The Eastern Queens Alliance is adamantly opposed to the siting of the NYPD Impound Lot on Rockaway Boulevard in Springfield Gardens, NY. For the past several years, the stretch of land along Rockaway Boulevard, just north of JFK Airport, has attracted projects that pollute the air we breathe, pollute our ground water, and only bring more smog, congestion and traffic into our area. None of them benefit the community. For example, the Economic Development Corporation pushed through the construction of the International Air Cargo Center which was constructed on 25 acres of alienated park land on Rockaway Boulevard. The siting of Logan Bus Depot and Quick Courier on the south side of Rockaway Boulevard was also approved. And now we face the siting of the NYPD impound lot which is proposed for a 13 acre open space area that contains 2.2 acres of wetlands. In addition, the MTA is planning to put a storage parking facility for out-of-service buses where the Nassau Expressway meets Rockaway Boulevard. This is very close to the two other EDC projects and the impound lot – and right across the street from the former Green Bus Garage, now operated by an MTA operating subsidiary. All of these projects are diesel-intensive, thus adding to the toxic mix of respirable particulates in the air we breathe here in the Brookville, Rosedale and Springfield Gardens Communities. They also all contribute to toxic runoff. We believe that this constant barrage of projects that negatively impact our community constitutes a violation of environmental justice policies.
Although the community has been calling for a cumulative risk assessment to take into account the many projects proposed and sited along this strip to evaluate the total cumulative impact, none has been completed. Our air and water quality are being negatively impacted despite “negative declarations” in the individual EIS’!
The site in question is valuable open space. It is not, as EDC claims, just empty space ripe for development. It along with the other green spaces that are being gobbled up along the northern edge of JFK airport have served as natural, green, environmental buffers between the airport, related services in the vicinity and the residential community. While communities all over the country are striving to preserve their open space for ecological, health, aesthetic, and economic reasons the city seems to have targeted this strip for projects that contribute to pollution rather than help prevent it. What is happening in our community is diametrically contrary to the Mayor’s PlanNYC that calls for greening of the city. The Mayor recognizes that trees and plants help to clean the air of pollutants, this being the motivation for the Million Tree initiative. We know that increasing, rather than decreasing the vegetation, the greenery in our community, is critical to the health of the residents in Southeast Queens who live in the JFK airshed. Yet what we are witnessing is a degreening of our community. While the city plants a million trees, thousands of trees and shrubs are being destroyed in this area.
Furthermore, the NYPD Impound project calls for filling 2.2 acres of freshwater wetlands. While these wetlands do not have a surface connection to other water bodies in the area, it is highly likely that they are connected to the system of ground water that is an integral part of the Jamaica Bay Watershed. We know that wetlands are natural sponges and filtering systems that aid in the prevention of flooding and poor water quality. Even small areas in our community should be preserved to help combat the flooding that plagues Southeast Queens. Yet the proposal for this project dismisses the importance of these wetlands by labeling them “non-jurisdictional”.
In fact, the letter it cites from the USACE states that the “site contains jurisdictional waters of the United States based on: the presence of wetlands determined by the occurrence of hydophytic vegetation, hydric soils and wetland hydrology according to criteria established in the 1987 Corps of Engineers Wetlands Delineation Manual.” It seems to note that the only reason that they are considered, for the time being (perhaps five years) “non-jurisdictional” is the result of a 2001 U.S. Supreme Court decision (Solid Waste Agency of Northern Cook County v. US Army Corps of Engineers, No. 99-1178, Jan. 9 2001, which ruled that the designation of “jurisdictional” cannot be based solely upon their use by migratory birds.” The USACE also makes a point of saying, “It is strongly recommended that the development of the site…avoid ,,,the discharge of dredged or fill material into the delineated waters of the US….If not, authorization from their office many be necessary.” Clearly USACE doesn’t view these 2.2 acres as just a mud puddle as we were given to believe at the Public Hearing.
The EQA maintains that these wetlands should be preserved, not filled for an impound lot. A close reading of the EAS would seem to support this view when it maintains that the “center of the project site “is a wetland which appears to be supporting a diversity of wetland plant species; that a review of historical aerial photographs indicates that the project site “might have been retained to serve as a storm water detention area, receiving runoff from all of the surrounding paved services;” and that the project site contains 7 metal plate covers that are associated with “some type of storm water drainage system that discharges to the project site.” Yet this project would cover this site with an impervious surface, contrary even to recommendations and BMP’s in the Jamaica Bay Watershed Protection Plan. What’s to become of this critical flood control function of this site if the impound lot becomes a reality?
Per mitigation policy, at least acre for acre mitigation should be provided to account for any wetland loss. This policy is not being honored in the plan.
Finally, the proposed project runs contrary to several recommendations in the Jamaica Bay Watershed Protection Plan. The JBWPP plan notes that some of the key issues that affect the water quality and the ecology in the bay are:
a. Surface runoff as a result of urban development and the spread of impervious surfaces
b. Displacing freshwater wetlands in the upper watershed … impeding the natural wetland filtration process.
c. Displacement and fragmentation of habitat…by land filling of ecologically sensitive areas, especially tidal…and freshwater wetlands and riparian areas in the upper watershed.
d. Covering of soils with impervious concrete and asphalt surfaces, thereby decreasing ground water infiltration, while increasing the volume and rate of storm water runoff.
The JBWPP cites as an objective—To preserve and enhance natural areas along the periphery of the bay and in the watershed. It advocates the promotion of the use of BMP’s in all new and existing development in the watershed, i.e.,
a. onsite detention and infiltration of storm water runoff
b. minimization of impervious surface
c. creation of natural systems to control and minimize storm water runoff
d. stabilizing and restoring salt marshes, wetlands, soils and other natural areas
e. strengthening ecological buffers
This is also an objective of the Alliance and is in concert with our efforts in Idlewild Park Preserve and all of the adjacent wetlands and open space in the area, It is towards these ends that we created a master plan for the Idlewild Preserve and ecological system and have been constantly seeking funds for the restoration of wetlands and upland areas in Idlewild replete with trails, boardwalks and open classroom areas that would not only return ecological function, but provide for environmental education, recreation–including waterfront access, and simply the enjoyment of the natural environment. It is for this reason that for the last several years we have also been calling for 1) the turning over of the Thurstin Basin area to NYCDPR for the development of a waterfront park, 2) the turning over of all the DCAS properties immediately adjacent to Idlewild Park Preserve to NYCParks as recommended by NYC Wetland Transfer Task Force, and 3) a moratorium on the further elimination of open space along Rockaway Blvd.
This project not only flies in the face of all that the Eastern Queens Alliance has been advocating for over the last six years, and discusses in its Whitepaper for Quality of Life in Southeast Queens, but it flies in the face of Environmental Justice Policies, the recommendations of the Jamaica Bay Watershed Protection Plan, the Recommendations for the Transfer of City-Owned Properties Containing Wetlands promulgated by the NYC Wetlands Transfer Task Force, the Mayor’s Plan NYC initiative as well the recommendations adopted by the NY/NJ Harbor Estuary, and a Community Board 13 resolution. We, therefore, strongly object to the siting of the NYPD Impound Lot on Rockaway Boulevard in Springfield Gardens.