Comments to the Final Environmental Impact Statement For the proposed Brooklyn Atlantic Yards Project Prepared by Valdlla Kaagys (0299) 206 Washington Park #2 Brooklyn, NY mos Wm December I, 2006 I would like to thank those who prepared the F818. 1 submitted 33 comments plus a public testimony. l2 comments were responded to. Nevertheless. I feel that two of them did not correctly address my concern. See below: 24.209: The FEIS fails to address my comment l2-4. 1he de-mapping of sheets will adversely affect traffic congestion. safety. and pollution. The 818 stated that de-mapped streets would create ?a number of design features that would enhance overall safety. including the elimination of several roadway segments through the project site." but it failed to justify this claim with evidence. Is the implication that view corridors are sufficient substitutes for a public right of ways? 24-2?: The FEIS failed to address askingto show evidence that de-rnapped streets and disproportionately tall buildings will improve connections between neighborhoods. The does explain how the open space in the project with improve connections but it fails to addreas how de-mapped streets and extremely tall buildings amidst brownstone Brooklyn will fit into the surrounding environment. othercommeatswereaot even addressed. Alter comments. In addition. the FEIS places my number (299) in 24-42. grouping me together with projectshouldbereduced. Please see my commentstothe followingthisnote. [have marked the teat inbluetoshow question;andlleflthetextblaclt I look forward to herring from you. Sincerely. Vaidils Kungys 206 Washington Park #2 Brooklyn. NY 1 1205 Wham TRAFFIC AND PARKING 12.2 The 0513 fails to analyse traffic adequately because of poor methodology?the intersections studied were too few and too close to the project site. In fact. 40 intersections within a quarter mile of the project site were not even looked at. It is not acceptable to plan for an additional 15,000 people and fail to analyze important intersections just two blocks away from the project, such as at Fulton and Clinton. 12-3 - The Traf?c Impact Analysis states that 73% of the intersections studied will be adversely affected by the time the project is completed in 2016. What about before 2016? Many intersections will surely be adversely impacted when streets are de-mapped before construction even begins. In addition. considering that most of the analyzed intersections were located within 56 mile of the project site, what adverse traffic and congestion impacts will the project have for Brooklyn and for Manhattan? 12-4 - The DEIS states that the project would incorporate ?a number of design features that would enhance overall safety. including the elimination of several roadway sepnents through the project This claim ls not supported. De-mapped streets will lead to more congestion and therefore less safety. De-mapped streets will significantly increase traffic around the project site and thereby increase the number of automobile-related accidents. To substantiate the claim that eliminated roadways will enhance safety; the EIS should provide data to corroborate this claim. 12-4 - In addition. the DEIS states that to ensure safety during games. ?police and trafilc control of?cers would be deployed at ltey intersections in the vicinity of the area. . This project should not plan to use publicly employed ofiicers to mitigate unsafe streets. which the project itself will generate. instead. the project should address the source ofthese unsafe streets. which is perhaps the TRANSIT AND PEDESTRIANS Atlantic Avenue subway station. In the 0818. table 13-3 shows that turnstile counts increased 12% in 2005 (24,573 to 27.559), and 13% the previous year. The actual historical growth rate of this station?sridershipistherefore names. The assumed growth rate of 0.5% is thaefore not consistent for all neighborhoods and should not be used for this project. 13-82 - Considering the addition of some 15,000 residents as a result of this project, the DEIS does AvenueJPacific Street subway station complex is not expected to be An additional MITIGATION 19-55 - Elimination of west crosswalk on 4? Avenue at Atlantic Avenue. The elimination of this crosswalk will force pedestrians to the center island named Times Plaza. Since many more pedestrians willbe will be a higher risk of automobildpedestrian accidents. what will be the impact of added pedestrian crossing from this island? This crosswalk should be studied further to ensure pedestrian safety. URBAN DESIGN 8-2 - The DEIS states that the project would be dramatically different from the surrounding neighborhood?s design and it would ?enhance the vitality of the