Selected DEIS Comments and Proposed Issues for Adjudication
“The Belleayre Project will result in significant and unmitigated adverse environmental impacts which will have a critical bearing on the future of the Catskill Park, the Towns of Shandaken and Middletown, the Route 28 Corridor, the central Catskill communities and the New York City Watershed and Drinking Water Supply…the DEIS does not provide a reasonable and candid evaluation of the adverse visual, traffic, noise, economic, water quality, ecological, wildlife and habitat, community character and cultural resource impacts. These fatal defects in the DEIS regarding the substantial adverse impacts which will result from construction and operation of the Belleayre Project deprive the Commissioner of the legally necessary environmental analysis and record upon which she must make SEQRA findings pursuant to 6 N.Y.C.R.R. § 617.11. Moreover, multiple aspects of the Belleayre Project do not meet permit standards pursuant to the Environmental Conservation Law…the Belleayre Project will dominate and irretrievably alter the landscape throughout the Towns of Shandaken and Middletown, the Route 28 Corridor, and the Catskill Forest Preserve. Its intrusion will be substantial and unavoidable. The Belleayre Project will degrade the landscape and substantially interfere with the region’s economic vitality and renaissance.”
Catskill Preservation Coalition
“NYCDEP believes that the proposed Belleayre Resort at Catskill Park does not embody environmentally responsible growth consistent with the spirit of the MOA. The DEIS is fundamentally flawed and incomplete because it fails to satisfy the State Environmental Quality Review Act (SEQRA) and the rules and regulations (6 NYCRR 617) enacted to govern such reviews. The DEIS fails to take a hard look at the project's potential for significant adverse impacts on the environment because it relies upon faulty assumptions and data and inaccurate predictive models as the basis of its conclusions. Since the basis for describing existing conditions and identifying significant adverse impacts of the proposed project is flawed, the identification of effective, reasonably available mitigation measures is woefully inadequate at best, and conspicuously absent at worst…Unless the analyses in the DEIS are substantially improved and demonstrate that the impacts of the project as proposed or a reasonable alternative project have been accurately quantified using complete, consistent, and accurate underlying data and fully documenting the measures through which the impacts are mitigated, the Applicant has not discharged its duties under SEQRA that all potential significant environmental impacts have been adequately identified, analyzed and mitigated. As such, NYCDEP is not, and until such steps are completed would not, be able to issue findings in support of the project or approve permits pursuant to it's independent regulatory authority over stormwater discharges and wastewater treatment at the site…”
NYCDEP
“The Alliance considers the proposed Belleayre Resort to be an ill-advised and inappropriate use of the land surrounding Belleayre Mountain. We continue to believe that the project, as proposed, will have irreversible adverse impacts on the towns of Shandaken and Middletown, as well as the Catskill Forest Preserve and the New York City watershed. The Alliance respectfully urges the DEC to require the applicant to address the DEIS deficiencies…and, ultimately, to reject the application in its current form.”
Catskill Heritage Alliance
“It is very disturbing that such an enormous project has been proposed for such a sensitive and valuable area. The Project, as currently planned, pits the personal vision and financial interests of a single developer against the character of the local community, the beauty of an important natural resource and the integrity of the New York City Watershed. That Watershed is the source of unfiltered drinking water for almost half the population of the State of New York. Although the Project Sponsor pledges to limit environmental impacts through the use of “space age” technology, the Catskill Center regards this proposed experiment as irresponsible, given that a failure of the Project’s mitigation measures could necessitate the construction of water filtration plants at a cost to the general public of approximately $6 billion. Moreover, failure of mitigation measures would mar the beauty of the Catskills…In our view, the Project should not go forward for three key reasons: First, the Project, at its present scale, is not compatible with Catskill Park. The Project is unprecedented in size, within not only the Catskill Region but indeed, the entire northeastern United States…Second, from an environmental standpoint, the proposed Project requires dramatic disruption in a particularly sensitive and valuable area. The Project is within New York City’s West-of-Hudson Watershed. The site is located at high elevations, on steep slopes, at the headwaters of both the Ashokan and Pepacton Reservoirs. This is a recipe for the contamination of the New York City water supply…Third, despite the extraordinarily high environmental stakes, the Project relies upon unproven technology and fails to provide for the comprehensive field testing of mitigation measures at each stage of construction…In sum, the Catskill Center believes the proposed Belleayre Resort at Catskill Park is the wrong type of development for such a beautiful and unique region. It will have serious negative impacts on community character and the environment without offering significant economic benefits.”
“The DEIS states that an extensive Air Quality analysis is not necessary, as the project is located in an attainment area. However, impacts on air quality are likely to accompany the increases in traffic associated with the project, especially combined with additional increases in traffic expected with the continued growth of the Belleayre Ski Center. The DEIS nowhere addresses the combined effects of traffic, blasting, and the operation of two rock crushing plants (permits for which are not included in the DEIS). The DEIS also does not consider the air quality impacts of large volumes of traffic being stopped by the Catskill Mountain Railroad during its frequent crossings of Route 28. The locomotives themselves are exempt from air quality regulations because they were manufactured prior to 2001. However, they and the cars they force to stop and idle on Route 28 will contribute pollutant gases and particulate matter that may harm streams and diminish the fresh, clean air quality so prized by residents of and visitors to the Catskills.”
“The applicant’s conclusion that a one golf course/one hotel option is not financially feasible is erroneous, and further ignores the natural resource benefits and other benefits of such an option…The applicant has completely failed to analyze any other reasonable alternatives of smaller scale or magnitude…The analysis of reasonable alternatives must be evaluated as a means to eliminate, avoid or mitigate the significant adverse impacts which will result from the proposed Belleayre Project. In light of the significant adverse environmental impacts associated with development on the east side of Belleayre Mountain, a western alternative must be evaluated.”
“Appendix 27 of the DEIS concludes that none of the four development alternatives examined in Appendix 27 of the DEIS are economically viable and thus cannot be considered a ‘reasonable’ alternative to the Proposed Action. This is not in compliance with SEQRA's mandate that an EIS evaluate a range of reasonable alternatives. At least some reasonable alternatives must be considered in the DEIS. Because alternatives were dismissed, the DEIS does not include an environmental analysis of any other possible development scenarios, and thus there is no means for decision-makers to determine if there is an alternative with less adverse environmental impacts and or impacts that are more realistically mitigatable.”
