2018.11.02 FP Clark Memo1
To: Paul S. Rosenberg, Mayor and the
Village of Rye Brook Board of Trustees
Date: November 2, 2018
Subject: 900 King Street, Petition to Amend the PUD Regulations
and an Application for a PUD Concept Plan – Substantive
Review of the Accepted Draft Environmental Impact Statement
As requested, we reviewed the Draft Environmental Impact Statement dated September
12, 2018, submitted to the Village of Rye Brook Board of Trustees by Rye King
Associates, LLC, as part of a petition to amend Section 250-7 E, Planned Unit
Development (PUD) regulations of the Village Code and an application for a PUD
Concept Plan regarding the property located at 900 King Street, Town of Rye Tax Parcel
129.68-1-13. The Proposed Action would construct 269 units of age-targeted housing
and related infrastructure, including driveways, walkways, garage and surface parking,
site lighting, signage and stormwater management facilities.
SUMMARY
Our office conducted a substantive review of accepted DEIS on behalf of the Village
Board of Trustees. Our comments regarding the document are included in this
memorandum. Based on our review, we believe the Applicant should be directed to
provide a Final Environmental Impact Statement (FEIS) that responds to comments and
concerns regarding the DEIS. The FEIS should address all comments provided by the
Village boards, consultants, and staff, and any comments submitted by the public and
other agencies during the SEQR hearings and the written comment period.
COMMENTS
LAND USE, PUBLIC POLICY AND ZONING [DEIS Section 3]
1. Page 3-1, Section 3.2.1.1, Current Conditions, Project Site, Zoning: The
discussion in the section correctly indicates that the current development on
the Site, though conforming as determined in 1998 by the Rye Brook Building
Inspector at the time, does not provide regulatory requirements specific to the
existing office building or the Arbors. However, demolition of the existing
office building and redevelopment of the commercial lot would be regulated
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by the current PUD district requirements that allow 9,000 square feet per acre and 6
residential units per acre, among other requirements regarding setbacks, buffers, maximum
building height, etc. Therefore, the current PUD regulations should be considered the starting
point for the Applicant’s proposed zoning amendments and PUD Concept Plan. The
proposed 26,000 square feet per acre gross floor area and the combined 10.4 dwelling units
plus 4.8 assisted living units (total of 15.2 residential units per acre) should be reviewed
against the current requirements of 9,000 square feet per acre and 6 residential units per
acre, and other PUDs in Rye Brook, such as the Arbors (15,900 square feet per acre and 7
units per acre), Sun Homes at Reckson(12,000 square feet per acre and 3.5 units per acre),
BelleFair (1.9 units per acre), Doral Green (7.9 units per acre).
The proposed 45-foot building height and 4 story building should be compared to the current
35-foot building height for senior living facilities, and the proposed setbacks/buffers of 16
feet, 22 feet, and 70 feet should be compared to the current required buffers of 150 feet, 100
feet, and 50 feet. These comparisons should be clear when considering the new zoning and
waivers requested for the Proposed Action.
2. Page 3-2 Table 3.1, Existing PUD Requirements: Table 3.1 is only a partial list of current
regulations for PUDs and should be considered with Table 3.2, Table 3.3 and Table 3.4.
3. Page 3-3, Section 3.2.1.2, Land Use: The density of residential development in the Arbors is
approximately 7 dwelling units per acre and 15,900 square feet of GFA per acre, which the
Village Board may want to review when considering the Applicant’s zoning petition to
change the use of the Site to senior housing and increase the number of allowable dwelling
units and the allowable total amount of GFA on the 17.77-acre Site. Revision of the PUD
regulations is recommended in the Rye Brook 2014 Comprehensive Plan, provided any
changes made maintain “… Rye Brook’s low density character,” which consists of the number
of dwelling units, the size and gross floor area of the units, and the type of buildings housing
the units on a lot. Any revised PUD standards should not stand out from, but should maintain
the low density character and complement the existing zoning and land uses in the
neighborhoods surrounding the Site, which are predominately attached townhomes, local
civic buildings (middle/high school, firehouse and village hall), and detached single family
homes.
4. Page 3-6, Section 3.2.2.1, Table 3, Proposed Additional PUD Dimensional Requirements:
The buffer/yard requirements of the proposed PUD zoning for the Site are less restrictive
than the current PUD buffer requirements. However, the setbacks of the proposed PUD
Concept Plan are less restrictive than the proposed zoning, which would require the Village
Board to waive certain of the setbacks in the zoning proposed by the Applicant. The Applicant
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should explain the need for the differences when the proposed zoning petition will create the
requirements for the plan.
