FULFILLING THE PROMISE OF MANHATTAN’S FAR WEST SIDE A Regional Plan Association Position Paper

{ July 2004 } Contents

Foreword 3 Executive Summary 4 Regional Development Principles 8 Development Priorities And The Far West Side 10 A Phased Strategy For The Far West Side 14 Components Of The Hudson Yards Plan 18 Zoning 18 Amenities And Urban Design 19 Transportation And Access 20 Javits Convention Center Expansion 22 The Western Rail Yards And 23 The New York Sports And Convention Center Financing 31

2 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER FOREWORD

RPA envisions the growth of a new, 21st Century more extensive than Board participation on any business district on the Far West Side of Midtown other issue in memory. The Board represents the Manhattan– a 24/7 mixed-use neighborhood region’s great diversity of professions, places and that emphasizes office development but includes interests, and naturally includes a broad range of significant residential, retail and entertainment opinions on any topic. In the course of the Board’s uses. Its modern buildings are environmentally- discussions, several Board members expressed friendly and nurture a tapestry of activities, with the view that the City's plan had been prepared office space, housing units, retail and nightlife as a package and the concern that removing activities woven tightly together. It is a place with any single element could put the whole effort grand new public open spaces that draw its resi- at risk and jeopardize this unique opportunity dents, workers and visitors to the great Hudson to develop the Far West Side. Others strongly River waterfront that defines its western edge. supported certain aspects of the City's plan that The City and State of New York have put RPA opposes, most notably the proposed New forward an ambitious proposal aimed at real- York Sports and Convention Center. In keep- izing this vision. Over the last year, RPA has ing with 80 years of tradition, at the end of this undertaken an intense assessment of the City-State process the Board broadly supported the release proposal in the context of the region’s needs and of this Regional Plan Association position paper. outlook. In the process, RPA has studied several Even after a year of research, this paper has current and past alternative plans, including the gone through several iterations and has been visions for the Far West Side that RPA articulated modified based on input from the City and the in each of its three regional plans. The effort RPA Board of Directors, and a review of the also included analyses of current trends, future Environmental Impact Statement released in projections and critical issues, much of which were June. The paper articulates the principles and articulated in three RPA research papers address- objectives that shape RPA’s recommendations. ing development, transportation and design issues. The Hudson Yards plan reflects a particular set of As important as the research, however, has values and priorities that determine how the City been an extensive dialogue with a wide range and State weigh the potential benefits and risks of of stakeholders and experts. Throughout this different policy choices. Similarly, RPA’s vision process, the plan’s supporters, including City and for the Far West Side is rooted in development State officials, the New York Jets and NYC2012, priorities that reflect our mission of promoting have been open and accessible. Their willingness the long-term prosperity of New York City and to clarify and debate elements of the plan have the region. RPA’s goal is to inform the public on certainly improved it and provided considerable this critical debate and promote further dialogue opportunities for public discussion. Numerous with the City, the State and the public to achieve meetings with public officials, civic and academic the best possible outcome for the citizens of observers, and both proponents and opponents New York City and the metropolitan region. of the plan culminated in RPA’s Regional Assembly on April 16, 2004. More than 600 participants heard and debated a range of views on the Hudson Yards plan, the RPA research papers and alternative visions for the district. In the months before and after the Regional Assembly, RPA’s 56-member Board of Directors engaged in a dialogue with the RPA staff far

3 EXECUTIVE SUMMARY

Regional Plan Association strongly supports of creating new office districts to allow for redevelopment of the Far West Side with the future expansion of the economy is only one density and mixed-use character proposed by the of three critical development priorities, each of City and State of New York. This underutilized which has a momentum of its own and could area represents the region’s best opportunity to be affected by the plan for the Far West Side: create a new 24/7 district in the region’s central core that can grow with an evolving 21st Century • The region’s transit network has almost no economy. Our vision emanates from development capacity for growth into and within the principles that have guided RPA throughout its Central Business District (CBD), and fund- history and from our economic priorities for the ing for both maintaining and expanding the future. These principles and priorities lead RPA to system are very much in doubt. Plans for oppose construction of the New York Sports and development of new office districts on the Convention Center and support a phased strategy Far West Side and in other parts of the City that implements much of the City’s plan on a will be greatly impeded without essential revised timetable. Most successful redevelopment projects to expand transit capacity, such as plans are altered and revised several times before the Second Avenue Subway and a new Trans- implementation, and this plan must be flexible Hudson passenger rail tunnel. Accelerating enough to incorporate changes if it is to succeed. office development without increasing transit capacity will only add to congestion that could Development Principles and Priorities hinder overall growth for the city and region. RPA’s core development principle is that the entire The proposed #7 extension may be essential region benefits when high-density, high-value to the development of the district, but adds development is located in the region’s urban core no new capacity into or within the CBD. and in transit-accessible suburban centers. • Housing availability and affordability are persistent impediments to both economic • For the Far West Side and other locations growth and social equity. While addressing the within the urban core, public policies need for housing should not be the primary should encourage office activities, high- goal of the West Side plan, the district can density residential development, and civic, make important near-term contributions to cultural and entertainment functions that both market-rate and subsidized housing. have a clear need for a central location. • Existing and emerging commercial centers • The Far West Side needs to be developed in other parts of the region need to be in a manner that enhances the success of strengthened along with the Far West existing and emerging commercial centers. Side. Development of the district must • The proposed uses for the Far West Side should be carefully coordinated with the recov- maximize the value of the waterfront, one of ery of Lower Manhattan and plans for New York City’s most underutilized resources. expanded centers in the outer boroughs, • The district needs to make the best possible northern New Jersey and elsewhere. connections to the region’s transit network, to enhance both prospects for success Immediate Actions, Long-Term Flexibility and benefits for the rest of the region. The region’s challenge is to capitalize on the momentum created by the Hudson Yards plan to The Far West Side also needs to be considered advance all of these larger objectives. This requires in the context of regional priorities. The goal immediate action to launch an incremental

4 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER westward expansion of Midtown that will proceed proceed mostly along east-west corridors and east over several decades in tandem with develop- of Tenth Avenue. ment in other parts of the city and the region. While there is an urgency to get started, there 2. Expand the Javits Center. The first phase of is a danger in rushing projects that will impede the northern expansion of the Javits Center will the flexibility of both the district and the region attract more conventions and trade shows that to adapt to changing market conditions. In the will bring out-of-town visitors to the region near term, there is less urgency to create new and its hotel rooms and restaurants. The design office space than there is to address a critical of the Javits Center should be modified to add housing shortage and a long delayed moderniza- more pedestrian-friendly spaces at its fringes and tion of the transit network. Vacant space, planned potentially bridge over the highway to connect to construction and identified development sites Hudson River Park. should give Manhattan enough office space to accommodate expected demand until well into 3. Design a mixed-use alternative for the Western the next decade. However, without opening the Rail Yards site that will draw residents, visitors and Far West Side for development, New York City office workers to the Hudson River waterfront. will eventually be unable to meet growing com- While much attention has been focused on the mercial demand, even if the timing, strength and potential merits or problems of the proposed New character of this market is impossible to predict. York Sports and Convention Center (NYSCC), To meet this challenge, RPA supports a phased the real question is whether it is the best use of implementation of most of the elements of the this critical piece of waterfront property. RPA Hudson Yards plan that will maximize benefits opposes development of the NYSCC because and minimize risks for economic growth, the the facility represents a suboptimum use of a City’s fiscal outlook, the region’s transportation site that is key to the long-term development system and the recovery of Lower Manhattan. of the district. There is no compelling need to Specifically, this strategy would unfold as follows: place this in a part of the city that should be devoted to high-value, high-density office and Phase I: 2004-2009 residential development. Its construction is in conflict with the district's overall goals, and 1. Proceed immediately with rezoning and public will stifle its long-term potential by limiting realm improvements to allow the district to respond waterfront access, adding congestion and loom- to market demands. By implementing the rezoning ing over the adjacent streets and Hudson River plan for the Far West Side, the district can imme- Park. Fortunately, the alternative is not simply a diately take advantage of the great demand for choice between the NYSCC or an open rail yard. residential development in areas that are currently The City and State should immediately pursue served by transit and facilitate redevelopment an alternative use that would catalyze the next west of Eighth Avenue. The public review process phase of development. With public investments should explore ways to improve the flexibility of comparable to those proposed for the NYSCC, the zoning, but this should not impede approval in there should be strong market demand on the site early 2005. In addition to the rezoning, highly vis- for private development. This location is ideally ible and relatively low cost investments in public suited for high-density residential development spaces, streetscapes and open space can encourage that would take advantage of its waterfront loca- this transformation. Development, which could tion and Manhattan's persistent demand for new also include some office construction, is likely to housing locations. The design should include

5 public open spaces, walkways and connections to district with unimpeded access to the Hudson Hudson River Park that will draw city residents, River. Public investments in infrastructure office workers and tourists to the western edge on both the Eastern and Western Yards at the of the district. New residents and visitors should beginning of this phase would allow for initial spur the development of restaurants, shops and development on both sites before 2015. cafes and the City can actively recruit cultural and community uses to further attract activity without 3. Complete the second phase of the northern the negative impacts imposed by the NYSCC. expansion of the Javits Center. Assuming contin- ued growth in the convention market, this will In this initial phase, the Yards should be re-zoned further strengthen the region’s competitiveness for for high-density mixed use and included in the exhibition and trade shows. overall zoning package currently being reviewed. A master plan should then be designed for study Phase III: 2016 – 2020 in the final EIS, due to be completed in the com- ing year. 1. Deck the Lincoln Tunnel “spaghetti” infrastruc- ture. Building over the exposed Port Authority Phase II: 2010-2015 infrastructure that snakes through the redevelop- ment area will remove a major barrier to the natu- 1. Complete the first leg of the #7 subway exten- ral westward development of the district. While sion. Investment in transportation access is the the actual covering and development is not antici- single most important action for spurring com- pated for a decade, the City and Port Authority mercial development west of Tenth Avenue. should complete their discussions to reach an Extending the #7 to a new station at 34th Street agreement on how this action can be implemented. and 11th Avenue will build on the momentum of More aggressive measures may be needed to pri- the first phase and trigger a more intensive west- oritize mitigation of this blight in the heart of the ward expansion of the district. This schedule will Far West Side. give Lower Manhattan an additional five years to recover before it begins to compete with office 2. Construct the second phase of the #7 subway projects on the Far West Side. It will also help extension. The 41st Street station of the #7 exten- limit the fiscal risk by allowing some initial devel- sion would be built in this period. Along with opment and further analysis of financing plans decking the Lincoln Tunnel infrastructure, this before major investments are made. Finally, it will will allow for office development in the northern allow time for construction to begin on the transit portion of the district in the later years of the expansion projects that are vital to the success of build-out period. the new district and the growth of the regional economy. Comparative Advantages and Risks 2. Complete public investments in the Eastern and Western Rail Yards and open space network. Every strategy entails inherent advantages and These investments will provide development risks. The strategy proposed by the City and the sites, open space and other amenities that should State seeks to capitalize on broad support for a pave the way for development of a dense, mixed- 2012 Olympic bid, a willing investor in the New use district on the western edge of midtown. York Jets, and the need for an expanded Javits It will open up the southern corridor of the Center to spur rapid approval of zoning and

