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HomeMy WebLinkAbout900 King Street HDR Environmental Review Technical Memo 2021-6-18 hdrinc.com P a g e | 1 Environmental Review Technical Memo Date: Friday, June 18, 2021 Project: 900 King Street Redevelopment To: Chairman Robert Goodman and Members of the Village of Rye Brook Planning Board cc: Jennifer Gray, Michal Nowak, Chris Bradbury From: HDR: Noemi Castillo Subject: Response to AKRF Comments on HDR’s Environmental Review Technical Memo, dated June 11, 2021 Introduction Henningson Durham & Richardson Architecture and Engineering, PC (HDR) performed a review of the supplemental Site Plan application submittals prepared for the property located at 900 King Street (AKRF; dated May 27, 2021) This review was completed for purposes of determining if previous HDR Site Plan comments have been addressed. On June 11, 2021, HDR submitted to the Village Planning Board outstanding HDR comments on the Site Plan application submittals received to date, including the Construction Noise Barrier Efficacy Assessment Report. On June 15, 2021, HDR received via email responses from AKRF on HDR’s June 11, 2021 Environmental Review Technical Memo. Below are the responses received, with HDR’s responses in red. The SEQRA Findings Statement, dated February 2, 2021, required that in addition to erection of a noise barrier, constructed of plywood, or similar material, that is 12 feet tall along the perimeter of the Project Site on Arbor Drive between the Main Site entrance and the southern site boundary, the Applicant shall erect a noise barrier on the entire perimeter of the Project site along the east side of the Stie (Village Hall, Police Department and Fire Department) and a noise barrier on the entire perimeter of the west side of the Site (The Arbors). The purpose of the eastern and western noise walls is to mitigate noise impacts during construction phases when noise impacts will be at their highest (approximately 12 dBA above ambient conditions). Per the Findings Statement, the barrier should be constructed of plywood, or a material of similar noise abatement properties. The purpose of the Construction Noise Barrier Efficacy Assessment Report was to evaluate the efficacy of the eastern and western noise walls to determine the height for these walls. P a g e | 2 Based on HDR’s review to date on the Construction Noise Barrier Efficacy Assessment Report and technical backup, HDR has no further comments on the analytical methods themselves. The Construction Noise Barrier Efficacy analysis shows that the construction of 12-foot eastern and western noise walls would not significantly reduce construction noise levels due to significant noise contribution from the background. The modeling results are affected by the existing topography in the area, as well as the existing background noise levels. Based on the Construction Noise Barrier Efficacy analysis, the Applicant proposes to construct 6-foot, plywood, eastern and western walls, to comply with the Findings Statement requirement of the erection of noise walls in these areas. Modeling of 6-foot noise walls was not performed by AKRF. However, it can be inferred that if 12-foot noise walls do not significantly reduce construction noise levels, 6- foot noise walls would not further reduce them and would not mitigate the FEIS predicted construction noise impacts. However, the proposed 6-foot noise walls would comply with the Findings Statement. The black text in the below bullets includes AKRF’s comments received via email on June 15, 2021. The red text that follows contains HDR’s responses. Construction Noise Barrier Efficacy Assessment Report, dated May 27, 2021 • No changes to the analysis or site plan documents are required. This comment does not affect the substance of the analysis submitted. As discussed with HDR and Village Counsel, an executive summary of the seven-page noise analysis is not warranted as it would be nearly as long as the report itself. Further, the contents of the report were summarized in the Construction Management Plan and verbally explained to the Planning Board. No further comments from HDR. • No changes to the analysis or site plan documents are required. This comment does not affect the substance of the analysis submitted. The report makes clear what the purpose of the analysis was. The Applicant believes that these two sentences are important to explain to the reader why the current analysis has different absolute levels of predicted construction Noise from the analysis in the FEIS. Regardless of the inclusion or removal of these two sentences, the conclusion of the analysis remains the same; a 12-foot tall barrier on the east and west sides of the Site would not appreciably change the amount of construction noise experienced off-Site. The first paragraph on page 6, after Table 5 of the Construction Noise Barrier Efficacy Assessment Report (dated May 27, 2021) states that “The noise levels calculated in the analysis described above under either barrier configuration are comparable or less than what was originally predicted in the FEIS. Where noise levels in this analysis deviate from those projected in the FEIS analysis, changes are due to refined schedule and logistics as well as more refined predictions of noise emissions from the equipment using the 3D noise model.” However, at the beginning of the report AKRF states that “The purpose of the refined analysis is not to alter the FEIS construction noise analysis conclusions or the areas at which the FEIS found the potential for construction noise impacts.” The statement on page 6 may confuse the reader as it is comparing the results to the FEIS P a g e | 3 results, however, it is stated that the noise barrier efficacy assessment results do not replace the FEIS results, which show higher noise