HomeMy WebLinkAboutLetter #09 Todd & Melisa KeiserMay 11, 2023
RE: Plan Commission Hearing re: Schafer/Pulte Andrews PUD
Carmel Plan Commission
c/o Joe Shestak, Secretary
jshestak@carmel.in.gov
Dear Plan Commissioners,
We are wriLng you as homeowners in the Gray Oaks subdivision, regarding the proposed development of the
adjacent acreage to the north of Gray Oaks with frontage on 146th Street in Carmel (aka Schafer/Pulte Andrews
Planned Unit Development District (Andrews PUD)). We understand that there is a Carmel Plan Commission
hearing on May 16, 2023, regarding the proposed development of this property and we are providing this
leUer/email as wriUen tesLmony for consideraLon. We also plan on aUending the hearing.
We have summarized many points here iniLally but have also provided the aUached pages to this leUer to provide
addiLonal detail about the impact we believe the high-density development of Andrews PUD project would have
on the Gray Oaks neighborhood, parLcularly if access is provided at the south boundary of the property into the
Gray Oaks neighborhood via Gray Oaks Court. Details include:
1.Concerns regarding the planned access point via Gray Oaks Court and how this has been represented to
current residences since the iniLal development of Gray Oaks.
2.Concerns about the traffic impact of allowing this access point through the Gray Oaks neighborhood, and
the insufficiency of the developer’s traffic study. We believe that given the restricLons to access
from/onto 146th Street the access through Gray Oaks will essenLally become the primary access point to
this development.
3.Concerns regarding construcLon traffic through the Gray Oaks neighborhood. These are in large part
similar to the overall traffic concerns; however, construcLon traffic should be addressed by the developer
regardless of whether an access point through Gray Oaks is approved due to the restricLons of access
onto/off of 146th Street.
4.Concerns over the current safety issues that exist at the intersecLon of Wellswood Bend and McCormick
Circle, and at the intersecLon of Wellswood Bend with Gray Road, and how these unsafe condiLons would
be exacerbated by adding traffic to these intersecLons.
5.Concerns regarding the construcLon quality and the compaLbility of HOA restricLons regarding street
parking within the proposed new development which would impact the Gray Oaks neighborhood.
6.Concerns with possible development of the Bardonner land east of Gray Oaks, parLcularly with the
locaLon of the stub street and potenLal request of an easement and addiLonal traffic paUern issues.
7.Exacerbated pond drainage concerns made worse by the new build of Andrews PUD.
8.In light of the recent elecLon and many claims of “transparency”, current level of support of this project
from the City Zoning Board, Technical Advisory Board and City Council members.
9.And lastly, given these concerns we peLLon the Plan Commission to deny the proposed Andrews PUD (as
a change from the current zoning of R-1 ResidenLal), as the change in zoning would mulLply the negaLve
impacts noted above via an increase in density.
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We hope that you will consider this input and invite you to contact us if you have further quesLons regarding
the arguments we put forward. We look forward to the hearing on May 16, 2023.
Todd & Melisa Keiser
4736 Gray Oaks Drive
Carmel, IN 46033
melisa@carmeltravelcompany.com and todd@bonedry.com
317-292-8551 and 317-362-2402
Cc: Carmel City Council RepresentaLve Sue Finkam:
sfinkam@carmel.in.gov
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The below concerns stem from listening to the February 2023 Technical Advisory Commi=ee (TAC) hearing:
We are also concerned about the development of the Bardonner land (property to the East of Gray Oaks).
Apparently there have already been discussions between this owner and the developer regarding the
locaAon of the stub street, primary quesAon was whether the developer of the Andrews PUD would be
requesAng an easement. There was no answer provided in the TAC hearing. But we believe that connecAvity
to this acreage is an issue. If plans proceed for the expansion of the Gray/146th intersecAon, AND this
'property to the east' is developed, it is likely that there will be limited access via Gray Road (only turning
right) and that access would come through the Andrews PUD and in turn, through the Gray Oaks access point
if permiRed. This further amplifies concerns regarding the traffic load onto Wellswood Bend as already
expressed.
