Commentary on the Final 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 latest document presented for comment in the process of rebuilding the destroyed World Trade Center is yet another milestone in shameless official disregard for public opinion while brazenly pretending to be following it.

From Draft Scope to Final Scope to Draft GEIS to Final GEIS, plan definitions have squirmed back and forth while determination to push ahead with a plan tailored to pre-existing misconception is rammed ahead full speed no matter what concerns are raised.

Governor Pataki remains determined to prevent anyone from having a chance to undo his mistakes,lately moving up groundbreaking despite the official review process still being underway.The accelerated timetable has drawn protest from many quarters.

The 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.It is admitted that there is no 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.

The "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,official prejudice against redevelopment based on restoration of what was destroyed ensures that the 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.

Numerous public comments urging the abandonment of the Proposed Action in favor of the Restoration Alternative were received. Reasoned arguments were reduced to one-liners in the Response section and flippantly dismissed with regurgitated falsehoods and invocations of unreasonable objectives.

It bears noting that no alternative drew close to the amount of public interest and comment as the Restoration Alternative. One entity each commented on the Memorial Only and Enhanced Green alternatives,eight on the Reduced Impact,and none at all on the others...but the Restoration Alternative was urged by nineteen.In the initial comments,more people urged the Twin Towers be rebuilt than expressed general approval of the Proposed Action.

What are claimed to be preferable attributes of the Proposed Action are NOT preferable to the Restoration Alternative in the eyes of the public regardless of the brazen claim that the Libeskind plan "achieved broad public support and fulfilled many of the goals articulated by the public".

The Libeskind plan finished LAST in the OFFICIAL public poll of the design process,which was won comfortably by "Neither" (of the last two plans considered)...there is no question that the priorities decided upon by the planners led to plans that do NOT have public support,least of all this one.

To far more people than the development corporation will admit, that the new World Trade Center be centered on towers every bit as tall as the old by every measurement and representing an updated reaffirmation of the design principles that produced the original World Trade Center is

More important than the extension of any streets into or through the site.

More important than "active enlivened street life".

More important than turning the distinctive quiet and low population density of the Financial District into yet another of the city's countless "24/7 communities".

More important than encouraging the disturbingly rapid growth of the population of Downtown.

And to many,more important than leaving the "footprints" of the former towers empty.(Before Governor Pataki aggressively intervened to pre-empt public debate,polls showed New Yorkers evenly divided on building on the old footprints).

All these issues must be given lower priority,and their merit subjected to question rather than imposed as a design requirement.Honest evaluation of adverse environmental impacts of encouraging 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 are a must for a responsible environmental impact statement.This one fails!

An environmentally conscious and appropriate redevelopment of the World Trade Center would see that the way forward for Lower Manhattan 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.

An environmentally conscious and appropriate redevelopment of the World Trade Center would call for the concentration of the office space into a smaller number of taller buildings than in the Proposed Action. Such construction would use less materials,less land,require less construction equipment and activity with resultant disturbance and proceed faster.Once constructed the scaled-up buildings would be more efficient in operation and safer for their occupants because they would be structurally stronger.Economies of scale would be possible in new Twin Towers that would not be possible in the much smaller Libeskind-plan buildings.

And such construction would leave more open space than before, rather than less,as is the functional consequence of the Proposed Action, which runs a street through what was one of the largest open spaces in the area.

The GEIS constantly soft-pedals the hazards posed by proceeding on the mistaken paths mandated by the development corporation.

Despite the substantial public pressure demanding a fair comparison the Restoration Alternative remains a "straw man" in the Final GEIS, barely touched from the unfair rendering in the Draft GEIS.The same three slanted paragraphs of the Executive Summary attempt to dismiss the Restoration Alternative as before.The characterization of the Alternative,and the subjective design criticism,misplaced priorities, and conveniently incomplete comparisons it is judged negatively for not meeting,are barely touched in Chapter 23.The shameful use of short-term market conditions created by the murderers as a reason future development should implement their desires remains.

No flexibility is shown as to how the Restoration Alternative could best meet objections,such as combining other uses into the two main towers to increase open space.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,and "meaningful recognition" creatively construed to mean total emptiness.To many, reclamation of that space,even a symbolic portion of it,for the purposes to which and for which the victims gave their lives is the best recognition possible.And only with the placement contrived through this constraint is the shadow effect any worse off the site than that of the Proposed Action.Every effort is made to paint restoring the Twin Towers as more inconvenient than it is.

This document in countless ways fails to fairly address the issues, in the furtherance of its objective to ensure the implementation of a disastrously wrong planning decision rather than permit wiser action. Approval of the Proposed Action would be a disgrace to the city,to the nation,and to the free world.

The bottom line for the Final GEIS remains what it was for the draft:

the GEIS unconditionally fails to justify the Proposed Action.

May 20,2004