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315.435.3770 • ECONOMICDEVELOPMENT@ONGOV.NET • ONGOVED.COM Special Meeting Agenda November 18, 2025 Call to Order the Special Meeting of the Agency A. Conflict of Interest Action Items:
Agency Action Requested:
a. A resolution of the Board approving the issuance of a findings statement pursuant to the State Environmental Quality Review Act for the Micron New York Semiconductor Manufacturing LLC Project Representative: Jeffrey Davis & Yvonne Hennessey, Agency Counsel
The Agency desires to lease and/or sell all or a portion of approximately 819.92 acres of real property located on Burnet Road, Caughdenoy Road and State Route 31 commonly referred to as the White Pine Commerce Park in the Town of Clay, Onondaga County, New York to Micron New York Semiconductor Manufacturing LLC for a sale price of $30 million.
Agency Action Requested:
a. A resolution of the Board authorizing the lease and/or sale of all or a portion of approximately 819.92 acres of real property located on Burnet Road, Caughdenoy Road and State Route 31 commonly referred to as the White Pine Commerce Park in the Town of Clay, Onondaga County, New York to Micron New York Semiconductor Manufacturing LLC, and execution of documents in connection therewith, subject to compliance with the Public Authorities Law requirements.
Representative: Robert Petrovich, Executive Director
Micron New York Semiconductor Manufacturing LLC is proposing to construct and operate two large-scale, state-of-the-art dynamic random-access memory (DRAM) semiconductor manufacturing facilities at the White Pine Commerce Park in the Town of Clay. Each fab will occupy approximately 1.2 million sq. ft. of land and contain approximately 600,000 sq. ft. of semiconductor cleanroom manufacturing space. The fabs will be supported by central utility buildings, warehouse space, and product testing space.
Agency Action Requested:
a. A resolution of the Board authorizing the financial assistance the Agency will provide. Agency benefits requested include exemptions from certain real property taxes, real estate transfer taxes and sales and use taxes.
Representative: Micron New York Semiconductor Manufacturing LLC Representative 4. Micron New York Semiconductor Manufacturing LLC (Rail Spur) (Project #3101-25-
Micron New York Semiconductor Manufacturing LLC is proposing to construct a rail spur and construction material conveyance facility on approximately 38 acres west of 8625 Caughdenoy Road in the Town of Clay to economically transport fill and other aggregate construction material to the Micron Campus by rail.
Agency Action Requested:
a. A resolution of the Board authorizing the financial assistance the Agency will provide. Agency benefits requested include exemptions from certain real property taxes, real estate transfer taxes and sales and use taxes.
Representative: Micron New York Semiconductor Manufacturing LLC Representative Adjourn New York State Environmental Quality Review Act Findings Statement Micron Semiconductor Manufacturing Project Town of Clay Onondaga County, New York This State Environmental Quality Review Act (SEQRA) Findings Statement documents the findings and decision of the Onondaga County Industrial Development Agency (OCIDA) to proceed with the Preferred Action Alternative, as described in the Final Environmental Impact Statement (FEIS), for the Micron Semiconductor Manufacturing Project. Pursuant to Article 8 of SEQRA of the New York Environmental Conservation Law (ECL) and Title 6 of the New York Code of Rules and Regulations (NYCRR) Part 617, OCIDA as the Lead Agency makes the following findings and decision:
Name of Action: Micron Semiconductor Manufacturing Project
Location: 5171 Route 31 Town of Clay, New York 13041 SEQRA Lead Agency: Onondaga County Industrial Development Agency Robert M. Petrovich, Executive Director
Syracuse, New York 13202 (315) 435-3770 SEQRA Status: Type I Action, Positive Declaration SEQRA Review Type: Coordinated Review Draft EIS Accepted: June 25, 2025 Final EIS Accepted: November 7, 2025
OCIDA is authorized and empowered by the provisions of Chapter 1030 of the 1969 Laws of New York, constituting Title 1 of Article 18-A of the General Municipal Law, Chapter 24 of the Consolidated Laws of New York, as amended, Chapter 435 of the Laws of 1970 of the State of New York and Chapter 676 of the Laws of 1975 of the State of New York, as amended, constituting Section 895 of said General Municipal Law to promote, develop, encourage, and assist
Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York in the acquiring, constructing, reconstructing, improving, maintaining, equipping, and furnishing of manufacturing, warehousing, research, commercial, and industrial facilities, among others, for the purpose of promoting, attracting, and developing economically sound commerce and industry to advance the job opportunities, health, general prosperity, and economic welfare of the people of the State of New York (the “State”), to improve their prosperity and standard of living, and to prevent unemployment and economic deterioration.
In accordance with its mandate, in the early 1990s, OCIDA and the City of Syracuse started to study potential sites for locating industrial businesses in Onondaga County to increase manufacturing employment. Central New York and other regions of New York State have experienced a reduction in manufacturing jobs over several decades. The White Pine Commerce Park (WPCP) was ultimately selected due to its proximity to water and energy infrastructure, highway access, and its zoning classification. OCIDA’s intent in forming the WPCP was buttressed in 1998 with the inception of the New York high-tech Semiconductor Manufacturing Initiative (SEMI-NY) program, a comprehensive effort to encourage semiconductor manufacturing in the state. Thereafter, following decades of unsuccessful efforts to develop the WPCP, OCIDA increased the size of the WPCP to make it more attractive to a broader scope of industries, particularly the semiconductor industry, and bring high-tech and high-paying jobs to Onondaga County.
OCIDA previously conducted multiple studies of the WPCP. In 2021, OCIDA prepared, as lead agency under SEQRA, a Final Supplemental Generic Environmental Impact Statement (SGEIS) that evaluated the contemplated expansion and development of the WPCP for semiconductor manufacturing. As OCIDA determined in its Findings Statement for the SGEIS, high-tech advanced manufacturing holds the promise of transforming the Onondaga County economy through new high-paying jobs, significant financial investment, and increased economic activity, including: (1) the creation of thousands of construction jobs and significantly more permanent jobs; (2) a robust supply chain of companies that will service a high-tech advanced manufacturing organization; (3) a reduction in poverty; and (4) secondary benefits such as increased local small business activity, growth in community civic and cultural organizations, and increased county and municipal investment.
Domestic production of semiconductor chips has also become a major focus of federal and state policy. In 2020, Congress enacted the Creating Helpful Incentives to Produce Semiconductors for America Act (CHIPS Act), as amended by the CHIPS Act of 2022, to strengthen and sustain American leadership in chip technology. The CHIPS Act directs the investment of tens of billions of dollars in semiconductor manufacturing incentives and research initiatives over the next 5-10 years. The Creating Helpful Incentives to Produce Semiconductors (CHIPS) Program Office (CPO), acting on behalf of the U.S. Department of Commerce (Department of Commerce) and the National Institute of Standards and Technology (NIST), is responsible for implementing the CHIPS Act by providing incentives for investment in semiconductor facilities and equipment in the United States. Incentivizing expanded domestic dynamic random-access memory (DRAM) production to a level sufficient to offset potential disruptions to United States economic and national security is a key Department of Commerce responsibility under the CHIPS Act.
2 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York The State of New York is similarly committed to creating 21st century jobs and becoming a global capital for semiconductor manufacturing. Adopted in 2022, New York’s Green CHIPS Program offers up to $10 billion in economic incentives to locate new, cutting-edge semiconductor manufacturing and supply chain projects within the state. New York’s Green CHIPS Excelsior Jobs Tax Credit Program provides certain semiconductor manufacturer tax incentives that are intended to help attract thousands of jobs and billions of dollars to establish New York as a leader in domestic re-shoring of semiconductor manufacturing. New York State is considering providing financial support and tax incentives to Micron under the Green CHIPS Act and the Green CHIPS Excelsior Jobs Tax Credit Program to support construction and operation of a semiconductor manufacturing facility in Clay, New York.
On June 14, 2023, Micron New York Semiconductor Manufacturing LLC (Micron), a wholly owned subsidiary of Micron Technology, Inc., submitted an application to OCIDA requesting certain financial assistance within the meaning of New York General Municipal Law § 854(14). Micron’s application, as amended and restated, includes, among other things, the acquisition of an interest in all or a portion of approximately 806 acres of land, which based upon final survey verification has been determined to be approximately 819 acres, located on the westerly side of Brunet and the undertaking of potential property condemnation pursuant to the New York Eminent Domain Procedure Law (EDPL), as well as the construction of two approximately 1.2 million square foot memory fabrication facilities (fabs). Micron also proposes to construct a rail spur and construction material conveyance facility to reduce truck trips and support construction as well as a childcare center, healthcare center, and recreation center to serve its employees, and to lease existing warehouse space.
On August 18, 2023, Micron filed an application with CPO for direct funding under the CHIPS Incentives Program’s February 28, 2023, Notice of Funding Opportunity for the construction of commercial semiconductor fabs in Clay, New York. On December 10, 2024, the Department of Commerce announced final direct funding awards of up to $6.165 billion under the CHIPS Incentives Program to support Micron Technology’s plans to construct two semiconductor manufacturing facilities in New York and one semiconductor manufacturing facility in Idaho. On June 12, 2025, the Department of Commerce announced a final direct funding award of up to $275 million under the CHIPS Incentives Program to support Micron Technology’s plans to expand and modernize a semiconductor manufacturing facility in Virginia and an amendment to the original agreement to include one additional semiconductor manufacturing facility in Idaho.
The Micron Semiconductor Manufacturing Project requires action from several federal, state, and local agencies. OCIDA is the Lead Agency responsible for environmental review, decision-making, and action under SEQRA, as codified at ECL § 8-0101 et seq. and its implementing regulations at 6 NYCRR Part 617, of the project based on its role in the proposed lease and subsequent sale of the WPCP, the potential granting of financial assistance within the meaning of New York General Municipal Law § 854(14), and the potential undertaking of property condemnation pursuant to the EDPL. Other state and local land use decisions, permits, authorizations and approvals are also under consideration by relevant authorities. In addition, Micron Technology is seeking federal funding under the CHIPS Act and has submitted applications and requests for certain federal permits and approvals that require federal 3 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York environmental review, including, but not limited to, federal wetlands permits pursuant to Section 404 of the Clean Water Act (CWA). CPO is acting as Lead Agency for environmental review of the action under the National Environmental Policy Act (NEPA), as codified at 42 U.S.C. § 4321 et seq.
For purposes of SEQRA, and to ensure that the potential environmental impacts associated with the full buildout of the Micron Campus were fully evaluated, the Action analyzed in the FEIS included the project described in Micron’s Application to OCIDA as well as the ultimate construction of all four (4) fabs, the Rail Spur Site and Childcare Site (as those terms are defined in Section 3.0 below). The Action also included various connected actions associated with the utility and infrastructure improvements necessary to meet the Proposed Project’s electricity, natural gas, water supply, wastewater, and telecommunications needs.
Micron proposes to construct and operate a large-scale state-of-the art DRAM semiconductor manufacturing facility (the Micron Campus) on an approximately 1,377-acre site consisting primarily of the current WPCP, in Onondaga County, New York. Micron also proposes to: (1) construct a rail spur and construction material conveyance facility to reduce truck trips and support construction of the Micron Campus (the Rail Spur Site); (2) construct a childcare center, healthcare center, and recreational center to support the estimated 9,300 employees who will ultimately work at the completed Micron Campus (the Childcare Site); and (3) lease an existing warehouse space in an industrially zoned area at a location to be determined within 20 miles of the Micron Campus (the Warehouse Site). The Micron Campus, Rail Spur Site, Childcare Site, and Warehouse Site are collectively referred to as the “Proposed Project.” The Proposed Project also will require utility and infrastructure improvements to meet its electricity, natural gas, water supply, wastewater, and telecommunications needs, collectively referred to as the “Connected Actions.” The construction and operation of the Proposed Project and Connected Actions is collectively referred to as the “Preferred Action Alternative” in this SEQRA process and its accompanying documents.
Proposed Project The Micron Campus is the primary component of the Proposed Project, occupying the WPCP, the Burnet Road right-of-way (ROW), the South Finger, and the one-acre Jack and Bore site for utility lines. The area surrounding the WPCP is sparsely populated with relatively low- density residential development, mostly along Caughdenoy Road and Verplank Road west of the WPCP. I-81 is located a little more than one mile to the east of the WPCP. The WPCP is approximately 7 miles north of the City of Syracuse. While a majority of the Micron Campus is contained within the Town of Clay, Onondaga County, New York, a small portion will be located in the Town of Cicero, Onondaga County, New York.
4 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Proposed Micron Campus Boundary 5 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Proposed Project Location Map 6 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York The Micron Campus will consist of a semiconductor manufacturing facility with four DRAM production fabs, ancillary support facilities, driveways, parking, and ingress and egress roads with access from NYS Route 31, U.S. Route 11, and Caughdenoy Road. Construction of each fab on the Micron Campus will occupy approximately 1.2 million square feet (sf) of land and contain approximately 600,000 sf of clean room space, 290,000 sf of clean room support space, and 250,000 sf of administrative space; and each set of two fabs will be supported by approximately 360,000 sf of central utility buildings, 200,000 sf of warehouse space, and 200,000 sf of product testing space housed in separate buildings. At full build-out in 2041, the Micron Campus will include 645 acres of new impervious surface, 58 acres of semi-pervious area, and 278 acres of green space within the 997-acre construction disturbance footprint. Construction of the Proposed Project will take place in stages over approximately 16 years. Subject to the receipt of all applicable permits, authorizations and approvals, Micron will mobilize for initial site preparation for the Proposed Project beginning in 2026, with the first two DRAM manufacturing facilities (fabs 1 and 2) estimated to be operational no later than 2030 and 2033, respectively, and the remaining fabs (fabs 3 and 4) estimated to be operational no later than 2037 and 2041, respectively. The manufacturing facility will ramp up to full production output by 2045. The Proposed Project will involve the development of three additional properties with uses ancillary to the Micron Campus – the Rail Spur Site, the Childcare Site and the Warehouse Site. The Rail Spur Site is an approximately 38-acre parcel on the west of 8625 Caughdenoy Road in the Town of Clay. The Rail Spur Site will include the following components: rail siding, rail yards, and an off-loading track and facility; the aggregate materials conveyance system; an office building and trailer; a locomotive shed; paved access roads and a parking area; paved storage areas; a backup stockpile area; a stormwater management area; and lighting. Construction of the proposed Rail Spur Site is expected to start in 2025 with tree clearing and take approximately seven months to conclude, concluding in 2026 with operations also anticipated to start in 2026. The Childcare Site is an approximately 31-acre parcel located at 9100 Caughdenoy Road in the Town of Brewerton, Onondaga County, New York. In addition to its childcare, healthcare, and recreation centers, the Childcare Site will include a soccer field, a tennis/pickleball court, the sewage disposal system and leaching field, stormwater management areas, a pedestrian walkway and bridge, and lighting. Construction of the childcare center will start no later than 2028. Construction of the healthcare and recreation centers will begin no later than 2032 and would open when the employee base at the Micron Campus grows large enough to support the need for those facilities.
