Loading...
HomeMy WebLinkAbout01-6361THE CUSTER COMPANY Appellant V. SILVER SPRING TOWNSHIP BOARD OF SUPERVISORS Appellee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW MANDAMUS LAND USE APPEAL NOTICE OF LAND USE APPEAL Appellant, The Custer Company., hereinafter "Custer" by and through its attorneys, Caldwell & Kearns, files this Notice of Appeal from the October 12, 2001 decision of the Silver Spring Township Board of Supervisors, and in support thereof avers as follows: 1. This appeal is brought pursuant to Section 804 of the Subdivision and Land Development Ordinance of 1999 of Silver Spring Township, the Local Agency Law 2 Pa. C.S.A. §751 et. seq., and the Pennsylvania Municipal Planning Code Act 247 of 1968, as amended, specifically §53 P.S. 11003-A, et. seq., as amended. 2. The Appellant is The Custer Company, a corporation duly organized and existing in accord with the laws of the Commonwealth of Pennsylvania having a principal place of business located at 1309 Laurel Point Circle, Harrisburg, Susquehanna Township, Dauphin County, Pennsylvania 17100. 3. The Appellee is the Board of Supervisors of Silver Spring Township, a duly incorporated political subdivision having its municipal office located at 6475 Carlisle Pike, Mechanicsburg, Silver Spring Township, Cumberland County, Pennsylvania 17050-2319. 4. Pursuant to the provisions of the Pennsylvania Municipal Planning Code (hereinafter, "MPC"), the "governing body" for Silver Spring Township is its elected Board of Supervisors (hereinafter, "Governing Body"), and the said Governing Body is vested with the duties, requirements and responsibilities imposed upon it under the provisions of the said MPC. 5. In accord with its responsibilities under the MPC, the Governing Body did enact and have in effect, at all relevant times, a certain Subdivision and Land Development Ordinance of 1999. 6. One of the duties imposed upon the Governing Body pursuant to the MPC and the Silver Spring Subdivision and Land Development Ordinance 1999 (hereinafter, the "Ordinance") is to review applications for approval of subdivision land development plats or plans, and to act upon those applications in accord with the provisions and standards as set forth in the MPC. 7. Section 508(1) of the MPC provides: (1) The decision of the governing body or the planning agency shall be in writing and shall be communicated to the applicant personally or mailed to him at his last known address no later than 15 days following the decision. (2) When the application is not approved in terms as filed the decision shall specify the defects found in the application and describe the requirements which have not been met and shall, in each case, cite to the provisions of the statute or ordinance relied upon. (3) Failure of the governing body or agency to render a decision and communicate it to the applicant within the time and in the manner required herein shall be deemed an approval of the application in terms as presented unless the applicant has agreed in writing to an extension of time or change in the prescribed manner of presentation of communication of the decision, in which case, failure to meet the extended time or change in manner of presentation of communication shall have like effect. 8. Appellant, The Custer Company, is the equitable owner of certain unimproved real estate, the subject of a Preliminary Subdivision and Land Development Plan (hereinafter, the "Plan"), of approximately 31.70 acres, more or less, bearing Cumberland County Tax Parcel No. 38-07-0459-018, located at or near the intersection of Woods Drive (Township Road 585) and State Route 114 (Hogestown Road). 9. The legal owner of the unimproved real estate is the Estate of Fred Schlosser, with whom Appellant has executed an Agreement for the sale of said unimproved real estate. 10. On or about June 14, 2001, the Appellant, The Custer Company, filed a with the Governing Body the Plan seeking approval of the Appellant's Plan for the location and construction of a residential development of approximately forty-nine (49) single family dwelling homes located at or near the intersection of Woods Drive (Township Road 585) and State Route 114 (Hogestown Road). 