Environmental Health Residential Development Protection Program

State: NY Type: Model Practice Year: 2014

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The goal of the Nassau County Department of Health (NCDH) Environmental Health Residential Development Protection Program is to assure that all residential developments in the County are served by an approved public water supply, and sewage collection or on-site sewage disposal facilities, and are constructed in an environment that is free of public health hazards. The objective of the practice is to review the proposed arrangements for water supply and sewage disposal and to confirm by the review of information and data regarding each proposed development site that the soil, groundwater and soil vapor conditions at each site are satisfactory for residential development or are properly mitigated to prevent potential public health, safety or environmental hazards.The Environmental Health Residential Development Protection Program is implemented by notifying all prospective developers of residential property in the County of the Department’s water supply, sewage disposal, site environmental assessment, and other agency requirements that must be satisfied before any development project in the County can be endorsed by the Department (Attached Supplement 1). The project developers are requested to respond to the Department within 60 days to a series of sixteen (16) guidelines and requirements that helps the Department determine if the prospective site can be properly and safely developed. The Department notification of development requirements is submitted to the property developer, consultant and other representatives with copies to the Nassau County Planning Commission (NCPC) and local municipality every time that the Department receives a notice of a proposed new or modified development.

The Environmental Health Residential Development Protection Program has been successfully implemented for over 100 projects and almost 5,000 housing units over the last 10 years.

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Nassau County Department of Health
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Environmental Health Residential Development Protection Program
Nassau County is a suburban county on Long Island, New York that has a population of 1.34 million residents (2010 census) and borders Queens County in New York City to the west and Suffolk County to the east. All county residents make up the target population that benefit directly or indirectly from the Department's Environmental Health Residential Development Protection Program, which helps to assure that residential developments are constructed in a manner that is protective of both the public health and the environment. Nassau County has been severely impacted by hazardous industrial, commercial and residential waste and wastewater discharges and petroleum and chemical spills that have contaminated soil, groundwater and in many cases soil vapors originating from the sources of contamination. This contamination has resulted in the identification of 15 United States Environmental Protection Agency (USEPA) National Priorities List (NPL) sites, 122 New York State Department of Environmental Conservation (NYSDEC) Inactive Hazardous Waste (State Superfund) Sites, hundreds of contaminated USEPA Underground Injection Control (UIC) sites and tens of thousands of petroleum/chemical spills that were reported to the NYSDEC for investigation. Many of these sites remain under active investigation and cleanup under the jurisdiction of the USEPA and the NYSDEC.In addition to the identified contamination and spill sites there are numerous potential sources of contamination that may exist at proposed sites for residential development. This would include floor drain drywells, underground toxic and hazardous material storage tanks, sewage disposal system cesspools and leaching pools and areas of surface and subsurface contamination associated with the prior use of the property. The end result of the known and suspected or potential sources of soil, groundwater and soil vapor contamination is that there are few sites available for residential development that have not been directly or indirectly affected to some degree by on-site or off-site soil, groundwater or soil vapor contamination sources. Each undeveloped parcel of land in the County, which has been impacted by soil or groundwater contamination and which may be a reservoir for soil vapor contamination, is an ongoing threat to the health and safety of county residents who may live on the property in the future. Under the Nassau County Department of Health Environmental Health Residential Development Protection Program, the Department provides comments and recommendations to all developers and project consultants for all development projects that are brought to the attention of the Department. This includes both the residential development realty subdivision projects consisting of 5 or more lots or units that are under the direct jurisdiction of the Department and the rental apartments and assisted living facilities that are approved for construction under the authority of the local planning and building department entities. The goal of the Nassau County Department of Health (NCDH) Environmental Health Residential Development Protection Program is to assure that all residential developments in the County are served by an approved public water supply, and sewage collection or on-site sewage disposal facilities, and are constructed in an environment that is free of public health hazards. The objective of the practice is to review the proposed arrangements for water supply and sewage disposal and to confirm by the review of information and data regarding each proposed development site that the soil, groundwater and soil vapor conditions at each site are satisfactory for residential development or are properly mitigated to prevent potential public health, safety or environmental hazards.The Environmental Health Residential Development Protection Program is implemented by notifying all prospective developers of residential property in the County of the Department’s water supply, sewage disposal, site environmental assessment, and other agency requirements that must be satisfied before any development project in the County can be endorsed by the Department (Attached Supplement 1). The project developers are requested to respond to the Department within 60 days to a series of sixteen (16) guidelines and requirements that helps the Department determine if the prospective site can be properly and safely developed. The Department notification of development requirements is submitted to the property developer, consultant and other representatives with copies to the Nassau County Planning Commission (NCPC) and local municipality every time that the Department receives a notice of a proposed new or modified development. The Environmental Health Residential Development Protection Program has been successfully implemented for over 100 projects and almost 5,000 housing units over the last 10 years.
