NYS Route 303 · Congers · Town of Clarkstown · SEQRA 24-084
561,520 sq ft of warehouse, 342 truck trips a day by the applicant's own count, and a corridor that is already failing
Take a second and imagine this.
You are sitting in traffic on Route 303, again. Except this time it isn't just the usual traffic. It's the trucks going in and out of another warehouse: close to 350 truck trips a day, by the applicant's own count.
You finally get home, but the noise doesn't stop, because those trucks keep rolling by all day.
Nearly 28 acres of woods are gone, replaced by concrete and loading docks.
More demand on our water, our power and our roads. And the tax revenue being offered in return is already the subject of an application for roughly $6 million in county tax benefits.
This isn't happening somewhere else. It's happening here, in our backyard. And once it's built, we don't get to decide we liked the way things were better. It will be too late…
The Cedar Corners warehouse project, now before the Clarkstown Planning Board, would merge sixteen tax lots into three much larger ones and build four warehouse buildings totaling 561,520 square feet, plus a drive-thru restaurant, on 41 acres of largely wooded land in Congers. It clears 27.6 acres of that woodland. It is not the only warehouse proposed for this stretch of Route 303: the environmental statement counts two of the others in its traffic forecast and leans on their signal work as its own mitigation, while assessing none of them cumulatively for air, water, waste or habitat. Every figure below is the applicant's own, from the DEIS, its appendices, the Supplemental DEIS or the Environmental Assessment Form, unless a note says otherwise.
Without anyone else on the road
The applicant's Traffic Impact Study, dated December 5, 2025, forecasts 194 vehicle trips in the weekday morning peak hour and 206 in the evening, every one of them through the single junction at Route 303 and Meola Road. Of the 194, the study counts 34 as trucks and 160 as passenger cars, and the simulation below is built to that mix. What you are watching is only the traffic this project adds. Existing Route 303 traffic is not in the picture at all, which is why this is the conservative version. This is that hour, at one simulated minute every four seconds.
Figures are the applicant's, from Table No. 1 of the Traffic Impact Study (DEIS Appendix M, December 5, 2025) and Table 4.3 of the Supplemental DEIS. The study does break trucks out: 34 of the 194 morning trips are trucks and 160 are passenger cars, so the mix you see is 34 box trucks to 160 cars, released in that proportion across the hour. Which way they go is the applicant's assumption too, not ours: Figures 12 and 13 of the study send 55 percent of arriving trucks in from the north, 35 percent down the US 9W north leg and 20 percent off the 9W east leg, with the remaining 45 percent coming up Route 303 from the south. Departures mirror it, 55 percent north and 45 percent south. If you expected most trucks to arrive from the south and the Thruway, that assumption is worth challenging in a comment, because the study assumes the opposite. The peak hour is also not the whole story: the applicant's Environmental Assessment Form puts the site at 342 truck trips a day, a figure that appears nowhere in the traffic study. That is note T-03. What the form never states is truck size or type, because it left that box blank. A red cab is leaving the site, a plain white cab is arriving. Vehicles brake to turn and accelerate away again, because nothing enters or leaves a driveway at highway speed, a heavy vehicle needs a long run to get back up to 55, and they hold back rather than drive through the vehicle in front. Nothing else is on this road. Every vehicle you see is one the project adds, running on an otherwise empty Route 303, so the queuing shown is only what the project does to itself. The real road is not empty: the applicant’s own week-long counter on this frontage recorded about 10,300 vehicles on an average weekday, close to 500 of them southbound in the busiest morning hour (automatic traffic recorder on Route 303 north of Hemlock Drive and south of Meola Road, week of May 6, 2024, Traffic Impact Study Appendix E). Put those back and what a turning truck costs goes up, not down. North of the site the road runs into the signalized Y where Route 303 ends at US 9W, and northbound traffic has to clear that light too. The frame is about 300 m of Route 303 with through traffic at 55 mph, so in real time a vehicle takes twelve seconds to cross and the road sits empty between arrivals. At one minute per four seconds the motion is capped so it stays watchable.
