A new and possibly more contentious phase of the Lower Manhattan rebuilding
effort is now beginning, as formal environmental reviews for key elements of
the unprecedented reconstruction projects move into the spotlight.
In October, the Lower Manhattan Development Corporation is scheduled to release
a draft environmental impact statement, covering its proposed plan for a memorial
and for the redevelopment of the World Trade Center site. That document will
trigger a formal period of public comment, as well as public hearings, that are
likely to focus on key details of the redevelopment plan for the 16 acre site
that had been home to the twin towers until they were destroyed in the terrorist
attacks of September 11, 2001.
Meanwhile, the environmental review of a separate but related project -- the
reconstruction and possible underground tunneling for West Street, which runs
along the trade center's western edge -- is also expected to gain increased public
scrutiny this fall.
As decision-makers begin their formal environmental reviews -- theoretically
before making important design decisions about the redevelopment project and
the adjacent roadway rebuilding -- the possibilities for conflict between environmental
and civic groups on the one hand, and commercial interests on the other, seem
WORLD TRADE CENTER MEMORIAL AND REDEVOPMENT PLAN
Public attention will of course continue to be centered on the planned memorial
and redevelopment at the 16 acre World Trade Center site itself. The formal environmental
review of this project is being coordinated by the Lower Manhattan Development
Corporation, a subsidiary of the Empire State Development Corporation, although
the Port Authority of New York and New Jersey, Governor George Pataki, Mayor
Michael Bloomberg and others will play key behind-the-scenes roles.
The "proposed action" that is the subject of the forthcoming draft
environmental impact statement includes a World Trade Center memorial and related
improvements, up to 10 million square feet of office space, up to 1 million square
feet of retail space, up to 1 million square feet of conference center and hotel
facilities, as well as additional open space and cultural facilities.
Earlier this year, the Lower Manhattan Development Corporation outlined its planned
review process, listing the 14 city, state, bi-state and federal permits or approvals
that may be required for whatever project is ultimately built on the trade center
site. And it summarized the topics that the environmental impact statement will
discuss, including among other things expected impacts on open space and recreational
facilities, neighborhood character, traffic, noise, air quality and waste disposal.
environmental study will also identify adverse consequences from the proposed
project, discuss alternatives to the proposed action and describe mitigation
measures that could minimize environmental harm.
In accordance with state and federal environmental laws, this environmental study
will be released in draft form and be the subject of a formal public review period.
After that, the development corporation will respond to comments and possibly
modify elements of the analysis and the project before issuing a final environmental
impact statement, seeking permits and approvals for the project and beginning
The final environmental review is projected to be completed,
in an accelerated process, sometime early next year. Governor George Pataki
has announced plans
for groundbreaking ceremonies to take place in September 2004.
ISSUES OF PUBLIC CONCERN
The development agency received wide-ranging reaction to its plan. One major
concern of environmental and civic advocates is that the environmental study
as currently designed will not examine options that would reduce the amount of
office space to be created at the trade center site. The proposed 10 million
square feet of office space has been a cornerstone of leaseholder Larry A. Silverstein's
plans for rebuilding.
"The program for office space and retail space should be developed in light
of the total needs for office space and retail for Lower Manhattan,” representatives
of the Civic Alliance wrote in its formal response, “not according to leaseholder
obligations to rebuild an office complex that dates back to the 1960s and embodies
assumptions about urban revitalization vintage to that era." The Civic Alliance
recommended that the environmental impact statement “evaluate...options
for significantly less amounts of office and retail, and greater amounts of cultural,
civic and open space" at the 16 acre site.
Another concern, once the rebuilding is under way, is how solid waste from the
redeveloped trade center site (and the rest of Lower Manhattan) will be managed,
and where energy needed for the new development will be generated. Environmental
justice advocates warn that the redevelopment project should not place additional
environmental burdens on other city neighborhoods.
A good plan for Lower Manhattan means a plan that will not require the building
of yet another power plant or solid waste management facility in a poor neighborhood
in order to meet the greater demands, says Gail Suchman, an attorney at New York
Lawyers For the Public Interest, who represents the Organization of Waterfront
Neighborhoods and other community groups.