Brief Description of LHD The Nassau County Department of Health provides services to 1,339,532 people, 448,528 households, and 340,523 families (2010 Census) and has the mission of promoting and protecting the health of the residents of Nassau County. The Department’s Division of Environmental Health works to promote safe water, food, air and land and protects the public from adverse environmental health effects. Statement of the problem/public health issue The Environmental Health Residential Development Protection Program that is implemented by the Department addresses the problem or issue of how to safely develop a property in a manner that is protective of the public health in a county that has few properties or development sites that have not been affected to some degree or other by environmental contamination. The problem is compounded by the fact that there are numerous agencies at the federal, state and local level that have regulations that may have to be satisfied before a property can be properly and safely developed. There is however no single agency or department that has jurisdiction over all of the potential air, land and water resources contamination issues that could affect the development of a single parcel of land. What target population is affected by the problem (Please include relevant demographics) All county residents make up the target population that benefit directly or indirectly from the Department's Environmental Health Residential Development Protection Program, which assures that residential developments are constructed in a manner that is protective of both the public health and the environment. The target population that is immediately and directly affected by the problem of residential development at sites with possible soil, groundwater and potential indoor air contamination are those residents who may be purchasing single family homes, condominiums or cooperative apartments in the future. The target population that may be indirectly affected by this problem is considered to be the entire population of the County which could be affected by contamination sources at or adjacent to these properties if the properties are not properly investigated to remove and mitigate sources or soil, groundwater and indoor air contamination that may be originating from sources at or in the vicinity of the development site. What is target population size? What percentage did you reach? The target population size that has already been directly protected from the problem is estimated to be 100% of the estimated 15,000 inhabitants of almost 5,000 single family homes, condominiums and cooperative apartments that now reside within the more than 100 realty subdivision projects that have been approved by the Department over the ten year period of 2003 to 2012. What has been done in the past to address this problem?In the past, many environmental problems were addressed only after the impact of the contamination became evident such as the discovery of contaminated soil beneath a leaking underground chemical or petroleum storage tank, or detection of organic chemical contamination in groundwater pumped from a private or public supply well in the vicinity of an industrial, commercial or residential source of pollution. The solution to such discoveries has frequently been to address or investigate the problem on a piece-meal involved-agency-only basis that addresses the nature and extent of the identified contamination source but not necessarily all of the other potential sources or potential impacts of the contamination that may be created on the property in question. This practice can be considered to be relatively new to the field of public health because it involves the investigation of actual and potential environmental contamination problems without the need to establish additional Department regulations. The environmental aspects of the Environmental Health Residential Development Protection Program are implemented on a voluntary basis by developers who are anxious to demonstrate that a proposed residential development will pose no hazards to the public health and safety. Why is current/proposed practice better? The current practice by the Department to assure a thorough environmental assessment of properties that are proposed for development is an improvement over past practices because the assessment investigates potential and actual sources of contamination on a property that is proposed for residential development and directly requests or recommends remedial actions or refers the investigation of the potential or identified contamination issues to the federal, state, or local agency that has jurisdiction for assuring that the investigation or necessary remedial action is properly conducted. Is current practice innovative? How/so explain? If so explain. New to the field of public health OR creative use of an existing tool or practice What tool or practice did you use in an original way to create your practice? The guidance provided to residential developers and their consultants can be considered unique or innovative because it not only addresses the traditional Department of Health concern of assuring that a satisfactory drinking water supply and sewage disposal facilities are available and provided for each new or modified development; but also assures that potential environmental contamination problems are investigated and corrected before a residential development is approved. The guidelines provided to consultants and developers for response and implementation identify a series of issues that correspond