HomeMy WebLinkAboutGreenport Medical Offices and Residences 1000-34.-2-1
Norklun, Stacey
From:Noncarrow, Denis
Sent:Wednesday, March 01, 2023 9:48 AM
To:Norklun, Stacey
Subject:FW: Letter/package to distribute to the Supervisor, Deputy Supervisor and Town
Board
Attachments:Town Board-Trustees letter 2023-02-28.pdf; GNNA membership list 2023-02-20.pdf;
22-072T Greenport Site Final Report.pdf; GNNA CND cover letter 2023-02-28.pdf;
GNNA CND requested actions 2023-02-28.pdf; Visual packagePB-ZBA-PD CND
2023-02-28.pdf
Denis Noncarrow
Southold Town Clerk.
Town of Southold, New York
www.southoldtownny.gov
denisn@southoldtownny.gov
631-765-1800
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged
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intended recipient, please contact the sender and destroy all copies of the communication.
From: Standish, Lauren
Sent: Wednesday, March 1, 2023 9:47 AM
To: Noncarrow, Denis <denisn@southoldtownny.gov>; Rudder, Lynda <lynda.rudder@town.southold.ny.us>; Doherty,
Jill <jill.doherty@town.southold.ny.us>; Doroski, Greg <greg.doroski@town.southold.ny.us>; Evans, Louisa
<louisae@town.southold.ny.us>; Mealy, Brian <brian.mealy@town.southold.ny.us>; Nappa, Sarah
<sarah.nappa@town.southold.ny.us>
Subject: FW: Letter/package to distribute to the Supervisor, Deputy Supervisor and Town Board
From: Carol Lindley <cmlindley@outlook.com>
Sent: Tuesday, February 28, 2023 4:25 PM
To: Standish, Lauren <Lauren.Standish@town.southold.ny.us>; Tomaszewski, Michelle
<michellet@town.southold.ny.us>
Subject: Letter/package to distribute to the Supervisor, Deputy Supervisor and Town Board
Hi Lauren and Michelle,
Attached is a cover letter addressed to the Supervisor, Deputy Supervisor and Town Board members, together with a
package of background materials. I would appreciate it if you would distribute these materials to all.
Thank you,
Carol
1
Carol M. Lindley
cmlindley@outlook.com
631-433-2237
ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders
or unexpected emails.
2
Greenport North Neighborhood Association
c/o 512 Sterling Place
Greenport, NY 11944
February 28, 2023
Town Supervisor Scott Russell, Deputy Supervisor Kevin Foote & Members of the Town Board
Board of Trustees President Glenn Goldsmith and Members of the Board of Trustees
Town of Southold
P.O. Box 1179
Southold, NY 11971
Re: Greenport Medical Offices and Residences (SCTM# 1000-34-2-1)
I am writing on behalf of the Greenport North Neighborhood Association, a group of 47
individuals and families who reside in the immediate area surrounding 160 Route 25 (a copy of
our membership list is attached). Since the subject site plan was submitted in the fall of 2021,
we have been advocating for the appropriate use of this parcel, a 4.7 acre piece of vacant land
that is located at a significant crossroads the entrance to Greenport Village and to the North
Fork.
Attached for your review is the package of requested actions that we submitted today in
response to the draft Conditioned Negative Declaration thatby the
Planning Board. The drafting a CND was in response to
a mitigation plan submitted by the applicant. The original site plan application, and the
possibility of a positive declaration, requiring a DEIS, also remains under consideration. Also
attached for your review is a traffic report that we commissioned in response to a faulty traffic
impact assessment that was included in the applisubmission.
We recognize that the Town Board does not typically get involved in the review of site plan
applications. However, in this instance, we recently learned that two Town Board members
purchasing and developing this property and the
Housing Advisory Commission
subsequently toured the property with the applicant. This was all revealed by the applicant and
public hearing on
th
February 6.
assume some responsibility for what may be the end result a strip-mall-style development
that offers motel-size apartments for transient workers that are not affordable and medical
, and turns an already dangerous intersection into a more dangerous
community-wide traffic nightmare. This development will forever change one of the most
visible locations on the North Fork into a little slice of Route 347 in Stony Brook or Sunrise
Highway in Patchogue.