Consideration of the buffer/setback requirements should be based, as a starting point, on the
current PUD regulations because the Proposed Action is a completely new use and concept
plan for the Site. The consideration by the Village Board of revisions to the current
requirements should include a determination of the appropriate setbacks/buffers for the size
and location of the proposed building allowable under the new zoning and its PUD Concept
Plan regarding loading areas, roads, and parking areas, and the environmental constraints
of the site, such as the presence of steep slopes and wetlands and wetland buffer areas.
Larger buildings should be setback farther from roadways, small residential buildings and
civic buildings than smaller buildings. Buffers between larger buildings and smaller ones
should be wider to allow space between the differently scaled buildings.
5. Page 3-9, Table 3-4 - Section 3.2.2.2. (Other PUD Requirements, Parking): Review of the
comparison between proposed PUD parking requirements and the proposed parking supply
for the site indicated that the proposed site will provide 300 parking spaces, while the
proposed PUD parking requirement is 263 spaces. The Applicant is providing an additional
37 parking spaces or 14 percent over the requirements. The Applicant should provide a
comparison using the latest Institute of Transportation Engineers (ITE) “Parking Generation,”
4th Edition for all proposed land uses to provide additional backup information for the parking
required for the proposed development.
6. Page 3-15, Section 3.3.1.2, Re-Assessment of the Provisions of the PUD Zone: The 2014
Comprehensive Plan addresses several aspects of existing PUDs in Rye Brook, including
the Arbors/900 King Street PUD. The last sentence of the first paragraph of the plan under
the heading “Re-Assess the Provisions of the PUD Zone,” Page 144, states that the Village
“… clearly desires to carefully control the type of large scale development that is
contemplated by the PUD Zone...” when considering adjustment of density to be less
restrictive. Further, any less restrictive regulations contemplated should maintain “… Rye
Brook’s low density character.” The proposed amendments in the Applicant’s zoning petition
and the accompanying proposed PUD Concept Plan would develop a high density, large-
scale multi-family building on a relatively small site that is not consistent with the
recommendation of the Comprehensive Plan in our opinion. The Applicant should re-consider
the zoning petition to reduce the allowable building bulk, the number of units per acre and
the gross floor area per acre to be more compatible with existing zoning adjacent to and
surrounding the Site.
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GEOLOGY, SOILS, AND TOPOGRAPHY [DEIS Section 4]
7. Page 4-3 and 4-4, Section 4.2.3: The DEIS states that an additional groundwater monitoring
well (OW-2x) was installed to provide supplemental geotechnical data after a high
groundwater level was observed in observation well OW-2. The DEIS then states that similar
conditions were found in OW-2x. The DEIS then concludes that there is a possibility of a
perched water flowing beneath the asphalt into OW-2. The Applicant should explain how this
conclusion was made. If there is perched water beneath the site, why were extra monitoring
wells not installed to explore the extent of the perched water. The Applicant should explain
why the two locations for the groundwater observation wells were chosen and why other
locations on the site were excluded from groundwater observation.
8. Page 4-5, Section 4.3.1: The DEIS states the grading for the Proposed Project was designed to
create a leveler site, which is necessary for the proper functioning of an age-restricted residential
community. However, the cut and fill and grading required to achieve the proposal results in
13.17 acres of disturbance, the creation of 0.72 additional acres of steep slopes and the removal
of 213 trees on the Site. The Applicant should explain the specific aspects of the existing site
that prevent it from properly functioning as an age-restricted community. The PUD Concept
Plan should be reconsidered by the Applicant to reduce disturbance to the Site.
9. Page 4-6, Section 4.3.2: The states that areas of steep slopes along the northern, western, and
southeastern portion of the Project Site have been avoided. However, based on Figure 4-5
“Proposed Steep Slope Condition,” the slopes along the northern and western portions of the
site have been disturbed and in some cases result in additional steep slopes. The Applicant
should explain specifically how the areas have been avoided. Based on review of the PUD
Concept Plan the areas have not been avoided. The only way to completely avoid these
areas would be for the PUD Concept Plan to be reconsidered by the Applicant to reduce
disturbance to the Site.
