NYSDEC Compilation of Comments
from Clough Harbour & Associates LLP
Comments Specific to Final Scoping Document

3.7 Traffic Patterns

A traffic study will be performed in order to characterize the existing local road network and traffic volumes.

A traffic impact study will be performed for the proposed action to assess the potential impact of project construction and operation on local traffic patterns and roadways. The traffic impact study will be included as an Appendix in the DEIS.

This section is present though the analysis limits the study area to a section ofthe Route 28 corridor. The DEIS indicates that various existing commercial establishments (specificaliv the gas stations and supermarkets) in surrounding communities will absorb additional demand far services and products. There is little or no mention of these establishments in the traffic portion of the DEIS. The few establishments mentioned should be examined from a traffic impact perspective as there will be probable impacts in these areas, especially considering many of these establishments are on the south bound side of Route 28. Motorists coming to the proposed resort may/will stop for gas, supplies or groceries, and will be crossing travel lanes for ingress/egress.

The DEIS will also provide an inventory of local pedestrian traffic in the vicinity of the proposed project site. This section of the DEIS will also describe the current availability of off-street parking in the vicinity and discuss current parking in relation to what would be necessary for any special event.

This section of the scope is poorly addressed in the DEIS. Special event parking is not covered, and is a very important aspect of the management of traffic in the area of the proposedfacility. Roadways in the area of the proposed project are somewhat narrow, and overflow parking on these roadways would cause a burden on the local road system. A thorough analysis of overflow parking and contingency plan should he included in the DEIS.

An assessment of potential vehicular and pedestrian conflicts will be included in the DEIS along with mitigation measures for any potentially significant impacts that are identified.

It has been indicated in the DEIS that there will be very limited pedestrian traffic on the proposed site due to the extensive use of a shuttle system. It should be anticipated that guests would choose to walk and enjoy the outdoor atmosphere of the Catskills and tend to walk regardless of provided transportation. Pedestrian safety on and off site is of paramount importance, with an emphasis on safety in theparking areas and in the enclosed parking area. A detailed discussion on pedestrian safety should be provided, specifically addressing safety provisions that can or will be provided, such as dedicated pedestrian walks, pedestrian refuges in high traffic areas, crosswalks and other modern pedestrian friendly amenities. A discussion should also be included outlining safety measures to be provided between pedestrians and the golf carts that will undoubtedly be used on the resort.

3.8 Land Use and Community Character

Include assessments of recent aerial photographs and land use maps of the site and surrounding areas, generally the Route 28 corridor from Boiceville to Margaretville. Discuss past use of the property and local community.

An assessment of the immediate project site is included and well documented in the DEIS. However, the DEISfails to provide derailed information on surrounding areas of Boiceville, including the past uses of properties in the corridor. A very limited discussion on the local community is included in the DEIS but should include a more thorough history of the communities that the project has the potential to impact. History should include information derivedfrom focal historians regarding thepast economies ofthe communities, and the changes that have occurred over the decades to the current state of the communities.

Describe how the proposed project and the required land use planning decisions could affect existing and possible future land use and community character, including Belleayre Mountain Ski Center.

The DEIS states that no significant impacts will occur as a result of the proposed project. It is indicated that off site development will be negligible, and only result in in-fell of the local hamlets and villages in the study area Currently, the Belleayre ski center serves mainly as a day-drip destination as it does not offer overnight accommodations. Overnight accommodations are limited in the vicinity of the ski centerfor visitors to stay off site. The proposed project would provide extensive overnight accommodations that could potentially impact the ski center severely. The DEIS does not indicate the maximum capacity that the ski center is equipped to handle or the overall number of possible patrons that would visit the ski center as a result of the project It is likely that the overall traffic will substantially increase at the ski center, creating additional demand for employees to operate the center. This topic is not discussed in the DEIS, and should be included with detailed information obtained from managers of the ski area and the DEC. Furthermore, the additional employee demand potential generated at the ski center could create a major void for available employees, forcing the ski area, local businesses and the proposed project to seek additional employees from outside of the local economy. This would create additional demandfor lemporary housing in the area, and an inventory ofshouldbe included in the DEIS and will create an additional traffic impact. The potential need for temporary housing or rental property should be covered in detail in the DEIS, including potential locations for such a land use.