At a point in time when the Town is embarking on significant changes in its code and
invigorating its commitment to implementing the Comprehensive Plan, we sincerely hope that
effect a
development that provides families and respects the
rights of the existing community.
Best regards,
Carol M. Lindley
cc: Chairman Donald Wilcenski, Southold Town Planning Board
Chairperson Leslie Kanes Wiseman, Southold Town Zoning Board of Appeals
Planning Department Director Heather Lanza
February 3, 2023
Donald Wilcenski, Planning Board Chair
Town of Southold Planning Board
54375 Main Road, P.O. Box 1179
Southold, NY 11971
Re: Proposed Greenport Medical Offices and Apartments
160 Route 25, Greenport
SCTM#1000-34-2-1
Dear Chairman Wilcenski and Planning Board Members:
Schneider Engineering, PLLC has been retained by the Greenport North Neighborhood
Association (GNNA) Group to evaluate the traffic impacts associated with the proposed
Greenport Medical Offices and Apartments located at 160 NYS Route 25, Greenport, New
York.
As part of our evaluation, we have reviewed the following materials:
1. Town of Southold Draft Notice of Intent to Prepare a Conditioned Negative
Declaration, dated December 5, 2022
2. Town of Southold Planning Board Work Session Notes, dated December 5, 2022
3. Group for the East End letter to Town of Southold Planning Board, dated
November 18, 2022
4. Traffic Impact Assessment prepared by LKMA, dated October 26, 2022
5. Proposed Site Plan prepared by LKMA, dated October 26, 2022
6. NYSDOT Final Design Report, dated July 2022
7. Group for the East End letter to Town of Southold Planning Board, dated April 22,
2022
8. NYSDOT Draft Design Report, dated January 2022
9. NYSDOT Roundabout Site Plan prepared by GPI
10. Town of Southold Planning Department Draft Impact Assessment
11. NYSDOT letter to residents, dated June 15, 2021
12. AKRF Memorandum to the Town of Southold, dated September 15, 2018
In order to properly evaluate the anticipated impacts of a newly proposed development,
it is critical to perform a traffic impact study that is based on the most up-to-date
information including but not limited to site description details, existing peak traffic
volumes, traffic volumes associated with the proposed development, traffic volumes
43 Seacliff Avenue Miller Place, New York 11764 631 698-6200
www.schneiderengineering.com New York New Jersey Florida
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associated with other proposed developments in the vicinity, and roadway design features
that are reasonably expected to exist when the proposed site is built. The Traffic Impact
Assessment prepared for this proposed development prepared by LKMA dated October
26, 2022 fails to incorporate the up-to-date details, and therefore the traffic impacts are
not appropriately evaluated for use as a traffic study to support the proposed new
development.
Based upon our review of the Traffic Impact Assessment and the above listed materials,
the specific concerns with the Traffic Impact Assessment are summarized in the following
points:
1. The existing conditions traffic volumes taken by NYSDOT for their Design Report
for the proposed roundabout at the intersection NYS Route 25 and CR 48 are the
Assessment did not obtain its own traffic volumes but instead relied on the
NYSDOT traffic volumes for its LOS analyses. The NYSDOT traffic volumes were
taken in pre-COVID. Since then, traffic volumes have resumed to more normal
conditions, if not have even increased from re-emerging activity associated with
nearby farms, vineyards and other tourist attractions. Thus, we recommend new
traffic counts be taken to reflect the increases in existing traffic volumes on the
roadway.
2. The Traffic Impact Assessment solely relied on the no-build future traffic volumes
calculated by the NYSDOT. However, as addressed in section 2.3.1.7 (2) of the
NYSDOT Draft Design Report and Final Design Report, the no-build traffic
volumes do not include traffic volumes associated with other proposed
developments in the vicinity because none were identified (for the next 20 years)
at the time of the report, including, and importantly, this subject development,
directly adjacent to the proposed roundabout. Recently, other
developments/applications in the Town of Southold have developed which will
increase traffic volumes on the roadway system and which will contribute to
creating new, unknown at the time impacts that the NYSDOT had available when
they prepared their study. In addition, there are sites that were existing when the
NYSDOT took traffic counts but that were not fully being utilized in the way they
are anticipated to in the future that should be re-accounted for. These
developments include the following:
a. The Enclaves Hotel, located at 56655 NYS Route 25, Southold. The
application is for the conversion of an existing 3,026 sq. ft. residence with a
584 sq. ft. addition into a 74-seat restaurant and the construction of a hotel
with 44 units and an outdoor pool.
