Comments on the draft scope of work for a Supplemental Environmental Impact Statement for the Atlantic yards Arena

and Redevelopment Project  By Steve Ettlinger Sent via email March 13, 2013 to   Thank you for an opportunity to clarify and expand on my verbal testimony of Feb. 27thʼs public scoping meeting.  My comments reflect personal experience from being a nearby resident as well as a lifelong interest in and study of urban issues. I am active in local block associations and sometimes with CB6 as well as with various related ad hoc groups.   Task 3 – TRANSPORTATION – PEDESTRIANS: SAFETY   The TDM did not take into account the dangerous situations caused by 15 years more of pedestrian walkways being moved onto streets, along with the narrowing of sidewalks.  This is of particular concern nearest the arena where, especially in an emergency or at the end of a popular concert with younger clients, sidewalk capacity needs to be maximized, not minimized.   Similarly, there will be 15 years more of compromised bicycle lanes, such as on Dean Street, in which the opportunity for fatal collisions between bicyclists and automobiles is dramatically increased.   All pedestrian safety issues during the extended Phase II construction are further compromised by the current issue of arena event attendees and their hired cars (buses, limos, black cars, etc.) parking illegally in areas immediately around the arena, a problem that the arena operators, in the aggregate, have been unable to eliminate as of March, 2013. This forces pedestrians (and bus passengers, etc.) into dangerous

situations, such as having to cross outside of crosswalks, step between idling cars in order board a bus, etc.   This shows a lack of planning on the part of the project sponsors.   Presumably more parking (indoors) will be provided by the completed towers; therefore during the extended build-out period less parking will be available, with impacts as described here:   Traffic studies as proposed deal with commuter peak periods which are emphatically NOT periods during which most arena crowding occurs.  However, there are severe impacts on commuting when residents, such as myself, return home around 7-8PM on an event night and are not only unable to park, but unable to drive efficiently due to traffic jams on streets such as St. Markʼs Avenue or Bergen Street between 4th and 6th Avenues.  Studies need to be done during arena event times, essentially one hour before and after concert and game events.   Traffic and socio-economic studies must also take into account the impact of removing public parking and traffic lanes from Atlantic Avenue by the police to provide parking during events for limousines and other hired cars.  The value of the public street being turned over to private use must be surveyed.  Alternative spots for limousines and other hired cars to park during events, with many idling during cold and hot weather, must be designated and the associated impacts considered. The Brooklyn Navy Yard, currently used for staging arena-bound trucks, must be evaluated as a staging ground for arenabound hired cars during this extended build-out period until such cars can pay to park in the indoor garages planned for the Phase II towers.   SOCIOECONOMIC CONDITIONS   This point is raised on page 20 of the Draft Scope document.  

Extended build-out will slow and/or discourage the establishment of new businesses in the area, inasmuch as they normally depend on increased pedestrian counts for their clientele. The type of business that is affected would expect to be drawing patrons from residents of the towers, not the arena attendees, although there is of course occasional overlap in the case of bars and restaurants only.   Potential residents far outnumber arena attendees in days and hours during which they might patronize a local retail business. These businesses that either might not establish or, if new, might not succeed, would be fighting for a much smaller number of customers during the years prior to completion than under the original Plan.  Examples of businesses that would be affected would include full-service restaurants, small restaurants, shoe repair stores, drycleaners, food stores, clothing stores, and so on— the typical stores found in a thriving retail district, such as found further down Flatbush Avenue and indeed throughout Brooklyn and Queens.   Incidental to this problem is the depressing effect on real estate values created by empty storefronts. Finally, for those developers waiting to build apartments in the area, the extended build-out is extremely problematic as potential condo-buyers would of course prefer a shorter build-out and its attendant disruptive nature.   In all the cases mentioned above, job creation is negatively impacted along with new housing.  Both of these problems mean less tax income for the city and state. Of all the benefits promised by the Atlantic Yards development, none are more important.   Studies must be made to indicate that FCRC demonstrate, as of 2013, overall increased (or decreased) economic activity in the area that is due to the arena construction on a level even with the amount of public investment.  This is a baseline metric that needs to be examined. Furthermore, all baseline metrics of this sort along with figures going forward need to be considered in light of the overall increase in prices or wages throughout all of Brooklyn.  

Please see the paragraph above about the studies needed regarding parking for hired cars during events during the extended build-out period.     BLIGHT   A long (not a spot, one-day) survey of pedestrians and neighbors should determine if people prefer to see the open railyards and construction fences for up to 25 years instead of 10 years.  The removal of blight is one of the main bases for justifying the project and must be a focal point of any EIS, because BLIGHT is essentially an environmental item.   A similar survey should determine if pedestrians and locals prefer to see a surface parking lot for up to 25 years instead of 10.   Similarly, the section of Pacific Street that is now closed and used for construction purposes should be re-opened to traffic and pedestrians unless a survey can prove that current use reduces blight and that such use is advantageous for residents of the area.   Portions of Pacific Street were turned over to Forest City Ratner under the assumption that they would be used for construction for ten years, after which they would either become part of the landscape or land under buildings. Instead, with the extended buildout, they will remain as unclean, commercial construction yard property.  Studies must be made to determine if the environmental impact of 15 additional years in this temporary and essentially dirty condition is supporting the removal of blight or contributing to it.     JOBS AND HOUSING The baseline metrics used to establish the benefits meant to accrue in 10 years are not readily available to the public.  The public needs to know the number of jobs and

apartments (by income tranche) in the area prior to commencement of the project, at the end of the original 10-year build-out, and at the revised, 10 and 25 year points.  The jobs and apartment prices (rental and owned) need to have dollar figures attached to them.   It is clear that most if not all of those people expecting to get either jobs or housing after ten years are not likely to get them after 25 years due to their own aging, having to find other options, or being priced out of the market. Furthermore, many of the originally intended beneficiaries will be dead before this project is completed, if it is allowed to continue for 15 additional years. The impact of delays in benefits for dead people are hard to calculate, but in the most basic sense the benefits are zero, and surveys should reflect this.    Task 4 CONSTRUCTION PERIOD IMPACTS ASSESSMENT - PUBLIC HEALTH   I vigorously object to the conclusion on pages 8 and 9 of your Draft Scope that public health will not suffer adverse environmental impacts, as the additional 15 years of construction truck traffic and construction itself will quite obviously bring an additional 15 years of noise, dust, and dangerous truck traffic to the area despite FCRCʼs attempts at mitigating those effects.  The problems will include those described often on the site.  Studies must reflect this issue.     Respectfully submitted,   Steve Ettlinger 39 St. Mark's Avenue Brooklyn, NY 11217