Here is the letter we just delivered to New York City Planning to meet tomorrow's deadline for **comments:
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 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.
Please see two photos of the the Gowanus Canal waters taken right in front of the
Lightstone Development by Katia Kelly (PMFA Blog) that depict the enormous
raw sewage problem we the community has at the Gowanus Canal right NOW.
Thank you. We welcome your comments and letters at cgcord@gmail.com
Sincerely,
CG CORD Co-founders:
Lucy DeCarlo
Rita Miller
Triada Samaras
**To make a comment of your own please go here:
then scroll down to here:
Public Scoping Meeting on Gowanus Neighborhood Rezoning and Related Actions
and click here:
