From the beginning we, as Community Boards, have aspired to be partners in the planning for the future of East Midtown. We are very open to the idea of re-thinking Midtown but it needs to be supported by a plan that carefully examines the many complex issues involved in charting Midtown's future. The issues involved are too important to hastily reach conclusions that will affect New Yorkers for decades to come. Unfortunately, the approach the Department of City Planning has taken thus far makes clear that a political timetable is guiding this work, not an effort to study the issues carefully and reach a consensus on the many challenges and opportunities that should frame Midtown's future. More time is needed to consider the implications of our suggestions and we continue to urge the City to take its time before putting forward a ULURP application.
A class "A" Office District is not just about Class "A" Office buildings. It's about efficient, comfortable, and convenient transportation options. It's about diversity of tenants, populations, and ideas. It's about having a civic experience that is worthy of the grandeur of Grand Central Station. We should start from what we want to see in East Midtown, what kind of experience we want office workers, tourists, and residents to have, and then determine what kind of development can provide this experience and how best to encourage it.
In order to help guide the work the Department of City Planning is undertaking we have developed the following principles that we believe would create a more careful and comprehensive plan. These principles will, in part, help shape our response to future land use applications.
- Infrastructure should precede development
- As the MTA made clear in their presentation to us, even in the absence of any new development there is an overwhelming need for transit improvements in this area, given the overcrowded subway platforms, the train delays, and poor rider circulation. The additional density that would be added as a result of the City's proposal only exacerbates the need for improvements. There is no clear sign that sufficient funds are or will be available to address this infrastructure need or that such funds could be acquired in time to make improvements before density increases. We need to explore alternate funding sources to ensure that East Midtown gets the improvements to the infrastructure it needs in order to be a competitive Class A office district. Among the options we believe merit consideration include the creation of a tax increment finance mechanism which we understand from the Department would require modifications to state legislation, the creation of a PILOT mechanism, the creation of a special assessment district, or a mixture of New York City capital funding, MTA funding, and federal funding. We trust the Department, in conjunction with the MTA, could develop even more sophisticated approaches to garner the financial resources required. In a region that is competitive because of the historic commitment to infrastructure represented by Grand Central, we need to continue to innovate. The need to study these possibilities provides a clear rationale for taking more time before moving to ULURP.
- A comprehensive public realm strategy
- We support the concept of incentivizing public improvements for developers; however, the public realm improvements are simply too vague. How can we begin to assess the virtues of a zoning plan when one of the plan's principle objectives is left completely undefined? Without a clear conception of what we're trying to accomplish with this rezoning, we may lose a fantastic opportunity to reshape East Midtown for the better. In addition to Vanderbilt, improvements to Pershing Square should be studied as well widening sidewalks along 3rd Avenue, Lexington, and Madison, widening the Park Avenue Malls, and key crosstown streets included 42nd Street and 47th, 48th, and 53rd. We would welcome the opportunity to have a more detailed conversation with DOT, DCP, and DPR about how to think more creatively and ambitiously about open space. Furthermore, we believe that incentivize zoning could be used to address not only mass transit and pedestrian needs, but could be used to mitigate other adverse impacts of a rezoning and support community initiatives more broadly.
- A mixed use future
- We have seen numerous areas of the city shift toward mixed uses with great success. The financial district is an example of how injecting a variety of uses (residential, hotel, cultural, among others) into a primarily office-dominated area can enliven and improve it. Mixed use can be and has been an effective tool within buildings as well. The Bloomberg building and Time Warner Center are examples of buildings in similar environments that have proved successful without compromising their commercial character. It's time to move beyond the Euclidean framework and recognize that a diverse mix of uses supports rather than impedes the development of a Class A office district.
- Protecting potential landmarks
- We are concerned that the proposal's process is inadequate for protecting historically valuable buildings that make East Midtown the world-famous place it is today. While landmarked buildings are protected, potential landmarks are not. There are scores of buildings throughout the proposal area that contribute greatly to the legacy and wonder of East Midtown, yet they are not landmarked. A clear preservation plan needs to be described before ULURP to understand what resources will be protected and which areas should be carved out in order to protect important buildings from the development pressure created by this re-zoning. Preservation of key buildings will support the creation of a vibrant, uniquely New York commercial district.
- An environmentally class "A" district
- We believe the proposal should provide greater incentives for green development. We need to continue to push the boundaries of what is possible and show the world that a successful partnership between private and public interests can create a responsible legacy for future generations. If the existence of aging building stock is truly problematic, energy efficiency and environmental impact should be high on the list of priorities for new buildings. Yet, there are no particular features of this proposal which exhibit an innovative approach to thinking about the environment, such as net-zero construction or co-generation or improvements to the public realm.
- Careful citywide planning
- The proposal, while aiming to address the needs of East Midtown, lacks cohesion with a development plan for the rest of New York. The effect this proposed development would have on the growth and ongoing change in newer office districts such as downtown Brooklyn and Long Island City should be studied and taken into consideration. We need to meaningfully support a strategy that capitalizes on the underused transit capacity of parts of our city and supports a five borough economic strategy rather than upending our policy of encouraging development in places outside of East Midtown.
- Protecting public investments
- The City (and indeed the State and Federal government) has made a large investment in office development in both Lower Manhattan and Hudson Yards and the structure and timing of this proposal has the potential to threaten those investments. If new development falters at Hudson Yards, the City could face higher interest rates on bonds that were floated to pay for the 7 line transit improvements, increasing the project's cost and delaying its completion. During a time of slow economic growth, when many of these new office developments are having trouble finding tenants, we fail to see the urgency in redeveloping East Midtown. We understand the "sunrise" provision is designed to prevent this sort of harmful competition, however with such an uncertain economic future ahead of us, a three and half year sunrise after the adoption of the proposal is hardly enough time to predict with certainty that Hudson Yards and Lower Manhattan will be on their feet. We shouldn't put tax payers at such risk.
- How about our skyline?
- This proposal encourages the development of buildings that will be among the tallest and largest buildings in New York City. How has this proposal considered the future of our skyline? Does the Chrysler or Empire State Building deserve any special protections? The creation of the extraordinary or iconic building special permit raises many profound concerns about the role of design review, and the lack of public review for most of the buildings that will result from this proposal will only ensure that the public has a limited role in shaping the future of our skyline. The proposal needs to be re-thought to allow for additional discretion in the review of these extraordinarily large buildings and needs to carefully consider the implications for our skyline.