Concerns raised by the City of Carmel engineer as to the drainage reserve (pond) and whether it was
adequate to handle the run-off from the build-out areas. The developer indicated that this was being
addressed. However, we believe that this quesAon is very perAnent to the Gray Oaks residents as we already
have issues with the retenAon ponds in our neighborhood, parAcularly ferAlizer rich run-off from Salisbury
that is causing vegetaAon issues in our ponds, and we are interested as to whether these concerns will be
fully addressed.
One of the few quesAons (may have been the ONLY quesAon - it stands out) pointedly asked by the
developer to any of the TAC members was directed to the City of Carmel Engineer - asking if he was
'supporAve of the connecAon to the south of the development' (aka the Gray Oaks access point) wherein the
engineer replies, somewhat ambivalently, that yes, generally there is an expectaAon that there would be
connecAvity. We are concerned that this exchange was prior to any traffic study being available (although as
previously noted, the traffic study performed is inadequate), and does not address why there is a ROW
easement, but not a stub street as required at the Ame of Gray Oaks development. It seems as though the
developer was trying to pin down a commitment/support to this before all data was available.
Near the end of the TAC meeAng, Alexia Lopez, Planner for the city brought up the issue of construcAon
traffic; she said, 'I don't know if this needs to be covered in the PUD or not' but 'prior standard would be to
have construcAon traffic to be off of 146th, and it would 'probably be the plan to try not have construcAon
traffic come through the neighborhood to the south'. The developer rep answered with a vague 'uh huh'.
When the same developer was asked about how construcAon traffic would be managed, at the neighborhood
meeAng on May 3, 2023, he deflected the quesAon to be addressed by the City of Carmel.
Our interpretaAon as to items 3) and 4) above are that the access point, through Gray Oaks Court is
recognized by the developer to be the PRIMARY access point into the Andrews PUD. It is NOT a point of
general connecAvity, as the developer is aRempAng to represent and have supported by the City of Carmel
Engineer, but the PRIMARY access point, given the restricAons off of 146th Street. Why else would this be a
key quesAon asked by the developer? The developer is likely very aware that there will be issues with
construcAon traffic through the neighborhood streets, and this is regardless of whether there is an access
point through Gray Oaks Court, yet there seems to be no plan to address this.
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Impacts of the Proposed Andrews PUD on the Gray Oaks Neighborhood as developed by Jayne Gates
1. Allowing access through the Gray Oaks neighborhood
The Andrews PUD proposes an entrance to the south of the property that would connect with Gray Oaks
Court. This is of great concern (and surprise) to Gray Oaks residents, and we believe that this access will
increase traffic, cause safety concerns, and decrease property values within our neighborhood. It is unclear
as to whether this access was previously considered when Gray Oaks was constructed. On one hand, the
UDO and presumably the preceding ordinances seemed to require that neighborhoods provide stubbed out
streets to adjacent undeveloped properAes. Other contemporary developments in our vicinity clearly
provided stubbed street to offset acreage. Yet, Gray Oaks Court was c onstructed as a cul-de-sac (presumably
with City of Carmel acknowledgment), is clearly indicated as a cul-de-sac on all public GIS map sources and
being called a ‘Court’ would certainly lead one to believe that was intended as a dead-end street. As well, it
appears that there is a fire hydrant that would impede a stub street from being constructed and this suggests
it was never intended to be a through street. As property owners in this relaAvely new neighborhood, this
access point seemingly would serve to increase traffic and decrease property values. We quesAon whether
this situaAon was an intenAonal decepAon by the developer (Old Town) and what role the City of Carmel may
have had in this situaAon.
2. Impact of traffic flow on the Gray Oaks neighborhood if Gray Oaks Ct access is allowed
The plan for the Andrews PUD specifies that traffic flow onto 146th Street can only occur by right turn, going
to the east, and traffic flow off of 146th will only be possible from the west, right turn into the property. I
understand that this restricAon has been required by the county. The property developer had a traffic study
performed in February 2023 to assess the impact on area traffic. This study primarily addressed how the
increase in homes (60) would impact the intersecAon of Gray Road and 146th Street. (I presume that this
study has been provided to the Plan Commission).
