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HomeMy WebLinkAbout20190117 Eberlein Subdivision Correspondance (6) To: City of Saratoga Springs Planning Board Department of Public Works Office of the City Engineer City Attorney CC: Mayor's Office 1 , From: The Raga Family Trust, 50 Ruggles R.., Saratoga prings, NY 12866 Re: 20190117 EBERLEIN SUBDIVISION 42 Ruggles Rd. Saratoga Springs, NY 12866 Subdivision of a 2-lot conservation subdivision Date February 11 , 2020 20190117 EBERLEIN SUBDIVISION The Raga Family Trust at 50 Ruggles Rd. is submitting comments in opposition to the 20190117 Eberlein Subdivision. The Raga Family Trust has submitted comments in opposition to the 2019117 Eberlein Subdivision: • at the May 16, 2019 written and oral comments were provided at the City of Saratoga Springs Planning Board meeting; • on June 3, 2019 additional comments in opposition were submitted to the City of Saratoga Springs Planning Board, the Department of Public Works, Office of the City Engineer, Mayor's Office and City Attorney; • on June 12, 2019 comments were provided to representatives of the Department of Public Works on site at 47 Ruggles Rd., Saratoga Springs, NY; • December 2019 written comments in opposition were submitted and presented at the Public Hearing held on December 12, 2019; • January 2020 an independent engineering review performed by Sterling Engineering was submitted documenting that the application is incomplete and inaccurate, and; opposition was again stated at the Public Hearing held on January 16, 2020; • February 2020 an additional independent engineering review performed by Sterling Engineering was submitted documenting that the application is incomplete, inaccurate, not in compliance with Law and code, and needs the Planning Board designated engineer to render an opinion regarding the need for a full SWPPP; and • February 2020 a legal review from Amanda J. Kukle of Caffry & Flower Attorneys at Law was submitted stating that the Eberlein application is incomplete and inadequate and should not be approved. 1 Neighbors in the immediate impact area of this project at 47, 50 and 51 Ruggles Rd., have raised issues regarding the topography of the project application. From the first Public Hearing in May 2019 the neighbors at 47 and 50 Ruggles Rd. have specifically raised issues regarding stormwater runoff and the impact on their properties. Issues pertaining to the culverts at 42-47 Ruggles Rd. and 50 Ruggles Rd. have been raised repeatedly, including an on on-site meeting with the Dept. of Public Works in June 2019 and photos of standing water at the 50 Ruggles Rd. culvert. Also, the 42 and 47 Ruggles Rd. properties have documented wetlands. On all three submissions of the Stormwater Pollution Prevention Plan (SWPPP), including the January 24, 2020 revision the NYS Department of Environmental Conservation State Pollutant Discharge Elimination System (SPDES) form question #15 states that there are NO CULVERTS. Culverts and the issues associated with the drainage have been well documented at 42- 47 Ruggles Rd. and 50 Ruggles Rd, including an on-site meeting with representatives of the City Department of Public Works. The City of Saratoga Springs is an MS4 (Municipal Separate Storm Sewer System) community, which means that the city has to sign off on the SWPPP taking into consideration potential impacts to existing stormwater infrastructure (e.g., ditches and culverts). The MS4 review and certification requirement was pointed out in the Sterling Engineering Review. The City of Saratoga Springs Planning Board should not approve the Eberlein application since there is an engineering and legal basis to disapprove. The Raga Family Trust, 50 Ruggles Rd., Saratoga Springs, NY OPPOSES the 20190117 EBERLEIN SUBDIVISION. 2 n/e Y r I 6403089820 Nid7P Slit/ PPP— -R,_ ,,„sa i p q ,,,, 7 15. Does the site runoff enter a separate storm sewer system (including roadside drains, swales, ditches, O Yes • No O Unknown culverts, etc) ? 16. What is the name of the municipality/entity that owns the separate storm sewer system? . 17. Does any runoff from the site enter a sewer classified O yes *No O Unknown as a Combined Sewer? 18. Will future use of this site be an agricultural property as defined by the NYS Agriculture and Markets Law? O Yes •No • 19. Is this properly owned by a state auLhofity, stale agency, federal government or local government? O Yes •No 20. Is this a remediation project being done under a Department approved work plan? (i.e. CERCLA, RCRA, Voluntary Cleanup O Yes • No Agreement, etc. ) , 21. Has the required Erosion and Sediment Control component of the SWPPP been developed in conformance with the current NYS R Yes O No Standards and Specifications for Erosion and Sediment Control (aka Blue Book) ? 22. Does this construction activity require the development of a SWPPP that includes the post-construction stormwater management practice component (i.e. Runoff Reduction, Water Quality and O Yes a No Quantity Control practices/techniques) ? If No, skip questions 23 and 27-39. 23. Has the post-construction stormwater management practice component of the SWPPP been developed in conformance with the current NYS O Yes O No Stormwater Management Design Manual? L Page 5 of 14 1 nn • 0251089825 3 �WpP /44/.:, 7 r - - /, 24. The Stormwater Pollution Prevention Plan (SWPPP) was prepared by: \ \ / ! Professional Engineer (P.E. ) ° Soil and Water Conservation District (SWCD) °Registered Landscape Architect (R.L.A) C) Certified Professional in Erosion and Sediment Control (CPESC) O Owner/Operator O Other . 1 SWPPP Preparer 1 I n , g a11 11s & lA s s c c ila t o s � , L L P 1 Contact Name (Last, Space, First) ' I n , g al is D av i d I • . Mailing Address 2 . 6 0 3 ': Gu i 1 dle r 1 a nod; A v en u e City _ S c 1 h e n e c t a di_.y_�__.-. ` �_...-�---1____- I____.�-___� . � � '_ i _ State Zip N Y 1 213 0 61 - j Phone Fax 5 1 8 - 3 9 ',3 - 7 7 2 5 — - - Email 1d. ingiallis@i1ngallsIllp . com I 1 i /, SWPPP Preparer Certification T hereby certify that the Stormwater Pollution Prevention Plan (SWPPP) for this project has been prepared in accordance with the terms and conditions of the GP-0-15-002. Furthermore, I understand that certifying false, incorrect or inaccurate information is a violation of this permit and the laws of the State of New York and could subject me to criminal, civil and/or administrative proceedings. First Name MI D a v id i i F1 Last Name 1 I ngla 1 11s Signature Date 1 LPage 6 of 14