Now imagine adding that to the 9W and 303 junction a short way north, where Route 303 ends and where residents already describe a steady stream of trucks.
The site is pinned between the CSX River Line to the west and Route 303 to the east, with US 9W crossing the north and meeting 303 at the top of the parcel. Everything the development generates leaves through a single signalized junction at Route 303 and Meola Road. The applicant's own drawing is laid over satellite imagery at its surveyed position. Tap anything highlighted.
The drawing is the applicant's own CAD, georeferenced to its surveyed position at 1 inch = 60 feet. Solid highlight means the alignment is drawn on the sheet. Dashed means it is projected beyond the drawn linework.
Warehouse projects along Route 303 between the 9W junction and the New Jersey line. Each is reviewed on its own. The Cedar Corners DEIS does add traffic from two of them, Intercos and the Lincoln Logistics application, into its 2027 no-build volumes, and it relies on both projects’ signal work as its own mitigation. Beyond traffic it assesses nothing cumulatively, and the other projects on this list it does not count at all.
Bar length is proportional to floor area where a figure has been published. Dashed bars mark projects whose size has not been disclosed. The DEIS names Intercos and the Lincoln Logistics application but gives no floor area, applicant or address for either. Chartwell and Aktina come from press reporting on the corridor and are not named in the DEIS at all. A separate completed building, roughly 220,000 sq ft at Executive Park in Valley Cottage in 2023, is reported as partly vacant and is a different project from the approved Lincoln Logistics application counted above.
Peak hour trips for the alternatives the applicant evaluated. The senior housing proposal this site was zoned for before it was rezoned commercial is deliberately left out of this table, because the applicant gives two irreconcilable figures for it in two tables of the same document, 112 morning trips apart. Until that is resolved the comparison cannot honestly be drawn, which is note T-02.
| Alternative | AM peak | PM peak |
|---|---|---|
| Proposed Action | 194 | 206 |
| Full Build Out, four lots | 303 | 316 |
| No Action | 0 | 0 |
Figures are the applicant’s own. The Full Build Out alternative develops four lots rather than three and generates about half again as much peak hour traffic as the proposal. The previous zoning alternative is handled separately in note T-02, because Table 4.2 puts it at 128 and 163 while Table 4.3’s own printed line items total 240 and 276, and the DEIS narrative relies on the lower pair while citing the table that contradicts it.
Rockland County Planning asked that US 9W and NYS 304 be added to the study area. More precisely, the County asked the Town to determine whether the study should be expanded north to include it. The applicant declined, on the grounds that the adopted scoping document did not include it and that the approved study area already reaches intersections at comparable or greater distances. The same scope-boundary argument is used again at item 17 to decline a reduced-impact alternative. Ask the Board to make the determination the County actually requested.
Source · Comment and response letter, item 12The previous AAR zoning allowed up to 322 active adult units; the alternative as actually analyzed is 280 units plus warehouse and drive-thru space. Table 4.2 puts that alternative at 128 morning and 163 evening trips, below the warehouses at 194 and 206. Table 4.3 itemises the same alternative and its printed totals come to 240 and 276, above the warehouses. The difference is the 112 morning trips from the 280 residential units, which Table 4.2 appears to have omitted. The DEIS narrative asserts a reduction of 66 morning and 43 evening trips while citing the table that says the opposite, and the same defect appears in the Revised DEIS. Ask the Board to require one reconciled comparison in the Final EIS before any alternative is weighed.
Source · Supplemental DEIS, Tables 4.2 and 4.3 and section 4.3; Revised DEIS March 10, 2026, Tables 4.1 and 4.2The Full Environmental Assessment Form the applicant signed and filed asks for the projected number of truck trips per day and type. The answer is 342 trucks, 171 entering and 171 exiting, roughly fourteen an hour around the clock. That figure appears nowhere in the Traffic Impact Study, which analyzes only two peak hours and counts 34 truck trips in each. Nothing in the document reconciles 34 in a peak hour with 342 in a day, and the form was left blank where it asks for vehicle type. Ask the Board to require three things in the Final EIS: a count of truck movements across a full 24 hours, a breakdown of what size and class of truck they are, and a picture of when they bunch up, because trucks do not arrive evenly and shift changes are when a warehouse empties and fills at once. Ask it also and to explain which of its own two truck figures the analysis rests on.
