Belleayre Resort at Catskill Park
DEIS Completeness Review
by Tim Miller Associates, Inc.

Section 2 Project Description

At 112 pages the Project Description is unnecessarily voluminous. The Project Description would benefit greatly from a thorough editing to reduce its length and focus its information for purposes of review.

For example, Paragraph 3 on page 13 is intended to discuss the project location within the New York City Watershed. A map is provided on Figure 1-4 showing that location. However, a lengthy discussion about the watershed follows that would better be placed in the Water Resources section. This information detracts from the purpose of this section of the report, which is to orient the reader as to the project location.

In general, throughout the project description, is too much numerical information presented within the text Data should be taken out of text where possible and organized in tables. The tabular format should reduce the length of the project description and substantially improve its readability,

The graphics in the project description, generally, need to be clearer and easier to read. The authors should consider color to assist in this goal.

Under Project Location, it would be useful to provide a series of maps that show the site's location from a regional to local setting to quickly orient the reader. Instead, location maps are dispersed later in the chapter.

Figure 1-1 shows the project's location on a State of New York map. This graphic would benefit from the addition of New York State Route 28 and possibly the Village of Fleischmanns on the map.

Figure 1-2, a regional location map, uses as a base the location of community water system sources from the Department of Health. This map is unnecessarily cluttered with streams and watercourses. The location stars are so large on these maps as one of them actually extends outside the boundaries of Catskill Park.

Figure 1-5 is a site location map. The map has been developed on a USGS base. Because the project area is located in a mountainous region this information on the map is dominated by dark contour lines. It is suggested that the contour lines on the map be screened back so that they are a light gray and that the site boundaries be shown with a thinner line in color that will allow one to differentiate easily between the property line and other lines on the map.

Moreover, if the topography is screened back and color is used, labeling can be provided which shows the eastern site boundary as being the Big Indian Plateau, and the western site boundary as being Wild Acres Resort and High Mount Golf Club.

It would also be possible, again using color, to shown the approximate areas within the individual properties that are slated for development.

On Figure 1-6, the layout plan, we again suggest the use of color to differentiate the property boundary lines and the proposed improvements from the base map information.

We also recommend that Figure 1-6 be better labeled so that the Wild Acres Resort is identified with the key development components proposed: i.e. the 18-hole golf course, the 250 room hotel, the 13,000 square feet of retail, 168 residential units and the 21-lot subdivision.

Likewise, the Belleayre Highlands should be identified as consisting of 88 residential units and the Big Indian Resort and Spa should be identified as having, the 18-hole golf course, 150 room hotel, a clubhouse and spa, and 95 lodging units. Providing this information on these graphics will allow the reader to make easy geographic connections with the components of the project and the location maps.

Section 1-2 would benefit by at least two sub-headers organizing and discussing the developed proposal on the east and the development proposal on the west side of the project area.

The section on background and history is not nearly as informative as it could be. What are the historic trends in number of resorts or visitors over time? Are resorts generally on the decline? There seems to be a potpourri of information in this section that is disjointed and out of context. Population increases in the last paragraph are meaningless when expressed as percentages.

There are six or seven pages that are allocated to a discussion of local land use regulations. It is suggested that they be listed here and the detail be provided at the end of the section, or in the land use section of the DEIS as they are not tied in well to the header of project purpose, need and benefit.

The lengthy discussion on site suitability for golf need not be in the Project Description. Suggest putting it in terrestrial ecology section. Figure 2-6, a picture of turf on Belleayre Ski Resort, if needed, can be relocated to the ecology section.

The lettering in Figures 2-14a. and b. is an unreadable size.

All of the discussions on potable water supply, wastewater treatment, traffic, parking, etc., should be shortened and details of existing conditions and the "fit" of this project placed in the corresponding section of the DEIS.

Figures 2-22 and 23 do not succeed in presenting clear information regarding access and roadways. Figure 2-22 is in black and white on a topographic base. The topo base information is extraneous. Screened back topo lines and color is needed to differentiate different lines on this map.

Figure 2-23, for Wildacres Resort, is a counterpart graphic to Figure 2-22. For some reason, it is on an entirely different base map. The authors need to rethink these two graphics to present more easily readable information that succinctly and clearly support the text. All of the destinations discussed in the text should be identified in the graphics. Existing versus proposed roads should be differentiated using color.

Put plant lists in the ecology section with a reference to that section in the project description.

The phasing graphics are impossible for the lay person to understand without detailed labeling.

LOCAL PLANNING ISSUES

2.2.3 Water Supply

(also applies to discussions in 3.9.3 Potable Water and 5.4 Alternative Water Supply.) (TMA did not receive Appendix 7, Water Supply Reports for further information)

A hydrogeologic investigation is mentioned (p. 57, para. 5). Who conducted it? Are the estimates listed in the last paragraph (p. 57) from the same investigation?

Total daily usage of the Village system is estimated exclusive of commercial use (p. 58, para. 2). Such use should be included in the estimate.

Page 58, last 2 paragraphs, and the same text on page 294, discusses developing a new groundwater source in Fleischmanns. What is the point of this information if it is not proposed?

Or is it proposed? What are the benefits and adverse effects of this? Would it be on Village land? Any benefit to the Village? If it would be dedicated to the project as stated, why should it be located near the Village well?

Page 59 at top, "Alternatively, treated water could..." should be changed to "As proposed, treated water would...".

Page 59, para.2 is disjointed. The sentence "The Village has applied for funding..." should be moved to the previous page 3rd para. where funding is discussed. The next sentence implies that the developer is counting on Village water system upgrades to meet its water needs. If so, this must be clearly stated and those upgrades listed.

3.8.2 Land Use / Community Character

"...need for an additional 76,700 square feet of new commercial development in the study area. This need may be accommodated..." (p.218, 4th paragraph)

Although it would not represent a significant increase in relation to the total study area, a single development of that size, as suggested, could be catastrophic for residents or businesses near it. Depending on location, such a size of development could ruin the "small-town, rural character" that the resort and the affected communities are trying to enhance. Would there be any type of business or businesses that could be attracted to the area of this size? The sentence should emphasize that this is an improbable scenario if that is the case and indicate to what extent in-filling of existing vacant buildings could accommodate this amount of square footage.

