In a blistering letter sent yesterday to the Empire State Development Corporation and numerous elected officials, Carolyn Konheim and Brian Ketcham of Community Consulting Services warned that the Atlantic Yards Final Environmental Impact Statement (FEIS) is deeply flawed regarding transportation impacts and should be rejected.
In fact, wrote the pair, who are transportation consultants to the Council of Brooklyn Neighborhoods, “numerous egregious errors and omissions” in the Draft Environmental Impact Statement remain unchanged and certain deficiencies “became more pronounced in the FEIS.”
Mitigation “a hoax”
For example, they pointed out that innovative parking/transit incentives, intended to reduce auto trips to the Nets games by 20%., do not apply to the expected 184 other events, which are left to manage on their own without any administrative framework, but are not analyzed on the unsubstantiated premise that they would likely attract fewer auto trips. The abdication of responsibility for non-Nets events is a prescription for traffic chaos on many days of the year.
The ESDC essentially punted:
As a conservative measure, it is assumed in the DEIS and FEIS that the demand management strategies (DMS) and remote parking required for arena basketball games would not be also used for other arena events. With the imposition of DMS and remote parking mitigation, the basketball games would still typically generate the highest expected level of vehicular travel demand for arena events, and thus, would continue to represent the reasonable worst-case scenario.
The comprehensive traffic management plan included for the Nets basketball games is made possible because of the project sponsors’ relationship with the basketball team and the nature of basketball games as an ongoing activity with a high percentage of repeat attendees. Other arena events would generally be operated by a variety of promoters who cannot be identified at this time.
Wrong peak period?
Konheim and Ketcham write:
The planned mitigation for Nets game traffic appears to be for the wrong time period. A comment on the DEIS revealed that East Coast NBA games start at 7:30 p.m., not 8:00 p.m. as assumed in the DEIS, resulting in the pre-game period being 6:30-7:30 p.m., not the7 :00-8:00 p.m. assumed in the DEIS. To defend making no change, the preparers of the FEIS wiggle through an argument that Madison Square Garden data suggests as much as 30% of game-goers arrive in the half hour after the game begins. Besides not making such anomalous data open to inspection, the preparers of the DEIS pretend not to understand that the real issue is that the baseline traffic volumes are for the wrong time period. Based on Brooklyn Bridge hourly counts, there is a significant drop in traffic volume after 7:00 p.m., suggesting that the analysis did not capture higher background traffic between 6:30 and 7:00 p.m. The matter could have been put to rest with the publication of hourly traffic volumes, required in the CEQR process for this very purpose. But that obvious response might have shown all that the pre-game analyses had to be redone, and slowed the project approval. Many errors of the DEIS/FEIS appear to be result of short-cuts and time pressures.
Data belatedly arrives
Actually, Konheim and Ketcham did get some data. In their message to officials and the press, Konheim wrote:
Just as I was about to e-mail this to you at 6:30 p.m. on December 6th, ESDC delivered 600 pages of crucial traffic data requested by Brian Ketcham during the DEIS process last summer. Who's kidding who?
They criticize the free MetroCard idea, writing:
The claimed effectiveness of the initial transit incentive mitigation in the DEIS, a 50% discount on a two-way MetroCard, was so debunked by the public that the FEIS now offers a “free” two-way subway pass, reinforcing the conclusion that the preparers of the FEIS are either hopelessly naive or are banking to be so. The free MetroCard would be targeted to on-line purchasers of high end tickets, which are well above $100/seat. This “$4 value” package is postured as a 100% in the cost (whereas, this is only for the MetroCard) and, in reality, $4 is less than a 4% saving on the entire $100+ package.
Then to justify that this estimated cost/benefit will get drivers and their passengers to give up their cars, the FEIS cites the MTA half-fare holiday bonus experiment in 2005. Selecting this as a justification is even more ludicrous than the example in the DEIS, since the holiday half-fare program was found to result in no increase of ridership whatsoever on commuter trains and a big loss in fares of subway riders who would have traveled anyway. The irrelevance the example to the Arena is underscored by the lack of any correlation of change in auto use corresponding to the change of fares. Thus, the key travel demand mitigation in the FEIS relies on a hoax.
Other charges include:
--no basis for the FEIS claim of mitigation of the two Atlantic Avenue intersections close to the exit and entry ramps of the Brooklyn Queens Expressway
--a method that analyzes each intersection in isolation seriously conceals the magnitude of the areawide impact of the project,
--failure to look closely or realistically at the traffic behavior immediately around the site entrance.
--failure to account for all Downtown Brooklyn development projects by 2016.
--failure to account for growth in subway trips
--lack of capacity by NYC Transit to put new trains in service in peak hours.