11. In the application for approval of the Plan, Appellant requested one waiver, to wit: a waiver of the requirement to provide a minimum rear yard of seventy- five (75) feet on all reverse frontage lots. 12. The Planning Commission of the Governing Body did consider and recommend the granting of the waiver request at its regularly scheduled public meeting held on August 2, 2001. 13. On October 10, 2001, at its regularly scheduled public meeting, the Governing Body did deny the waiver request, as above cited, but did approve the Preliminary Plan not as presented but subject to numerous conditions. The written decision of the Governing Body was communicated to Appellant by letter dated October 12, 2001, a true and correct copy of which is attached hereto, marked Exhibit "A", and made a part hereof by reference thereto. 14. Previous thereto, the Governing Body, at its regularly scheduled public meeting of August 22, 2001 considered, but tabled, action on the Plan at the request of the Appellant. Following said action, the Manager of the Governing Body, on behalf of the Governing Body, communicated certain comments of the Governing Body to Applicant as contained in certain correspondence dated August 24, 2001, a true and correct copy of which is attached hereto, marked Exhibit "B", and made a part hereof by reference thereto. 15. By correspondence dated and delivered October 10, 2001, in advance of the public meeting of the same date, Appellant Custer's Engineer for the Appellant, Dawood Engineering, Inc. did communicate to the Governing Body Custer's acceptance of many of the comments contained in the comment letter of August 24, 2001, but did specifically reject, as inappropriate and/or not required by the Ordinance, certain comments to specifically include comments Nos. 10, 11, 12, 1 $, 16, 17, 18, 19, 20, and 22. A true and correct copy of said correspondence is attached hereto marked Exhibit "C" and made a part hereof by reference thereto. 16. Furthermore, in said correspondence, Appellant's Engineer did outline its alternate proposed traffic improvements addressing comments Nos. 13, 14 and 15, which were accepted by the Governing Body as set forth in condition No. 30 of its conditional approval of October 12, 2001, Exhibit "A" attached hereto, which condition is accepted by Custer. 17. Appellant Custer does not accept conditions Nos. 10, 11, 12 (which apparently has been modified by condition No. 30, which is acceptable to Applicant), 13, 16, 17, 18, 20 and 22 of the conditional approval of October 12, 2001, Exhibit "A", attached hereto, thus resulting in a disapproval of the Plan as so stated in 4 the Ordinance. With regard to each and every condition to which Appellant, The Custer Company, does not accept, as hereinbefore identified, the Governing Body has completely failed to comply with the provisions of Section 508 of the MPC and the Ordinance requiring, in each instance, why such conditions do not fulfill the requirements of the Ordinance, and citing, for each and every condition which Appellant Custer does not accept, the provisions of the Ordinance relied upon by the Governing Body. 18. Furthermore, it is reasonably believed and averred by Appellant that, prior to a vote on the waiver request hereinbefore briefly identified, the waiver was denied on the basis of the failure of the Applicant to address a concern of the Board relative to providing a second accessway on the Plan, although not required by the Ordinance, and presumably, therefore, not on the merits of the waiver request. 19. Appellant, The Custer Company, believes, and therefor avers, that, in view of the failure of the Governing Body to communicate its decision in a manner, form, detail and specificity as required by the MPC, and indeed its Ordinance, there exists, pursuant to Section 508(3), a deemed approval of the Plan as submitted with only the conditions accepted by Appellant as hereinbefore identified. 20. Appellant, The Custer Company, furthermore avers that the Governing Body, in establishing such conditions which are not accepted, and also in denying such waiver request, did act arbitrarily, capriciously, with an abuse of discretion and contrary to law by establishing conditions not contained in the Ordinance with regard to the subject Plan and otherwise acting not based upon the merits of the waiver request. WHEREFORE, Appellant, The Custer Company, respectfully requests Your Honorable Court to enter judgment against the Appellee, Silver Spring Township Board of Supervisors, directing said Appellee to enter upon its records and execute such documents as appropriate, an approval (a "deemed approval") under Section 508(3) of the MPC of the Plan of Appellant, in terms as presented with only the conditions as accepted by Appellant, and also directing that it enter upon its records that the "waiver for the minimum rear yard for reverse frontage shall be so marked granted", plus costs and such other relief as the Court may deem adequate and appropriate. Dated: ~..