From the Daily News:
A group of Willets Point business owners fired another shot last week at the $3 billion plan to redevelop the Iron Triangle, but city officials don't expect to fall behind schedule.
The business owners - facing potential eviction when construction begins - charged that the traffic report from the city's Economic Development Corp. is flawed and is reason enough to bring the megadevelopment plan to a halt.
A traffic engineer hired by Willets Point United argued that the city misrepresented congestion on the Van Wyck Expressway created by other nearby projects in its proposal to build on-ramps and off-ramps near the gritty industrial area in the vicinity of Citi Field.
"There does not seem to be any area-wide planning going on for this community," said engineer Brian Ketcham. "They haven't done their analysis correctly."
The EDC's Access Modification Report, which outlines potential congestion on the Van Wyck, did not properly account for the added traffic from other developments, such as Flushing Commons and Sky View Parc, Ketcham said.
"They're trying to whitewash the impact of these projects," he said.
The state Department of Transportation kicked the report back to the EDC a few weeks ago, but agency officials said they are confident it will pass soon.
Richard Lipsky explains what is really going on here and here.
Wednesday, March 31, 2010
Saturday, March 27, 2010
Vince Tabone's letter to the DOT & FHWA
Tabone Letter
The Northeast Queens Community Action Network has joined with the Natural Resources Defense Council to call fora full, independent environmental review with regards to the proposed Van Wyck ramps.
The Northeast Queens Community Action Network has joined with the Natural Resources Defense Council to call fora full, independent environmental review with regards to the proposed Van Wyck ramps.
Monday, March 22, 2010
Brian Ketcham's Testimony at the Queens CB7 Public Hearing On the Flushing Commons DEIS
My name is Brian Ketcham. I am a traffic engineer. I have been working for Willets Point United, assisting them in understanding the full impacts of the Willets Point Development Plan. I am testifying on behalf of Willets Point United.
As I have reviewed the thousands of pages of technical materials for the Willets Point project I have found serious problems with that project that relate to the Flushing Commons; Problems that underscore the traffic problems that your community will suffer from new planned development.
You have already approved the Willets Point project, 9 million square feet of residential and commercial development that will produce 80,000 car and truck trips daily, 365 days a year. The Final Generic Environmental Impact Statement (FGEIS) reports that Willets Point traffic will gridlock your community morning, noon and night. And that is without accounting for projects like the nearby Sky View Parc nearing completion, a project that will add a thousand more trips in the PM peak hour, or what happens during Mets games and/or tennis matches.
What I have found in my review for Willets Point United is that the FGEIS for Willets Point failed to fully account for Sky View Parc and ignored the effects of Flushing Commons. In fact, there is little evidence that the FGEIS accounted for many of the 90 new developments surrounding the Willets Point Iron Triangle. You folks approved a project--Willets Point--that vastly understated its traffic impacts and still reported gridlocked traffic conditions. Clearly, adding another 800 to 1,000 car and truck trips from Flushing Commons in the PM peak hour to an already gridlocked Main Street will simply make life for you folks that much worse.
For Willets Point to work NYCEDC is convinced they need direct access to the Van Wyck Expressway. To get the ramps EDC must convince the Federal Highway Administration (FHWA) that the ramps will improve traffic conditions along the Van Wyck Expressway. To do that EDC has prepared an Access Modification Report or AMR. In doing so the EDC has cut the use of the ramps from 47% in the PM peak hour to 16%, leaving 1,900 PM peak hour auto trips to find other ways to get into or out of the Iron Triangle. Some of this added traffic will move through Downtown Flushing. None of this is accounted for in the Willets Point analyses or in the Flushing Commons DEIS. As bad as conditions are described in both the Willets Point FGEIS and in the Flushing Commons DEIS it will be much worse once these projects are completed.
The following summarizes just some of the issues that I have identified as I have reviewed the Draft Environmental Impact Statement for Flushing Commons.
