I am writing regarding The Post's coverage of the Giuliani administration's sale of community garden sites in New York City ["Mayor Giuliani Holds a Garden Sale," front page, May 12; "Plot Twist: $4.2 Million Saves New York Gardens," news story, May 13].

The articles suggest that the city faced a choice between community gardens and new housing. The Post reported that developers are "scrambling to buy once-dismal lots in once-dismal neighborhoods," but that is true for only a relatively small handful of city-owned properties. Most of the parcels on the May 13 auction block, for example, were not suitable for housing or economic development. However, they were located in neighborhoods with a severe lack of open green space.

Earlier this year, I released a study of similar vacant lots in the borough of Brooklyn that were sold through the city's auction process. Out of 440 properties investigated, a mere 6 percent were used productively for housing or other economic development purposes. My report also revealed that more than 60 percent of these previously auctioned properties are undeveloped dumping grounds for abandoned vehicles and garbage.

Based on this study, I and many other New Yorkers concluded that most community garden sites likely will not be converted into more productive uses when they are sold, contrary to Mayor Giuliani's assertion. It is more likely that they will revert to the eyesores they once were.

To prevent this fate, I urged the mayor to institute a sound planning process that would enable an extensive public review of the viability of community garden sites for housing. At my request earlier this year, the City Council introduced legislation that would have placed a one-year moratorium on the sale of community gardens and required a review of each on a case-by-case basis.

Even though these concerns were voiced repeatedly over many months in many public forums, it was only after I and other elected officials and environmental groups went to state and federal court that a satisfactory eleventh-hour solution was found for the disposition of these 112 community gardens.

Although this episode is over, a happier ending would have been for the city to have earmarked the $4.2 million from the sale for the improvement of these gardens. Also, I remain concerned about the future of more than 600 other vacant city-owned properties that may face a similar threat in the future.

HOWARD GOLDEN

President

Borough of Brooklyn

Brooklyn, N.Y.