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HomeMy WebLinkAboutPBA-09/09/2019 OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex �Qf so P.O.Box 1179 54375 State Route 25 ®� ®1 Southold,NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631765-1938 �s www.southoldtownny.gov UNT`I � CO PLANNING BOARD OFFICE RECEIVED TOWN OF SOUTHOLD r i f SEP X11 2019e4�� Q-3 ' 0', So old Town Clerk MEMORANDUM - To: Elizabeth A. Neville, Town Clerk From: Jessica Michaelis, Planning Department I*A Date: September 12, 2019 Re: September 9, 2019 Planning Board Public Meeting Attached please find the Final Agenda and Approved Resolutions from the September 9, 2019 Planning Board Public Meeting. A Records Transmittal Form has been submitted to Records Management. OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex ,e®f S®�j� P.O.Box 1179 54375 State Route 25 Southold,®�® Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold NY Telephone: 631 765-1938 www.southoldtownny.gov COU PLANNING BOARD OFFICE TOWN OF SOUTHOLD RECEIVED PUBLIC MEETING �, l 4 AGENDA SEP 1 1 201A3'o8P1V\ 0' n September 9, 2019 guthold Town,Clerk 6:00 p.m. Southold Town Meeting Hall SETTING OF THE NEXT PLANNING BOARD MEETING Board to set Monday, October 7, 2019 at 6:00 p.m. at the Southold Town Hall, Main Road, Southold, as the time and place for the next regular Planning Board Meeting. SUBDIVISIONS - STATE ENVIRONMENTAL QUALITY REVIEW ACT (SEQRA — Final Environmental Impact Statement (FEIS)) Tuthill Conservation Subdivision Final Environmental Impact Statement (FEIS) — This is to accept the Final Environmental Impact Statement for the Tuthill Conservation Subdivision. This proposal is for an 80/60 Conservation Subdivision of four parcels (total area=112 acres) into 17 residential lots, with 94 acres to be preserved. The properties are located on Main Road in Orient in the R-80 and R-200 Zoning districts. SCTM#'s 1000-17-4-16, 1000-17-6-14.2, 1000-18-3-30.3 and 1000-18-6-17.3. SUBDIVISIONS Extension of Time to Render Preliminary Plat Determination: Mazzoni Subdivision —This proposal is for a Standard Subdivision of a 22.94 acre parcel into 5 lots where Lot 1 = 2.34 acres, Lot 2 = 1.78 acres, Lot 3 = 2.18 acres, Lot 4 = 0.56 acres, Lot 5 = 16.06 acres inclusive of a 0.97 acre right-of-way, 8.58 acres of Open Space and 6 acres of a Conservation Easement held by the Peconic Land Trust (PLT) located in the R-80 Zoning District. The property is located at 500 Soundview Drive, approximately 782' to the north of NYS Route 25 and 256' to the east of Sound View Drive, Orient. SCTM#1000-13-2-8.2 Southold Town Planning Board Page 12 September 9, 2019 SITE PLANS Approval Extension: East End Tick & Mosquito Pest Control - This Site Plan is for the proposed conversion of an existing building to a single family dwelling with an attached business office with six (6) parking stalls on 0.25 acres in the Limited Business (LB) Zoning District. The property is located at 36570 Route 25, ±420' s/w/o of Skunk Lane & Main Road, Cutchogue. SCTM#1000-97-3-2 APPROVAL OF PLANNING BOARD MINUTES • July 29, 2019 • August 5, 2019 OFFICE LOCATION: - �: ,. MAILING ADDRESS: Town Hall Annex �1f , P.O.Box 1179 54375 State Route 25 .,:. Southold,NY 11971 (cor.Main Rd. &Youngs Ave.) ; -' Telephone:631 765-1938 Southold,NY -0 www.southoldtownny.gov Z' 'OUa PLANNING BOARD OFFICE TOWN OF SOUTHOLD September 10, 2019 Michael A. Kimack, Esq. 321 Riverside Drive Riverhead, NY 11901 Re: Extension of Approval Site Plan for East End Tick & Mosquito Pest Control 36570 Main Rd., ±420' s/w/o of Skunk Lane & Main Road, Cutchogue SCTM#1000-97-3-2 Zoning District: Limited Business (LB) Dear Mr. Kimack: The following resolution was adopted at a meeting of the Southold Town Planning Board on Monday, September 9, 2019: WHEREAS, this Site Plan Application is for the proposed conversion of an existing building to a single family dwelling with an attached business office with six (6) parking stalls on 0.25 acres in the Limited Business (LB) Zoning District; and WHEREAS, on January 8, 2018, the Planning Board granted approval with conditions, including one to be met prior to the Chairman endorsing the site plan, to the Site Plan shown on the survey for SCTM#1000-97.-3-2, prepared by John T. Metzger, LLS, dated November 1, 2012 and last revised March 1, 2017; and WHEREAS, on August 22, 2019, the applicant obtained Highway Work Permit #20191078547 from the New York State Department of Transportation (NYSDOT) as required by condition of approval; and WHEREAS, on August 22, 2019, the applicant submitted a letter requesting an Extension of Site Plan Approval and provided reasoning that obtaining the Highway Work Permit from the NYSDOT took longer than anticipated; and East End Tick & Mosquito Page 2 September 10;°20'i9, WHEREAS, at a Work Session held on September 9, 2019, the Planning Board reviewed the application and determined that the expired Site Plan was in compliance with current rules and regulations and granted an extension of one year to March 9, 2021; and RESOLVED, that the Southold Town Planning Board grants an Extension of Site Plan Approval for eighteen (18) months from September 9, 2019 to March 9, 2021 to the Site Plan shown on the survey for SCTM#1000-97.-3-2, prepared by John T. Metzger, LLS, dated November 1, 2012 and last revised March 1, 2017. If you have any questions regarding the above, please contact this office. s Respectfully, Donald J. Wilcenski Chairman cc: Michael Verity, Chief Building Inspector OFFICE LOCATION: 1\IA_LING ADDRESS: Town Hall Annex Q�•45 P.O.Box 1179 54375 State Route 25 �Q 4 Southold,NY 11971 (cor.Main Rd. &Youngs Ave.) Southold,NY ;•n Telephone: 631 765-1938 cn www.southoldtownny.gov PLANNING BOARD OFFICE ` TOWN OF SOUTHOLD September 10, 2019 Karen Hoeg, Esq. Twomey, Latham, Shea, Kelley, Dubin & Quartaro, LLP P.O. Box 9398 Riverhead, NY 11901 Re: Extension of Time to Render a Preliminary Plat Determination Proposed Standard Subdivision for Mazzoni Located at 500 Soundview Drive, approximately 782' to the north of NYS Route 25 and 256'to the east of Soundview Drive, Orient SCTM#1000-13-2-8.2 Zoning District: R-80 Dear Ms. Hoeg: The Southold Town Planning Board adopted the following resolution at a meeting held on Monday, September 9, 2019: WHEREAS, this proposal is for a Standard Subdivision of a 22.94 acre parcel into 5 lots where Lot 1 = 2.34 acres, Lot 2 = 1.78 acres, Lot 3 = 2.18 acres, Lot 4 = 0.56 acres, Lot 5 = 16.06 acres inclusive of a .97 acre right-of-way, 8.58 acres of Open Space and 6 acres of a Conservation Easement held by the Peconic Land Trust (PLT) located in the R-80 Zoning District; and WHEREAS, the Southold Town Planning Board, pursuant to the Southold Town Code, has 62 days to render a Preliminary Plat Determination after the Preliminary Plat Public Hearing is closed; and WHEREAS, the Preliminary Plat Public Hearing was closed on July 9, 2018; and WHEREAS, Southold Town Planning Board and the applicant have mutually agreed to extend the timeframe to render a Preliminary Plat Determination from August 5, 2019 to January 6, 2020; therefore be it Mazzoni Standard-Subdivision Pae 12 September 10, 2019 RESOLVED, that the timeframe to render a Preliminary Plat:Determination is hereby mutually extended from August 5, 2019 to January 6, 2020. If you have any questions regarding the information contained in this resolution, please contact the Planning Board Office. Respectfully, ; Donald J. Wilcenski Chairman 5 OFFICE LOCATION: AL&ILING ADDRESS: Town Hall Annex P.O.Box 1179 54375 State Route 25C , Southold,NY 11971 (cor.Main Rd. &Youngs Ave.) Telephone:631765-1938 Southold,NY • www.southolc1townny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD September 10, 2019 Mr. Reginald Tuthill Tuthill Oysterponds Holding Company P.O. Box 86 Orient, NY 11957 Re: SEAR FEIS Acceptance Determination Proposed Tuthill Conservation Subdivision Located at 21505 Route 25 SCTM#1 000-17-4-16, 1000-17-6-14.2, 1000-18-3-30.3, and 1000-18-6-17.3 Zoning District: R-80 and R-200 Dear Mr. Tuthill: The Southold Town Planning Board adopted the following resolutions at a meeting held on Monday, September 9, 2019: WHEREAS, on March 23, 2016 the Southold Town Planning Board, as Lead Agency, found that the Draft Environmental Impact Statement (DEIS) for the Tuthill Conservation Subdivision dated February 11, 2016 inadequate for public review; and WHEREAS, on, September 14, 2018 the applicant submitted a revised DEIS; and WHEREAS, on January 28, 2019 the applicant submitted a one page amendment to the original DEIS submission which has also been reviewed; and WHEREAS, on February 10, 2019 the Planning Board determined the DEIS to be adequate and ready for public review; and WHEREAS, on March 11, 2019 a public hearing on the DEIS was held and extended for two weeks for written comment to March 25, 2019; and WHEREAS, the Planning Board found that the number and content of substantive public comments on the potential moderate to large impacts to cultural resources required further coordination with the New York State Office of Parks Recreation and Historic Preservation and Native American Tribes, and F ,ith ill Cc !: setvat! a !l Page ? September 10 , 201 -0 S ib -,' ivj -, ion WHEREAS, this coordination involved numerous meetings and site visits to the North Brown and South Brown properties and prompted the need to extend the completion time to prepare the FEIS; therefore be it RESOLVED, that the Southold Town Planning Board, pursuant to the State Environmental Quality Review Act, hereby accepts the Final Environmental Impact Statement (FEIS) for the Tuthill Conservation Subdivision, dated as received September 9, 2019; and be it further RESOLVED, that the Southold Town Planning Board hereby authorizes the Planning Board Chairman to submit the Notice of Completion pursuant to Part 617 of the implementing regulations pertaining to Article 8 of the Environmental Conservation Law. If you have any questions regarding the information contained in this resolution, please contact the Planning Board Office. Respectfully, Donald J. Wilcenski Chairman Enck cc: Scott Russell, Southold Town Supervisor Southold Town Clerk for Southold Town Board ; Southold Town Zoning Board of Appeals Southold Town Building Department ; Southold Town Engineer Southold Town Police Department Southold Town Local Waterfront Revitalization Program Coordinator Southold Town Architectural Review Committee Southold Town Highway Department Southold Fire District Suffolk County Department of Health Services Suffolk County Water Authority Suffolk County Planning Commission Suffolk County Legislator NYS DEC - Stony Brook NYS DEC - Commissioner NYS Department of Transportation NYS Department of State NYS Natural Heritage Program Environmental Notice Bulletin File FINAL ENVIRONMENTAL IMPACT STATEMENT TUTHILL OYSTERPONDS HOLDING COMPANY HAMLET OF ORIENT,TOWN OF SOUTHOLD SUFFOLK COUNTY,NEW YORK PROJECT LOCATION: Orient,Town of Southold,Suffolk County,New York SUFFOLK COUNTY TAX MAP NUMBERS: Sections 1000-17.-4-16 1000-17.-6-14.2 1000-18.-3-30.3 1000-18.-6-17.3 1000-18.-6-18.1 APPLICANT: Tuthill Oysterponds Holding Company Contact: Carol Tuthill,Managing Director Tuthill Oysterponds Holding Company s LEAD AGENCY: Town of Southold Planning Board P.O.Box 1179 54375 Main Road Southold,New York 11971 Contact: Donald Wilcenski, Chairman (631) 765-1938 PREPARER & CONTACT: This Final Environmental Impact Statement was prepared by: Town of Southold Planning Department Southold Town Annex 54375 State Route 25 P.O.Box 1179 Southold, New York 11971 Contact: Mark B.Terry, AICP Assistaiit Tmwn Planning Directnr (631) 765-1938 DATE OF PREPARATION: September 2019 AVAILABILITY OF DOCUMENT: This document,together with the Draft Environmental Impact Statement(DEIS),is the Final Environmental Impact Statement (FEIS). It has been prepared for the Lead Agency. Copies are - available for public review and comment at the offices of the Lead Agency,54375 Route 25, Southold,New York 11971.This FEIS is also available electronically at the following address: http:l/www.SOLl thold townny_gov, DATE OF FILING: September 11,2019 a This document is a Final Environmental Impact Statement(FEIS)for the Tuthill Oysterponds Holding Company This FEIS incorporates,by reference,the Draft Environmental Impact Statement(DEIS)for this proposed action, submitted February 11,2016 and revised September 14,2018.The above- referenced DEIS was the subject of a Town of Southold Planning Board Public Hearing on March 11,2019, and written comments on the DEIS were accepted until March 25, 2019. The Written Correspondence and Public Hearing Transcript are provided in Appendices A and B of this FEIS,respectively. TABLE OF CONTENTS ' ~~~^...^^~^ ....................................................................................................................................-,.........................- l'1 Format ofFEIS ....... .......=-_-,..................... ...... ~ ...........................2 � DEISConoumrtsundResponses...............................................................................................................................3 2.1 Comments inGeneral Support ofthe Proposed Action.......................................................4 2.2 Comments buGeneral Opposition ofthe Proposed Action..................................................4 � � 2.3 Responses toSubstantive Comments......_-,r.............. ...... --�r�r-----------II ` / 2.31 Water °^ .. � ................................. _' _-_1� ' ''' .` r~^~'~ '-~^ '' ' 2.32 Vegetationand Wildlife,Utilities and Storm Water .....................16 � 2.3.3 Transportation, Safety and Access .~" ........°.........................,,-~'20 � � 23.4 Land Use and Zoning ................ . ....... ....... ........................ ...........23 ^ � 2.3.5 Aeatbetics .----...-.----.,—..-......-... ...... ............... .......24 ` 23.6. Cultural Resources ..............................' .............. ,.,°'...`..31 ' ' 2.37 Process .......... ................._ ...... ............................'............... ...... APPENDICES ~.4U � � � Appendix A-Writteo Correspondence ' Appendix B-Public Hearing Transcripts March ll, 20l9 ' Table of Cojitejits � LIST OF FIGURES f Figure 1. Town of Southold Orient Historic District Map overlay on the South Dyer parcel.....37 Figure 2. NYS Cultural Resource Information System Orient Historic District Boundary and area on the South Dyer parcel where a Phase IB Archeological Survey was conducted(Green Polygon)........ , ...................................... ......................... ...........38 i Table of Contents Introduction This document is a Final Environmental Impact Statement(FEIS) prepared in accordance with the State Environmental Quality Review Act(SEQRA) 6 NYCRR 617.9(x)(5), and in response to comments received by the lead agency, the Town of Southold Planning Board (hereinafter the s "Plaiuzing Board"), on the Draft Environmental Impact Statement(DEIS)for the proposed action, dated September 14, 2019. The DEIS for the proposed action was accepted by the Planning Board, as complete and adequate for public review, on February 11,2019, and circulated to all the involved agencies and interested parties, and a public hearing was held on March 11, 2019 and the comment period was held open until March 25,2019. In accordance with 6 NYCRR§617.9(b)(8): A final EIS must consist of. the draft EIS, including any revisions or supplements to it; copies or a sumnianj of the substantive comments received and their source(whether or not the connnents were received in the context of a hearing);and the lead agency's responses to all substantive comments. The draft EIS may be directly incorporated into the final EIS or may be incorporated by reference. The lead agency is responsible for the adequacy and accuracy of the final EIS, regardless of who prepares it.All revisions and supplements to the draft EIS must be specifically indicated and identified as such in the final EIS. All written correspondence received during the comment period is included in Appendix A of this FEIS, and the Public Hearing Transcripts are included in Appendix B. 7 1.1 Format of FEIS Among the comments received on the DEIS,multiple commenters expressed general support or opposition for the proposed action (see Appendix A and Appendix B).While these comments are included in the aforementioned appendices, they are not"substantive comments" as contemplated in 6 NYCRR§617.9(b)(8), and, therefore, are not individually addressed in this FEIS. All verbal comments made during the public hearing held on March 11,2019, were assigned a code that begins with "H." Each commenter who provided written correspondence in response to the DEIS was assigned a code beginning with"W." All written comments are provided in their entirety in Appendix A. 5 The hearing transcript,with comment designations,is included in Appendix B of this FEIS. Section 2.0 provides a complete list of commenters with their assigned code. Substantive comments were primarily related to the following topics and have been categorized as such:Water Resources,Vegetation and Wildlife,Transportation, Safety and Access, Land Use ; Zoning, Aesthetics and Process. The written and hearing comments have been paraphrased, since, in many cases, more than one commenter made the same or similar comment. 2 DEIS Comments and Responses All written correspondence is included in Appendix A of this FEIS. The public hearing transcripts are included as Appendices B (March 11, 2019). The following sections summarize the comments set forth in the written correspondence and stated during the public hearings, and provides responses to substantive comments.The following is a list of commenters whose substantive comments are addressed herein. Note that commenters who offered substantive comments in more than one piece of written correspondence or at more than one of the public hearings,will appear in the list multiple times.Both substantive and general comments, in either support or opposition of the proposed action, are included in the list. ,Public Hdaring—March 11,2019 Commenter Code Lyle Tuthill HI Edward Webb H2 Joel Klein,Ph.D. H3 Suzanne Horton H4 Venetia Hands H5 Nancy Kardwell H6 Jesse Gordon H7 Jerry Newman H8 Deborah ivlarkland H9 Glynis Berry H70 3 "Written Correspondence Commenter Code John&Thanne Dispenza W1 Orient Association W2 Joel I.Klien,Ph.D. W3 David Backus W4 Kenneth Terry W5 Jerie R.Newman W6 f Mary Morgan W7 Deborah Marland W8 James Haag W9 Barry Bergdoll&William W10 Carmela Constantino W11 Barry Bergdoll&WilIiam W10 ` 2.1 Support of the Proposed Action H7 -Lyle Tuthill > General support of project and the conservation subdivision approach. 2.2 Comments in General Opposition of the Proposed Action H2—Edward Webb -SouthDver > Concerned about the lots located on South Dyer and within the Orient Historic District. > DEIS incorrectly states that the subdivision parcels are adjacent to the Orient Historic District. 4 > Any construction on the lots located within the Orient Historic District will be subject to review by the Historical Preservation Commission. > The DEIS does not show how the visual setting of the Orient Historical District would be affected. > The DEIS does not mentioned individually,listed Town landmarks that are within or close to lots. > The DEIS implies that it will be the applicant who will determine what is appropriate, > Requests a Supplemental Environmental Impact Statement to address the identified outstanding issues. T 3 Joel Klin > Concerned about the adequacy information in the DEIS pertaining to historic and archeological properties. > Concerned that potential impacts to the Orient Historic District have not been adequately considered. > No View Shed Analysis was carried out with this project.The Visual Impact Study that was performed for the project was a study of the aesthetic impact of the project on the Route 25 scenic byway.It did not specifically address visual impacts to historical properties,most significantly, the Orient Historic District and numerous historic structures along Route 25 located outside the Historic District. > The DEIS is deficient in how it deals with potential impacts to archeological sites. > Concerns on the protection of the previously known Native American Sites on South Brown; ; an expected major habitation site. No attempt was made to delineate boundaries of this site within the South Brown parcel, apparently,because the investigator recommended a Phase Two intensive testing investigation to collect more information.However,he also states that this need not be done until prior to groundbreaking or construction.This was a serious error for several reasons: One, the absence of a specific condition in the site plan approval, the applicant cannot be required to conduct any archeological investigations and two, the discovery of a significant archeological site on a given parcel either before or during construction could render the parcel unusable or usable only after the expenditure of considerable sums to salvage any discovered remains—which could include human remains —in this case. > The Phase Two investigation should have been required as part of the DEIS process to eliminate the potential problem of a discovery being made on an approved buildirng lot by allowing the relocation of the proposed lot outside the limits of the archeological site and provide more permanent preservation of the archeological site within the conservation subdivision. > The NY State Historic Preservation Office (SHPO) has never commented on the Phase 1-B report or concurred with its recommendations- although it was submitted to the SHPO somehine prior to the spring of 2018. The reason for this is that on June 11, 2018, the SHPO requested that the Planning Department provide updated project plans because the areas investigated during the Phase 1-B study: "" ..do not correspond with the area of potential fact that was initially submitted for this project." > The final DEIS contains only a single pdge of uiigiiidl test dealing with historic resources including archeological sites. Only foto-sentences deal with archeology. > The DEIS also includes the three page text of the Phase 1-B report,but the 50 pages of maps, photos and data appendices have been redacted, it is unclear why this was done. > Concerns about how the DEIS process was handled;no formal scoping was done for this project. > Concerns about the organization of the DEIS and why some people could access the documents and others could not. H4—Suzanne Horton > What are the guarantees associated with that land never being built upon in the future? > It is R-80 zoning,which usually you have two acre lots. Is that part of a deal to give up that conservation land from preservation so that they can get smaller lots in that area for their family? H5 Venetia Hands -South Dyer > Glad it's an 80-20 conservation subdivision. > Wants to know what size the houses shown in the Visual Impact Study on South Dyer are, what is the actual square footage of those houses being represented there? > Concerned that the Visual Impact Analysis does not show the maximum house size. > Concerned that there are not regulations that mandate that the future homes are designed to fit into Orient in style and size. > We are told by the Visual Impact Study that there are lots of houses in Orient that are at least 40,000 square feet.Yeah,has anyone seen one of those?Would you tell me where they are so we can go look at them please?And would you tell us what size Iot they're on?Are they on an acre?And how visible they are from Route 25? > Is there some way the family can specify a limit on house size?Something less than maximum build out?And what might that limit be? > I'm wondering if there's a way that the Tuthill family, and you, can set a limit of 6,000 square feet then to the houses that can be built there? > Asked the Planning Board to confirm what square footage is shown for each house in the Visual Impact Study on South Dyer. > Does this acreage fall within the Orient Historical Preservation District?And we've heard about that and what does that mean? > Will homeowners and builders be required to install the most advanced wastewater systems available at the time that they build, in all of these lands? > And I think this is what I understand is the difference between Visual Impact and View shed, we're looking only from Route 25. > View shed was very limited in the Visual Impact Study.What happens if you're standing on Skippers Lane? Or Oyster Ponds Lane?Or even in your garden on Village Lane on the back? What happens when you're looking, when you're out sailing?It hasn't been looked at in its totality l-lta—t�lanc,r (.:arCf���t�ll > Is the height restriction of the house 35 feet in Orient? > Concerned about water supply. t; > If the town has looked into (water supply) and if there is any plan for moratorium on building that's in the present or in the future? > Very supportive of their efforts. Hi Jesse Gordon.-North Brown > North Brown—Requests that the access road be placed on western end (boundary) of lot due to fewer homes,better safety and less curb cuts. > Relocation of the road would be better ecologically and not break up three farms fields trying to preserve as open land.Utility lines and power poles would run through middle of lands that trying to be preserved. > Did not see any analysis of the impact that the construction of those parcels would have on the bluff. > Requests that the Planning Board insist upon an analysis of the stability of that bluff and the impact of all the drainage from that area(lots and farm)is going to have on that bluff. H8—Deborah Marland > Concerned about timeframe to answer questions. H9— erie Newman -Sou th Deer > Concerned about devaluation of property with view interrupted from residence. H10—Glynis Berry—South Dver > Required clarification of process. > What happens if we discover that these markup houses are 4,000 square feet footprint and 8,000 square feet totality—what are you going to do? W1 -,Tohn and Thanne Dispenza-South Over > Concerned with the four lots proposed on South Dver and how it will impact the view of shed of Orient and Oysterponds Lane. > Recommends the approval of two lots rather than four with the remaining transferred to one of the three other parcels. W2—Orient Association —South Dver > Voices appreciation for the TuthilI's to undertake a Conservation Subdivision. > Seek an accurate rendering of house sizes in the visual impact study conducted for South Dyer > Mentions Orient Hamlet Plan and resident endorsement of maximum allowable house sizes and to preserve view sheds. > Requests Thal the Tuthill Subdivision Visual Impact Study accurately depict the maximurn allowable house size to the bulk schedule regulations without accessory structures. > Concerns about the R-80 and R-40 setbacks and the possibility of a 16,000 square foot homes. 7 > Concerned that the visual impact study did not take into account Oysterponds Lane and Skippers Lane. > Identifies the 4 lot option on South Dyer as the preferred option. > Recommends the use of I/A OWTS. W3-Toe] Klein > Concerned about the adequacy information in the DEIS pertaining to historic and archeological properties. > Concerned that potential impacts to the Orient Historic District have not been adequately considered.The Orient Historic District is not adjacent to the project, the five proposed South Dyer building lots and their associated house are all located within the district. > No View Shed Analysis was carried out with this project.The Visual Impact Study that was performed for the project was a study of the aesthetic impact of the project on the Route 25 scenic byway.It did not specifically address visual impacts to historical properties, most significantly, the Orient Historic District and numerous historic structures along Route 25 located outside the Historic District. > Views observed by pedestrians,bicyclists, and motorists traveling through the Orient Historic District, particularly along Racketts Court, OysterPonds Lane, and Skippers Lane, will be changed to an unknown degree (unknown because these views, which are clearly within the Project viewshed, were never considered during the impact analysis).Views both of and from several individual historic properties within the Orient Historic District, which are also designated Southold Historic Landmarks, will also be affected > The DEIS is deficient in how it deals with potential impacts to archeological sites. > Concerns on the protection of the previously known Native American Sites on South Brown; an expected major habitation site. No attempt was made to delineate boundaries of this site within the South Brown parcel, apparently,because the investigator recommended a Phase Two intensive testing investigation to collect more information. However,he also states that this need not be done until prior to groundbreaking or construction.This was a serious error for several reasons: One, the absence of a specific condition u1 the site plan approval, the applicant cannot be required to conduct any archeological investigations and two, the discovery of a significant archeological site on a given parcel either before or during construction could render the parcel unusable or usable only after the expenditure of considerable sums to salvage any discovered remains—which could include human remains —in this case. > The Phase Two uivestigation should have been required as part of the DEIS process to eliminate the potential problem of a discovery being made on an approved building lot by allowing the relocation of the proposed lot outside the limits of the archeological site and provide more permanent preservation of the archeological site within the conservation subdivision > The SHBO has never commented on the Phase 1-B report or concurred with its recommendations- although it was submitted to the SHBG sometime prior to the spring of 2018 The reason for this is that on June 11, 2018, the SHBO requested that the Planning Department provide updated project plans because the areas investigated during the Phase 1-B study. "...clu iiot co,iespond with the area of potential fact that was initially submitted for this project." Is > The final DEIS contains only a single page of original text dealing with historic resources including archeological sites. Only four sentences deal with archeology. > The DEIS also includes the three page text of the Phase 1-B report,but the 50 pages of maps, photos and data appendices have been redacted,it is unclear why this was done. > Concerns about how the DEIS process was handled;no formal scoping was done for this project. > Concerns about the organization of the DEIS and why some people could access the documents and others could not. ; W4•—David•:B'akus.