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HomeMy WebLinkAbout20200574 Excelsior Park SUP LA Group Comments 5-18-20 The LA GROUP Landscape Architecture @ Engineering P.C. Peop(e.Purpose..Mace. 40 Long Alley Saratoga Springs NY 12866 F..518-587-8100 518-587-0180 www.thelagroup.com May 18, 2020 Bradley Birge Administrator of Planning & Economic Development City of Saratoga Springs 15 Vanderbilt Avenue (Recreation Center) Saratoga Springs, NY 12866 RE: City Designated Planning Services for Excelsior Park SEQR Review 264 Excelsior Avenue, City of Saratoga Springs, Saratoga County, New York Dear Mr. Birge: The following responses are in response to the comment letter issued by The Chazen Companies, dated February 26, 2019. Pursuant to the receipt of the letter we met with representatives from Chazen, the City Attorney, Susan, and yourself to further clarify the detail required to adequately respond to the comments listed below. It should be noted that the plans have been adjusted slightly since the original application to respond to comments from staff and the Planning Board. The responses are as follows. Additional Information Needed to Complete Review Comment 1: The updated documents do not provide a breakdown, by square footage (SF), of the proposed non- residential uses,which is needed to accurately compare the previously approved and revised proposal. This information to confirm accuracy and consistency between the various documents. Response 1: The following uses are allowed with maximum square footages as indicated on sheet L-02; Office, Service Uses, Financial Institutions& Banks, Retail,and Eating &Drinking Establishments. Those uses could be located in the commercial and mixed-use buildings in phases A, F&G. Additional non-residential uses include Community Space(5,000 sf/Phase D), 6 Short Term Rental Units(Phase D) , Hotel Restaurant(15,000 sf/Phase H), Hotel Spa (14,000 sf/Phase H)and Hotel (60 Rooms/Phase H). The maximum total for all non-residential uses is 147,600 sf. Comment 2: Page 2 of the 2002 FEIS indicates that the 150,000 SF of non-residential uses proposed for Excelsior Park would be 6.36%of the Downtown Business District(DTBD) non-residential space. While the applicant has provided information on the amount of non-residential floor area now being proposed, background existing conditions in the DTBD have changed considerably since 2002. Please provide information on changes in the DTBD and how this, in combination with the revised proposal, affect the conclusions of the 2002 FEIS. Response 2: It is the Statement of Findings,adopted on October 12,2002 which operates as the findings and thresholds for the Project under the SEQRA regulations. Under Land Use and Community Character(Page 22),the Lead Agency's finding was that the Project represented 5% of the available commercial space of"the downtown zone" and it was determined,that due to the "potential"that the Project"may augment"the office and non-residential in that zone, mitigation measures were proposed. Mitigation measures on non-residential development included "the Retail at Excelsior Park is limited to certain convenience-type establishments no larger than 3,000 square feet intended to serve the employees and residents of the immediate neighborhood." ooo ° o �j�i/mo/mo/mo/;7/, „,./"/"/"/"/"/".,/, However, it was specifically noted that"the potential effects that a proposed project may have in drawing customers and profits away from established enterprises or in reducing property values in a community may not be considered under SEQR. Potential economic disadvantage caused by competition or speculative economic losses are not environmental factors". However,the Planning Board, consistent with Saratoga Springs zoning,will consider this prior to issuing any Special Use Permit. Therefore,the Planning Board properly determined that economic competition with "downtown" was not an environmental impact as defined under SEQRA for consideration, but would be information considered by the Board under its Special Use Permit criteria,which is recited in the City of Saratoga Springs Zoning Code. During site plan review of any future development within the Project site,the applicant would necessarily discuss the 18 years of background development along the Route 50 corridor,the significant downtown urban infill with condominium development, and the adaptive reuse of many of the existing building stock. There is no question that Saratoga Springs has benefitted from a robust growth,as opposed to the"augmentation" that concerned the Board in 2002. Comment 3: The estimated completion year has changed significantly(from a 10-year buildout beginning in 2004, to a 10-year buildout beginning in 2018), which has implications on background growth and future conditions, as they relate to the various technical areas. Please provide additional documentation on the implications of this