to a variety of critical national, federal, state, and local regulations and guidelines that have been established to investigate or protect the soil, groundwater and drinking water resources and indoor air quality. The Environmental Health Residential Development Protection Program and the guidelines or tools utilized in this program are a mechanism for the screening of sites to assure that no significant or minor sources of potential soil, groundwater or soil vapor contamination remain or exist at a site so that the land is suitable for residential development. The program however is not a substitute for programs that are managed and enforced by other federal, state or local agencies such as the NYSDEC New York State Superfund or Inactive Hazardous Waste Disposal Site Program or the Brownfield Cleanup Program that insure that the most seriously contaminated parcels of land are evaluated and investigated and remediated as may necessary to restore a property to a condition under which it may be considered to be eligible for development subject to local municipal review and approval.Is current practice evidence based? The current practice can not be considered to be evidence based because the elimination of potential sources of environmental contamination can not be easily measured in terms of its effectiveness in protecting health and preventing disease. What is known however is that the elimination and remediation of sources of soil, groundwater and potential soil vapor intrusion into the indoor air at levels that exceed health standards or guideline levels will reduce the potential adverse health impacts resulting from residential exposure to those sources. Does practice address any CDC Winnable Battles? Select all that apply. This environmental health practice does not address any identified CDC Winnable Battles.
Goal(s) and objectives of the practice The goal of the Environmental Health Residential Development Protection Program is to assure that all residential developments in the County are constructed in a manner that assures that they are connected to a satisfactory water supply and sewage disposal system and that the future inhabitants will be protected from environmental hazards that may pose a threat to their health and safety by eliminating exposure pathways. The objective of the program is to notify developers and consultants of the Department’s Residential Development Environmental Site Assessment Policies and work cooperatively with them to assure that the program policies and requirements are considered, implemented and satisfied as part of the realty subdivision review, inspection and approval process.What did you do to achieve the goals and objectives? Steps taken to implement the Program The Environmental Health Residential Development Protection Program was developed as a result of the experience gathered by the Department over many years following the adoption and enforcement of a series of regulations (Articles) of the Nassau County Public Health Ordinance (NCPHO) including: Groundwater Protection: Regulation of Sewage and Industrial Waste Water (Article X NCPHO: January 8, 1985) Toxic and Hazardous Material Storage and Control (Article XI NCPHO: August 1, 1986) Private Drinking Systems (Article IV NCPHO: August 1, 1987) Article VI NCPHO: Public Drinking Water Supply (February 1, 1990) The Department has also gained experience in the implementation of environmental water resource and drinking water protection programs by assisting the following agencies in the enforcement of groundwater resource and drinking water protection and air pollution control programs: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (USEPA) Safe Drinking Water Act (SDWA) including the Public Water Supply Regulation Program and Underground Injection Control (UIC) Program NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION (NYSDEC) Petroleum Bulk Storage (PBS) Law, State Pollutant Discharge Elimination System (SPDES) Program, and the Air Emission (Discontinued) and Title V (Major Sources of Air Pollution) Air Pollution Control programs NEW YORK STATE DEPARTMENT OF HEALTH (NYSDOH): Public Water Supply Program and Realty Subdivision Program In order to achieve the goal of the Environmental Health Residential Development Protection Program, the Department provides a listing of policy objectives or guidelines (Supplement 1: Nassau County Department of Health Residential Development Environmental Site Assessment Policies) to residential property developers and consultants for response within 60 days. This notice is also provided to the county planning commission and the local planning and building department. The guidance applies to both the regulated developments such as realty subdivisions that consist of single family homes, condominiums and cooperative apartments; but also applies to apartment and assisted living facilities and other redevelopment projects that do not require Department approval prior to construction. The Department frequently meets with project developers and consultants prior to the submission of residential development engineering plans for Department or building department review and approval. This was the case many years ago when a developer came to the Department for guidance because there was no other agency willing to provide assistance in the development of an assisted living facility that was adjacent to a hazardous waste site. The Department assisted that developer by recommending the evaluation of soil and potential soil vapor intrusion problems on the site and the installation of a sub-slab