The Warehouse Site will be a leased space of 360,000-500,000 sf in an industrially zoned area at a location to be determined within 20 miles of the Micron Campus. The purpose of the Warehouse Site will be to store manufacturing equipment and materials, including spare equipment such as robots, hardware consumables, electronics parts, and components related to Extreme Ultraviolet Lithography and other process tools. Micron anticipates leasing the warehouse space for a 7-10-year term beginning in November 2028.
7 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Connected Actions Construction of the Connected Actions will include expansion of certain existing utility properties and the construction and operation of various utility improvements by National Grid, Onondaga County Water Authority (OCWA), Onondaga County Department of Water Environment Protection (OCDWEP), and others to support the electricity, natural gas, water supply, wastewater, and telecommunication needs of the Proposed Project. The Connected Actions will be constructed on a parallel schedule to meet the utility needs for the Proposed Project as it scales up over the 16-year construction period.
To supply the estimated electricity needs of the Micron Campus, National Grid proposes to undertake phased construction based on interconnection approvals from the New York Independent Systems Operator (NYISO). For fab 1, National Grid proposes to expand the existing footprint of the Clay Substation (located to the northwest of the WPCP across the CSX Railroad line) toward the north and east by approximately 10 acres. This expansion will enable the installation of four new 345 kV electric transmission lines that will run from the Clay Substation through eight new underground duct banks to four new 345kV substations on the Micron Campus (one for each fab). Construction of the proposed Clay Substation expansion and electricity improvements would start as early as 2027. For fab 2, National Grid has tentatively identified a general location in Lysander, New York for the new substation/switchyard required by NYISO. However, a specific location has yet to be identified. National Grid will be responsible for securing the necessary regulatory approvals for construction and operation of any additional electrical infrastructure upgrades determined to be needed by NYISO, which are anticipated to be completed under Article VII of the Public Service Law. For fabs 3 and 4, Micron will similarly be required to apply for interconnection approval from NYISO.
To supply the estimated natural gas demands of the Micron Campus, National Grid proposes to construct an approximately 3.1-mile long, 16-inch diameter below-grade (underground) natural gas distribution line from its existing Gas Regulator Station (GRS) 147 at 4459 NYS Route 31 to the Micron Campus and to construct a new GRS 147A at the same address. Construction of the natural gas distribution line is expected to take place as early as 2025. OCWA proposes to undertake two phases of water system capacity and transmission upgrades to supply water to the Micron Campus. OCWA’s existing water supply system has the capacity to service the 7.85 million gallons per day (MGD) demand from fab 1 with minor upgrades but will need to undertake further upgrades to service the 17.4 MGD demand when fab 2 comes online. Phase 1 will involve upgrades to the Lake Ontario Water Treatment Plant (LOWTP), Raw Water Pump Station (RWPS), and Terminal Campus in Clay, plus construction of an approximately 2.5-mile raw water transmission main from the pump station to the LOWTP for water supply redundancy, an approximately 22-mile clear water transmission main running parallel to the existing transmission main from the LOWTP to the Terminal Campus, and an approximately 5-mile transmission main parallel to the existing Eastern Branch Transmission Main. Phase 2 will involve additional upgrades and potential transmission lines based on need to serve fabs 3 and 4. None of OCWA’s proposed water infrastructure upgrades that are needed to meet Micron Campus water demands require permanent land acquisition.
8 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York OCDWEP proposes to undertake two stages of wastewater treatment system capacity and conveyance upgrades to serve the Micron Campus. Stage 1 will involve a bridging project at the existing OCDWEP Oak Orchard Wastewater Treatment Plant (OOWWTP) to receive sanitary wastewater and temporarily accommodate startup industrial wastewater from the Micron Campus as OCDWEP constructs a new Industrial Wastewater Treatment Plant (IWWTP) and water reuse facilities on 36 acres of its existing 76-acre Oak Orchard site. Stage 1 will also involve construction of a new conveyance between the Micron Campus and the Oak Orchard site to send pretreated industrial wastewater to the IWWTP and return reclaimed water to the Micron Campus. Stage 2 will expand and upgrade the IWWTP to serve additional campus industrial wastewater flows from Phase 2 of the Micron Campus build-out (fabs 3-4) and provide additional reclaimed water back to the Micron Campus.
To supply telecommunication and broadband internet connectivity to the Micron Campus Micron will make use of two existing fiber optic lines along Caughdenoy Road and NYS Route 31 accessible via two fiber optic connection entry points within a mile of the WPCP, one at the intersection of Caughdenoy and Verplank Roads, and one at the intersection of Caughdenoy Road and NYS Route 31. The existing fiber optic lines currently serve a cell tower on the southern portion of the WPCP, just north of NYS Route 31. Construction of the 1–2-mile cable extension is expected to begin and be completed in 2026.
9 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Proposed Project and Connected Actions Permits and Approvals The following table identifies the major permits, approvals, and consultations required for the Proposed Project and Connected Actions under the Preferred Action Alternative. Micron is responsible for obtaining all permits, approvals, or other authorizations required for the Proposed Project, regardless of whether they appear in the table below.1 1 This Findings Statement incorporates by reference the “List of Abbreviations and Acronyms” found on page 0-4 of the FEIS.
10 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Permits, Approvals, and Consultations Permit/Approval Agency Description Federal CWA Section 404 USACE Permit required for the discharge of dredged or fill material Permit into waters of the U.S. (WOTUS), including wetlands (33 U.S.C. § 1344).
Rivers and Harbors USACE Permit required for structures and/or work in or Act Section 10 affecting navigable WOTUS (33 U.S.C. § 403). Permit ESA Section 7 USFWS Formal consultation with a Biological Opinion and potential Consultation Incidental Take Statement issued by USFWS authorizing incidental take of endangered species (16 U.S.C. § 1536). NHPA Section 106 NYSHPO Consultation with consulting parties regarding effects of Consultation an undertaking on historic properties and development of a programmatic agreement (54 U.S.C. § 306108). State and Local Financial assistance OCIDA Approval of application for certain financial assistance; approval of lease and sale of the WPCP, as authorized under law (General Municipal Law Chapter 24). Financial assistance ESD Refundable tax credits under New York’s Green CHIPS Excelsior Jobs Tax Credit Program (Green CHIPS Act (S. 9467 / A. 10507)).
Authorizations for NYSOGS Approval of a lease, easement, or other interest for structures in state- structures and appurtenances in, on, or above state- owned lands under owned lands under water (Public Lands Law Articles 2 water and 6; 6 NYCRR Part 428).
Work and/or NYS Canal Permits for work in and/or occupancy on Canal Occupation Permit Corporation property (Public Authorities Law Chapter 43-A, Title 1, Section 1005-B).
Certificate of NYSDPS / Approval of application for certificate (Public Service Law Environmental NYSPSC Article 7) (exempt from SEQRA review; NYSDPS Compatibility and conducts a separate environmental review). Public Need Incidental Take Permit NYSDEC Permit required for incidental take of state-listed species (ECL Article 11; 6 NYCRR Part 182). Stream Disturbance NYSDEC Permit required for any change, modification, or disturbance or Modification of any protected stream, its bed or banks, or to remove from Permit its bed or banks sand, gravel, or other material (ECL Article 15; 6 NYCRR § 608.2).
Protection of Waters NYSDEC Permit required to excavate, or place fill in waters Permit protected by the State (ECL Article 15; 6 NYCRR § 608.5).
11 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Permit/Approval Agency Description Water Supply / NYSDEC Permit required for the construction, operation, or Withdrawal Permit maintenance of a water withdrawal system (ECL Article 15; 6 NYCRR Part 601).
Beneficial Use NYSDEC NYSDEC SPDESfor Permit permit required to the beneficial usedischarge or cause aof of large quantities surface or Determination groundwater imported discharge excavated of anythat materials pollutant are notfrom anyoroutlet mined or point source purchased (ECLinto the 27;
360-365). 17; 6 NYCRR Part 750).
Hazardous NYSDEC Registrations or licenses for facilities that store hazardous SPDES Multi-Sector Discharge Substances and NYSDEC Permit for or substances industrial petroleum activities that discharge above threshold stormwater quantities (ECL General Permit Permit Petroleum Bulk to surface waters of the State must obtain coverage Articles 17 and 40; 6 NYCRR Parts 597, 598, 610, 613). under (MSGP) Storage Permits MSGP (ECL Article 17; 6 NYCRR Part 750).
State AirGeneral Facility NYSDEC NYSDEC Construction State activities air facility permitswith soil disturbance are required of one for facilities or with Permit for / Registration more acres must obtain coverage under the potential air emissions that are below major sourceGeneral Construction Permit for but thresholds, Stormwater above 50% Discharges from of the level Construction that would make Activities Activities them (ECL a major Article source. Air17; 6 NYCRR facility Part 750). registrations are Reclaimed water required for facilities with regulated air emissions Registration required for use of reclaimed wastewater that are
registration below criteria for either State or greywater (ECL Article 15). facility permits or Title V permits (ECL Article 19; 6 NYCRR Part 201). Temporary NYSDOT Permit for new or temporary access to a state highway or
Roadway Discharge Access NYSDEC SPDES for permit activities to discharge conducted or the within cause a surface right of wayorof a NYS Permit, Permit Septic groundwater highway (NYSdischarge, Highwayand Lawapproval
§ 52).for System Approval septic disposal system (ECL Article 17; 6 NYCRR Access or Right-of- OCDOT Permit for construction or modification of buildings, Part 750).
CWA Section 401 Way Permit NYSDEC / driveway, andthat Certification activity means will not of access violate related state water to County Water Quality NYSDPS quality standards (33 U.S.C. § 1341). roads (NYS Highway Law Article VI, § 136). Certification County Wastewater OCDWEP Waste discharge permit to connect to or discharge into the CAA Title Permit Discharge V Permit NYSDEC Permit required County to construct sewer system and operate (Onondaga County aAdministrative facility that is considered a major source of air emissions Code Article XXII, Section 22, et seq.; Appendix that11-A, are at or above certain thresholds (ECL Article 19). Sections 1153 g, j, 11.67, 11.68, 11.79) and pursuant to
Activities on NYSDEC Relating Permit ortoletter the Use of the Public of permission SewertoSystem required conductissued by activities wetland and the on County wetlandsoforOnondaga, Department adjacent areas of Water not specifically Environment exempted adjacent areas Protection.
from regulation (ECL Article 24; 6 NYCRR Parts 663-664). County Planning Collection, Disposal Onondaga NYSDEC Review andgenerators Permit for recommendation by the Onondaga and transporters County of hazardous Review and and of Treatment County Planning Planning Department wastes (ECL relative
6 NYCRR Part 373). Recommendation Refuse and Other Department approvals required by the Towns of Clay and Cicero Solid Wastes (General Municipal Law Section 239). Subdivision of Land Town of Cicero Review and approval of applications for subdivision of land Zoning Amendment Town Planning of Clay Board Approval (Chapter by 185,Town CodeBoard of theofTown a Petition of Cicero). for Change of Zone, Town Board amending the zoning ordinance, and to reclassify the zoning district (Town of Clay Code Section 230). In addition to the Subdivision foregoing Town of Clay permits, approvals Review and consultations, and approval of applicationsthe for Proposed subdivisionProject of land is also subject to environmental approval review Planning Boardunder NEPA.
(Town Initially, of Clay following Code Chapter Micron’s 200, Chapter application 230 § 230- to the U.S. Army Corps of Engineers (USACE) for a (Subdivision 26.B.(2) permit pursuant to Section 404 of the CWA to of Land).
discharge dredged or fill Site Plan Review Townmaterial of Clayinto the waters Review andofapproval the United States, of site plans the USACE (Town of Claywas the lead Code federal agency for the Planning ProposedBoard Project§under NEPA.
230-26.B.(4)). By subsequent agreement with USACE, Special Use Permit Town of Clay Review and approval of applications for special use permits 12 Planning Board (Town of Clay Code § 230-26.B.(3); §§ 230-27, generally). Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York CPO became the lead federal agency for the Proposed Project on behalf of NIST and the Department of Commerce on April 6, 2024.
CPO and OCIDA agreed to act as joint Lead Agencies under NEPA and SEQRA and to jointly prepare the DEIS. The USACE and the United States Environmental Protection Agency (USEPA) agreed to act as cooperating agencies for the NEPA review. The U.S. Federal Highway Administration (FHWA), U.S. Department of Interior, Office of Environmental Policy and Compliance, the U.S. Fish & Wildlife Service (USFWS), and Onondaga Nation agreed to act as participating agencies. The Onondaga Nation agreed to be a participating entity in the development of the EIS.
Memory chips using DRAM technology have crucial applications in military equipment, cybersecurity technology, the aerospace industry, artificial intelligence (AI), and other cutting- edge uses, as well as more common areas of the domestic consumer economy such as medical devices and other healthcare technology. However, the global structure of the semiconductor supply chain is vulnerable to critical points of failure that create the risk of geopolitical tensions and large-scale supply interruptions, which could impair access to suppliers or customers. Expanding or “onshoring” domestic advanced semiconductor manufacturing capacity in key areas such as memory is critical to enhancing the resilience of the U.S. semiconductor supply chain to potential global disruptions. This need is particularly critical given that current DRAM production in the U.S. represents less than one percent of global DRAM production.
Although the Department of Commerce’s final award to Micron only includes direct funding to support Micron’s construction and operation of fabs 1 and 2, the Department of Commerce based its award decision on Micron’s proposal to establish a full 4-fab cluster by 2041 (which would ramp up to full operational capacity by 2045). The Department of Commerce’s funding award for a the construction of a semiconductor memory facility is based on two factors: (1) the amount of cleanroom space that is required to achieve an economically viable domestic memory chip output sufficient to meet U.S. economic and national security objectives, based on economic modeling; and (2) by extension, the amount of total building area and site configuration that is required to support that cleanroom space, accounting for technological, logistical, and cost considerations.
The Department of Commerce has determined that Micron’s proposal to the CPO for the construction of a new semiconductor manufacturing campus will achieve domestic memory production at the scale necessary to offset potential disruptions to U.S. economic and national security. When complete, the Proposed Project will be the largest domestic producer of DRAM, increasing national DRAM output by 1,200 percent. Micron Technology proposes to increase its U.S.-based DRAM production by a factor of 12 (i.e., to approximately 12 percent of global DRAM output) over the next two decades, which will also increase the U.S. share of global DRAM manufacturing capacity to a level that meets the U.S. need for domestically produced memory chips. This production increase is not achievable through modernizations and expansions at existing domestic Micron locations alone and would necessitate the construction of a new semiconductor manufacturing campus.
