HomeMy WebLinkAbout20260090 Lexington Rd & Bemis Heights Rd Watercourse/Wetlands Permit Public Comment (14)Outlook
Submission for Distribution and Public Record – June 18, 2026 Planning Board Meeting (#20240614, #20260090, #20260091 Lexington
Road / Bemis Heights Subdivision)
From Independence Square <independencesquaressny@gmail.com>
Date Tue 6/16/2026 12:30 PM
To Mark Graham <Mark.Graham@saratogaspringsny.gov>
1 attachment (276 KB)
Emergency Access and Fire Code Consistency.pdf;
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Dear Mr. Graham,
I hope you are doing well.
Please find attached my public comment regarding emergency access reliability and fire apparatus access considerations associated with the
proposed Lexington Road / Bemis Heights Subdivision, including applications #20240614, #20260090, and #20260091, in connection with the
June 18, 2026 Planning Board meeting.
I respectfully request that this submission be distributed to all members of the Planning Board in advance of the meeting and included as part
of the official public record for these applications.
Thank you for your time and attention.
Sincerely,
Janet St. Clair
13 Concord Dr.
Saratoga Springs, NY 12866
jstclair753@gmail.com
6/16/26, 12:35 PM Inbox - Mark Graham - Outlook
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Emergency Access and Fire Code Consistency
Dear Planning Board Members:
This submission concerns the adequacy and reliability of fire apparatus access associated with
the proposed subdivision modification.
The proposed project would increase the number of dwellings relying on the existing single fire
apparatus access road from approximately 68 to approximately 81 homes. This represents a
material increase in demand on a fixed and limited access system without any corresponding
change to the access configuration.
Fire apparatus access is not evaluated solely based on roadway geometry or the ability of fire
apparatus to maneuver within a development. It must also be evaluated based on the reliability of
access under actual operating conditions. As the number of dwellings served by a single access
point increases, so does the number of residents, visitors, emergency responders, and vehicles
that depend upon that access point during routine conditions and emergency events.
In a single-access configuration, any obstruction, congestion, disabled vehicle, weather-related
event, emergency operation, or other access-limiting condition can affect both responder ingress
and resident egress. A single-access system therefore functions as a single point of failure.
Increasing the number of dwellings served by that system increases both the number of persons
dependent upon the access road and the consequences of any access impairment.
A determination that fire apparatus can maneuver within the proposed subdivision does not
resolve the separate question of whether the overall access system remains reliable when
additional dwellings are added to a single-access residential area. Turning radius, hammerhead
turnarounds, and internal maneuverability address apparatus movement once access has been
obtained. They do not, by themselves, address whether the single access road can remain
available under conditions of obstruction, congestion, evacuation, weather-related impairment, or
simultaneous emergency response.
New York State Fire Code – Appendix D107
The New York State Fire Code includes Appendix D provisions addressing fire apparatus access
for residential developments.
Appendix D107.1, One- or Two-Family Residential Developments, provides that 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.
Appendix D107 also specifically addresses the issue of increasing the number of dwelling units
accessed from a single fire apparatus access road in Exception 2.
The Fire Code does not establish thresholds such as those in Appendix D107 arbitrarily. These
provisions reflect established fire service experience and life-safety principles relating to
emergency access, response reliability, and evacuation. As the number of dwellings served by a
single access point increases, both the likelihood and the consequences of access impairment
increase.
Application to the Proposed Modification
The proposed approval would increase the number of dwellings relying upon a single fire
apparatus access road from approximately 68 to approximately 81. Regardless of how the
proposed subdivision is categorized for other purposes, the record should clearly reflect how this
increased reliance on a single-access system was considered in evaluating fire apparatus access,
emergency response reliability, and consistency with the purposes and objectives of Appendix
D107.
This concern is especially important because the proposed project does not merely preserve an
existing condition. It would add additional dwellings to an already single-access residential area.
The record should therefore clearly explain how the proposed increase in dwelling units has been
evaluated in relation to the existing single-access condition.
The Fire Code framework also anticipates that where standard access configurations are not met,
alternative measures or site-specific considerations may be evaluated. However, it is not evident
from the current record what, if any, such measures have been identified or relied upon in
relation to the proposed increase in dwelling units and continued reliance on a single access road.
Request for Clarification and Record Consideration
Given the above, clarification of the following is respectfully requested for the record:
1. Whether the proposed increase from approximately 68 to approximately 81 dwellings
served by the existing single access road was considered in evaluating emergency access
reliability.
2. Whether the record identifies any alternative access provisions, mitigation measures, or
site-specific considerations relied upon to address the increased reliance on a single-
access system.
3. Whether the proposed increase has been determined to be consistent with the purposes
and objectives of Appendix D107, and where the basis for that determination appears in
the record.
Conclusion
This submission is provided to ensure that the Planning Board record clearly reflects
consideration of fire apparatus access and emergency response reliability in relation to the
proposed increase in dwelling units.
In the absence of clear findings on these points, it is not evident from the current record how the
proposed increase in dwelling units served by a single fire apparatus access road has been
evaluated in relation to the purposes and objectives of Appendix D107. Because the proposed
approval would increase reliance on an existing single-access system, the record should clearly
identify the basis upon which that increase has been determined to be consistent with applicable
Fire Code provisions and fire access considerations.
Respectfully submitted,
Janet St. Clair
13 Concord Dr.
Saratoga Springs, NY 12866
jstclair753@gmail.com