Date: Fri, 6 May 2005 14:50:24 -0400 (EDT)
From: Louis Epstein 
To: wtcenvironmental@renewnyc.com
Subject: Comments on Environmental Assessment


The "Environmental Assessment and Finding of No Significant Impact"
document recently distributed represents,as close observers of the
planning process for the rebuilding of the World Trade Center have
learned to expect,yet another milestone of narrow-minded incompetence.

You may consider this commentary to be my "Finding of No Significant
Improvement" by the tinkerings the Assessment attempts to excuse.

Chapter after chapter begins by alluding to the "Findings of the FGEIS"
which readers of that document know are as a rule highly flawed.The
FGEIS failed spectacularly to defend the General Project Plan's
overwhelming inferiority to the unfairly caricatured Restoration
Alternative,the ideal rendition of which alternative should always
have been the entire mission of the redevelopment planning process.

Building on a foundation with no more structural strength than a
soap bubble,then,the Environmental Assessment seeks to concern itself
with details of how to do the wrong thing--when the only responsible
course of action is to abandon the project in its entirety.

We repeatedly encounter the phrase "maintain the downward spiral"
in reference to modification of the proposed office towers.This is
both literally and metaphorically a bad idea;the design intent that
all other office towers be shorter than the "Freedom Tower" and
angled to amplify the effect of the indefensibly-left-empty Tower
"footprints" is a bad idea,and maintaining the downward course of
the planning process until hideous symbols of surrender are in fact
constructed is a bad idea.

The "Freedom Tower" is proposed to be functionally much smaller and
shorter (despite the pretentious superstructures over its roof) than
the lost Twin Towers,and if its construction can not be avoided then
it is of the highest symbolic importance that the remaining office
space be contained in a building or buildings that do not make this
mistake.Given the recent frogmarch back to the drawing board on this
project one expects future comment opportunities on future plan changes.
The only "downward spiral" one should "maintain" is that of the Libeskind
site plan down the drain so it is replaced by one that is prepared to far
more sensible guidelines mandating that the new WTC strongly evoke the
old on an absolutely undiminished scale.

In its details the Environmental Assessment continues to demonstrate
the preference for wrong choices within alternatives provided;failure
to move the museum to the former hotel site at the southwest corner
(thus,as noted,more closely restoring the pre-2001 land usage) is a
clear case in point.

Virtually every alteration in land use from the pre-2001 scenario is a
mistake.The outrageous division of the site into four blocks creates
the unacceptable result of no new office towers being even on the same
block as the old,the southwestern block being symbolically surrendered
to the will of the terrorists and inspiring future attacks by the implied
promise of future such results.Further,it even paves the way for such
attacks through the potential to drive truck bombs down the new streets
close by each one of the proposed structures.

The inclusion of the Southern Site and westward movement of Route 9A
are both invasions of the surrounding neighborhood designed to mask
the flaws of a plan properly discarded in its entirety.That the new
modifications amplify these departures represents further error and
not "refinement".The Environmental Assessment repeats the false claims
of the FGEIS that fundamentally destroying the distinct character of
the Financial District is "beneficial".

All in all,this document is an additional--if superfluous--demonstration
of the catastrophic consequences of allowing the organization long
aptly nicknamed the "Leave Manhattan Destroyed Committee" to act as
both proponent of plans and regulator of those plans.The crying need
for an outside authority to force the products of this incompetent
process to be abandoned immediately remains unmet.

-=-=-
The World Trade Center towers MUST rise again,
at least as tall as before...or terror has triumphed.