The Convention Follies,
Part 6
A Critical Moment Arrives
by Hank Bromley
Between noon and 8:00 p.m. on March 27, a “public information day” is being held at the current convention center on Franklin Street. Booths will describe the options under consideration and the information that Ecology & Environment (the firm conducting the study) plans to use in developing its recommendations. Comments from the general public will be recorded and included in the review process.
The County plans to establish a web site for ongoing public comment, but right now the event on the 27th is the only confirmed opportunity—until after the draft report has been completed—for members of the public to introduce their views and concerns into the review process. An open hearing will be held on the draft report, probably sometime in August, but making significant changes then will be far more difficult than making sure the study is based on appropriate considerations in the first place. Now is the time to have a say in how the analysis will be conducted.
So what’s an Environmental Impact Statement anyway?
Some 32 years ago, federal legislation (the National Environmental Policy Act) mandated an assessment of the environmental impact prior to initiating any of a broad class of projects. The meaning of “environment” has come to include not just the natural environment—release of pollutants harmful to human health, threats to endangered species, etc.—but economic, social, and cultural impact as well. Mandating preparation of an impact statement ensures at least some forethought as to what the effects of a proposed project are likely to be, with an opportunity for those affected to comment.
Typically an assessment begins with a list of alternative courses of action (in this case, razing the Mohawk Site/Electric District and building a new convention center there; building one on a parking lot near the HSBC Atrium and Arena; expanding the current center; or the “null option” of doing nothing). In the “scoping” phase—where this study is right now—those directing the assessment define the boundaries of the impact to be considered, the questions that are to be asked about the effects of the various alternatives. Then information is gathered to answer those questions, mostly by collecting existing studies and hiring consultants considered expert in what have been designated as pertinent areas. The alternatives are rated according to their impact on considerations within the scope of the study, and a recommendation is issued in the form of a draft impact statement. A public hearing is held on the draft statement (sometime late this summer), the draft is then revised in light of comments offered by the public, and a final impact statement is issued.
From theory to practice
This process does not, of course, guarantee an evenhanded and impartial assessment; what it does guarantee is that certain steps be exposed to public view, allowing any who see something amiss to try calling attention to the problem. There are many points at which any assessment is vulnerable to bias: what alternatives are on the table to begin with, what kinds of impact are included in the scope of the study, what information is considered in predicting the impact, which studies are drawn on, which consultants are hired, what questions are they asked to address, how is the public hearing conducted, what use is made of the public comments?
In all of those areas, bias can arise without deliberate efforts to rig the outcome (though that has also been known to happen). Everyone views the world from some perspective or other, makes certain assumptions without even realizing it, and may not think to ask certain questions. If a study is directed by a group sharing one perspective, whether intentionally or not they’re sure to overlook important considerations. For instance, because I’m an educator by profession I tend to see all problems in terms of education. Ask me what to do about this crisis or that, and more likely than not I’ll tell you the solution is better education. That’s how someone who spends his days immersed in and thinking about education sees the world. If you’re in the business of designing, building, managing, or financing convention centers, you may quite sincerely see a new convention center as the cure for what ails any city, and have a hard time perceiving evidence to the contrary. That’s just how you’re going to see the world, and it’s why the broadest possible range of perspectives among those directing the study and intense public scrutiny of the entire process are essential.
We’ve also seen some blatant and less-than-innocent bias in recent studies, like the Public Bridge Authority’s determination that the customs plaza lay outside the scope of the impact of replacing the Peace Bridge, and Empire State Development Corporation’s study (and farce of a public hearing) concluding that the limestone walls of the Commercial Slip would “blast apart” if left exposed.
