Environmental information document (draft), Clinton Street CSO Abatement Project — February 2005
Prepared by SGD Environmental Services
for Environmental Engineering Associates, LLP
PROPOSED LEAD AGENCY
Onondaga County, Department of Water Environment Protection
650 Hiawatha Blvd., W., Syracuse, NY 13204 Contact: Richard L. Elander, PE, Commissioner, 315-435-2260

5. Impact evaluation and mitigation measures—human resources

5.1 Transportation and parking

Based on concerns expressed during public meetings (see Section 9), potential impacts to downtown area transportation and parking resources have emerged as a primary concern for many local businesses. Given these concerns, County representatives subcontracted the services of Sear-Brown (DeWitt, New York) to conduct a traffic study to:

• Identify traffic volumes within the select project areas (i.e., road closures)
• Evaluate the streets to be temporarily closed during construction
• Propose detour routes to accommodate traffic flow during construction

In addition, the traffic study identified on-street and off-street parking areas that will likely be influenced during the installation of the conveyances. The study was developed in coordination with the Syracuse City School District, Syracuse Police Department, Central New York Regional Transportation Authority (CNYRTA) Centro, Hanford Pharmaceuticals, Byrne Dairy, the Greater Syracuse Tenants network, the MOST, and the Clinton Street Mitigation Advisory Committee (see Section 9) (SB 2003). A copy of the study has been included as Appendix D.
Click here for Appendix D. Detour technical memo: Detour for road closures associated with Clinton Street CSO abatement project.

The following subsections provide a summary of impacted transportation and parking resources and the mitigation measures to be initiated by the County (in cooperation with local entities) to minimize these impacts to the greatest extent practicable. In addition, the County will work closely with downtown representatives [e.g., Armory Square Association, Syracuse Convention and Visitors Bureau, Clinton Street Mitigation Advisory Committee (see Section 9), etc.], so that public information is kept up to date and if traffic/parking/pedestrian issues arise, they are addressed and resolved promptly (i.e., complaint response program).

5.1.1 Vehicular traffic

The following subsections have been prepared to address anticipated street closures and detour routes, as well as construction-related and operation-related vehicular traffic, associated with the implementation and operation of the Clinton Street CSO Abatement Project.

5.1.1.1 Street closures and detour routes

A summary of pertinent street closures and detour route information as detailed in the traffic study is presented in Table 5-1. In order to facilitate the effectiveness of the detour routes identified, various improvements will be undertaken (SB 2003):

• Adequate detour signage (especially to avoid traffic from detouring onto private roadways, parking lots and/or driveways)
• Adjusting signal timing
• Modifying signal phasing
• Temporarily allow turns on select streets where it is normally restricted
• Change lane designations (e.g., convert one-way street to two-way street, utilize more than one lane for turning)
• Prohibit and/or restrict parking on select streets.

Details regarding the level of service for the affected areas utilizing the detour routes are identified in Appendix D.
Click here for Appendix D. Detour technical memo: Detour for road closures associated with Clinton Street CSO abatement project.

TABLE 5-1 TRAFFIC STUDY SUMMARY
Sources: SB 2003, *EEA 2003a
Source for figures is Sear-Brown 2003, prepared by SGD Environmental Services

Fayette Street
Proposed closure	Duration (est.)	Centro route?	Detour route
East of Onondaga Creek	6 weeks	Yes	Figures 5-1 and 5-2 (two options depicted; final to be identified with input from involved parties)

Notes:
- Except for local traffic, it is anticipated that the block from Walton Street to Franklin Street will be closed to through traffic.
- The Walton/Fayette Streets intersection will remain open so that Armory Square traffic can access Walton Street.
- For West Fayette and West Onondaga, construction will be staged such that only one street is closed at a time.

Figure 5-1. Fayette Street detour route (option 1)

Figure 5-2. Fayette Street detour route (option 2)

 

Walton Street
Proposed closure	Duration (est.)	Centro route?	Detour route
East of Onondaga Creek at the Fayette/Walton Street and the Walton Street parking lots	8 weeks	No	Figure 5-3

Notes:
- Walton Street will be closed from Fayette Street to Franklin Street, except to local traffic, but will be completely restricted in the area of the Creek.

Figure 5-3. Walton Street detour route

 

West Jefferson Street
Proposed closure	Duration (est.)	Centro route?	Detour route
Street will be completely closed on the west side of the MOST, between the MOST and the railroad tracks	16-18 weeks*	No	Traffic will be detoured to east side of the West Jefferson Street circle.

Notes:
- Complete closure will be necessary to relocate existing utilities, construct conveyances, and bore under the railroad tracks. Pedestrian traffic will be allowed through the tunnel during boring activities.
 

West Street northbound service road
Proposed closure	Duration (est.)	Centro route?	Detour route
Northbound service road from Fabius St to West St Northbound	6-8 weeks (full)*; 20-30 days (partial)	No	No detour anticipated

Notes:
- The service road will remain open during part of the construction and closed temporarily at the point where the service road meets West Street.
 

Dickerson Street
Proposed closure	Duration (est.)	Centro route?	Detour route
West of Onondaga Creek and east of the Rescue Mission Recreation Center	6 - 8 weeks	No	Figure 5-4

Notes:
- The Clinton Street northbound service road will remain open during the Dickerson Street closure but closed temporarily during the installation of conveyances along the east side of the Creek.

Figure 5-4. Dickerson Street detour route

 

Gifford Street
Proposed closure	Duration (est.)	Centro route?	Detour route
West of Onondaga Creek and east of the Rescue Mission	8 weeks	Yes	Figure 5-5

Notes:
- Gifford Street will be open to local traffic only from Granger Street to closure area. Access from the Clinton Street side will be restricted. Gifford will be converted to a two-way street to allow access to the Rescue Mission. The Clinton Street service road will remain open during the Gifford Street closure.

Figure 5-5. Gifford Street detour route

 

Clinton Street
Proposed closure	Duration (est.)	Centro route?	Detour route
Clinton Street north of Onondaga/Gifford Streets will be partially closed; no full closure required	8 weeks (partial)	Yes, but only partial closure needed	No detour is proposed since Clinton Street will remain open.

Notes:
- The Clinton Street service road will remain open during the Clinton Street partial closure.
 

West Onondaga Street
Proposed closure	Duration (est.)	Centro route?	Detour route
West of Onondaga Creek between Seymour and Clinton Streets	8 weeks	Yes	Figure 5-6

Notes:
- Concerns regarding truck traffic exiting Oneida Street onto Adams Street are currently being investigated. - For West Onondaga and West Fayette, construction will be staged such that only one street is closed at a time.

Figure 5-6. West Onondaga Street detour route

Police, fire, emergency officials, and property owners in the affected areas will be made aware of (in advance) the schedule of street closures and detour routes. Construction will be coordinated to minimize peak holiday season impacts. Notifications will be published in local newspapers and the County will work with local media representatives (e.g., radio and television) to provide information regarding detour routes and alternate parking areas (especially during downtown events and Syracuse University events).

For those businesses within construction zones, impacts to accessing driveways/private parking areas may occur. Construction will be staged such that access (including deliveries) to these businesses remains open (or alternatives available) during project implementation. Lastly, separate design meetings with these individual property owners will be held to specifically address and minimize impacts (SB 2003).

As necessary, the County will coordinate with the City of Syracuse regarding the Creekwalk project to further minimize impacts from implementation of both the project within the relatively same timeframe.

5.1.1.2 Construction-related traffic

During the construction phase of the project, various construction-related vehicles (e.g., material delivery trucks, spoil trucks, concrete trucks, backhoes, etc.) will access and egress from the streets affected by the installation of the conveyances as well as the RTF. Selection of Clinton Station will require that the County reconstruct the Fabius Street bridge for construction access to Clinton Station (as well as during operation of the RTF). Such renovation will limit RTF construction traffic from entering the Armory Square area.

It is estimated that between 0 and 75 truck trips daily will be required during the construction period for removal of spoil material and delivery of select backfill, concrete and other equipment and materials (when RTF and conveyance construction are being performed simultaneously). Truck trips associated with conveyance and force main construction will range from 0 to 20 trips per day depending upon the sections of sewer being constructed. A range of 0 to 60 trips per day are projected for the RTF during the construction period (Albright 2004).

The contractor will be required to prepare a Maintenance and Protection of Traffic (MPT) Plan that provides details regarding:

• Details regarding the detour routes (see Section 5.1.1.1)
• Appropriate signage for construction vehicles
• Utilization of flag persons
• Use of flares (as appropriate)
• Utilization of barricades and/or guard rails
• Use of reflectors and/or lights on trenches left open at night
• Parking areas for contractor personnel (see Section 5.1.4 below).

During construction, the County will closely monitor the contractor and their adherence to the MPT plan. In addition, the County will mandate that the contractor:

• Coordinate with local officials to identify the most appropriate access routes for construction vehicles to and from the affected streets.
• Make deliveries of construction material during off-peak hours to the greatest extent practicable.
• Remove construction-related vehicles when not directly involved with construction to areas of low traffic flow or to an offsite location.

Based on the above mitigation measures, impacts to local traffic from construction-related vehicles will be temporary in nature and are not considered significant.

5.1.1.3 Operation-related traffic

RTF operation and maintenance.
The RTF will typically be serviced with pickup trucks or small utility vehicles. After a wet weather event, several staff would be dispatched to wash down the facility. The bar racks and grit sump will be cleaned periodically as needed. Covered dump trucks would transport the debris to a permitted offsite landfill. Small tanker trucks would be utilized for chemical deliveries. Loading and unloading of the trucks would be performed within the building with the overhead doors closed. The frequency of deliveries and maintenance will be dictated primarily by the occurrence of a wet weather event large enough to cause CSO to be diverted to the RTF. It is estimated that up to four vehicles (pickup trucks, panel trucks, dump trucks, and sewer jet-vac trucks) per event would travel to the RTF (CDM/C&S 2003).

Operation and maintenance-related traffic would primarily utilize the Fabius Street entrance proposed for repair as part of this project, thereby minimizing traffic through the Armory Square area. Given that vehicular traffic and facility operations will blend with existing traffic in the downtown Armory Square area, no significant impacts from operation and/or maintenance of the RTF are expected.

Conveyances operation and maintenance.
The County will need to periodically inspect the conveyances and the CSO diversion chambers. This is likely to be performed annually or on an as-needed basis, for example to verify a report of a dry weather overflow or investigate a complaint. Inspections can be planned around periods of lower traffic volume for the diversion chambers, while complaints or emergencies would have to be addressed immediately for the sake of public health and safety (Albright 2003a).

5.1.2 Mass transit

For the purposes of this document, mass transit consists of Centro bus traffic, City of Syracuse School District traffic, and train traffic.

5.1.2.1 Centro bus routes

As illustrated in Table 5-1, the traffic study identified that Centro utilizes various streets within the project area. Based on this study, the majority of the street closures will not directly impact Centro (SB 2003):

• Walton Street
• West Jefferson Street
• West Street northbound service road
• Dickerson Street
• South Clinton Street

It is proposed that the bus routes along Gifford Street and West Onondaga Street (two routes affected by street closures) follow the detour routes outlined above in Section 5.1.1 to minimize impacts. Alternate routes to Fayette Street during the construction phase of the project involve the temporary removal of parking from various portions of Walton and Franklin Streets. Alternative detours for the Centro buses utilizing this route are being investigated by Centro (SB 2003). The County will work with Centro representatives to minimize construction-related impacts.

5.1.2.2 City of Syracuse School District

As described in Section 3.1.2.1, the City School District utilizes the Centro bus system for transporting children to and from City schools. As such, those routes along Fayette, Gifford, and West Onondaga Streets, will be rerouted during the construction phase of the project (see above).

5.1.2.3 Rail services (OnTrack)

The County will work closely with OCIDA and NYS&W to obtain the necessary permits and easement to work within the railroad right-of-way as well as to bore under the tracks in the West Jefferson Street area. Discussions will include the identification of measures to be employed during boring activities to address the railroad's concern regarding access and parking (particularly during sporting events) (see Section 5.1.4 below). No impacts to the rail service are expected as construction and operation of the RTF and conveyances will not involve track closure.

5.1.3 Pedestrian traffic

Sidewalks and paths exist throughout the project area. During the construction phase of the project, pedestrian access to sidewalks and, therefore, businesses will be temporarily rerouted as needed. However, access to existing businesses will be maintained during construction through adherence to the following activities, as applicable:

• Temporary pedestrian bridges will be used during excavation that requires street closures.
• Signs will be provided throughout the affected areas to guide patrons to businesses.
• A review of pavement markings and crosswalks will be conducted to ensure well-marked pedestrian facilities during construction. The County will provide hatched crosswalks to improve visibility during construction.
• Covered walkways with plexiglas-type windows will be utilized to protect pedestrians while allowing pedestrians to observe construction activities.
• Separate design meetings with these affected property owners will be held to specifically address concerns and minimize impacts.

Currently only the northbound service road of West Street has a sidewalk to allow pedestrian traffic from the Fabius Street area to Walton Street. As such, a pedestrian access route along West Street to enable pedestrian traffic to Walton Street will be designed during construction. Collectively, given the above mitigation measures, pedestrian traffic will continue to be able to access the downtown area within the project area.

5.1.4 Parking

The traffic study prepared by Sear-Brown (2003) identified the on-street parking and off-street parking lots to be impacted during construction of the conveyances. The siting of the RTF at Clinton Station will impact available parking at the parcel itself since the site is currently a 700-space parking lot. Table 5-2 provides a summary of the parking areas expected to be impacted as a result of the construction and operation of the Clinton Street CSO Abatement Project (RTF and conveyances).

TABLE 5-2 ANTICIPATED PARKING CLOSURES
Sources: SB 2003, *EEA 2003a
See Figure 5-7 for project area

Project area	On-street parking	Off-street parking
RTF site (Trolly Lot)	NA	No impact to 245 spaces (est.), temporary closure of estimated 185 spaces (during construction only), and the permanent closure of 270 spaces (northwest portion of Clinton Station parking lot).

Notes and mitigation measures:
- A separate detailed parking resources development plan will be prepared (see Section 5.1.4.2) to mitigate the permanent loss of an estimated 270 parking spaces (430 estimated spaces would remain available in the Clinton Station parking lot following construction activities).
 

Project area	On-street parking	Off-street parking
Fayette Street	4-6 metered temporarily closed	Temporary partial closure of Mill Pond Landing 80-car surface parking lot.

Notes and mitigation measures:
- As previously noted in Section 5.1.1, two options exist for the Fayette Street detour.
- Depending on option selected, temporarily parking from one side of Walton and both sides of Franklin Street between Fayette and Walton will be closed. Centro is reportedly evaluating detours for the Centro buses.
- The extent of any partial closure will be identified during design. Separate design meetings will be held with the affected owners to specifically address/minimize impacts.
 

Project area	On-street parking	Off-street parking
Walton Street	4-6 metered temporarily closed	Temporary partial closure of Mill Pond Landing 80-car surface parking lot. Temporary partial closure of the Walton/Jefferson (Butler) 75-car surface parking lot.

Notes and mitigation measures:
See comment for Fayette Street options and associated on-street parking impacts.
During the Clinton Street CSO Abatement Project, the two lots will not be partially closed at the same time.
The extent of any partial closure will be identified during design. Separate design meetings will be held with the affected owners to specifically address/minimize impacts.
 

Project area	On-street parking	Off-street parking
West Jefferson Street	Parking on west side of MOST circle	Temporary partial closure of the Walton/Jefferson 75-car lot (Butler lot). MOST back entrances may be impacted.

Notes and mitigation measures:
The extent of any partial closure will be identified during design.
Separate design meetings will be held with the affected owners to specifically address/minimize impacts.
 

Project area	On-street parking	Off-street parking
West Street northbound service road	Parking along service road temporarily closed	None

Notes and mitigation measures:

 

Project area	On-street parking	Off-street parking
Dickerson Street	None	None
Gifford Street	20-25 parking spaces along road (both sides) will be temporarily closed	None

Notes and mitigation measures:
Alternate parking arrangements will be coordinated with the Rescue Mission.
 

Project area	On-street parking	Off-street parking
Clinton	Small parking lots under & adjacent to conveyances at Clinton may warrant closure during const. Given nearness of lots to Clinton Station, need for alternate parking will be identified during prep of parking resources dev plan.	-

Notes and mitigation measures:

 

Project area	On-street parking	Off-street parking
West Onondaga Street	None	None

Notes and mitigation measures:

Click to enlarge

Figure 5-7 shows the parking lots that will be affected. See Table 5-2, above.

5.1.4.1 Conveyance impacts and mitigation measures

No permanent parking replacement will be required as a result of installing the conveyances. Parking patterns will, however, be temporarily altered during the construction of the conveyances. Table 5-2 identifies measures to be undertaken by the County to minimize the temporary loss of parking as the installation of the conveyance progresses along the affected streets. In addition, the following general measures will be initiated:

• The County will develop temporary alternative parking plans with adequate signage and notification to business owners and the general public. Notifications such as press releases, webpage listing (e.g., Armory Square's webpage), and direct mailings may be used. Signage will differentiate between weekday and weekend/weekday evening parking locations.
• To maximize parking available to downtown patrons, contractors will be required to park outside the Armory Square area.
• The County will request that the City review Clinton Street operations and possibly add parking along the five-lane section of the street during construction.
• To encourage travel into the area during construction, the County will discuss with the City waiving of parking meter fees (with parking time limits).

It should be noted that a parking availability assessment conducted by the City identified that sufficient vacant parking spaces currently exist within the Armory Square area. In May 2002, the City of Syracuse collected parking data in the Armory Square area to evaluate potential parking impacts associated with the development of the proposed Creekwalk. In summary, the City assessment identified that vacant spaces during peak parking demand are available (i.e., noon on weekdays and from 8pm to 12am on weekends). Specifically, the assessment estimated that in the Armory Square area 688 vacant spaces are currently available during the weekday and 965 vacant spaces are currently available for parking on the weekend (Rauber 2002). As such, the findings of the assessment demonstrate that parking will be available in the immediate Armory Square area during the partial closures of the above parking lots and the metered parking spaces.

The 2002 City assessment described above also identified the permanent loss of 95 parking spaces due to the construction of the Creekwalk (Rauber 2002); no permanent parking will be lost due to the Clinton Street CSO Abatement Project conveyances. Given that 95 spaces will be lost due to the Creekwalk, weekday vacancy of up to 593 weekday parking spaces (870 spaces weekend) will be available in the Armory Square area following Creekwalk construction. Based on this information, sufficient Armory Square area off-street parking will be available (weekdays and weekends) during the construction of the conveyances. Mitigation measures associated with Clinton Station are discussed below. Therefore, with mitigation, construction of the Clinton Street CSO project will not have an adverse impact on the available parking resources in the surrounding area. Measures that could be considered to enhance available parking resources and implemented in conjunction with Clinton Station are discussed below.

5.1.4.2 Clinton Station parking enhancement measures

Construction of the RTF at Clinton Station will affect an estimated 455 parking spaces within the lot (185 temporarily and 270 permanently, estimated). The City parking availability assessment identified that 688 weekday and 965 weekend vacant parking spaces are currently available (following Creekwalk construction an estimated 593 weekday and 870 weekend vacant parking spaces will be available). These figures demonstrate that sufficient parking will exist during the construction phase of the RTF (as well as following construction of the Creekwalk). The County supports the need for an adequate parking inventory within the downtown central business district in order to maintain existing businesses as well as attract new business. As of the writing of this document, specific details regarding measures designed to develop/enhance alternate parking during construction and operation of the RTF had not been finalized. Alternatives discussed during Mitigation Advisory Meetings and among County representatives, but not officially endorsed by the County at this time, include:
 
Construction phase parking alternatives under consideration :
- Subsidize current patrons of the Clinton Station parking lot who volunteer to relinquish their parking spaces.
- County purchase of available parking passes at other existing garage and sell them at subsidized rates to Clinton Station parking lot patrons.
- Develop a new temporary parking lot.
- Provide a direct subsidy to the City that would be applied by the City to reduce monthly rates to accommodate lost parking spaces within a City-owned parking lot/garage.
 
Post-construction parking alternatives under consideration:
- Following construction of the RTF, allow parking at the Clinton Station parking lot outside the immediate area of the RTF. It is estimated this parking area would provide 430 spaces.
- Construct a parking deck within the Clinton Station parking lot.
- Develop one or more new surface parking lots.
- Provide parking mitigation funds to assist existing parking projects such as the parking garages proposed for Excellus and HaRTFord (see Section 3.2.2.4).
- Mitigation measures will focus on cost-effective enhancement.

For this project, the County seeks to work cooperatively with organizations such as the City of Syracuse, the Downtown Committee, the Armory Square Association, and Syracuse 20/20 to develop and implement a parking resource development program that will mitigate adverse parking disruptions.

5.2 Existing and planned land use

5.2.1 Existing land use

An urbanized setting of commercial, retail, and light industrial, with recreational and residential land uses, typify the project area (see Section 3.2.1). As such, it is the County's opinion that the proposed CSO facilities and conveyance pipes are compatible uses with the existing land uses within the project area. The project is a public works project intended to protect the health and welfare of the public and to improve the water quality of Onondaga Creek that flows through the project area and to Onondaga Lake. As such, even were it to be determined that the project was not compatible with the project area, the public need and benefits to be gained from the project immunize the project from any local zoning restrictions that might be construed as inconsistent with project implementation.

