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September 5, 2006

Purpose and Need

Brooklyn Views examines at one overarching flaw of the Draft Environmental Impact Statement, the statement of the "Purpose and Need" for the Atlantic Yards project.

According to the CEQR methodology followed for this particular project, the description of the purpose and need “should be framed in terms of how the action meets public needs and responds to public policies”.
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Initially, the DEIS for Atlantic Yards is as clear as it can be about the project’s Purpose and Need: “The overarching goal of the proposed project is to transform a blighted area into a vibrant mixed-use community”.
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But further on in the same Purpose and Need section of the document, more detail of the proposed design is provided. Does the Purpose and Need include providing an arena, a hotel, and exactly 6,860 units of housing? These sound more like specific features of the current plan. To include them as part of the Purpose and Need confuses the means with the ends, resulting in a document that can not be disputed but is ultimately meaningless: since the project is the same as the objectives, nothing can be changed. Because if it was, it wouldn’t meet the objectives. And, as we’ve previously noted, we see the results of this in the subsequent dismissal of the alternatives.

BV provides some examples of the conundrums and circular thinking that exists when the "purpose and need" is confused with the "description" of the project, and concludes:

If the arena is, in fact, part of the purpose and need of the project, say so, and show clearly how it furthers public policy. If the scale is required to make the project financing work, show us. The EIS should not be executed with a nod and a wink. Revise and resubmit a truly transparent document.

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Posted by lumi at September 5, 2006 6:49 AM