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MAS Comments on Anable Basin Rezoning

Full Title: MAS Comments on the Draft Scope of Work for an Environmental Impact Statement on the Anable Basin Rezoning Proposal, CEQR No. 18DCP057Q, Queens, NY.

The Municipal Art Society of New York (MAS) believes the Anable Basin waterfront in Long Island City may be an appropriate setting for well-planned and coordinated redevelopment. From an economic development perspective, we also find the potential establishment of an employment hub that would leverage Long Island City’s proximity to Roosevelt Island’s Cornell Tech campus worth exploring.

However, we are extremely concerned about two major issues with this rezoning proposal. One is the magnitude of the development proposed by Plaxall Plastic. The second is the significant cumulative environmental impacts that are very likely to occur as a result of other large-scale development and rezoning proposals in the area, raising the issue of segmentation of the environmental review process.

map of the Anable Basin Study Area

Figure 1: Potential Segmentation: Two ongoing projects within Anable Basin study area

Therefore, we call on the City to conduct a coordinated review of the cumulative environmental impacts of the Anable Basin Rezoning, the New York City Economic Development Corporation’s (EDC) Long Island City (LIC) Waterfront Project, and the Department of City Planning’s (DCP) LIC Core rezoning. The full array of potential effects and mitigation measures must be accurately identified, measured, and evaluated.

Background

Plaxall Plastics is proposing a series of zoning actions (Proposed Actions) that would create a 15-acre Special Anable Basin Mixed-Used District, including 13 major development sites. The development proposes five primarily residential towers, ranging in height between 500 and 700 feet, a public waterfront esplanade, and an off-site public school.

According to one of the two Reasonable Worst-Case Development Scenarios (RWCDS) described in the project DSOW, the rezoning would result in a maximum of 13,487 new residents, 4,995 additional dwelling units (25 percent of which would be affordable), 122,651 square feet (sf) of retail, 254,520 sf of light industrial, and 134,695 sf of open space, for a total over 5 million sf of new development.

Comments on Draft Scope of Work

Unprecedented Scale – The impacts of the development substantially exceed CEQR thresholds for all 19 environmental categories outlined in the CEQR Technical Manual. Each will require extensive evaluation. As an example of the scale of proposed development, CEQR requires an expanded analysis on open space when a project would introduce 200 new residents. The rezoning exceeds this threshold by a factor of 65!

In terms of population, the proposed rezoning surpasses all the other large-scale residential rezonings initiated under the de Blasio administration, with the exception of the 2016 East New York rezoning. On a dwelling unit level, the nine neighborhood studies conducted by DCP under its PLACES initiative would result in a range of between 2,500 and 3,500 new dwelling units. The Anable Basin Rezoning would result in almost 5,000.

Community Outreach – Although we recognize that this is a private application, MAS recommends that Plaxall conduct outreach within the local community during the environmental review process due to the immense scale of the project and the potential for long-term impacts.

Potential Environmental Review Segmentation – As previously mentioned, there are two other significant projects proposed within the Anable Basin Rezoning study area: EDC’s LIC Waterfront Project, adjacent to the north, and the LIC Core rezoning, to the east (Figure 1). The LIC Waterfront Project, which proposes commercial, retail, and housing redevelopment and a new 80,000 sf school, is of particular concern because it is within a 400-foot radius of the Anable Basin Rezoning, the area in which the most significant impacts of both proposals are expected to occur (Figure 2). The EDC project in itself would result in 1,250 new dwelling units and add almost 2,600 new residents and 1,500 workers to the area.

Based on guidelines provided by the New York State Department of Environmental Conservation (DEC) on segmentation in the environmental review process, MAS finds that these three projects share a number of factors that could point to potential segmentation:

Location

The three projects share the same study area. The LIC Waterfront Project consists of three City-owned properties. One (Block 24, Lot 7) is managed by the Department of Transportation (NYC DOT). The other two are on Block 489 (Lots 23 and 15) and are managed by the Department of Citywide Administrative Service (DCAS) and the Department of Small Business Services (SBS), respectively. Each property is within the 400-foot radius of the Anable Basin Rezoning project area.

satellite image of the Anable Basin Study Area

Figure 2: Potential Segmentation: LIC Waterfront Project within Anable Basin 400 foot study area

For the DCP LIC Core rezoning project, approximately one-quarter or 1.6 million square feet of the project area is within the Anable Basin ½-mile study area.

