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1336 Route 9 LLC, vs. TOW & TOW Planning Board 2026SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF DUTCHESS ------------------------------------------------------------------ -x 1336 ROUTE 9 LLC, Petitioner, Index No. 2026-51542 -against- THE TOWN OF WAPPINGER and THE TOWN OF WAPPINGER PLANNING BOARD, Respondents. ------------------------------------------------------------------- -x MEMORANDUM OF LAW IN SUPPORT OF ARTICLE 78 PETITION Received MAR 2 3 2026 Town of Wappinger Town Clerk BLEAKLEY PLATT & SCHMIDT, LLP Attorneys for Petitioner One North Lexington Avenue White Plains, NY 10601 (914) 9492700 A TABLE OF CONTENTS PRELIMINARY'STATEMENT.......................................................................1 STATEMENT OF FACTS............................................................................................................. 1 LEGAL STANDARDS.................................................................................................................. 1 ARGUMENT.................................................................................................................................. 2 A. The Planning Board's determination that an additional fuel pump dispenser would somehow increase site traffic and result in queueing conditions similar to the existing conditions has no support in the record.............................................................................. 2 B. The Planning Board's requirement that all vehicles exit the gas station onto U.S. Route 9 was arbitrary and capricious given that the Board's own traffic consultant found that drivers would ignore such a requirement............................................................................ 3 C. It was arbitrary and capricious for the Planning Board to deny Petitioner's application based on crashes that had nothing to do with the gas station layout ................................... 5 D. The Planning Board's other grounds for denial were unfounded and/or incorrect ............. 6 CONCLUSION............................................................................................................................... 7 TABLE OF AUTHORITIES Apache Assocs. v. Plan. Bd of Vill. of Nyack 131 A.D.2d 666 (2d Dep't 1987)........................................................................................ 2, 5, 6 Buenos Hill, Inc. v. City of Saratoga Springs 175 N.Y.S.3d 467 (Saratoga Cnty. Sup. Ct. 2022)..................................................................... 4 E. New York Props., Inc. v. Cavaliere 142 A.D.2d 644 (2d Dep't 1988)................................................................................ 2, 3, 4, 5, 6 Gerber v. Town of Clarkstown 356 N.Y.S.2d 926 (Rockland Cnty. Sup. Ct. 1974).................................................................... 4 Indep, Wireless One Corp. v. Town of Maryland Plan. Bd. 738 N.Y.S.2d 829 (Otsego Cnty. Sup. Ct. 2002)........................................................................ 4 Ramapo Pinnacle Props., LLC v, Vill. of Airmont Plan. Bd. 145 A.D.3d 729 (2d Dep't 2016)............................................................................................ 1,3 SCI Funeral Servs. of New York, Inc. v. Plan. Bd of Town of Babylon 277 A.D.2d 319 (2d Dep't 2000)................................................................................................ 3 PRELIMINARY STATEMENT Petitioner 1336 Route 9 LLC ("Petitioner") brings this Article 78 action to challenge the denial, by the Town of Wappinger Planning Board ("the Board"), of its application for an amended site plan approval. Petitioner sought merely to add an additional fuel pump dispenser to the two existing dispensers at a local gas station and reconfigure the station's internal layout accordingly. The application was supported by plans drafted by a licensed professional engineer in consultation with a traffic expert. It was uncontested that the additional fuel pump dispenser will help address unmet demand at the gas station, where long lines of cars waiting for the two existing fuel pump dispensers are common. The Board nevertheless denied Petitioner's application. As set forth in greater detail below, it did so for reasons that are internally contradictory and wholly unsupported by the record. Accordingly, the Court should find that the Board's determination had no rational basis and was arbitrary and capricious. STATEMENT OF FACTS The relevant facts are set forth in the accompanying Verified Petition, the exhibits attached thereto, and the annexed affirmation of Petitioner's traffic consultant Lee Klein, all of which are incorporated herein by reference. LEGALSTANDARDS "A local planning board has broad discretion in reaching its determination ... and judicial review is limited to determining whether the action taken by the board was illegal, arbitrary, or an abuse of discretion. A planning board's determination should be sustained upon judicial review if it was not illegal, has a rational basis, and is not arbitrary and capricious." Ramapo Pinnacle Props., LLC v. Vill. of,4irmont Plan. Bd., 145 A.D.3d 729, 730 (2d Dep't 2016). 1 However, a planning board's determination should be overturned if "the record lacks sufficient evidence to support the rationality of the Board's determinations." Id. Moreover, "[a] denial must be premised on clear findings of deleterious changes that adversely affect the adjoining area[.]" E. New York Props., Inc. v. Cavaliere, 142 A.D.2d 644, 646 (2d Dep't 1988); see also Apache Assocs. v. Plan. Bd of Vill. of Nyack, 131 A.D.2d 666, 666 (2d Dep't 1987) ("a planning board may not base its determination respecting an application for site plan approval solely upon its view of what is beneficial for the public health, safety and general welfare"). ARGUMENT A. The Planning Board's determination that an additional fuel pump dispenser would somehow increase site traffic and result in queueing conditions similar to the existing conditions has no support in the record. As set forth in the Planning Board's final determination, field observations of the gas station "documented queues up to five vehicles, backing almost to U.S. Route 9 ... and some vehicles leaving due to excessive wait times, indicative of unmet demand at existing conditions." (Ex. D to Verified Petition, at 3.) The Board's traffic consultant thus concluded, quite logically, that "additional fueling positions may reduce individual wait times." (Id.) The Board's traffic consultant also opined, however, that the additional fueling position would somehow "increase site traffic" and "would likely result in queuing conditions similar to existing conditions." (Id. ) The Planning Board based its denial largely on this inherently contradictory opinion. There is simply no support in the record for the Board's determination. Petitioner's own traffic consultant stated—without contravention—that the amount of site traffic at gas stations is a function of the amount of traffic on the adjoining roads.' In other words, the gas station at issue would only see an "increase in site traffic" if there were to be an increase in the number of cars 1 In addition to presenting this information to the Board during the application process, Petitioner's traffic consultant has submitted a sworn affirmation reflecting the same information together herewith. 2 travelling along U, S. Route 9 or Old Hopewell Road in this area. Nothing in the record suggests that this will occur.' Cf. SCI Funeral Servs. of New York, Inc. v. Plan. Bd. of Town of Babylon, 277 A.D.2d 319, 320 (2d Dep't 2000) (annulling denial of site plan application where applicant demonstrated that it would operate "in a safe and efficient manner without significant traffic problems"), Adding an additional fueling position capable of servicing two cars at once would necessarily reduce wait times at the gas station, resulting in shorter lines ------the very outcome supposedly sought by the Planning Board. For the Board to find that additional fueling positions would instead result in increased "site traffic" and/or unchanged "queuing conditions" was arbitrary and capricious as it was unsupported by the record. See.Ramapo Pinnacle Props., 145 A.D.3d at 730; see also E. New York Props., 142 A.D.2d at 646 (noting that petitioner's traffic expert "was not refuted or controverted by anyone at the public meeting or by the planning board's professional planning consultant") B. The Planning Board's requirement that all vehicles exit the gas station onto U.S. Route 9 was arbitrary and capricious given that the Board's own traffic consultant found that drivers would ignore such a requirement. It is undisputed that the Board's traffic consultant recommended "requiring all exit movements via the northerly driveway to U.S. Route 9," and that Petitioner did not "incorporate[] these operational changes" into its proposed site plan amendment. (Ex. D to Verified Petition, at 3.) As an initial matter, there were legitimate reasons for this decision—the configuration of the convenience store parking made it impracticable, and the Dutchess County Department of Public 2 The PIanning Board may have implicitly concluded that an extra fuel pump dispenser at the gas station would act as a "draw," i.e., that more cars would stop at the gas station once they realized it had three fuel pump dispensers instead of two. But if this was indeed the Board's rationale, it was not set forth in the January 21, 2026 denial resolution, and therc was nothing in the record supporting such a conclusion. 