6 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER infrastructure investments. It is hoped that this proposal assumes that rezoning, infrastructure “sports and convention corridor” will generate investments and gradual westward development immediate economic and fiscal benefits and will generate sufficient demand for predominantly become a magnet for pedestrian life and retail residential mixed-use development of the Western activity that catalyze commercial development, Rail Yards, with a strong open space component. primarily between 10th and 11th Avenues. If it proves difficult to attract sufficient private Supporters of the City’s plan fear that interest in the Yards, then development of the attempts to substantially revise it could doom district could be impeded. However, the City's the entire effort, leaving the district undeveloped entire plan is predicated on generating private for decades. Some observers have suggested development through zoning and infrastructure. that the elements of the plan were designed as a There is no reason to believe that these forces coherent whole, and that elimination, delay or would be any less likely to develop the Western modification of any of these components would Yards than the Eastern yards site or the pro- require a rethinking of the entire plan. Others posed mid-block boulevard between 10th and are concerned that the plan would lose important 11th avenues. In fact, the waterfront location political support among key constituencies if of the site should enhance its attractiveness. some elements, such as the New York Sports Another risk is that, if the City's economy and Convention Center, were dropped. expands very rapidly over the next decade, then RPA believes that its recommendations will the proposed phasing of the infrastructure make redevelopment of the Far West Side more investments could limit City employment likely rather than less. These recommendations growth in the 2010-2015 period. However, substantially accept the elements of the Hudson this level of growth is unlikely, and the Yards plan other than the New York Sports and risk is minimal compared to the potential Convention Center and the timing of the infra- for seriously impeding Lower Manhattan’s structure investments. The projected economic recovery with the current phasing strategy. benefits for the NYSCC are based on assump- The strategy described in this paper is tions for the highly unpredictable convention intended to maximize the strengths and minimize business, and both stadia and convention centers the risks of the Hudson Yards proposal. The frequently fail to live up to the claims of their rezoning and infrastructure investments are the proponents. These types of facilities have not keys to the birth of a dynamic new mixed-use attracted the type of large-scale office develop- district on the Far West Side. The proposed ment elsewhere, and are unlikely to do so on the revisions will make the most of the district’s Far West Side. The NYSCC is also by far the most waterfront location and build greater flexibility controversial element of the plan, and its removal into both the timing and character of develop- would increase support for the plan as a whole. ment. They will also help insure that development A different phasing strategy and altera- of the Far West Side proceeds in tandem with tions to the plan should also not impede its recovery and growth in other parts of the region. realization. History suggests that large scale The tremendous City-State effort provides the redevelopment projects, such as Battery Park vehicle for realizing the potential of the Far West City or Times Square, generally progress Side, and we must now take advantage of this through several iterations before they are imple- unique opportunity with the best possible plan. mented. In fact, flexibility and adaptation are essential ingredients to any successful plan. RPA’s proposed alternative also has risks. The

7 REGIONAL DEVELOPMENT PRINCIPLES

Regional Plan Association’s strong support for den- ences between districts within this core, the sity and mixed-use development on the Far West growing office districts on the periphery of Side emanates from the principle that high-value, Manhattan represent places where companies high-density development is most appropriate in the in Manhattan can diversify and expand in region’s urban core and in transit-accessible subur- close proximity. Regional downtowns, such ban centers. as White Plains, Newark and Stamford, This strategy maximizes economic benefits represent the next level of transit accessibil- by making the most efficient use of existing ity and existing density. A third tier would infrastructure and the agglomeration of diverse include both current and emerging suburban activities that are essential to attracting high- centers that can consolidate much of what value economic activity. It serves social equity would otherwise be low-density sprawl. goals by making jobs and services more acces- sible to the region’s low-income residents, who • Location criteria: The optimum location for are predominantly located in New York City an activity depends on balancing several and older urban centers, such as Newark and factors—the value of the activity, its land Bridgeport. It safeguards the region’s environ- intensity, its transportation needs, and how ment by limiting development in environmentally well it complements the existing or desired sensitive areas and the depletion of open space. character of the place. By these criteria, Center-focused and transit-oriented devel- activities on the Far West Side should ideally opment principles become complicated when be those which have a high value relative to it comes to evaluating where facilities such as the amount of land consumed, require and sports stadia, convention centers and other large, promote a very high level of transit service, special purpose structures should be located. and help attract office tenants without harm- Almost any activity located in the Manhattan ing surrounding residential and commercial Central Business District (CBD) will have a districts. These criteria need to be tempered by higher share of transit use than a similar facility the specific constraints of the place, including located elsewhere. The question is whether such its topography and the existing structures and a facility is the best use of scarce land in the uses that need to be accommodated or altered. CBD, and whether alternative uses might not be more beneficial on a number of criteria, includ- • Priority uses: For the Far West Side and other ing economic returns, the most efficient use of locations within the urban core, this translates transit infrastructure, and social equity goals. into a priority for several specific activities: Therefore, in addition to RPA’s broad mission of supporting growth in high-density -Office, particularly for high-value services; centers, the recommendations in this paper are -High-density residential; informed by a more specific set of develop- -Civic, cultural and entertain- ment principles related to the Far West Side: ment functions that have a clear need for a central location; and • Center criteria: Highest density is most -Support functions that are required to appropriate in an “extended regional Central make this agglomeration work (retail, Business District” and the eleven regional services, open space, some types of downtowns that were identified in RPA’s industrial and distribution functions). Third Regional Plan. The extended CBD includes Midtown and Downtown Manhattan, • Relation to the rest of the urban core: One of Downtown Brooklyn, Long Island City and the enduring strengths of the New York region New Jersey’s Hudson County waterfront. is the diversity and flexibility of its network While there are considerable functional differ- of highly-developed commercial centers and

8 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER infrastructure systems. The existing agglom- erations in Lower Manhattan and Midtown are unique and nearly impossible to replicate. The Far West Side needs to be developed in a man- ner that enhances, or at least does not dimin- ish, the success of these places and the trans- portation, power, communication and other infrastructure systems that make them work.

• Waterfront use: New York City’s waterfront is increasingly recognized as one of the city’s most underutilized resources. The proposed uses for the Far West Side should maximize the potential of its access to the Hudson River waterfront, not only for the success of the district but also for its role in the success of the Hudson River Park and its importance to the city as a whole.

• Transportation connections: The impacts of redevelopment are determined not only by what happens within the district but by what it stimulates in other parts of the City and region. The beneficial impacts are enhanced to the degree that the district is connected to multiple locations.

These principles are the starting point for determining how to redevelop the Far West Side. For these principles to have meaning, however, they must be connected to the actual context in which redevelopment will occur. This includes not only the planning and design constraints within the district itself, but also the regional economic, development and financial context that will determine both the success of the plan and its impact on the city and region. The objec- tives and strategies for the district need to flow from this context as well as core principles.

9 DEVELOPMENT PRIORITIES AND THE FAR WEST SIDE

RPA’s recommendations for the Far West Side are based on long-standing regional development pri- 2. Improve housing availability and affordability orities. The City has made a strong case that now to reduce these persistent impediments to both is the best opportunity in 80 years to realize the economic growth and social equity. Throughout vision of a redeveloped Far West Side, and RPA the region, the high cost of housing has become supports immediate action to capitalize on this one of the leading economic concerns as busi- momentum. However, the context in which these nesses find it increasingly difficult to attract plans proceed must be understood as well. A num- workers within a reasonable commuting distance ber of metropolitan development priorities must of their jobs. As documented in Out of Balance, proceed in coordination so as not to constrain the a recent report by RPA and the Citizens Housing overall capacity for growth. and Planning Council, housing affordability is at a crisis level for lower-income residents, while the combination of growing costs, lengthening com- The goal of creating new office districts to mutes and inferior housing quality pose increasing allow for future expansion of the economy competitive and environmental challenges for is only one of several development priorities, the region. While the need for housing should each of which has a momentum of its own that not drive the West Side plan, the Far West Side could be affected by the Far West Side plan: should complement Mayor Bloomberg’s housing plan, lend an immediate boost to both market rate 1. Maintain and expand the transit network that and subsidized housing, and provide a model for drives the region’s economy but is underfunded new approaches to funding affordable housing. and out-of-date. The region’s transportation system is at a critical juncture with enormous 3. Strengthen existing and growing commercial implications for the economy of New York City districts, including Lower Manhattan, and create and the region. Just as the Far West Side has lain a series of new mixed-use districts to expand fallow for decades, the capacity of the region’s the supply of office space in the urban core. transit network has not expanded in over 60 years Development plans for the Far West Side must despite substantial population and job growth and be viewed in the context of past and future dramatic changes in settlement patterns. Much growth trends and needs throughout the region. of the transit network is at or near capacity, par- Because of its potential to create a contiguous ticularly into and within the Manhattan Central expansion of Midtown, which is the region’s Business District, or is not adequately connected primary district for attracting high-rent office to growing sources of jobs and labor. For the first tenants, the Far West Side is likely to serve a time in decades, major capacity expansion projects different market than other districts. However, are advancing, particularly the Second Avenue plans for Brooklyn, Queens, and Hudson Subway, Long Island Rail Road access to Grand County could add another 40-50 million square Central Terminal, and a new Trans-Hudson pas- feet of office space over the same build-out senger rail tunnel. However, funding has not been period anticipated for the Hudson Yards. identified to complete these projects, and their With an integrated strategy, these plans can implementation is far from assured. Significant complement each other and provide the region development on the Far West Side without these with a growing, dynamic center with multiple projects will only add to congestion throughout location options for global businesses. However, the system and hinder overall growth in the city. there is the danger that public investments and