The Flushing Commons provides for 1,600 parking spaces in the project, 600 of which are assumed to be required by the project itself. The rest will be available to long term parkers at much greater cost than motorists currently pay. The developer assumes that approximately 70% of residents will own a car whereas 90% of residents in Queens own a car. The DEIS underreports auto use; Correcting for auto ownership alone would require nearly 30% more parking for residents.
Even with this adjustment a great many motorists currently parking at Municipal Lot No. 1 would be displaced by Flushing Commons to more remote commuter parking in Willets Point. There is no evidence that this displacement has been accounted for in the Flushing Commons traffic analysis. I can assure you it has not been accounted for in the Willets Point traffic analyses.
The developer assumes that less than 30% of all resident trips are made by auto for any purpose. Travel behavior in Queens is very different from that assumed in the Flushing Commons DEIS—most of which is lifted from the Willets Point FGEIS. Compared to the 30% assumption for auto use, 53% of Queens’s trips are made by auto.
The DEIS also assumes 46% of residents will use transit (Willets Point assumes 55%). Queens’ residents use transit for just 23% of travel. See attached Table. Auto use by Flushing Commons' residents is very likely substantially greater than what has been assumed. Correcting for this error will result in a near doubling of resident auto trips with a huge impact on congestion in your community.
The proportion of auto trips made by all land uses in Flushing Commons does not change by time of day. This is simply wrong. Trip purpose and volume does vary by time of day. Reference NYMTC’s “Household Interview Survey” for evidence of this behavior.
The developer has already reported to CB7 that congestion levels with the project will be severe in Downtown Flushing and that the traffic problems caused by the project cannot be mitigated. The DEIS reports huge impact at Downtown Flushing intersections such as at Northern Blvd. and Main Street where northbound left turn vehicle delay is increased from 7 minutes to 14 minutes or at Roosevelt Avenue and Union Street where the southbound right turn delay increases from 6 minutes to 18 minutes—I emphasize minutes of delay not seconds meaning severe gridlocked conditions.
Congestion levels in and around Downtown Flushing will be even worse than has been reported by the developer. First, because auto trip generation and temporal distributions for the project are wrong; Correcting for these errors will add significantly to congestion levels.
Plus, Flushing Commons has accounted for only a tiny fraction of the traffic generated by the Willets Point Development Plan.
Like Willets Point, Flushing Commons has low balled auto ownership, failed to provide sufficient resident parking and assumed very low usage of autos for trips. These assumptions are wrong and are contradicted by various sources. Correcting for these errors will add greatly to Flushing Commons’ No Build traffic volume in Downtown Flushing and therefore increase the severity of project impacts.
In addition, the Willets Point plan assumes about half the traffic produced by that project will use the proposed Van Wyck ramps. I have to emphasize that NYCEDC has recently cut this assumption to 16% of Willets Point traffic using the Van Wyck ramps leaving nearly 1,900 auto trips unaccounted for in the PM peak hour.
I have modeled the proposed ramps and demonstrated that the Van Wyck Expressway cannot accommodate even 16% of Willets Point traffic. Adding more traffic to the Van Wyck Expressway severely reduces travel speeds. The ramps will not work as hoped for.
The bottom line is that Flushing Commons has not accounted for Willets Point traffic and has under estimated the number of auto trips Flushing Commons will produce during peak commuter hours. Congestion levels reported in the DEIS will therefore be much more severe than the gridlocked conditions already reported by the developer.
I have not estimated the externality costs for Flushing Commons, but the costs of added traffic congestion, the addition of 1,000 more traffic accidents and the health and environmental damages from the full build out of the Willets Point Development Plan comes to more than $150 million annually, or about four times the benefits claimed for that project.
I suggest that CB7 undertake similar analyses for Flushing Commons to see if there is any economic benefit from this project. I also recommend that you get NYCDOT to undertake traffic simulation modeling so that you finally understand how your community processes traffic and how you can improve traffic flow.
Finally, you really need a wholesale revision for the DEIS that corrects for the many errors that I have identified before any action is taken by CB7 on this project.
