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1 Onondaga County Industrial Development Agency – 4/30/2026
2 STATE OF NEW YORK
3 TOWN OF CLAY
4 ONONDAGA COUNTY
5 INDUSTRIAL DEVELOPMENT AGENCY 6 (OCIDA)
7 In the Matter of the State Environmental
8 Quality Review Act in Regards to Proposed Development 9 of the White Pine Science & Technology Park, Location 10 at the Southeast Corner of the Intersection of NYS 11 Route 31 and Caughdenoy Road. 12
13 PUBLIC SCOPING HEARING 14
15 DATE: April 30, 2026 16 TIME: 6:03 p.m. to 8:00 p.m.
17 LOCATION: TOWN HALL OF CLAY 18 4401 N.Y.S. Route 31
19 Clay, New York 13041
20 BEFORE: ROBERT PETROVICH,
21 OCIDA EXECUTIVE DIRECTOR
22 ALEXIS RODRIGUEZ,
23 OCIDA SECRETARY 24
25 Reported by Kristen Lawler
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2 APPEARANCES:
3 FOR OCIDA:
4 BARCLAY DAMON, LLP
5 BY: JEFFREY DAVIS, ESQ.
6 125 East Jefferson
7 Syracuse, New York 13202
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2 (The hearing commenced at 6:03 p.m.)
3 MR. PETROVICH: Okay. Good evening,
4 everyone. I'd like to call the scoping session
5 public meeting to order -- public hearing to order.
6 My name is Bob Petrovich. I am the Executive
7 Director of the Onondaga County Industrial 8 Development Agency or OCIDA.
9 There are obviously exits clearly 10 marked for your safety, and also there are facilities 11 in the lobby for -- just off the lobby for men's and 12 women's rooms, if those are needed. I, along with
13 OCIDA's legal counsel, Jeff Davis, and OCIDA's
14 Secretary, Alexis Rodriguez, will be presiding over 15 this evening's public scoping session as we commence 16 the environmental review of the proposed development 17 of the White Pine Science and Technology Park in 18 Clay, New York.
19 This session is being simultaneously
20 translated into American Sign Language. We are
21 providing simultaneous Spanish translation. Please
22 advise us if you need the translation so that the
23 provider can provide you with a headset for this
24 meeting.
25 MR. DAVIS: Excuse me, translator. Do
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2 you want to say that, just in case?
3 (The translator recites the above in
4 Spanish) 5 MR. PETROVICH: OCIDA proposes to 6 develop the business park known as the White Pine
7 Science and Technology Park located at the southwest 8 corner of the intersection of New York State Route 31 9 and Caughdenoy Road. OCIDA currently owns 10 approximately one hundred and four acres comprised of 11 six tax parcels. The maps of the park are on display 12 at the easels up at the front, and the Park will be 13 capable of supporting a mix of industrial and 14 commercial uses and may include industrial-related 15 office, research, manufacturing, assembly, 16 warehousing, data management, material processing and 17 distribution facilities, including companies that 18 could support the Micron semiconductor manufacturing 19 facility.
20 The project may include utility
21 improvements, including expansion of infrastructure
22 both offsite and within the Park to support the
23 project. The project may also include the
24 acquisition of property through voluntary agreements
25 or through condemnation under New York State Eminent
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2 Domain Procedure Law. The project must be reviewed
3 under the State Environmental Quality Review Act or
4 SEQRA. In accordance with SEQRA, on September 14,
5 OCIDA declared itself as the lead agency for SEQRA 6 purposes. OCIDA also issued a positive declaration 7 due to the project's potential to result in one or 8 more significant adverse impacts and declared its 9 intent to prepare a draft generic environmental 10 impact statement or an E.I.S. for short. 11 The first step in preparing an E.I.S. 12 is scoping. Scoping is a process that develops a 13 written document, the scope, which outlines the 14 topics and analyses of potential environmental 15 impacts of an action that will be studied and 16 addressed in the draft environmental impact statement 17 prepared for this project. The purpose of scoping is 18 to narrow issues and to ensure that the draft generic 19 environmental impact statement will be a concise, 20 accurate, complete document adequate for public 21 review.