10 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER office construction will proceed in an inef- New York City’s loss of market share to the rest ficient manner, resulting in overbuilding or a of the region. In the 1970s and 1980s, over 110 failure to sufficiently differentiate these districts million square feet of new office space was con- to accentuate their particular strengths. structed in Midtown and Downtown Manhattan, Most notably, Lower Manhattan’s recovery about an equal amount in each decade. It is true is still in doubt. Its office vacancy rate remains that virtually no new office space was constructed above 14% and some companies are continuing to in Manhattan during the boom years of the 1990s. decentralize parts of their Downtown workforce. However, this was due primarily to the large New buildings under construction, the Freedom amount of vacant space available in the early years Tower and 7 World Trade Center, have yet to of the expansion and the reluctance of developers attract major private tenants. New public projects to repeat the mistakes that resulted in overbuilding and a commitment to world class urban design during expansion in the 1980s. New office projects and architecture by the City, State, Port Authority were beginning to advance at the end of the expan- and MTA provide reasons to be hopeful about sion, but were curtailed by the sharp contraction Downtown's future, but Lower Manhattan still in the technology sector, the decline on Wall faces an uncertain economic outlook and years of Street and, finally, the September 11 attacks. construction activity that could slow its recovery. Suburban office development occurred Unless the City experiences strong employment simultaneously with growth in Manhattan and, growth over the next several years, the Downtown as documented in the first of RPA’s three research office market is unlikely to stabilize before 2010. papers, The Far West Side and the Region’s Future Lower Manhattan represents an incompa- Development Needs, was actually stimulated by rable asset of existing businesses, residents and expansion in Manhattan. Manhattan’s share of infrastructure. Development of new office space metropolitan employment declined only modestly on the Far West Side will not benefit the City’s between 1980 and 2001, from 26% to 23%, while economy if it is at the expense of full utilization of its share of earnings increased from 32% to 36%. Downtown’s existing office space, infrastructure Suburban sprawl can be more appropriately and other assets. In 2002, RPA and the Civic attributed to a variety of factors, including half Alliance to Rebuild Downtown New York strong- a century of investment in highways rather than ly supported the ambitious and creative City pro- the transit network, demographic trends that posals to re-make Lower Manhattan. This vision contributed to labor force decentralization, and must be given every opportunity to succeed. the dispersal of lower-value office functions. In addition, office growth outside of the five ... boroughs does not necessarily contradict smart growth principles. For example, much new office To weigh these objectives, it is necessary to exam- construction built outside of New York City ine both past trends and future projections. The occurred in transit-accessible centers, such as City argues that the Hudson Yards plan must pro- Jersey City during the 1990s. The City and State ceed immediately and in its entirety to prevent the of New York have a legitimate fiscal interest in loss of jobs and residents to suburban locations, trying to keep commercial activity within their which it claims resulted from a lack of “space to political boundaries, and RPA strongly supports grow” in Manhattan. In fact, the lack of office the City’s efforts to strengthen business centers space in Manhattan is not the reason for either in places such as Downtown Brooklyn, Long the mushrooming of suburban office campuses or Island City and Jamaica. However, competition

11 with downtown centers in other parts of the that jobs grow from 2003-2010 at the same rate metropolitan area adds nothing to the regional that they did from 1993-2000, and thereafter economy or smart growth development patterns. at their average rate of growth between 1980 Looking ahead, it is clear that Midtown and 2000. While the 1990s are unlikely to will eventually run out of room to develop repeat themselves, this is a useful “best case” new office space. While business centers in the scenario. It indicates that current space would other boroughs, New Jersey or Connecticut be absorbed by 2009 and that other sites could can absorb some office growth that might accommodate growth until around 2017. have gone to Midtown, the region will be at a Beyond the current recovery, there are any competitive disadvantage if there is no capac- number of uncertainties that could affect both ity to expand its prime business location. demand and space needs, including technology This situation remains farther in the future, and demographic changes, structural changes however, than the City’s plan would suggest. in the economy and global competition. The While New York City’s economy turned primary value of the Far West Side is that it a corner in the last year, there are still tens of represents an opportunity to both anticipate millions of square feet of vacant office space and adapt to an economy that is likely to look that must be filled before demand will exist for much different than the economy of today. Its additional office space on the Far West Side. There potential to provide new office space may not is every reason to expect the economic recovery be an imminent need, but its ability to provide to continue, but its strength and duration are new space for both office and residential uses in difficult to predict. This recovery should begin to many different configurations can be a tremen- absorb both the large inventory of vacant space in dous asset to the future growth of the region. the region and the space that will be added from a number of planned office projects. Together, these account for about 115 million square feet in the region, about 70 million of which is in Manhattan. This includes projects such as 7 World Trade Center and the Freedom Tower, but not the other office buildings planned for the World Trade Center site. There is also the potential for nearly 30 million square feet in additional new construc- tion from identified sites in Manhattan alone. To absorb enough space to trigger the need for additional construction, Manhattan will need to attract 150,000 new office jobs. Other identified development sites could accommodate another 100,000 jobs. The chart below indicates when these thresholds would be met under dif- ferent assumptions. Using a forecast of office jobs in Manhattan by Economy.com, a highly respected private forecasting firm, it could take until 2015 before any new office construction is needed beyond currently planned projects.1 The alternative scenario in the chart assumes

1 This assumes that a vacancy rate of 8% requires new office space to accommodate demand efficiently, and that each new job will require 250 square feet of space. For a fuller discussion, see "The Far West Side and the Region’s Future Development Needs," Regional Plan Association, February 2004.

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This chart indicates when thresholds for construction would be met under different assumptions. Using a forecast of office jobs in Manhattan by Economy.com, a highly respected private forecasting firm, it could take until 2015 before any new office construction is needed beyond currently planned projects.1 The alternative scenario in the chart assumes that jobs grow from 2003-2010 at the same rate that they did from 1993-2000, and thereafter at their average rate of growth between 1980 and 2000. While the 1990s are unlikely to repeat themselves, this is a useful “best case” scenario. It indicates that current space would be absorbed by 2009 and that other sites could accommodate growth until around 2017.

13 A PHASED STRATEGY FOR THE FAR WEST SIDE

The City and State have devoted considerable attract businesses and residents. In large measure, resources and an extraordinary level of talent to RPA supports the specific solutions proposed address the formidable planning, design, financial by the City to address these issues—the rezon- and political barriers that stand in the way of imple- ing proposal, the Number 7 extension, and the menting a redevelopment plan. The plan also has decking of the Eastern and Western rail yards the attention of both citizens and public officials, and proposals for open space and amenities. who will now expect the Far West Side to remain The two other actions—expansion of the a focal point for the City's planning and economic Javits Center and construction of the New York development even if the current plan changes. Sports and Convention Center—are not essential This momentum and public focus must not be lost to redeveloping the district but could serve other as the plan evolves and moves forward. Like other goals. In fact, both facilities would impede water- successful large scale development plans, notably front access and occupy prime sites that could be Battery Park City and Times Square, success will devoted to uses more compatible with a mixed-use be achieved through flexibility and adaptation. district. In the case of Javits, the assessment needs to weigh the fact that the facility already exists and The City and State have articulated their goals that a strong case has been made for the need for clearly – to provide office space that will allow expansion. The NYSCC, on the other hand, rep- the City’s economy to expand, to improve the resents a new facility that would further wall off City’s competitiveness in the convention and the district from the waterfront and occupy a site tourism industries, and to bring the Olympics that could be developed for more compatible uses. to New York in 2012. These are all worthy goals RPA proposes an alternative approach that would that RPA shares. The recommendations in this allow development to move forward in a way that paper are designed to build on the tremendous supports all of the region’s economic development progress that the City and State has made while priorities, facilitates an organic westward expan- ensuring that redevelopment of the Far West sion of Midtown, and provides greater flexibility Side complements plans to address the City's to respond to the emerging development needs of and region’s other development priorities. the 21st Century. Removing the most controversial RPA proposes several changes in the strategy element of the plan, the NYSCC, may actually that the City is pursuing. The City argues that enhance the likelihood that the rest of the plan will the major elements of its plan -- revised zoning, be implemented. The facility would be replaced by extension of the #7 line, open space and amenity a mixed-use alternative, and would not remain an improvements, convention center expansion and open rail yard. The timing of the development will the New York Sports and Convention Center depend on market forces, but the transformation – must proceed as a package on the proposed of the district is likely to proceed even before the timetable or implementation will be endangered. Western Yards are developed, with residential and However, the plan can be fairly separated into some commercial development proceeding in the actions that are integral to the redevelopment of eastern part of the district and along the 42nd the district and those that must be to be justi- Street corridor. Once these areas develop, market fied on their own merits. The transformation demand for the Western Yards should increase. to a high-density office and residential district No course of action is without risk, but depends on three interrelated actions—rezoning the approach described below calibrates the to allow the development to occur, improved bold actions proposed by the City and the transportation access to support this development, State to the full range of development chal- and enhanced public spaces and amenities to lenges confronted by the New York region.