In the absence of any revised and corrected DEIS, Community Board 7 lacks the necessary information on which to base any approval of the Flushing Commons Project, and in that case must reject the application.
Brian T. Ketcham, P.E.
BRIAN KETCHAM ENGINEERING, P.C.
175 Pacific Street, Brooklyn, NY 11201
March 22, 2010
As I have reviewed the thousands of pages of technical materials for the Willets Point project I have found serious problems with that project that relate to the Flushing Commons; Problems that underscore the traffic problems that your community will suffer from new planned development.
You have already approved the Willets Point project, 9 million square feet of residential and commercial development that will produce 80,000 car and truck trips daily, 365 days a year. The Final Generic Environmental Impact Statement (FGEIS) reports that Willets Point traffic will gridlock your community morning, noon and night. And that is without accounting for projects like the nearby Sky View Parc nearing completion, a project that will add a thousand more trips in the PM peak hour, or what happens during Mets games and/or tennis matches.
What I have found in my review for Willets Point United is that the FGEIS for Willets Point failed to fully account for Sky View Parc and ignored the effects of Flushing Commons. In fact, there is little evidence that the FGEIS accounted for many of the 90 new developments surrounding the Willets Point Iron Triangle. You folks approved a project--Willets Point--that vastly understated its traffic impacts and still reported gridlocked traffic conditions. Clearly, adding another 800 to 1,000 car and truck trips from Flushing Commons in the PM peak hour to an already gridlocked Main Street will simply make life for you folks that much worse.
For Willets Point to work NYCEDC is convinced they need direct access to the Van Wyck Expressway. To get the ramps EDC must convince the Federal Highway Administration (FHWA) that the ramps will improve traffic conditions along the Van Wyck Expressway. To do that EDC has prepared an Access Modification Report or AMR. In doing so the EDC has cut the use of the ramps from 47% in the PM peak hour to 16%, leaving 1,900 PM peak hour auto trips to find other ways to get into or out of the Iron Triangle. Some of this added traffic will move through Downtown Flushing. None of this is accounted for in the Willets Point analyses or in the Flushing Commons DEIS. As bad as conditions are described in both the Willets Point FGEIS and in the Flushing Commons DEIS it will be much worse once these projects are completed.
The following summarizes just some of the issues that I have identified as I have reviewed the Draft Environmental Impact Statement for Flushing Commons.
The Flushing Commons provides for 1,600 parking spaces in the project, 600 of which are assumed to be required by the project itself. The rest will be available to long term parkers at much greater cost than motorists currently pay. The developer assumes that approximately 70% of residents will own a car whereas 90% of residents in Queens own a car. The DEIS underreports auto use; Correcting for auto ownership alone would require nearly 30% more parking for residents.
Even with this adjustment a great many motorists currently parking at Municipal Lot No. 1 would be displaced by Flushing Commons to more remote commuter parking in Willets Point. There is no evidence that this displacement has been accounted for in the Flushing Commons traffic analysis. I can assure you it has not been accounted for in the Willets Point traffic analyses.
The developer assumes that less than 30% of all resident trips are made by auto for any purpose. Travel behavior in Queens is very different from that assumed in the Flushing Commons DEIS—most of which is lifted from the Willets Point FGEIS. Compared to the 30% assumption for auto use, 53% of Queens’s trips are made by auto.
The DEIS also assumes 46% of residents will use transit (Willets Point assumes 55%). Queens’ residents use transit for just 23% of travel. See attached Table. Auto use by Flushing Commons' residents is very likely substantially greater than what has been assumed. Correcting for this error will result in a near doubling of resident auto trips with a huge impact on congestion in your community.
The proportion of auto trips made by all land uses in Flushing Commons does not change by time of day. This is simply wrong. Trip purpose and volume does vary by time of day. Reference NYMTC’s “Household Interview Survey” for evidence of this behavior.