—Nyrth B'rdwn > Concerned about the location of the access road on North Brown and adverse impacts on farming,vistas and wildlife habitat. W5—Kevin Terr`u > Concerns about adverse impacts to the aquifer.Mentions that the aquifer is sole source and periods of drought. > Mentions surface contamination to the aquifers by chemical or environmental contaminants. Identifies impacts and fresh water well contamination in Orient from the use of Aldicarb,a toxic pesticide now banned.Residents had to filter water using carbon filters. > Requests that a hydrogeoloo c impact assessment be included that addresses saltwater intrusion and sea level rise. ; W6.-Eerie R.Newman--South Liver > Very concerned about impacts to the scenic view from her property at 790 Oysterponds Lane. W7-1,tiry Morgan—North grown > Concerned about the increased traffic and pedestrians on NYS Route 25. > Requests that the access road for the North Brown parcel is placed on the west property boundary where existing access road (farm road) currently exists. W8—Deborah Marland—North Brown > Concerned about the proposed access road on North Brown parcel and the proximity to existing homes.There are 6 homes on the eastern border and 2 on the east. > Proposes to move the access road frown the east to the west border. > Identifies advantages of such a move as it would create one curb cut, lessen chances of accidents from ferry traffic and a lower elevation with less runoff. W9 1a hi s 1-Iag'- > Identifies the character of Orient as important and is concerned about the 17 lots adversely impacting the community and scenic character. 9 W10—Barry Ber4ddlI&.William Ryall—North Brown, > Requests that the access road for North Brown parcel be located on the west property line. > The eastern edge is occupied by a hedgerow and property what is protected by a conservation easement.Relocation of the road would prevent the interruption of protected ; lands(landscape). > Would also concentrate accesses. Y W1 1 -C armela"Gonstantino�—North Brown > Concerned about the proposed access road on North Brown parcel and the proximity to existing homes. Noise and dust from the road. > Proposes to move the access road from the east to the west border. > Identifies advantages of such a move as it would create one curb cut, lessen chances of accidents from ferry traffic and a lower elevation with less runoff. W12--Io Ann Crinstali'tulo—North Brown > Concerned about the proposed access road on North Brown parcel and the proximity to house, disturbance and storm water. Noise and dust from the road. > Requests to move the access road from the east to the west border. W13—Mary Ellen Stevens s > Opposed to proposal and alternative. > Concerned about the SEQRA assessment and adverse impacts on the environment from fertilizers, chemicals, water supply,fishing and shellfishing. > Concerned about impacts to open space on South Dyer and visual impacts. > Concerned about the disturbance to Orient Historic District. > Requests a housing size limit, controls on water usage and adverse impacts on scenic character and water quality. > Would like all subdivisions to stop. r W14—Leslie Black Robeft Black. Rick Pevsei-and tan Poyser > General opposition. > Concerned about the adverse impacts on the environment,history aesthetic and community character iiuludnhg building in the Orient Historic District. > , Concerned about the building of large homes_ > Requests that no variances from zoning or lot size be granted. > Requests moratorium on permitted house sizes. VV14—Alex Pearlstein and Bill Adanhs—North Brown > Concerned about the traffic and safety on SR 25. > Requests moving access road on North Brown parcel to ivestern edge. > Identifies eastern side location as dangerous. > There are two parallel dirt roads on the western edge that could become subdivision road. 10 > Close proximity of 6 houses on east side and only 2 on west side. > There is animal habitat on eastern border that would be destroyed,potential for disruption by utilities,risk of runoff and higher elevation. W 15-=William'MrNnught--North Brown > Concerned about the location of the access road on North Brown,the proximity of 6 houses < and adverse impacts. > Mentions the adverse impact to farmland views. > Requests moving access road on North Brown parcel to western boundary. 2.3 Responses to Substantive Comments 2.3.1 Water Resources Comments C2 C5 C13` Commenters voiced concerns on water resources and the potential adverse impacts to groundwater quantity from use and groundwater and surface water quality from sanitary waste. Response 1. Impacts from Sanitary Waste Disposal The DEIS states that the submission of an 80/60 Conservation Subdivision significantly reduces the number of sanitary systems and flow from Standard Subdivision density (from 42 residential lots to 17) thereby further mitigating moderate to large adverse impacts to the ground and surface waters. The development of a Standard Subdivision representing the maximum development allowed under existing zoning is included in the DEIS as Alternative 3. Under the proposed action, a total of 70.87 acres of buildable lands will be permanently preserved through the expected sale of development rights Overall, 95.91 acres or 85 percent of the combined 112 84 acre parcels total will be preserved. The DEIS calculates the annual water consumption for the 17 single family residences at 300 gallons per day for each lot or 5,100 gallons per day total (Page 18). Originally the initial and revised submission of the DEIS included a statement that"traditional septic systems will be used on our 17 lots". However, in a January 27, 2019 email sent to the Planning Board, the applicant offered further mitigation by agreeing to install a sanitary system with the technology to reduce nitrogen thereby mitigating potential adverse impacts on ground and surface water quality.The installation of these types of systems is discussed in the DEIS as Alternative 4 (Page 34) I1 Significant advances in the Suffolk County Department of Health Services(SCDHS)regulatory framework to allow the installation of I/A Onsite Wastewater Treatment Systems (I/A OWTS)have occurred in recent years that were not available when the Positive Declaration was issued by the Southold Planning Board.The installation of these types of treatment systems are now required as policy by the Planning Board on each newly created lot in Orient to mitigate the cumulative,long term, adverse impacts from nitrogen to ground and surface waters(Orient Harbor/Peconic Bay, Munn Pond,Long Island Sound and Narrow River/Hallock Bay). The required use of I/A OWTS systems would achieve the following: 1. A reduction in Nitrogen loading to the sole source aquifer. 2. A reduction in Nitrogen loading to surface waters. Each residential lot will be required to install a I/A OWTS system approvable under Suffolk County's Innovative and Alternative On-site Wastewater Treatment Systems Program (aka Article 19).The program allows the installation of new residential septic systems that will treat nitrogen in wastewater to 19 mg/L or less and will help mitigate impacts to water resources from nitrogen pollution.The specific system design to be utilized in the subdivision has not yet been chosen due to the expected technological advancements in sanitary waste treatment options by the time the ; single family residences are constructed. Impacts from sanitary flow will be minimized through the reduction in residential density and the installation of I/A OWTS on each residential lot and therefore,moderate to large adverse impacts are not expected.The DEIS points out that the continued operation of an aquaculture business on the South Dyer parcel that grows and harvests oysters also contributes to the removal of nitrogen in surface waters. 2. Impacts on the Sole Source Aquifer Concerns on Adverse Impacts to Ground Water Quality All parcels are located withuz Suffolk County Department of Health Services (SCDHS) Groundwater Management Zone IV The parcels are not served by public water and new private wells will be required to provide potable water to each future residence.Potable water supply to Orient is sustained from a sole source aquifer and the protection and conservation of ground water is critical due to the geography and geology of the Orient penirisula.The following challenges pose a threat to providing sustainable, potable, water supply to Orient: 1 Shallow freshwater lens and saltwater intrusion. 2. Overuse of potable water in irrigation. 3. Degradation of groundwater-quality from the use of chemicals and fertilizers. 4. Sanitary waste disposal. The freshwater lens underlying each parcel is expected to be shallow and saltwater intrusion through upconing in the future is probable due to use and sea level rise.Upconing occurs when a well pumps water to the surface from a single point in the freshwater lens essentially pullvig up the underlying salt water to the well head. 12 Water quality tests were conducted on each parcel to confirm that potable water is currently available.Results indicate that the saltwater interface occurs 42'+below grade on the North Dyer parcel.The interface mark is the point where freshwater and saltwater,meet. Above the interface mark, a freshwater lens is available to provide potable water.At the North Dyer parcel location, freshwater was encountered at 16' and 18' below grade.The area of freshwater saturated soils occurs between the 16' elevation and 42' elevation and indicates that the freshwater lens is approximately-26'+in depth and shallow.Due to the expected shallow depth of the freshwater lens; the potential of saltwater intrusion in private wells is high if overuse of potable water occurs and conservation measures are not applied. The hydrologic data presented is consistent with findings of the freshwater lens in Orient in areas of higher elevations toward the Long Island'Sound.However, properties at lower elevation,such as South Dyer and South Brown would exhibit a decrease in separation distance between grade and fresh water(depth to groundwater) and the sustainable supply of potable water would most likely require filtering or treatment(i.e.ion exchange, distillation or reverse osmosis) in the long term.The DEIS indicates that the depth to ground water on South Dyer ranges from 9' to 14' on the sampled lots. On South Brown ground water was encountered at 7'. As indicated in the DEIS, the availability of potable water on each parcel was confirmed through a series of test wells and water quality analysis performed by Suffolk County Department of Health Services.Test well water quality results identifies sodium levels in groundwater ranging from 11.6 to 59.5 mg/L.These levels meet the United States Environmental Protection Agency Drinking Water Advisory Consumer Acceptability Advice and Health Effects Analysis on Sodium (2003) that recommends reducing sodium concentrations in drinking water to between 30 and 60 mg/L based on esthetic effects (i.e., taste) and to 20 mg/L for individuals restricted to a total sodium intake of 500 mg/day. All water quality test results met EPA guidance on sodium levels in drinking water, New York Department of Health Drinking Water Standards and SCDHS test well standards.The SCDHS will require that additional test wells be conducted (one per lot) to confirm that the water well installation can be achieved in accordance with guidelines. A concern was raised on the threat to potable water quality from the application of fertilizers and herbicides.The DEIS indicated that there are no pesticides outside of standards on any of the four parcels based on test well data (Page 21). The applicant has agreed to include the following Best Management Practices in Homeowners Association documents and or Covenants and Restrictions to prevent the degradation of ground and surface water quality. 1. Using native, drought-tolerant}Tants 2 Fertihzer applications- (7 riitro<;en, phosphorous, or potassium only between November 1 and April 1 b Lawn Fertilizer Applicatiorrs- i. Orli/if more tliari 20'away front surface venter or zvithiii 3'of a 10'+ve,Setative border, or within 3'o1 siii face water if the spreader has a guard deflector shield or i,,, a drop spieader 13 it Only organic fertilizers where the water-soluble nitrogen is no more than 20% of the total nitrogen in the mixture may be utilized on the lots. iii. Maximaiin of 1 pound of nitrogen per 1,000 sq.ft in any one application, with a cumulative application of no more than 2 pounds per 1,000 sq ft per year iv. Phosphorus containing lawn fertilizer is prohibited unless establishing a new lawn or soil test shows that the lawn does not have enough phosphorus. The phosphorous level must be 0.67 or lower unless a soil test indicates it's needed. Additionally the subdivision design includes one-hundred foot wide non-disturbance buffers on North Dyer and North Brown to reduce turf and landscaped areas requiring irrigation and requires clearing limits to be imposed on each lot Pursuant to§240-49. Clearing of the Southold Town Code. The South Dyer, North Brown and South Brown parcels in active agriculture are encouraged to implement Agricultural Stewardship Programs that are currently implemented by Suffolk County and the Cornell Cooperative Extension of Suffolk County to improve agricultural BMPs by reducing the amounts of nitrogen and pesticides reaching ground and surface waters. Farm operations are also encouraged to participate in the New York State Soil and Water Conservation Committee Agricultural Environmental Management(AEM)program; a voluntary, incentive- based program that helps farmers make common-sense, cost-effective and science-based decisions to help meet business ob)ectives while protecting and conserving the State's natural resources. More information on the New York State AEM program can be found at: httla:l/���w>-�r.nys-soi land s�it�tr�r.c�rYg/��c�r�i,lindex.l7tti�1 Moderate to large adverse impacts on groundwater quality are not expected. Concerns on Adverse Impacts on Water Quantity As stated above, the annual water consumption for the 17 single family residences is estimated at 5,100 gallons per day (gpd) Traditionally, around 40 percent or 2,040 gpd of the 5,100 gpd is expected to be lost to irrigation with anticipated recharge loss (e.g. surface runoff, evapotranspiration) to the aquifer.The document concludes that: " . our project would not have a measureable impact on the existing and,fit ture ground zoater supply and therefore would not have an impact on the private or 00711717077 wells adioiriing our properties (zone of inftucnces). Although the statement supports a lack of short term impacts, the use ofpotable water to irrigate turf and landscaped areas poses a significant, long term adverse impact to the sustainability of the groundwater resources in Orient. The long tern influence of all proposed and existing wells drawing potable water from the sole source aquifer could result in adverse impacts to water duality and quantity increasing the risk of saltwater intrusion acid sliurtage5 uvei [he long term. During dry periods, the threat becomes more severe. Water conservation practices would mitigate the long term adverse impacts to groundwater quantity.These practices protect the proposed private wells and the neighboring wells (located 14 within 150' of each lot)from potential saltwater intrusion, shortage and degradation of water quality. Water Conservation Practices 1. Limit irrigated areas on each lot. 2. Require smart irrigation practices (rain sensors). 3. Install low flow wells with a maximum 10 gallons per minute (gpm)flow rate. 4. Space wells evenly and as far from the edge of the shore as possible to minimize saltwater intrusion. Potential adverse impacts to water quality and quantity of the sole source aquifer will be partially mitigated though the preservation of 95.91 acres of unbuildable and buildable acres of farmland and woodland on the 4 parcels,the reduction in residential density, and the installation of I/A OWTS.Further mitigation is necessary to minimize the adverse impacts to the greatest extent practicable.This mitigation includes the implementation of the above water conservation practices, and BMP's and faun management programs developed to reduce adverse impacts on the 3 environment, as described above. Significant adverse impacts to groundwater quantity are not expected. 2.3.2 Vegetation and Wildlife,Utilities and Storm Water "'Comments H7,'W4,.W14 Concerns were raised about the location of the access road on North Brown and the potential adverse impacts on animal habitat on the eastern border and from the placement of utilities and storm water runoff. Response Potential Adverse Impacts to Wildlife Habitat Specific concerns were raised on how the construction of the right of way on the eastern property boundary of the North Brown parcel would adversely impact wildlife and habitat due to the clearing of vegetation. The vegetation on the North Brown parcel is comprised of wooded areas located in the south against New York State Route 25 and in the north of the parcel and three wooded windbreaks along the east and west property boundaries and between the cultivated fields.The habitats on-site are not significant in size and are impacted by existing residences, roadways and cultivated fields.The habitats are expected to support wildlife indicative of woodland habitat and neighborhood settings (large and small mammals, reptiles, amphibians and avian spp.). Vegetation on both the east and western property boundaries are unremarkable and similar in composition and the wildlife use is expected to be bmulau ui species composition. The wmdbreaks are expected to offer food and cover opportiunities to avian spp. and small mammals. 15 The construction of the access road would involve the clearing of vegetation including a portion of the larger area of woodland in the north of the parcel and the windbreaks on the eastern property line.The heavily wooded area in the north of the North Brown parcel against the Long Island Sound bluff will be preserved through a 100' wide non-disturbance buffer and limits of clearing required by Southold Town Code applied to each residential lot. "Potential Adverse,impacts.cin Protected Species The DEIS discusses the presence or absence of protected species on all parcels and includes a response from the New York State Natural Heritage Program(NYSNHP)dated September 15, 2016. Based on the species and associated habitats listed in the response compared to those on each parcel, the discussion concluded that there is a low probably of the occurrence of protected animal species on each parcel,including North Brown. Eastern Box Turtle and Northern Long Eared Bat It is recognized that the protection of slow moving animals including reptiles and amphibians should be a priority during all clearing operations. Habitat types on site are suitable for the eastern box turtle(Terrapene carolinn) and other reptiles and amphibians.The box turtle is a Species of Special Concern in New York State. To minimize adverse impacts,best management practices to prevent the injury or death of animals should be taken during clearing and grading operations. Walkthroughs of each area prior to clearing could be conducted and all animals that can be captured be relocated to outside of areas to be cleared. The NYSNHP response failed to include the northern long eared bat(Myotis septentrionnlis) and therefore the DEIS impact on Plants and Animals discussion does not include the species.This omission was most likely due to the fact that the information provided by the NYSNHP reflects only occurrence records within their database. The following corrects the omission in the DEIS. The DEIS excludes the potential occurrence of the long eared bat on the North Brown (North Dyer and South Brown parcel also). The northern long-eared bat (NLEB) is listed as federally-threatened by the United States Fish and Wildlife Service (USFWS) under section 4(d) of the federal Endangered Species Act of 1973, due to significant population declines as a result of the white-nose syndrome fungal disease which is found in Suffolk County populations. The DEC identifies all four parcels as located within a Confirmed Summer Occurrence area. The USFWS final 4(d) rule for NLEB (effective February 16, 2016) includes certain prohibitions against incidental taking, which is defied as killing, wounding, harassing or otherwise disturbing a species that occurs incidental to, and is not the purpose of, an otherwise lawful activity. The DEC provides the following guidance for projects that result in a change of land use in areas of occupied habitat.The proposal to subdivide the parcels into residential lots constitutes a change of use. NYSDEC Recommendations for Northern Long Eared Bat Ful prujecls iequii ing tree rennoval to convert forest habitat to another land use that are within 5 miles of an occupied hibernaculum or 1.5 miles of a documented summer occurrence, the following recommendations must be followed unless a permit is obtained from the Department l5 April to October 31 (Clearing is restricted) During this period of time, NLEB are active and are within the forested landscape.The following restrictions are required unless a permit is obtained from the DEC: • No cutting of any trees may occur within the 1/4 mile buffer around a hibernaculum. o Please note that if you plan any tree clearing activities within 1/4 mile of a hibernation area for NLEB,you may be required to obtain a permit from the US Fish and Wildlife Service and the DEC. • For cutting of trees in occupied NLEB habitat outside of the 1/4 mile buffer around hibernacula or within 1.5 miles of a summer occurrence: o The following are restrictions that must be followed for forest management activities at this time of year: i ■ Leave uncut all snag and cavity trees unless their removal is necessary for protection of human life and property.For the purposes of this guidance,protection of human life and property includes removal of trees that, if not removed,could result in the loss of electric service.Snag and cavity trees are defined under DEC Program Policy ONR-DLF-2 Retention on State Forests.l-tttp_I/www:dee.nv:gov/IatidsfF t�58.htrr�l Leave uncut all known and documented roost trees,and any trees within a 150 foot radius of a documented summer occurrence. • Please note that if you plan any tree clearing activities within 150 ft. of a summer occurrence for NLEB during June or July,you may be required to obtain a permit from the US Fish and Wildlife Service and DEC. • If any bats are observed flying from a tree, or on a tree that has been cut, forestry activities in the area should be suspended and DEC Wildlife staff notified as soon as possible. If a project cannot follow the restrictions above, a permit from DEC under Part 182 would be required. November 1 to March31 (Clearing can occur) During this period of time, the NLEB are inactive and are within the hibernation sites. • No cutting of any trees may occur within the 1/4 mile buffer around a hibernation site. • No activities that may result in disturbance to a hibernation site including,but not limited to, actions that would alter the hydrology, increase noise or introduce fill may occur. o Please note that if you plan any development or tree clearing activities within 1/4 mile of a hibernation area for NLEB, you may be required to obtain a permit from the US Fish and Wildlife Service and the DEC. • For cutting of trees outside of the 1/4 mile buffer around hibernacula• o No restrictions, with the following voluntary measures recommended- • Leave uncut all known and documented roost trees, and any trees within a 150 foot radius of a documented summer occurrence 17 ■ Leave uncut all snag and cavity trees unless their removal is necessary for protection of human life and property.For the purposes of this guidance,protection of human life and property includes removal of trees that, if not removed,could result in the loss of electric service.Snag and cavity trees are defined under DEC Program Policy ONR-DLF-2 Retention on State Forestswill. htt .."/[N�yww.dec:nV:aovllallclsJfaJ658:lifml Potential moderate to large adverse impacts to the NLEB will be minimized by avoiding vegetative ` clearing during breeding and hibernation seasons. The imperiled plant species Woodland Agrimony(Agrimonia rostellata) was identified as potentially occurring on or in the vicinity of the parcels.The Orient record was established in 1938 and the ` location of the population is unknown. The North Brown parcel contains suitable habitat to ; support the species(Woods, fields and shrub thickets).The NYSNEP recommends that any field surveys to the site include a search for these species,particularly at sites that are currently undeveloped and may still contain suitable habitat. The method should be employed in the development areas on the North Brown and the North Dyer parcels. Clearing Timeframes Potential moderate to large impacts to wildlife species will be minimized by avoiding clearing during breeding and hibernation seasons(April 1 to October 31).Lots on North Dyer and North 4 Brown will be cleared applying regulatory controls and best management practices;excluding the disturbance buffers and the areas required to be left in vegetation through the establishment of clearing limits required in Chapter 240 Subdivision of Land of the Southold Town Code. North Brown provides the largest area of woodland within the open space area. The area is comprised of successional hardwood trees,brush and ground cover. It is recommended that the area is retained to the greatest extent practicable to continue to provide wildlife habitat. Correspondingly,based on the expected low species diversity and size of habitat in the tree lined ; windbreaks along the east property boundary (in the open space),moderate to large adverse impacts to wildlife and habitat from the construction of the right of way and road are expected to be low. Based on the above best management practices and mitigation proposed, significant adverse impacts on protected species are not expected. Impact from Utilities Chapter 240 Subdivision of Land of the Southold Town Code requires that all utilities are to be located underground for new subdivisions and thezefore utility poles will not be visible. There will be no visible impact from the placement of utilities on the North Brown parcel. i8 Impacts from Stormwater Runoff The higher elevation and risk of runoff from a future impermeable road surface is a public concern. Roads are designed to shed stormwater to passive drainage swales or discharge to underground catch basins. In accordance with the Town and the NYSDEC regulations, a Stormwater Pollution Prevention Plan(SWPPP) will be prepared and approved prior to construction.The SWPPP will outline all measures that will be required to prevent excess stormwater runoff from leaving the site and affecting neighboring properties both during construction and after.Stormwater runoff will be collected,stored, and infiltrated to groundwater via a private storm system of catch basins,piping, drywells and drainage reserve areas. Correspondingly, stormwater will be controlled with pursuant to Town of Southold Chapter 236 Stormwater Management regulations. 