Time

The three projects share common construction periods and active development would occur during the same time period. The Anable Basin Rezoning would have active development between 2020 and 2034. Although a build-year has not been disclosed for the LIC Waterfront Project, the EDC RFP stated that public review is expected to start in 2018. Therefore, the construction is likely to occur within the 2020-2034 time frame.

A build-year for the DCP LIC Core rezoning has also not been disclosed. However, based on the respective timetables for recent large-scale rezonings under the PLACES initiative, including Jerome Avenue, East Harlem, and East New York, which have all been projected at least 10 years into the future, it is reasonable to expect that the LIC Core rezoning would also fall within the 2020-2034 time frame.

Impacts

The impacts of the Anable Basin Rezoning and LIC Waterfront project would affect the same area. The two projects combined would bring 20,180 new residents, almost 30 percent more than what is identified in the Anable Basin Rezoning’s Reasonable Worst Case Scenario I (RWCDS), which proposes more residential development. In this scenario, the CEQR trigger for open space impacts would be exceeded by a factor of 78 instead of 65!

Although information on new population expected under DCP’s LIC Core proposal is not available, the previous rezonings under the PLACES initiative have resulted in a range of between 2,500 and 3,500 new dwelling units. If the LIC Core Rezoning added new dwelling units within this range the new residential population would be expected to be over 10,000.

If the three projects were to be evaluated in conjunction with one another, the total population would increase two-fold, from 15,681 to approximately 30,181. In this scenario, the CEQR trigger for additional open space evaluation would be exceeded by a factor of 125!

Purpose

The three projects have common goals. As stated in the Anable Basin DSOW “Purpose and Need,” the rezoning proposal is aligned with the New York Works plan to create high-paying jobs, the Housing New York plan to create affordable housing, and the Vision 2020 Comprehensive Waterfront Plan to guide responsible waterfront development.

Based on the DSOW narrative, the Anable Basin Rezoning would achieve a number of City goals, including increasing appropriate density, creating diverse employment and business opportunities, mixed-income housing, and access to the waterfront, among others. Similarly, according to the project RFP, the overarching goal of the EDC Waterfront Project is to create an economically diverse mixed-used development by including commercial and light manufacturing, providing affordable housing and creating publicly accessible open space on the waterfront.

The LIC Core rezoning also shares these goals. According to the PLACES initiative website, the LIC Core study seeks to foster commercial development and job creation, as well as increase mixed income housing.

Recent City Position on Segmentation – The City recently addressed segmentation when it called for a coordinated review of the Two Bridges Large Scale Residential Development as one project rather than three separate land use actions in the Lower East Side of Manhattan (CEQR No. 17DCP148M) in 2016. Elected officials had expressed concerns about potential segmentation if all of the actions in the area weren’t reviewed together. In response to these concerns, Carl Weisbrod, the former chair of the City Planning Commission (CPC), called for a coordinated review of all three actions in an EIS to ensure that full cumulative impacts were evaluated. 1

Therefore, MAS urges the City to implement a coordinated review of the three projects and properly address potential cumulative environmental impacts in the Final Scope of Work (FSOW).

Cumulative Impacts – In addition to the EDC and LIC Core projects, the Long Island City area is expected to see substantial growth fostered by numerous zoning changes approved over the past decade (Figure 3). These actions have already increased the area’s population substantially. For example, Queens Census Tract 1 – the location of the Anable Basin Rezoning – experienced a 261 percent increase in population between years 2000-2010.

map of the Anable Basin Study Area

Figure 3: Approved zoning changes within the Anable Basin Study Area: modifications to Southern Hunters Point District (approved in 2008 with build year amended to 2025) and Southern Roosevelt Island District (Cornell Tech approved in 2013 with build year 2038)

This increase can be partially attributed to the creation of the Southern Hunters Point Special District in 2008. According to project documentation, approximately 2,000 residents will have moved into the Special District by the year 2025. This will also increase population in the Anable Basin project area during an overlapping timeframe (2020-2034). 2

The Cornell Tech Campus on Roosevelt Island is another nearby development to consider in the DEIS cumulative impacts evaluation. It is expected to add 5,400 people (3,203 academic/research and 2,228 workers) to the area by 2038. This anticipated growth overlaps with the development period of Anable Basin Rezoning.

Based on these factors, the DEIS must take into account substantial population increases and create a proper framework to evaluate the cumulative environmental impacts of all the ongoing projects in the Anable Basin Project area.

Community Facilities and Services – Schools

Schools in Queens School District 30 are already overburdened. According to the Independent Budget Office (IBO), District 30 needs approximately 3,400 additional seats to reduce overcrowding. 3In itself, the Anable Basin Rezoning is expected to add approximately 2,700 school age children to the area.

Even though the proposal includes one new offsite public school with a total of 728 new seats, the DEIS must evaluate current and future public school utilization rates. It must consider the cumulative incremental population increases projected for the entire study area to determine if these additional school seats sufficiently accommodate the projected growth.

If the DEIS indicates area schools remain overcrowded, clear mitigating measures, included funding sources and potential additional schools, must be identified.

Open Space

The addition of approximately 12,900 residents and 2,700 workers under the Anable Basin Rezoning is expected to place significant demand on existing open space resources in the project area. According to the DSOW, the project area currently substantially exceeds the respective residential and worker analysis thresholds.

Therefore, the DEIS must evaluate the incremental changes to residential and nonresidential open space ratios by 2036 for the entire study area and identify appropriate mitigating actions, if applicable. Given the anticipated new population, the additional 135,000 square feet of open space proposed under the rezoning will fall short of the city goal of 2.5 acres per 1,000 residents.

Additionally, we question the feasibility of the creation of 135,000 sq ft of new open space. Based on our estimations, the shore public walkway, required under the Hunter Point Waterfront Access Plan (WAP), will create approximately 75,000 sq ft of new open space. It is not clear in the DSOW if the remaining 60,000 sq ft of open space would come from the upland connections and flexible lane zones or another area.

According to the massings for development under the RWCDS, the upland connections (particularly on Site G) and some of the flexible lane zones are depicted as being built out. To clarify what is actually being planned for open space, we expect the DEIS will include an open space plan that clearly shows the relation between the flexible lane zones, upland connections, and the projected building massings. Otherwise, by our calculations, the open space increment would only be approximately 75,000 sq ft, instead of the 135,000 sq ft included in the RWCDS.

Finally, because the rezoning area is within the current and future flood hazard zones, the DEIS must identify and evaluate specific strategies and measures for how the proposal will address climate change impacts, storm surge resiliency, and flood mitigation in the waterfront areas as part of the WAP. We expect the evaluation to address these factors in relation to existing and proposed buildings along the riverfront, infrastructure improvements to the riverfront area, view corridors connecting the waterfront to the rest of the neighborhood, and access points to the river.

Shadows

Given the height and proximity of the proposed towers under the Anable Basin Rezoning, we expect there to be significant shadow impacts on the East River. These are discussed under “Natural Resources.”

The DEIS must identify mitigation measures that eliminate or reduce shadow impacts to the greatest extent practicable. We also expect that the DEIS shadow analysis will indicate specifically which buildings would create the incremental shadows effecting the East River.

Natural Resources

Because of the expected shadows on the East River, the DEIS natural resource evaluation must examine impacts on specific marine species and habitats. The analysis must include a summary of the results of a new Essential Fish Habitat Study (EFHS) to accurately evaluate the potential impacts on ecological conditions in the river. We also request that the DEIS include the EFHS report and any State and Federal wetland permit applications and correspondence with DEC and the US Army Corps of Engineers as appendices.

Hazardous Materials

Because of the historic manufacturing and industrial land uses in the project area, many sites within the rezoning area are under the State’s Brownfield Cleanup Program. Therefore, the DEIS hazardous materials evaluation must summarize the findings of the Phase 1 Environmental Site Assessment and if applicable, the Phase 2 Environmental Site Investigation.

The evaluation must discuss the expected and approved remediation actions required under the Brownfield Cleanup Program that would bring the applicable sites into compliance for redevelopment. We also request that copies of the Phase 1 and Phase 2 reports are included as appendices to the DEIS. This is particularly pertinent given the potential siting of new public schools on currently contaminated property.

