Gotham Gazette

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Environmental Impact of Rebuilding Lower Manhattan

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 increasingly likely.


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.

The 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 actual construction.

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.


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."


On a different track, and outside of the public limelight, the New York State Department of Transportation is advancing a plan to reconstruct West Street (also 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 and accommodate increased visitors.

But in contrast to the openness that environmental and civic groups believe the Lower Manhattan Development Corporation has displayed as that agency has advanced its redevelopment and memorial work, the State Department Of Transportation's environmental review plans for the West Street project have come under sharp criticism.

As things now stand, the state transportation department will conduct no public scoping process for its environmental review (since it claims only to be preparing a "supplemental" environmental impact statement to an eight year old environmental review document). The agency does not plan to study any low-scale alternatives to the tunnel project. Nor does the state believe it must even hold a public hearing when it releases its supplemental draft environmental impact statement next year.

Not surprisingly, public opposition is mounting. Local elected officials, including Representative Jerrold Nadler, Assemblymember Deborah Glick, and City Councilmember Alan Gerson, are expressing skepticism. And in a July 31st letter to State Transportation Commissioner Joseph Boardman, six transportation and environmental organizations -- Coalition to Save West Street, NYPIRG Straphangers' Campaign, Tri-State Transportation Campaign, Enviornmental Defense, NRDC and Tranportation Alternatives -- criticized 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.

In the 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 an incredibly 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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