I would like to thank the Department of City Planning for the opportunity to testify on the proposed scope of work for environmental review on New York University’s Plan 2031 development. I would also like to thank and commend the members of Community Board 2, and their chair Jo Hamilton, for their diligent work in thoughtfully and thoroughly responding to NYU’s proposals.

In 2006, I convened the Community Task Force on NYU Development to engage the community in ongoing discussions with NYU around its campus planning and to work with the University on developing a strategy that balances NYU’s growth needs with the community’s concerns. After 50 meetings over a 40 month period, the Task Force issued a document of over 75 findings and recommendations to the University that articulated concerns, suggestions, and guidelines for the University’s growth. This document laid the groundwork for the Community Board’s recent advocacy and their thorough response to NYU’s proposed scope of work.

The responsible expansion of a university such as NYU can be a great benefit to the economic, cultural and intellectual capital of New York City.  However, if that expansion is undertaken without proper community consultation or appreciation for shared physical space, there could be a negative impact to the delicate balance that underlies the continued success of the Greenwich Village neighborhood.

Like other major developments, this project must balance local needs with the University’s need to expand.  From my work on other university expansion projects, such as Columbia and Fordham Universities, I know that this balance is achievable – and all stakeholders can win.  New York City’s growth depends on finding a way for all sides of this process to remain fully invested in the City’s future.

Today’s hearing offers the public an opportunity to comment on the scope of NYU’s environmental study. Scoping hearings are essential for determining a framework that will ensure a fair disclosure of potential environmental impacts and identifying appropriate alternative development scenarios. As a participant in the ULURP process, I will not issue a formal position until the project is before me for review. However, I remain concerned about the potential negative impacts of the project.  In order to ensure a fair and accurate reporting of potential impacts, I echo the concerns diligently laid out by Community Board 2 and specifically ask that the study be modified as outlined below.

Alternatives

While many alternatives may be offered through the course of this hearing, the community and the Community Board have consistently requested modifications to the proposed project.  In order to ensure that these modifications remain feasible through the ULURP process, they should be studied as alternative development scenarios in the Environmental Impact Statement (EIS).  Based on community concerns, I strongly urge NYU to study at least three alternative development scenarios in the EIS: an alternative with lower density; an alternative that does not include a hotel; and an alternative that does not include the acquisition of the publicly-owned property known as the “park strips.”

Many residents have expressed concern over the projects’ total density at 2.5 million gross square feet.  The University is able to achieve this greater density through the proposed rezoning and because the development is a superblock.  Superblocks became prominent in the 1950’s as part of Robert Moses’ slum clearance program.  The superblock design allowed planners to create tower-in-the-park developments, which were carefully planned residential communities with ample open space and tall slender buildings.  NYU’s proposed expansion is centered on two such superblocks, which were created by demapping the public streets and combining six city blocks.  This demapping increased the size of the lots and allowed a greater maximum total density than would otherwise be permitted.  The original planners of these superblocks never intended for this density to be utilized.  As such, NYU should study a lesser density alternative, which will not only minimize the potential impacts, but would also address a clear community concern.

In addition, the EIS should study an alternative without the proposed 180,000-square-foot hotel use. The surrounding neighborhood is defined by its predominately residential and community facility uses with limited local retail.  The hotel use will introduce a new transient population, new deliveries and services, and more intense traffic and pedestrian flows.  This use has the potential to increase impacts and, depending on its operation, may not be compatible with the neighboring residential uses.  Further, members of the community have expressed that the placement of a hotel on the superblocks is inappropriate.  As such, the EIS should include an alterative that does not include the hotel at this site.  Without the hotel, a commercial zoning district may not be necessary and any such alternative should reexamine the proposed C1-7 zoning district.

Last December, I stood with the Community Board, other elected officials, and the larger community to oppose NYU's plans to acquire the open spaces located along Mercer and LaGuardia Streets that are owned by the Department of Transportation and urge that they remain as public open space.  This sentiment has a strong resonance with community members as it recognizes the dearth of open space in the neighborhood.  Community District 2 has one of the lowest percentages of open space in Manhattan.[1] Therefore, I continue to urge the University to develop an alternative that does not involve taking public land as part of the proposed project.

Open Space

Retaining the park strips is an important community goal, and as NYU’s expansion plans move forward, creating and maintaining high-quality public open space areas is certainly a top priority.  Community District 2 has some of the lowest open space ratios of any neighborhood in the City. In addition, the proposed project area is specifically identified in the CEQR Technical Manual as “underserved” in the amount of total open space.[2] The proposed project, may therefore not only affect public open spaces in the neighborhood, but can have significant impacts on the open spaces located on the superblocks. Any open space affected by the University proposal must receive careful consideration of its overall design and usability.

The proposed buildings will surround open space, which has been traditionally accessible to the public.  As such, the proposed project has the potential to have significant impacts on the quality of remaining open space on the block.  The project should be analyzed for the potential loss of mature trees, shadow impacts, and accessibility.  Given the scarcity of open space in the area, any identified impact on the open space must be minimized and receive reasonable mitigations to offset those impacts. 

Additionally, the proposal to construct a temporary gym on the site of the Mercer Street Playground would remove a valuable residential resource and neighborhood amenity.  As an alternative, the University should study other on-site and off-site locations for the temporary gymnasium including the use of existing University recreational facilities such as Palladium and student housing with athletic equipment in the building.  Moreover, the current open space plan relocates the dog park next to existing residential units.  From a land use and planning perspective, the close placement of these two uses may result in unintended conflicts.  NYU should study another location for the dog run that may be more appropriate and complementary. 

