September 27, 2006
Charles A. Gargano
Chairman and Commissioner
Empire State Development Corporation
30 S. Pearl Street
Albany, NY 12245
Re: The General Project Plan (GPP)
The Draft Environmental Impact Statement (DEIS) and the Blight Study (BS) of the
Atlantic Yards (AY) Plan
Dear Chairman Gargano:
I preface my comments on the AY GPP and DEIS with my response to issues raised by elected officials, civic and neighborhood organizations who are opposed to this proposal as put forth by the Forest City Ratner Company (FCRC).
The proposed development has been promoted as "a done deal" ever since the first presentation over two years ago. The implications of this approach were that citizen participation would be kept to a minimum in the evaluation and approval process. The plan, from inception, was presented as already approved by the Mayor and Governor in a signed agreement. And, the agreement stipulated that the plan would not have to abide by the New York City Charter or local zoning rules. This eliminated the possibility of meaningful citizen participation.
FCRC engaged in a selective negotiating process by initiating a Community Benefits Agreement which promised affordable housing, job training, and construction jobs, among others, for people who live in the community. Without specific approval by local and state government officials, however, it is not clear as to who is authorized to enforce the agreement if the promises are not realized.
The CBA does not satisfy major concerns of neighboring communities. Regardless of the success or failure of the CBA, I strongly object to the notion that the CBA in any way satisfies the major concerns that have been raised about the AY. The issues of extreme high density, disproportionate bulk and height in relationship to the surrounding low rise neighborhoods, the large number of displaced residents that is and will take place, the threat of eminent domain to transfer property from private citizens and public city streets to a developer for his profit and the overall mass disruption of a decade of construction on at least five neighborhoods should addressed.
The primary benefit of the Community Benefits Agreement has been to split this community along racial and economic lines thereby creating a wedge between the developer and citizens within affected communities who raised legitimate issues regarding this colossal project.
My comments here reflect only a small fraction of the large number of outstanding issues and questions that were raised by the GPP, and unanswered in the DEIS:
• The DEIS is silent on the impact of present overdevelopment . The DEIS does not
respondto the total number of additional residential, commercial and office space already
completed as wellas developments approved and being constructed. All these developments –
within a two and a halfmile radius of the AY plan – is silent on the issue as it relates to the
environmental impacts,additional traffic generated by all these new developments, and the
services and needs of thethousands of new employees, residents and shoppers.
• The Council of Brooklyn Neighborhoods estimates that new projects already include
millions of square feet that are unaccounted for. The Downtown Brooklyn Plan, the
BrooklynBridge Park development, and developments in DUMBO, Red Hook, the 4th
Avenue corridor, and around the Gowanus Canal contain a minimum of 1,124,000 square feet
of residential units alreadycompleted (such as 223 Atlantic Ave. at Court St.) but not in the
DEIS as well as 928,000 squarefeet of office space (such as 9 Metrotech and 330 Jay St.).
Projects in the pipeline but notcompleted yet total an additional 1,132,000 square feet of
residential and 1,739,000 square feet ofoffice/commercial space (such as 110 Livingston St.,
245,000 square feet of residentialdevelopmentand the expansion of NYC Technical College).
• On top of this overdevelopment will be the impact of 18,000 visitors to the arena which
is expected to offer extensive programming besides the 40 plus nights of NETS
basketball games. As an example of what we can expect, consider the area surrounding
Madison SquareGarden: it is a large isolated building surrounded by streets that are devoid of
any sense ofneighborhood. The NETS arena has a similar design without any features to
integrate the buildinginto the surrounding neighborhoods. Moreover, the GPP and DEIS does
not address how the areawill be protected from the negative impacts of this structure in the
prevention of futuredisplacementand abandonment.
• The exclusion of these additional developments means that there is sorely inadequate
accounting of the future needs for additional sewage treatment capacity, energy
demands, as well as new facilities to accommodate education, safety and sanitation
• Where is the Traffic Plan? The DEIS does not propose a plan nor are there discussions with
civicgroups how to mitigate the problems of traffic and pollution for neighborhoods that are
outside ofthe AY study area such as Park Slope, Red Hook, Brooklyn Heights and Sunset
Park. The DEISseems to represent the narrowest possible environmental impact without
regard to the fact that allof the neighborhoods listed above share major traffic arteries. For
example, Atlantic Avenue is amajor truck route linking the BQE and Red Hook on the West
to Queens and Long Island on theEast. Fourth Avenue is a major route between the
Verrazano Bridge and Atlantic Avenue , not to mention Flatbush Avenue from the Manhattan
Bridge to all parts of Brooklyn. As a consequence of thepresent building boom, including the
AY plan, the already congested main arteries will be ingridlockat all hours of the day.
Already, my office gets complains about east-west, and south-north traffic seeking alternative
local residential streets that run parallel to the main traffic arteries.
• The Environmental Impact Statement should have a comprehensive evaluation of
security risks. The AY GPP shows huge skyscrapers and a glass enclosed arena above one
of thecity’s largest transportation hubs, which is a known terrorist target. Three Community
Boards, otherelected officials and I have all made our concerns regarding the security risks in
this plan known; however, they have not been addressed in the DEIS. They should be.
• And, finally, I oppose the present General Project Plan for the Atlantic Yards unless it
isreduced by at least 30 % in bulk, height and population.
Senator Velmanette Montgomery
18th Senate District
cc: Hon. George Pataki, New York State Governor
Hon. Eliot Spitzer, New York State Attorney General
Hon. Alan Hevesi, New York State Comptroller
Hon. Joseph Bruno, New York State Senate Majority Leader
Hon. Sheldon Silver, New York State Assembly Speaker