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Willets Point Rezoning Should Consider Green Manufacturing Alternatives

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Yesterday, MAS testified at the City Planning Commission hearing regarding the Willets Point rezoning plan. First and foremost, MAS stressed that the plan, which includes an urban renewal action that will allow for the use of eminent domain, must reflect the results of an inclusive planning and monitoring process. In regards to the rezoning – from manufacturing into a mixed-used residential and commercial district – MAS suggested the City conduct a thorough examination of the plan’s implication for long-term, industrial and manufacturing job growth, including a justified strategy deployment of public resources tied to agreed upon community benefits. Finally, MAS raised concerns over the purported high standards of sustainable neighborhood planning Willets Point aims to achieve. The full testimony is after the jump.

Willets Point Development Plan – Draft Environmental Impact Statement – August 13, 2008

The Municipal Art Society of New York is a private, non-profit membership organization whose mission is to promote a more livable city. Since 1893, the Society has worked to advocate excellence in urban design and planning, contemporary architecture, historic preservation and public art. The Municipal Art Society, having submitted scoping comments on May 14, 2007 offers the following testimony to the Department of City Planning on the Willets Point Development Plan.

We may all agree that Willets Point is in need of reinvestment given the substandard infrastructure conditions that currently exist on this sixty-one acre site; however, how and to what end this area should be redeveloped are key issues. The Municipal Art Society questions the New York City Economic Development Corporation’s development plans on two points: first, with respect to the proposed change in land-use, has the dramatic transformation from manufacturing to a mixed-use residential/commercial development concept received the careful, thorough examination it deserves? And second, with respect to the EDC’s proposed ownership model, given the current economic climate doesn’t structuring the plan around a single developer risk long delays at the cost of promised public benefits?

Equally important is the issue of declaring the site an Urban Renewal area, allowing the use of eminent domain. In this circumstance, MAS believes the redevelopment plan must meet such additional criteria for citizen participation and allocation of city resources as articulated in the urban renewal principles presented in this testimony.

The Willets Point Development plan currently in the ULURP process requires the following three actions:

  1. Designation of the site as an Urban Renewal area, defining acquisition and disposition of properties.
  2. Demapping of all public streets on the 61 acre site.
  3. Zoning changes from M3-1 and R3-2 to a C4-4 district

Land-use: Is Willets Point ripe for residential development? – The Willets Point Development plan is being hailed as both an opportunity to create a “dynamic sustainable community” (DGEIS 3-2) and a “transit-oriented development that would leverage the District’s superior transit and highway infrastructure” (DGEIS 6). Although the concept of mixed-use districts characterized by pedestrian friendly, activated streetscapes is a laudable goal that the MAS generally supports, we question whether the Willets Point site is appropriately suited for this type of development. Furthermore, the Willets Point site has been slated as a LEED Neighborhood Development (LEED-ND) Pilot Project and while the sustainability criteria under LEED-ND focus on transit infrastructure and green building as well as innovative technological solutions for energy efficiency, these goals often eclipse the imperative to also achieve social and economic sustainability. The City has not seriously considered alternate development scenarios for land use and, as the following discussion will illustrate, it is not clear that Willets Point is at all suitable for residential living.

The site abuts an undeveloped MTA site, which according to the DGEIS will remain undeveloped even with the proposed redevelopment (DGEIS 3-28) and is most probably slated by MTA as an expansion site for the Corona Yards. As a result, as currently proposed, residential development, which is to comprise approximately 62% of the proposed allowable square footage to be developed on the site, would either be built along side major highways, an unsightly undeveloped industrial site, or railyards. Thus, in addition to the potential public health hazards due to the site’s location and contamination, its lack of connectivity to surrounding neighborhoods will isolate potential residents of the development.