WATERS AND WETLANDS [DEIS Section 5]
10. Page 5-5, Section 5.3.2, Potential Impacts of the Proposed Project, Direct Impacts to Wetland
and Waterbody Buffer Areas: Section 245-9, A. (3) of the “Wetlands and Watercourses”
chapter of the Village Code requires mitigation for activities in a buffer at a ratio of 2:1 “… for
the area of wetland/watercourse buffer disturbed by the proposed activity that replace or
enhance the functions of the wetland or wetland/watercourse buffer…” Based on the
requirement of the code, and the information in the DEIS, 2.79 acres of buffer would be
disturbed by construction of the proposed PUD Concept Plan based on the zoning proposed
by the Applicant.
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As a new use and development, the Proposed Action will be required to comply with the current
requirements of Chapter 245 of the Village Code to obtain a wetlands permit from the Planning
Board. Based on the currently proposed PUD Concept Plan, the Proposed Action would
require 5.58 acres of buffer and/or wetland mitigation for the 2.79-acre disturbance. The DEIS
indicates that the current plan would provide only 1 acre of mitigation, which is inconsistent
with the requirements of Chapter 245. The Applicant should provide the required area of
mitigation.
Before mitigation is considered by the wetland regulations, Chapter 245 encourages the
conservation of wetland buffers and recommends re-design of impactful projects to eliminate
or reduce impacts. We recommend that the Applicant re-consider the zoning proposed and
the PUD Concept Plan to reduce or eliminate disturbance of wetlands buffers on the property
so the PUD Concept Plan complies with the requirements of Chapter 245.
VEGETATION AND WILDLIFE [DEIS Section 7]
11. Page 7-5, Section 7.3.4: The DEIS states that the only impacts from the proposed removal
of the 213 trees on the site would be the temporary impacts of reduced shade and tree habitat
during the construction period. The Applicant has not identified the impact of the loss of 213
mature trees on the existing site due to the excessive disturbance to site to achieve the PUD
Concept Plan. The FEIS should address the impacts of the loss of mature vegetation and the
Applicant should reconsider the PUD Concept Plan to reduce disturbance to the Site.
12. Page 7-5, Section 7.4: The DEIS states that 212 of the 438 trees proposed to be planted
would meet the requirements of Section 235-18 of the Tree Ordinance. The Applicant should
explain how the other 226 do not meet this criteria of the Code Section and why the Applicant
is proposing non-complying trees.
VISUAL RESOURCES AND COMMUNITY CHARACTER [DEIS Section 8]
13. Page 8-2, Table 8-2, Parcel Coverage Comparison: The Proposed Action includes a
collection of 2.95-acres of building footprints, 3.98-acres of on-grade parking/roadways and
445,000-square feet of gross floor, which leaves 10.84 acres of open space on the 17.77-
acre Site.
The existing office building and parking area/roadways include a 2.17-acre building footprint,
5.29-acres of on-grade parking and 215,000-square feet of gross floor, which leaves 10.31
acres of open space.
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For comparison, it would be helpful to provide the same type of statistics, presented in a
similar manner, for Alternative 17.3, Senior Living Facility under the Existing PUD
Regulations, to inform the Village Board’s review of the potential impacts to community
character from the current building as built, a development under the current zoning and the
Proposed Action.
14. Page 8-11, Section 8.2.4, Other Developments in the Village: While the DEIS presents large
commercial buildings in Rye Brook in this section to point out that there is a precedent of
large buildings in Rye Brook, it is the visual impacts and changed community character of
adjacent residential properties and the neighborhoods immediately surrounding the
Proposed Action that is of concern, especially as the proposed GFA would be significantly
higher than the current PUD zoning allows. In our opinion, the locations and siting of the
commercial buildings mentioned are very different from the situation of the Proposed Action.
These buildings are not impactful to the character of the residential neighborhoods they are
adjacent to or within by virtue of a number of factors.
The Atria at BelleFair is separated by significant topography from the BelleFair residential
neighborhoods and by distance from the closest residences in Greenwich, C.T. The
Doral/Arrowwood Conference Center is located on a very large site separating it by great
distances from the Doral Green homes, area roads and the Blind Brook Golf Club.The Hilton
at Rye Brook is located on a large parcel that is enclosed by significant topography and
separated from adjacent homes and area roadways by substantial grade changes. And, 800
Westchester Avenue is located on an insular large site surrounded by roadways, and it is not
located near any residences.