2.3.3 Transportation, Safety and Access Comments U6 H7 W4 W7 WS W10W11 W,12,,W14,W15 Response Location of Right of Way and Road on North Brown Parcel Several concerns were raised about the location of the 1.32 acre North Brown parcel right of way and access road along the eastern parcel boundary and the potential adverse impacts to existing homes, the existing hedgerow,wildlife habitat,protected lands and traffic and pedestrian safety. The DEIS does not specifically discuss the location of the right of way and access road on the parcel. The right of way is proposed at 25' in width with a 16'wide access road to serve 5 lots in the north of the parcel.The open space parcel is proposed to have direct access from NYS Route 25. To the east of the North Brown parcel are 5 improved,residential lots created under the Browns Hill Subdivision and one improved, residential lot located just north of NYS Route 25.Also bordering the eastern parcel boundary is a 16.89 acre lot upon which the Peconic Land Trust holds an easement;further east from this protected parcel,is a second 18.83 acre parcel upon which development rights have been sold to the Town of Southold. These two parcels form a contiguous block of 35.72 acres of farmland directly east of the North Brown parcel. Chapter 240 Subdivision of Land of the Town of Southold Town Code supports designing subdivisions to achieve contiguous blocks of open space.This design is even more important when preservnng active farmland_ Interruption of open space by roads, street trees and other improvements has the potential to conflict with farming operations. The right of way proposed along the eastern border abuts 4 lots improved with single family residences within the Browns Hill Subdivision All have varying widths of vegetated areas between the rearyards and the proposed right of way Further south and near NYS Route 25 the proposed right of way would also abut a single family residence. 19 r The approximate distances from the proposed road to the existing single family residences (principal structures) along the eastern parcel boundary are as follows: Tax Mah Distance Roadway. 1. SCTM#1000.-18-4-2.1 50' + NYS Route 25 2. SCTM# 1000-13.-3-5.1 50'+ Browns Hills 3. SCTM# 1000-13-3-4 96' +_ Browns Hills 4. SCTM# 1000-13-3-3 109'+ Browns Hills 5. SCTM#1000-13-3-1 69'± Browns Hills 6. SCTM# 1000-13- 1-1 383'+ Located to the north of the road and lots. The west parcel boundary borders a New York State storm water recharge area, two improved lots with single family residences, two vacant lots and a 11.06 acre lot upon which ; development rights have been sold to Suffolk County.The lots are accessed by two existing parallel curb cuts beginning at NYS Route 25. r If the right of way was relocated to the west boundary the distances to existing, single family residences would be as follows: 1. SCTM# 1000-18-3-9.11 131'+ 2. SCTM# 1000-18-3-9.2 170'+ Between the single family residences and the proposed right of way on North Brown is a wide vegetated area, an improved road and an unimproved driveway. If the right of way were to be relocated to the west parcel boundary the design would need to account for a 53.22' lot line ; deviation to the west.The adverse impacts on prime or soils of statewide importance would be similar if the right of way were located on the east or west side.The 1.32 acreage converted from agricultural use and woodland is expected to also be similar in size. Note that the design of the right of way and road proposed to access the North Brown lots does not currently meet required highway specifications in Chapter 161 Ighway Specifications of the Town Code and fire protection design standards.A 50' wide right of way and 26' wide load bearing surface is required to serve the lots in this location. The DEIS (Page 12) indicates that 25' wide right of ways will be sought to support the purpose of the Conservation Subdivision, allow better surface water management and retain lural character.The reduction in width requires that the right of way remain private and approval from the Town Fire Marshall and Town of Southold Superintendent of Highways. The relocation of the road from the east to the west property boundary would decrease the potential for noise and dust impacts to 5 improved, neighboring lots located on the east boundary of the parcel.The distance and width of vegetation between the residences and potential access road alulig the west parcel boundary would provide a more effective buffci to noise, dust and overall disturbance than the homes located along the proposed road in the east. This is due to the proximity of the homes to the proposed road and lack of screening vegetation of the homes in the 20 rear yards abutting the east property boundary.The re-location of the road to along the west property boundary would better protect the quality of Iife of the residents in the area and lessen adverse impacts to community character. Impact of Curb Cuts on North Brown and Traffic Safety Commenters voiced concerns about adding an additional curb cut to establish the North Brown access road along the eastern parcel boundary and the adverse impacts to traffic,bicyclists and pedestrian safety. Currently there is an unimproved farm road located on the east boundary, a driveway flag serving SCTM#1000-18-3-30.4(vacant) on the west boundary and a right of way easement located just west of the flag.The driveway flag is unimproved, in disrepair and shows no signs of recent use. The North Brown access road is proposed to be located over the existing farm road in the east adjacent to the parcel boundary. Commenters requested that the access road be relocated to the west property boundary, effectively creating "one curb cut". The creation or consolidation of one curb cut is a Planning Board policy for applications accessing NYS Route 25. NYS Department of Transportation also requires the consolidation of curb cuts where possible. However,in this instance, the creation of one curb cut cannot be achieved without further agreement between landowners because the access flag and right of way easement located along the west parcel boundary are under different ownerships and a shared access agreement has not been submitted for the action.The relocation of the right of way to along the west parcel boundary would congregate three separate curb cuts in this location"side by side". Commenters also pointed out that with such relocation, traffic safety would be improved and lessen chances of accidents from ferry traffic and with bicyclists and pedestrians.It is expected that the number of vehicle trips entering and exiting the North Brown access road would be the same irrespective of the curb cut Iocation. The proposed right of way location was discussed at the July 2, 2019 field inspection with the Planning Board.Adequate line of site for drivers enteruig NYS Route 25 from driveways and access roads was identified as a concern. Line of sight can be nnterrupted or obstructed by curvature of the roadway, vehicles pulling out of adjacent road and driveways, vegetation, structures, and other activities occurring within the shoulder of the road.The location of new access roads and curb cuts should optimize the line of site for vehicle operators A slight curve on NYS Route 25 is located to west of currently proposed access road (eastern) location and poses no significant impediments to the line of site looking east or west Vegetation occurs to the east and west of the existing and proposed curb-cuts in both locations. At the east location there are street trees to the east of the proposed access road that could potentially obstruct the view of a driver looking east for oncoming traffic (depending upon where the vehicle stops). The street trees are not located on the North Brown parcel and therefore, the ability to remove the trees is low. On the west property line at NYS Route 25 the vegetation is indicative of roadside, early successional field growth. No large trees occur along the roadway in this location. If the access road 21 were relocated to the west parcel boundary,vehicles pulling out of the three separate accesses at one time are possible due to the parallel alignment. If this occurs, the line of site of drivers looking west or east could be hindered depending on which driveway the vehicles are pulling out of.The probability,however, of this occurrence is low due to the low residential density on the parcels served and expected vehicle trips. The line of sight from a curb cut located along the west property boundary would not be significantly impacted from vegetation,however, could be impacted from vehicles exiting the parallel accesses at the same time.The probability of this occurring is low. The safety of bicyclists and pedestrians could be impacted if the operator of a motor vehicle does not see therm approaching from the east due to the street trees.Similarly, the pulling out of vehicles at the same time at the western location could result in safety risks to bicyclists or pedestrians. Significant, adverse impacts to pedestrians, traffic and safety are not expected. 2.3.4 Land Use and Zoning Coniinents.H4 ,H5,H10,W2,W4 Response: There were several comments concerning the development of and potential size of the 4 single family residences on the South Dyer parcel and whether a cap in total square footage could be applied.The South Dyer lot is zoned Residential 80 or R-80.The purpose of the R-80 Zoning District is as follows: The purpose of the Agi-icultural-Conservation (A-C)District and the Low-Density Residential R-80, R-120, R-200 and R-400 Districts is to reasonably control and, to the extent possible, prevent the Winecessm y loss of those currently open lands within the Town containing large and contigilolis areas of prinic agricultural soils which are the basis fpr a significant portion of the Town's econ07Ily and those areas with sensitive environmental fenttires, including aquifer)echarge areas and bluffs In addition, these nreas provide the open rural environment so highly valued by year-round residents and those persins who support the Town of Southold's 1 ecreation, resort and second-honie econoiny. The economic, social and aesthetic benefits which call be obtained fir all citizens by Inviting loss of such areas are well docuinented and have inspired-a host of governmental programs designed, with varying degrees of success, to achieve this result. Foi•its part, the Town is expending large simis of monel/ to protect existuig farm acreage. At the snore tinge, the Town has an obligntlon to exercise its author Ili/ to rensonnl:li/Iegnlate the subdivision and development of this land to fia thee' the same prirposes while honoring the legithiiate Interests of farniers and other forinland owners. The proposed construction of 4 single family residences and protection of open space do not conflict with the zoning district purpose.The Bulk Schedule of the R-80 Zoning District requires 80,000 square foot]ots h0X-%-ever, when an applicant is proposing to subdivide a parcel equal to or greater than 7 acres;Section 240- Clustering of the Town Code applies and lots are reduced in size (clustered) to less than 80,000 square feet The reduction in square footage of each lot is proportionate to the amount of land area required to be preserved and the number of lots (density) proposed. On South Dyer a total of 14.38 acres of buildable land is proposed to be preserved under 22 the 80/60 Conservation Subdivision program. The residential lot sizes proposed for South Dyer include: Lot 1 38,122 Lot 2 40,682 Lot 3 40,625 Lot 4 40,685 The lot sizes proposed on South Dyer have been reduced by approximately 50 percent in size than the permissible minimum lot area required (80,000) square feet through clustering. Community concerns also focused on the potential size in square feet and height of the future single family residences on the 4 lots.This is discussed below in Aesthetics. 2.3.5 Aesthetics Ciiaimerits'H2>.H3,H4,Mi K6,.M,H10,W1,W2,W3,W6..W9,W14 Concerns were express on the adequacy of the view shed analysis,potential adverse impacts of the location of lots and size of future structures on the South Dyer parcel view shed and the Orient Historic District. Response The SEQR assessment on impacts to Aesthetics Resources evaluates consistency in land use between a proposed project and other land uses that may be seen from or part of an officially designated and publicly accessible scenic or aesthetic resource.In this case,officially designated scenic areas include NYS Route 25 a scenic byway. Other designated areas may also include places or saes listed on the National or State Registers of Historic Places (Orient Historic District) and Orient Harbor.The DEIS recognizes the significance of NYS Route 25 and Orient Harbor stating that: "The proposed action on South Dyer will be visible year round by local residents, tourists and recreational visitors from the Route 25 NYS Scenic Byway and the Orient Hnrbor." Therefore, the DEIS discusses two view sheds; the first from NYS Route 25 looking south, east and west over the South Dyer parcel and the second from Orient Harbor looking predominately north. A Visual Impact Study prepared by Sam Fitzgerald,Architect PC and submitted on October 35, 2016 as part of the DEIS for the proposed development on the South Dyer parcel evaluates the view sheds. A total of 12 vantage points from NYS Route 25 were established and 2 from Orient Harbor. The DEIS did not contemplate how the proposed action would impact the view shed from properties on or eligible for inclusion in the National or State Register of Historic Places [36 U.S.C. 5 470a et seq., Parks,Recreation and Historic Preservation Law Section 14.071 including the Orient Historic Distract or on Iocal roads. 23 The view sheds from properties on or eligible for inclusion in the National or State Register of Historic Places will be affected from the construction of 4 single family residences on South Dyer, however, the adverse impacts on these types of structures are expected to be low for the following reasons: 1. The proposed action does not propose to alter or demolish any existing building on or off site. 2. The proposed residential use is compatible with and does not conflict with the existing historic,neighborhood setting of the hamlet of Orient and the Orient Historic District. The South Dyer property is zoned Residential 80(R-80) and the properties to the north, ^ west and south are also zoned R-80 and Residential 40 R-40. 3. The DEIS indicates that future construction of single family residences and accessory buildings will meet zoning of the R-80 district and include architecture compatible with the character of existing homes found within the Orient Historic District. Future construction of residences on North Brown, South Brown or North Dyer will not directly impact properties on or eligible for inclusion in the National or State Register of Historic Places. AIterations or demolition of structures on the parcels is not proposed and the lots are not located near NYS Route 25,which has a preponderance of these types of structures. The viewsheds from both NYS Route 25, a NYS Scenic Byway and Orient Harbor have been identified as important to the community and several concerns about the potential adverse impacts on the aesthetic qualities from the placement and construction of future residences of the South Dyer parcel were raised by the public. Page 26 of the DEIS states: "that the houses on South Dyer are placed in the least visible part of the lot. They will not obstruct, eliminate, or significantly screen the unportant scenic view of the farmland, the Peconic Bay and tidal creek." By design the 80/60 Conservation Subdivision requires the preservation of 80 percent of buildable lands and the reduction of overall density by 60 percent. These two parameters mitigate potential adverse impacts to scenic quality through mandatory clustering of lots, often near existing, improved lots and sterilization of acreage. The placement of residential lots is determined by the submission and evaluation of an Existing Resource Site Analysis Plan or ERSAP pursuant to SS240- 10. Technical regirire»ient,ti and the identification of Primary and Secondary Conservation Areas pursuant to Chapter 240 Subdivision of Land,Article XI Cluster Development§240-43 Determinntion of location of open spaces created by cluster development using primary and secondary conservation areas of the Southold Town Code. A primary goal of an 80/60 Conservation Subdivision design is to achieve, uninterrupted and undivided areas of open space to support agriculture. The Town of Southold Community Preservation Project Plan (2016) includes a List of Eligible Parcels and the Community Preservation Fund (CPF) categories for each listed parcel to qualify the reason to purchase the parcel All of the parcels are in included within the plan. 24 Table 1. Town of Southold Community Preservation Project Plan Parcels and Categories for Purchase Owner/Name SCTM# CPF Category North Dyer 17.-4-16 a.establishment of parks,nature preserves or recreation areas; b.preservation of open space,including agricultural lands and f; preservation of undeveloped beach lands or shorelines including those in significant risk of coastal flooding due to 'projected sea level rise and future storms. South Dyer 17.-6-14.2 a establishment of parks,nature preserves or recreation areas; b.preservation of open space,including agricultural lands; c. preservation of lands of exceptional scenic value; d. preservation of fresh and saltwater marshes or other wetlands; e.preservation of aquifer recharge areas and f. preservation of undeveloped beach lands or shorelines including those in significant risk of coastal flooding due to projected sea level rise and future storms. North Brown 18.-3-30.3 b.preservation of open space,including agricultural lands and f. preservation of undeveloped beach lands or shorelines including those in significant risk of coastal flooding due to projected sea level rise and future storms.. South Brown 18.-6-17.3 b.preservation of open space,including agricultural lands; c. preservation of lands of exceptional scenic value; d. preservation of fresh and saltwater marshes or other wetlands The designs of the parcels meet the 80/60 Conservation Subdivision program and support the Community Preservation Project Plan On the South Dyer parcel, exclusive of the proposed development area, the exceptional scenic value as a view shed should be protected, uninterrupted in perpetuity for the benefit of the public. On South Dyer, the clustering of the 4 proposed residential lots and access road in the east of the parcel supports the above categories.This design also results in the preservation of the working landscape as uninterrupted actively farmed open space, an aquaculture operation and supports the continued operation of Latham's Farmstand which is a contributor to the high scenic qualities of the hannlet of Orient and NYS Route 25.The location of the lots is discussed and supported in the DEIS on page 26 with reference to the NYS Route 25 North Fork Trail New York Scenic Bywav application: Route 25 is part of the North Fork Trail, which is designated as a New York Scenic Byvmy The NYS Scenic Byways npplicntion stated. .."Perhnps the road's Most drrnnntic scenic of/erni�; is rri erre of 25 these spots,a site where Orient Harbor can be seen to the southeast and Dam Pond to the north, featuring tidal marshes, distant water front housing and a poprtlar farmstand "The popular farmstand cited is Latham's Farmstand, which is on SD at the western property boundary. Our proposed houses would be on the east boundary and form a continuation of the distant waterfront housing that provides an interesting background for the spectacular water views If the lots were relocated to another location on the parcel and outside of the Orient Historic , District, a greater interruption of the designated scenic view shed would occur and oversight of future architecture of the residences will not be possible without a mutual agreement between the landowners and the Planning Board. Scenic Impacts on Local Roads A public hearing comment was made about the omission of vantage points on Racketts Court, Oysterponds Lane and Skippers Lane in the Visual Impact Study and notably the Orient Historic District and,properties on or eligible for inclusion in the National or State Register of Historic Places (W3). Racketts Court, Oysterponds Lane and Skippers Lane are collector streets located to the east and south of the South Dyer property.Racketts Court is a private road and not accessible to the public. Two private single family residences are served by the road and the occupants view into the property from the residences is west and south. Oysterponds Lane is improved with residences on single and separate lots on both the west and east sides.The private single family residences, accessory structures and landscaping located on the west side of the road obscure the view shed from the roadway looking west into the South Dyer parcel.Skippers Lane,located to the south of the parcel, provides an obstructed view north into the parcel due to a hedge and single family residence. None of the roads are identified as possessing scenic qualities important to the public in past Town plans. Public comments received at the public hearing suggest,however, that the scenic views from the roadways are important to members of the community. -, The three roads were not included as vantage points in the Visual hnpact Study because the Planning Board found that the proposal for a 80/60 Conservation Subdivision mitigated the significant impacts to the view sheds from the roadways with the significant reduction of density from a potential of 10 lots (Standard Subdivision) to 4-lots and that the level in which viewers are engaged from the local roads did not justify the inclusion. This decision was supported by the existing private, residential structures and landscaping that interrupt the view sheds looking west and south from Racketts Court across the parcel; ,vest from Oysterponds Lane and the hedge and residential structures and accessory buildings obscuring the view looking north from Skippers Lane. The NYS Route 25 view shed was included due to the relevance of the New York State Scenic Byway designation and identification of its scenic qualities in Town plans. Orient Harbor was also included due to the level of high public use on the waterbody. The design of the subdivision focused on the extremely high scenic value of the view shed from NYS Route 25 with the objective that the future houses VVrould not obstruct, eliminate or significantly screen the view. 26 To further protect scenic qualities on South Dyer one of the proposed lots from South Dyer will be relocated to North Dyer.As a result, a total of 4 residential lots are proposed on South Dyer even further mitigating impacts to aesthetic qualities through the reduction of unit density. Reducing the widths of the roads serving the lots to less than 50' would also minimize impacts. Size of Homes Modelled in DEIS Visual Impact Study In conjunction with the concerns about the architectural styles of future structures constructed in the Orient Historic District,several comments were received at the public hearing about the size of the future structural build out on the lots proposed on South Dyer; the total square footage of structures allowed under Southold Town Code;and what adverse impacts may result to the character of the Orient Historic District and the Hamlet of Orient.Specific questions were asked regarding the structure sizes modelled and submitted in the Visual Irnpact Study provided by the applicant. Concerns were also raised about ability to build twice the square footage over the total, percent cover permitted by 280 Attachment 3 Town of Southold Bulk Schedule for Residential Districts (Bulk Schedule) of the Southold Town Code with the construction of 2 and'/2 story principal and accessory structures.A related concern was the potential height of the structures. The Visual Impact Study included 3D Computer Models of single family residences for a 5 lot and 4 lot alternative that;maximized the bulk regulations;included architecturally appropriate designs with wide appeal;and that could be seen as reasonable to build in this location. Each lot was modelled to be consistent with the Bulk Schedule requirements for the R-80 Zoning District.Bulk Schedule requirements allow up to 20 percent total lot coverage,2 and 1/2 stories and a building height of 35' in the district. The DEIS states that houses built on South Dyer will meet all zoning and building requirements. Accessory Structures In the R-80 district, the Southold Town Code requires that accessory buildings and structures or other accessory uses must be located in the required rear yard. On lots ranging from 20,000 to 60,000 square feet the maximum area of an accessory building is 1,200 square feet. The maximum height of an accessory building varies and is dependent upon lot size and setbacks. The maximum accessory building height for lot 5 ranges from 18 to 22 feet with minimum setbacks for side and rear yards ranging from 10 to 20 feet.The maximum building heights for lots 2,3 and 4 is 22 feet with minimum setbacks for the side and rear yards of 20 feet. The maximum percent cover regulates the total amount of ground area in square feet that both the principal and accessory structures could occupy Lot coverage does not account for second stories; therefore there is potential that a future land owner could build a 2 and 1/2 story single family residence and accessory structures on each of the lots.This build out will meet all zoning and building code requirements. At the request of the Planning Board, as lead agency, on April 5, 2019, the applicant provided additional information that clarified the square footage of each principal and accessory structure for the South Dyer lots modelled in the Visual Innpact Study prepared by architect Sam Fitzgerald R A. 2; Tables 2 through 4 below summarizes the information submitted.The applicant reiterates in the submission that the modelled sizes of the stricture are a "worst case scenario" in conformance with the 20 percent lot coverage requirement and the Bulk Schedule. In a subsequent phone conservation with the applicant on April 19,2019 the applicant pointed out that the structures depicted in the Visual Impact Study are a representation of what could be constructed on each lot, and are not proposed.The DEIS states on page 26 (2018 resubmission) that the study included the "worst case scenario". "Since we are not planning any development in the foreseeable future, the size/design of facture houses is very speculative When we do develop SD lots, we will hilly comply with zoning requirements, ; which would be in keeping with other waterfront homes in Orient.At the Town's request we developed a worst-case visual impact study " Table 2. Maximum Structure Lot Coverage(Ground Surface Area)Modelled in the Visual Impact ` Study. 5 '> Lot 1 " rvL " 2. Lot Principal Structure 151 floor ` 3,750 sq. ft. 3,926 sq.ft. 3,815 sq. ft. 4,215 sq. ft. ; Decks and Porches 1st floor 825 sq.ft, 950 sq. ft. 850 sq. ft. 1,058 sq. ft. Garages/UtiIity 864 sq.ft, 1,200 sq.ft. 1,200 sq. ft, 864 sq.ft. Pool House/Pool 2,185 sq. ft. 2,060 sq. ft. 2,260 sq. ft. 2,000 sq. ft, Total 7,624 sq. ft, 8,136 sq.ft. 8,125 sq. ft. 8,127 sq.ft. Table 3. Total Living Space for the 15' and 2nd floors of the Principal Structure (Single Family Residence) Modelled in the Visual Impact Study. Lot 1, Lot 2 Lot 3 :Lot 4 Living Space 1,1 Fl 3,750 sq ft. 3,926 sq.ft. 3,815 sq. ft. 4,215 sq. ft: Livnng Space 2-1 F1 3,750 sq. ft. 2,400 sq. ft. 2,973 sq. ft 2,633 sq. ft. Total Floor Area 7,500 sq. ft. 6,326 sq. ft. 6,788 sq. ft. 6,848 sq ft. The maxununn ground cover allowed on each lot ranges from 7,624 to 8,137 square feet as shown un Table 4 beloxv. Accessory structures would also be allowed and would count towards the proposed total covera7r, hrmlover rhe ahplwan I noted that the accessory structures would be located in the rear-vards and would not be directly visible frons NYS Route 25 or Orient Harbor. 28 Table 4. Total Lot Size and Twenty Percent Lot Coverage of Structures as Permitted by Town Code. hot Number .Total Lot Area(SQ.,W) 20 Percent Cover(Sq.Ft.) 1 38,122 7,624 2 40,682 8,136 3 40,625 8,125 4 40,685 8,137 The visual impact study did not model the largest houses possible as shown by comparing Tables 2 and 3.The visual impact study included typical houses in the areas that are less than the size of what would be possible under the Town Code(e.g. on proposed Lot 4, a two story home with no additional structures with the maximum 20 percent ground cover and a second story mirroring the 15t floor could be as large as 16,274 sq.ft.). There is potential that homes with architecture, and a mass significantly larger and out of character with the surrounding older single family residences could be constructed on the proposed lots n1 the future. Structures designed to be similar to the size to the existing single family residences and accessory buildings found within the Orient Historic District would support the historic character, scenic view shed of South Dyer and minimizes impacts to aesthetic resources and community character. Some mitigation is provided by the conservation subdivision option, which requires the number of homes to be reduced by 60%, and the proposal to cluster the lots against existing single family residences in the west of the parcel. Additional mitigation is needed to insure that future structures are not discordant with the character of the Orient Historic District and the scenic view shed of South Dyer. This can be achieved by ensuing that at least 80 percent of the buildable lands are preserved, which will reduce the size of the development area to the required 20%. Currently it is proposed at over 35%. This would reduce adverse impacts from future build out of the lots by reducing lot size. To further mitigate potential adverse impacts frorn the mass, scale and architecture of future build out of the residential lots, the Planning Board will accept the recommendation made by Ms Beth Cwnming, Senior Historic Restoration Coordinator,Division of Historic Preservation of the OPRHP to review site plans, and elevatio i plans of structures proposed on Lots 1 through 4 in addition to the local review of applications for new construction by the Southold Historic Preservation Commission. Both reviews will take place prior to issuance of a building permit. 