Scoping Submissions
Dover Knolls

Jill Way Scoping Comments (Former Dover Town Supervisor) |
James Utter, PhD, Scoping Comments from FrOGS |
Don Geramita | Margery Josephson, President, Naromi Land Trust |
Stancy DuHamel Scoping Comments|
Warren P. Reiss, General Counsel, Scenic Hudson, Inc.|
Jeffrey Baker, Atty. for CRGD, Scoping Submission|
Mark Chipkin for Pawling Nature Reserve Management Committee|
Christopher Wood for Oblong Land Conservancy|
Carolyn B. Handler, Pres. Coalition for the Responsible Growth of Dover|
George Nichols

On the Town Website @ www.townofdover.us
2006: Dover Knolls Final Scoping Document Related to Their 3rd Submission |Dover Knolls 4th Application Dated March 3, 2008
(including Amended DEIS Scope)

Jill Way
Former Supervisor, Town of Dover
Posted June 11, 2008 on the Harlem Valley Herald

May 14, 2008
Dover Town Board
126 East Duncan Hill Rd.
Dover Plains, New York 12522

Re:       Knolls of Dover
            Scoping Comments

Dear Supervisor Courtien and Dover Town Board:

Thank you for the opportunity to make public comments at the scoping sessions held last week. Attached please find additional comments regarding the new Knolls of Dover application.

Sincerely,

Jill Way
Ernest Way

 Scoping Comments (Refer to March 08 proposed scope)

1. pg. 2, paragraph 2….The March 2008 new application does not “respect” constraints or natural features of the site. Please refer to the Klemens et al studies.
2. pg 2, paragraph 4    “less intense residential neighborhoods” might also be considered stand alone residential subdivisions since they are not w/in a ½ mile walkable radius. They will be primarily dependent upon vehicular transportation, particularly those neighborhoods that are located on the hillsides and steep slopes. They are not easily walkable, particularly for senior citizens and children.
3. pg. 2. Paragraph 5…”distinct neighborhoods”  They might also be described as distinct subdivisions.
4. pg. 3, paragraph 5…..Please reinsert the deleted text in order to facilitate the  technical review of the project
5. pg 4, Para 1, Please delete the word “typical” and insert “proposed”.
6. pg. 5, A4…Please explain why new text has been added.
7. pg. 5, A6….Why delete the inclusion of a full title report? Please restore the original language.
8. pg. 6, D1d……Development on sensitive areas should be avoided pursuant to the Klemens et al baseline environmental assessments done to date.
9. pg. 7, 2a...Please restore deleted text. The Town Board is required to do the minimum under the law, but can protect the future of our public and ask for maximum protections of resources.
10. pg. 7, b (i) …Please restore the original text. Why not be clear about the rules that shall apply to this resource in the future?
11. pg. 7, f…..Please restore to the original text. How will the Town Board truly assess impacts without this data?
12.  pg. 8, 3a….The Town should be given any information on file and/or in the developers’ possession. Please restore the word “construction” and delete consideration.
13. pg 9,4iii…Please restore to original language. The Town Board needs a plan for the entire campus, including the buildings in order to assess the true environmental impacts.
14. pg 10, b...What does the word “extent” mean in the context of assessing environmental impacts?
15. pg 10, 5c…What percentage of workforce/affordable housing will there be and where will it be located? What will the affordable price range be?
16. pg 10, 6….A discussion of and reference to existing HVPC tunnels are removed from this section. Why?
17. pg 11, 8   Why remove references to deed restrictions & easements? The Town needs to have this information to understand the project. Please restore all of the original language to this paragraph.
18. pg 11, 9…Please restore the reference to the form based code. Joel Russell, Planner, believed it to be a necessary and valuable tool in assessing the impacts to the project.
19. pg 11, E  Please restore the deleted language. It is necessary information in attempting to evaluate true environmental impacts and possible mitigation measures.
20. pg 12,   Please restore the last sentence to this section. It needs to remain in the scope to protect the Town’s future. The issue must be addressed.
21. pg 13, d (i) – (iii) Please restore the original language. We need to know how this project is consistent with other plans, policies etc. A description does not meet the same goal.
22. pg 14, 2b….Using the word “potential” appears to conflict with information contained in the EAF. Please explain.
23. pg 15  Please include an assessment of the impacts on the night-time sky, a visually sensitive resource.
24. pg 16, 4  Please assess larger sections of Rt 22 & 21, not just the Wingdale            

Hamlet. The project site is very visible from Rt 21 coming over Wingdale Mountain and parts of Rt. 22.

