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HomeMy WebLinkAboutProject Description Purpose and Need comments - JK SB - Rev6b FINAL - jkPage | Project Description - 1 Rev 6b PROJECT DESCRIPTION, PURPOSE, AND NEED Project Objective Section 1.3.1 of the DEIS (Objectives of the Proposed Project) states that “[c]limate-controlled (heated) space is essential for maintaining electrical systems in the types of vessels to be stored”(pp. ii, 14). This is both misleading and inaccurate. Not only is heated indoor storage unnecessary, but indoor storage in general is unnecessary both to a vessel’s electrical system and even the vessel in its entirety. Strong’s Marine is an authorized new boat dealer for manufacturers such as Cruisers Yachts and Regal Boats. Strong’s is also a former dealer for Sunseeker Yachts. All three manufacturers have debunked the developer’s claim that heated indoor storage is essential. Regal Customer Service noted “The majority of Regal boats do spend their winters outside, and seem to do very well.” Sunseeker noted “there are no issues with storing a Sunseeker outside in the winter.” Lastly, Cruisers Yachts noted that their boats are built in Wisconsin and “may sit outside for several months wrapped and winterized without issue” while waiting for delivery to their dealers. When asked specifically about electrical systems, Cruisers Yachts noted “…as far as any additional electrical concerns, you shouldn’t be worried.”1 Nowhere in the DEIS does the Applicant provide or discuss a demonstrated need for the Project. The financial risks of undertaking the Project without a demonstrated need are those of the Applicant and any financial supporters. However, if the Project proves to be financially non-viable, it would also mean that the Town of Southold would incur all of the environmental disruptions/devastation associated with Project construction without benefiting in any way from the Project. This is of special concern since the Applicant has advised at least one adjacent property owner that bank financing of the second of the two proposed storage buildings is contingent upon demonstrating a 60% occupancy of the first building.2 DEIS Scope calls for the DEIS to “include data about stored boat ownership and where the boat is docked during the season” (DEIS Scope p.23). THE DEIS addresses this in an inadequate and inconsistent manner. The DEIS states that “many of the yachts to be accommodated by the proposed action are anticipated to be existing boats utilizing local waters[,] customers electing to store their yachts in a climate-controlled facility closer to home rather and eliminates the need to relocate the vessel to warmer climates for winter storage”[sic](pp. xxiv, 249-250). However, this assumption fails to take into the account that many yacht owners choose to relocate their vessels to warmer climates during winter months so they can be made available for revenue-generating winter charters. For example, the M/Y Le Reve, pictured in DEIS Appendix M, and identified as typical of the vessels at SYC, is currently available for winter charter in the Caribbean.3 This practice eliminates the need for winter storage. 1 Per emails from: Sunseeker dated 2/23/2022, Cruisers Yachts dated 2/22/2022, and Regal Boats dated 2/24/2022 (ATTACHMENT DESCRIPTIONS -1a and 1b) 2 See comments on Employment and Economic Impacts. 3 https://iyc.com/charter/le-reve-lazzara/ Page | Project Description - 2 Rev 6b The DEIS also states that “The proposed action would keep those yachts that utilize local waters during the peak season on Long Island rather than being transported to warmer climates in the winter which would further support and revitalize the maritime and commercial hub in this area” (DEIS p. 174). However, at a May 14, 2023 meeting of the Southold-Peconic Civic Association, the Applicant indicated this was not the case.4 The DEIS also states that it “is anticipated the boat owners would be existing customers who currently dock at SYC or Strong’s Water Club, new yacht customers from the surrounding Southold community, as well as other owners on Long Island, Westchester County, and in the States of Connecticut and New Jersey” (pp. ii, xxviii, 20, 278); and that “a portion of these storage boat customers may be existing clients of SYC or the Strong’s Water Club, boat owners within the Town, while others are expected to be future boat owners from yacht sales by SYC or other brokers” (p. 312). DEIS Appendix M states that it “is anticipated new yacht customers would come from Mattituck Inlet private docks, Greenport, Montauk, Mount Sinai, Port Jefferson, Huntington, Port Washington, Westchester County, New York, Connecticut, and Northern New Jersey” (DEIS Appendix M, p.24). The language in these statements is very imprecise, witness the use of the words “many”, “anticipated”, “a portion”, and “may be”. Approximately how many yachts/customers are anticipated to be existing customers who currently dock at SYC?5 Approximately how many are customers at other Town of Southold facilities owned by the applicant? How many new yacht customers are expected to take advantage of winter storage at SYC? How many customers will be from outside Suffolk County or from outside New York State? The answers to these questions go