b. The Mattituck Hotel, located at 9025 NYS Route 25, Mattituck. The
application is for the re-development of an existing commercial site
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including the demolition of the existing building, and the construction of a
hotel with 121 rooms, restaurant, catering facility and indoor recreation
totaling 200,087 sq. ft.
c. Silver Sands Motel & Cottages, located at 1400 Silvermere Road,
Greenport. The application is for substantial renovations to the existing site
which will contain 30 motel rooms, 20 cottages and a new restaurant.
d. Vineyard View Affordable Apartments Complex, located at 6200 North
Road, Greenport. The site was constructed in 2020 as an apartment
complex with 50 one-to-three bedroom apartments. The initial lottery for
apartments was held on July 27, 2020, after the NYSDOT took traffic
counts.
e. The Sound View Motel and The Halyard, located at 58775 CR 48,
Greenport. This is an existing site containing 55 motel rooms and a
restaurant which was accounted for by the NYSDOT traffic counts, however
there has been post-pandemic upgrades and expansion of its wedding and
events business which may account for higher occupancy rates.
Thus, clearly shows the need that new traffic counts be taken, and the future no-
build conditions be recalculated to include these other identified proposed
developments in the area.
3. A Saturday peak hour count was not analyzed in the LOS analysis. The reason
majority of trips, and that their anticipated usage on a Saturday would be
significantly lower (ITE, which McLain used) actually stated with an insufficient
sample size for Medical Office Buildings on Saturdays), a Saturday peak hour was
area. ITE provides that the average rate per 1000 square footage for a Medical
Office Building on a Saturday is 3.10 spaces, which is based on 4 studies, and is
comparable to the AM peak rate of 3.53 and PM peak rate of 4.10 which indicates
that the Saturday rate may be consistent with the other peak periods. If the ITE
rate is unacceptable, another industry acceptable method to obtain a rate is by
researching past studies that have been performed for a similar site, or, obtaining
trip generation rates at a similar site to determine an appropriate rate. Because
traffic volumes are highest in the area on Saturdays, especially during the summer
months, it is critical the Saturday peak LOS be analyzed.
4. The Traffic Impact Assessment only analyzed the site driveways in an LOS
analysis and did not analyze any intersections. Because traffic volumes are likely
higher in the area from when the NYSDOT took traffic volumes and because there
are several other developments that have been unaccounted for by the NYSDOT
analysis, it is essential an updated LOS analysis be performed at the intersection
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of NYS Route 25 and CR 48. In addition, the intersection of NYS Route 25 and
Bailey Avenue, and Knapp Place should be analyzed since it is other primary
intersections in the immediate vicinity that residents are directly impacted by.
5. The Traffic Impact Assessment should include an alternative analysis of the
intersection of NYS Route 25 and County Road 48 without a roundabout, for two
reasons. Reason one is the roundabout is one of four locations for the NYSDOT
improvements project in which the contractor (after the project is awarded) has the
freedom to complete in whichever order they desire, and therefore this
development may be constructed before the roundabout is constructed. This was
confirmed in our conversations with NYSDOT Design Leader Vinicio Lora. Reason
roundabout from being constructed on-time or prevent it from being constructed
all-together. It is critical that the alternative analysis be conducted because without
the roundabout constructed when there are no other proposed developments
accounted for in the area, the northbound movement operates at unacceptable
LOS F during the Saturday peak and LOS C during the Midday and PM peak which
may be worsened with the additional currently unaccounted for traffic volumes.
6. The Traffic Impact Assessment LOS analysis is based on 4 buildings being
constructed at the proposed development. As proposed mitigation by the
developer, the westerly building will not be constructed and there will be a total of
just 3 buildings on-site. Therefore, the LOS analysis in the study should be
updated to reflect updated trip generation numbers for the proposed development.
7.
completely and having everyone enter and exit directly onto the northerly curb cut
on County Road 48. This would reduce a large safety hazard that would be created
by people attempting to make turns out of the westerly driveway to head on Main
Street southbound. It would also remove a curb cut so close to the residential
neighborhood near Knapp Place. By having all enter and exit onto a major
highway, away from residential streets, would be a highly improved traffic safety
alternative. Permitting a left turn out of the site onto County Road 48 would be a
safer alternative then allowing cars making a left turn out of the proposed westerly
driveway while cars are just leaving a roundabout to head southbound, fairly close
to the westerly driveway exit. It is just a safer traffic alternative.
8. With the new development being placed at the corner of the location of the
roundabout, a Draft Environmental Impact Statement may need to be prepared to
address the traffic safety issues at the intersection as well as other environmental
issues discussed in the New York State Department Of Transportation Report.
Δ
In conclusion, in addition to the concerns outlined above about the Traffic Impact
Assessment, we also recommend the westerly curb cut and driveway be relocated further
to the north, because its proposed location is just 12.5 feet from the southern property
line abutting the residential neighbors.
Based upon our review, it is our professional opinion the applicant be subjected to an
updated traffic impact assessment that should be part of an issuance of a positive
declaration for a Draft Environmental Impact Statement (DEIS) pursuant to the New York
State Environmental Quality Review Act (SEQRA) for a more in-depth review of traffic
impacts.
Further, because the subject development abuts NYS Route 25, the developer will have
to apply for work permits through the NYSDOT. As part of the permit process, a traffic
impact study will be required. The study submitted should be an updated study, at a
minimum addressing the concerns discussed in this report.
If there are any questions, do not hesitate to contact my office.
Sincerely,
Steven Schneider, P.E.
Principal
Greenport North Neighborhood Association
Draft Conditioned Negative Declaration Requested Actions
Impact on Transportation
1) Incorporation of all recommendations included in the Schneider Engineering traffic
report submitted to the Planning Board at the February 6 public hearing
2) Most important among the recommendations is the need for a traffic-count-
based traffic study that is conducted on weekends during the high season (July/August)
and focuses on all affected intersections, including:
Route 25/Bailey Avenue
Route 25/Sound Road
Route 25/northerly driveway
Main Street/Knapp Place
Main Street/Champlin Place
Route 48/Middleton Road
Route 48/Madison Street
Route 48/McCann Lane
3) Further, we request that this study includes a safety evaluation component that looks at
options for addressing safety issues at all intersections noted above and on the local
roads, considering various options for traffic movement to minimize the spill-over of
traffic onto local roads and to address the impact of spill-over, such as speed bumps and
implementation of one-way directions
4) All studies need to address the possibility that the development is constructed before
the roundabout (or that the roundabout come to fruition)
Impact on Aesthetic Resources
1) Lot coverage of the mitigation plan submitted by the developer is approximate 2 acres,
43% of the 4.7 acre parcel (building area of .6 acre, impermeable parking area of 1 acre
+ .4 acre of other impermeable surfaces 2 2-lane driveways, loading zones, sidewalks
and exterior entrances)
2) In order to further minimize density and overall impact, we request:
February 28, 2023
Reduction of parking to 50 stalls (and the required adjustments to the number
and/or size of the buildings, noting that the code guidance on the apartments is that
only one parking space is required for each apartment) with additional space to
allow for more planting beds throughout the lot, improving the residential character
and reducing the impermeable lot coverage
Elimination of the westerly driveway and shifting of the northerly driveway to the
east
Expansion of the buffers on the east and south perimeters to 100 ft.
