Sierra Club, Buffalo Niagara, responds to Perkins+Will Preferred Plan for the Outer Harbor

Below, with their permission, is the response  of our partner, The Sierra Club Niagara Group, to the Preferred Plan for the Outer Harbor, as presented by Perkins+Will, commissioned through the ECHDC.  This continues a series of dissents, which includes the recent release of an outer harbor vision from Riverkeeper, by our partners as well as like minded people and organizations.  Additionally, one developer recently spoke to Buffalo Rising also discussing the flaws in the current proposal process.

Niagara Chapter

Niagara Group

TO: Sam Hoyt, Erie Canal Harbor Development Corporation
Kenneth Adams, Commissioner, Empire State Development Corporation
Byron Brown, Mayor, City of Buffalo
Congressman Brian Higgins, US Congressman
Mark Poloncarz, County Executive
Perkins + Will, Consultants

FROM: Sierra Club Niagara Group

RE: Comments on the “Preferred Alternative” for the Outer Harbor, Buffalo, NY

Thank you for the opportunity to respond to the preferred alternative for the development of the Buffalo Outer Harbor as presented by Perkins + Will on Tuesday, September 9, 2014 at the WNED Studios in Buffalo.

To begin and to clarify the comments, the Sierra Club Niagara Group passed (6/24/14) a resolution regarding the development of the Outer Harbor:

The Sierra Club Niagara Group supports the establishment of a large public green park on the Outer Harbor with appropriate rehabilitation of existing buildings. We oppose the allocation of the currently open green space for new construction of housing or other types of facilities.

Within that context, we are formally filing comments regarding:

The Principles
The Design Proposals
Public Investment
The Public Process


There has never been a public discussion of the Principles adopted by the ECHDC and almost all of the opposition to the proposed plan stems from this lack of discussion. This serious oversight means that none of the meetings can be truly considered ‘public’ because the goals and the vision are without any public review.

The Principles offered are not even from or about Buffalo. In spite of the fact that planning for the Outer Harbor has been going on since at least 1982 and over the years literally thousands of people have been involved in sharing a vision for the Lake Front, none of this is reflected in the principles. Further, these principles do not reflect current planning in the city of Buffalo like the city’s comprehensive plan that says ‘no sprawl’ in the city and the planning for a sustainable city as being done by One Region Forward, the Green Code and the LWRP. What seems to have happened instead is that the original drafts of these last two documents have been manipulated to make them more hospitable to the developers on the Outer Harbor.

The adopted Principles and marching order to the consultants were adopted in their entirety from the Brooklyn Bridge project. There are many good things about the Brooklyn Bridge project but as an analogy for Buffalo, this is not an appropriate precedent. Let us name three reasons: first, the land on which their park was developed was a constructed landscape in ruin – piers, wharfs and so on, with no ‘natural’ landscape other than the water itself. Second, it was located next to a densely populated neighborhood that would be users of a new park, and the population context of NYC with over 8 million people cannot ever be considered a precedent for New York’s second largest city, Buffalo with a population of 270,000 and MSA of 1.5 million. And three, it is not located on the western end of Lake Erie with the ferocious weather we experience during the winter. This has been a serious misstep on the part of ECHDC as the principles adopted are not appropriate to our isolated, three season hospitable, regenerating area with a much smaller population.

The first three of the Brooklyn Bridge Principles sound fine in the abstract. But when you the fourth principle of Financial Payback, the set of principles require significant development such as housing, commercial and year round uses simply to pay for the investments that would be made. The range of use and aspirations embedded in the first three actually create a situation that then has to be resolved through development – a problem you’ve created. Rethink the principles and reframe the intention.

The Western New York Environmental Alliance, an organization that represents hundreds of people in the region many of whom have been working on some aspect of the Outer Harbor for many years, has proposed an alternative set of Principles. These would create a Lake Erie waterfront that would be uniquely Buffalo, provide wonderful opportunities for the people of the region, and cost very little. The Sierra Club has signed onto the Principles that are attached to this document.


