Finger Lakes East Business Park

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					                          USEPA Region 2
                          290 Broadway
                          New York, NY 10007-1866




          Finger Lakes East
            Business Park

   Cortland County Business
  Development Corporation/
Industrial Development Agency



   Environmental Assessment


DECEMBER 2009
                                              1



I.    Project Identification
      Project Name:   Finger Lakes East Business Park
      Lead Agency:    Cortland County Business Development Corporation/
                      Industrial Development Agency
      Location:       Town of Cortlandville, Cortland County, New York

II.   Purpose and Need
      The purpose of this project is to facilitate implementation of the Central New York
      Regional Planning and Development Board’s (CNY RPDB) recommended economic
      development investment in the proposed Finger Lakes East Business Park (FLEBP). The
      FLEBP is an integral part of the CNY RPDB’s plan to provide the resources needed to
      attract fast-growing, job-creating companies to the Central New York Region (Figure 1).
      The Central New York Region, centered on the City of Syracuse, is located in proximity
      to the cities of Rochester, Buffalo, Albany, and Binghamton, and is within a 4 to 5 hour
      drive to New York City, Toronto, Boston, Philadelphia, and Montreal.




                                   Figure 1 – Planning Area
                                          2


The FLEBP is in Cortland County, New York, which is located approximately 25 miles
south of the Syracuse metropolitan area and lies along the transportation corridor which
connects the Cities of Syracuse, Binghamton, and Ithaca, New York. The County’s 2005
population was 48,622. For comparison purposes, the Syracuse area had a population of
750,000 and the Binghamton area had an additional 250,000 people.

Cortland County is midway between Cornell and Syracuse Universities. In addition,
various other colleges and universities are located in the Central New York Region,
including a number of State University of New York (SUNY) campuses (Figure 2).




                      Figure 2 – Public and Private Universities


Even before the current recession, the region was struggling economically. The Cortland
metropolitan area was already significantly impacted by an economic downturn affecting
the Central New York Region. Over 2,900 manufacturing jobs were lost in the region
between the years 1989 and 2000. Despite its diverse economy and academic resources,
the area’s population figures are stagnant, per capita income is low, and long-term
unemployment rates are high. Losses of manufacturing jobs negated improvements in
other areas of the economy and stalled economic growth.
                                         3


The CNY RPDB is a public agency established in 1966 by Cayuga, Cortland, Madison,
Onondaga, and Oswego Counties. The CNY RPDB has developed a comprehensive plan
aimed at sustaining economic growth in the Region. The plan recommends
implementation of the following initiatives to support the region’s economic growth:

•   Developing a network of publicly-sponsored “shovel-ready” business parks
•   Providing individualized assistance to companies with high growth potential
•   Promoting industrial clusters through a regional research and technology
    collaborative
•   Expanding research centers and building product development centers
•   Expanding workforce development and retention programs
•   Increasing regional university research in areas relevant to the region’s technology
    clusters
•   Harnessing regional intellectual property for economic growth
•   Maintaining a region-wide capital network for entrepreneurs
•   Promoting creative sector occupational clusters
•   Implementing a regional branding and marketing campaign
•   Developing a university/industry applied research program
•   Creating a regional university research and technology advisory board
•   Supporting existing incubators and establishing a regional accelerator
•   Continuing to maintain and develop the region’s physical and human resources
•   Supporting activities that help retain and expand businesses which are net wealth
    generators for the region
•   Encouraging the growth of employment opportunities in the region’s economically
    distressed areas
•   Improving area services and public facilities to help retain existing businesses and
    attract new companies to the region
To implement the above recommendations, the CNY RPDB subsequently developed a
comprehensive economic development plan, the Central New York Initiative. The
specific construction projects identified in the Central New York Initiative include
investing in the following:

•   Finger Lakes East Business Park
•   Hancock Airport
•   Clay Business Park
•   Syracuse University Center of Excellence
•   Aurelius Industrial Park
•   Hamilton Airpark
                                               4


       The CNY RPDB proposed establishing the Finger Lakes East Business Park (FLEBP) in
       Cortland County, New York. It is being implemented as part of New York State’s “Build
       Now-NY” initiative to attract businesses by making available pre-approved “shovel-
       ready” sites. Thus, the proposed project would provide the roadway and the water and
       sewer infrastructure needed to implement the FLEBP concept.

