March 3, 2017

Honorable Ken Knuckles
Vice- Chair, New York City Planning Commission
120 Broadway
New York, NY 10271

James Patchett
New York City Economic Development Corporation
110 Williams Street
New York, NY 10038

Dear Vice-Chair Knuckles and President Patchett:

We write to express deep concern with the current proposal by the City of New York’s
Economic Development Corporation (EDC) to remove the requirement to preserve
manufacturing space in the city’s Garment Center. We strongly believe that this plan, predicated
on the promise of manufacturing space at Bush Terminal and other locations in Sunset Park,
Brooklyn, has not been sufficiently vetted and could jeopardize New York City’s status as a
garment and fashion industry hub.

The proposal presentation shared with many of us stated an early spring referral and a
communicated target date of April 3, 2017. It is now our understanding the target date has
shifted but we have no information on the new target date. We ask that you delay any and all
action on the plan and work with us and the stakeholders in the Garment District to adopt a better
plan for public review.

The first, most obvious question is this: why would the city lift restrictions protecting
manufacturing in the Garment Center in Manhattan before sufficient substitute space for these
operations is ready?

This prompts further questions. What entities are on board with the plan? Which stakeholders
have been consulted? Have the unions representing Garment Center workers been included?

These questions need answers.

While we understand EDC’s plan to move some manufacturers from older Manhattan spaces to
newer Brooklyn spaces may have merit, we are also aware that sufficient space in Brooklyn is
unavailable at this time, and many of the spaces targeted by EDC will not be ready for several
Garment Center
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We are concerned that premature removal of the Garment Center’s zoning protections will result
in the dispersal of this important industry and a workforce left without assurance that jobs will
remain in, or return to, New York City.

The city’s plans for operations that cannot be accommodated in the proposed space in Bush
Terminal require serious discussion as well. Our understanding from the information provided to
us by EDC is that fashion manufacturing currently takes up 830,000 square feet in the Garment
Center and the warehouse function takes up an additional 360,000 square feet, while the
proposed Bush Terminal facility, which is not yet developed, would accommodate
approximately 200,000 square feet of garment manufacturing operations.

In addition, we have heard anecdotally that a substantial portion of the garment manufacturing
workforce comes from Queens, the Bronx, and New Jersey – which, if true, may make relocation
to the Brooklyn waterfront extremely onerous for some firms. These concerns need to be

In any event, certification of any proposed text amendment to lift the preservation requirement
for garment manufacturing in the Garment Center should not proceed as planned.


Gale A. Brewer Congressman Jerrold Nadler NYS Senator Brad Hoylman
Manhattan Borough President 10th Congressional District (NY) 27th Senate District

Assembly Member Dick Gottfried Council Member Corey Johnson
75th District Manhattan Community Board 5
3rd District

Manhattan Community Board 4

Cc: Raju Mann, Director, Land Use Division, New York City Council