Royal Farms application must be denied

This letter is being submitted to express the Sierra Club of Delaware’s position regarding the conditional-use application for a small parcel at the intersection of Route 24 and Angola Road. Royal Farms is behind this third, ill-conceived application for this site. They want to put three separate trip-generating uses – a car wash, a gas station and a convenience store – on a site that has significant environmental value and also has significant access issues. County council twice denied other attempts to put a gas station and convenience store on this site. This application suffers from the same fatal flaws. 
 
First, the proposed gas station, convenience store and car wash would be on top of a hill. Gas spills will feed directly into the water supply for area residents. The county recently spent over $1.4 million to acquire other parcels near this site to conserve land adjacent to Sarah Run. This site is higher than the land recently purchased, so the proposed increase in impervious surface on the site will lead to more water and faster flow of water into the land purchased by the county, and then into the water supply. The proposed underground water-retention facility will not adequately protect the adjacent parcels. This should be enough of a reason to deny this application. 
 
Second, Royal Farms’ proposed three uses on the small site will cause increased traffic at an already overburdened intersection. The proposed ingress and egress for the site, as is required due to its slope, is not intuitive and likely will lead to more accidents at the intersection. The proposed access would cause some vehicles to make U-turns and others to make an additional turn through an already overburdened intersection. This intersection will already see a significant increase in traffic as other previously approved developments are built and occupied, and this intense use of this site was not envisioned when DelDOT made plans to improve this intersection. 
 
Third, the site is zoned and planned for agricultural or low-density residential use. Low-density use of the site is consistent with the comprehensive plan and the site’s current AR-1 zoning. Under Sussex County’s regulations, none of the three proposed uses is permitted as a “conditional use” in areas zoned AR-1 or AR-2.  Angola Road is planned as a transition between the long-established neighborhoods in the area, and the land west of Angola Road. The intensity requested by Royal Farms is not appropriate where, as here, the site is planned and zoned for its “highest and best use” – low-density, low traffic-generating uses. 
 
The owner of this parcel is not entitled to a windfall simply because he is persistent in attempting to develop this site more intensely than it is planned for. That this is the third application should not persuade you that the use is any more appropriate than the first proposal for a 7-Eleven years ago. The application must be denied.