IMPORTANT MEMO RE: LIBRARY EIS
July 6, 2015
TO: MEMBERS OF COMMUNITY BOARD 2’s
LAND USE COMMITTEE
FROM: CONCERNED COMMUNITY RESIDENTS
& CITIZENS DEFENDING LIBRARIES
RE: IMPORTANT ISSUES SURROUNDING THE LIBRARY
ENVIRONMENTAL IMPACT STATEMENT
INTRODUCTION: after careful scrutiny of the above, it is our belief that construction
of this large real estate project will harm the downtown footprint and will
indeed have negative impacts on traffic, transit and pedestrians, air quality
and noise. The 2004 Final Environmental
Impact Statement “FEIS” (on which much of this EIS is based) suggested possible
steps to mitigate expected impacts on the environment but the FEIS greatly
understated the number of luxury and market rate housing units that would be
included within the downtown Brooklyn development area. Moreover, the outdated
2004 FEIS, based on hearings held 10 years ago is not “a realistic assessment
of the burdens being imposed on the Downtown Brooklyn communities given the
extraordinary development that has already occurred in the last 10 years. Tens
of thousands of new residents strain an already overcrowded school system, park
system, transit system and police and fire departments.” (see Supreme Court of
the State of New York case in the matter of FUREE, then Councilperson Letitia
James, NYS Assembly Member Walter Mosley, et al v. Bloomberg, NYC EDC, HPD, et
al 5/01/2013).
The massive development occurring in
downtown Brooklyn exceeds anything contemplated by the 2004 FEIS. According to
The Downtown Brooklyn Partnership, “since 2006 Downtown Brooklyn has
experienced $4.9 billion in private investment, including 7,111 residential
units, 1,570 hotel rooms, 1.4 million square feet of retail space.” See
http//assets.downtownbrooklyn.com/maps/Development-Map-Mar-2013.pdf
By refusing to take a hard look at
this project based on post-March 2004 development in Downtown Brooklyn, a
Supplemental EIS is warranted and any go-ahead should be put on hold until the
obligations of such a review is undertaken. Here is just a brief overview of
some impacts associated with this development:
CONSTRUCTION: 40 MONTHS: DEMOLITION, EXCAVATION
& FOUNDATION, SUPERSTRUCTURE, EXTERIORS, SITE-WORK, INTERIORS &
FINISHING.
·
Construction allowed 7 a.m. – 6 p.m. on weekdays; weekend
work may also be required; curb-lane & sidewalk closures would be required
to allow for deliveries and laydown of construction materials. Trucks
delivering materials will enter primarily via CADMAN PLAZA WEST WITH CLOSED-OFF
AREAS for concrete pour and steel delivery; (Would cars, taxis, etc. use Clark
& Henry to circumvent the closing of Cadman?)
·
Estimated Trucks per day: 15 for
demolition; 25-35 for excavation; 10-35 for superstructure; 15-25 for interiors
and finishing; 35 trucks per day when activities overlap;
·
“Peak number of deliveries would
occur from the 4th quarter of 2016 to the 4th quarter of
2018 with 35 trucks per day. . . .note the estimated 35 trucks per day is not
the maximum number of construction trucks anticipated for each individual
construction stage” (from Attachment L)
TRANSPORTATION
PLANNING & ASSUMPTIONS: a quantified traffic analysis was not required
according to the EIS.
Trip generation factors for the
proposed project “were developed based on information from the 2004 Downtown
Brooklyn Development FEIS and U.S. Census Bureau 2008-2012 Five Year Estimates
– Journey-to-Work Data and CEQR Technical Manual. Simply put, vehicle
occupancies are from 2008-2012 U.S. Census and taxi numbers used are from the
2004 FEIS.
AIR QUALITY (FROM
THE EIS): “the proposed project would implement an emissions reduction program
too minimize the effects of the proposed construction activities on the
surrounding community.” This is not spelled out or fully addressed.
NOISE &
VIBRATION (FROM THE EIS): “some project-specific noise control measures would
be used to reduce the amount of construction noise.” This is not spelled out or fully
addressed.
RODENT CONTROL (FROM
THE EIS): “ construction contracts may include provisions for rodent, mouse,
rat control . . . during construction, the contractor would carry out a
maintenance program as necessary. . .rodent control in a manner not hazardous
to the general public, domestic animals. “ This is not spelled out – what EPA
registered rodenticides would be permitted?
EXCAVATION &
FOUNDATION (FROM THE EIS): “excavation and foundation activities would involve
the use of pile drivers, bulldozers, bobcats, loaders, compactors, generators,
compressors. . .this stage is anticipated to take approximately 15 months to
complete.” This machinery usage is not specific
and is not quantified in a noise analysis.
PARKING (FROM THE
EIS): “ number of workers would be 63 a day and based on 2000 Census data, it
is anticipated that 50% of construction workers would communte to the
development site by private autos . . . .generate a parking demand of 27
parking spaces. . . .workers expected to park in off-street spaces.”
NOISE (FROM THE
EIS): “ impacts on community noise levels during construction of the proposed
building could result from noise from construction equipment operation and from
construction and delivery vehicles traveling to and from the construction site.
. . .The New York City Noise Control Code requires the adoption and
implementation of a noise mitigation plan for each construction site, limits
construction absent special approvals to weekdays and sets noise limits for
specific pieces of construction equipment.” No mitigation plan has
been thoroughly explored or explained.
None of the attachments to the EIS adequately
assess the potential impacts of this proposed project including transportation,
hazardous materials, pollutants analysis (carbon monoxide, nitrogen oxides,
sulfur dioxide, respirable particulate matter), pedestrian operations, and the
building’s mechanical system (heating, ventilation and air conditioning). On
the latter, the EIS states that the aforementioned systems “would be designed
to meet all applicable noise regulations.” Yet there is no further information
or details on what kind of system would be used.
* * * *
In connection with the July 6, 2014 meeting see also:
* * * *
In connection with the July 6, 2014 meeting see also:
Handout Number 1 For July 6, 2014 Brooklyn Community Board 2 Land Use Committee Meeting- Let's Get the Record Straight! Concerns Re Proposed Library Sale+Shrinkage To be Voted On
Handout Number 3 For July 6, 2014 Brooklyn Community Board 2 Land Use Committee Meeting- Come To The Library Seeking Truth NOT Treasure
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