29 As a result of the mitigation described above, the proposed action will not result in moderate to large adverse impacts to the aesthetics. 2.3.6. Cultural Resources Comments H2,H3,W3 Concerns were expressed about the adverse impacts and protection of archeological resources on the parcels, the timing of the archeological surveys and overall process. Response i The Division for Historic Preservation of the Office of Parks,Recreation and Historic Preservation (OPRHP) and the New York's State Historic Preservation Office (SHPO)was contacted early in the subdivision process and a response was received on(March 13, 2015) that the agency concurred with the recommendation that a Phase 113 archeological investigation is warranted on each of the four parcels prior to any proposed development that would involve ground disturbance (NYSCRIS).The Phase IB field investigation was recommended by a previous Phase IA documentary study conducted on the property. From June 6 to September 6, 2015,Tracker Archaeology Services, Inc.conducted a Phase IB archeological investigation for the proposed subdivision on the 17 proposed lots,roads and some additional areas.The purpose of the survey was to provide physical evidence for the presence or absence of archaeological sites on the project area. On the South Brown parcel/lot 52 quartzite artifact fragments were found, which is evidence of a prehistoric site. Due to the findings,Tracker Archeology Services, Inc. recommended that Phase II intensive testing on the lot prior to any development related to grading or construction. A Phase Il archeological survey would include: 1. Site integrity, including the depth and extent of undisturbed soil horizons and the presence or absence of cultural features, and the degree of natural and/or human disturbance to those features. 2. Cultural components/affiliations and the time range present. 3. Vertical and horizontal distribution of archeological remains (spatial boundaries and stratigraphic levels). 4. Site interpretation, including any uniqueness/significance, in a local regional context,must be demonstrated. At the public hearing a concern was raised that SHPO never commented on the Phase 1B report or concurred ,,%,ith its recommendations "although it was submitted to the SHPO sometime prior to the spring of 2018" Tip mmmentnr indicated that the reason for this is "on June 11, 2018, the SHPO requested that the Planning Department provide updated project plans because the areas investigated during the Phase 113 study: ...do not correspond with the area of potential fact that was 30 initially submitted for this project."The file record was checked and no such correspondence was located. The request most likely was made through the CRIS system. No comments were received from SHPO during the DEIS public comment period which closed on March 24,2019.However,in response to comments made at the public hearing the Southold Planning Department contacted Tim Lloyd Ph.D.,RPA of OPRHP to discuss the archeological record on each of the parcels. Mr. Lloyd requested the latest subdivision maps and the link to the laser fiche file be sent to him on April 23,2019. Mr.Lloyd obtained the maps on April 30,2019. On May 6,2019 the Planning Department received a letter from Dr.Lloyd requesting revisions to the Phase IB report included and referenced in the DEIS.A supplemental`Phase 1B field investigation was also recommended for the North Brown parcel. Recommended revisions to the Phase 1B report(March 2011)included: North Dyer: A foundation found on North Dyer was not discussed.. • The text should be revised to clearly state that the foundation and rubble represent an archaeological site. i • An attempt should be made to correlate the foundation zoith structures indicated on historical maps that zoere analyzed as part of the Phase IA Documentary Study. • Recommendations should be made regarding the potential eligibility of the site for listing in the State and/or National Registers of Historic Places (SINRHP). • Recommendations should be made regarding the potential need for additional investigation to assess the site's eligibility for listing in the SINRHP. South Brown: A Pre-Contact Period Native American archaeological site was identified on Lot 1 of the South Brown parcel. OPRHP recommends the following revisions to the Phase IB report relating to the Native American artifacts recovered on Lot 1. • The text should be revised to include an analysis of the recovered projectile points • Figure 2D Addendum shozos the results of the shovel tests excavated ill Lot 1, but there is no indication of the sur face finds and no indication of the boundary of the archaeological site. The figure should be revised to include the locations of sio face finds, mid/or concentrations of artifacts, and the site boundary should be indicated • OPRHP recommends that impacts to the Native Anierican archaeological site on Lot 1 of the South Brozon pm-cel be avoided If impacts to the site cannot be avoided, then OPRHP recoirnriends a Phase 11 investigation to evaluate the site for cligibilil y for' listing in the SINRHP • A Phase IB archaeological survey/of the proposed route of the drivezuay to Lot 1 is also recommended. 31 On May 9, 2019 the P1armirng Department received a second letter from OPRHP requesting a supplemental Phase 1B field investigation on the North Brown parcel because shovel tests excavated at 15 meter intervals conducted during the initial Phase 113 investigation were inadequate for the identification of burials. The request was based on new information that a Native American burial site, known as the Orient Site may be located in the north of parcel. The Orient Site is repeatedly mentioned in archaeological literature,but the site's precise location is unknown. On May 28, 2019 the Planning Board received a letter from the Tribal Council Unkechaug Indian Nation concerned with the potential of Native American burials on the parcel and requested copies of Archaeological reports, the details of the subdivision and a meeting. On June 3,2019 the Planning Board agreed to arrange a meeting between the Unkechaug and Shinnecock nations,the landowners, staff and representatives from OPRHP. Information was also presented to the Planning Board at the public hearing regarding the potential of two archeological sites"on property' of South Brown and one"adjacent". The site is referred to as the"5 Acres Indian Village Site". A "fact sheet" on this site was provided to the Planning Department by the Southold Town Historian identifying the location of an archeological site referenced as the"Four-Acres Indian Site" on a certain Suffolk County tax map parcel. The tax map number referenced the Suffolk County Tax Map is not located on or adjacent to the South Brown parcel. The Planning Board discussed the recommendations made by OPRHP at their May 20, 2019 work session decided to coordinate with Tracker Archaeological Services,Inc. to seek guidance on how to proceed.Tracker Archeological Services,Inc.was contacted on May 21, 2019 and the two letters received by the OPRHP were forwarded to the company. In response to the information received,on June 25, 2019 the Planning Board held a meeting with applicants, and representatives from the Unkechaug and Shirmecock tribal nations, staff and representatives from OPRHP to discuss the North Brown and South Brown parcels.The meeting agenda included a project overview, discussion on the OPRHP recommendations and consultation from the Unkechaug and Shinnecock tribal nations. During the meeting representatives from OPRHP handed out a map showing three known archaeological sites east of the North Brown parcel.Two of the sites, referred to as Orient 1 and 2 are excavated burial sites.The exact location of the sites in relation to the North Brown parcel is unknown and it was agreed that further investigation is necessary to continue with processing the application. The recommendations made by OPRHP for further archaeological investigation on South Brown were also discussed for the lot and driveway locations. The Narrow River area includes a series of villages with burial sites but the exact locations are also unknown. Site visits to the North and South Brown parcels were conducted on July 2, 2019. In attendance included representatives from the Planning Board, Planning Department, the Unkechaug and 32 Shinnecock tribal nations and the landowners.The purpose of the site visit was to consult native American expertise and identify locations to conduct further archaeological investigations. Flags were placed in several Iocations at areas of higher elevations or around distinct boulder patterns on the North Brown property. A drive and walk through of the South Brown property was conducted and the location of the residential lot was discussed. In the field, the timing of the archeological investigation was discussed with those in attendance and if they would be opposed if a condition to conduct the archaeological investigation at a later date was placed on approval of the subdivision.The condition would require that the landowner of the North and South Brown parcels conduct the required archeological investigations prior to any ground disturbance on the residential lots.No decision was reached. Following the meeting,planning department staff developed a map of the flags in the field using ArcGIS and GPS reference points.Polygons were then drawn to delineate where a future archeological survey should be conducted. On July 24,2019 a letter was received by the Planning Board from Chief Harry Wallace of the Tribal Council of the Unkechaug Indian Nation which recommended the following: 1. With respect to the North Brown parcel ..potential burial sites were marked with flags for further examination utilizing the least invasive protocols by TRACKER Archaeology,Inc. to determine if there are possible burials. It was agreed that TRACKER Archaeology, Inc. would pe7 form the necessary investigation. 2. With respect to the South Brown parcel, TRACKER Archaeology,Inc. will examine, with the least invasive protocols based upon the findings of artifacts such as arrow heads No obvious burial sites were identified. 3. Pending the results of these investigations, we recommend that no digging or excavations take place at this present time. At their August 19 work session, the Planning Board accepted the recommendations from Chief Harry Wallace of the Tribal Council of the Unkechaug Indian Nation with the clarification that the additional archeological investigations would be conditioned to be completed prior to future ground disturbance on the North Brown and South Brown parcels and that no timeframe would apply. The placing of condition(s) on the parcels was in response to the testimony from the applicant that it is unknown when construction on the lots would commence.The applicant further acknowledged the risk of proceeding in this way and that if archeological artifacts or a burial site is located, the lot approved by the Planning Board may be partially or wholly unusable The condition(s) shall apply to all and any ground disturbance on the North and South Brown parcels and shall be recorded in the Final Plat resolution, covenant and restriction and Town of Southold inter-departmental Municity database Ongoing or future agricultural operations and practices shall be excluded from the condition(s). 33 The Planning Board also approved sending the map prepared by the planning department staff showing the delineated areas where additional archaeological investigations are required to Tracker Archaeology Services,Inc. and Chief Henry Wallace. The conditions requiring archeological investigations are as follows: North Brown 1. A Phase 1 B cultural survey shall be conducted within the areas identified and flagged during the July 2, 2019 Native American consult and field inspection.No ground disturbance within these areas shall occur prior to completion of the survey and the findings are published and made available to the Tribal Council of the Unkechaug Indian Nation, the Shinnecock Indian Nation and any and all parties who wish to receive a copy. 2. Agricultural operations or practices conducted in the open space areas as shown on the Final Plat are excluded from the above conditions. The potential occurrence of Native American burial grounds or individual burial pits where the residential lots are located on the North Brown parcel and the known burial sites that occur in the Browns Hills subdivision to the east supports the relocating of the access road from the west side of the North Brown parcel to the east side of the parcel.With the relocation, the consolidation of curb cuts or merging with the access serving SCTM#1000-18-3-9.2 (vacant)is recommended. The relocation of residential lots from South Brown or South Dyer to the North Brown Parcel would not avoid or reduce moderate to large adverse impacts to potential Native American archaeological sites and therefore, such relocation is not recommended. South Brown 1. A Phase II investigation to evaluate the site for eligibility for listing in the State National Registration of Historic Places shall be conducted by the landowner or future landowners prior to anygroui2d disturbance. 2 A Phase IB archaeological survey of the proposed route of the driveway to Lot 1 shall be conducted by the landowner or ftiture landowners prior to any ground disturbance. 3. Agricultural operations or practices conducted nn the open space areas as shown on the Final Plat are eticltided from the above conditions. All known archeological resources will be preserved to the greatest extent practicable under New York State Law. 34 Potential Adverse Impacts on the Orient Historic District Comment 111,H5,W2,W3 Community concerns include the design of the South Dyer subdivision,lot placement and the adverse impacts to the Orient Historic District. Response Orient Historic District Boundary The Orient Historic District is listed in the New York State National Registers of Historic places (S/NRNP). The Positive Declaration issued by the Planning Board incorrectly identified South Dyer as "substantially contiguous" to the Orient Historic District(District)using the best available information at the tune.The DEIS also references the Orient Historic District as "adjacent" to the South Dyer parcel(2018 DEIS,Page 5). The Orient Historic District as adopted by the Southold Town Board shows the western line intersecting a small area of the South Dyer parcel in the lower, southeast corner(Figure 1). The New York State Orient Historic District map includes the eastern portion of the South Dyer parcel within the District where the construction of 4 single-family residences is proposed (Figure 2).The North Dyer parcel north of NYS Route 25 abuts the District.This area is proposed as open space. Chapter 170 Landmark Preservation of the Southold Town Code establishes the review of certain actions within the Town's Historic Districts by the Town of Southold Historic Preservation Commission (Commission).The review of new construction in the District is not required by the Commission. Similarly, the New York State Historic Preservation Office also does not require review of new construction in the District, rather they recommend placing conditions on projects that require review though the local Commission.However Beth Cumming, Senior Historic Site Restoration Coordinator,Technical Services submitted a letter through the Cultural Resource Information System (CRIS 15PR00026) dated May 23, 2019 requesting details of the construction of homes on the proposed lots currently under review for the South Dyer parcel that is partially located within the Orient Historic District. On June 6, 2019 the Town of Southold Planning Board responded to the request through CRIS indicating that the Planning Board cannot provide the information requested at this time because the construction of homes are not proposed 33 The applicant has stated in the DEIS that the.future single family residences would be designed to reflect the existing range of architectural features of homes located throughout the hamlet of Orient and provide a good transition to the District. A Visual Impact Study with 3D renditions of potential architecture styles with historical features for single family residences proposed to be constructed on the South Dyer lots is included as part of the DEIS. Photographs of representative, existing,historic, single family structures were also submitted as a part of the DEIS. It is important to note that existing range of architectural styles in the District is dependent upon what period the structures were constructed and reflects many variations(not all with historic elements). The architectural styles of the single family residences submitted in the Visual Impact Study do not appear to be in significant conflict or discordant with the historic character of existing homes found within the Orient Historic District. �$ -�, -�'-�;', _. �gas-,,�r,As°�,�::' .,�,� '* w•. �.. .;-;�,���,—�.^,-,",� ... .. , »9 �i§3,=, rLB�bYs}'�y"�q�7�'.''•. ,�. �.g ".,,.g�:�x�'� d .., y "'" «a. " ti �'$�'��; ....14�, ,;• [p+y�j,` ^Y'.;,. ,+i>. °F`' ,; - �3$}' :'"' ..rCit;. �/y ;j t• ✓',° s. ^'a r" ., s pa°'h"�" '.�,;� '",?,a n• `r:° < s '' "G�'pmx«�3 °'TM�� c?T r.' <2• a �%' sy+z.f v w' + 5 i�;.' 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NYS Cultural Resource Information System Orient Historic District Boundary and area on the South Dyer parcel where a Phase IB Archeological Survey was conducted (Green Polygon). Impacts on Listed or Eligible State of National Historic Register Properties The proposal does not include the alteration or removal of listed or eligible State or National Register Historic Properties. North Dyer The North Dyer parcel abuts the Orient Historic District On July 1, 2019 the Planning Board received a letter from Mr. Tim Lloyd,Ph.D., RPA Scientist—Archeology of the NYS OPRHP regarding the North Dyer parcel.The following assertions were specified in the letter regarding the potential adverse impacts to the Orient Historic District: 1. The budding at 21505 Mau? Road (NYS Route 25) zuill be retaiured, and 2 The area inu?iediately adjacent to the Orient Historic District alone Main Road zurll r•en?mn as open space The leper CUJILIUL1425 [hat OPRI IP has no concerns regaidiing polenlial adverse impacls to (lie Orient Historic District if the open space area along Main Road is to remain undeveloped. If developnnent is proposed within the open space area, consultation with OPRHP is recommended. 37 r Furthermore, the letter indicates that the archaeological site identified in the "Phase 1B Archeological Survey for the proposed Tuthill Subdivision, Orient, Town of Southold, New York" requires no further investigation. South Dyer South Dyer lots 1 through 5 (now 4) are located within the Orient Historic District. On July 5, 2019 the Planning Board received a letter from Ms.Beth Cumming, Senior Historic Site Restoration Coordinator,Division of Historic Preservation of the Office of Parks,Recreation and Historic Preservation.Ms. Cumming recognized in the letter that the applicant has no plans to construct single family homes within the Orient Historic District at this time and recommended the following condition: 1. If construction is proposed,plans including site plans and elevation plans shall be submitted to our office for review and approval prior to construction. The proposed condition provides oversight of future construction to ensure that structures constructed on the South Dyer parcel are within character and context with existing structures representative of the Orient Historic District. Further oversight of the future architecture proposed for each single family residence and accessory buildings would be achieved under the review of the Town of Southold Historic Preservation Commission. Consequently,potential moderate to large adverse impacts to listed or eligible state or national historic register properties including those Iocated within the Orient Historic District are not expected. Design of Subdivision and Lot Placement The 80/60 Conservation Subdivision design on South Dyer involved numerous concept meetings between the landowners and Planning Board and Land Preservation Staff to discuss the preliminary design of the subdivision. During the concept meetings,Planning Board staff applied the Existing Resource Site Analysis Plan or(ERSAP) inethod outlined in Chapter 240 of the Southold Town Code. The purpose of the ERSAP is to identify and evaluate the scenic qualities, waters, wetlands, ground and surface waters, prime sods and soils of statewide significance, land in active agriculture (including aquaculture), flood zones, protected species and impact to cultural and archeological resources. ERSAP maps were provided to the Planning Board in 2014 and staff worked to identify the primary conservation areas (areas under legal protection) and secondary conservation areas (areas that are difficult or discouraged for development). Once the primary and secondary conservation areas were idellhfied, [lie bell layuul uI areas lu lie piesei ved and develuped [v avuid ui lessen adverse impacts to the greatest extent practicable were discussed. As a result of the ERSAP review, the high scenic quality and agricultural soils were identified as the most innportant attributes of the South Dyer parcel The applicant was aware of these qualities and 38 decided to cluster the lots to the east with the existing residential structures leaving a contiguous and uninterrupted view shed (excluding Lathain farm stand) over the parcel from New York State Route 25 across Orient Harbor.Further,later on in the process, the applicant agreed to amend the number of lots on South Dyer as outlined in Alternative 1 in the DEIS.This alternative proposes to transfer one lot from South Dyer to the permissible 80/60 Conservation density on the parcel from 5 to 4 lots.The transfer of the lot mitigates impacts to groundwater,surface waters, agricultural soils, scenic quality and cultural resources. The DEIS indicates that a total of 86 percent of the 35.34 acre South Dyer parcel is proposed to be preserved.The preserved area incorporates agricultural soils to preserve farming, areas currently farmed, waterfront access for an existing commercial aquaculture operation and statewide, important scenic view sheds. 2.3.7 Process Coniinerit9 113,W3 Comments were received concerning the availability of the Phase 1B Archeological Survey,SEQR Scoping and the DEIS public comment,period process conducted by the Planning Board. Response The Phase 1 Archeological Survey is available in its entirety through the Town of Southold website Laser Fiche system.The complete path is as follows:TownOfSouthold\Town Records\Planning Department\Applications\Conservation Subdivision\Pending\1000-17.-4-16 Tuthill Conservation Subdivision\Archaeological Survey Scoping The Planning Board, as lead agency decided that scoping was not required due to the 80/60 Conservation Subdivision design pursuant to Chapter 240 Subdivision of Land of the Southold Town Code.Relevant potential adverse impacts were identified by the Planning Board in recognition that a substantial reduction in yield on the four parcels is proposed.The Conservation Subdivision program mitigates most moderate to large impacts through design by requiring a minimum of 80 percent of the buildable lands to be preserved and 20 percent developed. In this instance the total area to be preserved equals 95.91 acres or 85 percent of the combined parcel acreage of 112.84. (DEIS) The DEIS Notice of Completion was filed on February 13,2019 and sent directly to numerous local, State and Federal agencies.Paperwork was also filed with the New York State Environmental Notice Bulletin to cause publication of the notice on February 20, 2019 and provide public comment. A public hearing on the DEIS was held on March 11, 2019 at 6:02 p.m. at the Town of Southold Meeting Hall , Main Road, Southold, NY and written comments were accepted to until March 25, 2019. No comments were received on the DEIS from local,State or Federal agencies. 39 Another concern raised was that access to the DEIS from the New York State Department of Y Environmental Conservation Environmental Notice Bulletin and Town of Southold website was inconsistent.The Planning Board office received complaints that certain people could access the documents and others could not.To rectify the situation,Planning Board staff contacted the t Southold Information Technology department.It was verified that the links to the DEIS documents worked on certain devices and not on others.All of the links were then changed to a working IP address which resolved the situation. Y i F 1 5 S f 40 APPENDIX A Vn To: Cummings, Brian A. El J�D Subject: RE: [SPAM] -did you receive? —,�„Planning Bo From: Cummings, Brian A. Sent: Wednesday, April 03, 2019 9:53 AM ��1 To: Michaelis, Jessica Subject: FW: [SPAM] -did you receive? f From: meeriit50t@aol.com-[mailta:rrieemt50@aol.cbM Sent:Tuesday, March 26, 2019 7:30 PM To: Cummings, Brian A. Subject: [SPAM] - did you receive? Hi Brian, I'm curious to know if you received my letter to the Planning Dept. If I don't hear from you I will presume that you have not, and send it again, as well as the additional concerns I am adding below. Another question I have for them is why 4-5 lots on SD are being allowed in R-200 zoning. The purpose of this zoning is to minimize the adverse impact of the effect of any development having close proximity to environmentally sensitive areas such as wetland, is it not? I do not see how a subdivision with 3 different geographical areas can offset this law, even if it is preserving many other acres. The acres that should be preserved are the ones which are the most likely to be adversely affected by development, are they not? Please let me know if you have receive my previous correspondence, and if it has been passed on to the Planning Department. Thank you, Mary Ellen Stevens From: Cummings, Brian A. �s Sent: Tuesday, March 26,2019 9:14 AM �°� To: Michaelis,Jessica Subject: FW:Tuthill Conservation Subdivision / SoUU101 l rovan— Planning Board From: Rblack [maiito.doriell6boatggtri6it,e6ml Cq)l prevtcz1y rcvd Sent: Monday, March 25, 20195:58 PM To: Cummings, Brian A. Subject:Tuthill Conservation Subdivision FYI Corrected Copy with local citizen addresses listed below From: Leslie Black-<les1kri6vs rbl�tck tt}�'"nam ul c'o 1? Date: March 23,2019 at 7:02:00 PM EDT To: bt`ian cuznri�i3i�st�t�tc�vvn.Solit}1F)1Cl t11.115 Cc: lesliep vcfblack(e�i,�,-- `—Ldorif Subject: Tuthill Conservation Subdivision To whom it may concern, Subject: Tuthill Conservation Subdivision I am writing on behalf of my family members who are all property and business owners in the Village of Orient. I would like to raise strong protest to the proposed Tuthill Conservation Subdivision. I am a 3rd generation homeowner of our family home and a business owner located on Village Lane in Orient. We think the time is now to enforce all codes,to the letter of the law,under which they are written and protect the environment,history, aesthetic and community of those that call Orient home. Too many parcels have been developed with maximum size homes on small lots and too many homes are being demolished thereby taking away much of the historic and village lifestyle with it While I understand that many acres would be put in preservation; I feel most of the preserved land would fail to be buildable anyway If we have min lots size, we should adhere to it. If they are preserving"unbuildable land" as part of this subdivision....it should be called out and refactored in the their request. If they are requesting to build or subdivision on ANY of the land that falls into Historic Preservation District that needs to be firmly prohibited. The subdivision request effects much of Orient and its inhabitants . It has potential to change Orient forever. Main Road ,Narrow River ,North Dyer each effer-ting nthrr homeowners; visitors and ycs even businesses as my business is built on people coming to Orient for a truly unique Historical lifestyle experience I would like to ask that NO zoning or lot size or other variances be granted to allow this "bundle type-- of building be permitted . I would also like to ask for a moratorium on i permitted house sizes that are permitted .Please do not support this Subdivision or building size application as it will have irreversible effects on ALL of the community. Sincerely, Leslie Black Robert Black Rick Peyser Jan Peyser 1420 Village Lane, Orient NY 11957 1240 Village Lane, Orient NY 11957 Phone : 610.574.3121 L From: Cummings, Brian A. Sent: Monday, March 25,2019 9:10 AMCEI 9�Jl To: Michaelis,Jessica _ Subject: FW: [SPAM] -Tuthill Conservation Subdivision MAP. 91X01 Southo o ToWri Planning Board From: Leslie Black [nal!o:le"sliegeyserblackggmail.corn] Sent: Saturday, March 23, 2019 7:02 PM To: Cummings, Brian A. Cc:_Ie51iepqyserblack(a)gmail:com Subject: tSP.AMa -Tuthill Conservation Subdivision To whom it may concern, i Subject: Tuthill Conservation Subdivision I am writing on behalf of my family members who are all