“While SEQRA mandates that decision-makers undertake a comparative assessment of all reasonable alternatives, the Belleayre Resort DEIS fails to seriously consider any alternative to the present proposal…Instead of analyzing true alternatives, the DEIS discusses fragments of the existing proposal and implicitly dismisses any version of the Project that does not maximize the Project Sponsor’s profits. This approach is wholly inconsistent with the court-tested notion that alternatives analysis is the ‘heart of the SEQRA process.’ A more genuine, legitimate, and statutorily sufficient analysis of the financial feasibility of Project alternatives must be conducted.”
“…the Belleayre Project raises substantive and significant issues for adjudication since the DEIS failed to adequately address the environmental impacts of the water withdrawal on the area’s surface waters and aquatic habitat in the vicinity of the project…The Belleayre Project will result in the following impacts: reduction of ground water levels and loss of base flow in adjacent streams; increased duration of low flows; increased water temperature; increased pollution levels; modification of stream morphology; reduction of fish densities and a shift of community structure from one dominated by trout towards generalist, warm water species (e.g. bluegill). Convincing proof that this will be avoided has not been provided in DEIS documentation. This habitat will be further stressed by the proposed expansion of the Belleayre Ski Center.”
“The case studies presented in the DEIS primarily focus on ski areas, while the proposed Belleayre Resort is focused on golf course development and hospitality/timeshare development creating, with the existing Belleayre Ski Center, a destination resort. Therefore, the case studies presented in the DEIS (though specified in the Final Scoping Document) are largely irrelevant and have little value in accurately predicting likely socioeconomic and induced growth. RKG performed a thorough survey and identified two destination resort developments that are more representative for evaluating the strength of conclusions reached in the DEIS about secondary impacts on surrounding communities, labor and housing markets, and commercial development that will follow the resort development. These case studies were Mountain Creek in Vernon. New Jersey, and Snowshoe Mountain in Snowshoe, West Virginia.”
“The DEIS’ conclusion that there will be no impact upon community character is based upon its assertions that: (1) “the Resort will be fairly self-contained [and thus] there will not be an affect on community character;” and (2) the Project will merely “re-introduce resort development uses into an area that historically supported such development locally and on a large scale.” CPC will present evidence that DEIS treatment of community character is critically flawed…One of the most important characteristics of the Catskills is its vast amount of open space. Approximately 500 acres of forested, open space will be directly altered if the Belleayre Project is approved…The open space impacts that have not been evaluated in the DEIS would include: …Cumulative impacts and secondary growth impacts from construction of the Belleayre Project and the expansion of the Belleayre Ski Center; …Loss of the wilderness and forest character of the area; …Impact on Route 28 as a scenic drive – and potentially as a State designated Scenic byway. The scale and design of the hotels is out of context with the immediate area and the evolution and development of the Catskills…the economic impacts of the proposed project will have a significant adverse impact on the existing community character as they will impact the number and type of jobs available, future surrounding land uses and the need for additional housing…Community character impacts of the proposed Belleayre Project are tied to the probable population growth that can be expected from the project, yet this population growth is ignored in the DEIS. This population growth will impact community character of the region and, in particular, the Towns of Shandaken and Middletown…Contrary to the DEIS, the Belleayre Project does not represent a continuation of the area’s resort history and culture. Rather, this proposal will overwhelm and destroy the diverse and intermingled land uses that currently characterize the area.”
“The DEIS is critically flawed because it fails to acknowledge the significant impacts that the Project will have upon the character of the surrounding community…Despite the DEIS’s suggestion that the resort will be “fairly self-contained,” it defies logic to think that the Project will not negatively impact the area’s scenic vistas and destroy the existing sense of community character: the Project is a near 600-acre behemoth with two golf courses, two hotels, and an additional 99 structures for detached lodging units and the Project is expected to attract an estimated 600,000 visitors per year…Furthermore, the secondary development that can be expected to accompany the Project will also affect community character…While the DEIS declares that the Project will merely “re-introduce resort development uses into an area that historically supported such development locally and on a large scale,” this statement is incredibly misleading. Though tourism generated by the area’s plentiful natural resources and ready opportunities for year-round recreation has been and continues to be central to the regional economy, the Catskills have never seen a resort development akin to the proposed Belleayre Resort…[E]conomic studies of the region have indicated that tourism may be best revitalized through “a focus on existing destinations and a series of niche-based accommodations,” including “historic village preservation with Bed and Breakfasts and shops.” Such development is most appropriate in “[e]xisting hamlets and villages [which] have unique character and can become focal points for development.” Significantly, one study, “Resource Protection and Economic Development Strategy for the Route 28 Corridor,” recommended: “Rather than recreate the over-sized resorts of Sullivan County and the southern part of Ulster County, four or five 100-room facilities built over a five to ten year period would be far more viable than either a multiplicity of smaller units or dependence on a mammoth new resort.” This Route 28 Corridor Study, authored by a committee chaired by Project Sponsor Dean Gitter, also noted that the local community “recoils from the idea of over-population,” that “[a]ssaults on our viewsheds would be tragic” and that “the Long-Islandization of the Catskills is unthinkable.”…The proposed Belleayre Resort is wholly incongruent with the character of the Catskill community.”
“…[T]he DEIS does not address the cumulative impacts which will result from construction and operation of the proposed Belleayre Project and the proposed expansion of the Belleayre Mountain Ski Center. Although the Belleayre Project is wed to the proposed expansion of the Belleayre Mountain Ski Center, the DEIS fails to acknowledge the synergistic and cumulative impacts which will occur. The two projects will result in cumulative impacts on the availability and adequacy of potable water supplies, surface water flow and aquatic habitat, traffic, use of Forest Preserve lands, and secondary growth.”
“Curiously, for a project called ‘The Belleayre Resort at Catskill Park,’ the DEIS provides very little information about its adverse impacts on and cumulative impacts with the Belleayre Ski Center, the entity it straddles on Belleayre Mountain…The DEIS does not seem to describe a project that truly complements the state-run facility at Belleayre. Moreover, the combined impact of Belleayre's growth and the presence of a gigantic new development seems likely to overrun the carrying capacity of the mountain: in terms of burgeoning traffic, in terms of already thinly-stretched water supply resources, and simply in terms of uncrowded space.”
