Dear Mr. Wemple and the Guilderland Conservation Advisory Council,

Thank you for letting me send you some maps and my comments.

Save the Pine Bush opposes the proposed sub-division of 10 New Karner Road.

Please see map below for location of items mentioned.

1. 10 New Karner Road is proposed to be subdivided.  10 New Karner Road borders land to be dedicated to the Preserve. For the developer to argue that the parcel to be developed is not contiguous to land that will become part of the Preserve is ridiculous. The subdivision application before the GCAC concerns all of 10 New Karner Road, not just 10B.  In addition, the parcel being added to 10A (40.00-2-18.4) is completely contiguous to land that will be dedicated to the Preserve.  
2. The proposed parcel 10B New Karner Road was cleared of vegetation between April 20, 2014 and April 30, 2017.  Please see attached photos.  The developer argues that there is no Pine Bush on the proposed 10B.  Well, if the owner cleared the land of all of the vegetation, then, of course there is no Pine Bush vegetation on it now.  The GCAC should inquire as to when the land was cleared of vegetation, and whether this has affected the bat population or other species. Or if some of the vegetation cleared included lupines and affected the Karner Blues and Frosted Elfins.
3. The applicant should be asked what the plans are for the parcel known as 40.00-2-18.4, which borders land that will become part of the Preserve.
4. The applicant should be asked what the plans are for the rear part of 10A.  If there are plans to build on more than just 10B, these plans should be noted now, so that the cumulative impact of all of this construction on the Pine Bush can be reviewed now.
5. In the application, the applicant states that the land contains Karner Blue and Frosted Elfin (answer to question 15 on the EAF).  A take permit is required to take any endangered species, such as the Karner Blue.  GCAC should require the applicant to apply for a take permit.

The Pine Bush is a rare, unique ecosystem.  It used to cover at least 55,000 acres. Now, it is estimated that less than 10% of the original Pine Bush land is still remaining.  The 2017 Pine Bush Commission Management Plan states that 3,300 acres have been permanently protected, a tiny fraction of the original Pine Bush.

The question is, will the Town of Guilderland continue to allow the destruction of this precious and rare resource or take steps to protect it?  This is especially important as even the applicant acknowledges that a known endangered species occupies the site.

Sincerely,

Lynne Jackson
For Save the Pine Bush

• 

•