15. Page 8-19, Section 8.3.3, Consistency of the Proposed Project with Existing Visual and
Community Character: Rye Brook’s low-density character is created by the size, scale and
building types of existing residential and PUD neighborhoods and the relationship of built
areas to the open space areas on lots. Any revised PUD regulations for 900 King Street
should not create development that alters the character of neighborhoods surrounding the
Site, which are predominately attached townhomes, local civic buildings (middle/high school,
firehouse and village hall), and detached single-family homes.
The proposed amendments in the Applicant’s zoning petition and the accompanying
proposed PUD Concept Plan would develop a high density, large-scale multi-family building
on a relatively small, environmentally constrained site, and would be significantly less
restrictive than the current PUD regulations, impacting the character of the neighborhoods
adjacent to the Site. We recommend the Applicant re-consider the zoning petition and the
PUD Concept Plan to reduce the allowable building bulk, the number of units and the gross
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floor area per acre to be more compatible with existing development adjacent to and
surrounding the Site.
SOCIOECONOMICS AND FISCAL IMPACTS [DEIS Section 9]
16. Page 9-7, Section 9.3.2: The loss per year of tax revenue was incorrectly calculated. The
loss of $65,000 in revenue took place over 5 years, not 1 year. The FEIS should provide the
correct calculations.
17. Page 9-7, Section 9.4.1: The DEIS states that the Proposed Project is anticipated to add a
population of 462 people to the Village. This was calculated by estimating 1 person per
Assisted Living facility bed, 2 people per Independent Living unit and 2 people per
townhouse. With the proposed age-restriction of 55 and the number of 2- and 3-bedroom
units, in addition to “empty-nesters” and elderly people, the proposed project would also
attract families with children. The projected population should be recalculated to take into
consideration the above.
18. Page 9-7, Section 9.4.2: The DEIS states that the Applicant has sought an estimated
assessed value from the Town Tax Assessor. However, the information was not provided at
the time of publication of the DEIS (September 12, 2018). The last correspondence with the
Town Tax Assessor is dated April 27, 2018. The Tax Assessor was awaiting more detailed
information from the Applicant in order to perform the estimated assessment. The FEIS
should provide the estimated assessment from the Town Tax Assessor and the projected
taxes for all jurisdictions used in Table 9-9 of the DEIS.
19. Page 9-8, Section 9.4.2: The DEIS states that the Applicant will not be seeking “standalone
tax-exempt status” from the Internal Revenue Code. The FEIS should identify any tax
exemptions or subsidies that the Project would be eligible to receive, other than the tax
exemptions and reductions that maybe available through the Westchester County Industrial
Development Agency.
COMMUNITY FACILITIES [DEIS Section 10]
20. Page 10-6, Section 10.2.3.1: According to the EMS, 50 of the EMS calls to the Atria for the
period from June 2017 to June 2018 were for “lift assist.” These are calls where no one is
hurt or needs care, they just require help getting up after a fall. The Applicant should advise
whether there will be a EMT required to be on-site 24 hours a day, 7 days a week in the
assisted living and independent living facility to help in cases that would require “lift assist.”
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If there is an EMT on-site, this would limit the number of calls to the Port Chester-Rye-Rye
Brook EMS.
21. Page 10-6, Section 10.2.3.1: The Port Chester-Rye-Rye Brook EMS received 1257 calls in
2017. By the Applicant’s estimate, the potential projected calls per year by the Proposed
Project would be 465. This would be a 37% increase in the numbers of calls to the EMS that
is currently operating near or at capacity, not a 7.8% increase as incorrectly identified by the
Applicant in the DEIS. The FEIS should analyze the cost of the 37% increase in call versus
the increase in funding from tax revenue and the 70% insurance recovery rate.
22. Page 10-12, Tables 10-8 and 10-9: The tables provide the amount of open space that should
be provided per 1,000 people based on guidelines provided by the New York State Office of
Parks, Recreation and Historic Preservation (OPRHP). The attached appendices and figures
do not contain the original information from the OPRHP and we have been unable to verify
the information. The FEIS should include the original report from the OPRHP to verify that
the information on recommended open space is correct.
23. Page 10-18, Section 10.6.4: The Applicant should explain why the Applicant believes that
residents of the proposed development will not use the existing Rye Brook Senior Center
inside the Anthony J. Posillipo Community Center.
