Factors the dGEIS should assess
The Multi Municipal Task Force (MMTF) developed a road use law and road use program (RUP) to protect towns from the financial burdens caused by damage to the roads by large-scale industrial developers. The intent of the MMTF draft Generic Environmental Impact Statement (dGEIS) is to assess the potential adverse impacts of the law, and to identify realistic and viable mitigations of the impact. The July 14 editorial incorrectly assumes that the RUP will not change the volume of truck traffic related to high-intensity industrial activities and, therefore, concludes that the dGEIS does not need to consider the impact of this traffic.
The MMTF Road Use Law will permit paving and widening of roads that would not otherwise support high-volume high weight truck traffic. These alterations will not only industrialize our rural roads but will clearly increase high-volume, high-weight truck traffic. In addition, concentration of such traffic on certain roads will exacerbate the impact of this traffic in certain areas of the town. Since this traffic volume and concentration is the result of the RUP, their impacts reasonably fall within the scope of the dGEIS.
One of the more likely industrial activities to fall within the purview of the RUP is gas drilling and its associated truck traffic. To not identify the impacts specifically related to gas drilling truck traffic is disingenuous. The impacts of gas drilling truck traffic are qualitatively and quantitatively more significant than any other high-intensity industrial activity that would likely occur in our towns. To be clear, what the dGEIS should consider are the impacts related to road use, i.e. the noise, the air pollution, the vibrations etc. of 2,000 truck trips on roads that have been altered to specifically allow this traffic. This is not an assessment of the impacts of the industrial development itself but an assessment of the impacts of the high-volume, high-weight truck traffic resulting from the RUP.
Finally, there is no acknowledgement of the effects that widening and/or paving of rural roads would have on the rural character of the community. The use of the word “upgrade” in the road use law connotes improvement but these “improvements” to roads are often the foundation for the industrialization of a rural community, a transformation with more negative connotations. Without a doubt, such changes in our roads will permanently alter the quality of life in our towns—a significant impact of the RUP.
The mitigations identified in the dGEIS should be realistic. For example, identifying use of electric or natural gas powered vehicles to mitigate noise is not a feasible substitute for diesel trucks. Increasing setbacks is also identified as a mitigation, when in most instances what will be permitted is widening of roads, thereby decreasing setbacks between roads and homes or businesses.
Calling for an adequate dGEIS is not an attempt to undermine the process or to obtain gas drilling regulations by subterfuge. I am a resident of Cochecton, and given the Millennium Pipeline debacle, I understand the need to protect towns from the predatory practices of some industries. At the same time, I believe that the road use law can do more than protect towns from the financial burdens resulting from road upgrades and repairs. The road use law can also protect towns from the other costs associated with the alteration of our rural roads for the profit of high intensity industrial activities. For example, the road use law should contain provisions for prohibiting high-volume, high-weight truck traffic on roads where adequate mitigation of the impacts is not possible. A dGEIS with a thorough examination of the impacts of the law and including realistic and viable mitigations would make that clear.
[Jane M. Roth is a resident of Cochecton, NY.]