Central Station Complex - aka Penn Station Redevelopment GPP.
Community Board Five Executive Committee unanimously passed the following resolution with a vote of 9 in favor; 0 opposed; 0 abstaining::
WHEREAS, the New York State Urban Development Corporation d/b/a as Empire State Development (ESD) is the sponsor of a land use proposal to redevelop all or a portion of nine tax blocks around Penn Station; and
WHEREAS, the proposed development would be located on blocks 783, 809, 808, 807, 781, 780, and 806 located in Community Board Five (MCB5) and blocks 755 and 754 located in Community Board Four MCB4; and
WHEREAS, the proposed development stated goals are:
Goal 1: Revitalize the area surrounding Penn Station with new, sustainable, high-density commercial development
Goal 2: Support improvements to address substandard conditions in Penn Station
Goal 3: Improve passenger rail and transit facilities and pedestrian circulation, access, and safety
Goal 4: Provide for future capacity increases at Penn Station
Goal 5: Implement public realm improvements; and
WHEREAS, on July 1st 2020, ESD issued a Draft Scope of Work (DSOW) delineating the scope of the project in order to prepare a Draft Environmental Impact Statement (DEIS); and
WHEREAS, on July 20th, ESD will hold a scoping session, inviting testimony by stakeholders and members of the public; and
WHEREAS, on July 13th, Manhattan CB5 held a joint Transportation & Environment and Land Use, Housing & Zoning committee meeting to discuss the DSOW; and
WHEREAS, Manhattan Community Board Five expresses numerous concerns about the proposal and recommends that the final Scope of Work be altered; therefore be it
RESOLVED, That in order to enable the preparation of a relevant Environmental Impact Statement (EIS), Community Board Five recommends that the final scope of work be altered as defined in the six categories below:
- TRANSIT AND TRANSPORTATION
Community Board Five notes that the General Project Plan (GPP) for the Empire Station Complex redevelopment excludes any transportation, transit and below grade improvements necessary to achieve the goal of transforming Penn Station into a dynamic and modern transit hub, rendering it impossible to properly assess the validity of the proposal, its ability to achieve any stated goals and to measure and possibly mitigate any impacts from said transportation improvements. Therefore we are requesting a new comprehensive proposal be issued that includes all parts of the proposal to reach the stated goals and avoid at all cost a piecemeal approach that will inevitably skew an environmental assessment. Community Board Five reminds ESD that segmentation is contrary to the intent of State Environmental Quality Review (SEQR) and this project does not meet any of the acceptable reasons for segmentation. On the contrary, the location, purpose, impact, and utility of the project are all shared under the master plan for an improved Penn Station. They therefore must be evaluated under one proposal.
Community Board Five notes that one of the stated goals of the land use proposal is to generate funding needed to perform the below grade upgrades and improvements to Penn Station. It is therefore critical to acknowledge that any change to the funding structure would radically change the scope of the proposal. We believe that given the prominence of the transit hub for the entire region, and the prominence of the region for the entire country, federal funding should more generously be allocated to our critical infrastructure, hence reducing the need to generate real estate wealth at our community’s expense. We demand that the scope be revised to reflect an increase in federal funding and a commensurate reduction in density.
Given the stated goal of the proposal to generate funding to perform upgrades and improvements to Penn Station, it is essential that the scope of work carefully detail the financial mechanism by which such funds will be levied. The scope of work must include a detailed financial analysis of the following:
- MADISON SQUARE GARDEN
Madison Square Garden (MSG) is considered by numerous urban planners, architects and land use experts as an obstacle in the renovation and sustainable future expansion of Penn Station. On February 15, 2013, Manhattan Community Board Five voted 36–0 against granting a renewal to MSG's operating permit in perpetuity and proposed a 10-year limit instead in order to build a new Penn Station where the arena is currently standing. Then Manhattan Borough President Scott Stringer noted that "Moving the arena is an important first step to improving Penn Station.” In May 2013, at the invitation of the Municipal Art Society, four leading architecture firms – SHoP Architects, SOM, H3 Hardy Collaboration Architecture, and Diller Scofidio + Renfro – submitted proposals for a new Penn Station. All four architectural firms recommended relocating Madison Square Garden to accomplish a meaningful transit hub redevelopment. In June 2013, the New York City Council Committee on Land Use voted unanimously to give the Garden a ten-year permit, at the end of which period the owners will either have to relocate, or go back through the permission process. On July 24, 2013, the City Council voted to give the Garden a 10-year operating permit by a vote of 47–1. At the time, the city Council Speaker Christine Quinn said: "This is the first step in finding a new home for Madison Square Garden and building a new Penn Station that is as great as New York and suitable for the 21st century; this is an opportunity to reimagine and redevelop Penn Station as a world-class transportation destination."
In 2016, architect and scholar Vishaan Chakrabarti also called for the relocation of Madison Square Garden as a necessary step to permit proper improvements to Penn Station.