The traffic study seems to be insufficient as it did liRle to address the impact on providing access through
Gray Oaks and instead primarily focused on the impact on the Gray Road/146th intersecAon. The scope of
the study designates that the only traffic counts that were gathered during the study period were at the
intersecAon of Gray Road and 146th Street. Yet p rojecAons are made in the study as to the percentages of
traffic that would use the Gray Oaks Court point for entry and exit at peak hours. There is liRle to no data
provided as to how these percentages were developed. To quote the study, under the heading of Assignment
and DistribuAon of Generated Trips:
The study methodology used to determine the traffic volumes from the site that will be added to the
street system is defined as follows:
1. The volume of traffic that will enter and exit the proposed development must be assigned to the
access points and to the public street systems. Using the traffic volume data collected for this
analysis, traffic to and from the site development has been assigned to the proposed driveways
and to the public street systems that will be serving the site.
2. To determine the volumes of traffic that will be added to the public roadway system, the
generated traffic must be distributed by direcAon to the public roadways at their intersecAon
with driveways. For the proposed development, the trip distribuAon was based on the locaAon
of the development, the exisAng traffic paRerns, and the assignment of generated traffic.
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These statements do liRle to explain how the study draws conclusions as to how much of the traffic would
choose to access the development from the Gray Oaks access point and we strongly quesAon the conclusions
in the study that say that only 27% of the traffic out of the neighborhood, and 55% of the traffic into the
neighborhood would be via this Gray Oaks access point. Having lived in Gray Oaks for almost 3 years, and
understanding my own ingress/egress routes, I believe that the traffic study has flaws in esAmaAng how liRle
traffic would use access through the Gray Oaks neighborhood, if provided.
With the limited access being allowed from 146th Street I believe that these numbers are significantly
understated, and I provide the following anAdotal evidence to support this belief.
Exit to Gray Oaks is underesQmated. The study projects that just 27% of the traffic exiAng the
Andrew PUD area will go through Gray Oaks. It projects that the remainder (73%) exits onto 146th
Street, going east (right turn). Of this traffic onto 146th going to the east, it then projects that 23% (of
the total exiAng the development) will travel to the Gray Road intersecAon and make a U-Turn back
to the west. This seems very unlikely if the alternaAve is to go through Gray Oaks, onto Gray Road
(going north) and use the Lek Turn light onto 146th Street. Likewise, the study esAmates that 12%
going north on Gray Road, and 5% going south on Gray Road will exit the development onto 146th
Street and then access Gray Road via the intersecAon with 146th Street. Again, this is unlikely when
there is direct access through the Gray Oaks neighborhood onto Gray Road. By canvas of neighbors
in Gray Oaks, essenAally at the same locaAon that the Gray Oaks access point would provide, these
opinions are widely supported, even though today we have opAons to cut through Stafford
neighborhood to access 146th and Gray Road. If these consideraAons are correct, about 2/3 of the
traffic (not 27%) would choose a route through the Gray Oaks neighborhood when exiAng.
Entrance via Gray Oaks is underesQmated. Likewise, the traffic study says that 55% of the traffic
entering the Andrews PUD would travel through the Gray Oaks neighborhood. This too could be
understated as generally traffic coming up Keystone is routed to exit onto Main Street, travel east,
and come up Gray Road to our neighborhood per Google maps, in order to avoid congesAon and
lights on 146th Street. Personally, this is my preferred route as well, as the roundabouts on this route
are much more efficient in moving traffic along. As well, since the Andrews PUD does not propose a
right turn lane off of 146thand given that there is a right turn lane at the next street to the west
(Alderbrook) it is likely that many may choose to exit onto Alderbrook, uAlizing this safer alternaAve
(a slowdown lane), and then travel into the Andrews PUD via Gray Oaks Court. Therefore, I believe
that a porAon of the traffic noted in the 45% entering the neighborhood off of 146th will be added to
the 55% that is designated in the study , thus making this the primary point of access.
The traffic study states Gray Oaks traffic will likely access 146th Street via the development. I find
this statement to be enArely false. Canvasing of current residents indicates that virtually all exit
currently to Gray Road (although there is access today directly up Wellswood Bend/Alderbrook). The
study provides no data to back up this statement.