22 As part of OCIDA's determination that
23 an E.I.S. was required, OCIDA noticed a draft scoping
24 document and invited the public to review and comment
25 on that scoping document. OCIDA posted a copy of the
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2 draft scoping document on its website for the
3 public's review. Copies of the draft scope are
4 available here in the room. I believe they're in the
5 back. That handsome gentleman in the back has them
6 if you would like a copy.
7 The purpose of tonight's scoping 8 session is for OCIDA, as the lead agency in this 9 process, to receive comments on the draft scoping 10 document. Tonight is not a question-and-answer 11 session, but an opportunity for the public to make 12 their comments on the draft scoping document on the 13 record.
14 There is a court reporter here
15 tonight, seated over here, who is going to make a
16 record of all comments made. If you do come forward
17 and make comments tonight, we ask that you please
18 state your full name and where you are from, and also
19 speak clearly and slowly so that the reporter can
20 make an accurate record of your statement. We are
21 asking those in attendance to please show respect for
22 the person that is speaking, even if you do not agree
23 with the comment, and also to please hold applause or
24 other noise so that we may make an accurate
25 accounting and record of this event.
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2 OCIDA encourages the public to 3 participate in this process. If you do not wish to 4 make a comment here this evening, you may submit your 5 comments in writing via email or the U.S. Mail to 6 OCIDA. The contact information for submitting 7 comments can be found on the notice, and we have 8 copies of the notice available if you would like a 9 copy. The notice and contact information for 10 submitting comments can also be found on OCIDA's 11 website. The contact information is also identified 12 on the science of the tables -- on the sign-in tables 13 here in the room. The written comments will be 14 accepted through May 15, 2026. Your input, both 15 verbal comments received here tonight as well as 16 written comments that are received by OCIDA, will 17 help OCIDA prepare a final scope, which will be 18 released after all comments have been received and 19 considered. Equal weight is given to both verbal and 20 written comments.
21 At this point, I will turn the meeting
22 over to Jeff Davis, and we'll begin taking comments
23 on the record.
24 MR. DAVIS: Thank you. I'll call up
25 by name those that have signed up so far to speak
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2 this evening, and if you’d come up to the podium one
3 by one. At the moment, we have five people that have
4 signed up -- six people that have signed up to speak,
5 and so we're not going to have a time limit.
6 I'll -- I'll ask folks to speak as they would like 7 to. If I feel as if they are getting repetitive or 8 something going on, I may ask you to wrap up your 9 comments so that those -- everyone that is registered 10 can speak. And then if you'd like to come back up 11 afterwards, recognizing that some people may have a 12 time limit where they need to go before the meeting 13 concludes this evening.
14 So with that, the first person that I 15 have will be Shelly Hotaling, and after that will be 16 Janet Rathburn. 17 MS. HOTALING: Shelly Hotaling. I'm 18 concerned about the -- the water distribution that 19 will come from this site. Now, I know that we're 20 built -- we're bringing in a lot of tonnage for
21 Micron, and we'll also have to bring in a lot of
22 tonnage for this area. How many retention ponds will
23 be put in? Because it's definitely going to affect
24 the people's houses that are in front of it. If --
25 not all of them have ditches in front that even lead
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2 all the way down.
3 If we're -- most of us are not on the 4 sewer system, we’re on septics. And it's not fair to 5 the residents to have to hook up to sewer. That 6 should be part of the deal that's made with doing 7 this because we're not going to be able to use our 8 septic systems at all. And since this is a large 9 partial, how many retention ponds do you feel that 10 will be needed?
11 Now, I've worked in semiconductor 12 heavy military for many years, and I know that with 13 circuit boards and things like that, there are many 14 chemicals. Now, is there going to be a safeguard for 15 the chemicals that are going to be used by these 16 industrial buildings? And how will it affect the 17 people's quality of life that's near it?