13 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Micron’s purpose and need for the Proposed Project are to construct and operate a state- of-the-art, economically viable semiconductor manufacturing facility. In coordination with CPO and OCIDA, and based on its Sales and Operations Planning (SNOP) process, Micron determined that the only feasible method of establishing an economically viable large-scale memory chip production facility in the United States would be to develop a 4-fab facility on a single site capable of efficiently increasing Micron’s U.S.-based DRAM production 12-fold from current levels to 52,000 wafers per week, which also would ensure a resilient domestic supply of DRAM chips consistent with CHIPS Incentives Program and New York Green CHIPS Program objectives. Micron identified the WPCP as a suitable location for the Proposed Project based on the site’s ability to accommodate a 4-fab footprint and its proximity to the utility, transportation, and human resources infrastructure necessary to achieve the economies of scale the Proposed Project would require. Accordingly, Micron proposes to lease and ultimately purchase the WPCP from OCIDA and to construct and operate a 4-fab facility at that location.
In addition to the SEQRA purpose and need, the Proposed Project also fulfills the Department of Commerce’s statutory responsibilities under the CHIPS Act, including the requirement to provide federal financial assistance to covered entities to incentivize investment in facilities and equipment in the United States for the fabrication, assembly, testing, advanced packaging, production, or research and development of semiconductors, materials used to manufacture semiconductors, or semiconductor manufacturing equipment. Moreover, it fulfills Onondaga County’s long-term mission to transform Onondaga County’s economy through new high-paying jobs, significant financial investment, and increased economic activity, including: (1) the creation of thousands of construction jobs and significantly more permanent jobs; (2) a robust supply chain of companies that will service a high-tech advanced manufacturing organization; (3) a reduction in poverty; and (4) secondary benefits such as increased local small business activity, growth in community civic and cultural organizations, and increased county and municipal investment. Similarly, it helps deliver on the State of New York’s commitment to attract new semiconductor manufacturing and related material supplier projects to the State.
SEQRA requires agencies to consider a reasonable range of alternatives to the proposed action that are feasible considering the objectives and capabilities of the project sponsor. Working with CPO, the evaluation criteria for considering the alternatives were (1) the ability to meet CPO’s purpose and need under NEPA; (2) the ability to meet Micron’s purpose and need under SEQRA; (3) technical and economic feasibility and practicability; and (4) reduced adverse and/or greater beneficial environmental effects when compared to the Preferred Action Alternative. Except for the No Action Alternative, if an alternative would not meet CPO’s purpose and need under NEPA or Micron’s purpose and need under SEQRA or would not be technically and economically feasible and practicable, that alternative was not carried forward for detailed analysis in the EIS, regardless of how it would compare against the fourth criterion.
The range of alternatives considered were the Preferred Action Alternative, the No Action Alternative, a Reduced Scale Manufacturing Alternative, a U.S. Route 11 Access Elimination Alternative, and six Micron Campus Site Layout Alternatives. As only the Preferred Action Alternative was feasible given Micron’s objectives and capabilities (as well as that of CPO), 14 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York OCIDA has selected the Preferred Action Alternative for construction and operation of the Micron Semiconductor Manufacturing Project. The Preferred Action Alternative was selected after weighing and balancing all relevant factors and considerations, including those provided through public comments, and allows for mitigation of all environmental impacts to the greatest extent reasonable and practicable.
No Action Alternative Under the No Action Alternative, the WPCP would remain in its current condition pending future development proposals. OCIDA acquired all parcels on the WPCP, the vast majority of which are presently vacant, for the specific purpose of creating an industrial park (as analyzed in the WPCP 2021 Supplemental Generic Environmental Impact Statement). The No Action Alternative would delay OCIDA’s long-standing objective to bring high-tech facilities and high paying jobs to Onondaga County at the WPCP until such time as OCIDA identifies another suitable development proposal for the property. The Rail Spur and Childcare Sites would remain vacant properties. The existing utility authorities would not undertake utility improvements or need to obtain easements for the Connected Actions.
Reduced Scale Manufacturing Alternative OCIDA considered reduced scale manufacturing alternatives in coordination with Micron. As described in the FEIS, reduced scale alternatives, including two- and three-fab configurations, would not be able to achieve the level of economically viable domestic memory chip output sufficient to meet Micron’s purpose and need. A reduced scale manufacturing alternative would incur significantly higher costs per unit of DRAM produced than a full-scale four-fab campus and would not meet Micron’s economic sustainability needs. Without a single campus capable of achieving 52,000 chip wafers of output per week, Micron also would not be able to facilitate co-
location and efficient operation of semiconductor manufacturing supply chain expertise and supplier delivery operations in the vicinity, which would impede the Proposed Project’s operational efficiency by making it more difficult to obtain critical materials and keep production high and costs low through collaborative engineering. Further, reduced scale alternatives would require constructing and operating additional fabs at other locations, above and beyond what is already being contemplated, which would have additional environmental effects. Based on the above factors, reduced scale manufacturing alternatives would not be economically viable or meet Micron’s purpose and need and were not carried forward for further evaluation.
U.S. Route 11 Access Elimination Alternative In coordination with Micron, OCIDA considered a potential site layout alternative for the proposed Micron Campus that would eliminate driveway access to the campus from U.S. Route 11. Eliminating the driveway would avoid the disturbance of 2.3 acres of Federal jurisdictional wetlands, including 0.71 acres of State jurisdictional wetlands accounted for within the 2.3 acres of Federal jurisdictional wetlands. The site access driveway from U.S. Route 11, however, would be a vital access point to the Micron Campus and would ensure sufficiently streamlined construction traffic movement to avoid interference with local traffic patterns, particularly during construction of fabs 2 through 4, when carefully managing the flow of construction vehicles, equipment, and personnel would be crucial to maintain efficiency and safety. Further, the driveway 15 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York would distribute site access more effectively across the area roadway network and would mitigate post-construction traffic effects from campus operations. Therefore, OCIDA did not carry this site layout alternative forward for further analysis in the Environmental Impact Statement (EIS). Micron Campus Site Layout Alternatives In coordination with Micron, OCIDA considered a further series of potential site layout alternatives for the proposed Micron Campus to determine whether a different layout of the fabs and supporting buildings from the Preferred Action Alternative site layout would result in fewer impacts to waterbodies on the WPCP. Specifically, six site layout alternatives were considered in addition to the Preferred Action Alternative. However, OCIDA determined that none of the site layout alternatives, besides the Preferred Action Alternative, would be practicable because each would create inefficiencies that would prevent the Micron Campus from achieving the semiconductor wafer output necessary to achieve commercial viability. In addition, OCIDA found that the Preferred Action Alternative would impact fewer Federal jurisdictional wetlands (approximately 190 acres) compared to other site layout alternatives, all of which would impact 200 acres or more of Federal jurisdictional wetlands. Therefore, OCIDA did not carry this site layout alternative forward for further analysis in the EIS.
Other Locations Although not a formal alternative, the EIS describes the efforts that preceded Micron’s application by the State of New York and OCIDA to identify a suitable location for a semiconductor manufacturing facility. This included (1) the process that the State of New York conducted to identify semiconductor technology parks sufficient in scale to advance the State’s semiconductor manufacturing sector; and (2) the process that OCIDA conducted to identify sites in Onondaga County sufficient in scale to host a large-scale semiconductor manufacturing facility. Of the four sites that New York identified, only the WPCP was available and met Micron’s criteria. OCIDA also completed a GEIS, which was supplemented in 2021, that identified and screened various alternatives to the WPCP within Onondaga County. The analysis concluded that the WPCP was the only viable option to meet the semiconductor industry’s needs, as it meets specific project pre-requisites, including a large, contiguous parcel of land controlled by a single owner, and access to significant, redundant, and resilient transportation and utility infrastructure. As part of the EIS, OCIDA required Micron to update these prior searches for alternative
locations within New York. Micron’s updated property search focused on identifying other potentially reasonable alternative sites for the Proposed Project. Using an available parcel listing survey, Micron identified three sites, including the WPCP, that were available for purchase and that were 1,000 acres or greater in size. Of the three sites, only the WPCP was located in a NYISO Load Zone with the potential to provide a sufficiently reliable and stable electricity supply to the Proposed Project. In addition, the WPCP satisfied all of Micron’s other site selection criteria,
whereas the other two sites failed several criteria.
The Preferred Action Alternative will complete the anticipated development of the WPCP, bringing its vision to reality and creating numerous benefits for state and local governments in the 16 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York form of capstone developments that are regional destinations, increased tax revenue, and additional economic growth, as well as fulfilling a need for domestic semiconductor industry growth in the United States. Specifically, the Proposed Project provides the following benefits: • The Proposed Project will construct and operate a large-scale state-of-the art DRAM manufacturing facility at the WPCP that will achieve state and federal initiatives to expand long-term economically sustainable growth in the domestic semiconductor industry in support of U.S. economic and national security. Upon completion, the Proposed Project will be the largest domestic producer of DRAM chips, which have crucial applications in military equipment, cybersecurity technology, the aerospace industry, AI, and other cutting-edge uses, as well as more common areas of the domestic consumer economy. The Proposed Project will produce 52,000 DRAM chips per week, increasing national DRAM output by 1,200 percent.
• The Proposed Project will generate substantial new economic activity in the local and regional areas. Operations of a 4-fab facility are anticipated to generate over $10 billion in real GDP impacts within the regional area. The Proposed Project will generate additional tax revenues for the local and regional areas and will invest $500 million in local and regional initiatives that advance identified community needs. • Construction and operation of the Proposed Project will lead to substantial job generation and increased wage potential within the local and regional areas. The construction of the Proposed Project is anticipated to generate over 4,000 on-site construction jobs, providing new construction employment opportunities and additional income. By 2045, the Proposed Project is anticipated to generate over 9,000 permanent on-site operational jobs, providing long-term skilled employment opportunities for unemployed, underemployed, and job-changing residents in the local and regional areas.
• Construction of the Proposed Project is anticipated to reverse the overall net job loss trend in the local and regional construction sector.
• Construction of the Proposed Project is anticipated to have significant beneficial effects on the local and regional areas through projected increases in average annual wages and household incomes for those areas, as well as the associated induced income growth through increased household spending. The Proposed Project is estimated to generate over $2 billion in induced disposable personal income in the five-county region by 2035 and over $3.3 billion by 2041.
• The Proposed Project’s construction and operational activities will generate off-site economic activity and additional jobs and labor income within industries supporting Micron’s construction, and within governments and businesses supporting workers’ day-to-day spending. By 2045 the Proposed Project is anticipated to generate demand for nearly 9,500 jobs at regional supply chain businesses and approximately 23,500 jobs at regional governments, institutions, and businesses supporting the growth in regional household spending (approximately 33,000 off-site jobs in total). 17 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York • The Proposed Project’s induced growth will encourage economic diversity, increasing regional competitiveness and strengthening regional supply chain industries. The supply chain and consumer spending activity will support existing businesses and attract new businesses to the region.
• In the longer-term, Micron and other construction-related employment opportunities will attract skilled workers to the region due to the increased labor demand. • The increased housing demand in the regional area is anticipated to lead to investment in neighborhoods where deferred maintenance and lack of housing production are present, including in the City of Syracuse, where housing conditions have been deteriorating.
• The Proposed Project will be the largest private investment in New York’s history. By the end of the decade, one in four U.S.-made chips are anticipated to be manufactured in and around Upstate New York.
• The Proposed Project will create new infrastructure in an industry and manufacturing facility of local, state and national importance, investment in workforce development, hundreds of construction jobs and thousands of permanent full-time positions and increased sales tax revenue, and thereby advance the job opportunities, health, general prosperity, and economic welfare of the people of the County of Onondaga and the State of New York.
On June 14, 2023, OCIDA received an Application for Financial Assistance from Micron for financial assistance within the meaning of New York General Municipal Law § 854(14) to construct the Proposed Project. Micron’s application has been amended and restated and includes the lease and eventual purchase of the WPCP in Clay, New York and the undertaking of potential property condemnation pursuant to the New York EDPL. In connection with this application and to assist OCIDA in determining whether the Proposed Project may have a significant impact upon the environment, Micron submitted to OCIDA a Full Environmental Assessment Form (EAF). In order to ensure that the potential environmental impacts associated with the full buildout of the “Micron Campus” were fully evaluated, the EAF covered both the project as described in Micron’s application as well as the construction of all four (4) fabs, the Rail Spur Site and Childcare Site. On July 20, 2023, OCIDA passed a resolution at a regular meeting declaring its intent to act as Lead Agency under SEQRA and classifying the proposed action as a Type I for purposes of a coordinated SEQRA review. Parts 2 and 3 of the EAF were completed by OCIDA, in accordance with 6 NYCRR § 617(f) of the SEQRA regulations.
On July 28, 2023, OCIDA circulated a public Notice of Intent to Establish Lead Agency to all of the required involved, and interested agencies, via receipted delivery. No objection to that notice was received during the subsequent 30-day comment period. At its regular meeting on 18 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York September 14, 2023, OCIDA issued a Positive Declaration, indicating the need for an EIS, and scheduled a public scoping meeting.
The following state and local agencies are involved agencies for the SEQRA review: • New York State Department of Environmental Conservation (NYSDEC) • Empire State Development, including the New York State Department of Economic Development and the New York State Urban Development Corporation (ESD) • New York Department of State (NYSDOS) • New York State Department of Transportation (NYSDOT) • New York State Office of Parks, Recreation and Historic Preservation (OPRHP) • New York Office of General Services (NYSOGS) • New York Power Authority (NYPA) • New York State Canal Corporation • Onondaga County Department of Transportation (OCDOT) • OCWA • OCDWEP • Town of Clay Town Board • Town of Clay Planning Board • Town of Cicero Planning Board The following state and local agencies are interested agencies for the SEQRA review: • New York State Public Service Commission (NYSPSC) • New York State Energy Research and Development Authority (NYSERDA) • Onondaga County Department of Planning • City of Syracuse • Syracuse Metropolitan Transportation Council (SMTC) • Town of Cicero Town Board Scoping Process OCIDA completed the SEQRA scoping process pursuant to 6 NYCRR § 617.8. At its regular meeting on September 14, 2023, OCIDA accepted a Draft SEQRA Scope of Work, made it available for review and comment by all involved and interested agencies, and by the public, in accordance with SEQRA, and scheduled a public scoping meeting to be held on October 11, 2023. The Positive Declaration and notice of public scoping meeting were published in the Environmental Notice Bulletin (ENB) on September 20, 2023. Notice of the public scoping meeting was placed in The Post Standard (Syracuse.com) – a newspaper of general circulation serving the broader Clay, New York area. Project information and a Draft SEQRA Scope of Work were posted on OCIDA’s website (www.ongoved.com).
A public scoping meeting was held on October 11, 2023, with public comments received on the Draft SEQRA Scope of Work until October 31, 2023. In total, 39 individuals, organizations, and agencies provided comments during the public comment period, including written comment 19 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York letters from USFWS and NYSDEC. Because the EIS was prepared to satisfy the requirements of both SEQRA and NEPA, a separate NEPA scoping comment period and scoping meeting was held as well.