“Although future improvements at the Ski Center are cited in the DEIS as support for the Project’s ‘purpose, need and benefits,’ the DEIS makes no effort to otherwise identify and assess how the simultaneous development of the Project and expansion of the Ski Center will cumulatively impact the environment…The failure of the DEIS to incorporate an assessment of the expansion planned for the Ski Center is confounding, given that the Ski Center is State-owned and operated by the DEC.”
“There are serious deficiencies in the economic impact analysis presented in the DEIS, which cause the results to be biased toward the developer…The DEIS states “it is reasonable to assume that the Resort management would make every effort to hire for all positions from within this two-county region.”…The Emerson Inn & Spa, another development near Belleayre in the Catskill region, was initiated by the same developer proposing the Belleayre Resort. The Emerson Inn & Spa appears to make an effort to hire staff outside of the region, and in fact, outside of the country…This international hiring practice will not diminish local unemployment, and a large portion of the wages will not be spent locally, resulting in little stimulus to the local economy…The development as proposed at Belleayre is similar to an “all inclusive” resort where visitors stay in the one resort for recreation, food, drink and accommodation. Large “all-in” resorts do not tend to help the localities…Tourists visiting a self-contained resort buy all food and entertainment on site, but the adverse effects are felt by the community outside of the resort (traffic, water pollution, air pollution, etc.)…Diversification of an economy is desired for long-term economic strength. Introducing a large development that would far exceed the size of any other business in the area would result in a very low level of business diversification in the economy, which is risky. Jost Krippendorf, in The Holiday Makers: Understanding the Impact of Leisure & Travel, emphasizes that “over reliance on any single economic activity is dangerous and in the case of the tourist trade, the risk is even greater.” He further states that “under no circumstances should a development relying solely on tourism be allowed. A maximally diversified economic structure must be strived for in tourist destination areas.” In the case of the Catskills, this implies that forestry, handicrafts, small-scale industry and non-tourist services must be promoted as well. Tourism, if done properly, can have a considerable impact on employment and income in a locality, but Krippendorf emphasizes the reverse side of the coin, seldom mentioned: “jobs in tourism are mostly unattractive, working conditions are hard, the hours are irregular, there is seasonal overload, overtime is more or less compulsory and one is at the mercy of the guest. Earnings are below average. The range of professional and training possibilities is limited. Many jobs are unskilled and considered socially inferior, for example the work behind the scenes such as in the kitchen or cleaning. Tourism-related occupations therefore enjoy very little prestige, especially in developed countries.””
“The DEIS does not contain required site-specific cost analysis of the proposed resort. The scoping document for the project sets forth that "the projected demand for police, fire and ambulance service would be used to estimate new potential costs to municipal governments based on the project and any new population within the residential communities." Ignoring that requirement, the initial version of the DEIS, submitted in January of 2002, contained no such cost estimates, perhaps suggesting the resort, whose projected visitors and employees would increase the local population by nearly a third, would somehow not increase either the number of emergency service calls or municipal infrastructure costs…[T]he revised and accepted DEIS still omits the requested cost estimates. Rather than including the required cost analysis, the DEIS makes misleading and irrelevant claims about the proposed resort's costs…[T]he DEIS states "both portions of the project site will supply their own internal security force on a 24-hour a day 7-day a week basis,” implying there will be no burden on town budgets…In Shandaken, there is no doubt that witnesses and victims of crime at the resort would call 911 and that Shandaken Police would then be dispatched, exactly as it should be since only those officers are properly trained, equipped and authorized to handle criminal activity. Since the resort is projected to increase local population by a third, these calls would likely be a considerable additional burden on our existing police force, which would also have to cope with the estimated 1.7 million trips by vehicles going in and out of the resort annually…The DEIS should include a proper fiscal impact analysis of the project that adequately addresses the costs of community services.”
“The DEIS does not contain required site-specific cost analysis of the proposed resort. The scoping document for the project sets forth that "the projected demand for police, fire and ambulance service would be used to estimate new potential costs to municipal governments based on the project and any new population within the residential communities." Ignoring that requirement, the initial version of the DEIS, submitted in January of 2002, contained no such cost estimates, perhaps suggesting the resort, whose projected visitors and employees would increase the local population by nearly a third, would somehow not increase either the number of emergency service calls or municipal infrastructure costs…[T]he revised and accepted DEIS still omits the requested cost estimates. Rather than including the required cost analysis, the DEIS makes misleading and irrelevant claims about the proposed resort's costs…[T]he DEIS states "both portions of the project site will supply their own internal security force on a 24-hour a day 7-day a week basis,” implying there will be no burden on town budgets…In Shandaken, there is no doubt that witnesses and victims of crime at the resort would call 911 and that Shandaken Police would then be dispatched, exactly as it should be since only those officers are properly trained, equipped and authorized to handle criminal activity. Since the resort is projected to increase local population by a third, these calls would likely be a considerable additional burden on our existing police force, which would also have to cope with the estimated 1.7 million trips by vehicles going in and out of the resort annually…The DEIS should include a proper fiscal impact analysis of the project that adequately addresses the costs of community services.”
“The fiscal impact analysis section of the DEIS looks at potential property tax revenue increases but does not discuss, or attempt to quantify, any increase in costs for municipal services, including schools, police, fire, etc. This is a critical flaw, as fiscal impact evaluations must quantify both the benefits and costs of developments on host communities. The potential adverse impacts and reasonable mitigation measures are not evaluated. The report provides very little information on either Middletown or Shandaken, both of which would bear the major impact of this project, particularly from a fiscal impact perspective. Since the majority of the proposed resort improvements would be located in Shandaken, Shandaken is likely to see the majority of new tax revenue associated with the development. Development in Middletown would [be] limited to the 21 new homes at Highmount Estates and six of the eighteen holes of the Wildacres golf course. However, since housing is generally less expensive in Middletown, resort workers (and their school-aged children) would likely elect to live in Middletown. This could create a significant negative fiscal situation for Middletown, which would experience increased demand for education and municipal services while receiving tax revenues, which would not cover those expenditures.”
