We've just received a copy of a draft scoping document, required under NYS SEQR rules, that has been prepared for the Planning Board of the Town of Ramapo. What we see in front of us is a seriously deficient document that fails to address a number of key issues. It is now incumbent on the Board to reject this scope as inadequate.
The major deficiency, and we're still examining the document along with Brian Ketcham our consultant, is its failure to consider the economic impact of the giant retailer on the areas existing neighborhood stores. In the more rigorous NYC CEQR rules the examination of both "direct" and "indirect" displacement of business is required.
As far as Wal-Mart is concerned we have a well-documented record of the store's devastating impact on existing stores in a community. Given these well-recorded dangers it is imperative that the Ramapo Planners demand that the developer of this store include an analysis of the Walmonster's impact on business in its EIS.
In addition, it is also imperative that the EIS include a full Wal-Mart market study as part of its impact analysis, This study would enable the Town to better understand just where Wal-Mart's customers are going to come from. Once this is known, it is possible to more fully understand potential traffic patterns. Without this data all of the consultant's traffic figures are basically unrefutable since no one would be able to judge the accuracy of the estimates without a benchmark.
So, given these deficiencies we're calling on the Planning Board to send the Wal-Mart consultant back to the planning board. Otherwise the Alliance and its allies may have no choice but to legally challenge the certification of the Draft EIS. There's simply no way for a document that is deficient from the start to somehow address key issues that it never felt were necessary to address in the first place.