Too Close For Comfort: DUMBO Development to Abut the Brooklyn Bridge
March 5th, 2009, 8:26 am
The Municipal Art Society yesterday testified before the City Planning Commission expressing our concern about an 18-story building adjacent to the Brooklyn Bridge in DUMBO. While 18 story buildings are not un-common in DUMBO, this site on Dock Street between Water and Front Streets, across the street from the Empire Stores at left (MAP), is exceptional because it abuts the Brooklyn Bridge — a local, state, and national landmark. In fact, a portion of the development site even runs underneath the Bridge’s span. The Brooklyn Bridge is one of New York’s most iconic historic structures, and it is one of only 11 National Historic Landmarks — the highest recognition a building can receive in America — in Brooklyn. As such, it should be protected from large-scale development encroachments. MAS believes that the development proposed for the site will mar iconic views both of the bridge from DUMBO’s streetscapes, and from the bridge of DUMBO, the Manhattan Bridge, and the East River. The development is currently going through the city’s land use review procedure for zoning changes. ULURP Review of the Dock Street Development, DUMBO, Brooklyn Given Before the City Planning Commission Tuesday, March 4, 2009 The Municipal Art Society’s Preservation Committee reviewed the EAS and the ULURP actions before the Commission today in light of the effect the new development would have on the area’s architectural resources, particularly the Brooklyn Bridge. We are concerned about the bulk, height, and configuration that these ULURP actions will allow and their adverse impacts. The CEQR manual directs the assessment of adverse impacts on architectural resources to question whether the change is “likely to diminish the qualities of the resource – including non-physical changes, such as context or visual prominence – that make it important.” Without a doubt, in this case, the new development allowed by the ULURP actions will diminish the context and visual prominence of not only the Brooklyn Bridge, but also the DUMBO local and state/national register historic district and the Fulton Ferry local and state/national register historic district. In light of the adverse impact to the historic resources, particularly the Brooklyn Bridge, we ask that these ULURP actions be rejected. MAS has long scrutinized development adjacent to the Brooklyn Bridge that would affect the Bridge’s integrity and alter views both of and from the Bridge. The Brooklyn Bridge is an indisputable icon of New York City, and protecting it from encroaching large-scale development is of utmost importance. The Brooklyn Bridge is no ordinary historic structure; it has been afforded the highest level of recognition and protection in the United States, that of National Historic Landmark status. It is one of only 11 National Historic Landmarks in Brooklyn, and as such, is recognized as being of “exceptional value to the nation” as a whole. Under federal regulations, federal undertakings that adversely affect a National Historic Landmark must be minimized “to the maximum extent possible” (36 CFR 65.2 “Effects of Designation” (c)(1-7)). Even if it no federal action is involved in this development, we believe that this directive should be applied to the site in order to protect the integrity of this national treasure. An 18-story building directly adjacent to the Brooklyn Bridge is simply not acceptable. The EAS for this project justifies the height of the new development by comparing it to other historic buildings in the neighborhood, including the Gair buildings, 30 Main Street, and One Main Street. It claims that the new development will “relate in height and bulk to several of the taller loft buildings in the area.” However, these buildings are not located directly adjacent to the Bridge and therefore do not adversely impact the Bridge’s historic integrity. By contrast, the development site directly abuts the Brooklyn Bridge, with a portion of it actually running underneath the Bridge. The 18-story portion of the building, although set back somewhat from the Bridge, still sits too close to its span. The distance between the 18-story tower and the Bridge is not an adequate to minimize the adverse impact of the development on the views of the Bridge from the street and the iconic views of DUMBO, the Manhattan Bridge, and the East River from the Bridge. We find that the EAS fails to assess just how much of an adverse impact the new development’s height and proximity will have on the Bridge. For instance, there is no mention of the specific architectural importance of the Bridge’s anchorage, one of the most significant features of DUMBO’s streetscape, and how this development will adversely impact that feature and views of it. Moreover, other ways to reduce and/or reconfigure the building’s bulk were not adequately examined in the EAS. Lastly, we question whether or not the NYC Landmarks Preservation Commission has any jurisdiction over this site, since a portion of it does run under the Brooklyn Bridge and is therefore part of the landmark site. The 1967 designation report for the Brooklyn Bridge lists Brooklyn Block 36, Lot 1 (in part) as part of the landmark site. Since this also happens to be the development site before us today, we believe an LPC permit is required for this development. We have reached out to the LPC about this matter. In conclusion, the adverse effect of approving these ULURP applications that permit the proposed development are too great on the architectural resources of the Fulton Ferry Historic District, the DUMBO Historic District, and, most importantly, the Brooklyn Bridge.