With comments on ECHDC preferred alternative

It should be clear that we are not supportive of building another city on the Outer Harbor. The draft proposal was presented in a vacuum, as if this parcel of land were not a part of the entire city. In a city with little development pressure, it replicated proposals already in place for the Inner Harbor and activities being implemented at the new state park south of the land. ECHDC itself has significant housing and commercial development planned for the Inner Harbor and would be competing with itself. Erie and Niagara Counties have 45,000 vacant units of housing, much is disrepair, and if we could actually finance 2000 units of housing, it should be done in the near vacant areas of the city. Lou Ciminelli’s plan for the Central Park area is a great precedent, and the development ongoing around the Buffalo Medical Campus represents the kind of investment that has a triple bottom line.

The preferred plan assumes private development on the Outer Harbor yet this is public land being held in trust for the people of Buffalo by the State of New York. The Outer Harbor belongs to all of the people of this state and it not up for auction or economic wealth for a few. Housing on the Outer Harbor would result in publicly subsidized housing for rich people on land that belongs to all of us. If development were confined to existing building footprints of the ground floor and former head house of the Connecting Terminal, and Terminals A and B (and Harvest Queen which is currently not a part of the project to date), there would be thousands of feet of commercial space available, certainly more than we could absorb.

Specifics: Rather than addressing the specifics of the proposed plan, most of which we find inappropriate, we will offer an alternative vision of development on the Outer Harbor. There are three basic premises:

*Protect and expand all natural habitats between Times Beach and the Terminals – all this should be a ‘natural area’ with paths, environmental interpretations and careful insertions of other uses to be mentioned below. At all costs, protect Times Beach, the Bell Slip, Tifft Nature Preserve and the emerging forest and grasslands!

*Confine development to the areas where there are current buildings.

*Consider the Outer Harbor a three season venue with ‘cheaper, lighter, quicker’ responses and investments.

Here are a few ideas of development that could occur:


  • The Connecting Terminal has a 20’ high basement that could be developed with public activities along the Buffalo River accessible by ferry and other boats during warm weather. During the cooler and cold months, this would be closed. The area now owned by NYPA and to be transferred to ECHDC should be ‘park-like’ transitioning into Times Beach Nature Preserve beginning at Fuhrmann Blvd. The top of Connecting Terminal has a spectacular view – build a public overlook and restaurant on the top.
  • Wilkeson Point to Times Beach – this should be transitional native vegetation to protect Times Beach with the existing small beach, perhaps some small picnic areas. Limit the areas of mowed grass.
  • The Seaway Piers. The proposal for a swimming area similar to the former Erie Beach in Fort Erie or the swimming area that was once located at the foot of Porter Street is a good idea. This might suggest a small facility to make it more comfortable, but the feel should be more of a natural park than municipal park. The north end of the wharf could be primarily fishing and the south edge some pool area. Having boats being able to dock is critical as is access from the level of the water to the top of the piers.
  • Pier Restaurant site: This area is serviced and could have more seasonal development such as a line of cargo containers with services for boaters and other visitors (particularly if priority is given to local venders). This is the appropriate area for an amphitheater as it offers just a little bit more protection from the wind than the area south of Bell Slip. The area of the audience could be a large meadow that could be used for concerts but not opened before bird nesting season is over. The stage could be designed to be dismantled in the winter but still leave a structural icon for the waterfront.

 BELL SLIP AND SURROUNDING AREA – what you have called the Great Lakes Park.

 The waterfront edge along the entire site should be vegetated among the riprap, and wooden piers built over the stones to give people access to the water. Although we like the scalloping of the shoreline, an engineer colleague who worked with the Corps of Engineers on the Buffalo Waterfront for many years is not certain it can be done. The proposal is worth additional investigation to consider engineering feasibility, habitat value, and cost. But the planting and wood piers over the riprap can be easily done – “quicker, lighter, cheaper.”

