New York State Department of Environmental Conservation

625 Broadway Albany, New York 12233

RE: Support for Village of Woodbury as SEQRA Lead Agency

Dear DEC Officials,

The Town and village of Woodbury were served by the Town of Palm Tree a petition to annex 497.83 Acres of land.  We, the undersign concerned citizens and neighbors of the Town and Village of Woodbury write to formally request the Village of Woodbury as Lead Agency under the State Environmental Quality Review Act. It has come to our attention that while the Village of Woodbury has rightfully requested Lead Agency status under the State Environmental Quality Review Act (SEQRA), both Kiryas Joel and the Town of Palm Tree are contesting that designation. This effort to control the environmental review process is deeply troubling and undermines the integrity and purpose of SEQRA.

The Village of Woodbury is the most appropriate entity to serve as Lead Agency for the following reasons:

1. Geographic Impact: The annexation affects land currently within Woodbury’s jurisdiction. Woodbury's residents, infrastructure, environmental systems, and emergency services will bear the brunt of any adverse consequences.

2. Impartial Oversight: The Village of Woodbury has no vested interest in maximizing development over this land and is therefore best positioned to conduct a neutral and comprehensive environmental review. In contrast, both Kiryas Joel and Town of Palm Tree have demonstrated a history of promoting rapid, high-density development, and would not serve as unbiased stewards of the SEQRA process.

3. Capacity and Experience: Woodbury has the institutional infrastructure and historical involvement with the region’s land use and to handle the complex analysis and community concerns this project entails.

As DEC knows, SEQRA regulations (6NYCRR Part 617.6) Assign Lead Agency status based on which agency has the broadest governmental powers for investigation and approval of the action and its most directly impacted. In this case, this is unequivocally the village of Woodbury. The DEC must not allow an interesting party with a clear agenda for development to take control of the review process, thereby undermining both the law and the public trust.

The proposed annexation will lead to significant deforestation and overdevelopment In an area not designed to support dense housing. The environmental consequences, loss of tree canopy, disruptive water tables, and wildlife displacement, are not just local concerns but regional ones. Moreover, the Orange County Sewer District #1 is already overburdened. Even with a proposed 50% expansion, there is no credible evidence that it can support the additional demand from a development of this size.

Historically, development associated with the Town of Palm Tree has led to highly concentrated, single Community Housing models that sidesteps inclusive planning and create demographic enclaves. Such patterns have raised legal red flags under federal fair housing law. In United States V. City of Black Jack (1974), and later in Willowbrook V. Olech (2000), courts Have ruled against zoning and planning practices that foster segregation or lack of rational bias. The DEC Must recognize that facilitating development with exclusionary effects, whether intentional or not, opens the door to legal and ethical challenges.

The Department of Conservation's (DEC) role is critical in ensuring that this annexation receives the full, impartial scrutiny it deserves.  That begins with honoring the Village of Woodbury’s rightful request to act as Lead Agency under SEQRA.  To allowed an interested party like the Town of Palm Tree and Kiryas Joel To assume control over the environmental review process would be a dangerous conflict of interest and a violation of public trust.  For the protection of our natural resources, municipal integrity, and community equality. I urge you to ensure that the Village of Woodbury retains Lead Agency status.

Thank you for your attention to this urgent matter.