Additionally, the commercial and convention center aspects to the development are unlikely to fulfill the intention of transit-oriented development and sustainable development as potential visitors to the commercial areas are more likely to drive there than take public transit. While most of the site may technically be within a 10 minute walk to the subway lines, in reality the site is located such that it facilitates automobile access. The DEIS acknowledges that the proposed plan will generate significant vehicular traffic increases. Unlike the “existing lower-density uses currently within the Willets Point Development District…, the Willets Point Development Plan is expected to be a significant traffic generator on both the highways surrounding the District—including the Grand Central Parkway, the Van Wyck Expressway, and the Whitestone Expressway—and the local street network” (DGEIS 17-2). Given the emissions and noise pollution to which residents would be exposed, due to increased vehicular traffic; the site’s condition and the plan’s impacts will negate the goals of creating a residential, pedestrian friendly streetscape and sustainable neighborhood. The bleak assessment regarding traffic and parking begs the question: what makes this a sustainable and transit-oriented neighborhood development plan?

The aforementioned major highways create a boundary around the site, and would effectively hem in this new neighborhood and interrupt pedestrian access to the waterfront. Northern Boulevard, running along the Western side of the site counts multiple lanes of moving traffic on elevated roads with lanes of traffic below. The White Stone / Van Wyck Express Ways, which converge with Northern Boulevard at the Northern tip of the site, also consist of multiple lanes of elevated thru-way traffic, not including on and off ramps (see aerial photograph below).

Highway underpasses present formidable psychological barriers to successful pedestrian pathways and highway noise notably reduces the quality life of nearby residents with particularly detrimental effects on children. The DEIS has already acknowledged that “noise may interfere with human activities, such as sleep, speech communication, and tasks requiring concentration or coordination. It may also cause annoyance, hearing damage, and other physiological problems” (DEIS 20-2). In the case of Willets Point, current measures of noise levels are fairly high to begin with and with the proposed project according the DEIS would have to be “attenuated“ (DEIS 20-13). Moreover “[t]he noise levels and the impacts predicted exclude noise from aircraft operations at LaGuardia Airport, which is adjacent to the District” (DEIS 23-14). As a result, the livability analysis is flawed and does not adequately address whether existing noise-level conditions should preclude outright residential and particularly school uses on the site. Furthermore the analysis only takes into consideration the incremental change in noise pollution due to the plan and does not assess whether the existing conditions are appropriate for residential living and schooling. The question is: how will the current site conditions that cannot be altered impact adults and children mentally and physically?

Land Use: Transit-oriented Industrial Development and Sustainability: – The city has been marketing the Willets Point Development plan as a “sustainable” neighborhood development; but, what do we mean by “sustainability”? While technically the plan might certify under LEED-ND, the sustainability criteria associated with this program do not fully address the socio-economic costs associated with the wholesale removal of viable businesses and potential industry clusters; nor does it adequately respond to long-term economic sustainability plans for the city as a whole.

Since the City has only a sustainability framework and not a comprehensive long-term plan, it is hard to weigh the impact of any given individual rezoning action and the consequent redevelopment of particular areas, such as Willets Point. PlaNYC does not offer a long-term vision for economic development and the development of new industries, yet the City continues to propose the removal of manufacturing zones from its land-use map. The City’s plans for Willets Point, among others, raises crucial questions regarding the long-term costs to the City of removing these sites that have potential to host new industries, especially green industries. Since environmental testing has been limited thus far, the full extent of environmental contamination is not known. Some parcels may be more contaminated than others, thereby raising the price of remediation. Rather than supporting or catalyzing redevelopment through public sector investment in infrastructure, the proposed plan facilitates the erasure of an industrial land-base at a time when New York City is rapidly losing areas for manufacturing and industrial firms to locate and expand. Other cities, such as Los Angeles and Chicago are grappling with precisely this issue and initiatives closer to home in the Bronx and Brooklyn should be models of how we plan for a sustainable future that aligns sustainability concerns with real opportunities for economic and industrial growth. This means, however, having a comprehensive land-use plan that understands and incorporates the changing needs of new industries and related firms.