18 Now, I see that you said on there that 19 they could be doing some Eminent Domain. Now, right 20 now we go over to a certain part, and then there's an 21 additional ten acres that has not been bought yet.
22 Now, are they planning on expanding this park more or
23 less? And basically, the -- the output of noise and
24 stuff, compliance that we'll have to deal with that's
25 going to be right outside our bedroom doors. So
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2 that's --
3 MR. DAVIS: Shelly, can you -- I'm
4 sorry. Could you just state your address?
5 MS. HOTALING: Yes. Eighty-four
6 forty-four --MR. DAVIS: Eighty-four forty-four --
7 MS. HOTALING: -- Caughdenoy Road.
8 MR. DAVIS: -- Caughdenoy. Thank you.
9 Great. Janet Rathburn. And after Janet, next is
10 Paul Doody.
11 MS. RATHBURN: I live off of Henry
12 Clay Boulevard across from the industrial park that's 13 been there for years. The problem that we've had in 14 the past is that they've always wanted to put intense 15 uses over the industrial park, and there's really no 16 buffer between the industrial park and the existing 17 homes that are over on the other side of Henry Clay 18 Boulevard. We've had a concrete batch plant want to 19 go in there. We had a trash transfer station 20 twenty-five years ago, whatever it was.
21 What I'd like to see happen with this
22 is -- I know you want to put industrial uses there,
23 but I feel what they should look into doing is doing
24 some kind of step-down or split zoning where you put
25 the more intense uses up by Route 31 and put the less
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2 intense uses towards the back of the property where
3 it abuts the neighbors. When I bought my property,
4 the industrial zone was already there. The people
5 that live back further from this area, they were
6 there before you wanted to make this industrial, so I
7 feel you need to protect them.
8 MR. DAVIS: Paul? And then after Paul
9 is Ralph Turner.
10 MR. DOODY: All right. Thank you for
11 the opportunity to provide some comments. My name is
12 Paul Doody. I reside at 3308 Misty Cove Circle in
13 Baldwinsville, Town of Lysander. I may provide some 14 additional comments by the 15th of May, some more 15 detailed comments. I just thought I'd throw a couple 16 of general comments out this evening.
17 The first one is, I guess I'd ask you 18 folks to provide a bit more community engagement when 19 you do have the E.I.S available. And what I mean by 20 that is be able to present the findings. I was quite 21 disappointed that with the Micron E.I.S. for the main 22 facility, there was no presentation, no information 23 sessions to educate the public about what was in the 24 document and be able to answer people's questions.
25 So I guess I'd respectfully ask you guys to do that
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2 this time for the science and technology park.
3 Second general comment is, this 4 general E.I.S. presents some kind of unique 5 challenges in that you don't know what's going to be 6 on this property. You've got some renderings here of 7 potential buildings, but you really don't know who's 8 going to be there, what they're going to be doing, 9 and I understand you need to be able to prepare an 10 E.I.S., so you're going to have to make some 11 assumptions on things. And I would ask that you look 12 at it from a conservative standpoint so you don't end 13 up, after developing this E.I.S., have some industry 14 come in or some tenant come in that's creating more 15 impacts than you would assumed in the E.I.S. and then 16 have to go through a whole supplemental process, 17 which I could see that delaying the acceptance of 18 that -- that new tenant.
19 So I'd encourage you to look at 20 conservative assumptions on what may be used here. I 21 suspect that Micron probably knows the types of 22 entities that -- that -- that would be attracted to 23 this particular park to support their operations. So
24 I guess that's what I would ask, is to be
25 conservative with that and don't be optimistic, and
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2 then down the road have to pay the price with delays
3 in -- in tenancy.
4 My last general comment. See, good
5 thing I did have notes here. The other thing is,
6 given the fact that this is so directly associated
7 with Micron, I'd ask that you look at these impacts
8 as cumulative impacts, along with what you presented
9 in the final E.I.S for Micron. I think it's
10 important to look at that, particularly with the
11 proximity. It's directly related to Micron, and the
12 community here is going to feel those impacts on a
13 cumulative basis. So that's it. I appreciate the
14 opportunity to provide some comments.
