ABRACADABRA – From Traffic Nightmare To Open Roads

Decision-makers confront Willets West mall developers' questionable traffic mitigation report, whose author has not committed to the "feasibility" or "effectiveness" of the alleged solutions it presents

The proposed Willets Point development was already considered a huge traffic generator back in 2008, when its size was limited to 62 acres of Willets Point property. At the time, traffic experts warned of severe impacts on many of the roadways that pass by and through Willets Point, should the development proceed. One such expert, Bernard Adler (former Traffic Commissioner of the town of White Plains), testified: "I have never seen this level of unmitigated impact, in the forty years I've been practicing."

Concerns about the traffic impacts of that original 62-acre project are well-documented (see http://www.trafficnightmare.org/the-future-with-the-ramps.html), and were intensified by the proposed project's location at the nexus of popular Queens roadways that are routinely used by daily commuters, and that are also the main routes serving both of New York City's airports.

Flash-forward five years – and now Mayor Bloomberg, Sterling Equities and Related Companies have expanded the proposed development from 62 acres to 108.9 acres, and added a 1.4 million square foot mall called "Willets West" to be built on parkland property located west of Citi Field stadium. As intolerable as the traffic resulting from the original 62-acre project would have been, it can only get worse with the addition of a 1.4 million square foot mall (which adds 950,000 square feet of retail space to the development).

The developers' new traffic report prepared for the present project (Chapter 14 of the current Draft Supplemental Environmental Impact Statement) describes future conditions if the development is built. The report includes separate analyses of "Non-Game Day" and "Game Day" traffic (naturally, there is more traffic when there is a Mets game at Citi Field). Since Sterling/Related are proposing to construct the Willets West mall and develop "Phase One" of the Willets Point property, let's see what the future traffic conditions will be if they do so and the roadways remain as they are now. Note that this example represents a "Non-Game Day", when traffic is less than when there is a game.

The top circled row in the chart above shows that the travel speed on the westbound Grand Central Parkway, mid-day during the week, will go down to 0.4 miles per hour with the project. In the weekday PM hour, the speed will be just 1.7 miles per hour. Saturday mid-day it will be 0.5 miles per hour. The proposed project would reduce this portion of the Grand Central Parkway to a stand-still. By comparison, without the project, travel speed would be roughly 40 miles per hour.

The circled line toward the middle of the chart shows the southbound Whitestone Expressway, where the travel speed mid-day during the week will go down to just 12.2 miles per hour with the project, versus 34.3 miles per hour without the project. Saturday mid-day it will be just 7.6 miles per hour, down from 33 miles per hour without the project.

The bottom of the chart shows travel speeds on various ramps. The second-to-last row shows speeds going down to 1.1, 0.1, 0.1 and 0.2 miles per hour, depending on time of day, versus an average of 43 miles per hour without the project.

These are just a few examples of significant impacts that result from constructing the Willets West mall and Phase One of Willets Point. Game days will be even worse. And these conditions already presume that new access ramps to and from the Van Wyck Expressway are constructed – as they must be, for all of Phase One to be built.

Another traffic chart marks each significantly impacted local intersection with an "X". The chart is loaded with "X"s.

To this point, we have discussed future traffic conditions if the Willets West mall and "Phase One" of Willets Point are developed, with the roadways remaining as they are now. A project with such severe traffic impacts might not be approved by decision-makers, and would create horrendous conditions. So, the developers devise and propose hypothetical "mitigation" measures that they hope may alleviate the traffic impacts.

It is the more favorable, post-mitigation traffic statistics that the developers then claim represent what the future conditions will be, with their project constructed – no matter how drastic, hypothetical and non-final those proposed mitigation measures happen to be. It is in the developers' interest to produce a traffic mitigation report that claims to eliminate project-related traffic impacts to the greatest extent, to convince decision-makers that traffic impacts are not a reason to disapprove the project.

Enter Babu

The person introduced by the developers during recent committee meetings of Queens Community Board 7 who is said to be responsible for devising mitigation measures for the Willets West / Willets Point Phase One project, is Babu Veeregowda, PE – referred to as "Babu".

Babu Veeregowda, PE; VHB, Inc.

Babu's work apparently consists of simulating combinations of potential traffic mitigation measures, and assessing whether they would improve traffic flow at particular locations, compared with the impacts of the development project without those mitigations; and if so, by how much. Potential mitigation measures – Babu's tools of the trade – include such things as manipulating traffic signal operation; signalizing intersections; installing louvers on traffic signals; lane re-striping; prohibiting parking; prohibiting turns; widening ramps; installing quick-curb channelization; and other more intensive mitigation measures.

Babu's written assessment for the Willets West / Willets Point project is found in the developers' mitigation report (Chapter 21 of the current Draft Supplemental Environmental Impact Statement). Indeed, not every traffic impact can be mitigated; and in our opinion, the remaining unmitigated impacts are collectively so severe as to make this proposed development inappropriate and unworthy of approval. Even with mitigation measures in place, a number of intersections at major entry points to the proposed development will operate at Level of Service "F" (fail), with delays of between 100 seconds and more than 800 seconds (13 minutes!).

Nevertheless, the developers' self-serving mitigation report claims vast improvements in certain other areas when mitigation measures devised by Babu are in place. For example: Remember the chart, above, showing that the travel speed on the westbound Grand Central Parkway, mid-day during the week, would be just 0.4 miles per hour with the project built? Mitigation supposedly increases that travel speed to 42.4 miles per hour – virtually the same speed as if the huge project is not built at all. In the weekday PM hour, when the speed with the project built would be just 1.7 miles per hour, mitigation measures supposedly bring that speed back up to 37.3 miles per hour. Saturday mid-day, when the speed with the project built would be 0.5 miles per hour, mitigation measures supposedly bring that speed back up to 37.4 miles per hour.