3 Works would not allow removal of the channelization at the Old Hopewell Road driveway. (See Affirmation of Lee D. Klein, at 2-3.) Regardless, a site plan applicant is not required to adopt every recommendation made by a municipal planning board any more than is the municipality itself.3 See, e.g., Buenos Hill, Inc. v. City of Saratoga Springs, 175 N.Y.S.3d 467 (Saratoga Cnty. Sup. Ct. 2022), aff'd, 223 A.D.3d 1030 (App. Div. 2024); Indep. Wireless One Corp. v. Town of Maryland Plan. Bd., 738 N.Y.S.2d 829, 833 (Otsego Cnty. Sup. Ct. 2002); see also Gerber v. Town of Clarkstown, 356 N.Y.S.2d 926, 928 (Rockland Cnty. Sup. Ct. 1974) ("this Court cannot and will not direct that the defendants follow the recommendations of [the County Planning] Board"). This is especially so where, as here, the Planning Board's traffic consultant had already concluded that adopting his recommendation would have little practical effect. In his August 14, 2025 letter to the Board, the Board's traffic consultant specifically noted that even if Petitioner adopted his recommendation to require exiting from the gas station onto U.S. Route 9, "drivers will likely not be familiar with the restrictions and still try to navigate back to Old Hopewell Road." (Ex. C to Verified Petition, at 2 (emphasis added).) The danger this would pose is self-evident. In any event, it is well established that denial of a site plan application "must be premised on clear findings of deleterious changes that adversely affect the adjoining area[.]" E. New York Props., Inc., 142 A.D.2d at 646. Petitioner's application would not have effectuated any "changes" regarding the gas station exit; cars may currently exit onto either U.S. Route 9 or Old Hopewell Road and would continue to do so under the amended site plan. Stated differently, there were no 3 It is worth noting that Petitioner adopted most of the Board's other recommendations and submitted multiple changes to the underlying application over the course of several months to comply with comments from the Board and its consultants. Cf. Bongiorno v. Plan. Bd of Inc. VUL of Bellport, 143 A.D.2d 967, 968 (2d Dep't 1988) noting that "planning board consistently withheld approval" despite petitioner's "repeated and costly concessions." M "clear findings" that Petitioner's proposed changes would have somehow made the gas station's layout worse, and it was arbitrary and capricious to deny the proposal on such a basis. Id.; see also Apache Assocs., 131 A.D.2d at 666. C. It was arbitrary and capricious for the Planning Board to deny Petitioner's application based on crashes that had nothing to do with the gas station layout. The Board's denial was based in part on its finding that there were "eleven crashes between January 1, 2022 and February 28, 2025 at or near the Site ... underscoring existing safety concerns that must be addressed in any expansion." (Ex. D to Verified Petition, at 3.) But Petitioner's traffic consultant reviewed the crash reports in detail and learned that one was actually a duplicate. Moreover, as he informed the Board, two of the ten crashes "involved rear end crashes ... and did not involve traffic entering or exiting the gas station, while "[t]wo other crashes involved single vehicles losing control, which [similarly] did not involve vehicles accessing the gas station." (See Affirmation of Lee D. Klein, at 3.) Indeed, Petitioner's traffic consultant found that "none of the crashes were related to the design of the access driveways on Route 9 (which was the focus on the Planning Board's traffic consultant)." (Id. ) It is undisputed that there have been six crashes that "involved two vehicles maneuvering within the site." (Id.) However, as Petitioner's traffic consultant explained to the Board, "[t]he proposed new diagonal layout of the gas pumps will help prevent crashes of that nature by limiting the need for vehicles to reverse from a fueling position." (Id.) There was no contrary evidence in the record; the Planning Board simply ignored this information, which is grounds to overturn the challenged determination. See E. New York Props., 142 A.D.2d at 646. E D. The Planning Board's other grounds for denial were unfounded and/or incorrect. The Planning Board denied Petitioner's application based in part on input from the Dutchess County Department of Public Words, which advised that the fuel delivery truck turning plan "would block both lanes on County Route 28 [Old Hopewell Road] if entering the intersection on red[.]" (Ex. D to Verified Petition, at 3.) But there was no basis to conclude that a fuel delivery truck would ever break the law by "entering the intersection on red." More importantly, it was undisputed that "the fuel delivery truck has accessed the subject property at least once a day for the past ten years without any reported crashes." (Affirmation of Lee D. Klein, at 3.) In other words, although it sounded facially in "public safety," this aspect of the Planning Board's denial was in fact based on a purely hypothetical scenario and had no actual basis in the record. See Apache 4ssocs., 131 A.D.2d at 666; see also E. New York Props., 142 A.D.2d at 646 (rejecting planning board's contention as "conclusory") The Planning Board also based its denial in part on the fact that Petitioner had not yet obtained permits to commence work from the New York State Department of Transportation or the Dutchess County Department of Public Works. (Ex. D to Verified Petition, at 4-5.) But such permits are typically obtained after an applicant obtains site plan approval from the local municipality, not before. There was simply no reason to seek work permits until and unless the Planning Board allowed Petitioner to move forward with an amended site plan, and it was arbitrary and capricious to, in effect, penalize Petitioner for proceeding in the way it did. Finally, the Planning Board based its denial in part on a finding that Petitioner's "lighting submission lacks a complete photometric plan[.]" This was simply incorrect; Petitioner provided a photometric plan as part of its updated submissions to the Planning Board dated June 23, 2025. (See generally Ex. B to Verified Petition.) 6 CONCLUSION For the foregoing reasons, the undersigned respectfully submits that this Article 78 petition should be granted in its entirety, Dated: White Plains, New York March 20, 2026 BLEAKLEY PLATT & SCHMIDT, LLP One North Lexington Avenue White Plains, NY 10601 (914) 949-2700 Attorneys for Petitioner by: Isl David A Chm David H. Chen, Esq. dchen@bpslaw.com Lino Sciarretta, Esq. lscirretta@bpslaw.com 7 PRINTING SPECIFICATION STATEMENT 1 hereby certify that according to CPLR 2101 and Section 202.5(a) of the Uniform Civil Rules for the Supreme Court that the foregoing Memorandum of Law in Support of Verified Petition was prepared on a computer with a proportionally spaced typeface. Name of typeface: Times New Roman Point size: 12 Line spacing: Double The total number of words in this memorandum, inclusive of point headings and footnotes and exclusive of the cover page, table of contents, table of authorities, and this printing specifications statement is 1997 as determined by the word count feature of Microsoft Word. Dated: White Plains, New York March 20, 2026 8 IslOavid X. e&a iQ Received SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF Dutchess MAR 2 3 2026 ......... ------------------ ,...------------------------.............-x 1336 Route 9 LLC Town of Wappinger Town Clerk Plaintiff/Petitioner, - against - Index No.2026-51542 The Town of Wappinger and the Town of Wappinger Planning Board Defendant/Respondent. ---------------------------------------------------------------- -x NOTICE OF ELECTRONIC FILING (Mandatory Case) (Uniform Rule § 202.5 -bb) You have received this Notice because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New York State Courts E -filing system ("NYSCEF"), and 2) You are a Defendant/Respondent (a party) in this case. • If you are represented by an attorney: Give this Notice to your attorney. (Attorneys: see "Information for Attorneys" pg. 2). • If you are not represented by an attorney: You will be served with all documents in paper and you must serve and file your documents in paper, unless you choose to participate in e -filing. If you choose to participate in e -filing, you must have access to a computer and a scanner or other device to convert documents into electronic format, a connection to the Internet, and an e-mail address to receive service of documents. The benefits of participating in e -filing include: • serving and filing your documents electronically • free access to view and print your a -filed documents • limiting your number of trips to the courthouse • paying any court fees on-line (credit card needed) To register for e -filing or for more information about how e -filing works: • visit: www.nycourts.govlefile-unrepresented or • contact the Clerk's Office or Help Center at the court where the case was filed. Court contact information can be found at www.nycourts.gov _ Page 1 of 2 616118 EFM-1 To find legal information to help you represent yourself visit www.nycourthelp.gov Information for Attorneys (E -filing is Mandatory for Attorneys) An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the a -filed matter on the NYSCEF site www.nycourts.gov/efile; or 2) file