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HomeMy WebLinkAboutReview of Revised DEIS re: The HeritageReview of Revised Draft Environmental Impact Statement For the Heritage at Cutchogue Planned Adult Active Community To determine whether to accept the draft EIS as adequate with respect to its scope and content for the purpose of commencing public review. Prepared for Southold Town Planning Board June 2008 Prepared by KPC Planning Services, Inc 108 Mill Road, #3 Westhampton Beach, NY 11978 w~ X V u~ JUN 3 0 2008 KPC Planning Services, Inc. has reviewed the revised Draft Environmental Impact Statement (DEIS) for the proposed Heritage at Cutchogue project, prepared by Greenman-Pedersen, Inc. dated as revised May 27, 2008. This document was submitted in response to our report dated March 2008, which indicated that the original DEIS was not adequate for public review. The purpose of this analysis is only to determine if the revised DEIS is adequate for public review in terms of scope and content. The content of the DEIS has been compared to the original DEIS as well as the Final Scope, which was adopted by the Southold Town Planning Board on September 10, 2007 and provides the specific requirements for completing the DEIS. The SEORA Handbook is published by the New York State Department of Environmental Conservation and provides very detailed and user-friendly information as it relates to the entire SEQRA process. The following excerpts are taken directly from the handbook, which the Planning Board should take into consideration as they review the draft EIS: A draft impact statement should describe the action, alternatives to the action and various means of mitigating impacts of the action It should discuss all significant environmental issues relates to the action, but it is not the document in which all such issues must be resolved. Resolution of issues before acceptance of a draft EIS, in fact, defeats one of the major purposes of the draft EIS; that is, to give the public an opportunity to comment on the various alternatives regarding the action, so that such comments may be part of the final decision making considerations. The lead agency should remember that a draft EIS does not need to be perfect. It should contain a discussion of information, including sign cant impacts, alternatives and mitigation measures requested by the lead agency in a reasonable level of detail. The purpose of the public comment period is to allow all involved agencies and the public to review the draft EIS and comment on its inadequacies. These can usually be corrected in a final EIS. If there is a fundamental disagreement between the lead agency and the preparer of the draft EIS about its acceptability, it is possible to simply disclose that disagreement in the document itself and explain how the parties vary in their opinions. The public will then be able to comment on this as well. Must differences in interpretation between the project sponsor and lead agency experts regarding a technicalissue be resolved before determining a draft EIS is complete? No. It is not necessary to resolve these types of disputes before accepting the draft EIS as complete. In cases where there are valid differences in interpretation of a technical issue, the lead agency should include both interpretations in the draft EIS. Providing both positions allows a reviewer to reach an independent determination regarding the impact. Project Location The subject property is a vacant 46.17-acre parcel located on the northwest comer of Griffing Street and School House Lane, 1,079 feet north of Main Road (NYS Route 25) in Cutchogue. The property is currently zoned Hamlet Density (HD) and is identified as Suffolk County Tax Map Number 1000-102-2-33.3. Project Description This proposed residential site plan application is for the development of a Planned 55+ Active Adult Community consisting of 139 detached and attached dwellings, 14 of which will be permanently affordable. The affordable units are approximately 1,135 sq. ft each. 46 units will be 2,647 sq.ft. each, 21 units will be 1,930 sq.ft. each, 36 units will be approximately 2,700 sq.ft. each, and 20 units will be 3,110 sq.fr. each. Additional buildings proposed are an 8,840 sq. ft. clubhouse; a 1,160 sq. ft. swimming pool; two 3,200 sq. ft. tennis courts; a 2,400 sq. ft. maintenance garage; a gazebo; a gatehouse; 316 parking spaces, of which 272 are associated with the individual dwelling units and 44 are associated with the clubhouse and recreational facility; 197,043 sq. ft. of manmade ponds to serve as natural drainage basins/irrigation systems; 1,162,022 square feet (27.676 acres) of landscaping; and various other site improvements including road pavement, patio and sidewalk improvements, on a vacant 46.17-acre parcel in the Hamlet Density (HD) Zoning District located on the it/w comer of Griffing Street and School House Lane, approximately 1,079 feet n/o the Main Road, in Cutchogue. SCTM#1000-102-1- 33.3 Review of Revised DEIS We have reviewed the revised DEIS to determine if all of the information requested in our report of March 2008 has been provided and whether the document complies with the requirements of the Final Scope and is adequate for public review. Scone Requirement • Backeround and Historv The project description provided in Section 1.1 of the DEIS has been adequately revised to include a more detailed description of the project, including the number and types of structures proposed, site amenities and accessory