To what extent will project induce new residential development nearby?

3.8.3 Local/Regional Plans

The 1977 Ulster County Land Use Plan is not discussed. What does it say relative to the project area?

Per scope, could this project affect future land use plans?

3.9.1 Emergency Services

Statements conflict in potential impacts discussions for hospitals and police. If service providers are fully capable of serving the project, then additional staff or resources is not needed. If this is not the case, state the shortcomings. What are the expected numbers of emergency calls to the project? (TMA did not receive Appendix 6, Letters of Record for further information.)

3.9.3 Potable Water

B. Potential Impacts

A water supply evaluation is cited (page 238, 2nd para.) but the evaluation results need to be stated as well.

Total daily usage of the Village system is estimated exclusive of commercial use. Such use should be included in the estimate.

Page 238, 2nd para., "opportunities to develop new source capacity with the Village" of Fleischmanns is mentioned. What is the point of this statement, given the tremendous existing supply?

C. Mitigation

If the Fleischmanns water supply system is so seriously in need of repairs, and this project expects to connect to it, this project should contribute its fair share to make such repairs. The alternatives section indicates "improvements must be made to enable the Village to sell water to the development". Specifically what are the proposed improvements? Without repairs, would the significant draw from the project impact the existing system facilities? Can the Village treat the additional water needed for the project? How does the cost of additional treatment compare with revenues generated by the water purchase? Should treated water be used for irrigation?

Section 4: Unavoidable Adverse Impacts

As there is no summary of potential project impacts elsewhere in the document (other than benefits in section 1.3.4), this section should include quantification of all impacts for each of the studied assessment areas, broken down by project component in the project and local regulatory jurisdiction (to facilitate review by each municipality). Reference to this section should be added to Section 1.3.4 of the DEIS Introduction.

LOCAL TRAFFIC ISSUES

Site Plans / Maps

Sight distances should be added to the full size plans and any easements necessary to obtain clear sight distances should be indicated. Also indicate areas where snow accumulation may be a sight line problem.

There should be a regional map provided to cover the larger area described in the DEIS text. This is important to trip assignment.

Section 2.2.7

Sight distance for the golf course maintenance facility access to County Route 49A needs to be discussed. Sight distances at golf cart path road crossings should be indicated on plans and discussed in the text.

Discussion of ATV or snowmobile use needs to include provisions to prevent trespass by unauthorized individuals.

3.7 Traffic Patterns

Although traffic counts are not required at existing local roads, the intersections need to be characterized generically. Construction traffic has been discussed in terms of volumes for cut and fill. Additional information on construction traffic including routing has not been discussed. The lower trip assignment to local roads does not abrogate the need to discuss local intersections with basic descriptions. geometric deficiencies, and sight distances.

The traffic study does not discuss other recent studies by the New York State Department of Transportation (NYS DOT) or other agencies. It does include limited data from the 1999 traffic volume report.

Has the NYS DOT ever been consulted regarding seasonal adjustments? Obtaining traffic counts from NYS DOT does not qualify as consultation. The Scope for attachment 5, item 6, specifies using NYS DOT projected growth rates.

The inventory of pedestrian activity was limited to those locations where intersection counts occurred. There should be discussion of activity at local intersections and internal locations. At a minimum, pedestrian activity should be characterized. Figures should be added to show key pedestrian routes, and text should indicate if these have lights.

The discussion of off street parking should be summarized with a table showing land use, number of employees, parking by type (staff, guest, shuttle bus etc.), pedestrian connections and shuttle bus access. There is no discussion of special event parking.

The scope requires projected analysis for first year open and one year after full utilization. The traffic report indicates the project will open in 2006 but not be completed until 2008. The scope infers the analysis should then be for 2006 and 2009 (one year of full utilization). The traffic study only shows 2008- If the mitigation is to occur in 2008 this means up to two years of increased traffic without mitigation. Timing of each mitigation measure should be clarified. (The reviewer suggests that intersections at level of service C or better for all movements in the build condition without mitigation would not benefit much from further analysis of 2006 and 2009.)

A qualitative assessment of internal and local vehicular and pedestrian conflicts should be included in the document. This should also include a map indicating shuttle bus routing, parking lots, and major pedestrian ways between different plan elements.

Police accident reports should be reviewed also. There have been historical problems with State records being incomplete.

Given the deviation of accident rates for zero-to-two-accident locations, this data should be deleted from the discussion, as it is not sufficiently precise. The accident rate data was not required as part of the accident history data.

Scope Attachment 5. Traffic

Item 2 requires evaluation of Main Street and Bonnieview Avenue. This evaluation may be more general than is required for intersections to be studied for level of service.

Item 3 specifies that existing data from the NYSDOT and County will be obtained. There is no indication that turning movement data or detailed automatic traffic count data was obtained from the NYS DOT or any County data was obtained.

Item 3 also specifies that attendance records and trends from the Belleayre Mountain Ski Center be obtained. Recent data should be discussed in light of historic attendance. As this year has had little natural snow there is reason to validate the data. Figure 3.5 should be referenced as to the source and year of data.

Item 4 sight distance discussion must show the recommended intersection sight distance and stopping sight distances based on the existing speed limits. The failure to meet even stopping sight distances at site accesses needs to be discussed in relation to NYS DOT policy and standards for Entrances to State Highways and County standards. The study should also look at sight distances of vehicles turning left from the main highway and vehicles approaching from behind vehicles stopped in the main highway making left turns. In the latter case, stopping sight distances should be evaluated.

Build conditions should show the delay and level of service with and without mitigation.

Since standards for level of service are based on lane groups and not approaches, summary tables should show lane groups when different from approach values.

