Like many community groups in the area, the Glenwood/Glen Head Civic Association is concerned that there will apparently be no mandated public review of the Environmental Assessment prepared in connection with the new generators proposed for Shore Road in Glenwood Landing. Despite this concern, the Civic Association is continuing to encourage dialogue among all parties. The statement below, which I presented to the Department of Environmental Conservation at the hearing held on Dec. 6, outlines the issues we are emphasizing:

The Environmental Assessment appears to be a comprehensive and well-researched document. However, in our opinion, there is considerable room for improvement. Unfortunately, at this point, there appears to be no formal, publicly accountable mechanism for making the comments that would produce these improvements. This comes as a surprise. We believed this opportunity would be provided based on the advice of many of the concerned parties.

We appreciate the opportunity to comment on the EA at this hearing. However, two permit applications are tonight's official subject. Therefore, we believe this is an inadequate forum for addressing the EA. Consequently, we strongly request that a well publicized, organized process for gathering comments on the EA be outlined. This process should include a summary of any comments made to date and how they have or have not been addressed; a summary of the comments made from this date forward; a careful evaluation of all comments presented; and an amended EA.

Also, for some time, we have been discussing with LIPA the possibility of forming an advisory committee comprised of representatives from local community groups, the Town of Oyster Bay, LIPA, KeySpan, and any other concerned parties that may be appropriate. We believe that such a committee could improve this project from a community, corporate, and environmental point of view. We also believe it could serve as a model for other communities facing similar development challenges around the state. We hope such a committee will be formed as soon as possible.

Among our specific concerns about the EA are:

* What guarantee is there that the surrounding woodland and hillsides, repeatedly referred to in the EA as screening devices, will be preserved? How would the alteration of these features affect emissions and air quality?

The ridges and woodland referred to as screening devices in the EA are currently in private hands. Their ownership and use could change at any time. In fact, a petition for a subdivision that will alter existing vegetation and topography is currently being reviewed. Therefore, the EA should consider the potential visual and air quality impacts of altering existing topographical and vegetative features that are outside the LIPA/KeySpan property line. Measures to protect existing features should be considered, including conservation easements to serve as buffers between the generators and nearby recreational and residential areas, and the provision of paid legal counsel and expert testimony to counter future projects that may propose changing these features.

The EA says that the "eastern region along Hempstead Harbor is characterized by industrial development that affects the overall unity of the landscape" and that "the proposed facility would ultimately be incorporated into this existing industrial landscape." This statement is misleading. The industrial lots along the Glenwood Landing Waterfront coexist with many nearby recreational facilities, wildlife resources, and service industries, including: ponds, mud flats, woodlands, and wetlands; two long-established, up-scale restaurants; a beach, marina, pool, picnic ground, and playgrounds; a private golf course; and a waterside esplanade. It is important to ensure that any future industrial development is compatible with these uses and does not infringe on them. There are only two major industrial tenants: LIPA/KeySpan and Mobil/Exxon.

* What assurance does the community have that the two utility lots directly on the water and across from the proposed generator site will be preserved as open space?

The installation of two generators in this NYS-designated Coastal Zone Management Area represents a major intensification of industrial use. It is our contention that development of the waterside lots mentioned above would create an unsustainable environmental load that would make this project unacceptable on environmental grounds. The town has expressed interest in purchasing these lots. We request assurances that LIPA and KeySpan will fully cooperate in this transaction. It should be noted that the Glenwood Landing Waterfront has priority status in the recently revised NYS Open Space Plan and is being considered for inclusion in the county open space plan currently in preparation.

* How does the EA address the Hempstead Harbor Water Quality Improvement Plan?

There appear to be no references to the water quality plan or its recommendations. This seems like a major oversight, especially since the plan was produced with government funding and DEC participation.

* How does the EA address the Glenwood Landing Waterfront Revitalization Plan?

Similarly, there appears to be no mention of the soon to be completed waterfront revitalization plan. Again, this seems like a major oversight, especially since the plan is being funded by the Department of State's Division of Coastal Resources.

* What will a total increase of "no more than 6 dBA" sound like?

We are concerned about the potential noise impact of start up and normal operation at the site and at surrounding locations, including Tappen Beach, the corner of Kissam Lane and Glenwood Road, and the golf course, and whether there is any perceived difference in volume depending on the time of day. There had been tentative plans to visit a generator using the same cooling technology as the proposed Glenwood Landing generator. We request some type of demonstration of noise levels, either at the Glenwood Landing site or at an existing plant that uses the same technology.

* Where will the stacks be visible?

We would like to know what portion of the stacks will be visible from various locations, including Tappen Beach, Kissam Lane, various points on Glenwood Road, Ram's Hill, and the golf course. We understand a balloon was floated recently to evaluate the visual impact of the stacks but we do not know at whose request or what vantage points were included. This is a good example of why a well publicized, well coordinated public review process would be helpful. We are also concerned about the effectiveness and appearance of screening devices, including the height and footprint of the proposed wall, type of plantings, and the proximity of the generators to the road.

* What security and fire precautions will be taken?

The EA seems to dismiss security and fire safety concerns. Shore Road has always been relatively safe and free of graffiti and vandalism, largely because of utility security. Indeed, I believe a 24-hour, manned presence was routine under LILCO. My own observations have led me to believe that there has been a significant increase in graffiti and vandalism since KeySpan's arrival and an accompanying decline in manned security. Given these developments, as well as increased terrorism concerns and the fact that only one employee-if that-is anticipated at the site, we believe that security concerns have not been adequately addressed. Similarly, the proximity of the generators to tens of thousands of gallons of gasoline and heating oil at the nearby Mobil Oil Terminal is likely to require additional local fire department services, if only in terms of training and preparedness.

* What about traffic impacts?

While little increase in passenger or truck traffic is likely to be associated with the plant, there appears to be no mention of how or how often supplies, such as ammonia and water, will be delivered.

* Air, soil, water concerns.

The EA includes many air, soil, and water parameters, along with many different technologies for mitigating many potentially harmful by-products of energy production. The civic association is ill equipped to evaluate these aspects of the document. An organized, public review process would permit these issues to be addressed by others with more expertise. We are eager to hear their comments and concerns.

Patrice Benneward

President, Glenwood/Glen Head Civic Association, Inc.