Commentary on the Draft Generic Environmental Impact Statement for the World Trade Center Site

By Louis Epstein
R.D. 2,Carmel,New York 10512
Founder & Director,World Trade Center Restoration Movement

This new document presented for comment in the process of rebuilding the destroyed World Trade Center is another illustration of the profound problems in the way the process has been conducted.

From Draft Scope to Final Scope to Draft GEIS,definitions have been altered back and forth as alterations are made to plans to appease various constituencies and confuse everyone.How are we to react to what is really planned while there is still time to stop it?

That is always a concern...Governor Pataki remains determined to prevent anyone from having a chance to undo his mistakes.The acceleration of this review process has drawn protest from many quarters.

The Draft GEIS does not bear the imprimatur of the Port Authority, though it concerns the construction of Port Authority-owned buildings on Port Authority-owned land...the Port Authority did not bother sending the designated representative to the Draft GEIS hearings. And it has recently been admitted that there is not yet any agreement with the development corporation to allow its plans to proceed. This is a good thing,as the development corporation is not likely to have to deal with the lasting consequences of its actions the way the property owners are.However,political pressure to pave the way for the horribly misconceived Proposed Action to proceed appears inevitable.

At long last a "Pre-September 11 Scenario" and "Restoration Alternative" are explicitly recognized as benchmarks for the GEIS,after a prolonged process in which such strategies for redevelopment have been implacably opposed despite broad public support.However,given the history of official prejudice against redevelopment based on restoration of what was destroyed, it is no surprise that the Draft GEIS seeks to portray these scenarios unfairly,in a bid to justify the unreasonable programmatic requirements that have led to designs such as the Proposed Action.

In rebuilding where renowned icons of America have been destroyed, the presumption must be in favor of rebuilding in the same spirit and image,applying the latest technologies toward restoring what was there stronger than before,and the burden of proof that any new design is better must rest on the new design's proponents;
in this regard,the DGEIS unconditionally fails to justify the Proposed Action.

The adverse environmental impacts of the official program requirements are evaded,and the environmental advantages of discarding the Proposed Action in favor of redevelopment based on updated reaffirmation of the design principles that produced the original World Trade Center are likewise obscured behind subjective sophistries.

An environmental impact statement needs to take into account responsible priorities toward superior environmental health,with particular suspicion toward anything that encourages population or traffic growth either at the location in question or as a result of the decisions made regarding what is to be built there.
This DGEIS turns its back on these issues,and virtually glorifies the effects of this nature that would be caused by the Proposed Action.

The narrow-minded obsession with running streets completely through the site is a dramatic step backward,even apart from the disturbing insensitivity of using the occasion of the murder of thousands to repudiate the urban design principles that gave us the beloved Twin Towers.

To "integrate the site into the surrounding neighborhood" means to destroy the distinct nature of the site,and the official fixation with turning Lower Manhattan into a 24-hour community constitutes destroying the distinctive character of that part of the city in order to make it like countless others.

And contrary to the dubious representations of the City Planning Department,the way forward for Lower Manhattan surely lies in further de-vehicularization,not the creation of more space for future traffic jams and auto accidents.This is an area uniquely suited to being dominated by pedestrian traffic arriving by mass transit.

Chapter 10 begins by praising the neighborhood character created by the old World Trade Center,and then sets about implementing the above policies in order to ensure that that character is never restored, and the action of the terrorists in erasing it perpetuated.

Chapter after chapter tries to justify the Proposed Action,glossing over areas of concern.The last-place finish of the Libeskind plan in the official public poll prior to its selection is nonetheless vindicated.

While the exposure of the slurry wall has been reduced,it remains an objective of the design to perpetuate the terrorist-created exposure of this crumbling structure never intended to be exposed to the elements and designed to always have the weight of the Twin Towers holding it in place.

Pits remain as part of the design on the sites of the former Twin Towers, deep receptacles for the settling of heavier-than-air pollutants from the traffic invited through the site by the inappropriately restored streets and sources of chemically contaminated mist.Cold winters and deep snowfalls will present difficult challenges to these exposed below-grade structures.

The GEIS can not be allowed to soft-pedal the hazards posed by leaving these open wounds as part of the plan.(What of suicide leaps into the sunken pools?).

