Editor’s Note: The following was submitted to the Westport Planning Commission and all members of the Westport Representative Town Meeting by Dara Lamb on behalf of the Westport Alliance for Saugatuck.

By Dara Lamb

After reviewing the P&Z May 14, 2025 staff report and attending P&Z May 19 meeting on the Hamlet, we would like to thank town officials—including the Department of Public Works, Flood & Erosion Commission, Conservation Commission, and P&Z—for their diligence in ensuring the Hamlet application receives proper scrutiny. We especially thank Michele Perillie for her comprehensive and high-quality report, and the P&Z commissioners for the time and effort they devoted to formulate thoughtful, informed questions.

The Application Is Incomplete and Non-Compliant

The staff report and the May 19th meeting made one thing clear: this application is incomplete and does not comply with the text amendment or multiple town and state requirements. These deficiencies are significant, some are dependent on state responses, and cannot be resolved within the timeline to close the hearing on June 18.

Furthermore, the developer has changed plans so many times, it is impossible for the public to keep up with the mountain of constantly changing documentation which appears to be strategically submitted at the very last minute. To date, plans are still incomplete and without working designs for crucial mechanical and flood water mitigation systems. Commissioners from numerous committees have spent an inordinate amount of time on this application already and are set to spend much more with no end in sight.

At the May 19 meeting, the developer tried to lay the blame on the P&Z, stating they need more guidance. But they’ve already been given guidance, by the ARB, by the Flood and Erosion commission, by the public for some three years, and in the comments by commissioners.

It’s simply not fair for the developers to continually ignore recommendations with very clear guidance on what is required for this application to be complete and to comply with the needs of the town as written in the text amendment. In the meantime, other worthy applications sit and wait while the Hamlet gets prioritized and takes up the town calendar.

Many of the more than 1,100 signers of the Westport Alliance for Saugatuck petition built or renovated homes in Westport and were sent home to wait months to get back on the calendar when their application was missing required information or other approvals.

Rather than wasting more town resources, we respectfully request the applicant withdraw their application and return with an adjusted plan that meets the town’s needs, in full compliance and complete. The following is a summary of many, but not all defects in this application:

Architecture + Mass and Density not in Compliance with Text Amendment

Westport’s Architectural Review board unanimously rejected this application because it does not comply with the TEXT AMENDMENT’s requirement that its architecture be in keeping with the vernacular of a New England Coastal Village. We applaud the Planning and Zoning commission’s recognition of the ARB’s hard work and in particular, commissioner Wistreich’s statement that she would be troubled to go against their recommendation. After all, if the ARB is to be ignored, why have one at all?

Traffic & Parking: Outdated Data, Inadequate Solutions

The TEXT AMENDMENT requires the applicant not to make traffic worse than it already is. The applicant’s own traffic study by SLR indicates the Hamlet will negatively impact the key intersection of Charles/Park St at the entrance of commuter lot 1. Due to the Hamlet, this intersection will drop from LOS C to F on weekday afternoons, and LOS B to E during midday on Saturdays.

We understand a detail like this could get lost in a 70-page document. This underscores why having a peer reviewer is such good practice. However, the town’s peer reviewer, Sharat Kalluri, completely ignored this intersection in his review. 

M.Paquette’s 4-26 letter to P&Z, forwarded and responded to by Mr. Kalluri, highlighted this once again. Once again, he ignored this. Why?

Below is a picture of current conditions at this intersection, taken at 4.18pm on May 18. As you can see, traffic is backed up all the way down Charles to Riverside Avenue.

Traffic backs up on Charles Street to Riverside Avenue

What is not shown in this photo is this backup continuing all the way up the exit 17 off ramp.

How will Emergency Service Vehicles navigate this when minutes can make the difference between life and death or a debilitating permanent injury?

In addition, the applicant’s traffic study and proposed solutions are based on COVID-era data and do not reflect current or projected conditions. Mr. Kalluri, the peer reviewer, stated he could not adequately establish traffic patterns and loads from the site plan and had to rely on the developer’s data. We appreciate his transparency that he will soon be presenting another Saugatuck project to P&Z on behalf of another developer.