The character of the proposed RTF is benign in its operation, and its architecture will be compatible with other building structures in the area. The RTF will include an aboveground building approximately 1.5 stories in height, constructed of concrete and masonry sound proof building materials, and designed with a state-of-the-art activated odor control system. In addition, as noted above in Section 5.1 - Transportation, the County will develop and implement a parking resources development program that will mitigate parking disruptions due to the siting of the RTF at Clinton Station. As such, significant long-term impacts from the RTF will not occur.

Potential impacts during construction.
The route of the conveyances will be within street rights-of-way, vacant lots, parking lots (private and public), and along and within Onondaga Creek (see Figures 1-7 and 1-8). The installation of the conveyance pipes will restrict building development atop the conveyances, but will be compatible with current and proposed land uses (such as the Creekwalk and surface parking amenities). During the construction phase of the project, however, a community concern expressed to the County appears to be the potential loss of patrons to the downtown area.

Construction-related mitigation measures.
Permanent dedication of land for public infrastructure and facilities is a legitimate and necessary function. The lack of critical infrastructures and facilities can also be an impediment to urban development. Disregard for the existing and potential future urban uses and building and landscape forms could result in degradation of current land uses and/or inhibit future economically beneficial uses.

The County will work closely with businesses, local planners, and the City prior to and during construction of the project. To date, the following activities have been identified and will be undertaken by the County to minimize impacts to area businesses:

• The County proposes to undertake mitigation measure to the extent practicable to maintain vehicular and pedestrian flow in the project area.
• During construction, a full-time construction management and inspection program will exist.
• A complaint response program will be utilized: Project representatives will be on the construction site continuously and will develop an ongoing relationship with adjacent businesses and residents with regard to construction-related concerns and issues. The representatives will work closely with the project contractors to see that issues or incidents are quickly addressed/resolved. The County will also publish a telephone number(s) so that individuals can report complaints or make other comments.
• Meetings will be held on a regular basis to allow an opportunity for residents or businesses to discuss any issues or incidents directly with representatives of the contractor, project engineer and the County. The time, dates and locations of these meetings will be established for the duration of the construction project and written notifications of the meeting schedule will be distributed throughout the impacted area.
• Newsletters will be published on a regular basis and distributed to residents and businesses in the impacted area. The newsletters will provide information of the status of the construction project.
• The County will work in coordination with the impacted businesses, residents and organizations to produce appropriate public information materials in order to inform the public at large regarding traffic detours, parking alternatives and business access plans.
• The County will work with local media representatives (e.g., radio and television) and provide information regarding detour routes and alternate parking areas (especially during downtown events and Syracuse University events).
• A public information brochure will be produced to depict the improvements being developed within the area. This brochure will highlight the new Dickerson Street bridge (if applicable), the Syracuse Creekwalk, and the cleanup of Onondaga Creek and Lake through the removal of untreated combined sewer overflows.
• Construction will be coordinated to minimize peak holiday season impacts through coordination efforts described above.
• A business compensation program, proposed by the Armory Square Association, is being considered by the County.
• The County will assess providing nighttime security for the construction work zone.
• Hold events during construction to celebrate completion of critical phases and announce new detours.
• Upon completion, celebrate the "closing of the ditch" to attract patrons to the downtown area.

In summary, implementation of the above-described mitigation measures will result in relatively minor impacts to area land use when compared to the benefits of such a project. Based on the information presented above, impacts to land use from the construction and operation of the Clinton Street CSO Abatement Project will be minimized to the greatest extent practicable.

5.2.2 Planned land use by others

New development and re-development is planned by the City of Syracuse and private developers within the general downtown and Clinton Street combined sewer service area. The Clinton Street CSO Abatement Project may have short-term adverse impacts associated with construction, which the County will endeavor to mitigate to the extent practicable. Long-term impacts will be positive resulting from:

• Significant improvements in water quality in Onondaga Creek and Onondaga Lake.
• Reduction or elimination of sewage-type odors within and beyond the project area.
• An attractive urban building (RTF) and landscaped site.

As such, enhancement to Creek conditions will improve the success of proposed projects such as the Onondaga Creekwalk, Rescue Mission park plans, and other existing or proposed recreational facilities along Onondaga Creek and Onondaga Lake. As described below, it is the County's objective to work closely with the City and local businesses regarding construction schedules and activities planned for the immediate future.

5.2.2.1 Proposed Onondaga Creekwalk

No permanent loss of parking from installation of the underground conveyances will occur (see Section 5.1); temporary parking and traffic-related impacts during the installation of the conveyances in the vicinity of the proposed Creekwalk will occur.

Above grade structures will not be allowed to be built over the conveyances. Such dedication of open space is consistent with the City's plan to develop this area for a Creekwalk. Coordination of project schedules for the Creekwalk and conveyances will minimize the duration of impacts. Without such coordination, construction of the conveyances and the Creekwalk in the West Jefferson to Fayette Street area would result in unnecessary and/or prolonged impacts to both environmental and human resources (e.g., geology, water, and traffic patterns) in the area.

A potential additional benefit to coordination activities includes the possible assistance by the County in the development of the Creekwalk (i.e., subsurface preparation and/or non-federal financial assistance). This measure will assist in minimize impacts (environmental, human and financial) associated with the construction of the Creekwalk. In summary, impacts from the construction of the West Jefferson to Fayette conveyances and Creekwalk can be mitigated through the coordination of construction activities with the City as described above.

5.2.2.2 Proposed Dickerson Street replacement

Depending on construction schedules the County will endeavor to work with the City to minimize construction-related impacts should the Dickerson Street conveyance construction activities coincide with the Dickerson Street bridge replacement activities. Collectively, therefore, impacts from construction activities would be minimized to the greatest extent possible.

5.2.2.3 Proposed Hanford Pharmaceuticals expansion

Given that the construction of the conveyances will be within the West Street service road right-of-way (outside the proposed expansion area of the Dupli Graphics building), direct impacts to the expansion efforts planned by Hanford Pharmaceuticals are not anticipated. As described above in Section 5.1.1, the County will continue to work closely with the pharmaceutical company prior to and during conveyance installation in this area to minimize construction-related impacts.

5.2.2.4 Other possible downtown planned land uses

Impacts to the New York State funded projects (parking garages and Landmark upgrades) are not expected as these projects are outside the project area. Renovations to the former Dunk & Bright building are anticipated by SU. The Rescue Mission's park plans between West Onondaga and Gifford Streets will commit the area to open space. Such land use will be consistent with that required from the installation of the conveyances. In summary, no long-term impacts from the installation of the conveyances in these areas are expected. In addition, as described above in Section 5.1.1, during the construction phase of the project, the County will continue to work closely with the Rescue Mission and SU to minimize construction-related impacts.

5.2.3 Noise

P.It otential impacts. According to the NYSDEC, "noise is defined as any loud, discordant or disagreeable sound or sounds." A number of environmental factors, however, dictate the level or perceptibility of noise at a given point of the receptor. These factors include:

• Distance (sound decreases with distance).
• Multiple sources (sound is not cumulative).
• Temperature, humidity, and wind direction (relatively insignificant role in sound perception).
• Structures (can influence perception: windows open vs. closed, and structures can act as barriers or can produce a canyon effect).
• Sound characteristics (sharp and startling vs. continuous and dull) (NYSDEC 2001).

