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.
175 Pacific Street, Brooklyn, NY 11201
March 22, 2010