Source · Full EAF Part 1, question E.2.j.ii, filed with the adopted Final Scope; Revised DEIS Table No. 1Answering the County on odor from idling trucks, the applicant replies that such effects are typical of the commercial uses already found along Route 303, which it notes is a dedicated truck route. The same logic runs through the traffic and air responses. It is the argument that a corridor already carrying too much can absorb more without analysis.
Source · Comment and response letter, item 14At both Lake Road intersections the applicant’s numbered recommendations offer nothing of its own. Recommendation 7 reads that it is the applicant’s understanding that an adaptive traffic control system is proposed at Route 303 and Lake Road in Congers as part of the Intercos Warehouse Expansion; recommendation 8 says the same of Lake Road in Valley Cottage as part of the Lincoln Logistics application. The level-of-service tables carry the same note in capitals. The sketch plan for Route 303 and Lake Road labels the adaptive control an INTERCOS requirement and marks the signal work as modifying the existing signal; the covering letter describes it instead as a full signal replacement. So the answer to the degradation this project causes is equipment it does not own, fund or control, and which this Board cannot compel it to build. Ask what the mitigation is if either project does not proceed. Worth adding that the retiming shown alongside it does not simply fix things: at Lake Road in Valley Cottage it lifts the overall morning grade from E back to D, but it pushes the eastbound approach from level of service E at 75.4 seconds to F at 80.3 seconds, and the westbound approach from 61.0 to 70.6 seconds. The side streets get worse so the overall grade can look better.
Source · Revised DEIS section 3.11, recommendations 7 and 8 and level-of-service tables; Colliers Engineering sketch SK-01, May 27, 2026; Colliers letter, June 6, 2026Trip generation uses ITE Land Use 150, Warehousing. Lot 1 alone carries 72 loading berths across 380,780 sq ft, roughly one dock per 5,300 sq ft, which is the profile of a high-throughput distribution operation rather than storage. The DEIS states in its own project description that the expected tenants are larger users such as interstate trucking companies. No lease has been signed. The applicant has run a sensitivity analysis using the higher Land Use 130 rates and offers a site-plan note requiring a supplemental study if a High-Cube Fulfillment Center or Parcel Hub use is later proposed. That offer is worth having, but it is written as a note that can be added rather than a condition, it names only two of the intensive ITE categories and omits transload and cold storage, and a supplemental study is not a limit on anything. Ask the Board to impose a numeric trip cap as an enforceable condition of approval, with re-analysis on any change of use, and to explain why Land Use 150 was chosen for a site whose expected tenants are interstate trucking companies.
Source · Revised DEIS section 2 project description and section 3.11.2; TIS Appendix HOf the 194 forecast morning peak-hour trips, 76 come from the drive-thru restaurant and 118 from more than 561,000 sq ft of warehouse. The restaurant is three tenths of one percent of the floor area. The applicant will point out that a 25 percent pass-by credit reduces the restaurant to 58 new trips out of 176, which is still a third of the total from a building the size of a house. Either way, when a building the size of a house is credited with more traffic than a warehouse the size of eight football fields, the warehouse rate being used is implausibly low. Note too that the DEIS describes this building as 1,500 sq ft and expects a Pizza Hut or similar, while the traffic study models it at 1,680 sq ft.
