Willets Point / Willets West ULURP DENY THIS APPLICATION BECAUSE: It prioritizes construction of an unnecessary 1.

.4 million square foot mall on 30+ acres of parkland property that was never considered as part of the Willets Point development with the excuse that a huge mall is needed to popularize the area, before any Willets Point neighborhood can be built. As the written contract between the developers and the City allows, Phase "1A" may be all that is built consisting of the huge mall on parkland, plus ancillary retail and a hotel along 126th Street (all with no new Van Wyck Expressway access ramps). The mall has been prioritized, while key "benefits" of the Willets Point development that were touted during 2008 as justifying its approval are being delayed, minimized, subject to prerequisites that no one is responsible to satisfy, and susceptible to contractual "out" clauses. Housing and affordable housing linchpins of the Willets Point development when it was approved during 2008 are delayed until the year 2025; and are not certain, even then. Housing and any other development beyond Phase "1A" is contingent upon new Van Wyck Expressway access ramps first being constructed but neither the City nor the developers are contractually obligated to build those ramps (with the City absolutely rejecting any responsibility in the contract "for the avoidance of doubt"). The contract allows the developers to build no housing upon payment of a penalty, the amount of which is so low that it is a mere "cost of doing business". Converting Willets Point property into a parking lot to facilitate a mall elsewhere does not realize goals of the original Willets Point development, and does not justify the contentious acquisition of Willets Point property under the threat of eminent domain, and ousting scores of existing businesses. Although during 2008 the City stated a cost of $570 million for onsite infrastructure and to thoroughly remediate all 62 acres of Willets Point, the remediation to be performed on Phase 1 property has been drastically reduced in cost, to just $40 million as budgeted now (which, extrapolated to the entire 62-acre Willets Point site for direct comparison with the previously-claimed $570 million, equates to $120 million). The kind of thorough remediation that the City said was essential simply cannot be accomplished when the budget is slashed to a fraction of what it was, originally. Either the developers' present plan fails to deliver the necessary, very thorough remediation or the City falsely exaggerated the extent of remediation during 2008, to horrify the City Council and provide a false pretext to approve the project.

 Adding the "Willets West" mall effectively doubles the size of the entire proposed development, from 62 acres as considered during 2008, to 108.9 acres as proposed now. The expanded project's impacts will be commensurately worse. Especially if Phase "1B" and beyond are built, intolerable traffic and other significant impacts will result from this project, affecting surrounding communities and commuters alike. The City's own traffic study admits numerous significant impacts at each stage of development that cannot be mitigated, and level of service degradations to "F" (failure mode). It is irresponsible to inflict such conditions upon Queens. The proposed project simply does not belong at this location. The new Van Wyck Expressway access ramps that must be constructed to facilitate Phase "1B" and beyond, only connect to and from the area south of Willets Point. Coming from the north, there will be no greater access traveling to, or past, Willets Point than there is today but there will be severe traffic congestion on roadways that exit into, or just travel past, Willets Point. In bad faith, the City has manipulated this project's environmental review so as to ignore impacts of other nearby projects that the City fully intends be built. For example, the City told CB7 that the impacts of events at a future Major League Soccer stadium are to be disregarded because the stadium has not yet been announced even as "Mayor Michael R. Bloomberg told reporters last week, 'Hopefully, were getting close to announcing a new soccer stadium here in Flushing Meadow Park.'" (Longman, Jere. 2013. Sheik Said to Pursue Soccer Franchise for Queens. New York Times, April 28.) The Mayor's dictatorial reconfiguration and vast expansion of this project are an insult to CB7, which was guaranteed to participate in the developer selection process, then was shut out of it. As it turned out, that developer selection process was also an opportunity to reject the present proposal of Sterling/Related, which sacrifices parkland property for a huge unnecessary mall, vastly expands the entire development from 62 acres to 108.9 acres, and increases its impacts. Is it any wonder that CB7 was excluded from that decision? This project rewards financiers of illegal lobbying. Sterling Equities is owned by the Wilpons, who also own the New York Mets a heavy financier of Claire Shulman's local development corporation (LDC), and a participant on its Board of Directors, during the time that the LDC lobbied for legislative approval of the proposed Willets Point development without filing any of the required registrations or periodic disclosure forms lobbying which the New York State Attorney General has since found constituted a fundamental violation of the state's Not-for-Profit Corporation Law. During 2008, the City Council questioned whether developer firms that were members of Shulman's LDC should be "prohibited from bidding" on the proposed Willets Point development. Now five years later, those developer firms not only weren't prohibited from bidding, but Sterling has been awarded the prize that was an objective of the illegal lobbying.

 This project continues to abuse eminent domain for a non-essential, non-public purpose to enrich a private developer a disgraceful practice which 43 other states have already enacted laws to prohibit or curtail, and which the U.S. House of Representatives voted during 2012 to punish by withholding federal funds. During 2008, labor union representatives testified to the City Council that the New York City Central Labor Council had reached an "historic agreement" with the City, requiring a provision pertaining to "living wage" to be included in the Willets Point Request for Proposals. However, despite that "historic agreement" being a basis of the City Council's approval of the proposed development, the City later reneged, and published a Request for Proposals that did not contain the required living wage provision. As a result, respondent developer firms were not required to explain how their proposed tenanting plans would maximize the number of jobs that meet living wage criteria. By the City abandoning a living wage for Willets Point, retail workers at any future development there will earn the minimum wage, which is approximately 37 percent less than living wage. By denying this application, you make clear that the goals and specifications of the Willets Point development, as presented during 2008 when that development was approved, are to be respected, not circumvented by a cabal at City Hall. We do not want or need a vastly expanded development that unnecessarily sacrifices 30+ acres of parkland for use as a mall. Make the City publish a new Request for Proposals, and insist that the City fulfill its written commitments to include CB7 in the developer selection process, among other commitments. In that way, CB7 can do its part to ensure that proposals of all developers not just those who have special access to property beyond the boundaries specified within an RFP are fairly considered. Information presented by Willets Point United Inc.