14 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER utilized to provide the greatest possible support Phase I: 2004 – 2009 for the high-value, high-density development that is envisioned for the district. Use of the site 1. Proceed with rezoning and public realm improve- should capitalize on its waterfront location and ments to allow the district to respond immediately the connection to the 30th – 34th Street corridor. to market demands. With the implementation RPA opposes constructing the proposed New of the rezoning plan for the Far West Side, the York Sports and Convention Center in this central district can immediately take advantage of the location. There is no compelling need for a second high demand for residential development in New regional football stadium, and there are alterna- York City, especially in areas of the district that tive locations that could potentially serve this are not dependent on the #7 extension and other purpose. The convention uses proposed for the infrastructure investments. While some modifica- facility, if needed, could be accommodated with tion to the rezoning plan is needed to allow for a more functional and less imposing extension more flexibility and residential income diversity, of the Javits Center. Further, by walling off the it should be implemented upon completion of district from the river and creating both auto and the public review process. Rezoning should pedestrian congestion, the facility will make the promote the beginning of a westward expansion area a less pleasant place to live and work, deter- of Midtown and will remove obstacles to more ring the long-term development of the district. extensive commercial development once the The alternative is not simply a choice between major infrastructure investments are made. the NYSCC or an open rail yard. Public invest- In addition to the rezoning, the City should ments in infrastructure on both the Eastern and invest in a series of highly visible, rapidly built Western Yards at the beginning of this phase but relatively low-cost public realm improve- would allow for mixed-use development on both ments such as tree planting and streetscape sites before 2015. While this would mean that improvements to make the area more attractive the rail yards would remain exposed for 5 to 10 to investment. With these actions the City can years, incremental development in the eastern promote private investment immediately, begin half of the district is likely to occur before the to collect some tax revenues, and encourage Yards are covered and developed. Commercial and the growth of residential-supporting uses. residential activity around the site is incompat- ible with an exposed rail yard, but substantial 2. Expand the Jacob Javits Center. The expansion development is unlikely to reach the western of the Javits Center northward will attract addi- portion of the district before 2015 in any case. tional convention business to New York City and In this initial period, the City and State promote spending at local restaurants and hotels should re-zone the Yards for high-density mixed- by out-of-town visitors. This improvement should use activities, and include them in the overall therefore be pursued immediately, though with zoning package for the Hudson Yards. They modifications to its design to better connect the should then proceed with design of an alternative facility to the waterfront and the adjacent district. master plan for the Yards for inclusion in the final EIS to be completed in the coming year. 3. Design a mixed-use alternative for the Western The alternative should emphasize residential Rail Yards site that will draw residents, visitors development with well-designed public spaces and office workers to the Hudson River waterfront. and amenities. It should also include guidelines to The Yards offer a one-of-a-kind opportunity meet several objectives -- compatible scale, visual adjacent to the Midtown CBD that should be and pedestrian access to the waterfront, and a

15 reasonable rate of private return on investment. open space and other amenities that should pave These early investments will capitalize on the way for development of a dense, mixed-use the momentum built by the City and ensure district on the western edge of midtown. that plans for the district are not abandoned Designing and implementing an alterna- yet again. These actions can be completed in tive development on the Western Yards will a relatively short timeframe and without rely- require that the redevelopment authority ing on complex financing mechanisms that request proposals for development late in the require greater scrutiny and public debate. first phase or early in the second phase. Actual development will take place once related public Phase II: 2010 - 2015 investments, especially the #7 extension and Eastern Rail Yards, are underway in this phase. While the rezoning and Javits expansion begin to reshape the Far West Side, three key regional 3. Complete the second phase of the northern events should unfold to prepare the Far West Side expansion of the Javits Center. Assuming for more intense development: the advancement continued growth in the convention market, of Lower Manhattan’s recovery; absorption of this will further strengthen the region’s com- the region’s vacant office space; and progress on petitiveness for exhibition and trade shows. key transportation capacity expansion projects. Movement on these three fronts will set the stage Phase III: 2016 - 2020 for the next phase of growth on the Far West Side by creating demand for new development 1. Deck the Lincoln Tunnel “spaghetti” infrastruc- and providing the transit network improve- ture. The exposed Port Authority infrastructure ments needed to support the #7 extension. that snakes through the redevelopment area will be a major barrier to the incremental 1. Construct the first phase of the #7 subway development of the district over the long-term. extension. RPA supports the extension of the #7 While the City has been in discussions with subway line as the best way to connect the City’s the Port Authority regarding air rights, and has subway system to the Far West Side. Completion included a mechanism in the zoning to allow of the first phase, with a station at 34th Street developers to fund the construction of deck- and 11th Avenue, will trigger development of ing by purchasing air rights, more aggressive the Eastern and Western rail yards, and later measures may be needed to prioritize mitigation development to the north of the yards. This of this blight in the heart of the Far West Side. schedule will allow additional time for Lower Manhattan to recover, as well as for construction 2. Complete the second phase of the #7 extension. to begin on the transit expansion projects that The 41st Street station of the #7 extension would are vital to the success of the new district and be built in this period. Along with decking the the growth of the regional economy. It must be Lincoln Tunnel infrastructure, this will facilitate noted that by itself the #7 extension brings no new office development in the northern portion of the capacity into the CBD -- it simply redistributes district in the later years of the build-out period. capacity in an already overcrowded system. When complemented by planned projects that The strategy described above will catalyze the add new capacity, particularly the Second Avenue birth of a dynamic new mixed-use district on Subway and a new Trans-Hudson passenger rail the Far West Side. By starting with the rezoning tunnel, the #7 extension will serve the mobility and Javits expansion immediately, momentum needs of an expanded Far West Side district. will be captured and results will be immediate. By slightly delaying the #7 extension and other 2. Complete public investments in the Eastern and infrastructure improvement until office demand Western Rail Yards and the open space network. grows, regional transportation expansion begins The City has proposed a strong urban design and Lower Manhattan recovers, the regional and amenity package that RPA largely sup- impact of the district will be complementary, not ports, with a unique open space network that deleterious. New York City will have created the creates a sense of place on the West Side. These capacity for growth as the demand materializes, investments will provide development sites, ensuring that high-value, high-density activities stay in the region’s core, where they belong.

16 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER Program City/State RPA Element Milestone Plan Plan

Rezoning Approval Early 2005 Early 2005

34th Street Station 2010 2015 operational No. 7 Extension 41st Street Station operational post 2010 2020

Phase I Expansion 2010 2010 Javits Center Phase II Expansion post 2010 2015

Multi-Use Facility complete 2010 n/a

Mixed-Use Alternative Western designed n/a 2005 Railyard Alternative Public Investments and Initial n/a 2010-2015 Development

Public Investment and Eastern 2005-2013 2010-2015 Railyard Initial Development

Midblock Boulevard to 36th 2010 2015 Street

Midblock Boulevard to 42nd Open Street post 2010 2020 Space Decking Lincoln Tunnel n/a 2020 Infrastructure

Public Space Improvements 2005-2010 2005-2010

17 COMPONENTS OF THE HUDSON YARDS PLAN

The following sections break down the City’s Discussion plan into its component parts, stating RPA’s The primary conclusion from RPA’s research and position and recommendations for each of the several noted real estate professionals and scholars major components of the Hudson Yards Plan: at the April Regional Assembly is that it is impos- sible to anticipate the mix of activities or space • Zoning requirements that will emerge over the next few • Amenities and Urban Design decades, suggesting that the City should build as • Transportation and Access much flexibility as possible into its plan. They also • The Jacob Javits Convention Center note that the commercial development may take • The Western Rail Yards and the New far longer to materialize than the City anticipates York Sports and Convention Center while residential development could proceed more • Financing rapidly. The City, RPA and most others are in agreement that substantial housing development ZONING is necessary to create a lively mixed-use district that will attract office tenants. However, several The City’s Proposal of the Assembly speakers and others interviewed The City is proposing a comprehensive rezon- by RPA argued that a more aggressive residential ing from manufacturing to commercial and schedule could make the district more attrac- residential uses for a new Special Hudson Yards tive to a broad range of office industries. District in the area roughly bounded by 8th Housing experts at the Assembly also noted Avenue, 30th Street, 43rd Street and the Hudson that both the City’s 80/20 housing mechanism and River. The heart of the concept is the proposal the Inclusionary Housing bonuses are relatively to create a spine of new high-rise, large floor rigid tools that target a narrow income band, and plate commercial structures organized along a may not result in either a substantial number of new boulevard between 10th and 11th Avenues. affordable units or a diverse population that could Within this commercial core, residential develop- enliven the district. The use of Battery Park City ment would be restricted to approximately 2 reserve funds to finance the convention expansion million square feet of market rate housing that also depletes a revenue source that was designated would be permitted only after a substantial for affordable housing when the Battery Park City amount of office development is in place. Authority was created, violating the spirit of the In total, the rezoning is intended to result original commitment, if not the letter of the law. in 28 million square feet of office develop- ment and 12.6 million square feet of residential Recommendations development that would be eligible for 421-a tax RPA supports the level of density proposed by the exemptions, which would require developers City and the objective of encouraging large-scale who take the exemption to create housing with Class A office development in the context of a 20% of the units affordable to lower income mixed-use district. The zoning also includes a renters, known as 80/20 housing. There is also range of neighborhood types, uses and densities a limited amount of density bonus that can be that can provide the basis for a dynamic and suc- obtained by creating more affordable units. The cessful extension of Midtown. RPA appreciates proposed stadium/convention center would be the City’s willingness to further evaluate ways developed by an Empire State Development to add flexibility to the use regulations dur- Corporation subsidiary and would therefore ing the public review process. This can best be not be subject to the City’s zoning resolution. accomplished with the following modifications:

18 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER Permit greater amounts of residential development • Include an affordable housing requirement for in the General Large Scale Development District any density bonuses that are granted in the that contains the 10th-11th Ave. commercial core. district. While this would reduce the value This can be accomplished either by reclassifying it of density bonuses to pay for infrastructure as a mixed-use area or creating more exceptions to improvements, it is a legitimate value capture the residential restrictions. The City has a legiti- strategy to fulfill an important public purpose. mate concern that residential development will absorb too many sites before commercial demand takes hold. However, there is a greater risk that AMENITIES AND URBAN DESIGN all development will be delayed indefinitely if the zoning incorrectly anticipates future demand. The City’s Proposal One way to limit both risks and accommodate The City has proposed creation of a network of greater flexibility is to establish commercial and new open spaces, principally in the new “10 ½ residential thresholds on a Special District-wide boulevard” and the public plaza to be located on basis and for the Commercial Core. This would the Eastern Yards. The City has also proposed allow for a wider range of building types and landscaping the “spaghetti” of roads, rails and uses in response to market demand in both areas. ramps serving the Lincoln Tunnel, the bus termi- Interim threshold levels could be set to trigger a nal and the Amtrak West Side right-of-way, but reassessment of commercial and residential targets decking over or otherwise screening only a small and design standards as the districts develop. portion of this area. Physical and visual access to the Hudson River would be seriously compro- The rezoning should be an opportunity to mised between 32nd and 42nd streets, both by the develop more creative approaches to achieving a proposed Javits Center expansion and the con- broader mix of residential incomes in the district. struction of the NYSCC on a prime riverfront site. Considering the amount of value that the plan could create, the City and State should work Discussion to create considerably more affordable units The open space network that the City has than the current mix of incentives would yield. proposed would be a major new amenity for the Also, both 421-a and the Inclusionary Housing district, helping to create a sense of place on the bonuses permit development for a fairly narrow Far West Side. Other amenities will be needed, income band, approximately $34-45,000 per however, to make the district attractive for the year for a family of three. This excludes many density that is planned. Physical and visual access households that would work in and near the to the River is one of the prime amenities around district and create a more diverse and vibrant which the district could be redeveloped. The neighborhood. A more creative and success- exposed “spaghetti” infrastructure in the middle ful approach could include the following: of the district presents a major impediment to the area’s success, and is not adequately addressed • Modify the 421-a program or develop a new in the City’s plan. It divides and blights the program specific to the district to both ensure district and removes large amounts of real estate that a minimum amount of affordable housing in the heart of the district from development. is developed and to cover a broader range of rent levels. This would require a more flexible or sliding income eligibility scale.