Thus far, this assessment appears to be a different case. The mere fact that the county government, as the lead agency for the project, volunteered to conduct a full environmental review sets this case apart; the others proceeded only when facing court-ordered injunctions blocking all other paths. And County Executive Giambra has repeatedly stated his commitment to an open and thorough review. I’ve seen no reason so far to doubt it. But he and other key officials are also under enormous pressure from those who stand to profit from construction of a new center at public expense (or mistakenly think they do—Paul Snyder of the Hyatt should take a close look at what happened to the Statler after its owner pushed through construction of the present convention center, adjacent to his hotel; the boom-and-bust pattern of convention center usage, with enormous crowds one day alternating with a vacant cavern the next, are useless for sustaining adjacent businesses).
“Public information day”
So I say we take Giambra at his word and respond to his call for public participation. If he does want a fair and open assessment, he’s going to need our help making it happen. And if he doesn’t mean it, well then, he’s really going to need us to help him make it happen. Either way, we’d better not assume a fair assessment will happen without us, because by the time we find out if it was fair it’ll be too late to do much about it. Be there on the 27th, and tell them what questions you have.
Here are some of mine: Does the information E&E intends to base the study on address the real costs and benefits of the proposed project? Does it account for what’s lost in tearing down 35-40 buildings on the Mohawk Site/Electric District? Do they even know how much economic activity is already being generated there? Are they comparing this project to alternative strategies for developing that site (e.g., conversion of existing stock to housing and small business, with moderate-scale infill construction)? How will the proposed project and associated demolition affect the prospects to get more people living downtown? Will it promote or inhibit 24-hour, seven-day pedestrian activity downtown (what is its trip-generation per square foot, and how evenly is it distributed)? What is the value of Buffalo’s unique architectural heritage? What is the impact on the urban fabric of placing a monolithic, single-use facility of this size within the downtown core? Is there a feasible reuse plan in place for the current convention center? Are they comparing the economic impact to other ways of investing $151 million in downtown? What is the cost per job created, and per dollar of wages created? What is the relative risk of spending it all on one big project vs. a number of independent smaller projects?
Do the projections of increased convention business due to a new and bigger center take into account the projections by Tradeshow Week for a 25% increase in the capacity of competing facilities by 2005, and an increase of only 4% in attendance (plus the latest data showing a massive drop in planned convention attendance nationally this year)? Do they take into account the difficulty of attracting conventions here during the colder months of the year? And do they take into account the convention business now being attracted by the Adam’s Mark and the new Clarence Convention Center? Is the assumed number of average hotel-room-nights per meeting attendee borne out by the experience of similar cities? Are they looking comprehensively at how accurate projections have been of increased business after building new centers in other cities? Are they looking at the accuracy of previous projections in this region, i.e., the projections on which the current center was based, and those made for the Niagara Falls convention center? Where convention attendance actually has increased, was there in fact a related increase in retail and other economic activity, and how much?
Assuming we do attract more large meetings, is there a plan for providing hotel rooms, given that the existing downtown hotels are already at capacity in the summer, when we would draw the bulk of our convention business? Who is going to invest privately in a new convention hotel given the likely low occupancy in the winter? Will we then have to, like many other cities, build a publicly funded hotel along with the convention center, and how much will that add to the project’s cost?
Having examined both the 1997 Johnson Feasibility Study and the 2000 KPMG update (the basis for the current plan), I assure you they address none of these questions. Zero. Yet at present those remain the sole source of evidence for judging feasibility in the current assessment: at the Information Day visitors “will be able to learn about the research being used by the Greater Buffalo Convention and Visitors Bureau and its supporters to justify building a new center” (Buffalo News, 3/11/01).
What we need on the 27th is public participation, and gobs of it. We need to make them dash out halfway through the day to print more comment sheets. We need to stuff the convention center so full of people wanting to comment that we almost lend credence to claims that we need a bigger one.
Be there, or watch another tract in downtown Buffalo die.
Hank Bromley teaches at the UB Graduate School of Education and is a member of Citizens for Common Sense. He can be reached at hbromley@buffalo.edu. Previous articles in this series are available at http://www.gse.buffalo.edu/fas/bromley/CCS/.