Source · Revised DEIS Table No. 1 and section 2; Supplemental DEIS, Table 4.3Level of service grades an intersection from A to F on how long you wait. The applicant sets the standard itself: “A Level of Service ‘C’ is generally used as a design standard while a Level of Service ‘D’ is acceptable during peak periods. A Level of Service ‘E’ represents an operation near capacity.” Measured against that, its own 2027 build year does not hold the corridor at B. Route 303 at Lake Road in Valley Cottage goes from D to E in the morning peak, average delay rising from 50.5 to 55.4 seconds, which is past the point the applicant calls acceptable. Route 303 at Lake Road in Congers goes from C to D in the morning, and in the evening its northbound approach reaches level of service E at 75.8 seconds. At the site access the Meola Road approach is forecast at E in the morning, 46.1 seconds, and F in the evening, 50.8 seconds, without a signal. Of the eight intersections studied, only Route 303 at US 9W and Leif Boulevard holds at B or better. Ask the Board to state in its findings the level of service and the delay each studied intersection is expected to carry with this project built.
Source · Revised DEIS section 3.11.2, description of analysis procedures and level-of-service tables for study area intersections 1, 2, 4 and 5Signalizing Route 303 at Meola Road is what turns a level of service E and F site access into an overall B. The DEIS describes that signal as subject to NYSDOT approval and to be reviewed through the Highway Work Permit process. NYSDOT’s email of June 1, 2026 agreed to left-turn lanes on the Route 303 approaches and a signal replacement at Lake Road. It did not approve the Meola Road signal. Ask the Board what the finding would be, and what the mitigation is, if the signal is denied or conditioned after the Final EIS is adopted.
Source · Revised DEIS section 3.11.2 and mitigation item 3; NYSDOT email June 1, 2026 via Colliers letter June 6, 2026Every traffic count in the study was collected in May 2024, against a 2027 design year, and the hearing was held in July 2026. Of the eight study area intersections only three rest on counts taken for this project. Four reuse volumes from the Town’s own Routes 303 and 304 Safety and Sustainability Study. Background growth was applied at 1 percent a year, a total of 3.03 percent compounded, where the New York Metropolitan Transportation Council factor for this road class in Rockland County is 0.78. Ask whether counts more than two years old, four of them borrowed, are an adequate baseline for a corridor the applicant itself calls a dedicated truck route.
Source · Revised DEIS section 3.11.1, Year 2024 Existing Traffic Volumes and footnotes 1 to 3; section 3.11.2Everything this development generates uses a single junction at Route 303 and Meola Road. The applicant looked at a second connection opposite Hemlock Drive and dropped it, stating that it “was determined as not feasible since the Applicant has no control to the adjacent property.” What is offered instead is an emergency access connection to Route 303 and an internal loop that the applicant told the scoping hearing is “just for emergency service,” adding that “between that building on the south side you do have emergency access that meets the code.” That is the applicant’s own assurance. Nothing in this record is a written determination from the Congers Fire Department, a volunteer department, that a single public access serving four warehouse buildings and 72 loading berths is adequate for fire apparatus. The fire code lets the fire official require more than one access road rather than fixing a number, so this is a question for that official, not a box already ticked. Ask the Board to obtain the Congers Fire Department’s written sign-off on access and apparatus circulation, and to put it in the Final EIS.
Source · Revised DEIS section 3.11.2 and mitigation item 5; Final Scope, scoping hearing transcript; Revised DEIS community facilities sectionThe Conservation Plan drawing carries one note, and it reads that tax lot 35.19-2-3 has access rights over the natural area. That lot is not one of the sixteen the applicant is merging, so a third party holds rights over ground being offered as mitigation. The appendix schedule of easements lists a 25-foot right of way and a 50-foot easement benefiting the same lot and marks both as not affected by the project. The DEIS text never identifies the holder or discusses what the rights mean for the conservation area. Reporting on the corridor separately lists Intercos, and expansions by Chartwell and Aktina, as further warehouse projects on this stretch of 303. Ask the Board to put on the record who holds the rights over the natural area, and how land encumbered by them can count as mitigation.
