October 18, 2004

William S. Moncrief, Real Estate Specialist
Northeast FSO, United States Postal Service
6 Griffin Road, Windsor CT 06006-0300
Dear Mr. Moncrief,

I was unable to attend the meeting on the proposed new Aurora USPS facility which you held in our village on Tuesday, October 12 Unfortunately, scheduling the meeting at the end of the fall break in local schools and colleges meant a number of other residents were also unable to attend.

However, I was assured by friends in attendance that you promised to answer any letters you received, although you apparently provided no contact information to the general public. I hope you will provide answers to the questions below and help clear up some confusion in the village.

1.) At what step is the Aurora Post Office project right now, in reference to the process laid out in the brochure send to us by Paul Senk last June? (See: “In Partnership... A 6-step primer on community involvement concerning expansion or relocation of your post office.”) Residents who attended the meeting said they did not think that you had initiated a public comment period, and some received the impression that there would not be one.

2.) Will the Aurora P.O. approval process follow the steps in the brochure? Or, because it does not involve the expenditure of USPS funds, will the public review process be circumvented?

3.) Does the USPS plan to accept this new facility as a “gift” from the Aurora Foundation LLC, a for-profit real estate development corporation, without input from the many of residents who oppose the move?

4.) This project requires federal permits within a National Historic Register District. As such, it should trigger a Section 106 Review by our State Historic Preservation Office. When will this review be initiated?

5.) The only documentation our Village Clerk could provide from your visit were two single sheets. One showed partial plans for rebuilding the interior of the recently gutted Old School building, and lacked crucial site information on the proposed parking and driveway. The other was a list of benefits to be bestowed upon the village by this new postal facility. Was this list submitted by the corporate developer, or the USPS? She was uncertain.

6.) Are you aware that many residents understand that the pursuit of this project would result in the foreclosure envisioned in Section 110(k) of the National Historic Preservation Act of 1966?

a) The original 2001-2003 Aurora Inn / Market project included an expansion of the adjacent parking lot. That portion of the plan was withdrawn by the developer when it became clear that the necessary renegotiation of the USPS lease on parking spaces would trigger a Section 106 Review of the project. Having successfully shielded its controversial project from SHPO review, the developer is now reintroducing the “trigger” portion of the plan. This follows the demolition of the Vanderipe Market, and the total gutting, full interior reconfiguration, and radical exterior alteration of the 1833 Aurora Inn -- the destruction of the authentic heart of our National Historic Register District -- against the advice of the SHPO and the NYS Department of Environmental Conservation, and in opposition to the efforts of the Preservation League of New York State and the National Trust for Historic Preservation.

b) Anticipatory demolition, another type of foreclosure under 110(k), took place with the total gutting of the Old School (a.k.a.Heary Building) before the required Section 106 Review of this portion of the developer’s current project. Please note that while this building housed the Aurora Post Office for about twenty of its 209 years of service to our community, it was constructed originally in 1901-02 as a public school house. In recent years it has been used for commercial space, but prior to its complete gutting this year by the developer, the building retained many original details evocative of its historic prior use -- wooden wainscoting, floors, wide student stairway, banisters, newel posts, cupboards, built in book shelves, large transoms, classroom doors. These significant architectural elements, and their eloquent contribution to the history of our tiny village, are now lost forever.

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29 October 2004

William S. Moncrief, Real Estate Specialist
USPS Northeast Facilities Service Office
6 Griffin Road North, Windsor, CT 06006-0300

Dear Mr. Moncrief:

I am writing as long-time resident, property owner, and taxpayer in the Village of Aurora, regarding the proposed relocation of the village post office. I am opposed to the relocation of our postal facility from its current site to our former school building, and I ask that you consider my reasons very seriously.

The proposal of the Aurora Foundation L.L.C may appear attractive to the USPS, but it is not advantageous to the taxpayers and residents of the Village of Aurora who are your patrons.

Should this plan move forward, we will lose to demolition our only functional publicly owned building. We also will lose the buiding’s rental income, which is not inconsiderable in relation to our total village budget. Our taxes will have to increase to make up for the lost rent, which instead will go to the so-called “foundation,” which is registered with the state not as a non-profit organization, but as a profit-making corporation.