Item 6 - Have local planning boards been consulted about other projects that need be included in the no build traffic?

Item 7 requires a check of unsignalized intersections to see if signal installation is warranted. This has not been done even for the intersection with a proposed signal mitigation. There should be a discussion of the warrants for left turn lanes. Left turn lanes should also be considered where main highway through traffic has nonstandard sight distance to left turn queues in the same lane.

Item 8 requires that any local intersections where volume may increase by 10% or more be discussed. This leaves the document to either generically discuss the local intersections or count them and show volume increases are less than 10 percent. Trip generation assignment of even two percent could result in a volume increase of 10 percent and thus such is insufficient cause to eliminate discussion. Traffic distribution from the project is shown as distribution percentages but also needs to be shown as overall site trips in the network.

Page 20 of the traffic study indicates that "There will be no patron parking located on the Wilderness Activity Center site so, no additional trips were added to the trip generation estimates for this facility" It would be expected that some people would still go to this site because of the activity center. Thus, trips would be generated between the activity center and other parts of the site and there would be some level of shuttle bus traffic associated with it.

Shuttle bus routing and frequency needs to be discussed as part of the trips generated by the site.

Tables 3.2, 3.3 and 3.4 should contain information as to the season for each trip generation period.

Item 9 requires improvements be shown to offset unacceptable operating conditions. These should be shown in a summary table for level of service with no build, build and build with mitigation. Where new sight distance conditions do not meet standards, a closer examination of grading and realignment changes to meet acceptable operations verses signing is needed. Sight triangles should also be reviewed for maintenance of vegetative cover.

An overall evaluation of the County road geometry is needed to review whether the existing speed limit is too high. A map depicting existing warning signs, recommended speed plates, and speed limits should be included to characterize existing conditions

SOCIOECONOMIC ISSUES

3.10.1: EXISTING CONDITIONS

A. Methodology:

The Study Area is not well defined which makes it difficult to understand the impact in the context of the area. A map is included (Figure 3-43 and 3-44) but the zip codes and geographic boundaries are not clear. The Figures as presented are unreadable and the two Figures should be provided at the same scale. Appendix 26 (Figure 2-1) identifies the zip codes, but not in a geographic context such as roads and municipalities. The maps in the DEIS should clearly identify the study area.

It would be helpful to include a chart in this narrative section with the following information for all 15 Zip Codes:

Zip Code	Municipality in which Located	County
12406	.	.
12410	.	.

The text states that this section relies upon a business field survey conducted by the applicant. This survey should be described, its validity and limitations explained. Wherever the survey is relied upon in the socioeconomic section, it should be cited.

B. Demographic Characteristics of the Study Area:

Because the study area is only 4 percent of the Total Tri-County population, a statement such as the following is exaggerated:

"... the population of the three counties was about 274,000 in 2000, growing 6.5 percent since 1990, significantly faster than the study area." (page 244, Section B., paragraph 1)

All of the data is aggregated for the entire study area. If the study area was disaggregated by zip code and then grouped by County, comparisons among the three counties could be more clearly made.

Such comparisons would be justified if more detailed information on the study area demographics was provided that supports them. For instance, Age Group Distribution and Household Characteristics for the Study Area and the three counties are not included in the DEIS or in Appendix 26. This information is necessary to understand Household Trends, Population Changes, and Income Distribution. If there is a large proportion of people over Age 65 or a large proportion of single-parent household families, the lower incomes would be more easily understood.

In the same vein, average income is used as the indicator rather than the more acceptable median income. Average income does not account for extremely high or extremely low incomes in the distribution while median income gives a clearer comparison.

"The percentage of these second home units is significantly higher within the study area. For example, in 1990, 43.0% of all housing units in the Town of Shandaken...while 45.2% of all housing units in the Town of Middletown were for seasonal, recreational, or occasional use. Second-home owners and users are not accounted for in the population figures cited above and in Table 3-39." (p. 245, paragraph 3 of Section B.)

The large proportion of second homes suggest that there is a large part-time resident population with plans to retire to the area. The fact that the project is intended to provide yearround recreational activities makes the second-home market characteristics important. Are they relatively wealthy and intending to retire to the area if there were more year-round activities? Are they entrepreneurs who would establish home offices or businesses in the area if there were more year-round activities? Even some anecdotal or narrative description would address the significance of the second home population.

C. Workforce Capacity and Opportunities:

"As shown in Table 3-44 below, from 1990 to 1999 Greene County maintained the highest rate of unemployment among the three counties from 1990 to 1999. Over the decade, the tri-county area mirrored the general unemployment trends for the State as a whole." (page 246, last paragraph of Section C.)

The unemployment rate is exaggerated and is not significant. Table 3-44 indicates that in Delaware and Greene Counties the unemployment rate is less than (or about the same as) the State unemployment rate for each year from 1990-1999. Furthermore, Greene County's unemployment rate may have been the highest of the three study area counties because it was the only one that had a positive change (2.5%) in the labor force per Table 3-43. In 1990, 1991, 1992, 1993, 1996, 1997, 1998, and 1999 Greene County's unemployment was either less than, or no more than 0.4% higher than, the State wide rate.

D. Labor Force Demographics:

"Delaware and Greene Counties both lag behind New York State in the proportion of population over 25 years old with a high school diploma (see Table 3-45 )." (page 246, paragraph 2 of Section D)

The "lag" does not appear to be significant. While the New York State percentage was 74.8, Delaware County was not far behind at 74.0% and Greene County was 72.8%. The lower percentage of the over 25 population with college degrees does not indicate that Greene & Delaware County residents are undereducated as there may be people that have more than two years of college but never finished their degree. Further, it is not unusual for rural counties such as Greene and Delaware to have a lower percentage of college graduates as many employment opportunities in rural areas do not require college graduates.

"The average household income in the NY Route 28 corridor is less than that for all the individual counties, ... The potential problems associated with relatively low levels of education and income are exacerbated by labor force dynamics typically associated with rural areas:..." (page 246, paragraph 3 of Section D.)

Age distribution may also explain lower income. If there are many retirees on fixed incomes, the income level will average out to a lower amount and they may have assets (wealth) which would not be reflected in the income data. It is also important to use median income, not average income as it is a more revealing indicator.

Another important point with regard to income is that manufacturing and construction jobs tend to pay relatively high wages, and typically do not require a college degree. Therefore, too much of an interrelationship between income and education is drawn from the statement noted above.

"The commuting patterns shown in 3-46 suggest that the area's workforce is dispersed among at least three different labor markets. It is clear that there is a substantial labor market that is highly localized in nature." (p. 246, par. 4, Sec D.)

Which three labor markets? In all 3 Counties more than half of the workers work in their County of residence and in Delaware County 52% work in their Town or Village of residence. This does not indicate a dispersed workforce. Although Table 3-47 explains somewhat where the outcounty workplaces are, this is reported in numbers only which makes it impossible to compare with Table 3-46 data which is reported in percentages only.

"...during the relative prosperity of the 1980's, each of the counties experienced an increase in the number of relatively high-skilled precision production, craft and repair occupations (See Table 3-48). Yet, even in the midst of the economic expansion, there were dramatic declines in such lower-skilled manufacturing , occupations manufacturing occupations..." (p. 247, par. 6 of Sec. D)

There was no economic expansion in the manufacturing sector anywhere in the country as industrial firms were becoming more automated in the 1980's. Again, too much importance is placed on the lower rate of college graduates, because high-skilled precision production jobs typically do not require a college degree.

"The data for Delaware County show a substantial cut-migration among the 25 to 29 year olds, which can only be partially accounted for by the exodus of SUNY Delhi graduates returning to their home counties. This out-migration ...may account for the workforce's low education level, despite the strength of the area's public schools." (p. 247, last par. of Sec. D.)

There is no out-migration data in Section D, nor was any found in the Appendices, thus, there is no evidence of substantial out-migration. The data must be cited.

E. Economic Trends and Conditions:

Per the scope, potential new commercial development projects that could effect local employment must be identified.

"Other major sectors include manufacturing, with 13.5 percent of the employment, and public administration, with 10.9 percent for the three counties. Both these sectors are slightly higher than the state ..." (p. 248, Sec. E, paragraph 1)

Table 3-50 indicates that the Manufacturing Sector in Delaware County was 27.6% in 1999 which is significantly higher than the State and the other two counties. The fact that this percentage is such an outlier suggests that same plant or major industry is present in Delaware County and it should be explained.

Retail trade is also significantly higher than the State and, given its importance to the proposed project, there should be more specific information on the existing retail businesses in the study area.

"As shown in Table 3-53, tourism accounted for more than $395 million of the tri-county area's economy in 1997. ...expenditure figure includes spending on hotels, transportation, food/dining, shopping, and entertainment and miscellaneous expenditures comprising elements of both the service and retail sectors." (p. 248, paragraph 4 of Sec. E)

What were the total expenditures? What percentage of the total expenditures did the $395 million represent?

There should be a summary inventory of the retail / service mix in the study area. This will help explain the significance of the large total tourism expenditures. It is also important to know what types of local businesses may be impacted by the proposed development.

"There was great variation among the three counties, with a 0.8% increase in total service sector employment in Delaware County, a 20.2 percent decrease in Greene County, and a 2.0 percent increase in total retail employment in Ulster County." (p. 248, paragraph 6 of Sec. E.)

The paragraph starts out discussing service sector, however, retail employment is referred to for Ulster County. The 20.2% decrease in Greene County is not specified, although it is assumed to be service employment. In any case, some attempt should be made to explain a decrease so much higher than that of the neighboring Counties.

Tables 3-56, 3-57, 3-58, and 3-59 are all described on page 249. However, there is no real analysis and no data is reported in terms of the study area, only in the context of the three Counties. It is critical to have some summary information about the types of retail and service establishments in the study area as the existing businesses will be the most intensely impacted by the proposed development.

In conclusion, Section 3.10.1 would be improved with available data from the 2000 Census, as too much reliance is placed on the 1990 Census data.

3.10.2.1 Potential Impacts / Construction Phase

A. Introduction

"This analysis examines the effect of the project in terms of employment, wages and salaries, and tax dollars generated during the projected eight year construction period." (p. 250, par. 1)

This would be a good place to summarize what will be included in each phase of construction as it would help to clarify the cumulative effects during construction, not just at the end of eight years. Perhaps a chart with the following information could be inserted in the next paragraph or immediately following Table 3-60.

Phase	Building	Year 1	Year 2	Year 3	Year 4	Year 5	Year 6	Year 7	Year 8
1	Golf Course 1	ü	ü	.	.	.	.	.	.
.	Hotel - 150 Rooms	ü	ü	.	.	.	.	.	.
2	Golf Course 2	.	.	.	.	.	.	.	.

The RIMS II model should be explained more fully, including the appropriateness of its application to this situation, its shortcomings, assumptions and adjustments made and why.

RIMS model data is not included anywhere in the document and is needed to verify the information provided.

B. Economic Benefits

"The table shows the estimated cumulative effects of the project investments over the eight-year construction period, and models the projected benefits on an annual basis. Table 3-62 presents the same information broken out by each of the major components of the project." (p 251, par 2 Sec B)

Since the economic benefits are broken out by the various components of the project, it would help to know the phasing. Showing the timing for each component would indicate whether the initial phases will generate enough revenue to begin the revitalization of the area. Averaging out the benefits over 8 years does not demonstrate what impact components completed in the first two years will have during the six remaining years.

Employment

"In addition to the direct employment resulting from construction activities, the total employment resulting from construction ... includes jobs in businesses providing goods and services to contractors and workers..."

Examples of businesses that would benefit (e.g., lumberyards, plumbing supplies, etc.) and some sense of whether any of these businesses exist in the study area should be cited.