property and business owners in the Village of Orient. I would like to raise strong protest to the proposed Tuthill Conservation Subdivision. I am a 3rd generation homeowner of our family home and a business owner located on Village Lane in Orient. We think the time is now to enforce all codes,to the letter of the law,under which they are written and protect the environment,history,aesthetic and community of those that call Orient home.Too many parcels have been developed with maximum size homes on small lots and too many homes are being demolished thereby taking away much of the historic and village lifestyle with it While I understand that many acres would be put in preservation,I feel most of the preserved land would fail to be buildable anyway . If we have min. lots size, we should adhere to it. If they are preserving"unbuildable land" as part of this subdivision....it should be called out and refactored in the their request. If they are requesting to build or subdivision on ANY of the land that falls into Historic Preservation District that needs to be firmly prohibited. The subdivision request effects•much of Orient and its in-babitant"s .It has potential to change Orient forever. -.Main Road ,Narrow-River,North Dyer each�effecting other honieowners,visitors and-yes even businesses as my business is built on people coming to,'Orient-fora truly unique Historical lifestyle experience. I would like to ask that NO zoning or lot'`size or other variances be granted to allow this"bundle type' of building be permitted . I would also like to ask for a moratorium on permitted house sizes that are pen-nitted . Please do not support this Subdivision of building size application as it will have irreversible effects on ALL of the community. Sincerely, Leslie Black Robert Black Rick Peyser Jan Peyser ' / From: Cummings, Brian A. . / Sent: Monday, March Z5, 20199:09AMFRECEIVED To: Michaelis,Jessica ` Subject: FVV [SPAM] - MykettertoSoutho|dTownMAR ' 5 LI 19 Attachments: Tuthill proposal response . , March 23'docx Sr whPlanning Board � � � � � From: Sent: Sunday, March 2-4, ^°^� `^`` "` . To: Cummings Brian A. � Subject: [SPAM] - My letter to Southold Tow . ' Hi Brian, ` I spoke with you last week about sending a response letter to the town regarding the Tuthill � subdivision proposal, and so, as you have suggested since Heather was away this past week, I am � sending ittoyou eothat you can forward itontoher. ^ Thank you for facilitating this. � Mary Ellen Stevens ` . � � ` � � ' ' / i ' z Mary Ellen Stevens March 24,2019 32217 Main Road Orient, NY 11957 Heather Lanza,AICP RECEIVE® Planning Director Town of Southold Planning Board 1� Ii� AR 2 5 2019 < 53095 Main Road __ " Southold, NY, 11971oulhio�d Town Planning Board Dear Heather, I attended the hearing at Southold Town on the proposed Tuthill Conservation/Subdivision on Monday, March 11th. I feel compelled, as a long time resident of Orient, to present my thoughts and concerns associated with this proposal. After reading the DEIS, I am struck by the disparity of the Adverse Impact-SEQRA Assessment, and the Beneficial Impacts, including the Proposed Mitigations presented by the Tuthill Oysterponds Holding Company. The attempt to erase, or"mitigate",the stated adverse impacts that this subdivision proposes is repetitions, and hints at an attempt at psychological brainwashing. The Tuthill's answers and responses to the statements in the SEQRA Assessment, as well as to other assessments made by various parts of the DEIS are repeated over and over, like a mantra, on the subjects of water quality impact-the oysters eating up the nitrogen, and regarding the overall effect of the proposal-the fact that they will be preserving 96 acres because of their intended cluster, rather than standard,type of subdivision. These responses make it appear like Orient is being done a big favor-despite the scientific studies to the contrary that have been done. I would say that a moderate to large impact is nothing to be taken lightly, when talking about areas which are already compromised by actions of landowners already misusing their land with fertilizers and chemicals, and overusing the water supply with filling pools and lawn irrigations, possibly due to unawareness. All the areas cited for development in this plan will be suffering further damage to the soil, fauna,flora, and waters. The area surrounding Munn Pond is filled with wildlife and vegetation which will be destroyed by the excavation of the area. Tearing up the open space on SD will most definitely disturb the ecosystem of the adjacent meadowland, bay frontage, and nearby estuary. It also stands a chance of appearing like a mini "Keys", or Dune road, if the largest allowed monoliths of houses are constructed on this "conservation"/subdivision I fully realize that this is their property, and they are entitled to do whatever they choose with it. I don't agree with it however. What is wrong with being a gnnd steward of their land, in keeping with their forefathers? I view this entire application as a greedy, unconscionable act in that they are knowingly disturbing the historic character of Orient, putting the water quality and quantity,the soil, and the ecosystem of the bay at risk of irreparable damage. By implying that they are "saving" it for future generations,they contradict what this very action will, in effect, do. Their"probable" and "should be" remarks in attempts to downplay the negative impact of their actions are not definite, nor exact, even if these statements are made in good faith. They should not be allowed to be used as arguments against scientifically tested studies. My father, Lloyd Terry, also had many acres of wetlands taken by Eminent Domain in the 1980's. Our family and forefathers were also excellent stewards of our land for 200+years. Dad, also, owned 80+acres which he willed to my siblings when he died in 2001. They have sold the Development Rights on the majority of those acres,thus assuring the prohibiting of any future housing developments. He had a similar option of what to do with the land when he finished farming. Having a true love for the land and the natural resources it held, he could not, in good conscience, pave the way for its development, even for the use of future generations. He was, however,forced to put in a minor subdivision in the 1970's so that he could pay off a large debt incurred from a bad year in farming. It was not an action well liked by the family, however it was a necessary one in order for him to continue farming. I am disappointed that a "first family" of Orient is taking the steps outlined in this conservation/subdivision. In owning five homes in Orient, do the Tuthills not have adequate housing to provide current and future generation Tuthills a place to spend summers/vacations "many years"from now? Perhaps other families who haven't sold development rights will do the same. Certainly the Town of Southold cannot grant permission for some, only to deny it to others. If this is granted for a proposal that will negatively impact a fragile region, surely there will be no problems with others having less impact. Where are our safeguards? When will it end? When our water needs to be carted in from off the island? When the shellfish and fishing industry is forced to end because of pollution from contaminants? When future generations have stopped coming to Orient because it is no longer the Orient they remembered as a child, and go elsewhere? Will the Tuthills feel the same and sell to "outsiders",thus ironically backfiring on the basic premise for this proposal in the first place? It has been made more apparent to me since the public hearing, that Orient desperately needs a housing size limit to fit the historic character of our hamlet. It also needs safeguards to insure that what is left of the natural resources in this delicate region will be protected from those who are unconcerned about our fragile state of affairs. We need controls on our water usage, and further housing developments because they will eventually suck out more water than can be replaced, other than with salt water. I think that any subdivisions proposed for an area that will be negatively impacted visually, and environmentally, such as this one, should not be allowed unless they are necessary for the greater good of the community. The Tuthill Conservation/Subdivision does not fit into this category. I continue to be amazed at the liberties of some residents in doing pretty much anything they want with their property. Helipads are one example Destroying wetlands and its inhabitants (even though supposedly protected),for personal gain is another. Turning a blind eye on some activities regardless of the ecological impact they create, while shining a spotlight on others which have no deleterious outcomes, hardly seems like a fair justice system. As a taxpayer I object to the continued raping of the land around me, and to the anticipated disastrous results of unchecked building engagements in Orient. As a taxpayer, I look to Southold Town to protect my water quality as well as my acre in Paradise. am opposed to this proposal, as well as the "alternative" proposal. If we had the proper land use restrictions and/or controls in place, we wouldn't be having this dilemma. I hope,and pray, that the officers in Southold Town begin looking at what the future of Orient will be, if drastic measures are not adopted now. I understand the concept of Cluster subdivisions vs Standard, and I agree they have been beneficial in many instances, however there needs to come a time when ALL subdivisions need to stop. I believe that time is now, before we are all sorry. i Respectfully submitted, Mary Ellen Stevens, longtime resident, and lover of Orient From: Cam Constantino <cammycon@aol.com> ��- Sent: Friday, March 22, 2019 10:51 AM RECEIVE To: Michaelis,Jessica Subject: Tuthill Subdivision Road I so-utnUC-1 Town To whom it may concern: Planning-Board ; I am a resident of Browns Hills and am writing in regards to the new road that is proposed to be put in to accommodate a new housing subdivision. Of course, you a`re awbre-that the location of this road will impact many of my neighbors directly which in and of itself should tie-addre'ted. My;understanding is that there.are already dirt roads in place that could very well take care of the new proposed housing as well as keep traffic accidents to a minimum. In addition the elevation of the area where the dirt road that already has access to the subdivision is at a lower elevation which would provide less runoff and erosion. The road proposed would be;a problem with the noise and dust elements to all of us whor;enjoy our,;quiet time in Browns Hills. Mybeautiful view.-of:l]he'fa6nIand below to-the bay will be,interrupted vuith,this newly'proposed road. 1 believe the Tuthill 16mi ily;should beheighbbrly,ah&take the feelings of Browns Hills residents into consideration. I thank you for your help in advance to work on this issue and hope you will take all of our feelings and thoughts into consideration. Carmela Constantino 2105 Browns Hills Road 3 From: William McNaught <wmcn@optonline.net> �)�prr Sent: Thursday, March 21, 2019 10:21 PM To: Michaelis,Jessica E C E I V E 1.J Subject: Tuthill:North Brown parcel MAR } 2 J_019 $(uthol 'own— To the Members of the Planning Board: Planning Board_ ' Y As a resident of Brown's Hills Estates which borders the North Brown parcel of the Tuthill Subdivision, I am writing in hopes that the Board will strongly consider an alteration to the current plan for the road on the North Brown parcel.The current plan is for the road to extend along the easterly border of the North Brown parcel.This is very close to five or six houses and within clear sight of several more houses.All those houses will be adversely impacted by the proposed road. The beautiful farmland views-getting so be so rare in Orient-would be severely marred by such a road.I very much hope that the proposed road on the eastern edge of the North Brown parcel could instead be moved to the westerly border. Thank you for considering this suggestion. William McNaught i RECEIVE® MAR 2 2 2019 SIL outhaT�°t aiirt Planning Board Southold Town Planning Board. March 17, 2019 3 Re:Tuthill Subdivision t Dear Board Members, It is commendable that the Tuthill family has decided to preserve the majority of their land holdings.They have consistently shown an affection for Orient and had the best interests of our Hamlet in mind. The issue that has concerned so many in our community is the proposed four building lots on the South Dyer property. We believe there may be a satisfactory compromise that would preserve the view shed entering Orient as well as the views from Oysterpond Lane. Rather than, as proposed, a wall of four building lots, consider an approval of two lots with the remaining two transferred to one of the other three parcels. Thank you for considering our comments and suggestion. r � 4� �/'u'l� �-' v r John and Thanne Dispenza Orient y . �.�,��, •� mss+ .'�� '�s ..'s, ,...�,; i rF ��" ' Fri � aq,�•�'�• '��R�. 1 t� d � � � m' _ •,tyil• � �. e ry+�, fA. BOX 282• 0 111 E^J1;NEW YORK 11957•OPUENTASSOCIATION.ORG EEIV .D S rJ rim Southold Town Planning Board MAR 21 2019 Jai I ao 1 � 54375 Main Road 31 Southold, NY 11971 Southot.. Town Planning Board S Dear Chair of the Southold Planning Board, �k� i)l 17�- F1' Board members from the Orient Association attended the March 11,2019 Southold Planning Board hearing on the Visual Impact Study for the Tuthill Conservation Subdivision DEIS applica- tion. The views of the Orient Association were presented on the accuracy of the Visual Impact Study submitted to the Planning Board. While we seek an accurate rendering of house sizes on the South Dyer subdivision,we also want to express our full appreciation of the Tuthill Family for undertaking a conservation subdivision that preserves a great deal of open space. In addi- tion,we welcome the opportunity to present our concerns at additional hearings,including at the Historical Preservation Commission. The Orient Association has spent several years working on a hamlet plan that will attach to the new Comprehensive Plan being created for Southold Town. Our hamlet plan has been sup- ported by a significant portion of the community, planning staff and Town Board members, A substantial portion of Orient residents overwhelmingly endorsed several key proposals,two of which are to reduce the allowable house size to keep new homes in scale with the existing ar- chitecture and to preserve viewsheds. Many surrounding townships already have such re- strictions in place. Therefore,we request an accurate portrayal of the maximum house size allowable in the Visual Impact Study, and a full rendering of all aspects of that impact on the viewshed: o Depict Maximum Allowable House Size: The Orient Association Board is writing now to 'request that the Tuthill Subdivision Visual Impact Study represent a full and accurate rendering of the maximum house size possible on the site without including accessory structures. The existing Visual Impact Study depicts a house that is described as appro- priate and in keeping with the surrounding village of Orient. However, it does not de- pict what is the maximum allowable size under the current Southold Town code without the"accessory structures". We request that the Visual Impact Study be redone with the house sizes shown at the maximum allowed without accessory structures. We believe that it is the purpose of a Visual Impact Study to show what the houses would look like if they were built to the maximum size permitted However, in depicting the houses in the study,the applicants utilized setbacks that they considered appropri- ate (R-80 setbacks), even though the lots are approximately one acre and would be enti- tled to R-40 type setbacks.This resulted in a depiction of buildings that are much smaller than the maximum that would be allowed on those lots. Under current law, the maximum allowable building area on lots of that size is 8,000 sq.ft., which would create a two-story house of 16,000 sq.ft. No one living on the North Fork of Long Island would ; think that a home of 16,000 sq.ft. is within the scale of the current village homes which are on average less than 2,500 sq.ft. ®. Viewshed Geographic Vantage Points: We also note that the Visual Impact Study did not take into account the impact these houses will have on Orient residents living on,or passing through, Oysterponds Lane,Skippers Lane,and even the rear yards of some Vil- lage Lane houses.We request additional vantage points be included from each of these areas. As part of viewshed preservation,we note that the Tuthill Family DEIS recognizes an op- tion to build 4 houses on the South Dyer site, rather than 5. The 4 lot option is prefera- ble to the 5 lot option as it preserves a greater portion of the viewshed. • Use of Advanced Septic Systems: As part of the Orient Plan which we mentioned above,the Orient Association and a majority of Orient residents support the require- ment that advanced septic systems be installed on any building in a fragile environment , such as South Dyer. We also understand the intent of the Tuthill Family is to pass this land onto younger members of the family,anticipating that no houses will be built in the near future.Their expectation is that when family members do build,they would do so in keeping with size and style norms of the Village. However well-intentioned the family is,there is no guarantee under current code that houses on these lots will be in keeping with the size and norms of the Village. Respectfully, The Orient Association Board ,JOEL 1. KLEIN,, Ph.D., .��RPA 635 Lloyds Lane,Mattituck,New fork 11952 March 19,2019 RECEIVED-- -., Southold Town Planning Board 1 MAR 12019 Town Hall Annex Building 1 54375 Route 25 �- u-Oiol'd 7i5VV P.O.Box 1179 Planning Board Southold,NY 11971 RE: DRAFT ENVIRONMENTAL TMAPCT STATEMENT(DEIS) PROPOSED TUT13ILL CONSERVATION SUBDIVISION LOCATED AT 21505 ROUTE 25 SCTM#1000-17-4-16,1000-17-6-14.2,1000-18-3-30.3,AND 1000-18-6-17.3 ZONING DISTRICT:R-80 AND R-200 Chairman Wilcenski and Members of the Board: I am writing to expand and provide additional information relating to the comments I made at the March 11, 2019 Public Hearing relating to the DEIS for the proposed Tuthill Conservation Subdivision (the Project). As indicated in my previous remarks, my concerns are primarily, but not exclusively, with the adequacy of the information in the DEIS relating to historic and archeological properties, and withwhat I believe to be irregularities in how the State Environmental Quality Review Act(SEQRA) process for this project has been handled. Given the deficiencies in the DEIS described below,I believe that the Planning Board erred when on February 11,2019 it deemed the DEIS "complete for public review and comment," and has failed to take the requisite"hard look"at the Project's environmental consequences. I want to repeat what I said at the Public Hearing that I am not advocating for or against the Project. I believe that the basic idea for the conservation subdivision is a good one. My concerns relate to a failure on the part of the Applicant and the Board to fully identify both the nature and extent of potential environmental impacts, and potential mitigation for those impacts, that the Board itself identified as potentially significant when it completed the Environmental Assessment Form(EAF)for the Project,and issued a Positive Declaration requiring a DEIS,in 2015. I believe that both the inadequacies in the DEIS,and the way the SEQRA process has been handled,leave the actions of the Board relating to the SEQRA process and subsequent actions relating to the Project subject to legal challenge. I am concerned as a Town of Southold taxpayer that tax dollars may have to be spent defending any such actions. Likewise, both the Applicant, and potential bringers of legal challenges, who will almost certainly be Southold residents, will also be forced to incur legal expenses. Finally, I believe, as I will explain below, that the Board's premature acceptance of the DEIS, has exposed the Applicant to a likely significant financial risk that could be avoided. Visual Impact to Historic Resources One of the principal reasons for the Board's Positive Declaration resulting in the requirement that a DEIS be prepared,was the determination as stated in the attachment to Part 3 of the EAF that"The South Dyer property is adjacent to the Orient National Historic District . . " The.Pnsitive Declaration goes on to say that"Potential moderate to large adverse impacts to the National Historic District must be assessed."In spite of this recognized concern, the DEIS provides virtually no information dealing with if or how historic properties would be affected by the Project. Throughout the project review process beginning in 2015 there were numerous calls for a visual impact study and a viewshed analysis. The terms seem to have been used interchangeably,yet they are not the same thing, and this has caused considerable confusion. A viewshed analysis is usually a precursor to a visual impact analysis. It defines the geographic area--called the Zone of Visual Influence (ZVI)--from within which a proposed project will be visible.It is the basis for determining where visual impacts must be considered. No viewshed analysis was carried out for this project. This confusion could have been avoided had the Applicant taken note of the October 23, 2014 Planning Department's mention to the Applicant that the "New York State Department of Environmental Conservation has produced a policy memorandum on assessing visual impacts." The Planning Department also provided a web address where that memorandum, Assessing and Mtigating Visual Impacts (DEP-00-2), could be found. That memorandum discusses the relationship between a visual analysis and a viewshed. In an attempt to address the question of visual impacts in general, not specifically impacts to historic , properties, the Applicant retained the services of Sam Fitzgerald Architect PC. An October 16, 2015 report entitled Visual Impact,Study (VIS)–South Dyer Lots–Supplemental Report,was prepared for the ; Applicant. It is unclear when this report was fust made available to the Board(see below). The DEIS title page identifies Sam Fitzgerald-Architect as the party that prepared the portions of the DEIS dealing with"Aesthetic Resources,View Sheds,Architectural Perspective."Only the 3-page text of the visual assessment is included in the DEIS. The 54 pages of accompanying photographs and ; photosimulations, although they can be found on the Town website, have not been included in the DEIS (although the DEIS says the "complete report can be found in Tab 12)". The DEIS table of contents incorrectly states that 36 pages of photosimulations are included. The Visual Impact Study states that its purpose "is to accurately portray the visual impact of the five South Dyer lots along Rt. 25 and Orient Harbor as if the lots were fully developed." It is quite clear that the Visual Impact Study limited itself to only the consideration of impacts to aesthetic–not historic— resources—the NYS Route 25 Scenic Byway and Orient Harbor. It should be noted that the DEC guidance memorandum noted above clearly states that aesthetic resources of statewide significance can include "propert[ies] on or eligible for inclusion in the National or State Register of Historic Places [16 U.S.C. § 470a et seq., Parks, Recreation and Historic Preservation Law Section 14.07]". The Orient Historic District is one such property and, as discussed below, the Applicant made no attempt to identify National Register"eligible"properties that might be affected. The photosimulations which form the basis for the Visual Impact Assessment are problematic in several regards. The DEIS states that"At the Town's request we developed a worst-case visual impact study."It is unclear whether the simulated house in the photographs do represent the "worst-case." One of the reasons for this is that neither the Visual Assessment nor the DEIS states the size or actual height of the simulated houses. The DEIS states that computer modeling was used to"adjust"the simulated houses"to maximize the profiles visible to the public." Presumably this is referring to views from Route 25—not views from within the Orient Ilistoiic District.The Visual Assessment also notes that the"houses and lots meet the maximum bulk regulations for the zone . . ." It goes on to state that"the maximum allowable Building Area would be 8,000 sq ft."(which could include accessory structures, decks, swimming pools, etc.). No such structures are visible in any of the photosimulations. This leaves open the questions: how large are the simulated homes, and how do they compare to the sizes of existing houses in the associated viewsheds?l The photosimulations are also misleading in that they show the simulated houses with associated simulated mature landscaping which in many cases partially blocks views of the simulated homes. Even if the Board were to require, as part of its site plan review, specific landscaping requirements, it is obvious that it would be many years before the conditions portrayed in the Visual Assessment Study would actually exist. The photosimulations also fail to account for the possible inclusion of overhead electrical service connections which could have a significant visual impact. The DEIS is also silent on this. Does the Board plan to include a requirement that all required utilities be underground installations as a mitigative measure? One of the principal failings of both the DEIS and the Visual Assessment is their failure to address impacts to the Orient State/National Register Historic District. The DEIS notes that the Lead Agency [Planning Board's] Concern Area regarding historic resources is "Potential moderate to large adverse impact of South Dyer, which is adjacent to the Orient National Historic District." It goes on to conclude that the proposed 5 new single-family house lots "will not destroy or alter any of the Orient Historic District site, property, setting or integrity. No evidence to support this conclusion is presented in either the Visual Assessment or the DEIS, and there is evidence to support a contrary conclusion. The'0xiPrit 1-1i*ric District is not a4jrrcent"tri the Prbject-. The five proposed South Dyer'building lots and their associatcd,house are all located wiffiln the district2. Views obsciv_ed bypcdestriaiis: bicyclists, and motorists traveling through the Orient Historic District, particularly along Racketts Court, Oyster Ponds Lane, and Skippers Lane, will be changed to an unknown degree (unknown because these views, which are clearly within the Project viewshed,were never considered during the impact analysis).Views both of and from several individual historic properties within the Orient Historic District,which are also designated Southold Historic Landmarks,will also be affected. 1 When a representative of the Orient Association expressed concern at the March 11, 2019 Public Hearing about the size of permitted houses, noting that an 8,000 sq. ft. Building Area would permit construction of houses considerably larger than those found in Orient,the Board Chair incorrectly stated that the 8,000 sq.ft. was referring to the size of the houses—not the Building Area. z The February 12,2015 Southold Planning Department's Staff Report to the Board states that"Portions of the Orient National Historic District are contiguous with South Dyer. .. this threshold would classify the entire action as a Type 1. The LWRP map below shows the . . . District boundary just east of the South Dyer property.This is our best example. The NRHP website has not digitized the map yet." The LWRP map included in the report is of such small scale as to be virtually useless.It is true that the NRHP website does not have a digitized map showing the Orient Historic District boundaries. However,a digital copy of the NRHP form, which includes both a map, and a metes-and-bounds description for the Orient Historic District was,and is,available on the New York OPRHP website through OPRHP's Cultural Information System (CRIS). A GIS-based scalable map showing the Orient Historic District boundaries on a variety of map and aerial photo bases,was,and is,also available. As noted above,the Applicant made no attempt to identify State/National Register"eligible" properties that might be affected,nor does the DEIS address"eligible"properties. On January 13, 2015 the Planning Board Office notified the Applicant of the resolution adopted by the Board classifying the Project as a Type I action under SEQRA. The resolution reads,in part: "WHEREAS, pursuant to 6 NYCRR Part 617.4(b)(9), another Type 1 Action is " any Unlisted Action(unless the action is designed for the preservation of the facility or site) occurring wholly or partially within, or substantially contiguous to, any building, structure, facility, site or district or prehistoric site that is listed on the National Register of Historic Places ; or that has been proposed by the New York State Beard on Historic Preservation for a recommendation to the State Historic Preservation Officer for nomination for inclusion in the National Register, or that is listed on the State Register of Historic Places (the National Register of Historic Places is established by 66 Code of Federal Regulations(CFR)Parts 60 and 63, 1994 [see 617.17]", and WHEREAS, this proposed subdivision is located substantially contiguous to the Orient National Historic District located to the east of the South Dyer property; and" . . Y [therefore this is a Type I action]. The resolution references a version of 6 NYCRR Part 617.4(b)(9)that had been superseded at the time it was cited.The correct version reads: 4 "(9)any Unlisted action(unless the action is designed for the preservation of the facility or site), that exceeds 25 percent of any threshold established in this section, occurring wholly or partially within,or substantially contiguous to,any historic building, structure, facility, site or district or prehistoric site that is listed on the National Register of Historic Places (voltune 36 of the Code of Federal Regulations, parts 60 and 63, which is incorporated by reference pursuant to section 617.17 of this Part), or that is listed on the State Register of Historic Places or that has been determined by the Commissioner of the Office of Parks,Recreation and Historic Preservation to be eligible for listing on the State Register of Historic Places pursuant to sections 14.07 or 14.09 of the Parks, Recreation ` and Historic Preservation Law;" The differences are significant because; 1) they makes clear that "eligible" properties are also covered. Eligible properties include all historic pro perties that in the opinion of the State Historic Preservation Officer (SHPO-the FIP e OPR C:ommissioner)3 satisfy the eligibility criteria for the State or National Register of Historic Places. In reviewing the potential effects of a project on historic properties, all potentially eligible properties— including those not previously identified—must be considered. That is why historic architectural surveys of what is known as a project's Area of Potential Effect(APE)are necessary. In the case of above-ground historic structures the APE is generally considered to be the viewshed associated with a historic structures setting; and 3 The Commissioner of the New York State Office of Park, Recreation and Historic Preservation (OPRHP) is also the New York State Historic Preservation Officer (SHPO). OPRHP's Division for Historic Preservation sei ves ds the SHPO staff. The acronyms OPRHP and SHPO arc used here interchangeably. 