development studies. The first step is avoidance.”

Spotted SalamanderIn reply to a question about ecological disruption from the project asked by Ms. Tooher, Dr. Klemens replied (pgs. 1067-68, lines 15-24, 1-2): “There are large zones of influence on wildlife which will be disrupted by the project. People look at wildlife. They think wildlife moves in corridors. Wildlife moves across the landscape almost like sheet flow of water. There’s movement all through the landscape. And that continues for some species, less effectively in a logged landscape, but it continues, and there’s recovery. Once you put on a hard landscape of roads, development, and other amenities, you fragment that sheet flow of wildlife and organisms across the landscape.”

Dr. Klemens continued: “I would anticipate based on my rapid amphibian assessment that there would be at least fifteen species of amphibians breeding on the site. For their small size, amphibians pack an ecological wallop because they control so much of the energy transfer in and out of ecosystems. Amphibians are bi-phasic, meaning that they breed in vernal pools and move to uplands the rest of the year. Wetland protection alone will not protect these species. The habitats of these animals are linked to uplands.”

Dr. Klemens was asked whether the existing ACR design constituted a satisfactory model for development in RM where the law mandates protection of “delicate physical and biological resources.” He answered, “no” (Klemens prefiled testimony, pgs 6-7). The design “completely ignores the interdependency between wetlands and surrounding uplands that most wildlife requires. What sense is there in protecting the wetlands where these amphibians return to breed one month each year, while destroying the upland habitat used for foraging and hibernation for the remaining eleven months of the year? How could such an approach be considered protective of the delicate physical and biological resources?”

Dr. Klemens supplemental testimony (Exhibit 208) concludes: “A comprehensive amphibian study would provide much additional information and would enable prioritization of areas essential for amphibian survival. This is especially important as amphibians form a huge biomass component of the site, and have complex habitat utilization which spans both wetlands and non-wetland habitats. Certainly this speaks to the protection of the delicate ecological interconnections of the ACR site.”

Asked by Ms. Tooher about buffers that might protect amphibian habitats (April 27, pg. 1086, lines 4-24), Dr. Klemens replied: “The conservation strategy basically on those pools is to obviously leave the wetland intact, leave the first hundred feet, which is known as the vernal pool envelope, intact and then protect seventy-five percent of what’s called the critical upland habitat zone. That is the zone that is one hundred to seven hundred and fifty feet from the pool where ninety-five percent of the population of amphibians resides. You could develop up to twenty-five percent of that…There’s a whole methodology that you can develop sensitively using this approach in these areas. It’s not a prohibition against development, but it’s an intelligent application of where to develop and how to use these best development practices.”

Building upon Dr. Klemens’ testimony, APA expert witness and resource analyst Dan Spada produced a map (Exhibit 244) of potential amphibian upland habitats extending 750 feet out from mapped wetlands and potential vernal pools west and just east of Read Road within the Resource Management area. Mr. Van Cott asked Mr. Spada about the significance of areas 100 and 750 out from the edge of identified wetlands and breeding areas for amphibians.

Spada answered (June 23, page 4048, lines 7-18): “These zones, the one hundred foot buffer and the seven hundred fifty foot buffer comport with the literature out there that describes the critical habitat area for amphibians. It doesn’t include all of the habitat that amphibians may occupy. It includes critical habitat for a bulk of amphibians. And so this helps to analyze the impacts to those organisms which spend at least a portion of their life cycle — and a critical portion of their life cycle. It goes back to wetland protection, protecting the value and function of fresh water wetlands.”

Mr. Van Cott then asked Mr. Spada to identify whether any of the Great Camp lots and their development envelopes lay within that seven hundred and fifty foot buffer within resource management. Mr. Spada answered (June 23, page 4047, lines 1-16): “Yes, I can do that. Lot Three, Lot Twelve, Lot Seven, Lot Thirteen, Lot Fourteen, Lot Fifteen, Lot Twenty, Lot Twenty-one, Lot Nineteen, Twenty-eight, Lot Twenty-nine, Lot Thirty, Lot Thirty-one, and Lot F. In addition, the west face expansion. Q. In its entirety? A. No. The southwesterly portion of west face expansion. Yeah, all but four units.”

