We commented earlier today about the fact that we believe that EDC is operating outside of the NYS not for profit law-but it is also true that, however it operates, it does so we a complete lack of integrity. After all, what agency-governmental or quasi-governmental-could submit two absolutely contradictory traffic reports on Willets Point?
And in that case, the discrepancies are fully transparent-for the goal of the original EIS was to mitigate the project's impact on local streets, and therefore the traffic report claimed that 46% of all the cars and trucks would be diverted to the proposed Van Wyck ramps. But in order to get state and federal approval for the ramps, the goal was to minimize the traffic impacts on the arterial-so the subsequent report submitted for that purpose told those overseeing agencies that only 14% of the Willets Point traffic would be diverted onto the highway.
But EDC's mendacity is the gift that keeps on giving. When we come to the Flushing Commons project, the litany of misrepresentations continues with a certain savoir faire. In the first instance, the project needs to account for the Willets Point traffic overflow-and therefore, as would be expected, it utilizes the Willets Point EIS study that maximized the diversion of cars onto the Van Wyck. If it had relied on the second ramp report an extra 1,000 car trips for peak PM hours would have had to be accounted for; a no no when even with this sleight of hand the project's consultants predict severe gridlock for downtown Flushing.
As our consultant Brian Ketcham told the planning commission: ""The Flushing Commons EIS estimates project impacts at 30 intersections in and around Downtown Flushing. It assumes two-thirds of the Willets Point traffic impacts for No Build conditions by simply proportioning the trip assignments from the Final Generic Environmental Impact Statement (FGEIS). However, because the FGEIS assumes approximately half the Willets Point traffic would use the Van Wyck ramps, no correction is made for the change reported in the AMR, that just 16% of Willets Point traffic would use the ramps, leaving the rest, about 1,900 car and truck trips in the weekday PM peak hour, to find other routes to gain access to or egress from the Willets Point site. This is a 60% increase in local and nearby expressway traffic that was not accounted for in the AMR or in the EIS for Flushing Commons. Flushing Commons therefore only accounted for approximately a third of Willets Point traffic ultimately assigned to Downtown Flushing. The result of this oversight would add 200 more auto trips to Northern Blvd. and 100 more trips to Roosevelt Avenue in the PM peak hour further adding to the reported gridlocked conditions described in the DEIS."
But that's not the end of this lack of integrity. When examining the Flushing Commons EIS we find there is a built in contradiction: We reviewed the DEIS with regard to the types of retail space used in the traffic analysis and the socioeconomic impact analysis. Page 14-40 of Chapter 4 (Traffic and Parking) along with the rest of this Chapter assumes 36,225 sq. ft of "Destination Retail" Page 3-35 of Chapter 3 (Socioeconomic Impacts) along with the rest of this Chapter assumes 120,750 sq. ft. of "Destination Retail" By using two different assumptions the DEIS underestimates the already unacceptable traffic impact and then deliberately underestimates the effects on our local businesses. With such a bold-faced self-contradiction, how can we rely on any of their assumptions?
At the same time, by employing dishonest methods EDC also gets to minimize the key parking impacts; Destination retail will eat up 1,000 or so spaces-or 62% of the available spots. Local retail has a less intensive utilization and it's no accident that the bait and switch is used here. Lest we forget, it's also important to point out that the change of zoning (this is a spot zoning development) to C4-4 (an R7 equivalent) means that the developer gets to provide about 900 less spaces than what would be required under the current zoning! The 1.9 million sq. ft. under existing zoning needs over 2500 parking spaces-a more realistic provision given the demands of both the project and the Flushing small businesses.
And let's also not forget that the entire traffic report for the development assumes a new one way traffic pattern for downtown-a change that DOT has already invalidated; making the current traffic projections in the DEIS null and void in our view. What this all underscores is the fact that Flushing Commons is way too dense, and will generate a great deal more traffic than even the gridlock predicting consultants for the developer envision.
But in order to sell this tainted product, the last thing that EDC wants is honest data. What can be gleaned from this dishonesty is that Flushing Commons, far from being sustainable development, is a dagger in the heart of Flushing-and EDC should be ashamed of putting this development forward for approval.