In order to assess the noise-related impacts, consideration of the existing background levels in the project area, as well as the anticipated noise levels of equipment to be used must be evaluated.

The following provides a summary of typical sound levels:
 

Source	Level (dBA)	Distance (feet)
Quiet suburban area nighttime	40	--
Quiet urban area	50	--
Undisturbed speech	65	3
Commercial area	65	--
Garbage truck	71-83	50
Highway traffic	75	50
Noisy urban daytime	75	--
Freight train	75	50
Bulldozer	80	50
Jackhammer	82	50
Backhoe	83-86	50
Diesel truck	91	50
Sources: NYSDEC 2001, Landrum and Brown 2001

Notes: dBA = sound pressure level or perceived loudness expressed in A-weighted decibel scale (dBA) which is weighted towards those portions of the frequency spectrum most sensitive to the human ear.

Typical human reactions to increases in sound levels above background are as follows (NYSDEC 2001):
 

Increase in sound pressure (dB)	Reaction
Under 5	Unnoted to tolerable
5 - 10	Intrusive
10 - 15	Very noticeable
15 - 20	Objectionable
Over 20	Very objectionable to intolerable

Click to enlarge

Figure 5-8 shows noise dissipation at the northern end of the project area.

Based on the above information, the dissipation of noise from common construction-related equipment was evaluated. Table 5-3 provides a summary of two noise dissipation scenarios.
 

 

Table 5-3 Noise Dissipation Analysis Typical scenario: Jackhammer operation.
Distance*	Decibel level and reaction outside	Decibel level and reaction inside
50 ft	82 objectionable (+17 above background)	~67 - 77 decibel tolerable to very noticeable (+2 - 12 above background)
200 ft	71 intrusive (+6 above background)	~56 - 66 decibel not audible to tolerable (? +1 above background)
800 ft	66 unnoticed to tolerable (+1 above background)	~51 - 61 decibel not audible (< background)
1600 ft	65 not audible (at background)	~50 - 60 decibel not audible (below background)

Worst case scenario: Jack hammer, backhoe, and truck operating at the same time
50 ft	92 very objectionable to intolerable (+27 above background)	~77 - 87 decibel very noticeable to intolerable (+12 - 22 above background)
200 ft	80 very noticeable to objectionable (+15 above background)	~65 - 75 decibel background to intrusive/very noticeable (+0 - 10 above background)
800 ft	70 intrusive (+5 above background)	~55 - 65 decibel not audible (? background)
1600 ft	67 unnoticed to tolerable (+2 above background)	~52 - 62 decibel not audible (below background)

Notes:
* = Approximate
Assumed background: commercial area: 65 decibels
Influence of other structures not accounted herein (e.g., barrier/canyon effect)
Noise dissipation levels are approximate and designed to provide insight into potential noise levels in project area during construction; values based on literature review. No physical studies were conducted.
Equip. decibel levels, calculated levels, & human reaction(s) based on DEC: Assessing and Mitigating Noise Impacts (2002).

Click to enlarge

Figure 5-9 shows noise dissipation at the southern end of the project area.

In summary, based on the above information, as construction activities progress along the route of the conveyances, impacts to area receptors will diminish. Although construction of the RTF will have the longest period of construction, impacts to area receptors will be limited at Clinton Station given the buffer the railroad tracks offer. As described below, initiation of the mitigation measures will further minimize impacts to area receptors.

Mitigation measures.
Table 5-4 has been prepared to identify mitigation measures associated with identified noise-related impacts.

TABLE 5-4 NOISE-RELATED MITIGATION MEASURES

Noise from construction equipment will be audible within the project area during the construction of the RTF and conveyances. However, the impacts will be limited to the duration the construction activities take place. It is anticipated that noise from facility operations (e.g., influent pumps, odor control equipment, and ventilation blowers and fans) beyond the property limits of the RTF site will not occur based on the design measures to be employed by the County. Given the above noise avoidance and reduction measures to be employed by the County, expected sound levels will not produce significant long-term noise impacts or permanently impair the use of neighboring properties.

5.3 Community services

5.3.1 Fire, police, recreation and utilities

The Clinton Street CSO Abatement Project will not place an unusual burden on community services such as fire, police, recreation, or utilities:

In summary, significant impacts to community services, recreational facilities, and local utilities are not anticipated. Disruptions in the current transportation network will be short-term and mitigated to the greatest extent practicable based on community and City-identified concerns.

5.3.2 Waste management

5.3.2.1 Waste management during construction - general practices

Left unmitigated, construction-related impacts could include aesthetic impacts from disorderly and unsightly work areas and accidental releases of materials such as petroleum products and/or lubricants used onsite by the contractors. Construction mitigation measures include the following:

• Dumpsters will be closed when not in use and locked at night.
• Fuels and lubricants stored onsite will be kept in locked, well-maintained storage areas accessible only by authorized personnel.
• Site-specific health and safety plans will be required for contractors working onsite.
• The County will utilize a complaint response program.
• C&D debris will be removed in a timely manner based on contract requirements.
• Contractors will be required to properly dispose of C&D debris at a licensed offsite facility.

5.3.2.2 Waste management during construction - contaminated materials assessment

Federal and state regulations will govern the County's management of contaminated materials if identified during the construction phase of the project (e.g., contaminated soils, asbestos-containing materials, and lead-contaminated building materials). Based on a Phase I Environmental Assessment (draft) conducted by EEA in July 2003, several properties located in the RTF area, northwestern, northeastern, and southern conveyance areas have been used at different times for commercial/industrial activities that may pose potential environmental concern (EEA 2003b).

During trench excavation activities associated with archeological studies (Section 3.5.1), field screening with a photoionization detector was performed. In addition, a limited number of soil samples were collected and analyzed as part of the Phase I Environmental Assessment. As reported by EEA (2003), although field screening of soils detected the presence of volatile organic compounds (VOCs) in some locations, subsequent laboratory analysis did not indicate the presence of elevated VOCs (EEA 2003b).

Semi-volatile organic compounds (SVOCs) and Resource Conservation Recovery Act (RCRA) metals were detected in samples collected from some of the archeological trenches. As reported by EEA (2003), the presence of such parameters is potentially associated with fill at and in the vicinity of the site. While standards for fill in soils in former industrial sites have not been developed by New York State, the levels detected in the samples collected during the Phase I Site Assessment were below New Jersey historic fill criteria (EEA 2003b).

Two ground water samples were collected from observations wells at the RTF area. Two parameters (lead and selenium) were detected in one well at concentrations slightly above state ground water standards (EEA 2003b).

While ongoing remedial activities supervised by the state are being conducted at one of the commercial locations identified during the Phase I Environmental Assessment, EEA recommended that various soil and ground water investigations be conducted "to determine if there are impacts to the site from historic operations." Such investigations, referred to as a Phase II Environmental Assessment, included advancing soil borings and installing temporary wells at or adjacent to identified areas of concern. Soil and ground water samples would be collected for VOC, SVOC, polychlorinated biphenyl (PCB), and RCRA metal analyses. The data from the Phase II investigation would be used for the following purposes as warranted or as needed:

• To aid the construction contractor with preparing a worker and community Health and Safety Plan to mitigate potential exposures to constituents in soil/ground water
• To identify appropriate handling techniques for impacted soil and ground water removed during construction activities.
• To identify disposal procedures for impacted ground water (e.g., discharge to the environment following treatment, discharge to sanitary sewer, etc.).
• To aid the County with identifying fair market prices for properties that may be impaired due to environmental conditions (EEA 2003b).