15 MR. DAVIS: Thank you. Next is Ralph
16 Turner, and after that is Cody Kelly.
17 MR. TURNER: Good evening. Thank you,
18 team, for giving me the opportunity to speak. My
19 comments would also be general in terms of the
20 scoping. I would like to speak to the displacement
21 of people or residents that -- and displacement of
22 the land and the results that that may bring. I
23 would ask that the -- the report in the E.I.S. would
24 speak to the consideration of accountability for any
25 environmental problems. For example, impactful
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2 concerns coming from this type of development that
3 may cause, for example, disturbance of compound
4 chemicals that may be dangerous or perhaps affect the
5 land or the -- the air and, thus, the people around.
6 And also I would ask that the E.I.S.
7 would address accountability of some of these
8 supportive contractors or businesses or agencies, 9 whatever they would be, as well as Micron itself.
10 And to look for applications where Micron and its
11 indirect supporters could be more instrumental in --
12 in addressing concerns, especially where it concerns
13 any chemicals or things of that nature. Thank you.
14 MR. DAVIS: Thank you. Next, Cody
15 Kelly. After that is Baxter Hannox (phonetic).
16 MR. KELLY: Good evening. My name is
17 Cody Kelly. I am the County Legislator for the 14th
18 District, including the Science and Technology Park.
19 I reside at 5 Sherwood Circle in Clay. Before I go
20 on with my own comments, I'd like to build off some
21 of the other things that I've heard tonight, namely
22 something that I've stated on the record in the past
23 with regards to this project that I personally do not
24 want to see the use of Eminent Domain and hope that
25 that can be avoided going forward.
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1 Onondaga County Industrial Development Agency – 4/30/2026
2 I've spoken a lot about the economic 3 opportunity sitting in front of us. I know that
4 OCIDA is working to maximize that opportunity with 5 additional supply-chain investments at this site and 6 elsewhere. I'd like you to keep in mind throughout 7 the environmental review, there are a lot of people 8 living nearby between Country Meadows and Coachman's 9 Crossing, where I grew up. These people deserve to 10 know that every step is being taken to ensure that we 11 are protecting our air, protecting our water, 12 protecting our soil, limiting light and noise 13 pollution, mitigating traffic issues, and more. I 14 encourage OCIDA to leave no stone unturned to ensure 15 those questions are answered to the satisfaction of 16 myself and my constituents. Thank you. 17 MR. DAVIS: Thank you. Baxter Hannox. 18 MR. HANKIN: Hi, I'm Baxter Hankin. 19 MR. DAVIS: Sorry, Baxter. 20 MR. HANKIN: No worries. 21 MR. DAVIS: H-A-N-K-I-N. Sorry. 22 MR. HANKIN. You're all good. So
23 I -- I'm an architect, and when I look at the plan
24 for the layout of the site, that's where my concerns
25 are, personally. I know that, you know, with Micron
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2 right across the street, there's going to be a bus
3 running to Micron in this area. And this site, as
4 it's shown in the drawing here, is not laid out in a
5 way that would enable people to walk between the
6 buildings or from the buildings on this site across
7 the street to Micron, which would reduce the
8 usefulness of that bus stop and bus route, reducing
9 access to employment for those using the bus, unless
10 the layout of the site is -- is changed.
11 And furthermore, reorganizing the site
12 to sort of have these different buildings and Micron
13 all sort of being able to have people who work there
14 walk between the different locations, can sort of
15 spur a greater mixing of people who are working at
16 these different spots, increasing interactions,
17 collaboration, and innovation. And beyond all of
18 that, you know, when we set up the site -- if we set
19 up the site for more walking locally, as well as
20 greater bus access, we reduce the number of cars on
21 the road, and that can significantly help with
22 traffic in the area for people who work and live
23 here. Thanks.