• pg 16, 4   Please put Wingdale Hamlet back in. Portions of the site will be seen from the hamlet.
• pg 16, 5 Please restore the original text, “line”.
• pg 16, 5b Please restore to original language. Secondary impacts are environmental impacts and should be assessed. I agree that site lighting impacts in leaf on and leaf off conditions should be assessed.
• pg 17, C  The word suburban is critical to this discussion. The Master Plan refers to Dover’s rural community character. The neighborhoods on the perimeter of the new plan are suburban in nature. The DEIS should address this.
• pg 17, D1a(i)[a]  Please restore to original language. A clear breakdown and assessment is necessary to understand and mitigate impacts.
• pg 18, a (iv)    Please restore to original language. 25 % is an unacceptable threshold, and an overview is meaningless. How do we assess real impacts using an overview?
• pg 18   The changes generally take the substance out of the requirements of the scope and/or relieve the developer of providing the kind of detailed information on which the Town can truly make a reasoned assessment and decision.
• pg 19, 2a(i) Please restore to original language. The developer should not be allowed to ignore inclusion of data that is already available and/or on file. The Town Board should insist that the project design respect the natural resources and habitats of the site. Those resources and/or habitats are home to the wildlife we find so important to the community. They provide us with the quality of life that we enjoy.
• pg 19, 2a (iv) Please remove the words “if any” The flooding issues are well documented.
• pg 20, b (i)  Please restore to the original language. This information is important to understanding the real impacts that will result from this project. It is also important to assessing mitigation strategies.
• pg 21, c (v) and (vi)  Please restore original numbering and language. A project of this size and in this environmentally sensitive location should have plans to address enforcement and monitoring. The developer should consider avoiding and/or disturbing environmentally sensitive areas of the site. These measures result in protection of resources that will ultimately benefit the public.
• pg 21, 3(ii) Please restore to the original language. This recommendation was made by Dr. Klemens. This information is necessary to evaluate the impacts of the project and to identify potential mitigation measures.
• pg 22, c (iii) Please restore original language. This was recommended by Dr. Klemens and its actual implementation has the potential to benefit the applicant as well as the habitat. This would be a positive environmental impact.
• pg 23, 1st & 2nd paragraph  Please restore the original text. A thorough evaluation of our water resources is crucial to our future since virtually all of the water in the valley bottom comes from one source, the aquifer. While the former HVPC campus has its own reservoir, the rest of the public in the valley bottom have no secondary source. The impacts to the aquifer must be thoroughly assessed and mitigated.
• pg 24, c(iv) Who defines “excessive”. This word is too subjective.  Standards should be defined.
•  pg 25, 3c  Please restore original language. The words “any necessary” lack meaningful definition.
• pg 28, e (I) Please restore to the original language. The word “critical” lacks a meaningful definition.
• pg 28, 2. “speculative” is undefined.  Cumulative impact assessment should be included.
• pg 29, 3a Please return to the original language. The scope is critical to our understanding of the project, its impacts and mitigation measures.
• pg 29, G1a&b    Ignoring the comments from the Fire Chief is unacceptable. The Chief understands the emergency response needs of Dover and his concerns are important to address.
• pg 30 G    Same as above.
• pg 31, 3a(iv)  Please return to the original language. Why not use real data from Dover to assess potential impacts?
• pg 31, b (i)  Please return to original language. Why not consider a range?
• pg 32, 4b (ii) Please restore to original language. There is a current deed restriction on file in the Dutchess County Clerk’s Office. It is only a    “potential” deed restriction if the developer seeks to amend the restrictive paragraph and the Town Board votes to amend it.  Why has the word “potential” been inserted here regarding solid waste disposal? Is the developer planning to dispose of any components of the solid waste stream, including C & D anywhere on site?
• pg 33, 5b (vi) Please restore the original language.
• pg34, 6c (ii) Please restore the original language. The scope of the project is important to understand in order to truly assess potential impacts.
• pg 36, 3e  …again, the scope is important…
• pg 36, Ia(I)     Why not.map areas of environmental concern so that we all know where they might exist for current and future reference?
• pg 37, J1  Please return to original language. Understanding the costs to the Town from partial completion of the project is important in order to protect existing residents and taxpayers quality of life and to assess socioeconomic an other impacts.
• pg 39,  Generally, the Alternatives Section is lacking. Please return to original language. For example, why not study an alternative project size?
• pg 39, D For another example, removing proposed units from hillside and sensitive environmental areas are options that need to be explored.
• pg 40  Please restore original language. This is important to the quality of life and health safety and welfare of the public and environment.
• pg 40, E1,  Removal of the word “initial” would make one conclude that the commercial development will not occur early in the construction process. Please reinsert the word.
• pg 40, E2  Please restore to the original language. Why not focus on commercial uses that reduce impacts such as traffic and noise? We do not want the impacts of big box commercial development.
• pg 40, VIIC  Please restore to the original language. There is no definition of  non-speculative.

James Utter, PhD
Chairman, Friends of the Great Swamp (FrOGS)
Scoping Comments, submitted to the Dover Town Board, May 14, 2008

TO: Ryan Courtien, Supervisor
       Town Board Members                     
         Town of Dover, NY
  
FROM:  Friends of the Great Swamp (FrOGS)

RE:  Final Written Scope for Draft Environmental Impact Statement for
Dover Knolls Development Proposal, Dated March 2008

DATE:  May14, 2008

Thank you for the opportunity to continue participating in the scoping process for this very significant proposal.  The prospect of having a dynamic economic asset on the grounds of the former Harlem Valley Psychiatric Center (HVPC) is exciting to most, but it is also an opportunity to shape the future of the Town of Dover into an environmental and “quality of life” leader in the region.   The current proposal will concentrate 30% of the Dover population into this one site and may change the demography of the Town by the residents it attracts.  Thus it is important to assess the range of options on the property and to critically explore and clearly present the potential long-term, as well as short term, impacts of each alternative. 

Please also consider this letter as a request by Friends of the Great Swamp to continue to be considered A Party of Interest in the proceedings as the Dover Knolls Project goes forward.

Our concerns about the project, both as individuals and as an organization, cover a wide range of topics, but our major focus is on the impacts to the Great Swamp and its watershed ecosystems.  The Great Swamp is one of the largest wetlands in New York State and has been designated a Critical Environmental Area by both Dutchess and Putnam Counties.  This is in recognition of its regional importance and local significance in protecting our water quality, flood prevention, wildlife and rare species support, and other aspects that affect our quality of life.  It is vulnerable, however, and requires constant vigilance to protect its ecological integrity or health.  The major threats today act indirectly, their impacts result from developments and other activities that occur along the wetland edge and in the uplands of the watershed.  Rather than the cut, drain and fill activities of the past, today’s impacts are more insidious. They come from the nutrients, silts, pesticides, road salts, heavy metals, organic pollutants, and alien species, which drain down into the wetland from homes, businesses, roadways, gardens, and farms.  Wetlands are also totally dependent on hydrology, the quantitative, spatial and temporal patterns of water inputs and outputs, both surface and subsurface. Major changes in hydrology are often indirect.   Therefore, we are especially concerned that indirect impacts, as well as direct impacts, are fully addressed in the EIS, especially for such a large project as Dover Knolls.
A more general indirect impact of Dover Knolls will result from its growth inducement effect on the Harlem Valley; we are hopeful these will be fully explored in the EIS. 

Alternatives to be considered. 
SEQRA requires that alternatives to the proposed project design be evaluated, including the “no build” option.  Other realistic plans that could redress major community concerns should be presented and evaluated in the Scoping Document. 

We request that the development team seriously evaluate:

• lower density alternatives,

We note that the number of housing units has risen from 1338 in the 2006 Proposed Action to 1378 in the 2008 Proposed Action, a trend totally in opposition to our major contention that the project already was too large. Simultaneously, the current Action reduces the retail and personal service use (i.e. commercial) space which the community seems to desire.

• reduced footprint alternatives, and

• especially “the full environmental protection” alternative. 

This is the largest development ever proposed for Dutchess County and it is an opportunity to produce a model project that sets the environmental standards for future proposals.  Dover is the place for this showcase to be developed.
Such a plan would include conforming to all the recommendations of the Klemens and Kiviat reports, keeping development off the slopes, increasing set-backs from wetland and other critical habitat areas, reducing the number of housing units, clustering more of the housing units, and adopting “green architecture” for energy and water conservation in all buildings.

