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Scoping Comments
FEB 28, 2008 NYS DEC Final Scoping Document PDF
FEB 28, 2008 NYS DEC PRESS RELEASE Bellyare Scoping Document Released
FEB 28, 2008 Daily Freeman Scope of Belleayre review expands
JAN 8, 2008 Comments letter: Jerry Fairbairn, Supervisor - Town of Hardenburgh
Jan 14, 2008 Comments of the Office of the New York City Watershed Inspector General
Orange County Federation of Sportsmen's Clubs SPARC and Stewart Park & Reserve Coalition OCFSC joint comments 7 page letter
Sierra Club Scoping Comments 15 page PDF
Ulster County Environment Committee Scoping Letter
Delaware River Defense Coalition Scoping Comments
Resolution adopted by Greene County Legislature regarding Belleayre Project and Scoping
UC Legislator Brian Shapiro's Letter to Daniel Whitehead PDF
UC Legislator Don Gregorius' Letter to Daniel Whitehead PDF
Riverkeeper Scoping article
Highmount Preservation Association comments 6 page PDF
Matthew Frisch oral comments PDF
Ulster County Environment Committee Letter to Daniel Whitehead
Dear Mr. Whitehead,
As Chairman of the Ulster County Environmental Committee, I am submitting the following concerns for inclusion as part of the scoping process for the proposed Wildacres, Highmount and DEC project.
The Ulster County Environmental Committee unanimously resolved at its meeting on December 19, 2007 to request that issues raised in the New York State Office of the State Comptroller’s August, 2006 report titled “Belleayre Resort Development Review” be considered as part of the SEQRA review. The Ulster County Environmental Committee believes that the following issues cited in the State Comptroller’s report deserve review
and inclusion in the pending Supplemental Draft Environmental Impact Statement.
• Investment Proposals
These include concerns about franchising, borrowing costs, investment profitability and regional development. It is our understanding from sources familiar with the Agreement In Principle that investment issues will not be given consideration in the scoping process or acknowledged as a piece of the environmental review. We disagree, given the fact that a tie-into the proposal includes public investments through the Belleayre Ski Center, which is wholly a publically owned entity.
• Secondary Growth Impacts
According the State Comptroller’s report, “There are substantive and significant issues with respect to secondary and induced growth impacts, including commercial development along the major public access road, Route 28, (and) a large increase in the permanent population of the area with the accompanying burdens on public service.” The report recognizes a “significant possibility that this project could stimulate secondary
development that would be incompatible with the Catskill Forest Preserve and with lands that serve as a water-supply watershed for nine million downstate New Yorkers.”
• Conclusion
A series of findings contained in the report’s conclusion are of great concern:“There are too many unknowns surrounding the Belleayre project. The formal DEIS contains incomplete and contradictory information. Furthermore, the proposal fails to address a number of local economic development concerns. This is crucial since the proposed resort would be located in the middle of the constitutionally protected Catskill Forest Preserve. In summary, the Belleayre Resort project appears to be a speculative venture that may
well endanger existing resource uses and end up placing unacceptable burdens on State, City and local taxpayers.”
The Ulster County Environmental Committee also wishes to share its concern regarding significant designs for County Road 49a as specified in the Agreement In Principle. As the County of Ulster was not present or represented during the AIP process, we wish to note that operating and maintenance cost for CR49a over the last ten year period amounts to a total of $214,869.95. This does not include annual contracting cost of $52,000 in an arrangement with the Town of Hardenburgh for their share of maintaining 11.7 miles of CR49a (this figure will see a 2% increase beginning in 2008). Costs associated with possible increased usage of CR49a should not be a burden of either the Town of Hardenburgh or Ulster County.
The Ulster County Environmental Committee requests a revisiting of the Belleayre Resort Development Review as part of the scoping process. Given that the original plan detailed in the review has undergone significant changes since its publication, we ask for a thorough examination to determine if any of the issues raised remain relevant to the newly revised project.
Thank you kindly for the opportunity to share these concerns.
Respectfully submitted,
Brian Shapiro
Chairman, Ulster County Environmental Committee
On behalf of the Ulster County Environmental Committee
More Scoping Letters
Friends of Catskill Park 18 page letter
From HART Chairman John Carney 4 page letter
Town of Hardenburgh Scoping Comment 3 page letter
From Stephanie Blackman 5 page letter
From Mary Herrmann 8 page letter
From Erik Holmlin read letter
From Kevin Millar read letter
From Maureen Nagy read letter
From Lem Srolovic 3 page letter
Dear Friends at the DEC,
My letter arises from concern for both the affects large “destination resorts” have on the infra-structure of the region through which resort builders and users traverse and the resulting economic drain on “downtown” retail communities along the way.