If the proposal is adopted, all of our residents will lose safe, direct, easy access to the postal facility at ground level with off-street handicapped parking. This loss of accessibility will be felt severely by those in the community with limited mobility. Clearly, such a loss is undesirable and unacceptable.

The “old” firehouse has served the community well as our postal facility since 1979. To my knowledge, no resident had complained that these premises were inadequate. Nor, prior to the initiation of this project, had the USPS indicated to the village, which owns the building, that it was unhappy with the arrangement. The proposal to move to another site was initiated by a third party, a Limited Liability Corporation, which by its very definition does not necessarily have the best interests of either the village or the USPS at heart.

I fear that the uncritical enthusiasm of the USPS for this project is being used to pressure our village to comply with the demands of the developer. The supposed “need” to destroy the municipal building now housing our post office in order to to create additional parking is a situation created entirely by the L.L.C. The problem should be addressed by the L.L.C. with its own resources and property, without forcing further loss upon our village’s economic, social, and historic fabric.

By the action of the L.L.C, we just lost all of the many original interior appointments of our 1901 School House, the proposed location of your new postal facility. The developer totally gutted this historic structure prior to your belated initiation of a SHPO review. For the developer to claim that this project promotes historic preservation is ludicrous; for the USPS to support this claim is a grave disservice to the public.

Please cut our losses now by listening to resident concerns and dropping this project.

Sincerely,
Crawford R. Thoburn

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November 11, 2004

Dear Mr. Moncrief:

I am writing with regard to the proposed relocation of the Aurora, NY Post Office. I believe that there must be a compelling reason for such a move, such as more efficient handling of mail, a substantial reduction in cost, an increase in customer convenience, etc. In the present instance there is only an almost trivial decrease in cost and at least one compelling reason against the move.

The present PO has a ground-level entrance while Heary building's entrance is elevated by about three feet from the ground. I shall discuss the implications of this, with myself as an example, but I'm sure there are others with the same predicaments.

There are a substantial number of elderly in the village; and, given national demographic projections, there will be more in the future.

I am a 75-year-old male who had a stroke about five years ago. I have recovered quite well, but my right leg (and arm, for that matter) is weaker than the left to a degree that going down steps is awkward and downright precarious. I can handle two or three steps down, such as those at thw Aurora Bank, but the Heary building would be a potentially impossible challenge.

The post office buildings in Scipio Center and Union Spring apparently were built to PO specifications and have ground-level entrances such as the current building in Aurora. The area post offices with elevated entrance (Poplar Ridge, Moravia, and Cayuga) appear to be older, but they all have ramps to the entrance used by the general public. They seem to be in accord with the Americans With Disabilities Act.

I suggest that the plans for an accessible rear entrance for the Heary building in Aurora would not meet ADA regulations. The ADA states: "The accessible route shall, to the maximum extent feasible, coincide with the route for the general public" (4.3.2). A rear entrance is hardly the maximum extent feasible. Anticipating an argument that exception is made for historical structures, I submit even then it does not meet ADA standards. A simple ramp going to the front entrance will not destroy any historical significance that the building may have, and this will coincide with the ADA criterion.

To summarize, I urge that the present PO be retained. If the relocation to the Heary building is recommended, the rear entrance for the handicappedshould be eliminated as discriminatory and a ramp to the general public entrance should be substituted.

Thank you for your time.

Shelby J. Harris, Ph.D.
Emeritus Professor of Psychology
cc: Aurora Village Trustees

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November 22, 2004

To: William S. Moncrief, Real Estate Specialist
USPS Northeast Facilities Service Office
6 Griffin Road N Windsor CT 06006-0030

Re: Aurora Foundation, Limited Liability Corporation, and Wells College application to demolish the existing Aurora post office building, use the village property on which the present post office is sited for a parking lot expansion, and move the post office into the 1901 School House building now owned by Wells College

Our immediate family has lived, paid taxes, and gone to the several post offices in the village of Aurora since 1930. Our ancestral family arrived here with the early Old Stock settlers. We have serious reservations and many concerns about the Aurora LLC’s application.