On December 14, 2023, OCIDA adopted the Final SEQRA Scope, which was made available to the previously noticed agencies and posted on OCIDA’s website. Notice of the final scoping document was published in the ENB on December 27, 2023.
Preparation and Acceptance of the DEIS CPO and OCIDA jointly prepared the Draft Environmental Impact Statement (DEIS) to evaluate the potential environmental effects of the Proposed Project as required under NEPA and SEQRA. OCIDA prepared the DEIS to consider the environmental effects of the Proposed Action and alternatives, equally with social and economic factors, before it or any involved State or local agency may issue SEQRA findings and exercise discretionary decision-making or funding authority with respect to the Proposed Project, and to propose mitigation measures to avoid or minimize adverse environmental effects to the maximum extent practicable.
During development of the DEIS, OCIDA regularly consulted with other SEQRA involved and interested agencies (including but not limited to NYSDEC and NYSDOT) to ensure that all environmental impacts were identified and fully evaluated in the DEIS while at the same time CPO regularly consulted with NEPA participating and cooperating agencies (including but not limited to USEPA and USACE). OCIDA created a working group to understand and evaluate the Proposed Project and Connected Actions and all potentially significant environmental impacts, including available avoidance, minimization and mitigation measures, as well as to consider and assess preliminary drafts of the DEIS. In May and June of 2025, OCIDA staff held numerous agency working group sessions during which OCIDA’s counsel and consultants discussed each environmental resource area evaluated in the DEIS and addressed all questions.
On June 25, 2025, OCIDA adopted the DEIS as complete for the purpose of commencement of public review and set an August 11, 2025, deadline for the receipt of public comments. On that same date, OCIDA adopted a Public Hearing Resolution and filed the DEIS with the involved and interested agencies, including with the Chief Executive Officer of the Town of Clay and the Town of Cicero and published the Notice of Availability in the ENB and The Post- Standard. CPO filed the DEIS with USEPA for issuance of a Notice of Availability in the Federal Register and mailed the Notice of Availability to the parties on the mailing list. The Notices of Availability provided notice of public hearings to take place, explained how to access the DEIS either in-person or on CPO’s and OCIDA’s websites, announced a 45-day period for the public to comment on the DEIS, and explained how electronic or written comments can be submitted to CPO and OCIDA. The DEIS was made available at the OCIDA office at: 335 Montgomery Street, Floor 2M, Syracuse, New York 13202; Onondaga County Public Library, 447 South Salina Street, Syracuse, NY 13202; Town of Clay Town Hall, 4401 Route 31, Clay, NY 13041; Town of Cicero Municipal Offices, 8236 Brewerton Road, Cicero NY 13039; and posted on OCIDA’s website to facilitate public review.
As noticed, three public hearings on the DEIS were held on July 24, 2025, from 10AM – 20 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York 1PM, 2PM – 5PM and 6PM-9PM at the Liverpool High School Auditorium, 4338 Wetzel Road, Liverpool, New York, 13090. Written public comments were accepted until August 11, 2025. Comments on the DEIS were accepted in writing, either by first class mail or electronic mail, or as part of the July 24, 2025, Public Hearing. In total, there were approximately 1270 comment submissions received from the general public on the DEIS, some of which were duplicates, from a total of approximately 1050 commenters, some in support of the Proposed Project and Connected Actions and others opposed, which includes three comments from local elected officials. In addition, comments were received from 12 federal, State and local agencies.
Preparation and Acceptance of the FEIS In response to public comments on the DEIS, comments made by involved and interested agencies and further development of the Proposed Project and Connected Actions, OCIDA made the following revisions to the DEIS that were incorporated in the FEIS:
• Acknowledgement of a potential revision to the Proposed Project’s construction schedule and commencement of construction for each fab and the Child Care Site as well as Connected Actions;
• Addition of a new substation based on the recent decision by NYISO that a new electrical substation will be required for operations of fab 2;
• Revisions to noise mitigation measures requested by the Town of Clay Planning Board for the Proposed Project;
• Addition of Appendix A-5 which includes a summary of all comments received from the public, including the involved and interested agencies, during the public comment period, and responses to those comments. Copies of comments that were received are provided in Appendix A-6.
• Addition of Appendix L-1 which expands on the discussion in the DEIS on the proposed use, management, and disposal of per- and polyfluoroalkyl substances (PFAS) as part of the Proposed Project and Connected Actions;
• Addition of Appendix R-2 which expands on Micron’s public outreach activities; • Other minor revisions to the DEIS in response to agency and other public comments or to update Tables and Figures, as needed.
During development of the FEIS, OCIDA regularly consulted with other SEQRA involved and interested agencies (including but not limited to NYSDEC and NYSDOT) while at the same time CPO again regularly consulted with NEPA participating and cooperating agencies (including but not limited to USEPA and USACE). OCIDA also held additional Agency working group sessions during which the Agency’s counsel discussed the process and the changes from DEIS to FEIS and addressed all questions. OCIDA ultimately determined that none of the changes from DEIS to FEIS materially change the reasonably foreseeable effects that were described in the DEIS 21 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York for the Proposed Project and Connected Actions or alter the significance of those effects. The FEIS was accepted as complete by OCIDA on November 7, 2025. OCIDA caused the FEIS and Notice of Completion of Final EIS to be filed in accordance with SEQRA, with copies of the FEIS sent to the Involved and Interested Agencies. Copies of the FEIS were also made available for public viewing at the office of OCIDA during business hours and at the Onondaga County Public Library. The FEIS can be viewed on OCIDA’s webpage at:
https://ongoved.com/micronfeis2025/. The Notice of Completion of Final EIS was published in the ENB on November 12, 2025, in accordance with SEQRA (6 NYCRR § 617.12(c)(1)).
This Findings Statement considers the relevant environmental, economic and social impacts, facts and conclusions disclosed in the FEIS for the action, including all appendices and applications for permits and approvals, as well as the Final SGEIS for the WPCP (2021) and all other documents prepared in conjunction with the SEQRA process. Other federal and State agencies, including the USACE, USFWS, USEPA, NYSDEC, NYSDOT, and New York State Office of Parks, Recreation and Historic Preservation participated in the environmental review of the Proposed Project and offered their technical advice within their agency’s areas of expertise. OCIDA relies on this technical expertise, including the USFWS’ Biological Assessment, the Section 106 consultation process led by CPO and the permitting processes before the USACE and NYSDEC for the Proposed Project and Connected Actions.
This Findings Statement weighs and balances relevant environmental impacts with social, economic and other considerations and provides a rationale for OCIDA’s decisions regarding potential environmental impacts associated with the action and certifies that the requirements of 6 NYCRR Part 617 and Article 8 of the ECL have been met. OCIDA further certifies that the action chosen is the alternative that, consistent with social, economic, and other essential considerations, avoids or minimizes potential significant adverse environmental impacts to the maximum extent practicable and that such impacts will be avoided or minimized to the maximum extent practicable by incorporating, as conditions, those mitigating measures that are identified as practicable herein. The FEIS identifies both short-term, construction-related activities and long-term impacts associated with the Preferred Action Alternative and No Action Alternative. The facts and findings of the potential impacts of the Preferred Action Alternative by topic (including impact thresholds), as well as best management practices (BMPs) to reduce or eliminate potential adverse impacts and, where required, mitigation measures, are summarized by topic below.
Land Use, Zoning and Public Policy Impacts Land Use and Zoning Construction of the Proposed Project and Connected Actions under the Preferred Action Alternative will convert existing vacant land and residential land uses to industrial use over a 16- year timeframe, representing a significant direct change to existing land use. At full build-out, the 22 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Micron Campus, Rail Spur Site, and Childcare Site will replace existing vacant land and limited residential uses with industrial and commercial uses. Construction will require removal of the existing structures on the WPCP (the four remaining single-family homes on Burnet Road and Caughdenoy Road) and the Childcare Site (the former single-family home and barn vacated in 2024). The existing high-power transmission lines and telecommunications tower will remain on the WPCP, while the existing OCWA water line will be relocated on the WPCP site. Further development of the Micron Campus will remove Burnet Road and create new access roads and driveways leading to the manufacturing facility from NYS Route 31, U.S. Route 11, and Caughdenoy Road.
The vast majority of the WPCP is zoned Industrial (I-2) under the Town of Clay Zoning Code, except for the three parcels along Burnet Road with vacant single-family homes which are zoned Residential/Agricultural (RA-100). Construction of the Proposed Project will require rezoning of the remaining residential parcels along Burnet Road to I-2. Rezoning this land, however, will be consistent with the I-2 zoning for the majority of the WPCP and OCIDA’s intended use for the WPCP as an industrial park and employment center, as well as public policies. Micron, together with OCIDA as the current landowner, has submitted an application to the Town of Clay Town Board requesting these parcels be rezoned to I-2.
Construction of the Connected Actions will not result in land use changes except for certain changes to properties required for the wastewater conveyance system build-out. For construction of the new OCDWEP industrial wastewater conveyance system a new easement area will be required, running through portions of vacant land and farmland on the parcels between the Oak Orchard site and the Verplank Road ROW. This easement currently contains ten properties. The conveyance system will require a change in use and demolition of existing structures on one of the properties, a privately owned residential parcel previously acquired by Micron. Micron also has secured easements with the owners of seven of the other properties. Easements on these seven properties and on the two remaining properties will not require demolition, relocation, or movement of any existing structures or change the current use of the property outside the easement area. If agreements cannot be reached with the owners of the remaining two properties, OCIDA will move to acquire the properties by eminent domain under the EDPL, and the owners will receive just compensation. The remainder of construction of the Connected Actions will occur at existing utility properties (the National Grid Clay Substation, the OCDWEP Oak Orchard site, and the OCWA LOWTP) and in existing easement areas and ROW.
Public utility projects in New York State are generally exempt from local zoning regulations. Therefore, the Connected Actions that will be undertaken by OCDWEP and OCWA may be exempt from some or all local zoning requirements. To the extent the improvements are subject to any zoning requirements, OCDWEP, OCWA, and National Grid will apply for any necessary local approvals and will work with the municipalities to ensure the proposed improvements comply with applicable zoning requirements.
The proposed Micron Campus, Rail Spur Site, and Childcare Site do not include properties with active agricultural uses, but portions of these sites were formerly agricultural land, and the Natural Resources Conservation Service (NRCS) classified most of the soil on the sites as prime farmland. The Proposed Project willl directly and indirectly convert a total of 1,043.2 acres of protected farmland to industrial and commercial uses: 975 out of 1,276 acres of prime farmland 23 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York and farmland of statewide importance on the Micron Campus, 38 acres of prime farmland on the Rail Spur Site, and 31 acres of prime farmland on the Childcare Site.
NRCS conducted a land evaluation and site assessment and determined by letter dated December 5, 2024, that several Proposed Project and Connected Action components are exempt from Farmland Protection Policy Act (FPPA) provisions because they will be implemented in existing urbanized areas, utility corridors, ROW, or already converted areas. Following the NRCS assessment, CPO completed the rating forms, which resulted in scores below 160 for all sites. Therefore, the Preferred Action Alternative does not require consideration of alternative sites or project adjustments, and no further action under the FPPA is necessary. To comply with Article 25-AA of the New York State Agricultural and Markets Law, Micron and the agencies responsible for the Connected Actions will be required to follow its applicable requirements and notification procedures.
Public Policy The Preferred Action Alternative was analyzed for consistency with all applicable public policies related to land use and planning in the local region, including the Onondaga County Comprehensive Plan, the SMTC 2050 Long Range Transportation Plan 2020 Update, the Town of Clay Northern Land Use Study, the draft Town of Cicero Comprehensive Plan, and the New York Green CHIPS Program. Although the Proposed Project does not directly support all elements of each of these plans, overall the Proposed Project will be consistent with each of these policies and will fulfill several of their goals relating to economic development and industrial use of the WPCP. Growth Inducing Effects The Proposed Project would likely induce substantial new residential and commercial growth in the five-county region primarily due to increased demand for housing and business services as well as supply chain growth, resulting in gradual changes to land use over an extended period as Micron builds the Proposed Project and as job opportunities attract new populations to the region. The locations and scale of this induced commercial and residential development cannot be predicted at this time, but at least some of this induced growth would potentially result in upzoning existing residential and commercial districts for higher density or occur outside of districts already zoned for residential and commercial development. These growth inducing effects of the Preferred Action Alternative would result in significant changes to land use, including any future rezoning, but would continue to be subject to local discretionary approvals and planning policies, including applicable measures to avoid or minimize adverse development effects. Minimization and Mitigation Although the Preferred Action Alternative will result in significant changes to existing land use, those changes will continue to be subject to local discretionary approvals and planning policies, including applicable measures to avoid or minimize adverse development effects and preserve community and regional character, and will likely result in beneficial effects by fulfilling economic development policy goals.
Findings 24 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York OCIDA finds that the Preferred Action Alternative will not result in any significant adverse effects with respect to land use, zoning or public policies and will likely result in beneficial effects by fulfilling economic development policy goals. No mitigation measures are required. Geology, Soils, and Topography Impacts Construction of the Proposed Project and Connected Actions under the Preferred Action Alternative will include removal of substantial volumes of soil and bedrock, and extensive fill and grading resulting in permanent changes to these resources.
Construction of the Micron Campus will require a total area of ground disturbance of approximately 997 acres within the WPCP, 445 acres of which are currently forested land. The construction is estimated to require: (1) the removal of 1.5 million cubic yards (CY) of soil from the WPCP; (2) the removal of 978,000 CY of near-grade bedrock;2 (3) the construction of drilled pier foundations to support each of the four fabs; and (4) the import of 9 million CY of fill material to the site. Construction of the Micron Campus foundations will also require drilling and placement of approximately 25,200 20-foot piers drilled 3.6 to 4.6 feet into bedrock, or 6,300 drilled piers for each fab.
The removal of 1.5 million CY of soil from the WPCP will be necessary to remove existing soil types with conditions that would otherwise pose compression and instability risks for construction of the manufacturing facility foundations and structures. Micron will reuse excavated soils within the project area to the greatest extent practicable, where reuse is consistent with soil stability requirements. Micron will reuse all excavated material smaller than six inches for structural fill within four feet of the bottoms of proposed foundations and slabs and as much of the remaining excavated material as practicable for non-structural purposes, such as landscaping. Import of 9 million CY of stable and clean fill material to the Micron Campus site will still be necessary to replace excavated soils and surficial material and achieve required soil stability and final site grading, which will range from 385 feet above sea level in the northern portions of the site to 425 feet near NYS Route 31, consistent with present topographical conditions. Due to the number of available quarry sources, it is anticipated that adequate volume exists to meet the needs of the Proposed Project without adversely affecting regional supply. Fill material will be transported to the Rail Spur Site primarily by rail, with additional shipments by truck. Rail cars are anticipated to transport up to 1,500 short tons per hour of aggregate fill material during construction windows.