In addition, based on the results of the Phase I Environmental Assessment, EEA (2003b) recommended that prior to demolition of structures, a visual survey be conducted to assess the need for (and scope of) characterization activities (e.g., building material sampling, etc.), including a thorough asbestos inspection.

5.3.2.3 Waste management during operation

No impacts from waste management activities during facility operation are anticipated. As conditions dictate, sanitary and non-sanitary solids and floatables will be pumped from the RTF and transported by a force main to the main interceptor sewer for treatment at Metro. Larger materials and grit (approximately 500 cubic yards/year) will be removed from the site on a periodic basis and disposed at a New York State permitted landfill/waste incinerator (EEA 2003a). This quantity of material does not represent a significant increase in waste generation.

5.4 Demographics

5.4.1 Population

According to SOCPA records, the City has experienced a decrease in population since the 1950s (SOCPA 2003a). More recently, as previously noted in Section 3.4.1, the City of Syracuse has experienced a 10% decrease in population since 1990. The Clinton Street CSO Abatement Project has been designed to improve the quality of effluent-related discharges to Onondaga Lake, decrease odors associated with combined sewerage entering the Creek, and improve water quality and aquatic habitat. These improvements, coupled with anticipated planned land uses in the area (see Section 5.2.2), may help facilitate or encourage the redevelopment of commercial and residential uses (or create new opportunities for such) within the immediate project area.

5.4.2 Housing

Based on the siting of the conveyances (see Figures 1-7 and 1-8), no residential structures will be demolished as a result of installation activities (one vacant commercial building will be demolished at the corner of West Onondaga Street and Clinton Street). In addition, permanent impacts to residential structures will not occur since the RTF will be constructed at Clinton Station, an area devoid of structures. As such, based on this information, no long-term negative impacts to residential structures within the project area will occur. To the contrary, as noted above, the implementation of the project will improve area aesthetics for existing residents and may encourage the redevelopment of residential properties within the area.

5.4.3 Employment

Construction-related.
Until such time that the Clinton Street CSO Abatement Project has been fully defined and design has been initiated, it would not be appropriate to proceed with preparation of a labor estimate specifically for the project. As the Midland Phase II project and the Clinton Street CSO Abatement Project are of comparable size, it is believed that the average labor force requirements over the construction period would be similar (Albright 2003b):

• Startup activities (shop drawing submission, mobilization and site preparations) and closure activities (demobilization, punch list and finish work): less than 10 workers.
• Construction activities: 13 - 153 workers (Note: peaks are expected to be different due to variations in the scope and phasing of the work).

The Clinton Street CSO Abatement Project will require that 10% of the workforce be contracted to minority-owned business enterprises (MBE) and 5% to woman-owned business enterprises (WBE). Contractors will also be required to achieve an Equal Employment Opportunity goal of hiring 10% minority employees and 5% female employees as part of the project workforce. As with other CSO projects, the Clinton CSO Abatement Project is subject to a Project Labor Agreement.

Operational.
The automated design of the RTF will allow it to operate without full-time staff assigned to the facility. Current OCDWEP personnel will be required to perform periodic maintenance of mechanical, electrical, control, and building systems/components. Maintenance personnel will be required for wash down after wet weather events. As such, workforce increases within the OCDWEP are not expected.

5.4.4 Economics

5.4.4.1 Regional and local economics

Implementation of the projects associated with the ACJ-mandated Lake Improvement Program represent the largest single municipal capital improvement project in Onondaga County history. To minimize adverse impacts to the local economy, the Lake Improvement Program is being partially funded by federal and state grants. Without grant funds, however, the cost of constructing and operating the individual ACJ projects would represent a significant drain on the local economy. Further, since much of the work is anticipated to be completed by local companies (including labor), much of the expenditures from the ACJ projects will stay local. At the time of the ACJ negotiations, Onondaga County and Central New York were in the midst of a significant economic slow down that started in the early-1990s and extended throughout the late-1990s. Construction-related jobs for the Lake Improvement Program (as well as others in the area) are now on the rise and the County is working with local labor unions and training agencies to gear up the area's workforce to fill the necessary jobs (EEA 2000).

The cost of the Lake Improvement Program, including operational expenses, will be born by the Onondaga County Sanitary District, which includes approximately two-thirds of the County's population and most of the businesses and industry. Therefore, the cost of the program will not fall unfairly on any one particular City or County resident. The total 15-year impact of the program on the sewer unit charge has been estimated to be approximately $234 per unit. The increase is projected to rise over the period of 15 years between $5 and $25 per year (Karsinski 2005). The total estimated project cost for the Clinton Street CSO Abatement Project (in-line storage/vortex separator RTF at Clinton Station) is $71,300,000 (EEA 2005).

5.4.4.2 Local business district

During construction, the potential loss of patrons could potentially cause disruptions to a small number of businesses. The County will work closely with businesses, local planners, and the City prior to and during construction of the project to minimize overall economic impacts during construction. As previously noted in the Land Use section (Section 5.2.1), the following activities will be undertaken by the County:

• The County proposes to undertake mitigation measure to the extent practicable to maintain vehicular and pedestrian flow in the project area.
• During construction, a full-time construction management and inspection program will exist.
• A complaint response program will be utilized: Project representatives will be on the construction site continuously and will develop an ongoing relationship with adjacent businesses and residents with regard to construction-related concerns and issues. The representatives will work closely with the project contractors to see that issues or incidents are quickly addressed/resolved. The County will also publish a telephone number(s) so that individuals can report complaints or make other comments.
• Meetings will be held on a regular basis to allow an opportunity for residents or businesses to discuss any issues or incidents directly with representatives of the contractor, project engineer and the County. The time, dates and locations of these meetings will be established for the duration of the construction project and written notifications of the meeting schedule will be distributed throughout the impacted area.
• Newsletters will be published on a regular basis and distributed to residents and businesses in the impacted area. The newsletters will provide information of the status of the construction project.
• The County will work with local media representatives (e.g., radio and television) and provide information regarding detour routes and alternate parking areas (especially during downtown events and Syracuse University events).
• The County will work in coordination with the impacted businesses, residents and organizations to produce appropriate public information materials in order to inform the public at large regarding traffic detours, parking alternatives and business access plans.
• A public information brochure will be produced to depict the improvements being developed within the area. This brochure will highlight the new the Dickerson Street bridge (if applicable), the Syracuse Creekwalk, and the clean up of Onondaga Creek and Lake through the removal of untreated combined sewer overflows.
• Hold events during construction to celebrate completion of critical phases and announce new detours.
• Upon completion, celebrate the "closing of the ditch" to attract patrons to the downtown area.
• Construction will be coordinated to minimize peak holiday season impacts through coordination efforts described above.
• A business compensation program, proposed by the Armory Square Association, is being considered by the County.
• The County will assess providing nighttime security for the construction work zone.

