HomeMy WebLinkAbout1000-106.-6-10 & 13.4 OFFICE LOCATION: ® Qv SQ � MAILING ADDRESS:
Town Hall Annex P.O.Box 1179
54375 State Route 25 Southold, NY 11971
(cor. Main Rd. &Youngs Ave.)
® a0 Telephone: 631 765-1938
Southold, NY 11971
LOCAL WATERFRONT REVITALIZATION PROGRAM
TOWN OF SOUTHOLD
To: James H. Rich III, Chair
Town of Southold Planning Board
From: Mark Terry,AICP
Assistant Town Planning Director
LWRP Coordinator
Date: July 8, 2024
Re: LWRP Coastal Consistency Review for Strong's Yacht Center
SCTM 1000-106.-6-10 & 13.4
The proposed action includes the construction of two, one-story buildings of 52,500 SF and
49,000 SF to provide indoor winter storage of larger yachts, up to 86 feet in length, with
associated improvements including gravel-based driveways and parking areas, water supply,
sewage disposal, site grading, and drainage, landscaping, and lighting. Also proposed is the
removal of a pool and patio.
The Strong's Yacht Center is situated on a 32.96±-acre parcel located south of Old Mill Road
and on the west side of Mattituck Creek on lands zoned M-II (approximately 16.46 acres) and R-
80 (approximately 16.5 acres). Prior to its purchase by Strong's in April 2017, the subject site
was known as the Mattituck Inlet Marina and Shipyard which existed as a full-service marina,
maintenance, repair and storage operation for over 60 years. As illustrated on the proposed site
development plans prepared by Young &Young, the subject property is currently comprised of
40 boat slips with associated ramps and fueling and developed with eight buildings to support the
operation of the marina, as well as the sale,maintenance, dockage and storage of boats. The eight
existing buildings include the following:
• Building 1: One-story residence(1,610 SQ. FT.)
• Building 2: Two-story office(2,702 SQ. FT.)
• Building 3: One-story storage(17,320 SQ. FT.)
• Building 4: One-story storage(169 SQ. FT.)
• Building 5: One-story storage(341 SQ. FT.)
• Building 6: One-story storage(10,766 SQ. FT.)
• Building 7: One-story storage(15,076 SQ. FT.)
0 Building 8: One-story storage (22,425 SQ. FT.)
The two proposed buildings would become Building 9 (49,000 SQ. FT.) and Building 10 (52,500
SQ. FT.). Upon implementation of the proposed action, the total gross floor area of all buildings
would increase from 69,245 SQ. FT. to 171,929 SQ. FT.
The proposed action has been reviewed to Chapter 268,Waterfront Consistency Review of the
Town of Southold Town Code and the Local Waterfront Revitalization Program (LWRP) Policy
Standards. Based upon the information provided in the submitted documents, as well as the
records available to us,it is my recommendation that the proposed action is INCONSISTENT
with LWRP policy standards and, therefore, is inconsistent with the LWRP.
Policy 1 Foster a pattern of development in the Town of Southold that enhances community
character,preserves open space, makes efficient use of infrastructure, makes beneficial use of a
coastal location,;and minimizes adverse effects of development.
Based upon the information provided in the file documents, the removal of trees, adverse impacts
to habitats, and significant impact on the quality of life of residents and visitors in the region
resulting from noise, vibration, and disruption of daily activities long in duration, the proposed
action cannot meet this policy. The proposed action does not 'foster a pattern of development in
the Town of Southold that enhances community character,preserves open space, and minimizes
adverse effects of development. "
The community character impact of the Proposed Action is not the maintenance of an existing
maritime aesthetic,but the destruction and excavation of a natural forested area and its
replacement with over 100,000 square feet of industrial maritime warehouse. The community
character impact of the Proposed Action is the expansion of the existing maritime use and the
potential impacts that would have on adjacent uses, namely, the open space and outdoor
recreational uses of the Mill Road Preserve and the Mattituck Creek and the low-density
residential uses in the surrounding area(FEIS).
Policy 2 Preserve historic resources of the Town of Southold.
The applicant has not proved that policy"2.1 Maximize preservation and retention of historic
resources"has been met and that potential adverse impacts of new development on nearby
historic resources have been avoided to the greatest extent practicable.
Policy 3 Enhance visual quality and protect scenic resources throughout the Town of Southold.
The visual quality of the landscape is a major contributor to the community character of the
Town of Southold. The Town includes different landforms, a variety of upland and shoreline
vegetation, a complex land and water interface, well-defined harbors, and historic hamlets. In
addition to the many highly scenic natural resources found throughout the Sound, the variety of
cultural elements in the landscape and the interplay of the built and natural environments,
especially along the waterfront, are of particular importance to the visual quality of the Town
(LWRP).
The analysis provided relies upon the narrative that the visual nature of the Site is that of a
maritime use and that the Proposed Action will continue to have the visual nature of a maritime
use.
