Image above: 25 story building

We are finally getting to another major change happening in our city around development. The removal of the requirement for Developers who want to build up to 25 stories not to perform any type of environmental review.

However, before we can discuss this issue you may need some back ground information to understand this proposal.

Please Note: this is not apart of the City of Yes Economic/Business Text Amendment “COY”.  This is a completely separate amendment happening at the same time as COY.

Environmental Reviews

It is New York State Law that any development project that is requesting to change the zoning (how something is built) must conduct an environmental review of the project.

This law is a disclosure law, it does not stop a project if it is determined to be harmful, but does have a component within it that would allow the project to be modified, changed, parts to be eliminated and provide community benefits.

 Two Different Reviews.

An Environmental Assessment Statement “EAS” a Short 4 page form to determine if an EIS should be preformed. This is a fast form that was created to reduce the time and money for developers.  The form itself takes a few minutes to fill out with the possibility of a few small studies if the project is next to a sensitive ecosystem.

An Environmental Impact Statement “EIS” – If the EAS determines that an EIS must be performed, then a developer must engage in this very   intensive environmental review that would require changes to the project, mitigating scenarios to be employed, input from other city agencies, community benefits provided to compensate the community etc..

In order for a project to completely avoid this entire process, it must be classified as Type II. These are normally projects such as a redesign or maintenance project, where it is clear that no new environmental impacts would occur.

The Green Fast Track Amendment

The City is currently asking to add development projects that can go up to 25 stories high and have less than 250 apartments as a Type II project. There are a few situations where a project would not be able to be a Type II depending upon where it is being proposed, including inside landmarked districts, near a public park (not playgrounds) etc..

The Studies

The Department of City Planning “DCP” has made the claim that they conducted a study of over 1,000 applications which showed that no EIS was needed, thus making the EAS an unnecessary burden for developers. 

However, MTOPP and Community Boards have asked for the study and even have submitted Freedom of Information Law “FOIL” requests for it but still DCP has refused to provide it to the public!

Others have claimed that over 80% of the 1,000 cases studied pertain to single one and two family homes, which in no way represents the 250 apartments and 25 stories exemption. Also the 25 story height seemed not to make sense, since 250 apartments  would be outrageously large to fit into a 25 story building.

The Legal Challenge

DCP has also stated the legal challenges for projects under 25 stories have all failed in the Courts with regards to having to conduct an EIS.

This is not true.

In fact, MTOPP was a part of a lawsuit that pertained to this specific issue, showing that legal challenges have been upheld by a Judicial body.

Above Image: Community residents at the Bklyn Supreme Court. “Boyd vs. Cornell”

Example

In Boyd vs. Cornell Realty Management Company, a developer proposed to build two 17/19 story towers containing a total of 390 apartments, along three city blocks bordering the Brooklyn Botanic Garden in a 6/7 story height limited zone.

The Community filed a lawsuit against DCP, when it was discovered, via the EAS, that the developers underestimated the number of apartments, to avoid an EIS, showing that over 589 apartments not 390 were going be built, and three towers instead of two.

After almost three years and several million dollars later (spent by the Developers, who hired Mayor Adams, former Chief of Staff, Frank Carone as counsel), Judge Boddie, determined in a 29-page decision that in fact, the City failed to conduct a proper environmental review “EIS” and declared the new zoning void.

However, with a 100% reversal rate at the Appellant Court, the 2nd Department reversed Judge Boddie’s decision in their 4-page decision which did not contain explanation for their position, declaring that Judge Boddie’s numbers were wrong.

The Developers went ahead and built the three towers with 589 residential units, with more apartments coming, showing the ineptitude of the Appellant Department, and not the need to do away with an EAS for apartments that are less than 25 stories high.

Just like developers did in this case, they can do again and again: declare a project to have less than 250 apartments, avoid any type of environmental review, and once they get approval they can change the numbers build twice as many or even more apartments. Now the 25 story height limit makes sense.

 

Developer and the City Learn from Lawsuits  Empowers Communities

Lawsuits can be very effective even if the Appellant Division always sides with the City and Developers regarding legal challenges!

For example, because the lawsuit stated above was very costly to Cornell and the Judge Boddie did find in our favor, other proposed projects took heed.  They decided not to try to cut corners, but actually conducted an EIS, when proposing a project that was smaller than Cornell’s and right next to it.

By taking away our rights to know what is happening in our community and to challenge these proposals, this amendment is meant to disempower us, not to fast track their project!

Doing Away with Racial Impact Studies

Just a few years ago the City Council passed into the law the need for developers to conduct racial impacts studies when building in low to moderate income communities of color. This is a result of gentrification that occurs with introduction of luxury apartments coming into communities of color.

With the new proposed Type II designation the Racial Impact Study will be worthless, because Type II projects won’t have to conduct any type of environmental review including the Racial Impact Study!

But it isn’t just racial impacts but also alteration of a community’s character that would not be considered.  Just image a community with  2 to 3 story buildings all of a sudden getting a 25 story building!  Talk about a drastic change!

Please Note that Public Advocate Jumaane Williams pushed for the Racial Impact Study, yet on January 24, 2024 at Brooklyn Community Board 9 general board meeting, he claimed he had no idea if the new Type II designation would affect the Racial Impact Study! 

We are still looking to hear back from him.

Other Tricks of the Trade

This is not just underestimating the number of apartments, or not having to conduct racial impacts, or building towers in very low rise communities, but purposely separating development projects and then joining them later.

We can see a developer buying several large parcels of land all connecting, and then separating each parcel into it own proposed project by creating a different LLC for each project, to avoid having to do an environmental review.

Once they get these approvals, the projects all of a sudden get bought by one entity and you have a whole row of 25 story buildings that never got an environmental review, never were required to do any infrastructure upgrades, no community benefits and completely by- passed the environmental review process.

Take Action

Attend the City Planning Public Hearing
on Green Fast Track
 February 7, at 10 am

The NYC City Planning Commission will be conducting a in-person and via conferencing hearing on the Green Fast Track – Text Amendments.

This is the Commission that approves, modifies or changes the Department of City Plannings proposals for rezoning.

Everyone will have three minutes to speak, and there is an opportunity to submit comments as well. The City Planning Commission will vote on these amendments late February.

Please Note: Over 60% of the Commissioners are appointed by the Mayor, making this basically the Mayor’s commission, who is supporting, pushing and created Green Fast Track Amendment, with the help of Developers and the Real Estate Industry.

https://www.nyc.gov/assets/planning/download/pdf/about/commission/calendar.pdf?r=012424

In-Person Location:

City Planning Commission Hearing Room, Lower Concourse
120 Broadway, New York, NY 10271

Below information came from DCP’s Website. Please confirm for yourself the below information because it might have changed!

Details on how to testify by videoconference will be posted on nyc.gov/engage one hour in advance of the meeting.
If you do not wish to testify but would like to watch the meeting via livestream, please visit

https://www.nyc.gov/site/nycengage/events/city-planning-commission-public-meeting/461665/1

 

 

 


0 Comments

Leave a Reply

Your email address will not be published. Required fields are marked *