Wages and Salaries

Again, using averages and lumping the single family residential wages and salaries in with the larger project components does not present a clear picture of the up-front benefits in the first couple of years. Further, there is no analysis of what these totals mean at certain junctures in the eight year project.

Economic Activity

"...construction workers would be expected to travel fairly long distances to work at the project site, as there are not enough specialized construction workers locally within Delaware and Ulster Counties. Vendors and businesses serving the construction activities would also be expected to be drawn from a wide area." (p. 252, last paragraph of this subsection)

Are there local unemployed or underemployed workers with skills transferable to construction?

Although construction of the project is temporary, this project will occur over an eight year period. It seems that there will be some long term impact on the local economy that could be mentioned in this section.

C. Fiscal Benefits

"Of these amounts, the largest portions would be derived from sales tax, personal income taxes and corporate, business, and related taxes on the direct and indirect economic activity." (p. 253, last sentence of this subsection)

A breakdown of what is included in the Table 3-63 totals should be included because there is no way of knowing whether the above statement is true. What proportions of the totals are represented by the specific taxes mentioned in the above cited statement?

3.10.2 Operational Phase

"For the purposes of this analysis, all operations are assumed to begin only after full construction of the resort's planned amenities. This is a more conservative approach to estimating future economic benefits, as it does not account for the economic benefits of resort amenities that would be operational during the eight - year construction period." (p. 253, last paragraph of Section 3.102 A.)

Presumably, some of the recreational amenities could be operational by the third year of construction. This could be significant in terms of revenue for the local economy and the project itself and further emphasizes the importance of indicating what will be constructed in each phase. A pro-rated share of the total economic benefit for each component could be annualized to demonstrate the economic benefits in the early operational years before total completion. It seems that eight years is a long time to wait for any long-term economic benefit when there will obviously be economic benefit at least by the third year of the construction period.

B. Direct Economic Benefits

Direct Employment

"When complete, Belleayre Resort would represent one of the region's largest private sector employers.... However, full-time employment demand is not anticipated to overburden the existing labor supply." (p. 254)

If 747 full-time equivalent positions will be available at completion, how many will be available by the end of Phase 1, Phase 2 and so on. Some people who could be considering outmigration may be encouraged to stay in the area if a significant number of permanent jobs will be available in two years. However, eight years is a long time to wait for the hope of a large influx of permanent jobs.

Also, who are the other major employers in the area?

Direct Wages and Salaries

"The salaries ...range from $28,000 to $150,000." (p. 254, last sentence in subsection)

This is a wide range, some idea of salaries within the range (e.g. middle-management range) and number of employees in the higher range would give a clearer picture. Table 3-65 could indicate what year each component is expected to be completed to give a sense of when jobs will be available.

Projected Annual Revenues

If Table 3-66 identified year of completion, it would indicate more clearly how significant the project will be. An eight year wait for the $20,858,187 annual Hotel revenue is along time. If it could be 50 percent complete by the third year that could mean a 5 year jump-start with about $10 million in annual revenue.

C. Indirect Economic Benefits

Overview of Methodology:

This section should include some inventory of existing business types in the Towns of Shandaken and Middletown that are used in the RIMS II analysis and the secondary activities (e.g., gas stations, restaurants, lodging, etc.).

It is stated that the RIMS II model used the latest available data in November 2000, however, the source of the data should also be stated.

Actual RIMS II output data would substantiate the detail included in the summary tables throughout this section.

Employment:

What is the distribution of 211 off-site jobs? At least a narrative description would be useful, as there is no analysis of Table 3-67.

Wages and Salaries:

Table 3-68 should at least have a column with average wage shown. There is only a recitation of the numbers in the narrative. There should be a brief analysis of what the numbers mean in the context of existing wages and salaries or existing businesses.

Total Economic Impact

There is no analysis of Table 3-69. Some mention of the annual indirect effect of $21.11 million in the context of the existing sales in the three counties would lend some meaning to the numbers.

D. Fiscal Impacts

This section should follow Tables 3-67 through 3-69 because the tables refer to the previous section.

A list of the specific taxing jurisdictions by County in this introductory paragraph would lend some perspective to the remainder of the section.

Sales Tax:

"Based on the anticipated patterns of visitation (drawing from a wide area, including much of southern New York State), much of this revenue might not be new for the state, but rather would reflect revenues from purchases already occurring in the state that would be transferred to the site." (p. 257, paragraph 2)

This sentence is run-on and redundant and should be split into two. Also, there should be some more specific information about where the visitors originate for the second-home market and the existing ski facility. To put increased sales tax revenue into perspective, add a column to Table 3-70 with average annual sales tax revenue for the last 3 years.

Existing Property Taxes:

If a listing of the taxing district (listed in 4-8) had been provided in the introduction to this section as mentioned above, the reader would not have to refer to 4-8.

Table 3-71 and 3-72 should break down the assessed value by residential and commercial property because the project will be predominantly commercial. The Format shown below is a suggestion as to how this could be shown. Is the 387.22 acres in Town of Middletown (Table 3-72) taxed as residential or commercial? If it is all commercial this should be noted. If a portion is residential this should be reflected as shown in the sample format shown below.

Taxing District	Res. acres	Res. AV ($000)	Comm acres	Comm AV ($000)	Total AV	Tax Rate/$1K	Estimated 2001 Tax
Ulster County General	.	.	.	.	.	.	.

Future Property Tax Revenues with the Proposed Project:

The values in Table 3-73 would be more meaningful if, in the first paragraph of the section, development components were described in a format such as the one below. In fact, if this type of format were used in the Project Description it would help to understand most of the Tables in Section 3.10.1 and 3.10.2.1

.	.	Phase	Year Complete	Percent in Middletown	Percent in Shandaken
Big Indian Plateau	150 room hotel	.	.	.	.
.	Detached lodging	.	.	.	.
.	Country Club	.	.	.	.
Wildacres Resort	250 room hotel	.	.	.	.
.	Conference Center	.	.	.	.
.	Detached lodging units	.	.	.	.
.	Golf Club	.	.	.	.
High Mountain Estates	21-lot subdivision	.	.	.	.
Wilderness Activity	Description	.	.	.	.