Elimination of the third building to the east (see attached revised site plan drawing)
Detailed landscaping plan, with a range of plantings that reflects seasonal changes
Detailed lighting plan that is Dark Skies compliant (including 2700 K warm bulbs)
and addresses the significant impact that light pollution will have on the surrounding
neighborhood (the lighting plan implement at Vineyard View is unacceptable)
Detailed fencing plan, including height and fencing material, that mitigates the visual
impact on the neighborhood
Impact on Noise, Odor and Light
1) The removal of the westerly driveway will significantly reduce the noise/odor/light
impact for the neighbors on Main Street
2) Need covenants/restrictions that do not allow any commercial use that functions
outside of standard 9-5 business hours or on weekends
3) Need a construction noise monitoring plan in place before construction is allowed to
begin
4) Buffering requirements noted under Aesthetic Resources will also mediate the impact
of noise/odor/light
5) In addition to Bailey Avenue and Champlin Place, clearing/grading/construction vehicles
cannot be permitted on Knapp Place (with some clearly defined access allowed to install
water/sewer access) and Sterling Place
February 28, 2023
Impact on Human Health
1) Based on the concerns expressed by the DOT in its final report that the site may contain
hazardous materials, an environmental screening is needed to ensure that there are no
known contaminants on the site and, if there are, a mediation plan needs to be
established prior to granting site plan approval
Consistency with Community Character
1) Removal of the westerly driveway will have a positive effect on this impact
2) The current design and height of the buildings is inconsistent with the style of
construction in the neighboring communities (predominantly bungalow, cottage and
farmhouse style homes)
Additional concerns to be addressed
1) The medical office use needs to be clearly defined and the necessary covenants and
restrictions need to be put in place to make this the only allowable use in perpetuity
2) All aspects regarding the structure, use and management of the workforce housing
apartments need to be clearly defined, with the necessary covenants and restrictions
put in place in advance of project approval, including:
The apartments remaining affordable in perpetuity
Applicants must be registered on the Southold Town Affordable Housing Registry
and eligible for placement prior to possession being taken
Leases will be on an annual basis only (i.e., no short term or month-to-month lease
provisions)
Clearly defined house rules regarding noise, allowable occupancy levels and other
standard use requirements
February 28, 2023
Greenport North Neighborhood Association
Name Address Email Phone
David Berson and Meg Bennett 508 Sterling Place dberson1@yahoo.com 631-477-2515
mbenn47939@aol.com 631-664-6728
Robert Corwin Sound Road recorwin@optimum.net
Joyce Covello and Peter Maltese 506 Bailey Avenue jtvoice@mac.com 917-597-7875
maltesep@optonline.net
Deb Cutler and Ray Norton Sound Road rnorton901@hotmail.com
Margaret Rose de Cruz 25 Washington Avenue mrdecruz@gmail.com 917-865-4655
Kirsten Droskowski 531 Sterling Place droskdk@aol.com 631-831-7582
Petrina Engelke and Thomas Halaczinsky 1116 Main Street petrina@petrina.tv 646-498-6198
thomas.halaczinsky@gmail.com 347-985-6885
Lucy and John Eustice 305 Bridge Street leustice@mzwallace.com 917-756-5186
jde@spartacycling.com 917-699-4566
Mary Gabriel and Adrian Greenberg Sound Road agreenberg825@optonline.net
Cara Galowitz and Anders Goldfarb 465 Bailey Avenue cgalowitz@nyc.rr.com 917-887-8787
Bruce Garritano and Peter Harbes 619 Bailey Avenue brucegarritano5@gmail.com 631-745-0289
peterharbes5@gmail.com 631-617-8552
Tammi and Tim Grattan 69305 Route 48 tgratt10@yahoo.com 631-495-9110
Joanne Greenbaum 495 Sterling Place joannegreenbaum@me.com 917-476-8652
Carolyn and Steve Greer 260 Sound Road cgreer3339@gmail.com
Carol-anne Hoffmann 307 Champlin Place choffmann4@gmail.com 631-553-3930
Lori Hollander and Scott McIntire 22 Sound Road lorihollander1@gmail.com 917-697-5986
scotmcintire@earthlink.net
Cheryl Horsfall 295 Bailey Avenue chorsfall@mac.com 917-763-0364
Gregory Hugunin and Laura Raps 504 Sterling Place laurar50@mac.com
Greg Humphreys and Rubina Costabile Sound Road humphreys.greg@gmail.com
rmc_77@hotmail.com
Cynthia Ickes cynthiaickes@gmail.com 631-766-0233
Joan Kart 611 Bailey Avenue joankrt@hotmail.com
Anthoula Katsimatides 335 Sterling Place anthoulakats@gmail.com 917-770-7004
