Wednesday, September 06, 2006

CBN, Brooklyn Views pile on the DEIS criticism

Graphics and data bulletins emerging from the Council of Brooklyn Neighborhoods (CBN) provide snapshots of criticisms from experts who will submit more substantive analysis to the Empire State Development Corporation later this month. First, CBN offers some graphical representations (right) from the Environmental Simulation Center, which show not only Forest City Ratner's Atlantic Yards plan but also the alternatives.

The latest data bulletin offers some harsh criticisms of the Draft Environmental Impact Statement (DEIS). Some excerpts:

DEIS overall

Many parts of the DEIS read like promotional material for the development, not a balanced analysis of impacts. There is more focus on the presumed benefits of the project than on the costs or problems. The purpose of the environmental review is to disclose potential impacts and identify negative impacts, not promote the project.
The three alternative plans (UNITY, Extell and Pacific) are never analyzed or discussed in any detail. For the most part they are only described; the relative impacts are never quantified. They are simply discounted as not achieving the project goals that promise more housing and jobs, but the quantitative goals set up by the developer are self-serving. The alternatives would all bring new housing and jobs and result in fewer negative impacts, yet because they don’t achieve the numbers arbitrarily advanced by the project developer they are discounted.


Land use and zoning

Since 1974, the Atlantic Terminal Urban Renewal Area (ATURA) plan never outlined development over the rail yards nor did the City ever consider expansion of ATURA boundaries beyond the rail yards. Therefore, statements asserting that the Atlantic Yards project is consistent with ATURA are not supported by facts. It has been the City’s policy over the last 30 years NOT to make the rail yards a development site, NOT to expand ATURA, and NOT to change the zoning even while it undertook a massive rezoning in downtown Brooklyn.
The DEIS states many times that this is an example of “transit-oriented development.” But building next to mass transit by itself doesn’t make this or any other development “transit-oriented,” otherwise any new development in New York City could be “transit-oriented.” The project will result in more traffic and no transit improvements. It will provide 3,800 parking spaces and shuttle arena customers from remote parking.


Housing

Some 70% of the housing units in the project will be market-rate, but the DEIS gives the impression this is an affordable housing project.
The analysis of indirect displacement doesn’t try to estimate potential increases in rent and house prices in the surrounding area due to the project. The DEIS reasons that since the surrounding neighborhoods are already gentrifying, the project won’t be responsible for any future gentrification. This has to be proven, and the DEIS doesn’t prove it.


Community facilities

There is no analysis or review of existing and projected response times for Police and Fire, only short statements from the City agencies.
There is no analysis of the adequacy of existing fire equipment for emergencies in the proposed high-rise buildings, which would be the tallest in Brooklyn.


Urban design/shadows

While the DEIS states that shadows will produce a significant negative impact, it does not elaborate on the effects of that impact, including the cost in terms of long-term energy use (that is, higher fuel costs in winter, loss of opportunities for the use of solar energy, etc.).
The DEIS does not assess the negative health impacts on residents or productivity losses due to the loss of sunlight.


Noise

The DEIS uses outdated criteria for measuring noise levels.
Noise monitors were placed mid-block and therefore did not measure the worst-case scenario.
The DEIS mitigation measures do not address street noise, only interior noise.


Construction impacts

The “solution” of providing double-pane windows and air conditioners to residents and community facilities in the area condemns everyone to their private spaces and makes a mockery of the project’s claims it will provide a quality urban environment. These solutions don’t take into account children playing in schoolyards, on sidewalks and in their back yards. They project a ten-year construction period in which everyone should stay indoors.

Criticism from Brooklyn Views

In Purpose and Need, architect Jonathan Cohn of Brooklyn Views points out that the Atlantic Yards DEIS initially offers a clear Purpose and Need: “The overarching goal of the proposed project is to transform a blighted area into a vibrant mixed-use community.”

Cohn asks:
Does the Purpose and Need include providing an arena, a hotel, and exactly 6,860 units of housing? These sound more like specific features of the current plan. To include them as part of the Purpose and Need confuses the means with the ends, resulting in a document that can not be disputed but is ultimately meaningless: since the project is the same as the objectives, nothing can be changed. Because if it was, it wouldn’t meet the objectives. And, as we’ve previously noted, we see the results of this in the subsequent dismissal of the alternatives.
...On the other hand, an enormous event venue, which causes huge traffic surges, congestion, noise and air pollution, is in fact the antithesis of a vibrant mixed-use community. That is why, for example, it would be necessary to override current zoning that does not provide for arenas in residential areas. Enormous event venues can be, in fact, blighting influences in and of themselves.
...If the arena is, in fact, part of the purpose and need of the project, say so, and show clearly how it furthers public policy. If the scale is required to make the project financing work, show us. The EIS should not be executed with a nod and a wink. Revise and resubmit a truly transparent document.

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