the Notice of Opt -Out form with the clerk of the court where this action is pending and serve on all parties. Exemptions from mandatory e -filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)] For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: nysceMnvcourts.aov). Dated: March 20, 2026 David H. Chen Name Bleakley Platt & Schmidt, LLP Firm Name To: Town of Wappinger 20 Middlebush Rd Wappingers Falls, NY 12590 1 North Lexington Ave. Address White Plains, NY 10601 (914) 949-2700 Phone dchen@bpslaw.com E -Mail Index # Page 2 of 2 616118 EFM-1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF DUTCHESS ----------------------------------_---------------------------------x 1336 ROUTE 9 LLC, Petitioner, -against- THE TOWN OF WAPPINGER and THE TOWN OF WAPPINGER PLANNING BOARD, Respondents. --------------------------------------------------------------------x Index No. 2026-51542 NOTICE OF PETITION PLEASE TAKE NOTICE that upon the accompanying Verified Petition, the exhibits annexed thereto, and the Memorandum of Law in support of same, an application will be made at 9:30 a.m. on the 27th day of April, 2026, or as soon thereafter as counsel may be heard, at the Dutchess County Supreme Court located at 10 Market Street, Poughkeepsie, NY 12601, to a Justice of the Supreme Court to be assigned, for a judgment under Article 78 of the Civil Practice Law and Rules vacating and annulling the final determination of the Town of Wappinger Planning Board adopted on January 21, 2026 and filed with the Village Clerk on February 19, 2026, which denied the Petitioner's application for an amended site plan approval. Petitioner additionally seeks a judgment and order directing the Planning Board to issue the amended site plan approval, reasonable attorney's fees and costs, and such other and further relief as may be just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 7804 (c) and (e), a copy of the certified record, an answer and any supporting affidavits shall be served on the undersigned attorneys for Petitioner no later than five (5) days before the return date of the Verified Petition Dated: White Plains, New York BLEAKLEY PLATT & SCHMIDT, LLP March 20, 2026 One North Lexington Avenue White Plains, NY 10601 (914) 949-2700 Attorneys for Petitioner by: lsl bawd X Ma David H. Chen, Esq. dchen@bpslaw.com Lino Sciarretta, Esq. lscirretta@bpslaw.com X19 T E) w m -t a 0 9r 0 1 A N D E w E) w w a � 8 th 6 h fir 6 b' 8 0 tv w a 0 2026-51542 1 W sa# N D A oLk 8 6 h R f) d a ji 4 a � 8 th 6 h fir 6 2026-51542 1 W sa# A oLk 8 6 h R f) d a ji 4 a � 8 th 6 h fir 6 b' 8 0 tv w a iy 6iry F n Y a 2 if b a di k 3 Rs ath 0 Pi 0 d El b kv 6 N It a d8 Rd 2d F 4 % it 6 AV s a in d h kv 6 N w 8 1 6 h s 0 kv F v I 5. Respondent the Town of Wappinger Planning Board (the *Planning Board") is the duly constituted plarming board for the Town, consisting of seven members appointed by the Town Bo=t At all relevant times the Planning Board was chaired by Bruce Flower. JUMSDICTION AND VENUE & The Supreme Court has jurisdiction over this special proceeding under Article 78 of the CPLR. It may exercise pevsonal jurisdiction over Respondents because they are municipal entities located within Dutche-ss County. 7. Venue for this action is proper in Dutchess County under CPLR §§ 506(b) and 7804(b) as that is where Respondents' principal place of business is located and where the complained -of Planning Board determh1ation wasn-tade. FACTUAL BACKGROUND S. Petitioner owns the real property located at 1.336 Route 9 in Wappingers Falls, New York, which is identified as Tax Lot 6157-02-614569 (hereafter "the Property"). The Property comprises approxinuatelt' 0.68 acres in the Town's Highway Business (HB) zoning district. 9. . The Property hosts a gas station and convenience store which are situated at the northeast corner of the intersection between 'U.S. Route 9 and Old Hopewell Road. 10, Currently there are just two gas pump dispensers at the gas station. 11. Via the underlying amended site development plan application, designated No. 25- 3507 by the Planning Board, Petitioner sought to relocate the two existing gas pump dispensers, add oac additional one, add a caiiopy over the dispensers, and reconfigure the station's curbs mid traffic signage, (See general4y Exhibit A.) Petitioner's application was accompartied by plans drafted by a licensed professional engineer in consultation with a traffic expert who analyzed the flow of vehicles in and out of the gas station. W 11 On or about May 20, 2025, Petitioner submitted updated plans that addressed con-n-i-ients received from the Planning Board at the Board's May 5, 2025 meeting. These updated plans addressed traffic flow and maneuvering, parking, landscaping, said the design of the canopy. 13. On or about June 23, 2025, P(,-titioner again revised its plans, to address additional comments received at the Plamiing Board's June 16, 2025 meeting. (See generally Exhibit B.) 14. The Planning Board's consultant, Hardesty & Hanover, noted that Petitioner's application was considered a Type 11 Action and required no further action with respect to SEQRA. 15. On or about August 14, 2025, the Town's tTaffic consultant wrote to the Planning Board to recorDniend that Petitioner require vehicles "to exit via the northerly driveway to Uu S. Route 9." (See generally Exhibit C.) The'rown's traffic consultant noted that even if Petitioner did so, however, drivers -will likely not be familiar with the restrictions and [will] still try to navigate back to Old Hopewell Road." The Town's traffic consultant also requested "crash data at the existing driveways for the latest three-year period," which Petitioner provided, 16. At the October 6,2025 Planning Board ineeting, Petitioner's own traffic consultant noted that most of the crashes that had occurred at the intersection of U.S. Route 9 and Old Hopewell Road did not actually involve the gas station. He flarthet noted that driver error and not the gas station's design, was responsible for the three crashes that involved vehicles turning into the gas station. petitioner's traffic consultant further noted that the proposed new diagonal configuration of the gas purnp dispensers would reduce the likelihood of oollisions on site, all of which had been caused by vehicles backing away frown the pumps or from the adjacent Convenience storax. 17, The Planning Board did not take issue with Petitioner's crash analysis. Nevertheless, at the conclusion of Petitioners, October 6, 2025 presentation, the Maiming Board's chairman stated that the entire Board had an "uncomfortable feeling" amort "the traffic flow," and advised Petitioner lo revise its application yet again.. When Petitioner declined to do so, the Planning Board scheduled a public hearing on. the underlying application, which was held on. November 3, 2025, No members of the public spoke at the hearing. 18. At the Planning Board's Novernber 3, 2025 meeting, its chairrftaii opined that adding an additional gas pump dispenser would "increase the traffic on thu Property," even though Petitioner's evidence had demonstrated that the additional dispenser would sirnply meet existing demand and accordingly reduce queuing and wait times for the gas pumps. Planning Board members also expressed concern about fuel delivery trucks backing out of the gas station, even though this had never caused any accidents. 19. When Petitioner declined to revise its application again, the Planning, Board cbein.'riati. told petitioner that its site plan application would be denied, 20. At its January 21, 2026 meeting, the Planiting Board vowd, without further debate or discussion, to adopt a pre -written resolution denyi-ug Petitioner's site plan application. 21. The denial resolution (see generally Exhibit D) stated, infer alia: * "that while additional fueling positions may reduce individual wait times, they would also increase site traffic and, given the proposed pump orientation and on-site circulation, would fikely result in queueing conditions similar to existing conditions;" * that the Planning Board had recommended "requiring all exit movements via the northerly driveway to U.S. Route 9." and * that "[c]rash. data -from NY DOT CLEAR confirms eleven ermlies between January 1, 2022 and FebruW: 28, 2025 at or near the Site." The resolution further stated that Petitioner's application "fails to mitigate documented queuing that encroaches toward U.S. Route 9, and does not resolve conflict points exacerbated by the proposed fueling position orientation and increased site traffic identified by the Town's traffic consultant .1" The denial resolution was filed with the Town Clerk on February 19, 2026. M AS AND FOR A FIRST CAUSE OF ACTION 21 Petitioner repeats all prior paragraphs as if fully set forth herein. 23, The challenged determination of the Planning Board is contrary to law, lacks a rational basis, constitutes an abuse of discretion and is arbitrary and capricious. Moreover, the .record does not disclose a sLifficient basis for the challenged determination. 24. For example, there is no evidence in the record that adding an additional fueling position to the Property would "increase site ti-tdFic" as the Planning Board found. On the contraq, the evidence demonstrated that "site traffic"is determined by the volume of traffle on the adjoining roads and is not affected by the number of pumps at the gas station. 