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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 2290 BROADWAYNEW YORK, NY 10007-1866

AUG - 5 2013Mr. Phil YoungbergEnvironmental Managerc/o Mr. John DuganU.S. General Services Administration10 Causeway Street - Room925Boston, MA 02222Dear Mr. Youngberg:

In accordance with ou r responsibilities under the National En viron men tal Policy Act, (NEPA) andSection 309 of the Clean Air Act, the U.S. Environmental Protection Agency (EPA) has reviewed th eFinal Enviro nme ntal Impact Statement (FEIS) for the Sale of Plum Island, New York. EPA's comm entsare presented below.As you may know, since the Draft Enviro nmen tal Imp act Statement (DEIS) w as completed, the Town ofSouthold has proposed an ordinance that would create a conservation area that would limit developmentand preserv e much of the island . This specific proposal is not evaluated in the FEIS. The purpose ofthis ordinance is to create and establish zoning districts on Plum Island and to expand permitted uses inthe Marine II District to accommodate necessary access to the Island. The P lum Island Research Districtwould encourage the use of the island for research and educa tional opportunities, prov ide qualityemployment opportunities, an d preserve Plum Island's regionally significant natural, historic an d scenicresources. The purp ose of the Plu m Island Con servation District wo uld be to preserve the inte grity of theregionally significant natural, historic an d scenic resources of Plum Island.EP A strongly believes that conservation options have the best potential to respect the rich ecologicalresources of Plu m Island. The island provides importan t habitat for a num be r of species and we hopethat it will be protected and preserved. Moreover, any development that may occur sho uld incorporatethe potential impacts of climate change on future inhabitants an d operations.The FEIS was prepared by the General Service A dm inistra tion (GSA) and the Department of HomelandSecurity (DHS) to describe the impacts associated with the planned gove rnm ent sale of the Plum IslandAnimal Disease Center (P1ADC) on the 850-acre island in Long Island Sound , New York. The P1ADCis cur ren tly operated by the DHS in cooperation with the U.S. Department of Agr icultu re (USDA). Thesale of Plum Island is specifically mandated by The Consolidated Security, Disaster Assistance, and1 The comments contained in this letter were created in coordination with EPA's Region 1 office an d EPA's Long Island FieldOffice given the shared interest in the futu re of Plum Island.

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Continuing Appropriations Act of 2009. The DHS plans to move current operations on Plum Island to ane w facility in Manhattan, Kansas; this action was addressed in a prior EIS.After the sale, GSA has estimated that approximately 195 acres of the island may be suitable fo rdevelopment. Although GSA does no t have specific authority over th e future use of the property, it sidentification of existing resources and the potential impact of possible uses is important as future landuses have the potential to affect the island's environment in a number of ways.EPA's June 2010 scoping comments on the project highlighted th e 2006 joint designation by EPA, th eConnecticut Department of Environmental Protection and the New York State Department ofEnvironmental Conservation of Plum Island as one of thirty-three inaugural Long Island SoundStewardship Areas. In the case of Plu m Island, this designation was based on exemplary colonialwaterbird habitat, inc luding habi tat for several federally threatened an d endangered species. In addition,our scoping comments recommended that th e EIS:

study options to permanently conserve and preserve undeveloped portions of Plum Island whilealso analyzing opportunities for balanced and appropriate public uses after the sale includingpreservation of public access rights from Orient Point;

include a comprehensive evaluation of the ecological importance of Plum Island and an analysisof opportunities for balanced and appropriate public uses; evaluate potential contamination threats to pub lic health and the environment; and include permanent protection of the ent i re undeveloped portion of the property as a developmentalternative, with existing developed areas sold for appropriate future development.

