Handout Number 2 For July 6, 2014 Brooklyn Community Board 2 Land Use Committee Meeting- Important Memo Re: Library Environmental Impact Statement Documents

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 Moreover, the outdated 2004 FEIS, based on hearings held 10 years ago is not “a realistic assessment of the burdens being imposed on the Downtown Brooklyn communities given the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 4^th quarter of 2016 to the 4^th 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.

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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