Editor’s Note: The author is the executive director of SECoast.

If the ends justify the means – and supporters are willing to overlook a flawed planning process, a dubious subdivide and shell corporations designed to skirt environmental regulation – we ask simply that the public and Zoning Commission members consider carefully the true character of those ends.

Surely, it’s never been the case that a failure of ends can justify a failure of means. But failed—and at best uncertain ends—are exactly what Hope Partnership, Women’s Institute, and attorney David Royston asked members of the Commission to approve last night in an effort to establish an aura of inevitability and bureaucratic momentum for the project.

At the very least, we expected the applicants to resolve those issues directly acknowledged under health and safety rules as the basis for their request for a continuance on July 11, 2018. Pedestrian safety? Months later, still crickets. Really, how is it possible, that plans submitted last night included a crosswalk between residences and the community center within the development, but failed to address pedestrian safety and a crossing of Route 156 to the nearby shopping district?

In defense, attorney Royston leans heavily on the letter of the law, but what he does not explain is that a street design can be defective—and thus unsafe—even if the design is otherwise legal. Years ago, the design for I-95 between Exit 70 and Exit 74 met the letter of law, but as we understand now, the geometry of the roadway was fatally flawed. Oh the irony, that we might repeat a similar mistake in the very same location.

We understand that many of the numerous issues of health and safety considered separately may not rise to the high bar of outweighing the real public good of affordable housing, but to be clear as a matter of the law, these issues should not be considered separately – a practice called segmentation – but rather as a meaningful whole. As Ms. Marsh, and others have pointed out amply in questioning safe exit and entrance to the property, it’s possible that each sightline considered as a piece is sufficient, but considered together, lack commonsense and safety.

We believe that this project makes that same error of segmentation not once, but many times over, aided too often by fibs and later revisions along the way to secure the aid and approval of various boards, commissions, and bodies, including (but not limited to) misleading filed papers to secure the subdivide, the promised recusal of counsel and ‘completed’ water testing to secure approval of wetlands, the use of shell corporations and the subdivision to avoid DEEP oversight and regulatory standards for a project of this size, the steady growth of the project over the course of months from a dozen or 16 units to 37 units and 950 ft of retaining walls reaching to eight feet in height. You might ask yourself why these retaining walls were never a serious topic of conversation at the Inland Wetlands hearing earlier this year. Perhaps, it’s because they weren’t in the plan approved at the time.

Now the applicants ask that the commission members and the public put this all aside and approve a project without solutions in place even for automobile traffic, water or septic; without designs which comply with the 2018 Fire Code. If this constitutes sufficient planning, truly we wonder what an incomplete or inadequate plan for the applicant would be. Really, are we to believe that nonexistent or endlessly variable plans better meet the rules of health and safety, than mere bad plans? We remain unconvinced.

For months, the best defense this plan had was the apparent – we were repeatedly promised – lack of a better location. We fully understand those who might embrace the good of affordable housing when presented with such a solitary opportunity. But it appears that even this is untrue, as already last night Kristin Anderson of the Women’s Institute made clear that this project was the first of others already contemplated or in part planned in Old Lyme. We strongly advise the community, the Commission, and the applicants to leave aside the current project, and embrace these other alternatives.