Thursday, May 26, 2011

Technically Flawed by Design: Kill the Van Wyck Ramps

As we approach the June 8th EDC-sponsored gearing on the Willets Point ramps, the wicked web that the agency is attempting to weave is becoming clearer. EDC has produced so many competing traffic documents that it is hard for even WPU's Brian Ketcham to keep up with the competing claims and "updates." But as Mayor LaGuardia once famously said, "No matter how you slice it, it's still baloney."

In the interest of truth and greater transparency WPU has been calling for an independent review of the traffic impact of, not only the ramps, but the entire Willets Point project-including the Phae 1 add on, that EDC tries to claim with a straight face will have no real need for those pesky ramps. As part of this effort we went down to the College Point Civic Association last night in order to update as well as exhort the community to attend the EDC hearing.

Our major point was that our roads and highways are already jammed. The last thing we need is a massive auto dependent development that will further erode our community quality of life. The ramps should be turned down and the entire project re-thought. But even more compelling is the fact that EDC is trying to hide these impacts in its desperate need to get the mayor's legacy project off of the ground.

We need an independent review because EDC and the city can’t be trusted to mark its own tests. Whether it is the bike lanes, school test scores or now the Van Wyck ramps, the city must be held accountable to independent review.

We asked College Point to join with us and oppose the ramps-helping to put the lie to EDC's claim that the ramps are uncontroversial. After WPU's presentation Senator Avella came back to the podium and said, ": "What this guy is telling you is VERY important; these ramps and this whole project will wreck this community; you MUST attend the hearing on June 8 or you will be very sorry; etc." He went into detail. The reaction in the room seemed to be squarely against the ramps, the traffic and the development.

Then, Avella acknowledged comments that I made regarding the city's manipulation of traffic reports however necessary to gain approval of ramps, and Avella said: "Make no mistake -- EDC lies. And so I arranged for the Willets Point group to meet with the Office of the Attorney General. Because the lies cannot continue."

But they are continuing as Ketcham's incredible truth seeking effort on the city's Phase 1 technical analysis points out:

"The bottom line is that this TM4 Appendix fails to focus attention on traffic operation actually servicing the Phase I project and instead focuses on the area wide project impacts; it fails to fully account for all Phase I trip generation and/or precisely how these trips will access the Phase I site or how this traffic accesses the 910 space off-street parking garage; it fails to estimate traffic operations in and near the Phase I site other than the two major entry/exit points, 126th Street at 34th Avenue and 126th Street at Roosevelt Avenue especially along 126th Street; and in spite of this it reports severe gridlock conditions at the intersection of 126th Street at 34th Avenue as well as severe gridlock conditions for southbound trips exiting the site through the intersection of 126th Street at Roosevelt Avenue.

Finally, there is still no evaluation of parking demand or of how motorists will travel to and from the proposed parking garage site below the hotel in Lot A1.” There in nothing in the subject EDPL Comments that changes this summary."

We'll leave you with the following memorandum that explains why this entire corrupt process needs to be over turned-and the lies exposed as Avella says:

What Needs to Be Done:

(1.) NYS DOT and FHWA must reject the Environmental Assessment (EA) that is the subject of the hearing, because it does not compare the proper scenarios, low-balls traffic, and is therefore defective and unworthy.

(a) Failure to compare proper scenarios: The EA attempts to justify the proposed ramps by comparing an invalid baseline condition – a fully developed Willets Point, but without the ramps – to a fully developed Willets Point together with the ramps. EDC is shrewdly using a baseline condition which assumes that the entire Willets Point project will be built even if ramps are not involved, yet at the City Council EDC said that the project cannot be built unless the ramps are approved. So, the comparison of conditions within the EA is both self-serving and false.

(b) Under-reporting of traffic: The Flushing Commons project and an additional 20 million square feet of development are not factored into any EDC analysis of traffic impacts. Making this even worse is that the consultants for Flushing Commons were the same ones who did the FGEIS for Willets Point and their analysis also claims that 46% of the Willets Point traffic will go on the ramps-an assumption that is now discarded by the newly created EA for the ramps.

(2.) NYS DOT and FHWA must find that the proposed ramps do have significant impacts, and therefore that a full Environmental Impact Statement (EIS) is mandated. The ramps enable the full Willets Point development, which in turn generates traffic – 80,000 vehicle trips per day –having severe adverse impacts which are indirect impacts of the ramps and cannot be disassociated from the ramps.

What follows here is a bill of particulars concerning the lack of professionalism and basic integrity of the review process for the Willets Point/Van Wyck ramps. Why this is important devolves from the fact that the proposed project-even according to the low balled estimates of EDC-will generate 80,000 new car trips every day; inundating local streets and the highway grid with traffic gridlock.

*Gross Discrepancy between original EIS and the ramp report (AMR): why wasn’t this flagged by NYSDOT staff before the intervention of Willets Point United’s consultant;

Discussion: The original EIS said that 46% of the Willets Point traffic would be diverted to the Van Wyck ramps; the actual ramp report-done under the supervision of the same consultant-informed State DOT that only 16% would be diverted. This discrepancy has never been adequately addressed or resolved.