1.1.2 Adjacent Land Uses and Community Character

Provide a description of uses of adjacent lands and in the general vicinity of the project site (Route 28 corridor from Boiceville to Margaretville), including State lands.

Although this section meets the requirements of the scope of the DEIS, it is difficult to determine the land uses in the DEIS at a local or street scale. Maps should be provided to indicate the land uses at a smaller .scale to give the public at-large the opportunity to determine what potential impacts may result in their respective communities, giving them an opportunity to comment during the public comment period.

This section shall provide a discussion of how the proposed project may affect future land use of other property in the vicinity ofthe site and how the project will alter current land use of the site. The relationship of this project to other development projects in the area, either under construction or under review, shall be assessed.

As mentioned previously, the DEIS needs to provide smaller scale land use mapping and analysis to determine what the potential impacts will be to the local communities. Currently, the DEIS does not focus on the hamlets, villages or individual communities of residential and commercial properties. More detail will provide the public with the locations ofthe "in-fill" commercial development that will reduce the need to build new commercial and residential structures as stated in the DEIS. The DEIS should also identify all properties located on secondary roads and offaccess roads that are potentially developable, as these properties are typically considered prime real estate in a resort project of this type Milt the introduction of the project, it is anticipated that adjacent properties would substantially increase in property value. According to the median incomes stated in the DEIS, an increase improperly values could create real estate prices that are out of financial reach of the "average "person in the community. A detailed analysis should be provided indicating the impacts to real estate values in the study area in contrast to the values if the project is not constructed.

The introduction of the project on the proposed proj ect site shall be assessed from the standpoint of currently undeveloped land in the vicinity, and the type of future development of such lands if the project was to be developed.

The DEIS does not address this scope Item, rather it states that future development will be minimal due to thefact that the resort will contain all needed services. The report does not contain any inventory of the existing capacity of current vacant undeveloped land or vacant structures, commercial property or residential property in the area The DEIS should include information on the potential sites that could be affected by development, either anticipated or speculative (which is typical with a large-scale resort).

The proposed project's compatibility with the existing character of the surrounding lands shall be addressed in the DEIS.

The applicant only discusses the ski center in proximity to the project, which is vaguely similar to the project Belleayre Ski Center does not offer overnight accommodations, timesharefacilities, residential opportunities, fine dining or golf; the ski center is not a fourseason resort offering four-season amenities. Most areas surrounding the proposed project are residential and agricultural in nature and would potentially suffer same type of impact as a result of the project due to such a large tract of land changing in land use. At a minimum, the DEIS should contain some analysis of the potential for agricultural lands in the study area, towns and general corridor to change from an agricultural use to some other use (e.g. residential or commercial).

Discuss construction bonding requirements of the local municipalities and how these requirements can address concerns related to project economic viability.

The DEIS mentions these requirements, but offers no detailed information. A detailed discussion should be provided explaining the requirements of the Town. Potential bond amounts need to be includedfor thepublic to understand the construction bondingprocess for theproject, as the amount could be potentially significant, and have a financial impact on the Town.

1.1.3 Local and Regional Land Use Plans

The DEIS shall discuss how the proposed project and local land planning decisions required for the project could affect future land use plans both locally and regionally.

The DEIS discusses that the proposed project would have a negligible effect on the local and regional land use plans, as off-site development will be minimal due to a combination of land use and environmental constraints. As has been proven with the submission of the project DEIS, potentially large-scale similar developments could indeed arise with the application and approval of the appropriate permits. The DEIS should provide some scenarios where competition is introduced to the project which could indeed cause more future growth beyond the current project at hand (e.g. competing motel/hotel, additional golf course or resort type business). It is also recommended that the DEIS address the notion of possible competition to its own hotel and time share projects, as an increasing amount of visitors to the area will look for overnight accommodations. Historically, the Belleayre Ski Area has been a day trip destination. This will potentially change and the DEIS should reflect this major change.

1.1.4 Socio-Economic Setting

Fiscal and Economic Benefits Analysis
The project will generate substantial employment opportunities, new economic activity, and tax revenues during both the construction and operation periods. The following tasks would be performed to generate a complete profile of fiscal and economic costs and benefits within the study area.

