October 6, 2004
Mr. William Mazzuca and The Town Board
Town of Philipstown
238 Main Street
Cold Spring, NY 10516
RE: Proposed Philipstown Comprehensive Plan
Dear Supervisor Mazzuca and Fellow Board Members:
The Planning Board has started
its review of the proposed Comprehensive Plan and would like to submit these
initial comments for your consideration.
The Planning Board intends to continue its review and may refine these
comments as that occurs.
The Plan is very well written and
the Planning Board commends the Comprehensive Plan Committee and its advisors
in the preparation of a thoughtful document.
Because the Planning Board
believes that the Comprehensive Plan is an important template for setting forth
policies for the future of our town, we request the Town Board’s indulgence in
extending the public hearing.
The Planning Board has not been
able to complete its review of the Comprehensive Plan but has spent several
hours discussing its contents. In this regard we would request that you hold
the public hearing open for future comment or at a minimum keep the written
comments period open for an additional period of time so that the Planning
Board and others may provide further input.
Also, as a Type 1 action, the New
York State Environmental Quality Review Act must be complied with before
adoption of the Plan
In general, the Planning Board believes that certain
statements and goals of the plan would be better presented as areas that
require further study, as opposed to defined specific goals.
For example, the Plan talks about
Perks Plaza as a targeted area for a pedestrian friendly, mixed-use project. The
Planning Board believes that a better stated goal would be for the town to study
the potential for such an action occurring at Perks Plaza. In order to make good judgments about this
kind of goal, it would be useful for the town to have additional information
including the ownership and size of tax parcels in the Perks Plaza area, their
proximity to Clove Creek, traffic access and circulation data, size and use of
existing buildings, and perhaps even some economic information regarding the conditions
and operation of the existing Plaza.
This would put into perspective the actions needed to bring about an
investment in the area relative to density, uses and feasibility. Without such information, the goal of
a mixed use center at this or any other location is highly speculative and
difficult and may be unlikely to be
realized.
The background section of the plan
that discusses housing offers a statement relative to future development
projects that troubles the Planning Board. It specifically states that “concentrating
residents in large enclaves of the same housing type and affordability will threaten
Philipstown’s authenticity.” It goes on to suggest that multi-family housing for
seniors and the general population should be distributed throughout the Town in
small groups, and that senior housing should be located adjacent to hamlet centers
where residents would be close to amenities and public transportation.
The Planning Board felt strongly
that this language needed to be taken out of the Philipstown Comprehensive Plan
for a variety of reasons.
1.
The term authenticity is undefined and vague. What does this mean?
2.
The Town of Philipstown at the present time makes no provisions
whatsoever for multi-family housing or for seniors. The Planning Board believes that the Comprehensive Plan needs to
do a better job at addressing this critical issue and is surprised that the
Plan does not directly acknowledge the PIP site as a targeted site for seniors
and affordable housing (especially after the many years of study that the town
has invested in this possibility).
3.
It will be difficult if not impossible to develop multi-family
senior housing in small groups to be distributed throughout the Town because of
infrastructure limitations on water and sewer. Frankly, the Planning Board does not believe that
there is much likelihood that this would ever happen.
4.
Aside from Garrison Landing and the two Village’s, there
really are no hamlet centers in the town.
Garrison Landing is not viewed as a location that can support much in
the way of multi-family housing. Perks
Plaza needs further study. Thus, the
plan is unclear as to the town’s strategies for accommodating multi-family and
senior housing. The Planning Board
does not believe it to be prudent to await some future hamlet center before
addressing the needs for multifamily or senior housing.
5.
The language in this section seems to go directly in opposition
to the Town Board's multi-year study and planning of potential senior housing
at the Quarry Pond site. Language of this nature in a comprehensive plan will
make it difficult if not impossible to implement the proposed Quarry Pond PDD.
The Planning Board suggests
that the Comprehensive Plan should focus on greater incentives for existing businesses
along Route 9 to upgrade their properties, develop better landscaping and improve
asthetics. This is a matter that needs more study, including the potential pursuit
of grants and other monies or tax incentives for a set period of time that would
allow for beautification to occur.
The Planning Board
supports the Goal to conserve Philipstown’s rural, historic and river community
character. Item A(i) in this section discusses
incentives for voluntary density reductions. The Planning Board does not know
what exactly this means and where it would be applicable.
Generally speaking, the
Planning Board does not believe that development density is an issue in the
Town of Philipstown given its current zoning designations and topographic
conditions. The vast majority of lands in the Town of Philipstown are two acre
zoning or greater, and because of open development regulations, the typical lot
size is six acres or greater. Voluntary density reduction is unrealistic and would
only result in higher costs of housing in the Town of Philipstown.
The second goal in this
section suggests that the Town should encourage open space development, also known
as clustering or conservation development. The Planning Board does not believe that this goal
should be in the Comprehensive Plan. There are very few circumstances
in the Town of Philipstown where clustering or conservation development makes
sense. Again, this in large part is due to the topographic conditions in the
Town infrastructure constraints and the
open development regulations.
The tools are already
in place under New York State Town Law, for the Planning Board to pursue a
cluster development, if it makes sense to do so. In such an event, the Planning Board could request authorization
from the Town Board for clustering which could be done by local law. That tool
is available to the Town at the present time; however, the Planning Board does
not believe that the encouragement of open space development given the circumstances
surrounding the Town of Philipstown has sufficient merit to include it as a
goal in the Comprehensive Plan.
Goal 1, Item b)(i) discusses dirt roads. The Planning
Board suggests that the language of this goal be changed to read: Preserve the
character of designated dirt roads. Establish a dirt road master plan.
Study the
establishment of a dirt road district that would accommodate the upkeep and
maintenance of dirt roads by those being served by the dirt road. Designate
roads to remain unpaved and preserve their character.
With regard to goal
number c) the Planning Board suggests a third goal here, to establish strict
landscaping guidelines and incorporate them into the zoning law.
Goal number 2 is directed
towards maintaining and enhancing the socioeconomic diversity of Philipstown’s
population. Goal (a)(i) suggests that accessory housing should be allowed by right.
The Planning Board believes that this goal could be dangerous and could have a large
impact on the Town’s population and its schools if implemented without further
study. The Planning Board believes that accessory housing by special permit
would provide better oversight and allow the town to better monitor its growth.
Some Planning Board members felt that
allowing accessory housing by right or by special permit on ODA roads could be
a problem. Others did not feel that
way.
Item (a)(iii) suggests
that the Town should encourage multi-family housing located in or next to mixed
used centers. Again, the Town does not have any mixed-use centers nor is it likely
that a mixed-use center would come about in any foreseeable future. This, in
essence, restricts opportunities to develop multi-family housing.
Regarding Item (a)(v) the Planning
Board suggests that this be rewritten to simply say; Encourage senior housing.
Regarding Goal
2(b), the Planning Board suggests this be rewritten to say; Promote
senior housing including senior housing that addresses local and regional
income levels and needs.
At the end of this item the Planning
Board suggests a sentence that says; Consider Planned Development Districts or other
zoning mechanisms to support senior housing in instances that would support the
overall goals of the Comprehensive Plan and the Philipstown community.
The aforementioned
represents the Planning Board’s preliminary comments on the Comprehensive Plan.
We are certain that we will have further comments to assist the Town in shaping
the plan in the best interest of the community.
Again, we request that
you keep the public hearing open or continue to accept comments until after the
SEQRA process is completed.
Thank you for your consideration.
Sincerely,
George Cleantis
Chairman,
Philipstown Planning Board
c: Planning Board
E. Doyle
S. Bates