"Is it not cruel to let our city die by degrees, stripped of all her proud monuments, until there will be nothing left of all her history and beauty to inspire our children? If they are not inspired by the past of our city, where will they find the strength to fight for her future?" Jacqueline Kennedy

Tuesday, May 28, 2019

"We Do Not Want The Cart Put Before The Horse": Carroll Gardens Coalition For Respectful Development Comments On NYC's Gowanus Environmental Impact Statement

Toxins, raw sewage and a flood zone.

Gowanus area residents and groups had till yesterday, May 27th, 2019 to send NY City Department of City Planning (DCP) their comments on the Gowanus Neighborhood Rezoning Draft Scope of Work for an Environmental Impact Statement.(DSOW).

DCP had asked the community for input on the Gowanus Draft Scope of Work at a public meeting on April 15th, and accepted written comments until last night.  A DSOW is a "technical document that lays out proposed methodologies and assumptions and that identifies the project and the types of environmental analyses that may be performed. The DSOW helps the public understand and participate in the CEQR review from the start and a necessary precursor to preparing a Draft Environmental Impact Statement."

We are posting below the comments that Carroll Gardens Coalition for Respectful Development sent to City Planning regarding the Gowanus Rezoning because we agree with CORD and support their assessment of the rezoning.

To: The NYC Department of City Planning
From: CG CORD Carroll Gardens Coalition for Respectful Development

When digesting the framework and plan to rezone the Gowanus and this Environmental Impact Statement, the one phrase that continually comes to mind is, "putting the cart before the horse".

The Gowanus Canal is a Superfund site. Her waters are classified as industrial which legally allow for a certain level of toxins and pathogens to remain in the water.

Under the EPA's Record of Decision , two retention tanks of different sizes are to be constructed in order to reduce the CSO emitted pathogens and the resulting "attached" toxins. ( We note here that we are aware of NYC's continuously and deliberately keeping this plan in flux, but that is, nevertheless, the mandate issued by the Record of Decision.)

If no rezoning of the Gowanus were taking place, then, ideally after the Superfund cleanup, we reach acceptable levels of toxins and pathogens for an industrial waterway.

This is definitely an improvement to the health and safety of all Gowanus, Carroll Gardens, Cobble and Boerum Hill, Red Hook and Park Slope residents and the very aim and purpose of the EPA/Superfund will have been successfully achieved.\

With the proposed Gowanus rezone, this EIS does not insist or even recommend the classification of the Gowanus Canal to be upgraded to the more appropriate CERCLA standards for RESIDENTIAL classification.

It does not even suggest the inadvisability of residential development along the banks of any industrially classified waterway. Nor does it suggest or even hint at the inadvisability of building ANYTHING residential in an area that is classified as a flood zone. WHY NOT?

In addition, this EIS does not effectively model how new developments in the Gowanus neighborhood would naturally increase CSO discharges into the Canal.

It is bewildering that this topic is not more thoroughly addressed within this EIS.

While these glaring omissions by this EIS have us questioning the very purpose of what purports to be an ENVIRONMENTAL IMPACT STATEMENT, it also has us questioning how our other city, state and federal agencies are going to cope with what we have heard as described "the largest rezoning" of an area in New York City ever.

We wonder if the FDNY, the NYPD, OEM, EMT SERVICES, DSNY, DOE, DOT, NYCT, DCP, DEP, PARKS, DEC, MTA and FEMA are taking any steps to prepare for the estimated nineteen thousand (19,000) new residents occupying approximately eight thousand two hundred (8200) new apartments- - which by the way, works out to 2.3 people per apartment - a number representing complete fantasy.

We wonder where all the .3 people will go to school? How will all of the 2's fit on trains and busses? Where will all of the automobiles owned by the conservatively estimated 19,000 residents be? What, if any, hospital emergency facilities will be added? What tentative plans are being made to accommodate this huge increase in population in the event of an emergency/natural disaster?

We seem to recall that the "evacuation route" for Carroll Gardens takes us down to Bond Street. Will all of us be directed there and provided with canoes in the event of an evacuation scenario?

During Hurricane Sandy, this "escape route" was completely flooded by many feet of awful smelling water with our neighbors parked cars freely floating within it.

How is the current evacuation "plan" being adjusted? Is it even being considered?

So, since the apparently acceptable bunch of words that substitute for an Environmental Impact Statement, do not seem to address any of the truly important impacts this rezoning will inflict upon all of us actually living here, we add to our above comments the following:

A panel of all of the above mentioned agencies along with our EPA Region 2 team, be brought together for a minimum of two (2) TOWN HALL conversation/question answer periods as to how these agencies plan to address and resolve the REAL environmental impact of this very poorly thought out rezoning.

These meetings are to be organized, held and hosted by our COMMUNITY BOARD 6 and announced widely throughout the district.

This panel must be assembled and the town hall meetings MUST TAKE PLACE WELL BEFORE THE ULURP Community Board 6 Land Use Committee vote on the Gowanus Rezoning proposal in order to give the community the time to understand what is being presented and how it will affect them.

Right now there are no meetings scheduled or being held by our Community Board to discuss this EIS, neither what it says nor what it doesn't.

It is unreasonable for any community to attend one land use meeting for a proposal of this proportion and be expected to digest and comment intelligently without all of the players involved being there to answer questions.

Our Community Board may not be "required" to do this, but they should do it anyway-- in the spirit of being good neighbors and community guardians.

If meetings of this type are not required by NYC procedure or law-- then set some precedent here. This is an extremely ambitious rezone. It is not the same as many others before it. Let's do some things differently and better than before not just the same.

We do not want the cart put before the horse.

We want answers to our questions.

We do not need to hear how all of the appropriate boxes have been checked off.

We want a responsible rezoning.

Thank you. We welcome your comments and letters at cgcord@gmail.com

CG CORD Co-founders:
Lucy DeCarlo
Rita Miller
Triada Samaras

We join CORD's call for an inter-agency panel discussion on the rezoning of the Gowanus Canal to be held by Community Board 6, so that the community can assess for itself if the City has the means, the resources and the will to TRULY plan for the impact of about 8,2oo new housing units and an estimated 20,000 new residents. After all, WE will have to live with the consequences of the rezoning.

If you agree, send an email to Community Board 6 at  Info@BrooklynCB6.org and to Jonathan Keller of City Planning at JKeller@planning.nyc.gov .
Please copy CORD cgcord@gmail.com, so the group has a record of the ask,

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