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Home My WebLink About20260091 Lexington Rd & Bemis Heights Rd Subdivision Modification Public CommentDear Planning Board Members, I am a resident of the Independence Square neighborhood and am writing regarding the proposed 20240614 Lexington Road / Bemis Heights Subdivision. Attached is a snap showing the existing development and the proposed addition. As illustrated, the project would result in 81 homes being served by a single access road. I wanted to share this because of concerns related to fire apparatus access and evacuation capacity, particularly given the scale of the development and the lack of a secondary access point. I appreciate your time and consideration as you review this project. Sincerely, lie Anderson Wendy Gavert 8 Bemis Heights Dr. Saratoga Springs, NY 12866 IndependenceSquareSSNY@gmail.com (518) 584-7418 4 Bemis Heights Dr. Saratoga Springs, NY 12866 IndependenceSqLiareSSNY@gmail.com (518) 879-7647 h w �, `a, r > O ly a ro ed., Y par "" us cc ss r 49 4W .� - �� Lam• , s. ' RSl hh S •4y �' u � 1•� ,r ram' ��: ..-� Y• 31 +I { ,..� eener...-. ,wM• -ten-•- ...— ......, � - `r k� 1� . �• 3 6 i 10n..f (._ t 13J � a !J k f CR.MK.n 166. Z ll o-M'i ur„�atr! ROb r �\I A.,+ Ir / Proposed h:; ",� Lexington Rd. / Bemis Heights Subdivision Fire Apparatus Access — 20240614 Lexington Road / Bemis Heights Subdivision Key Concern — Evacuation Capacity and Emergency access: The proposed subdivision would increase die number of dwellings relying on the existing single fire apparatus access road from 66 to 31 bones. This raises a significant concern about evacuation capacity-_ in the event of a fire_ natural disaster, or other emergency —particularly at night —the limited access could delay emergency responders and impede residents' ability to evacuate safely, potentially affecting overall conununity safety. The neighborhood is located near Interstate 37 (I-37)- a major north —south highway linking New York City to the Canadian border that carries heavy commercial and hazardous materials traffic. Highway accident risk assessments have identified I-87 as a high -risk corridor for collisions and hazardous materials incidents. In the event of an incident, road closures or restricted access could further limit evacuation capacity and delay emergency response: compounding the risks associated with the single -access subdivision road. New York State Fire Code —.Appendix D107 D107.1 One- or two-family residential developments Developments of one- or to o-family dwellings where the number of dwelling units exceeds 30 shall be provided with two separate and approved fire apparatus access roads. Exceptions: 1, Vhere more than 30 dwelling units are accessed from a single public or private fire apparatus access road and all dwelling units are equipped with an approved automatic sprinkler system- access from two directions is not required. 2. The number of dwellina units accessed from a single fire apparatus access road shall not be increased unless the access road will connect with future development, as deternnined by the fire code official. 3. Construction of dwellings on premises with local site plan approval prior to January 1, 2011. with no modifications to the approved site plan. KEY FACTS • Existing homes served ed by one access road: 63 • Proposed new homes:.13 • Total homes served by one access road: 31 Fire Code threshold requiring two access roads: 30 dwellings The proposed addition of 13 homes to an existing 68-home neighborhood served by a single access road —without a secondary access, emergency access easement, or planned future connection —raises significant concerns under the Fire Code of New York State that warrant clear consideration and findings regarding fire apparatus access, emergency response, and evacuation capacity. Fire Code limits on single -access residential developments are based on how risk increases as more homes rely on a single point of access. The issue is not simply the number of dwellings, but how emergency response and evacuation demands interact under real -world conditions. As the number of homes increases, risk does not grow linearly. Instead, it increases non -linearly (effectively exponentially) due to compounding factors: • Increased vehicle volume during evacuation, leading to rapid congestion at a single exit • Greater probability of simultaneous or overlapping emergencies • Higher likelihood that the sole access route becomes blocked or restricted • Direct conflict between inbound emergency responders and outbound evacuating residents Emergency management research shows that once a roadway approaches capacity, even minor disruptions can produce disproportionately large delays and system -wide failure effects, particularly in evacuation scenarios.' 2 At relatively low densities, these risks remain manageable. However, beyond approximately 30 dwellings, a single access point becomes a critical bottleneck, where failure of that access route —whether due to an accident, fire apparatus placement, or other obstruction —can significantly delay both emergency response and evacuation. This principle is codified in the Fire Code of New York State, Appendix D107, which requires two separate and approved fire apparatus access roads for residential developments exceeding 30 dwelling units, unless specific safety -based exceptions are satisfied. These risks are further elevated in this location due to its proximity to Interstate 87, a major regional corridor carrying substantial commercial and hazardous materials traffic. Incidents along such corridors can result in road closures, delayed emergency response, and the need for rapid evacuation, placing additional strain on limited local access infrastructure.3 For these reasons, the two -access requirement is not a formality —it is a core life -safety standard intended to ensure that emergency response and evacuation can occur simultaneously, reliably, and without catastrophic bottlenecks. References Federal Emergency Management Agency, Evacuation Planning Guide for Communities (2019). — Discusses traffic congestion, evacuation clearance times, and cascading failure effects in constrained networks. 2. National Institute of Standards and Technology, Community Resilience and Evacuation Modeling Research. — Identifies non -linear increases in evacuation delay as roadway demand approaches capacity. 3. Federal Motor Carrier Safety Administration, Hazardous Materials Transportation Safety and Incident Data. — Documents risks associated with high -volume truck corridors and hazmat incidents affecting roadway access. 4. International Code Council, International Fire Code, Appendix D. — Model code basis for New York State's two -access requirement for developments exceeding 30 dwelling units.