In all, Mr. Spada easily identified about 44 Great Camp and West Face Expansion lots in Resource Management which would encroach upon and both directly and indirectly impact the upland habitats of sensitive wetland species of wildlife which spend the bulk of the year in upland habitats adjacent to their breeding ponds. “It includes critical habitat for a bulk of amphibians,” Spada said. The map “helps to analyze the impact,” he noted.

Photos: Above, Michael Klemens sampling for amphibians; middle, Dr. Klemens points to how development impacts biologically sensitive sites at ACR; below, spotted Salamander.

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Dave Gibson, who writes about issues of wilderness, wild lands, public policy, and more, has been involved in Adirondack conservation for over 30 years as executive director of the Association for the Protection of the Adirondacks, executive director of Protect the Adirondacks and currently as managing partner with Adirondack Wild: Friends of the Forest PreserveDuring Dave's tenure at the Association, the organization completed the Center for the Forest Preserve including the Adirondack Research Library at Paul Schaefer’s home. The library has the finest Adirondack collection outside the Blue Line, specializing in Adirondack conservation and recreation history. Currently, Dave is managing partner in the nonprofit organization launched in 2010, Adirondack Wild: Friends of the Forest Preserve.

30 Responses

  1. Mark says:

    Dave Gibson of Adirondack Wild and his radical friends at Protect the Adirondacks represent the extreme fringe who for years cheered the decisions of the APA but now denegrate the same agency after it took eight years to review this project and approved the ACR permit with a 10 to 1 vote. We are tired of the whining. It’s time to move forward. The amphibians are smart enough to adapt. Are the radical enviros?

    • Alan Senbaugh says:

      “The amphibians are smart enough to adapt.” It’s fine to have the opinion that the project should move forward but don’t make ignorant statements like this. It makes you sound stupid.

      • Mark says:

        Did I upset your sensabilities Alan? As a resident of Tupper Lake I am tired of the do gooder enviros who have overstayed their welcome with regards to the project. I support the working men and women of Tupper over a few salamanders and frogs. I don’t care who I upset in supporting the economic welfare of our town.

        • Alan Senbaugh says:

          I tend to agree with you. However, moronic statements like yours makes those of us in favor of the project sound like hicks.

          • Mark says:

            “Stupid” and ” moronic” . You have a real flair for the English language Alan. So what is your purpose for posting?

            • Alan Senbaugh says:

              It is funny that you are far more educated than I am. No one would know that meeting us both but it is true.

  2. Tom Vawter says:

    Amphibians, as a group, appear to be in trouble worldwide. A recent study shows that the situation in the United States is evn worse than previously thought.

  3. Michael Smith says:

    Somehow I suspect that no amount of study, either before or after, would have been sufficient for die hard opponents of the project. Identifying travel corridors would be helpful to modify roads and other features but if the travel is like sheet flow, then it doesn’t make much difference anyway. As for me, I think that redirecting high-end development from the waterfront to the uplands, especially in distressed communities is a good idea.

  4. Tom is on the mark. The study to which he refers has received some nice media coverage, but by no means all that it is deserving of. Regarding the Tupper Lake “development,” the minute a dozer starts pushing earth in the process of making a “new” road and thereby fragmenting habitat and likely killing some herps (like salamanders, outright), there will be an impact.

  5. Paul says:

    I don’t think there is any argument that there will be impact. I am curios to know what the alternate designs are that Dr. Klemens would suggest. Dave, I think you said he is also a planner as well as a scientist.

    “I think that redirecting high-end development from the waterfront to the uplands, especially in distressed communities is a good idea.”

    I think that in the ACR projects they decided to not develop any of the Raquette riverfront property on the site and leave it as it is. Not positive. But Michael I have also seen Dave write articles on the problem with upland development so maybe there are very few remaining places where you can build based on some of the environmental criteria.

  6. Paul says:

    Dave, I should clarify. I understand that Dr. Klemens did not have an opportunity to do an in-depth (I think it looks like a well funded and manned year long study would be the minimum) study so he could not give us specific design suggestions. But what do you do? Make sure you don’t pave the road or is there some kind of culvert? What other studies and organisms should be part of a good project plan and what is the cost and the time frame. One or two years might be sufficient for animals with a short life span like frogs, I would assume for larger mammals you would want to study them for decades at least, maybe longer?

    • Dave Gibson says:

      Paul, thanks for your questions. A good project plan would have started with a comprehensive (inclusive of amphibians, but much more as well) wildlife survey and assessment of the ecology of the 6200 acres, and of course how it lies within the larger landscape. Beyond wetlands, steep slopes, stream corridors which the obvious features that can’t be developed there are all kinds of sensitive habitats and ecological transition zones listed in the APA regulations which APA has full authority and responsibility to have studied and evaluated – so that when it makes a decision about whether or not there are “undue adverse impacts” from the subdivisions the agency has a pretty good handle on what is living and growing there. That work could have been done over two years. It was never done over the course of 7 years before the hearing began. Why? the applicant simply refused to do it from 2005-2007 after the agency asked for the information three times because it was required as part of a complete application. Then, lacking that information, politics dictated that the application be deemed complete in 2007. From 2007-2010, the agency still could have placed effective pressure on the applicant to do this work before any hearing began, but it did not. Thus a good part of the 2011 hearing was spent debating the lack of information instead of how good the information was.
      Several hearing witnesses offered good ideas for redesigning ACR, none of which the Agency fully reviewed in its evaluation before making a decision.

      • Paul says:

        Dave, thanks. Yes, I get all that history and the “political” stuff. So was there a fairly simple re-design that could have addressed this issue? Were those evaluated for impacts on the economics of the business plan? I think in this particular case since the APA wasn’t putting much pressure on ACR to do this sort of thing we can’t necessarily blame the developer. Although you would hope they would want to look at this. I think that many potential investors could be interested in being able to market this project as one that is ecologically sound. Buyers actually care about this kind of things more and more.

  7. Mark says:

    Could we have crossing guards for the amphibians? Maybe Dave Gibson and Peter Bauer and the like could form a volunteer task force complete with crossing guard uniforms.

    Mankind has an impact on the environment. We can develop with less impact but we will still disturb the environment. This is private property being developed with private investment. The project has been approved by the State of NY. Get out of the way.

  8. Realist says:

    Mark: 2:15 pm “This is private property being developed with private investment”. Don’t they have to actually buy the property to develop it? That takes real money of which the main developers appear to have none. And they actually owe huge sums to banks, the US government and Franklin County for back taxes. Given the fact that the project as proposed is dependent upon upwards of 36 Million dollars from the Franklin County Industrial Development Agency, to be paid back by the forfiture of Property,School and County tax revenue, I wouldn’t characterize it as “private investment”.

    • Mark says:

      The project received a 10 to 1 vote and it deserves to succeed or fail on it’s merits. That is how the free market works. With regards to the IDA, the project is not dependent on those bonds. If they did usd the IDA it’s important to note that those bonds are bought by privste investors. Ask our mayor, our town supervisor and school superintendant if they support the project. All three do.There is no risk to the village, town or county taxpayer. With regards to school and property taxes, the vacant land generates less than $200K per year which is a fraction of what it could be.

    • Paul says:

      This is all totally irrelevant to the question of permitting for the project. Anyone who wants can apply for a permit even if they have no clue or chance to pay for a particular project, and they deserve to get a thumbs up or down. Here they got a thumbs up but some folks think it should have gone a different way. It has nothing to do with the financial health of the developers.

      • Mark says:

        They got a thumbs up and now it’s time to move on. The environmental community tried its best to kill the project but they failed. It was a shock but perhaps the APA and DEC can manage the park without interference.

  9. Realist says:

    Mark: 9:43pm “With regards to the IDA, the project is not dependent on those bonds”. If you had actually read the Application submitted to the APA you would see clearly where it states that the project is not viable without the PILOT program. As the record shows, the Bond Counsel for the FCIDA even questions the legality of the Bond/PILOT scheme.

    ” There is no risk to the village, town or county taxpayer”? While that may be correct from a technical/legal point there is definite risk to the local taxpayers. By diverting tax revenue to pay off the Bonds instead of going to the local taxing entities, while providing services to all these new homes etc, there will be a shortfall. That shortfall will have to come from somewhere and that somewhere will be in the form of higher taxes on the existing locals.

    The vacant land that now generates less than 200K is a lot more than the taxing enetities will be getting if the Bond/PILOT scheme is used.

    • Mark says:

      By diverting what tax revenue? There is little to no revenue now generated by vacant land. Hundreds of home sites will generate tax revenue either thru traditional methods or thru a pilot program. The net gain is clearly to the town, village and school system which will absorb few school age children. Your disbelief won’t change the math.

  10. Realist says:

    Mark, “What tax revenue?” Exactly! Hundreds of home sites will generate tax revenue but as proposed the local taxing entities won’t see any of it until the debt service on the Bond is paid each year. That’s the problem with the proposed financing of this project.
    If you don’t get that concept then you really need to go to the application and the formal record from the Hearing and sit down and read it.
    As proposed the debt service on the bond will be over $900,000./yr and that needs to be paid before any local taxing entities get a nickel. At the present tax rate of about $20/$1000 that will require 47 Million in sales just to make the bond payment.
    Why any elected official would agree to such a scheme is perplexing, especially the Superintendent of the School. He really needs to do some homework.

  11. mark says:


    You need to catch up. If you’re relying on info contained in the original application you are 5-6 years behind. The project has already been approved for phase 1 as soon as the article 78 is thrown out. There have been NO negotiations with any taxing entity regarding a pilot to date. Am I going to fast for you? Call the IDA and ask about the pilot. Our officvials are for the project because they know the facts, not just tslking points.

    • Realist says:

      Mark, I can only go by what is shown in the official record from the Adjudicatory Hearing and the info I have posted is directly form that record. If you know of another financing mechanism that doesn’t involve the IDA and a PILOT please let us in on it.
      In your previous post you alluded to “hundreds of home sites will generate tax revenue”. That may be just a little optomistic given the fact that the Front Street development at the base of Gore Mountain has had an APA permit for over 5 yrs and haven’t sold a single lot/home.

      • mark says:

        Vermont resorts have been using EB-5 monies that would be available to the ACR once the appeal is struck down.

  12. Phillyrocks says:

    We could divert those frog legs into my frying pan, tastes like chicken, yummy! Seriously though, there’s thousands of undeveloped acreage in the ACR plan, and I know Mike and Tom are paying attention, let’s build a free range frog farm and ship some of those yummy legs to restaurants. What a perfect combination of conservation and capitalism.

  13. tom sciacca says:

    what many people like to forget is that extensive mitigation is front loaded into the plan. APA staffers will usually not present an plan to the board until the plan plan comports with existing laws and protective regulations (set backs from wetlands and shorelines etc)

    this is why APA approves the vast majority of applications, they are pre screened for for environmental issues

  14. LkS2 says:

    Great article, Dave. However, it comes about six years too late! Any responsible planner, designer, developer or investor knows the proper way to develop any kind of project is to determine what you have to work with before you do any detailed designs. That process was never followed in this case! The APA “requested” wildlife surveys several times over the years, absolutely no data was furnished by the developers, yet the Agency approved the project anyway. Why?

    The ACR proposal is huge and complex. Most folks have no idea what is involved unless they took the time to review the volumes and volumes of documents. Instead, many have formed opinions based upon biased, unprofessional and sometimes unconscionable local media stories.

    The so-called “enviros” have continually advocated for a properly designed and better project, not to kill or delay it as many assume. Most of the delays were caused by the developers themselves by not providing requested data in a timely fashion.

    What Dave did not conclude in his piece is that the APA approved the proposal despite the reservations and concerns of its own staff! (Mr. Spada’s comments were only one of several.) Virtually none of the information compiled by the APA hearing staff was presented to the Commissioners during their deliberations.

    The approval process is clearly flawed, particularly in this case. Our great overseer, the APA, has no idea whether or not there will be any “undue adverse impact” resulting from this project as currently designed. That is truly sad! We all deserve better.

  15. Wally says:

    Time for an update on this study.

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