Stop the Special Flushing Waterfront District!

We, the undersigned, join the Flushing for Equitable Development and Urban Planning (FEDUP) Coalition in opposing the Special Flushing Waterfront District (SFWD) application currently undergoing the Uniform Land Use Review Procedure (ULURP). FEDUP represents Flushing residents and advocates who have expertise in affordable housing, urban planning, economic development, community engagement, senior care, youth empowerment and education, environmental justice, stormwater and wastewater management, climate change planning and waterfront access. The coalition has compiled the following concerns regarding the SFWD and our suggested recommendations moving forward. 

Concerns Regarding Process

The City’s land use review process (ULURP) for this special district lacks transparency and robust public engagement. None of the organizations within this coalition, which represents diverse aspects of the community and ecology most impacted by the development, were contacted prior to the ULURP certification or by Queens Community Board 7’s (CB7) Land Use Committee prior to the Board’s vote on the proposed development. While this may appear to be a simple communications error, a lack of substantial public oversight can have grave repercussions for large-scale development, especially in one of the City's densest urban areas. 

For example, the only environmental organization contacted by CB7 to participate in the review of the proposed 29-acre development (on a floodplain along a polluted body of water) was Friends of Flushing Creek, a front group for developers. This is particularly alarming in a process where the required Environmental Assessment Statement (EAS) of the City Environmental Quality Review (CEQR) does not adequately account for climate change and where the only building with affordable housing will be built entirely in a 100-year flood plain (the other buildings straddle 100 and 500-year flood plains). In this situation, public oversight could have put greater emphasis on the flood risks and climate resilience concerns raised by this project. This example represents only one of the many potential consequences of sub-par community involvement. 

Project Concerns

Outside of the process, the proposal itself has too many defects to warrant an approval. The most glaring issue is that the entire project will be privately owned. While the developers maintain that the privately owned streets and public spaces will act as any other public space, the fact remains that they are not public. In a CB7 land use committee presentation the project lead said that the SFWD will be a ‘new neighborhood’, unknowingly naming the problem of a privately owned neighborhood—privatized spaces make for separate neighborhoods that are not integrated into the existing fabric of the community. Instead, they act as privately-owned commercial districts for those who can afford the luxury condos. This description is similar to the description of any gated community, minus the gate. If approved, the SFWD will be one horrific step closer to having a gated community in a densely populated, socio-economically and ethnically diverse New York City downtown district. 

Additionally, the SWFD lacks a plan for any of the publicly owned institutions that are critical for an increase of 1,725 living units in a densely populated area. The City does not have a plan to increase the number of public schools, libraries, youth centers or senior centers, all of which were outlined as key recommendations by the Flushing Rezoning Community Alliance (FRCA), during the City’s previous Flushing West neighborhood rezoning proposal. FRCA’s recommendations can be found in the "Flushing West: Recommendations for a Just Rezoning" white paper. The required privately-owned public waterfront esplanade is often hailed as an important amenity brought on by the development. However, the esplanade is shockingly limited. It lacks connections to the Queens bike network, does not have a single proposed public bathroom and does not allow for direct access to the water. Furthermore, the owner of the UHaul site may not be required to include the esplanade, so it is possible that this plan will not actually result in continuous waterfront access for the community. Although the applicants maintain that the proposal is meant for the public, it does not have any of the amenities that would make the public want to use it. 

Privatization of public goods and the lack of necessary community institutions is one aspect of the economic separation of the ‘new neighborhood’ created by SFWD. Another is the lack of deeply affordable housing. Of the 1,725 units added by the proposal, only 60 to 90 units will be "affordable." These units will be priced at 80 percent of the Area Median Income (AMI), which is equal to $85,360 for a family of four. The median household income in downtown Flushing is closer to $41,000. This huge affordability discrepancy, combined with privately-owned streets, privately-owned public spaces, and no plan for new public institutions, tells low-income Flushing residents that the new development is not built for them. 

Recommendations

FEDUP asks that you consider the following recommendations:

• Require an Environmental Impact Statement and Transparent ULURP Process: The Department of City Planning issued a negative declaration on the Environmental Assessment Statement. The negative declaration eliminates two pre-ULURP opportunities for public review and comment on the socioeconomic, environmental and neighborhood impacts of this complicated and transformative special district and rezoning application.  Because of the negative declaration, Flushing stakeholders were denied an opportunity for a public scoping hearing to comment on topics that should be part of an Environmental Impact Statement, and another opportunity to review and comment on a comprehensive Draft Environmental Impact Statement. 
• Increase Affordable Housing: 100% of the housing units built in this development area need to be affordable to the current residents of Flushing (with 25% reserved for senior citizens). 
• Increase Public Amenities and Institutions: Add a new school, library, a youth center, and senior center on 10% of the square footage of the development.
• Include NYC-Owned Public Space: The applicant stated that there will be no direct water access built into the esplanade design due to concerns about liability; it cited Domino Park in Williamsburg, Brooklyn as an example of a privately-owned public waterfront access park that also does not permit direct water access. The liability issue could be solved with a NYC Parks Department-owned park at the waterfront maintained by either the Parks Department or a public-private partnership as seen in Brooklyn Bridge Park, which allows for public access. Domino Park does not allow for waterfront access because it is located on the East River, a tidal straight that has heavy boat traffic and strong currents. Flushing Creek is more similar to Newtown Creek, which has multiple public and private access points.
• NYC-owned streets
• Zero Increase to CSO Discharge: Managing rainwater and sewage.
• Hire Locally and Create Union Jobs: union jobs at prevailing wages from beginning to end; unionized workers from doormen to hotel clerks; job training for NYCHA residents and job fair for every job opening.

We demand an immediate stop to the City's land use review process for this Special Flushing Waterfront District until a comprehensive Environmental Impact Statement (EIS) is completed with participation by all the relevant community stakeholders who will face the burden of increased traffic congestion, environmental degradation, and risk of displacement. Thank you for your consideration of our concerns and asks. We look forward to hearing you. 

Sincerely, 

Flushing for Equitable Development & Urban Planning (FEDUP) coalition of local residents and small business owners, allies, and concerned members of the public.