structures, the amount of landscaping and open space and a general description of the overall site design and layout. It is noted that the DEIS consistently refers to the property being 45.99 acres when the survey shows it as 46.17 acres. This discrepancy needs to be addressed. Final Scone Requirement ~ Public Need and Municipality Objectives Section 1.1.2 of the DEIS has been adequately revised to include a more detailed discussion of the affordable housing requirements of the Town Code and the manner in which the proposed project complies with the regulations. Final Scone Requirement • Benerts o the Prot It was previously indicated that the project is a "fulfillment of the Town's vision for the subject property as expressed in the Town of Southold Comprehensive Plan and zoning code. " However, we requested that the applicant provide additional information to support the statement. Section 1.1.4 of the DEIS has been revised to indicate that that the property is zoned Hamlet Density (HD) and is being developed in a manner that is consistent with the zoning, but falls short of providing additional information to support the statement that the property is being developed in accordance with the Town's "vision" for the site. If there are no specific recommendations or "visions" for the subject property as contemplated in a Comprehensive Plan or other planning studies, the DEIS should specify such. It was also previously indicated that the project will generate a substantial amount of tax revenue for the Town but did not provide any numbers. Table 1-2 on page 6 of the DEIS has been revised to show that the total tax revenues expected to be generated is $375,000 per year, of which $264,112.50 represents school taxes. A brief explanation of how these numbers were determined should be provided. Final Scone Requirement: Pro[ect Design and Lavout Our initial review of the DE[S indicated there were deficiencies as it relates to a number of items as required by the final scope, specific item #'s 1, 6, 7, 9 and 10 on page five of the final scope. The basis for the site yield in accordance with the requirements of the Town Code has been provided and adequately addresses the issue as it relates to site yield (Section 1.3 of the DEIS). Adequate details have been provided as it relates to the overall site layout, including a detailed description of all of the proposed structures, services, utilities, access points, the road system, drainage and site amenities (Section 1.3 and subsection 1.3.1 of the DEIS). It was previously indicated that the proposed project is a "hamlet design" which provides for "clustered housing: ' We requested additional information to support these statements, particularly as it relates to specific design elements that have been incorporated into the project. Section 1.3 of the revised DEIS no longer indicates that the project is a "hamlet design" that provides for "clustered housing". Parking calculations are still not adequately addressed and it unclear as to whether or not the parking requirements of the Town Code have been met. The gross floor area of the community center must be included in the calculations. This includes any rooms on the second floor or in the basement. We previously requested additional information regarding the design of the internal road network. Section 1.3.3. ofthe DEIS has been revised to indicate that the "concept behind the internal road layout was to slow vehicular traj~c by creating meandering roadways rather than linear roadways often prone to speeding. The layout is also intended to make the environment conducive to pedestrian traj~c, by providing interest in the curved roadway pattern and by providing sidewalks throughout the site. The proposed roadway was also destgned to create an environment that provides a sense of prtvacy by breaking up the units as opposed to having homes all lining the roadways with full views up and down the neighborhood streets. The design is intended to provide a sense of serenity, which is in keeping with the objectives of an active adult community. " While it will be up to the Planning Board to determine whether or not they agree with these statements as it relates to the design of the site, the information has been provided as requested and is adequate for public review and comment. It was previously recommended that across-access with the adjacent property to the east, which is a vacant undeveloped farm parcel with the potential for development, be considered. Section 1.3.3 of the DEIS has been revised to indicate that the adjacent property owner is not interested in providing an easement over their property that would provide direct access to Depot Lane. We previously noted that the Town Code requires public water and public sewer to allow a density of 1 unit per 10,000 square feet of land area in the HD Zone. This proposal calls for on-site septic systems, designed as gang systems (multiple unit systems), which is not community/public sewer. However, the DEIS references a letter dated March 27, 2007 from the Town Attorney indicating that if the project meets Suffolk County Health Department approval with regard to the proposed septic systems, the Town will consider their requirement for a public sewer satisfied. Information re ag rding site lighting still remains inadequate. Section 1.3.5 of the DEIS still only provides limited information regarding the site lighting. As requested in our previous memorandum of March 2008, a detailed lighting plan should be submitted which consists