depressurization (SSD) system beneath the building footprint thereby eliminating an exposure pathway.Department meetings are particularly necessary when the proposed development site may be under investigation or subject to remedial action by the NYSDEC as a spill, hazardous waste or voluntary (Brownfield) clean up site. Department representatives will discuss site investigation requirements and the soil, groundwater and soil vapor standards that may apply. On-site inspections are frequently conducted with the project consultant to help identify potential areas of concern (AOCs). The Department reviews each application for approval of a realty subdivision or residential development to determine if the proposed water supply and sewage disposal arrangements are satisfactory and if the necessary development details depicting the arrangements for water supply, sewage disposal and storm drainage disposal are included on the realty subdivision Map (plan). This Map is submitted to the Department for review, approval and ultimate processing to other agencies including the local municipality and the Department of Public Works, the Planning Department, the Assessors Office and to the County Clerk for review and approval. The Department requests the submission of a Phase I Environmental Site Assessment (ESA) that is prepared in accordance with ASTM Standard Practice Site Assessments for review prior to the approval of all realty subdivision and other residential or property redevelopment projects. This must include information that describes the past use of the property and shows the location of all buildings, structures including underground tanks, drywells, leaching pool, cesspools and floor drains connected to those structures; and a listing of the capacity, contents and status of all above and below ground petroleum, chemical or other hazardous substance storage tanks or storage areas that have existed at the site along with evidence that those tanks were installed, registered or removed or abandoned in accordance with the USEPA, NYSDEC, Nassau County Fire Marshal, Department Article XI NCPHO Regulations. The Department also requests the completion of a survey and map of potential off-site sources of contamination that may impact the development. This includes a survey of gas stations, automotive repair facilities, dry cleaners, manufacturing facilities etc. and identification of all sites identified by the NYSDEC as Inactive Hazardous Waste, Voluntary, or Brownfield cleanup and spill sites and USEPA National Priorities List (NPL) sites. The Department reviews the information submitted regarding the environmental condition of the site and potential on-site and off-site sources of soil, groundwater and soil vapor contamination; reviews available records of the site facilities and compliance with federal, state and local regulations and evaluates the results of the requested Phase I Environmental Site Assessment (ESA) to assure that suspected areas of concern (AOC) have been identified. The Department will perform site inspections to evaluate conditions at the site and then, as may be necessary, requests the preparation of a work plan to investigate and remove potential soil, groundwater and soil vapor contamination sources and impacts. The Department conducts further site inspections as may be necessary during the implementation of the work plan and during any subsequent remedial actions that may be performed at the site.All on-site sources of contamination or hazardous materials must be closed or removed in accordance with applicable federal, state, and local requirements. This may include an investigation of soil vapor intrusion that is conducted in accordance with NYSDOH guidelines to determine if there is a potential for contamination of indoor air by volatile organic contaminants (VOCs) that may originate from on-site or off-site sources of contamination. The investigation of potential soil vapor intrusion will determine if there is a need to install a soil ventilation (sub-slab depressurization) system to protect indoor air quality. A Phase II and Phase III ESA may be required to investigate potential environmental contamination at the site and in proximity to the site and determine the impact of this contamination on the soil, groundwater and soil gas beneath the site. The results of the investigation of site conditions and testing of soil, groundwater and soil vapor conducted as part of the site evaluation and completion of remedial actions, as may be necessary, are evaluated for compliance with all applicable federal, state, and local requirements. This includes the USEPA Underground Injection Control (UIC) program requirements, New York State Department of Environmental Conservation (NYSDEC) (Part 375) Unrestricted Soil Cleanup Objectives (USCOs), Groundwater Standards and SPDES permitting requirements, as well as the New York State Department of Health “Guidance for Evaluating Soil Vapor Intrusion in the State of New York” and all Nassau County Department of Health Ordinances and Regulations. Proposals for new developments in the Special Groundwater Protection Areas (SGPAs) of the county, which are relatively undeveloped and not served by public sewers, are also reviewed to prevent groundwater contamination by industrial waste water (heavy metal or organic chemical contamination) and excessive quantities of sanitary sewage (nitrate contamination). This is accomplished by the enforcement of Article X NCPHO, which limits the number of dwelling units to one per 40,000 square feet for residential developments and an average