19 Recommendations can capture value for the City and Port Authority. The City has proposed a strong urban design This infrastructure separates the commercial core and amenity package that RPA largely sup- of the district from the rest of Midtown, making ports. There are two areas that require further it less likely that office tenants will be willing to work to truly make the district attractive locate there. While the City has identified a mech- for development: access to the waterfront anism for developers to pay for decking of the and the “spaghetti” infrastructure. ramps by purchasing the air rights from the Port Authority, we fear that this will be a last option Any Far West Side open space and amenity for developers and hope that decking of this area plan should include the direction of funding to will be integrated more directly into the heart of complete the section of Hudson River Park the plan. By pursuing this more aggressively, the adjacent to the new district. The park – a City and Port Authority could greatly enhance the longstanding priority of the State and City – is prospects for phased redevelopment of the district. clearly the most important open space amenity in the area and vital to waterfront enjoyment. However, construction of the Clinton por- TRANSPORTATION AND ACCESS tion of the park, from 38th to 45th streets, has not yet started and funding is not in place. The City’s Proposal The City’s transportation plan for the Far West Even with a complete Hudson River Park, the Side consists of extending the #7 subway line district as planned will suffer greatly from west and south from its current terminus in limited waterfront access. This can be attributed Times Square. The extension would move west to the nearly ten block wall that will be created along 41st Street, curving south below 11th by expanding the Javits Convention Center Avenue to a station adjacent to the NYSCC at and constructing the New York Sports and 34th Street and 11th Ave. A second phase would Convention Center, projects which we address include another station at 41st Street and 10th later in the document. Waterfront access in Avenue. The extension is estimated to cost this area will always be problematic because approximately $2 billion, with funding coming the deck over the rail yards will be higher than from a variety of value-recapture mechanisms the surrounding streets on three of four sides. as part of the City’s overall financing plan. Nevertheless, a less imposing development on the western yards, with more highly animated Discussion and variegated edges would be more successful To succeed as a mixed-use district, the Far in extending 31st and 34th streets to the river. In West Side will need to be easily accessible from addition, a less monolithic development would all directions. The #7 extension is designed to allow for the continuation of the 32nd Street axis, provide direct access from the east, and indirect which the City’s plan is promoting, across the access from the north and south via connections deck to the water. Residential development could at Grand Central and Times Square. No provi- easily accommodate better waterfront access. sion has been made for access from the west, even though NJ TRANSIT expects to run out The City should continue to work closely with of capacity into Penn Station by the year 2009. the Port Authority of New York and New Jersey to RPA’s analysis of the Far West Side plans pursue opportunities for decking over the exposed concluded that the #7 extension adds substantial infrastructure with appropriate development that capacity to the Far West Side from within the

20 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER city, but also presents problems for the larger the #7 to make a direct connection between system. For subway commuters, the #7 has enough Grand Central and Penn Station, an added capacity to accommodate most of the anticipated feature likely to cost upwards of $1 billion. commercial development, although it could lead to unacceptable levels of crowding when the full 28 Recommendations million square feet projected by the City is built. Extending the #7 line is the most effective way to RPA’s study also concluded that as the West connect the City’s subway system to the Far West Side grows, the #7 extension will lead to an Side, but it will not support long-term economic untenable situation at Grand Central Station growth unless other vital expansion projects are and the network of pedestrian passageways that also completed. The questions regarding transpor- connect the #7 platform with the Lexington tation for the Far West Side, then, revolve around Avenue subway line and Metro-North. The the timing and financing of the extension, as well construction of the Second Avenue Subway as what other projects would be needed to deal would solve this over-crowding. The Draft EIS with its impacts and provide additional service addressed this issue implicitly by assuming that to the new district, particularly from the west. the Second Avenue Subway would be completed. In so doing, however, the EIS neglects to directly Given that the need for office development in this acknowledge that without the Second Avenue area is unlikely to exist for more than a decade, Subway there will be a serious crowding problem. construction of the #7 line should be pushed back While the #7 accounts for commuters from until 2010. Some initial residential development the city, those from west of the Hudson River is likely to occur without the #7 extension, and seem to be overlooked entirely. This is extremely extending the subway line immediately will problematic, as 89 percent of the growth in lead to unhealthy competition with a recovering suburban commuting into Manhattan in the last Lower Manhattan and other markets in the City. 20 years has come from west of the Hudson River, Further, a reliable financing plan that has been and existing rail and auto links are already at, or vetted through a robust public process must will soon reach, capacity limits. In this case, the be in place before the project moves forward. draft EIS incorrectly assumes that the commuter The project must also be proven not to have a rail system will have the capacity to handle the negative impact on the MTA’s operating budget trips generated by the full build-out of the project. or on its ability to complete other approved First, the EIS underestimates the proportion of capital projects. Finally, it will allow time for rail commuters who will travel to and from points construction to begin on the transit expansion west of the Hudson River. The EIS assumes that projects that are vital to the success of the new the current geographic split will remain despite district and the growth of the regional economy. the overwhelming evidence of a massive shift of suburban commuting growth in the last 20 years Over the long-term, the major system expansion toward commuting from west of the Hudson sub- projects currently in planning – Second Avenue urbs. Second, it ignores the fact that current peak Subway, East Side Access and Access to the hour commuter rail capacity under the Hudson Region’s Core – must be completed for Far West River is at or close to its limits. The absence of Side plans to succeed. Without these vital expan- a new tunnel will likely curtail the ability to sion projects, development on the Far West Side achieve the projected growth for the project. and throughout the region will lead to further Some observers have also questioned the congestion that will hinder overall growth. impact on development of choosing not to extend Connections to Penn Station, such as express bus service and light rail should also be considered.

21 waterfront access. The existing convention center JAVITS CONVENTION clearly has not revitalized the neighborhood or the adjacent waterfront, impeding access and CENTER EXPANSION providing almost no activity in the surround- ing area. The expansion has the potential to The City/State Proposal aggravate this problem if not designed properly. The City and State have proposed a two-phased northern expansion of the Javits Convention Recommendations Center that would nearly double the center’s RPA strongly supports expansion of the conven- convention space. The expansion would add tion center to attract more conventions and trade meeting rooms and contiguous exhibition space, shows that will bring out-of-town guests to New as well as modernizing the entire facility. The York. However, current designs for the expan- first phase would go one block north to Quill Bus sion do not sufficiently connect the facility to Garage at 40th Street, with the second phase com- the waterfront or the adjacent district-to-be. mencing once the bus garage has been relocated. There have been discussions about a green roof, The northern expansion plan should be revised, access to the waterfront through the building at adding more pedestrian friendly space on all sides 39th Street and other amenities, but details have and potentially bridging over the highway in key been scarce. The project is estimated to cost $1.4 places to connect to Hudson River Park on the billion, with the City and State each contributing west. This edge of the convention center could approximately $350 million to the total pricetag. be lined with cafes, shops and other amenities, The convention function of the adjacent Sports creating a new destination for convention-goers and Convention Center has been positioned, and residents. Other options should be identi- most recently, not as part of Javits expansion fied for connecting through the facility to the but rather as an adjunct, complementary facility. waterfront, including a major connection via the No agreement has yet been reached regard- 39th Street corridor. These changes will not only ing the operation of the convention aspect of make the convention center a friendlier neighbor the facility, which we consider separately. for the new district, it will also make its suc- cess as a convention center much more likely. Discussion Regarding the southern convention space, the Although there are some voices of dissent, there following section discusses the reasons that RPA is broad consensus that the City is in need of opposes construction of the New York Sports more convention space, and that the Javits Center and Convention Center. However, RPA does not must be expanded. Most experts also agree that oppose additional convention space in New York the top expansion priority – beyond simply City, and would support its construction elsewhere adding more space – is to provide contiguity, flex- in the right circumstances. The possibility of con- ibility and a greater diversity of space, including structing additional convention space on the east more meeting rooms. The northern expansion side of 11th Avenue should also be closely studied. fulfills some of these needs, although there is speculation that the difficulties of moving the Quill bus garage may prevent the second phase of the expansion from ever being completed. A topic that has largely escaped debate is the impact of expansion on the new district and on

22 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER While proponents of the facility claim that this is THE WESTERN RAIL YARDS the only viable option for the site, there has been no in-depth analysis of potential alternative uses AND THE NEW YORK SPORTS for the site within the context of the City’s plan.

AND CONVENTION CENTER Discussion The site of the proposed NYSCC provides one- The City/State Proposal of-a-kind river frontage near the leading Central The City and State have proposed construction Business District in the country. At the nexus of the New York Sports and Convention Center of the waterfront, the 34th Street corridor, the (NYSCC) on a platform over the rail yards west Javits Center and the proposed 10th-11th Avenue of 11th Avenue, between 31st and 33rd streets. commercial corridor, use of the site will greatly The football stadium would be designed with a influence development in the district. Both sup- retractable roof to accommodate stadium events porters and opponents of the NYSCC acknowl- – football, international soccer, concerts, etc. edge that this site is crucial to the future of the – as well as indoor arena and convention events. Far West Side. While much of the debate about While the initial proposal called for many arena the project has revolved around traffic, revenue events, the latest iteration focuses on increased and usage projections for the proposed facility, convention usage, with arena usage limited to the key question to be answered is how the major events such as college basketball’s Final Western Rail Yards should be developed to best Four. The facility would provide 200,000 square support the broader goals for the Far West Side. feet of exhibition space, in addition to a plenary Related to the discussion of how the site hall for up to 40,000. The total cost for the facil- should be developed is the question of when ity is estimated at $1.4 billion, with the City this needs to happen. Clearly, commercial and and State each contributing approximately $300 residential activity around the site is incompatible million in public funds and the Jets financing $800 with an exposed rail yard. However, incremental million. Details of the financing arrangements development in the eastern half of the district is have not yet been finalized or made public. likely to occur even before the Yards are covered The proposed facility is a 300-foot high super- and developed. It is also reasonable to assume that structure encompassing two city blocks from 11th there would be strong market demand for hous- Avenue to the Hudson River that will host thou- ing or office development on the site if the City sands of people at a time for a variety of events, and State are willing to make public investments but will be largely quiet when events are not tak- similar to what is being offered to the New York ing place. Supporters see the facility as an econom- Jets. Both the Eastern and Western Rail Yards ic development tool, a vital expansion of conven- should develop as soon as the market materializes, tion space in the City, a key piece of the NYC2012 probably soon after the Number 7 line is extended Olympic bid and the catalyst for development but before development occurs between 10th and in the district. Opponents see it as a magnet for 11th Avenues to the north. In fact, if the zoning traffic congestion, an inferior convention center, and transportation improvements of the plan were the Achilles’ heel of the Olympic bid or a deter- in place today, there is every reason to believe that rent to development in the surrounding district. the City could attract a number of viable proposals to capitalize on the current shortage of locations to meet the explosive demand for new housing.