“…[T]he Belleayre Project will result in substantial adverse impacts to the Forest Preserve land and resources due to the large increase in visitors to the area which the DEIS predicts the Belleayre Project will generate…[T]he DEIS predictions set forth in Appendix 26 indicate that the projected visitation will be approximately 637,800 visits to the Belleayre Project. The Belleayre Project will generate more than ten times the current annual reported use of the trail visits on all trails in all areas of the Catskill Park. Even assuming that each visitor will spend only one trip per year on Forest Preserve lands, the Belleayre Project will result in a seven hundred (700%) percent increase in use of the Forest Preserve trails…The DEIS fails to address these impacts. DEC has already acknowledged that the potential for overuse of the Forest Preserve lands presents its greatest danger even before the Belleayre Project was proposed…[T]he potential biological and ecological impacts include trampled and disturbed vegetation, disturbance of breeding and nesting birds and animal behavior, changes in the ecosystem due to physical changes in the environment; physical changes to the trail system and visitor distribution and the resultant social conditions which will result from increased visitation and use of the Forest Preserve.”
“…[T]he DEIS failed to adequately address the significant adverse impacts on the extensive forestlands of which the site forms one component. On either side of the Big Indian site are extensive tracts of wilderness areas of the New York State Forest Preserve. Yet, the DEIS does not account for private forest fragmentation which will result from development of the site including habitat and biological impacts. In addition, notwithstanding that private forest land continues to be lost at an alarming rate in the Catskill region, the DEIS does not account for the cumulative loss of this significant resource.”
“The DEIS does not adequately evaluate the hydrogeology of the area, which is critical to preparing an accurate water balance for the site. taking into account recharge from the surface into regional subsurface features and ensuring that modifications to the existing recharge patterns made by the development of the proposed Belleayre Resort do not compromise the protection of existing local drinking water supplies. In short, it is not clear how the Applicant plans to protect groundwater resources since the DEIS has not presented the results of detailed literature and site investigations conducted to gain an understanding of the hydrogeology of the area…In addition, the stormwater management plan should be evaluated more thoroughly to determine potential impacts to ground water resources. Actions that would impact groundwater include the filling of wetlands, regrading of the site, and placement of underdrain systems on the golf course fairways. Potential impacts from these actions, including addition of pesticides, herbicides, phosphorous and other nutrients and disruption of recharge areas, are not identified. Other potential impacts would include under sized irrigation ponds, based on the water budget, that do not provide sufficient irrigation supply for the turf and fairways, resulting in using more groundwater supply and therefore, having a significant impact on the Village of Fleischmanns and hamlet of Pine Hill water supplies.”
“The proposed groundwater withdrawal rates from Rosenthal wells R2 and R1, required to meet potable and irrigation water demands for the eastern portion of the project (Big Indian Plateau), cannot be sustained over dry weather periods…Extensive lowering of bedrock water levels due to pumping at the Rosenthal supply wells, estimated to exceed 45 to 50 feet within a half-mile radius of the wells, could adversely impact a number of residential wells located outside the Pine Hill Water Company service area…Re-evaluation of bedrock hydrogeology and spring capture areas, with due accounting for structural effects of a stacked multi-aquifer bedrock and the role of open holes, should be conducted by the Applicant in order to assess and quantify groundwater-related impacts and to develop reliable monitoring of such impacts.”
“The DEIS describes its requirements for pesticide and fertilizer storage, and bulk petroleum and chemical storage without detailing sufficient mechanisms for the safe handling of such substances. The Environmental Protection Agency (EPA) has issued a checklist and new site security guidelines for storage of large quantities of "chemicals, pesticides, or other materials that could be used to attack the United States." Since the combination of chlorine and fertilizers could be considered to fit that description, and since many people seek out the Catskills for travel or residence based on a perception of its healthy and health-promoting environment, state of the art security for handling these hazardous substances should be in place before any consideration is given to permitting bulk storage facilities.”
“One of the primary economic development initiatives already being pursued by the Catskill Heritage Alliance and other local groups involves hamlet revitalization and historic tourism. Historic tourism demonstrates strong resilience as a tourism market, and studies have shown that visitors seeking historic sites and activities have longer stays and explore host communities more fully than other tourists. The Town of Shandaken has seven sites listed on the State and National Registers of Historic Places, and the area near Middletown has several. Five of the historic Catskill Fire Towers have been renovated, and one of them has been listed on the State and National Registers. The Catskill Center for Conservation and Development has promoted historic barn preservation and already offers a driving tour of the region's historic barns, many of which are eligible for state and national listings. At least one of the project's buildings (the Big Indian resort) fits very poorly with the local architecture and historic character of the region. The DEIS provides no information about the project's impacts on the development of historic tourism, which naturally complements the area's primary hiking and nature-based tourism, as a more sustainable approach to improving the area's economy.”
“…[T]he DEIS fails to adequately consider impacts to historic resources despite the fact that the following sites listed on the National Register of Historic Places are located within the affected project area: the Zen Mountain Monastery (Camp Wapanachki), Old St. Rt. 28 at junction with Miller Road, Temper, New York; District School No. 14, Academy Street, South of junction with Birch Creek Road, Pine Hill, New York; Elm Street Stone Arch Bridge, Elm Street, over Alton Creek, Pine Hill, New York…”
“…[V]irtually no attention has been given to protecting the five historic sites found in Pine Hill, especially its two historic stone arch bridges. The DEIS does address the absence of historic landmarks on the project site, but does not note the seven sites in Shandaken listed on the State and National Registers of Historic Places (or the several more such sites nearby in Margaretville, Andes, and Bovina). The DEIS specifically does not discuss the traffic hazards to the two stone arch bridges in Pine Hill. Changes in traffic patterns related to increased traffic to and from the resort, and particularly with reference to construction vehicles and emergency access to the resort via Woodchuck Hollow Road, should have been described and analyzed in the DEIS, including appropriate mitigations. Most obviously, these traffic impacts could be mitigated by the inclusion of alternative or additional construction and emergency access via an extension of Lost Clove Road.”