TRAFFIC AND TRANSPORTATION [DEIS Section 12]
24. Page 12-1 and 12-2 - Section 12.2. and Pages 2 and 3 – Appendix F, Section D (Existing
Traffic Conditions): The turning movement counts were conducted when School were open
on both Wednesday, March 29, 2017 and Wednesday, January 31, 2018. The spring recess
for the 2016-2017 School year was from April 8 to April 16, 2017 (Easter) and Passover was
from April 10 to April 18, 2017. *Both the Middle School and High School start at 7:50 A.M.
and end at 2:17 P.M.*
As requested, Maser Consulting conducted traffic counts when School were open at the
North Ridge Street/Hutchinson River Parkway Southbound Ramps on Thursday, September
20, 2018 during the weekday morning and weekday afternoon peak hours and on
Wednesday, September 26, 2018 during the weekday midday peak hour. It was determined
that the counts conducted on Thursday, September 20, 2018 should be recounted, as the
day before Schools were closed for Yom Kippur. Therefore, Maser Consulting conducted
counts on Thursday, October 18, 2018 during the weekday morning and weekday afternoon
peak hours. Below are the results of the comparison between the June 22, 2018 counts and
the September 26, 2018 and October 18, 2018 total intersection traffic volumes:
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NORTH RIDGE STREET AT HUTCHINSON RIVER PARKWAY SOUTHBOUND RAMPS
Weekday Morning Peak
Hour
(7:30 – 8:30 A.M.)
Weekday Midday Peak Hour
(2:30 – 3:30 P.M.)
Weekday Afternoon Peak
Hour
(5:00 – 6:00 P.M.)
June
2018
October
2018
%
Difference
June
2018
September
2018
%
Difference
June
2018
October
2018
% Fixed
Difference
780 777 -0.38 635 654 3.00 675 680 0.74
Based on the comparison provided, the traffic volumes from June, which were used in the Traffic
Study, are reasonably acceptable for the purposes of this Study.
In addition, Clark Associates has conducted their own traffic counts at the King Street/Arbor
Drive intersection on Tuesday, October 2, 2018. Below are the results of the comparison
between the March 29, 2017 counts and the October 2, 2018 total intersection traffic volumes:
KING STREET AT ARBOR DRIVE
Weekday Morning Peak
Hour
(7:30 – 8:30 A.M.)
Weekday Midday Peak Hour
(2:30 – 3:30 P.M.)
Weekday Afternoon Peak
Hour
(5:00 – 6:00 P.M.)
March
2017
October
2018
%
Difference
March
2017
October
2018
%
Difference
March
2017
October
2018
% Fixed
Difference
1,876 1,864 0.64 1,545 1,575 -1.94 1,784 1,779 0.28
In our review of the data, the October 2018 counts had a weekday afternoon peak hour from
4:30 to 5:30 P.M. The intersection overall volume for this peak hour was 1,847 vehicles and
when compared to the March 2017 volumes for the 5:00 to 6:00 P.M. peak hour was 3.53
percent higher than the volumes in Traffic Study. Intersection volume fluctuation of 5 percent
or less is typical. The intersection total volume comparison indicated that the traffic volumes
used in the Traffic Study are reasonably acceptable. Attached please find the traffic counts
conducted by Clark Associates.
An Automatic Traffic Recorder (ATR) was installed by Clark Associates on King Street north of
Arbor Drive twice; however, there was a technical issue (tampered with) and will be recounted
the week of October 29th. Once the data is received it will be compared to the Applicant’s
existing traffic volumes.
As part of the evaluation and review of the traffic section, field observations were conducted by
staff on multiple occasions along King Street and including the Hutchinson River and Merritt
Parkway Interchange Ramps, the Arbors Drive and Blind Brook Schools signalized
intersections. During the morning peak period, as it relates to both commuter traffic and School-
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related traffic, significant delays were observed along King Street generally from and including
the Parkway ramp intersections, along King Street in the vicinity of the Arbors signalized
intersection and including the Blind Brook School’s driveways. This congestion and delays were
clearly related to School activity and included School buses, staff, parents and students.
Combined with this traffic was the typical commuter traffic found along King Street.
During the afternoon School dismissal, traffic conditions were found to be better with reduced
delays; however, there were observed traffic delays related to the School dismissal, mostly in
the vicinity of the Blind Brook School’s signalized intersection, which continued to the Arbors
signalized intersection. However, during both the morning and midday time periods the Arbors
Drive intersection driveway had minimal traffic delays. The dismissal time delays were found to
dissipate within 15 minutes and is typical for any School activity on adjacent roads.
During the typical weekday afternoon commuter time period, which essentially excludes any or
most School-related traffic the delays were found to be less and traffic flowed reasonably well,
although there were short-terms delays at the signalized intersections near Glenville Street.