25. Similarly, fli.cre is no evidence in the record that "the proposed pump orientation and on-site circulation[] would likely result in quetteing conditions similar to existing conditions." Indeed, this finding was directly conti,adicted by the Planning Board's finding that "additional fueling positions may reduce individual wait times," Logically, if "individual wait times- are reduced, "queuing" is also reduced. 26. The Planning Board denied Petitioner's application in part beeauw Petitioner declined to adopt the Board's recommendation to require "all exit movements via the northerly driveway to U.S. Route 9:1 But the Planning Board's own traffic consultant had opined that even if Mitioner adopted this reconin-tendation, drivers would "still by to navigate back to Old Hopewell Road." It was arbitrary and capricious to penalize Petitioner for not adopting a recommendation that, acoording to the Board's own expert, would not actually mitigate any traffic issues at the gas station, 27. The Planning Board also based its denial on the fact that 'data from NYSDo,r CLEAR confirms eleven crashes between January 1, 2022 and. February 28, 2025 at or near the 5 Site." But Petitioner demonstrated that most of these crashes occurred at the intersection of US. Route 9 and Old Hopewell Road, not tit the gas station. For the three crashes that involved vehicles turning into the gas station, Petitioner demonstrated that the cause was driver error, not the gas station's design. It was arbitrary and capricious to deny Petitioner's application for reasons that had nothing to do with the underlying site plan. 28, The Planning Board based its denial in part on the fact that Petitioner had not yet obtained permitsto co Bence work from NYSDOTor Dutchess County DPW. This was arbitrary and capTieious insofar as such permits are typically obtained after an applicant obtains site plan approval frons the local municipality, not before. 29, flic Planning Board also based its denial in part on a finding that Petitioner's "lighting submission lacks a complete photometric plan[.]" But Petitioner in fact provided a complete photometric plan as part of its updated submissions dated June 23, 2025. WEERE FORE, Petitioner respectfully requests a judgment and order: (1) vacating and annulling the final determination of the Planning Board, adopted via resolution dated January 21, 2026 and filed with the Town Clerk. on February 19, 2026, which denied Petitioner's amended site development plan application; (2) granting the amended site development plan; and (3) awarding Petitioner the costs and expenses incurred in the instant action, including reasonable attorneys' fees, together with such ffirther relief as this Cotwt deems just and proper. Dated: Wbite Plains, New York March 20, 2026 BLEAKLEY PLATT' & ScilMIDT, LLP One North Lexington Avenue White Plains, NY 10601 (914) 949-2700 A ltorneyspr Petitioner by- WjQatadX David H. Chen, Esq. dchenoo bpslaw.com Lino Sciarrem, Esq. Iscirretta&pslaw,corn 6 VERIFICATION STATE OF NEW YORK ) ).-SS COUNTY OF DUTCHESS ) Mark Dombal, being duly sworn, deposes and says: I ani the business development officer for the petitioner hi the above-captiomd matter. f have read the foregoing petition and I know the contents thereof to be true of my own knowled go, except those niatters stated on irtrormation and belief, and as to those matters, I believe thern to be ffm Sworn before me this lk day of March, 2026 Notary Ptiblie 7 D 19 8 Ea 9c I1 i N K E w D IF d H 01N E) N 0 D w @IN 11 6 L DK h§ h fo gT d b y p 1 Iat b �o b K Thi €iu h4 f b N Y k d a hT i I y C R ikh T fiic a F 0 u It' u Ph it x firl g b u Ili agi p h i ik V S 2 Iw rhd h 0I a h hid e b k Whi b t b iFw f 9 0 c dm b h foh im I d $8 R 9i > Ig Ft W Yk. 3 ppE;dth i t!pI mai yck onfai nmpsgi i d h e wf li mpt a i 4� g for fu i g► 4 If R n g 8 da h ba tLi I 5 1 vi dr h a biln i ngh F h i d a Eb D t b huip g � I p d b h Foiv g b W R n g 9 ffi ut n d h t bli Eug p b t i ,ik a s i ter 5 A I i n da b P g 0 it h opinion, site generated traffic of a gas station is determined by the volume of traffic on the adjacent roads. During peak periods of travel, a gas station with convenience store draws most of its customers from the stream of traffic that is already on the adjacent roadway traveling between other destinations such as home to work or school or shopping. This is called pass -by traffic. According to the Institute of Transportation Engineers (ITE), Trip Generation Handbook, 31 Edition, September 2017, a national industry guide for all traff=ic engineers, the pass -by percentage of vehicles entering a gas station with convenience store is 63 percent during the weekday AM peak period and 66 percent during the weekday PM peak traffic periods. 7. The Planning Board's traffic consultant also concluded that the additional fueling pump station "would likely result in queuing conditions similar to existing conditions." In my professional opinion, the additional fueling pump station (two fueling positions) will increase the capacity of the gas station, which will address the unmet demand, the potential increase in traffic volumes entering the site, and in turn result in less queuing within the gas station. The current fuel pump positions allow 4 vehicles to dispense fuel while only 2 vehicles can wait for an available fueling position.. The reconfiguration of the fuel pumps and the increase in fueling positions will allow 6 vehicles to dispense fuel simultaneously, will allow up to 6 vehicles to wait for an available fueling position, which will address the unmet demand, reducing the potential for vehicles to leave without fueling. Based on my field observations as well as the field observations of the .Board's expert, the demand for fuel is already there. The improvements will address the unmet demand. 8. The Planning Board's traffic consultant recommended "restricting Old Hopewell Road access to right -turn entering only and requiring all exit movements via the northerly driveway to U.S. Route 9." However, this was impracticable due to the configuration of the convenience store parking, which would facilitate a convenience store customer to exit via a right 2 turn: onto Old ;Hopewell Read. Dutchess County will not allow removal of the channelization at the Old Hopewell Road driveway. 9. The Planning Board noted that there were"eleven crashes Between January i, 2022 and February 28, 202`5 at or rear the Site." 1 reviewed: all eloven crash reports. and learried that one was u duplicate, Two involved rear end. crashes (cine on Old .Hopewell. Rd and one on Route 9, mthhound In the left tum lane) and did: not involve traffic entering or exiting the gas station, Two other crashea involved ,single vehicles losing control, which did not involve vehicles accessing the gas station. Six of the crashes involved two vehiclos maneuvering within t1le site.. The proposed new diagonal layout of the gas pumps will help prevent crashes of that nature by limiting the need for vehicles to reverse from a fueling position. In my professional opinion, gone of the crashes were related to the design of the access driveways on Route 9 (which was the focus on the Planning: Board's traffic consultant), 10. Finally, the Planning Board expressed concern. about the exiting ofthe fluel delivery true from the gas station. This concern was unfounded-, the fuel delivery truck has aceessed the sul:jject property at least. once a day for the past ten years witli ut any reported crashes. Sworn before nee this ft day of March, 2026 Lary Pulalze JESSIOA A STEINFELR Notary Public of New Jersey COMMISSION NO. 2362258 COM.MISS1014 EXPIRES 0,91;ZWi47 3 TOWN OF WAPPINGER PLANNNNG BOARD Application INO. Date Received: Fee Meiv d: Escrow Received: APPLICATION FOR SITE i' ,AN S'I'T° VAL TITLE OF PROJECT. 1 o l i t L.o adon of'Property � 6 ��+xf�� Ct, NAME &:. ADDRESS OF APPLICANT (Corporation or fndividuai): Z 6%; e c PLA),d I re C r s3% Street Town Stag Zip Conract person _ �Phona i�iurnbcr .._ Email m. NAME & ADDRESS OF OWNER (Corporation or I tdi-idual): 334 Pw u 2-6 AnItZ, 1.,47,v (2�Ab A k tt trot � �'0�4� m_�...�..��Statc: dip Ih1 ....0 sf�' `0q 'o—niact person Phone Number Grid No. 6 l- 7 - Q 2, ... 6 l4(,5"6 q �'l��s�: �p��if; tsar Kir ua�s �rf`�tailt�ir�� at�d a���atrtit of`flpe�r area. de��teri t� encu: Existia« Use: &A5 57A r,?o f (ON v4wlevc6 S' -OAP' Proposed Use: C14f 9"A jjy �v Existing Sq. Footage: Z Y'S UsM: c - 7,/,6® Proposed Sq. footage: �_��� Use: c - Y F O_ Location of Property Zoning District: 1134 �,'7P, q , fv�� M AfttMpated No. ofErnplayees: drug P j.SH;W Acreage: 47 1 Evitinz No- of Parkin=, SpaQe,�` , 15 _e..� PrEvosed No of Parking Spaces: t 1336 Rome 4 Ltd Type Name (Corporation, LLC, Individua , etc. dr'aj� Date Oj w QLa S. t t e' f(3na ure repres (OQS') 765" 95107 AIVX, AAEA46A Owner's Telephone No, TName and `tilde pT Owner's Address ***If this is a Corporation or LLC please provide documentation of authority to sign, Notee *The appliMaL is responsible for the cost invol%°cd in publishing the required lqgzal notice in the local new5paper; W S p%cial Use Pe nit for the above use has been applied for, pleas4. checkEl. # Application Fees are noo-refundable. TOWN OF WAPPINGER PLANNING BOARD & ZONINGBOARD OF APPEALS 20 MIDDLEBUSH ROAD WAPPINGERS FAU$, NY 125K PH: 645.297.6256 Fax: 845-297-0579 Dinner Consent For Project ; Date: Grip! Cho,: �! � "� � �� - � 1 �' � � `� Zoning District- f� Location of Project - 133C Rowk q WAeM 14tX Nam? of Ap li nt» 173 17OUTP, L4C n OV)1127. zVy Print name and phone number Desaription of project: )ezcr;w4 ,4 6-oi loO1244opta ;Obi'�:��ai tNTI-S �,Vxj FAVI % nr, Of S71'" E -SPED 11,;A OIArvy hereby give permission for the Town of Wa' accordance with local and state codes and ft�,i Date Owner's Telephone Number Forint Name and Title *** Idincg ili ation in *** if this is a Corporation or LLC, please provide doc-amentation of authority to sign. If this is a subdivision application, please provide a copy of the deed. 61220 App eii (lix B Short Eiii>ieottiitetit(flAss e-isinent Form jutmfions for Completing Part I - Project Information. 