change, in combination with the revised proposal, on all EIS technical analyses. Response 3: On October 16,2018,the applicant submitted a letter and table of"changed conditions" to the City of Saratoga Springs. The table has been revised to match the adjusted plan. Comment 4: Please provide a general location map, as required per Section A of the EAF. Response 4: The Location map is located on the cover page of the plan set. Comment 5: Section D.1.e of the 2017 EAF indicates that Phase 1 of the revised proposal will begin construction in June 2018. Please update all documents and analyses, as needed, to reflect the delay in the start of construction. Response 5: The EAF has been adjusted to indicate a commencement date of June 2021 and a completion date of December 2031. Comment 6: Section D.1.g of the 2017 EAF indicates the dimensions of the largest proposed non-residential structure, in addition to the approximate extent of non-residential building space to be heated or cooled. As this information is not included on any of the other plans provided, please provide backup documentation. Response 6: The maximum square footage of the three commercial buildings is 110,500 square feet. The original total included the commercial square footage in the mixed-use buildings. The largest commercial building is the hotel. Comment 7: The values cited in Table E.1.b of the 2017 EAF for the following land uses/cover types cannot be confirmed with the documentation provided: forested; meadows, grasslands, or bushlands; agricultural; surface water features; wetlands; non-vegetated; and other. Please provide supporting documentation. Response 7: The existing survey was utilized to complete area take-offs Comment 8: Please advise how phases A through H in Drawing L-04 of the revised SUP site plans correlate with the numbered phases cited in the other documents. Response 8: The phases have not been numbered, only lettered. There are eight proposed phases; A—H. The proposed Special Use permit would allow them to be developed in any order based on market demand. Geological &Topographical Resources Comment 9: Please provide additional information on the status of the SWPPP for the revised project and advise if the measures incorporated into the SWPPP are consistent with those outlined on Page 11 of the 2002 Statement of Findings. 0110.11 Response 9: A SWPPP will be developed for each project meeting the most current general permit at the time of site plan approval for each individual project. The existing phased construction follows this procedure. Comment 10: Please provide further information to explain whether any updates are needed to the previous construction impact mitigation plan. Response 10: The originally approved construction impact mitigation plan can be provided with the proposed Special Use Permit if requested by the Planning Board. However, many of the requirements are required by the City and NYS DEC by local ordinance and the individual project SWPPP's Comment 11: Please provide further information to explain whether changes to the number of phases of construction affect the conclusions of the construction analyses, as summarized on Page 12 of the 2002 Statement of Findings. Response 11: Additional phases translate to smaller areas of impact and controlled development. Site Plan approval would be required with each phase as with the original project which will include detailed construction plans. Wetlands Comment 12: Section D.2.b indicates that the revised proposal will result in an encroachment into the area for NYSDEC S-16 and that this encroachment was previously permitted by NYSDEC. Please provide additional information on whether, compared to the previously approved proposal,the revised proposal results in any changes to the total encroachment area. Response 12: As stated there is no further encroachment into jurisdictional wetlands. Traffic Comment 13: Page 12 of the 2002 FEIS indicates that the traffic impact study takes into account the two projects that were approved at the time the study was prepared: the proposed expansion to"The Mill" complex located to the west on Excelsior Avenue and the conversion of the former CHP building to a boarding school.The document further indicates that traffic from these two sources were incorporated into the annual growth rate provided by NYSDOT and the Capital District Regional Planning Committee, and that these background growth rates are intended to account for other development expected to take place in the general area. Please provide additional documentation on (1) projects that have subsequently been approved; and (2)changes to background growth for the new 2028 analysis year, and the implication of these changes, in combination with the revised proposal, on the findings of the traffic impact study. Response 13: As discussed with the Planning Staff,the intent is to set up meeting with the staff of the