We recommend the following strategies be included in all alternatives and
that the Scoping Document specifically address:

• Separation of grey water from black water with reuse of the gray water for watering the golf course and lawns;

This will reduce the water withdrawal pressures on the aquifer, reduce the nutrient load for the STP and the Great Swamp, and stand as a model for similar projects.

• Utilizing tertiary treatment of sewage with sufficient capacity to process the waste from homes and other buildings of Wingdale; 

The high concentration of people with the high through-put systems typically found in high-end homes and offices will result in excessive nutrient loading to the Swamp River unless a tertiary treatment wastewater system is utilized.  If the hamlet of Wingdale residents and businesses are
also tied into the system there would be a major benefit of improving water quality, a significant value from the Project.  By removing the grey water from the routine waste stream, the excess capacity of the STP should be able to accommodate the hamlet. 

• Utilizing minimal fertilization and water management practices on the golf course; 

Golf courses are notorious for water use and as sources of polluted runoff due to the high levels of fertilizers and pesticides used at most facilities to maintain the quality of the playing surfaces.  High run-off from these surfaces aggravates the pollution problems so detention swales are also critical.  State-of-the-art management practices minimize watering and applications of chemicals while optimizing their effectiveness. 

• Utilizing low tech stormwater treatment systems such as rain gardens for roof runoff, infiltration swales distributed throughout the site, curb-less crowned roads with infiltration borders, and infiltration pools so that none of the stormwater runoff is discharged into the Swamp River or wetlands.            

Wetlands
Under any of the alternatives, wetlands and their controlled areas should be restored or left untouched.  The EAF indicates that 12 acres of wetland would be destroyed under the current proposal; this must be avoided.  Even mitigation of additional constructed wetland area is unsatisfactory since they do not function as well as established natural wetlands.

The buffers around the wetlands need to be protected and restored with native plant cover.  This protects and enhances the values and functions of the wetlands including:

• filtering surface water runoff,
• retaining water and allowing infiltration when groundwater is low, and
• serving as valuable wildlife habitat and movement corridors.

For the rare, environmentally sensitive fens and vernal pools, the buffer zone should be extended as recommended by Klemens and corridors between them should be preserved.  These are especially sensitive habitats and depend on the surrounding uplands for proper functioning.

Marble Knolls
These special habitats are the Dover Knolls which the project’s name trumpets.  They are sites of uncommon biota and are visual signatures of Dover; they should be protected and fostered, especially in this project which carries their name.

Water Use Impacts. 
The projected daily withdrawal of 300,000 gallons of water from the aquifer raises concerns of a significant impact on the wells of surrounding homes that are tapping the same aquifer.  This massive withdrawal is also expected to impact groundwater levels, lowering stream depth and reliability, and drying wetlands deeper and more frequently.  The impact will affect habitat and biota associated with the Swamp River and wetlands, both on-site and off-site, possibly including our new Slocum-Mostachetti Preserve.  During drought periods the impact would be most severe.   The potential impacts of these aquifer withdrawals need to be fully explored in the Scoping Document.  What measures are planned to reduce water requirements by the project?  Who will be monitoring ground water levels and making decisions on water use?  What happens if the projections are wrong and five years after project completion the wells of neighbors go dry and the wetlands on which many species depend disappear?  These concerns and other mitigations should be fully addressed in the Scoping Document.

Management of Open Space and Operation of the Site as a Whole.
We are concerned about the project management system once the development is completed and responsible for assuring proper operation, maintenance, and compliance with standards agreed to during the development phase of the project.   What are the impacts of alternative forms of ownership/management?
Who will own the open space and assure proper protection and maintenance of it?  The prospect of a homeowners association being in charge is disconcerting.

Elimination of the wording in the March 2008 Scope specifying Conservation Easements and Deed Restrictions, such as in II.D.2.a. (p. 7) suggests there will be no legal protection of the environmental and other open space resources, but if there is any, they will discuss it in the Scope.  This protection must not be optional and must not be delegated to a home-owners association or other such arrangement.

Recreation facilities impacts.
Recreation facilities at Dover Knolls will be an important part of the community, but they need to be placed where they will have minimal impact on important ecological resources.  Impacts of location and operations of recreational foci need to be evaluated. They should be kept from the wetlands, marble knolls, and other sensitive ecological areas.  The proposed boat launch on the Swamp River should only be considered if it is restricted to canoes and kayaks.

Minimizing road surfaces. 
Road density correlates with stormwater runoff and with level of salinization of streams, both of which are serious environmental problems.  As the slope of roads and building sites increase, the amount of road salting increases, as does erosion.  Phosphate input into wetlands and streams correlates with stream sediment load, so reducing this pollutant can be accomplished by minimizing erosion and stormwater runoff by not building on steep slopes.  The new Plan increases these pollution risks so the Scope needs to address these impacts and mitigation efforts. 

Construction Impacts.
Erosion during construction and the long term effects after the full build is a major problem for wetlands and streams and needs to be addressed in the EIS.  Construction on slopes exacerbates this problem and is one argument against developing the slopes.  Sediments that wash into the Great Swamp are serious pollutants that degrade the wetland and reduce its functional capacity.  

Monitoring Environmental Impacts
It is important that there be adaptive management of the site as it is developed and for at least a few years after completion.  This requires monitoring of key environmental variables by an independent professional contractor that will provide ongoing feedback concerning environmental conditions so that systems under development or in operation may be modified to meet targeted goals.  This must include obtaining baseline data now for water quality of Swamp River, the reservoir, and key streams, as well as other environmental parameters.  A fund needs to be established to assure the monitoring work is completed independently and on a timely basis.

The following are additional comments on specific statements in the
March 2008 Scope Proposal: 

p.6  II D 1 d.   This is an important component, although we encourage the Board to refuse to allow such incursions once the Developer has described what is planned.
p. 7  II D 2 a  and (p.11) 8. To reiterate and expand on above, the only protection for environmental resources is legal.  It is fundamentally important that environmentally sensitive areas be protected by Conservation Easements or Deed Restrictions.  The Board must insist on this provision and not leave it to the convenience of the Developer.

p. 13 Part III. Impact Analysis
Why is the information from specific sources, as specified, only considered and not incorporated into the DEIS, along with the explanations of why the Developer has not abided by said information?  In the SEQRA spirit of open disclosure, it would seem to be necessary.
p. 16  III B 5.  Site lighting is potentially a very significant environmental issue; examination of this problem has been eliminated from the Scope on p. 16 and I am not able to find it elsewhere.  Site Lighting should be restored to the list of environmental issues addressed in the Scope.
p. 18  III D 1 b (ii)  Addressing construction impacts on slopes must include all areas with slopes over 15%,  and should not be limited to slopes over 25% as stipulated in the revised Scope.  Apparently the new Action Plan involves building on slopes over 15% which greatly increases associated environmental impacts and is normally not allowed. 
                        (iv).  Proposed cut and fill activities must be analyzed, not just described, as substituted in the March 2008 Scope.
                     c. (i). The erosion and sediment plan and other points struck in new version should be re-inserted.  Public access to information is enhanced when it is incorporated into one document.
p.19  III D 2 a (v).  Swamp River’s very low flow rate combined with large water volume in the channel at the STP discharge area, contribute to very low turnover of the receiving water, puts exceptional pressure on the waste disposal plan for Dover Knolls.  This puts added importance on a tertiary treatment facility.
                  2 b (i).  The struck portion of this section should be re-inserted to make the information more complete and more readily available.
p. 21          3 a (ii).  This struck information should be re-inserted and acknowledged as part of the Scope.

p. 22   III E  2 c.  Sanitary Sewage  Mitigation Measures.  We are pleased to see the list of strategies to be examined in the Scope.

p.39.  V. Alternatives t0 Proposed Action
We encourage the Board to establish an alternative plan that minimizes environmental impacts and follows the guidelines of Klemens and Kiviat as presented earlier.  This would provide illuminating comparisons with the Proposed  Project that may lead to meaningful compromises.

Thank you again for the opportunity to participate in this process.  Dover Knolls provides an opportunity to create a showcase for environmentally sensitive development and we look forward to working with you in pursuit of such a model.

Respectfully submitted,

James Utter, PhD
Chairman
Friends of the Great Swamp

Don Geramita
Wingdale, New York
Scoping Comments Submitted to Town Board at Scoping Session
May 7, 2008

Supervisor Courtien and Members of the Town Board:

I grew up in a “traditional neighborhood” and appreciate the design, benefits and amenities that such a neighborhood offers.  At the March meeting here, the Dover Knolls representatives nicely presented their plans for a traditional neighborhood development with a description of all the benefits to those who will reside there.  As one gentleman from the public commented, he felt like he was being given a sales pitch to buy one of the units. 

In this development application process, the focus now has to switch away from the benefits for future residents, and specifically to the impacts of this development on me and all the other current residents.

Presented in this letter are my comments and questions regarding the Knolls of Dover Redevelopment Application, amended March 3, 2008, which includes application forms and proposed zoning amendments, a disclosure of interest form, master development plan report, environmental assessment form, amended DEIS scope and master development plan. 

If you cannot answer all my questions tonight, I request that you provide me with answers prior to the Board’s approval of the DEIS scope, as revised subject to the Board’s and the public’s comments.  Your responses may lead to additional comments.  Also, I expect that you will include all my comments in your revised DEIS scope and the proposed zoning amendments.

• Proposed amendments to Section 145-16 of the current zoning law

1. Section C.

• Proposal to delete “Total allowable development of the district or any portion thereof under review shall not exceed 50% more than would be otherwise permitted in the underlying districts, except that in the portion of the MC Overlay District which is zoned SR a density bonus of 100% shall be allowed.”
• Also, proposal to delete the current Section E – Limitation on residential development.  
•  Proposal to replace this/add new Section D. Limitations on development.

What is the effect of changing the current zoning with the proposed Section D.?  Has this been quantified?  I believe this proposed change should be quantified so that the Board and the public can assess the impacts.

• Proposed Section D.1.(b)

This section sets the maximum square footage of non-residential development and refers to section C.2(a) for a definition of part of the calculation.  There is no section C.2(a).    Please demonstrate how the “floor area ratio” is calculated.

2.  Disclosure of Interest Form

• The list of interested parties is missing, as the form did not indicate that there are “none”.

3.  Master Development Plan Report

• Page 5 of the plan indicates that there will be 1376 dwellings.  Just to try to visualize this, I compared the number of dwellings to the number of dwellings at the town’s currently largest development – Woodwinds, which has 210 dwellings.  This plan has more than 6 ½  times the dwelling units as Woodwinds. See the attachment.

• Page 6 of the plan indicates there will be some age-restricted units.  When calculating in the DEIS the fiscal impacts of new children who will be using the town’s resources, primarily recreational and school, be sure to include children in the age restricted units.  Adults over 55 do have children.  I was one of three children in my parents’ household.  My brother, at age 55 had 3 children in elementary school K-8.  Now, almost 61, he still has three children in school – 2 in high school and 1 still in elementary school.  Also, my sister’s daughter was 10, thus in elementary school, when her father was 55.  So for another 8 years she attended her local public school system.  Furthermore, in some families, the grandparents over age 55 are raising their grandchildren. 

Further on the age-restricted units, how will the restriction be enforced initially and then in the future, upon change of resident due to perhaps re-sale, sub-let, or rental?  Who will bear the cost of enforcement, initially and in perpetuity?  The fiscal impacts on Town and school system services of the answers to these questions need to be considered in the DEIS. 

• Page 6 of the plan also indicates that there will be age-targeted units.  Here again, the fiscal impacts of children in these units must also be included in the DEIS.  Perhaps the units will initially be sold to buyers without children.  However, subsequently, units will be resold and/or rented.  The age-targeted marketing will no longer be in effect and thus children will probably occupy these units also.  Furthermore, since a marketing plan is non-binding and may easily change, the DEIS needs to include the impacts of children in these units from day 1.

• Page 7 of the plan includes a table of Proposed Housing by Type.  The unit types include single family, duplex, townhouse, flats, townhouse conversions, apartments (above retail/flex), and loft conversions.  These unit “types” are not defined anywhere.  To determine the fiscal and environmental impacts of these units, the “types” need to be defined and quantified.  For example, what is a flat? A British apartment?  What is the square footage range?  How many bedrooms?  What is a townhouse or loft conversion? What is an apartment (above retail/flex)?  What is the difference between an apartment and a flat?   

