Coral Lakes would set bad precedent

January 25, 2022

This letter has been submitted to the Sussex County Planning & Zoning Commission with a copy sent to the Cape Gazette for publication. 

The following are comments on land-use application S-2021-06, Coral Lakes.

This application for a cluster subdivision proposes to develop 152.35 acres containing woodland and non-tidal wetlands. Efforts to develop this tract date back to 2009, when 209 houses were proposed. A 2010 application proposed to build 160 units, and in 2020, another application proposed to build 304 units. The application now submitted to the county proposes to build 315 units.

Given the physical characteristics of this tract and its location on Robinsonville Road, the best use of this acreage would be a woodland park with gravel walking paths. Such a park would be compatible with the state’s assignment of its Level 4 investment level to most of the acreage – a small segment has been assigned a level 3 classification. A park also would be consistent with the Cape Henlopen transportation improvement district development plan, and with the Center for the Inland Bays plan. Last but not least, a park would fulfill the goals of the county’s own comprehensive plan.

The best available information about this proposal is from the state’s PLUS review of application 2020-11-05. That proposal (304 units) required clearing 95.5 acres, or 67 percent, of the 143.5 acres of woodland. It also would have disturbed upwards of 25 acres of non-tidal wetland. In its review, DelDOT estimated that the proposed development would generate close to 3,000 trips a day on Robinsonville Road. This road is on its way to becoming yet another traffic headache for both residents and DelDOT.

Another disturbing feature is the developers’s design strategy. Since they seek approval as a cluster subdivision, they must satisfy criteria set forth in Section 115-25 in the county’s subdivision ordinance. One such criteria requires contiguous open land: Section F(3) “… Required open space shall comply with the following criteria: (b) Required open space must be designed to be beneficial to the residents or users of the open space. It shall not be constituted of fragmented lands with little open space value ... Accordingly, 30 percent of all required open space shall be located on a contiguous tract of land ...” One look at the concept drawing from the 2020 application shows a development comprising mainly houses and irrigation ponds. The concept design links strips of land with bodies of water to qualify as “contiguous.” In reality, much of the open land qualifies as buffers to adjacent land parcels. The 2020 design concept might satisfy the “contiguous” requirement from a technical standpoint, but it absolutely fails to satisfy the purpose of this criterion. This design will be a bad precedent. In closing, I urge the planning & zoning commission to deny this application.

Carol Conroy
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