The removal of 978,000 CY of near-grade bedrock from the WPCP is necessary to accommodate the construction of the four fabs. Each fab requires specialized foundations and sufficient below-grade or “sub-fab” building space to house various aspects of the necessary 2 Karst features (e.g., sinkholes, depressions, solution cavities, caves, escarpments, ridges, etc.) were not observed within the WPCP either at the surface or within boreholes performed by the geotechnical engineers.
25 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York physical and utility infrastructure to support the fabs and their cleanrooms. In certain limited
locations, blasting operations may be necessary as a last resort to fragment the largest segments of bedrock. If used, blasting is expected to produce ground vibrations that may travel as seismic waves through the geology surrounding the blasting locations. In addition, blasting may produce air blasts and fly rock. All bedrock removal activity, including any blasting operations (if needed), will be conducted in accordance with applicable state and local blasting safety regulations, as well as with Micron’s Blasting Plan.
Construction of the Rail Spur Site will require approximately 24 acres of ground disturbance on the 38-acre site. In addition to tree clearing, the construction will require up to 85,000 CY of soil removal and import of up to 150,000 CY of fill material to achieve final site grading, followed by installation of new rails to support Rail Spur Site operations. Construction of the Childcare Site will require 13 acres of ground disturbance on the 31-acre site. In addition to tree clearing, the construction will require up to 50,000 CY of soil removal and import of up to 25,000 CY of fill material to achieve final site grading. In certain limited locations, blasting operations may be necessary as a last resort to fragment the largest segments of bedrock at the Rail Spur Site and Childcare Site.
Construction of the Connected Action improvements will involve ground disturbance across the various utility properties and routes, including soil removal and potentially the import of some fill material at certain locations. Rock removal may also be required which will be achieved primarily through chipping, where necessary; however, blasting is not anticipated. BMPs for rock removal will be utilized during construction activities to avoid significant adverse effects on geologic conditions.
At full build-out, the Proposed Project and Connected Actions are not anticipated to generate any further disturbance to geology, soils, or topography in the study area. Full build-out of the Micron Campus will result in 645 acres of new impervious surface, including asphalt and concrete cover, and 58 acres of semi-pervious surface. The remaining areas of the campus will be permeable land consisting of stormwater areas, softscape, water easements, gravel, bioretention, and undisturbed land. Approximately 273 acres of permeable land will remain forested land. The Preferred Action Alternative would result in growth inducing effects on geology, soils, and topography to the extent that increased demand for new housing and businesses would result in new development and attendant effects on geological conditions. Future development scenarios resulting in potentially significant broad-scale effects on geology, soils, and topography in the study area cannot be ruled out but would likely occur over many years at the pace of broader development and socioeconomic trends in the five-county region and would be subject to independent environmental review.
Minimization and Mitigation Micron will be required to implement the BMPs stated in FEIS Table 3.2-5 for soil and bedrock removal, pier drilling, and use of fill material throughout construction activities. Construction activities at the Proposed Project sites will be required to be conducted in accordance with Micron’s soil and materials management plan as well as State Pollutant Discharge Elimination System (SPDES) program requirements, including preparation of a Stormwater 26 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Pollution Prevention Plan (SWPPP). Micron will monitor groundwater levels in 17 monitoring wells to minimize the effects on groundwater drawdown. Adaptive management will be used throughout construction and will involve targeted surface and groundwater monitoring before, during, and after construction to characterize the relationship between surface water and groundwater, assess flow characteristics of the water resources study area, and identify if modifications in the design, construction, and management of the Proposed Project are necessary to minimize and avoid impacts to stormwater.
If blasting is deemed necessary in certain locations, Micron will implement its Blasting Plan. Construction of the Micron Campus will involve the use of drilled pier foundations as an alternative to driven piles, as they generate less construction noise compared to pile driving and also reduce the need for deeper excavation activity. All soil excavation activities will be required to be managed in accordance with Micron’s Soil and Materials Management Plan (SMMP). Connected Action construction activity will be subject to applicable laws and regulations, and terms and conditions of any required permits or approvals, which may include conditions relating to potential discharges to water resources, stormwater management measures, sediment and erosion controls, or noise and vibration mitigation measures.
Findings OCIDA finds that with implementation of the BMPS and compliance with applicable laws, regulations and permit conditions, the Preferred Action Alternative will not result in any significant adverse effects with respect to geography, soils and topography. No mitigation measures are required beyond those required by applicable law, regulation and permit conditions. Water Resources Impacts Wetlands Micron considered various design modifications to the Proposed Project to minimize losses of wetlands and wetland buffers. In total, construction of the Proposed Project under the Preferred Action Alternative will result in the permanent loss of approximately 193.38 acres of wetlands being treated as Federal jurisdictional wetlands (184.47 acres on the Micron Campus and 8.91 acres at the Rail Spur Site), or approximately 174.77 acres of wetlands being treated as State jurisdictional, which completely overlap the Federal jurisdictional wetlands except for less than one acre within wetland complex W2. Construction will also result in the permanent loss of approximately 10.50 acres of non-jurisdictional wetlands and an estimated 315 acres of protected wetland buffer areas on the Micron Campus, in addition to the approximately 15 acres of wetland buffer areas that will be lost at the Childcare Site.
These permanent losses of wetlands and wetland buffers will occur as a result of the excavation, filling, and grading activities necessary to create the level upland conditions required for construction of building foundations, walkways, parking lots, and all other associated Proposed Project components. The permanent loss of these wetlands from construction of the Proposed 27 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Project, the majority of which are considered to be high quality wetlands, will eliminate their principal and suitable wetland functions and services, as described in FEIS Appendix F-3.1. The permanent loss of jurisdictional wetlands will also result in indirect long-term effects on the remaining wetlands as a result of subsequent changes in hydrology, including increased stormwater runoff and decreased groundwater recharge. The permanent loss of wetland buffer areas may further increase the indirect effects on remaining wetlands. These losses constitute a significant adverse effect on water resources.
The Proposed Project is anticipated to result in a permanent increase in impervious surface coverage of approximately 28 million square feet (653 acres), including approximately 645 acres at the Micron Campus, 4.3 acres at the Rail Spur Site, and 2.6 acres at the Childcare Site. The loss of wetlands and conversion of surface area to impervious surfaces could lead to subsequent changes in hydrology, including increased stormwater runoff and decreased groundwater recharge. Stormwater runoff can also accumulate and carry pollutant loads downgradient, which could result in adverse effects on water quality and plant and wildlife species.
Construction of the Connected Actions will result in the permanent loss of a total of 6.40 acres of wetlands being treated as Federal jurisdictional wetlands, including 4.04 acres within the proposed Clay Substation expansion area, 0.087 acres within the natural gas improvement Limit of Disturbance (LOD), and 2.27 acres within the IWWTP LOD. The 2.36 acres lost within the natural gas improvement LOD and the IWWTP LOD are also being treated as State jurisdictional wetlands. The natural gas improvement project is also anticipated to result in the permanent conversion of 0.033 acres of Palustrine Forested (PFO) and 0.132 acres of Palustrine Scrub/Shrub (PSS) wetlands to Palustrine Emergent (PEM) wetlands from ROW maintenance (e.g., clearcutting, grubbing).
Construction of the Connected Actions also will result in temporary effects on a total of 72.30 acres of wetlands, including 4.30 acres within the Clay Substation expansion area (being treated as Federal jurisdictional only), 7.12 acres within the natural gas improvement LOD (being treated as both State and Federal jurisdictional), 53.62 acres within the water supply improvement LOD (being treated as both State and Federal jurisdictional), and 7.26 acres within the wastewater improvement LOD (being treated as both State and Federal jurisdictional). The Connected Actions are anticipated to result in permanent increases in impervious surface coverage, in particular within the Clay Substation expansion area, from facility upgrades at the LOWTP and Terminal Campus, and within the IWWTP LOD. The full extent of increased impervious surface coverage that would be associated with the Connected Actions cannot be determined at this time.
Routine operational maintenance of utility ROW along linear improvement LOD corridors could potentially require occasional mowing and removal of wetland trees and shrubs within the corridors for maintenance access or safety reasons. These maintenance activities could indirectly lead to regression of PFO and PSS wetland cover types to PEM wetland habitat over time. Maintenance work required along the proposed natural gas line route is anticipated to indirectly convert 0.033 acres of PFO and 0.132 acres of PSS type wetlands being treated as State jurisdictional to PEM wetland habitat. It is currently unknown how many acres of State jurisdictional PFO and PSS wetlands would be subject to habitat conversion as a result of future maintenance on the proposed water supply lines or the proposed wastewater conveyance. OCWA 28 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York and OCDWEP will be required to avoid disturbing these PFO wetlands during maintenance to the greatest extent practicable.
Surface Water Micron considered various design modifications to the Proposed Project to minimize losses of surface water features to the maximum extent practicable. Within the Youngs Creek basin, construction of the Micron Campus will result in the permanent loss of 6,283 linear feet (LF) of stream channels being treated as Federal jurisdictional, consisting of 2,585 LF of intermittent streams (41.1 percent) and 3,698 LF of ephemeral streams (58.9 percent). There will be no losses of State jurisdictional river or stream features or any surface water features in the Shaver Creek basin. The proposed Micron Campus layout has been designed to avoid construction in the perennial main channel of Youngs Creek. The proposed Childcare Site layout has been designed to avoid losses to the 18 LF of stream channel identified along the western edge of the site boundary. No rivers or streams were identified at the proposed Rail Spur Site.
Construction of the Connected Actions will result in the permanent loss of a total of 1,545 LF of regulated ditches being treated as Federal jurisdictional, all within the proposed Clay Substation expansion area. Construction will also result in temporary effects on a total of 3,491 LF of rivers and streams being treated as Federal jurisdictional, including 380 LF within the substation expansion area, 175 LF within the natural gas improvement LOD, 2,835 LF within the water supply improvement LOD, and 101 LF within the wastewater improvement LOD.
The permanent loss of headwater streams within the Youngs Creek basin will cause the loss of their principal functions, including wildlife habitat, retention of organic and inorganic particulates, nutrients, and contaminants, and stabilization of the beds, banks, and floodplains of Youngs Creek and its tributaries. Secondary functions will also be lost, including the ability to transport woody debris and sediment to influence stream bed forms and provide thermal regulation. The loss of these stream channels, in combination with the wetland losses described above, constitutes a significant adverse effect on water resources. These losses will alter local hydrologic conditions and could lead to indirect effects on downgradient surface water conditions including altered transport, downstream flooding, stream bank erosion, soil erosion, excess pollution loads, increased water temperature, increased turbidity, excess nutrient loads, and excessive aquatic algae/weeds.
During operations, wastewater from the Micron Campus will be required to be treated and managed in accordance with applicable regulatory requirements, law and permits prior to discharge to surface waters. Industrial wastewater generated at the Micron Campus that is not treated at the campus on site for reuse shall be treated on the Micron Campus to levels necessary to meet discharge limitations and conditions contained in an Industrial Wastewater Discharge Permit (IWDP) that will be issued by OCDWEP to Micron. Micron also will be required to work with OCDWEP to develop a plan to reuse treated Oak Orchard IWWTP effluent volumes as makeup water for the Micron Campus’ cooling towers and other mechanical systems. Only treated effluent from the IWWTP that is not recycled and returned to the Micron Campus will be discharged into the Oneida River. This discharge will comply with the OOWWTP’s approved SPDES permit issued by NYSDEC and applicable regulations.
29 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Stormwater Construction of the Proposed Project and Connected Actions may temporarily alter existing land cover and soil type characteristics that influence stormwater infiltration. Activities such as clearing, grubbing, excavation, and land disturbance involve the removal or disturbance of vegetation and soil within construction footprints. Because vegetation and topography slow the movement of stormwater, removing or disturbing these features can directly affect stormwater runoff by reducing infiltration time and increasing runoff flow, which could exacerbate stream bank erosion and habitat destruction, and cause flooding and infrastructure damage, depending on the intensity of precipitation events and the extent of impervious surfaces. The completed phases of the Proposed Project and Connected Actions will create new impervious surfaces that could increase potential stormwater runoff flow and pollutant discharge during operations that, unless adequately managed, could exacerbate downstream effects on other water resources and water quality.
Many of the Connected Actions will involve installation of underground utilities in trenches that would be returned to existing grade and revegetated once construction is complete; these activities will result in negligible stormwater runoff effects during operation. Groundwater Construction of the Proposed Project will require clearing and grubbing of existing vegetation and soil excavation. Vegetation removal may change runoff characteristics within construction areas, which could reduce stormwater infiltration and groundwater recharge. Dewatering, which involves pumping groundwater out of excavation areas to allow for dry working conditions, will be performed as necessary during Proposed Project construction to allow for proper building footings, foundations, and waterproofing. Dewatering may lower the local water table, which could cause changes to the surrounding hydraulic gradient that could affect groundwater movement and availability. Construction will also require substantial volumes of fill material, which could alter groundwater movement and storage capacity.
No primary or principal aquifers or sole source aquifers have been identified beneath the Proposed Project portion of the study area, but confined and unconsolidated aquifers exist on the western edge of the Shaver Creek watershed. These aquifers are not currently used as public drinking water sources. Instead, all public drinking water for the area is sourced from surface water resources and is distributed by OCWA. In addition, there are only nine private domestic wells within approximately one mile of the WPCP, including two directly on the WPCP and one approximately one-quarter mile southwest of the proposed Rail Spur Site, which may be used for drinking water or agricultural purposes. Operation of the Proposed Project will rely on water supplies from OCWA, which obtains water from surface water sources. Therefore, the Proposed Project will not require and will not be authorized to use any groundwater withdrawals. Construction of the septic system associated with the childcare facility will require excavation for the installation of a septic tank and leach field. The septic system for the Childcare Site will be installed and maintained in compliance with NYCRR Title 10 Part 75 and will be permitted by NYSDOH prior to operation. If not designed, installed, or maintained properly, septic systems can contaminate groundwater with pathogens, chemicals, and nutrients, which can 30 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York adversely affect groundwater quality. If operation results in more than 1,000 gallons per day of discharge to groundwater, Micron will be required to obtain a SPDES permit from NYSDEC. Forty-two (42) groundwater monitoring wells have already been installed at strategic
locations around the WPCP as part of pre-design activities. Micron will be required to periodically assess the information gathered from these monitoring wells and identify any changes that would warrant alterations to Proposed Project design and construction. If required based on the amount of groundwater withdrawal needed for any dewatering activities, Micron will obtain a Water Withdrawal Permit from NYSDEC and implement a dewatering plan.