~,~-'~ ~::~i~_~'~ (32030) Respectfully submitted, CALDWELL & KEARNS ~'~ ulre B Y: !~3 rr~i~h~l.~PrN~i~sEegl q ' Harrisburg, PA 17110 717-232-7661 VERIFICATION I, Stan Custer, Jr., President of The Custer Company, who, having authority to execute this Verification on its behalf, verifythat the statements and averments contained in the foregoingNotice of Land Use Appeal are tree and correct upon my personal knowledge, information and belief. I understand that false averments herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. THE CUSTER COMPANY Stan Custer, Jr., President Dated: THE CUSTER COMPANY VS. SILVER SPRING TOWNSHIP BOARD OF SUPERVISORS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6361 Civil Term WRIT OF CERTIORARI COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) SS. TO: Silver Spring Township Board of Supervisors We, being willing for certain reasons, to have certified a certain action between The Custer Cu,,Fany vs. Silver Sprin.q Township Board of Supervisors pending before you, do co~nand you that the record of the action aforesaid with all things concerning said action, shall be certified and sent to our judges of our Court of Co~m~n Pleas at Carlisle, within 20 days of the date hereof, together with this writ; so that we may further cause robe done that which ought to be done according to the laws and Constitution of this Cc~rnonwealth. E. Hoffer, P~J. the 8th day of November , 2001 Prothonota~ THE CUSTER COMPANY Appellant V, SILVER SPRING TOWNSHIP BOARD OF SUPERVISORS Appellee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-06361 CIVIL ACTION - LAW MANDAMUS LAND USE APPEAL PRAECIPE TO THE PROTHONOTARY: Please file with the Land Use Appeal filed in this matter on November 8, 2001, the attached Exhibit "A", Exhibit "B" and Exhibit "C". By: CALDV~LL\\ ~,~'-~ ~ ~--.& KEARNI James/R~lippinger, E~uire Attorr~rey I.,ID. No. 0715~_) 3631 oN.~¢~ Front Street Harrisburg, PA 17110 (717) 232-7661 01-390/32497-1 18/14/2881 14:13 717232~029 CUSTER GROUP OF CO PAGE 82 SILVER SPRING TOWNSHIP Wayne M. P~ht, Chairman' Jackie Eak~. Vice*Chatrman ]~n N. L~Blanc Maria L. L~vis The Cusler Company Attention: Stan Custer, Ir., President 13091_aurelP0intCircle ~ Hardslmx,g, PAl?ll0 October 12, 2001 RE: .Pr~.'limina~ Subdivision Plan 2001-7P Tlie Manors at Cntriage Plnce Dea~ Mr. Custer: The Silver Spring Town~p. Board of. SuPervLsors at its n{~ling held October 10, 2001 deo/ed the follow/ng waiver reqhest for the above noted preliwh~sty subalvision plan: 1. The minimum rem' yard. for a reverse frontage'lot shall be 75' (605.04.6). In addi{ioll~ the Board o~-Supervisors approved the above note~ p~]|min~y stlbdivisiol1 plan subject to the fOllowing.tonal/t/ohS: The plan shall· be. drawn at a scale of ! 0, 20, 30, 40, 50 or 100 feet to-the inch (402~01'A). 'Waiver statemeat must by revised to acknowledge the outcome ofreclU~ted waivers (402.'04~14). p]anni~g module~ ~r exemption must be approved by the ToWnship and DEP (402.05.2). PrOvide max. i~tttn curb cut on driveway detail (602.17). "' Stormwatvr M~se~nent Permit must be issued by Township when all Conditi°ns are mot. 6475 Cntlhle P/kc' · Mechanicsburg, PA 17050-2391 * (717') 766-0178 · (717) 766-1696 FAx EXHIBIT "A" ~0/14/200~ ~4:~3 ?~72326029 CUSTER GROUP OF CO PAGE: 83 The Custer Company Attm Stan Custer, Jr., President October 12, 2001 Page 2 Provide evidenCe of an approved Soil Erosion and Sedimentation Control Plan. Basin B ouffall change in characteristics is not acceptable. Basin discharge should be directed to cross culvert. Rq~ort indicates that discharging flows will cross Woods Drive; which is unacceptable. 8; Buried pipe downstream of Basin B must be identified. The need to open or · · roplace,~ pipe .