Citizens Request Positive Declaration in SEQR for the proposed Irish Cultural Center of HV
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To the City of Kingston Planning Department and Planning Board,
Although we feel a cultural center to celebrate Irish history and culture is a great idea, we believe that the current proposal as submitted to the City of Kingston, NY, for the Irish Cultural Center of the Hudson Valley (ICCHV) at 32 Abeel Street would cause major adverse impacts on the Rondout neighborhood.
On October 5th, 2016, a public hearing will occur at 6:00pm at Kingston City Hall located at 420 Broadway in Kingston (Council Chambers) where the public will be given the opportunity to have a voice on whether a positive or negative declaration under SEQRA (State Environmental Quality Review Act) is issued by the Kingston Planning Board, which is acting as the Lead Agency for conducting the environmental review of the current ICCHV proposal. A determination is expected to be made at the following Planning Board meeting on October 17th, 2016.
A SEQR Determination can be done in one of two ways: the Planning Board must decide whether the proposed ICCHV project may cause one or more significant adverse impacts on the environment or whether the project will not have a significant impact on the environment:
* POSITIVE DECLARATION: When an action is determined to have potentially significant adverse environmental impacts, the Planning Board can require the applicant to prepare an Environmental Impact Statement (EIS), which will also make the public’s input an important part of the process along with examining viable alternatives to the project as currently proposed.
* NEGATIVE DECLARATION: When the Planning Board determines that the project will not result in any significant adverse environmental impacts.
Because the ICCHV proposal could cause major adverse impacts on the Rondout neighborhood as it currently stands for a whole host of reasons, we urge the Kingston Planning Board to declare a Positive Declaration for this SEQRA Action for the following reasons:
1. SCALE OF PROJECT IN A HISTORIC LANDMARK DISTRICT: According to Policy 1D of the Local Water Revitalization Program (LWRP), it states that "new construction shall be compatible with the established character of existing development in the district." Given the new structure's modern and voluminous design to be located in the center of the Rondout-West Strand Historic district, a National Register of Historic Places site since 1979, additional studies are required that may lead to adjustments in the project’s design and scale so that it can be more consistent with the area’s historic character and will not detract from the neighborhood's historic charm.
ADDITIONAL READING: Local Water Revitalization Program Document (LWRP) VIEW Document
2. ZONING: According to section 405-19(B)(1) of the City Code, only buildings which have “direct frontage” on the West Strand can be used for certain enumerated purposes. 32 Abeel Street does not, according to the ICCHV’s survey maps or the property's deed, have direct frontage on West Strand. Most, if not all, of the Center’s proposed high-intensity commercial uses are not included in the uses permitted by right of this City of Kingston zoning code for this RT Rondout District. The Zoning Board of Appeals is determining whether a decision by the Zoning Enforcement Officer that the frontage on Company Hill Path constitutes frontage of a West Strand sub area, and, consequently, if the uses are allowed. This must be furthered studied in the EIS so that the Planning Board can be assured that it is properly following the Zoning Law.
ADDITIONAL READING: City of Kingston Zoning Codes VIEW
3. PARKING AND TRAFFIC: The Center's proposed scale and multiple high-intensity commercial uses have created an occupancy capacity in great excess of its parking proposal.
The project as currently proposed will provide for 18 parking spaces where the City requires at least 57 spaces. This is woefully inadequate and is less than one-third of what is required by the Zoning Law.
Severely inadequate parking alone would impose multiple and profound adverse impacts upon the neighborhood, community and environment, and would bring to residents, businesses, and visitors an increased parking burden in already-constrained parking areas, as well as noise, incompatible operating hours, traffic, light pollution, and increased demand on municipal services without equalization in this location in the center of the Rondout-West Strand Historic district.
This proposal could amount to a substantial new demand for parking in an area that is already acknowledged in official City planning documents as lacking in parking supply. Furthermore, the ability of the project to accommodate parking must be demonstrated in the Planning Board's SEQR review process and findings with regard to the approvability of the Site Plans in order to take a hard look at the environmental impacts of traffic on the neighborhood and City.
The traffic narrative needs to be properly scoped, undertaken by the applicant’s traffic professional, and then verified by the City’s own traffic professionals in order to support the Planning Board's "hard look" requirement. This can only be cured by a fully developed traffic and parking study prepared by a traffic and parking professional and included in an EIS.
ADDITIONAL READING: See City of Kingston Zoning Codes for Parking requirements at Section 405-34(J)(2) VIEW
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