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Jenna Orkin of 9/11 Environmental Action doesn't think much of what's happening at Ground Zero. "This is a rush job," she said. "The reasons have to do with image and politics."

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Patricia Noonan of the Partnership for New York City reached the opposite conclusion, praising the plan for its "balanced approach."

On the stage, officials from the Lower Manhattan Development Corporation sat and listened politely to the two of them, and dozens more -- each required to say their piece in three minutes or less.

The occasion was the public hearing for a 2000-page technical document issued by the Lower Manhattan Development Corporation: The Draft Generic Environmental Impact Statement for the World Trade Center site. Just as in the public hearings in January 2003, anyone who wanted to could sign up to speak. Since then, those who spoke - and those who couldn't make it - have been refining written comments that the corporation will accept until March 15.

Responses were not limited specifically to issues of the environment; the environmental impact statement process is the major remaining chance for the public to respond to the plan for Ground Zero. The cooperation of public and private interests working on the site, the historic significance of the site, and the Lower Manhattan Development Corporation itself were all subject to critique.

Business As Usual -- Sort Of

Environmental impact statements are a required part of any proposed building in the city, and comment periods for these statements present a major opportunity for members of the public to voice concerns or offer suggestions. Writing the statement, holding public hearings, and accepting comments are business as usual for developers.

The Draft Generic Environmental Impact Statement for Ground Zero is different mainly because of its scope. The document is referred to as a generic statement because it discusses buildings that have not yet been designed, and covers a large area that will be built over many years. This will release the Lower Manhattan Development Corporation from having to have a similar process for each building that goes up. Also, since the Lower Manhattan Development Corporation is exempt from the city's land use review process, the environmental impact statement is the only officially required avenue for public response on the Ground Zero project as a whole.

Despite its size, the environmental impact statement process for Ground Zero is proceeding on a tight timeline. The draft statement was made public on January 22, the hearings were held about a month later, and public comments are being accepted for about another month, until March 15.

All of these comments will be incorporated into the final environmental impact statement, according to the Lower Manhattan Development Corporation. Below are excerpts of comments that have been submitted so far:

Keep The Process Moving -- Patricia Noonan
Slow Down -- Caroline Martin
Tell The Whole Story -- Ernest Hutton
Skimming Over Environmental Concerns -- Jenna Orkin
Define the Footprints -- Anthony Gardner
This Is A Collaboration, So Work Together -- Jordan Gruzen
Don't Miss The Opportunity To Build Green
There Is An Alternative - Rebuild The Towers -- Alexander Butziger
Decide What Is Historic In Order To Preserve The Past, Not To Clear The Way For The Future -- Robert Kornfield, Jr.
Don't Bury West Street -- John Dellaportas
Environmental Impact Extends Beyond Ground Zero
--Catherine McVay Hughes
Miscalculating Open Space -- Diane Dreyfus

Keep The Process Going To Keep Businesses Downtown
The business community commends the Lower Manhattan Development Corporation and its partners in the EIS. They have set forth a balanced approach to expedite construction while minimizing the impacts on businesses, residents and workers in Lower Manhattan. A host of major Lower Manhattan businesses will soon be faced with renewing leases; they will be making location decisions within the decade. In order to remain in Lower Manhattan, they must be confident about its future.

If they decide not to stay in Lower Manhattan , there is no guarantee they will stay in the city at all. Once they begin evaluating alternative locations, it is possible that they will choose to locate elsewhere. Some place where rents are lower and labor costs less. Neither Lower Manhattan nor the city at large can afford to let these firms relocate

The business community believes that it is important to expedite the rebuilding process of the commercial sites in order to maintain the commercial character of Lower Manhattan and keep this important business district, which is the third largest CBD in the country.

The same sense of urgency and focus that drove the clean up of the World Trade Center site -- which took 9 months rather than one year and cost $750 million, not the projected $2.5 billion -- must continue to drive the rebuilding process.
-- Patricia Noonan, Partnership for New York City

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Slow Down
In the Catskills an Environmental Impact Statement is being prepared, and due to public pressure the time for comment is being extended an additional two months. I formally request that the public comment period for this draft EIS be extended from the current minimum of 45 days by an additional 2 months e.g. until May 15.