Existing Conditions
Provide Existing Demographic and Economic Profile.
A demographic and economic profile of the communities within the study area will be compiled and described in terms of population and employment patterns. Based on information available from local, county, state, and federal sources, employment and economic baseline information by key industries (i.e., mining, agriculture, tourism) will be summarized and described. Anypotential new commercial development projects that could affect local employment patterns in the region would be identified through discussions with local and county government representatives.

The DEIS does a very thorough job of analyzing the numbers from many well-respected sources of economic data. However, the DEIS does not indicate any discussion with and information gained from localsources (elected officials, Town Clerks, etc.) that have inside knowledge ofthe communities, and the status of the local economies. It is important to get local insight, as the DEIS itself admits; however, much of the data for the immediate local economy (the study area) Is suppressed by the Census and the BEA and has been provided at the broad county level. Ulster County contains three larger economic areas: the Town of Ulster, the Town of Saugerties and the City of Kingston. These areas can tend to skew the economic numbers as they contain services not currently provided in thestudy area (but are similar to serviees proposed in the project). Speaking with local representatives may not give exact numbers, but may provide some economic trends in the local communities' economies.

Construction Phase
Estimate Construction Generated Economic Activity.
Based on the estimated capital investment for Belleayre Resort, the economic analysis will summarize the key economic benefits associated with the project. These benefits include direct activity associated with construction wages and salaries and the purchase of goods and materials, as well as the ripple- or multipliereffect generated as this economic activity is felt in the larger regional economy (including tax revenues generated by the construction project). The analysis will utilize the econometric model, Regional InputOutput Modeling System (RIMS II), developed by the U.S. Department of Commerce and customized for the project area.

This section of the DEIS scope has been addressed and strictly consists of numbers derived from the RIMS II analysis tool. There are many assumptions based on information derived from the project sponsor that are not qualified (typically denoted as the source information oblainedfrom Crossroads Ventures LLP). The RIMS II model depends on accurate Input numbers to provide the output formulas in each SIC code; thus, accuracy of the Input is extremely important. It is recommended that the sponsor provide sources far the numbers used in the input phase, or at least a discussion on how these numbers have been derived Additionally, the RIMS II analysis has been limited to two (2) digit SIC codes, rather than three (3) or four (4) digit SIC codes that would give very specific economic data for individual businesses. The data presented is very broad and encompasses many different business types rather than using 3 and 4 digit SIC codes that would provide more detail on the local effects of rhe project More detailed analysis at lower SIC levels (e g. 3 digit SIC's) would show some of the direct economic impacts to individual business types that maybe in the study area. It is noted that the RIMS 11 model is only available at the county level; thus this regional perspective is the smallest geographical level available.

Operations Phase
Estimate Potential Economic Benefits.
Based on anticipated employment generated by the project once it is completed and operational, a similar evaluation of the total economic effects would be prepared also using the RIMS II model. This effort would summarize the estimated number ofjobs to be generated during operation of the proposed resort (along with anticipated wages and salaries) and how much this increased expenditure in the local economy will create demand for goods and services and labor in the regional economy. The study will evaluate whether the existing labor supply can meet the expected increased demand. Where demand for labor exceeds the local and regional supply, some secondary impacts may occur from new residential development (see Growth Inducing Aspects, below). The proposed resort will be described in terms of future employment, annual payroll, and property taxes to each of the taxing jurisdictions. Property taxes would be calculated based on current tax rates and assessment practices within each of the taxing jurisdictions.

See comments above.

Evaluate Potential Community-Related Costs
Changes in property tax revenues will be summarized and evaluated in comparison with the potential increases in the cost of providing municipal services such as provision of emergency services to the new facility and any public infrastructure improvements required to service the facility. In coordination with Section 3.9, the projected demand for police, fire, and ambulance services and any public infrastructure would be used to estimate new potential costs to municipal governments based on the project and any projected new population within the residential communities.