Only in Chapter 23 is it at last admitted that "The Proposed Action is not,however,the only option considered by or open to LMDC." Yet,in the presence of other options,it does not then,as would be logical for many reasons,abandon the Proposed Action in favor of the greatly superior Restoration Alternative.

Rather it attempts to dismiss the Restoration Alternative in three ill-supported paragraphs of the Executive Summary.The first paragraph describes the alternative.The second shamefully invokes the fears that the terrorists sought to inflict as justification for submitting to their murderous will that we be denied the possibility of again working as high in the skies as before.The third for no reason assumes that environmental mitigating measures would not be a part of future independent development of the southern site.

Yet if one looks at Chapter 23 for the detailed treatment of the Restoration Alternative,subheading after subheading admits that the Restoration Alternative would be no worse than the Proposed Action,even while avoiding the ways the Proposed Action would be worse than the Restoration Alternative.

In trying to come up with reasons to prefer the Proposed Action, the Draft GEIS is driven to refuge in subjective design criticism. It is complained that the Restoration Alternative would need truck checkpoints to be on the site;but only in the Proposed Action can trucks...or truck bombs...rumble unchecked through the site, and on either side of every building.

Above-ground retail space,found all over the city,is extolled and the underground retail space a distinguishing feature of the World Trade Center is denigrated.Yet the site has lost its retail operator because the plans called for too much of the retail space to be above ground when shoppers prefer it underground,the more so in bad weather...this was what made the World Trade Center mall among the most profitable in the world.

The Restoration Alternative's skyline impact is denigrated compared to the Freedom Tower,with its roof hundreds of feet lower and dozens fewer office floors.The space not accounted for in the envisioned towers is accused of making the project denser.Yet it would be wholly in the spirit of this Alternative to consolidate these functions into the new Towers to make them even taller,and the density less than the Proposed Action.Open spaces would be increased,where analysis shows that the Proposed Action reduces open space significantly.

The placement of new Twin Towers is said to be constrained by "the public's expressed desire for some meaningful recognition of" the footprints of the old Towers.Before Governor Pataki aggressively intervened to pre-empt public debate,polls showed New Yorkers evenly divided on building on the old footprints,and meaningful recognition does NOT have to be total emptiness.

Only with the placement contrived through this constraint is the shadow effect any worse off the site than that of the Proposed Action. Even placement of the new Twin Towers blocking Greenwich Street's course,since it would not be reopened in this scenario although the DGEIS seems inconsistent on this,would affect the open spaces and pull shadows away from surrounding areas as well as enhancing the towers' security.But every effort is made to paint restoring the Twin Towers as more inconvenient than it is.

The safety technologies seen as advantages of the proposed buildings would of course be scaled up for new Twin Towers with more effectiveness than for smaller buildings.Engineering realities ensure that taller towers are necessarily built stronger and safer than smaller ones.

The new Twin Towers would be engineering marvels embodying the technologies of the new millennium to a degree only made possible by their breathtaking scale,which would also be the only way for them to generate revenue on a sufficient scale to pay for their construction.Neither the original Twin Towers nor the Empire State Building filled up in their first years,but had they been built more cautiously they could never have been as profitable as they were in the long run.

The "Restoration Alternative" must be no empty "straw man" in the final GEIS.It must be fleshed out,regardless of official bias toward the Proposed Action,sufficiently to demonstrate its numerous advantages. The current effort reads like a rationalization for proceeding with the vastly inferior official design.There can be no assuming that,if the decision is made to proceed with the Restoration Alternative,no environmental mitigation or safety enhancement proposed in other contexts will be adapted.

Until September 11th 2001 the status quo had no established lobby because it did not need to be a conspiracy of bureaucracy seems determined to leave the status quo of before September 11th 2001 defenseless.This environmental review process must not be perverted into another stage of that conspiracy,but must honestly weigh the drawbacks of failing to set ourselves back onto the course we were on before thousands of valiant lives were unconscionably snuffed out,and iconic structures revered the world over collapsed into ruin.

Blinkered dedication to proceeding further down a wrong turn can not allow the final GEIS to be a biased attempt to sell an eyesore imposed the teeth of public disinterest and dislike,rather than the required fair evaluation of the consequences of the choices before us.


March 9,2004