“The Sponsor of the proposed Belleayre Resort has not sought, nor has the DEC considered the need for, a mined land reclamation permit. Pursuant to the New York State Mined Land Reclamation Law and its implementing regulations, a mining permit is required for the proposed development…According to the DEIS, the first year of construction on the eastern component of the proposed Project will necessitate the stripping of 6,800 cubic yards of soil and the blasting of 18,200 cubic yards of rock to create the Project’s detention ponds for treated wastewater. These plans, which involve the mining of 25,000 cubic yards of minerals (more than 30 times the minimum amount required to trigger the statute) within a 12-month period for the creation of a water body, clearly fall within the scope of activities for which a mining permit is required…Significantly, all mining permit applicants must develop a land-use plan and furnish a financial surety…The surety—which may be furnished in the form of a bond, irrevocable letter of credit, or certificate of deposit—is intended to insure that a Project Sponsor does not begin extractive activities without the financial wherewithal to complete the appropriate reclamation…Remarkably, despite this enormous amount of proposed blasting and earthmoving, the Project Sponsor and the DEIS concede that the financing is not yet in place for the Project’s construction. Project approval in the absence of a financial surety raises the possibility that construction of the Project might begin—entailing the blasting of bedrock and the stripping of soil on a scale never before seen in the region—without any guarantee that the Project will ever be finished…Accordingly, a mining permit and the attendant financial surety is an absolute must for this Project.”
“…[T]he Belleayre Project …will result in significant adverse noise impacts which have not been and cannot be mitigated by Crossroads Ventures…The Sound Impact Study (SIS) for the DEIS assumes that increases in existing sound levels of 9 dBA or less are: “insignificant, temporary construction noise”. The DEIS improperly refers to the noise generated at these levels as “insignificant”. Pursuant to DEC’[s] Policy Assessing and Mitigating Noise Impacts, DEC refers to these levels as intrusive and may cause complaints. Yet, these impacts are dismissed in the DEIS without any discussion of mitigation. Clearly, according to the DEC Policy, further consideration is needed…The DEIS states that typical blasting noise levels range between 93 to 94 dBA at a distance of 50 feet. The DEIS also states that blasting noise levels will be only 46 dBA for the proposed project which is 4 dBA below the existing ambient daytime average sound level. The existing daytime sounds, as documented in the DEIS, range from 41 to 50 dBA and are characterized by “wind rustling through the trees” and the sound of a “nearby creek.” The DEIS wrongfully implies that, through noise attenuation, these activities will not increase the current noise levels in the area…Blasting the mountaintop will create an amphitheater effect and the noise levels will be in excess of existing, ambient wind and creek levels…Increased noise levels will impact local neighborhoods during construction of the proposed Belleayre Project. The cumulative effects of blasting and construction will increase the noise levels from levels associated with a rural community to those at equal to an urban industrial area…The Belleayre Project will result in significant adverse noise impacts which will have long term detrimental effects to the surrounding communities which cannot be mitigated and which are not outweighed by the social, economic and other essential considerations.”
“The CPC contends that the DEIS did not adequately address the potential impacts from pesticide use on the proposed Belleayre Project Golf Courses…The LEACHM model the Applicant used to evaluate post-development pesticide transport was run using an inaccurate assumption about the depths of soils at the site after development. The modeling was based on erroneous assumptions and data concerning soil depths at the site. The model also greatly overestimates the attenuation of pesticide loading to transport to surface and groundwater…The pesticide discharges will exceed the limits set forth in the Wildacres Draft SPDES permit due to the defective stormwater plan as designed. The Big Indian Draft SPDES Permit does not include any effluent limits for the pesticides and therefore the permit provides no protection against violation of the water quality standards…The modeling of pesticide leaching to groundwater erroneously uses a default assumption of 2.5 meters of soil above the water table or bedrock. The Belleayre Project plans require only 6 inches of topsoil on the golf course over gravel and sand underdrains, or, in some areas, other boundary conditions such as bedrock. These conditions will likely channel pesticide-laden runoff into the micro-detention ponds and to surface water resources, or into bedrock fractures and then into groundwater…The pesticide monitoring wells set forth in the Draft SPDES Permits will not ensure the protection of water quality. Water quality monitoring must not only occur on a regularly scheduled basis, but samples must be taken from sources that actually reflect any water quality impacts that are occurring since the monitoring requirement is designed to protect drinking water and sensitive trout-spawning habitat from pesticides which can harm human and aquatic life if not detected. The Draft SPDES Permits at issue here, however, designate groundwater monitoring wells that are entirely insufficient to detect such impacts.”
“The Alliance objects to the decision by the DEC not to require the applicant to provide access to the materials in the DEIS through the provision of searchable files in order to insure meaningful, much less full participation of the public and all involved agencies in the review of the DEIS. The DEC's decision not to require this of the applicant constitutes a failure of the DEC in its role as lead agency to provide a complete and impartial review and to facilitate " the weighing of social, economic and environmental factors early in the planning and decision-making process" (6 NYCRR 617.2(n)). Indeed, it is hard to imagine that the DEC would even consider conducting its own review of this mammoth document without the ability to search for information about related subjects across multiple volumes for cross-comparison. The negative impact of this decision was magnified by the DEC's reluctance to extend the public comment period beyond a meager 60 days. Although a longer public hearing period and additional legislative hearings were eventually provided, the constricted initial review period and the limited opportunity for public comment sanctioned by the DEC in its initial notice had the effect of discouraging orderly consideration of the issues and hindered the review of the DEIS by the public and by involved agencies.”
Catskill Heritage Alliance
"…[T]he Alliance notes that several "regional planning studies" cited in support of the proposed project were proposed by and written under the direction of Crossroads' principal, Mr. Dean Gitter. For studies that purport to show the importance of a resort like the proposed Belleayre Resort to have credibility, they should be conducted independent of the applicant. This has not been the case for at least two of the reports cited in the DEIS, the "Route 28 Corridor Commission Report" and the "Tourism Development Plan for the Central Catskills," of the Central Catskills Planning Alliance. Indeed, the degree to which Mr. Gitter, as a private entrepreneur, has insinuated himself into Shandaken's planning process has been remarkable…Can the applicant be requested to prepare a statement of disclosure of his participation relative to the committees and studies mentioned above and any other planning or economic development initiatives cited in the DEIS in support of the proposed project?"