'Fite appucant or project Sponsor Is re,%pomlble for tho completion of Part I. Responses lmome part of the application for approval or ikm6d g, are stibjeut to public review, aad may be Subject to further veriffoatim Complete Pan I bawd on laformatim ourventlymilable. if Kddiflonal.rcsramh or investigation would be rweded to fully rospond to any item, please answer as thoroughly tis passible based Go mnrmt informatiou. Complete all itams in Part 1. You may also provide any additionni information which you believe will be needed by or w9eflil to the lead aganoy; attach additional pagez as necessary to supplemont any item. Part I - Project tuid Spomor Information 1336 go4if ILLC rime of -Action or Projrot: 1334 gDart" q LLC TrWJ,cotTQoation (describe, and attach a location map): 133 4 gog,7,g 9 , iA , P4 Y Brief Desiniption of Proposod Aofiox Of#Vf 6XrAA' r4 e-N,4,AvP� CA,-,,#fv To 7M pq OP44 7s; aJ5 R,140 );? A K e fy;/- )4w rA ,r '86 00tA) 5 e7&ffT Namo ofMplkant or Sponson elephono; 1334 9"'.rx N'te - city/po. 61-- legiglative ado tion of as plarl, local law, Ordinance, NO YVS as trativa rule, or ragulation? If Mesa attach a narsdive dogc-dp4on of the intent of the proposed salon and Vie envirommW regoumu that may be afrorw4 ift the municipality aild pi -owed to Patt. 2, 2, Does the proposad acloa reqdre a pormit, approval or fundiag ftm any other govern.moni'll Agonq? .a. Total acmagc of tbo site, of the proposed action? CA 6r acres b. Totalntefqe- to be phy,&ioafly diaturbod? 0:1 acres a. Total acreage (project site and any contiguous properdes) owned 0 4'71 or controlled by the applicant or proj"t spoimor? , ---acres k 911 land ms that occur on, adjoining and near the pmpagod action. B Urban DRwral(nonagiculture) [31ndmtrlaf MConummial EIResidential (suburban) DFOrest DAgriculture L3Aquafio L3Dthor (speoify): Mparklaild M�� N a. A pennitted oso tindcr the zoning regnlafious? �L] YES. z N/A 11 b, Cons'Wnt with the adopted compreh.-osive plari? Er ......... .. .. .. 6. Is the propo3cdaolioa consistent with the predoninant character of gic existing built or nawral landscape? NO ARS 11 7, Is the site of the proposed action located iii, or does it adjoin, to state listed Crikal Environmental Area? If Yes, identify: NO YES 8. a. Will the proposed action result in a substantial inorea-se in traffic above pra serit levels? NO YES b, Am public trangpoilation service(s) available at or near the site of the proposed action'? e, Are any pedestrian acconimodations or bicycle, routes available on or aupr site of the proposed action? Tboes ilio -Proposed Rotiou muet or fmcced the, state euergy toderequirearzts? If the proposed octicii will exceed requitomenf% describe, design feats es and technolo&3: NO YES N0 YES If No, dosorlbe method foT providiiig potable water: 44 I I Will t1115 proposed action connect to exiging was tawater Uttlitits? NO -YES If No, describe method for providing wasiewater trey ment.- SOW- 5 V,-4^ 6107-1,V& 12, at. iio s ti sib contain -astnicture _&t is -listed on Register of Historic NO YESI b, Is the proposed action ioa4tcd in on serisittvi; =0 13, a. Dom any portion of the site of the proposcd action, or lands adjoining the proposed aotion, contain NO YES wetlands or Acr waterbodies reBulated by a fWaral, sftto or local figLmcy? b. Would the proposed action, physiully alto, or mmaoh into, any existing wetlond or watcrbodY7 E 0 If Yes, idmiffy the, wottaad or watarbody and extent of afterations in star feet or steres.q a7, 1d71-de-affy ffio'p-0iml habitat types that occurring or are likely to lie found on the project site, Check all that apply: 0 SLorobne Forest AgriculturWgrasslands Barty mid-suocegsional Wedand Urbm Suburban M Does the sho oftbo proposed action contaia &iy species of animal, or associated habitats, listed NO YE S by the state or Fcderal govornmont as threatened or endangered? _TK _in& ls­t_h100 year flood plaia? NO YE 8 X 17. Will the proposed action create lorm. teat discharge, either from point or tion-polut sources? If Yes, a, Will s' touii water disci drgos flow to adjamt prop mfios? NO DYES NO YES K Will storm water discharges be directed to �abfimhed conveyance systemsMinnoff and a f YNO jrdrarns)? Ies, briefly di=tlbo: IM . ... . ... .. .. Page 2 of 4 li 18. Does the proposed action includo contnicfi.r otoa r othz° activities dist Yeau tin the iinponsicaaient o water or other Hquids (e,g, retention pond, waste lagoon, dam)? If Yeg, oxplain purpose and siize: r-71 19, Iles Ell yn the site of the proposed actiau or, an adjoining property been the location OraCM n active or 1( d N solid waste managemont facility? if Yes, dosoribo: M Hat; the site of the proposed action or to adjoining property been the s0ji�ct of reaqQdiation (ongoiag or NO YES completed) for hazardous waste? If Yes, desurl'be: Z El -iAFF1 R '17111's , INFORMATION PROVIDED ABOVE IS TRUE AND ACCURATE TO ME BEST OF illy KNOWLE LED Appliowitigpomor na ZOZ Signature- Part'.7 - InTatt Asstisment. Tlw, Lead Agency Is respoasiblo for the voulpletion of Part 1 Ausiver all of the fbilowing. questions in Part 2 using the laformation contained in Part I and offier materials submitted by the projeat spowor or o4herw3so available to the reviewer, lien aaworing the qimstiona ft reviewer should be guided by the waoept'Trvo any responses been rmonWc cons, dering the scale znd context of thvpwposed action?" L Will the proposed action GreaW awatedt)J conflict with or adapted land use plan orzowng regulations? 2, Will 3. Will ffioproposod action impair tire. characwxorgala litycif the 4. 'Will the propmod k'~tion "RVO M" 'nPUCt 011 tho 0JJVjM=WJW obvuaotcrislics that Mused t� estabRahment tufa Critical Enviromnontal Area (CM)? S. WILU the proposed aCtio'll rQJJJLJt in Qn. adVeT8Q 011angg in title eXiSting level or. traffito 01' affect eximthig infrastructure for miss firuiW4 biking or walkway? 6, Will the proposod action cause an irrrrease in the use ofenergy wid it fails to incorporate Lamonably available enoc gy_n2nsoaatiort or renewable enorgy opporhuiifies? 7. Will the ptopmedact[on: irupactexigdag: a, pubic / prim water sugpli%? b. public /private waaWwater treatmeat utilities? R. WM the propose d action impair the chawtor or quality of importmitWorio, twohaeologioal, avehitectural or aosthotio rucerin 7 9. Will the proposed action result in an adverao climi.ge to natural resources (e g., wetlands, watzrbodies, gromidwater, air qiiatfty, flan and fauna)? Page 3 of 4 Impa P'T Loplict WAY aveUr may 00pur El El C - 11 El li-� C 11 P 41yt 3 - Ueterndnati(II) of �Jgjjjfjoqnea, The Load Agoncy Is respotisIblo for the c*raplefion of Part I For every quadon in Part 2 that was stiswerod "moderate to largo impact may occue', or if there is need to mplain why a particular element of tho proposud Wflon may Of Will not result in a significant adverse envireamontal impact, plisse complete Part 3, Part 3 shotild, hi sufficient detail, identify the impact, including any meamtes or design elements that have beon included by the, prqjt spot=r vo avaid or redvice impacts. Part 3 should also explain how the lead agenoy detvnninGd that th� impact BTA"Y or will not bo Signifimat, Ewh powitlil finpaot sboutd be assessed considering its settingg, probability of ocQurding, duration, LT4-versibihty, geographic scope and magnitude. Also cornsider the potontial for short-temi, loilg-tella and cumuhalvo impacts. lieu% this box if cats nve -&Wnninod, -bawd on the idurm4on and analysis above, and any siipporting dwwwtadoyt, thA, the proposed action may rogult in ono or 11jorc potentially largo or significant adverse impacts tnd aa environnte,mal impact statement is req*ed. Check, this box if yogi five dCerin hiod, based on the information and analysis abovo, imd any mpporting d"umontation, that the proposed action will not result in any aignificar"t adverse ia111nwt& Narao of Lcad Agency Date, Print or Type Namo of Rcspoasiblo Officer in Lead Agency Title afRovons6le Ofter Sl&ature of Responsible Offt"r in Lml Agoacy Sigaamro of Preparer (if differeat from Raspawlbh� Officer) E�:P�RINT Page 4 oN small to large inipact Impact may Y occur occur M Will the proposed action rtstdt in tm iiieremu in the powntial toy oro6ion, floo(bg or drainage Ej 11 probtems? IL Will tKe proposed action create a hazard to enviroill-gentil reso llvces or human heafth? 