The visual impact of the Proposed Action is not the maintenance of an existing maritime
aesthetic,but the destruction of an elevated natural forested aesthetic and its replacement with
over 100,000 square feet of industrial maritime warehouse. This narrative is easy to overlook
with the lack of a defined ZVI, viewshed analysis, and existing viewpoint photographs with
corresponding proposed condition photo simulations. The DEIS visual impact analysis fails to
deliver what was required in the scoping document and instead presents an unsubstantiated and
narrative of no visual impact that cannot be relied upon (FEIS).
As indicated in the FEIS and Findings, the proposed project will result in the physical loss
(Forest, Northern Long-Eared Bat (Federally Endangered) habitat, and other bat and wildlife
species)), degradation (trees and soils), and functional loss of ecological components (Reduction
of Contiguous Woodland and other Habitat Assemblages: Mill Road Preserve.), and does not
meet `Policy 6 Protect and restore the quality and function of the Town of Southold's
ecosystem".
1. Physical loss of ecological components
Physical loss is often the most obvious natural resource impairment to
identify. It usually results from discrete actions, such as filling or
excavating a wetland or clearing an upland forest community prior to
development.
The proposed project will destroy a forest community habitat. The LWRP
defines habitat destruction as the loss of fish or wildlife use through direct
physical alteration, disturbance, or pollution of a designated area or
through the indirect effects of these actions on a designated area. Habitat
destruction may be indicated by changes in vegetation, substrate, or
hydrology, or by increases in runoff, erosion, sedimentation or pollutants.
The physical impacts, edge effects to adjacent ecosystems, and
construction noise may potentially disrupt or destroy the surrounding
ecosystems.
2. Degradation of ecological components
Degradation occurs as an adverse change in ecological quality, either as
a direct loss originating within the resource area or as an indirect loss
originating from nearby activities. Degradation usually occurs over a
more extended period of time than physical loss and may be indicated by
increased siltation, changes in community composition, or evidence of
pollution.
Degradation of habitat direct loss originating within the resource area
(Parcel) or as an indirect loss originating from nearby activities would
occur from removing the forest, habitat assemblages, and -documented
species, including those with protected status living on the parcel and in
the adjacent Mill Road Preserve.
3. Functional loss of ecological components
Functional loss can be indicated by a decrease in abundance offish or
wildlife, often resulting from a behavioral or physiological avoidance
response. Behavioral avoidance can be due to disruptive uses that do not
necessarily result in physical changes, but may be related to introduction
of recreational activities or predators. Timing of activities can often be
critical in determining whether a functional loss is likely to occur.
Functional loss can also be manifested in physical terms, such as changes
in hydrology.
The adverse impacts from removing the forest, habitat assemblages, and
documented species, including those with protected status living on the
parcel and in the adjacent Mill Road Preserve, are expected. A functional
loss would occur.
6.4 Protect vulnerable fish, wildlife, and plant species, and rare ecological communities.
The project site adjoins the state-designated Mattituck Inlet Wetlands and Beaches Significant
Coastal Fish and Wildlife Habitat, which is incorporated into Southold's Local Waterfront
Revitalization Program (LWRP).
The proposed project would result in physical loss of wildlife habitat and species. The sub
policy Protect vulnerable fish and wildlife species is not met. The proposal fails to protect
habitat of listed species identified through field surveys or other methods during all stages of
their life cycles. As indicated in the FEIS, fauna with protected status documented to be on or
adjacent to the Project Site that were not accurately described in protected status or not
sufficiently included in the analysis, or both; specifically, the Piping Plover, the Eastern Box
Turtle, the Northern Long Eared Bat, and the Bald Eagle. The protected status of the Northern
Long-Eared Bat (NLEB) has been heightened from "threatened" to "endangered"by the United
States Fish and Wildlife Service since the drafting of the DEIS. Further:
• The DEIS does not discuss the Bald Eagle population that has been documented in the
adjacent areas. Additionally, the DEIS does not address the Peregrine Falcon, the
Nighthawk, the Common Loon, the Horned Lark, or the Osprey, all species listed under
the New York State status of Special Concern.
• The analysis does not discuss the impact that the forest edge effect would have on the
habitat of documented species with protected status living in the adjacent Mill Road
Preserve.
• The analysis underrepresents the diversity of birds,bats, and insects living on or adjacent
to the Project Site and the impacts that the Proposed Action would have on those
populations.
• Supporting documentation lacking in detail, quality, or with inconsistencies between the
data and how the data is used and presented in the DEIS
The proposed project does not meet sub policy 10.4 Minimize adverse impacts of new and
expanding water-dependent uses and provide for their safe operation.
B. Avoid development of new water-dependent uses at sites that are located outside of the
traditional concentrations of water-dependent uses or at sites that exhibit important
natural resource values or where the proposed use will cause significant adverse effects
on community character, surrounding land and water uses, or scenic quality.
The proposed project can potentially cause significant adverse effects on community
character, surrounding land and water uses, and scenic quality.
Please contact me at(631) 765-1938 if you have any questions regarding the above.