The DEIS currently does include information on the increase of tax revenues to the municipalities. However, the DEIS does not clearly detail the potential demands for police, fire and ambulance services or public infrastructure as a result of the projecl. The sponsor has contacted the various agencies that provide emergency services who have indicated that they will be able to continue to provide service at current levels. However, the DEIS should include specific calculations for the increased calls to agencies based on the number of the following: I. New employees to the municipality: 2. The number ofnew residences and or residential housing on and offsite: 3. The number of holel rooms available 4. The number of restaurant/seats available. Additionally, as a resort community, there are times when areas may he uninhabitedfor lengths of time and possibly susceptible to deviant behavior.

Section 7.0 GROWTH INDUCING, SECONDARY AND CUMULATIVE IMPACTS OF THE PROPOSED ACTION

This section of the DEIS shall discuss the anticipated off-site impacts of the Belleayre Resort at the Catskill Park project The secondary impacts that the proposed project and any required land planning decisions may have in inducing economic growth or development in the vicinity of the project shall be discussed. The analysis shall focus on the hamlet areas on the NY Route 28 corridor between Boiceville and Margaretville.

The DEIS shall evaluate additional traffic, stormwater and wastewater that could accompany potential development outside of the project site, and potentially affect water quality in the NYC watershed.

Currently, the DEIS contends there will be no impacts due to the lack of additional commercial and residential development, therefore, this item has been omitted from the DEIS. This section should be revised to include any potential properties and the effects they may have. Additionally, this section should include analysis detailing the re-establishment of existing vacant commercial properties on Route 28 and in the hamlets.

The analysis of secondary and cumulative impacts shall include housing, economic development, effects on Belleayre Mountain Ski Center, Forest Lands, and the added visitors to Forest Preserve land.

This section is not addressed The DEIS needs to include details on the potentially increased number of visitors to Forest Preserve land and potential effects on Belleayre Ski Center.

The large-scale nature of the proposed Belleayre Resort establishes the significant potential for secondary economic impacts and induced growth. Three key areas of potential secondary growth will be examined:

New commercial activity seeking to capture a portion of the new economic activity generated by the project;

The DEIS contends that commercial development will be contained in the hamlet areas in existing vacant sites. It also states that the existing operating commercial ventures will be able to expand to meet the needs of the additional customer base. The DEIS does not analyze the fact ihat new businesses may attempt to establish to attract traffic or visitors of the project in the 28 corridor. The DEIS needs to examine the possible impacts based on other projects.

Additional year-round residential activity created if new employment opportunities exceed the local supply of labor or if the project attracts new and permanent user populations (i.e., retirees); and

It is difficult to determine from the DEIS the "available" laborpool. The DEIS describes in detail the available number of workers, but does not clearly indicate haw many individuals are available for part time seasonal work or how many are currently employed or unemployed in the study area. This information needs to be included (clearly) to determine the demand for housing. The DEIS does not contain a rental housing inventory indicating what the available rental property levels are in the study area. This is important as the DEISstates that most employment will not be full time, and most part time employees rent rather than build This could have an impact due to potential building of apartment facilities to housefuture employees. Additionally, the DEIS does not address housingfor seniors in the study area or any potential demand for such services. Senior housing is a growing concern for many communities, and resorts such as the proposed project tend to attract retlrees for recreation and/or residence. An inventory and subsequent discussion on the existing senior housing (if any) and potential demand jar new senior housing should be included.

Seasonal residential activity if new recreational amenities generate new interest not currently served by existing seasonal accommodations or residential areas. Based on the projections of economic activity generated in the Fiscal and Economic Benefits analysis described above, new growth would be allocated within the study area based on the existing development pattern, an analysis of current zoning within the study area, and an inventory of likely development locations.

The DEIS contains an analysis of existing zoning within the study area, however, the DEIS contends that no new (or extremely limited) development will occur. The DEIS states that only existing vacant buildings will be used. It is important for the DEIS to demonstrate any likely locations of development, such as high traffic areas and intersections that are unconstrained by zoning or environmental regulations.

Existing Land Use and Zoning Analysis. -Evaluate the existing land use pattern and zoning regulations with respect to new commercial and residential development.

The DEIS does not demonstrate where new development has occurred recently on any mapping. It is important to demonstrate where commercial and residential development Is focused at the current time, or that there is no focus (which could assist in the refocusing of development as per development guidelines). The DEIS does contain an adequate explanation of existing land use and zoning within the study area.