The developer has already reported to CB7 that congestion levels with the project will be severe in Downtown Flushing and that the traffic problems caused by the project cannot be mitigated. The DEIS reports huge impact at Downtown Flushing intersections such as at Northern Blvd. and Main Street where northbound left turn vehicle delay is increased from 7 minutes to 14 minutes or at Roosevelt Avenue and Union Street where the southbound right turn delay increases from 6 minutes to 18 minutes—I emphasize minutes of delay not seconds meaning severe gridlocked conditions.
Congestion levels in and around Downtown Flushing will be even worse than has been reported by the developer. First, because auto trip generation and temporal distributions for the project are wrong; Correcting for these errors will add significantly to congestion levels.
Plus, Flushing Commons has accounted for only a tiny fraction of the traffic generated by the Willets Point Development Plan.
Like Willets Point, Flushing Commons has low balled auto ownership, failed to provide sufficient resident parking and assumed very low usage of autos for trips. These assumptions are wrong and are contradicted by various sources. Correcting for these errors will add greatly to Flushing Commons’ No Build traffic volume in Downtown Flushing and therefore increase the severity of project impacts.
In addition, the Willets Point plan assumes about half the traffic produced by that project will use the proposed Van Wyck ramps. I have to emphasize that NYCEDC has recently cut this assumption to 16% of Willets Point traffic using the Van Wyck ramps leaving nearly 1,900 auto trips unaccounted for in the PM peak hour.
I have modeled the proposed ramps and demonstrated that the Van Wyck Expressway cannot accommodate even 16% of Willets Point traffic. Adding more traffic to the Van Wyck Expressway severely reduces travel speeds. The ramps will not work as hoped for.
The bottom line is that Flushing Commons has not accounted for Willets Point traffic and has under estimated the number of auto trips Flushing Commons will produce during peak commuter hours. Congestion levels reported in the DEIS will therefore be much more severe than the gridlocked conditions already reported by the developer.
I have not estimated the externality costs for Flushing Commons, but the costs of added traffic congestion, the addition of 1,000 more traffic accidents and the health and environmental damages from the full build out of the Willets Point Development Plan comes to more than $150 million annually, or about four times the benefits claimed for that project.
I suggest that CB7 undertake similar analyses for Flushing Commons to see if there is any economic benefit from this project. I also recommend that you get NYCDOT to undertake traffic simulation modeling so that you finally understand how your community processes traffic and how you can improve traffic flow.
Finally, you really need a wholesale revision for the DEIS that corrects for the many errors that I have identified before any action is taken by CB7 on this project.
In the absence of any revised and corrected DEIS, Community Board 7 lacks the necessary information on which to base any approval of the Flushing Commons Project, and in that case must reject the application.
Brian T. Ketcham, P.E.
BRIAN KETCHAM ENGINEERING, P.C.
175 Pacific Street, Brooklyn, NY 11201
March 22, 2010
Saturday, March 20, 2010
We agree!
From a letter to the editor of the Queens Tribune, written by Lenny Rodin of Forest Hills:
...the worst decision the Supreme Court has made in the past few years was Kelo v. New London where the court ruled 5-4 that states and localities could use the power of eminent domain to take over private property for the benefit of private developers. You can see the result of that in Willets Point and Brooklyn, where the city is trying to take over property for private uses. It is ironic that the four justices who voted in the minority against this power grab were the four most conservative judges who liberals love to hate.
...the worst decision the Supreme Court has made in the past few years was Kelo v. New London where the court ruled 5-4 that states and localities could use the power of eminent domain to take over private property for the benefit of private developers. You can see the result of that in Willets Point and Brooklyn, where the city is trying to take over property for private uses. It is ironic that the four justices who voted in the minority against this power grab were the four most conservative judges who liberals love to hate.
Friday, March 19, 2010
Interesting explanation for Willets Point delay
From the Gotham Gazette:Also this morning, [New York City Economic Development Corp. Seth] Pinsky said the city is still negotiating with property owners in Queens so it can move forward with its Willets Point development. Currently, he said, the city has secured 70 percent of the property and is negotiating the relocation of other property owners for the final 30 percent.