I have operated my business, Dharmaware, which includes a retail store, in NY State for 32 years, and in the Town of Woodstock, for the past 23 years. When I or other business owners in Woodstock request our town officials to repair sidewalks, bridges and roads, we are quite accustomed to the answer “it’s up to the State” because Route 212 is a State Highway. Therefore, repairs are rare. So how is it possible that the State has millions of dollars to help finance a mega resort for rich folk, expanding and maintaining access thereto, but rarely money to repair infrastructure in Woodstock?
I am aware that nearby counties and states charge no sales tax on clothing but that I have to charge my customers 4% and most other years 8%. Also, I watch many of my friends as they consider selling their homes and leaving town because they are unable to pay the high property taxes.
Please specify how much of our sales tax and property tax dollars will be used to finance this strange mix of big business and government interests.
Please specify that all monies capitalizing the cost of the ski area are to be generated solely from lift ticket sales, rentals, restaurant, and such associated revenues; and that monies generated from hotel rooms, restaurant, and associated charges are to cover the amortization of the capital and operating costs of the spa.
Please specify precisely how much Crossroads Ventures is contributing towards the upkeep of Route 28 and auxiliary access roads in Ulster and Delaware Counties. If there is an expansion of Route 28 in the plans, please specify how much of each lift ticket price and each room rate will be applied thereto. If monies are being applied from elsewhere, please specify precisely wherefrom.
Please specify how many “ton miles” of trucks carrying building materials and “passenger miles” of cars carrying engineers, planners, builders, Governors, Dean Gitters, etc., will pass along the Route 28 corridor during the planning and building stages of the Mega Resort and Ski Area. What dollar amounts are being applied as the environmental and infrastructure costs of each of these “ton miles” and “passenger miles“? Same questions for the vehicles of the golfers, skiers and spa attendees using the facilities after they open. This is tedious, I know, but the point is two-fold:
“Who is paying for all this?” and “How is it going to benefit our local communities?”
Sincerely,
Erik Holmlin
BSIE ’69 and MBA ’70 Cornell University which I mention because we were taught that only when all hidden costs were properly integrated into a systems study would correct solutions reveal themselves.
The following comments are to be make part of the DEIS scoping documentation for the proposed "Belleayre Resort at Catskill Park"
1 ) The original DEIS done in 2003 has been assessed by many parties as woefully inadequate and a new DEIS should be completed. I do not think that a supplemental EIS added to the 2003 DEIS does an adequate job of addressing the many environmental and economic factors attendant to this project. In the Positive Declaration dated November 21,2007 on page 3, under "Reasons Supporting This Determination" it states that "While the current integrated project proposals represent an attempt to create a lower impact overall project as compared to the original Crossroads proposal, it may still have significant adverse effects...". The new proposal decreases the number of dwelling units by only 15% which is not much of a decrease and it is that number which will determine the impact on the environment more that any other factor.
2 ) There should be a thorough and aggressive evaluation of the total carbon footprint of this project. Commissioner Grannis has emphasized this as a top priority and has stated that the DEC will take greenhouse gas emissions into account in State Environmental Quality Review actions where the DEC is the lead agency. The assessment of the greenhouse gas production should begin with the 8 year construction phase, transportation of workers and equipment to and from the construction site, transportation of patrons to and from the resort and expanded ski areas, the added carbon dioxide needed for more lifts and snow making. It should also project the increased carbon dioxide output in the future needed to power snow making equipment,as scientific studies predict an increased need for snow making as winter temperatures rise in the Northeast.
"In order to minimize ski season losses,snow making requirements are projected to increase substantially, raising important considerations about water availability and costs"*
" Wintertime warming trends experienced in recent decades and predicted to increase in the future present serious challenges for ski areas and whole regions that depend on winter tourism"**
"Across the northeastern United States, the number of days with snow on the ground has decreased substantially. The results hold important implications for the winter economy and recreation in the area"†
3 ) Fiduciary Responsibility and Economic Analysis:
"The Resort is intended to be the catalyst that will drive the revitalization of year-round tourism and provide improvements to the quality of life of those who live in, as well as those who visit, the Catskill Park." Crossroads DEIS September 2003
"In summary, the Belleayre Resort project appears to be a speculative venture that may well endanger existing resources uses and end up placing unacceptable burdens on State, City and local taxpayers." NYS Office of the Comptrollers Report, August 2006.
