Greenwich Municipal Code was written to "conform" to the Connecticut Enviornmental Protection Act (CEPA) which, in turn, was written to "conform" to the Federal "Clean Water Act" (CWA).
The December 3, 2012 "Toxic Substances Control Act (TSCA) MISA Footprint Approval", accepted by The Town of Greenwich (TOG) on December 12, 2012 "does not release GPS (Greenwich Public Schools) from any applicable requirements of federal, state or local law."
A "site plan" is a federally defined document containing specific elements which must be certified to "A-2" survey standards.
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Following is item 19 from the TOG Site Plan Checklist:
- "All applications for final site plans shall be in the form of a survey prepared by a registered Connecticut land surveyor having metes and bounds, dimensions of all buildings, parking and drives, setbacks of all structures from property lines, setbacks between buildings, and certification that building dimensions shown thereon are the same as the approved architectural plans. Architectural and drainage plans are to be referenced by title, date(s) and sheet numbers."
I have seen no approved "Final Site Plan" for any aspect of the PCB remediation approved by the TSCA administrator.
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AECOM has proposed PCB field remediation stretching out over as many as 12 summers. MISA construction can neither precede PCB remediation nor commence concurrently. The minimum time frame for acquisition of all required Federal, State, and Local permits is 5 years.
No matter how much time and money is wasted on MISA, it cannot be built until after the TSCA administrator signs off on the final PCB remediation.
