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Home My WebLink About20230877 NYS Route 29 Multi Family Public CommentJuly 17, 2025 Chair Mark Pingel and Members, City of Saratoga Springs Planning Board City Hall 474 Broadway Saratoga Springs, NY 12866 Re: NYS Rt. 29 Mixed -Use - Project # 20230877, Index # 20241018. Consideration of SEQRA review for a proposed mixed -use project including multi -family residences (approx. 400 dwelling units) and a 110-room hotel in the Neighborhood Commercial (T-5) District. Dear Chair Pingel and Planning Board Members: I have reviewed all of the available documents posted online as of today's date for the above agenda item, and respectfully offer the following comments. The Saratoga Springs Planning Board should require a full study of impacts to open space, wildlife and wildlife communities, forest ecology, localized wetlands and water resources of the subject project site that will result from the current proposal as denoted above on your July 17, 2025 meeting agenda. To facilitate this study being provided for its review, the Planning Board should issue a Positive Declaration pursuant to SEQRA and require a project - specific EIS addressing all foreseeable adverse impacts to these community environmental resources. According to the applicant's LEAF posted online apparently dated "10-6-23"(?): • The 16.66-acre site is currently completely forested (LEAF E.1.a.) but the project will remove 15.66 acres of forest, leaving just 1 acre. (LEAF E.1.b.). This project will replace that removed forest with 10.8 acres of roadways, buildings and other impervious surfaces and 4.86 acres of "grass" (LEAF E.1.16). • Per the LEAF, the site contains wetlands or other waterbodies (LEAF E.2.h.i) and these also adjoin the project site (LEAF E.2.h.ii). The site is also located over a "Principal Aquifer" (LEAF E.2.I.i). • The applicant's LEAF unacceptably goes on to "identify" the "predominant wildlife species" of the site as "small animals" (LEAF E.2.m), and states without providing evidence that there are no designated significant natural communities on site (LEAF E.2.n), no federally or state designated endangered or threatened species or habitats thereof on site (LEAF E.2.o), and no species that are designated by NYS as rare or of special concern on site (LEAF E.2.p). • Despite being located less than 5 miles from the Saratoga Spa State Park, the applicant also states that the site is not within 5 miles of any "officially designated and publicly accessible federal state or local scenic or aesthetic resource" (LEAF E.3.h, see LEAF E.3.h.ii, "state or local park") The City's Planning Board must conduct a "Hard Look" now at impacts of the proposed project, pursuant to the New York State Environmental Quality Review Act (SEQRA). Once an Environmental Impact Study pursuant to SEQRA is produced and provided to it, the Planning Board should review the submitted baseline data for forest, wildlife, wetlands and open space resources and the anticipated significant cumulative and long-term impacts upon them, using its own independent expert consultant or contractor, one with a proven track record of understanding and accurately assessing project reports and documentation of impacts upon existing wildlife diversity and communities, native plant communities, wetlands, forest ecology including mature and maturing forest tree assemblages, and impacts to open space of the City and site. Frequent observations made along the perimeter of the site during the past year from surrounding properties have informed me that the subject site functions as a "reservoir" of native biodiversity in the northwest quadrant of the City of Saratoga Springs. As the largest remaining forested upland parcel in its natural state left along West Avenue, it's especially important as a refuge and a nesting and habitat area for amphibian, avian and mammalian wildlife species. The extraordinarily intensive project being proposed for the site will irreversibly decimate and destroy the vast majority of these natural resources of the site, including localized wetlands habitat functions, amphibian vernal breeding pools, an extensive and functional forest ecosystem tract, native plant communities, and the diverse wildlife habitat they provide and support at the site. A comprehensive Natural Resource Inventory (NRI) of the site -- one that addresses at minimum the biotic resources categories just cited -- should be required to be completed and provided to the Planning Board as the basis of the applicant's study of these resources and impacts thereon, for review by the Planning Board and the public, prior to this Board considering granting any project site approvals, including land clearing, tree cutting or other land disturbance or soil disturbance activities. This Natural Resource Inventory should be accompanied by a detailed discussion describing how the existing values of the extant natural resources inventoried as just noted will be altered or obliterated by the proposed project. It should explain how alternate uses, including the "No Action" alternative, can avoid or minimize these impacts. If any possible mitigation measures are proposed, the site's remaining natural resource values upon implementation of the proposed project's proposed mitigation measures should be quantified and critically compared with the existing values of functional forest assemblages, diverse plant communities including significant mature and mixed -age stands of deciduous and coniferous trees and native understory plants, and extant populations of wildlife species that are endemic to and which frequent the site. It is clear that it won't be possible for the vast majority of these wildlife and forest resources to survive or continue normal biological functions, if the project proceeds at any scale similar to what is being proposed as of this date. Prior zoning and planning decisions don't exempt the applicant now from providing needed documentation of existing resource values and long term and cumulative impacts thereupon that will likely be caused by the applicant's project going forward. As a long-term resident of the area, and as Saratoga Springs resident for the past year, and a frequent visitor to the City for most of my life, I submit that such resources in the City's Inner District are rare and worthy of protection. The biotic diversity and values of this landscape are remarkable and significant, even as observed carefully from adjacent roadways, sidewalks and properties. As an example, its flora and fauna diversity exceed that of Congress Park, to cite one cherished urban green space of the City. I understand that the current site includes and connects to an existing trail network - one which could be used by the public, if it were the City's desire to conserve this landscape in the public domain, rather than have its forest and wildlife resources fall to the bulldozer. The open space, watershed, forest and wildlife habitat values of the existing site are very much worthy of careful scrutiny and conservation, regardless of whether public trail access might someday be possible. During this year (2025), 1 have frequently observed amphibian species dispersing from the site to adjacent areas during the spring and summer breeding season. A breeding population of wood frogs (Rana sylvatica) -- a representative, forest breeding amphibian species -- occurs on this site. This is just one indicator of the existing site's habitat values as a functioning forest ecosystem, and of the land's local importance as a healthy, functioning reservoir of representative biodiversity of & for this City. It seems quite obvious that the proposed project's impacts will extirpate (make extinct at the site) this and nearly all other wildlife species, save perhaps a few of the most common species that might persist for a limited time in a degraded landscape. Based on the applicant's LEAF, a drastically different, destroyed or severely diminished ecology is the most likely result. Therefore, I respectfully call upon the Saratoga Springs Planning Board to thoroughly examine the impacts of concern discussed here before granting any project approvals, and to make robust use of the SEQRA process by issuing a Positive Declaration under SEQRA, and requiring an Environmental Impact Statement of the proposed project and its impacts of significance upon wildlife, forest resources, open space, wetlands and water resources, and any other resources the Planning Board may determine as creating or resulting in significant adverse impacts and/or non-mitigatable impacts of the proposed project. Thank You very much for your kind attention to these concerns. Sincerely, William Engleman / General Delivery Saratoga Springs, NY 12866 4