On October 25, 2012, EPA submitted comments on th e Draft Environmental Impa ct Statement (DEIS).In that letter, EPA recommended that the FEIS:

include a mitigation plan that details measures that can be taken by the developers to reduceand/or offset the potential air quality impa cts associated wi th the range of developmen t optionsdiscussed in Reuse Option 2;

include detailed mitigation options that could reduce th e impacts of development on surfacewater for the range of development options;

include detailed information on the nature of the impacts of stormwater runoff to the localenvironment that can be expected from the range of development options as well as theappropriate mitigation measures that could lessen the impact from development to the LongIsland Sound;

include informatio n on the status of Endangered Species Act and Ma rine Mam mal ProtectionAct consultations with th e Fish and Wildl i fe Service (FWS) and the National Oceanic andAtmospheric Administration (NOAA);

include a detailed explanation of the clcan-up process as it relates to the research facility an dpotential biological contamination including a discussion of the components of th e clean-up,what each component will achieve, and how th e process will ensure th e safety of future potentialinhabitants of the island;

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include a discussion of when the risk of spread of disease to large wild mammals such as white-tailed deer will no lo nge r be an issue of concern and what clean-up m easures will be utilized toeliminate any remaining pathogens;

include a discussion of the long-term potential health implications fo r future residents in theevent of a dev elopm ent scenario as it relates to access to the CER CLA landfill (i.e., WMA 26)site for recreation or as it relates to living in close proximity to the site, as well as an estimatedtimeline for the remaining clean-up actions.

EPA also commented that the "DEIS discussion of the environmental impacts associated with futureredevelopment of th e island under the various redevelopment scenarios underestimates the potentialenvironmental impact of the sale by failing to provide sufficient detail necessary to illustrate th e fullrange of potential impacts from both low-and high- dens ity development." T o this point, EPA feels thataddressing the development scenario through a devel opm ent option that exam ines a range of residentialdensity scenarios, as done in the FEIS, is a more illustrative and inform ativ e approach to demonstratingthe potential impacts from development.On the whole, however, EPA feels that GSA did not offer mitigation options as EPA recommended inou r comment letter on the DEIS. Addi tiona lly, the FEIS is not significantly enhanced from the DEIS anddoes no t provide a sufficiently detailed evaluation of the potential impacts of the sale of Plum Island. Itis our hope that al l parties invo lved with the sale of the island inclu ding state an d local government,local residents, and potential purchasers will consider the issues that EPA has raised in regards to thesale and future use of Plum Island and take all the necessary steps to protect the natural resources on andsurrounding Plum Island.EPA offers the foll ow ing resources that address a n um ber of the deficiencies in the FEIS and w ould lik eto see this information included as an attachment to the Record of Decision and documents transferringeventual owne rship of the island.

EPA's Clean Construction program offers resources for developers that address a variety of airquality issues associated with constructionand development from exposure reduction to dieselexhaust to green building standards. Information on EPA 's Clean Construc tion program can befound here: http://www.epa.aov/cleanschoolbiis/construct-ovcrvicw.htm

Water pollution prevention and control measures are critical to improv ing water qual i ty andreducing the need fo r cos tly wastewater an d drinking water treatment. Because water pollutioncan come from many different sources, a variety of pollution prevention an d control measuresare needed. Additional information on pollution control is available here:http://water.cpa.iiov/polwastc/

Low impact development (LID) is an approach to land development (o r re-development) thatworks with nature to manage stormwater as close to its source as possible. LID employsprinciples such as preserving an d recreating na tural landscape features, minim izing effectiveimpervio usness to create functional and appealing site drainage that treat stormwater as a

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resource rather than a waste product. Low impa ct developmen t design and guidance manuals areavailable here: http://water.epa.gov/polwastc/grccn/flguidc

EPA continues to believe that the adaptive reuse an d conservation options have th e best potential torespect the rich ecological resources of Plum Island. The island provides imp orta nt habitat for a nu mb erof species and we hope that it will be protected an d preserved. Moreov er, an y development that mayoccur sh ould be mindful of the potential impacts of climate change on future inhabitants and operations.Thank you for the oppo rtunity to comm ent on the FEIS for the Sale of Plum Island. Our comments onth e FEIS contained in this letter ar e intended to help inform local, state an d federal decision-making andreview related to land use and impacts. In addition to the online resources shared above, EPA has staffwith technical expertise in areas including sustainable development, green construction, greencommun ities, low impact deve lopment, and stormwa tcr manage men t to name a few. Sh ould you haveany questions regarding the comments and concerns detai led in this letter, or for further technica lassistance in one of EPA's program areas, please feel free to contact Stephanie Lamster at212-637-3465.

Sincerely,

Judith A. EnckRegional Administrator