24 MR. DAVIS: Thank you. That is the
25 last of people that signed up. So first, if anybody
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2 that would like to speak that has not spoken,
3 and -- look, we're here until eight o'clock, so you 4 don't need to run up here all at once, but if there's 5 anybody that does want to speak that hasn't spoken, 6 feel free to come up. If there's anybody that has 7 already spoken and wants to take a second shot, also 8 welcome to come up. And -- but we could have people 9 that come in at seven o'clock, and so if people are 10 done speaking, we'll also just kind of hit pause for 11 a little bit and see if anybody else wants to arrive 12 that may want to have an opportunity to put their 13 comments on the record. So I’ll open the room up to 14 anybody that would like to speak that has not. 15 Okay. Is there anybody that wants to 16 come back up and speak that has already spoken? 17 Sure. Let me go back to my cards. Shelly. 18 MS. HOTALING: Yeah. One thing I 19 forgot to add is, I've talked to a few of my 20 neighbors and they're all concerned that they're kind 21 of left in the dark. I would hope that, OCIDA, if 22 you do plan on coming down and buying more property, 23 that you notify the people that are there, because
24 it's a big concern. That's something that's
25 life-changing for many of us that have been there
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2 thirty-plus years. So if there's any way possible
3 that you could inform us or have some type of direct
4 impact statement. Thank you.
5 MR. DAVIS: Okay. Is there anyone
6 else at this time? Okay. It is six twenty-five.
7 I'm going to pause. Okay? Meaning, I'm not going to
8 talk anymore. If anybody else decides that they want
9 to come up, raise your hand and let us know, and
10 we'll let the stenographer know and everyone else
11 know that they kind of go back into work mode. But
12 otherwise, we will be here until eight o'clock, and
13 if other people arrive, we'll give them an
14 opportunity to speak. Thank you.
15 (The hearing concluded at 8:00 p.m.)
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3 I, KRISTEN LAWLER, do hereby certify that the foregoing 4 was reported by me, in the cause, at the time and place, 5 as stated in the caption hereto, at Page 1 hereof; that 6 the foregoing typewritten transcription, consisting of 7 pages number 1 to 18, inclusive, is a true record prepared 8 by Associated Reporters Int'l., Inc. from materials 9 provided by me.
10 IN WITNESS WHEREOF, I have hereunto 11 subscribed my name, this the 20th day of May, 2026. 12
13 KRISTEN LAWLER, Reporter
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From: Kukko, Melanie D (DEC) <melanie.kukko@dec.ny.gov>
Sent: Friday, May 15, 2026 3:51:19 PM (UTC-05:00) Eastern Time (US & Canada)
To: ED-WPSTP <WPSTP@ongov.net>
Cc: Glance, Dereth B (DEC) <Dereth.Glance@dec.ny.gov>; Balduzzi, Kevin M (DEC) <kevin.balduzzi@dec.ny.gov>;
Foster, Patrick E (DEC) <patrick.foster@dec.ny.gov>; Vigneault, Thomas M (DEC) <thomas.vigneault@dec.ny.gov>
Subject: DEC Draft Scope Response - White Pine Science & Technology Park - DEC ID#: 7-3124-00616
NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments.
Good afternoon.
Attached, please find DEC’s Draft Scope Response letter for the subject line project. A paper copy will
not be provided at this time.
Please reach out to me with any questions or concerns regarding this document at (315) 426-7482.