Source · Conservation Plan drawing dated June 1, 2026, note 1; Revised DEIS Appendix B, summary of easements; corridor projects from Rockland County Business JournalLincoln Equities completed roughly 220,000 sq ft at Executive Park in Valley Cottage in 2023, the first modern logistics facility built in the county since 2009. It was described at the July hearing as partly vacant, and residents raised the county’s existing surplus of warehouse space directly. Note that this completed building is a different thing from the approved Lincoln Logistics application whose traffic the Cedar Corners DEIS counts in its no-build volumes; the DEIS gives no size, applicant or address for the latter. Both figures come from press reporting rather than from this record, so cite them as reporting.
Source · Rockland County Business Journal, July 30, 2026; ROI-NJ, March 2023. Not stated in the DEIS.The 162-acre former Novartis campus in Suffern is slated to become a warehouse hub of up to 1.2 million sq ft. In West Haverstraw a 454,000 sq ft warehouse with 76 truck bays operating around the clock is proposed on a closed landfill. Cedar Corners is one piece of a county-scale shift.
Source · Rockland County Business Journal; Real Estate In-Depth, 2024On water resources the County wrote that SEQRA requires cumulative impacts to be considered and that the Town should look at this proposal alongside current and future watershed conditions. On solid waste it again urged the Town to weigh cumulative impacts, noting that the project’s 21.12 tons of additional waste a week is what about 492 households produce, and that it has to be hauled hundreds of miles for disposal. Neither response supplies a cumulative assessment. The DEIS does count two other warehouse projects in its traffic forecast, which makes the absence of any cumulative analysis for air, water, waste or habitat harder to defend, not easier.
Source · Comment and response letter, items 1 and 15SEQRA prohibits segmentation, the practice of splitting a development so no single piece triggers full review. Lots 2 and 3 were presented in earlier filings as conceptual with no immediate development plans, yet their traffic, waste and emissions all count toward the totals. Ask the Board to confirm on the record that the whole action has been reviewed as one.
Source · SEQRA 6 NYCRR 617; Rockland County Business Journal, May 2024The DEIS projects $3,067,449 in annual taxes, and that revenue is the central public benefit on offer. Reporting from the July hearing describes an application for roughly $6 million in benefits from the Rockland County Industrial Development Agency filed under GK Congers LLC. The Planning Board attorney first told the room no such application existed, then acknowledged it. A payment in lieu of taxes agreement would change the fiscal case materially.
Source · Rockland County Business Journal, July 30, 2026; DEIS Table 4.2The Chairman told the room the project complies with zoning and the applicant has a right to build. That is true and it is not the whole test. SEQRA still obliges the Board to take a hard look, to weigh social and economic factors, and to adopt written findings that the action chosen minimizes environmental harm to the maximum extent practicable.
Source · SEQRA 6 NYCRR 617.11; public hearing, July 29, 2026Clearing removes about 1,616 trees across 27.6 acres. On the Environmental Assessment Form it filed, the applicant answered yes to whether the site contains a designated significant natural community, named it Oak-Tulip Tree Forest, gave DEC as the source, put its extent at 175.0 acres, and entered NO CHANGE for both the extent after completion and the gain or loss. Elsewhere the same applicant states that the oak-tulip community lies a quarter of a mile north-east of the site rather than on it, and the DEIS calls the on-site forest Appalachian oak-hickory and a functionally isolated woodland and wetland fragment. The words oak-tulip appear nowhere in the 217-page DEIS or its 694-page appendix, so the form is never corrected or explained. Either the EAF answer is wrong and must be formally amended, or 27.6 acres of a state-designated significant natural community are being cleared with no analysis at all. Ask the Board to resolve which, on the record, before it adopts findings.
Source · Full EAF Part 1, question E.2.n and EAF Mapper summary, filed with the adopted Final Scope; Final Scope comment and response; Revised DEIS section 3.7; response letter, item 11The appendix air quality screening states that Route 303 and Lake Road in Valley Cottage achieves level of service D in both the no-build and build scenarios, and that no degradation of the intersection is therefore anticipated. The traffic study in the same submission forecasts that intersection at level of service E in the morning build condition, at 55.4 seconds of delay. The screening used the incorrect D to conclude that no microscale carbon monoxide or particulate analysis was required. This is not a typographical slip; the error is what the screen-out rests on. Ask the Board to require the air quality screening to be redone against the correct level of service, and the microscale analysis to be carried out if it no longer screens out.