Inventory of Likely Development Locations. - An inventory of "soft-sites" within the study area would be prepared based on windshield surveys, discussions with local communities and county planning representatives, and use of Geographic Information Systems (GIS) data.

The DEIS contains a GIS inventory of "soft-sites" as required by the DEIS scope. This inventory is at a very large scale, and does not offer the reader an idea of what would be available "on their street" At times, is difficult to determine these potential sites at a scale that would demonstrate this information at the hamlet level or neighborhood unit.

Identification of Environmental Constraints - New development within the study area will also be constrained by topography, hydrography (streams and wetlands, and regulated areas around reservoirs), soils, State Forest Preserve land, and wastewater infrastructure. Sites identified in the soft-site inventory would be screened for likely elements that would constrain development.

This is covered in the DEIS, however, as stated previously, information on soft-sites is at a large scale that makes It difficult to understand.

Prepare Secondary Development Analysis - Using the inventory of development locations, screened for environmental constraints, the likely level of secondary development induced by the Belleayre Resort project would be projected for the year 2010 based on forecasts for new commercial and/or residential development. Current zoning would be used as the basis for development allocation within the study area. Additional data may be obtained from the New York City Department of Environmental Protection's Final Environmental Impact Statement for the Watershed Regulations (November 1993) regarding potential level of development within the study area.

The DEIS consistently states that negligible development will occur as a result of the project, with o maximum build out of 79,000+1- sq. ft of commercial development As a result, very little emphasis is given to potential locations ofnew development in the project area. No inventory of existing facilities is presented in a map form (such as gas/oil stations, convenience stores, etc.) that are typical stops for commuting travelers in need of these services. The DEIS does indicate that there are only S eslablishments from the project site to Boiceville (Table 5.16). Additionally, the DEIS does not indicate any hours of operation and the number of establishments described in the DEIS is not actual local data. The DEIS does not indicate that a windshield tour has taken place to verify the actual existence of these businesses.

Conduct a Case Study Comparison - Case study situations will be evaluated for "lessons learned" in what may be expected from a large economic development project in a rural area with a high degree of environmental sensitivity and a tourist-based economy. The developers of a large-scale resort, as well as municipal and regional planners and economic development officials would be contacted for their perspectives on how the investment helped shape, change, or induce new growth in their regional area. The initial step would be to identify likely locations that have recent investments in established but under-built tourist areas in four- seasons resorts combined with environmentally sensitive park or watershed settings.

This section in the DEIS seems to focus on the positive aspects ofa large-scale resort on the surrounding community. There is little evidence included that details any "problems" that may have occurred in the past with such a project, such as citizen complaints, traffic problems or a negative economic effect. As difficult as it may be to quantify, it should be demonstrated so thepublic at-large has some insight as to theproblems that may arise with such a project.

With the Windham example, it is noted that residential development may have been slower in the community than what was expected. Did this lack of residential development introduce a higher traffic impact due to more visitors at the facility driving for a day trip? This level of analysis should be included not only for the proposed project, but for the BeUeayre Ski Center to gauge impacts to this facility as well.

The case studies to be examined shall include the Windham area in the Catskills and within the NYC Reservoir system. This case study will be examined in the most detail. Other case studies to be examined include the New York State operated ski center at Gore Mountain in the Adirondack Park of New York State as well as the recently approved development around Graylock Mountain in the State of Massachusetts that is adjacent to large areas of lands under State control.

This section is covered in the DEIS report. However, the Graylock Mountain development may not be the best example for a case study since this resort has not been developed to date. However, this situation in itself might be a good example for a case study as an example of the potential of a large-scale project that did not come to fruition, and the effect this has had on the surrounding communities.