23 Recommendation ity located in the Manhattan Central Business RPA supports immediate pursuit of alternative District will have a higher share of transit use than development plans for the Western Yards site a similar facility located elsewhere. The question that better connect to the waterfront, animate the is whether such a facility is the best use of scarce neighborhood and support the development of the land in the CBD, and whether alternative uses district. Specifically, the site should be zoned for might not be more beneficial on a number of high density mixed uses with a strong focus on criteria, including economic returns, impact on residential development that could be combined surrounding locations, the most efficient use of with open space, cultural activities and many transit infrastructure, and social equity goals. of the same amenities that are being planned to The NYSCC does not meet this standard. animate the edges of the multi-use facility. RPA Neither football stadia nor convention centers opposes the construction of the NYSCC because need a CBD location to be successful. The poten- there is no compelling need to place this facility tial reduction in highway traffic on event days in a part of the city that should be devoted to due to increased transit use is a modest benefit high-value, high-density office and residential compared to the increased congestion the facility development. At a minimum, alternative uses are will bring to Manhattan entry points and streets likely to be far more successful in supporting and the opportunity costs of developing the site the goal of creating a successful commercial and for other uses. Most importantly, either com- residential district in the Far West Side. At worst, mercial or residential uses on the site, designed to the proposed facility may in fact impede these maximize waterfront access, open space and ame- goals. In any case, there are viable alternatives to nities, would do more to animate the district and the stadium that cover the rail yards and must be meet the region’s economic development needs. studied. These arguments are detailed below. The fact that there are no truly comparable examples in the world should be seen as evidence 1. Manhattan is the wrong location for a sta- that these facilities do not belong in central busi- dium/convention facility. As stated previously, ness districts, not for believing that this case will RPA’s support for a dense new district on the be different. Similar facilities have not been con- Far West Side emanates from the principle that structed in the heart of other CBDs because stadia high-value, high-density activities are the most are not efficient or compatible uses for these areas. appropriate uses for scarce developable land in While not completely comparable, it is instruc- the region’s urban core. Activities in the urban tive to consider the impact of other facilities in core should ideally be those which have a high North America. RPA studied facilities in Toronto, value relative to the amount of land consumed, Seattle, Baltimore and St. Louis in its research require a very high level of transit service, and paper, The Far West Side: An Urban Design help attract office tenants without harming sur- Analysis. The paper concluded that the biggest rounding residential and commercial districts. issue, beyond the transportation and urban design Land-intensive, special use facilities must challenges, is what kind of development these meet a very high standard to be located in the projects can promote in adjacent areas. When clus- core of the region, particularly in a district where tered together, stadia and convention centers often the primary goal is to encourage the development make for a successful tourist corridor, but as yet, of Class A office space. The City has argued they have not shown the ability to sponsor devel- that constructing the proposed NYSCC in the opment of intensive mixed-use districts. There is CBD would be an example of smart growth or little evidence of such facilities thriving in districts transit oriented development. Almost any activ- as dense as the one proposed for the Far West Side.

24 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER 2. The proposed NYSCC does not support the A less imposing development on the western district’s long-term goals. There are many unique yards, with more highly animated edges would aspects of Manhattan, the Far West Side, and be more successful in extending 31st and 34th this facility and site, and the Jets and the City streets to the river. In addition, a less mono- have gone to great lengths to design the facility lithic development would allow for the contin- and add uses that will minimize the problems uation of the 32nd Street axis, which the City’s usually associated with football stadia. However, plan is promoting, across the deck to the water. RPA’s research concludes that the NYSCC will likely deter, rather than attract, the large-scale • The mass and volume of the proposed facility redevelopment that the district needs. Despite will create an unpleasant pedestrian experience all the effort that has gone into this plan, many in its vicinity. The City and the Jets have made of the essential characteristics that make stadia several changes to soften the impact on the poor neighbors for office and residential tenants pedestrian experience of what will be one of remain. During major events, the area will be the single largest structures in the City. The congested with auto and pedestrian traffic. On challenge of fitting a regulation-size football nights when no events take place, the facility will stadium onto a constrained urban site results be a massive superstructure that is likely to deter in a structure that is still essentially a two- pedestrian activity on all sides. At all times, the block “superblock,” up to 300 feet high. building will obstruct access and connections Along the 34th Street corridor, there are to the waterfront, helping to create a nearly ten intermediate-scale structures at the base of the block wall, along with the expanded Javits Center, stadium which are meant to create the same between the new district and its most important effect that a base and set back would achieve amenity. Siting the NYSCC in this location would for a less massive building type. On the other limit the potential of the waterfront, disrupt three sides, the strategy for integrating the the pedestrian experience in the new district stadium into the pedestrian experience of the and add an unpleasant level of congestion. streets and the surrounding context of the Hudson River Park is to line the ground floor • The NYSCC would limit the potential of the with retail uses, some of which are shown in waterfront. For this district to succeed it must the renderings as spilling out onto new public offer a package of unique amenities to potential spaces along the first story of the structure. In developers, businesses and residents. At the top addition the design tries to break up the big of the list should be the Hudson River water- box by layering it inside a more transparent front, the district’s natural western border. superstructure, evoking the cables and steel RPA acknowledges the need to expand Javits beams of the George Washington Bridge. to the north – and this paper discusses ways to These are worthy strategies but fail to relieve potentially connect that expansion to the water the massive scale of this edifice. – but laments its negative impact on waterfront The pedestrian experience is not limited access. The stadium will extend the wall that to what happens in the first fifteen or twenty separates the new district from the waterfront, vertical feet of street wall, even though this in the form of a towering superstructure. is where textures of materials, landscape ele- While the extension of Hudson River Park ments, street furniture and transparency to over the West Side Highway is a good idea, it the activities within buildings come together could be done in more effective fashion if the to create the primary street experience. The development over the yards were less bulky. overall quality of the street as a space is also a

25 function of what happens above this zone. The doors from morning to evening, with interior amount of transparency on the upper stories, food courts to ensure that no time (or money) level of architectural articulation and, perhaps is lost by patrons venturing away for lunch. most importantly, changes in the massing Despite the daily pedestrian traffic generated or volumetrics of the building impact how by the Javits Center today, few ancillary the structure fits in its surrounding area and activities apart from parking lots have been how it is perceived from the street. Changes spurred by the Javits Center’s location in in massing create the intermediate scale that the district. Therefore, the incorporation of is also part of the experience of the district, convention uses at the NYSCC does little to in addition to allowing for day lighting. This stem the concern that the facility will have is precisely the logic behind the height and a deadening effect on the neighborhood. setback regulations that are properly being In fact, while the City claims that “the imposed on the rest of the district. It is also NYSCC will be alive with sports, entertain- part of the logic behind the City’s Unified ment, and convention uses every single day of Bulk Program created in reaction to the “tower the year,” their own analysis anticipates only and plaza” developments that abandoned the 136 event days annually. This leaves 229 days street wall. per year in which the NYSCC would rely on To get a sense of how out of proportion the its animated edges to enliven the neighbor- NYSCC will be with the rest of the district, hood, like the planned terrace café, retail, it is helpful to compare the NYSCC’s 20 to 31 farmers market, and open space—activities that story façade with the set-back requirements for could exist in the district without the NYSCC. the rest of the area. Despite all the increases in These uses—particularly the retail and café density, the maximum allowable base height establishments—will bear the burden of in the rest of the district will be 150 feet, or activating an otherwise undesirable and static 15 stories, before setback. Other areas will urban form on days that the NYSCC hosts have street facades of only 60 feet, or 6 stories. no activities, and will have to do so without Thus, the pedestrian experience of the NYSCC the foot traffic generated by event patrons. will be a building up to twice as tall and imposing as the next largest building bases in • The facility will have a negative traffic impact the district – creating a sheer vertical structure on the surrounding neighborhood, Hudson River of 200 to 300 feet. The City and Jets have Park and entertainment activities in the City. done an admirable job of “taming a monster,” The fear of greatly increased congestion associ- but in the end, there is legitimate concern ated with events at the sports and convention that the stadium will seem to loom over the center has been one of the main sources of streets around it and the Hudson River Park. opposition for local residents, elected officials and those in the theater community that • The facility will fail to animate the surround- oppose the project. While RPA’s main concerns ing area. As demonstrated by the impact with the facility are not based on the projected of the Javits Center on the surrounding traffic, we remain concerned that the facility district, it is clear that convention activities would add congestion to an already heavily do not necessarily contribute to animating clogged district. a neighborhood. Indeed, conventions aim Two sets of traffic studies are routinely precisely to keep their patrons inside their referenced by supporters and opponents of the