Collectively, based on the information presented above, impacts to local businesses from the implementation of the Clinton Street CSO Abatement Project will be minimized to the greatest extent practicable. Aside from meeting ACJ mandated requirements to improve the water quality of Onondaga Creek, implementation of the project may induce both commercial and residential growth of the area on a long-term basis.

5.5 Cultural resources

5.5.1 Historic and archeological resources

A Letter of Understanding between the County and OPRHP regarding the Onondaga Lake Improvement Project was signed in April 2000. Consistent with the terms identified in the letter (as well as the National Historic Preservation Act of 1966), detailed studies have been performed and documented by Hartgen (2001 and 2003) that indicate historic and archeological resources exist in the project area. Mitigation measures identified to date [as recommended by Hartgen (2003)] include avoidance of select areas known to be culturally sensitive and/or a combined Phase II/III archeological investigation. The County will continue to consult with OPRHP (in conduction with Onondaga Nation) to minimize impacts to the historical and archeological resources of the project area.

5.5.2 Visual and aesthetic resources

Potential impacts.

Significant aesthetic impacts are those that may cause a diminishment of the public enjoyment and appreciation of an inventoried resource, or one that impairs the character or quality of such a place (NYSDEC 2000a).

Given that conveyances will be underground, discussion regarding visual impacts is limited herein to the presence of the RTF building. As described in Section 1.3, the RTF is estimated to be a 25-foot tall, 40,000 square foot (maximum) structure; essentially a 1.5-story building. A stack approximately 10 feet above the rooftop will also be visible. As described below, based on the building height and location (RTF will be located behind the elevated railroad embankment and creek bank vegetation), building visibility will be largely obscured or blend into the existing downtown setting.

Sensitive receptors and state-recognized historic sites within 1000 feet of the RTF site:

• Gethsemane Holiness Church at 201 Gifford Street (sensitive receptor)
• Rescue Mission complex on Gifford Street (sensitive receptor)
• PEACE West Side Center at 200 Wyoming Street (sensitive receptor)
• Armory Square Historic District (a National Register Listed site)
• 206 Gifford Street (a historic site eligible for listing)
• Clinton Plaza Apartments at 550 South Salina Street (sensitive receptor)
• Hanford Pharmaceuticals at 429 West Street (sensitive receptor)
• Galaxy Communications at 235 Walton Street (sensitive receptor)

Due to the presence of the elevated railroad embankment (which ranges in height from an estimated 8 - 20 feet), views of the RTF building from the Armory Square Historic District will be substantially obscured. Views from the PEACE Center, Galaxy Communications and the Gifford Street sites (206 Gifford, Church, and Rescue Mission) will be largely obscured due to other multi-story buildings, vegetation located along Onondaga Creek, and the intervening distances between the RTF and receptors.

The RTF will be visible to workers at Hanford Pharmaceuticals having windows on the east side of the building (approximately 10-15 windows), residents of Clinton Plaza Apartments having windows on the west side of the building (approximately 50), and persons continuing to park their cars at Clinton Station after project completion (Clare 2003). Occupants of multi-story commercial and residential properties, such as Hawthorne Suites, Hotel Syracuse, MONY building, Chimes building, Marx Hotel, etc. will be capable of seeing the RTF.

Mitigation measures.
Views of the RTF building will likely be limited to nearby structures at, or above, the height of the RTF structure due to the following:

• The topography of the surrounding area is relatively flat (400 ft above sea level) thus limiting views of the structure.
• The location of the RTF building on the northern portion of the Clinton Station parcel is away from Clinton Street/Dickerson Street and commercial traffic.
• The RTF building height is relatively short (approximately 25 feet or 1.5-story) with an estimated 10-foot stack.
• The RTF building will be located behind the elevated railroad embankment that ranges in height from an estimated 8-20 feet.

To further improve the aesthetics of the area to the sensitive receptors and historic properties identified herein, as well as to commercial and residential properties within view of the RTF, the mitigation measures listed below will be undertaken by the County. These measures not only minimize the view of the RTF building from neighboring buildings but significantly reduce and obscure the view of the RTF from ground level as pedestrians (residents and/or patrons) travel downtown.

• The building will house only the minimum amount of equipment and staff-related space necessary to operate effectively the RTF building thus minimizing the footprint of the building to the greatest extent practicable.
• The building site will be landscaped and the building and site will be properly maintained by the County.
• The architecture of the building will be compatible with other buildings within the project area.

Based on the above measures, the RTF will not present adverse aesthetic effects. No impacts that diminish the public enjoyment and appreciation of the inventoried resources, or that impairs the character or quality of such a place, have been identified. From ground level within the Armory Square area, view of the RTF will not be possible. In addition, the RTF will be designed and landscaped to be compatible with surrounding architecture and, as such, will enhance the overall appearance of the view shed by replacing part of a barren parking lot and neglected creek bank with an attractively designed and landscaped facility. Furthermore, as described herein, the Clinton Street CSO Abatement Project provides an opportunity for a secondary aesthetic improvement of the proposed Creekwalk along Onondaga Creek. The project provides an opportunity, both timely and economically, to assist with the extension of the Walton Street to Fayette Street portion of the Creekwalk.

5.6 Environmental justice review

The state's environmental justice policy is "designed to ensure fair treatment and meaningful involvement of all people, regardless of race, color or income, with respect to the development, implementation and enforcement of environmental laws, regulations and policies" (NYSDEC 2003b). The state's policy applies to NYSDEC applications requiring review of major projects or major permit modifications such as SPDES that could impact a potential environmental justice area. An environmental justice area is described by the state as a minority or low-income community that may bear a disproportionate share of the negative environmental consequences resulting from project operations or the execution of governmental programs and policies. Applicable state environmental justice definitions are as follows (NYSDEC 2003a):

The USEPA recognizes that census data are useful for screening analyses, but results should always be validated through other means, including public participation, touring the community, and talking with local officials and community leaders.

Given that the Clinton Street CSO Abatement Project will involve the issuance of a SPDES permit, a preliminary assessment of potential environmental concerns was undertaken. The steps used to assess such concerns consist of the following:

• Identify the area to be affected by the project.
• Evaluate whether the affected area consists of a minority and/or low-income community.
• Identify the potential adverse environmental impacts of the project.
• Evaluate whether the potential adverse environmental impacts are likely to disproportionately impact the identified environmental justice area.

The Clinton Street CSO Abatement Project EID embodies the review elements that can be used to assess whether the proposed project places a disproportionate amount of adverse environmental, economic, social, or health impacts on low-income and/or minority populations. The following subsections provide a preliminary assessment of environmental justice applicability with regard to the Clinton Street CSO Abatement Project based on the above methodology.

5.6.1 Affected project area

In assessing environmental justice, the County's review focuses on the potential impacts associated with the construction and operation of the RTF. In an effort to locate the most viable site for the RTF, an alternatives review process (Section 7) and numerous community meetings were conducted, including those with representatives from neighboring residential communities (see Section 9). To meet the requirements of the ACJ, placement of facilities associated with the Clinton Street CSO Abatement Project is limited to the downtown area since the CSOs to be abated are located along Onondaga Creek in this area 1-2). Based on this requirement, the majority of the conveyance lines must parallel the Creek where the CSOs exist. For this reason regardless of where the RTF is sited, common conveyance routes exist along West Onondaga to Dickerson, West Street (northbound service road), and West Jefferson to Fayette Streets.