“There are a variety of concerns related to the potential for induced growth associated with the proposed Belleayre Resort. These include demand for new residential housing, development of additional commercial space along NYS Route 28, competing hotel and residential developments, escalation of housing and land prices, and conversion of some residential structures to non-residential uses. In contrast to the DEIS, which ignores the potential for induced residential growth. NYCDEP's analysis indicates that in the next ten years the proposed Belleayre Resort would induce demand for as many as 158 housing units in the primary market area and an additional 160 units in the outlying communities of the secondary market area…The 158 potential new units is greater than the 137 net new units that were added in the host communities during the 1990s. Therefore, compared to a no-action scenario, the development of the proposed Belleayre Resort could potentially more than double the rate of housing growth experienced over the last census decade. While the DEIS states that no new residential development and minimal commercial development will occur, there is evidence in the marketplace that speculative competing developments are already being pursued…The REMI model that NYCDEP used in its evaluation of the DEIS predicts that over the course of the next twenty years, regional land use changes associated with development of the proposed Belleayre Resort are expected to be significant. The predicted 323 housing units that would be built in the primary economic impact area over this period as a secondary economic impact of the proposed Belleayre Resort, could result in the conversion of between 975 and 1.625 acres of land for residential uses (assuming an average of 3 to 5 acres per new housing unit)…A nunber of natural resource impacts are likely to occur as a result of this increased need for residential development (not accounted for in the DEIS), as well as anticipated commercial development, which would have the potential to adversely impact water quality. Potential alterations to natural resources include land clearing for residential and commercial units, addition of impervious surface through paving of roads, driveways and parking lots, and conversion of forest to landscaped areas, which would increase sedimentation, pesticide use, phosphorus and other contaminant loads within the watershed.”
“The CPC contends that the failure of the DEIS and application to adequately address stormwater controls, erosion and sedimentation of the areas surface waters raises substantive and significant issues for adjudication. The DEIS fails to describe, anticipate, and mitigate the effects of large areas of land disturbance (up to 25 acres at a time) in connection with the particular soils and geology of the project sites…As indicated, the applicant’s phased construction plan proposes to disturb up to 25 acres of soil at one time during Phase I and up to 16.4 acres during Phase II. Disturbances of this magnitude would likely cause severe water quality impacts and are not in compliance with permit limits. The New York State General Permit for Stormwater Discharges Associated with Industrial Activities from Construction Activities…limits areas of unprotected, exposed soil to no more than 5 acres at any given time without prior written approval from DEC. Limiting the phasing of construction activities to disturb less than 5 acres or less at a time reduces sediment loadings to wetlands and watercourses; however, exposure of 16-25 acres of bare soil on a mountainside will compromise the effective management of stormwater runoff and may result in catastrophic sediment loading of receiving waters during rain events. The sensitivity of the site including the nature of the soils on the site, the steep slopes and its location amidst important trout streams and the Catskill/Delaware watershed justify a condition that not more than one acre be disturbed at any one time…The Applicant should be required to show exactly how erosion and sediment control would be addressed in an area. The Applicant is requesting that NYSDEC waive its disturbance requirement, but the Applicant has not properly demonstrated that proper erosion and sediment controls will be used to protect these large areas of soil disturbance. Without specific erosion control plans and details the Applicant’s waiver request should be denied.”
“Erosion during the construction phase could have disastrous impacts on receiving waters. Due to the steep slopes, it is unlikely that the level spreaders proposed to establish sheet flow discharge from the temporary construction sediment ponds and the operational phase detention ponds will prevent reconcentration of stormwater flows and erosion of existing drainage channels…The DEIS provides details of gravel/sand check dams for temporary erosion control, which are insufficient and sub-standard practices that will not protect water quality. The Applicant is required to obtain a State Pollutant Discharge Elimination System (SPDES) permit to construct the project because the total disturbed area is greater than 1 acre. The stormwater management criteria are established in the NYSDEC SPDES General Permit for Stormwater Discharges from Construction Activity… The maximum area of disturbance typically permitted under these regulations is 5 acres. Due to the size and complexity of the proposed project, the Applicant has requested orally at a meeting and is acting that it is accepted by NYSDEC to submit a plan with up to 25 acres of unstabilized soil at any given time within each reservoir basin. This deviation was dependent on slope, soil, proximity to watercourses and other site constraints. It is NYCDEP's position that many of the temporary erosion controls are undersized and in some cases inappropriate. It would be catastrophic to the New York City water supply if several of these areas that have been previously stabilized fail, resulting in significantly more than 25 areas of unstablized soil and a potential for a significant release of sediment and nutrient load to the streams and reservoirs.”
“…[T]he DEIS and the applications do not contain sufficient information to analyze stormwater impacts from the proposed Belleayre Project…[T]he use of the WinSLAMM model to characterize pre-development conditions related to stormwater runoff at the project site was improper and that operation of the effectiveness of the stormwater management infrastructure will not achieve the results predicted by the applicant…[N]either the DEIS nor the applications and supporting documentation show whether the project will meet the Total Maximum Daily Load (TMDL) for phosphorous.”
“The DEIS does not adequately address the hydrologic setting for the entire project. Multiple gauging station data was used for various DEIS analyses, which led to an overall design composed of elements that are not based on precipitation data that is representative of the project site. This inconsistency resulted in modeling errors that were used to evaluate the stormwater quantity, the sizing of stormwater Best Management Practices and erosion control measures. These modeling errors will have very significant damaging impacts to the regional streams and reservoirs with increased pollutant loadings, particularly phosphorous and sediment, in the Ashokan and Pepacton Reservoirs. In addition, the stormwater plan relies on sequential routing of stormwater through a series of micro-detention ponds to control the quantity and quality of runoff. While the performance of the micro-detention ponds can not be sufficiently analyzed with the engineering models used in the DEIS, NYCDEP's analysis concludes that they discharge more volume and accomplish pollutant removal less effectively than stated in the DEIS. Finally, the DEIS has not accounted for springs and intermittent channels that exist along the slopes off site where stornwater will be discharged. The existing springs and intermittent streams will add to the volume of stornwater carved through the channels transmitting stormwater discharges from the project site into receiving streams.”
“…[T]he applicant proposes to treat captured stormwater in detention basins with an allegedly “environmentally-friendly” flocculent called chitosan acetate before pumping the treated stormwater into forested land…[T]here is conflicting information on the toxicity of this flocculent to rainbow trout. Since there is a genuine question as the toxicity of this flocculent, the Applicant must be required to evaluate the potential toxicity of Storm Klear under site specific conditions."