"We hope and expect that this new project will be a world-class model for
green building and energy efficiency," says Ashok Gupta, energy expert at
the Natural Resources Defense Council (where I work). Gupta and other advocates
note that the development corporation’s plans promise that they will “consider” green
building and sustainability principles in the environmental review. But energy
specialists caution that unless a strong set of such design guidelines are incorporated
into the draft environmental impact statement, the prospects for making this
new development a show-case for energy-efficiency would dim considerably.
Environmental and civic groups are also urging that the environmental review
analyze "truckless goods delivery" for the trade center site and study
incentives to reduce traffic, encourage walking and reduce pollution in and around
the site. Many of these organizations also remain concerned that environmental
review for the trade center site explicitly take into account the separate environmental
reviews being conducted for other closely-linked projects (e.g., the permanent
PATH station , the Fulton Street transit center, the West Street reconstruction)
to insure that these projects do not proceed in isolation and that the cumulative
impacts of the combined projects are fully analyzed.
In response to these and other challenges, the staff of the Lower Manhattan Development
Corporation remains optimistic.
"We were not surprised by the substantive points in the comments we received
and we are going to explore alternatives that consider additional areas for commercial
development outside of the 16 acre site," says LMDC Counsel Irene Cheng.
But the recent report that two insurance companies -- Allianz and AXA -- may
block plans to demolish the damaged Deutsche Bank building, just south of the
Trade Center site, could further complicate any proposal to disperse office and
retail space beyond the 16 acres.
"As this is hardly a routine development project," the Bar Association’s
Task Force the environmental review process should not be viewed as routine."
WEST STREET CONTROVERSY
On a different track, and outside of the public limelight,
the New York State Department of Transportation is advancing a plan to reconstruct
known as route 9A) and to replace it with a covered tunnel that could cost
up to $860 million.
At a recently held but little-publicized "public information" session,
state transportation officials presented their plan for an underground bypass
tunnel to be built -- during a five year construction period -- as a replacement
for West Street. The only other option that would be considered by the transportation
department in its environmental review process is a "no-build" alternative.
Transportation officials suggested that the massive tunnel project would
create a park-like setting above ground, provide more space for pedestrians
But in contrast to the openness that environmental and
civic groups believe the Lower Manhattan Development Corporation has displayed
as that agency
its redevelopment and memorial work, the State Department Of Transportation's
environmental review plans for the West Street project have come under sharp
As things now stand, the state transportation department will
conduct no public scoping process for its environmental review (since it claims
to be preparing
a "supplemental" environmental impact statement to an eight year
old environmental review document). The agency does not plan to study any
alternatives to the tunnel project. Nor does the state believe it must even
hold a public hearing when it releases its supplemental draft environmental
statement next year.
Not surprisingly, public opposition is mounting. Local
elected officials, including Representative Jerrold Nadler, Assemblymember
Deborah Glick, and
Alan Gerson, are expressing skepticism. And in a July 31st letter to State
Transportation Commissioner Joseph Boardman, six transportation and environmental
-- Coalition to Save West Street, NYPIRG Straphangers' Campaign, Tri-State
Transportation Campaign, Enviornmental Defense, NRDC and Tranportation Alternatives
both the process and the substance of the West Street reconstruction project.
Of course, the new State DOT plan for Route 9A is not the first time engineers
have sought to address traffic issues along Manhattan's west side.
l930's master planner Robert Moses sought to advance his "West Side
Improvement" project, including a five-mile expressway from the southern
tip of Manhattan to 72nd Street. The story is recounted by Robert Caro is
his award-winning biography of Robert Moses: "The Powerbroker."
"The West Side Improvement had two purposes," Mr.Caro writes: "to
reclaim Manhattan's waterfront for its people, and to alleviate Manhattan's
traffic congestion. It was to achieve these purposes that Robert Moses spent
large sum of money."
"But despite that expenditure -- all but inconceivable in terms of urban
spending of that era -- the first of the two purposes was achieved only in
part, " Mr.Caro concludes. "(I)nstead of reclaiming the waterfront
for Manhattan's people, the West Side Improvement deprived them of it. And
the second of the
two purposes was not achieved at all."
With that history in mind, environmental
and transportation groups are now gearing up for a fall campaign to secure
a full-scale environmental review of the State
Department of Transportation proposal for reconstructing West Street.
Eric Goldstein is co-director of the urban program at the Natural Resources Defense Council.
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