"As shown in Table 3-_' the estimated total assessed value..." (p. 258, last sentence) Insert the Table number "3-73".

Table 3-76 should be inserted at the end of section rather than following the introduction to Section E.

E. Effects of Resort Visitors and Guests

What was the source of Crossroads, L.L.C. data?

Projected Resort Visitation

"The visitors attracted by the resort would generate economic activity on account of...." (p. 260, paragraph 1 of subsection) Sentence is run-on and hard to follow.

Will the existing businesses be hurt by the restaurants and retail outlets or will the new businesses provide a catalyst to revitalize existing business activity? It is important to have some sense of what comprises the existing retail / service mix.

"As shown on Table 3-78 above,..." (p. 263, paragraph 7 of subsection) Change "above" to "below".

"Industry surveys conducted by RCI Consulting..." (p. 263, 2nd last paragraph) This paragraph would be better placed in the introduction to Timeshare and Vacation Club Visitation as it describes the market demographics for the two types of facilities. This would help to clarify much of this section.

"Table 3-79 below..." (p. 265, last paragraph of subsection) Change "below" to "above".

Hotel Visitation

"These overnight lodging accommodations would be divided between the Big Indian Resort (150 rooms) ... and the Wildacres Resort (250 rooms)."

Insert number of rooms as indicated in underlined above on p. 265, second sentence of subsection.

Highmount Estates

Estimated home construction cost is cited as $500,000 here, while is cited as half that amount in 3.10.2.1.

"Based upon research conducted by the U. S. Census Bureau, the anticipated median age of buyers of Highmount Estates-type properties would be 52..:" (p. 268 , last paragraph)

Where is the back-up data for this entire paragraph. Also, given the anticipated market there is a need to have some age group distribution data for the. study area.

"...second home owners in mountainous vacation areas could be expected to spend from approximately $120 to $212 per day or an average of $166 ... similar to $170 per visitor party ... estimated by RCI Consulting." (p. 269, first paragraph)

On page 267 the assumption is $100 per day - needs clarification.

Conference Center

"...due to the captive nature of conference visitors, the effect of conference visitors on businesses in the study area is anticipated to be negligible:" (p. 270, end of first paragraph)

Many conventioneers and conference attendees may want to visit local restaurants, or return to area for vacation - this could be a significant secondary impact. The assumption above seems flawed and should be reconsidered.

Restaurant Visitors

"The economic effects of the restaurant revenue and employment is accounted for previously in this section:" (last sentence of section)

What is not accounted for is the effect of 10 new dining facilities with a combined total of 1,080 seats on the existing local restaurants.

Summary of Effects of Resort Visitors

There should be some brief recap of the analysis and what the impacts will be. All the summary does is repeat the total numbers without any relationship drawn between existing conditions and the proposed development.

3.10.3 Mitigation Measures

"Municipal revenues generated by the project will greatly exceed any cost..." (p. 271)

There is no cost projection. What about Fire? Police? EMT? Utilities? Are schools overburdened now? If there are new residents with school age children can schools handle increased enrollment?

GROWTH INDUCING / SECONDARY / CUMULATIVE IMPACTS

7.1 Introduction

"Two main types of potentially induced economic activity are considered:

New commercial development (or'gateway development") along NY Route 28; New residential development, both seasonal and year-round." (p. 322, paragraph 1)

Equally important is a third type of economic activity that should be considered - that is, expansion of existing businesses. The local village and hamlet commercial activity help establish the identity and attraction to the area and the effects on them are critical.

"The three case studies ...provide an important perspective on the manner in which resort-type development affects the surrounding communities in terms of commercial and residential demand and growth:" (p. 322-323, last sentence of paragraph 4)

Given the importance placed on the case studies, a summary comparison chart of the three resorts along with the proposed resort should be provided in this section. While the Appendix includes fairly detailed descriptions of each, there is not even a description of their locations in Section 7

7.2 Commercial Development Demand

"This section describes the economic model... and estimates how that new demand might be manifested in terms of new or expanded business development in the study area." (p. 323, paragraph 1 of section)

Briefly define the "economic model" and sources used to develop "reasonable estimate."

"new expenditures are then compared with existing sales in the corridor measure the relative impact of the new demand." (p323, last sentence)

Also should mention that approximate existing square footage should be considered as a reference to existing sales and sales per square foot estimate.

Insert underlined sentence:

"...a certain amount of off-site economic activity by visitors to the Bellesyre Resort. Typical trip expenditure categories include Restaurants Groceries Gas & Oil. Recreation. Personal Services, Apparel and General Merchandise. Based on research regarding typical expenditures of visitors to other resorts.... (p. 324, paragraph 2)

"The corridor represents only about five percent of the households or workforce of the tri-county ...model assumes that 50 percent of the wages and salaries would be paid to (and subsequently spent by) employees within the corridor." (p.324, second paragraph of subsection)

Clarify what this means. e.g. 50% of wages (from the Resort? in the Region?)

Distinguish between households and workforce. Is the corridor 5% of the households or 5% of the workforce?

"the corridor's share of the total activity is approximately $2.17 million per year." (p. 325, last paragraph of subsection)

Was the 5% share based on Households or Population? This makes a difference, particularly with such a large proportion of seasonal homes. The rationale used for the calculation is not clear.

Summary

Insert text as follows at the beginning of the first sentence on p. 325 to clarify where the numbers in the paragraph come from.

"Figure 7-1 illustrates that, in total, the proposed project will generate..."

"...demand that will either be accommodated by the existing business in the corridor or through new business development." (p. 325, second last sentence)

Why not change to something like the following:

"...demand that is likely to be accommodated by expansion of existing business in the corridor. The limited developable land, environmental constraints, and the existing business community make entirely new commercial development an improbable outcome."