III.   Description of the Proposed Project
       To begin implementation of the Finger Lakes East Business Park concept, the current
       project would provide the necessary public water supply mains, sanitary collector sewer
       service, roadway and stormwater management facilities needed to facilitate development
       and build-out of “shovel-ready” parcels around two existing businesses, the Monarch
       Machine Tool Company and the Essex Structural Steel Co., Inc., located within an
       existing New York State-designated “Empire Zone” on the north side of NYS Route 13,
       between Gracie and Bennie Roads, in the Town of Cortlandville, New York (Figures 3
       and 4).




                                   Figure 3 – Project Location
                                        5




                              Figure 4 – Aerial View



The proposed FLEBP property comprises approximately 133 acres. Eighty acres are
proposed for development as a 13-lot business and technology park. Fifty-three acres are
to remain undeveloped and/or wooded.

To facilitate and encourage economic development at the site, public water supply mains
are proposed to be installed to service all of the proposed subdivided parcels on the
property (Table 1 and Figure 5). The water supplied to these lines would be obtained
from the Town of Cortlandville’s existing public water system, which is supplied by two
municipal wells. The information provided indicates that the Town has adequate water
capacity to serve the FLEBP’s anticipated water supply needs of 115,000 gallons per day
at full build-out.
                                        6




     Table 1 – WATER SUPPLY SYSTEM COMPONENTS

           WATER SUPPLY MAINS                           quantity       unit

 8-inch diameter ductile iron pipe – Class 52            5,180      linear feet

 12-inch diameter ductile iron pipe – Class 52           4,955      linear feet

 8-inch gate valve                                         16          each

 12-inch gate valve                                        12          each

 Hydrant Assemblies                                        19          Each


The proposed sanitary sewer system would drain to a small on-site wastewater pump
station which would convey the collected wastewater, via a short force main, to the
existing sanitary sewer main located to the east of the site on NYS Route 13 (Table 2 and
Figure 6). The existing sewer main would, in turn, convey the wastewater to the City of
Cortland for treatment and disposal. The City’s wastewater treatment plant has adequate
capacity available to accept the wastewater expected to be generated by the FLEBP.



    Table 2 - SANITARY SEWER SYSTEM COMPONENTS

              SANITARY SEWERS                           quantity       unit

 6-in diameter PVC – SDR-35                               362       linear feet

 8-in diameter PVC – SDR-35                               690       linear feet

 10-in diameter PVC - SDR-35                             1,140      linear feet

 12-in diameter PVC - SDR-35                             4,214      linear feet

 Pre-cast Concrete Manholes                                25          each

 Pumping Station/Generator/Force Main                       1          Each
          7




Figure 5 – Water Supply Lines




Figure 6 – Sanitary Sewer Lines
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      Finally, the stormwater management area (SWMA) facilities to be constructed as part of
      the overall project are depicted in Figure 7.




                      Figure 7 – Stormwater Management Areas (SWMAs)



IV.   Cost


                            Description                        Amount

       Total Project Cost                                          $5,794,753

       Estimated EPA Eligible Cost                                     $788,545

       Projected EPA Grant (55%)                                       $433,700

       Local Share of Project Cost                                     $354,845

       Other Federal/State Grants or Loans                         $4,844,904
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V.   Alternatives
     A. No Action - Under the no action alternative, no new roads, water or sewer lines would
        be installed, and Cortland County would not proceed with rezoning, subdivision, and
        development of the project site. Although the site could continue to be developed in
        accordance with its current zoning, the lack of availability of public water supply and
        wastewater disposal facilities, storm water management facilities, and reasonably-
        sized, road-accessible land parcels would significantly restrict development of the site.
        The CNY RPDB’s goals and objectives related to promoting economic development
        and job creation in the region would not be met. Consequently, the no action
        alternative was rejected.
     B. Alternative Sites/Utility Routing Alternatives – An extremely thorough process was
        utilized to arrive at the site that is being proposed for the FLEBP. Prior to proposing
        this particular site, Cortland County officials evaluated various in-county alternative
        sites based on the following parameters:
         •   Significant acreage (200+ acres) with minimal number of property owners
         •   Location away from the primary aquifer protection area
         •   Location on a state highway within five miles of an interstate highway
             interchange
         •   Proximity to municipal services for easy extension of municipal infrastructure
         •   Proximity to electrical substation or major power line
         •   Appropriate zoning
         •   Compatible adjacent land uses and cooperative neighbors
         •   Conformance with the “Build Now-NY” requirements
         • Good site access
         • Availability of site for purchase
         Utilizing the above criteria, twelve sites were ranked by the County Planning
         Department. The proposed site was evaluated and found to substantially meet the
         siting requirements. An application, supported by the landowners and the Town, was
         submitted and approved by the New York State Build Now-NY Program in 2002.
         New York State’s Build Now-NY program utilizes a competitive and coordinated site
         selection process. Thirty-eight sites applied for program grants; only twenty-six sites
         around the State received matching grants. Of these, only nineteen sites met the
         criteria and guidelines for being marketed under the State’s “Multi-tenant Business
         and Technology Park” development profile. The proposed FLEBP site is one of the
         nineteen sites that were selected through this process.
         Because the proposed water and sewer lines must be accessible to all of the proposed
         subdivided parcels, their locations are heavily influenced by the layout of the
         proposed roads and lot lines. Wherever feasible to do so, the water and sewer lines
                                               10