1 7 � 7 P 41yt 3 - Ueterndnati(II) of �Jgjjjfjoqnea, The Load Agoncy Is respotisIblo for the c*raplefion of Part I For every quadon in Part 2 that was stiswerod "moderate to largo impact may occue', or if there is need to mplain why a particular element of tho proposud Wflon may Of Will not result in a significant adverse envireamontal impact, plisse complete Part 3, Part 3 shotild, hi sufficient detail, identify the impact, including any meamtes or design elements that have beon included by the, prqjt spot=r vo avaid or redvice impacts. Part 3 should also explain how the lead agenoy detvnninGd that th� impact BTA"Y or will not bo Signifimat, Ewh powitlil finpaot sboutd be assessed considering its settingg, probability of ocQurding, duration, LT4-versibihty, geographic scope and magnitude. Also cornsider the potontial for short-temi, loilg-tella and cumuhalvo impacts. lieu% this box if cats nve -&Wnninod, -bawd on the idurm4on and analysis above, and any siipporting dwwwtadoyt, thA, the proposed action may rogult in ono or 11jorc potentially largo or significant adverse impacts tnd aa environnte,mal impact statement is req*ed. Check, this box if yogi five dCerin hiod, based on the information and analysis abovo, imd any mpporting d"umontation, that the proposed action will not result in any aignificar"t adverse ia111nwt& Narao of Lcad Agency Date, Print or Type Namo of Rcspoasiblo Officer in Lead Agency Title afRovons6le Ofter Sl&ature of Responsible Offt"r in Lml Agoacy Sigaamro of Preparer (if differeat from Raspawlbh� Officer) E�:P�RINT Page 4 oN ADMINISTRATIVE REGULATION OF THE TOWN OF WAPPINGER PLANNING BOARD l ZONING BOARD R QUIREMla NT "OIC. ESCROW FTJNDS SECTION 1. ESCROW FUNDS EST LIQI-JE I) By the authority granted by Section 240-110 € f the'romr of Wappinger Toning Law and iti order" to erasure that the cost of any Engineering, SEAR Experts, PlanAn , Legal or other consultation, fees incurred by the Town of talaprpinger with respect to natters Wore the Planning Board l Zoning Board are borate by the applicants, there is hereby established an Escrow bund. Upon filing an application for either subdivision or site plan, special perrttit approval, or Dor a. building p5erixiit err° certificate of oNnp5antry, the applicant shall deposit with the Towa Conta°ollw, via certified check, ,sum of rtaoriey if) acoordance with the ttibN below. `l"lie Controller shrill pay from these funds the foes ebaarged dry any professionals employed by the Planning Board with respect to the applicants parQiect. Said fees shall bu subm,itted by voucher and paid as ap3proved by the Zonin Adriaitai wator. The applicant shall deposit additionxat fa nds into such account to bring its balance up to 100% of the amount ofthe full eseTow deposit try the last day of each ruoirth. U such account is not firily replenished by the last day oftho vionth, the approving agency sMI suspend its review of the application, lza �o c<�e of past�rrpproval i pertituas a reviews in�roivirag �iastntotiti� the Town ruay issue a stops warp order. No sabdivislon plat or site evolo t t plan shall be endirrurd err fid d u uttl all prokgional. r"t.vi w fees e.h r e o rrr c fees this` a rr ` ire r t v cl. rr sett t iae' tc vit, irrrll l g ati l ba i aiii esu tr ` Its r t v r cl. rr sr tl t ire' rr var, hrr9i i g atr I ha i trn es all amfesslnc • i.re i ee it ti ria ` v f ha a 1➢.cant's ro eel li ave bei re rad e t i d t ,new Us r . "di'd Lit : Ia tit iitn`. a ras e� tr tri ctrr , t •rtetio ads aired tlriv vL s, No Certificate of Occupancy shall be issued unless all professional roview fees obarged in connection with the paost� approval inspeetion acrd review of the projen have been reirrabursed to the Town. No ref aids of any funds remaining on deposit in escrow shall be issued until all perLblent pr€rfessiolral review charges have been paid wi.d the tnarl cerdf'cate of occupancy has been issued W the paroject, or where applicable, the road leas been accepted by the Town acrd th.e one-year uminterratice period loris expired. SECTION 2, CALCULATION OFi SCROW FUND For SLU_DDIVISIQNS, the applicant shall deposit a sum calculated as follows: A) Number of lots Amount 0 - 2 5, 13.00 3-10 10,000m I1-35 $22,500M >35 $52,500,00 For SI`L`L PLANS & REGULAR SPECIAL USE PCWMITS, the applicant shall deposit a sure calculated as follows: B) ASuare F tam Amount Up to 3,000 $ 5,000.00 3,001 to 20,000 %'10,000.00 20,001 to 50,000 $ 22,500.€0 > 50,000 52,500.10 For AffNOR _APPLICATIONS, the applicant s1u 1 deposit and maintain a sum calculated follows. C) $2,500.00 For VAMANCES,the applicant shall deposit a sum deterrained by the Zon n .Board rrl`Appeals. . For RCS AD N x; EC I NS, the ap licatit shall deposit and maintaina sum oc1ual to 3% of the ons etiou costs as sti t by hr" `I'"ovm Engineer. 240.112,A,(2) ADDHc:ation [Pefition Fee for Rezoning. $1001.00 Administrative Reguladou of the Town of %ppinger Planning Board Requirement for Escrow Funds Page 2 For Post plaallia �.�the applicant shall deposit a sum calculated as follows prior to the Resolution and Maps being signed by the Chairman of the Planning Board Site Plans: A) Number of lots Amount 0-2 $5,000.00 3 -10 s I0,000.00 11-35 $16,875.00 > 35 $26,250.00 B) _S:�Uare �Footamye Amount Up to 3,000 $5,000.00 to 20,000 $10,000.00 20,001 to 50,000 $16,875M > 50,000 $ 26,250M SECTI ON 3. REVILIONS This rcgtdation may be revised by the Planning Bo-ard of the Town of Wappinger following a public he-aHng and approval by the Town Board. Signed: Bruce Flower, Chairman Town of Wappinger Planning Board Dated: August 21, 2023 Town of Wappinger Planning Board and Zoning Board of Nppeals CURRENT FEE SCHEDULE 2023 PLANNING DEPT. FEF, Subdivision Fees: Subdivision Application Fee: Recreation Fee-. Lot Line, Realignment: Lot Consolidation: Site Plans: Site Plan Application Fee: Amended Site Plan Application Fee - Conceptual Fees., Architectural Fee,: Architectural Fee: Special Use Permit Fees: $1500, plus $250 per lot. For I - 9 lots, $5,000.00 per lot; For 10 or more lots, the Planning Board all determine whether to require the reservation of land or payment of $5,000.00 per lot. $500 plus escrow $500 plus escrow $15 00, plus $250 per 1000 sq. ft. of gross floor area of the building, plus $20.00 per parking space. $750, plus $250 per 1000 ft of floor area, plus $X00 per parking space $250.00 No escrow $250 Minor — no escrow (Deteiamain ed. by ZA) $250 Major - $2,000 escrow Commercial Fee: $750.00 per application Accessory Apartment Fee: $750.00 per application. ZONING DEPT. FEES Variance Fee: (Resident) Area/Use Variance Fee: $375.00 per application. (Commercial) Area/Use Variance Fee: $1,000.00 per apple Interioretation Fee: Residential $150.00 per application. Commercial $500.00 plus escrow All application fees are non-refundable. Copy work: $.25 per page Please note that all, applicants will belilled by the local newspaper for their legal notice. Escrow Funds. See attached schedule Effective date: August 2023 9:1 1336 Route 9 Proposed Project: Existing gas pumps to be removed and relocated, one extra pump and canopy to be added. A portion of the concrete curb at the northerly egress will be removed and relocated, and pave area. Existing yard light to be removed and relocated. The northerty curb wilt be removed and re(ocated and area paved. Traffic diversion to/from Old Hopewell Road removed. Propose to pave over disturbed area, keep the directional signs, and paint new flow signals' ort the pavement. - Shed to be removed, - Retocated entry doors from the right aide of the store front glass to the (eft side of the storefront gtass, 0 I `5 jp n �PF�� py�'uzw'"a3 pq a7 t! jH (p i gg6413•y1gg @RBipgg�yigg r k� I `5 n r k� C) L, . a m jJ r dei: ° $" LIts�� kFl 'r " Al1- - �, ,N3'ffyy.t. � �Q1g•��� �Q . �r38(P174G, O A 9 RAM � a E fo 0,11 k A g gg pp � €��.utt°RonRil �k+kw�am.ar, q n RAM � a E fo 0,11 k A g gg pp � €��.utt°RonRil �k+kw�am.ar, q _� i NY1d8310 � *eS�. � aasoawa � �� d 77 •�. wxevw� �vw oeeeawwus .. E� j fi Mw Am,mlgd suawddw ! -m)'�v w- p ; 8 vd0o'd am 6 "Rold 8E64 0r t ara7 $moans � �� y� Naf�AfPUlls s awmp-0rnrmz i � NYld Ella � G �I 8211108 PS£4 � �4nnaa, � ,no„ru •rmma - - ..-$ 5 - :d3Nxa _. rrn:xHiav �na'�z I awnv++!.m I, I'41 FROS� OVON I� o -------- t D' F,4 �1 all, e LU Q. J 1 l% .- Y \ I d' tE s 1 LU it I aF.. a i 1 Z. I W Ju ED Q IN - 6b ttpp lees awnn�u� Qvo® duuyvc�nl u3nr ,. 77�Rl+�gif. Q7o Sf aift, �Y�a ' �3 .L80 re��°V 780yd urtos to aoq , R4�'ly � Ar. moi: J � 8� t� Na16�a7nsr � Y R p � "i uo s WV.4 �� jlkYl3a adaNu]9NV Nola9Vh• ._.. N-r5� t+ero gid. m��nH�fri OW. 10'A94re¢ P w,uu -evw� aaue�unoiav it - �� •� € � '. -, �• -��23 Q ..�...-., ..._.�..... ..._. .,._._...... a_..._ rldFerwa,m+sla.0 �xn�u 'a'd Lm3 s �SUOVUV N MIME oez�nxB3aae�c�04 xdaaM I `� Y I NOLLVh3190H'/Mlhi WOii j� { €'0116 '01'I 6Wa2i 8Ef4 ' Cillos , slYtllf�TC� LI i I 'I i I - ---___ wwrwo aa.._.......aJ E I u I S7 I N33 E I S7 I N33 a I a e i u� 1 : ..i I �I 0 0 q lig I iI`I` Y I I I i. idl , s�lv�aanr - F•^�hNS7lytl[d Si19`91Nk[1d�/VM� W3tsAa �NNI1FNl '3116 apoN a84 i Nib'. AO;rna 1 S _ NOIIrTIvd6k W2.lSArJ N�liaNd!#Wd ^^ e3L10119f6 P �. .. a J' V ' _..,..._ _... ,.. _. `b.t. a°n _ - .LOS ANl'?H i.Nd$ M F w OEC j # @ ? OEC I ggg .aural i'�38 � �` A II ..&fit.. ............. ....._...... ................ ------... I I �'� i I �- w t� og c a m � �:!01 z I f er Qa 773�rj' a7a 5107 aNy",9 7Jj1 BWaoJ to aNu NVR9T3' � Nl�7N"ua�8 � A+015f4fQs� S Ire w �I �:!01 z E v 3, I 3 4r .t 3' a4l F]• IV r �7 g � ix t � pp gt I: kL jByF '# - w L ,1, v 3, I 3 4r .t 3' a4l F]• L ,1, H&H MEMORANDUM To: Bruce M. Flower, Chairman, and the Town of Wappinger Planning Board Date: August 14, 2025 41.1 Theodore Frerrrd Ave, Suite 206 South Rye, NY 10580 T: 97.4,967.6540 www.liardestyhanover.com Subject Citgo Gas Station Expansion -1336 US -9, Wappingers Falls, NY 12590 As requested, we have reviewed the Site Plan, as well as the video of the Planning Board Meeting held on June 16, 2025. The proposal is to increase the existing four fueling positions to six fueling positions and orient the fueling position locations. Our office conducted field observations on Wednesday, August 6, 2025 from 4:00 to 6:00 P.M. Based on our observations the maximum queue was found to be 5 vehicles waiting for a pump to free up, which backed almost to U.S. Route 9. About 90% of vehicles entered/exited the site via U.S. Route 9. Due to excessive wait times, some vehicles exited back onto U,S. Route 9 without fueling. Vehicles entering from U.S. Route 9 were observed traveling at a fast speed to avoid a rear end condition and turning into the site. The following section provides our comments and evaluation of the Applicant's information provided; Review Comments 1. Site Traffic Generation — The Board questioned the increase in traffic due to the increase in fueling positions proposed by the Applicant. Based on the latest Institute of Transportation Engineers (ITE), "Trip Generation," 11th Edition, the increase in fueling positions is estimated to result in an increase in total site traffic at the site driveways of 21, 27 and 26 vehicle trip ends during the weekday morning, weekday afternoon and Saturday midday peak hours, respectively. NYSDOT allows a 25 percent pass -by credit for vehicles that are already on the adjacent roadways that will now stop at the site as they pass. This results in a reduction of 6, 7 and 6 vehicle trip ends during the weekday morning, weekday afternoon and Saturday midday peak hours, respectively. This results in a total of 15, 20 and 20 new vehicle trip ends to the adjacent roadway network during the weekday morning, weekday afternoon and Saturday midday peak hours, respectively. The attached Table 1 provides the site traffic estimates in more detail. As noted, our observations found that some motorists would pull in and then leave the site due to long wait times (unmet demand). Page 2 August 14, 2025 2, On -Site Queueing — The Applicant has stated that the additional two fueling positions will help reduce existing queueing issues at the fueling positions. While the additional fueling positions may reduce wait times, the proposal will likely also see an increase in site traffic due to additional pumps, as shown in the site traffic estimates and field observations of unmet demand, which may result in queueing conditions similar to existing conditions. In addition, the way the fueling positions are laid out in the proposal most likely will lead towards an intermittent condition when all six pumps are occupied. When this occurs, the seventh vehicle will likely wait behind the first fueling position, thus reducing the available queuing space down to three vehicles. 3. Internal Circulation — The Board was concerned with proposed internal circulation and the crossing of opposing traffic trying the exit the site to Old Hopewell Road, especially when the fueling truck is on-site. To better improve on-site circulation, we recommend restricting the Old Hopewell Road to "right turn entering only" and all traffic required to exit via the northerly driveway to U.S. Route 9. This would reduce internal conflict concerns and have traffic flowing into and out of the site generally in a counterclockwise direction (Note: driver's will likely not be familiar with the restrictions and still try to navigate back to Old Hopewell Road). The angle of the fueling stations may help mitigate this movement. 4. Crash Data — The Applicant should provide and summarize in a tabular format crash data at the existing driveways for the latest three-year period. Findings As noted above, the addition of two new fueling positions will likely result in an increase of total site traffic to the site and adjacent roadway network during the weekday morning, weekday afternoon and Saturday midday peak hours, respectively. While the additional fueling positions will likely reduce wait times on-site, the proposal will also likely see an increase in site traffic, as shown in the site traffic estimates, which may result in queueing conditions similar to existing conditions. To better improve on-site circulation, potential changes could include changing the Old Hopewell Road to right turn entering only and all traffic exiting via the northerly driveway to U.S. Route 9, which would reduce internal conflict concerns and have traffic flowing into and out of the site generally in a counterclockwise direction. Page 3 August 14, 2025 Respectfully submitted, Steven T. Cipolla, PE, PTOE Senior Traffic Engineer Hardesty & Hanover, LLC RESOLUTION TOWN OF WAPPINGER PLANNING BOARD RE: CITGO 1336 ROUTE 1336 ROUTE 9 LLC — RESOLUTION DENYING AMENDED SITE DEVELOPMENT PLAN At a regular meeting of the Planning Board of the Town of Wappinger, Dutchess County, New York, held at Town Hal[, 20 Middlebush Road, Wappingers Falls, New York on the 21st day of January, 2026 at 7:00 P.M. The meeting was called to order by the Chairman Bruce M. Flower and the Planning Board member attendance was as follows: Bruce M. Flower PRESENT Paul Freno PRESENT Markos Peratikos ABSENT Thomas Truss Jr. ABSENT James Glor[oso PRESENT Richard Barth PRESENT Robert Meehan PRESENT The following resolution was moved by PAUL FRENO and seconded by JAMES,GLGRIOSO WHEREAS, the Town of Wappinger Planning Board (the "Planning Board") received an application from Mark Dombal (the "Applicant") on behalf of 1336 Route 9 LLC for Amended Site Plan approval to; add one fueling pump and relocate the existing two fueling pumps; relocate and modify the existing canopy to accommodate the additional and relocated pumps; remove an existing shed; modify existing lighting; modify and relocate doors of the existing convenience store; and modify and repair existing paving and curbing (the "Project" or "Proposed Action"); and WHEREAS, the property is located at 1336 Route 9, identified as Tax Lot 6157-02-614569, consisting of approximately 0,68 acres in the Highway Business (HB) zoning district (the "Site"); and WHEREAS, the Applicant submitted the following materials; Application for Site Plan Approval dated 1131125; Short Environmental Assessment Form Part 1 dated 411125; narratives dated 411125 and 5122125; a comment response memorandum by Mark Dombal dated 5122125; vehicle turning template drawings (6 sheets) dated 5116125; and a set of plans (generally entitled "1336 Route 9 LLC") prepared by Anthony Sottile dated 6123125, with sheets including lighting and landscaping, as more fully described in the record; and WHEREAS, the Town's planning consultant, Hardesty & Hanover, reviewed the application and issued a memorandum dated June 13, 2025 identifying deficiencies and required revisions regarding photometrics, luminaire count, fixture heights, color temperature, and traffic/internal circulation; and WHEREAS, the Town's consulting engineer, Paggi Engineering, reviewed the application and issued memoranda dated October 3„ 2025 noting, among other things: (i) the need for approvals/permits from NYSDOT (U.S. Route 9) and Dutchess County DPW (Old Hopewell Road) before site plan approval and prior to commencement of work; (ii) potential front setback nonconformitles related to the canopy, possibly necessitating a variance if the canopy footprint is enlarged; and (iii) the need to complete and clarify construction details, show existing trees potentially affected by curb relocation, and show existing septic/sewage disposal areas,; and WHEREAS, Dutchess County Department of Public Works, by letter dated April 23, 2025, advised that the turning movements for a WB -50 truck indicate the truck would block both lanes on County Route 28 (Old Hopewell Road) if entering on a red light; that the existing exit to State Route 9 northbound appears navigable by the delivery vehicle; and that the County will not allow removal of the channellzation at Old Hopewell Road; and WHEREAS, the Planning Board's traffic consultant, Hardesty & Hanover, reviewed the Site Plan and the June 16, 2025 Planning Board meeting video, conducted field observations on August 6, 2025 from 4:00-6;00 PM, and issued memoranda dated August 14, 2025 and October 2, 2025, finding, inter alla, maximum queues of five vehicles backing almost to U.S. Route 9, approximately 90% of vehicles entering/exiting via U.S. Route 9, unmet demand causing vehicles to leave without fueling, and recommending operational restrictions (right -turn -in only from Old Hopewell Road and all egress via the northerly U.S, Route 9 driveway) to reduce internal conflicts; and further concluding that adding two fueling positions would increase site traffic and could perpetuate queuing similar to existing conditions; and WHEREAS, the Planning Board is familiar with the Site and surrounding area and has reviewed the Project in accordance with the Town Zoning Law (Chapter 240) standards for site plan approval; and SEQRA WHEREAS, the Planning Board determined that the Proposed Action is a Type II action under the State Environmental Quality Review Act (°SEQRA"), requiring no further environmental review; and PROCEDURAL HISTORY; PUBLIC HEARING; REF'E'RRALS WHEREAS, in accordance with General Municipal Law §§ 239-1 and 239-m, the Planning Board referred the application to the Dutchess County Department of Planning and Development, which responded by letter dated December 8, 2025, stating the matter is of local concern but commenting that the submitted lighting plan does not sufficiently demonstrate existing and proposed fixture details and