Pinksy [sic] said the corporation is waiting out the economic downturn to put the project out to bid, which he projected could happen later this year or early 2011. The corporation put out a “request for qualifications” — the precursor to the actual request for proposals — late last year. They received 29 responses. The city will develop the area piece by piece, starting in the southwest, he added.
We suppose the delay has nothing to do with the fact that WPU has been meeting with NYS Dept of Transportation and the Federal Highway Administration to discuss the Van Wyck ramp project and Brian Ketcham's impressive analysis has caused both agencies to ask for EDC's traffic impact study to be redone. Which will take at least a year.
Or maybe none of the developers is qualified to take on such a huge project - especially not TDC, who along with EDC, can't even get their act together on a much smaller project in the middle of Flushing that was supposed to have been built 5 years ago.
Let state conduct better traffic study
From the Times Ledger:Thursday, March 18, 2010
On behalf of the Northeast Queens Community Action Network, I am writing to join with the National Resource Defense Council as well as other concerned citizens and groups in expressing concern over discrepancies in study results that could mean greater effects on traffic mobility, noise and air pollution and congestion than anticipated.
Our understanding is that the Environmental Impact Statement prepared by New York City pursuant to the State Environmental Quality Review Act projected significant traffic effects while the draft Access Modification Report showed minor effects. This divergence in results gives one pause as to the reliability of the underlying study methodology as well as the adequacy of proposed mitigation measures.
The NEQCAN’s ultimate mission is to assist our community in combating neighborhood deterioration through dissemination of information and to ameliorate problems associated with public safety and quality of life issues. In keeping with that mission, we urge you to consider our concerns.
I for one, as a former New York City economic development official, do not impute ill motive to the project proponents — in this case, the city Economic Development Corp. From personal experience, I have never met or worked with a more dedicated group of public servants more eager to fulfill their agency’s mandate to promote and advance development.
Indeed, they have a cadre of planning, transportation and real estate professionals of consummate ability and integrity.
Notwithstanding the same, there is a significant and inexplicable divergence in results and given the potential effects and amount of public investment contemplated, it stands to reason further study is called for to ensure mitigation measures, design, etc., are optimized.
To this end, the NEQCAN joins with the NRDC in calling for full independent environmental review pursuant to the National Environmental Policy Review Act of the proposed access ramps and their effects on the Van Wyck Expressway.
This approach should ensure that adequate mitigation measures and design features are implemented and community concerns that potential effects are properly addressed and implemented to the extent possible.
Vince Tabone
President
Northeast Queens Community Action Network
Whitestone
Wednesday, March 17, 2010
Precedent for ramp rejection
From Neighborhood Retail Alliance:
Well, one thing is really good to know. When state DOT finds that ramps are not in the community's interest they get busy to jettison them-even when the ramps in question are their own idea. That's exactly what happened with ramps that the agency planned to build off of the Deegan, and the Mott Haven Herald has the story: "Pummeled by public outcry against a plan to extend the off-ramps on the Major Deegan Expressway, the State Department of Transportation has abandoned the project. Much-needed repairs will be made to the aging roadway over Mott Haven, but the plan to extend the highway’s exit ramps in order to calm the traffic that backs up as cars merge onto Exterior Street is on hold indefinitely, said DOT spokesman Adam Levine."
So this post now becomes a tale of two ramp projects-and the Mott Haven victory demonstrates that state DOT does listen to the voice of the community; and needs to do just that when it considers whether or not to build ramps off the Van Wyck in order to facilitate the Willets Point development. In fact, the Van Wyck ramps need to undergo the same vigorous community review that the ones in the Bronx went through.
As the MH Herald tells us: "Every speaker at a public hearing at Hostos Community College on Nov. 9 denounced the state proposal. Some speakers also expressed concern that efforts to ease congestion would simply attract more cars, and more pollution. Others criticized plans to use eminent domain to seize existing businesses in order to make room for the new ramps. “We need more jobs, more affordable housing, more clean air, not more highway,” said Mychal Johnson, a member of Community Board 1 who initiated a petition campaign against the state plan. “The Deegan should be repaired, but not expanded,” he said in an interview."