2) because Section 14.09 of the Parks,Recreation and Historic Preservation Law is cited. Section 14.09 requires all state agencies, prior to issuing permits (such as the DEC Article 25 permit that will be required for the Tuthill Subdivision)to obtain SHPO comments on the potential effects of an undertaking on historic properties, and to determine if prudent and feasible project alternatives that could eliminate or minimize any adverse effects. OPRI P's Cultural Information System (CRIS) indicates that there are at least ten unevaluated historic homes or structures within 300 feet of the North and South Dyer parcels, and an additional nine within 300 feet of the North and South Brown parcels. Most of these are located along Route 25, and many of them will have views of the proposed house lots on the South Dyer parcel. Although these properties are classified as"unevaluated"by OPRNP, all but five of the nineteen are included in in the 1987 Society for the Preservation of Long Island Antiquities (SPLIA 4) survey, sponsored by the Southold Town Community Preservation Office, and the 2013 Historic Building/Places Inventory sponsored by the Southold Landmarks Preservation Commission. Complete sets of both inventories are posted on the Town of Southold website. Neither appears to have ever been consulted by either the Applicant or his visual assessment consultant. DEIS does not mention these properties, or consider if or how they might be affected. Prior to its January 13, 2015 resolution, on October 8, 2014, the Planning Department submitted a completed Project Review Checklist to OPRHP "seeking information on potential cultural resources that could be impacted on or near each parcel for SEQR purposes."The Checklist calls for"maps locating the project in the community[which] clearly show street and road names surrounding the project area as well as the location of all portions of the project. Appropriate maps include tax maps,Sanborn Insurance maps, and/or USGS quadrangle maps."The Planning Department checked the box indicating such maps were attached. In fact, what are attached to the Checklist are aerial photographs with only a few street or road names, and with the four project parcels (one per photo) identified only by arrows. No boundaries or limits of the four parcels are indicated. On January 26,2015 OPRHP responded via the CRIS system: "the project is adjacent to properties that have been determined to be potentially eligible as part of an historic district along NY Route 25.In addition to the Phase 1B [archeology] report, please document any adjacent properly 50 Years of age or older.Documentation should include original photos of each exterior elevation, construction date if known, current address, and comments about current condition. A brief history of each property would also be appreciated. If you have any questions, please contact Lorraine Weiss in the Survey Unit at 518-268-2129. .." This request for additional information necessary for OPRHP to render an opinion regarding possible impacts of the Project on historic properties was not responded to, in spite of a subsequent request from OPRHP for additional information (see below) The DEIS makes no mention of the fact that OPRHP, acting in its capacity as the State Historic Preservation Office (SHPO), was consulted, that OPRHP had requested additional information,and that the requested information was never provideds. SPLIA is now known as Preservanon Long Island. s The Phase IA archeological study,discussed below,does contain limited information on five standing structures on or adjacent to the Project Although the Planning Department contacted OPRHP to seek that office's comments, neither the Planning Department nor the Applicant has ever consulted the Southold Historic Preservation Commission. This was pointed out by the Commission Chairman at the Marchl1, 2019 Public Hearing. This remains a significant error.The DEIS states: Based on the Orient Historic District website, the houses in the district cover several different styles. Cape Cod,framed dwellings sheathed with shingles or clapboard having a moderately pitched roof, Federal, Greek Revival, Iialianate, Second Empire, rural vernacular frame architecture and the ornate frame structures of the late Victorian era. The website describes Orient as exhibiting a notable congruity in appearance despite the numerous styles represented in its structures. Our intent would be to develop the SD House lots in a way that would harmonizc with the range of styles present in the District. We would build all houses in accordance with any standards set by the Zoning or Building Departments in affect at the time of development. There is no "Orient Historic District website." What is being referred to is a commercially sponsored website called Living Places, from which four pages have been extracted and inserted into the DEIS.This website appears to be the sole source of information used to establish the context for evaluating impacts to the historic district. Determining if future homes would "harmonize" with existing homes in the - historic district is not a decision that can be made by either the Applicant or the Board. Stating that houses would be built"in accordance with any standards set by the Zoning or Building Departments"is not sufficient,and does not eliminate,mitigate,or even address,potential impacts to the historic district. The DEIS fails to consider or note that any homes constructed on the five proposed South Dyer lots ; Iocated within the limits of the Orient Historic District would have to obtain a Certificate of Appropriateness from the Southold Historic Preservation Commission. It is the Commission, not the Applicant,the Planning Department,the Building Department,or the Zoning Board of Appeals, that will determine what is architecturally appropriate for a new home in the historic district. Finally, the Planning Board's July 6, 2015 Positive Declaration states that"the following [SEQRA EAF questions]must be addressed: . . . ii.The proposed action may result in the alteration of the[historic]property's setting or integrity. iii. The proposed action may result in the introduction of visual elements which are out of character with the[historic)site or property,or may alter its setting. The DEIS does not adequately address these issues. In summary, in regard to historic(non-archeological)resources the DEIS: incorrectly notes that the Project is adjacent to,rather than partially within,the Orient Historic District; makes no mention of historic (non-archeological) properties, other than the Orient Historic District, that could be visually(or otherwise)impacted by the project; • makes no mention of previously inventoried individual historic structures located outside the Orient Historic District; • bases its assessment of aesthetic and visual impacts to historic properties on a visual impact assessment that was designed only to address aesthetic impacts to a portion of the Route 25 Scenic Byway; • does not address visual impacts to the Orient Historic District; • bases its limited visual impact assessment upon photosimulations which may not accurately represent post-construction views; makes no mention of the fact that OPRHP, acting in its capacity as the State Historic Preservation Office (SETO), was consulted, that OPRHP had requested additional information, and that the requested information was never provided; * fails to take into account possible, because they were never solicited, comments from the Southold t Historic Preservation Commission; o incorrectly implies that it is the Applicant who will decide whether future homes "harmonize' with existing landmark structures within the Orient Historic District;and fails to consider that Certificates of Appropriateness from the Southold Historic Preservation Commission will be required for proposed homes within the limits of the Orient Historic District. Impacts to Archeological Resources In 2011 the Applicant had prepared what is known as a Phase IA cultural resources assessment for the Project. This is a desktop study to identify previously known and recorded historic structures and archeological sites that could be affected.The report was prepared by Tracker Archaeology Services,Inc. The Town of Southold received the Phase lA report on July 3, 2014, and at some point submitted it to OPRHP for comment, because in response to the Planning Department's October 8, 2014 information request to OPRHP(see above), OPRHP responded via CRiS on January 26, 2015, and again in writing on March 12,2015,as follows: "We have reviewed the report entitled "Phase IA Archaeological Documentary Study for the Proposed Tuthill Subdivision, Orient,Town of Southold, Suffolk County,New York"(dated March 2011). OPRHP concurs with the report recommendation,that a Phase I136 archaeological investigation is warranted,prior to any proposed development that will involve ground disturbance." The Phase IA is relatively brief.It concluded that"the entire study area is seen as having a high to higher than average potential for the recovery of prehistoric sites" [and] "the entire study area was seen as having a high to above average potential for nineteenth century [archeological] sites and a higher than average potential for encountering historic aboriginal sites." These conclusions were the basis for recommending that a Phase 1B field investigation be conducted_ In conformance with OPRHP's 2005 Phase 1 Archaeological Report Format Requirements,the Phase 1 A report includes,in tabular form,the results of a search of OPRHP's archeological site file for information on previously recorded archeological sites within one mile of the Project. Eight sites are listed in the 6,,A Phase 1B investigation consists of a systematic, on-site Geld inspection designed to assess archaeologically sensitive areas and environmental characteristics relevant to site locations and formation processes. Such investigations include, but are not limited to systematic surface survey, subsurface shovel testing, and remote sensing studies . . Field-testing procedures for Phase IB Field Investigations should verify site locations provided by informants,confirm site locations suggested by the literature search,and discover previously unknown sites.The areas to be subjected to a field survey are selected on the basis of the data gathered during the Phase IA evaluation and all probable locations of project construction, staging areas, or any other areas of potential impact." (From: Standards for Cultural Resource Investigations and the Curation ofArchaeological Collections in New York State). I, table. Under the table heading"Distance from APE'ft(m)"two sites are identified as"on property" and one as"adjacent": NYSHPO Site 10310.008 is listed as "on property (So. Brown)." Under the heading"Site Description" the report says"5 Acres Indian Village:area of several camp[sic]about 600 years prior to Euro-American settlement, relics found, shell midden (Late woodland[sic]?" The Phase lA report omits significant information: OPRHP's Archeological Site Inventory form for Five Acre Indian Village Site notes that the Oyster Ponds Histprical Society had erected a.plaque at;the lodations,tb6f=excavations 63.=R.-Latham, R. Wi;gins had taken p1ace in 1925 and l 968,and'that"Tabor&Sons cxhausted'the area many years ago.i' The site form lists as references the Southold Bicentennial Map and R.Latham 1978. NYSHPO Site 10310.0254 is listed in the Phase IA report as "on property (South Dyer)." Under the heading"Site Description"the report says"Major Banks [site] (form unfilled),no info."Information not included in the Phase 1A report is that OPRHP's Archeological Site Inventory form for the Major Banks Site gives its location as "North Bank of Orient Harbor," and that the"Source of Information"about the site is listed as the Museum at Southold,presumably the Southold Indian Museum. NYSM [New York State Museum] Site 697 is listed as "adjacent(No_ Brown).Under the heading"Site Description" the report says "no info." The Phase lA is particularly deficient in regards to NYSM 697. ; NYSM 697 is identified in OPRHP files as the Orient No.l Site. This site is part of the Orient Burial Complex. It is arguably the most important site ever studied on Long Island, and is one of the most significant sites in northeastern United States. No mention of the Phase IA study or its results can be found anywhere in the DEIS. On March 12, 2015 the PIanning Department notified the Applicant that it accepted OPRHP's recommendation that a Phase 1B archeological investigation be undertaken,and referred the Applicant to OPRHP's 2005 Phase I Archaeological Report Format Requirements. On March 24,2015 the Applicant advised the Planning Department that Tracker Archeological Services, Inc. had been retained to conduct the Phase 1B investigation. The Phase 113 investigation was conducted in the summer of 2015 and a report of that work, dated December 2015 was prepared.The report does not incorporate or consider the results of the Phase 1 A investigation. The Board's July 6, 2016 Positive Declaration states "The action is located within an Arebeo-sensitive Area. The New York Department of Parks, Recreation and Historic Preservation is requiring a Phase I Cultural Assessment for all areas to be developed.The assessment must include the results of the study. It is unclear when the Phase 1B report was submitted to OPRHP. However, on June 11, 2018 Dr. Timothy Lloyd of OPRHP's Archaeology Unit advised the Planning Department via CRIS as follows: "I have reviewed the report of the archeological survey of the. . . project area. The area surveyed does not correspond with the area of potential effect that was initially submitted for this project.I would like to see project plans to determine of the area surveyed was sufficient. Please review the specific information 7 APE refers to the "Area of Potential Effect" which in this case refers to areas of Project-related ground disturbance. 8 The Town Historian has advised that the plaque was removed to deter looters q The site is far from exhausted as evidenced by the results of the Phase 1B arrheningiral survey,SPr hrinw) t request (s) below and click the Process button to respond to each request." The specific information request reads:"Please provide project plans." As of last week, OPRHP has advised me(T.Lloyd,personal communication)that they have not received the requested information. OPRHP has not commented on the results of the Phase 1 B investigation or on how the Tuttle Subdivision project could affect archeological resources. With a few exceptions the Phase 1B fieldwork seems to have been conducted in a satisfactory manner. However,Phase 113 report has some significant failings. OPRHP's Phase I Archaeological Report Format Requirements specifically call for Phase 113 reports to , include "Estimated site size (horizontal and vertical)based on artifact distribution, topography, etc. Site boundaries must illustrate maximum possible boundaries until closer interval testing is conducted.Please note that the site boundaries for each site identified must be included on the project map so that the ; relationship of the site to the APE is clear." Although at least one aboriginal archeological site was x located during the Phase 1B investigation on the South Brown parcel building lot, no information is provided regarding the boundaries of the site as determined through the surface collection of artifacts.No mention is made of the fact that this area may correspond with the reported location of the Five Acre Indian Village Site(even though this was noted in the Phase IA report). No photographs of the artifacts recovered,nor any detailed artifact descriptions are included in the report. On the North Dyer parcel the report states that"The remains of an early twentieth century building(brick and lumber), about 20 feet by 35 feet, destroyed by a hurricane of 1938 was also encountered, mostly buried_According to the property owner,this was the remains of the"House of 7 Gables",from Orient.A single course stone foundation base was found in the vicinity of the house rubble. According to the property owner,this may have been a foundation for either 1 of the outbuildings of the House of 7 Gables or the old school house." It is unclear from the report exactly where on the North Dyer parcel this historic period archeological site is located. There is no mention or discussion of this site in the DEIS The text of the DEIS limits its discussion of possible impacts to archeological resources to four sentences: "The Archeological IB Survey did Shovel Tests and walkovers covering our 17 proposed lots, roads and some additional areas. No historic artifacts were found. However, there were white quartzite artifact fragments found on the proposed SB lot, which is evidence of a prehistoric site. If we want to proceed with this SB lot location, Phase I1 intensive testing is recommended." The three pages of the Phase 1 B report text are incorporated into the DEIS, but the 53 pages of maps and data appendices have been omitted. The "white quartzite fragments" referred to are, in fact, 51 prehistoric artifacts from the South Brown parcel, 9 of which were classified as tools, at least some of which should be amenable to style dating.The remainder was mostly stone tool manufacturing debris known as debitage. As noted above, it seems likely that this is one of the previously known Native American sites reported in the Phase 1A report. I would add that the number of artifacts, and the ratio of tools to chipping debris, especially given the history of prior artifact collecting on the property, is suggestive of a major Native American habitation site. Again, as noted above, no attempt was made to delineate the boundaries of this site within the South Brown parcel. Although OPRHP calls for this to be done during Phase 1 B investigations,it may not have been done because the investigator recommended a Phase II intensive testing investigation to collect more information. However, he made a serious error when he states that this need not be done until "prior to ground breaking or construction which threatens site information". While this type of recommendation is appropriate in many cases, it not appropriate here for several reasons. First, in the absence of a specific condition in any future site plan approval, the Applicant(or any future owner of the affected lot)cannot be required to conduct any additional archeological investigation. Second, the discovery of a significant archeological site, especially one which might contain human remains, on a given parcel either before or during construction could render the parcel unusable, or usable only after a costly archeological data recovery project. r Requiring the Phase 11 investigation as part of the DEIS process would have had two benefits: 1)it would eliminate the potential problem of a discovery being made on an approved building lot, by allowing a relocation the proposed lot outside the limits of the archeological site, and 2) it would provide for the permanent preservation of the archeological site within the conservation subdivision. The DEIS makes no mention of the fact that although comments on the project were,solicited from OPRHP, no final response was received because information OPRHP requested so that they could complete their review of the Phase 1B archeological study was never provided.As a result, and because the Board made no attempt to seek independent expert advice concerning archeological issues,it has been G forced to rely solely on the information provided by the Applicant. As a result, it is my belief that the Board failed to take a"hard look"at the potential impacts of the Project on archeological resources. t Irregularities in the State Environmental Quality Review Act(SEQRA)Processlo In addition to the DEIS' problems relating to archeology and historic resources I also want to comment on the how the SEQRA process for this project was handled. No formal scoping was done for this projectll. Although scoping was not required under the DEC SEQRA regulations in force at the time the EAF was being prepared,DEC guidance highly recommended that it be done for all projects_ The crucial importance of scoping was formalized on January 1 when the SEQRA regulations were amended to now require scoping for all Type I and Unlisted actions. Had scoping been done the problems with the work scopes for both the visual impact study and the archeological investigations might have been avoided.For example, on January 16,2015,the President of the Orient Association advised the Planning Board that "A narrowly-scoped DEIS could be carefully tailored to refine and resolve the visual impact aspects of this application that have already been identified during the early stages of review." Io In addition to the issues discussed below, the DEIS also suffers from several other deficiencies. SEQRA regulations at 6 CRR-NY 617.9b3 state that an EIS must be preceded by a cover sheet that identifies"the date of its acceptance by the lead agency; and in the case of a draft EIS, the date by which comments must be submitted." Both dates are missing from the DEIS cover sheet for the Project.While not significant In itself, this speaks to the entire lack of care with which the entire DEIS was prepared and made available for public review. IIThe Board's July 6,2015 Positive Declaration notes that no scoping was done for the Project. The record for the Tuttle Subdivision project contains no explanation, especially given the well- recognized concerns about the Project, as to why the Planning Board determined that no scoping would be necessary. More than a dozen Draft Environmental Impact Statements can be found in various locations on the Town of Southold's website. In all but one of these cases, some form of pre-DEIS scoping seems to have been conducted. Why was no scoping required in this case? A second issue that needs to be mentioned is the manner in which the DEIS has been made available to the public for review.When the Board voted to declare the DEIS complete,the legally required notice of that, and the announcement of this hearing, was published in the DEC's February 20 Environmental Notice Bulletin. SEQRA regulations require that a DEIS be accessible electronically.The ENB notice for this project states that"The Draft EIS is available from the Southold Town Planning Department and on line at: http://www.southoldtownny.gov/270/Environmental-Impact-Statements." Almost everyone I have spoken with who has tried to access the DEIS through that link, have told me ' that when they try to access the Tuttle Subdivision DEIS through that link they get a message that says the website is online but isn't responding.On February 28 I advised the Planning Department that the link was not functional. Later that day the Planning Department responded, saying that the Information Technology department had checked the link and it was working. I again informed the Planning Department it was not, but received no further response..It's unclear why some people have been able to access the DEIS in this way but most others cannot. Admittedly,one can find the DEIS on the Town's website. It can be found by taking the following steps: • Going to the Town of Southold website,then m going to the"How do I"tab,then ® going to the Public Records link,then • going to the Planning Department Folder,then • going to the Applications folder(not the SEQRA documents folder),then • going to the Conservation Subdivision folder,then • going to the Pending folder,then m going to the Tuttle Conservation Subdivision folder,then • going to the DEIS Received 9-14-2018 folder. One can then attempt to download DEIS through Laserfiche. The document at that location is the final version of the DEIS. However, the metadata for the site indicates that it was not posted until March 4, 2019.Prior to that date while all of the text and attachments to the DEIS were available on line,they were seemingly randomly located throughout a more than 400 page document simply labeled Tuttle Conservation Subdivision. The inability of the public to easily access the DEIS runs contrary to both the intent of the State Environmental Quality Review Act and general principles of open government. Finally, I want to raise one other procedural issue. On February 12, 2419 the Board issued its formal Determination of Adequacy for the Tuttle Conservation Subdivision DEIS. On February 25,2019,almost two weeks later, I attended a Planning Board Work Session at which the principal agenda item was a review of the Tuttle Conservation Subdivision "Visual Impact Study in DEIS." At the work session individuals from the Planning Department made a presentation to the Board which included a display of some of the photosimulations from the visual impact study At the conclusion of the work session I observed members of the Board being given binders which appeared to be copies of the Visual Impact Study. Why did the Planning Board vote to deem the DEIS adequate when it had not yet reviewed the results of the study dealing with what is perhaps the most consequential environmental issue associated with the Project? All of the issues I have raised here could have been addressed had the Board,once it was made aware of their general nature at the Public Hearing, called for either a Supplemental DEIS to be prepared, or minimally kept the Public Hearing open so that the Applicant and the Board could have additional time to consider the issues of concern. Instead, without any discussion, the Board voted to close the Public Hearing. f Given the limited time within which a Final EIS must be prepared,I find it hard to believe that all of the issues raised here can be adequately addressed in that document.The Board has left itself in the position of having to deal with most of them as part of the Site Plan approval process. This will be particularly problematic since the most likely way to deal with most of the issue raised here will be through relocating proposed building lots. That, in turn, could necessitate the need for additional visual and archeological studies to assess changing impacts. Sincerely, J Joel I.Klein,PhR,RPA S From: Bufk!ns, Erica Sent: Tuesday, March 19, 2019 9:40 AM To: Terry, Mark;Michaelis,Jessica;Lanza, Heather, Palmeri,Allison Subject: FW:Tuthill Subdivision North Brown Parcel FYI! _' ECEIVED From: david backus fmailto:dmbackus ime.conil h 1� Sent:Tuesday, March 19, 2019 9:13 AM _ To: Bufkins, Erica soisthof�'T�w�i, Subject: Tuthill Subdivision North Brown Parcel Planning Board Dear Southold Town Planning Board, I am a Iong time Brown Hills resident and I am shocked that a plan to divide farm fields would be brought before your board.The North Brown Farm field will continue to be farmed and is adjacent to two more farm fields creating the uninterrupted farm vistas favored in conservation subdivision. I would also like to note that a road now exists on the west border of the North Brown Tuthill parcel.No road exists on the east border. 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F :s:�a:' �t B,F:,'P.• a.. �.'*�si vrke k�..,." - �`�, ' {; °'r1. �>.., s.tr' a+�.