of an illumination plan detailing the footcandle renderings in 5' grids, extending 10' beyond the property line, and includes all exterior luminaires on every building in the site, including wall mounted fixtures, lamps, poles or other supports. In addition, show the isoplots for each luminaire in its place on the site plan. A schedule of on and off times for each light must also be provided. A manufacturer's cut sheet for each luminaire type should be provided. All luminaires should be full-cutoff fixtures that minimize glare. It is noted in the DEIS that the outdoor lighting fixtures will not exceed 14 feet in height as required by the Town Code. However, the street light detail shows that the street lights will be 15' in height, which does not conform to the Town's requirements. The map should be revised accordingly. There is also insufficient information as it relates to the site landscaping. While Section 1.3.5 of the DEIS indicates that a detailed landscaping plans are provided in Appendix C, said information cannot be found in the document. Information regarding the amount of fertilized vegetation and the watering schedule has been provided and is adequate. Final Scope Requirement Construction Section ].4.1 of the DEIS has been adequately revised to include a more detailed description of the construction plan, which now specifies a general work schedule, 4 including the proposed construction at each phase of the project. In addition, information regarding which structures are going to be built first, the location of model units, equipment staging/storage area and the location trailer/construction field office has been provided. Final Scone Requirement: Operation Our initial review of the DEIS found that item #'s 1 thru 7 on page 5 of the final scope were not adequately addressed as it relates to the operation of the site, which includes the establishment of a Homeowner's Association. Section 1.4.2 of the DEIS has been adequately revised to provide a more detailed description of the operation of the site, including the specific use of the site's facilities, seasonal operations, special events, the number of anticipated employees, the type of truck traffic that can be expected and the general location of the truck loading to be provided at the community building. Final Scone Reguirement • Permits and Approvals Required Section 1.5 of the DEIS had been revised to provide the specific agencies required for utility hookups as identified in Table 1-5 on page 15 of revised DEIS. Final Scope Reauirenrent: Soils Our initial review of the DEIS revealed there was no discussion regarding the loss of agricultural soils as required in item # 1 on page 6 of the final scope (soils). Section 2.1.2 of the revised DEIS includes a statement which indicates that the proposed project will result in a loss of approximately 45 acres of agricultural soils for which no mitigation is offered but indicates that the property is being developed in accordance with the zoning requirements of the Town Code. As it relates to the proposed mitigation relating the contaminated soils, we previously requested that a more detailed soil management plan be provided to mitigate the potential exposure to arsenic and mercury, particularly during and after construction when the soils are disturbed. According to the conclusions of the Pesticide Report prepared by Nelson and Pope dated November 8, 2007, "based on laboratory rest results, elevated concentrations of arsenic and mercury were identified. As a result, it is recommended that a sod[ management plan be prepared to mitigate potential exposure to arsenic and mercury. " It is stated in Section 2.1.3 of the DEIS that the proposed mitigation will involve "isolation of the soils as part of the grading plan to ensure that either non- impacted subsoils are exposed at the surface, or impacted surface soils are covered with at least one (/) foot of clean soil. " The DEIS also references the Suffolk County Department of Health Services soil management guidance to ensure that contaminants aren't ingested or inhaled. This information was already put forth in the original DEIS and does not include the additional information we requested as stated in our memorandum of March 2008, which requested that a more detailed soil management plan is needed to mitigate the potential exposure to arsenic and mercury, particularly during and after construction when the soils are disturbed. Once excavated or collected, contaminated soils must be managed so that they do not constitute a new source of contamination for the environment. The mitigation should include a detailed description of the levels of contamination, the amount of contaminated soil to be removed, 5 preventive measures to protect adjacent property owners from exposure, methods for re- use or relocation of contaminated materials and other remediation that may be necessary. Final Scone Requirement: Water Resources Our initial review of the DEIS indicated that item #'s 2, 3, 4, 6, 10 and 1 ] of page 6 of the final scope were not adequately addressed as it relates to water resources. Soil boring data with the depth to groundwater has been provided and is adequate. It is noted in the Section 2.1.1 of the DEIS that the depth to groundwater was observed to be 25 feet. It is noted that on the test boring location plan prepared by Nelson and Pope dated last revised May 7, 2007, there were eight (8) test borings dug on this site. Boring # 3 revealed the depth to groundwater to be 25.6 feet and boring # 2 with a depth to groundwater at 17.6 feet. All other borings show the depth to groundwater to be over 25 feet. Section 2.1.1 of the DEIS has been adequately revised to indicate that the direction of groundwater flow is determined using the groundwater contour map published by the Suffolk County Department of Health Services, a portion of which is shown in Figure 2-2 in the revised DEIS. Based on this data, the groundwater moves northwest to southeast. The location of the private wells on adjacent properties has been provided as requested and shown on Figure 2-3, preceding page 23 of the revised DEIS. In addition, Section 2.2.2 of the DEIS has been adequately revised to include a discussion about the potential impacts to adjacent private wells servicing the residential lots to the east. Although not discussed in Section 2.2.3 of the revised DEIS, an alternative design for the site which includes an onsite sewage treatment facility is discussed in the alternatives section of the DEIS and therefore has been addressed as required. Final Scope Requirement ~ Vegetation and Wildlife Our initial review of the DEIS indicated there was inadequate information regarding the impacts on wildlife and vegetation. Specifically, we found that item #'s 1 thru 6 on page six of the final scope as it relates to vegetation and wildlife were not addressed. The plant species found on-site have been identified by Green Shield Ecology Group through an inspection of the site conducted on April 30, 2008. The credentials of the company and the ecologists who preformed the survey have also been included. In a letter dated May 5, 2008 from Steven N. Handel, Ph.D , a Certified Senior Ecologist with the company, it has been indicated that no rare, endangered or special status species were identified on the property. The original DEIS indicated that "overall, the site's biodiversiry will remain at an equivalent or higher level than under existing conditions. " Given the proposal to clear the entire property of its natural vegetation, we requested additional information to support this statement. Section 2.3.1 includes a brief discussion regarding the invasive plant species, which, according to the DEIS, "detracts enormously from its overall ecological value." However, as stated earlier in this memo, a detailed landscaping plan 6 was not provided with the revised DEIS and therefore an assessment of the adequacy of the site landscaping cannot be determined. In addition, there is no discussion about the feasibility of preserving some of the existing vegetation to mitigate the potential impacts to wildlife. It is noted that if said opportunities to preserve existing vegetation do not exist, either due to the level of invasive species found on site or for other reasons, Section 2.3.3 of the DEIS should specify such. Final Scone Requirement: Transportation We previously noted that the final scope identified 16 specific items relating to traffic impacts based on staffs review of the Traffic Impact Study prepared by Nelson and Pope dated November 2007. It was not clear whether these items were addressed in the Traffic Study, which, based on our discussions with the Town, had been revised after it was initially reviewed. In a letter dated April 30, 2008 from Nelson and Pope, a copy of which is provided in Appendix H of the DEIS, responses to each of the 16 items of the final scope have been provided and are further explained. Final Scooe Requirement: Land Use Zoning and Plans Our initial review of the DEIS indicated that item #'s 1, 2, 3, 4, 5 and 6, of page 9 of the final scope were not adequately addressed as it relates to land use zoning and plans. With respect to the existing land use character of the site and surrounding area within 500 feet of the subject property, Section 3.2.1 of the DEIS has been revised to include information as it relates to the surrounding land uses and zoning and is found to be adequate. While Section 3.2.2 of the DEIS has been revised to indicate that there are no impacts on zoning due to the project's conformance with the zoning requirements of the HD Zoning District, there is no discussion regarding the compatibility and consistency of the proposed land use on the surrounding land uses and therefore needs to be addressed as previously requested. As previously requested, the DEIS does not identify and discuss the North Fork Recreation Travel Needs Assessment as required by the final scope for this project. Final Scope Requirement: Community Facilities and Services Our initial review of the DEIS indicated that item #'s 2, 3 and 5 on pages 9 and 10 of the final scope were not adequately addressed as it relates to community facilities and services. Information regarding tax revenues generated by this project has been addressed earlier in this report. As stated earlier, although estimated tax revenues are provided in Table 1-2 on page 6 of the DEIS, an explanation of how these numbers were determined should also be provided. The revised DEIS indicates that each of the service providers have been contacted (police, fire, school district) a second time but responses have not been received to date. Each of the letters indicate that if a response from each of the service providers are not received within two (2) weeks, it will be assumed that they are able to provide services for this project. Copies of these letters are provided in Appendix H and show that responses were requested by May 30, 2008. The project sponsor should indicate if any information came in during the time period between May 27, 2008 (date of the DEIS) and the May 30, 2008 deadline for responses. Section 3.3.3 of the revised DEIS still does not provide information as it relates to the overall site design features that would mitigate potential impacts as it relates to fire and police services. While it remains noted in the DEIS that the "facility will have state of the art fire facilities that will aid in all fighting needs of the local fire departments" specific information has not been provided. In addition, it was previously requested that the DEIS identify, if any, design elements of the site (e.g. security cameras, officers, lights, fencing, building orientation, etc.) that would reduce the demand for police services. Said information has not bee provided. Final Scope Reauirement.