So who's right here? I think I'd tend to think the NYS Comptroller, but a hard headed economic analysis of the projects impact on the local (Kingston to Margaretville) economy and states coffers is lacking and needs to be done.
4 ) Transportation Issues
a) There is a free bus, noted on Belleayre Mountain Ski Center's ( BMSC ) web site,from various points along the Rt 28 corridor that will take people to Belleayre. I would like to know the past, present and anticipated number of riders on those buses.
b) Has the cost of gas been projected into the decision making process of people to continue to drive to Belleayre for day or even weekend visits. There needs to be a projection of the effect of $4 -$6 a gallon (or more) gasoline on visits to BMSC.
C) The accident and death statistics for the Rt 28 corridor from Margaretville to Kingston needs to made public ( they used to be on their web site) and analyzed in terms of the increase in traffic at peak hours that a BMSC and the Belleayre resort project would bring.
In summary, I think that a reading of the New York State Comptroller's Report of August 2006 is the most concise and objective analysis of this project. While the NYS DEC is a participant as an owner at Belleayre, lead agency and reviewer and arbiter of the State Environment Review process I think that the fiduciary responsibility of NYS and NYS DEC weights heaviest against their financial exposure in this speculative venture.
Thank you for the opportunity to comment,
Kevin Millar
Owego NY
* Scott, D et al,July 2007, Climate Change Vulnerability of the US Northeast Winter Recreation-Tourism Sector, Journal of Mitigation and Adaptation Strategies for Global Change ,special issue on " Northeast United States Climate Impact Assessment ".
2) Hamilton,L et al, 2003,Warming Winters and New Hampshire's Lost Ski Areas, International Journal of Sociology and Social Policy, 23(10):52-73.
** Hamilton,L et al,2007,Ski Areas, Weather and Climate: time series model for New England case studies, International Journal of Climate, 27:2113-2124.
† Burakowski, EA, et al, Fall 2007,Trends in Wintertime Climate Variability in the Northeast United States,American Geophysical Union, Abstract #GC21A-0159
From Robert B. Ewald Chairman, Delaware River Defense Coalition
Dear Mr. Whitehead
My name is Robert B. Ewald and I am writing to you regarding the proposed development at the Belleayre Resort. I am Chairman of the Delaware River Defense Coalition - DRDC. We are a successful coalition of local, regional, state, national and international organizations and agencies. We support all efforts to protect and enhance the streams and rivers of the Catskill Region and their watersheds. Our legal resources have successfully challenged those who wish to take personal gain by compromising the natural environmental resources and in some cases ignoring them completely Those who degrade the natural environment for their financial gain should be forced to give back in kind a part of this gain to make up in some way for these losses. The guardians of the natural environment of the Catskill Region have their baskets filled to the brims with the many concerns and need lots of help. Needless to say that every legal means should be taken now to leave to our later generations a better natural environment.
Presently the Catskill Region is being jabbed with a thousand “dirty needles of development” Each needle is not fatal but the total is producing a painful death to our natural environment.
Our coalition is prepared to take legal actions to see that all developments that degrade the natural environment of the Catskill Region waterways and the watersheds are stopped “dead in their tracks”. If the governing agencies of the State of New York are not able to save these natural resources with or without our help then a bit may be saved by consideration of the following points:
- None of the streams or tributaries should be reclassified to fit the degraded state brought on by the proposed development.
- Sewerage discharge classification limits should be adjusted so as to upgrade the water quality of the receiving natural waterway not down grade it.
- Greatly increase the fines for pollution violation.
Further, if the development can not be stopped then financial retribution should be made by the offending parties to the dedicated FISH AND WILDLIFE HABITAT/ACCESS fund. Suggested penalties to be considered would be (¼ of 1% of the yearly net profit) or $5,000,000 per year paid by the profiteering developers.
Only then will our coalition feel that a bit of good has come to be!!
Robert B. Ewald Chairman, Delaware River Defense Coalition
Pine Bush, NY
Comments to the DEC, Scoping Hearing for the proposed Belleayre Resort
December 12, 2007
Hello, my name is Maureen Nagy and I live in Pine Hill. I would like to add my voice to those who have called for community character to be included in the scope as an impact.