So, as WPU continues to present its critique of the city-sponsored Van Wyck ramps to impacted community groups, it is incumbent upon NYSDOT to initiate its own community review process-Flushing, Corona, College Point and all of the surrounding Queens nabes deserve no less.. And the more facts we find out about these ramps-and the faulty report submitted by DOT-the worse they look. Put simply, they are exacerbators not mitigators.
Well, one thing is really good to know. When state DOT finds that ramps are not in the community's interest they get busy to jettison them-even when the ramps in question are their own idea. That's exactly what happened with ramps that the agency planned to build off of the Deegan, and the Mott Haven Herald has the story: "Pummeled by public outcry against a plan to extend the off-ramps on the Major Deegan Expressway, the State Department of Transportation has abandoned the project. Much-needed repairs will be made to the aging roadway over Mott Haven, but the plan to extend the highway’s exit ramps in order to calm the traffic that backs up as cars merge onto Exterior Street is on hold indefinitely, said DOT spokesman Adam Levine."
So this post now becomes a tale of two ramp projects-and the Mott Haven victory demonstrates that state DOT does listen to the voice of the community; and needs to do just that when it considers whether or not to build ramps off the Van Wyck in order to facilitate the Willets Point development. In fact, the Van Wyck ramps need to undergo the same vigorous community review that the ones in the Bronx went through.
As the MH Herald tells us: "Every speaker at a public hearing at Hostos Community College on Nov. 9 denounced the state proposal. Some speakers also expressed concern that efforts to ease congestion would simply attract more cars, and more pollution. Others criticized plans to use eminent domain to seize existing businesses in order to make room for the new ramps. “We need more jobs, more affordable housing, more clean air, not more highway,” said Mychal Johnson, a member of Community Board 1 who initiated a petition campaign against the state plan. “The Deegan should be repaired, but not expanded,” he said in an interview."
So, as WPU continues to present its critique of the city-sponsored Van Wyck ramps to impacted community groups, it is incumbent upon NYSDOT to initiate its own community review process-Flushing, Corona, College Point and all of the surrounding Queens nabes deserve no less.. And the more facts we find out about these ramps-and the faulty report submitted by DOT-the worse they look. Put simply, they are exacerbators not mitigators.
Thursday, March 11, 2010
Could the FHWA be going our way?
From the Neighborhood Retail Alliance:
The team from Willets Point United met with the Federal Highway Administration in order to brief the agency about the complexity of the traffic impacts generated by the development at the site of the Iron Triangle-and the ramps that are supposed to mitigate said traffic. The FHWA, along with NYSDOT, need to approve these ramps if the the Willets Point project is to be able to go forward.
Now it is our contention that the entire review process should be subject to an independent evaluation under the National Environmental Policy Act (NEPA). Our rationale derives from the faulty and self serving traffic data submissions from the Economic Development Corporation and its hired guns from URS-something that we have already pointed out here, and here. EDC and its minions have proven to be-either through mendacity or inadequacy-simply not up to the task of providing quality data.
Now the glaring nature of this insufficiency is underscored by the discrepancies between the original EIS done for the ULURP application; and the subsequent report done exclusively for the ramp approval process (called an AMR report). Here's how consultant Brian Ketcham summarizes these inadequacies:
"1. Too many discrepancies between AMR and FGEIS for the AMR to be reliable assessment of ramps.
2. FGEIS reports severe traffic impacts even w/ramps; the AMR reports no problems.
3. Field observation confirms the FGEIS.
4. AMR greatly misrepresents future traffic growth.
5. AMR does not account for all Willets Point trips.
6. AMR shows that ramps make no difference.
7.Modeling shows the ramps are counter-productive for highway system, violating FHWA key criteria.