Given its adjacency to other industrial sites, its relative proximity to the College Point industrial park, and its accessibility to major transportation routes as well as the airport, the site may be more appropriate for strategic investment in industrial uses. Access to the Van Wyck is invaluable to manufacturers, especially those with a regional customer base. Prospective industrial developers may have been wary of assembling properties in the area due to the lack of infrastructural investment by the City. The City should, therefore, seriously and thoroughly examine the Municipal Services alternative the EDC has proposed in the EIS for its potential to catalyze industrial reinvestment in the area. Furthermore, the site holds the potential for increasing freight transport via barges. The Maritime study released by EDC in 2007 recognizes barge traffic as crucial to long-term sustainability: “one standard dry barge, which carries garbage, sand, and gravel, can carry the equivalent of 60 trucks.” The DEIS states that barging activity at College Point is poised to increase in the future as the “converted North Shore MTS, in the College Point Section of Queens, to the east of the proposed Plan becomes operational in 2011.” How does this increase affect other potential recreational uses in the area? Does Willets Point represent an opportunity to increase water-born and intermodal freight transportation?

Ownership: The One-Developer Model has not proven effective – The Willets Point Development and Urban Renewal plans have been ill conceived.

  • The City should invest in infrastructure and site preparation
  • The City should incorporate a multiple-developer model with clear public oversight

In reserving the City’s action to rezone the area, acquire and assemble the land — currently under private ownership — and subsequently transfer the responsibility and financial burden for brownfield remediation, major site preparation, and infrastructure work to the potential developer, major community benefits, such as significant affordable housing, for example, may be cost-prohibitive and unrealizable.

The Willets Point development plan, which relies on a single developer for site preparation as well as build-out, is a redevelopment model that has not proven to be successful, as demonstrated by the Atlantic Yards and Hudson Yards projects. By eschewing the public sector’s responsibility to prepare the site and provide the public infrastructure necessary for redevelopment, the City is running the risk that the development at Willets Point, as at Atlantic Yards, will stall indefinitely. At the same time, if the City acquires control over the entire site – if necessary through the use of eminent domain – local property owners will have relinquished their stake in the area. This creates the possibility that the site will remain vacant and/or underutilized for years to come.

Battery Park City and Queens West, on the other hand, illustrate that a phased development process where multiple developers are granted development rights and where the project is overseen by a specially designated public authority may be a more effective model. Battery Park City has also demonstrated that such a model provides additional long-term revenue benefits to the City of New York by capturing funds that can be dedicated to affordable housing.

Will the development result in significant affordable housing? – As the proposal is currently structured, the City is taking on responsibility only for the acquisition of land from private property owners and for infrastructure improvements outside of the district, while any future developer will be responsible for remediation and site preparation. Since the City is seeking to designate Willets Point as an Urban Renewal area in order to be able to acquire private properties on the site through eminent domain, affordable housing must make up a significant portion of new development on the site should the land-use change be approved. Incentive FAR bonuses are not adequate, however, as they do not guarantee construction of affordable housing on the site. The cost of environmental remediation is unpredictable since Phase I and II testing “was conducted from public-rights-of-way, along street and sidewalk areas” only, and ”permission was not obtained for access to the privately owned sites” (DGEIS, 12-5). If costs for remediation exceed what is predicted for the site, affordable housing will likely be the first casualty of a modified plan. Should the rezoning be approved before a final RFP for a single developer is selected, a defined amount of affordable housing, responding to the needs of the surrounding neighborhoods, should be guaranteed for the site; this should be included in the zoning text as mandatory inclusionary housing tailored to the specific needs of the surrounding Queens neighborhoods. The City should position itself as the broker of potential construction subsidies for the development, in return for the guarantee of their construction. The public should be advised as to whether market analysis data exists that supports the plan and the feasibility of creating a significant proportion of affordable housing.