This may help to alleviate the anxieties of some existing business owners in the area.

7.3 Potential Induced Development

"Based upon the inventory of existing businesses, a business survey..., there is sufficient capacity within existing businesses to accommodate the projected spending.." (p. 326, last paragraph)

How do we know this if we do not know what kind of businesses are in the Corridor? Include a chart with types of businesses. For example, add a column to Table 7-1 after "Categories" with "Number of Establishments" for each category in Table 7-1.

The study should also be referenced and summarized in Section 3.10.2 as it is important to the discussion of off-site economic impact.

"Approximately 21,500 square feet of general and miscellaneous merchandise could theoretically be supported by new spending. Much of this new growth would occur within existing commercial area, especially as reoccupancy of vacant structures or in-fill development in hamlets and villages. ... Alternatively, one new shopping center totaling 21,500..-" (p. 327, paragraph 3)

Why not expand on the potential of development within existing? How many square feet of General Merchandise and other retail currently exist? Are there adjacent vacant stores for expansion opportunities?

A new 21,500 square foot shopping center is highly unlikely, Chances are that the demand could be supported by existing business expansion and the retail in the proposed development.

"The second largest potential increase ... is in the eating and drinking sector where ...$4.4 million in new sales would support an additional 17,600 square feet." (p. 327, last paragraph)

Again, what types of restaurants currently exist? Are there vacant spaces within existing commercial areas suitable for new restaurants? Is there potential for many different types of cuisine to provide a supplement to rather than direct competition against existing restaurants?

Page 328, 2nd paragraph includes the level of detail and analysis that should be provided for the other types of business. Are there other new specialty food stores planned? How many additional square feet have been approved for the A& P supermarket ? It is conceivable that this one expansion could provide the additional 12,600 square feet of potential demand.

"...automotive uses. ... Approximately 70 percent of the increase is attributable to sales of gasoline, oil, and service..." (p. 328, last paragraph)

Using 13,900 square feet of new development for this category is not meaningful. It may be better to note locations of existing gas / service stations and whether their locations adequately serve the area. If locations are not too far apart, then do they each have a sufficient number of pumps and / or service bays? Dc they have adjacent land to expand stations? Is there a need for a new station in some part of the service area that is underserved?

2. Guiding New Commercial Development

"Even if all of the 76,700 estimated square feet of new commercial activity were to be developed in one project, the total amount of land required would be between 5 and 10 acres. In a 107,000 acre study area, this does not represent a significant increase." (p. 329, last paragraph)

Although it would not represent a significant increase in relation to the total study area, a single development of that size, as suggested, could be catastrophic for residents or businesses near it. Depending on location, such a size of development could ruin the "small-town, rural - character" that the resort and the affected communities are trying to enhance. Would there be any type of business or businesses that could be attracted to the area of this size? The sentence should emphasize that this is an improbable scenario and indicate to what extent infilling of existing vacant buildings could accommodate this amount of square footage

"It can safely be assumed that all interval units would be purchased on a seasonal basis, and that most, if not all, of the 21 single-family detached homes ... would also be seasonal." (p. 330, paragraph 1)

Why would the 21 single family homes necessarily be seasonal? If the idea is to create year-round recreation amenities would some of these owners be retirees or others who might want to make this their primary residence?

1. Seasonal Residential Development

"As the case studies in Chapter 6 of Appendix 26 have indicated ..." (p. 330, first sentence of subsection)

Insert location of case studies as noted above.

"For example, as Gore Mountain, located in the Adirondacks near Lake Placid, has upgraded its facilities and enhanced its market, the demand for seasonal residential real estate and overnight accommodations has increased." (p. 330, second sentence of subsection)

Insert location of resort or include chart in this section with location of resorts used in case studies. Note that the seasonal residential real estate may be better than in Windham (as described in the next few sentences) because Gore Mountain is farther from urban centers. Therefore, visitors are more likely to come for extended stays rather than for day trips.

"Greylock Center's creation of seasonal residential housing is largely speculative, and is occurring in a climate of limited demand far seasonal second homes." (p.330, second last sentence of paragraph 1)

Note the access problems at Greylock from Chapter 6 of the Appendix.

"Belleayre Resort's marketing program would target the demographic groups most likely to find this form of ownership attractive, and would draw from an international pool of prospective purchasers... special marketing effort will target New York and Albany metropolitan area skiers." (p.331-332, last two sentences)

Who are the target groups? Briefly describe the demographics or note that some characteristics are described in the narrative for Tables 7-2 and 7-3.

In general, this section is rather long and disjointed. It would be easier to follow if it were broken up into subsections.

2. Year-Round Residential Development

"The Resort would ...provide a small number of mid-and upper-management jobs that would probably be filled by non-residents-" (p. 334, paragraph 3 of section)

There may be people that grew up in the area or some that have second homes in the area suitable for the mid to upper management positions, particularly, since there are only 16 to 20 positions in that category. It seems that some of the people that grew up in the area could be graduates of Cornell University or Culinary Institute. Both schools are noted for hotel or restaurant management.

7.4 Potential Impacts From Induced Growth

Where is the Alpine Inn (p. 335, last sentence of paragraph 2)? Are there other substantially improved businesses in the area to support the statement?

"The Resort is expected to meet the housing demand that its amenities generate, and it is designed to capture the latent seasonal housing demand that the case studies indicate has been generated by the adjacent Belleayre Mountain Ski Center..." (p. 336, last paragraph)

A summary of the case studies must be included in this section, particularly, in view of the weight that is placed on them in the conclusions. There is no information as to whether they are comparable to the proposed development in terms of location, accessibility, amenities, market area, etc. Thus, there is no basis presented from which to draw these conclusions. The last sentence of the report is not clear and needs to be revised to say what it means.

GENERAL COMMENTS

Section 2 Project Description

The design of the Big Indian Resort and Spa building is highly unique and unusual. At first glance, it appears out of character with any local architecture in the Catskills. This is perhaps better discussed as a substantive issue in the visual character section.