To calculate the fiscal impacts of these types of units, the definition of these units also needs to also include the relative price ranges of the units and their construction time table, by type.  Although the future unit prices are currently not known, the fiscal analysis could perhaps be done in today’s dollars as a base.   Or, perhaps the applicant’s economic consultants used sales price assumptions in their analysis, which I will also discuss below.

• The plan touts itself as being a “walkable” and “transit oriented” community.  Page 7 of the plan indicates that only slightly over half, or 56%, of the units are within an approximate 10 minute walk of the Metro North Station.  That also means that almost half of the residential units are not “walkable” – meaning within walking distance to the train station and the retail and commercial area.

Looking at the plan in a physical way, there are 6, I believe, residential neighborhoods.  Of the 6, only 2, or 33%, significantly less than 56%, are “walkable” or “transit oriented”.  The remaining 4 neighborhoods are located on the extreme western and northwestern ends of the site, on an eastern hilltop and in the north east area of the site, removed from the inner core.  These neighborhoods, or 67% of the plan, are not deemed to be “walkable” to the train nor the retail or commercial sites.  Simply, they are stand-alone residential developments.  The allure of a transit-oriented development is thus a minor portion of this application plan.

• The Master Development Plan Report also refers to open space, recreation components, running track, boat launch, 9 village greens and commons, recreation fields, bike paths, trails and a community center at Smith Hall.  If these items are to be owned by the Town, the DEIS needs to address the fiscal impacts of all the taxpayers maintaining these facilities, including additional labor, equipment, utilities, insurance, liability, overhead, among others. 

• Page 10 of the report justifies the proposed zoning amendments to the MC district based on an analysis prepared by the applicant’s consultants – ERA and Torti Gallas.  Has the Town Board read or reviewed this analysis?  If not, is the Board going to make decisions on significant zoning changes based on an analysis prepared by someone who was not working on behalf of and representing the town residents?

• Page 16 of the plan discusses the Dykeman property which apparently has already been rezoned as part of the MC district.  How would the plan have differed if the Dykeman property had not been rezoned, but developed as part of the plan under the zoning law prior to January 2008?  Less density?

4.  Environmental Assessment Form

• Page 4, item 9 - Number of jobs generated after project is complete is stated to be +/- 650.   To determine the impacts of these jobs, the types of jobs and wage ranges by number and type should be defined.  Also, this indicates the number of jobs, not the number of employees.  Jobs can be full time, part time, seasonal, etc.  The number of “full time equivalents” (FTEs) should be disclosed so it can be used in the impacts analysis of the DEIS.

• Does the “number of jobs generated after project is complete” include the municipal jobs that will have to be paid for by us, the local taxpayers, that will be created to provide the additional services to the new residents? 

5.  Final Written Scope for Draft Environmental Impact Statement

• Page 5  Section II A. 6. 
• The applicant proposes deleting a full title report as part of the project location description.   Does the Board concur?  If so, why?

• Pages 7-8 Item 2. Open Space, Recreation and Environmental Preservation Plans
• Page 10 Item 6a.(ii) Community Facilities
• All spaces and  facilities that are intended to be ultimately owned by the Town or County should include the fiscal impacts of operating and maintaining these items.

• Page 10 Item 5.c. Residential Development, Workforce/Affordable Housing
• To determine the impacts of workforce/affordable housing, the DEIS should include the definition, needs justification and quantity of proposed workforce/affordable housing.  Existing affordable housing in the Town of Dover should be quantified to determine if there is an additional need.

• Page 11 Section E.  Phasing Plan
• The applicant proposes to include only “conceptual” instead of “detailed” plans for phases two, three and four.  How can a “meaningful SEQR analysis be prepared” with concepts and not details?

• Page 12   Section E. 3.
• The applicant proposes deleting “a discussion of steps to be taken in the event the project is not completed at any phase”.  The DEIS scope should continue to include such discussion.  For example, if the applicant does not complete the commercial/retail area, then the impacts and mitigations would be substantially different if the area was completed.  The town residents should be protected.

• Page 14. Section B. Visual Resources
• The visual resources and impacts should be presented in both a day and night scenario so that night lighting impacts can be studied and mitigated

• Page 27.  Section F.  Traffic, Transportation and Parking
• Add to this section a fiscal analysis of the municipal costs of maintaining all the new roads, including at least labor, equipment, facilities to store highway equipment, utilities, overhead, repairs of roads , repairs of machinery, and snow plowing/sanding.

• Page 31.  Item 3. Schools
• Calculating the impact of the increase in costs to the school district from a proposed residential development is an exercise in estimates and projections which can be prepared in part based on statistics derived in national areas.  Two, large (to date) residential developments have been built in Dover over the past 20 or so years and provide valuable local information.  This data is based on the types/size of individuals and families who have indeed moved here and their actual impact on the school system.  When the Woodwinds development was undergoing this process, the school superintendent at the time wrote that the development would have no impact on the school system.  On the contrary, as a result, a large school expansion was imposed on the taxpayers.

Real projections of costs per student and the number of school children should be based on recent actual local experience.  Thus the applicant’s proposal to delete the Dover school system’s twenty year cost per student trend and enrollment should not be accepted. 

• School enrollment is cyclical.  The cost analyses should include peak enrollment as the school system has to pay for and accommodate peak not average enrollment. 

• Further, for reasons stated earlier, the cost analyses should include children in age targeted and age restricted housing.  The applicant’s proposal to delete this requirement should not be accepted.

• Page 32. Item 5. Socio-Economic Issues
• A residential development of almost 1400 units will require the expansion of many Town services, such as schools, library, roads, recreation, senior programs, public facilities and all the others listed in this section of the Scoping document.  The applicant proposes to delete the analysis of the cost of these services.  The proposed deletion of these costs should be declined.  Otherwise, it is requested that the Board explain why.

Thank you for your attention to these matters. 

Sincerely,
Don Geramita
Wingdale, New York

Margery Josephson
President, Naromi Land Trust, Sherman CT
Scoping Comments

Stancy DuHamel
Duell Hollow, Wingdale, NY
Scoping Comments

To the Dover Town Board:

At the Town Board meeting on Wednesday, March 26th, I believe our Town Planner Graham Trelstad stated, and the majority of you agreed, that the current application is "substantially the same" as the last application. As such, I believe you should be using the exisiting 2006 scope and ask that it be included in it's entirety excepting the references to the PADS. As I understand it, the developer believes that the current application is the PADS itself. If that is the case, I request that the developer submit the less dense alternative development scenario required under SEQR.  As a contingency, I attach in a PDF some line-by-line comments for the scoping session.

