Letter to Planning Board Chairman Richard Brownell
March 5, 2012
From: William R. Spade, Architect
C. Keiko Sasaki-Spade, Architect
Wallace Toscano, Architect
Mr. Richard Brownell, Chairman
Town of New Castle Planning Board
200 South Greeley Avenue
Chappaqua, NY 10514
Re: Hunts Lane Affordable Housing Development Proposal
Dear Chairman Brownell and Members of the Planning Board:
We are professionals that have collectively practiced architecture and planning in this Town for over 70 years. We care deeply about the character of this Town, and through our work, strive to create a harmonious and enriching environment for all who reside or work in this Town.
While we strongly support the effort to bring affordable housing to New Castle, we are dismayed by the proposal for the massive and banal 5-story affordable housing project on the Olivier property on Hunts Lane. We believe strongly that this proposal is an inappropriate location for any type of housing, that it is far out of scale and character with this community, and that it contradicts the very core of the planning concepts on which the character of this Town has been built. In order to protect this character for present and future generations, we feel that we must speak out loudly and clearly about the failings of this proposal, and to volunteer our assistance with helping the Town to identify more responsible and appropriate locations for the much-needed affordable housing.
It is important to bear in mind that we as a Town are making the decisions about where we will locate the affordable housing that will eventually be located in our community. This will first and foremost be our decision, not the decision of a private landowner or developer. As such, we should cherish the opportunity to do it the right way, as these will be our new neighbors, and we should care about their welfare as deeply as anyone else in our community.
Additionally, we are concerned that a single affordable housing building is not an appropriate response to this need. By congregating all of the affordable units into a single building, the potential will exist that residents will be stigmatized. We have seen this with the small collection of affordable units that already exist in Town. It would be much better to create housing that mixes market-rate and affordable housing, so that the affordable units are indistinguishable from the market-rate units. This is the crux of the 80-20 programs in many municipalities, and would be the better solution for our need.
Following is our detailed list of the reasons why we believe that you should reject this proposal, and encourage the Town Board to make the long-overdue concerted effort to identify other locations and solutions for affordable housing.
Inappropriate Location for Housing, especially Affordable Housing
First and foremost, this property is not appropriate for any type of housing. It is sandwiched between a highway, a railroad and a highway bridge, with extremely limited access. Any residents located in such a facility would be hugely and negatively impacted by the many environmental deficiencies that are present. These include noise, traffic, air, lack of open space, and restricted access to other residential parts of the community. There are also below grade environmental contamination issues still present on the site, on a property that is in a flood plain, and a lack of sufficient parking. It is especially important to consider that there would be children living in such a facility. With these types of environmental impacts on such a property, what manner of home life would these residents, and particularly the children, face?
When this property was previously presented to the Town for market-rate housing (in 2006) with the same 5-story, fully developed site, and then subsequently withdrawn, the Town Planning Consultant’s review from that time identified some of the many deficiencies of the site and proposal. Their comments included the following concerns:
• Road network: “not particularly pedestrian-friendly”;
• Surrounding traffic conditions: “already experiencing problematical conditions”;
• Proximity to Quaker Street, the Saw Mill Parkway and Metro-North Railroad: “poses serious land use and site planning challenges” and “noise impacts could be of potential concern to prospective residents”;
• Development density: “the scale of the proposed development is too large for the subject site…”
If by withdrawing the application, the developer was acknowledging that the property was inappropriate for market-rate housing, no twist of logic should enable thoughtful and caring people to conclude that it would be appropriate for affordable housing. Our new neighbor residents in affordable housing should be entitled to the same level of protections and quality environment that we would expect for a market-rate housing.
It appears to us that the only justification for considering an affordable housing project in this location is that the conclusion has been made that people in this income category will be desperate enough to live in this community that they would be willing to accept this substandard environment, lacking many of the qualities of housing that are provided to all other residents of this community. That is a shameful and inappropriate conclusion. Since we are making the determination as to where this type of use should be located, we should hold the same standards for this housing as we hold for any other.
Out of Scale with the Community and the Zoning on the Property
This 5-story building (at nearly 60 feet tall, it is effectively 6 stories if its roofline is considered) is also massively out of scale with the rest of the downtown fabric, and would stick out like the literal sore thumb.
From all approaches to the downtown area - whether Quaker Street, King Street, or either direction on the Saw Mill Parkway - this building will be by-far the most prominent structure in Town. It would be at least 2 stories taller than the next tallest building in the downtown area. Presently, the tallest building is the elegant 3-story tudor-style building at the end of Allen Place on the east side of the railroad tracks. The proposed building would dwarf this and every other building. We believe that this would be a huge mistake and would permanently mar the 300+ year historic character of the Town.
On top of this, we are befuddled by the fact that the material submitted by the developer seems to indicate that that they believe that they are already entitled to the proposed 5-story structure. As the property is in the I-G zone, which has a height limit of 2 stories / 30 feet and setback requirements of 8 feet to 25 feet, and there does not appear to have been any action by the Town to change the zoning on the property, or to alter the bulk controls for an affordable housing proposal in this zone. How, therefore, is the developer able to claim that the project is already permitted by the present zoning, and does not require a zoning review or variance by the ZBA? Has the Town already provided a mechanism for the developer to achieve this bulk without providing for a thorough environmental review of this change?
In addition, there is also not adequate parking provided in the proposal, in specific contradiction to the I-G zoning and the Workforce Housing zoning.
