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Testimony of
New York State Senator Liz Krueger Before the
Department of Sanitation Regarding the
Draft Scoping Document for the
Environmental Impact Statement for the
Comprehensive Solid Waste Management Plan June 28th,
2004 Good
evening. My name is Liz Krueger and I
am the State Senator for New York’s twenty-sixth senatorial district, one
primarily comprising parts of Manhattan’s Midtown and East Side. I would like
to thank the Department of Sanitation (DSNY) for hosting this public hearing
and allowing me to speak. I
was alarmed when initially notified of the DSNY’s intention to resume
operation at the 91st-Street marine transfer station (MTS). Although this MTS was an active component
in the City’s waste disposal system as recently as 1999, its location both
within a serene residential neighborhood and adjacent to a resource like
Asphalt Green—a City park and needed recreation space for the Upper East Side
and all of the City—would hopefully dissuade a restoration of service given
the intrusions beyond adequate mitigation promised by a facility that will
undoubtedly emit pungent odors, host a constant procession of
pollutant-emitting trucks, and create maddening traffic disarray. In other words, the proposed site is
completely inappropriate and unacceptable. That
said, I remain convinced that marine transfer stations can play an important
role in solving New York City’s waste management problems. Furthermore, I recognize that waste
disposal is a messy issue because garbage, by definition, is not anything
that anyone wants any part of.
Accordingly, I am sympathetic to the demands placed on the DSNY. The “not-in-my-backyard” syndrome (NIMBY)
is one that has routinely complicated waste disposal planning. So that I am not seen as a NIMBYist, I
would like to make clear that I do not oppose the placement of a marine
transfer station on the East Side. We
must all be responsible for our own waste, and I encourage DSNY to find a
suitable MTS site within the boards that this one would serve. However, the proposed site at 91st
Street—behind Asphalt Green and just north of Carl Schurz Park and several
landmarks—is completely inappropriate because it would fundamentally alter
the character of a dense, residential neighborhood and irrevocably harm
Asphalt Green, a unique resource. Criticism
without suggestion is easy to offer, though, and lest anyone mistake this
testimony as anything other than constructive, I would like to assist the
Sanitation Department’s good-faith efforts to produce an environmental impact
statement (EIS) by offering several concerns that should each receive
genuine, close consideration. The
Department, if it acts responsibly, will find the 91st-Street site
wholly unfit to host the converted MTS currently proposed. The
draft scoping document sets inadequate and incomplete parameters for a
legitimate environmental impact study, severely neglecting the maximum
operation capacity of the converted MTS at 91st Street and,
resultantly, woefully underestimating the mitigation required to compensate
for the tremendous burdens that would be subsequently created. As written, the scoping document will
yield an EIS that does not properly account for the traffic, odor, noise, air
quality, and health impacts that the MTS at 91st Street would
create. Additionally, it erroneously
excludes consideration of landmarks like Gracie Mansion, the Church of the
Holy Trinity, the Municipal Asphalt Plant that now houses Asphalt Green, and
Henderson Place within a half-mile radius of the proposed MTS site; a
cost-benefit analysis of the retrofitted MTS site compared to the five token
alternatives explored; and alternative sites for the proposed MTS. I sincerely hope that the DSNY closely
listens to the plethora of logical objections that will be presented by many
speakers tonight and faithfully administers a review process that yields a
comprehensive and responsive environmental impact statement. Despite
being unclear about the design of the new facility and the mitigation options
for its myriad negative impacts, the SWMP makes clear that the marine
transfer station at 91st Street will be expanded and improved,
replete with a bigger footprint, a larger building, and a greater capacity
for waste. The plan forecasts that 91st
Street will receive roughly 1,190 tons of residential garbage per day,
however it also discloses that the MTS could accommodate up to 4,290 tons of
refuse in that same twenty-four hours if so required. The 4,290-ton capacity mentioned in this
draft scoping document seems to account for the commercial waste that could
be delivered to the 91st-Street station were the City to also
implement its commercial waste plan, a schematic already studied by the
DSNY. To conclude that the proposed
MTS at 91st Street would become a destination for commercial trash
seems rational and justified because the plan has already been considered,
the garbage will not dispose of itself, and New York City must immediately
begin to correct its deficient waste management system. So what would that mean for the Upper East
Side? An
MTS receiving 4,290 tons of trash from four community boards would operate
six days a week and receive trucks throughout the day and night. As these trucks traveled to their
destination, they would increase the volume of traffic on already-crowded
streets, sit in a queue along York Avenue, and carry a trail of odor that
would significantly alter the character of the neighborhoods through which
they passed. The stench would be