The field observations mostly match the results of the computer modeling for these
intersections, as completed by the Applicant’s Traffic Consultant.
25. Page 12-2 and Page 12-5 - Section 12.3.1., 12.5.2. and Table 12-4 and Pages 7 through 18
– Appendix F, Section I and Tables 1 and 2 (Capacity Analysis – Existing Conditions): The
capacity analysis provided is reasonably acceptable and is properly calibrated to illustrate
existing conditions with capacity deficiencies on the minor street approaches at the
Hutchinson River Parkway interchange as well as queue along King Street at key signalized
intersections.
26. Page 12-3 - Section 12.4. and Page 4 – Appendix F, Section F (No-Build Conditions): The
current office building is 215,000 square feet not 200,000 square feet, which was used in the
Traffic Study. However, the use of 200,000 square feet is acceptable for purposes of this
Study, which illustrates that the proposed uses generate significantly less traffic than the
current office building, if fully occupied, at 200,000 square feet. The existing office building
traffic estimates are acceptable. After further review, the percent distribution for King Street,
north of Anderson Hill Road may be higher than the estimated 10 percent for the re-
occupancy of the office building traffic. The Applicant has accounted for five other
developments and has used an appropriate growth; therefore, the 2025 no-build traffic
volumes are reasonably acceptable.
27. Page 12-3 and Page 12-5 - Section 12.4., 12.5.2. and Table 12-4 and Pages 7 through 18 –
Appendix F, Section I and Tables 1 and 2 (Capacity Analysis – No-Build Conditions): The
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capacity analysis provided is reasonably acceptable. However, the northbound through
movement at the intersection of King Street/Betsy Brown Road during the weekday peak PM
highway hour should be 542 vehicles, not 452 vehicle. This should be revised and the capacity
table updated.
28. Page 12-4 - Sections 12.5.1 and Pages 4 and 5 – Appendix F, Section F (Site Generated Traffic
and Distribution): The Applicant has increased the trip rates for the 160-units of senior adult
housing by 25 percent (x 1.25) to account for larger units and is acceptable. Site traffic estimates
for the 24 residential townhouses and 94-Bed assisted living are acceptable. Site traffic
distribution is reasonably acceptable for the proposed residential development.
29. Appendix F, Section G (Build Conditions): The 2025 build traffic volumes are reasonably
acceptable.
30. Page 12-5 - Section 12.5.2. and Table 12-4 and Pages 7 through 18 – Appendix F, Section
I and Tables 1 and 2 (Capacity Analysis – Build Conditions): The capacity analysis provided
is reasonably acceptable.
31. Page 12-6 - Section 12.5.6. and Appendix F, Section J and Tables 3A through 3C (Accident
Data): The Applicant has provided accident data from 2014 to 2016 and is acceptable.
CONSTRUCTION [DEIS Section 16]
32. Page 16-9 - Section 16.3.2.2. and Appendix F, Appendix G (Construction Traffic Analysis):
The Applicant has provided an analysis for a worst-case condition at months 20-21 where up
to 180 workers will arrive to the site between 6:00 and 7:00 A.M. and leave between 3:30
and 4:30 P.M. To develop the 6:00 to 7:00 existing baseline volumes, the Applicant reduced
the 7:00 to 8:00 A.M. traffic volumes from their counts by 50 percent. This was based on the
latest New York State Department of Transportation (NYSDOT) data from September, 2009
for King Street. As noted above in Comment 2, once the ATR data is received it will reviewed
to determine if the 50 percent reduction is appropriate. If it is, the construction analysis is
reasonably acceptable.
If you have questions or would like to discuss our comments, please contact us.
Michael A. Galante Steven T. Cipolla, EIT
Managing Principal Senior Associate/Transportation
Marilyn Timpone-Mohamed, AICP, RLA Sarah L. Brown
Senior Associate/Planning/Environmental Senior Associate/Planning
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Cc: Christopher Bradbury, Village Administrator
Michal Nowak, Superintendent of Public Works/Village Engineer
Jennifer L. Gray, Esq., Village Attorney
Peter Feroe, AICP, for the Applicant
Mark Miller. Esq., for the Applicant
James Ryan, RLA, for the Applicant
J:\DOCS2\500\RyeBrook\900KingStSeniorHousingSEQRA2018\DEISReviews\DEISSubstantiveReview\538.693.900KingSt.SeniorHousingDEISSubstantiveReview.docx