area and foster connections between How would dramatically different buildinp lead to better neighborhood connections? lt is likely that a drastically different environment will isolate and separate the existing neighborhood from the new neighborhood. especially considering the breaks in the street wall. and enormous heights (that will cause increased shadows). and de- mapped streets. which hold together the sense of connections in urban settings. To justify the claim that this dramatically different new neighborhood will enhance connections. the DEIS needs to show evidence that dc-mappcd streets. disproportionately tall buildings. and open space within a private compound will. in fact. improve the connections between neighborhoods. 8.23 Future without Proposed Project - it cannot be assumed that ?the project site would remain unchanged and would continue to be inconsistent with the visual character of the surrounding area." In fact. development is already spurring inlill within the same Va mile area. with several new buildings being constructed just one block from the project site at Dean and Carlton. in addition. the underlying zoning may change very soon since there is significant interest from real estate developers to build over the Atlantic Yards. in fact. the NYC Department of City Planning is currently preparing to rezone the Fort Greene/Clinton Hill neighborhoods and has stated that the review process for this rezoning should begin by the end of 2006. The northern side of Atlantic Avenue will be up-zoned in this rezoning project. Therefore. it is false to assume that the Atlantic Yards will not be rezoned. A clear example ofthis is taking place at the Hudson Yards in Manhattan. which were originally slated for the development of the construction of the Jets Stadium and Olympic Center and are now being planned to sell for non-stadium development after completionofthc platform. develop the site will continue regardless ofwhether or not the initial plan was realized. it is completely likely, hence. that local groups and elected of?cials work to rezone the site and then develop a plan with greater local participation to realize a different and better project that becomes a long-term visual and cultural resource. This possibility should not be discounted. as it is in the DEIS. outdoor space. The space is described a ?a publicly accessible covered pedestrian space providing main terminal at Grand Central Station in Manhattan. Why is this space being called a publicly accessible open space if it?s covered and has walls? Shouldn?t this place be called the foyer to the building and subway entrance? Regardless what this space is called. it is not Open space and its area 8-26 - Visual Resources This section is misleading and inaccurate. De-mapped streets do result in theurban understanding of his/her location in respect to what is beyond the de-rnapped street. and it removes in perpetuity the opportunity to build a signi?cant visual structure within that view corridor. 8-28 Street Pattern. Street Hierarchy. and Block Shapes - This section is simply false: the proposed project will adversely affect street patterns. in de-mqsping three streets the project is essentially removing over l24.000 square feet of public though space (the area of the de-mapped roads) currently used for the free transportation of automobiles, pedestrians. and bicycles. By removing over a V. mile of public roads the project destroys the street grid. creating fewer places to access the surrounding neighborhoods and risking increased traf?c and congestion on other roads. egress for pedestrians, cyclists. and automobiles. The proposed project will adversely affect street patterns. 8-28 The project would alter a streetwail that is consistent and clear: buildings front the street line. The proposed project would set back buildings. which would not create strong streetwalls; rather. the setback buildings would detract horn the consistent Brooklyn framework where most buildings front the streetde so that the line of sight along a block is consistent. A consistent streetwali helps to maintain a uniform structure while allowing individual buildings to have signi?cantly different architectural styles. The streetqu should be maintained and altering would harm the project?s connection to the surrounding neighborhoods. 8-29 - Spelling error - The closure of 5" Avenue (between Flatbush and Atlantic) would significantly add traffic to both Flatbush and Atlantic creating more congestion and more pollution sentence where itisstatedthatthestreetclosure would help. ?by eliminating intersections that are near on another?" 