The reason why it is so important for community character to be included is that this area has a very strong and appealing regional character that is one of its chief assets. That quality comes from a landscape that blends spectacular natural mountain scenery and the warm, human quality of authentic historic hamlets and buildings that date from the 1800s, as well as the presence of the railroad that caused them to be built and still physically links them.
Many communities in American have lost their historic character – here it has almost miraculously survived to continue to tell the human story of the Catskills. In fact, that historic character has not only survived, it’s the very medium in which we live. It’s in all of our faces, and it’s fragile.
A change of the magnitude brought on by the prospect of a large resort cannot help but impact that precious character. First, the resort threatens to draw focus away from the hamlets as a destination and proper center of life in the Catskills. It’s the hamlets that deserve our care and attention, not the ski mountain in tandem with the proposed resort. Second the size of the resort joined with the ski center creates a sudden mega-development that’s out of scale and inappropriate for this community the way it has naturally evolved.
Personally, the strong regional character has had such an effect on me that I have come to organize much of my volunteer life around it for many years. I am now an assistant historian of Shandaken, and am or have been a trustee of the Shandaken Historical Museum, the Empire State Railway Museum and the Ulster County Historical Society. I was on the committee that organized the Shandaken Bicentennial Celebration of 2004 and the successive annual Shandaken Days, and I was part of the team spearheaded by Mark Loete to produce a documentary on the history of Shandaken.
Proponents of the resort may well wonder at the passion and determination that has fueled so many for so long to fight this fight. I think the distinctive character of this area, and the personal connection and sense of discovery it creates in many of us who live or visit here, are important factors in our willingness to go to the mat for as many rounds as it takes to preserve this precious character.
Scoping is the legally-mandated detail of Public Concerns about all possible Impacts of the proposal.
Deadline for comments was January 14, 2008.
Brief Overview of State Environmental Quality Review (SEQR) process
What is scoping?
How to prepare your comment letters
Where to send your comment letters
Brief Overview of State Environmental Quality Review (SEQR) process:
- Scoping:
December 10 - Developer Presents the Plan
December 11 - Public Comments on Impacts of the plan - DEIS is issued (Draft Environmental Impact Statement)
- NYS-DEC determines the DEIS is adequate
- Public commentary period (and possible Public Hearings)
- Issues Conference
What is scoping?
The lead agency NYS-DEC) must provides an opportunity for the public and other interested agencies to participate in the scoping process.
"Scoping" is the process by which the scope of issues to be addressed in the (DEIS) Draft Environmental Impact Statement is identified. (All issues are identified NOW.) Scoping session provides the public with an the opportunity to participate in the identification of impacts. Scoping focuses the draft EIS on the potentially significant adverse environmental impacts. Environment includes the human environment too! Impacts on YOUR life and YOUR community.
It is vital to point out all issues at this time, so that they be included in the review process. Anything that concerns YOU about this project can be included. Be as specific and concise as possible. No issue will be considered during review that is not raised now.
The deadline for public comments is January 14, 2008!
DEC should extend this period due to the holidays and short notice, even hold another public scoping session!
Submit your comments as instructed below. Remember, everything must be put on the table NOW. Speak up! BE HEARD on this critical topic!
Prepare and Send your comments
Deadline for comments January 14, 2008
Send letters to Daniel T. Whitehead (contact info below) and copy others at the DEC. Write a letter to the editor (get newspaper list here) about NO advance publicity and the habit of putting these brief and important periods for commenting on the Belleayre Resort over the holidays!
Daniel T. Whitehead, Environmental Analyst
Division of environmental Permits
625 Broadway, 4th floor
Albany, NY 12233-1750
Tel: (518) 402-9167
Email: wildacre@gw.dec.state.ny.us
(Put "Scoping -Belleayre" in Subject Line)
For more information and stats on the project go to Catskill Heritage Alliance at www.catskillheritage.org. or see important documents below and on Save the Mountain's Resources page. Get latest headlines.
Links to important related documents:
http://www.dec.ny.gov/docs/permits_ej_operations_pdf/Belleayreposdec.pdf
http://www.dec.ny.gov/docs/permits_ej_operations_pdf/Belleayredraftscope.pdf
http://www.dec.ny.gov/permits/6061.html
Save the Mountain's Resources page
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