In the face of all of this, what choice is there? NYSDOT must disapprove the AMR."
These problems are also fatal when you examine what the federal highway guidelines are for the approval of ramps-as item 7 above highlights. Ketcham's work for WPU-and remember that Brian, as well as WPU attorney Mike Gerrard, were the young turks who brought down Westway-was damning enough to prompt the NYSDOT to spit back the first AMR to EDC for serious revision.
In fact, the glaring, and problematic nature of the city's work product, has prompted the following from the National Resources Defense Council-in a letter to NYSDOT and the FHWA "NRDC is not taking a position on advancing the Willets Point project or on constructing the ramps. But based on our preliminary review, we are concerned over the discrepancies in the study results, and also by the prospect that a project could impair regional mobility by disrupting a key highway like the Van Wyck."
And NRDC goes on to say that because of these discrepancies, "...we believe that the best course of action is for the FHWA and NYS DOT to undertake a full NEPA review of the access ramps and their impacts on traffic-including the Van Wyck-without undue reliance on the analysis performed by the City, the project's proponents."
Nothing less should be required here, because as we have seen with Columbia, there is alot of incestuous activity going on between the City and its hired guns-and the first victim in all of this is the truth. But the good news emanating from today's meeting is that the folks at FHWA believe that our (really Brian's) critique has serious merit-and it will be undertaking a comprehensive environmental assessment to determine what the appropriate course of action should be in the case of these ramps-taking the process out of the hands of biased, parochial interests.
The next step for WPU is to bring the message to the Queens civic groups so that they can see for themselves the traffic nightmare in their future if this Willets Point project is allowed to go forward. In the process, the self serving dealings of the city's lead economic development agency will be thoroughly hung out to dry for everyone to plainly see-from illegal lobbying and false city council testimony, to cooked traffic books; sunlight will be the best disinfectant.
The team from Willets Point United met with the Federal Highway Administration in order to brief the agency about the complexity of the traffic impacts generated by the development at the site of the Iron Triangle-and the ramps that are supposed to mitigate said traffic. The FHWA, along with NYSDOT, need to approve these ramps if the the Willets Point project is to be able to go forward.
Now it is our contention that the entire review process should be subject to an independent evaluation under the National Environmental Policy Act (NEPA). Our rationale derives from the faulty and self serving traffic data submissions from the Economic Development Corporation and its hired guns from URS-something that we have already pointed out here, and here. EDC and its minions have proven to be-either through mendacity or inadequacy-simply not up to the task of providing quality data.
Now the glaring nature of this insufficiency is underscored by the discrepancies between the original EIS done for the ULURP application; and the subsequent report done exclusively for the ramp approval process (called an AMR report). Here's how consultant Brian Ketcham summarizes these inadequacies:
"1. Too many discrepancies between AMR and FGEIS for the AMR to be reliable assessment of ramps.
2. FGEIS reports severe traffic impacts even w/ramps; the AMR reports no problems.
3. Field observation confirms the FGEIS.
4. AMR greatly misrepresents future traffic growth.
5. AMR does not account for all Willets Point trips.
6. AMR shows that ramps make no difference.
7.Modeling shows the ramps are counter-productive for highway system, violating FHWA key criteria.
In the face of all of this, what choice is there? NYSDOT must disapprove the AMR."
These problems are also fatal when you examine what the federal highway guidelines are for the approval of ramps-as item 7 above highlights. Ketcham's work for WPU-and remember that Brian, as well as WPU attorney Mike Gerrard, were the young turks who brought down Westway-was damning enough to prompt the NYSDOT to spit back the first AMR to EDC for serious revision.
In fact, the glaring, and problematic nature of the city's work product, has prompted the following from the National Resources Defense Council-in a letter to NYSDOT and the FHWA "NRDC is not taking a position on advancing the Willets Point project or on constructing the ramps. But based on our preliminary review, we are concerned over the discrepancies in the study results, and also by the prospect that a project could impair regional mobility by disrupting a key highway like the Van Wyck."