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CLOUGH, HARBOUR & ASSOCIATES LLP
ENGINEERS, SURVEYORS, PLANNERS & LANDSCAPE ARCHITECTS

April 30, 2002

Mr. Alexander Ciesluk, Deputy Regional Permit Administrator
New York State Department of Environmental Conservation
Division of Regional Permits, Region 3
21 South Putt Comers Road
New Paltz, NY 12561-1696

RE: Draft Environmental Impact Statement -Bellenyre Resort at the Catskill Park
CHA job number 10065

Dear Alec,

We have completed a preliminary technical review of the Draft Environmental Impact Statement (DEIS) for the Belleayre Resort at the Catskill Park. This review has identified areas of concern in the document that reach beyond completeness of the document. In several areas, there are inconstancies and omissions that would be best addressed early in the process (as you have suggested), rather than wait until the document is considered complete and released for public comment. Sections reviewed contain information we have been deemed responsible for including:

• Traffic, Parking and Pedestrian Circulation
• Local and Regional Planning
• Community Socioeconomics
• Growth inducing, secondary and cumulative impacts

General Comments

In general, the document is difficult to navigate within. It is difficult to find text pages mingled within many pages of maps and its often difficult to find specific sections. The general public may find this even more frustrating and many may simply give up rather than struggle to find a specific section or information.

It is recommended to move map figures to a specific, separate section or to the back of each section and be referred to by the figure number. Possibly a separate section divider for the map sections would enable the average reader to maneuver through the report much easier and refer to specific maps when it is needed.

Section 1-Executive Summary

This summary is long (25 pages), containing a mix of confusing numbers and statistics starting on page 1 and mapping continuing throughout. The executive summary should be a short, clear and concise discussion of the project with extremely limited statistics. If statistics are required in the Executive Summary, charts, graphs and tables be used to create a quick and clear message to the reader (who will be the general public).

References to other sections can provide the reader of the Executive Summary to more in-depth material. Mapping included in the Executive Summary (including the project location map figure 1-1) is difficult to interpret and could confuse readers in the first pages of the DEIS. Additionally, project location mapping (figure 1-5) is extremely difficult to read with project boundaries as dark as topography lines, making the project area almost impossible to determine. These maps should be corrected and confined to a distinct area with local points of interest identified to give readers a waypoint to identify location in the "big picture" of the Catskill Park and State.

Traffic

The DEIS contains a great deal of information on traffic in the immediate area of the project but does not address concerns of communities to the north and south along the Route 28 corridor. Route 28 should be examined from the NYS Thruway in Kingston to the project site and include all intersections along that route. It should be assumed that impacts would be present from the beginnings of construction traffic to employee commuter traffic and guests/residents.

Pedestrian traffic on and around the resort should be openly addressed in the DEIS. The current conditions in the area have been identified as having virtually no pedestrian traffic. It should be assumed that this condition would change with a pedestrian intensive use such as golf. Many who play golf like to walk the course and will walk around the site and off site on local roads. The DEIS should address the compatibility with local road networks and identify areas of concern and offer mitigation to address pedestrian safety. Additionally, as previously stated in our completeness review, there is no information in the DEIS that address pedestrian safety in the vast parking areas proposed on the resort. The DEIS should also address pedestrian safety with regard to the many golf carts that will be used on the resort.

Community Character

Additional areas of concern have been identified in Section 3.8 of the DEIS that addresses Community Character. It is repeatedly stated that no major changes in community character are expected, yet in the Executive Summary the traffic section identifies immediate mitigation.to NYS Route 28 in several locations, including major construction projects (e.g. turn lanes, traffic control devices and signage). It is also stated that this portion of the DEIS that State funds will be required (on a cost sharing basis) to complete improvements.

Communities can consider highway improvements a change to the character of the community. The report also indicates that "because the resort will be fairly self-contained there will not be an affect on community character" The project proposes a very large increase in traffic on the highway system (over existing levels) that provide access to the local, rural community that the project is proposed to be located.

The project proposes several large conference size hotel complexes, two large golf courses and a residential housing element (both single family homes, condominiums and time share facilities). This report should evaluate the local communities of Pine Hill, Fleischmanns, Arkville, Boiceville and other neighboring Route 28 communities that will be impacted by travelers to and from the project regardless of its inclusion into the original seeping document. The DEIS has limited most analysis to a seven zip code area with little information offered at the hamlet, village or town level of detail. In a rural economy, this is a very important level to identify possible impacts in a limited economy.