The mitigation report contains many other similar instances in which very severe traffic impacts caused by the proposed development are completely reversed by the recommended hypothetical mitigation. We think it is dangerous to trust this mitigation report.

Unsettled "Effectiveness" and "Feasibility" of the Proposed Mitigation Measures

First, the mitigation report quietly states: "The effectiveness and feasibility of proposed mitigation measures will be further assessed between the draft and final SEIS" (page 21-2).

In other words, no one is committing to the effectiveness and feasibility of the specific mitigation measures that are being touted now to decision-makers, and which so miraculously improve traffic conditions. Rather, a future, final version of the mitigation report may conclude that all or some of the recommended mitigation measures are simply not effective, or even "feasible" – in which case improvements in traffic flow shown in the present mitigation report will not occur, and those impacts may instead be unmitigated.

How can anyone rely upon a report whose author is unable to vouch for even the "feasibility" of the alleged solutions that it presents?

How can the report represent that certain mitigations are essential – without knowing if they are even feasible?

NYCDOT and NYSDOT Have Not Reviewed – And May Reject – Proposed Mitigation Measures

Per the mitigation report, some of the recommended mitigations are "measures that may call for detailed review by both NYCDOT and NYSDOT and which represent preferred improvements that would benefit the overall traffic network. As discussed above, if these mitigation measures are modified or rejected by the review agencies, significant adverse impacts identified above would be unmitigated" (emphasis added; page 21-29).

In other words, achieving the vastly improved traffic flows described in the mitigation report requires measures that NYCDOT and NYSDOT have not yet reviewed or approved, and which they may eventually reject. At the present time, no one can guarantee that any such mitigation measure will actually be implemented.

"Cost Intensive Mitigation Measures"

Certain recommendations within the mitigation report are said to be "cost intensive". One example:

• "34th Avenue at 126th Street … To fully mitigate significant impacts during six of the seven time periods, this intersection would require cost intensive mitigation measures including closure of the existing slip ramp from GCP/Astoria Boulevard to 126th Street and combining it with the existing ramp from eastbound Northern Boulevard to 126th Street".

"Combining" two existing ramps, a "cost intensive" mitigation measure – What will this cost? Who will pay for it? No funding is identified. Is there any more commitment to construct this proposed combined ramp, than there is to construct the proposed new Van Wyck Expressway ramps (i.e., the ramps that neither the City nor the developer is obligated to construct)? Moreover, has this mitigation measure been reviewed and approved by NYCDOT and NYSDOT?

Telling Decision-Makers What They Want To Hear?

As discussed above, there are indications that this traffic mitigation report is a smokescreen, and that mitigation measures it recommends may not be implemented: Its author has not committed to the effectiveness or even the "feasibility" of the mitigation measures it describes; NYCDOT and NYSDOT have neither reviewed nor approved – and may even reject – recommended mitigation measures; and "cost intensive" mitigation measures are proposed, with no funding identified.

But there is a larger context for this mitigation report – namely, it is presented by project proponents who have already demonstrated that they will say or write whatever is necessary at any given time to gain the approval of decision-makers and advance this project; then later abandon those same things, after decision-makers have relied on them. NYCEDC and the City administration are the same project proponents who:

• Promised Queens Community Board 7 and the Willets Point Advisory Committee, in writing multiple times, that they would "participate in developer selection" – then blatantly reneged, by shutting them out of developer selection.

• Obtained approval to develop Willets Point property – then selected developers that intend to build primarily on other nearby parkland property that was never mentioned during the 2008 approval process.

• Testified to the New York City Council that remediating and developing Willets Point in phases was impractical, and that the entire 62 acres needed to be taken over – then issued a Request for Proposals to develop "Phase One".

• Agreed in writing with the New York City Central Labor Council to include a "living wage" provision in the Willets Point Request for Proposals – then issued a Request for Proposals that omitted the required provision.

• Submitted an affidavit to New York State Supreme Court, stating that they would not acquire property via eminent domain until the proposed Van Wyck Expressway ramps had first been approved – then commenced eminent domain proceedings, without the Van Wyck ramps being approved.

Considering the foregoing, the traffic mitigation report may be just the latest example of project proponents saying what they believe decision-makers want to hear – regardless of whether or not it will be honored or implemented, later.

Decision-makers need to ask themselves: Do I trust that the severe traffic impacts of the Willets West mall / Willets Point Phase One development can and will certainly be mitigated, as described in the mitigation report?

If the answer is "no", then the traffic impacts to be caused by the development could very well be the unmitigated disasters shown in the two charts above, and elsewhere throughout the traffic report. Tolerating such conditions in order to gain an unnecessary Willets West mall on parkland is not an acceptable bargain.

Or, as our own traffic expert, Brian Ketcham, puts it: "How can you justify so large a project with horrible traffic conditions reported in the Draft Supplemental Environmental Impact Statement? When faced with breakdown conditions in all directions can you honestly say that this project will not create huge traffic delays along access roads, spilling back onto the surrounding expressway system? Can you not admit that it will have a huge negative effect on this community, imposing greater traffic delays, more traffic injuries and deaths and other costly externalities, borne by the million motorists already passing by Willets Point each day on nearby expressways and arterials?"

Babu Veeregowda, PE describes potential traffic mitigation measure.