Further, if it is possible to expand the Bell Slip to increase the blue/green edge, this would be worth doing.

THE TERMINAL AREA – foot of Ohio Street

Do not sprawl in the city, do not replicate proposals such as a playground currently proposed for the park, do not build any additional structures at this part of the site. Use the existing buildings for appropriate uses (not plastics molding factory). For example, the deep water pier between the Terminals could be used as a Great Lakes Cruise ship Terminal with some facilities for a port of call – but minimally.

The most important issue here is that this area should not even been considered for redevelopment unless the city itself is overflowing with residential and commercial development.


The economic consultants have not given any figures for the cost of any of these proposals but they were honest in their statement that all of the early investment will be public and it will cost a lot!   The transportation proposals alone with bridge and light rail extension would probably pay for the entire investment required for the vision presented above.

The region has already made huge commitments of public dollars: Inner Harbor, Medical Campus, Riverbend, Ohio Street to name a few. Each of these investments provides jobs, dense developments to provide high quality urban life and walkable neighborhoods, all within the existing street and serviced area of the city. These should be supported. As citizens of the city, we are insistent that our public dollars be spent wisely. Private development on the Outer Harbor is not a wise investment for all the reasons listed above.


We come back to the principles as outlined by the Western New York Environmental Alliance. Sierra Club and many others have asked for public discussion of alternative visions and have been denied. Like others who have spent years working on the Outer Harbor and all the waterfront of this city, we resent being asked to move things around a landscape that we don’t believe should be even considered. We want a frank and open discussion with all parties.

This process has been organized so that groups organized to represent specific interests not been seriously engaged – all in the name of being more public. But the public always operates with intermediate institutions which represent interests such as community groups, labor unions, business organizations and so on. To eliminate the immediate institutions such as environmental groups in this situation means that you are denying the planning process and consultants years of experiences, knowledge and insight that should be informing the process.[i] If environmental groups are considered a ‘special interest’ group, one has to ask what special interest is represented by the ECHDC board and Commission who will, in the end, decide on the preferred alternative. They are, in no way, representative of the people of the city.

Unlike the mantra that has been used by the consultants and development agency, the Sierra Club is not in agreement that ‘nothing has been done’ on the waterfront in the City of Buffalo, including the Outer Harbor. This statement is false and misleading to the people and disrespectful of people who have worked hard to get things done like Brian Higgins and George Arthur, to organizations and agencies like the Greenway Commission, the Times Beach, Tifft Farms, Gallagher Beach, Riverkeeper, and 21st Century Park on the Outer Harbor for their efforts, and to Mother Nature herself for transforming a former port into an intriguing and beautiful landscape.

In the end, the Sierra Club has two requests.

  1. We ask for an open discussion on first principles so that we can create a shared vision of the Outer Harbor before we start designing it.
  2. We ask for your reconsideration of the ‘preferred alternative’ and to offer the public real alternatives that are not just the same program moved around on the board.


Lynda Schneekloth, Chair
Sierra Club Niagara Group

[i] We have seen the use of the image from the charette of the Congress of New Urbanism done in 1 ½ day last spring as if this is a serious proposal for the Buffalo Outer Harbor. The designers from the Congress of New Urbanism would have presented the same plan for housing/neighborhoods if asked to do it at Riverbend or abandoned railroad yards. The proposal has no foundation in the physical, economic or social context. We ask that you stop using it as an exemplar of serious planning for the waterfront.

  1 comment for “Sierra Club, Buffalo Niagara, responds to Perkins+Will Preferred Plan for the Outer Harbor

  1. waltolszowy
    September 17, 2014 at 5:26 pm

    This is a really well thought out response. This has been one of my biggest complaints of this ‘public process’ The Process has not been in reality all that public. That was particularly evident in the August meeting, when they just rushed us through the renderings like cattle, not explaining any of the key points of the plans or even allowing any time for Q & A. We need to make sure we do our best to prevent the over development of this precious public property.

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