HomeMy WebLinkAbout20230877 NYS Route 29 Multi Family Public Comment (2)
To: Saratoga Springs Planning Board
From: Sustainable Saratoga
Subject: Project 20230877 – NYS 29 Mixed Use
Date: 8/29/2025
The Planning Board has resumed review of a project to build 344 residential units in two
4-story buildings, along with 40 2-story row houses and a 110-room hotel on a 17-acre
parcel between Route 29 and Station Lane. The parcel is forested and undeveloped.
The Unified Development Ordinance (UDO) includes the parcel in the Neighborhood Center
zoning district, which “is intended to accommodate a wide variety of residential and
nonresidential uses in a moderate intensity mixed-use environment. This district also
focuses on providing quality streetscape amenities and civic spaces to enhance pedestrian
activity.”
Sustainable Saratoga supports growth and development in the city that conforms with the
principles of sustainable land use, as embodied in our city’s Comprehensive Plan. The
Plan’s city-in-the-country vision “reflects a city with an intensively developed urban core and
an economically vibrant central business district, with well-defined urban edges and an
outlying area of rural character, comprised of agriculture, open lands, natural and diverse
environmental resources, and low-density residential development.” Where appropriate
development is proposed, we believe it should be designed and conducted to minimize
environmental impacts and enhance environmental benefits.
Wetlands
Sustainable Saratoga strongly supports the protection of streams and wetlands. According
to the application materials available on the City website, there is a large area of regulated
wetlands near the east boundary of the project parcel. The application materials include a
letter from DEC dated February 15, 2024, which makes reference to the proximity of
regulated wetlands and the importance of protecting them, as well as the surrounding
buffer, from disturbance.
The letter reflected the DEC position at the time. However, the Board should be aware that
the letter is out of date. As of January 1, 2025, the jurisdiction of State wetlands regulations
was expanded to include “wetlands of unusual importance,” defined as wetlands of any size
that meet any of 11 specified characteristics. One of the characteristics is a location within
or next to an urban area, as designated by the US Census Bureau. Because the project
parcel appears to lie within a designated urban area, wetlands of any size within the project
parcel would now be under DEC jurisdiction.
Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer, Richard Romano
(Secretary), David Sayer, David Washburn
Sustainable Saratoga | PO Box 454, Saratoga Springs, NY 12866 | www.sustainablesaratoga.org | info@sustainablesaratoga.org
The Board should ensure that the applicant contacts DEC as soon as possible to
determine whether there are regulated wetlands within the project area and to what
extent the project design should be modified to protect them.
Landscape
Article 11 of the UDO contains extensive requirements for the preservation and planting of
trees and other vegetation. It requires specific plantings in and around parking areas and
along streets.
Section 11.9.A. provides:
Existing significant trees should be preserved to the maximum extent feasible.
Where preservation is not feasible, trees that are removed should be replaced
on-site with comparative native trees that will provide the same benefit in
accordance with this section.
Section 11.9.C. provides:
As part of site plan review, a tree survey depicting the species, size, location, and
condition of any existing significant trees on the site by a land surveyor or
registered arborist is required, including a preservation and replacement plan to
demonstrate compliance with these standards.
While it is inevitable that a development as intensive as the one proposed will require
significant tree cutting, the UDO indicates that project design, including the layout of
buildings and streets and the size of their footprints, should maximize the
preservation of existing trees and the size of areas set aside for new trees and other
vegetation.
The Board should work with the applicant to enforce the remaining sections of 11.9, with
particular attention to 11.9.E, Permitted Tree Removal, 11.9.F, Tree Replacement or
Mitigation, and 11.9.H, Clearcutting of Forest Prohibited. Planting trees along streets or in
undeveloped areas at greater densities than required minimums could serve as partial
mitigation for the removal of trees to accommodate buildings and infrastructure.
Sincerely,
Kelsey Trudell
Executive Director
Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer, Richard Romano
(Secretary), David Sayer, David Washburn
Sustainable Saratoga | PO Box 454, Saratoga Springs, NY 12866 | www.sustainablesaratoga.org | info@sustainablesaratoga.org