sewage discharge rate of 0.00375 gallons per square foot of net area for non-residential developments, and prohibits all discharges of treated or untreated industrial wastewater. These measures are implemented in coordination with local planning and building department entities to protect the prime Nassau County groundwater recharge areas of the USEPA Designated Long Island Sole Source Aquifer. The Department also takes actions to protect the residential environment from contamination by asbestos, lead and rodent infestations when existing buildings are being demolished on proposed re-development sites. A New York State Department of Labor (NYSDOL) licensed inspector must survey all buildings or structures for the presence of asbestos containing building materials (ACBM) prior to the demolitions. Identified ACBMs must be handled in accordance with NYSDOL and USEPA regulations. The Department also requests that developers obtain a certification of rodent free inspection from the Department (Office of Community Sanitation) and submit the certification to the local building department in order to obtain a demolition permitAny criteria for who was selected to receive the practice if applicable? Under a Memorandum of Understanding with the State Department of Environmental Conservation (NYSDEC), the New York State Department of Health (NYSDOH) has statewide responsibility for approval of all realty subdivisions, including the review and approval of plans for individual sewage treatment systems. As the Designated Representative of the NYSDOH, the Nassau County Department of Health reviews and approves all plans for realty subdivisions in Nassau County. The New York State Realty Subdivision Laws are established under the Public Health Law Article 11–Title II Realty Subdivision Water and Sewerage Service and the Environmental Conservation Law Article 17-Title 15. These regulations include the requirements for the preparation of maps and requirements for water supply and sewage disposal as well as for the consideration of environmental pollutants or hazards on the property from surrounding areas and the potential effect of the subdivision on environmental factors in surrounding areas. All developers and consultants who complete State Environmental Quality Review Act (SEQRA) applications that are processed for review and comment by the Department or who submit plans to the Department for the approval of residential developments or realty subdivisions in Nassau County receive the practice. The practice has been included as a policy for the review and approval of those applications and is included as Supplement: No. 1 entitled “Nassau County Department of Health Residential Development Environmental Site Assessment Policies”. What was the time frame for the practice? The time frame for the completion of the practice for the evaluation and approval of each proposed development may vary from a few months to a few years depending on the extent of the environmental challenges. The timeframe for the Departments’ evaluation of the practice itself is ongoing and will enable the practice to evolve and improve as additional experience is gained in the implementation of residential property investigations and remedial actions. Were other stakeholders involved? What was their role in the planning and implementation process?Many other stakeholders are involved in the Environmental Health Residential Development Protection Program planning and implementation process including the Nassau County Department of Public Works, the Department of Planning, the Nassau County Fire Marshal, and Nassau County public water supply officials and consultants, and other regulatory agencies including the USEPA and the NYSDEC. The Department coordinates with the Nassau County Department of Public Works and the Department of Planning in the review and processing of realty subdivision applications. The Planning Department reviews realty subdivision applications in the unincorporated areas of the County. The Department of Public Works reviews the design and arrangements for public sanitary sewer and storm drainage facility construction. The Department cooperates with the Department of Public Works in the support of initiatives to extend public sewer service outside the boundaries of sewer collection districts as may be feasible. The Department coordinates with public water supply officials and consultants who prepare and submit engineering plans for the installation of new or modified water mains and backflow prevention devices that may be installed to serve the proposed residential development. The installation of dead-end water mains and private wells in areas served by a public water supplier are prohibited under Article IV NCPHO. The Department also coordinates with the USEPA, NYSDEC and the Nassau County Fire Marshal to assure that underground storage tanks (USTs) containing petroleum or other hazardous substances have been registered, and removed. What does the LHD do to foster collaboration with community stakeholders? The Department arranges to meet with community stakeholders, municipal officials, regulatory agency representatives and developers and their consultants to discuss planned realty subdivision developments whenever requested or necessary in order to explain the Environmental Health Residential Development Protection Program Policies and to improve program collaboration, coordination and program effectiveness. Any start-up or in-kind costs and funding services associated with this practice? Please provide actual data, if possible. Else provide an