I cannot stress enough the return to best practices of restricting development to slopes of 15% grade or lower which is consistent with our Master Plan and the generally accepted practices of the rest of the towns in Dutchess County.

We need the developer to go into great detail about the sewage treatment plant. I would like to see the plans for the underground infrastructure and the monitoring of treated effluent which will be entering a very slow moving river. I would like to see the financial costs and the resultant negative impact on our taxes assuming the worst but most likely scenario that the plant will eventually revert to the Town for operation and maintenance.

I would like multiple public notices months in advance of asbestos removal.  I would like monitoring to be carried out at the County and State level, as asbestos fibers can travel hundreds of miles. I would like the appropriate Connecticut and Massachusetts State Agencies to be notified as I expect them to be negatively affected if the removal is not done properly. I would like the asbestos removal company to be vetted by the DEC.

I would like our Supervisor to state publicly and put in writing that he will refuse to allow Dover Knolls to bury construction and demolition debris on the site.

Please register the Duell Hollow Conservation Association (DHCA) as an Interested Party, and send communications and documents to my attention at 212 Duell Hollow Rd, Wingdale, NY 12594.

Thank you for your consideration,
Stancy DuHamel
Duell Hollow
Wingdale, NY

Warren P. Reiss, Esq.
General Counsel
Scenic Hudson, Inc.
Submitted to the Harlem Valley Herald on May 14, 2008

To Supervisor Courtien and Members of the Town Board:
 
We have had the opportunity to review the Amended "Final Written Scope" for the proposed  Dover Knoll's project, and provide the following comments.
 
In order to insure a full and proper SEQRA review in a case such as this, it is imperative that the EIS contain a full and robust analysis of any and all potential environmental impacts. In turn, it is imperative that the final written scope adequately outline the various studies and analyses  to be included in the subsequent EIS.
 
In the matter at hand, however, it appears that many of the initial scope's requirements for inclusion in the EIS are being proposed for elimination with no discenrable or legitimate basis to do so. We beleive that virtually all the proposed changes to the scope as shown in the proposed Final Written Scope are inappropriate, and would result in significant relevant matters NOT being  included in the EIS. We beleive this does a diservice to the Town and its citizens. A full record is a matter of necessity for the Town, as Lead Agency, in order for it to make the requisite SEQRA Findings at the conclusion of the process.

We beleive that all the elements of the initial scope should be reinstated, and the applicant be required to complete a full and thorough EIS on the basis of the scope.
 
We have also reviewed the comments submitted electronically by Carolyn Handler  on March 11, and concur therein.
 
Thank you for your consideration of this matter.
 
Sincerely,
Warren P. Reiss
 
Warren P. Reiss, Esq.
General Counsel
Scenic Hudson, Inc.

Jeffrey Baker
Scoping Submission to the Dover Town Board
Attorney for Coalition for the Responsible Growth of Dover
Submitted by Carolyn B. Handler, CRGD President
May 14, 2008

Mark Chipkin
Chairman, Pawling Nature Reserve Management Committee
The Nature Conservancy
May 13, 2008

To Supervisor Courtien and other Members of the Town Board:

The Pawling Nature Reserve Management Committee is composed of over 20 members. We help to maintain the biodiversity and appropriate use of the 1,000 acre Pawling Nature Reserve parcel owned by The Nature Conservancy.  The Pawling Nature Reserve surrounds the Dover Knolls Development Site on the east side of route 22. I appeal to you to do all you can to help us maintain this sensitive habitat for present and future generations. It is very important to take the time to do the most diligent and thorough environmental assessment process that you call.

Please use the more thorough scoping documents of 2006, as this document better addresses the negative impact of the development.   Of particular concern is the view shed from the Pawling Nature Reserve.  The current plan shows housing on steep slopes east of route 22 and what could look like suburban sprawl on the lower elevations of the development.  Accepting building on grades steeper than 15% would likely cause increased erosion problems and produce a greater number of view shed issues,  as houses are placed on higher elevations.  Please consider not allowing a greater than 15% grade for building.

The following practices would be helpful to wildlife. Some of them were discussed in the 2006 scoping documents:

• Provide wildlife corridors and safe  crossings
• Have limited lighting and face this lighting down and away from the reserve.
• No connecting trials from the site should lead into the reserve to prevent ATV use and illegal hunting.(An ongoing problem)
• Clear hunting regulations within the community – there is no general public hunting in the reserve and a buffer no hunting zone can be established between the development site and the reserve.
• Native plantings which encourage wildlife would be preferable to non-native species
• Identification and protection of sensitive environmental and hydrological areas.
• Identification and protection of threatened and endangered species on the site  is necessary

Thank You,
Mark Chipkin
Chairman
Pawling Nature Reserve Management Committee

Christopher L. J. Wood
Chair, Oblong Land Conservancy
Posted here in the Harlem Valley Herald on May 13, 2008

May 9th, 2006

The Honorable Ryan Courtien, Supervisor
Town of Dover,
Duncan Hill Road,
Dover Plains, NY 12522

Dear Supervisor Courtien and Members of the Town Board;

Scoping for Dover Knolls - SEQRA

The Oblong Land Conservancy (OLC) is a local land trust established in 1990 to serve the south-eastern Dutchess County area.  We both own outright and hold conservation easements on land in Pawling and Dover and own numerous parcels in The Great Swamp which we maintain as preserves.  Overall, we protect almost 1,000 acres.

The primary function of the OLC is to protect, for the benefit of future generations, our community’s natural assets.  The protection of The Great Swamp has long been officially recognized as one of our primary goals. We have been engaged in basic research projects in The Great Swamp for years and have also been engaged in studies of the ecological/historically unique Duell Hollow area.

Accordingly, on behalf of the community, we take a keen interest in the proposals for the development of the former Harlem Valley Psychiatric Center and now write to record our views in regard to the scoping for the SEQRA process for Dover Knolls.

In the broadest terms the OLC is concerned with land use issues both as to the present and how they will impact the future.  Accordingly, our comments fall under the following three general headings:

1.             Land Use Impact Issues

2.             Transportation Impact Issues

• Environmental Impact Issues

However, before embarking upon our more detailed observations we are obliged to comment upon a strategic matter.  In the ordinary course of events there is a division of responsibility between the various functions of government.  In relation to land use a Town Board acts in a legislative function and a Planning Board in an executive function within the scope devolved to it.  This provides for the checks and balances for which the US system of representative government is held in such high regard.