8-29 - Visual Reaourees- Howcan itbeeatpected that theproject will ?make positive contributions shadows. it will removethevisuai corridors produced by the de-mappedstreets, it will notprovidea To make area. the projectwouidhave to scale down its size significantly. maintain the street grid. andpiace OPENSPACE therefore not consideredimpacttiueshoids.? To why the goaisarenotconddered feasible forpartsof the city. DoestheCity of New York claim aibeitachievable. goals? mention Coney lslandbecause ittoo is accessible ?om theproject site. Discussingparksoutsidethc should not be mentioned in the F518. 6-15 -0pcn SpacewithouttheProposedProject space are ?expected" to occur without the proposed project. This is an unsubstantiated assumption. In fact, therehasbecn liketobuildaplatform abovetherail yardstodevelophousing. forthe Atlantic Yards. Should this project fail to materialize a different project may develop a park that is not only publicly accessible but a truly public venue. such as Fort Greene Park or Bryant Park. 6-23 Open Space; Probable impacts ofthe proposed project - 20l6 - ln l6-l0. the DEIS describes the Atlantic Terminal Houses: ?This development has a tower-in-theeparlt configuration. which consists of a residential tower surrounded by lawns. trees. walkways. benches. and playgrounds.? This description appears to describe the style at the project site. The DEIS should state whether this project is planned to be in the style of tower-in-the-park and if not. it should explain how this project is not of the tower-in-theoparlt genre. This is important because urban model becausetheopen space is perceived as private or semi-private. thereby discouraging the public to use it. If this project is planning to construct a development in a style that has already been tried unsuccessfully. then an alternative plan should be chosen. such as the Reduced Density Arena Altemstive. 6-23 - Bicycle path through Blocks ?20. a ll29 -The DElSstatesthat a bicycle path ?would alsobe sitetothe accessibilityot'theopen space." Nevertheless, in the next paragraph it states that ?The open space would be available for public use from 7:00 AM to l0:30 PM from May through September. and from 7:00 AM to the later of8:00 PMandsunset route will notactasafunctional transportation route because it will be closed at various timesot?the day. This is not consistent with basic transportation planning concepts. How can the project claim to provide a bicycle path that will lt'abicyclepathis planned to pass through the project site. it needs to be accessible twenty-four hours a day. every day. 6-24-0pen Space (and challengetoCEQRde?nition ofopen build version scenarios equally. the net change in publicly accessible open space must be documented. In the build scenario, over 124,000 square feet (2.75 acres) of public open space are removed in the tie-mapping ofthe 5? Avenue and Pacific Street. Although CEQR states that streets wrong: Streets are public rights of way; they are not private. Streets should be considered at least sidewalhtoenjoy a leisurely bicycle ride. toplay neighborhood. Perhapsitwouldbebestto Passiveopen space. isclassifiedas ?passive.? Facilities may includethefollowing; areas (sunbathing). picniclring areas. and esplanades (sitting. strolling). paths. accessible areas used. for example. for streilag. dog walking. and bird watching. Therefore. a road's removal should be tantamount to the removal of public open space. indeed, the proposed Iocationsasopenspace. The factisthattheroadswere l00% of the time 24 hours a day). while the proposed project?s open space would be publicly accessible open space only 50% of the time because it would be closed in the evening hours. Further. demapped streets are both active and passive publicly accessible open spaces. After subtracting the roads that are proposed for tie-mapping due to this project. the net increase in publicly accessible open space is only 4.24 acres. not 7 acres. Therefore. 4.2 acres is the approximate figure that the project should use when assessing the project's impact on open space. In addition. even considering unreasonable position that streets and sidewalks are Chapter 3. Table of Contents. Definitions. Open Space) that private open space not included in the quantitative analysis but may be considered in the qualitative assessment of potential open space impacts.? Therefore. the 818 should state qualitatively that. when taken into account. the de- mapped streets' elimination would lower the increue of the proposed project?s open space. Or stated ll20. ll2l.and ll29 wouldbeanintegralpartofthe development ?facilitatingconnections will beclosed for approximately half of every day; it will have limited access points; and it will be private space. Therefore. thee?'ect of open spacemay actually severneighborhood connections by isolatingthissite from the spaceswould be deededtoenot-for-prefit entity establishedby the project sponsors tomaintainand operate." ls itarealistic expectationtoplan publicly should maintenancebeplannedandpaid Perhapstheresidents would haveahigher maintenance This bepublic; anonproiitorgovernment agency take ituponthemselvestomanageand operate. 