estimate start-up costs/budget breakdown. The program has evolved over a number of years utilizing existing staff at no additional cost to the Department or the County. The program is staffed and supervised by senior public health engineers who are New York State Licensed Professional Engineers. The staff has many years of experience in a variety of environmental engineering programs that include: Air Pollution Control, Groundwater and Soil Remediation, Public Water Supply Regulation, Evaluation of Soil Vapor Intrusion, Sewage Collection and Disposal, Realty Subdivision, and Toxic and Hazardous Material Storage engineering plan review. The staff is capable of readily adjusting to changing environmental engineering and Environmental Health Residential Development Protection Program work loads. Realty subdivision plan review fees are collected in this program on the basis of the number of lots or units in the residential development and whether or not there is a need for Department review of engineering plans for on-site sanitary sewage disposal facilities if public sewers are not available. The fee does not vary based on the nature or extent of environmental contamination or remedial actions that may be required to assure the safe development of a property. The uniform application of fees in this regard and the absence of Department penalties associated with the discovery or correction of environmental contamination problems also promotes an open dialogue with the developer and his consultants. This approach however does not preclude potential fines or penalties by the NYSDEC or USEPA where severe contamination problems are discovered and formal enforcement actions by those agencies may become necessary.
What did you find out? To What extent were your objectives achieved? Please restate your objectives from the methodology section. “The objective of the practice is to notify developers and consultants of the Department’s Residential Development Environmental Site Assessment Policies and work cooperatively with them to assure that the program policies and requirements are considered, implemented and satisfied as part of the realty subdivision review, inspection and approval process.”During the 10 year period of 2003 through 2012, the Department issued an estimated fourteen hundred and forty (1440) environmental site assessment comments for land development projects. During the same 10 year period, the Department reviewed engineering plans for the development of one hundred and seventeen (117) parcels of land containing four-thousand nine hundred and eighteen (4,918) residential units. The Department reviewed the water supply, sewage disposal and environmental conditions of each of these properties and identified and requested corrective actions to address environmental contamination problems as may have been necessary prior to the issuance of a project approval. The Department’s objectives were achieved for every realty subdivision application submitted to the Department for review and approval. The value of the Environmental Health Residential Development Protection Program practice can be illustrated by comparing the value of an undeveloped parcel of land with multiple areas of soil, groundwater and soil vapor contamination to the value of a developed parcel of land that has been constructed in a manner that has eliminated sources and evidence of contamination and provides a safe and healthful environment for residential, commercial or industrial purposes. Parcels of land that are contaminated may remain unusable for generations if they are not properly investigated and remediated to assure compliance with environmental standards for residential use. Did you evaluate your practice? List any primary data sources, who collected the data, and how. The Department maintains records of all realty subdivision applications and environmental assessment projects completed by the Department’s public health engineering staff. Records are maintained in computer log books that summarize information for all projects and in individual files that contain records for each project. The records indicate that project developers cooperated in the completion of environmental assessments and ultimate submission of realty subdivision maps that were found to be eligible for Department of Health approval. The Department records also include information concerning the referral of some contamination problems to the NYSDEC for investigation and enforcement action because of the nature and potential extent of the site contamination (e.g. the discovery of a shooting range on a former estate where evidence of widespread bullet and shot gun casings was found that required investigation under the NYSDEC RCRA requirements). Records are also maintained of development projects that may involve the adoption of covenants and restrictions that require the completion the design, installation and operation of sub-slab depressurization systems to protect indoor air from potential soil vapor intrusion. List any secondary data sources. Not applicable. List performance measures used. Include process and outcome measures as appropriateThe following performance measures were used in the evaluation of the Environmental Health Residential Development Protection Program: Preparation and periodic updating of the Department of Health “Residential Development Environmental Site Assessment Policies” statement Distribution of the “Residential Development Environmental Site Assessment Policies” statement to the developer, consultant, planning department, and the SEQRA Lead Agency with