*AKRF was the original consultant hired by EDC for both the EIS and the AMR (ramp report). How could this consultant not be aware of the discrepancies-really blatant contradictions-between two reports that it had supervision over?

*After NYSDOT was made aware by Ketcham that the two traffic reports were contradictory, why didn’t the DOT look for a disinterested consultant to analyze the viability of the proposed ramps;
Discussion: WPU called for an independent review; as did the Natural Resources Defense Council, the Sierra Club, and half a dozen civic groups.

*If the AMR said that there would only be 16% diversion of local traffic onto the ramps (the EIS had said 46%), where did EDC think the additional 1900 vehicles would go during peak travel hours, if not to the already gridlocked streets?

*EDC’s consultants argue that half of the trips will be diverted to mass transit. But no one has analyzed whether the 7 Line and local buses can accommodate all of these thousands of daily extra riders. Shouldn’t this be a concern of the committee?

Discussion: The potential calamity here is made worse by the fact that Flushing Commons and an additional 20 million sq. ft. of development is not factored into any EDC analysis of traffic impacts.

*The NRDC has endorsed an independent review under the Environmental Policy Act because it believes that the applicant (EDC) is not a disinterested party-a fact borne out by the exposure of the contradictory reports;

*E-mails obtained under FOIA by Willets Point United indicate that there was a potential collusion between NYS DOT and EDC to expedite the review even after staff had pointed out what it believed were fatal flaws in the AMR;

*E-mails obtained by WPU indicate that the second ramp located near the Northern Boulevard Bridge is too close to the bridge and will have to be widened. Has a cost for this been estimated? But that widening would impact on the wetlands next to the Flushing River. Has this been considered by NYSDOT?

*Why has it been necessary for Willets Point United to FOIL information after it was promised that-owing to the manner in which consultant Ketcham had exposed the flaws of the AMR-it would be allowed ongoing access to the data and reports?

*The New SDOT commissioner is Joan McDonald who used to be an executive at EDC. Since she took over at the agency we have seen a complete sea change in attitude and a willingness to go along with EDC’s deficient data-witness the upcoming public hearing. Why hasn’t McDonald recused herself for a conflict of interest?

*When EDC went before the community board and the city council it told one and all that Willets Point needed to be developed as a, “totality.” Now, stymied by WPU’s critique of its deficient traffic data, EDC has gone back on its word and is developing a Phase 1 that it says doesn’t need the ramps. According to whom? The same consultants who have proven to be not up to the task of providing reliable data?

*EDC is arguing that the ramps are essential in order to mitigate the traffic from their development, but it is doing so dishonestly by saying that the choice is between a Willets Point project with, or without the ramps. The honest choice-since EDC has always said: no ramps, no project-is between a project with the ramps versus one with no project at all. This is the only true baseline analysis and EDC avoids it for the obvious reason that it would compel DOT to turn down the ramp application since the massive traffic influx will seriously degrade the Van Wyck.

Discussion: The Van Wyck ramps, and the entire Willets Point project will create a massive impact on the local road and mass transit infrastructure. In order for the true community impacts of the traffic to be properly gauged an independent review is essential. Anyone concerned with the public interest-and community quality of life-should support this position.

EDC’s notice of the public hearing associates the proposed ramps with purported “previous planning strategies undertaken by and for the local community”. Presumably, the plan “undertaken by the local community” to which EDC refers is the Downtown Flushing Development Framework (DFDF), which EDC routinely points to as proof that the our community consents to EDC’s plans. The DFDF cheerfully advocates extensive development in downtown Flushing; development of the eastern portion of the Flushing River waterfront that is located mid-way between downtown Flushing and Willets Point; and development of Willets Point.

Discussion: The Downtown Flushing Development Framework (DFDF) contains no mention – let alone any actual analysis – of any environmental impact of any of the untested development ideas that are imagined within the DFDF. Although the DFDF is a wish-list of potential future development projects, the mere existence of the DFDF does not permit any of the potential projects to evade appropriate scrutiny of the impacts that such a project will create; nor does the mere presence of an untested idea within the DFDF suggest that the community has granted EDC a license to create traffic gridlock, hinder business efficiency, and reduce the quality of life.

To the contrary: each and every potential project that is contemplated by the DFDF – including the proposed Willets Point development, and especially the proposed new Van Wyck ramps which enable the full development – must undergo a rigorous environmental evaluation, which necessarily must include the possibility that the potential project cannot be approved due to its impacts. The proposed Van Wyck ramps are presently undergoing such a review, which they did not undergo during the creation of the DFDF. Public support, if any, for any part of the DFDF has never taken into account any environmental impacts or the public’s concerns about them, and certainly does not constitute a willingness on the part of the public to tolerate any and all impacts that a potential project will create