�r'f 4' v "r 'r•*°,<"+" 4',0. e'•.,« z.°y' »i. -°F 1 ..Y.`.F r t ?.-'�•' ,r '!"mss �, 'G,. w -y�-�'y t, Yiy' ','}�;•__,?} ?.>`y?i.!,,., , •'E '+ -b`• �'c3" `'b': :1 ..t?`trt�"z?'��',,.✓,.Lxr.g�Gk:�-z�yr��s`�.r�,'ea`x:?�.r�°' �'`��7",:•„Syj =�.,.f;+�"ti�� ��"ti=°" ee ,.ti! • k 'a Yd FX:r�.ti, ti s P �'• ♦�-G�-..:$,e'3 �t`,�';t,;,?a .xK:�; '� h->. > SM$ $'. .�t•s, r���� T�. K�d �+° ^�'F'r'������„ 'n-'^t4_�4�p���"`�� i first r$'v'�4�� m'`sfs°°P' -�s.`':•�d�`�..`'af'��s�.;;�d�t+��� �a �����.-. .��-�a4�ts�.'�.rP.'s9ue2= %','��+a:•i� �,2'+...'„_= °�-'-�°iis�i View from soutl Pto north fwest border of North Brown'Iutlull parcel. Note the evsting dirt road on property. This long standing access to this parcel should continue to limit the impact of development. There are an amazing number of cov1s, loons^ wild tutkevs and osprey that live 3n the woods of this property- `1 here ate also a number of people that live alone the proposed ro£t(1\�a) Millen those homes were built they had to be a number of feet i\\,ay from their side and back lot lines Rather ironic that no tiles apply to a lau-ge subMslon toad on the same lot line. is thus ind) your hest Conseivatton QvIrownentnl Impact flan? naN td BackLIS -t From: Alix Pearlstein <alixpearlstein@gmail.com> �� Sent: Monday, March 18,2019 9:21 AM '+�, "Ci' To: Michaelis,Jessica RECEIVED Cc: Bill Adams Subject: Tuthill Subdivision- North Brown Attachments: Tuthill-N. Brown_Letter.docx .�Soutnoid ToNn Planning Board , 3/14/2019 Dear Southold Town Board Members, We are writing regarding several serious concerns in relation to the Tuthill Subdivision-North Brown Site. We live in Brown's Hills Estates on North View Drive. Driving home from the town hall meeting on Monday night, a deer ran across the road right in front of our car just before we were to turn left onto Brown's Hills Road. Cars racing to the ferry were right behind us, it was a very close call. We think it is crucial to locate the access road to the subdivision on the western edge of the site. It is currently drawn on the eastern side,which is problematic for numerous reasons—chief amongst them is that is would further congest this dangerous traffic apron.And,there are already two parallel dirt roads on the western edge, one of which could easily become the Tuthill access road. Also of critical importance is the close proximity of six houses on the eastern side,while there are only two on the western side—and these have much larger setbacks.There is much mature vegetation and animal habitat along this eastern border that would be destroyed to make way for the road,along with the disruption of utilities and cables—and increasing risk of runoff as this western end is at a higher elevation than the eastern. These concerns for safety of both current and future residents and anyone entering these roads to visit or work, along with concerns for the preservation of the beauty of this site suggest that it would be a much easier and all around positive solution to locate the road on the western side. Thank you so much for your thoughtful consideration. Alix Pearlstein and Bili Adams 1060 N. View Drive, PO Box 112, Orient,NY 11957 917-817-7486/646-673-4531 3/14/20'19 Dear Southold Town Board Members, We are writing regarding several serious concerns in relation to the Tuthill Subdivision - North Brown Site. We live in Brown's Hills Estates on North View Drive. Driving home from the town hall meeting on Monday night, a deer ran across the road right in front of our car just before we were to turn left onto Brown's Hills Road. Cars racing to the ferry were right behind us, it was a very close call. We think it is crucial to locate the access road to the subdivision on the western edge of the'�site. It is currently drawn on the-easfem side, which is problematic for numerous re4ons—chief amongst them is that is-would further congest this dangerous traffic apron. And, there are already two parallel dirt roads on the western edge, one of which could easily become the Tuthill access road. Also of critical importance is the close proximity of six houses on the eastern side, while there are only two on the western side— and these have much larger setbacks. There is much mature vegetation and animal habitat along this eastern border that would be destroyed to make way for the road, along with the disruption of utilities and cables —and increasing risk of runoff as this western end is at a higher elevation than the eastern. These concerns for safety of both current and future residents and anyone entering these roads to visit or work, along with concerns for the preservation of the beauty of this site suggest that it would be a much easier and all around positive solution to locate the road on the western side. Thank you so much for your thoughtful consideration. Alix Pearlstein and Bill Adams 1060 N. View Drive, PO Box 112, Orient, NY 11957 917-817-7486/ 646-673-4531 RECEIVED is MAR 1 S 2019 From: Jo Ann Constantino <joann6337@aol.com, I : opt o d Town , Planning Board Sent: Monday, March 18,2019 9:24 AM To: Michaelis,Jessica Cc: Edward Constantino Subject: [SPAM] -Tuthill Proposed road on Eastern border of Browns Hills Community To The Southold Planning Board: My name is Jo Ann Constantino and I reside at the Browns Hills Community. I bought my home 15 years ago and was immediately drawn to this community because of he peaceful atmosphere. What a pleasure to wake up to hearing birds sing especially since I live in Brooklyn. My house is on the side of Browns Hills where a road is proposed to go by the Tuthill family. This is very disturbing to me since my house is the closest to the proposed road. Imagine waking up now to cars going by my home and seeing a road on the other side of my fence while I'm having coffee in the morning sitting out on my patio. I am also worried about the water run off on my gardens which I care for with lots of love. I urge the board to rethink the approval of the placement of the road from the Easterly border to the Western border. I ` am not adverse to building houses but I am very concerned about a road next to my property which is also my back yard. I ask why can't this proposed road be moved to the Western border? Why is the Tuthill family not opened to hearing our issues? I sincerely request that the planning board consider this letter when deciding on the issue of road placement. I love Orient and would not want to move because of this problem. Thank You,Jo Ann Constantino,SouthView Drive. Sent from my iPad i J�t� REICEIVED Attn: Brian Cummings (iia„ 18 71119 Town Of Southold NY - S— ourhofd'fawn Re: Tuthill Conservation Subdivision Planning Board 18 March 2019 Comments submitted by Kenneth W.Terry,former resident of Orient Background: My name is Kenneth Terry and I currently live in South Carolina. I lived in Orient from birth till moving away at age 21. Although I once did, I no longer can claim ownership to any property in Orient. However,I have 4 siblings who continue to own some form of real estate in the Hamlet. We are 10`h generation descendants of some of the original settlers of Southold Town,including Richard and Thomas Terry. One of the original settlers of Southold was John Tuthill,who was the progenitor of the Tuthills who currently own the land in question,and who also was my 7`h Great Grandfather. Along with said John Tuthill, I have tracked my ancestry to the Town's founding families of Hortons,Wells, Conklin(es), Budds and Young(s). I graduated both Orient and Greenport Union Free School Districts, and from Worcester Polytechnic Institute,as did at least two of my Terry and Tuthill ancestors. learned a degree in Mechanical Engineering, and have worked in a number of capacities over my career in the Environmental, Health and Safety field. Even though I can claim no direct personal gain or loss due to the ultimate final decision regarding the Tuthill Subdivision in question, I continue to have keen emotional interests in Orient's history,residents and survival. My concerns regarding the continued approval of subdivisions in Orient in general are as follows: 1. The continued increase in tapping into the aquifers that feed fresh groundwater to the eastern part of Long Island can have a detrimental effect on this fragile supply. As there is no current municipal supply of water to Orient, all homes require wells to be connected to the aquifers to obtain usable water_These aquifers are then the sole supply of water to the area and the sole makeup of said aquifers is due to precipitation. However, periods of drought have been experienced throughout the history of this area,and studies have shown that migration of the rain to the aquifers can take from 25 to 1000 years depending on the depth of the aquifer (There are 4 aquifers on Long Island located at different depths). 2. Historically,there have been episodes of surface contamination to these aquifers caused by either chemical or environmental contaminants Two such episodes of note were the 1,4– dioxane leakage issue which involved numerous areas of Long Island as well as the rest of the Country. This chemical is used to stabilize trichloroethylene from eroding their containers. Trichloroethylene is used as an industrial degreaser in many manufacturing processes. Numerous studies(almost 1000 on Long Island alone)have been done by the United States Geological Survey and published in their USGS Publications. The Environmental Protection Agency has classified 1,4-dioxane as likely carcinogenic to humans. Due to the nature of this substance, it is extremely costly to remove and resists natural degradation. The second episode closer to Orient was the 1974-79 use of Aldicarb, a highly toxic oxine-carbonate pesticide used by farmers to control potato beetles and golden nerndlodes Fresh wdler wells in 01ienL were found contaminated by this pesticide, and the use of Aldicarb on Long Island was eventually banned as an approved pesticide. Union Carbide, maker ofTemik,which contained the aldicarb, was forced to provide carbon filters on over 1000 wells in residences, including Orient,for a number of years. 3. My opinion is that an environmental impact assessment is fine so long as a hydrogeology impact on the supply of fresh water is included.The real question is how long can we collectively draw from the fragile fresh water supply before the scale balance tips irretrievably toward salt intrusion. Historically,there have been episodes of salt intrusion in driven wells in Orient,which has caused the requirement to move the location of the well. I would suggest that the mean elevation of Orient is around 14 feet above the mean sea level.These means however are changing due to the global warming effect,which is causing a definitive rise in the mean sea level.We have all seen the results of the sea level rise in relation to Orient by the effects of the sound bank erosion,the encroaching water at the Island end at Plum Gut,and how far the sea water comes up at Pete's Neck and around the Yacht Club during storms. Irrespective as to the viability of whether this is due to global warming or not,the fact remains that sea levels are rising and the risks of salt intrusion into the fresh water supply increase along with that rise. i I have presented the above as my personal concerns and opinions regarding the continued subdivision allowance/approval within Orient. Historically,a number of such developments have already taken place such as Willow Terrace, Brown's Hill, King's Farms, Ryder Farms, Douglass Properties,etc. Historically,the sale of development rights on various open farmland plots in Orient has helped to control further land development. Respectfully submitted, Kenneth W.Terry 229 Colfax Dr Boiling Springs,SC 29316 Subs ;;N LL,rvCi- EIVC� JERIE R. NEWMAN I MAR I S 2019 922 Youngs Road—PO Box 327 3 Orient, NY 11957 Q6'0 �oJ0,t&vn Planning Board March 14,2019 Members of the Planning Board: RE:TUTHILL CONSERVATION SUBDIVISION—SOUTH DYER I was in attendance at the Planning Board meeting on March 11 and spoke briefly regarding the South Dyer portion of the Tuthill Conservation Subdivision. As I said, I consider the Tuthills' as friends. That goes way back to our ancestors in the 1600's when Samuel King,John Tuthill, and Richard Brown were among the first settlers in Orient, and every piece of information I have found,stated they were best friends. The Tuthills' are subdividing their properties as a "family plan"for their children and grandchildren so each will be able to have a home in Orient. My late husband, Kenneth, and I also have a "family plan"which is just as important to us. A little history In 1938, Harry and Helen Newman, Kenneth's parents, purchased an 18th century house (an original Rackett home)that was on the property now owned by Florence Horton on Rt. 25 (across from the Latham farmstand). The person who purchased the property did not want the house,so she sold it to the Newmans for$100, but they had to move it from the property. The Newmans' purchased the lot, now known as 790 Oysterpond ; Lane and had the 181h century house moved to that spot where it still remains. At that time there were no homes on Oysterpond Lane. It was all farmland. The house passed to Kenneth Newman and upon his death,to me. We have a trust that we did a number of years ago for our four children. The house on Oysterpond Lane will go to our third child. As I said at the hearing, Helen Newman loved her historic house.She loved the vista which she called her million-dollar view. She spent many hours on the porch playing solitaire and entertaining friends. She requested that on her death she wanted to be cremated and her ashes spread in Long Island Sound and Gardner's Bay(the million- dollar view she had from her porch). Kenneth honored her wishes. When the house passes to our daughter, she will not have that million-dollar view. Her view will be the back of a very large house. Imagine our 18th century but small Cape Cod house with an 8,000 sq. ft. mansion behind it! In our opinion,this devalues the property at 790 Oysterpond Lane that we wanted OUR daughter to have so she could live in Orient. This is very disappointing. sincerely, fti,•� ;�� / LLL/ March 10,2019 —rte' L (��' F Southold Town Panning Board *�ETVED , Mr.Don Wilcenski � Mr. Pierce Rafferty 'VAR 1 1 2019 Ms.Mary Eisenstein Mr.James Rich Mr.Martin Sidor SOu lofd 7"own`� ning Board RE:Tuthill Subdivision:Access Road to North Brown Subdivision Plan Dear Chairman Wilcenski and Planning Board Members, My husband,Tom Morgan,and I,have been living year round at 855 S.View Drive, Brown's Hill,Orient,for 18 years.We have witnessed the intense lncrease,ln-Jraffic to and fmrn the ferry on Route 25,as well as the increase in bike riders,joggers,and dog walkers, etc. I am writing to request that you consider requiring the access road to the Tuthill Subdivision north of Route 25, North Brown,be placed on the east side of the property,whej'e there-is already-an access road. In our view,the fewer access roads to Route 25,the safer is our community. An event last summer frighi&riid us: Tntn Wavddving„i yeas the passenger We stopped,atthe end of Brown's Hill Road,looking both ways, ready.to drive'onto Rte 25. tom�rnade one last iodlctckh led,a4started to accelerate when I saw out of the corner of my eye two_joggers fast approaching us.from the•right,,tuririing against jraffic--9-n.tlto wrong side of the roadl I yelped,Tom braked,and:'We neatly hit the first runner,who banging his fist on our car. The woman jogger behind him stopped. My heart was in my throat We were,both shaken: Children and young,people bike and run up and down;Rte'25,all summer;long, Cars•race for the ferry all year long,especially m summer. Entaring onto Rte25;is extremely,dangerous;and requires alert attentiah;and awarenes"s of;people and cars that could be approaching from almost any direction— especially,'sp'eedir`g'Ors,passing oars,and;ignorant of the law bikers and joggers. The fewer curb cuts the better. Please consider our safety. Thank you very much, Mary McfMorgan <mcfm.morgan@gmail.com> RECEIVED March 11,2019 +` r'-` -y—-!"1� nn'� E Pl1nR �. 1 2U IJ TO:Southold Planning Board FR:James Haag,Orient RE: Hearing on Tuthill Conservation Subdivision March 11,2019 Planning Board ' Dear Don and Planning Board Members: I have lived in Orient for 22 years and have enjoyed the quality of life and the character of this historic hamlet. Every day when I drive over the causeway from East Marian, I am amazed by the vista of the harbor framed by steeples of the churches and the historic homes.And I was attracted to the town because of the passion of the residents to maintain the character and beauty of this preserved community.Corcoran real estate begins its website with the following words: ...But what gives you butterflies when you enter Orient by the causeway is its heart-stopping view of the Long Island Sound and Gardiner's Bay. Look out farther and you can see the Orient Beach State Park, a barrier island that is a summer playground of infinite pleasures. I cannot imagine anyone wanting to place a subdivision of 17 homes in this vista. Over the years, I have been impressed with the Planning Board's awareness of maintaining Southold Town character. No matter what the party affiliation, members of the Planning Board seem to s be in agreement that what is special about the North Fork must be maintained—or we have nothing. I think most people would agree that there is no finer example of the Fork's essential character than the East Marian/Orient causeway. Please will you seriously consider what is about to happen here? I realize there is a generous acreage being preserved, but a subdivision of 17 houses clustered together in the midst of this? How can we be doing this? People fell in love and moved their lives to this district because of its character.Tourists flock to the causeway and pull over their cars when they first see this breathtaking view. It is not right to alter this. Once we begin to compromise the district, it loses its character—and we all lose. Thank you for your consideration. I have learned the people's opinions mean something in Southold, and I love our town for that.Thanks for considering mine. Best regards, James Haag 4725 Orchard Street Orient, NY 6319026452 From: Barry George Bergdoll <bgbl@columbia.edu> RECEIVED Sent: Monday, March 11,2019 9:29 AM I---- To: Michaelis,Jessica; Bill Ryall MAR 1 1 2019 Subject: [SPAM] - Re: Re Tuthill Subdivision/Orient 1 .I ��uchtr7dl'Town • Planning Board Dear Southold Town Board members, Here is a corrected version of my letter sent yesterday relative to tonight's consideration of the Tuthill property in Orient: Dear Southold Town Board Members, We are writing to second the letter submitted by our Browns' Hills Estates neighbor Deborah Marland. We strongly endorse the idea of requiring the subdivision to locate its access road at the western edge of the site. There are already two parallel roads there providing access to houses on the bluff and the Tuthill estate could take advantage of one of them or add width to an existing road. Since the town professes to want to maintain as much as possible large tracts of open land as natural assets rather than subdividing such natural parcels by roads it seems only logical to consider the following: The eastern edge --where the Tuthill plan filed proposes to cut a new road--is currently occupied by a mature hedgerow that appears to straddle the Tuthill property and property of the late Stewart Johnson. The former Johnson property has a conservation easement and it the center of what will be three adjacent preserved fields if the Tuthill field bordering the road is also preserved. Relocating the Tuthill access road to the west to join or parallel existing un-paved roads would keep the beautiful sequence of three fields intended to be preserved as a single landscape uninterrupted by utility poles and wires,preserve mature trees and shrubs, and concentrate access to the main road at one point rather than multiplying points of access to the often busy Main Road with its notorious ferry traffic. It seems like a much happier solution both for current and future residents. Sincerly yours, Barry Bergdoll William Ryall 915 Southview Drive, Orient, 11957 tel+ 1 646 379 4055 On Sun, Mar 10, 2019 at 3.33 PM BaiTy Georgc Bergdoll <b"2h l.u-columbra edu>wrote: Dear Southout Town Board Members. We are writing to second the Ietter submitted by our Browns' HilIs Estates neighbor Deborah Marland_ We strongly endorse the idea of requiring the subdivision to locate its access road at the western edge of the site. There are already two parallel roads there providing access to houses on the bluff and the Tuthill estate could take advantage of one of them or add width to an existing road. The eastern edge -- where the Tuthill plan filed proposes to cut a new road -- is currently occupied by a mature hedgerow that appears to straddle the Tuthill property and property of the late StewartJohnson. The former .lohnson property has a conservation easement and it the center of what will be three adjacent preserved fields if the Tuthill field bordering the road is also preserved Relocating the Tuthill access road to the west to join or parallel existing un-paved roads would keep the beautiful sequence of three fields intended to be preserved as a single landscape uninterrupted by utility pools and wires,preserve mature trees and shrubs, and concentrate access to the main road at one point rather than multiplying points of access to the often busy Main Road with its notorious ferry traffic. It seems like a much happier solution both for current and future residents. Thank you for your consideration. Barry Bergdoll and William Ryall 915 Southview Drive, Orient PO Box 57, Orient,NY 11957 tel 646 379 4055 r 2 From: Deborah Marland <debmarland@yahoo.com> Sent: Tuesday, March 05, 2019 3:31 PM kE EIVED To: Michaelis,Jessica !J Subject: Tuthill Subdivision 1�AR J S 2019 oUtnr�i rown Dear Southold Town Board Members, 9 Board I am writing you ahead of the Draft Environmental Impact Statement and Conservation Subdivision Town Hall'M.ee,ting on March lith 2019. Many members of Brown's Hills Estates are concerned about the close proximity to our homes of an access road to the proposed Tuthill Subdivision. Please look at the goggle earth photo in your folder of existing homes along the eastern border of Tuthill Property a compared to the western border.There are 6 homes on the eastern border as opposed to only two on the western border.Those two are set back further from the property line with two parallel dirt roads side by side.So no mature vegetation to clear or animal habitat to displace. On the eastern side all houses are very close with one extremely close to border where the proposed road is on the property line. I am proposing that this access road be moved from east to west border.This has other advantages to the town with just one curb cut on route 25 to maintain the apron of. Organizing the entrance and exits of three roads into one instead of three separate ones.Certainly this will lessen the chance of accidents into ferry traffic. Or out of ferry traffic on opposite side. There is another advantage that the developers may appreciate as there is a much lower elevation of the western border making road construction easier with less runoff. Thank you for your consideration. ; Deborah Marland Sent from my Whone A�P � � Dox e Chairman Wilcenski: 6:02 p.m. - Tuthill Conservation Subdivision Sketch Plan and Draft Environmental Impact Statement (DEIS) —This proposal is for an 80/60 Conservation Subdivision of four parcels SCTM#'s 1000-17-4-16, 1000-17-6-14.2, 1000-18-3-30.3 and 1000-18-6-17.3 (total area=112 acres) into 17 residential lots, with 94 acres to be preserved. This project proposes the transfer of yield pursuant to §240- 42G of the Southold Town Code. Chairman Wilcenski: Before we open the floor, I would just like to make a couple of comments. The purpose of this meeting tonight is to continue the adjourned public hearing on the sketch plan and the hold a new hearing on the DEIS which is the Draft Environmental Impact Statement. Comment period on the DEIS and the Sketch plan for written comments will remain open for another 10 days closing on March 21, 2019. We have received several emails and letters of concern about this project in the Planning Department as of today. Is there someone here from the family and would like to speak? Yes. I'd like to first have a representative from the Tuthill family speak and give a basic background to everyone and then we'll open up the floor to other speakers. Thank you. Yes. Please state your name and write your name for the record. And again, just as a reminder to everyone in the forum, the process of the DEIS here is any questions or concerns that anybody has are being recorded and the Planning Staff—we will do all the research to have all those questions answered and will be printed and made public again during the Final EIS. Lyle Tuthill: My name is Lyle Tuthill, I'm the son of John Tuthill who is a long-term resident and, as a matter-of-fact, had a genealogy that goes back to 1640... Chairman Wilcenski: Excuse me, Lyle; you'll have to address the Board. ; Lyle Tuthill: Ok, I'm sorry. And so, we asked, John wanted, as he got older to do things that could get his children to come back to Orient and to also maintain as much of a hamlet atmosphere as he could. And I think you could remember, John had his license plate, he loved old west Orient. So he then inherited from his mother that John H. Brown property and from his uncle, the other property, so at his death, we ended up with a lot of property that —we're wondering what we could do in order to meet what John wanted to do and, INAUDIBLE, and that was to keep the land as open as we can, but also allow his children to come to Orient and stay there. Through our discussions with my family, Rich Tuthill and his wife, Ruth, we felt that a conservation subdivision approach would probably be the best we could do, in that, it would keep land as open as possible, we could develop lots that basically, fit our size that we can transfer down to our children and let them use that property and use those lots to have summer homes/full-time homes, whatever to encourage that return. And, in fact, that's kind of where we ended up working with Mark and Heather over the years and going through the other requests that have come through, and the DEIS, and various searches to come up with this approach So that's kind of where it is and it's really something the Tuthill's are trying to do to keep it in their family Thank you Southold Town Planning Board Page 12 March 11, 2019 Chairman Wilcenski: Thank you, would anybody else like to address.the Board? Pease write your name, state your name and address the Board Thank you. Edward Webb: My name is Edward Webb. I'm the Chairman of the Southold Town Historic Preservation Commission and I just want to state, not for the record, but I've known the Tuthill family for many years. My ancestry only goes back to the 1720's so you got me beat on that, but I've known his mother all my life. We grew up across the street from each other, summer kids in the hamlet of Orient. However, with that, I'll share the following information with you: As I've said, I'm the Chairman of the Southold Town Historic Preservation Commission. Several items have been brought to our attention regarding the Draft Environmental Impact Statement provided for the proposed Tuthill Conservation Subdivision in Orient. To this date, the Historical Preservation Commission has not been consulted by the applicant, its consultant, or the Town staff to obtain our input. This is important because the proposed South Dyer parcel includes 3 plots within the boundaries of the Orient Historic District. In fact, the DEIS incorrectly states that the subdivision properties are adjacent to the Historic District. Any construction on these plots, therefore, would be required to come before the F Commission for approval. There's nothing in the DEIS to show how the visual setting of the Orient Historic District would be affected. The DEIS does not mention individually listed town landmarks within the Orient Historic District that are adjacent to or in close proximity to proposed building plots on the South Dyer parcel. Stating that the new South Dyer parcel houses will be compatible with the existing styles of homes in the Orient Historic District is not sufficient. The DEIS implies that it will be the applicant who will determine what is appropriate. Determining of the proposed home in the Orient Historic District is architecturally compatible with the Orient Historic District is the responsibility of the Historic Preservation Commission and not the applicant. Given these issues, which have not been addressed in the DEIS, it is the sense of the Historic Preservation Commission that supplemental and environmental impact statement that addresses these issues should be required. Thank you. Chairman Wilcenski: Thank you, Mr. Webb. We will definitely be reaching out to you through this process for your input. Would anybody else like to addresses the Board on Tuthill Conservation Subdivision? Joel Klein: Good evening Mr. Chairman, members of the Board. My name is Joel Klein, I live in Mattituck and I'm a registered professional archeologist I want to stay historic by saying that I'm not advocating for or against the project, my concerns are with