Activity in a National Historic Register District

1. What federal and state oversight should be given to this project proposed by the Aurora LLC? This corporation proposed expansion of the same parking lot for its Aurora Inn and Market project several years ago, then withdrew the parking lot part of the project when it became apparent that federal oversight might impact a project in the National Historic Register District of Aurora.

This withdrawal reflects a pattern of behavior on the part of the Aurora LLC and Wells College in their development in the village: devise projects in such a way so as to make them come in just under the threshold of federal or state or village oversight, or, simply execute projects without regard for government regulation.

Having circumvented federal and state oversight that might have limited the Aurora LLC’s earlier plans for a parking lot expansion, the LLC now has devised a plan to get the USPS to require essentially the same parking lot expansion as a necessity for the proposed new location of the post office: through this developer’s clever machinations, the federal government as protector could become the federal government as destroyer.

2. What federal and state oversight should be guiding the “renovation” of the 1901 School House building? Already the Aurora LLC has gutted the building, and this action means the loss of historic and characteristic interior architectural details.

3. Claims that the relocated post office would be returning to its “historic” location are silly. Most of its life, the post office in Aurora has not been located in the 1901 School Building.

Disregard of needs of elderly and handicapped

The Aurora LLC’s plan for their relocated post office provides this unsafe and thoughtless situation for the elderly and handicapped patrons of the post office. The handicapped/elderly would have to park in front of the building on NY State Rt. 90, a narrow and busy truck route, and exit their vehicles into traffic. If the handicapped/elderly survive getting out of their cars and to the main sidewalk, then they must make their way to the back of the north side of the building, enter the building via the handicapped entrance, make their way to the front of the building for mail and service, make their way to the back of the building to exit, make their way to the front of the building, and navigate the traffic on Rt. 90 to get into their vehicles. Is this really the best the USPS can do for its handicapped/elderly patrons?

The present post office building provides nearby parking, building access, and service all on one level.

A Complex of Related Problems for Villagers

If the Aurora LLC moves the post office, tears down the village building presently housing the post office, and co-opts the village property for a parking lot expansion, this Corporation also creates a complex of other problems and concerns for the villagers. And the USPS contributes to these problems if it chooses to ignore the many aspects of this package deal offered by the Aurora LLC. Here are a few problems:

1. The village loses the rental income from the USPS, a sizable contribution to this small municipality’s budget.

2. The village loses a village building that could house village offices or small local businesses, at a time when more space is seriously needed.

3. The village effectively loses the only Main-Street property it owns in the center of the village. The village loses the opportunity to establish a presence and identity in the center of the municipality. Is the central identity of the Village of Aurora to be a parking lot? Are we sure we want to change the name of our village to “Asphalt”?

4. Should the largest structure in the center of the village be a parking lot? –a parking lot on the lakeside of the road no less! Surely, a big parking lot is questionable, if not foolish and immoral, use of land in the heart of the village and next to the lake.

5. Why should the village surrender land for a parking lot when Wells College and the Aurora LLC own a great deal of land (60% of the village), much of it suitable for parking? Available sites for parking in the village center include land north and east of the Fargo and land south of Lafayette Street. Thoughtful landscaping of these sites for parking would preserve the aesthetics of green space. Relocation of parking to the east side of NYS Rt 90 would free the properties in question on the west side for development as village offices and perhaps a streetside green space/park connected to the isolated village park at the lakeside.

6. The Aurora LLC and Wells College’s failure to develop off-street parking elsewhere in the village has created real hardship and driving hazards for the village’s residents, tourists, non-resident workers, and construction companies workers and their equipment. The Corporation and College have chosen to ignore village zoning which requires employers to provide off-street parking for their employees.

The proposed parking lot expansion would provide a piddling increase that does not address the needs of villagers, nor those of visitors and employees of the Inn, Market, flower shop, Fargo, PizzAurora, 1901 School House building, bank, and present post office.

7. What is the impact of parking lots, existing and proposed, on the water quality of Cayuga Lake? Parking lots produce concentrated toxins in runoff water. Installation and maintenance of filtration systems deal with this problem. Sadly, Wells College, the builder and user of many parking lots, appears to have restricted its work with the Cayuga Lake Watershed Network to providing box lunches.

