Environmental Challenge

With the state senate hearing on the building of the Willets Point ramps off of the Van Wyck approaching next month Brian Ketcham, the veteran traffic guru for the Willets Point United, has issued a challenge to area environmental groups to stand up against the unsustainable over development being promoted by the Bloomberg administration-not only at Willets Point, but in scores of additional auto dependent projects in and around the Iron Triangle site.

One major environmental group, the Natural Resources Defense Council, has already written to NYSDOT and the FHWA calling on the agencies to insure that an independent review is conducted under the terms of the National Environmental Policy Act (NEPA). Other groups, including the League of Conservation Voters and the Environmental Defense Fund have come out publicly in support of the Willets Point development claiming, against all evidence, that the 9 million sq, ft. project would be a hallmark of sustainability.

In fact, Andrew Darrell, VP, Regional Director, Environmental Defense Fund and Marcia Bystryn, Executive Director, New York League of Conservation Voters both signed on to a letter of support for the Willets Point project that was circulated by "non-lobbyist" Claire Shulman and her bogus grass roots LDC. In part, the letter claimed, "This project offers perhaps the greatest return: the rehabilitation of a 60-acre brownfield which has been abused for decades into a sustainable 21st century LEED community."

Ketcham, however, has done an exhaustive examination of the environmental impact statement for the project-as well as of the companion traffic report for the ramps that was submitted by EDC to the state. His conclusions dramatize the extent to which Willets Point and these other Queens area projects-far from being models of sustainability will devastate local roads, the Van Wyck, and the fragile mass transit infrastructure-causing immense environmental damage in the process.

The Ketcham letter, then, challenges Bystryn and Darrell-along with the leaders of the Sierra Club and Transportation Alternatives-to take a stand once they have a chance to review the documentation that he provides. If they don't-and if they refuse to join with the NRDC in calling for an independent traffic study of the ramps-then the question will be raised as to whether these groups have enough independence themselves to continue to speak-without fear or favor-on behalf of the environment that they purport to to defend.

What follows is the full Ketcham letter to Marcia Bystryn:

Ms. Marcia Bystryn

Executive Director
League of Conservation Voters, NY
30 Broad Street - 30th Floor
New York, NY 10004

RE: Willets Point, 23 million square feet of new development, 144,000 new auto and truck trips and more than 160,000 new bus and subway trips all concentrated in north-central Queens

Dear Ms. Bystryn:

I am writing to alert you to concerns that I have-after an extensive traffic and transit analysis-about the massive development in and around downtown Flushing. Projects include the Flushing Commons in downtown Flushing and the Willets Point Development Plan, plus nearly 90 other developments some, like Sky View Parc at the intersection of Roosevelt Avenue and College Point Boulevard. Total new development on the books right now exceeds 23 million square feet of various uses. I am attaching my recent report summarizing these land uses and illustrating the overall impact of this new development.

Together, the projects will daily generate another 144,000 car and truck trips to an area that has been characterized in both the Willets Point FGEIS and the Flushing Commons FEIS as gridlocked for much of the day. These projects will also generate another 92,000 daily subway trips and more than 70,000 daily bus trips, more than doubling the demand for transit service in downtown Flushing and at nearby bus and subway stops (only the Flushing 7 line services the area plus the LIRR Port Washington Branch, both at capacity during peak hours).

What should be of particular concern for folks who have made environmental and transit issues the focal point of their professional careers, is the complete contradiction between the professed goals of the Bloomberg sustainability PlaNYC 2030, and the facts on the ground generated by massive and unsustainable auto dependent development. Additional concerns should devolve from the unmistakable effort on the part of the consultants who have prepared the environmental reports to either mask or downgrade the real environmental dangers of these developments-both individually and cumulatively.

So, north-central Queens faces a serious problem. It cannot accommodate the transit trips estimated using data from the Willets Point FGEIS and the Flushing Commons FEIS. The environmental analyses have over-estimated transit use to under report auto impacts and related environmental damages assuming no one would catch this sleight of hand. Should all 23 million square feet of development be completed, it is likely much more car and truck traffic will be produced gridlocking an area up to three miles from the Willets Point site for much of the day on both weekdays and weekends.

No cumulative impact analysis has been undertaken for this development, a practical undertaking one would think even developers might be interested in. Plus there is clear evidence our city government-despite its much ballyhooed support for sustainable development- has been working hand in hand with developers to get these projects approved. Sadly, the current administration has, on the area’s largest project, the one with the greatest environmental impact, convinced some of you to endorse the plan as an example of sustainable development.

The massive project in question, the one that contributes about half the auto, truck and transit trips, is the Willets Point Development Plan. This project requires additional access to the Van Wyck Expressway south of Northern Boulevard to even work. And, herein is another problem: New York City has to justify these ramps to the Federal Highway Administration. They cannot do it, at least not without lying.

I have prepared simulation models of the Van Wyck ramps. They cannot work. The Van Wyck already has too much traffic to accommodate Willets Point traffic. The result is that nearly 2,000 cars and trucks will have to be accommodated on local streets during peak commuter hours causing huge traffic and environmental damages. Willets Point, at more than 11 million square feet, is an environmental catastrophe.

I am writing to inquire about your position on all this new development that poses huge environmental and socioeconomic impacts. I invite you to review the data I have collected and analyzed to determine whether your organization wants to take a position concerning the request by the Natural Resources Defense Council to the NYSDOT and the FHWA for an independent review of the proposed Van Wyck ramps under purview of the National Environmental Policy Act.

In addition, since what I have analyzed is the cumulative damage being wrought by the overdevelopment in question, would your organization be willing to come out and call for a moratorium on all new Queens development until an independent evaluation of the environmental impacts can be commissioned?

We all know that it is enticing to stand with elected officials when they are announcing plans that appear to be uniquely environmentally friendly. But as environmentalists, isn’t it more compelling to be able to speak truth to power when those plans turn out to be nothing but self-serving spin?

There is a state senate hearing on August 12th that will focus on the Willets Point ramps. It would be nice if your organization could join with NRDC and dozens of local civic groups in calling on state and federal regulators to not rely on the traffic reports submitted on behalf of EDC and, instead, ask for a truly independent analysis of what will undoubtedly be a massive impact on the environment.

Sincerely,

Brian T. Ketcham, P.E.

Attachment: TRANSIT TRIPS GENERATED BY NEW DEVELOPMENT IN AND AROUND DOWNTOWN FLUSHING, 2017, Brian Ketcham Engineering, PC, July 20, 2010