a request for a response within 60 days for every residential development project presented to the Department for review, comment or approval. Review of the response to the Department’s “Residential Development Environmental Site Assessment Policies” notification letter including the Phase I ESA and determination of the acceptability of the water supply and sewage disposal arrangements and determination of the environmental investigation needs. This evaluation includes the Department inspection of site structures and potential contamination sources to confirm project design and site investigation needs. Review and approval of a Work Plan for the investigation and remediation of environmental areas of concern (AOCs), completion of site inspections as applicable during Phase II ESA and Phase III ESA investigations and remedial actions. Review of the reports of soil, groundwater and soil vapor investigations and remedial actions as may have been required to confirm that each proposed subdivision site is suitable for residential development prior to the Department approval of a subdivision map. Describe how results were analyzed The results of the Environmental Health Residential Development Protection Program are under constant scrutiny and analysis to assure that the Department is using the most effective tools in promoting the investigation and remediation of each parcel of land that is proposed for residential development. These evaluations are conducted for each proposed development in consultation with the developers and consultants and with the NYSDEC, USEPA and local Department of Public Works and Planning Department officials. They may also include project and Department attorneys to resolve legal issues and solutions. The satisfactory results of the program are evident by the voluntary participation of developers and their consultants in the environmental investigation and remedial aspects of the program, as well as the mandatory water supply, sewage disposal and groundwater protection program aspects. The Department also keeps the NYSDEC and USEPA aware of the program site investigation findings and planned and completed corrective actions so that they can determine when direct state or federal involvement, investigations or enforcement actions may be required. Were any modifications made to the practice after the results were analyzed? Modifications are made to the practice periodically to revise the program guidelines that are sent to developers and consultants that form the basis for the investigation of environmental conditions at each site that is proposed for residential development.
Lessons learned in relation to practiceThe Department has learned that the implementation of the Environmental Health Residential Development Protection Program practice is an extremely valuable method of assuring that all sites proposed for residential development in the County are properly investigated and remediated. The Department’s timely and consistent implementation of the practice enables developers and consultants to properly plan their current and future development projects so that all information and environmental investigation and remediation needs are satisfied prior to the project approval. Lessons learned in relation to partner collaboration (if applicable) The Department has also learned how to more effectively collaborate with partners and stakeholders so that every agency is aware of the status of investigation of each proposed development site. This is especially valuable when circumstance arise where extensive contamination problems are involved and State or Federal enforcement actions may become necessary. Is this practice better than what was done before? The practice is better than what was done before because it effectively crystallizes the identification of actions that developers must take to assess the environmental condition of a site and investigate potential and actual sources of contamination on the residential property that is proposed for development. Prior to the implementation of this practice, the developers and their consultants were considered to be totally responsible to check with numerous agencies that regulate a variety of potential contamination sources to determine if those individual agencies requirements were satisfied. This practice is better because the Department directly assists in helping to identify environmental concerns and directly refers the investigation results to those other agencies that may require further investigations or necessary remedial action under their jurisdiction. Did you do a cost benefit analysis? If so, describe. There was no cost benefit analysis performed because it would be difficult to place a monetary cost on the value of this practice which helps protect the health and safety of our county residents.The implementation of the program is supported by realty subdivision plan review fees as well as partial program cost reimbursement by the NYSDOH. The program staff is highly experienced and provides engineering support in a variety of environmental and public health engineering programs and therefore the practice work load can be more effectively managed to minimize program costs. Sustainability-Is there sufficient stakeholder interest to sustain the practice? Yes this program is of great value and interest to all stakeholders who rely on the program to help identify and correct environmental problems in planned residential developments that may impact the public health and safety of county residents.
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