The GPP does not propose to relocate Madison Square Garden and therefore is not addressing a major limitation to their stated goal. Unless the sports and concert arena is relocated, its structure will continue to impede any meaningful improvement to Penn Station. Therefore we demand that the relocation of Madison Square Garden be included in this proposal (including exploring block 809 as a possible relocation site), and the redevelopment of block 781 be part of the scope of work. Manhattan Community Board Five notes that the city deserves a 21st century transit hub as well as a 21st century sports and concert venue.
- SOCIOECONOMIC IMPACTS, URBAN DESIGN, HISTORIC RESOURCES
The proposed land use action if approved would be the densest rezoning ever passed in New York City. Some of the proposed development sites would reach a FAR of 33. The impact would be of high magnitude and high importance.
The scope should include a much more robust evaluation of the environmental impact in many different areas.
SUBSTANCIAL INCREASED STUDY RADIUS
- The study area for pedestrian flow, vehicular traffic flow, and bicycle circulation must be broadened as a ¼ mile radius will not accurately capture the impact generated by the additional 20 million square feet of commercial, retail and hotel development.
- The study area must be broadened to evaluate the cumulative impacts of the concomitant redevelopment of the Port Authority Bus Terminal (including its land use portion), the proposed upzoning of Macy’s Department Store directly to the north of the development area, as well as the impact of further influx of commercial office space in an already saturated office market flooded by Hudson Yards as well as East Midtown. The proposed development may contribute to a collapse of an already eroded retail and office real-estate market. It should be noted that the profound negative impact caused by Covid-19 pandemic on office space needs is unknown and a grave cause for concerns as many Fortune 500 companies have expressed the intention to sharply reduce their office footprint.
- The study area must be broadened to assess the direct and indirect displacement of businesses and residents as the proposed development will profoundly impact the urban fabric of the blocks to the south and to the east of the development. Specifically displacement of long term residents, displacement of garment district businesses and non-for-profit organizations must be closely evaluated and every attempt must be made to eliminate displacement of these vital groups.
- The threshold for evaluation of business and residential displacement must be strengthened as the stock of existing buildings slated for demolition no longer exists in our district and it is very unlikely that displaced populations and businesses would find a suitable alternative in Community Board Five or even in Manhattan.
- The threshold for pedestrian traffic assessment must also be strengthened to provide for proper pedestrian flow. The area is currently extremely congested and the proposed sidewalk enlargement currently presented in the Draft Scope of Work is not adequate.
ADDITIONAL SCOPE FOR EIS
- The proposed development should include affordable real estate development at some of the sites and therefore the environmental impact to added residents must be evaluated, including open space, school capacity, and health care facilities capacity.
- The threshold for open space should be strengthened to require the creation of a public park, for example at the location of site 3.
- Thermal comfort analysis must be performed that includes shadow studies onto open space, including sidewalks, as well as on open space that would be created under this proposal.
- Traffic and sanitation impacts must be evaluated and best practices must be developed to collect the extremely large amount of refuse produced by the added density, including using railway transit rather than trucks to transport refuse out of the area.
- The proposal will have a tremendous detrimental impact on our historic and cultural resources. As the proposal calls for the demolition of 6 ½ city blocks, a large swath of urban landscape will perish. Many historic buildings would be demolished. Historic buildings must be evaluated, regardless of their status with the NYC Landmarks Preservation Commission, including but not limited to St John the Baptist RC Church, and Penn Station Service Building. Community Board Five will provide a list of historic resources under separate cover.
- The proposed development would also have a disastrous impact on visual resources, most significantly on the Empire State Building that would be boxed off by the large developments along 7th Avenue. It is imperative that visual corridors be identified and fully protected, as New York City’s skyline is a public asset that should never be impeded.
- The proposed project energy impact must be assessed in light of Local Law 97. In order to proceed, the proposed project must fully comply with current energy requirements and the Environmental Impact Statement must establish that once fully completed and occupied, the buildings as well as the transit hub would be energy efficient.
- The proposed project must clearly state that the added density can only be constructed at the identified sites and that no transfer of air rights mechanism shall apply to any of these sites, as the impact of any shifted density will not be and cannot be properly assessed.
- REASONABLE ALTERNATIVES
The proposal must be evaluated in light of other reasonable alternative developments that would achieve similar goals.
An alternate proposal that includes substantial affordable housing must be evaluated.
A reasonable alternative in which the proposed real estate development would be spread out between Penn Station and other areas that use the transit hub should be considered (New Jersey, Long Island).
- PUBLIC BENEFITS
Manhattan Community Board Five will bear the brunt of the negative impacts generated by this project, including added pedestrian flow in an already highly congested area, incremental shadows, significant direct and indirect displacement, and the loss of historic fabric. We demand that the proposed development include plans for a portion of it to serve our district’s needs. Such public benefit could be in the form of a cultural institution (museum), a substantial open space (public parkland), a health facility (hospital), or an educational facility (school). Such public benefit should be included in the Final Scope of Work so as to guarantee its viability.