We should also keep clearly in mind that the property owner and developer are motivated by their own self-interests to see the largest possible development happen on this property, and clearly do not have in mind the long-term interests of this community, or the people who would reside in this building. The property owner purchased the property subject to the existing zoning restrictions, and as such does not have the right to build anything beyond a 2-story building set back appropriate distances from the property line.
New Castle Comprehensive Plan and Zoning Code Standards
As this proposal is at substantial variance to the uses and zoning that are in place on this property, as well as the Town’s Comprehensive Plan, the proposal contradicts in many ways the very core standards that have been used in this community to develop appropriate, beneficial and healthy uses of land. These are contained in the overall planning goals that have been established by the Town Comprehensive Plan, as stated in the Zoning Code:
Ҥ 60-100. Purposes of chapter:
A. This chapter has been prepared and enacted for the purpose of promoting the health, safety, morals and the general welfare of the Town of New of Castle and is in accordance with a carefully studied and considered Comprehensive Plan intended to guide the future growth and development of the Town of New Castle in such a way as to encourage the most beneficial and appropriate relationships among land uses and, more particularly, to accomplish the following specific purposes:
(1) To lessen congestion in the streets.
(2) To secure safety from fire, flood, panic and other dangers.
(3) To promote health and the general welfare.
(4) To provide adequate light and air.
(5) To provide for the use of solar energy.
(6) To prevent the overcrowding of land.
(7) To avoid undue concentration of population.
(8) To facilitate the adequate provision of transportation, water, sewerage, schools, parks and other public requirements.
B. In preparing and enacting this chapter, reasonable consideration has been given to the character of each district and its peculiar suitability for particular uses, with a view to conserving the value of buildings and encouraging the most appropriate use of land throughout the Town of New Castle.”
It is our strong belief that the proposed project contradicts most of these purposes, rendering it inappropriate according to these standards. These are:
(1) Congestion in the streets:
The location of the proposed project, at the intersection of Hunts Lane and the off-ramp of the Saw Mill Parkway, is already over-taxed with traffic congestion at certain times of the day. The road configuration at this point, with the narrow 2-lane roads and the traffic light at the intersection of Rt. 120 & Hunts Lane, creates long delays for vehicles trying to pass through that intersection to and from Hunts Lane. This includes vehicles entering and exiting the Parkway, as well as vehicles for the businesses on Hunts Lane, including the Bus Company, World Cup and the Town DPW yard and Recycling Center. Locating a 36-unit residential facility in this already over-crowded street network will worsen these conditions, and would be an unconscionable additional burden to these businesses and the residents of such a facility. Locating a residential facility here would require accommodation of bus pick-up & drop-off for school-age children, as well as trip generation for vehicles. Adding this traffic load to already congested streets is inappropriate.
(2) Safety from fire, flood, panic & other dangers:
The proposed structure covers almost the entire site with on-grade parking and 4 levels of housing above. There is therefore no access around the building for fire-fighting purposes, and particularly from the railroad side. What if there were a fire on that side of the building - how would it be addressed? What if there was an accident on the railroad tracks - how would that affect this property, with children living inside? This proposal cannot be adequately served from a fire safety perspective.
(3) Promote health and the general welfare:
The location of this building between a highway, a railroad and a highway bridge, will bring negative health effects to any residents, including long-term exposure to higher carbon monoxide levels from the constant traffic. In urban environments, this has shown to lead to greater instances of asthma, particularly in children. As there is no convenient outdoor recreation or play space, residents and children will either go without, or will have to negotiate highly trafficked streets to get to play space. This location does not adequately promote health and general welfare.
(4) Provide for adequate light and air:
As stated above, the air environment around this building will be a health hazard, and with no outdoor spaces, residents will not be able to enjoy adequate natural light and air. Without adequate amenities for light and air, residents will be forced to spend inordinate amounts of time indoors.
(5) To provide for the use of solar energy:
There does not appear to be a solar energy component to this proposal;
(6) To prevent the overcrowding of land:
As the proposal is to build-out the property from edge to edge, and far in excess if the zoning limits, this is an extreme example of overcrowding the land.
(7) To avoid undue concentration of population:
As stated above, this proposal over-develops this parcel, resulting in an unhealthy and undue concentration of population on this small lot;
(8) To facilitate the adequate provision of transportation, water, sewerage, schools, parks and other public requirements:
This location will not provide for adequate private transportation needs, and due to the pedestrian unfriendly surrounding road network, will result in resident’s being isolated from other public amenities.
In summary, we believe that this proposal for affordable housing is highly inappropriate for this location, is excessively out of scale with the character of the community, and does not comply with the planning goals that have been employed in this Town. We ask your Board to reject this proposal and request that the Town Board immediately embark on a process to identify more suitable locations for affordable housing.
With regard to more suitable locations for affordable housing, we believe that there are several sites that comply with the Workforce Housing and AFFH guidelines that should be investigated further. These sites may require that we re-order our priorities in terms of land-use in the downtown area, but they would ultimately result in a far more appropriate solution for housing. This should include consideration of mixed-use developments that provide for affordable housing mixed in with market-rate housing, such that there is no stigma attached to someone living in the “affordable” building.
We believe that with courageous leadership, and through full participation by a variety of stakeholders, more appropriate locations for affordable housing can be identified. This would enable our future new neighbors to enjoy all of the qualities and benefits of this community in equal proportion to those that are available to all other residents. It is critical that we not make the mistake of creating affordable housing that is any less equal.
William R. Spade, Architect
C. Keiko Sasaki-Spade, Architect
Wallace Toscano, Architect
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