And NRDC goes on to say that because of these discrepancies, "...we believe that the best course of action is for the FHWA and NYS DOT to undertake a full NEPA review of the access ramps and their impacts on traffic-including the Van Wyck-without undue reliance on the analysis performed by the City, the project's proponents."
Nothing less should be required here, because as we have seen with Columbia, there is alot of incestuous activity going on between the City and its hired guns-and the first victim in all of this is the truth. But the good news emanating from today's meeting is that the folks at FHWA believe that our (really Brian's) critique has serious merit-and it will be undertaking a comprehensive environmental assessment to determine what the appropriate course of action should be in the case of these ramps-taking the process out of the hands of biased, parochial interests.
The next step for WPU is to bring the message to the Queens civic groups so that they can see for themselves the traffic nightmare in their future if this Willets Point project is allowed to go forward. In the process, the self serving dealings of the city's lead economic development agency will be thoroughly hung out to dry for everyone to plainly see-from illegal lobbying and false city council testimony, to cooked traffic books; sunlight will be the best disinfectant.
Atlantic Yards opponents basically being held hostage in their own homes!
From Atlantic Yards Report:
Things are getting truly strange for Daniel Goldstein, spokesman for Develop Don't Destroy Brooklyn, who with his wife and child is the only resident left on Pacific Street between Fifth and Sixth avenues.
Goldstein lost his condo to condemnation last week and his street and two others were closed and made private.
Now that his street is closed to traffic--permanently at Fifth Avenue, and via guarded barriers at Sixth Avenue, anyone visiting Goldstein must provide advance notice, which means friends have been stopped by guards and kept him on the phone today with representatives of both Forest City Ratner and the Empire State Development Corporation (ESDC), which owns his property.
Goldstein on March 4 received a letter (below) from Charles Webb, ESDC Condemnation Counsel, informing him that "ESDC requires you to relocate by April 3, 2010 (thirty days after the date of this letter) so that development plans for the Atlantic Yards Arena and Redevelopment Project... may proceed."
Goldstein's attorney Michael Rikon responded forcefully, on behalf of Goldstein and other footprint property owners, calling Webb's letter "an attempt to intimidate our clients":
First, you have absolutely no right to inform anyone that they must vacate by April 3, 2010. You must understand that condemnees have the protection of New York's Eminent Domain Procedure Law. You cannot even suggest a vacate date until you comply with the requirements of the law.
Those requirements include a notice of acquisition and a good faith advance payment. Then the date to vacate would be set by the condemnation court.
He added that "no roadway or access to a street or highway may be interfered with."
Things are getting truly strange for Daniel Goldstein, spokesman for Develop Don't Destroy Brooklyn, who with his wife and child is the only resident left on Pacific Street between Fifth and Sixth avenues.
Goldstein lost his condo to condemnation last week and his street and two others were closed and made private.
Now that his street is closed to traffic--permanently at Fifth Avenue, and via guarded barriers at Sixth Avenue, anyone visiting Goldstein must provide advance notice, which means friends have been stopped by guards and kept him on the phone today with representatives of both Forest City Ratner and the Empire State Development Corporation (ESDC), which owns his property.
Goldstein on March 4 received a letter (below) from Charles Webb, ESDC Condemnation Counsel, informing him that "ESDC requires you to relocate by April 3, 2010 (thirty days after the date of this letter) so that development plans for the Atlantic Yards Arena and Redevelopment Project... may proceed."
Goldstein's attorney Michael Rikon responded forcefully, on behalf of Goldstein and other footprint property owners, calling Webb's letter "an attempt to intimidate our clients":
First, you have absolutely no right to inform anyone that they must vacate by April 3, 2010. You must understand that condemnees have the protection of New York's Eminent Domain Procedure Law. You cannot even suggest a vacate date until you comply with the requirements of the law.
Those requirements include a notice of acquisition and a good faith advance payment. Then the date to vacate would be set by the condemnation court.
He added that "no roadway or access to a street or highway may be interfered with."
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