6-26-Openspace much as the 0818 claims that it will be it does not take into consideration the loss of publicly accessible open streets that. after being de-mapped, take away the public?s ability to stroll. bicycle. play Frisbee on a calm Sunday afternoon, or just sit to enjoy the streetscape. The amount of additional open space therefore is approximately 28.2 acres in 20l6 (and not 30.95). 6-28 states?1heproposedproject would affectanopenspace in another way." This is another spelling error. 6-28 Shadows on the Atlantic Terminal Houses - The states that shadows would create adverse effects on the Atlantic Terminal Houses and that ?on the cooler analysis days when shadows are longer (March/September and December). the duration and extent of the shadow coverage would adversely affect users as these shadows might diminish the attraction to use this open space resource.? This adverse effect is not simply an issue of open space. but of environmental justice. The residents of the Atlantic Terminal Houses are mostly of lower income and minority families. and the proposed project could place undue burdens upon them due to their close proximity to the project site. The effects of shadows need to be malyaed more closely to ensure that lower income. minority families are not disproportionately affected by this project 6-28 Qualitative Considerations ofOpai Space - in regard to the Reduced Density Arena Alternative. in 20-61 the states ?The pocket parks would be surrounded on three sides by new residential buildings; therefore. they may not be perceived as public parks by other residents of the community." Nevertheless. this is not memioned in the Chapter 6 (Open Space) for the proposed project. Why not? The fails to be consistent in methodology. If it is assumed that pocket parks logic.itwould buildings would similarly not be perceived as public space by outside residents. This is yet another clear example to shows that the 0818 is inconsistent and filled with poor meaning NEIGHBORHOOD CHARACTER l6-l sitewould notalterthebasic located designations.? This claim is completely unjustified and countaintuitive. How can it be claimed that over l6 tall within 2-5 traf?c will would not alter the basic character of the surrounding nei?iborhoods? In addition, the de?ning elements neighborhoods are not located ?at somedistance away" from theproject site, they sit literally across the street from the project site. Shadows will cast much furtherthm Dean Street. they will go well into Park Slope and Fort Greene. l6-2 Transforming a community - The states that ?the overarching goal of the proposed project vibrant mixed-use community." Nevertheless. the project that FCR is proposing goes counter to many accepted principles for developing successful communities. The Municipal Arts Society echoed this when their representatives stated on June I6. 2006 that certain principles must be followed to bring about a successful project. These principles are summed up as l) Respect the existing neighborhoods; 2) Don?t eliminate streets; 3) Create a real public park; 4) Promote lively streets; 5) Don't choke the streets. This project should follow these guidelines, especially considering the amount of public subsidies that are going to the developer. UNAVOIDABLE IMPACTS Chapter 2l-3 Shadows - The states that an unavoidable adverse effect would be the casting of shadows. It states: ?Reducing the height of these structures would be inconsistent with the goal to establish a high-density. mixed-use project in an area that is well served by necessary infrastructure. particularly transportation.? It would not be inconsistent with the goal of establishing a high- density. mixed-use project to reduce the heights of the proposed building In fact. according to a residential permit parking study that was commissioned for the Downtown Brooklyn Council. the nearby communities of Fort Greene. Brooklyn Heights. and Boerum Hill are some of the most densely populated areas in the country. with over 32.000 residents per square mile. This project does not have to build over 8 million square feet of mixed-use space to achieve a high-density project. The typical neighboring blocks maintain about 75 building each. and each one is about 4.5 stories tall. Therefore neighboring block to