The DEIS identifies a subdivision of upscale single family homes that will become part oŁ the community in the Towns of Shandaken and Middletown. The community does not normally see applications for upscale single family subdivisions of homes. This element of the project, in and of itself represents a major change in the character of the community. It could be assumed that the presence of an upscale development of single family homes will increase housing values in the adjoining communities, effectively eliminating any affordable housing that may exist currently. The report does not indicate the average value of real estate in the surrounding communities in relation to the proposed cost of a home in the Highmount Estates subdivision, which is estimated at several hundred thousand dollars each. Housing at these prices would be relatively new to the neighboring communities and would most definitely constitute a major change in the character of the community, as well as a possible change to the community's economics.

Communities mentioned previously do not typically contain major developments of condominium or time-share housing. This style of housing also represents a major change in the character of the community by introducing high-density residential development to a historically low-density rural environment. It cannot be assumed the project will not effect the character of the community because it is itself a major change. The resort has the potential to change the traditional type of housing that exists in the neighboring communities that are typically single family homes, farms, seasonal cottages and residential structures in hamlet and village atmospheres. The project could create demand for off-site development of the condominium and time-share style housing in a speculative environment. This development would likely be at lower costs to attract would-be purchasers of on-resort property, time-shares or hotel accommodations. This scenario is not only possible, but likely given the fact that property values would likely increase in the communities surrounding the resort and this scenario should be addressed in detail in a revised DEIS.

Community Socioeconomics

Labor availability is another area of concern. The DEIS repeatedly states that the existing supply will be able to meet expected demand, yet provides little to support this claim. By its own admission, the DEIS indicates most of the jobs available at the resort will be service type positions (e.g. housekeeping, cooking, grounds maintenance), many seasonal and/or part time. The report indicates that many of the administrative jobs such as management will most likely come from outside of the immediate economy and possibly outside of the region. The DEIS should include a detailed discussion on the availability of labor in the immediate area, as it is unlikely that individuals would commute for a potentially low paying, part time or seasonal resort job.

It would be appropriate to identify what the potential housing availability is for part time employees, such as apartment, motel and rental housing levels. The report specifically mentions it wants to leave the economic benefit of supplying housing to the community, yet the report fails to indicate if the community actually has enough housing to accommodate the 747 full time equivalentjobs it is proposing. It would be helpful to provide rental costs with this discussion, as it could be determined that rental prices could be expected to increase as supply decreases. This would put housing costs outside of the range of part time employees.

With regard to community economics, as previously discussed in CHA's completeness review, the DEIS contains little information on existing businesses in the region. The DEIS should include an inventory of existing businesses, and vacant commercial sites available for new businesses. It would be beneficial to know prior uses of the vacant commercial buildings to identify the potential future uses. This information should be easily obtained from the local assessor's office or building inspector that would record types of construction and tax assessed by use.

Growth inducing, secondary and cumulative impacts

Growth inducing, secondary and cumulative impacts in the DEIS are often addressed with a blanket statement that the "Resort is expected to absorb on-site the bulk of any seasonal or second home demand that it creates." The DEIS, as stated previously, contains little or no information on available housing (rental or sale) in the immediate area or region of the project.

The DEIS should address the possibility that the resort will create additional, off-site demand for housing, whether it is rental, seasonal or year-round. It has been discussed in the report that single-family housing on the resort will be upscale development, which is uncharacteristic of the communities it will reside in.

Finally, the Alternatives discussion contains almost no indications of a site other than the proposed resort in its current location. It is understandable that tracts of land this large are becoming increasingly difficult to obtain, but little effort is evident that an alternative site was considered. A more thorough alternatives discussion with alternative sites may be difficult, as it does not appear that one was investigated initially. Alternative designs for the current site are appropriate. Scaled back scenarios will show the effects of a smaller development and would be beneficial to readers. This would give the local communities some idea of the effects of different sized resorts would have on their neighborhoods and economy.

The focus of this letter review has been on the technical deficiencies identified in the DEIS as prescribed in the Scoping Document, dated 11/03/2000. Please feel free to contact my office should you have any questions, comments or concerns. My direct number is 518-453-8207.

Very Truly Yours,

Clough, Harbour & Associates LLP
Engineers, Surveyors, Planners
& Landscape Architects

Gerald A. Engstrom Jr., AICP
Planner