26 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER stadium, respectively. Supporters note two sur- and include more green time, changes to veys of Jets season ticket holders that predict signal timing and phasing, striping of lanes, in excess of 70 percent will use mass transit changes from two-way to one-way streets (11th to attend Jets games. These surveys failed to Avenue), and discounts for using transit and look beyond football games, which are likely “intelligent transportation systems,” among to make up only half of stadium events, and others. But at some intersections no mitiga- didn’t account for the many season tickets that tions capable of relieving traffic have yet been are shared or sold by their original owners identified. Moreover, the effectiveness of the during a season. In addition, asking people to proposed mitigation measures remain in doubt predict their future travel behavior is far from pending further study. scientific. What we do know is that since 95% Thus, the question is not whether the facil- of Jets fans currently travel to games by auto, ity will add to the area’s congestion, but to if transit proves less convenient they can easily what extent and at what price. Theater owners decide to drive, with thousands of parking representing more than half of all Broadway spots planned or existing in the area. theaters fear that increased congestion will The other set of surveys were commissioned come at the cost of their business. On a major by Madison Square Garden, which opposes the event day, an already congested trip into Times proposed stadium, first in 1987 and then in the Square would be made even more difficult. past year. The 1987 study looked at travel to Broadway adds upwards of $4 billion annually and from three weeknight events, and found to the City’s economy, drawing more than transit usage averaging approximately 50%. 200,000 weekly patrons. Most importantly, The more recent study provides similar figures, 55% of these theatergoers arrive from out-of- with a transit low of 40% for one Sunday the-region, staying in the City’s hotels and event. Both studies looked at a limited number eating at its restaurants. The region’s economy of events, and have been criticized by the City cannot afford to jeopardize this asset. and the Jets as biased due to their association Finally, Hudson River Park – already with a stadium opponent, MSG. overcrowded on weekends – will have to While it is difficult to draw definitive accommodate thousands of people walking conclusions for an unbuilt stadium, it is very and possibly “tailgating” between the ferry unlikely that a facility located between 11th terminal and the stadium, making the park Avenue and the West Side Highway would a de facto extension of the stadium on event have greater transit ridership than Madison days. Even 15 or 20 major events will limit the Square Garden, located directly on top of the benefit of the park as a community amenity Long Island Rail Road, NJ TRANSIT and two and magnet for residential development. subway lines, and one block from three other subway lines. 3. From a regional standpoint, the proposed Even if one assumes that the Jets’ projec- NYSCC is not necessary. In addition to the tions are correct, almost ubiquitous traffic mit- arguments against constructing this facility igation measures will be necessary, as reported in Manhattan generally and on the Far West in the draft EIS. On special event days the EIS Side specifically, RPA questions whether a projects that 26 intersections will be seriously new facility is even necessary from a regional affected and on “football Sundays” 35 intersec- standpoint. While the facility would include tions seriously affected. Mitigation measures some attributes new to the region, they can be are identified for the majority of intersections, provided elsewhere, and in any case do not justify a project that is a poor fit with its surroundings.

27 • Economic Impacts: In addition to the addition, the benefits to the metropolitan NYSCC’s impact on development in the region would be significantly less than esti- district, the facility’s ability to generate mates of benefits for the City alone. Benefits jobs and income from its operations are an related to some uses, particularly stadium uses, important consideration. This involves not largely represent a shifting of activity from only estimating how many jobs and how much one part of the region to the other, resulting economic output it would produce, but also in no net gain for the region as a whole. how these benefits would compare to alterna- tive uses that could be produced by similar • Stadium Usage: Regardless of the other investments in public subsidy and land. uses proposed for the NYSCC, it is fair to The Hudson Yards draft EIS adopts evaluate its impact first as a football stadium. estimates of the jobs, output, wages and Structurally, the facility is a stadium. It will tax revenue that would be produced by the be developed by a football team, and we can NYSCC from the studies undertaken by the expect that the needs of the Jets will get prior- New York Jets. These studies, particularly a ity over other uses. RPA has been strongly study by Ernst and Young, estimates that the supportive of creating an office district on the facility will create 6,971 jobs, add $623 million West Side because this is an appropriate use for annually to New York City’s economy, and the CBD and because there is a long-term need generate $72.5 million per year in tax revenues to develop office space in the region’s core. for the City and the State. The largest share of The same cannot be said for a football stadium. these benefits result from activities that are not The Meadowlands complex was designed for related to Jets football games—national events this express purpose, and will better serve fans such as a Super Bowl or political convention, from New York and throughout the region plenary sessions for large events, and exposi- when a new transit link is built in the coming tions such as trade shows and conventions. years. New Jersey has plans to invest $300 mil- The only independent analysis of the lion in renovating Giants Stadium, making that NYSCC’s economic impacts is a recent facility even better positioned to serve both report by the New York City Independent of the region’s football teams, and in line to Budget Office. Using what it considered host the Super Bowl. Recently, the Giants have to be an optimistic assumption, the IBO begun to consider building an entirely new, estimated that “…the facility would create state-of-the-art facility on the site. From a 3,586 jobs—barely half the 6,971 claimed by regional standpoint, it makes perfect sense for the project’s proponents—and generate $28.4 the two teams to work together in building a million in new city tax revenues…,” more than world-class facility that could serve most of the enough to cover the City’s debt service for proposed functions for the NYSCC, including its investments, but $6.7 million less than the playing host for the Olympics, Final Four, Jets’ estimate. Further, it found that even these Super Bowl and other major events. estimates are subject to substantial risk. With There would be no economic benefit to the more than two-thirds of the benefits coming region of having the Jets relocate from New from non-stadium uses, they depend heavily Jersey to New York City. Even its benefits to on assumptions regarding convention uses, New York City alone are suspect. Consistently, a business that is very difficult to predict.2 independent studies of the economic impacts As described below, RPA’s analysis sup- of sports stadia indicate their benefits tend to ports the conclusions of the IBO report. In be exaggerated and rarely justify the public

2 New York City Independent Budget Office, “West Side Stadium: Touchdown for the City?,” Inside the Budget, No. 131, July 1, 2004.

28 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER investment.3 It should also be noted that all Center in Indianapolis share contiguous or of the region’s sports franchises will be look- connected floor space on the same level. The ing for similar public subsidies to upgrade or NYSCC on the other hand would be accessible replace their aging facilities, potentially requir- from the Javits Center by a 100-yard-long ing billions of dollars in additional City and underground passageway, and then an escala- State funds. tor ride to the floor space built above the The only potential need for a new stadium rail yards. This lack of contiguity calls into would be to host the Olympic Games. RPA question whether event planners would view supports the City’s bid to host the 2012 the NYSCC and Javits Center combination as Olympic Games. The Sports and Convention viable exhibition space for a single large event. Center is a key piece of the NYC2012 Olympic A New York Times article published bid, and will need to be replaced. There are on June 20, 2004, noted that many in the indications that a new location for the stadium industry have doubts about the facility but could even help the bid, which finished last in have expressed support under political pres- public support in the International Olympic sure. A leading show producer was quoted Committee (IOC) rankings provided in May. anonymously saying “nobody thinks the We believe that one of the sites identified Jets Stadium makes sense as a convention in Queens can work if NYC2012 puts its hall.” Further, in an analysis of more than resources behind making this a reality, and the 30 studies justifying expanded convention aforementioned discussions regarding a new centers, Professor Heywood Sanders from the stadium in the Meadowlands provide another University of Texas, one of the nation's leading possibility. convention experts, found that these studies Of course, as on the Far West Side, any were invariably flawed and overly optimistic.4 proposed stadium must prove a worthwhile If it is determined that convention space project independent of the Olympics to is vital adjacent to Javits (in addition to the warrant construction. In the end, 17 days planned northern expansion), then a facility in 2012 should not drive the planning for a can be designed to the south or even the east crucial part of the City for the next 50 years. that provides this space without the many negatives associated with the football stadium. • Convention and Arena Usage: The NYSCC It could be smaller, have animated edges, be would add some capabilities that no other wrapped with mixed-use development and facilities in the region possess: additional better connect to the waterfront. It is also clear convention space and the ability to host major that if the stadium were not being contemplat- indoor events like the Final Four and politi- ed, this is not how an expanded Javits Center cal conventions. However, there is reason to would configure additional convention space. believe that the space will not be as successful as supporters suggest. 4. The Western Rail Yards should host a mixed-use First, the convention configuration of the development featuring residential uses, open space facility is not ideal, as it lacks contiguous floor and amenities that will do a better job stimulating space between the stadium and the convention development in the district and connecting it to center. Prototypes of multi-use football dome the waterfront. For all of the objectives proposed and convention centers such as the Edward for the NYSCC—football stadium, an exten- Jones Dome and America’s Center in St. Louis sion of the convention center, stimulus for new and the RCA Dome and Indiana Convention office and residential development—the facility

3 Baade, R. A. “Professional Sports as Catalysts for Metropolitan Economic Development,” Journal of Urban Affairs, 18 (1), 1996; Noll, R.G. and A. Zimbalist, Sports, Jobs, and Taxes, Washington, D.C.: Brookings Institution Press, 1997; Siegfried, J. and A. Zimbalist, “The Economics of Sports Facilities and their Communities,” Journal of Economic Perspectives, 14 (3), 2000.

4 Sanders, Heywood T., “Convention Myths and Markets: A Critical Review of Convention Center Feasibility Studies,” Economic Development Quarterly, August 2002, pp. 195-210.

29 represents a suboptimum use of the Western on the area surrounding it, it should not be driven Rail Yards. While in the short-term the NYSCC exclusively by either private return or tax revenues would likely encourage some tourist-related generated from activities on the site itself. growth, over the long-term it could become a To insure that development meets these major deterrent to creation of the new district objectives, the yards should be developed through the City has planned. Fortunately, the City’s a master plan that can be very detailed in terms choice is not between this facility or an open rail of building scale and character and which is yard. With public investments comparable to closely overseen by the redevelopment author- those proposed for the NYSCC, the site could be ity. In this sense, Battery Park City is a similar developed for a range of uses that would have a model where the authority reviews individual reasonable economic return and provide a better design submissions above and beyond a detailed catalyst for development elsewhere in the district. set of special district guidelines in the zoning This location is ideally suited for high- resolution. Guidelines for the individual sites density residential development that would take can be quite comprehensive, establishing on a advantage of its waterfront location and the site by site basis not only the appropriate mass- city's strong demand for new housing develop- ing and scale but other urban design elements ment. New residents and visitors should spur such as locations of entrances, expression lines the development of restaurants, shops and on building facades and primary orientation. cafes and the City can actively recruit cultural Designing and implementing an alternative and community uses to further attract activity will require several steps. First, the City and State without the negative impacts imposed by the should move forward immediately to re-zone the NYSCC. Rather than having too much auto and Western Yards for high-density mixed-use activi- pedestrian traffic on event days and not enough ties, and include it in the overall zoning package foot traffic on others, these uses will enliven the now being reviewed as part of the Uniform Land area 365 days per year and help pave the way Use Review Procedure (ULURP). They should for office development to the north and east. then proceed with design of an alternative master Significant public investment will still be required plan for the Yards for inclusion in the final EIS to deck the yard and for public improvements, to be completed in the coming year. The master but these are likely to be significantly less than plan should include public open spaces, walkways the $600 million required for the NYSCC. The and connections to Hudson River Park that will $225 million for the facility’s retractable roof draw city residents, office workers and tourists would not be needed. It is also possible that to the western edge of the district. It should the deck could be built for less than $375 mil- also designate parcels for development, allowing lion if it did not need to support a stadium. flexibility to allow the market to determine what The alternative should meet several objec- type of development occurs. The redevelopment tives: scale and uses that are compatible with authority can then determine the most appropriate the rest of the district; visual and pedestrian means and time to request proposals for develop- access to the Hudson River and Hudson River ment, and the master plan could be revised based Park; and open space, cultural uses and ameni- on the response. Actual development is most likely ties that will make the district, and particularly to take place once related public investments, the commercial core, more attractive to office especially the Number 7 extension and Eastern workers and residents. It should also provide a Rail Yards, are underway. However, if the hous- reasonable rate of return for private developers. ing market continues to show the strength that However, since the site will have major impacts it has in recent years, development may occur even before these improvements are completed.