Updated traffic data is essential. We request an updated traffic study be done by a different peer reviewer who is not scheduled to have business before the town.

Common sense dictates the addition of 500 cars/hour, plus trucks and pedestrians unloading and loading will undoubtedly cause more backups. We appreciate commissioners Wistreich and Injeski’s probing questions on this.

Parking Concerns

Similarly, the parking plan fails to account for the true demand and relies on outdated data from 2024 before return-to-office rules were enforced. 5-day return to office rules are scheduled to go into effect this June for many if not most companies and will immediately spike demand for parking.

The applicant projected creating 640 jobs in their own brownfield remediation application. Most of these employees will arrive at the same time as commuters and may opt to park in commuter lots. Plus, to succeed, this development requires foot traffic of hundreds of daily visitors and event attendees. It is vastly under-parked.

There is no realistic way to prevent employees and patrons from occupying scarce commuter parking, especially during peak hours. Anyone from virtually anywhere can buy a Westport parking permit, and there is no practical way to police who parks where.

The proposal assumes availability that simply doesn’t exist.

The parking demand analysis REQUIRED BY THE TEXT AMENDMENT is missing. This is because a demand analysis would reveal this site plan is not in compliance with town regulations requiring sufficient on-site parking.

Below are pictures of Lots 1,2 and 3 taken at 6pm on May 8, 2025.  As you can see, lots are full.

Commuter Lot 1 at the Saugatuck (Westport) train station.
Commuter Lots 2 and 3 at the Saugatuck (Westport) train station.

The text amendment gives P&Z latitude to determine how much parking is required for events. It also gives P&Z the right to require the development be scaled back to meet these requirements.

To determine parking for events, we suggest a good measure is to look at the severely deficient planned parking for the Black Duck: 2.7 parking spaces (see developers plan below, from their slide show presented at the P&Z public hearing). Whether this allocation complies with a badly written code or not, anyone visiting this icon of Westport sees many more than 2.7 cars for lunch, dinner and drinks patrons.

Where the commissioners do have latitude, we implore them to use their discretion for realistic instead of untenable parking demand assumptions.

Below is a photo of the slide developers presented at the P&Z public hearing.

Flooding, Contamination & Engineering Risks

Significant concerns remain regarding stormwater systems, contamination remediation, and long-term maintenance. Town engineers have raised red flags about drainage designs that don’t function. Secant piling systems, especially when exposed to contaminated soil and water can degrade over time and allow offsite contamination to migrate through. This is exactly the case in this development, since lots to be remediated abut unremediated, contaminated lots.

Venting and treatment plans appear speculative, estimated to continue for decades by the remediation contractor, with no clear long-term safeguards. Commonly occurring heavy winds and flood risks further complicate safe soil handling during the remediation.

An additional peer review was requested by P&Z but, to our knowledge, the developer has not yet funded it.

Maintenance and Oversight

This development proposes complex, interdependent systems (e.g., automated flood doors, tunnels, storm water treatment). Manufacturer’s specs for the flood doors have yet to be submitted so they can be thoroughly assessed by town engineers. Without proven plans for maintenance and failure protocols, the risks of systemwide failure are high.

No Basis for Conditional Approval

We understand that approvals must be based on regulatory grounds, not opinion. Fortunately, this application provides multiple fact-based reasons for denial, as outlined in the text amendment and highlighted by town staff. Approving this plan with conditions to be satisfied later shifts the burden unfairly onto the town with no assurance of timely or complete compliance, particularly given this developer’s track record with their special permit application.

Respect Town Time and Process

This application has consumed disproportionate time and attention, delaying other deserving projects. In addition, meetings and reviews have often occurred on Zoom, without appropriate public oversight. Constant document changes, often submitted at the last minute, make public review and informed feedback nearly impossible. Over 1,100 residents have documented their opposition to this project through our petition, many providing experience-based comments.

We urge the commission to ask the applicant to withdraw, revise, and return only when they have a complete, compliant proposal that respects Westport’s standards.

Sincerely,


The Westport Alliance for Saugatuck