HomeMy WebLinkAbout20260091 Lexington Rd & Bemis Heights Rd Subdivision Modification Public Comment (2)
Dear 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 map 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,
Julie Anderson
8 Bemis Heights Dr.
Saratoga Springs, NY 12866
IndependenceSquareSSNY@gmail.com
(518) 584-7418
Wendy Gavert
4 Bemis Heights Dr.
Saratoga Springs, NY 12866
IndependenceSquareSSNY@gmail.com
(518) 879-7647
Fire Apparatus Access – 20240614
Lexington Road / Bemis Heights Subdivision
Key Concern – Evacuation Capacity and
Emergency Access:
The proposed subdivision would increase the number
of dwellings relying on the existing single fire
apparatus access road from 66 to 79 homes. 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 community safety.
The neighborhood is located near Interstate 87 (I-
87), 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 two-family dwellings where
the number of dwelling units exceeds 30 shall be
provided with two separate and approved fire
apparatus access roads.
Exceptions:
1. Where 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 dwelling units accessed from a
single fire apparatus access road shall not be
increased unless the access road will connect with
future development, as determined 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 by one access road: 66
• Proposed new homes: 13
• Total homes served by one access road: 79
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.¹ 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
1. 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.