What follows is my response to the draft scope of the Environmental Impact Statement as presented by to the Department of City Planning on July 31, 2007.
My name is Leah Kreger. I'm an Architect who has been in private practice for 14 years with residential, industrial and commercial projects constructed in Williamsburg and Greenpoint. My husband Miles Bellamy is a book dealer with a store on Bedford Avenue near the L train. It has been a joy to raise our four-year-old daughter in Williamsburg with so many children nearby.
Seeing the development of Williamsburg is something that concerns us personally and as a community. I am aware of the need for a certain amount of density in order for our city to grow, and I'm not against development; however, I would like our community to increase its density in moderation.
We hold the opinion that the proposed rezoning of Domino needs to be considered cumulatively with the effects of the zoning adopted in 2005 for the waterfront from N4th to Manhattan Avenue. The neigborhood needs assistance financial and otherwise to create a comprehensive plan instead of spot rezoning such as that proposed for Domino.
Perhaps CPC has the wherewithall to support a comprehensive community plan given the magnitude of their investment.
Please note that we are very much in favor of preserving existing affordable housing and creating new affordable housing that preserves the quality of life in the neighborhood and character of the buildings.
Careful consideration is requested, also with regard to Domino's unique position in the history of New York. The Domino Sugar site has an historic importance that goes back to the roots of New York City. Like Ellis Island, although not with official status as such, many immigrants touched U.S. soil for the first time there. This makes it an area to be considered even more carefully.
We respectfully request an extension of the time for public comment considering that many New Yorkers are on vacation.
Below we will comment on the plan following the structure of the proposal, per task.
Task 1: Project description
In general, we request more information about the architectural design in order for the public to have a sufficient understanding upon which to comment, i.e:
• What do the proposed buildings look like in terms of surface material?
• What is the proposed connection to Grand Ferry park and South 5th street?
• How does the applicant propose to construct the basements in the waterfront location?
• How much parking is proposed to be located where? Where are the entrances and exits proposed?
• How will the applicant address the extremely narrow side walks on Kent Avenue?
• What are the differences between the proposed upland connections on the north and south sides of the refinery buildings, and those on North 1st and South 4th street?
• What will the upland building look like?
• Since the affordable component figures prominently, please have the applicant describe the strategy for financing the affordable component as they relate to tax and government subsidies.
• What amenities will be proposed such as public bathrooms, seating, lighting, bicycle racks and drinking fountains?
• Please clarify the total number of units.
Task 2: Land use, Zoning and Public Policy
The developer claims that approximately 268,765 sq. feet of water surface area extending to the pier head line, is directly affected by this proposal, and that “The Water surface area includes the portion of Block 2414, lot 1 that is underwater.”
Considering the sensitive nature of claiming formerly public lands on the East River, I respectfully request that you require legal support for such a claim, documentation of clear title, and an examination of public lands.
Task 3: Socio-economic conditions
The proposed average size of the affordable units (726 sq. feet) is 2/3 the size of the market rate units (as Susan Pollock of CPC said on 6.28.07). As such, the affordable units will not address needs for large working class families who need 2, 3 and 4-bedroom apartments. I respectfully request that the city require minimum room counts in the affordable apartments when considering the developer's request.
We ask you to consider how the proposed shuttle bus service will affect local businesses - between Domino and the J,M, Z stop on Broadway and the Bedford Avenue stop on the L-train - that rely on pedestrian traffic and could otherwise benefit from the development?
We are concerned that new condos are being purchased as investments by people who don't live in the country and don't live in the apartments much of the time. Can any mitigation be examined to prevent "emtpy" apartments from causing secondary displacement of housing for low income families?
Task 4: Community facilities
An informal group of parents in the area has organized to address the state of the public elementary schools. Schools effect an area larger than the proposed study area - considering that many children go outside their district to attend school. I am concerned that the proposed development will exacerbate that trend - instead of putting much needed parent resources into local schools. Please read attached appendix 1- written by the parents of the Williamsburg/Greenpoint Schools Initiative Group (WIGSIG). The article is also available online via http://parents11211.com/article.php?story=20070611150839559 .
I request a survey of children and an assesment of who is attending school in district in a large study area, since the 2000 Census and Department of Buildings certificate of occupancies do not show this information.
Task 5: Open Space:
Considering the large number of children who already live and/or play within the area, where will the playgrounds be located and will they be accessible to the general public?
Who does the applicant see as using the open space? Have they studied how they will travel there? How will that affect the parkings? How have they addressed bicycle parking?
Task 8: Urban design/visual resources and
Task 9: Neigborhood Character
To quote the Zoning Resolution about, the general purpose of residential districts, (ZR, 21-00e) it is “To protect the character of certain designated areas of historic and architectural interest, where the scale of building development is important, by limitations on the height of buildings.”
One of the defining characteristics of Williamsburg as noted by many residents, is its relationship to light. Because most of the buildings are 3, 4 and 5 stories, residents enjoy an exceptional relationship to the sky and daylight. The proposed buildings would block much of the light, views on the Williamsburg Bridge and Manhattan Skyline - three of the neigborhood's defining characteristics.
Two of the proposed buildings are more than ten times higher than most of the existing highest neighboring buildings in the ¼ mile, ½ mile and ¾ mile study areas, excepting those as Schaffer’s Landing and Northside Piers. They are proposed to be more than twice as high as the buildings facing them on the other side of the East River.
I provide Appendix 2: a collection of photographs that show the charcter of Williamsburg and its visual resources.
I request in independent field study and interviews to assess the visual resources, pedestrian activity and character of Williamsburg. How many apartments would have shorter days and be in darkness? How many apartments woud loose their view of a neigborhood landmark - The Williamsburg Bridge?
Task 10: Natural Resources
Since the area is known to be the habitat of Perrigrine falcons as well as water fowl, swallows and cormorants, we ask that investigative field work not only take into account endangered species but other animal life as well.
Task 16: Traffic and Parking
Several intersections near schools in the study areas are in need of traffic lights, i.e. all the intersections around PS.04, the Williamsburg Neigbourhood Nursery School, Kids in Control, Streb Lab for Action Mechanics and Padre Kennedy Head Start. We ask for a specific traffic study and mitigation that addresses the safety of our children in respect to these intersections and their schools.
In light of Mayor Bloomberg's Congestion Pricing proposal, we applaud the consideration of a shuttle bus to the trains and water taxi service. Nonetheless we are concerned that the proposed development will create more dependence on cars, since there are no subway entrances within 1/4 mile radius. I am also concerned that the expense of water taxi services, and high priced retailers will be way beyond the means of families living in the affordable apartments.
We request that when considering the on-street local parking conditions, that existing need for parking be inventoried.
Task 19: Noise
Noise complaints continue to be the number one quality of life issue for New York City residents. The City's new noise code (Local Law 113 0f 2005) took effect on July 1, 2007. We ask that the developer submits a mitigation plan as per the new noise law.
Task 22: Alternatives
We ask that you consider a community plan based on the density outlined in the WIlliamsburg 197A plan and the density proposed by GWAPP in 2005.
See appendix 3