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Organizational Statement on QCL Proposal

Organizational Statement from Buffalo Niagara Waterkeeper Executive Director Jill Jedlicka

“We are at a critical moment in time, where our community is having a constructive debate on defining the future of Buffalo’s unique Great Lakes waterfront. Our leaders and citizens are faced with tough decisions on what the future use of the shoreline of this critical resource should be, and determining the effect those decisions may have on the public, the environment, and future generations.

Luckily for us, hundreds of leaders and citizens have spent decades evaluating the scenarios of what a thriving economy could and should look like along our various waterfronts. This collective vision came from an inclusive public process that had been debated for years, and was codified into the City’s Comprehensive Plan, Local Waterfront Revitalization Plan (LWRP), and the Green Code (aka the Unified Development Ordinance, or UDO).

Any proposal for development on the Outer Harbor must undergo thoughtful and careful scrutiny, and should be held to the highest standards. Our community and natural resources deserve this level of stewardship, especially for a waterfront that is only just recovering from 100+ years of pollution and poor land use decisions.

The proposed tower development concept by Queen City Landing could make an attractive investment in our community, if only it was located in the urban core, where it would be integrated into the fabric of our existing communities, infrastructure, and city services. The authors of our regional Plans and Ordinances would agree, as they never envisioned, endorsed or would support the building of a 20+ story tower along our lakefront. This proposal is completely out of character from the current and envisioned land uses of the surrounding lakefront properties.

The pursuit of the Planned Unit Development (or PUD) designation and the attempt at rebranding the project as ‘lofts’ rather than a tower, is, by their own admission, an obvious attempt by the QCL developer to bypass the zoning laws and land use procedures put in place to protect our lakefront.

PUDs are supposed to only be applied to projects that facilitate development for the public good, not to be used as an end-around of environmental rules and public process.
Buffalo Niagara Waterkeeper has outlined our legal, technical and scientific feedback based on the publicly-available information associated with the developer’s PUD proposal in our January 13th letter to the Buffalo Planning Board (link to full comment letter here).

From our review, we believe that:
• The Project Does Not Meet the Review Criteria Required for a PUD
• The Project Does Not Provide the Public Benefit Required for a PUD
• This Project Should be Considered a New Project and Subject to New Environmental Review
• Coastal Resiliency and Stormwater are Not Adequately Addressed

Buffalo Niagara Waterkeeper maintains its original public position that this site could be developed sustainably in some limited form, and there are opportunities to provide a beautiful, ecologically sensitive, multi-use space which simultaneously provides public access, climate resiliency and protection of Lake Erie and the nearshore area. The site could also serve the community and Lake Erie well by simply being maintained as a natural regeneration area and buffer to the City of Buffalo in the face of a changing climate and extreme weather events such as the more intense lake seiches and heavy winds we are experiencing. The proposed QCL tower plan is in stark contrast to the City’s efforts to establish a Green Code and the intent of the LWRP, and should not go forward as designed.”