“The DEIS misrepresents pollutant loading in stormwater runoff from the site. Analysis of levels of pesticides, nutrients, and sediment that will be discharged to off site receiving waters is misleading. These pollutants will leave the site in quantities that will cause environmental harm…[T]he literature-derived characterizations of both the types and depths of existing soils do not correspond to actual conditions at the site and…the proposed final conditions do not correspond to those utilized in the analysis…Other key stormwater quality issues include insufficient detention pond size to adequately address pollutant removal in accordance with the Watershed Rules and Regulations, due to under-prediction of runoff amounts by the modeling as performed in the DEIS, understating of potential point source discharges which could affect Birch Creek, and failure to perform manual calculations to compensate for the inability of the modeling to fully quantify runoff during winter months…The DEIS explicitly states that both pollutants and solids will be discharged from the site because stormwater detention ponds have been configured with the goal to eliminate temperature impacts in receiving streams, but not also to achieve phosphorus and other pollutant removal level necessary to prevent conditions that are both deleterious to the aquatic biota in the streams and which compromise the quality of the water supplied from the reservoirs. The resulting system is predicted to increase phosphorus loadings from the site under post-development conditions…The effect of the addition of these pollutants and sediments on all organisms in the ecology of the receiving streams is not considered in the DEIS. The effect of the addition of these pollutants to the Ashokan Reservoir, which can become severely eutrophic from phosphorus additions and which has already been designated by NYSDEC as impaired for total suspended solids, has also not been evaluated in the DEIS, nor have mitigation measures been suggested.”
“…[T]he Belleayre Project…will result in significant adverse impacts to the area’s surface and ground water resources which have not been and cannot be mitigated by Crossroads Ventures. The Belleayre Project will result in violation of New York State Water Quality Standards and unduly stress the region’s water resources. As a result, the valuable and unique fisheries will be irrevocably degraded and potentially destroyed.”
“The watercourses impacted by the proposed Belleayre Resort are fed from wetland areas and groundwater that would also be impacted by these discharges. Many wetland areas on the site also would be destroyed. thus preventing their continued contribution to the water quality of the reservoirs. The streams and tributaries throughout the vicinity must meet NYSDEC surface water quality standards designed to support the propagation and spawning of trout. and a varied population of aquatic species on which the trout depend.. This healthy ecosystem forms the basis for Esopus Creek being considered one of the most renowned game fisheries in the world. The unmitigated pollutant discharges to these streams could impair or destroy the trout spawning habitat that supports the fisheries. The Esopus Creek is also enjoyed for recreational and competitive canoe and kayak activities, which could be impaired by degradation of water quality and ecological conditions.”
“The DEIS understates the magnitude of traffic associated with the Belleayre Project and the magnitude of background growth which is likely to occur…The DEIS also fails to consider the effects of the Belleayre Mountain Ski Center expansion…The DEIS utilizes inappropriate traffic count figures for analyzing the worst case traffic impacts…The Belleayre Project will result in significant adverse traffic impacts which will have long term detrimental effects to the surrounding communities which cannot be mitigated and which are not outweighed by the social, economic and other essential considerations. The DEIS did not take a hard look at these adverse traffic impacts and does not provide the Commissioner with an adequate legal or technical record on which to predicate findings…”
“The potential impact on traffic during the construction period (at least 8 years) from worker vehicles, lumber, logging, and concrete trucks, as well as dozens of pieces of large equipment such as cranes and earthmovers, is not included in the DEIS…Vehicular traffic has the potential to adversely impact water quality in the region. Of great concern is that the amount of impervious surface would likely increase significantly through widening of existing roadways off site. Water that washes off paved roadways carries a mix of chemicals, animal waste, and other contaminants. Vehicles leave behind zinc and copper dust from brake pads, tire dust, exhaust particles, and oil and grease. Thus, increases in traffic will increase the amounts of these contaminants present in local streams, all of which supply NYCDEP reservoirs.”
“The Alliance joins with others (Ketcham, Ferrandino) in its critique of the traffic sections of the DEIS. The DEIS clearly does not accurately depict the traffic increases likely to be engendered by the proposed resort and expansions of the Belleayre Ski Center and the Catskill Mountain Railroad. It also does not adequately mitigate the problems associated with expected changes in traffic flow.”
“…[T]he reported development plans of the Ski Center represent a substantial increase in visits and related traffic that have not been accounted for in the DEIS’s impact analysis…The DEIS is thus incomplete until appropriate cumulative impact analysis is completed…Apart from the failure to address cumulative impacts, the DEIS and its traffic impact study are also inadequate because of their singular focus on NY Route 28. NY Route 47 represents an alternative travel route to the proposed Belleayre Resort, particularly for visitors traveling to the site from locations to the South and West…Because this likely possibility is not addressed by the DEIS, the DEIS cannot be accepted in its present form.”
“The DEIS identifies—and the Project Sponsor, in public discussions, is always quick to highlight—an array of technology that is intended to reduce the environmental impacts of the proposed resort, especially on the eastern side of the Project. The effectiveness of such technology, however, must be proven and guaranteed by performance bonds or equivalent financial assurance. Unproven technology cannot be used to justify the issuance of a State Pollutant Discharge Elimination System (SPDES) permit by the DEC…Because the draft SPDES permit relies on unproven technology, it is inadequate as a matter of law. Similar to the technology cited as justification for the issuance of a SPDES permit, the Project Sponsor also relies upon unproven innovation to mitigate the visual impact of the Project. The DEIS acknowledges that the eastern portion of the development will be visible from several nearby viewpoints. In response to the complaints of local hiking groups and in an effort to reduce this visual impact, the Project Sponsor has proposed a “pioneering design” for the eastern hotel and spa which allegedly renders visual impact of the complex “virtually eliminated.” Unfortunately, the Project Sponsor does not offer any study or research to validate its assertion that the innovative design will minimize the negative impact of the hotel upon the viewshed. Because the area’s viewsheds have been identified by local community leaders as among the community’s top assets, the DEC cannot accept the Project Sponsor’s assurances regarding the visual impact of the Project without adequate substantiation.”