appropriate departments; Planning and Public Safety,to determine the applicability of the original mitigation requirements with respect to the increase in background growth along with an increase in vehicle trips associated with this change and what adjustments may be required to the proposed mitigation. Comment 14: Section D.2.j.ii of the 2017 EAF indicates"Not applicable" in response to the questions about projected daily semi-trailer truck trips for commercial activities, but commercial activities are proposed. Please provide an estimate of the number of daily trick trips. Response 14: The estimated truck trips have been calculated by the traffic consultant based on the maximum build-out. Approximately 75 truck trips are proposed for a 24-hour period. The number has been added to the SEQRA form. Comment 15: Section D.2.j.iii of the 2017 EAF indicates 403 existing spaces, and 522 proposed spaces, for a net increase of 522 spaces. The increment should be updated to reflect the change from existing to proposed. In addition,the 522 proposed spaces cannot be confirmed based on the supplemental information provided. Please provide the relevant backup information to confirm the accuracy of this number. Response 15: The numbers have been revised to indicate the total spaces. The parking spaces are indicated on the masterplan and the breakdown is as follows; 247 surface parking space, 155 parking garage spaces, 113 townhouse garage spaces and 31 individual driveway spaces which totals 546 spaces. Comment 16: Table 4 does not provide a comparison between the total buildout trip generation for the revised proposal and the previously approved project's total buildout trip generation (as presented in the 2002 ' FEIS). Please provide further information to explain whether the additional trips associated with the Ilikt,!iia%,,,,/,,, /; revised proposal (above and beyond those projected for the previously approved project), in addition to changes in background and future conditions,would trigger the need to analyze any additional intersections,would result in any new impacts not identified in the 2002 FEIS,or require additional or different mitigation measures. Response 16: As discussed with the Planning Staff,the intent is to set up meeting with the staff of the appropriate departments; Planning and Public Safety,to determine the applicability of the original mitigation requirements and what adjustments may be required. Comment 17: The November 3, 2017 Transportation Study does not account for the 5,000-SF community building proposed (per the site plan). Please explain why this new land use is not accounted for in the report. Response 17: The community building is meant to serve the residents of the neighborhood and not create additional vehicle trips. Comment 18: Page 3 of the November 3, 2017 Transportation Study notes that the 9th edition of the ITE Trip Generation Manual is used for trip generation, rather than the more recent 10th edition. Please confirm whether the trip generation rates for any of the proposed land uses have changed and update the analysis accordingly. Response 18: The 10th edition ITE trip Generation manual was utilized for the revised Transportation Study. Comment 19: Page 6 of the November 3, 2017 Transportation Study notes that"it would seem to be appropriate to revisit the 2002 Special Use Permit to see if the traffic mitigation improvements listed are still applicable." Please provide a status update on this work, as the revised proposal would generate more trips than the previously approved project and the report has already confirm that, at a minimum, all of the mitigation required for the previously approved project is needed. Response 19: As discussed with the Planning Staff,the intent is to set up meeting with the staff of the appropriate departments; Planning and Public Safety,to determine the applicability of the original mitigation requirements and what adjustments may be required. Comprehensive Plan and Zoning Comment 20: Please provide additional information on how zoning has changed since the previously approved project and the implications of these changes, in combination with the revised proposal,on the findings of the EIS. Response 20: The current zoning for the Project is T-4 and T-5 zoning under the current Saratoga Springs Zoning Ordinance. The T-4 is intended "to accommodate development of neo- traditional neighborhoods with primarily residential uses incorporating a mix of unit types and small-scale commercial uses where appropriate." The T-5 zone is intended "to accommodate a wide variety of residential and non-residential uses, building and frontage types. This district also focuses on providing quality streetscape amenities and civic spaces to enhance pedestrian activity." It is the applicant's position that these zones encompass the original Project scope and uses and is not materially different from the Outer