Dear Members of the Philadelphia City Council:

I am writing on behalf of the Southeastern Pennsylvania Group of the Sierra Club to urge you to oppose Bill Nos. 990760 and 990762, which would amend the City Zoning Code and allow for residential re-development of Venice Island in Manayunk.

Our organization is committed to promoting responsible floodplain management. In our educational materials and advocacy work around the country, we strongly support efforts to protect undisturbed floodplains from development, to prevent more intensive re-development in the floodplain, and to restore floodplains through mitigation measures. Restoring floodplain areas along our rivers and streams is a critical ingredient in the overall effort to restore and maintain healthy watersheds. Responsible floodplain management is no less important for the sake of protecting life and property.

The legislative measures before you simply do not represent responsible floodplain management. Nor are they responsible government. Allowing the re-zoning and residential re-development of Venice Island would:

• put more people in harm's way, directly in the path of future floods;
• aggravate the problems that Manayunk must handle in times of flooding emergencies; and
• increase the already heavy burdens on city, state and federal taxpayers for flood damage relief and related public spending.

In addition, approving these bills would forfeit the very significant opportunity that the City presently has to adopt a forward-looking and creative comprehensive plan for Venice Island. In our view, such a plan should be respectful of the island's location in the floodplain of the Schuylkill River, by providing for substantial floodplain restoration and dedicated, open space. It should also address the community's existing needs, especially for improved traffic management.

Twenty years ago a forward-thinking City government adopted restrictions on the types of development activities that could occur in the floodplain, and in the floodway, for the express purpose of ensuring proper protection of its citizens. The City Council found that "development along the existing rivers and creeks within the City of Philadelphia has led to increased flooding, thereby endangering the loss of property and life, creating health hazards, and causing the expenditure of public funds for protection and relief. To prevent such adverse conditions, it is necessary to impose restrictions and regulations on development along rivers and creeks that are subject to flooding. " [City Code and Home Rule Charter, Title 14, Sec. 1606.] Now, so soon after the major flooding brought on by Hurricane Floyd, is not the time for the City to abandon that commitment. Approving Bills 990760 and 990762 would do exactly that.

We believe it is important to draw your attention to an argument that was made during the Rules Committee's deliberations on these bills. The point was made that if financial institutions are willing to back the projects proposed for Venice Island, then they must not represent an unacceptable risk for the City. We urge the members of City Council not to delegate a decision of this magnitude to the banking industry. City officials should recognize that banks are guided by the financial interests of their clients. They provide backing for projects in flood-prone areas as long as the projects are eligible for flood insurance. The City government answers to a different constituency -- its residents. City Council should make the decision as to whether re-zoning Venice Island is in the best interests of Philadelphians, and they should do so knowing that they would be making a long-term commitment of public funds to cover the repercussions.

Around the country we are seeing a growing appreciation of the need for floodplain protection and restoration, as well as a growing recognition that more intensive development in floodplains is foolhardy and dangerous. In the present instance, Philadelphia is facing developers' pressures to make a short-sighted decision that would reap them substantial financial rewards. Giving in to those pressures would invite new public safety risks and place added, long-term burdens on the City's resources and on limited state and federal relief funds.

For the reasons we have stated above, and in the name of common sense, we urge you to vote down these proposals.

Sincerely yours,

Ron Weisen, Chair
Southeastern Pennsylvania Group, Sierra Club