Best regards,
Melanie Kukko
Environmental Analyst, Division of Environmental Permits
New York State Department of Environmental Conservation
5786 Widewaters Parkway, Syracuse, NY 13214
P: (315) 426-7482 | F: (315) 426-7425 | melanie.kukko@dec.ny.gov
www.dec.ny.gov | | |
1
KATHY HOCHUL
Governor
AMANDA LEFTON
Commissioner
May 15, 2026
Onondaga County Industrial Development Agency
Attn: Robert Petrovich, Deputy County Executive
355 Montgomery St, Floor 2M
Syracuse, New York 13202
RE: White Pine Science & Technology Park
SEQR Draft Scoping Document Comments
Town of Clay, Onondaga County
Dear Mr. Petrovich:
The New York State Department of Environmental Conservation (DEC) reviewed the “Draft SEQRA
Scope of Work” and Full Environmental Assessment Form (EAF) documents, received on April 13,
2026, associated with the State Environmental Quality Review (SEQR) for the proposed White Pine
Science and Technology Park (Proposed Project) in the Town of Clay, Onondaga County. Based on
current information, DEC’s potential jurisdiction(s) under the Environmental Conservation Law (ECL)
are listed in Attachment A. Please note that DEC may identify additional jurisdictions as information
becomes available and specific park tenants are identified.
DEC offers the following comments on the draft scope for consideration in the preparation of the final
scope for the Draft Generic Environmental Impact Statement (DGEIS).
Project Alternatives
1. Please include a discussion of potential alternatives and mitigation that could reduce energy
and fuel demands during construction and the long-term operation of the Proposed Project,
including renewable energy sources.
2. The alternative project layouts should be designed to maximize natural resource impact
avoidance to the greatest extent practicable.
Water Resources (Sections 3.3 and 4.3)
1. (3.3) The DGEIS should describe the requirement that wetland boundaries must be delineated
precisely and confirmed by DEC and the U.S. Army Corps of Engineers. Delineation maps and
shapefiles should be included in the DGEIS to the extent they are available. The DGEIS should
state that a request for a jurisdictional determination must be submitted to the DEC and all
applicable ECL Article 24, Article 15 permits and the necessary Water Quality Certificates
should be applied for and obtained prior to work commencing.
Division of Environmental Permits, Region 7
5786 Widewaters Parkway, Syracuse, NY 13214 | Email: dep.r7@dec.ny.gov | Phone: (315) 426-7438
RE: White Pine Science & Technology Park Date: 5/15/2026
SEQR Draft Scoping Document Comments
Town of Clay, Onondaga County
2. (4.3) The DGEIS should include consideration of stormwater runoff (construction and industrial)
and water quality. This section should identify the current requirements of NYSDEC’s State
Pollutant Discharge Elimination System (SPDES) Permit, including the Construction General
Permit (GP-0-25-001) and Multi-Sector General Permit (GP-0-23-001). The Stormwater
Pollution Prevention Plan (SWPPP) needs to address hydraulic changes pre- and post-
construction, all changes to hydrology from filling in any wetlands, streams, and drainageways
on site, best management practices, and all changes to avoid, minimize, and mitigate adverse
effects. Sufficient information should be developed to identify the approximate size and location
of necessary stormwater management measures and outfalls during and after construction.
When sizing stormwater management measures, there should be consideration if an Article 15
Dam Safety Construction Permit is required.
3. (4.3) When considering an overall approach to stormwater management at the site, the DGEIS
should pay particular attention to Chapter 3 of the NYS Stormwater Management Design
Manual (SMDM). This chapter focuses on Stormwater Management Planning. The SMDM
requires a specific planning process when addressing stormwater management on a project site
and guides the planner through steps to maintain pre-development natural hydrologic conditions
of the site by application of environmentally sound development principles, such as green
infrastructure, as well as treatment and control of runoff discharges from the site.
4. (4.3) It is important to note while DEC Region 7 Division of Water and Town of Clay will jointly
evaluate the required SWPPP prepared by the applicant, the SWPPP will require the Town of
Clay’s approval per the MS4 General Permit (GP-0-24-001). The MS4 Acceptance Form signed
by the Town of Clay must be submitted with the Notice of Intent to gain coverage under the
SPDES Construction General Permit.
5. (4.3) Given the size of the project, large stormwater management practices may be required.
The DGEIS should discuss the potential need to obtain a dam safety permit if stormwater
impoundments exceed dam safety permit thresholds contained in ECL 15-0503. A dam safety
permit is required to construct an impoundment, unless the structure satisfies one of the
following exemption criteria: maximum of 6ft or less, and maximum impounding capacity is one
million gallons or less; maximum height is between 6 feet and 15 feet and maximum impounding
capacity is less than three million gallons.
