HomeMy WebLinkAbout20260091 Lexington Rd & Bemis Heights Rd Subdivision Modification Public Comment (10)
April 21, 2026
To: Saratoga Springs Planning Board
Re: 20260091 – Lexington Road & Bemis Heights Road Subdivision Modification
Dear Chairman Pingle and members of the Planning Board,
On behalf of Sustainable Saratoga, we appreciate the Planning Board’s continued
attention to the proposed Lexington Road/Bemis Heights subdivision and the care you
bring to reviewing complex applications of this nature. Thank you for receiving the
following recommendations.
Prior Determination of the applicable Zoning District must be provided.
We respectfully request that the zoning determination for this project be clearly resolved
and formally reflected in the record before the Planning Board takes any further action.
Based on the materials currently available—including the applicant’s own submissions,
the city’s zoning map, the UDO subdivision plat expiration procedures, and the full
record of this application in Planning Board minutes—there remains a fundamental
question as to whether the property is properly located within the UR-1 district, as
assumed in the current review, or within the Rural Residential (RR) district, which has
long applied to this area. The distinction is consequential. If the property lies within the
RR district, it is part of the city’s Greenbelt and subject to a markedly different,
conservation-oriented regulatory framework, including lower allowable densities, altered
site design expectations, and additional conservation requirements. Because these
districts reflect materially different standards and policy objectives, the Planning Board
should establish a clear and well-supported determination before proceeding further.
Continue Environmental Review and Impact Evaluation.
We note that the project site appears to encompass, both on-site and downstream,
environmentally sensitive areas that are hydrologically connected and warrant careful
evaluation. Although the Planning Board has issued a negative SEQRA declaration, we
respectfully encourage continued scrutiny of the project’s interaction with these natural
systems as additional public comments are received and as the Watercourse/Wetland
Permit application is reviewed. In particular, we urge close attention to floodwater
storage capacity, sedimentation and erosion controls, accurate wetland and stream
delineation and appropriate buffering, and the adequacy and enforceability of proposed
mitigation measures.
Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Dianna Goodwin, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer
(Secretary), Bob Radliff, David Sayer, David Washburn
Sustainable Saratoga | PO Box 454, Saratoga Springs, NY 12866 | www.sustainablesaratoga.org | info@sustainablesaratoga.org
Establish Monitoring and Performance Guarantees.
The conditions of any approval should articulate a clear and enforceable monitoring
framework. This should provide for pre- and post-construction observations, including
assessment of site conditions during significant weather events, and a defined process
for reporting and addressing impacts. An appropriate performance guarantee or escrow
mechanism should be seriously considered to accompany any approval, to ensure that
corrective actions can be implemented as needed and without undue burden on
neighboring property owners or the city itself.
Require a Permanent and Enforceable Conservation Easement.
Regardless of the zoning district, the ecological characteristics of this site make
essential the permanent protection of key natural areas. Any Conservation Easement
must be meaningful, perpetual, and enforceable. Importantly, the easement should
clearly describe the protected area and its conservation purposes (including wetland,
flood storage, habitat, and open space functions), specify prohibited and limited
activities (such as new structures, filling or grading, alteration of natural drainage,
degradation of buffers, etc.), and clearly identify a capable easement holder with
defined monitoring and enforcement authority. It should also establish a regular
monitoring schedule and baseline documentation, spell out maintenance responsibilities
and a process for restoration if damage or noncompliance occurs, and confirm that the
easement runs with the land and is fully consistent with and implements the Planning
Board’s conditions of approval. Reliance on individual property owners to fulfill this role
is inadequate on its face and is extremely unlikely to provide consistent or effective
stewardship over time.
Include the Final Conservation Easement in the Planning Board’s decision.
In addition, the Conservation Easement document should be fully drafted and included
in the application materials prior to Planning Board action. The Board should have the
opportunity to review and approve the complete easement terms—including the identity
of the holder and the land management and monitoring provisions—as part of the
project record and as an integral component of any Planning Board approval, rather
than deferring those details to a later stage.
Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Dianna Goodwin, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer
(Secretary), Bob Radliff, David Sayer, David Washburn
Sustainable Saratoga | PO Box 454, Saratoga Springs, NY 12866 | www.sustainablesaratoga.org | info@sustainablesaratoga.org
As you all know, the city has a planning framework based not just on the UDO and the
Comprehensive Plan, but on recent planning and non-regulatory policy documents,
including the Open Space Plan and the Natural Resources Inventory, all adopted
unanimously by recent City Councils. All of these documents convey the same basic
message: Wetlands, streams, watersheds, wooded areas, and ecologically important
open lands need to be regarded as valuable resources for the benefit of residents and
visitors. Sustainable Saratoga’s recommendations are made with this framework in
mind. Our goal is to support high-level evaluation standards for this site that ensure both
the city’s planning objectives and the community’s long-standing commitment to
protecting its natural resources and systems.
Thank you for your consideration and for your continued service to the Saratoga
Springs community.
Sincerely,
Kelsey Trudell
Executive Director
Amy Durland
Board Chair
Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Dianna Goodwin, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer
(Secretary), Bob Radliff, David Sayer, David Washburn
Sustainable Saratoga | PO Box 454, Saratoga Springs, NY 12866 | www.sustainablesaratoga.org | info@sustainablesaratoga.org