the adequacy of the information in the DEIS pertaining to historic and archeological properties and with what I believe to be irregularities in how the SEQRA process had been handled. I second the Commission's concerns that potential impacts to the Orient Historic District have not been adequately considered. Over the course of the review of this project, there were numerous calls for a Visual Impact Study and a View Shed analysis. The terms seem to have been used interchangeably, yet they are not the same thing. View Shed Analysis is usually a preuuisur to a Visual Irnpact Analysis It defines the geographic area, sometimes called the "Zone of Visual Influence" from within which the proposed project will be visible It is the basis of determining where Southold Town Planning Board Page 13 March 11, 2019 visual impacts must be considered. No View Shed Analysis was carried out with this project. The Visual Impact Study that was performed for the project was a study of the aesthetic impact of the project on the Routh 25 scenic byway. It did not specifically address visual impacts to historical properties, most significantly, the Orient Historic District. It also failed to consider possible impacts of numerous historic structures along Route 25 located outside the Historic District. Only the three page text of the visual assessment is included in the DEIS. Fifty-four pages of photographs and photo simulations - although they can be found on the town website - have not been included in the DEIS. The DEIS table of contents incorrectly states that 36 pages of photo simulations are included. The DEIS is also deficient in how it deals with potential impacts to archeological sites. In 2011, the applicant had prepared what is known as a "Phase 1-A Cultural Resource Assessment" of the project. This is a desktop study to identify previously known and recorded historic structures and archeological sites that could be affected. The 1-A report identified three prehistoric Native American sites as being on or adjacent to the project parcels but only provided the Estate Historic Preservation office file numbers. The SHBO is their informational division for Historic Preservation in the New York State office in Park Recreation and Historic Preservation. Phase 1-A report also noted the presence of six historic structures on or adjacent to the parcels. These two findings were the basis for the report's author recommending a Phase 1-B field investigation, which would be limited to those areas which would be affected by proposed building lots and associated infrastructure. At some point, the town of Southold submitted the 1-A report, which is not referenced or included in the DEIS for the State Historic Preservation office for comment and on January 26, 2015, the SHBO concurred with the recommendations for a 1-B study. The 1-B field investigation report was completed in December 2015. It makes no mention of any of the previously reported archeological sites or historic structures mentioned in the 1-A report. It notes that field investigations did locate remains of historic structure on the North Dyer parcel. The Field Investigation recovered 51 prehistoric artifacts from the South Brown parcel, 9 of which were classified as tools. The remainder were mostly stone-tool manufacturing debris known as "Debitage." It seems likely that this is one of the previously known Native American Sites. I would add that the number of artifacts and ratio of soles, tools to tripping debris is suggestive of a major habitation site. No attempt was made to delineate boundaries of this site within the South Brown parcel, apparently, because the investigator recommended a Phase Two intensive testing investigation to collect more information However, he also states that this need not be done until prior to groundbreaking or construction. This was a serious error for several reasons One, the absence of a specific condition in the site plan approval, the applicant cannot be required to conduct any archeological investigations And two, the discovery of a significant archeological site on a given parcel either before or during construction could render the parcel unusable or usable only after the expenditure of considerable sums to salvage any discovered remains, which could include human remains in this case Requiring the Phase Two investigation as part of the DEIS process would have had two benefits One, it would eliminate the potential problem of a discovery being made on an approved building lot by allowing the relocatiori of [lie proposed lot outside the limits of the archeological site And two, it would provide more permanent preservation of the archeological site within the conservation subdivision The SHBO Southold Town Planning Board Page 14 March 11, 2019 has never commented on the Phase 1-B report or concurred with its recommendations, although it was submitted to the SHBO sometime prior to the spring of 2018. The reason for this is that on June 11, 2018, the SHBO requested that the Planning Department provide updated project plans because the areas investigated during the Phase 1-B study: "...do not correspond with the area of potential INAUDIBLE that was initially submitted for this project." As of last week, the SHBO comments on the Phase 1-B report were still pending because they have not received the requested information from the Planning Department. In spite of the fact that the SHBO comments have not been received, and in spite of the fact that the one of the principal reasons for DEIS being required in the first place, was because of the projects potential to affect historic and archeological sites INAUDIBLE on the recommendation of the Planning Department voted on the DEIS complete. The final DEIS contains only a single page of original text dealing with historic resources including archeological sites. Only four sentences deal with archeology. One of the sentences reads: "No historic artifacts were found." This is potentially misleading. What is should have said was that "No artifacts dating to the historic period, as opposed to the prehistoric period, were found." It addresses the prehistoric site found on the South Brown parcel by noting that only that white quartzite fragments were found. The final sentence indicates that Phase two investigation on South Brown is "recommended if we want to proceed with this SE lot." A recommendation by an applicant to conduct additional studies is not a requirement, has no enforceability and is not an assessment of project impact. The DEIS also includes the three page text of the Phase 1-B report, but the 50 pages of maps, photos and data appendices have been redacted, it is unclear why this was done. In addition to the DEIS problems relating to archeology and historic preservation, I also want to comment on how the SEQRA process of this project was handled. First, no formal scoping was done for this project. Although scoping was not required under DEC SEQRA regulations, the DEC highly recommends it. Had scoping been done, the problem with the work scopes with both the visual impact study and the archeological investigations might have been avoided. I also want to add that as of January 1St, scoping is no longer really recommended under SEQRA regulations, it is now required The second issue I wanted to talk about is the manner in which the DEIS has been made available to the public for review. When the board voted to declare the DEIS complete, the legally required notice of that and the announcement of this hearing was published in DEC's February's environmental notice forum. SEQRA regulations require that a DEIS be accessible electronically. The environmental notice forum notices that this project states that "the draft DEIS is available from the Southold Town Planning Department and online at www.southoldtownny.gov1270/environmental impact statements. I had spoken to many individuals who have told me that when they accessed the Tuthill Subdivision DEIS through that link, they get a message that says the website is online but it's not responding. On February 28t", I advised the Planning Department that the link was not functional. Later that day, they responded by saying that the information technology department had checked the link and it was working. I again informed the Planning Department it was not. It's unclear why some people have been able to access the DEIS in this way but not others. One can find where the DEIS is luc;ated ur, rnoie accurately, buried, on the Town's website. It can be found by taking the following steps: Going to the Town of Southold's website, going to the "How do I" tab, then going to the Southold Town Planning Board Page 15 March 11, 2019 "Public Records" link, then going to the "Planning Department"folder, then going to the "Applications" folder— not the SEQRA documents folder—which is different. Then going to the "Conservation Subdivision" folder, then going to the "Pending" folder, then going to the "Tuthill Conservation Subdivision" folder, then going to the "DEIS Received 9/14/2018" folder. One can then attempt to download the DEIS through Laserfiche. The document that is located is the final version of the DEIS, it was not posted until March 4th, prior to that date—while all of the text and the captions to the DEIS were available online —they were seemingly randomly located throughout more than 400 page document simply labeled "Tuthill Conservation Subdivision."Within all of the problems with the DEIS, I wanted to request that the Planning Board find that a supplemental DEIS is required and failing that that this public hearing be kept open until such time that the applicant has addressed all of the issues that have been raised here. Thank you. ,Chairman Wilcenski: Thank you Would anybody else like to address the Board? Yes? Suzanne Horton: Hi, my name is Suzanne Horton. And again, my family's been here since 1640 so, and I have extended relations to Lyle Tuthill as well. I've known John Tuthill a long time. I think he really... Lyle did a wonderful job in summing up what his intent for the vision of the property was. They really want to encourage, you know, they're trying to preserve such an iconic view to enter into Orient which is iconic and nobody wants that disturbed, but they do want some lots for their children to be able to build upon them in the future. I think, for clarity, for, probably everybody, so that we understand it a little bit better, what would be helpful to everyone is to understand with the open spaces, that land bank preservation, what are the guarantees associated with that land never being built upon in the future? And secondly, it is R-80 zoning, which usually you have two acre lots Is that part of a deal to give up that conservation land from preservation so that they can get smaller lots in that area for their family? I think, those would be helpful if those questions could be answered in the process. Thank you. Chairman Wilcenski: Okay, Thank you. Would anybody else like to address the Board? Venetia Hands: Good evening. Chairman Wilcenski: Good Evening. Venetia Hands: I'm Venetia Hands and I live on Brown's Hills in Orient and I'm also a member of the Board of the Orient Association, which, many of you have heard of I'm actually here today in that capacity, to speak on behalf of the Board and its members on continuing the conversation that we've had previously about this project. I can say a lot of really wonderful things about how great this is and how much I appreciate and how much I esteem about the Tuthill's, how much we're glad it's an 80-20 conservation and so on and so forth. But you would know that there's a "but" coming And so I think I'll just get to the "but." And so the "but" is some questions and here's my number one question. I want to know what size the houses shown in the Visual Impact Study on Southold Town Planning Board Page 16 March 11, 2019 South Dyer are, what is the actual square footage of those houses being represented there? Nowhere is that stated. We are told that we are looking at a worst case scenario full build there. We are told that the building area maximum size is 8,000 square feet. Driving here today, I suddenly realized 8,000 - 9,000 square feet happens to be the same size as a certain barn being built a little further down the road on 35 acres. So we're talking about an 8,000 square foot footprint on four, less than 1 acre plots here and it doesn't tell me this but it does show it in the pages and I know that I can build a two-story house there. So I've got now a 16,000 square foot house. I also know that if I get permission, I can put another half story on my house, which gives me a 20,000 square foot house. But let's not push that one, because we've got to cover pools and tennis courts and patios and other things so, let's say the houses - in the worst case scenario - are 16,000 square foot. Those are huge houses! I've seen those houses on the south fork, they look nothing like these. Nothing! So my question is: what is the size of those houses that we're looking at? And I guess, reading between the lines, I'm saying, I and others are not sure we're really being showing maximum build out there. Now, we are told that their designed to fit into Orient in style and size and we're told — and I appreciate this- that the goal is to bring Tuthill family members back to have it be they who build houses. They probably won't do it very quickly, they probably won't do it ; all at the same time, and we're told that when they do do it, it's like our hope and intention that whey will build in a size and design appropriate to Orient. But where are the regulations or rules or restrictions to make sure that happens? We are told by the Visual Impact Study that there are lots of houses in Orient that are at least 40,000 square feet. Yeah, has anyone seen one of those? Would you tell me where they are so we can go look at them please? And would you tell us what size lot they're on? Are they on an acre? And how visible they are from Route 25? Don't just assert there are lots of 40,000 square foot houses in Orient. We're not going to just allow that. So to come back to the family's plans to build — have these houses be for the members of the family— which is great- and if a family member sells to somebody not in the family to have the Tuthill trust or whatever it is- have the right for first refusal — these things are wonderful, wonderful , wonderful, but how can you make sure it works out in that way without, in practice, without having some kind of implementation, restriction, plan, whatever. Is there some way the family can specify a limit on house size? Something less than maximum build out? And what might that limit be? You know, this whole project got us thinking about house size in Southold and it's now being looked"at by the Mattituck Civic Group, the —what else is there- all the civic groups* East Marion, and so on, because we've got creep coming up from the south fork. 1 remember, my friend , Bill Riles, standing here saying "Who in their right mind would want to build a 20,000 share foot house" indeed. But they do. And they're coming. So let's look at what some of the other towns are doing Riverhead has maximum size on 1 acre of 12,000. Southampton Village — and we're talking about village- has maximum 6,300. East Hampton Village has maximum 5,000 square feet. Sag Harbor has maximum 5,200 Shellshore Layland brought a maximum — on any size piece of land — of 8,000 square feet and then they took a look at that and said. "Oh no! That's much too big!" and brought it down to 6,000 square feet and — believe me- that's still very big I'm wondering if there's a way that the Tuthill family, and you, can set a limit of 6,000 square feet then to the hoiisPs that can be built there "It's still too big" I hear behind me in chatter and they're doing it at 3,000 Southold Town Planning Board Page 17 March 11, 2019 too. But, you know, I'm not going to say what the right size is. But that's my question, my priority question, we don't know what size those houses are that have been taken photographs of and we're having a very hard time, based on other things we've seen, believing that they are 16,000 square feet. Sorry about that, I have three other questions. Chairman Wilcenski: I'd like to just make a comment; I don't want to spend a lot of time answering questions here because that's just part of the procedure. But I believe those houses that were shown on the Visual Impact Study were 8,000 square feet, and that was the maximum. I don't know where you're getting 16,000 feet from. Venetia Hands: Well they're two stories, Sir: Chairman Wilcenski:. No, that includes all of the square footage. That's not of the footprint, that's the total square footage. They were assimilated at 8,000 square feet. So that's all I'm going to say. Keep asking questions and we'll get them answered for you. Venetia Hands: Okay. So what I'm going to say to that is that is not a worst-case scenario. If those houses are 8,000 square feet total and they are two stories, they are half the size of what is allowed in Southold on one acre and l would ask the Planning Board to confirm that. Chairman Wilcenski: We'll have those answers for you. That is not my understanding; ; my understanding is that those assimilations were 8,000 square feet, total home size. Venetia Hands: Alright, so let's find out. Chairman Wilcenski: We will. Venetia Hands: That's a huge difference. So, my next question was, does this acreage fall within the Orient Historical Preservation District? And we've heard about that and what does that mean? Another question is, will homeowners and builders be required to install the most advanced wastewater systems available at the time that they build, in all of these lands? Again, the intent is expressed in the DEIS that we want that to happen, but how to we insure that?And I think this is what I understand is the difference between Visual Impact and View Shed, we're looking only from Route 25. What happens if you're standing on Skippers Lane? Or Oyster Ponds Lane? Or even in your garden on Village Lane on the back? What happens when you're looking, when you're out sailing? It hasn't been looked at in its totality. Were the houses up on the hill there? So it's a very limited Shed that I think is what's being done. But that's it. But my main question is and if you're right, that an 8,000 square foot house is that maximum that's allowed, two stories, on one acre of property, we'll have a lot less to save. But I'm sorry I believe it is an 8,000 footprint twice, which is 16,000. Okay? Thank you Chairman Wilcenski: Thank you, Would anyhody Plse like tn nddress the Rnard? Yes? Southold Town Planning Board Page 18 March 11, 2019 Nancy:KardWell:.I have two questions. My name is Nancy Kardwell. Good Evening. I have two quick questions. One relates to the questions from the lady who was here just asked. She had mentioned that the height. Is the height restriction of the house 30 feet? t Chairman Wilcenski: I think it's 35 in the town, Nancy Kardwell: 35 in Orient? Chairman Wilcenski: In Southold Town, Nancy Kardwell: The whole town. Thank you. My other has to do, most of these studies have been done over the last several years, correct? Environmental studies? Chairman Wilcenski: Yes, and their continuing to be done. Nancy Kardwell: They're continuing. During the last six months, I've been told that there is a considerable problem now with the water supply, the water table in our area and everyone needs to be very vigilant about it. And I was just curious, if the town has looked into that and if there is any plan for moratorium on building that's in the present or in the future. I just... Chairman Wilcenski: We'll have that question answered for you. I can't answer that question. Nancy Kardwell:,Thank you. I'm very familiar with the Tuthill's, I'm very supportive of their efforts. I understand their family concerns; I just wanted to ask this just to see them addressed. Chairman Wilcenski: Thank you. Would you please be sure to sign your name for the ; record? Would anybody else like to address the Board? Yes? You can step to this side Again, I dust want to make a quick notation that this is not a Q & A session. We're taking your questions and they will all be addressed. Thank you. Jesse Gordon: Good Evening, my name's Jesse Gordon and I'm going to shift our focus away from the village for a moment, if that's ok, to the North Brown lot. I am speaking on behalf of multiple homeowners around the fence of Browns Hills, which, boarders the North Brown parcel And we have one particular and specific concern and that is the location of the road as it currently exists accessing the subdivision which is currently to the eastern portion of the plot which is directly bordering numerous houses in the Browns Hills community. So we believe, and I believe that that road would be better placed, for multiple reasons, on the western end of the lot. First being, the impact it will have on the neighborhood gaggle, which is, there are, you know, if you look at the aerials view, which you don't have to now but I'm sure you'll see, there are several houses along that stretch on the Brown's Hill side, whereas on the western side of the lot, there are only two houses and those two houses are set back from the property line. Southold Town Planning Board Page 19 March 11, 2019 Also, from a safety perspective, I mean, I think we all know there's a tremendous amount of traffic coming down that road; people going to the ferry, people biking, people running, and its hairy pulling out from out of those roads. As it currently exists, there is an entrance to Brown's Hills, there's a road apron there. And then the next one is where those three houses are currently located, so if the road were put on that side of the property, I believe from a safety perspective it would be considerably safer because there would be less curb cuts and less opportunity for people... I cannot tell you how many times I've pulled out, going to drive west and I've looked at oncoming traffic and haggled onto the traffic heading east and my biggest fear is when somebody rushing to the ferry is going to be passing and I'm not going to see it and I'm just going to slam into them making that right-hand turn. I think to the extent that multiple road aprons and curb cuts can be put to place, you know, if we can reduce that by moving the road to the western portion of the parcel, I think that would be beneficial, not only to us but to the safety of the community in general. I also think there are some other compelling ecological reasons that that road should be moved to the west as well. First being that the eastern edge where the Tuthill plan proposal exists, their new road is currently occupied by a hedge row that straddles the Tuthill property and the property that once belonged to Stuart Johnson. That property, I don't believe this was addressed in the DEIS, has a conservation easement on it as well. Essentially, that would be the center of where those three adjacent parcels, that we're trying to preserve, would be. So by putting the road through,over there would essentially breaking up those three farm fields that we're trying to preserve as open land, whereas if the road was to the western : portion, we wouldn't be doing that. We also would be making sure that there weren't, you know, power lines and utility poles running through the middle of that land that's trying to be preserved. Another issue and I can't say that I'm stating this on behalf of all the members of the Browns Hills community but, I'm going to say this in my own capacity, which is looking at the DEIS, I did not see any analysis of the impact that the construction of those parcels would have on the bluff. I understand that's going to be a hundred foot setback and that's great, but this will be a lot more open land which is going to result in a lot more runoff and I think it's important to know that there was an area of that bluff, let's say a half a mile away, that caved in a few years ago So I would urge the Planning Board to insist upon an analysis of the stability of that bluff and the impact of all he drainage from that area is going to have on that bluff. If it's in the DEIS, I missed it but I didn't see it and I don't know if that's required by any means but I think it should be encouraged. Really, that's all I have for right now, so thank you very much. Thank you for your diligent work in looking at this and I appreciate your time, thank you Chairman Wilcenski: Thank you. Would anybody else like to address the board? You could write your name after you finish talking, how's that? Jerry Newman: Thank you, I'm very slow. Chairman Wilcenski: That's okay. Jerry Newman: My name is Jerry Newman, and we have a home on Fast Oyster Pond Lane It's an 181h century house, not very big It was moved there in 1938. Actually it's in Southold Town Planning Board P a g e 110 March 11, 2019 the spot where Suzanne's house is now sitting. I've been persecuted for trying to build there, didn't want the house so my father-in-law bought it for $100 and moved it across the fields which were all four fields at that point. Sorry, I know the Tuthill's and actually, my family not my husband's family, but my family was also one of the first settlers in Orient, as well as the Tuthill's and the Browns, so we've lived in Orient a long time. We also, my husband and I, we also had a family plan and this house was to go to our younger daughter and it's obviously going to devalue our property to be looking into the back of an 8,000 square foot or even a 4,000 square foot- house because this is not a big house, it's a little cape house. And my mother-in-law, I'm glad she's not alive right 5 now, I'm sorry but she would be having fits because her biggest thing was sitting on that porch and watching the sunset at the sound and also when her desire was to be cremated and her ashes spread where she could see from the porch, which was Long Island Sound and Garners Bay. And now, we won't have that vista anymore. She lost her million dollar vista because that's exactly what she thought it was. So it's a disappointment, I've known the Tuthill's a long time, I like them, I consider them friends, but this is a disappointment because I think it will devalue our property. Thank you, I'll write my name now. Chairman Wilcenski: Thank you. Anyone else? Would anybody else like to address the Board or make comments to the DEIS for the Tuthill Conservation Subdivision? Deborah Marland: Deborah Marland from Brown's Hills. It does seem that 10 days is not quite enough to resolve all these issues and questions that have been posted. I was just concerned. Chairman Wilcenski: Thank you. I was just going to talk to council about that, would you just bear with me.. Chairman Wilcenski: Okay, after discussion, what we're going to do is close the public hearing but we'll leave the public comment hearing open for two weeks because we, and again we have to generate all the answers for your questions so we're just going to push things back two weeks. So that's what the Board has just decided with council. Glynnis Berry: Excuse me. I'm sorry but you're going to be able to answer all those questions, in what timeframe and where will we find them? Chairman Wilcenski: Well, we actually. I'm not sure exactly about the timeframe by the state . Mark knows better. But my answer would be, as long as it takes to answer all your questions. Glynnis Berry: My request would be that after they're all answered, we have "X" amount of time to write back. Mark Terry: This is a public hearing on the Draft Environmental Impact Statement. So what that means is that, as these comments come in, the questions that you rose here will actually turn into the Final Environmental Impact Statement But that the Board will Southold Town Planning Board Page 111 March 11, 2019 answer every relevant question grouped within that. And that would become that document. Glynnis Berry:,Okay and this is the hearing and is there another hearing then? Mark Terry: There is no other hearing on the FEIS. Chairman Wilcenski: No, the FEIS will be formed, the DEIS turns into the FEIS once all these questions and concerns are answered. The staff and board will entertain and answer all those questions. Mark Terry: So it's important, within the next 14 days to provide any more additional comments, in written form to the Planning Board as they are the lead agency. Glyririis Berry: What happens if we discover that these markup houses are 4,000 square feet footprint and 8,000 square feet totality, what are you going to do? Mark Terry: So once the FEIS is drafted, the Planning Board evaluates all of the comments received and develops a Findings Statement. The Findings Statement is a list of mitigation that would be required by the applicant to proceed with this application.. Glynnis Berry: I don't get that, Mark, but never mind. You'll get my concern. _Chairman Wilcenski:,Okay, this is what I can say to answer your concern is to submit as many and as much questions or concerns that you have in the next two weeks. 'Glyhnis Berry:.,Okay. From as many people as we can? Chairman Wilcenski: Yes. Thank you. James H. Rich III: Mr. Chairman, I make a motion to close the hearing now but remain open for a two week period for written comment. Mary Eisenstein: Second. Chairman Wilcenski: Motion made by Jim, seconded by Mary_ Any discussion?All in favor? Ayes. Opposed? None Motion carries