levels. • The prior version of this appendix was inadvertently sent to HDR. Attached is the updated version of the appendix to the construction noise barrier analysis, which itself is an appendix to the CMP. It is important to note that this appendix to the appendix does not change the analysis summarized in the report or the previously submitted data; rather, it adds additional information and slightly changes the presentation of the information in this appendix to the appendix. It does not affect the conclusions of the analysis, which have been agreed to by HDR. No further comments from HDR based on the updated version of Appendix D to the Construction Noise Barrier Efficacy Assessment Report. • The EFS requires, and the CMP (at Section 10.3 stipulates) that, “the Village may require in-field noise level readings upon request, if warranted based on site work activities.” Conducting noise monitoring prior to, or outside of, construction or demolition activities may be useful. However, it would need to be timed to capture the appropriate traffic conditions of adjacent roadways, which may or may not occur prior to demolition. Given the extensive analysis performed with respect to the potential noise impacts of construction, the Applicant requests that new, baseline data not be required prior to demolition; but rather be required at appropriate times (of the day/month/season), and preferably prior to construction or demolition, or as soon thereafter as is reasonably possible. Construction and demolition should not be delayed in the event that additional existing condition noise data could not be collected. These conditions are not necessary. We believe the condition is necessary. Noise monitoring for the FEIS was performed years ago. The analyses have been performed based on this dated existing noise data. As such, baseline noise conditions should be obtained prior to construction and demolition activities for comparison purposes if there are concerns raised during construction that require in-field noise level readings. Scope and schedule for baseline noise readings should be coordinated with the Village Building Department. • The EFS already requires, and the CMP so states (as will the final MMP), that blasting and rock crushing are not permitted without separate approval of the Building Department. Neither of these methods are anticipated during construction. Pile driving and jackhammering are not anticipated during construction and, therefore, do not need to be separately called out. Construction of the Project already must conform to the S&E plans (i.e., construction phasing plans). A duplicative condition is not necessary. The noise analysis performed did not include construction noise levels due to pile driving (impact and vibratory), blasting, jack hammering, and/or rock crushing activities. Therefore, the restriction of no blasting and rock crushing is important to be also tied to noise. In addition, there is currently no restriction regarding pile driving and jackhammering. It is recommended that the Village Planning Board apply a specific condition in the resolution that clearly restricts pile driving (impact and vibratory), blasting, jack hammering, and/or rock crushing activities due to potential noise impacts. • The EFS requires, and the CMP already states (at Section 8) that delivery trucks are not permitted to idle. This duplicative condition is not necessary. HDR’s comment is actually that Construction trucks shall be required not to idle engines. (This was written P a g e | 4 incorrectly in the June 11, 2021 memo). Section 8 of the CMP stats that construction trucks would not be allowed to idle for longer than 3 minutes. Since the noise modeling assumes no idling of these trucks, this restriction should be added. Revised Construction Management Plan (CMP), dated May 27, 2021 Construction Noise • The CMP does not require an update for the reasons stated above. This restriction is important to list in the noise section of the CMP due to potential noise impacts from these activities as the CMP will be an important on-site document which will be followed by all parties involved during demolition and construction. The noise analysis performed did not include construction noise levels due to pile driving (impact and vibratory), blasting, jack hammering, and/or rock crushing activities. Comments on the Site Plan Approval Drawings dated May 27, 2021 Construction Noise • The S&E legend on Sheet C-010, as submitted in May 2021, was updated. The 6-foot tall barrier is represented by a line with squares; the 12-foot tall barrier is represented by a line with circles, and the chain link fence is represented by a line with “X”s. The location of the barriers is shown on Sheet C-200, which was not resubmitted as part of the May site plan submission as it did not change from the previous (4/28) full submission. Although this information is indicated on Illustrative DRAFT Sheet C-200 provided for purposes of showing construction period noise barrier only, this information is not part of the drawing set. Operational Noise • No update to the operational noise analysis is required. While the wording in the report with respect to Table 2 may not have been as clear as desired, the conclusions of the study were clearly explained to the Planning Board at their May 13, 2021 meeting and it was our understanding that there were no substantive questions on this matter. Further, the Village’s own consultant agreed, based on this analysis, that the HVAC systems would not have an adverse noise impact to surrounding receptors. Any updates to the wording of this report would not change this conclusion, nor the Village Consultant’s agreement with the same. If the Village agrees that revisions to address these clarification are not necessary, then HDR has no further comments.