~s. a'paxl of this project should be provided ir~ the Stormwater Management Report. Show that 100.y~r StOrm can safely bo conveYed through site (e.g. show safe overland conveyance.from, low points in wad). In addition to exhibit, provide calculation showing that flow will not effect proposed structures (402,02). 10. · Lot 50 should be'.aC%ssed to internal street system as a part oftbo overall sim concept' for r~idential developazent. "Curb Cuff for Lo150, as a part of emergency ascesi right-of-way, is not acceptable. ll. .R~commend providing two access points off WoodS Drive rather than one boulevard entrence, The Planning Commission also agreed with this recommcn~tion.:' 12. Development hag:direct impact of Route 114 and Woods Drive. In 2002, the intersection will OPerate at LOS 'D' or better during thc AM and PM w/thom development exCePt weathound will operate at LOS qi' (90.5 sec) during PM peak. With development, the westbound appwa~h will drop to LOS 'E' during the AM P.C..'ak and increased delay to 166.9 secondS during the PM peals Recomme~l · develoP/r niakeimprovemen~s Of adding n0r~hbo~a ami s°uthbound ieR mrs lanes on Route 1. ! 4 at Woods Drive intersection. In addition, provide funds in lieu of.widening for westbouud Woods Drive and provide contribution for future signalization. 13. Developer should fund timing modifications at Route 11 and Route 114 if necessary at time. of 0pening. 14. 15. ffbouleva~! s~6 entrance is used; a hazard marker must be placed at each end of the median with ,the ~Keep Right' signs. Note on plan that all signs win be per PennDOT specifications. Sewage. of lots mUst be approved by Authority, 10/14/2001 1~:13 ?172326029 OUSTER GROUP OF CO PAGE 04 The Cus~r Company Attn: Start Custer, Sr.; President October 12, 2001 Page 3 16. 17. 18; 20. 21. 22, 23. 24. 25. 27. 28. 29. What is the intended use of Lot $07 Developer should:look at ,alternate access lo~ations to Woods Drive to ellmln~te conflicts with adjacent residential uses. The introduction of an additional access/egress location will'reduce ~ips to tho Carriage Place location. DevEloper. should~.e, onsider. .. . trans£~rdng, small strip of land.behlnd existlug lands of Ftmkhouser and ..~amotto'property owners. Only one. tTpe of .bydran' t should be located in the development. HYdrant locations must be approvedlby F.~IC. Eliminate 12' emergency access drive that is proposed. Second full access point should be provided as discussed in comment 11 above. Actual proposed Waterline location from water companies should be shown on the plan. i' Developer shoul~ donsider'sidewalks and street lights for the developments of this density and namre~ Recreation fees in. the amount of $350 per building lot must be paid prior to final plan recording (SLDO 615.01). Recording fees must be paid prior to final plan recording. 100 year flow for ~basin' A outlet/s incorrect/n pipe calculations.. The column designated 'Flow to~ shows incorrect inlcts for Al to A.9. Show centerllnes.~nd right-of-way lines for Woods Drive and Cobblestone Way on Emergency Drive Access Profile, along with proposed grades, vert/cal curves, Extend taper on Carriage Place to a minimum of 95 feet (per MUTCD).' The minimum rear yard for a reverse frontage lot shall be 75' (605.04,6). 10/14/2001 14:13 7172326029 CUSTER GROUP OF CO PAGE 05 The Custer Company Arm: Start Custer, Sr., President October 12, 2001 Page 4 30. The Board acceptS, the Route 114 improvements as presented to include the ixmallation of a 1~ turn lane from eastbound Route 114 onto Woods Drive as well'as,the 2' w/dening of Woods Drive along tho oolite lellb~ of thc development. 31. If you have an~, qU¢~oks l~lease contacl KoII~ K. Kelch, Assii~a~ Tswnshil~ Mm~k,~'r.. Sincerely, .William S. Cook Township Manager Kelly. K. Kclch, Assi~t~t:Township Maua~r · Mark B. Bxueoing, P.E., ToWnShip Engineer Dawood F~gine~dng, Inc',, Applicam's E~ine~ Estate of Frederick Schlosser, Jr., Property Owner SILVER SPRING TOWNSHIP. Wayne M. Pecht, Chairman Jackie Eakin; Vice-Chairman Jan N. LeBlanc William C. Dunn Maria L. Lewis August 24, 2(/01 The Custer ComPany Attention: Stan Custer, Jr., President 1309 Laurel Point Circle Harrisburg, PA 171 I0 RE: Preliminary Subdivision Plan 2001-7P The Manors at Carriage Place Dear Mr. Custer: The Silver Spring Township Board of Supervisors at its meeting held August 22, 2001 tabled action on the above noted preliminary subdivision plan at your attorney's request and acknowledged the granting of an extension of time until September 13, 2001 for plan review. The following comments need to be addressed: The minimum, rear yard for a reverse frontage lot shall be 75' (605.04.6). Applicant requested a waiver to this requirement.. The Planning Commission recommended the granting of the waiver request at its meeting held August 2, 2001. The plan shall be drawn at a scale of 10, 20, 30, 40,.50 or 100 feet to the inch (402.01.1). Waiver statement must be revised to acknowledge the outcome of requested waivers (402.04.14). Planning module or exemption mfist be approved by the Township and DEP (40,2.05.2). 