         are to be installed in the shoulders of the planned and existing roadways, so as to
         avoid sensitive areas and simplify future connections and the necessary ongoing
         maintenance activities associated with them.

VI.   Environmental Consequences of the Selected Plan/Mitigation Measures
      A. Air Quality - Because this project will be funded in part through a Federal grant, the
         project is subject to the general conformity regulations (40 CFR 93 Subpart B). This
         project is located in Cortland County, New York, which is in attainment of the
         National Ambient Air Quality Standards. Thus, no further air quality general
         conformity analysis is required. Air emissions of NOX, VOC, CO, PM2.5, and SO2
         from construction of this project will not result in any significant air quality impacts.
         During construction, dust will be generated from trench excavation and backfilling
         activities and vehicles travelling on unpaved surfaces. These impacts will be short-
         term and intermittent and will be mitigated by implementation of dust control
         measures (e.g., water spraying, pavement sprinkling, vehicle washdown, on-site
         speed limits). Soil storage piles will be covered or temporarily seeded.
      B. Surface Water - The project site is located within the Susquehanna River drainage
         basin. Based upon site reconnaissance and map investigation, there are no streams or
         wetlands on any of the areas where development of the FLEBP has been proposed.
         The gravelly soils at the site allow much of the precipitation to percolate into the
         ground; the remaining stormwater runoff drains toward the northern and southern
         portions of the site.
         With respect to stormwater, the project will utilize various structural and non-
         structural best management practices recommended by the New York State
         Department of Environmental Conservation and the Natural Resources Conservation
         Service to control the rate and quality of stormwater flow off-site. Siltation controls
         will be provided along the construction areas to prevent potential silt migration to any
         off-site wetlands or surface waters.
         A number of stormwater management measures and facilities (pre-treatment type
         detention basins designed to detain stormwater for a short duration) will be
         constructed as part of the overall project, including grass-lined swales and stone rip-
         rap at entrances and exits of the stormwater culverts. Thus, although the FLEBP will
         result in an increase in impervious surfaces (roofs, roads, driveways), runoff will be
         detained in on-site storage basins such that the rate of runoff does not exceed the pre-
         project existing conditions. In addition, the Town has a Stormwater Management and
         Erosion and Sediment Control Ordinance in place, which regulates site preparation
         and construction activities so as to manage stormwater and runoff and prevent
         problems related to erosion, sedimentation, flooding or drainage. The proposed water
         mains and sewers will be buried below-ground, and the surfaces will be subsequently
         restored. Consequently, the project will have no significant wetland or water quality
         impacts.
      C. Groundwater/Sole Source Aquifer - The project site is located in the area of the
         Cortland-Homer-Preble Aquifer System, which EPA designated as a Sole Source
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   Aquifer on September 11, 1987. EPA has reviewed the project’s potential impacts on
   the aquifer pursuant to the requirements of Section1424 (e) of the Safe Drinking
   Water Act.
   The Town of Cortlandville has adopted a Land Use and Aquifer Protection Plan, and
   the site is located within the Town’s Aquifer Protection District. To ensure protection
   of the aquifer, end users within the Aquifer Protection District will be required to
   obtain an “Aquifer Protection District Special Permit” from the Town Board. These
   permits are meant to ensure that appropriate site-specific and user-specific protective
   mitigation measures are implemented by the end users. As discussed above, several
   management methods will be used to control stormwater from the site.
   There will be no septic systems or other means of on-site disposal of the wastewater
   that would be generated by development on the site. Instead, a wastewater pumping
   station is proposed to convey the wastewater collected by an on-site sanitary sewer
   system to the City of Cortland for treatment and disposal. The City of Cortland
   Wastewater Treatment Facility (CCWTF) serves the City of Cortland, the Village of
   Homer, the Village of McGraw, and much of the Town of Cortlandville. It currently
   treats 7 million gallons of wastewater per day. With a rated flow of 9 million gallons
   per day, it has sufficient capacity to treat wastewater generated by the proposed
   business park (115,000 gallons per day) at full build-out. Pursuant to the facility’s
   New York State Pollutant Discharge Elimination System discharge permit (SPDES
   Permit No. 002-7561), the CCWTF provides advanced secondary treatment
   (including de-chlorination of its treated effluent in the summer) prior to discharging it