directly to accurately estimating tax revenue aspects of the Project, as well as assessing whether aspects of the Project’s environmental impacts are merely being moved from one location to another, or whether certain impacts will be intensified. This information is not included in the DEIS. It is difficult to believe that the Applicant is proposing a project of this magnitude without a firm basis for believing it will be economically viable. The DEIS includes nothing to support or document a demonstrated need for the Project, other than the Applicant’s assertions. Something more than “If I build it, they will come,” needs to be provided to the Planning Board by the Applicant to demonstrate a 4 The Applicant state, in response to a question: “In the research studies we’ve done . . . there are a lot of large yachts, which is not what this project is geared for. We define large yachts . . . as 85-ft and above. Most of those have captains and they’ll take them down south in the winter . . .That’s not our customer—not what these are built for. Our average size is roughly a 60-ft yacht. Those generally don’t travel down south.” The Applicant later stated, in contradiction of his earlier statement, that “at least half of those [60-ft boats] are captained boats. 5 Although the DEIS does not directly provide this number, Appendix M indicates that 22 yachts in the 60-105 ft class were included in the 2020 SYC inventory. The DEIS states that “Based upon an average yacht size of 60 feet in length, it is estimated that approximately 88 yachts could be stored within the proposed buildings.” Assuming that all of these vessels opted to utilize the proposed storage facilities, a minimum of 66 60-ft vessels would be owned by individuals who are not currently SYC customers. Page | Project Description - 3 Rev 6b need for indoor winter yacht storage, and some basis for estimating the number and geographic distribution of anticipated customers. Project Description The DEIS states that “existing storage buildings would remain the same and a reconfiguration of the staging areas and drydock storage is not proposed.” The DEIS fails to mention that the reason there does not need to be a reconfiguration of the staging area is because the developer made modifications to the existing haul out slip at the southern end of the property to accommodate larger boats, while the Project is under SEQR review. On July 16, 2020, the Applicant applied for a wetlands permit to replace an in-kind bulkhead and make a modification and extension to the southern haul out slip. Comment letters from Save Mattituck Inlet, Save the Sound, and the Southold Planning Board were submitted to the Southold Board of Trustees expressing concern about the apparent segmentation of the review of the Project, which was and is, under review by the Planning Board. The written comments were supplemented by verbal comments from representatives of the two former organizations at the May 19, 2021 meeting of the Board of Trustees.6 The Southold Planning Board’s memorandum to the Board of Trustees dated May 19, 2021 noted that the Planning Board was the designated Lead Agency under SEQRA, and had issued a positive declaration for a project (the proposed Project) which included aspects of the work the Board of Trustees was being asked to approve. The Planning Board noted that it “is the determination of the Planning Board that portions of the proposed work are connected to the whole action and, consequently, approving them could be considered segmentation of the SEQR review process. This work, which includes the extension of the travel lift and work associated with the travel lift extension, as well as any other new work, should not be allowed to move forward until the SEQR process has been concluded.” In spite of this, the Board of Trustees voted, inappropriately we believe, to approve all work in the application despite the public comments, public letters, and the Planning Board’s written objection.7 The Planning Board should also be cognizant of the fact the Project, as described in the DEIS, does not appear to be the project the Applicant intends to build. First, the Applicant has indicated in other venues that it is likely that the Project will be constructed in phases, with initial phase including only one yacht storage building. The second building, would be constructed only if factors such as suitable bank financing, and if interest rates and the price of steel come down.8 Second, the proposed water line, which 6 Minutes, May 19, 2021, Southold Board of Trustees. 7 Memorandum dated May 19, 2021 from James H. Rich III, Vice Chairman, and Members of the Planning Board, to Glenn Goldsmith, President, Town of Southold Board of Trustees. 8 This is discussed in greater detail in the comment section relating to Project Alternatives. Page | Project Description - 4 Rev 6b is touted in the DEIS as a Project benefit is, according to the Suffolk County Water Authority scheduled for construction in May 2023, and will be in place independent of construction of the Project.9 9 This is discussed in greater detail in the comment section relating to Water Supply. Page | Project Description - 5 Rev 6b ATTACHMENT DESCRPTION-1a Page | Project Description - 6 Rev 6b ATTACHMENT DESCRPTION-1b