Excelsior Avenue District in place at the time of the Project's approval in 2002. In 2015,the City modified its Comprehensive Plan to include the Project site as "Community Mixed Use"which "designation includes areas of moderate density residential and community- supported commercial uses. These areas are characterized by mixed use neighborhoods that are walkable and connected to adjacent residential neighborhoods. Each area includes a variety of neighborhood-scale businesses and services that meets the needs of the surrounding community." The CMU designation is not materially different from the SDA designation which was part of the 2001 Comprehensive Plan when the Project was originally reviewed and approved. Land Use Comment 21: One of the land use mitigation measures cited on Page 24 of the 2002 Statement of Findings is limiting the hotel to 120 rooms. The revised proposal now proposed 160 rooms (100 already approved, plus 60 new hotel rooms). Please provide additional information on how the revised proposal affects this previous mitigation measure. Response 21: The allowable hotel use can be discussed with the Planning Board if there is a concern. Aesthetic Resources Comment 22: Please provide additional documentation on the implications of the revised proposal on the need for noise attenuation. Specifically, advise whether any new or additional buildings require noise attenuation and/or whether attenuation is no longer needed for any buildings that previously warranted such a measure. Response 22: Noise has been addressed by the project developers on an individual basis and not required on previous projects approved and constructed. The 100 foot no-cut buffer along the Northway will be retained and a large majority of the remaining residential uses are within the interior of the site. However, noise attenuating construction may be desired in the future. Comment 23: Please provide additional documentation on whether the revised proposal would result in any changes to building height or site plan that would affect the findings of the 2002 FEIS's visual resources analysis, and specifically the"Limits of Visibility" discussion cited on Page 25 of the 2002 Statement of Findings. Response 23: The proposed building locations closely match the locations and height of the original 2002 plan. No increased visual impacts are anticipated. Municipal Resources/Community Services Comment 24: Page 18 of the 2002 FEIS indicates that the City had a current(2002)Annual Daily Demand (ADD)of 4.32 Million Gallons per Day(MGD). Please provide updated information on the City's current ADD and provide additional information on the implications of this background conditions change, in combination with the revised demand estimate for the proposal, on the findings of the EIS. Response 24: The City's current ADD is 3.96 MGD as listed in the City's 2019 Annual Drinking Water Quality Report. The applicant will confirm with the City Department of Public Works that they have no issues with the projected demand for this project during the approval process. Comment 25: Page 19 of the 2002 FEIS indicates that the number of emergency calls that could be anticipated to be generated by the proposed development,which was reviewed and approved by DPW. Please indicate the number of emergency calls that could be anticipated under the revised proposal and provide additional documentation on the implications of this change on the findings of the EIS. Response 25: The Department of Public Safety will be contacted to determine if providing emergency services to this development is a concern. Comment 26: Section D.2.k.i estimates an annual electricity demand of 560,000 Kw. Please provide backup documentation substantiating this estimate. Response 26: The number has been revised and included in The SERA form. National Energy Commission reports were utilized to calculate energy consumption based on the maximum square footages of the uses. Comment 27: The November 9, 2017 Engineering Report indicates that the revised proposal would generate a total daily water demand of 107,734 gallons per day (gpd), compared to the 100,400 gpd cited on Page 26 of the 2002 Statement of Findings. Please provide additional documentation explaining whether this change will affect the conclusions of the FEIS. Response 27: The total daily water demand is 101,010 gallons per day with the revised project. The engineering report has been submitted to the City of Saratoga Springs Department of Public Works to determine any impacts on the existing systems. Comment 28: Page 27 of the 2002 Statement of Findings indicates that the previously approved project would impact school enrollment by less than 1%. Please provide an updated estimate of the impact of the revised proposal on school enrollment, in consideration of both the additional units being proposed and the changes in background existing and future