In this particular instance the Town Board has removed from the Planning Board its usual site plan review functions.  This creates a situation where the Town Board may be capable of acting as judge and jury in its own case.  Indeed there is scope for land use to become politicized – a dangerous precedent.

Without in any way opining as to the merits or otherwise of this if does create a situation where the Town Board needs to proceed with the utmost caution to ensure that no stakeholder interest is compromised.  This means that the nature of the Scope needs to be drawn with particular care and attention.

With that in mind we proceed to identify some issues to which attention should be directed:

1.             Land Use Impacts

• The proposals contemplate significant new construction and extensive demolition of existing structures.  We consider that more extensive use of the existing structures on the property is appropriate since it will preserve physical infrastructure, retain the historic character of the community and conserve presently open space.  We recognize that some demolition of existing structures is needed to allow light and air to penetrate the core areas and to allow for appropriate car parking and circulation.

To the extent that significant demolition is required it should be appropriately justified.

• Development on steep slopes must be avoided.  Erosion and long-term degradation of such terrain will otherwise follow.  We question the wisdom of any development on a slope of 15% or more.

• The development of age restricted and age targeted residential accommodation should be exhaustively studied for its near, mid and long term effects.  It is often the case that this form of development is proposed as a mitigation measure for over-crowded schools.  Analysis of the demand for and the supply of this type of accommodation needs to be undertaken.  There is a real risk of the over-provision of this type of accommodation with the associated economic implications both for the developer and the social fabric and economic well-being of the community.

• The development should stress, as it appears to, the transit orientated development potential and strive to ensure that as many residents as possible should have the shortest practical walk between the rail road station, their homes and the core of the community.  We recognize that the location of the Swamp River, the associated buffer zones and the use of land west of Route 22 for development poses challenges.

• Development of recreational and other uses in and around the Swamp River must be carefully considered.  There is a delicate balance to be struck between public access, habitat preservation and resource degradation.

• The appropriate phasing of the development is vital and safeguards should be established to ensure that the diverse elements of the multi-phase project proceed in a measured and balanced way.  The objective should be to ensure that no aspect of the development gets ahead of itself in terms of its environmental, social or economic impact.

2.             Transportation Impacts

• We add our concern to those of others in that the need for appropriate study of traffic and associated mitigation measures are vital.  Route 22 is the principal artery servicing the property and consideration must be given to the impact on the complete road hierarchy serving the area in all directions.

• Given the scale of the proposed development it will likely unfold over several years.  The implications of this in terms of heavy construction-orientated traffic must be considered from the perspective of volume and weights of vehicles.

• Proposals to enhance the provision and use of public transportation will be important to mitigate the impact of the private ownership of vehicles.

• The promotion of live-work spaces will reduce commutation times and transportation impacts. 

• To the extent that emphasis can be given to stimulating the creation of small and medium business enterprises so the associated service traffic may be reduced in scale and impact.

• Duell Hollow is steeped in a rich Quaker history and has numerous surviving historic homes.  The Pawling Nature Reserve, a former Girl Scout Camp, and the Hollow’s unique geological structure have contributed to the preservation and maintenance of this place’s unique bio-diversity. 

In the flood of 1955, the steep roads crossing Hammersley Ridge were totally washed out, and were never re-constructed.  These former road extensions: Askins and Leather Hill, followed mountain streams.  There should be no plans to reconnect and re-establish these roads.

3.             Environmental Impacts

• The Great Swamp (DP-22) 

This is one of New York State’s largest and most significant wetlands.  Every effort must be made to protect the Swamp, including:                

(a)  An accurate delineation of boundaries by qualified professionals.

(b)  Extension of the buffer zone to an appropriate depth, as determined by the potential impact of the proposed development in that area.

(c)  Maintain (or restore historic) hydrology.  In this regard, there needs to be comprehensive study of hydrology (surface and groundwater).  Existing studies should be re-examined.

(d)  Maintain and upgrade water quality in the run off to the Great Swamp, including:

Stormwater Treatment
Discharges to watercourses and tributary wetlands.
Consider alternative grey and black water treatment options.

• Prime Agricultural Soils: 

Significant areas of prime agricultural soils are present on the project site.  It is important that these are protected and incorporated in an overall plan.  The Harlem Valley Psychiatric Hospital once produced a substantial quantity of homegrown food on its farms.  This agricultural history seems to invite a Community Supported Agriculture (CSA) project.

• Golf Course 

There are a number of issues associated with this facility.  First, as a community land use facility it should remain a public resource.

Second, alternative management techniques that minimize the use of chemicals and pesticides will result in a reduction or elimination of health threats to the golfers and maintenance staff and will eliminate the potential poisoning of wildlife, water supplies and the reduce the nutrient contamination of The Great Swamp which is adjacent to the course.

• Aggregation and consolidation of development will serve two ends – (a) conservation of presently undeveloped land and, (b) the minimizing of fragmented habitats, now recognized as a key element in species protection.

• Since hazardous materials management practices were not regulated during the prior use of the Center it will be vital to research, inventory and remediate the presence of such materials.  The scope should provide for detailed remediation plans and for appropriate monitoring of the implementation of such plans.

• Best Management Practices

Dr. Michael Klemens has worked with the prospective developer to identify significant areas on the site and has proposed measures to minimize development impacts.

It will be important to ensure that as part of any overall development plan recommended “Best Management Practices”, as described in WCS’ publications, are fully adopted and implemented.  It is not clear to us that the present proposals fully reflect Dr. Klemens’ recommendations.

The OLC is keenly interested in participating with the Town Board, the community and the prospective developer in ensuring that the plans for Dover Knolls, as they evolve, meet the needs and requirements of all concerned.  Our perspective is that of steward of community resources and as a Trust we have the longest of time frames in view unfettered by personal preferences or profit.

Within the OLC Board there is a wealth of experience in dealing with land use issues including its conservation and development.  This experience is available to assist your Board in addressing the many and complex issues associated with this exciting opportunity.

We look forward to being of assistance.