In summary, it would seem that if access is provided through Gray Oaks Court, this would essenAally become
the primary access point to the proposed Andrews PUD, transforming a street that the Gray Oaks residents
were led to believe was a cul-de-sac, into the primary entry to a proposed denser development. Given this
view which widely shared by neighbors within Gray Oaks and Stafford, I recommend that the Plan
Commission require the developer to provide a more thorough and complete traffic study, that would provide
actual data reflecAng traffic choices made by current residents.
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3. ConstrucQon Traffic Impact on Gray Oaks neighborhood
Earlier discussions with the developers indicated a willingness to aRempt to keep construcAon traffic off of
Gray Oaks streets. However, with the understanding of restricted flow of traffic off of and onto 146th Street,
this would seem to be very difficult to achieve, and equally difficult to then enforce. Referencing notes above
regarding the current general traffic flows, it is likely that construcAon vehicles from the east would unable to
access the site off of 146th, unless they were to make a U-Turn at some point, or as an alternaAve take an
alternate route to come in from the west (e.g. south on Gray Road, west on Smoky Row, north on Carey, then
east on 146th Street). It is unlikely that construcAon contractors would be easily convinced to use this route
and would instead choose to travel through Gray Oaks if this were an opAon. Of course, if the access through
to Gray Oaks was not provided, this would be a lesser issue, however, it is sAll likely that traffic from the east
would favor to travel south on Gray to Wellswood Bend and out onto 146th via Wellswood Bend/Alderbrook
(Stafford neighborhood), thus coming in from the west on 146th Street.
In order to miAgate the concern regarding construcAon traffic coming through the Gray Oaks (and Stafford)
neighborhood, I believe that the developer should be required to develop a ConstrucAon Traffic Plan that
bypasses neighborhood streets. This plan should be required as a ‘Commitment’ of development approval, to
be provided to all Contractors, and the developer should be required to report on compliance with this plan
to the appropriate City of Carmel authority on an ongoing basis.
4. Vehicle/Pedestrian Safety Risks that would be exacerbated with added traffic through Gray Oaks
In the event that the proposed development is approved, and access through Gray Oaks Court is also
approved, the safety risk due to increased traffic on Wellswood Bend should be addressed. In the area of
Wellswood Bend and the intersecAon of McCormick Circle, improvements in signage and the addiAon of a
crosswalk should be considered. Currently traffic traveling eastbound on Wellswood Bend has a stop sign at
the boRom of the hill, aker the bend, at the intersecAon with McCormick Circle. Drivers seldom come to a
stop, and many barely slow down when taking the right turn toward Gray Road. Pedestrians crossing
Wellswood Bend (from the northwest side to the southeast side) at this point are at risk of being struck by
speeding drivers who do not observe the stop sign and travel at excessive speed around the bend. The
addiAon of a warning sign (‘Stop Ahead’) and a marked crosswalk crossing Wellswood Bend would help to
miAgate this safety risk.
A further safety risk exists at the intersecAon of Wellswood Bend with Gray Road. Due to a dip in Gray Road
to the north of Wellswood Bend (near the entrance to the gas staAon), drivers entering onto Gray Road
cannot see traffic traveling south unAl these vehicles have crested the small hill and are quickly approaching
the intersecAon. This situaAon could be also exacerbated by the speed limit change from 40 mph north of
146th, to 30 mph south of 146th, causing some drivers to conAnue at speeds exceeding 30 mph. ConversaAon
with many Gray Oaks neighbors confirms that this is a risky situaAon, and several have nearly been hit when
pulling out on Gray Road. I am uncertain as to how to miAgate this situaAon but possibly the addiAon of
signage indicaAng to Gray Road southbound drivers that a ‘Hidden Drive Exists’ ahead would help.
Obviously if the traffic flow is increased, due to the proposed development connecAng into Gray Oaks
Court/Wellswood Bend, these traffic risks will increase. Currently residents from the subdivisions to the west
of Gray Oaks travel this route when either 1) traveling south on Gray Road (avoiding the light at 146th St and
Gray Road), or 2) when intending to travel west on 146th, choosing this route in order to gain safer access to
146th. As indicated above, I strongly feel that residents of the proposed development will likewise choose to
travel through Gray Oaks for similar reasons. I propose that the City of Carmel assess and consider the costs
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of improvements for both of these intersecAons prior to approving the adding of more traffic onto Wellwood
Bend.
