I can pretty much immediately contradict this as all you have to do is look at the Rivera DVC. It's a brand new built on land that was formerly occupied by CBBR, a moderate property.I think they are counting the CBBR sit down as the one for Riviera though.
So they could easily make it a FW DVC and count Trail's End as the sit-down restaurant (as well as the dinner shows). Build an infinity pool that overlooks the lake (bring in dirt to build up the land) and then add in a few other DVC amenities like laundry and stuff and done.