HomeMy WebLinkAboutWritten statement Woodworth - March 16, 2017Over 2 years ago, I wrote a petition that raised objections to the breadth of David Hall's
proposed rezoning for PDZIO. In that document, I also expressed general agreement with the
concept of an autism clinic.
Because of previous experiences, I am well aware that the accuracy, consistency, and clarity of
the documentation is extremely important. When PDZ10 was initially approved, I attended
many meetings and listened to what was said. But I didn't actually read the documents. That
was a big mistake. The verbal proposal suggested there could be a small number of employees
(about 10, as I recall). But the actual law was quite broad and, according to data submitted to the
town by the previous owner, the number of employees grew to 70. The impact of that size
operation was much more significant. I am aware that such a high level of employment was not
sustainable at that location and that the number of employees decreased after some work was
out -sourced to Lithuania.
So now I read the actual documents. And I firmly believe that no special permit should be
approved unless the documentation is clear, accurate, and consistent. This is especially
important because a special permit applies to the property not one specific owner. When sold to
a new owner, the special permit still applies. With inaccurate, unclear, and inconsistent
documentation, a new owner could interpret the possibilities in unexpected and damaging ways.
I have several issues with the current documentation,
1. Site plan page 1, paragraph 3:
Presumably from an external source, the document states the following: "Applied Behavioural
Analysis (ABA) programs which are recommended at 25 hours per client per week"
The next sentence states that for this proposed clinic, "Individualized programs will include a
minimum of 6 hours per week and a maximum of 25 hours per week."
In Paragraph 4 another specification for this clinic states:
"Social skills classes will run up to 4 times per week..."
I couldn't understand the connection between the external recommendation of 25 hours per
client per week and the specifications for this proposed clinic (unless the individual hours and
the social hours combined would be 25 hours per week - eg. 6 individual hours would be
combined with 19 social hours.)
2. Site plan page 1, paragraph 3.
Capacity at "...25 clients per week and 15 staff per week..." In previous meetings, David Hall
said that 10 clients were likely while 25 clients were a maximun (but unlikely). It would be
useful to have data on both options throughout the document.
3. Site plan page 1, paragraph 4:
"The most active hours of operation will be between 9:OOam and 6:OOpm." But all hours of
operation are not specified. (Note: Part 1 of the SEQR form does list hours as 8:OOam to 8:00
pm Monday - Friday plus occasionally hours on Saturday and Sunday from 10:00am to 5:OOpm.)
Identifying the most active hours does not automatically mean there will be a constant
distribution within those hours. For example, if some clients attend school and their parents do
not want them to miss school, there could be more clients between 2:00pm and 6:00pm than at
other times during the day. This would impact traffic.
4. Site plan page 2, APPENDIX I
"...this proposal seeks to create a clinic ... under the Hospital designation..."
I believe that the consensus of the planning board at the last meeting was that the Hospital
designation is not appropriate. So the designation would be "Other uses not specifically listed
above but deemed by the Planning Board to be similar in nature and compatible with the
purposes of the zone."
5. Site plan page 4, paragraph 1 and 2 and Water Usage report from, John M. Andersson
"You anticipate a staff of 10 with 15 of 25 clients on site at any one time."
On page 1 of the Site Plan, a staff of 15 is specified for 25 clients.
In addition, the data does not include parents who will likely wait for their children at the clinic.
From the report and repeated in the site plan:
"The 2010 report stated that there were no known yield problems..." for the previous operation.
This completely omits the well problems that have been repeatedly stated at several meetings by
2 neighbors.
1 assume the Planning Board does not intend for the documentation to gloss over that fact.
(i.e. codify the position that the impact on neighbors is not relevant.)
6. Site plan page 4, Section IN:
Two objectives (CM & C3.2) from the Town of Danby Comprehensive Plan are cited but
Objective C3.3 is not cited. Objective C3.3: "Restrict traffic -generating business development in
Danby to the areas of the Central and West Danby hamlets..."
This proposal is not consistent with objective C3.3.
7. Site plan page 5, Traffic and separate Traffic Study by SRF Assoc and Partl SEQR question j
on page 7
Question j: "Will the proposed action result in a substantial incrase in traffic above current levels
The report uses data from a NYS DOT study from 2010 (7 years ago). The DOT study lists the
test site as .2 miles east of 96B on Gunderman Rd. Actually there is no Gunderman Rd. east of
96B. Gunderman Rd. only exists west of 96B. I called the DOT office and the raw data
included the actual GPS location. Google maps shows that location to be about .2 miles east of
Comfort Rd. The proposed site for the clinic is west of Comfort Rd.
In any case, the traffic study does not remotely represent the current level of traffic.
The report states "Historical data provided by the sppiicant stated that a maximum of 90
employee commutted to and from the site during the AM and PM peak hours with a small
number of visitor trips (approximately 10 per day) and deliveries (approxiazntely 10 per day)"
In response to a request from the town, the previous owner said the maximum number of
employees was 70. He was never asked about visitors and deliveries. The input data to the
report is unsubstantianted. In addition there is no indication when the maximun level occurred
but it was reached and then declined over 10 years ago.
The current level of traffic due to the Angleheart Designs clothing business is zero.
The report says the current proposal "...is expeted to generate 20 fewer vehicles during the AM
hours and fewer than 23 vehicles during the PM hours"
That conclusion is based on unsubstantiated and very old input date.
This proposal will increase traffic not decreae traffic over the current levels.
The site plan also states that "most coming and going will occur during typical business hours
when neighborhood residents will themselves be traveling to and from work."
This is seriously flawed. Some residents of Danby are retired, some have home businesses,
some telecommute (full or part time), some work part-time, some are stay-at-home parents, some
have more flexible schedules (ex. 4 days per week and 10 hours per day), etc. Travel times for
many residents are not your typical AM and PM commute times. In addition, there is no
indication about the percent of sessions that will need to be scheduled for after school hours.
Summary:
I believe that all these issues can be easily and accurately addressed. Only then will it be
reasonable to determine if the proposed autism clinic would be appropriate for 303 Gunderman
Rd.
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