It is our understanding that the large terraces on each level will be covered with soil and planted. This raises a number of questions that the applicant may wish to consider early in the process. What will the depth of the soil be? What are the implications of freezing temperatures and freeze thaw cycles on the structures? How will the terraces drain? What will the loads on the terraces be with soil, plant material, water and snow? How will heavy snow be removed from the terraces? Will a heavy snowfall block windows and light from guest rooms? What happens if plantings are impacted by blight or disease?

Our primary concern is that the architecture may be viewed as a novelty that could impact. upon the image of the resort. The structure itself may be extraordinarily expensive and the beauty of the building may be seasonal. Given the large financial investment to construct such a building, a more traditional, classic design may be more in order for the site.

Figure 2-2 show schematics of what appear to be flat roofed buildings. Again, snow and freezing water may impact upon the long term integrity of roof structures, if this is the case.

SOCIOECONOMIC ISSUES

3.10.1 Construction Phase

E. Economic Trends and Conditions:

"The tri-county area outperformed the state in terms of real wages in only one sector--construction-largely due to a 35.9 percent increase in real construction wages in Delaware County." (p. 248, paragraph 3 of Sec. E.)

Why was there such an increase in construction wages? What was going on in Delaware County and was it only a short-term project without any lasting impact on the local economy?

3.10.2 Operational Phase

E. Effects of Resort Visitors and Guests

Timeshare and Vacation Club Visitation

Should all of the time-share units be 2-bedroom? Where will the timeshare visitors tend to live - New York City, Westchester County, New Jersey, or from more distant areas with other timeshare opportunities?

Vacation Club Visitation

Where will the Vacation Club members tend to live? Where are the primary residences of existing second-home owners in the area? Would some of these people be tired of the homeownership responsibilities described in paragraph 6 of this subsection on page 263? This could provide an existing market for the vacation club and cause existing second-homes to be sold as primary residences.

Hotel Visitation

" ... daily expenditure would be approximately $100 per day, excluding lodging expense, and further assumes tha 75 percent of the visitor spending would occur on-site by hotel and lodge guests. " (p. 267, last paragraph of subsection)

This implies that the resort retail amenities will directly compete with existing businesses. It is also not clear why $100 daily expenditure was assumed since on p. 269, $170 is assumed by RCI and an average of $166 by U of M study. Why would hotel visitors be spending so much less if time share owners and single family residents have kitchens?

Wilderness Activities Center and Children's Center

"The Wilderness Activities Centers clientele is expected to be drawn largely from families already vacationing at the Belleayre Resort ... expected to be negligible" (p. 270, second paragraph in subsection.)

Earlier in report they did not expect many children at the resort. What about children living in the area? If there is a need for year-round activities - the Activities Center would be great for school groups, day camps, etc. Could have much stronger impact than what is implied.

"Children's Center activities are expected to be drawn entirely from within the overall resort complex ... a family-oriented resort." (p. 270, last paragraph of subsection)

This is the first mention of a "family-oriented resort." Furthermore, if we had some idea of the number of children in the area, there could be potential for the children's center to draw from outside the resort.

GROWTH INDUCING / SECONDARY/ CUMULATIVE IMPACTS

7.1 Introduction

"While the resort does not propose to significantly tap the demand for year-round housing, it will provide a limited number (21) of high-end year- round opportunities that will appeal to a very small market segment. " (p. 323, middle of paragraph 2)

It remains unclear whether these will be second homes or primary residences. They could be either.. If they end up as primary residences there has been no discussion of cost of services.

7.3 Potential Induced Development

"Further, many overnight visitors would likely find the cost of the Belleayre Resort's lodging facilities to be expensive, and would choose to stay in less expensive, perhaps less luxurious motels and "bed & breakfast" accommodations in the area. It can be expected ... that the resort would compete with the region's traditional lodging market and that its presence could,...decrease the demand for existing lodging facilities by introducing to the area a new range of overnight stay options." (p. 331, end of first full paragraph)

Does this indicate that some of the proposed lodging should be moderately priced? It is unclear what is being said here as the project description indicated that there was a 500 room deficit in the area. If this is the case, then the new lodging facilities will not compete with existing lodging facilities. Rather, they will supplement the existing facilities.

"In any case, the demand for seasonal homes as a result of the Belleayre Resort would not be any greater than the second-home demand generated by the ski area, and it may, in fact, satisfy a portion of the ski area's demand for new housing thereby reducing the ski area's growth - inducing effects." (p. 334, end of last paragraph of section.)

What does this mean? If the idea is to create year-round recreation and the golf courses are an integral part of this plan, why would the demand for new housing be the same as the demand generated by the ski area? Not all golfers are skiers and some demand may come from golfers who also enjoy a rural, mountainous area relatively close to a major metropolitan area.

2. Year-Round Residential Development

"Bellesyre Resort is expected to have a negligible effect on year-round residential development in the study area-.. although it is conceivable that the Highmount Estates 21 single family detached homes could become year-round homes-" (p.334, first paragraph of section)

What about the existing second home owners? If they were to buy a time share and sell-their homes to new year round households, there could be a significant impact on year-round residential market. Some may also want to buy one of the single family homes and make that their primary residence. New employees could impact the year-round residential market. For instance, if there are young people who grew up in the area and wish to return there or remain there could have the option with the new jobs, allowing them to establish new households in the area.

7.4 Potential Impacts From Induced Growth

"...presence of the Resort as a direct competitor to existing businesses would be expected to stimulate existing businesses to upgrade their facilities." (p. 335, paragraph 2 of section)

This statement appears somewhat threatening to local businesses. The Resort is presented as a supplement or another option for recreation, not necessarily a direct competitor. The market for moderately priced recreation options will still exist and it should not be implied that existing establishments do not have their own niche. Although "upgrading" does not necessarily mean the existing businesses will be more expensive, it should be more clearly stated that the Resort will offer another choice and not directly compete.