Pratt Center

October 10, 2012

Proposed SEIS Scope of Work for Willets Point Development CEQR Number 07DME014Q


Testimony to NYC Planning Commission

Joan Byron, Director of Policy, Pratt Center for Community Development.


We join with community representatives in calling for a full new Environmental Impact Study that will allow a comprehensive approach to this and other transformative projects now proposed within Flushing Meadows Corona Park.

These projects represent both a threat and an opportunity for the communities of northern Queens, and for the City as a whole. Neither the threat nor the opportunity can be understood without a new, comprehensive Environmental Impact Statement that takes into account the City’s current understanding of economic and environmental reality – including the costs and challenges of remediating sites within the established Willets Point Special District, and the degree to which these conditions make it unrealistic to develop the project as proposed in the original EIS, and defers the construction of the promised housing units until at least 2028.

The development of that housing, along with the schools, retail space, etc. that would create “a lively, mixed use district” – was presented in 2008 as a public benefit that justified the taking of private property, the disposition of public land, and enormous public investment in property acquisition, remediation, and infrastructure.

The City agencies who administer our laws, programs and regulations, the legislators who represent us, and above all, the people who live and work in the impacted communities, and the taxpayers of New York City, all deserve a full and up-to-date set of facts in which to ground our thinking about the development not only of the proposed “Willets West” addition to the district, but about the full set of projects being proposed within and around the borough’s flagship park.

Those projects include the proposed expansion of the National Tennis Center, and of the unannounced but widely-anticipated proposal to construct a stadium for Major League Soccer, both of which would expand the footprint of paved and privatized land within Flushing Meadows Corona Park, and diminish the amount of green open space available to the public for active recreation.

A comprehensive Environmental Impact Study would give full consideration to ALL of the alternatives for development of the parkland now used as parking for CitiField, not only the proposed 1.4 million square foot shopping mall. Understanding that this project would require a renegotiation of the lease for that parkland, we call upon the City to examine whether a mall is actually the best use of this irreplaceable resource – from a social, environmental, and even economic standpoint.

We do not accept the premise that a mall falls within the definition of “edification” or other activities permitted on this site without new alienation legislation. Even if that were the case, a decision about the future of a major site, in the heart of an area undergoing profound change, and facing serious shortages of open space, housing, schools, and community facilities, should not be made solely on the basis of administrative expediency. If this site is to be put into play, ALL potential uses, including housing, should be considered.

Housing might, in fact, represent the best use of public funds, and the best return on private investment. The EIS should disclose whether a mall this size – it would be the largest in New York City – can be viable without significant subsidy, including subsidy in the form of substantially below-market rent. Less than a mile away another large mall, Sky View opened in 2010 and remains only partially leased up. Lease terms for the proposed project should be fully disclosed to the public as they are being negotiated, not after the fact. Since a developer has already been designated, there is no justification for secrecy.

Impact area and retail displacement
We also question the use of a ½-mile, or even a ¾-mile buffer as an appropriate delineation of the study area. The urban fabric in this part of Queens is fragmented by major highways, and the residential and commercial areas- particularly the retail corridors on Roosevelt Avenue, Northern Boulevard, Astoria Boulevard, and downtown Flushing, all begin within the ½ mile buffer, but extend well beyond it. Small, locally-owned businesses in these areas are highly vulnerable to unfair competition from national, formula-based chains operating in subsidized space, and benefiting from the pull of big-box anchors.

Traffic, transit, and Environmental Justice
A mall of this size generates thousands of car trips per day – tens of thousands on peak shopping weekends. And peak traffic to this mall would inevitably coincide with peak days for other destinations, including game days at CitiField and at the proposed soccer stadium, if it is built.

Though the Number 7 train is accessible, the 7 will continue to operate at unacceptable levels of crowding, even if new technologies allow for more frequent service. Mall shopping trips differ drastically from trips to traditional retail streets, and skew heavily toward driving. The proposed project contravenes the laudable goals of PlaNYC 2030, and the good work of the Office of Long Term Planning and Sustainability, to reduce car trips and the concomitant greenhouse gas emissions.

While the proposed SEIS scope would follow standard procedures for estimating added traffic volumes and congestion, it will inevitably find (as did the 2008 EIS) that not all impacts can be fully mitigated, and that residents of the densely populated communities of Corona, Elmhurst, and Flushing will simply have to live with the added air pollution, noise, and degradation of their health and quality of life. The EIS should fully identify these health impacts, so that decision-makers can fully take into account their economic and human costs, and understand the magnitude of the environmental justice challenge that the proposed project represents. We look forward to presenting these issues in greater detail in our written comments, and to continuing dialog between the developer, EDC, and the community.


Thank you for the opportunity to testify.


Note: This testimony was prepared by the Pratt Center for Community Development. It does not necessarily reflect the official position of Pratt Institute.