6475 Carlisle Pike · Mechanicsburg, PA 17050-2391 · (717) 7664)178 ~ (717) 766-1696 FAX EX}IIBIT "B" The Custer Company · Attu: Start Custer, Jr., President Aiagust 23, 2001 Page 2 5. Provide maximum cUrb.cut on driveway detail (602.17). Siormwater Management Permit must be issued by Township When all conditions are met. 7. Provide evidence of an approved Soil Erosion and Sedimentation Control Plan. Basin B outfall change in characteristics is not acceptable. Basin discharge should be directed to cross culvert. Report indicates that discharging flows will cross Wood, Drive; which is unacceptable. '9. Buried pipe downstream of Basin B must be identified. The need to open or replace this pipe as a part of this project should be provided in the Stormwater Management Report. 10. 11. Show that 100 year storm can safely be conveyed through site (e.g. show safe overland conveyance from low points in road). In addition to exhibit, provide calculation showing that flow will not effect proposed structures (402.02) Lot 50 should be accessed to internal street system as a part of the overall site concept for residen, tial development. "CUrb Cut" for Lot 50, as a part of" emergency access fight-of-way, is not acceptable. 12. Recommend providing two access points offWoods Drive rather than one boulevard entrance. 13. Development has direct impact ofRonte 114 and Woods Drive. In 2002, the intersection will operate at LOS 'D' or better during the AM and PM without development except westbound Will operate at LOS 'F' (90.5 sec) during PM peak. With development, the westho~und approach wilt drop to LOS 'El during · the AM peak and increased delay lo 166.9 seconds during the PM peak. Recommend developer make improvements of adding northbound and southbound left mm lanes on Route 114 at Woods Drive intersection. In addition, provide funds in lieu of widening for westbound Woods Drive and provide contribut!on for future signalization. 14. Developer should fund timing modifications at Route 11 and Route 114 if necessary at time of opening. 15. Study recommends the widening of Woods Drive approach to two (2) lanes at the intersection with Carlisle Pike. Due to sight distance limitations, developer The Custer Company At~: Start Custer, Jr., President August 23, 2001 Page 3 should provide funds in lieu of widening for future improvements when signalized. 16. If boulevard style entrance is used, a hazard marker must be placed at each end of the median with the "Keep Right" signs. Note on plan that all signs will be per PennDOT specifications. 17. Sewage of lots must be approved by Authority. · What is the intended use of Lot 50? Developer should look at alternate access locations to Woods Drive to eliminate conflicts with adjacent residential uses, The introduction of an additional access/egress location will reduce trips to the Carriage Place location. 20. Developer should consider transferring small strip of land behind existing lands of Funkhouser and Starner to property owners. 21. Only one type of hydrant should be located i~ the development. Hydrant locations must be approved by EMC. 22. Concerned with 12' emergency access drive proposed. Second full access point should be provided as discussed in comment 12 above. 23. · If the rightyo~-way for stablized emergency access is provided as shown on this plan, the lands between the right-of-way and Lot 29.should be added to Lot 28. 24. Ac _tt¢l proposed waterline 19cation from water companies should be shown on the plan. 25. Developer should consider sidewalks and street lights for the developments of this density and nature. 26. Recreation fees in the amount of $350 per building lot must be paid (SLDO 615.01). 27. Recording fees must be paid prior to final plan recording. 