lighting levels for the entire site and recommending that the Planning Board require a plan that adheres to the applicable requirements in Section 240-23 of the Town Code; and WHEREAS, in accordance with Town Code § 240-88, the Planning Board conducted a duly noticed public hearing on November 3, 2025, at which all persons wishing to speak were heard; and FINDINGS OF FACT 1. Site and Proposal o The Site contains an existing gasoline station and convenience store, with two fueling pumps; the Applicant proposes to add one pump (increasing fueling positions), relocate existing pumps, and modify the canopy accordingly; additional site changes include lighting modifications, door relocations, and paving/curb work. 2. Traffic. Safety, and Internal Circulation Town Code §240 -86(A) -(C) o Heid observations documented queues up to five vehicles, backing almost to U.S. Route 9, with 90% of vehicles entering/exiting via U.S. Route 9, and some vehicles leaving due to excessive wait times, indicative of unmet demand at existing conditions. o The Planning Board's traffic consultant concluded that while additional fueling positions may reduce individual wait times, they would also increase site traffic and, given the proposed pump orientation and on-site circulation, would likely result in queueing conditions similar to existing conditions, including reduced queuing storage when all six pumps are occupied. o To mitigate internal conflicts and improve circulation, the consultant recommended restricting Old Hopewell Road access to right -turn entering only and requiring all exit movements via the northerly driveway to U.S. Route 9, which would promote counterclockwise circulation; however, the Applicant has not incorporated these operational changes. o Crash data from NYSDOT CLEAR confirms eleven crashes between January 1, 2022 and February 28, 2025 at or near the Site, including four at the U.S. Route 9 entrance, one at Old Hopewell Road driveway, and six on-site, with two injury crashes, underscoring existing safety concerns that must be addressed in any expansion. o Dutchess County DPW advised the WB -50 delivery truck turning plan would block both lanes on County Route 28 if entering the intersection on red and prohibited removal of the Old Hopewell channelization, constraining feasible changes at the County approach and implicating onsite circulation design. 8. Acres Management and Agency Approvals Town Code„ X240-84(8),�§240-86(B), (H) -(I) o Portions of the proposed work lie within or depend upon the rights-of-way and access of NYSDO)T (U.S, Route 9) and Dutchess County DPW (Old Hopewell Road). The Applicant must demonstrate approvals from these agencies prior to site plan approval and obtain permits prior to commencement of work; no such approvals have been demonstrated in the record to date. 4. Lighting Com fiance Town Code 240-23 §240-86(F) o The Applicant's lighting submission lacks acomplete photometric plan demonstrating foot-candle levels and interactions of proposed and existing lighting;; and the luminaire schedule contains inconsistencies between counts and depicted locations, 5, Plan Completeness and Engineering Details Town Code 240-84 o Additional construction details are required, including asphalt/pavement, curbing, and island details; clarification of a "Sidewalk with Grass Plot" detail; addressing potential ponding from a 24 -Inch gutter at the mountable curb; details for all new/rebuilt curbing; depiction of existing trees potentially impacted along the north side by curb relocation and 2 -ft pavement expansion; depiction of the existing on-site sewage disposal area, clarification of jurisdictional requirements along State and County rights-of-way, and providing associated notes and details as required by the NYSDOT and Dutchess County DPW. 5. Zoning Nonconformities and Potential Variance Town Code 240-88 o The plan indicates front setback nonconformities related to properties on two County/State highways (75 feet each per Town Code Chapter 240, Attachment 4). While existing conditions may be legally nonconforming, enlargement of the canopy footprint may require a variance; the Applicant has not demonstrated that a variance is unnecessary or that relief has been obtained. 7. Applicant Submissions and Responses o The Applicant's May 22, 2025 narrative asserts revisions addressing traffic flow and maneuvering, including revising the delivery truck to exit to Route 9 North, updating truck dimensions, adding parked cars to templates, adding photometrics and landscaping pages, proposing a mountable curb channelization with details, adding curbing/pavement replacement details, and changing canopy design; however, the Planning Board's consultants identified continuing deficiencies and safety concerns as outlined above, and the Applicant has not incorporated the Board's traffic operational recommendations to resolve internal conflicts and queuing impacts. CONCLUSIONS OF LAW 1. Site Plan. Approval Standards Based on the record, the Board finds that the Project fails to demonstrate safe and adequate on-site circulation and access management, faits to mitigate documented queuing that encroaches toward U.S. Route 9, and does not resolve conflict points exacerbated by the proposed fueling position orientation and increased site traffic identified by the Town's traffic consultant, resulting in adverse traffic and safety impacts inconsistent with applicable site plan standards under Town Zoning Law Chapter 240. See Town Code §240-83, §240-84, §240-86 2. Agency Approvals as Prerequisites. The Applicant has not provided evidence of necessary NYSDOT and DCDPW approvals and permits for work affecting U.S. Route 9 and Old Hopewell Road. Given County DPW's prohibition on removing channelization and the delivery truck lane blockage concern at Old Hopewell Road, the absence of agency approvals further precludes a finding that access and circulation will be safe and adequate, See Town Code §240-84(8), §240-86(B), § 240 -86(H) -(I) 3. Pian Com leteness and Com fiance. Lighting submissions are deficient and noncompliant with the applicable requirements of Section 240-23 of the Town Code; plan details remain incomplete; potential vegetation impacts and on-site septic features are not shown; The application therefore fails to satisfy the completeness and technical sufficiency necessary for approval. See Town Code §240-23, §240-84 4. Variance Contingency. The potential enlargement of the canopy footprint may necessitate a front setback variance. No such variance has been granted, and the Applicant has not demonstrated compliance or that the Project would not become more nonconforming. See Town Code §240-38 5. SEQRA, The Proposed Action is Type 11; no further SEQRA action is required. NOW, THEREFORE, BE IT RESOLVED, that the Planning Board hereby denies the application for Amended Site Plan Approval for the Project at 1336 Route 9, Tax Lot 6157-024614569, for the following reasons, each of which is independently sufficient for denial and all of which collectively warrant denial: 1. Traffic and Safety. The Applicant failed to demonstrate that internal circulation, access operations, and fueling position orientation will provide safe and adequate traffic flow and will not exacerbate queuing that presently backs toward U.S, Route 9; the Applicant has not incorporated the Board's traffic consultant's recommended operational restrictions to mitigate internal conflicts, and crash data evidences existing safety issues requiring mitigation not provided by the application. 2. Reguired Agency Approvals._ The Applicant failed to submit evidence of necessary approvals/permits from NYSDOT and DCDPW for work and operations affecting U3. Route 9 and Old Hopewell Road; DCDPN's prohibition on removing channelization and concern regarding WB -50 blocking lanes further constrains feasible design and remains unaddressed, 3. Lighting Noncompliance and Plan Deficiencies. The application lacks a compliant photometric plan, , and contains inconsistencies in luminaire countsllocations; construction and site details remain incomplete; existing trees potentially impacted are not shown; and existing septiclsewage disposal features are not shown, 4. Zonina Compliance/Variance. The plan indicates front setback nonconformities that may be intensified by canopy enlargement and may require a variance; no variance has been obtained, and compliance has not been demonstrated. BE IT FURTHER RESOLVED, that the Planning Board's denial is without prejudice to a future, duly filed amended application that comprehensively addresses the foregoing deficiencies with revised plans, agency determinations/permits, safety and circulation measures consistent with the Town's traffic consultant recommendations or equivalent engineering solutions, complete lighting compliance or requested waivers, and all required engineering, landscaping, and health department documentation. The question of the adoption of the foregoing resolution was duly put to a vote on roll call, which resulted as follows: The question of adoption of the foregoing resolution was duly put to a vote on roll call, which resulted as follows: Bruce M. Flower AYE Paul Freno AYE Markos Peratikos NIA Thomas Truss Jr. NIA James Glorioso AYE Richard Barth AYE Robert Meehan AYE The resolution is hereby duly declared adopted. Dated: January 21, 2026 Wappingers Falls, New York Bruce M. Flower, Chairman Town of Wappinger Planning Board o� 19 Date