If you have made comments on the Draft EIS, you are entitled to a copy of the Final EIS under NEPA rules - no mention of it only being available electronically, or having to pay for the privilege. I would like to go on record as stating that I want a free hard copy on the day the Final EIS is made available to the public, and I want to be affirmatively informed when that date is, and where I can pick up my copy.
-- Caroline Martin, Family Association of Tribeca East

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Tell The Whole Story
The World Trade Center Draft Generic Environmental Impact Statement before us may fulfill the legal and administrative requirements as set forth in federal, state and city regulations, but its scope is limited to the areas required by environmental law. The Draft Generic Environmental Impact Statement can't and doesn't look at the full planning context of the proposed site plan, nor of that plan's relationship to the many other planned improvements within Lower Manhattan.
-- Ernest Hutton, New York New Visions

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Skimming Over Environmental Concerns This is a rush job. Although the rebuilding of Ground Zero will be one of the largest construction projects in the world, the usual three year EIS process has been condensed to one for reasons that have nothing to do with the environment or public health. Once again, the reasons have to do with image and politics. In this respect as in others, the rebuilding process shows signs of repeating the reckless behavior of the cleanup operation...

The Draft Environment Impact Statement consists in large part of sanguine projections into the future and assurances that where there are problems they'll be handled appropriately "when practical." Who determines what's practical? Who defines it and according to what criteria? During the cleanup it was often found to be impractical to wet down dust during the winter for fear the water would freeze. Is that going to happen again? Will other actions protective of human health be considered impractical because they require too much time or money? Will it be considered impractical to enforce the rules against truck and bus idling? And how will those rules be enforced?
-- Jenna Orkin, Steering committee, 9/11 Environmental Action

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Define the Footprints The Draft Environmental Impact Statement does not define what it means by the term "footprints." Although this has been a matter of discussion for more than two years, LMDC continues to refuse to acknowledge that the "footprints" are the outlines of the Twin Towers perfectly delineated by the remains of the exterior support box-beam columns presently visible at the lowest exposed level of the site-not some mythical void suspended in mid-air.
-- Anthony Gardner, Coalition of 9/11 Families

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This Is A Collaboration, So Work Together
Each part of the plan is being developed by a separate group of design professionals, each working for a different client, whether it be Lower Manhattan Development Corporation, the Port Authority, Metropolitan Transportation Authority, New York State Department Of Transportation, or Silverstein. In examining these plans we have observed a weakness in the continuity between adjacent elements. There also may be a difference of opinion between groups about how these land use and circulation issues should be resolved. This is not surprising since these ideas are now just emerging in physical form and can now be measured and evaluated when seen in the light of the overall master plan. This master plan, broadly conceived by Daniel Libeskind, has had many evolutionary changes since its introduction but still remains the dominant concept. New York New Visions has been supportive of this overriding vision. We encourage Lower Manhattan Development Corporation and the other controlling authorities to work more closely together so that we do not end up with powerfully expressive individual solutions to the parts without the connectivity that makes for an integrated urban fabric.
-- Jordan Gruzen, New York New Visions

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Don't Miss The Opportunity To Build Green
We appreciate the effort that has been made to incorporate guidelines for sustainability. While recognizing that this is a work in progress, it is important to note that what has been proposed is focused primarily on the individual development projects and makes no call for a comprehensive master plan for sustainability. What is needed, as part of the design guidelines and incorporated into the standards established for the Generic Environmental Impact Statement, is a study of the entire site and its environs that sets forth sustainability measures that will be common to all projects -- and allocates responsibility for those measures. While the guidelines presented are at the leading edge of the norm for large-scale developments, they generally do not seize the unprecedented opportunity afforded here to set new benchmarks that will advance state-of-the-art of sustainability practices and technologies. The fact that tenants, the occupants of 80-85 percent of the above-grade floor space, are not mandated to comply with the guidelines suggests business as usual.
-- Ethel Sheffer, New York New Visions, Metro Chapter of American Planning Association