Urban Renewal Underwriting the redevelopment of Willets Point is an urban renewal plan; as such, the plan should establish a nexus between the proposed redevelopment actions and the public benefits to be derived from the plan. MAS believes that the Urban Renewal Plan should meet the following principles:

Principle: constructive outreach to and participation of all major stakeholders must serve as the foundation of the proposed plan – The Willets Point plan seems to have been the outgrowth of a planning process primarily focused on the downtown Flushing area. The city appears to have failed to involve on-site business owners and property owners, whose livelihoods will be most directly affected by the proposed plans, in a deliberative process. These stakeholders would include not only the owners of the affected parcels but the operators/leasees of businesses as well. If eminent domain is used, the relocation process of current businesses would be best served by a detailed disposition of the businesses on site and their needs for space. Melrose Commons in the Bronx – also a LEED-ND pilot project – may serve as a model here; in this more inclusive process, property owners were approached on a lot by lot basis to determine who wanted to sell and leave and who wanted to stay with the urban renewal plan being built around them.

Principle: the plan represents a strategic use of city resources – The city has already set aside close to 389 million dollars to support the redevelopment of Willets Point; and as part of this plan the city will be using public monies to either buy out the owners or to pay fair market value via eminent domain. The question is whether the resources invested in the acquisition of properties and proposed infrastructure improvements outside of the district represent the best use of public monies when site preparation and site infrastructure improvement cost are to be borne by the developer of the site. The recent experience at Atlantic Yards serves as a cautionary note to the strategy of developer constructed infrastructure, as their decision making is tied more to capital market fluctuations, compared to the public sector.

Principle: the plan supports long-term planning for sustainability, including social and economic sustainability. – A widely accepted definition of sustainability identifies the Triple Bottom Line as a measuring tool to assess sustainability, which means developments should “perform to not just a single financial bottom line, but the simultaneous pursuit of economic prosperity, environmental quality and social equity – Profit, Planet & People.” PlaNYC 2030 effectively sets guidelines to move our city in the direction of sustainable and “greener” development by focusing on our environment, our green spaces as well as housing, infrastructure and transportation needs; yet, the city lacks a comprehensive plan of how it intends to grow industries and create employment opportunities that give New Yorker’s the chance to gain skills and build assets as well as long-term security.

The Willets Point plan fails to address long-term economic sustainability. At the same time, the city’s industrial areas, such as the Brooklyn Navy Yard and even College Point just across from Willets Point, have very low vacancy rates, indicating a pressing need for adequate space for industrial firms; therefore, the city should carefully examine a development scenario that invests in and promotes industrial growth. (See above)

Principle: the plan benefits existing affected community stakeholders – As the city seeks to catalyze development in areas previously subjected to disinvestment by the city and the private sector, the needs of and costs to the local stakeholders must be carefully weighed against the projected public benefits.

In the case of Willets Point, the needs of the local property and business owners and workers as well as stakeholders in the two neighborhoods adjacent to the site must be carefully considered as the city seeks to declare an Urban Renewal area. The proposed benefits for the existing communities must be guaranteed by binding agreements and delivered according to an agreed upon, reasonable and predictable timeline. In particular, current business owners, land owners and employees must be fairly treated not only to compensate for current losses but to ensure their future economic situation and growth. Employees should be placed in comparable employment in order to secure their families’ survival and future. Seriously examining green industries as potential growth engines for NYC’ employment base should be a priority when making land-use decisions, and support for such industries should be considered a strategic investment in the City’s work force building crucial human capital.

Principle: the urban design as well as design of open spaces and parks promotes a public, open feeling and ensures public access. – New Yorker’s deserve quality urban design and architecture as well as public open spaces akin to parks or public plazas that are not susceptible to privatization.

As part of the proposed actions in the Willets Point redevelopment plan, the NYC EDC is asking the Planning Commission to demap public streets and acquire private properties to be developed by a single developer; thus, it is imperative that safeguards are included to ensure that the development maintains an open feel, is truly accessible to the public and welcoming to residents from surrounding neighborhoods. As our analysis illustrates, MAS has serious doubts that this is possible given the current site conditions, the proposed demapping of all of the streets and redevelopment under a one-developer ownership model.

Principle: the plan includes a governance structure to ensure stakeholder participation in the monitoring of the development and design review process. – Given the lengthy timeline for the Willets Point redevelopment and, consequently, the likelihood that any plan will change over time, a governance structure that gives relevant stakeholders oversight over the planning as well as monitoring process must be established – such as a local development corporation with broad representation.