30 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER share. The Sports and Convention Center will FINANCING be financed with $800 million from the New York Jets and $600 million in public funds, The City Proposal divided equally between the City and the State. The City’s proposal has been put on a rapid timetable, with the first phase of construction Discussion planned to begin early next year, including the RPA is concerned about three aspects of the NYSCC, subway extension, platform over the financing plan: compensation to the MTA Eastern Rail Yard and public amenities. With for their development rights to the Hudson the exception of the 41st Street station on the Yards, the risks to the City of the proposed #7 extension and some of the public spaces infrastructure financing, and the adequacy between 10th and 11th avenues, all of the public of the public process for such a complex construction is to be completed by 2009. project requiring extensive public subsidy. While public review and City Council approval are required for the zoning changes, MTA Development Rights the other elements will receive far less public and The Hudson Yards occupy the sites that are legislative scrutiny. As structured, the NYSCC planned for the proposed NYSCC and a major proposal could proceed without any legislative public space and development over the Eastern review. Some elements of the convention center Rail Yard, and from which air rights are to be proposal and financing would require approval transferred to other parts of the district. The by the state legislature. Because federal funding Yards are owned by the MTA, which invested is not being sought for the #7 extension, the in engineering improvements needed to accom- normal review requirements of the Federal Transit modate major air rights development when the Administration do not apply. Also, it appears yards were completed in the 1980s. The MTA then that the financing mechanisms proposed for the put forth a major development proposal for the infrastructure investments would not require Yards themselves in the late 1980s. Compensation any public review or legislative approvals. to the MTA for these rights does not appear as To fund the nearly $3 billion required for the a major cost assumption in the plan, in spite of #7 extension, Eastern Rail Yards platform and the potential value of these development rights. public space amenities, the City has proposed a RPA has a longstanding interest in promoting the complex financing plan that relies on a variety MTA's financial well-being, given its critical role of value recapture mechanisms, including pay- in sustaining the transportation infrastructure ments in lieu of taxes (PILOT), payments for that underpins the regional economy. These density bonuses and designated residential assets represent one of the few resources that the property taxes. Because these sources will not MTA has available to fund a five-year capital produce significant revenues until well after the plan that will likely require over $18 billion just investments are made, and because their revenue to maintain the system in a state of good repair. potential is uncertain, revenues from the City’s Both the City and State have substantially reduced Transitional Finance Authority are being used their contributions to the MTA’s capital plans as a credit enhancement. The convention center over the last decade. Giving up the development financing includes a hotel room surcharge and rights for less than market value is effectively an $350 million each from the City and State, with additional reduction in revenue for this program. the City proposing to utilize reserve funds RPA agrees with the two principles that from the Battery Park City Authority for its the City has articulated for determining com-

31 pensation—that the MTA should receive fair not allow the HYIC to default, both because it value for its assets and that City investments would have a damaging effect on the City’s cred- that enhance the value should be taken into ibility in the investment community, and because consideration. We also appreciate that determin- the City would have both economic and political ing value is a complex exercise. The calculation incentives to insure that projects are completed. should also take into account the critical RPA finds these to be persuasive arguments importance of these sites to the redevelopment and is hoping to see a thorough examination of proposal and how they would be valued if zoned these issues by independent financial experts. for high-density development similar to what is proposed for other sites in the district. Public Process The City’s position is that the review process Infrastructure Financing includes all customary City and State approvals The City argues that its only fiscal risk is from and is adequate to give the public and legislators the commercial paper it will offer to bridge the reasonable input and oversight. Specifically, the gap between the initial investments and the City argues that the financing cannot proceed receipt of property tax revenues. They calculate without the zoning, which must be approved that this exposure is limited to a $923 million by the City Council, and that approvals by the contingent liability to the Transitional Finance Empire State Development Corporation and the Authority through 2012 when they project that Convention Center Development Corporation revenues will be sufficient to cover the interest for the New York Sports and Convention Center payments on the long-term bonds issued by the and Javits expansion, respectively, represent Hudson Yards Investment Corporation. Even normal procedures for these agencies. if revenues are insufficient, the TFA would In spite of these explanations, RPA remains only need to back the incremental commercial concerned that the project is not being given paper required to cover the difference between adequate review and that normal processes are revenues and interest payments. The City also being truncated. The review process designed states that it is confident of getting an investment for land use decisions should not be used as grade rating for the long-term bonds and that a proxy for informed debate on financing. To interest payments would be only slightly higher do so would prevent a Council Member from than they would be if the City used general approving the zoning but disagreeing with how obligation bonds to finance the investments. the infrastructure is being financed. In addition, Both the New York City Comptroller and the NYSCC, a central element of the plan, can the New York City Independent Budget Office, proceed with no legislative oversight whatsoever. along with other financial experts, have raised Finally, the State has proposed legislation that serious concerns about both the costs and risks of would restrict any legal challenges to the Javits this approach. While the issues are complex, these expansion to the Appellate Division of the concerns can be generalized to two key points. State Supreme Court. In addition to curtailing The first concerns the trade-off between costs the normal review process, this action would and risks. Since the revenues for the bonds are undermine the intent and effect of the New York speculative, the City may have to choose between State Environmental Quality Review Act. increasing their credit enhancements or accepting higher interest costs. The second concern is that Recommendations the City, even if it has no legal obligation for inter- est payments beyond the transition period, would • The MTA should be compensated for the fair

32 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER market value of their assets based on an inde- pendent appraisal of what these assets would be worth if zoned for high-density development.

• The City Council should be given an oppor- tunity to approve the financing plan following the completion of analyses underway by the City Comptroller and Independent Budget Office. If these analyses demonstrate that the costs and risks of the financing proposal are significantly greater than funding through general obligation bonds, then normal capital budget procedures should be followed.

33 Acknowledgements

Over the past year, almost every member of the RPA staff has participated in the research and analysis that led to the conclusions drawn in this position paper. Principal contributors include:

Robert D. Yaro, President Thomas K. Wright, Executive Vice President Chris Jones, Vice President, Research Jeffrey M. Zupan, Senior Fellow, Transportation Jeremy Soffin, Director of Public Affairs Rob Lane, Director of Regional Design Programs Nicolas Ronderos, Associate Planner Petra Todorovich, Associate Planner

The report was designed by Jeff Ferzoco, Senior Designer.

34 FULFILLING THE PROMISE OF THE FAR WEST SIDE: AN RPA POSITION PAPER 35 4 Irving Place Two Landmark Square 94 Church Street 7th floor Suite 108 Suite 401 New York, NY 10003 Stamford, CT 06901 New Brunswick, NJ 08901 212.253.2727 203.356.0390 732.828.9945

Regional Plan Association (RPA) is an inde- come, and we mobilize the region's civic, busi- pendent regional planning organization that ness, and government sectors to take action. improves the quality of life and the economic RPA's current work is aimed largely at implement- competitiveness of the 31-county New York-New ing the ideas put forth in the Third Regional Plan, Jersey-Connecticut region through research, with efforts focused in five project areas: com- planning, and advocacy. Since 1922, RPA has been munity design, open space, transportation, work- shaping transportation systems, protecting open force and the economy, and housing. For more spaces, and promoting better community design information about Regional Plan Association, for the region's continued growth. We anticipate please visit our website, www.rpa.org. the challenges the region will face in the years to

BOARD OF DIRECTORS

Chairman Robert F. Arning Joseph J. Maraziti, Jr. Peter W. Herman Hillary M. Ballon John L. McGoldrick Charles A. Bauer The Very Reverend James Vice Chairman and Laurie Beckelman Parks Morton Co-Chairman, New Jersey Stephen R. Beckwith Peter H. Nachtwey Christopher J. Daggett Edward J. Blakely Jan Nicholson J. Max Bond, Jr. James S. Polshek Vice Chairman and Roscoe C. Brown, Jr. Richard Ravitch Co-Chairman, New Jersey Richard J. Carbone Gregg Rechler Hon. James J. Florio Edward T. Cloonan Robert N. Rich Tina Cohoe Mark F. Rockefeller Vice Chairman and Jill M. Considine Elizabeth Barlow Rogers Co-Chairman, Connecticut Michael R. Cowan Janette Sadik-Khan John S. Griswold, Jr. Paul A. Crotty Stevan A. Sandberg Alfred A. DelliBovi H. Claude Shostal Vice Chairman and Nancy R. Douzinas Susan L. Solomon Co-Chairman, Connecticut Barbara J. Fife Luther Tai Matthew S. Kissner Michael Golden Karen E. Wagner Arthur E. Imperatore, Jr. Mary Ann Werner Vice Chairman and Kenneth T. Jackson Paul T. Williams Jr. Co-Chairman, Long Island Ira H. Jolles William M. Yaro David J. Manning Richard A. Kahan Richard D. Kaplan Vice Chairman and Shirley Strum Kenny Co-Chairman, Long Island Susan S. Lederman Robert A. Scott Richard C. Leone Charles J. Maikish President Robert D. Yaro

Treasurer Brendan J. Dugan