conditions. Response 28: At the time of Project review and approval in 2002,the Saratoga Springs City School District had a combined enrollment of 6,905 students and the Findings indicated that number could increase as a result of the Project by less than 70 students (1%). Over the course of the last sixteen ' years,the total enrollment of the Saratoga Springs City School District has declined to a total Ilikt, /,,,,/,,, ;, , ii i,M,AAA, A ,, ///,,,,,,,,A,,; iiiiiiiiiiiiil June 2018 enrollment of 6,341 students (most current available data), representing a total decline in enrollment of 564 students. The Project currently proposes 100 additional residential units beyond the threshold set in the 2002 Statement of Findings which has a maximum impact of 0.30 students per new residential unit. The nine short term rental units have been removed since these will be offered to visitors of the community only. Applied to the residential units proposed,the impact would be a maximum of 102 students. When added to the current enrollment of 6,341,the total impact would be 6,443 which is below the impact threshold studied in 2002. Therefore,the impact to the Saratoga Springs City School District is less than the impact contemplated in 2002 and does not implicate an exceedance of the original SEQRA Findings.' Socio-Economic Setting Comment 29: Page 28 of the 2002 Statement of Findings indicates that"based on the results of the fiscal impact analysis,each of the project alternatives considered as projected to result in a net gain in revenues to the City." Please provide additional documentation that this statement is still correct, in consideration of both the additional units being proposed and the changes in background existing and future conditions. Response 29: The 2002 Statement of Findings made the fiscal impact determination based upon the following support: "The retail component of the project will be ancillary and is not expected to draw customers beyond the immediate area of the proposed project site. New residents and employees will increase overall spending. The Spring Run Trail connection to Excelsior Park will provide potential customers with a direct link to the downtown area, in particular during the summer months" (page 28). The retail component of the project remains ancillary even with the proposed changes and consumer spending will necessarily increase with new residents and employees. The Spring Run Trail connection has been fully completed2 and operates as intended with the ability for the Project residents to walk or bike to downtown. It is the applicant's position that none of the Project's proposed changes implicate the Findings and, in fact, reinforce the prescient view of the Board in 2002. Cultural Resources Comment 30: Please provide further documentation to explain whether the changes to the site plan and proposal affects the conclusions of OPRHP's previous review, specifically as it relates to the site's archaeological sensitivity. Response 30: The entire development area was previously cleared by OPRHP. The new development remains within that development envelope. Document Inconsistencies/Corrections: Comment 31: Page 3 of the October 16, 2018 Carter Conboy letter indicates that the remaining development will occur in 8 phases,while page 2 of the attached SEQR Compliance Analysis table indicates that remaining development will occur in 7 phases, and Section D.1.e of the 2017 EAF indicates 9 phases. Please provide additional documentation on the number of phases anticipated and update all documents for consistency. Response 31: Eight phases are proposed;A—H.All documents have been revised to reflect this number. Comment 32: The November 9, 2017 Engineering Report indicates that full build-out sanitary flows from the revised proposal would be 107,724 gpd, or 0.11 MGD, an increase of 0.02 MGD compared to the 2002 FEIS (see page 19). However, the Engineering Report indicates that this would be 2,806 gpd less than the original design. Please advise on this inconsistency and update the relevant documents, as needed. Response 32: As stated,the proposal has been adjusted and the new flows have been calculated. As indicated in the revised Engineering Report,the total projected usage would be 101,010 gpd. In the 2002 FEIS,the projected flows are indicated as 100,040 gpd. The proposed project %� 'Information on the history of enrollment can be found here: https://data.nysed.gov/archive.php?instid=800000038555 wi),; 2 https://www.saratogaplan.org/explore/public-preserves-trails/spring-run-trail/ !iia/,, , represents a slight increase; however, the proposed load will be reviewed by the City of Saratoga Springs Department of Public Works to determine if any infrastructure improvements are required to service the project. Comment 33: Section D.1.b of the 2017 EAF indicates that the total acreage of the proposed action is 34.72 acres and that 9.7 acres will