Commentary on the Draft Scope for the 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

The latest document presented for comment in the process of rebuilding the destroyed World Trade Center presents an interesting turn of events.

I note that the Draft Scope 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 development corporation is not likely to have to deal with the lasting consequences of its actions the way the property owners are.

It is gratifying that at long last a "Pre-September 11 Scenario" and "Restoration Alternative" are being 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, there is a clear and substantial risk that the GEIS will seek to portray these scenarios unfairly,in a bid to justify the unreasonable programmatic requirements that have led to designs such as the Proposed Action.

Rather,it is time that the adverse environmental impacts of these requirements be evaluated,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 be acknowledged.

From the beginning of the design process there has been insistence that no portion of either of the "footprints" of the Twin Towers be reclaimed for the purposes to which and for which the murderered thousands gave their lives.This is a contentious issue on which many have strong feelings on both sides...but total surrender to one side of the issue has been an unreasonable constraint from the beginning.

Another constraint has been the narrow-minded obsession with tearing the site completely apart by the total restoration of Greenwich Street, dividing the site into sections with widely different uses and making a mockery of the very idea of an integrated site design.Slashing an arterial thoroughfare through one of the largest open spaces in Lower Manhattan,seeking to create a busy vehicular intersection where there was a pedestrian plaza,is among the most environmentally retrograde proposals possible for the project area.Yet this was demanded of all designers seeking to propose site plans...though everyone who bothered to comment when the Project for Public Spaces opened a message board for commentary on reopening Greenwich Street opposed the idea.

And there was the recurring demand for "phased construction", rather than the speculative boldness solely responsible for the Twin Towers being renowned and beloved icons of size far beyond the typical and prudent...with its result that the commercial space had to be carved into enough separate buildings that none of them could be of particularly imposing size,certainly not two.And with a large number of buildings required on a site fragmented by streets and with a substantial portion forbidden to development,crowding was assured.

Together these three requirements form a prescription for disaster, and the design by Studio Daniel Libeskind has amply fulfilled this request.

The signature of this design,the largest block left after the floodgates were opened to traffic passing through the Tobin Plaza site day and night,is of course the gaping pit...widely referred to as the "deathpit".This chilling effort to enshrine the handiwork of ten terrorist murderers,exposing the crumbling slurry wall laid bare by their horrific destruction,is a nightmare for numerous reasons.

The symbolism of such deference to the killers' intent,the open inspiration to future terror attacks offered by the assurance of their leaving a lasting legacy,can be left aside in this commentary as it concerns the environmental drawbacks.But we can not forget that Daniel Libeskind stated explicitly that the attacks would be "taken as guidance".

This pit is exposed to the weather cycles,which the slurry wall was never meant to be.Snowdrifts will pile up with no means to plow them out,rain will accumulate,frost will form on exposed surfaces. Maintenance will be both necessary and difficult,year by year, in the shadowy depths of this depression.

Should the exposed wall,built with the intent of the weight of the World Trade Center complex being there to hold it and push it west against the encroaching river channel even before the World Financial Center was built with the potential to push it east,not be maintained assiduously enough,there is the risk of collapse.Slight seepage has already been noticed in the few years the wall has been exposed,and the partial reburial of the wall will not be enough to eliminate this risk.

Heavier-than-air pollutants will settle from the surrounding streets into the confines of the pit,the exhausts of passing motorists silently sinking into the memorial section.The unique size and depth of this sector may make it a singular magnet for noxious fumes.

The depression below ground level has been defended as offering respite from the noise of the surrounding streets...but it can not reclaim the refuge that was offered by not having Fulton and Greenwich Streets run through the site in the first place.Simply leaving the site whole is both safer and more sensible.

The obstacle the pit presents to those seeking to cross the site from east to west and back has been highlighted.Where in the old WTC going between West and Church Streets required simply walking through the side spaces between buildings,under the Proposed Action it requires avoidance of the pit and a crossing of busy Greenwich Street,envisioned as full of traffic meant to encourage acceleration of the already rapid population growth of Downtown...another environmentally retrograde vision of the unpopular incumbent Mayor.

The GEIS must not soft-pedal any of these hazards.

The issue has been raised of how to handle the traffic of visitors to the memorial.It needs to be recognized that this traffic will hit peaks early on that will not be revisited...those most interested in seeing the memorial will see it as early as they can,and return only rarely thereafter,while future generations will feel less and less connection to the event.There is a long history of memorials becoming backwaters with time,including within Manhattan.The recent fall-off in interest after the death of Diana,Princess of Wales is instructive...where in its first year the family memorial to her sold all its tickets rapidly,today her memorial charity is being urged to close its doors.The GEIS plans to examine conditions anticipated in the years 2009 and would be a mistake to assume that,if the memorial is open by 2009,by 2015 the traffic would not have declined permanently from the early level of interest.

For these and other reasons the "Restoration Alternative" must be no empty "straw man" in the GEIS.It must be fleshed out,regardless of official bias toward the proposed Action,sufficiently to demonstrate its numerous advantages.

While it must necessarily be seen as a restoration of the 16 acres to a large open space dominated by two gargantuan towers surrounded by far lower structures,it is disingenuous to treat these new towers as if they would be built with the technology of the 1960s with no form of improvement.The Restoration Alternative against which the Proposed Action must be measured must be one that would now be built,given a mandate to rebuild in the spirit of what was destroyed.

The past 35 years of technology would unquestionably be employed in constructing the new Twin Towers,improving their strength and safety to levels never before seen,levels only made possible by the buildings' breathtaking size offering sufficient income to make them economical.

Environmental mitigation of adverse consequences of the former Towers would be certain,and environmental hazards of the Proposed Action would be avoided.The new Towers would be engineering marvels of their own time as the originals were of theirs...Mr. Libeskind's slant-topped wall of Church Street high-rises and his flimsy and transparent "Freedom Tower" are more examples of abstract art, and the entirely ornamental cagework proposed by David Childs would eliminate the last vestiges of functionality for any space above the 70th floor.

Of course a Restoration Alternative would not mean no memorial...the attacks of 1993 led to the creation of a memorial,and the attacks of 2001 would be recognized as well.And a proportionate memorial would be easily accomodated by the traffic capacity of a restored World Trade Center,which was a tourist attraction on a scale both large and stable over the long term,thanks to the distinctive characteristics of the buildings.

Other voices will urge modification in other directions. But it is important to understand the motives behind various interest groups.Just as the small active cadre of those who seek to speak for the families of those who were slaughtered represent not a cross-section of such survivors,but a self-selecting sample of those both most emotionally distressed by their loss and most determined that their personal grief guide public policy,the "civic interest" groups like New York New Visions,Imagine New York,and the Civic Alliance are not representative of public opinion,but of established lobbies demanding change in the city.The desire to treat the terror attacks as a handy chance to implement wish-lists must be rejected.

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.

Where ten murderers in hijacked airplanes set out to humble New York's financial district never to rise again,timid beancounters and utopian theoreticians must not be allowed to finish the job.

The GEIS must be a fair evaluation of the consequences of the choices before us,not a biased attempt to sell an eyesore imposed in the teeth of public disinterest and dislike.

July 30,2003