• Aesthetic Resources. Open Space/CommunitL Character and Public Health Our initial review of the DEIS revealed inadequate information with respect to items #'s 1 thru 8 on page 10 of the final scope as it relates to aesthetic resources, open space/community character and public health. Section 3.4.1 of the DEIS has been revised to provide a more detailed discussion regarding the existing site and community character as it relates to the zoning, land uses and the open space potential of the sun•ounding properties. However, it still lacks substantive comments as it relates to issues like architecture, massing and scale, connectivity to the nearby business district, and other physical features that define the existing character of the community. Section 3.4.1 of the DEIS has been revised to provide additional information as it relates to the impacts relating to the construction activities. In addition to providing a detailed discussion of the phasing of the development, this section of the DEIS now includes a description of the methods that will be utilized to mitigate the impacts associated with construction activities, such as silt fencing, storm drain inlet protection and haybales, which are widely accepted practices and are often conditions of site plan approval in most municipalities. There is no vegetation proposed to screen the east side of the development from the neighboring property or the scenic viewshed of Depot Lane. As stated earlier in this report, there is a lack of information as it relates the site landscaping, which must be provided to assess the impacts as it relates to aesthetics. Section 3.4.2 of the DEIS states that over an eight year period, the vegetation along the westerly property line will grow to buffer the development from the adjacent residential properties and that ultimately only the roofs of the structures will be visible. The DEIS must specify the height to which each of the plant species is expected to grow and in how 8 many years. The DEIS must also provide a detailed landscaping plan for the Planning Board to make findings as it relates to visual/aesthetic impacts. Section 3.4.3 of the DEIS has been adequately revised to address safety hazard issues relating the site construction. The DEIS indicates that a number of safeguards will be in place, such as fencing, covering of holes, limited hours of operation and proper storage of construction material. The revised DEIS fails to adequately address the visual impacts as requested in our initial review as follows: Overall, the DEIS lacks a discussion ofthe visual impacts of the proposed project. While there are a number of color renderings provided in Appendix C, it is not clear from what vantage points these are based. The DEIS must provide a detailed visual assessment for this project such as viewpoint panoramas to illustrate existing and potential visual impact from key viewpoints, a written analysis of the magnitude and significance of potential visual impact related to change through time, appropriate mitigation to limit visual impact and demonstration of its effectiveness by computer modeling or color renderings and photomontage based on accurate three dimensional models to illustrate the proposed development. The DEIS should include a discussion of the visual impacts as it relates to the character of the surrounding community, including the degree to which the development would result in buildings that would detract from the existing style or image of the area due to density, height, bulk, setbacks, signage, architectural style, massing or other physical elements. The DEIS should provide an internal visual assessment to get a sense of pedestrian scale and what this project will Zook like from the inside. Are the proposed structures effectively integrated into the aesthetics of the site, through appropriate design, and have the objectives of creating a traditional streetscape been accomplished though the proposed site design? Will this project connect to the existing community and how will the site design promote or enhance the economic vibrancy of the Cutchogue Hamlet Center? Final Scope Reguirement• Use and Conservation olEnerQV Resources As requested, Section 4.0 of the DEIS has been revised to indicate that the "applicant intends on incorporating Leadership in energy and Environmental Design building guidelines and principles in the proposed construction project. " Basic, but sufficient, information regarding the use of energy efficient building materials and mechanical systems has been provided, although there is no discussion as to how the overall design of the site promotes energy reduction/efficiency through such features as building orientation and the use of