   to the Tioughnioga River.
   Based on the above measures, EPA has determined that the project will have minimal
   impact on public health and ground water resources, including the sole source aquifer.
   Thus, the project complies with Section 1424(e) of the Safe Drinking Water.
D. Wetlands – State and federal wetlands boundaries on the site have been delineated
   and surveyed, including the wetlands called the Chicago Bog. No encroachments on
   these areas are proposed for the FLEBP. The stormwater management facilities and
   post-development grading plan were developed to maintain drainage to the existing
   wetlands so that they will continue to receive runoff and will not be adversely
   impacted. As discussed above, under surface water, suitable erosion control measures
   will be implemented in work areas before beginning construction.
   Clearing and grading will be limited to only that which is necessary, vegetated buffer
   areas will be maintained, and continued coordination with the Cortland County Soil
   and Water Conservation District will all ensure that the project will not significantly
   impact wetlands.
E. Land Use – A majority of the site is currently zoned for industrial use, with a lesser
   part zoned for agriculture. The Town, however, is in the process of rezoning the land
   within the proposed business park so that the proposed project’s land use will be
   consistent with the Town’s zoning code and land use plan.
F. Transportation – With the exception of the off-site connections to the existing water
   and sewer lines along Route 13, the construction activities associated with the water
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   and sewer lines will be contained within the Finger Lakes East Business Park land
   parcel. Thus, construction impacts will be limited to construction equipment and
   construction workers entering and leaving the site. Standard maintenance and traffic
   protection measures will be implemented to reduce traffic disturbances during
   construction. Some minor short-term delays are likely in areas along NYS Route 13
   where the off-site work needs to be performed to connect the proposed water and
   sewer lines to the existing facilities. Delays will be minimized, however, by ensuring
   that the maintenance and protection of traffic plan (e.g., work zone signs and flag
   persons) for the project area is followed and that all state and county highway permit
   requirements are implemented by the construction contractor.
   Implementation of appropriate mitigation measures will require consultation with and
   acquisition of highway permits from Cortland County and the New York State
   Department of Transportation. Consequently, no significant traffic impacts are
   expected to result from the project.
G. Aesthetics – Cortland County has indicated that it intends to develop a business park
   that includes progressive, environmentally-sensitive land use planning, with attractive
   architectural and landscape design. Existing vegetative buffers will be maintained
   between the FLEBP, the Chicago Bog, and the lands utilized by the Lime Hollow
   Center for Environment and Culture. Further, the on-site utilities will all be installed
   below grade. Consequently, no significant adverse aesthetic impacts will result from
   the proposed project.
H. Noise - Noise generated by construction equipment will be temporary and localized.
   Construction equipment will be equipped with mufflers in accordance with state
   regulations, and local noise ordinances will be followed. The small pump station will
   produce low-level operation noise, but the pump housing will be designed so that
   ambient noise levels outside the pump station are not affected.
I. Endangered/Threatened Species - The U.S. Fish and Wildlife Service (FWS) and
   New York State Department of Environmental Conservation were consulted about the
   project. In a letter dated July 16, 2004, the FWS stated that no known federally listed
   endangered/threatened species or designated critical habitat is present in the area, and
   recommended that the New York State Department of Environmental Conservation
   be consulted about whether any other species of concern were known in the vicinity
   of the project area. Subsequent on-site visual characterization of the site, supported
   by the consultation documentation from the NYSDEC, established that the project
   will affect only common species (native, transplanted or transient) and habitat present
   in the area. Consequently, no significant adverse impacts will occur to
   endangered/threatened species or designated critical habitat.
J. Cultural Resources - The New York State Office of Parks, Recreation and Historic
   Preservation reviewed the cultural resources investigations for the project. In a
   September 4, 2008 letter, the State Historic Preservation Officer indicated that the
   project will have No Adverse Effect on historic properties in or eligible for listing in
   the State and National Registers of Historic Places, and concurred that no additional
   investigations are necessary. EPA concurs with this conclusion.
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K. Socio-Economic Impacts – No significant adverse socio-economic impacts are
   anticipated. There is, however, the potential for benefits to indirectly result from the
   project, including:

   •   Enabling full build-out of a new business and technology park,

   •   Employment opportunities for a highly trained workforce,

   •   Potential for 1,000 to 1,500 jobs under a full build-out scenario,

   •   Establishing a stable business network providing goods and services, and

   •   Increased tax revenues for infrastructure/service improvements and/or tax relief.
L. Cumulative Impacts – A traffic impact study was completed to evaluate potential
   traffic related impacts from full build-out of the FLEBP on existing conditions. The
   study, completed in consultation with the NYSDOT, identified existing conditions
   (including five intersections along NYS Route 13 during morning and evening peak
   travel hours), background conditions (anticipated future traffic conditions without the
   proposed FLEBP), and future conditions (background conditions plus project–related
   traffic). An additional analysis of the proposed site was reviewed, which included
   development of a proposed Wal-Mart Supercenter site located between an existing
   Wal-Mart and Bennie Road on NYS Route 13. Based on consultation with the
   NYSDOT, a reasonable estimate of traffic generated at the site was used to identify
   the cumulative impact of the proposed FLEBP in combination with the traffic impacts
   of the proposed retail development. The analysis indicates that, if the recommended
   traffic infrastructure improvements for the retail center and FLEBP are implemented,
   the proposed projects will have no notable effect on adjacent roadway patterns.
   Operationally, it is expected that the full build-out of the business park would occur
   in phases which are dependent upon economic conditions and the needs of the
   businesses that utilize the business park. The traffic impact study for the project
   indicates that, with implementation of various recommended improvements, the
   existing highway system will be able to accommodate the anticipated development-
   related increases in traffic volume.
   The recommended phased roadway improvements, by phase of build-out, are:
   Phase I – The appropriate improvements for the traffic generated by this phase, 30
   percent build-out, include constructing the main entrance road, and a traffic signal
   with northbound left turn and southbound right turn lanes on NYS Route 13.
   Phase II – 60 percent build-out would require a second entrance with traffic signal
   and turning lanes along NYS Route 13.
   Phase III – Between 60 percent and 100 percent build-out, depending on the location
   of lots desired by tenants, an entrance on Gracie Road would be needed.
M. Environmental Justice Issues -The EPA Region 2 Environmental Justice (EJ)
   analysis methodology supports EPA Region 2's Interim Policy for Environmental
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EPA’s demographic analysis utilizes a Geographic Information System (GIS) to
estimate the percent minority and percent poverty for the community of concern and
compares them to appropriate statistical references. Analysis of the project area
indicates that minorities compose 3.72 percent of the population of the local
community (compared to 34.73 percent, the percentage that EPA uses to determine
minority areas in rural sections of New York State), and that 11.67 percent of the
population has income that is below the poverty level (compared to 23.59 percent, the
percentage that EPA uses to identify low income rural sections of New York State).
Accordingly, the area does not meet the EPA criteria for being classified an EJ area
and no additional EJ analysis is necessary.


                                   New York State
  Demographic Analysis                                        Cortlandville
                                     Threshold
     Percent Minority                    34.73                     3.72
     Percent Poverty                     23.59                    11.67

For environmental burden analysis, Region 2 advances the concept of an
"Environmental Load Profile (ELP)." The profile would provide a representation of
the environmental load (i.e., relative environmental burden) within a community.
The ELP serves to identify communities that may bear a disproportionate
environmental load in comparison to statewide-derived thresholds. Currently, the
Environmental Load Profile consists of the following three indicators: Toxics
Release Inventory (TRI) Air Emissions, Air Toxics, and Facility Density.