8. Can/Should the village government decide land use of village property, which is held in trust for all the people of the village, without a referendum of all the people of the village?

As important as it is to think very carefully about the proposed relocation of the post office, it is equally important to think about the complex and many impacts such a relocation would have on the community’s land use, infrastructure, character, and citizenry. Until all those issues are considered carefully and fully by the public, village boards, and other government agencies (including the USPS), the post office relocation project should be put on hold.

Disappointments with the October 12, 2004 meeting in Aurora with USPS representative Moncrief

• 1. At the Oct 12, 2004 meeting, Mr. Moncrief failed to state that this meeting was the public comment meeting for the Aurora LLC’s proposal for a new postal facility. Some people thought it was an informational meeting preceding a public comment meeting.
  
  
• 2. If the Oct 12 meeting was the public comment meeting, no thought went into scheduling the meeting as part of a common-sense sequence of events. At the Oct 12 meeting, the public saw for the first time the proposal by the Aurora LLC. Prior to the Oct 12 meeting, there had been no time for the public to see, much less to study, the Aurora LLC’s proposal, no time to reflect on the proposal, no time to formulate concerns and questions—no time or way for the public to come thoughtfully prepared for what apparently was a public comment meeting.
  
  
• 3. Before the meeting started, Mr. Moncrief and mayor Tom Gunderson were discussing the new postal facility proposal. Montcrief said to Gunderson, “Once you get that done, you can just go ahead with the project.” Mr. Moncrief’s declaration was disheartening because it seemed to indicate the USPS representative viewed the proposal as a done deal. The public would prefer officially open minds.
  
  
• 4. Mr. Moncrief did not come to the meeting prepared to give his business card or other how-to-contact-the-USPS information to people who attended the meeting. He stated that he had only a few business cards and indeed he had only a few, too few. Why does a USPS representative come unprepared to facilitate ongoing communication between the public and the USPS?
  

Thank you for a thoughtful reading of our concerns and questions. We look forward to your letter of reply.

Sincerely,
Elizabeth A. Knight
Alan Ominsky

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November 24, 2004

William S. Moncrief, USPS FSO
6 Griffin Road North, Windsor CT 06006-0300

Dear Mr. Moncrief,

Thank you very much for your response, which was delivered and dated via email on 10/25, although the letter itself is dated as originating on 10/19.

Thank you, also, for initiating the long awaited Section 106 Review of the proposed Aurora Post Office relocation the day after you received my 10/18 email asking for such a review.

While I am glad to read that you “support and act within the process of the Historic Preservation Act,” I am concerned by your admission that you do not know what is meant by foreclosure under Section 110(k) of the HPA. It is complicated, particularly since we have two levels of foreclosure here, so I will explain again.

THE HISTORIC PRESERVATION ACT OF 1966

Section 110 (k) reads, with insertions relating to Aurora: “Each Federal agency shall ensure that the agency will not grant a loan, loan guarantee, permit, license, or other assistance [a rental agreement with the USPS] to an applicant [the Aurora Foundation LLC] who, with intent to avoid the requirements of section 106 of this Act, has intentionally significantly adversely affected [gutted] a historic property [the Old School, a.k.a. Heary Building] to which the grant would relate.”

That’s the easy one. The developer foreclosed preservation options by destroying historic resources before the project could be reviewed under Section 106.

Things get more complex in relation to the developers’ larger ongoing project. For that, let’s go to the Advisory Council for Historic Preservation for clarification of 110(k): “Congress also added a new provision that directs Federal agencies to withhold grants, licenses, approvals, or other assistance to applicants who intentionally significantly and adversely affect historic properties. This provision, known as the ‘anticipatory demolition’ section, is designed to prevent applicants from destroying historic properties prior to seeking Federal assistance in an effort to avoid the Section 106 process.” (See seewww.achp.gov/book/sectionII.html#IIC2)