Yours sincerely,

Christopher L. J. Wood
Chair
Oblong Land Conservancy

Carolyn B. Handler
President of the Coalition for the Responsible Growth of Dover
Submission to Scoping Session May 7, 2008

Dover Knolls Scoping Session Held on Wednesday, May 7, 2008

Comments Submitted by Carolyn B. Handler, Wingdale, New York

As President of the Coalition for the Responsible Growth of Dover and a resident of Dover for close to 20 years, I approve and endorse the comments made on the Coalition's behalf by our attorney, Jeff Baker.  The Coalition's stated goal and mission is to ensure that we have a plan for the development of the Harlem Valley Psychiatric Center which we can all be proud of, and to take whatever steps are necessary to ensure that the project proceeds in the most responsible manner possible.  Our scoping comments represent the best of our collective efforts and abilities to achieve those ends.  By restoring many of the mitigation measures and protections previously identified and specified in the original Final Scope, we can hopefully prevent our Town from being left with no alternative but to remediate problems which may occur with the site in the future.  We believe it to be in our collective best interest to try if possible to address and hopefully avoid those problems at the outset by giving careful, thoughtful and rigorous scrutiny to this scoping process.. 

My specific comments are directed to phasing of the project:

There have been substantive changes made in the proposed amended scope with respect to phasing.  For phases other than phase one, Dover Knolls now says it will provide only conceptual rather than detailed plans, heightening a concern that many of us have that later phases may never come to fruition.   Each phase of the project should be detailed rather than detailed as to phase one and conceptual as to all later phases.  Most importantly, Dover Knolls should restore to the scope a discussion of the steps to be taken in the event the project is not completed at any phase.

Similarly, more discussion needs to be given to assure that residential development is done in tandem with commercial development.  Part of our concern stems from a change made by Dover Knolls in the proposed amended scope to delete any discussion of providing for ongoing or planned marketing for the commercial space and to reduce the overall retail space by 100,000 square feet (that is from 350,00 square feet to 245,000 square feet).  We are concerned that if Dover Knolls is not called upon at the outset to provide sufficient detail on the commercial development we will not have adequate assurance that the project will be built as advertised.  On that point, Dover Knolls should be called upon to post a bond large enough to mitigate the financial impacts on the Town and the school district if the project is not completed or if the demands for public services by 1,400 new families exceed the value of their property tax payments.

As a corollary to this sequencing discussion, I can not emphasize enough the importance of any residential development beginning on the site of the Harlem Valley Psychiatric Center, that is, on the site that many of us consider to be the eyesore.  I am concerned that the Dykeman parcel not, under any circumstance, be allowed to be developed first, a parcel which any of us familiar with the site knows is as remote from the Psychiatric Center campus as is possible while still being contiguous.  To permit the Dykeman parcel to be developed first is wholly inconsistent with the original intent of the MC Overlay district law as initially drafted and in our view allows the developer to go for the low hanging fruit. 

In the proposed scope, the developer has deleted a requirement to address the construction process and needs of each phase of the project.   In particular, Dover Knolls should restore specificity to its discussion of the construction process at each Phase and be called upon to address construction for all project components with the expected year of completion for each project component. Given the scope of the project, there should be a more detailed discussion of the general construction process and needs including but not limited to hours of operation, plans for construction monitoring, particularly on local streets, dust suppression, housing for construction workers, schedule and map of construction, erosion and sediment control to be utilized during construction and construction equipment and staging areas.  The description of the proposed construction sequencing needs to include a flowchart for the maximum anticipated duration, including start and completion for key milestone tasks such as site clearing and debris removal, grading and fill replacement, infrastructure and foundations.  The developer needs to identify staging areas for material handling and storage, including access and egress during construction. 

Finally, as to all residential development taking place, the scope should discuss the roles and relationship between the developer, homeowners, management of the development and how these roles may change over time.  The scope should describe any plans for use of homeowner associations and their areas of responsibility in monitoring and mitigation, if any.  The scope should discuss how the undertakings, agreements or representations of the developer will be binding upon successor owners or developers should the project site be sold or conveyed to others.

Submitted by Carolyn B. Handler to the Harlem Valley Herald on May 12, 2008

George Nichols
May 12, 2008

To the Dover Town Board:

I have been a resident of Dover for more than 16 years.  I support the positions of the Coalition for the Responsible Growth of Dover and its actions.  I might not have been inspired to state my solidarity for the public record if it were not for a puzzling comment in a letter to the Editor of the Harlem Valley Times.  It was alleged that the Coalition for the Responsible Growth of Dover is in fact for no growth.  It is a curious statement.  Everyone is for development of the Harlem Valley Psychiatric Center.  No one could be satisfied with that deteriorating eyesore.  This is not the case with many development proposals, against which a minority or a majority advocates for the status quo.  Any of us may disagree on the process - and on the form and extent of that development.  But we agree that it is needed.  To mischaracterize the motives of our concerned fellow citizens is injudicious and polarizing as we begin a long and vigilant effort together.  Indeed, the great strength of this project is the unanimity that action must be taken.  We should be respectful of the good intentions of our neighbors.

And we should be realistic about what has happened in the world since the first development proposal was withdrawn.  The economic climate for it has deteriorated, and a credit crisis is impacting the potential purchasers of these 1,376 units, whoever they may turn out to be, and it is impacting developers.  Several developers in the New York area have gone bankrupt in the past few months.  This applicant is not seeking financing for this project yet, and by the time the SEQRA process has been completed, the economic climate may have improved, and the credit crisis may have abated.

Or they may not have, for a project of this scale in this location.  The final scope should be at least as rigorous, thorough, transparent, and verifiable as was the original, before the credit crisis.  This scope mentions four phases, not more and not fewer.  It is not apparent what they are.  By the time the SEQRA process has been completed, we must all know, first, what the phases are in detail and, secondly, how the phasing was determined in a way that can be verified.  To what extent is the phasing justified by engineering and construction practices and efficiencies?  To what extent is the phasing determined by marketing considerations?  And to what extent is the phasing driven by the financial requirements of the applicant or its lack of financing capability at the time?

Any of these factors might be valid reasons for the phasing, and it will probably be determined by a combination of them and many others that I am not expert enough to know about.  In that context it is mystifying to see the deletions on pages 11 and 12 under “Phasing Plan.”  Details on “all project components with expected year of completion for each component and detailed information on areas affected with specific location and acreage and marketing of commercial development” must be required.  The “discussion of steps to be taken in the event the project is not completed at any phase” must be restored.

Long after this applicant has moved on to new challenges, this community will have to live with the state of the Harlem Valley Psychiatric Center property, what may be done and what may have been left undone.

George Nichols