The Valley Alliance today submitted comments on behalf of its supporters to supplement the legal memorandum filed yesterday by our counsel, Warren S. Replansky. This second, 24-page document includes a concise executive summary as follows:
- I. RAIL ALTERNATIVE: The Plan has yet to consider a rail alternative for aggregate transport which bypasses the Waterfront altogether, making the Hudson dock area available for more compatible, beneficial uses.
- II. SEGMENTATION:Paid for by O&G, this Generic Environmental Impact Statement is not 'generic' at all, but tailored instead to a single, site-specific project, whose review has been illegally segmented under SEQRA.
- III. 'MAKING THE MOST OF YOUR WATERFRONT': The clear lack of community consensus and public acceptance of this Plan endangers its future implementation and success, a problem which needs urgent correction, with State assistance.
- IV. ABANDONED RAILROAD BED: Holcim itself has repeatedly described the 'causeway' as an abandoned, demolished, dismantled and/or inactive 'railbed'; yet the GEIS insists that it's always been a road.
- V. MOORE LETTER: The head of the lead agency for this review has arbitrarily and capriciously discarded his own prior laundry list of problems with this Plan, pushing it forward without resolving those concerns.
The full document can be downloaded by clicking here.