HomeMy WebLinkAbout20230378 Washington Land Disturbance Public Comment (25)Outlook
Online Form Submittal: Land Use Board Agenda Public Comment
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Date Tue 11/12/2024 3:28 PM
To Julia Destino <Julia.Destino@saratoga-springs.org>; Susan Barden <Susan.Barden@saratoga-springs.org>
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Land Use Board Agenda Public Comment
SUBMIT COMMENTS REGARDING CITY PROJECTS
Thank you for submitting your comments. Your feedback will be forwarded to the
City's Planning Department and Land Use Board members. NOTE: Comments
submitted later than 12:00 noon on the day before the Land Use Board meeting
may not be reviewed prior to their meeting. All comments will be added to the
project file in the Planning Department.
Land Use Board Planning Board
Name Elizabeth Reardon
Email Address Field not completed.
Business Name Field not completed.
Address 11 Outlook Ave
City Saratoga Springs
State NY
Zip Code 12866
Phone Number 518-641-8029
Project Name 239 Washington St Land Disturbance
Project Number Field not completed.
Project Address Field not completed.
Comments Please see attached PDF.
Attach Photo (optional)ConcernSubmission_239WashingtonProposal.pdf
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11/12/24, 3:29 PM Mail - Julia Destino - Outlook
https://outlook.office365.com/mail/inbox/id/AAQkADI5NDIzZGRiLTQwNjEtNGM1MS05ZmQxLTUyZTNkMzFiZDJiZQAQAKDyPAQe45RLrEApyoTO2qc…1/1
FROM:
Robert Loccisano & Kelsea Flannery (9 Outlook)
Elizabeth Reardon (11 Outlook Ave)
Joseph & Lorraine Tesoriere (13 Outlook Ave)
TO:
Chairman Martin and Members of the Planning Board
City of Saratoga Springs
City Hall – 474 Broadway
Saratoga Springs, NY 12866
Date: November 12, 2024
We're here to express serious concerns about the proposed land disturbance project at 239
Washington Street. After careful review of the submitted documentation, we have identified
several significant issues that warrant your consideration.
First, we'd like to address the timing and intent of this application. The applicant states they
have "no plan to develop this site" but simply wish to "make it shovel ready" for marketing
purposes [Development Letter, September 9, 2024]. This is particularly concerning given that
NYSDEC has explicitly indicated "changes to Article 24 regulations are expected in January of
2025" and "wetland determinations may be subject to change" [NYSDEC Letter, March 13,
2024].
Second, there are substantial technical deficiencies in the proposal:
• The proposed retention basin "does not follow NYSDEC Blue Book design for retention
basins" [LaBella Response, October 3, 2024]
• No geotechnical studies have been conducted despite "shallow bedrock" being
documented in the area [City Engineer's Comments]
• The proposed basin will only "function similar to a pretreatment forebay" rather than a
proper stormwater management system [LaBella Response, October 3, 2024]
• The SWPPP lacks "proper operation and maintenance" documentation required by Part
VII.L of the permit [SWPPP]
Third, the project poses significant hydrological concerns:
• Adjacent properties experience "water comes into their basement during intense
storms" [City Engineer's Comments]
• The existing culvert has "limited inflow capacity" [LaBella Response, October 3, 2024]
• The developers acknowledge "issues cited by the adjacent landowners are an existing
conditions problem... and would continue" [LaBella Response, October 3, 2024]
• Current design point areas "fill up rather quickly" [City Engineer's Comments]
Fourth, the environmental impact is considerable:
• The project will destroy "2.01 acres of wetlands on the total 8.90-acre site or roughly
22% of the site" [City Engineer's Comments]
• The site contains documented "Northern Hardwood Forest Zone" with "oak, beech,
maple, birch and hemlock trees" [Archaeological Study, p.8]
• "Phragmites can spread both by rhizomes and by windblown seedheads" with no
ejective management plan proposed [LaBella Response, October 3, 2024]
• The property historically functioned as natural drainage where "Waterbury's cattle are
reported to have frequently gotten stuck in the bog" [Archaeological Study, p.15]
Finally, the proposal fails to meet several key requirements of the SPDES General Permit,
specifically:
• Must "minimize soil compaction and preserve natural bujers" [SWPPP Part I.B.1]
• Must "prevent violations of water quality standards" [SWPPP Part I.D]
• Requires "sound engineering judgment" [SWPPP Part I.B]
• Must provide "proper operation and maintenance" [SWPPP Part VII.L]
Based on these documented deficiencies, we respectfully request that the Planning
Board:
1. Defer consideration until after the implementation of new wetland regulations [NYSDEC
Letter, March 13, 2024]
2. Require comprehensive geotechnical studies as noted as missing by the City Engineer
3. Mandate a complete development proposal rather than speculative clearing
[Development Letter, September 9, 2024]
4. Insist on stormwater management design that meets NYSDEC standards [SWPPP Part
I.B]
5. Ensure adequate protection for adjacent properties from flood risks [City Engineer's
Comments]
The SPDES permit explicitly states that "the Department may suspend or revoke permit
coverage" if the SWPPP fails to meet requirements or protect water quality [SWPPP Part II.D.4].
The deficiencies documented in these materials clearly demonstrate that this project, as
proposed, does not meet these standards.
In closing, we'd like to reflect on what makes our historic Saratoga Springs special. Our city has
thrived for centuries because of our commitment to health and history. Indeed, these wetlands
are part of the same natural water systems that first drew people to Saratoga. As the
Archaeological Study documents, this very property has been an integral part of our water
resources since 1787. For over 200 years, this land has quietly served our community,
providing natural drainage and water management that protects our homes and
neighborhoods. As we look to Saratoga's future, we have not just an opportunity, but a
responsibility to honor this legacy and protect our ever-diminishing natural resources.
Thank you for your consideration of these concerns.
Robert Loccisano & Kelsea Flannery (9 Outlook)
Elizabeth Reardon (11 Outlook Ave)
Joseph & Lorraine Tesoriere (13 Outlook Ave)