the project provides about 375 floor-through apartments per block. The proposed Atlantic Yards projects spans approximately 5% blocks. so at the existing neighborhood scale 75, 4-5 story building per block) the site would create some 2062 floor- through apartments. Nevertheless. by reducing the residential component of the proposed project by 50%. the product would still make qrproxirnately 3.000 residential units. which is 50% more dense than the surrounding neighborhoods. Reducing the heights of the proposed project's building is not inconsistent with the goal to create density. and it would avoid the negative impact ofshadows on surrounding building and neighborhoods It is not reasonable to state that any reduction in density would be ?inconsistent with the goal to establish high-dauity.? A reduction in density from 8.7 millionsquare feettoSmillionsquare surrounding neighborhood. a 5 million square foot project would still be very dense indeed. FRAMEWORK 2-3 - Public Review - The public review process conducted by the lead agency. the ESDC. was poor and lacking sufficient planning. The public hearing on August 23. 2006 began late and little timewas giventothepublictocomment. In fact. nearly? the lendagencyallowed meetingwas apublic Thiswasoneertampleofthe lead agency's failure to provide suf?cient public review. Other failures include the lead agency?s inconsistency of timekeeping during speakers' comments; the choice of a small venue for such a large and contentious project; the failure of the lead agency to fairly monitor the venue's entrance policy hundreds of people were locked out); the failure to maintain a civil public hearing by not enforcing measures to counter disrespectful and irreverent behavior con?stently. ALTERNATIVES 1120. and 1121)wouldremain make this claim? wouldre- fails to materialize that anotherproject, even different from theother alternatives. wouldnot rise. The bid Therefore. this isafalse assumption. 20-52 - Reduced Density Arena Alternative The Bills states that the Reduced Density Arena Alternative would create an arena that is too small. ?As described in Chapter 1. ?Project Description." only one National Basketball Association (NBA) arena is smaller than 700.000 square feet. and every facility that has been constructed since 2000 has been larger that 750.000 square feet. The larger footprints of new arenas have been required to meet the logistical considerations of modern. professional sports venues.? The 0818 does not substantiate this claim with any proof. Perhaps most facilities are built larger than 750.000 square feet simply because they are built in locations with more flee space to build. This claim is complme unsubstantiated. 20-61- Qualitative Assessment ofOpen Space - The says that the Reduced Density Arena Alternative would place its largest park to the south of Atlantic Avenue and that ?l?his location is not ideal for a park. It would be bordered on all sides by city streets. including Atlantic Avenue. which carry heavy traf?c volumes." Nevertheless. streets border many of our best parts: Park.Central Park. qualitatively better than most of the proposed project's open space because it would clearly be public private mixed-use development. Also. Atlantic Avenue does carry heavy traf?c volumes but traf?c calming techniques could be implemented to make for safe crossings. Moreover. the added streets (8. Oxford Street and Cumberland. for instance) would provide more opportunities for traf?c calming techniques. such as traf?c lights. bulb cult. improved lighting. and well-painted crossings. neighborhoods. GreeneParkarethosewho open to all. Therefore. the location ofthe park would not isolate the open space from the residential neigiborhood. would be provided under the Reduced Density?Arena Alternative would be less Qpealing for space? rights of way. This claim,thatthe Reduced Density?Arena Alternative wouldbeless appealing for general public use is unsubstantiated. 20-62 Urban Design and Visual Resources - The DBIS states ?The Reduced Density?Arena Alternative proposes to continue the yid pattern ofFort Greene south across Atlantic Avenue into Prospect Heights by extending South Oxford and Cumberland Streets, and Clermont Avenue throughtherail yardonBlocks llZOand 1121 streets would terminate at Pacific Street. creating rnidblock T-intersections and five smaller blocks. and would serve mostly project-generated vehicles." it should not be assumed that a one-block extension of the grid is not simificant. These three added blocks would provide much li?lt and air to the development to make the increased density feel more bearable In addition, the added streets crossasuperbloclr. Rockefeller Plaza