With respect to the Connected Action sites, the natural gas, water supply, and wastewater improvement LODs will overlay approximately 86.53 acres of unconsolidated aquifers; the IWWTP will overlay 6.65 acres of a principal aquifer in Onondaga County and the water supply lines will overlay 43.97 acres of the Fulton primary aquifer in Oswego County. Construction of the Connected Actions will require clearing and grubbing of existing vegetation and soil excavation. Although required excavation depths for the Connected Actions are not known at this time, dewatering also may be performed as necessary as part of temporary cut and cover trenching, which would be the primary construction method used for most of the linear improvements. Construction may also require fill material at certain locations. If required during construction of the Connected Actions, National Grid, OCWA, and OCDWEP will obtain site-specific Water Withdrawal permits from the NYSDEC and implement dewatering plans for these activities. If required, National Grid, OCWA, and OCDWEP also will obtain SPDES CGPs and develop SWPPPs and SPCC/SPR Plans to reduce the risk of accidental releases, leaks, or spills during construction activities and provide instructions for immediate containment and cleanup of any release.
Floodplains Construction of the Proposed Project and Connected Actions may alter existing land cover and topography, which could lead to temporary and permanent alterations in existing hydrology, including effects from stormwater runoff on downstream receiving waters that could reduce floodplain functions or storage capacity, or increase flood risk or frequency. However, effects from changes on floodplains within the Proposed Project portion of the study area will be minimal. The proposed Micron Campus, Rail Spur Site, and Childcare Site are not directly on or adjacent to any special flood hazard areas (SFHAs) or 500-year floodplains; only a portion of the study area to the west of the Childcare Site includes such floodplains.
Within the Connected Actions sites, 28.28 acres of the water supply improvement LODs and 1.36 acres of the IWWTP LOD will be located within regulated floodplains. Construction activities in these areas may include excavation, trenching, grading, horizontal directional drilling (HDD), or temporary water impoundment or diversion structures for channel crossings. Most of these construction activities will be temporary; the water supply lines will be installed below ground, with the ground restored to original grade, and will not permanently occupy any floodplain surface areas. Further, construction work in navigable waters will be subject to applicable requirements for Rivers and Harbors Act Section 10 Permits from USACE and possible Protection of Waters Permits from the State. Construction activities in SFHAs will be subject to floodplain 31 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York development permits from the relevant municipalities, including any permit conditions requiring floodplain damage prevention measures.
Coastal Areas No Proposed Project components will be located within the coastal zone in New York State or within the Town of Clay or City of Oswego Local Waterfront Revitalization Program (LWRP) boundaries. Construction of the new water supply line terminating at the RWPS will be within the coastal zone boundary but will not be within any Coastal Erosion Hazard Areas. Construction of the proposed water supply improvements and wastewater conveyance with portions of their LODs within the City of Oswego and Town of Clay LWRPs will primarily involve temporary cut and cover trenching activities. In addition, the new IWWTP within the Town of Clay LWRP is unlikely to be visible above the tree line from off-site. Any potential visibility will likely occur through existing vegetation and is anticipated to be extremely limited in extent.
Growth Inducing Effects The Preferred Action Alternative would potentially result in growth inducing effects on water resources primarily to the extent that increased demand for housing and business services in the five-county region, including supply chain growth, would lead to further development in wetlands, rivers, or streams, cause increases in stormwater runoff, or increase the potential for effects on groundwater, floodplains, or coastal resources. These changes would be gradual and would be subject to applicable environmental laws and regulations and permits and approvals. Minimization and Mitigation Mitigation will be required under Section 404 of the CWA and Article 24 of the ECL to address the anticipated permanent losses of federal and State jurisdictional wetlands and surface water features. Under the proposed Mitigation Plan, Micron will be required to enhance, establish, or restore in-kind a total of 422.14 acres of wetlands and 14,030 LF of stream features across six mitigation sites located within a nine-mile distance to the northwest of the WPCP. Overall, approximately 1,341 acres of land within the Oneida River watershed will be protected in perpetuity under the mitigation plan. Additionally, Micron will purchase nine in-lieu fee program credits from the Johnson Farm Preserve.
Consistent with federal regulations, the Mitigation Plan has been designed to replace the suite of lost functions and services from Proposed Project construction, including hydrology and sediment dynamics, biogeochemistry and nutrient cycling, and habitat and food web maintenance. In general, the required mitigation, which will be finalized prior to any ground disturbance as part of the USACE’s 404 permit and NYSDEC’s Article 24 permit, will improve the wetland and stream functions and services over those lost, increasing both the quantity and quality of wetlands and streams within the larger watershed.
The routine operational maintenance along linear improvement LOD corridors may require occasional mowing and removal of wetland trees and shrubs within the corridors for maintenance access or safety reasons. Under ECL Article 24, PFO wetlands converted to PEM habitat as a result of regular utility ROW maintenance would be subject to compensatory mitigation requirements for any PFO wetlands that are also State jurisdictional wetlands. Although compensatory 32 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York mitigation may be required for these future maintenance activities, indirect conversion of one wetland habitat cover type to another would not be considered a significant adverse effect. Micron, National Grid, OCWA, and OCDWEP will each be required to implement and maintain stormwater BMPs identified in applicable SWPPPs during construction to reduce stormwater runoff rates, reduce erosion of disturbed land and downgradient sedimentation, and protect stormwater from contamination. All BMPs will be designed to meet the performance criteria in the New York State Standards and Specifications for Erosion and Sediment Control manual (NYSDEC, 2016), or the version in effect at the time of approval given the phased development and will be appropriately documented in relevant SWPPPs. Stormwater management areas will be designed to meet New York State Stormwater Management Design Manual requirements (NYSDEC, 2024a), or the version in effect at the time of approval given the phased development, to ensure waters of the State are protected from adverse impacts of construction stormwater runoff and no downgradient increases in stormwater quantity would occur. Micron will be required to implement the BMPs listed in FEIS Table 3.3-12, including the institution of BMPs during operations to manage, control, and monitor wastewater flows during operations by engaging in the following: (1) incorporate facility segregation processes to facilitate enhanced water treatment, testing, and recycling; (2) implement a Supervisory Control and Data Acquisition alarming and control system; (3) off-spec wastewater treatment tanks; (4) redundant pH flow meters at compliance points; (5) auto shut-off valve to control discharge of off-spec wastewater off-site (Note: This requires real-time monitoring which is not possible for all discharge parameters); (6) maintain preventative maintenance program for compliance equipment; (7) utilize internal chemical review; (8) implement an Accidental Spill Prevention Plan; (9) implement a Toxic Organics Management Plan; and (10) incorporate measures to implement anticipated near-term updates to regulatory requirements. Micron will also be required to increase and maximize water recycling, reuse, and restoration, where feasible during operations. In addition to the stormwater BMPs that Micron will be required to implement as part of the Proposed Project design, post-construction SMPs will be required to meet MSGP effluent limitations for stormwater discharges from industrial activities for the protection of water quality. Micron will be required to propose one or more feasible alternatives based on stormwater modeling from the SMPs listed in FEIS Table 3.3-11. These operational SMPs will be documented in the SWPPP required under the MSGP and will include monitoring conditions. National Grid, OCWA, and OCDWEP will implement similar SMPs to reduce post-construction stormwater runoff from the operation of the Connected Actions. The IWWTP will be required to implement such SMPs as a condition of its SPDES CGP, and the SMPs will be used to meet MSGP effluent limitations for stormwater discharges from the IWWTP. These SMPs will be designed to meet the 2024 New York State Stormwater Management Design Manual requirements, or the requirements in effect at the time of approval, and will be documented in relevant SWPPPs. The SMPs will be employed to maintain existing drainage patterns to the greatest extent practicable, continue the conveyance of upland watershed runoff, control increases in stormwater runoff, prevent soil erosion and sedimentation, and provide runoff reduction using green infrastructure measures where feasible. In addition, the wet extended detention ponds and filtration bioretention areas will reduce the potential for stormwater runoff to contribute to downstream flood hazards.
33 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Several of the stormwater BMPs and SMPs that Micron will implement as part of the Proposed Project will filter out pollutants and provide on-site stormwater detention, which will avoid or minimize effects from stormwater runoff on downstream receiving waters. The stormwater BMPs and SMPs will also serve to increase infiltration of stormwater runoff from impervious surfaces to mimic the existing storage and runoff rates at the WPCP and proposed Rail Spur and Childcare Sites and maintain the hydraulic balance within the Youngs Creek and Shaver Creek watersheds, which will avoid or minimize potential effects on floodplains. The reduced runoff rate will also promote groundwater recharge and ensure that the hydroperiod for downgradient wetlands will not be significantly affected.
Micron, National Grid, and OCWA will use adaptive stormwater management informed by groundwater monitoring well data and supported by the Surface Water Report. The Surface Water Report is an in-depth evaluation of the surface water dynamics and is part of Micron’s Wetland Adaptive Assessment and Management Plan. Together these documents will inform adaptive management efforts to protect water quality, sustain wetland functions, and identify the need for modifications to Proposed Project or Connected Action designs to avoid or minimize effects from stormwater runoff, minimize the effects on groundwater draw down and verify that the groundwater flow component to downstream wetlands is not affected. Of the 42 groundwater monitoring wells installed as part of pre-design activities, 17 will be used as a basis for developing adaptive stormwater management measures. Information gathered from the remaining 25 monitoring wells, the additional 15 surface water monitoring points (7-culvert and 8-channel), and the five piezometer wells proposed to be installed within wetlands around the WPCP, will be periodically assessed to determine if any alterations would need to be made to the stormwater management measures. Micron will continue to conduct targeted and comprehensive surface and groundwater monitoring before, during, and after Proposed Project construction to inform adaptive management as needed to protect domestic wells, and promote groundwater recharge, filtration, infiltration, and storage to ensure groundwater hydrology is maintained at a level equivalent to pre-construction conditions. Micron also will continue to perform surface water level and flow monitoring as part of its SWPPP and refine SMPs and techniques as appropriate to avoid or minimize changes in flows downstream that could result in floodplain effects.
To further protect surface and groundwater, Micron, and if required, National Grid, OCWA, and OCDWEP, will obtain SPDES CGPs and develop SWPPPs and SPCC/SPR Plans to reduce the risk of accidental releases, leaks, or spills and provide instructions for immediate containment and cleanup of any release.
For construction activities within coastal zone boundaries, OCWA and OCDWEP will adhere to erosion and sediment control standards and incorporate construction BMPs to ensure consistency with federal and State coastal resource use policies and the Clay and Oswego LWRPs. Further, no actions within the coastal zone will take place until a written finding is made that the action is consistent to the maximum extent practicable with federal and State coastal resource policies and any applicable LWRPs.
During operations, OCDWEP will set limits in the IWDP that must be met at the point of discharge from the Micron Campus, prior to being sent as secondary residual wastewater via the wastewater conveyance to the IWWTP. These effluent limitations will be consistent with EPA pretreatment guidelines and the requirements of the OOWWTP SPDES permit. Micron’s IWDP 34 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York will include monitoring and reporting of regulated parameters. Monitoring and reporting for these parameters will also be conducted by OCDWEP and reported to NYSDEC through the established SPDES permit prior to discharge to the Oneida River.
Micron will also be required by OCDWEP to develop a plan to reuse treated IWWTP effluent volumes as makeup water for the Micron Campus’ cooling towers and other mechanical systems. Only treated effluent from the IWWTP that is not recycled and returned to the Micron Campus will be discharged into the Oneida River. This discharge will be required to comply with the OOWWTP’s approved permit and applicable regulations.
Findings Due to the requirement that Micron obtain all pertinent water resource permits and comply with all applicable laws and regulations governing water resources, OCIDA finds that construction of the Proposed Project and Connected Actions will not result in significant adverse effects from stormwater or significant adverse effects on groundwater, floodplains, or coastal resources. Post- construction operation of the Proposed Project and Connected Actions will not result in significant adverse effects on water resources.
Even taking into consideration design considerations to avoid wetlands loss and compliance with all applicable permits, laws and regulations, construction of the Proposed Project and Connected Actions will result in significant adverse effects on wetlands and surface water; however, the mitigation measures that will be required as part of the federal and State wetlands permitting will mitigate the permanent losses of federal and State jurisdictional wetlands and surface water features functions and services to the maximum extent practicable. Biological Resources Impacts Ecological Communities – Construction Effects Micron Campus Construction of the Micron Campus will result in the loss of approximately 253.3 acres of successional old fields, 187.5 acres of successional shrublands, and approximately 194 acres of delineated wetlands, 10.5 acres of which are non-jurisdictional. Construction will also result in the loss of 6,283 LF of jurisdictional surface water features within the Youngs Creek basin. Although the upland communities that will be lost are common throughout Onondaga County and the surrounding region, the loss of the wetlands and riparian stream channels and their conversion to developed land cover types will likely fragment and alter the composition of wetland, forested, and grassland habitat at the site where terrestrial wildlife, aquatic life, and special status species would potentially occur or are known to occur. The loss of ecological communities will result in significant adverse effects on biological resources.
Highly mobile mammals, such as white-tailed deer and coyote, and semiaquatic mammals with the ability to relocate, such as American beaver, North American river otter, mink, and muskrat, would likely retreat to remaining undisturbed portions of the site or abandon the site in search of other habitat not already at carrying capacity. However, these highly mobile mammals 35 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York may be challenged to find habitat elsewhere that is suitable and not already at carrying capacity. Some mortality of small mammals unable to relocate, such as those trapped in dens or burrows or unable to avoid the paths of site clearing and earthmoving activities, would be expected to occur. Mammals sensitive to noise and lighting disturbances would be expected to relocate to similar habitats off-site, leaving only synanthropic species (i.e., species accustomed to humans), including generalist species (e.g., rabbits and squirrels), on-site and in immediately adjacent areas. Construction effects on special status species are described under Special Status Species below. Tree clearing will be prohibited during the primary breeding season for most bird species (April through July). Therefore, construction will avoid direct effects on actively breeding woodland birds protected under the Migratory Bird Treaty Act (MBTA). Consistent with NYSDEC guidance, to avoid effects on grassland birds, construction in open fields will be limited to late summer and early fall, after the breeding period but before the wintering period. However, most bird species that currently occupy the Micron Campus site, aside from highly synanthropic, disturbance-tolerant species, are expected to retreat to remaining undisturbed portions of the site or abandon the site in search of other habitat not already at carrying capacity over the course of construction. Noise and lighting disturbances will potentially affect birds in immediately adjacent areas. Overall, many bird populations at the site are expected to experience reduced fitness and survival, and steep declines of populations in the immediate area around the site is expected to occur. Construction effects on special status species are described under Special Status Species below.
