THE FOLLOWING IS THE REPORT OF PLANNING CONSULTANT EDWARD BUROUGHS WHICH WAS CRITICAL OF THE JANUARY 2000 VERSION ON THE PROPOSED COMPREHENSIVE MASTER PLAN

As requested, I have reviewed the report submitted to the Town Board titled "Town of Carmel Comprehensive Plan," dated January 2000, prepared by Buckhurst Fish & Jacquemart, Inc.

I have reviewed this document in the context of the Agreement between the Town of Carmel and Buckhurst Fish & Jacquemart, Inc. (approved by resolution of the Town board dated April 7, 1999), the Town's "Request for proposals to Develop the Croton Plan and the Town's Comprehensive Plan and Zoning Ordinance" (dated September 10, 1998), the discussions held at meetings with the consultant and the description of "Town Comprehensive Plan" sot forth in New York State Town Law.

In summary, it is my Finding that significant work remains to be performed by the consultant in order for the Town to have before it for its consideration a comprehensive plan that meets the scope of the Agreement and Town Law and that complies with the objectives of the overall Croton planning program.  It is my understanding that this January document is a “draft” document and that several tasks of the scope of work have not yet been completed.  Such assumptions make the purpose of the document even more puzzling- It is a misnomer to title it a "comprehensive plan" at this time.

My specific comments follow:

1. Lack of Croton Planning context. The document does not make reference to the Croton Planning process and the preparation of the Croton Plan This is unacceptable for three major reasons:

• The City of' New York is providing funding for most of this project It is not a slight to the Town that this funding be acknowledged, particularly when the history behind this funding is identified.
  

• The consultant is required to produce data focused on the Town of Carmel for the Putnarn Croton Watershed-wide "Croton Plan." There has always been the reasonable expectation that this data would be used as, part of the Town Comprehensive Plan. There is no reference to this Work effort in the current text.  The Croton Plan effort and the results must be fully integrated.
   

• New land use and zoning proposals, in the final Town Comprehensive Plan would presumably be based, at least it,. part, on the analysis prepared for the Town of Carmel as part of the Croton

Review of "Town of Carmel Comprehensive Plan (January 22, 2000)

February 22, 2000

Page 2

plan.  The Comprehensive Plan needs to reflect and fully discuss this "influence." This is critical if for no other reason than if the Plan's eventually recommendations suggest new restrictions on land use, tile tie-in to the Croton Plan will provide increased justification and legal defense.

 2.      Bulk of text is Inconclusive data reporting.  With few exceptions (namely tile "transportation" chapter and the final three pages) the draft Plan is a report on data.  There is no analysis of what the data presented means for the current state and future options of the Town. There is no projection or estimation of trends that may be revealed by the data.  Frankly, as now complied, this data is not very useful or informative. Listed below are some examples of the inadequacy of the text:

• Section 2 on history is interesting but it stops at 1900 on page 6 with unsupported generalizations.  A discussion of the Carmel and Mahopac hamlets over time would be useful.  When did commercial development move out along Route 6? Doesn't the town have a few large shopping centers?  When did they open?  What is the nature of this development - local or wider market area?  Page 11 of the Draft Plan states that the Town has experienced "over 400 acres of commercial development since 1968." On the surface of the page 6 discussion, this "fact" is an obvious inconsistency.  What is the real story that can help the Town define its role and plan for the future?
  

• The Section 3 discussion of population provides no sense of what has happened over time in the Town.  How do the population characteristics relate to building permits (by type) issued over time? How does they relate to household size?  One key indicator - population age and how it changes over time – is missing? This must be discussed if the Town is to understand school population, senior needs and recreation trends.
  

• There is no discussion of "type of housing" (e.g. single4farnily, two-family, multifamily, seasonal).  This type of data is needed in order to allow the Plan to have a basis for recommending provisions for future housing types and for ii1suring provision of a diversity of housing types.
  

• In Section 4 there is major problem with the land use discussion and the data that it is based on.  The classifications used provide no perspective on the true amount or the location of "undeveloped" and potentially developable land.  (The "forest category is basically meaningless for land use planning.) Without this data, there is no basis for projecting future development trends including population, school needs, traffic, sewer and water. (The Draft Plan does not include any such projections although it should.) Even basic, easily available land data from tax records is not included, such as the amount of acreage owned by tile City of New York, the amount of acreage that can be considered permanent open space, the amount of acreage that is owned by the Town and School Districts.
  

• The 15% threshold for avoiding development on slopes may be stated too definitely.  If included in the Plan, more citation and justification for this threshold is required than is now presented.  What is the source of the data shown on Figure 5.1?  Where are the State regulated wetlands?

Review of "Town of Carmel Comprehensive Plan (January 22, 2000)

February 22, 2000

Page 2

Where is a discussion of the extent of protection now provided by Town regulation on slopes and wetlands?

• Section 6 should include a map that shows the hierarchy of roads by ownership as discussed in the text.
  

• The discussion on parks and recreation on page 27 is confusing, What does this sentence mean, `85 acres in 46 parcels that have been acquired through the process are presently vacant"?  There should be a discussion of open space as distinct from recreational land. There should be a discussion of the Town's experience with cluster subdivision and open development areas.
  

• On page 26, more specific information should be provided on the County's bike trail plans and the schedule for implementation.  Such information would permit a more useful discussion of the Town's projects could link with the County's "trunkline" trail.
  

• On page 30, the library discussion should include the Mahopac Library expansion plans that have already received wide coverage in local newspapers.
  

• The sewer discussion on page 32 must be related to the Croton Plan programs and studies including the sewage diversion study.  This discussion must also relate to existing density of housing, septic problem areas and the location of undeveloped land.
  

• Where does the "Proposed Sewer District" identification come from as shown on Figure 7-1?  There is no basis for it in the Draft Plan text.
  

• The water district discussion should include a straight-forward account of recent and current controversies.

3. The Comprehensive Plan Section (8) comes out of nowhere.  There is little if any reasoning in the preceding 36 pages that leads to the bullet recommendations set forth in Section 8 on pages 37 and 39.  The recommendations are too general and poorly presented.  Worse is the lack of recommendations for at least one key parcel on Baldwin Road.  The purpose of the Plan is to provide guidance for the Town.  At a minimum, the pros and cons of alternative uses need to be presented in the context of an expanded plan text and analysis.

4. No goals and objectives presented.  The Draft Plan does not specify any goals and objectives for the Town.  It does not summarize the results of the two community workshops.  Both items must be included in the Plan for it to have utility for the Town.  A discussion of how such goals and objectives are different from those in previous plans would be useful.

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