particularly strong around Carl Schurz Park and Asphalt Green, two open
spaces that serve an Upper East Side generally bereft of true parkland. While the City should be commended for
converting its fleet of garbage trucks to one populated by vehicles whose
engines burn biodiesel fuel, these vehicles do still release some unhealthy
emissions, and many of the merchant carriers who would also deliver refuse to
the MTS at 91st-Street continue to rely on heavy-polluting diesel
trucks responsible for sulfur-, nitrogen, and carbon-based emissions. This
bleak, though thankfully still hypothetical, circumstance will become a
reality if the marine transfer station behind Asphalt Green is converted and
reopened. New York City would be
committing an injustice against its own citizens. To ameliorate any confusion about this outcome, the Department
of Sanitation must conduct a thorough environmental impact study including
the worst-case, 4,290-ton scenario
“…Consideration will be given to possible traffic, air and noise
impacts attributable to the facilities and their possible impacts upon nearby
open spaces, if applicable,” is what the scoping document says about
open-space impacts. A circumstance in
which large, polluting trucks filled with refuse rumble through Asphalt Green
at all hours qualifies. The
draft scoping document is serially plagued by this sort of myopic
planning. The proposed traffic
analysis, for instance, will be one conducted under the assumption that the
91st-Street MTS will receive 1,190 tons of garbage each day. However, as earlier discussed, there is a
great likelihood that the MTS will instead receive 4,290 tons. As a result, the current traffic
projections are dangerously obsolete!
On peak collection days, the MTS would receive 469 delivery
vehicles, not 130. On off-peak days,
the site would still need to accommodate—given a conservative assumption of
15-percent less traffic—398 trucks, or seventeen per hour. While the scoping document is vague or
neglectful concerning the MTS design and the refuse offloading process, it
seems fair to assume that in order to go through Asphalt Green, unload its
contents into non-spill containers, turn around, and then exit, each truck
will require more than the three-and-one-half-minutes average that the
current plan would allow.
Reconfiguring a few intersections or altering some traffic light
patterns seem like hopeless remedies for this potential plague. As
trucks took longer to unload their cargo, those that arrived later would
begin to line-up along the delivery routes—the narrow streets running
east-west and congested York Avenue, a thoroughfare that already barely
accommodates two bus routes, FDR Drive access, and a high volume of
cars. While idling, waiting to
dispatch the waste that they carried, the trucks would be sitting with their
motors running, releasing exhaust pollutants, emitting odors, and creating a
din. Again, I must return to the
faulty parameters proposed by this document when I assert that this situation
will cause problems for which there is no adequate mitigation. Here’s
an example: Under the residential-waste only assumptions, the scoping
document concludes that the odor impact of the trucks will be one that is
detectable though not insufferable.
Any already detectable foul scent would likely be unbearable were its
intensity increased four-fold, as would be the case given the staggering
number of additional trucks that would enter the area. Such an impact cannot be mitigated, and it
would effectively ruin the crucial facilities in the area, like Asphalt
Green. Similar arguments can be made
about the four-fold increase in traffic, noise, and air pollution. If you think that driving on York Avenue
is already frustrating, wait until there are standing trucks constantly
clogging the road; if you currently enjoy a restful evening of sleep,
remember it fondly as diesel engines roar throughout the night. A single area of Manhattan should not be
asked to accommodate these overwhelming impacts. Beyond
the environmental and quality-of-life problems that the MTS would cause at
this location, there would also exist a significant threat to public
health. With fifty-five schools
sending almost 4,000 children to Asphalt Green for recreational activities,
permitting heavy polluters like diesel-fuel trucks to constantly idle near
the site and imperil a population particularly susceptible to respiratory
ailments is not only unsafe but negligent.
New York City already has alarmingly high rates of asthma among some
youth populations, and the proposed MTS at this location could push those frightening
numbers higher. The
effects of converting the MTS in question will be disastrous: a renovated
station would stagnate traffic flow, destroy air quality, erode the character
of a neighborhood, threaten the safety of our children, create noise
pollution, emit unbearable fumes, and cripple Asphalt Green. An
appropriate EIS—one that displays a far greater understanding of these
ramifications than the scoping document that preceded it—would account for
residential and commercial waste processing at the 91st-Street
MTS, strenuously explore other sites along the East Side that could host a
marine transfer station, and fairly assess the risks associated with the
proposed location. If the EIS
accomplishes all this, I feel confident that Asphalt Green and the residents
of Gracie Point will have nothing to fear.
There is a place for a marine transfer station on the East Side, just
not at 91st Street. Thank
you for your time. |
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