28. The Planning Commission recommended that two (2) access points be provided to the development. The Custer Company, At'm: Stan Custer, Jr., President August 23, 2001 Page 4 29. 30. 100 year flow for basin A outlet is incorrect in pipe calculations. The column designated "Flow to" shows incorrect inlets for A1 to Ag. 31. Show centeriines and right-of-way lines for Woods Drive and Cobblestone Way on Emergency Drive Access Profile; along with proposed grades, vertical curves, 32. Extend taper on Carriage Place to a minimum of 95 feet (per MUTCD). This plan will be reconsidered by the Board of Supervisors at its meeting scheduled for Wednesday, September 12, 2001 at 5:30 p.m.. Please submit revised plans to the Township office by Friday, August 31, 2001. If you have any questions, please contact Kelly K. Kelch, Assistant Township Manager. William S. Cook ToWnship Manager WSC/ksd CC': Kelly K. Kelch, Assistant Township Manager Mark B. Bmcning, P.E., Township Engineer Dawood Engineering, Inc., Applicant's Engineer Estate of Frederick Schlosser, Jr., Property Owner DAWOOD ENGINEERING, INC. Silver Spdng Township Board of Supervisors 6475 Cadisle Pike Mechanicsburg, PA 17050-2391 Re: Preliminary Subdivision Plan 2001-7P The Hanors at Carriage Place Dear Members of the Board: On behalf of the CUSTER COHPANY (the Applicant), DAWOOD ENGINEEILTNG, INC. (DAWOOD) would like to summarize and address the remaining items for the above referenced project. The following responses are in accordance with the Township Manager, Mr. William S. Cook's comment letter dated August 24, 2001. The Applicant has requested a waiver of the requirement to provide a minimum rear yard of 75 feet on all reverse frontage lots. We have provided a separate waiver justification letter dated 3une 14, 2001 that we reviewed with the Planning Commission and the Board of Supervisors. The Planning Commission recommended the granting of the waiver request at its meeting held on August 2, 2001. The Applicant, as provided in the review letter, will accept the following comments: comment nos. 2, 3, 4, 5, 6, 7, 10, 17, 21, 24, 26, 27, 29, 30, 31, and 32. We offer the following responses and summations from pdor meetings for the Board of Supervisors review: In accordance with an earlier meeting with the Township Engineer, we will accept the Township Engineer's determination that the buried pipe should be replaced. The applicant will replace the existing pipe within the Township's existing right-of-way as requested. The discharge from our pond will be directed to this location. 11., 18. The Applicant does not accept this recommendation. Lot 50 as stated by the Applicant, is not part of the single-family development and, as such, will not be accessed from an internal street. The applicant does not have any plans for the development of this area. General Note 1 on the plan specifically states that any future development of Lot 50 will require further Township approval. /~MN OFF1CE-HAP,~$BURG, PA PO. BOX 246 2040 GOOD HOPE ROAD ENOLA, PA 17028 717.732,8876 FAX: 717.732.8596 REGIONAL OFFICE-PITTSBURGH, PA FOSTER PLAZA 651 HOLIDAY DRIVE SUITE 300 EXHIBIT "C" PITTSBURGH. PA 15220 412.928.2051 FAX: 412.928,2052 Silver Spring Township Board of Supervisors October 10, 2001 Page 2 The applicant does not accept this recommendation. The Applicant and ~WOOD firmly feel that a development, of this size and character is adeqUately ~ served by one access point~ a boulevard entrance. The boulevard entrance will provide a separate ingress and egress lane each consisting of 18 feet in width. A ten (10) foot landscaped median shall also be provided. Ma ntenance responsibilities for this island shall be assigned to the Homeowner's Association. Our Traffic Consultant has reviewed this issue and has indicated in the Traffic Impact Study that one access point is appropriate for a development of this size. In addition, at an earlier meeting with the Township's Traffic Engineer, he also confirmed to us that, on a transportation basis, one access point is adequate for a development of this size. Our Traffic Consultant's review indicated that traffic from the development, including emergency vehicles, could adequately exit and enter the site from the boulevard style entrance. The Applicant has indicated that-a singular access provides better safety to the community and character that is essential for his planned development of the subject property. We also feel the boulevard style entrance has been successfully used in the past to provide adequate ingress and egress for developments with one entrance. The additional ingress/egress that has been provided for emergency vehicles should eliminate any additional concerns of the Township. Zn summary, we feel that the access for the development has addressed, on a traffic and safety basis, a reasonable access point for the project. The plan as submitted currently meets Township Ordinance requirements. 