Attention: Kenneth Kovalchik, Town Planner, Kovalchikk@togny.org

The Draft Environmental Impact Statement (DEIS) for the proposed development by Pyramid (Crossgates) on Rapp Road, the Mall Road and Western Avenue to build up to 360 Apartments with up to 3 five-story apartment buildings, up to 50,000 sq ft of office space and up to 278,900 sq ft commercial expansive retail including including a Costco with a 700 car parking lot and a 18 pump gas station should be rejected because the following are not adequately addressed:

1. The quality of life in Guilderland is changing drastically with the explosion of  growth that is occurring. The previous building of the hotel and now this expansion of Crossgates Mall on over 46 additional acres with multiple high-rise apartment buildings, office buildings and a proposed big-box retail Costco is creating a very dense city/urban area that will directly impact neighborhoods that should remain suburban. The Transit Oriented District is supposed to “incentivize development that adequately protects nearby residential neighborhoods” according to the stated purpose in section § 280-18.19(a) of the Town Zoning Code.  This development does not meet that standard.
    
2. Crime is already a problem at Crossgates Mall and Pyramid has reneged on their promise to pay for additional police officers. We do not need to encourage more potential issues in this area with high-density housing and commercial retail. There are several small residential neighborhoods that will be directly affected and overwhelmed by this surge in density.  Traffic and home values being the most obvious impacts that will be detrimental to the homeowners and other residents in this area. We need to preserve and protect the way of life that this suburban area has offered to the current residents of this town and which attracts others to move here.
    
3. The proposed expansion by Pyramid to build a huge Costco big-box store with 18 gas pumps also does not fit the stated purpose of the Transit Oriented District and gas stations should never be built over known aquifers and environmentally sensitive areas.
    
4. This intense development will not help the traffic in this part of Guilderland. To increase the development on these roads and expect traffic to go down, especially on Western Avenue, is magical thinking. 

   From just 2 of the 3 sites, the DEIS traffic study predicts 364 new trips during the weekday AM peak, 662 new trips during the weekday PM peak and 911 new trips during that Saturday peak.

   The traffic congestion on Western Avenue is already horrible and dangerous.  More traffic will only make it more difficult to patronize local businesses. It is almost impossible to make left hand turns from either direction in a safe manner. With the addition of a regional attraction like Costco, the amount of non-local traffic will sky rocket leading to an increased probability of more accidents that will further stress Guilderland’s first responders. This will only get worse around the holidays in the winter.
    

5. The town’s infrastructure has not had any major updates in quite some time. By allowing the projects that Pyramid wants will further stress the water, sewer and road infrastructures. This town cannot continue to allow this unfettered growth without major concerns for the infrastructure of the entire town.  Again, Pyramid has already reneged on its promise to pay for police officers.
    
6. The DEIS does not adequately consider other options, particularly the option to not build these developments at all or to build them inside the Mall Ring Road to make better use of Crossgates Mall and existing under utilized parking lots.
    
7. The core vision for the Town of Guilderland includes a balance of business and residential components that are conducive to the suburban/rural way of life in this town. The growth that is occurring, specifically that of the type that the Pyramid Corporations want to build, does not belong in Guilderland. Huge Malls and big box stores are better situated in areas zoned Industrial or more densely populated areas that are for businesses. Over the past 20 years, we have watched urban and multi-dwelling apartments projects continue westward into Guilderland. This has increased traffic, noise and dirt for anyone who lives a block or two from Western Ave. Let’s protect what we have and say no to any future corporate expansion in town.
    
8. The town must consider the financial status of the applicant. News reports indicate that the Pyramid Group is considering filing bankruptcy.  The Town of Guilderland should not allow projects to begin that have a high likelihood of not being completed.

Thank you,