October 6, 2004
Mr. William Mazzuca and The Town Board
Town of Philipstown
238 Main Street
Cold Spring, NY 10516
RE: Proposed Philipstown Comprehensive Plan
Dear Supervisor Mazzuca and Fellow Board Members:
The Planning Board has started its review of the proposed Comprehensive Plan and would like to submit these initial comments for your consideration. The Planning Board intends to continue its review and may refine these comments as that occurs.
The Plan is very well written and the Planning Board commends the Comprehensive Plan Committee and its advisors in the preparation of a thoughtful document.
Because the Planning Board believes that the Comprehensive Plan is an important template for setting forth policies for the future of our town, we request the Town Board’s indulgence in extending the public hearing.
The Planning Board has not been able to complete its review of the Comprehensive Plan but has spent several hours discussing its contents. In this regard we would request that you hold the public hearing open for future comment or at a minimum keep the written comments period open for an additional period of time so that the Planning Board and others may provide further input.
Also, as a Type 1 action, the New York State Environmental Quality Review Act must be complied with before adoption of the Plan
In general, the Planning Board believes that certain statements and goals of the plan would be better presented as areas that require further study, as opposed to defined specific goals.
For example, the Plan talks about Perks Plaza as a targeted area for a pedestrian friendly, mixed-use project. The Planning Board believes that a better stated goal would be for the town to study the potential for such an action occurring at Perks Plaza. In order to make good judgments about this kind of goal, it would be useful for the town to have additional information including the ownership and size of tax parcels in the Perks Plaza area, their proximity to Clove Creek, traffic access and circulation data, size and use of existing buildings, and perhaps even some economic information regarding the conditions and operation of the existing Plaza. This would put into perspective the actions needed to bring about an investment in the area relative to density, uses and feasibility. Without such information, the goal of a mixed use center at this or any other location is highly speculative and difficult and may be unlikely to be realized.
The background section of the plan that discusses housing offers a statement relative to future development projects that troubles the Planning Board. It specifically states that “concentrating residents in large enclaves of the same housing type and affordability will threaten Philipstown’s authenticity.” It goes on to suggest that multi-family housing for seniors and the general population should be distributed throughout the Town in small groups, and that senior housing should be located adjacent to hamlet centers where residents would be close to amenities and public transportation.
The Planning Board felt strongly that this language needed to be taken out of the Philipstown Comprehensive Plan for a variety of reasons.
1. The term authenticity is undefined and vague. What does this mean?
2. The Town of Philipstown at the present time makes no provisions whatsoever for multi-family housing or for seniors. The Planning Board believes that the Comprehensive Plan needs to do a better job at addressing this critical issue and is surprised that the Plan does not directly acknowledge the PIP site as a targeted site for seniors and affordable housing (especially after the many years of study that the town has invested in this possibility).
3. It will be difficult if not impossible to develop multi-family senior housing in small groups to be distributed throughout the Town because of infrastructure limitations on water and sewer. Frankly, the Planning Board does not believe that there is much likelihood that this would ever happen.
4. Aside from Garrison Landing and the two Village’s, there really are no hamlet centers in the town. Garrison Landing is not viewed as a location that can support much in the way of multi-family housing. Perks Plaza needs further study. Thus, the plan is unclear as to the town’s strategies for accommodating multi-family and senior housing. The Planning Board does not believe it to be prudent to await some future hamlet center before addressing the needs for multifamily or senior housing.
5. The language in this section seems to go directly in opposition to the Town Board's multi-year study and planning of potential senior housing at the Quarry Pond site. Language of this nature in a comprehensive plan will make it difficult if not impossible to implement the proposed Quarry Pond PDD.
The Planning Board suggests that the Comprehensive Plan should focus on greater incentives for existing businesses along Route 9 to upgrade their properties, develop better landscaping and improve asthetics. This is a matter that needs more study, including the potential pursuit of grants and other monies or tax incentives for a set period of time that would allow for beautification to occur.
The Planning Board supports the Goal to conserve Philipstown’s rural, historic and river community character. Item A(i) in this section discusses incentives for voluntary density reductions. The Planning Board does not know what exactly this means and where it would be applicable.
Generally speaking, the Planning Board does not believe that development density is an issue in the Town of Philipstown given its current zoning designations and topographic conditions. The vast majority of lands in the Town of Philipstown are two acre zoning or greater, and because of open development regulations, the typical lot size is six acres or greater. Voluntary density reduction is unrealistic and would only result in higher costs of housing in the Town of Philipstown.
The second goal in this section suggests that the Town should encourage open space development, also known as clustering or conservation development. The Planning Board does not believe that this goal should be in the Comprehensive Plan. There are very few circumstances in the Town of Philipstown where clustering or conservation development makes sense. Again, this in large part is due to the topographic conditions in the Town infrastructure constraints and the open development regulations.
The tools are already in place under New York State Town Law, for the Planning Board to pursue a cluster development, if it makes sense to do so. In such an event, the Planning Board could request authorization from the Town Board for clustering which could be done by local law. That tool is available to the Town at the present time; however, the Planning Board does not believe that the encouragement of open space development given the circumstances surrounding the Town of Philipstown has sufficient merit to include it as a goal in the Comprehensive Plan.
Goal 1, Item b)(i) discusses dirt roads. The Planning Board suggests that the language of this goal be changed to read: Preserve the character of designated dirt roads. Establish a dirt road master plan. Study the establishment of a dirt road district that would accommodate the upkeep and maintenance of dirt roads by those being served by the dirt road. Designate roads to remain unpaved and preserve their character.
With regard to goal number c) the Planning Board suggests a third goal here, to establish strict landscaping guidelines and incorporate them into the zoning law.
Goal number 2 is directed towards maintaining and enhancing the socioeconomic diversity of Philipstown’s population. Goal (a)(i) suggests that accessory housing should be allowed by right. The Planning Board believes that this goal could be dangerous and could have a large impact on the Town’s population and its schools if implemented without further study. The Planning Board believes that accessory housing by special permit would provide better oversight and allow the town to better monitor its growth. Some Planning Board members felt that allowing accessory housing by right or by special permit on ODA roads could be a problem. Others did not feel that way.
Item (a)(iii) suggests that the Town should encourage multi-family housing located in or next to mixed used centers. Again, the Town does not have any mixed-use centers nor is it likely that a mixed-use center would come about in any foreseeable future. This, in essence, restricts opportunities to develop multi-family housing.
Regarding Item (a)(v) the Planning Board suggests that this be rewritten to simply say; Encourage senior housing.
Regarding Goal 2(b), the Planning Board suggests this be rewritten to say; Promote senior housing including senior housing that addresses local and regional income levels and needs.
At the end of this item the Planning Board suggests a sentence that says; Consider Planned Development Districts or other zoning mechanisms to support senior housing in instances that would support the overall goals of the Comprehensive Plan and the Philipstown community.
The aforementioned represents the Planning Board’s preliminary comments on the Comprehensive Plan. We are certain that we will have further comments to assist the Town in shaping the plan in the best interest of the community.
Again, we request that you keep the public hearing open or continue to accept comments until after the SEQRA process is completed.
Thank you for your consideration.
Philipstown Planning Board
c: Planning Board