landscaping. As required in the final scope and identified in our initial review of the DEIS, there needs to be a discussion and evaluation of "dark sky" standards to mitigate the potential impacts as it relates to energy consumption and light pollution. Final Scope Requirement: Cumulative Imnacts As stated in our previous review, the DEIS should specify if there are any design elements of this project that would mitigate potential impacts in conjunction with the potential future development of the adjacent residential property to the east or the commercially-zoned properties along Griffing Street. Final Scone Reguirement: Adverse Imnacts That Cannot Be Avoided The issue regarding the potential impacts to endangered floral species has been adequately addressed. At stated earlier in this report, the plant species found on-site have been identified by Green Shield Ecology Group through an inspection of the site conducted on April 30, 2008. The credentials of the company and the ecologists who preformed the survey have also been included. In a letter dated May 5, 2008 from Steven N. Handel, Ph.D., a Certified Senior Ecologist with the company, it has been indicated that no rare, endangered or special status species were identified on the property. Although not discussed in this section of the DEIS, it is noted that we previously requested that alternative sewage treatment systems be evaluated. Section 5.0 of the DEIS discusses the alternatives to the proposed project, including an alternative design for wastewater treatment and therefore has been adequately addressed. With respect to our previous request for an analysis of the potential impacts associated with the multiple septic systems proposed for this site, it is noted that Section 2.2.2 of the DEIS provides a discussion regarding the potential impacts relating to Nitrogen loading of the groundwater. In addition, appendix E provides the BURBS calculations in determining the nitrogen impacts of the project. According to the DEIS, BURBS is the modeling program developed by the Northeast Regional Agricultural Engineering Service at Cornell University, which "computes the potential impact of the proposed development on the groundwater within a community due to nitrogen. " Accordingly, the DEIS has been adequately revised to address the issue of impacts relating to the septic systems for this site. Section 4.2 of the DEIS has been adequately revised to identify the permanent loss of prime agricultural soils as an impact that cannot be avoided. Final Scone Reauirement: Irreversible and Irretrievable Commitment of Resources Section 4.3 of the DEIS has been revised to remove the statement "there will be a minimal removal of vegetation from the site, as only a small amount of vegetation exists at the site " and now adequately represents the actual proposal to remove all of the vegetation of the site. Final Scope Requirement: Alternatives to be Studied The final scope requires the five (5) alternatives be discussed in the DE[S: 10 1. No action alternative. 2. Alternative design including, but not limited to clustering of detached and attached units to create meaningful open space and maximize vegetative buffers along the perimeter of the property. 3. Reduce existing number of units. 4. Partial of full preservation of the property. 5. Alternative design for wastewater treatment. Section 5.0 Alternatives of the DEIS is not adequately addressed. This section of the DEIS must provide a discussion of each alternative, sequentially, as they are described in the Final Scope. The Final Scope's Alternative #3 requires that the number of existing units be reduced. The intent of this alternative is to provide a plan that shows less than the 139 units that are existing on the current plan. The DEIS does not provide this alternative. Additional Comments/Recommendations Page 3 of the DEIS refers to the Village Zoning Code when it should read Town Zoning Code. 2. Within the zoning discussion on Page 41 of the DEIS, the R-40 Zoning District is described as being Residential Low Density AA. This does not appear to be a valid zoning district within the Town. 3. Section 3.2.1 of the DEIS should specify that the property is listed as eligible in the Community Preservation Project Plan. 4. The second paragraph on page 66 of the DEIS should specifically identify the park that is being referred to and its location in relation to the subject property. 5. The DEIS is missing the floor plans and elevations for the community center and each of the five types of units proposed for this site. The DEIS only provides the floor plan and building elevation for one residential building. 6. It is noted that Section 2.3.3 refers to a densely vegetated berm around the perimeter of the project. However, that the easterly property line does not contain a vegetated berm. In addition, and as stated earlier in this report, the berm detail should be clarified to identify the maximum height that the plantings can be expected to reach. Conclusions Based on our review of the DEIS as discussed in the above analysis, the information, data, analyses and discussions identified in this report as being deficient are of such a magnitude that they should have full public review at the draft stage. The Planning Board is advised to review our findings and advise the applicant of the changes that will be required. If you have any questions concerning our comments or wish to discuss them further, we would be pleased to meet with you at work session to discuss. 12