Finally, the proposed open space on Washington Square Village will replace the existing historic Sasaki Garden.  Recently the garden was placed on the State and National Registry for Historic Places. Any development on the site must be respectful of not only potential open space impacts, but also potential impacts on historic resources.

Transportation

NYU plans to add nearly 2.5 million square feet of new development which may include a combination of a hotel, classrooms, faculty housing, offices, and student dormitories.  These uses will introduce new populations which may have significant impact on the City’s transportation systems.  This impact may be further exacerbated during specific times of the year, such as at the beginning and end of the school year when significant numbers of students are moving in and out of dorm rooms.  As such, the traffic analysis should be expanded to include additional street intersections, as recommended by Community Board 2, and unique annual events such as move-in and move-out days for students.  Additionally, the Community Board’s suggestions for extended times and days of study should be strongly considered, since they come from residents who are familiar with the day-to-day traffic patterns and conditions.    

The increase in traffic and pedestrian flows should be considered, in particular, as they relate to and impact the response time of essential City services such as the Police and Fire Departments. Emergency response time in Manhattan has declined in recent years. According to New York City statistics, police response times have increased every year since 2007. It now takes an average of 8.4 minutes to respond, which is 90 seconds longer than the response time in 2007.  It is critical then for the EIS to study and identify mitigations to increased traffic that may be a further impediment on the delivery of these vital services. 

Socio-Economic Conditions

The displacement of residents in the neighborhood as a result of this project has always been a significant concern for this community.  I am specifically concerned with NYU's plan to introduce a Commercial Overlay Area at 15 Washington Place, which will help facilitate the conversion of a 74,000 square-foot residential building into a 129,000 square-foot academic building.  The resulting displacement is in contradiction to the Planning Principles my Task Force developed with NYU in 2006.  The University agreed to support community sustainability by preserving the existing diverse social and economic character of the neighborhood.  It recognized the importance of sustaining affordable housing and local retail.  In 2010, the Task Force's Findings and Recommendations reconfirmed these Planning Principles and stated that NYU should avoid displacing existing residential tenants.  I therefore urge the University to study the potential impacts of its development on the rent-regulated housing for the community.  

Additionally, I recommend the EIS include analysis of the proposed development's indirect effect on the increase in land rents at 505 LaGuardia Place. 505 LaGuardia Place is one of the few remaining Mitchell Lama properties in the area and is an integral part of the diverse housing stock in the Village. The Mitchell Lama has a land lease with NYU and its rent may be adjusted based on the value of the property. The proposed actions will facilitate new construction and will increase the value of the land. The proposed actions, therefore, could have an indirect effect on the affordability levels of the Mitchell Lama. These indirect effects must be studied and the University should make every effort to ensure it does not cause undo hardship on the residents of 505 LaGuardia Place.

Environmental Sustainability

Environmental sustainability reaches across many categories indicated in the CEQR Technical Manual.  I am pleased to see that all new construction will be held to LEED Silver standards, but as a leading center for learning and research, I urge NYU to set the bar even higher by exploring the highest level of sustainable practices possible. Further, as LEED ratings can be achieved through improvements in multiple environmental categories, it is important that the University provide a plan outlining specific anticipated sustainable practices.

Schools

School overcrowding has been a consistent problem for Greenwich Village and School District 2. In my reports “Crowded Out” (2008), “Still Crowded Out” (2008), and “School Daze” (2009), I found that every public school in Community Board 2 was at or above capacity.  The latest statistics from the Department of Education’s Capacity and Utilization Traditional Report 2009-2010, also known as the Blue Book, indicates this trend continues – P.S. 3 is at 112 percent utilization, P.S. 41 is at 118 percent utilization and P.S. 130 is at 111 percent utilization.[3] For years, Community Board 2 and local parents have been sounding the alarm on the severely overcrowded conditions in their local schools.

In recent years, these local schools have lost critical cluster spaces for art and music. Further, P.S. 3 and P.S. 41 have lost a combined three sections of pre-kindergarten over the past few years. Waitlists for kindergarten at the local schools have approached close to 100 children. Unlike other neighborhoods, if children do not move off the waitlist, there are no other elementary schools in Community District 2 they can attend. 

NYU’s Environmental Assessment Statement assumes it will not require a detailed analysis of the area’s public schools. This assumption, however, is based on the illustrative program not the maximum build out.  The illustrative program assumes only 105,000 square feet for faculty housing (a residential use) and not the maximum 200,000 square feet actually sought in the application.  At 600 square feet per unit, this could result in an additional 333 units and the families and children who will occupy them.

The lack of capacity in local schools means that even a modest increase to the public school population strains the existing infrastructure.  Every new public school student in this area will be added to an overcrowded classroom or sent to a school outside of his or her neighborhood.

The existing statistics on the area’s crowded schools and the proposed scale of NYU’s project warrant special considerations, and a full study of the impact of the project on the public school system is warranted.  Further, as the surrounding schools are simply unable to absorb an additional student, NYU must propose full mitigation for any potential impact.  

I was dismayed to learn that NYU’s commitment to donate space for a school did not extend to providing physical space and had an expiration date as indicated in their Draft Scope of Work. Providing space for a school means more than just giving the dirt patch.  Children need a building for their desks and seats to learn.  The University needs to live up to its commitment and come back to this community with a proper alternative that includes a core and shell for the school.    

Conclusion

I look forward to seeing the results of this Environmental Impact Statement and urge that all potential impacts be examined carefully and thoroughly. In the meantime, I encourage the University to continue working closely with the community to ensure that any future development properly balances the needs of the community and the need for the University to grow.

Thank you again for the opportunity to testify.