Comments Needed on Camp FIMFO Permit Application

• The proposed Camp FIMFO project is still being reviewed under the New York State Environmental Quality Review Act by the Lead Agency, the Town of Highland Planning Board.
• The Town of Highland Planning Board has yet to issue a Final Environmental Impact Statement (“Final EIS”) for the project, which is necessary for the project to receive approval, and could potentially request changes to the number of campsites and therefore the water utility plan.
• The National Park Service determined that the project does not substantially conform with the Upper Delaware Scenic and Recreational River Management Plan, in part because of the newly proposed sewer connections for the campsites.
• The Town of Highland Planning Board is working with the Town Engineer and contracted  subject area experts to review the proposed project, including the proposed water utility plan. Those reviews are not yet complete.
• Without a Final EIS, the Town of Highland Planning Board, nor the other involved agencies including the New York State Department of Health, New York State Department of Transportation, New York State Office of Parks, Recreation, and Historical Resources, and Sullivan County Department of Planning & Development, AND THE NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION, are unable to issue findings statements on the adverse environmental impacts of the project, which are required for the project to receive approval.

For all of the reasons above, the proposed Camp FIMFO project is still subject to substantial modifications, and therefore NYSDEC does not have all of the required information to make an informed decision on the SPDES permit application. As a result, NYSDEC must deny the current permit application.

Further, NYSDEC has not made the application materials readily available to the public in its Notice of Complete Application. Even if individuals were to submit a FOIL request for the materials on the day of the Notice’s publication, May 6, 2026, the 30-day window that NYSDEC has to respond may fall outside of the public comment due date (30-day FOIL response deadline: June 6, 2026, public comment due date: June 5, 2026). For this reason, I also request that the comment period be extended to 60 days in length, thus ending on July 6, 2026, so that the public has adequate time to receive the application materials, review them, and submit informed comments on the SPDES permit application. The comment period should allow comments until July 6, 2026 at the earliest.