Environmental Impact Study for Yorktown’s Underhill Farm Proposal is Flawed

By Trish Sullivan-Rothberg

The 180-page Underhill Farm Full Environmental Assessment Form (EAF) submitted to the Planning Board is inadequate, incomplete and unacceptable.

• It fails to meet the basic requirements of the State Environmental Quality Review Act (SEQRA).
• It ignores potential impacts the Planning Board specifically asked the developer to address.
• It relies on self-serving statements without any supporting documentation.
• It includes numerous misrepresentations of facts.

The Planning Board has no choice. It must reject the document and send Unicorn Contracting, the developer, back to the drawing board.

When the Planning Board reviews a development proposal, SEQRA requires the developer to identify and discuss ALL the development’s potential adverse environmental impacts. And, after reviewing those impacts, the Planning Board is required to determine their potential magnitude, aka, their level of significance.

While some impacts may be minor and can be satisfactorily mitigated, such as the impact on air quality, others, including changes to neighborhood character, are significant – and permanent – and can’t be satisfactorily mitigated. When that happens, the Planning Board has two options:

• It can require the developer to modify the plan in order to lessen or eliminate the significant adverse impact, or
• It can reject the development plan in its entirety.

The list of Underhill Farm’s potential significant adverse environmental impacts is long – very long. And the developer’s full EAF either fails to address or misrepresents many of those impacts. Here are just some of those failures.

Impact on neighborhood character

The full EAF fails to analyze how a high-density development of 148 dwelling units and 17,750 square feet of commercial space will dramatically change the character of the existing residential neighborhood of single-family homes and condominium developments at much lower densities.

There’s no discussion of the adverse environmental impacts on the residential neighborhood of commercial truck traffic, outdoor lighting, odor from restaurants, signage and noise.

The EAF’s photos fail to illustrate the plan’s overall visual impact on the neighborhood, from Route 118, Underhill Avenue or Glenrock Street, or how the 40-foot-tall commercial building will not overpower the abutting historic main house.

Impact on site’s history

The EAF fails to address many unresolved historic, archeological, architectural and landscape issues raised by the town’s Heritage Preservation Commission.

The development plan is still vague about the future use(s) of the historic main house. As long as the plan for the building keeps changing, it’s impossible to evaluate potential adverse impacts.

Impact on traffic

The EAF fails to explain how the proposed $1 million of improvements to the Route 118-Underhill Avenue intersection will be paid for and whether the state Department of Transportation has even approved the developer’s improvement plan.

The EAF fails to consider the adverse impact of diverting Underhill Farm traffic onto the Beaver Ridge site and whether the existing Beaver Ridge driveway can safely accommodate an increase in two-way traffic.

Impact on trees

The EAF fails to address the long-term adverse impacts on the site’s biodiversity, wildlife habitat, climate and noise control, as well as visual aesthetics resulting from cutting down 523 trees – 74 percent of the site’s 703 trees – and eliminating more than five acres of woodlands.

Impact on demographics

The EAF fails to use current Census data when projecting increases in overall population and school children, a point made during the Planning Board’s June 2022 public informational hearing.

Impact on parking

The EAF fails to adequately project parking needs for the site’s multiple uses and totally ignores parking needs for some uses, such as a proposed conference center in the main house and the offices of the Parks & Recreation Department on the second floor of the proposed senior citizens center. Eight visitor parking spaces for 148 dwelling units and a public park is woefully inadequate.

Impact on recreation

The EAF’s plan to create a public park on a portion of the site in order to satisfy the town’s $592,000 recreation fee requirement fails to document a community need for another park in the Heights hamlet, especially when the town needs the money from the fee to finance needed upgrades to existing parks and aging recreational facilities.

Impact on housing

The EAF totally ignores the Planning Board’s directive to address the town’s housing needs for different age groups, e.g., seniors as well as young families, an issue that was raised during last June’s hearing.

Missing alternative plans

Among the document’s most significant omissions is its failure to discuss any meaningful alternative development plans that would lessen or eliminate some of the significant adverse environmental impacts, such as reducing the number of housing units, keeping more of the site’s historic features or eliminating commercial development in a residential neighborhood.

As has been clearly demonstrated, the Planning Board must reject the 180-page full EAF and send the developer, Unicorn Contracting, back to the drawing board.

Trish Sullivan-Rothberg wrote this article on behalf of Protecting Yorktown’s Quality of Life Foundation, Inc., a New York nonprofit corporation comprised of Yorktown residents committed to protecting and preserving the town’s neighborhoods and community for current and future generations.