5. ConstrucQon Quality and Street Parking
Regarding the appearance and quality of construcAon of the proposed townhomes and duplexes, they should
be modeled aker the general construcAon materials and methods used in the Gray Oaks subdivision. As well,
when HOA restricAons are being developed for the new area, they should include a review of the Gray Oaks
HOA restricAons. One element that needs to be considered before approval of the Andrews PUD is on-street
parking. Gray Oaks currently limits regular on-street parking by residents. It appears from the proposed
development plan that there is very liRle overflow parking included in the proposal. With the proposed
density of the homes, it appears that providing for off-street overflow parking areas in order to avoid regular
on-street parking would be advisable and should be a condiAon of development. On street parking within the
development will also contribute to congesAon and safety issues.
6. Concerns regarding Change of Zoning from R-1 ResidenQal to Andrews PUD
It is my understanding that the Andrews PUD proposal requests that the zoning be changed from R-1
residenAal (the most restricAve of residenAal zoning in regard to spacing and dwelling size) to the PUD
specificaAons that call for duplex and townhome development. While my personal interests are that no
development take place on the subject property, I come from a background in business and industry and
understand that property rights (including the right to develop within current regulaAons and zoning) must be
respected. That said, regional consistency of developments resulAng in cohesive communiAes, and
protecAon of exisAng property values are the result of effecAve zoning applicaAon. I believe that zoning
integrity is a valued quality for a community.
The developer of the Andrews PUD notes the benefits of the proposed development align with the City of
Carmel Comprehensive Plan 2020. ParAcularly, as it pertains to the plan for higher density, smaller homes, it
notes the benefit of providing for a housing type that allows current residents an opAon for right-sized
housing and an opportunity to ‘age in’ Carmel. While I support this intenAon of the City of Carmel, I suggest
that it NOT be accomplished by a strategy of zoning changes in reacAon to individual change requests.
Achieving this goal through incremental, independent zoning deviaAons in a scaRered fashion would seem to
have a large impact on current residents surrounding each zoning deviaAon. Instead, if the City of Carmel is
serious in its aRempt to achieve this goal, the Plan Commission should proacAvely study where and how this
goal should be achieved and make regional recommendaAons with public input. On this note, there are a few
other parcels of undeveloped land in close proximity of this proposed development. I am concerned that if
one zoning change is allowed, it will result in others making similar requests, and it will become difficult to
deny these once a precedence has been set.
I do not believe that the Andrews property owners provide a sufficiently compelling argument for proposed
zoning deviaAon that would jusAfy diminishing the integrity of zoning regulaAons and ignoring the interests of
exisAng neighborhood property owners. The Carmel Unified Development Ordinance (UDO) ArAcle 1.04
states as one purpose of the UDO “G. CompaAbility: To bring about compaAbility between different land uses
and to protect the scale and the character of exisAng development from the encroachment of incompaAble
uses or intensity.” Thus, I peAAon the Plan Commission to not grant the proposed the Andrews PUD.
In summary, I have expressed concerns above regarding the significant impact on the Gray Oaks
neighborhood if development of the adjacent property were to progress with restricted access onto/off of
146th Street, and the majority/primary access being through Gray Oaks Court. I fail to see how the Plan
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Commission can jusAfy the Andrews PUD as proposed, as it would not only fail to miAgate these concerns but
would further exacerbate the traffic and safety issues by increasing the density by 2-3 Ames the R-1 zoning
density. Residents of Gray Oaks are generally long-Ame Carmel residents that downsized by relocaAng into
the neighborhood and made significant investments in their homes based on current zoning designaAons,
believing that the R-1 zoning of all adjacent property would protect this investment, with the Plan
Commission as its steward. We are fairly united in our views toward rezoning of the proposed Andrews PUD.
Deciphering the "Traffic Impact Study" by Ralph Roper
Aker reading Jayne Gate’s in-depth analysis of the adverse impacts the proposed “Andrews PUD” would have
on our neighborhood, I sat down this morning and studied the engineer’s “Traffic Impact Study” in an effort
to decipher how much of the traffic into and out of the proposed development would most likely be imposed
on our neighborhood via the Gray Oaks Ct. south entrance.
