We the undersigned citizens of Sussex County, Delaware, residing in or around the Angola Neck area oppose the approval of the proposed Terrapin Island Cluster Subdivision. This proposed new subdivision is located on a parcel that is zoned AR-1 and considered to be in the Coastal Area, to include marsh land, wetlands and the floodplain, and an area designated as Investment Level 4 pursuant to the State’s 2020 Strategies for Policies and Spending.

The basis of our opposition is well stated in the May 25, 2021, letter from the Delaware Office of State Planning and Coordination to the developer and the County, with selected portions of this letter provided below:

“This project represents a land development that will result in 42 residential units in an Investment Level 4 area and an Out of Play area according to the 2020 Strategies for State Policies and Spending. Investment Level 4 indicates where State investments will support agricultural preservation, natural resource protection, and the continuation of the rural nature of these areas. New development activities and suburban development are not supported in Investment Level 4. These areas are comprised of prime agricultural lands and environmentally sensitive wetlands and wildlife habitats, which should be, and in many cases have been preserved. Out of Play reflects lands that, at the time the State Strategies were developed, were not available for private development due to public ownership and/or preservation.”

“From a fiscal responsibility perspective, development of this site is inappropriate. The cost of providing services to development in rural areas is an inefficient and wasteful use of the State’s fiscal resources. The project as proposed will bring a new residential development to an area where the State has no plans to invest in infrastructure upgrades or additional services. The intended development will need access to services and infrastructure such as police, and transportation. To provide some examples, the State government funds 100% of the cost of police protection in the unincorporated portion of Sussex County where this development is proposed. Over the longer term, the unseen negative ramifications of this development will become even more evident as the cost of maintaining infrastructure and providing services increases.”

“In addition, this site is environmentally inappropriate. The existing plans pose both flooding risks and considerable impacts to wetlands and wildlife habitat. The entire parcel is located within both the Delaware Ecological Network and the Angola Neck Natural Area. The site plans propose the removal of significant amounts of mature forest that are a key part of these larger ecological systems. Impacts to non-tidal wetlands include proposed disturbance of wetlands, secondary impacts, and the disconnection of large expanses of contiguous habitat. Future residents will likely face flooding concerns, which will be further exacerbated by sea level rise in the near future.”

The above comments comport with the Comprehensive Plan requirement that special scrutiny of development plans proposed in Investment Level 4 areas be given to ensure these activities are consistent with State and local development and preservation policies. Terrapin Island clearly is not consistent with these policies.

We maintain that approval of this proposed cluster subdivision by the Sussex County Planning & Zoning Commission will result in direct injury or harm to the undersigned and other citizens of Sussex County. The State’s comments set forth above along with additional pertinent comments contained in its May 25, 2021, letter discussing the environmental and fiscal harm posed are unrefuted by any evidence of record in this matter. Moreover, since neither the Planning & Zoning Commission nor the County Council have the authority to burden the State fiscal resources without its consent, the approval of this subdivision would constitute an ultra vires act by our local government.

WE URGE YOU TO DENY THIS APPLICATION.