TimesRatnerReport

The influential Municipal Art Society has finally posted its comments on the Draft Scope of Analysis for an Environmental Impact Statement for the Atlantic Yards. (The Draft Environmental Impact Statement, observes MAS, could come as early as mid-February.)

There are many finely grained observations, with several exceprted below, but the most interesting ones come in the section called Alternatives, in which the MAS suggests studying a project that included no arena and buildings with a height limitation of 120 feet (as opposed to more than five times that).

Thinking about density

Another suggestion is for a development with an arena but with a height limitation of 320 feet (about half the current proposed level) and 4.9 million square feet (as opposed to 9.1 million square feet). The suggested Floor Area Ratio is 6.5, not dissimilar from that discussed by architect Jonathan Cohn in his Brooklyn Views blog.

Forest City Ratner argues that adding density allows it to meet its affordable housing pledge. But until we know the costs and benefits of the project, as well as the developer's projected profits, it's impossible to calculate.

And shouldn't the appropriate density be driven by a planning process, rather than a developer?

MAS alternatives

The MAS suggests:

• Study an alternative to reduce land use impacts, that includes the following components:
o No arena;
o 600,000 sf of at-grade retail space;
o Minimal office space, with priority given to community and educational facilities;
o 2300 units of housing with a height limitation of approximately 120 feet;
o 1100 parking spaces;
o Green public walkway, roughly parallel to Atlantic Avenue and a landscaped public park;
o No residential displacement with development limited to MTA site only;
o Extension of existing Fort Greene street grid across the rail yards, creating smaller blocks with more street frontage.

• Study alternative to reduce land use impacts, that includes the following components:
o A non-arena development with buildings at a density of between 3 million sf of development over the yards only;
o An arena development and 4.9 million square feet of development and lower scale with a maximum combined FAR of 6.5 and a height limit of 270 feet for residential buildings and 320 feet for commercial buildings, for a site bounded by Atlantic Avenue, Flatbush Avenue, Sixth Avenue, Pacific Street and Vanderbilt Avenue (to the extent that these parcels would not have to be acquired through eminent domain);

• To increase public access and usability of proposed open space, consider alternative with buildings on sites 5-14 reconfigured. Study alternative that maximizes public access to fully usable open space that is designed to address the specific needs of the existing community as well as new users.

• Study alternative with different mix of uses, including space for high-performing light industrial uses.

• Study alternative with arena reconfigured at Vanderbilt Avenue, where there is more traffic capacity than Flatbush Avenue.

• 5th Avenue is a major connection between Park Slope, Prospect Heights and Ft. Greene. It is also major point of access to an enormous retail center. Alternatives that do not lead to closure of this street should be analyzed.

Taking a broader view of the impact

The MAS observes, as have others, that the environmental review should take a much broader view of community impact:

• The impacts of this development, particularly as it relates to traffic, should be studied in conjunction with the entire redevelopment plan for Downtown Brooklyn, including both proposed and projected development sites identified in the Downtown Brooklyn Rezoning EIS, and the upcoming Fort Greene Rezoning.

STUDY AREA: Proposed ½ mile and ¼ mile study area is not sufficient to determine true land use impacts in certain instances.
1. Study area for traffic and transit should include Grand Army Plaza, the Brooklyn Bridge, the Manhattan Bridge, the Brooklyn-Queens Expressway, and the Brooklyn-Battery Tunnel. Study use of congestion pricing model to control vehicular traffic to arena.
2. Study area for parks and open space should include all of Fort Greene Park and all of Prospect Park. However, these areas should not be included in the required open space ratio for the proposed development.
3. Number of intersections identified in traffic study area should be increased to include all intersections within ½-mile study area. Drivers will seek alternative routes through residential neighborhoods at peak traffic hours.
4. Study area for land use, zoning, and public policy impacts should be increased to include all of the Downtown Brooklyn Rezoning Study Area. • While there are no 197-a plans for the study area, the site is shared by three community districts—Brooklyn 2, 6, and 8. All public policy documents created by the affected community boards, including but not limited to Community District Needs Statements, annual budget priorities, and adopted resolutions pertaining to the Atlantic Yards and development and rezoning proposals such as the Downtown Brooklyn Rezoning, should be analyzed.

• Study the impact of the proposed development on the Clinton Hill, Boerum Hill, Fort Greene, and BAM Historic Districts.

Socioeconomic Conditions

The MAS wants more clarity about jobs:

• In the analysis of the operating period benefits to the state and city after the project is fully developed, provide working definition of “permanent employment.” While jobs associated with operation of sports facilities may be permanent, they are often part-time, or only occasional, as the need arises.

Also, the MAS asks when affordable housing would be built:

• Specify whether any low and moderate income housing will be built in Phase I and provisions to be made for community preference in allotting units.

Open Space

The MAS says the arena roof shouldn't count as open space and warns that the open space promises are out of sync with the project timetable:

• Rooftop space for commercial tenants should not count against required ratio.
• The proposed development will not result in any public open space until 2016. Determine impact of new residents and workers added to area in Phase I of construction in terms of current open space ratio.

Cultural Resources
The MAS warns that a narrow focus has its costs:
• The scope document states that the analysis of known resources will focus on resources closest to the development site. All resources in the study area should be equally analyzed. In recent large-scale rezonings, the area impacted by accelerated land values has been more generalized than the limited study area. Subsequently, attempts at the preservation of noteworthy historic buildings in the general area but not within the study area is weakened because the resources have not been identified.
• The field survey of the project site and study area for potential architectural resources is defined as being limited to those buildings that will be affected by the project. The survey should be of the entire study area, not just those with known impacts. The range of possible effects needs to be analyzed on all of the potential resources. Limiting the scope of review to a small subset of buildings is to determine in advance what those impacts might be.
• The visual impact of new buildings on resources, including the impact on the Williamsburg Clock Tower Building, must be analyzed, and binding mitigation measures must be developed.

Shadows
The MAS brings up the issue of solar rights:
• Impact of shadows on ability of surrounding residences and businesses to utilize solar heating potential should be studied.

Traffic and Parking/Transit and Pedestrians
The MAS has concerns about the narrowness of the scope so far:
• Times for analysis should be expanded to peak traffic hours of 7-10 AM, 4:30 –7:00 PM weekday for commercial and residential.
• Weekend Hours analyzed should be from 10-6 when most retail businesses are open, and traffic eastbound on Atlantic now backs up to 3rd Avenue or farther.
• Study potential for parking sharing agreements with surrounding businesses and residents for off-peak hours
• Study should include analysis of a regional transportation plan to reduce vehicular traffic to the area. The plan needs to address impact of new traffic patterns associated with events at the arena and vehicular trips associated with other commercial and office uses on the site and with the addition of (an estimated) 3600 cars for the 7300 new residential units.

Neighborhood Character
How would the Gehry plan impact the neighborhood around it? The MAS observes:
• In defining neighborhood character to determine impact of proposed development, examine:
o Low-rise character;
o Low-medium density character;
o Typical block/lot configuration;
o Typical street grid pattern;
o Mix of land uses;
o Brownstone character;
o Historic districts;
o Predominant building form and type;
o Pedestrian scale of buildings;
o Synergy between local businesses and local needs;
o Absence of social, commercial, and visual connections between neighborhoods of Fort Greene and Prospect Heights;
o Unique landmark status of the Williamsburg Clock Tower Building.