Rory Klinge and Carol Lindley 512 Sterling Place roryklinge@gmail.com 631-433-2236
cmlindley@outlook.com 631-433-2237
Sue Kreiling and Paul Henry 820 Main Street suekreiling@yahoo.com
as of 2/20/2023
Greenport North Neighborhood Association
paulmichaelhenry@hotmail.com
Stephen Kustera and Elizabeth Talerman 304 Sterling Place skustera@gmail.com 848-219-3980
etalerman@gmail.com 917-674-6202
Adriene Lakowitz 324 Knapp Place scopes31@optonline.net
Chris Larkin 765 Cedarfields Drive chrislarkin55@gmail.com
Helena Ludrosky and Stephen Worsham Manhanset Avenue helena.ludrosky@gmail.com 631-479-7951
sduvworsham@gmail.com
Kristie Lutz and Pi Waller 202 Knapp Place kristie.lutz@gmail.com 609-432-6998
pi.waller@icloud.com 917-913-3457
Carol Marker 526 Bailey Avenue c.marker@verizon.net
Cathleen Marshall cathleenmarshall@gmail.com
Carole and Richard Mavity Sound Road rmavity@earthlink.net
Chris McGlinchey 735 Champlin Place cwmcglinchey@gmail.com 917-957-5970
David Mendelsohn 455 Knapp Place davemendelsohn@yahoo.com
Leslie Merinoff Kwasnieski and Brian 455 Route 25 leslie@matchbookny.com 646-879-0875
Kwasnieski brian@matchbookny.com
Sarah-Mai Miller 1155 Main Street sarahmai@chalk242.com
Paula Muth 213 Knapp Place paulamuth@gmail.com
James and Kathleen Nenopoulos 317 Knapp Place jnenopoulos@gmail.com 917-583-8413
kathleenbb2@aol.com
623 Bailey Avenue greenport925@optimum.net 917-299-2784
631-477-9629
Tom Padden 435 Sterling Place peconicappr@gmail.com
Margot Perman and Jurgen Riehle 1200 Main Street margot@rdany.com 917-660-3727
jurgen@rdany.com
Susan Pinkwater and Sally Searby 675 Champlin Place susan@pinkwatergroup.net 917-864-5531
salsearby@gmail.com
Ruth Shank backstreetdesign1@yahoo.com 631-291-2245
Jonathan Sperling 503 Main Street khyber95@aol.com 703-402-5075
David Vincents 900 Bailey Avenue davidjv@protonmail.com
Rena and Barry Wiseman Sound Road wisebody@verizon.net
Jackie Wolfson 509 Sterling Place jwolfson@optonline.net
as of 2/20/2023
Greenport North Neighborhood Association
c/o 512 Sterling Place
Greenport, NY 11944
February 28, 2023
Chairman Donald Wilcenski, Planning Board
Chairperson Leslie Kanes Weisman, Zoning Board of Appeals
Director Heather Lanza, Planning Department
Town of Southold
P.O. Box 1179
Southold, NY 11971
Re: Greenport Medical Offices and Apartments (SCTM# 1000-34-2-1)
I am writing on behalf of the Greenport North Neighborhood Association (GNNA) in response to the
draft Conditioned Negative Declaration. Attached are three documents:
A listing of all requested actions to address the impacts on Transportation, Aesthetic Resources,
Noise/Odor/Light, Human Health and Consistency with Community Character. In addition,
outlined a number of additional concerns to be addressed, including proposed covenants
and restrictions, related to several components of the project.
A panoramic photo of the medical office complex on Manor Lane, across from ELIH. This is
submitted as an example of a construction style and scale that we feel is much more consistent
with the character of the surrounding community. The design and scale of the buildings
proposed by the developer are decidedly not consistent with the neighborhood and, as such,
they do not conform to the RO code which encourages the adaptive reuse of existing
older residences to preserve the existing visual character of the
Our recommended modifications to the mitigation plan drawing incorporating the density
reducing actions requested in the Aesthetic Resources section, namely:
1) Reducing the parking area to 50 spaces, with additional space to allow for more
planting beds throughout the lot, improving the residential character and reducing
the impermeable lot coverage
2) Eliminating the westerly driveway
3) Shifting the northerly driveway to the east
4) Expanding the buffers on the east and south perimeters to 100 ft.
5) Eliminating the third building at eastern side
Note: The area labeled represents the area we are recommending
for the buildings to be constructed (we are not requesting the construction of one
long building); this should be broken up according to the allowable footprint).
February 28, 2023
Page 2
Although we are submitting this package of proposed actions, please know that we remain committed
to our position that the size, complexity and unique nature of this mixed-use development requires a
positive declaration and a DEIS in order to ensure a comprehensive and transparent review of the
project.
Best regards,
Carol M. Lindley
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