Dear Stewards of the City of New Rochelle:
As a longtime New Rochellean, I read the DGEIS for the City’s 10-year Comprehensive Plan and want to express my appreciation, but need to convey a much greater concern.
The DGEIS states that the Comprehensive Plan calls for “future higher density development in New Rochelle” without “directly resulting in physical changes to the environment.” This is a laudable and potentially realistic goal, but not as it is currently written. As the Plan pertains to the Waterfront area (referred to in the Plan as WR and WR-1), it outlines “key steps in rebranding the City of New Rochelle as a major local and regional coastal destination” through outsized commercial development and rezoning. If the City is intent on reaching such a “destination” through commercial enhancement of the proposed scale, it must give equally aggressive consideration to how it will protect the unique Waterfront environment and its neighborhoods.
As examples of how the economic sustainability can go hand-in-hand with environmental stewardship, both Provincetown, MA on Cape Cod, and Mystic, CT are major tourist destinations, but have maintained a vision that the local community and environmental agencies support. In Mystic, the maritime study programs there offer perhaps the best hands-on sea education of any coastal destination, a significant component of their economic growth. In P-Town, where tourists flock, their mission states that “development that is out of scale and character will continue to be discouraged by local regulations. Environmental quality and natural resources will be protected. We will continue to expand local protection of wetlands, ponds, harbors, floodplains, groundwater supplies,” etc.
The Plan for New Rochelle proposes to allow far-reaching, long-term commercial development in WR and WR-1, which are designated by NY State as Critical Environmental Areas (CEA). These sections are also at the heart of one of the heaviest concentrations of Tidal Wetlands in New Rochelle. There’s no dispute that the area has been neglected, so an economic resuscitation of that area would be welcome. But as it reads now, the Plan’s lack of attention and mission to limit its impact, ultimately signals an overall failure:
- While the goals of the pertinent Agency, the City Council, are far reaching and comprehensive, they don’t appear to allow for alternatives or adjustments. A key concern is that the only named alternative to the Proposed Action is the Proposed No Action, which suggests that the City aims to do all that they outlined in the Plan or do nothing. This is an all-or-nothing vision that is reckless and scary. There should exist the wherewithal to propose expertly-guided changes to the Comp Plan. Right now, it appears that one cannot agree to the development of Hudson Park, say, or the Municipal Marina, for multi-use dwellings, and at the same time also commit to limits on zoning proposals, or seek to implement studies of adverse environmental impacts. This lacks foresight and balance.
- Additionally, when the Agency proposes that future building will be allowable, they can’t realistically state that there will likely be no adverse impact by future buildings due to existing codes and regulations. How responsible is it to declare specific building allowances without also specifying what measures should be taken to limit the surrounding impact of those buildings? That kind of planning is only half baked.
- Where there is consideration of the environmental impact on the Waterfront in the Plan, it is indeed welcome, but it is also troubling. While pains are taken to show how development would be protected from another Sandy, the Agency has minimized the equally real danger of increased population and building density and everyday storm run-off.
- Other potential risks are discussed in tones of warning, such as the following statements:
- Major storms: “Small area islands will become increasingly vulnerable.”
- Drainage of streams and ponds: “all in varying states of distress.”
- Wetlands erosion: “This is of great concern, as salt marshes are considered the most ecologically productive, diverse and valuable land areas in this region and a vital component for aquatic and avian species survival.”
- Sea Level Rise: “Residential areas, businesses, industry, municipal facilities and parks are at risk to flood and tidal damage. Sea Level Rise has been documented in Long Island Sound… Sea level rise will further the destruction caused by storm surges including threats to life and property.”
If the risks are so great, why are the “resiliency measures” barely mentioned? Such mitigating measures, which are missing throughout the proposal, must be named, studied, pass review, and emerge from a deep concern for human and environmental safety.
There exists a real danger that the Agency is “kicking the can down the road.” If the City Council is allowing development, they must also order thorough environmental studies NOW, rather than wait until future building permits are sought. Then it will be too late. If they are flexing enough authority to permit future development, they ought to be responsible enough to use the same authority to order comprehensive ecological surveys and review of potential costs on climate, ocean, bay and wetland life, etc.
Whether or not aspects of this Plan are inevitable, adequate time should be given to allow for neighborhood and environmental protections to be put into place, and to allow the neighborhoods themselves to become part of the development process.
What’s missing from this proposal is a collaborative spirit and the balance of community input. Letting the economic forecast of this project be known is admirable and shows promise for the future of the City. But what is of equal, if not greater, concern is an accurate reporting of the environmental and community support this project requires. Regard for the well-being and ecological health of the Waterfront must be evident for the proposed renewal to be a genuine success.
Peter Carlin
152 Sutton Manor Road
New Rochelle, NY 10805