The developers' plan to expand their privately owned parking lot to serve their customers is not new. It was originally part of their proposal to gut-rehab the 1833 Aurora Inn and demolish the 1922 Vanderipe Market, both contributing members of our National Register Historic District. However, the parking lot portion of the project was withdrawn when the developers learned that a federal license (renegotiation of a USPS lease on the lot) would bring a Section106 Review of the Inn/Market project. Rather than submit their planned gut-rehab and demolition of historic properties to a SHPO Review, the developer withdrew the parking lot from the project. The LLC partners and Village were warned by the DEC of the consequence of this apparent attempt to avoid a 106 Review. The advice was ignored. The “adverse impact” went forward, and the remarkable centerpiece of our district was irreparably harmed, its historic value and authenticity lost forever.

Recently, the developers again asked for the expanded parking it wanted earlier, requesting roughly the same dozen space increase previously proposed and withdrawn. In order to get it now they need to destroy our Post Office, since their replacement Market building grew so large that the developers subsequently decided to give it more space by encroaching on their parking lot. The current proposal to move our USPS facility cannot be divorced from this context: that is the consequence of the developers’ prior avoidance of a Section 106 Review.

The HPA clearly prohibits the cooperation of the USPS with this project. Under Section 110(k)the USPS cannot grant a discretionary permit enabling the developers to enhance their commercial project with the deferred expansion of their parking lot, as it would inappropriately assist developers who engaged in “anticipatory demolition” on a grand scale.

You assert in the letter to Ms. Pierpont initiating a SHPO 106 Review that you do not know if the applicant “has previously operated at odds with several aspects of the Historic Preservation Act.” I would suggest that in this situation it is your responsibility to know just that.

OTHER MISUNDERSTANDINGS

Having addressed this one misunderstanding at length, I would like to note briefly several other anomalies in your letter. Contrary to your misrepresentation of ADA compliance issues to Ms. Pierpont of our SHPO, we now have an accessible Post Office, while the replacement design places unacceptable burdens on patrons with limited mobility. You allege that our current P.O. is unsafe without documenting when and by whom this determination was made, explaining why this public hazard was not revealed by the USPS until now, or considering alternative solutions. You make assertions about the historic locations of our postal facilities based on anecdotal evidence rather than research, and you persist in calling our elected officials Selectmen and our Village a Town. You also neglect to consider the comment letters received by the USPS last summer in your one-sided summary of public opinion on this project for your Section 106 initiation letter. You tell me that you will not advertise for alternative locations, but fail to explain your contradiction of Mr. Senk’s letter of June which stated that “since the proposed alternate space [is] privately owned, competitive offers would have to be publicly solicited, even if the location under discussion was supported by the Village.”

THE ROLE OF THE USPS

In conclusion, I must reflect upon the nature of your response. It has been my experience that a federal official overseeing a public comment period simply receives comment for agency review and answers questions about procedure. While I appreciate your attempts to asnwer questions, it seems inappropriate for a civil servant soliciting public comment to argue with constituents about the comments they offer. You take this contention to such an extraordinary degree that your response was fully three times longer than my original letter, and you dispute even the most mundane matters. (E.g., your friend’s daughter may have been residing at Wells on October 12 because some dorms remain open over the fall break, but I assure you, the college was not in session.)

Having read some of your other responses, it becomes clear to me that you are intent on dismissing the comments of nearly any resident who expresses concern about this project. You falsely justify this dismissal by equating opposition to the P.O. move with opposition to the Aurora Foundation LLC, which you feel somehow renders our valid concerns unworthy of consideration.

Your strenuous advocacy of the project in your replies was preceded by your avid support for it in the initial public meeting. While I can understand your interest in the prospect of a new facility offered at no expense to the USPS (but considerable cost to my village), you nevertheless arrived in Aurora with such a deep and firmly set bias in favor of this project that it seems to prejudice your perception of all the public comment you receive.

In fairness, I hope that if the USPS moves forward with this misguided project, you will remove yourself from the process and have someone without your strongly held preconceived opinions supervise the subsequent 30 day comment and appeal period.

Thank you for your consideration of my comments herein, and your previous reply to the questions of the Aurora Coalition, Inc.

Sincerely,
Karen A. Hindenlang
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