be physically disturbed,while the Development Comparison Table included in the October 16, 2018 Carter Conboy letter indicates that the development area is 21.8 acres. Please advise on this inconsistency and update the relevant documents, as needed. Response 33: All numbers are accurate. The total area of the proposed action is 34.72 acres. The 9.7 acres represents the proposed disturbance and 21.8 acres represents the area of the existing and proposed built area (project footprint). This number was provided at the request of the Planning Board for comparison to earlier masterplan options. Comment 34: There are several inconsistencies in the number of units proposed between the documents: a. Section D.1.f of the 2017 EAF indicates that 46 one-family, 32 two-family, and 85 multi-family units would be constructed, for a total of 163. This is inconsistent with the 169 units indicated on page 2 of the October 16, 2018 Carter Conboy letter(in addition to page 1 of the SEQRA Compliance Analysis table and the Development Comparison table provided with the letter). Please advise on this inconsistency and update the relevant documents, as needed. The values included in Section D.1.f of the EAF are accurate but have been revised based on the new plan. The Carter Conboy letter includes the 6 short term rental units as residential units which do not fit within a category of the EAF table but now have been included. b. Pages 1 and 3 of the November 9, 2017 Engineering Report indicate that the revised proposal consists of 62 three-bedroom townhouses (16 of which would include a one-bedroom apartment that could be sublet)and 76 two-bedroom apartments and that 6 short-term/guest room rentals are also include in this number. This compares to the 62 condos, 102 apartments, and six short-term rentals (for a total of 169 units)cited in the October 16, 2018 Carter Conboy letter. Please advise on this inconsistency and update the relevant documents, as needed. The numbers in the Engineering Report have been revised based on the adjusted plan. c. Page 1 of the November 3, 2017 Transportation Study indicates that the revised proposal will add 147 additional housing units, including townhomes, apartments, and townhomes with attached apartments. The 147 units cited in the report is inconsistent with the 169 units indicated in the October 16, 2018 Carter Conboy letter. In addition, the 6 short-term rental/guest rooms are noted. Please advise on these inconsistencies and update the relevant documents, as needed. As stated in the Transportation Study,the unit counts and commercial square footage values are based on the worst case scenario for traffic impacts;the commercial square footage is maximized and the residential unit count in the mixed-use building is minimized based on the maximum commercial square footage. The residential number in the Carter Conboy letter was based on the maximum residential units. d. The breakdown by"Area" provided on Page 1 and Table 2 of the November 3, 2017 Transportation Study does not include the 5,000-sf community space located in Area"A" (per the revised SUP site plans); and the 61 apartments cited for Area"B" is inconsistent with the 82 units shown for this area on the revised SUP site plans. Please advise on these inconsistencies and update the relevant documents, as needed. ion The community building was not included in the traffic study since it is meant to serve the community and not outside users. The Transportation Study explained that the analysis is based on a conservative,worst case scenario. The large mixed-use building in Phase F can have a maximum of 52 apartments or a maximum of 27,000 square feet of commercial space depending on market conditions. Maximizing the commercial space in this building is a more conservative approach from a traffic standpoint and will reduce the residential unit total. 111111111111W. • 4,,, /, .„;.. W.i.. /Re**************., .,******./ e. In Figure 1, "Proposed Site Layout with Development Areas Defined for Study Purposes" in the November 3, 2017 Transportation Study,the large mixed-use building in Area B indicates 30 apartments,versus 52 per the revised SUP site plans. As stated above,the apartment total has been reduced to maximize the allowable commercial space to conservatively project traffic. f. Drawing L-02 of the revised SUP site plans indicates that 163 units are proposed, versus the 169 units indicated in the October 16, 2018 Carter Conboy letter. Please advise on this inconsistency and update the relevant documents, as needed. As stated above,the Carter Conboy letter included short-term rental guest rooms as residential units while on Drawing L-02 they are included as commercial,similar to a hotel unit. The numbers will be adjusted for clarity. Comment 35: Section D.1.g of the 2017 EAF indicates that 4 non-residential structures are proposed. It is unclear how this number corresponds