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There Is An Alternative - Rebuild The Towers If you choose to replace the Twin Towers with the Libeskind World Trade Center, the other office towers besides Freedom Tower should be super tall (taller than 1,000 feet) too. After all, we did not lose just one "skyline element" (as you like to call it) on September 11, 2001, but two. How can the two lost Towers be replaced by just one building? - Given the mediocrity of all aspects of the Libeskind plan and its buildings, I am glad that you recognize that "The Proposed Action is not, however, the only option considered by or open to LMDC." The only truly worthwhile way of rebuilding is the Restoration Alternative. The new WTC should conform more to that what was taken from us on September 11, 2001, than to Mr. Libeskind's plan. It is obvious that you do not evaluate the Restoration Alternative fairly, but try to denigrate it as best you can, to whitewash the Proposed Action.
-- Alexander Butziger, World Trade Center Restoration Movement

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Decide What Is Historic In Order To Preserve The Past, Not To Clear The Way For The Future
The risk of having developers perform their own historic assessment is obviously that their historic consultants may act as advocates of the proposed plans rather than impartial experts. This Determination does not attempt to identify the historic resources that exist on the site thoroughly and accurately, or to recognize their integrity and significance. Rather, it appears that the purpose of the Determination is to insure that the redevelopment can proceed without finding any adverse effect, and without the obligation to mitigate any adverse effects.

The World Trade Center is one of the nation's most significant historic sites and it deserves a thorough and legitimate Determination. The failure to produce this would be a grave injustice, and an insult to those who lost their lives in the disaster and those who risked their safety in the aftermath. The historic resources of this site must be evaluated based on their merits, not on tactical considerations for the redevelopment.
-- Robert Kornfield, Jr, Historic Districts Council

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Don't Bury West Street
I believe the Lower Manhattan Development Corporation's three and a half year projected tunnel construction is wildly optimistic. The problem with highway tunnels is that no one knows what they will find underground until they start digging. That is why the Big Dig in Boston, which was originally projected to take only five years, has now been going on for 15 years and counting. Expect similar delays for the West Street tunnel, as anyone who has lived in NYC for any amount of time knows that these projects always run extra long.

Second, whether construction takes three years or 10, the plan to reduce West Street to four lanes during the entire construction period will be economic disaster for Battery Park City. During these years of construction, access to and from Battery Park City will be degraded to a similar extent as it was in the months after 9/11. The gridlock will not just hit West Street. The vehicle traffic will invariable try to find alternative north-south routes, which will spell lots of traffic jams for Greenwich, Broadway and Church as well.
-- John Dellaportas, Save West Street

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Environmental Impact Extends Beyond Ground Zero
Your Generic Draft Environmental Impact Statement needs to adequately address the accumulative impact beyond the immediate WTC site since more was severely damaged on September 11, 2001 and more than that remains to be damaged two and half years later. These large projects listed below must be included in the cumulative construction period analysis since they "represent a change from conditions existing prior to September 11, 2001":

- 130 Liberty Street (Deutsche Bank) "de-construction" and site "re-construct" of contaminated and exposed building which covers two city blocks
- 30 West Broadway (Borough of Manhattan Community College's Fiterman Hall) "de-construction" and site "re-construct" of contaminated and exposed building which covers one city block
- South Ferry Subway Station
- 7 World Trade Center (construction in progress)
- 90 West Street renovation and conversion to residential building (construction in progress)
- Infrastructure Repair which consists of digging up many streets to access cables, pipes, and wires

All these projects combined with your construction phasing has and will have an enormous impact on air quality from the exposed contaminated Deutsche Bank & Fiterman buildings to the truck traffic to construction machinery. These projects will include traffic beyond the estimated 176,000 truckloads calculated from the various tables listed in Appendix J.
-- Catherine McVay Hughes, downtown resident

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Miscalculating Open Space
Let's look at what passes for Open Space...Examining the original World Trade Center Plan you will notice that the side along 9A West Street did not count as open space until after 9/11. But the legend shows us that, now the road shoulder on the other side of 9A is included in the LMDC open space calculations. [The figures that Dreyfus is referring to are DGEIS figures 1.2 and 6.5] I bring this up only to indicate the acres of "open space" can include such unsavory parcels. Essentially, this quality of Open Space is as hospitable as the traffic triangle in Harold Square. Yes, there is a tree and a statue to admire and you could have a cup of coffee or meet a friend there. But would you want to?
-- Diane Dreyfus, M.S Architecture, Urban & Regional Planning


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