Wetlands and Streams
6. (3.7) To the extent available, all DGEIS conceptual project plans should have confirmed wetland
boundaries and regulated adjacent areas shown along with potential impact tables for each
wetland by cover type, identifying potential permanent and temporary impact areas. Each
individual wetland will have unique identification, such as a numbering system. The DGEIS
should include a table summarizing the amounts and types of wetlands, streams, and other
waterbodies on the Proposed Project site.
7. (4.3) Impacts to be evaluated include surface water volume and flow regimes, including
streams, drainageways and ground water elevations before, during and after construction of the
facility including connected actions such as all utility upgrades and connections. Stream flow
impacts to Shaver Creek (NYS Water Index #: ONT-66-11-12, Class C), downstream from the
site should be considered along with hydrologic and biological impacts to stream connectivity.
The DGEIS should consider flood impacts on and off site due to expected wetland function
losses and disruption of natural drainage patterns including flow paths for intermittent and
ephemeral streams and other drainages along with hydrologic impacts to wetlands remaining on
site which are dependent on these sources.
Page 2 of 9
RE: White Pine Science & Technology Park Date: 5/15/2026
SEQR Draft Scoping Document Comments
Town of Clay, Onondaga County
8. (4.3) The DGEIS should demonstrate avoidance of impacts to regulated resources from the
project, including describing methods used to prevent hydrologic impacts to wetlands and
streams remaining on site after project completion and monitoring protocols for those wetlands
and streams.
9. (4.3) To the extent it is available, the DGEIS should consider onsite wetland mitigation for
permanent unavoidable wetland losses. Onsite and offsite wetland mitigation plans should
consider the details contained in Attachment B.
Biological Resources (Sections 3.4 and 4.4)
1. (3.4) The natural resource analysis of the Proposed Project should also include details on
wildlife that likely use the site based on habitat types and any ancillary observations made by
on-site natural resource consultants. Additionally, the DGEIS should discuss the impacts on the
species associated with converting these habitats to an industrial site. Mitigation could include
the consideration of connective habitat corridors.
2. (3.4) Given the aquatic habitat that may be on site, the DGEIS should include an evaluation of
marsh bird habitat, which may include a marsh bird survey. In the event state listed threatened
or endangered breeding marsh birds are found onsite, work should be restricted to the non-
breeding season (September-March) and loss of habitat mitigated at a 2:1 ratio of new to
impacted habitat. Habitat creation, restoration, or preservation are optional methods of
mitigation.
3. (4.4) To avoid adverse impacts to the state and federal listed endangered Indiana Bat, any
project plans for construction activities on these parcels must specify that cutting of any and all
known roost trees be avoided and clearing of other trees must occur from October 31 through
March 31. If these steps are taken, the project will likely avoid any suitable habitat for this
species, and an Incidental Take of an Endangered or Threatened Species Permit (6 NYCRR
Part 182) will not be required from DEC. The DGEIS should discuss coordination with the US
Fish and Wildlife Service regarding federal requirements.
Historic and Cultural Resources (Sections 3.5 and 4.5)
1. (3.5) Part 1 and 2 of the EAF, Appendix A of the White Pine Science and Technology Park
SEQR Resolution, incorrectly assesses cultural resources. Approximately half of the project
area is shaded archaeologically sensitive in Cultural Resources Information System mapping.
2. (3.5) The DGEIS should describe previously known cultural resources and archaeological
sensitivity within the project area and reflect the results of new cultural resources surveys to
assess previously unidentified aboveground and archaeological resources within the project site
and ¼ mile study area. Without final project details, it may not be possible to develop a
complete assessment of impacts on cultural resources in consultation with NYS OPRHP. If
potential adverse impacts are identified, the DGEIS should consider the feasibility of avoiding
impacts through design in addition to assessing alternatives for mitigation.