Mass mortality of reptiles and amphibians, including salamanders, frogs, turtles, and snakes, is expected to occur during construction as a result of site clearing, grubbing, and grading, as these taxa are not mobile enough to avoid the paths of most site clearing and earthmoving activities. Noise and lighting disturbances are also expected to affect reptiles and amphibians in immediately adjacent areas. In addition, construction could indirectly affect amphibians and aquatic reptiles by altering the water balance and water quality of the Youngs Creek basin. Construction effects on special status species are described under Special Status Species below. The filling of wetlands and surface waters during construction of the Micron Campus will reduce the Youngs Creek wetland complex on the site and associated aquatic habitat. The elimination of wetlands and headwater streams could permanently alter the transport of sediment, organic matter, nutrients, and macroinvertebrates that are critical to downstream physical, chemical, and biological attributes and processes, including species composition and food web dynamics. Vegetation clearing and other construction effects may elevate stream temperatures, which could cause temperatures to exceed the tolerance levels of sensitive species, including many cold-water fish and macroinvertebrates. Changes in topography and soil exposure may temporarily increase soil erosion, which could increase sediment, turbidity, and nutrient loading in receiving waterbodies. This could lead to harmful algal blooms and decreased dissolved oxygen levels, which could lead to fish kills, increased establishment and spread of invasive plants, or other adverse effects on aquatic biota. Construction effects on special status species are described under Special Status Species below.
Rail Spur Site Construction of the Rail Spur Site will result in the loss of approximately 9 acres of wetlands (8.4 acres of red-maple hardwood swamp, 0.1 acres of shallow emergent marsh, 0.1 acres 36 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York of shrub swamp, and 0.4 acres of farm ponds/artificial ponds) and 13.6 acres of hemlock northern hardwood forest. The effects on ecological communities at the Rail Spur Site as a result of these changes is anticipated to be similar to those that would occur at the Micron Campus. Childcare Site Construction of the Childcare Site includes approximately 13 acres of ground disturbance, with effects on wetlands limited to the loss of 0.06 acres of non-forested, non-jurisdictional wetlands. The conversion of approximately 13.3 acres of cropland / field crop cover type will not significantly decrease the presence of that cover type in the area, given that more than two thirds (150,000 acres) of Onondaga County’s land area is made up of agricultural fields. However, the conversion of approximately 13 acres of open habitat (including the cropland cover and the small portion of non-jurisdictional shallow emergent marsh) to developed areas adversely affect the site’s grassland habitats. Construction is not anticipated to cause abrupt microclimatic changes within these forested communities or create “sharp edges” around them (i.e., expose the edges of the communities to light, wind, temperature shifts, or moisture).
Construction of the Childcare Site will displace most of the mammals, birds, reptiles, and amphibians within the approximately 13-acre ground disturbance area. Highly mobile wildlife sensitive to construction noise are expected to relocate to the undeveloped 18 acres on the site or in search of other off-site habitat. Most species in the disturbance area are expected to experience reduced fitness and survival. Some mortality of small mammals, reptiles, and amphibians unable to relocate to suitable alternative habitats not already at carrying capacity will occur. Wildlife expected to occur at the site, including the undeveloped 18 acres, during the early construction period will generally be limited to generalist species tolerant of human activity, but no suitable habitat would remain in the area of disturbance after clearing and construction of site facilities. Connected Actions The assessment of impacts to ecological communities from construction of the Connected Actions assumed that construction will disturb the ecological communities in all 594 acres across the Connected Action LODs, although actual disturbance to existing ecological communities and land cover types is likely be less than the full extent of all of the LODs, given that actual construction activity is not anticipated to occur across the entire footprints of existing utility properties or the entire widths of existing utility easements. Most construction disturbance within the LODs for the Connected Actions will occur in previously disturbed areas (roughly 385 acres of developed land, mowed lawn, mowed roadside / pathway, and paved and unpaved road / path cover types) and areas associated with various levels of human activity (roughly 26 acres of active cropland), with the remaining disturbance occurring in forested uplands, shrubland, old fields, and wetlands (roughly 182 acres of upland forests shrubland, old fields, forested and non-forested wetlands, and scrub-shrub wetlands).
Wildlife with the ability to relocate are expected to abandon the LODs in search of other habitat. Some mortality of smaller or less mobile wildlife may occur. Disturbances to wildlife in immediately adjacent areas from human activity and construction noise and lighting also may occur. Wildlife sensitive to these disturbances is expected to move away from these adjacent areas, leaving primarily synanthropic generalist species in the vicinity.
37 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York The permitting processes for the Connected Actions is expected to incorporate conditions relating to wildlife, including restrictions on work in wetlands and time-of-year restrictions, as applicable. National Grid, OCWA, and OCDWEP will be required to coordinate with permitting agencies on these restrictions. Installation of utility lines under mapped rivers and streams and construction of other Connected Actions in the vicinity of surface waters will be conducted in accordance with applicable permits, including erosion and sediment control measures in SWPPPs to minimize potential adverse effects on aquatic resources.
Ecological Communities – Operational Effects In general, the effects on ecological communities at the operational stage of the build-out of the Proposed Project are similar to those during construction, including fragmentation and altered composition of ecological communities, pressures from invasive plant species, and potential hydrological and water quality effects. Wildlife tolerant of fragmented habitats, anthropogenic noise, and lighting is expected to occupy the remaining undeveloped portion of the Micron Campus north of the electric transmission corridor and east of fab 4. During longer-term operations of the Rail Spur Site, the biotic integrity of the approximately 14 undeveloped acres on the site is expected to decline due to changing microclimatic conditions from fragmentation, dust and soot deposition from aggregate material transported through the site during the 16-year construction window and changed hydrology from filling of wetlands.
The Childcare Site would create 2.6 acres of impervious surface coverage, but will leave approximately 18 acres undeveloped, including the shelterbelts at the site boundary and the floodplain forest area in the northeastern portion of the site. Operation of the Childcare Site will lead to an increase in existing daytime noise levels due to increased vehicle traffic, human activity, and operation of rooftop air handling units and other external building maintenance equipment. Wildlife tolerant of fragmented habitats, anthropogenic noise, and lighting is expected to occupy the remaining undeveloped 18 acres of the site. Lighting effects from operation of the site will be reduced through the use of downward-directional lighting and extinguishing of larger light sources at night.
Wildlife is also expected to occupy undeveloped parts of Connected Action LODs, utility ROW, and adjacent areas during longer-term operations. Wildlife remaining in the Clay Substation expansion area will largely be limited to synanthropic generalist species. Wildlife occurring at and adjacent to the Oak Orchard site is already largely limited to common generalist species, and that composition is expected to continue during operations. For the linear utility improvements, areas disturbed by trenching will be covered and appropriately seeded or mulched for re-vegetation. Portions of the linear improvement alignments would be periodically mowed and maintained as herbaceous or low shrubland communities, but unmaintained corridor edges would be allowed to re-vegetate and eventually revert to forested cover.
Special Status Species Bats As the lead agency for purposes of Section 7 consultation under the ESA, CPO determined early in the consultation process that the Proposed Project is expected to have effects on two Federal listed endangered species, the Indiana bat and the northern long-eared bat, as well as the 38 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York tricolored bat, which is proposed to be listed as a Federal endangered species. Tree clearing and construction of the Proposed Project and Connected Actions will eliminate potential foraging and roosting habitat for the bat species by converting the forested ecological communities at the sites through development. This will include the permanent loss of approximately 467 acres of potential roosting habitat, based on the anticipated effects on forested ecological communities at the Micron Campus site and the Rail Spur Site. These changes will leave no foraging or roosting habitat of sufficient size or sufficiently free of high levels of disturbance to support the species. As a result, CPO anticipates making a “may affect, likely to adversely affect” determination for the Indiana bat and the northern long-eared bat, and a “not likely to jeopardize; may affect, likely to adversely affect” determination for the tricolored bat.
The Indiana bat and the northern long-eared bat are also State listed endangered species, and NYSDEC will be responsible for issuing an ECL Article 11 Endangered and Threatened Animal Species Incidental Take Permit for the Proposed Project and has issued a notice of complete application on August 12, 2025. While the public comment period has closed, the take determinations for the two State-listed bat species are subject to ongoing NYSDEC review and will be the subject of a future permitting decision.
Based on information available to date, construction of the Connected Actions is conservatively estimated to disturb approximately 82 acres of potential roosting habitat for Indiana, northern long-eared, and tricolored bats, based on the acreage of all forested land cover types and ecological communities in the Connected Action LODs. Effect and take determinations for the Connected Actions are subject to ongoing coordination and consultation that must be completed before any ground disturbance activities will be permitted to occur.
Following Proposed Project construction and anticipated fragmentation of Indiana bat, northern long-eared bat, and tricolored bat habitat, bat activity will be significantly reduced during operations, and the species generally would not be expected to roost or forage at the Proposed Project sites. Site operations will result in increased regular human activity and noise and lighting disturbance. Each of the three bat species exhibits a degree of tolerance of anthropogenic noise while roosting, but the species are likely to avoid foraging in areas with increased noise, which could limit potential foraging habitat to the edges of forested areas. Indiana and northern long- eared bats are also generally averse to artificial light.
Following disturbances during construction of the Connected Actions, to the extent that suitable forested areas for the bat species remain in the Connected Action LODs, returning bats may potentially be able to inhabit remaining suitable habitat, and generally are expected to experience a lesser degree of noise and lighting disturbance compared to Proposed Project site operations. Suitable bat habitat in the Clay Substation expansion area and at the Oak Orchard site will largely remain similar to the suitable habitat present on those sites today. Some of the utility corridors will be allowed to re-vegetate, which could potentially improve foraging and commuting conditions for Indiana bats and tricolored bats over time and compensate for initial losses in tree cover. The 70-foot-wide permanent corridors that will be maintained during operations will likely be narrow and vegetated enough to avoid fragmentation effects on northern long-eared bats. Northern Harrier and Short-eared Owl 39 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York The northern harrier is a State listed threatened species and a migratory bird of prey, and the short-eared owl is a State listed endangered species and a migratory bird of prey. The Proposed Project will likely result in a taking of northern harriers and short-eared owls under NYSDEC regulations due to habitat loss from site clearing and displacement in response to human activity, noise, and lighting disturbances from construction. Construction of the Micron Campus could potentially result in these species no longer using the site and being displaced from the area. NYSDEC anticipates making a take determination for these species due to construction of the Proposed Project. No suitable open habitat is present at the Rail Spur Site. The natural gas, water supply, and wastewater lines would run through or adjacent to large agricultural fields with the potential to support northern harriers. Construction of those utility improvements would potentially displace northern harriers from selecting these fields as nesting or wintering habitat during one nesting and wintering season. Effect and take determinations for the Connected Actions are subject to ongoing coordination and consultation.
Following Proposed Project construction and anticipated fragmentation of northern harrier and short-eared owl habitat, northern harrier and short-eared owl activity will be comparatively limited during operations, and individuals are not expected to winter at the Micron Campus or the Childcare Site. Large fields in or adjacent to the natural gas and wastewater improvement LODs will continue to provide suitable habitat to these species during operations.
Sedge Wren The sedge wren is a State listed threatened species. Suitable habitat for the sedge wren is
present within or adjacent to segments of the natural gas line and wastewater conveyance that pass
through successional old fields. Construction of these improvements could temporarily displace sedge wrens from selecting the associated habitat, but such displacements will represent a spatially and temporally minor reduction in potential sedge wren habitat. Effect and take determinations for the Connected Actions are subject to ongoing coordination and consultation. Large fields in or adjacent to the natural gas and wastewater improvement LODs will continue to provide suitable habitat to sedge wrens during operations.
Bald Eagle The bald eagle is not currently listed under the ESA but is protected under the MBTA and the BGEPA, and is a State listed threatened species. Suitable bald eagle habitat is present in the vicinity of the water supply and wastewater improvements, and the species has been documented nesting in the vicinity of the Oak Orchard site. Construction activities will adhere to the distance- specific criteria in the USFWS National Bald Eagle Management Guidelines and other conditions imposed by USFWS and NYSDEC. Suitable bald eagle habitat will remain in the vicinity of the Oak Orchard site during operations. OCWA and OCDWEP will coordinate with USFWS and NYSDEC as part of the permitting processes for their improvements on measures to protect bald eagles.
Black Tern The black tern is a State listed endangered species. Suitable habitat for the black tern is
present near the water supply improvement LOD within approximately 60 hectares of large
emergent wetlands in the vicinity of the Oneida River near Country Route 12 and Peter Scott Road. 40 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York OCWA will coordinate with NYSDEC as part of the permitting process. Construction activities will adhere to time-of-year restrictions, wetland matting requirements, and other conditions imposed by NYSDEC. Operation of the water supply improvements will not affect the black tern’s emergent wetland habitat in the vicinity of the Oneida River.
Pied-Billed Grebe The pied-billed grebe is a State listed threatened species. Suitable habitat for the pied-billed grebe is present in emergent wetland habitats adjacent to the water supply and wastewater improvements, in the vicinity of the Oneida and Oswego Rivers. The species has been documented in the vicinity of the Oak Orchard site. OCWA and OCDWEP will coordinate with NYSDEC as part of the permitting processes for their respective improvements. Construction activities will adhere to time-of-year restrictions, wetland matting requirements, and other conditions imposed by NYSDEC. Emergent wetlands adjacent to the water supply and wastewater improvements in the vicinity of the Oswego and Oneida Rivers is anticipated to continue to provide suitable habitat to pied-billed grebes during operations.
Monarch Butterfly The monarch butterfly is proposed to be listed as a Federal threatened species. Construction of the Proposed Project will result in substantial losses of suitable habitat for the monarch butterfly, including successional shrublands and old fields at the Micron Campus and Rail Spur Site and agricultural fields at the Childcare Site, as well as some mortality at the latter end of the winter season when monarch butterflies begin to emerge. However, given the abundant suitable habitat throughout the region, overall adverse effects on the species in the area from construction of the Proposed Project and Connected Actions are expected to be limited. CPO anticipates making a “not likely to jeopardize” determination for the monarch butterfly.
Proposed Project and Connected Action operations also are not expected to adversely affect monarch butterflies or suitable monarch butterfly habitat, which is expected to continue to be abundantly present in the surrounding areas and will potentially regrow in utility corridor areas. Micron’s landscape management plan shall promote flowering species used by monarch butterflies.
Lake Sturgeon Lake sturgeon is a State listed threatened species. Suitable habitat for the lake sturgeon is
present where the water supply improvements would cross the Oswego River and in the Oneida
River near the outfall from the OOWWTP at the Oak Orchard site. Construction of the IWWTP will not involve construction in the Oneida River. OCWA will coordinate with NYSDEC as part of the permitting process for the construction of the proposed water supply improvements, which will include installation of water transmission lines using HDD under the Oswego River. Construction activities will adhere to applicable NYSDEC permit restrictions to avoid disturbing sturgeon during sensitive periods. OCDWEP will be responsible for operating the IWWTP in compliance with SPDES industrial wastewater permit conditions, including conditions to protect water quality in adjacent lake sturgeon habitat in the Oneida River.