Given that the RTF is the only above ground structure associated with this abatement project, the affected project area is considered that area surrounding the RTF building itself. The selection process for siting the RTF was based on environmental evaluations (including impacts to natural and human resources) and engineering evaluations; the process was conducted independent of factors such as income or ethnicity. As a result of the above selection process, as described in greater detail in Section 7, Clinton Station was identified by the County as the recommended/preferred siting alternative for the RTF (see Figure 1-7). In summary, siting of the RTF at Clinton Station offered the least overall impact to the community while remaining the most cost effective alternative.

5.6.2 Affected communities

Land use within the project area is comprised largely of parking, street rights-of-way, and commercial/light manufacturing (Hanford). Residential properties such as the Rescue Mission, Clinton Plaza Apartments, and the Center Armory exist in proximity to the project area. These properties are diverse and range from assisted housing at the Clinton Plaza Apartments to upscale townhouse/condominium complexes within the Armory Square Historic District (SDCD 2000 and SOCPA 2003a).

To assess potential environmental justice concerns, it is necessary to characterize the area population affected by the proposed RTF at Clinton Station in terms of minority composition and in terms of relative income distribution. Based on the above descriptions regarding minority and low-income communities using Block Group data presented in Section 3.4 - Demographics:

• Approximately 56% of the RTF project area is identified as minority, and
• Approximately 49% of the RTF project area is identified as existing below the poverty level.

Both of these numerical representations using Block Group data exceed the criteria specified by the state regarding minority and low-income communities (greater than 51.1% and 23.59%, respectively). Given such findings, an assessment of whether potentially adverse environmental impacts are likely to disproportionately impact the identified minority and low-income community of the affected project area was undertaken.

5.6.3 Identification of potential adverse impacts

As previously noted, land use within the project area is comprised largely of parking, street rights-of-way, and commercial/light manufacturing (Hanford). Based on Census Block data (subset of a Block Group), an estimated 485 persons reside in the immediate area of Clinton Station. Construction of the Clinton Street RTF will result in short-term disruptions to resources such traffic, parking, noise, and air quality (see Sections 4, 5 and 6 and the Assessment Summary Table). No residential structure demolition will occur at the RTF site.

From an operational standpoint, the influent pumps within the building will not operate continuously. The building will be constructed of soundproof materials and noise issues will be minimized to the greatest extent practicable. Impacts to area residents are not foreseen as the site is (and will be) buffered by the elevated railroad embankment, landscaping, Creek vegetation, and the building's distance from nearest receptors (site is five acres). As stated in Section 4.3.1, the chlorination/dechlorination process is state and federally approved for sewage-related uses and does not pose a significant risk to aquatic animals or to humans. The facility will operate in accordance with applicable air resource regulations. In addition, odors from the facility as a result of treatment activities will be minimized to the greatest extent practicable as the RTF will utilize state-of-the-art activated carbon odor control systems to eliminate sewage-type odors. Furthermore, the County will adhere to applicable regulations with regard to the storage (and transport) of chemicals. As identified in Section 4.2.2, similar facilities utilizing the same carbon odor control systems have not experienced complaints from neighboring properties.

As noted in Section 5.5.2, the RTF will resemble a 1.5-story building and built consistent with local architectural styles. The facility grounds will be landscaped to provide an aesthetically pleasing setting. The RTF will be designed and constructed to minimize permanent impacts to the neighboring community and transient receptors. In addition, long-term aesthetic benefits include the elimination of CSOs that include floatable solids within the Creek during storm events.

Given that the facility will operate periodically, operational truck-related traffic will not significantly affect the community. As previously noted, reconstruction of the Fabius Street bridge will allow RTF traffic to utilize West Street (a major arterial) and bypass smaller secondary downtown streets consisting of, and utilized by, local residents.

In summary, the Clinton Street RTF may have short-term adverse impacts associated with construction but given the mitigation measures program described herein, the short-term impacts will be relatively minor when compared to the benefits of such a project. No significant impacts from the operation of the RTF are anticipated.

5.6.4 Impact comparative analysis

As previously noted, to meet the requirements of the ACJ, placement of facilities associated with the Clinton Street CSO Abatement Project is limited to the downtown area because the CSOs to be abated are located along Onondaga Creek in this area. Based on this engineering requirement, the siting of the RTF must be in close proximity to Onondaga Creek. As described in greater detail in Section 7 (Alternatives), two alternative RTF sites emerged as the most feasible out of an original seven possible locations identified by EEA (2005). The two alternative locations identified as most feasible consist of Clinton Station (the recommended/preferred location) and the Dickerson Street alternative (EEA 2005).

The Dickerson Street alternative is located between Fabius and Dickerson Streets. Utilizing the state's environmental justice review policy with respect to a Block Group evaluation reveals that the same Block Groups are affected with the Dickerson Street option as the Clinton Station option (i.e., T30-BG1 and T32-BG1). Such findings indicate that the Dickerson Street option is also comprised of minority and low-income communities.

Given the common Block Group data, and consistent with the USEPA's approach of validating the census data through site reconnaissance, actual land use at the Dickerson Street alternative was compared to Clinton Station. In summary, the Dickerson Street site is a mix of both active and inactive commercial and residential properties. Selection of the Dickerson Street alternative would require the demolition and relocation of commercial and residential properties. Wherein Clinton Station is buffered by the elevated tracks and creek vegetation, the Dickerson Street alternate would not be buffered and would be located directly adjacent to the Rescue Mission's recreation center in a mixed commercial and residential area. The Rescue Mission residential treatment center would be located across Dickerson Street to the south of the Dickerson Street RTF site option.

5.6.5 Summary

Although the RTF project area is located in a low-income and minority community, based upon the information summarized above and described in detail within this document, adverse environmental impacts disproportionately affecting a specific ethnic and/or low-income population were not identified. Furthermore, placement of the RTF in Clinton Station has less potential for directly impacting residential and commercial properties than the Dickerson Street site alternative since no residential structures will be demolished. In summary, the project will be of benefit to the community as a whole by removing a significant source of odors in Onondaga Creek within the project area as well as improve the water quality of both the Creek and Lake.

Given the assessment described above, it is the County's determination that the Clinton Street CSO Abatement Project is not subject to the state's environmental justice policy since adverse environmental impacts disproportionately affecting a minority and/or low-income population were not identified. The project as proposed is designed to address longstanding environmental and public health concerns regarding untreated CSO discharges to Onondaga Creek and subsequently the Lake. The ACJ mandated Clinton Street CSO Abatement Project creates beneficial and positive long-term conditions to an area currently experiencing deleterious impacts from untreated CSO discharges. As such, even if it is ultimately determined that the project will result in significant adverse impacts, it is the County's position that the overall public health and environmental benefits of the project will justify such impacts. Consistent with the policy's directives, however, the County will continue to communicate project activities with the community through various meetings and written documentation (see Section 9).

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Susan Miller, Project Deputy Director
Phone 315-435-2260   Fax 315-435-5023
 Onondaga County Dept of Water Environment Protection