3. (4.5) It is appropriate to consult with Indigenous Nations regarding cultural and environmental
resources. The project site is within the Onondaga Nation’s area of interest, and near areas of
interest for the Oneida Indian Nation, Tuscarora Nation, and Stockbridge-Munsee Community.
Depending on the results of the Phase IA survey, the Nations may desire cultural monitoring
during archaeological surveys and/or construction.
Page 3 of 9
RE: White Pine Science & Technology Park Date: 5/15/2026
SEQR Draft Scoping Document Comments
Town of Clay, Onondaga County
Air Quality (Sections 3.6 and 4.6)
1. (3.6) In addition to the approved Micron facility, emissions from the Rail Spur facility located on
Caughdenoy Road should also be considered when discussing existing sources of air emissions
in the study area.
2. (4.6) Potential impacts from potential mobile sources should also include any potential impacts
from increased vehicular traffic which may be expected to occur as a result of the Proposed
Project.
3. (4.6) When discussing potential ambient air impacts caused by air emissions generated by Park
tenants, the DGEIS should identify and discuss potential impacts to sensitive receptors in the
study area.
4. (4.6) The DGEIS should consider and discuss any potential air permitting which may be
required for the various industries to be established by the Proposed Project. DEC requires air
pollution control permits and registrations, under 6 NYCRR Part 201, for certain operations that
release air pollution. Applications for air permits or registrations must include information on the
facility's emissions, the operating processes at the facility, the raw materials being used, the
height and location of stacks or vents, the applicable sections of the regulations that apply to the
facility, and the controls being applied. Any necessary air permits and/or registrations must be
obtained before construction begins.
Greenhouse Gas Emissions, Climate Change, and Climate Resiliency
Greenhouse Gas Emissions (Sections 3.7 and 4.7)
1. (4.7) DEC recommends the DGEIS evaluate and quantify estimated greenhouse gas (GHG)
emissions that will result from construction and operation of the Proposed Project, including, but
not limited to, estimated direct and upstream emissions, mobile emissions, and any emissions
from wetland conversion. A conservative best estimate should be made given as end uses are
unknown.
2. (4.7) Along with NYSDEC permits, other state agency decisions may require compliance with
CLCPA Section 7 and, therefore, may require a CLCPA analysis, and should be referenced in
the DGEIS, as appropriate.
3. (4.7) The ½ mile study area should not be relevant to GHG emissions and instead, emissions
from the Proposed Project should be analyzed.
Page 4 of 9
RE: White Pine Science & Technology Park Date: 5/15/2026
SEQR Draft Scoping Document Comments
Town of Clay, Onondaga County
4. (4.7) If the Proposed Project will result in an actual or potential increase in GHG emissions,
including both direct and indirect GHG emissions, the DGEIS should include a discussion of
potential justification for the Project, along with the technical and economic feasibility of any
alternatives or GHG mitigation measures to address the increase. Any such mitigation should
take place at the New York facility or in the immediate area, rather than in other cities or out of
state. DEC offers the following details and illustrative examples regarding potential alternatives
and mitigation measures the DGEIS could consider:
a. Given the large site footprint, the facility should explore geothermal heating and cooling.
Further details about the Proposed Projects operating profiles (MW) and the annual
heating/cooling loads (MWh) would help determine the balance of heating and cooling
and how much of the thermal process loads could be efficiently supported by a ground
loop heat exchanger (geothermal). This would require information about the size of the
facilities, including its thermal load profiles, peak loads, and annual loads.
b. Installation of solar arrays to provide power directly to the facility and minimize energy
demands for facility operation.
c. Assessment of mobile source emissions consistent with guidance from the New York
State Department of Transportation (NYSDOT).
d. Use of electric powered alternatives wherever fossil fuels are typically utilized.
e. Include infrastructure supporting mass transit in the design and planning for such
transportation.
5. (4.7) Energy efficiency goals are not in and of themselves sufficient mitigation as they are
aspirational.
Climate Resiliency
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