Hairy Small-Leaved Tick Trefoil 41 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Hairy small-leaved tick trefoil is a State listed threatened plant species. Suitable habitat is
present at the Oak Orchard site and the species has been documented in the vicinity of the Oak
Orchard site. OCDWEP will coordinate with NYSDEC to ensure that any individuals found at the site are identified for on-site protection (through avoidance) or off-site protection (e.g., through transplanting or seed collection and propagation).
OCDWEP will continue to coordinate with NYSDEC during operations to ensure that any hairy small-leaved tick trefoils discovered at the Oak Orchard site are identified for on-site protection (through avoidance) or off-site protection (e.g., through transplanting or seed collection and propagation).
Growth Inducing Effects The Preferred Action Alternative would potentially result in growth inducing effects on biological resources primarily to the extent that increased demand for housing and business services in the five-county region, including supply chain growth, would lead to further development in the ecological communities and species habitat, including water resources, although the extent of impact cannot be predicted at this time. Because projected losses of forestland and grassland habitats due to induced growth are contingent on the specific locations, extent, and nature of future development, it is not feasible to project specific future losses of forest- and grassland-dependent wildlife, including protected bats or grassland birds. Overall, the projected net habitat losses described in the FEIS pp. 3-137 and 3-138 are relatively low, and may be offset by land cover succession rates.
Minimization and Mitigation Micron will be required to implement BMPs to help minimize the effects of the Proposed Project on biological resources, which are listed in FEIS Tables 3.4-8 and 3.4-12. These BMPs include construction effect minimization measures such as vegetative buffers, an Erosion and Sediment Control Plan, an Invasive Species Management Plan, a Landscape Management Plan, and water quality BMPs and SMPs, as well as retention of on-site roosting and foraging habitat, landscape management, noise reduction, lighting reduction, water quality protection, and biological monitoring. The Childcare Site will also include a pollinator garden, shade trees, and vegetative screens. To further protect aquatic habitat, IWWTP effluent discharges will be subject to applicable SPDES industrial wastewater permit pretreatment standards and toxic effluent limitations. Utilities near waterbodies with suitable sturgeon habitat will have SPCC/SPR Plans to avoid or minimize effects on habitat water quality. Notwithstanding these BMPs addressing effects such as fragmentation, altered composition, invasive species, and impacts on aquatic habitats, significant adverse effects on Federal and State listed bat species and State listed grassland birds remain such that mitigation is required.
Mitigation – Bats To mitigate the unavoidable effects on the Indiana bat, northern long-eared bat, and tricolored bat, Micron will purchase and permanently protect twice the amount of roosting habitat that would be lost due to Proposed Project and Connected Action construction and would fund research and monitoring efforts to benefit science-based bat species conservation and management programs in New York State. This 2:1 ratio amounts to a minimum of approximately 1,182 acres 42 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York of protected roosting habitat that will be protected via conservation easement, resulting in a total of at least 1,454 permanently protected acres of roosting habitat for Indiana, northern long-eared, and tricolored bats. Additionally, 1,367 total acres of forested roosting habitat across 9 parcels has been reviewed by USFWS and NYSDEC and acquired for permanent protection via conservation easement by the Wetland Trust Inc.
Other mitigation measures described in FEIS Table 3.4-13 and the Biological Assessment that will be required to be implemented by Micron include the purchase and installation of roost boxes, funding for hibernaculum gating, and acoustic bat monitoring. Micron will sponsor research and monitoring projects recommended by and designed in consultation with USFWS and NYSDEC to help improve the science-based management and conservation of Indiana, northern long-eared, and tricolored bats in New York. To further support the conservation and management of the Indiana bat, northern long-eared bat, and tricolored bat, and to help compensate for future cumulative impacts that could result from Micron-induced economic growth in the region, Micron will establish a $1 million fund from which grants would be awarded for projects that benefit these species. Micron will contribute up to $50,000 towards the fabrication and installation of gates to prevent people from entering and disturbing the Glen Park bat hibernaculum or another hibernaculum of USFWS’ and NYSDEC’s choosing. Finally, Micron will conduct acoustic bat monitoring on the Micron Campus during each year of its construction and for the first two years after full build-out in accordance with USFWS survey guidelines and approved study plans. Mitigation – Grassland Birds To achieve a net conservation benefit for northern harriers and short-eared owls lost due to Proposed Project construction, NYSDEC will require that either three acres of new or improved habitat be protected for every acre lost, or one acre of new or improved habitat be protected for every one acre lost along with a commitment to manage that habitat in a grassland state for 15 years. Micron and The Wetland Trust (TWT), a 501(c)(3) nonprofit organization, will purchase 650 acres of sufficiently high-quality habitat for permanent protection and to restore and manage the habitat as grassland for 15 years (in 3-year cycles) to achieve the required net conservation benefit. A final grassland protection plan will be developed in coordination with NYSDEC and will be subject to NYSDEC review and approval.
The specifics of these required mitigation measures are included in the BA and the grassland bird incidental take permit application. In coordination with the USFWS and NYSDEC, Micron will develop a mitigation masterplan that details all final, agreed-to mitigation actions by the time formal Section 7 consultation with USFWS is completed. As part of the ESA Section 7 consultation process, USFWS is responsible for issuing a BO concerning the incidental take of Federal listed species in connection with the Proposed Project. The BO will include reasonable and prudent measures necessary or appropriate to minimize the impact of the incidental take of such species.
In addition to the BO to be issued by USFWS, NYSDEC will be responsible for issuing an ECL Article 11 Endangered and Threatened Animal Species Incidental Take Permit for the Proposed Project. Micron will be required to have both the BO and Incidental Take Permit prior to any ground disturbance activities.
43 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York The Connected Actions will be subject to separate permitting processes. As part of those processes, National Grid, OCWA, and OCDWEP will be required to coordinate or consult with Federal and State agencies concerning potential effects on and incidental take of listed special status species.
Findings OCIDA finds that construction of the Proposed Project will result in significant adverse effects on biological resources. This includes significant adverse effects on Federal and State listed threatened and endangered species, including the Indiana bat, northern long-eared bat, tricolored bat, northern harrier, and short-eared owl. Construction of the Connected Actions and post- construction operation of the Proposed Project and Connected Actions will not result in significant adverse effects on biological resources. Special status species will be subject to future coordination or consultation with federal and State agencies concerning potential effects on and incidental take that, where necessary, will require appropriate minimization and mitigation measures. The required BMPs, as set forth in the FEIS, and the mitigation measures that will be incorporated into the BO and state Incidental Take Permit will avoid, minimize and mitigate adverse effects to biological resources to the maximum extent practicable, and for the state Incidental Take Permit will be required to achieve a net conservation benefit.
Historic and Cultural Resources Impacts CPO is serving as the lead Federal agency for the Section 106 consultation process under the National Historic Preservation Act (NHPA) for the Proposed Project and Connected Actions. CPO, in consultation with the New York State Historic Preservation Office (NYSHPO), the Advisory Council on Historic Preservation, OCIDA and other consulting parties, including Indigenous Nations with an interest in potentially affected areas, has identified areas of potential effect (APE) for both historic architectural properties and archaeological resources. Micron, as a non-Federal party, is helping CPO fulfill its Section 106 obligations by preparing necessary information and analyses as authorized by 36 C.F.R. § 800.2(a)(3).
CPO is in the process of preparing a Programmatic Agreement (PA) in coordination with the Onondaga Nation, NYSHPO, OCIDA and other Section 106 consulting parties for the Proposed Project and Connected Actions. The PA provides a framework for identifying historic properties and assessing effects through a phased survey approach. The PA allows for portions of construction to commence after the Area of Potential Effects (APE) has been thoroughly investigated. CPO has reviewed and approved six Phase 1A Archaeological Documentary Studies of the Proposed Project and Connected Actions (Electric Service, Natural Gas Line, Water Supply Improvements, Industrial Wastewater Treatment Plant, Industrial Wastewater Conveyance). Thus, many of the impacts from construction and operation of the Proposed Project and Connected Actions to historic and cultural resources will be assessed in the future. Phase IB archaeological investigations have been recommended for the Proposed Project and all Connected Actions, which will be completed in a staged approach following the PA.
To ensure that CPO’s responsibilities under the NHPA and its implementing regulations are met, as well as ensure that impacts to historic and cultural resources are not adversely effected, 44 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Micron will not be authorized to begin construction of the Proposed Project or commence use of staging, storage, or temporary work areas or new or to-be-improved access roads until Section 106 obligations have been met as defined under the PA, even if Micron receives funding and all other permits are obtained.
Proposed Project APEs NYSHPO identified one historic archeological property within the indirect APE of the Micron Campus as eligible for inclusion in the SR and NRHP, a two-story residence with a detached garage built circa 1875 located on the east side of Brewerton Road in the Town of Cicero, but found that the Proposed Project will have no effect on this historic architectural property. CPO proposed a finding of no adverse effect with respect this historic architectural property. In a letter dated June 23, 2025, NYSHPO concurred with CPO’s finding of no adverse effect to historic properties.
No historic archaeological properties were identified within the APEs of the Rail Spur and Childcare Sites. On August 29, 2025, CPO provided a finding of no historic properties affected (36 C.F.R. § 800.4(d)(1)) for the Rail Spur Site for review and comment with consulting parties. On September 10, 2025, CPO provided a finding of no historic properties affected (36 C.F.R. § 800.4(d)(1)) for the Childcare Site for review and comment with consulting parties. NYSHPO concurred with CPO’s finding of no historic properties affected on September 5, 2025, for the Rail Spur Site and September 15, 2025, for the Childcare Site.
Consultation for the entire Proposed Project APE is ongoing. Phase 1B archaeological testing for the Proposed Project identified one precontact period archaeological site and one historic period archaeological site within the Micron Campus construction Phase 1A direct APE that were recommended for further Phase 2 testing. A Phase 2 Work Plan for the W. Anderson Historic Site is under review by CPO.
Connected Actions APEs The historic architectural survey of the proposed Water Supply Connected Action identified one historic property within the Direct APE, the New York State Barge Canal Historic District, a previously recorded historic property that is listed in the New York State Register of Historic Places (SR) and the National Register of Historic Places (NRHP). Phase 1B testing is ongoing for the Water Supply Connected Action. CPO will review the Phase 1B and any subsequent reports, make determinations of eligibility, and distribute the reports to consulting parties as they become available.
CPO also identified one historic property within the indirect APE of the Water Supply Connected Action, a two-story Gothic Revival-style house on NYS Route 31 in the Town of Clay built circa 1860 and incorporated as part of a commercial parcel that contains a retail store (SHPO USN 06703.000411). In a May 16, 2025 letter to CPO, NYSHPO concurred with CPO’s determinations of eligibility. Archaeological investigations are ongoing; consultation for this Connected Action is ongoing and CPO will provide a determination of effect to consulting parties for review and comment when it is available.
45 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York Phase 1B and Phase 2 archaeological testing was completed for the direct APE of the Electric Service Connected Action. CPO identified two historic properties, the J. Young historic archaeological site and the J. Somers historic archaeological site eligible for listing in the NRHP. On June 20, 2025, CPO proposed a finding of no adverse effect to the two historic properties. In a letter to CPO dated June 23, 2025, NYSHPO concurred with CPO’s finding of no adverse effect. Consultation for the remaining Connected Actions is ongoing and CPO will provide findings of effect as the archaeological investigations are completed and information becomes available.
Growth Inducing Effects Induced growth throughout the five-county region has the potential to affect historic properties. Although it cannot be predicted exactly when, or to what degree, induced growth would affect historic properties; any future development requiring discretionary approvals that would be undertakings under the NHPA or NYSHPA would be required to comply with Section 106 of the NHPA or Section 14.09 of the NYSHPA.
Minimization and Mitigation The final PA will describe the measures that CPO, in coordination with all other signatories of the PA, will implement to avoid or minimize adverse effects to historic properties and to ensure that any potential historic properties discovered during archaeological investigations and ground- disturbing construction activities are thoroughly investigated. The mitigation measures proposed for discoveries during archaeological investigations and construction are outlined in FEIS Table 3.5-2.
Archaeological testing for several APEs is either awaiting approval or ongoing and may continue to be conducted during the Federal and State agency reviews of the Proposed Project and Connected Actions. In the event that a future or ongoing Phase 1B Archaeological Investigation confirms the presence of archaeological resources requiring further archaeological analysis, a Phase 2 Archaeological Survey and Evaluation would be conducted. If any identified archaeological resources are determined to be SR- or NRHP-eligible, and those sites cannot be avoided, Phase 3 Data Recovery for the identified sites and resources would be completed in consultation with NYSHPO, the Onondaga Nation, and other consulting parties. The PA also allows for further archaeological investigations in the event of inadvertent discoveries during ground-disturbing construction activities. In such cases, all construction in the area would be stopped and the protocols and procedures for inadvertent discoveries that are outlined in the PA would commence.
Indigenous Nation monitoring has been utilized for all phased archaeological investigations and will be utilized for any future archaeological investigations and ground- disturbing construction activities. Indigenous Nation monitors have been provided by the Onondaga Nation, and other consulting Indigenous Nations should they choose to participate. Findings 46 Onondaga County Industrial Development Agency Findings Statement Micron Semiconductor Manufacturing Project, Clay, New York CPO and NYSHPO review of historic, architectural and archaeological properties in the Proposed Project and Connected Action APEs is ongoing in accordance with Section 106. Based on the investigations that have occurred to date and because construction of the Proposed Project cannot begin until all consulting parties are afforded an opportunity to comment on whether historic properties (including historic architectural properties and archaeological resources) would be adversely affected and CPO reviews and approves the results of any further applicable historic architectural surveys or archaeological investigation work.
Air Quality Impacts Under the Preferred Action Alternative, construction and operation of the Proposed Project and Connected Actions will generate new air pollutant emissions from stationary and mobile sources.
The stationary source emissions estimates for the Micron Campus construction activities include fugitive dust from operation of a concrete batch plant, material handling, aggregate processing, and storage piles, along with combustion associated with the conveyance system generator and heaters, boilers, steam generators, and diesel generator in support of the concrete batch plant, assuming the sources operate at 6,000 hours per year based on operations during daytime hours. The stationary source emissions estimates from operation of the Rail Spur Site include fugitive dust from material handling and storage piles and combustion associated with the conveyance system generator.
An analysis was performed of the emissions and dispersion of carbon monoxide (CO), nitrogen oxides (NOx), particulate matter (PM, including both “PM10" and “PM2.5"), volatile organic compounds (VOC), sulfur oxides (SOx), and total hazardous air pollutant (HAP) from the Proposed Project’s construction stationary sources, which determined that such emissions will have a temporary adverse, direct impact on air quality. Air quality permits for the operation of the Rail Spur Site and the Micron Campus construction stationary sources are anticipated to be obtained separately by the contracted operators. These contracted operators will also be required to maintain compliance with air quality requirements separate from Micron.
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