Like Jayne, I too am an engineer, and conAnue to be a registered professional environmental engineer in
Indiana. Because the engineer’s study focused solely on 146th St. impacts, several of assumpAons they made
were obviously geared towards a worst-case scenario that maximized impacts on 146th street. However,
those same assumpAons produced unrealisAcally low esAmates of traffic impacts on our neighborhood
streets, i.e., Gray Oaks Ct. and Wellswood Bend. Accordingly, I modified some of their assumpAons to more
accurately reflect normality to develop what I believe are more realisAc esAmates of the traffic that would
likely be imposed on our neighborhood.
The results are illustrated in the aRached drawings. Figure 1 illustrates traffic routes entering the proposed
development. Though not menAoned, the engineer’s report indicated 74.4% of the entering traffic would
likely via Gray Oaks Court! Moreover, I believe it can be reasonably assumed that about half of the drivers
approaching the proposed development from the west on 126th street would prefer to turn right onto
Alderbrook Trail using the safety of the turning lane (see dashed lines in Figure 1). As indicted in Figure 1,
revision of the engineer’s esAmates using this new assumpAon suggests that over 87% of the traffic entering
the proposed development would be through our neighborhood via Gray Oaks Court.
Figure 2 illustrates traffic routes exiAng the proposed development. As indicated by the first bullet, the
engineer’s report indicated only 16.7% of the traffic leaving would use the Gray Oaks Ct. exit to south.
However, the esAmate was based on an unrealisAc assumpAon that 17.7% of drivers leaving the proposed
development east onto 146 St. would do a U-turn at the Gray Rd. intersecAon to head west. Not too
surprisingly, the engineer’s field data reported in the appendix indicated essenAally zero U-turns at that
locaAon. Thus, as indicated by the second bullet in Figure 2, eliminaAng that assumpAon increased the
percentage using the proposed Gray Oaks Ct. exit to 31.5%. The engineer’s traffic report also assumed the
desAnaAon of travelers leaving the proposed development would be heavily skewed in favor of an easterly
direcAon. That assumpAon development would be heavily skewed in favor of an easterly direcAon. That
assumpAon is unrealisAc because the development, like ours, is very centrally located with growing
communiAes in all direcAons. Assuming that travel desAnaAons to the North, South, East and West are all
equally distributed, the most likely result would be that about 50% of the
traffic leaving the proposed development would be through our neighborhood to the south. This simply
assumed the 50% of those heading south would exit from Gray Oaks Ct.; 50% of those heading north would
exit from 146th St.; 100% of those heading east would exit from 146th St. and 100% of those heading west
would exit from Gray Oaks Ct.
CollecAvely these revised esAmates suggest that about 87% of the traffic entering and 50% of the traffic
exiAng the proposed development would be through our Gray Oaks subdivision via Gray Oaks Ct. Thus, as
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you recently stated, the traffic issue is HUGE. I think we all agree that Gray Oaks cannot absorb the amount of
traffic generated from a 60-unit development that logically would travel through our neighborhood to access
Gray Road and 146th. Further, the safety issue as well as preservaAon of our neighborhood atmosphere are
also very concerning.
Please also see the aRachment with Roper – Drak IllustraAons Gray Oaks Traffic Impact.
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Figure 1 – Estimates of Traffic Volumes Entering the Proposed Development via Gray Oaks Ct.Traffic Entering from South via Gray Oaks Court: Assuming 0% use of Alderbrook Trail Route : 74.4 % (per Fig. 6 of A&F Engr. Report)Assuming 50% use of Alderbrook Trail Route: 87.2%Prepared by Ralph Roper/ resident ‐ Gray Oaks Subdivision / May 8, 2023
Figure 2 – Estimates of Traffic Volumes Exiting the Proposed Development via Gray Oaks Ct.Traffic Exiting from South via Gray Oaks Court: Assuming 17.7% U‐Turns at 146th St. & Gray Rd. per Fig. 6 of A&F Engr. Report: 16.7%Assuming no U‐Turns at 146th St. & Gray Rd: 31.5% Assuming North, South, East & West travel destinations are equally distributed: 50.0%Prepared by Ralph Roper/ resident ‐ Gray Oaks Subdivision / May 8, 2023