Loading...
HomeMy WebLinkAbout2024-5-22 975 Anderson Hill Road Keane & Beane P.C. Comments on Draft Scoping Document ◼ Westchester 445 Hamilton Avenue Suite 1500 White Plains, NY 10601 Phone 914.946.4777 ◼ Mid-Hudson 200 Westage Business Center Suite 120 Fishkill, NY 12524 Phone 845.896.0120 ◼ Long Island 534 Broadhollow Road Suite 130 Melville, NY 11747 Phone 631.776.5910 ◼ New York City 60 East 42nd Street Suite 810 New York, NY 10165 Phone 646.794.5747 MEMORANDUM TO: Mayor Jason Klein and Village of Rye Brook Board of Trustees FROM: Keane & Beane, P.C. RE: 975 Anderson Hill Road - Comments on Draft Scoping Document dated March 27, 2024 DATE: May 22, 2024 Keane & Beane, P.C. (“K&B”) has reviewed the Draft Scoping Document, dated March 27, 2024, submitted by property owner Cohen Purchase Building Company LLC (“Cohen”) for the redevelopment of property located at 975 Anderson Hill Road. The following are K&B’s comments for consideration by the Village Board of Trustees: Overall Comments: 1. The document should clarify what it means to study the “existing conditions,” “existing buildings” and “existing development” given that the Doral Arrowwood building is currently being demolished. Introduction 2. Page 2, second paragraph. Delete “To identify appropriate measures to mitigate potential impacts and allow the public the greatest opportunity to comment on the potential impacts of the Proposed Action, the Board of Trustees adopted a ‘Positive Declaration’ on ___, 2024, requiring the preparation of an Environmental Impact Statement (“EIS”).” Replace with a sentence that states the Applicant voluntarily agreed to the preparation of an EIS by unilaterally submitting the Draft Scoping Document with its initial application on March 27, 2024. Description of the Proposed Action 3. Page 3. Delete paragraph beginning “All the Project elements are envisioned…” and delete the paragraph beginning “The Project would also constitute…” Required Approvals 4. Table 1. As of the early 2000’s Anderson Hill Road (the portion in NY) is a Village Road – not a County Road. Therefore, any required road permits would issue from the Village, not Westchester County Department of Public Works & Transportation. Please update Table 1 as necessary. General Guidelines Regarding Organization and Expected Content of DEIS 5. The first paragraph states, “For purposes of the SEQRA analyses, when establishing the existing or baseline conditions, the analysis shall assume the presence and full operation of the former Doral Arrowwood Hotel and Conference Center building.” That baseline condition is appropriate in some instances, but since the hotel and conference center has been shuttered for several years and prior to its closure was not operating at full capacity, it will be important to include in the SEQRA analyses a comparison to the existing condition of a vacant property with no existing buildings to re-occupy. Zoning, Land Use and Public Policy 6. Section 3.2.2, p. 8. Include Airport Zoning District Z-1 (Instrument Approach Zone) and Airport Zoning District Z-4 (Outer Turning Zone) Geology, Soils, Topography 7. Section 4.3, p. 9. In second paragraph, revise to read “Analyze the conformance of the Concept Plan with the requirements of Chapter 213, Steep Slope Protection of the Rye Brook Code, including quantification of the area of disturbance for each of the relevant slope categories.” 8. Section 4.3, p. 9. Consider whether the WCDOH permit for on-site materials processing should be added to the “Required Approvals” chart. Waters and Wetlands 9. Note that the existing pond(s) on-site shall be included in the analysis under this section as it meets the Village Code’s definition of watercourse and wetland. Stormwater Management 10. Section 6.2, p. 10. Strike portion of the sentence which states, “…including the Village-owned properties that have an easement to discharge stormwater to the Project Site.” Or provide a copy of the referenced easement. Vegetation and Wildlife 11. Section 7.2, p. 11. Add the following after the first sentence of the third paragraph: “The EAF Mapper identified the sedge wren as an endangered or threatened species contained on or in proximity to the site.” 12. Section 7.2, p. 12. Strike the following sentence: “No further analysis of rare, threatened, or endangered species, or species of special concern or significant natural communities is warranted.” 13. Add reference to Section 7.3 and Section 7.4 regarding the potential impacts of the proposed project to the sedge wren, if any, and any relevant mitigation measures. Visual Resources and Community Character 14. The locations from which photographs should be taken to demonstrate views of the site from a leaf-on and leaf-off condition are not identified. These publicly accessible vantage points should be included in the scope, including any specific vantage points that the Lead Agency finds to be particularly important. Community Facilities 15. Section 10.5.2, p. 17. Strike the following sentence: “Describe the generation and collection of solid waste and recycling from the Project Site that could occur in a future condition in which the existing office building was fully occupied.” Hazardous Materials 16. Section 13.2, p. 21. Revise to account for the fact that the structures are already demolished or in the process of being demolished. Construction 17. Section 14.2, p. 22. Strike the following which does not seem relevant due to this project’s distance from the high school and middle school: “…coordination with the school district regarding minimizing impacts to the operation of the high school and middle school and impacts to students.” Alternatives 18. Section 15.1, p. 23. Modify to add the word “vacant” as follows: “…and the property remaining in its current vacant condition.” Other 19. The Draft Scoping Document does not include a discussion of post- construction, operational noise impacts. Based on whether the proposed project includes the potential for outdoor programming or outdoor amplified sound which could cause noise impacts, consider whether noise impacts should be studied.