Energy, Air Quality and Greenhouse Gas Emissions

We expect that the DEIS energy evaluation will go beyond merely disclosing the projected energy demand of the new development under the rezoning. Based on the magnitude of the development expected, the evaluation should analyze the energy efficiency of the proposed developments in comparison to minimum requirements for LEED certification or an equivalent environmental standard.

The DEIS should also provide a detailed analysis of the sustainability measures that will be employed to reduce greenhouse gas emissions in line with New York City public policy, including but not limited to, design guidelines that promote sustainable demolition and construction methods, green roofs, tree planting, new open space, and state-of-the-art energy efficient HVAC equipment. MAS recommends for these and other environmental factors to be evaluated as an Optimal Sustainable Development Scenario alternative that demonstrates application of sustainable practices at the highest achievable standards.

Furthermore, as mentioned in our discussion regarding the WAP, because of the development will occur within the 100-year floodplain, with many street elevations significantly below the base flood height, we expect the DEIS will include detailed drawings and descriptions of the resiliency design measures that will be implemented under the plan.

Traffic and Transportation

The projected incremental increase of more than 15,000 residents to the study area will undoubtedly strain existing transit infrastructure, affect traffic patterns, and increase greenhouse gas emissions due to increased automobile trips in the area. The nearest transit hub the project area is the Court Square complex, where the E, G, M, and 7-lines converge. Court Square saw an almost 8 percent increase in average weekday ridership between 2011 and 2016 4, with the E and 7 trains carrying over 100 percent of their maximum load guidelines during peak morning rush hours as of 2016. 5 We expect these conditions to be exacerbated by the development under the rezoning.

As a result, the DEIS must identify clear and realistic actions to mitigate these conditions given the cumulative anticipated growth of population and ridership in the study area.

Construction Impacts

Given the scale of the expected development, the multiple construction sites, the 15-year construction period, and the substantial construction that will occur near the proposed EDC school site, the construction analysis must include details on the timing and sequencing of construction activities in relation to other projects in the area, as well as an evaluation of construction traffic, air quality, and noise on nearly residences, schools, and hospitals. We also expect a robust evaluation of mitigation measures to address the construction impacts.

Conclusion

The Anable Basin Rezoning proposal will bring about a massive increase in development and population to the Long Island City waterfront. The environmental impacts are expected to be significant. When these impacts are considered in concert with the planned EDC development and the LIC Core rezoning, and with the understanding of the population growth that is currently occurring in Long Island City, it is incumbent upon the City to conduct a comprehensive coordinated review that takes into account the full cumulative environmental impacts of these actions on Long Island City.

We remain steadfast in our concerns about segmenting the environmental review. The risks of separately evaluating these actions may result in severe unmitigated environmental impacts that will affect the neighborhood for generations.

In taking a comprehensive approach to the environmental review, we hope the City sees the opportunity to create a truly complete and livable neighborhood along the Long Island City waterfront. Given the scale and potential for long-term adverse impacts on the Long Island City area, Plaxall Plastics must engage in meaningful community engagement before the rezoning proposal can be advanced.

MAS recognizes the importance of accommodating growth in the city, and believes the Anable Basin area and Long Island City in general provide the necessary conditions to foster well-planned and managed growth. However, in order to ensure this vision, it is paramount that all environmental factors are addressed comprehensively.

Thank you for the opportunity to provide comments on the DSOW.

  1. Response letter from City Planning Commission chair Carl Weisbrod regarding Pre-Application Statements (PAS) for Two Bridges Manhattan Block 246, 247, and 248. August 11, 2016
  2. Technical Memorandum 005 CEQR Number 08DME006Q Hunter’s Point South Rezoning and Related Actions. November 30, 2017
  3. Testimony of Sarita Subramanian Senior Education Budget and Policy Analyst, New York City Independent Budget Office to the New York City Council Education Committee on Overcrowding in the City’s Public Schools and Plans for Increasing Capacity. March 3, 2015.
  4. MTA, “Facts and Figures,” 2016.
  5. NYPIRG Straphangers Campaign, “State of the Subways Report Card,” 2016.