to the revised 2017 SUP site plans,which appear to show 3 100% non- -- ,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,, residential on- residential buildings and 3 mixed-use buildings. Please advise on this inconsistency and update the relevant documents, as needed. Response 35: We included the community building as a non-residential building since it included apartments that would be in a rental pool,similar to hotel units. We have revised the number in the EAF to 3. Comment 36: Section D.2.c and D.2.d of the 2017 EAF, respectively, indicate that the revised proposal will generate a total water usage/demand of 60,020 gpd and a total liquid waste generation of 60,020 gpd. This is inconsistent with the 63,404 gpd cited on page 3 of the November 9, 2017 Engineering Report. Please advise on this inconsistency and update the relevant documents, as needed. Response 36: The revised engineering report and EAF include a usage/demand of 56,680 gpd. Comment 37: Section D.2.c.iii of the 2017 EAF indicates that a line will need to be extended further east along Ormandy Lane, but page 1 of the November 9, 2017 Engineering Report states that this improvement was constructed during phases 1 and 2 of the development. Please advise on this inconsistency and update the relevant documents, as needed. Response 37: Both statements are true. Gravity sewer and a force main was developed as part of phases 1 and 2. These existing facilities will need to be extended to the east to serve the proposed development. No revisions to documents are necessary. Comment 38: Section D.2.d.iii of the 2017 EAF indicates that sanitary mains will be laid west along Whistler Court, east along Ormandy Lane, and north from Ormandy Lane into townhouse developments but page 1 of the November 9, 2017 Engineering Report states that these utilities were constructed during phases 1 and 2 of the development. Please advise on this inconsistency and update the relevant documents, as needed. Response 38: As stated above; a portion of these services were constructed in phases 1 and 2 but need to be further developed and extended for future development. Comment 39: Section D.2.e.i of the 2017 EAF states that 6.1 acres of impervious surfaces will be created,while the Development Comparison table included with the October 16, 2018 Carter Conboy letter indicates that the project will introduce 3.0 acres of building area and 3.0 acres of pavement area (for a total of 6.0 acres of impervious surface area), and Section E.1.b of the 2017 EAF indicates that 5.9 acres. Please advise on this inconsistency and update the relevant documents, as needed. ion Response 39: The correct value is 5.90 acres of new impervious area. The documents have been adjusted. Comment 40: There are several corrections and inconsistencies in the land use/cover types table included in Section E.1.b of the 2017 EAF. Specifically: a. The 2017 EAF indicates 1.81 acres of existing impervious surfaces and 7.71 of future impervious surfaces,for a total increase of 5.9 acres. In addition to the inconsistency with the incremental 5.9 acres noted in the table (see previous comment): (1)the 1.81 acres is Meme% • inconsistent with the 2.2 acres of building area and 5.6 acres of pavement(for a total of 7.8 e acres) indicated in the Development Comparison table included in the October 16, 2018 Carter !iia%,,,/,• /,/�� Conboy letter; and (2)the 7.71 acres is inconsistent with the 5.2 acres of building area and 8.6 acres of pavement(for a total of 13.8 acres)indicated in the Development Comparison table. Please advise on this inconsistency and update the relevant documents, as needed. b. The totals of the"current acreage" and"acreage after project completion" columns do not match and are also inconsistent with the values cited in Sections D.1.b and D.2.e of the 2017 EAF: the"current acreage"column totals 36.93, the"acreage after project completion" column totals 36.92,while Sections D.1.b and D.2.e cite 36.23 acres. Please advise on this inconsistency and update the relevant documents, as needed. c. The totals in the"change" column should net zero (since the total project acreage is not changing). Please update this column to correct. The The total change for the non-vegetated land use cover should read"-0.25" rather than"0.25." Please update this cell to correct. Response 40: The values have been adjusted based on the new plan. The inconsistency between the acreage controlled by the client and the development area was based on the anticipation of a land transfer from the City of Saratoga Springs to the project sponsor which has not happened and has been removed from the project. Also,the development comparison in the original Carter Conboy letter addresses the existing and proposed project combined not only the proposed development. Sincerely, /4 /4"/ „„„„„„,., „„„„„„,., „„„„„„„ David R. 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