13. 14. 15., The Applicant has met with Township staff concerning these comments. Based on the approved Traffic Impact Study it has been presented to the Township that our project comprises only 1.6% of the traffic impact to the Route 114 and Woods Drive intersection. We realize that the subject intersection functions at poor Levels of Service with or without this development. As a result of earlier .meetings, the Township Engineer has provided us with concept sketches and budgets for improvements to the intersection of Woods Drive and Route 114. In reviewing the options the Applicant is proposing to construct a lef~ turn lane improvement for the Southbound approach on Route 114 at the Woods Drive intersection. Since our project has no impact on turning movements from Noffchbound approach on Route 114 traffic onto Woods Drive (West) these improvements are not being proposed with this project. These improvements will significantly reduce the length of time traffic on Woods Drive would have to wait until accessing Route 114. The wait time will be reduced from 983 seconds to 44 seconds for a westbound vehicle on Woods Drive (2012 no build versus build). MAIN OFFICE-HARRiSBURG, PA REGIONAL OFFICE-PITTSBURGH, PA Silver Spring Township Board of Supervisors October 10, 2001 Page 3 The Applicant is proposing to provide the referenced improvement subject to approval. These improvements would also involve the upgrading of the North side of Woods Drive to current Township standards from Route 114 intersection to the entrance to the Manors at Carriage Place. 16. The Applicant accepts this condition. ~Keep Right" signs and hazard markers will be placed at each end of the median. We would request a modification to the note requested by the Township Engineer to read, "all signs will be per Township Engineer's ~pproval" instead of "PennDOT specifications." This may allow more options for project signage. 19. The Applicant does not accept this condition. The Applicant has reviewed many alternate locations for the access and has selected the best location based on sight distances and conflicts with residences. 20. The Applicant does not intend to transfer the small strip of land behind the existing lands of Funkhouser and Starner to them. The Applicant will provide a planted buffer in that location. 23. The Applicant does not accept this condition. The stabilized emergency access has been provided with a 16-foot easement through Lot 50. The driveway location currently meets Township Ordinance requirements. 25. The Applicant has revieWed the need for sidewalks and feels that, in a development of this character and target market, sidewalks are not needed. The cartway provides adequate space for pedestrians. [n addition, the Applicant believes that the house lighting will provide adequate lighting in the development and that street lights are not needed. The plan as submitted currently meets Township Ordinance requirements. Having addressed the Township's outstanding comments above, the Custer Company respectfully requests approval of the Preliminary Subdivision Plan 2001-7P, The Manors at Carriage Place, conditioned upon fulfilling the outstanding comments. Sincerely, / / INC. Cc: Mr. Stan Custer, Custer Homes Mr. James R. Clippinger, Caldwell & Kearns ~/ Dell c my doc\land dev pro\201029\Board of' Supervisors Let MAIN OFFICE-HARK1SBUKG, PA REGIONAL OFFICE-PITTSBUKGH, PA THE CUSTER COMPANY VS. SILVER SPRING TOWNSHIP : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-06361 : : C1VIL ACTION - LAW : : MANDAMUS : LAND USE APPEAL pRAECIPE TO THE PROTHONOTARY OF SAID cOURT: Kindly mark the above-captioned action settled and discontinued, with prejudice. Respectfully submitted, CALDWELL & KEARNS By:~ James Attomel 3631 N~ ). No. ~,~159 Front Street Harrisburg, PA 17110 (717) 232-7661 78511