Senator Gonzalez Public Comment on the Freedom Plaza SoW

Brian O’Dwyer 

Chair, New York State Gaming Commission 

354 Broadway 

P.O. Box 7500 

Schenectady, New York 12301-7500 

Dear Chair O’Dwyer, 

As an elected representative for the district with the lot under consideration for the proposed Freedom Plaza development, I am writing to share my concerns about the proposed scope of the Freedom Plaza development.

Numbers alone cannot tell the full story of a project’s impact on our community. Qualitative data matters. It is not enough to compare the no-action condition to the proposed development. the Environmental Impact Statement should consider the unique impact of a 300,000 sq. Ft. gaming facility. This impact statement should reflect the specific impact a gaming facility could have on nearby infrastructure, air quality, water and sewer infrastructure, open space, community facilities, transit, and general quality of life.   

East Midtown is one of the most greenspace starved areas of the city. So, whether it is the 3.1 acres of open space proposed by the no action condition or the 4.7 acres of open space proposed by the Freedom Plaza development, it is vitally important that this open space is high-quality and publicly accessible to the existing community that surrounds it.  

Regardless of whether it’s the 400 affordable units included in the no action scenario or the 513 affordable units in the proposed Freedom Plaza development, we desperately need affordable housing. However, it must be truly affordable housing. 

This is the largest undeveloped site in Manhattan, and it has been empty for the last 15 years. The people of this community deserve a development with green space, construction projects, and long-term community businesses that provide good union jobs, but they also deserve a high quality of life. To determine whether this proposed new development, and specifically the proposed gaming facility, will adversely impact quality of life, not only for the 1,250 proposed new residents but also for the surrounding community, the Environmental Impact Statement (EIS) must take into consideration the unique impacts a gaming facility might have on traffic, noise, the water supply, water, and sewer infrastructure, carbon emissions and more.  

Open Space: 

A truly comprehensive study of open space must take into account not only the amount of open space proposed by this project as compared to the non-action condition, but also the quality of that open space. This open space is intended for use not only by the 1250 new residents, hotel guests, workers, and casino visitors, but also an unknown number of daily museum visitors, tourists, and nearby community members. The peak non-residential users formula should be adapted to include these metrics, considering how close the development is to the UN and given how green space-starved this community is.  

Shadows:  

A significant portion of the development is already in shadow from nearby towers. Given the development’s location and the current impact of shadows from nearby prior-existing developments, the project generated shadows should not be studied in isolation. The DEIS should consider the cumulative impact of these shadows on the quality of open space included in this plan. 

Water supply:  

This project is just under the required threshold of 1 million gallons a day that warrants a water supply assessment. Given the city’s most recent issues with drought, and the potential for increasingly frequent drought, the impact of this project on the water supply should be considered.   

Noise:  

Currently, noise monitoring devices are located along 1st Ave, 41st Street, and 38th Street but not on FDR Drive, where the proposed point of entry for the gaming facility is located. A noise monitoring device should be also placed at the proposed point of entry for the gaming facility. 

Sincerely, 

Senator Kristen Gonzalez 

NYS Senate District 59