 Environmental               New York
                                              Cortlandville        Ranking
 Load Analysis               Threshold
 TRI Indicator                   2.6                0.1                0
 Facility Density
                                  56              113.27               4
 Indicator
 Air Toxics Cancer
                                63.55             24.94                0
 Indicator
 Air Toxics Non-
                                 11.3              2.33                0
 cancer Indicator
                                             15



        The ELP generates a summary report that provides numeric values for state
        thresholds, indicator of the community of concern, and the ranking of the community
        in the state. These calculated values not only identify whether the particular
        community meets an ELP threshold but further, if the threshold is exceeded, the
        indicator value is ranked to provide a measure of magnitude.

        The Environmental Load Analysis for the Town of Cortlandville indicates that only
        one of the indicators evaluated, facility density, exceeds the respective New York
        State threshold. The analysis indicates a risk ranking of four, with a facility density
        indicator of 113.27. While this value is greater than the overall New York State
        value, the ranking of 4 means that the load for the COC is not at the high end of the
        spectrum. Moreover, it supports the goal of industrial clustering to facilitate
        economic growth. And, as indicated above, the area does not meet the criteria for
        being classified an EJ area. Consequently, no further evaluation is necessary.

VIII. Coordination of Environmental Review
     A. Public Participation - In 2005, the Cortland County Industrial Development Agency
        (IDA) solicited and received public and agency input on a Generic Environmental
        Impact Statement (GEIS) for its proposed FLEBP, pursuant to the requirements of the
        New York State Environmental Quality Review Act (SEQRA). The GEIS and the
        IDA’s subsequent “Findings Statement” are incorporated into this EA document by
        reference.
        The 30-day public comment period on the draft GEIS, included a public hearing on
        the matter at the Cortlandville Town Hall on September 21, 2005.
        After evaluating public comments on the project, the IDA prepared a final GEIS and
        issued its public findings on the project on February 16, 2006. The SEQRA findings
        were that, consistent with social, economic, and other essential considerations, the
        proposed action minimizes, avoids, and mitigates adverse environmental impacts to
        the maximum extent practicable.
     B. Indian Nation Notification - EPA notified the Onondaga Nation of Indians and the
        Haudenosaunee Environmental Task Force about the project via letters dated
        September 4, 2003. No responses or comments were received from either
        organization.
     C. Federal, State and Local Agencies Notified/Consulted/Involved
        •   U.S. Fish and Wildlife Service
        •   U.S. Army Corps of Engineers, Regulatory Branch
        •   New York State Department of Environmental Conservation, Regional Permit
            Administrator, Region 7
        •   New York State Office of Parks, Recreation and Historic Preservation, Field
            Services Bureau
        •   New York State Department of Health, Bureau of Public Water Supply Protection
        •   New York State Department of Transportation
                                          16


        •   Empire State Development Commission
        •   Central New York Regional Planning and Development Board
        •   New York State - Governor’s Office of Regulatory Reform
        •   Susquehanna River Basin Commission
        •   Time Warner Cable
        •   Verizon Communications
        •   Energy East Telecommunications
        •   Cortland County Department of Planning
        •   Cortland County Soil and Water Conservation District
        •   Cortland County Health Department
        •   City of Cortland
        •   Town of Cortlandville
        •   Niagara-Mohawk – A National Grid Company
        •   New York State Electric and Gas
        •   Lime Hollow Center for Environment and Culture
        •   Tunison Laboratory for Aquatic Science

IX.   Reference Documents
        •   Response letter to EPA’s June 26, 2008 comment letter concerning the
            Environmental Information Document for the Finger Lakes East Business Park,
            O’Brien & Gere Engineers (May 13, 2009)

        •   “Environmental Information Document, Finger Lakes East Business Park, A
            Build Now NY Site, Cortlandville, New York,” O’Brien & Gere Engineers
            (April 2007)

        •   “State Environmental Quality Review Act – Findings Statement,” Cortland
            County Industrial Development Agency (February 16, 2006)

        •   “Final Generic Environmental Impact Statement,” Cortland County Industrial
            Development Agency (December 12, 2005)

        •   “Draft Generic Environmental Impact Statement,” Cortland County Industrial
            Development Agency (August 8, 2005)

        •   “Finger Lakes East Business Park – Traffic Impact Study,” O’Brien & Gere
            Engineers (June 2005)

        •   “Phase 1A Literature Review and Sensitivity Assessment, Cortland County
            Business Development,” Birchwood Archeological Services (May 2005)