“No visual assessment or simulations were completed from the Pine Hill hamlet, the Belleayre summit and slopes or Route 28, the areas most likely to be impacted within the five-mile radius…Based on a review of the surrounding topography, the worst-case scenario for visual impacts will be from across the valley; namely Rose Mountain, Monka Hill and Hog Mountain…The following significant adverse visual impacts should have been evaluated in the DEIS but were omitted: Visual impacts of blasting the top of a currently forested and undisturbed mountain with no consideration to the changes in topography; Visual impacts and potential erosion of stockpile areas and the lack of a stockpile management plan; Visual impacts of clear-cutting over 500 acres and turning much of the area into lawned golf courses and buildings; Loss of forest land that includes the destruction of over 278,000 trees; Light pollution, including night glow, lighting visible from an elevation perspective and glare from lighting during the winter (snow glare), on an historically “dark” region; Impacts on panoramic views and vistas along Route 28 and from other places within a five mile radius of the project site.”
“The DEIS proposes the construction of a new access road extending from Friendship Manor Road perpendicular to Route 28, which would be unsightly and require extensive blasting; no evaluation of the aesthetic impacts or possible mitigations is provided; The DEIS omits mention of and assessment of an access road which was included in the original plans for the resort presented to the public: this access road, formed as an extension of Lost Clove Road, would be nearly invisible from Route 28 and must be considered as a mitigation for aesthetic purposes and noise reduction (less blasting is needed for construction of the extension)…”
“The DEIS does not adequately address the wastewater treatment issues during the eight-year construction period for the project...Ten State Standards requires a proposed plan for management of wastewater during construction activities. The proposed 2.114 person-years for an 8 year construction activity is a significant number of construction workers on site without adequate wastewater management. The DEIS also does not address when the WWTPs will be put on line. or the operation of the WWTP under low flow conditions until fill build out.”
“The CPC contends that the use of the water resources and systems identified in the DEIS (including Water Supply Applications and Water Conservation Programs) for the Belleayre Resort project raise substantive and significant issues for adjudication since the DEIS and water supply applications fail to demonstrate that it can meet the criteria set forth in ECL § 15-1503(2). Neither the DEIS nor the application demonstrate that: the potable water resources proposed for the Big Indian Plateau are adequate…; the use of the potable water resources proposed for the Big Indian Plateau are just and…; the use of the potable water resources proposed for the Big Indian Plateau is necessary…In addition, the DEIS fails to provide essential documentation regarding the applicant's ability to satisfy all of the legal and regulatory prerequisites to use of the identified water supply resources for both the Big Indian Plateau and the Wild Acres portions of the proposed resort…Finally, the CPC will argue that the DEIS does not supply sufficient legal and engineering detail regarding the Water Supply Application for the Village of Fleischmanns to complete an adequate analysis.”
“The project has not been designed to avoid and minimize wetland impacts. The Applicant must demonstrate that wetland fill and other impacts have been minimized and/or avoided. In addition. NYCDEP believes there are wetlands onsite that were incorrectly determined by the US Army Corps of Engineers (ACOE) to be non-jurisdictional. For their vital role in the removal of pollutants from water as it enters watercourses that lead to NYCDEP reservoirs and recharges groundwater systems in the region, these areas should be protected and preserved, regardless of jurisdictional status, to the greatest degree possible.”
“…[T]he DEIS failed to adequately address the significant adverse impacts on wildlife, habitat and fauna…The area provides diversity and rich biological resources. For example, large areas of forest near the Long Clove Trail are dominated or co-dominated by beech which is likely unusual for the Catskill Mountains and may provide special biodiversity values associated with rare specialist insects, fungi or animals that use beech mast as a critical resource…The site is also potential habitat for Northernmonkshood which is designated as a threatened plant species by the federal government…The zoological surveys in the DEIS were not adequate given the size of the site and its seeming diversity…Forest fragmentation and parcelization will degrade the intact hardwood forest cover and likely will result in an adverse impact on the assemblage of forest responsibility species; species that rely on the particular habitat of a region for their long-term conservation…The zoological survey ignored rare or uncommon mammals which would be expected to be present in the well-developed forests and rocky habitats present at the site…The DEIS fails to identify or discuss the potential significance of the Belleayre Project on the extensive forests adjacent to the site. The site forms part of an extensive forest, including the two largest designated wilderness areas of the Catskill Park…A rare plant survey should have been conducted as part of the DEIS process in order to identify rare species in the Catskills in flowering and non-flowering form and sedges of statewide or regional significance…The site survey did not adequately evaluate the site for the presence of Wood and Spotted Turtles, species of special concern and Spring Salamander and Red Salamander which are both regionally rare but which may have been discovered with a thorough analysis..The streams on and adjacent to the site support trout Brook Trout and slimy sculpin which depend on cool flowing water with high dissolved oxygen content and good water quality. As indicated in the expert reports in the Petition for Party Status, the Belleayre Project will cause significant erosion on steep slopes and elsewhere on the site which will result in increased turbidity nutrient levels and temperature which would decrease the dissolved oxygen in the local streams. In addition, as indicated in reports provided by experts in the Petition for Party Status, pesticides and nutrients from operation of the golf courses will threaten the fish population of the local streams.”
"Given the importance of existing town regulations regarding protection of the environmental protection and existing community character, the applicant should be required to comply strictly with them. Yet many aspects of the DEIS are clearly incompatible with the regulations. As an example, consider the clear-cutting required to develop more than 80 acres for buildings as proposed in the DEIS (we could find no indication of how much additional clear-cutting is required for proposed greens and fairways). No mention is made in the DEIS of the fact that the Town's regulations clearly and unambiguously limit the clearing of land for construction of residential or commercial structures to five acres. Similarly, no mention is made of the permits necessary for the land disturbances proposed or to operate rock-crushing and cement mixing plants, yet, again, the Town's zoning regulations…strictly limit such operations. Moreover, the DEIS proposes this project to be registered as both a Petroleum Bulk Storage facility and a Chemical Bulk Storage facility, uses clearly at odds with its mountaintop location in a residential district! Other aspects of the DEIS simply cobble together features of Shandaken's zoning and subdivision laws, as though the project can contain any permitted use or activity from any zone, without any of the restrictions attendant on such uses. For example, the last version of the project application submitted to the Planning Board lists the project as a "vacation resort," a term for which the applicant sought an interpretation from the Shandaken Zoning Board of Appeals in 2001. Leaving aside the most confusing aspects of that interpretation, the clear text of the regulation related to "vacation resorts" states that the "cabins or cottages" of the resort "shall be designed for one (1) family only..." (Code of the Town of Shandaken, Section 116-40E(2)), a provision that the plans of the DEIS patently ignore."
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