Source · Revised DEIS Appendix, air quality screening, AM build; against Revised DEIS section 3.11.2 level-of-service tablesRockland County Planning recorded that the site sits in a census tract designated a Disadvantaged Community by the State Climate Justice Working Group under the Climate Leadership and Community Protection Act, and that the DEIS dismisses it. The applicant concedes the designation but argues that site-specific conditions do not reflect the burdens usually associated with it. The DEIS adds that with no response from NYSDEC on the designation since September 2024, it is assumed no further action is needed. A Disadvantaged Community, 342 truck trips a day, and an air quality analysis screened out on an incorrect level of service is a combination the Board should address directly rather than assume away.
Source · Comment and response letter, item 16; Revised DEIS pp. 138, 141 and 146-147The applicant offers roughly 4,650 solar panels, projected to mitigate about 69 percent of operational emissions, and 528 replacement trees rising to 603 under the Conservation Plan. Its own carbon analysis states that sequestration occurs gradually and that under conservative assumptions full offset exceeds forty years. A fully electric scenario would have needed about 9,165 panels. On heating the DEIS commits only to complying with the energy code in force at the time of permitting, and notes that no rule prohibits fossil-fuel systems. Ask the Board to weigh a forty-year offset against a permanent loss, and to condition approval on the electrification measures the County recommended.
Source · Comment and response letter, items 6, 9, 10 and 13; Revised DEIS section 3.6 and Appendix C carbon analysisThe warehouse floor area is 561,407 sq ft in the traffic study, 561,520 sq ft in the fiscal analysis, and the DEIS body puts all five buildings at 563,020 sq ft. The drive-thru is 1,500 sq ft in the narrative and 1,680 sq ft in the traffic study. Loading berths were 71 in earlier filings and are 72 now, and it is not clear whether 72 is Lot 1 alone or the whole site. Parking is 394, 24 and 181 spaces in the DEIS, 394, 34 and 199 in the County’s project description, and about 640 on the Environmental Assessment Form. These are small differences individually, but trip generation, tax revenue, water demand and emissions are each calculated off a different one of them. Ask the Board to require a single reconciled schedule of floor area, berths and parking, and to state which figures the Final EIS analysis rests on.
Source · Revised DEIS sections 2, 3.11.2 and 3.12.2; Appendix D fiscal analysis; Full EAF Part 1 question E.2.j.iii; County project description, June 22, 2026Stated fairly, because a comment that ignores it is easy to dismiss.
Written comment period closes August 10, 2026
The Clarkstown Planning Board is lead agency. Written comments go to c.cirrone@clarkstown.gov or planning@clarkstown.gov.
Every note above is numbered and carries its source. Comments that ask a specific question the Board must answer in the Final EIS carry further than comments that state opposition. Pick two or three, cite the table, and ask for the analysis that is missing.
Compiled from the Revised Draft Environmental Impact Statement dated March 10, 2026 and its appendices, the adopted Final Scope dated December 30, 2024 including the applicant's Full Environmental Assessment Form Part 1, the Supplemental DEIS distribution dated June 22, 2026, the comment and response letter to the Rockland County Department of Planning revised June 1, 2026, the Conservation Plan drawing dated June 1, 2026, the Colliers Engineering letter dated June 6, 2026 and sketch SK-01 dated May 27, 2026. Corridor and hearing context from Rockland County Business Journal reporting, including coverage of the July 29, 2026 public hearing, ROI-NJ and Real Estate In-Depth; those items are attributed to reporting because they do not appear in the SEQRA record. Every other figure is the applicant's own. Each note carries the section, table or form question it comes from so it can be checked. Where the applicant's documents disagree with each other, both figures are given rather than the more convenient one.