101 L AFAYETTE S T , 9 TH F LOOR T HE C OUNCIL OF N EW YORK, NY 10013 T HE C ITY OF N EW Y ORK 212-587-3159 PHONE 250 B ROADWAY, S UITE 1762 MARGARET S. CHIN N EW YORK, NY 10007 212-788-7259 PHONE ST COUNCIL MEMBER, 1 DISTRICT, MANHATTAN CHIN@ COUNCIL. NYC.GOV January 11, 2021 Joint Testimony from the Office of Council Member Margaret S. Chin and the Office of the Manhattan Borough President Gale A. Brewer Comments on the Draft Scope of Work for 250 Water Street (CEQR No. 21DCP084M) ULURP Nos. Pending We are writing to submit comments in response to the 250 Water Draft Scope of Work (DSOW) for an Environmental Impact Statement (EIS) released by the Department of City Planning (DCP) on November 16, 2020. The Applicant, 250 Seaport District, LLC, is proposing the following actions: (i) a special permit for bulk modifications on the development site, a development rights distribution from an area generally corresponding to the Pier 17 Large-Scale General Development to the development site, and potential streetscape, site plan and district improvements in the affected area; (ii) possible zoning text amendments to the special permit and special purposed district text; and (iii) an authorization for a curb cut on Pearl Street, to enable a mixed-use development at the development site with affordable units under Mandatory Inclusionary Housing parameters. The Project Area includes the development site at 250 Water Street (Block 98, Lot 1), the site occupying the southern portion of the block located between John Street (currently occupied by the South Street Seaport Museum), South Street, and Fulton Street (a portion of Block 74, Lot 1), and several additional areas that may include streetscape, open space or other improvements pursuant to the special permit. 250 Water Street The proposed project at 250 Water Street under the “with action condition” would consist of a building of approximately 912,762 gross square feet, including 640,186 gross square feet of residential use, 257,886 gross square feet of office use, 9,690 gross square feet of retail use, 5,000 gross square feet of community facility uses, and 128 parking spaces. The DSOW averages a unit size of 1,000 gross square feet of residential space per dwelling unit. The proposed project at 250 Water Street assumes 640 total dwelling units, of which approximately 25 percent of 640 dwelling units will be affordable housing under Mandatory Inclusionary Housing. The building will consist of a seven-story, full-block base with mixed- Page 1 uses. Both north and south towers will rise from the base to 37 and 38 stories, respectively, with each tower reaching a total height of approximately 470 feet. South Street Seaport Museum Expansion The proposed project at the corner of John Street and South Street under the “with action condition” includes the restoration and expansion of the existing South Street Seaport Museum space. The museum expansion would include a new building of approximately 32,383 gross square feet. The new building would be seven-stories and approximately 62 feet tall and would contain additional exhibits and back offices for the Museum. Background The ever-evolving South Street Seaport Historic District, nestled in the East River waterfront of lower Manhattan, is a site of historic significance and has played an important role in the history of New York City. From its beginnings in the mid-to-late 17th century, the Historic District was a leading port and commercial center. By the mid-19th century, the Historic District became home to a number of architecturally significant buildings, exemplified by several different styles of mercantile architecture including Georgian, Federal and Greek Revival designs. Efforts to preserve the culture, history and structures of the South Street Seaport neighborhood resulted in the creation of the South Street Seaport Museum in 1967. Its establishment is credited with not only being the anchor in the creation of the South Street Seaport Historic District, but also responsible for the restoration of many of the historic buildings of the area. Through the Museum’s efforts, the area was officially landmark designated in 1977. Some of these buildings are occupied by the Museum today and are once again in need of restoration work. In addition to the Museum’s efforts to preserve the South Street Seaport area, the City has taken several significant steps to preserve the history and architectural significance of the neighborhood’s buildings. In 1977 the Historic District was designated and in 1989 it was expanded. Those actions have allowed for a careful balance between the preservation of the District’s historic character and new development. Low- density, historically significant buildings and pedestrian areas remain closer to the waterfront and taller buildings have been constructed further inland. The Seaport Working Group and the Seaport Advisory Group In 2014, Manhattan Borough President Gale Brewer and Council Member Margaret Chin formed the Seaport Working Group and initiated a pre-planning process for the South Street Seaport Historic District. The group was re-established in 2018 as the Seaport Advisory Group, which includes elected officials and members of City agencies, Community Board 1, Save Our Seaport, and other key stakeholders. The Seaport Advisory Group met in several roundtable discussions to address issues in the District including historic preservation, economic development, and environmental resiliency. Overall, our comments focus on the need to thoroughly consider the potential impact of this proposed development on the South Street Seaport Historic District, the surrounding neighborhood, and its residents. We must also ensure that appropriate mitigation measures are in place. Several issues are of particular concern in the Final Scope of Work (FSOW) in accounting for all relevant data, including pre- and post-COVID-19 data as applicable, the most recent data regarding the presence of hazardous materials at the site, and impacts to the infrastructure and resiliency measures within the surrounding neighborhood that may be triggered by this proposal. Our comments below reflect the order of tasks listed under “G. Scope of Work for the EIS” (DSOW, Page 7). Task 1: Land Use, Zoning and Public Policy Page 2 The proposed development would result in a change in land use within the project area. The DSOW proposes a detailed assessment of several factors, including land use patterns and development trends, and a list of projects; and pending zoning actions or other public policy actions that could affect such patterns and trends. For the proposed detailed assessment, the FSOW should consider all available data, including pre- and post-COVID-19 patterns and trends. Likewise, when considering a comprehensive list of projects or actions within the study area, the FSOW should be inclusive of any projects or actions that may be temporarily stalled as a result of COVID-19. City Waterfront and Resiliency Studies The FSOW should also take into account public policy concerns related to resiliency for the site and surrounding sites as the site may have the potential to redirect water to surrounding properties causing deterioration. The environmental land use study will extend approximately a quarter mile from the borders of the project area. The Applicant must list projects that are also being studied, in addition to those expected to be built or will concurrently be constructed within the study area. This includes a number of resiliency studies put forth by the City and the New York City Economic Development Corporation (EDC) including the Lower Manhattan Coastal Resilience study released on March 14, 2019, and its Financial District and Seaport Climate Resilience Master Plan. The DSOW notes that the project area is located within the City’s Coastal Zone and therefore will be assessed through the New York City Waterfront Revitalization Program’s (WRP) Consistency Review. The WRP was first adopted in 1982 and revised in 2013 to advance long-term goals for the City’s waterfront detailed in the City’s 2011 report titled Vision 2020: the New York City Comprehensive Waterfront Plan, a strategic 10-year plan for the waterfront. The City Planning Commission, acting as the City Coastal Commission, and the New York City Department of City Planning (DCP) are responsible for administering the WRP. The proposed project will be assessed through a Consistency Assessment Form and whether it will promote or hinder the ten WRP policies. The completed WRP assessment and all related explanations for each of the ten policies must be provided to Manhattan Community Board 1 and all related agencies as part of the Land Use, Zoning and Public Policy section within the Environmental Impact Statement. The Applicant must also include information about how the concurrent Uniform Land Use Review Procedure (ULURP) application and the Environmental Impact Statement for Zoning for Coastal Flood Resiliency (ZCFR) (ULURP No. N210095ZRY, CEQR No. 19DCP192Y) will impact this proposed project along the waterfront and the larger South Street Seaport Historic District neighborhood. Task 2: Socioeconomic Conditions The DSOW socioeconomic study includes population, housing, and economic activity, with an emphasis on indirect residential displacement, indirect business displacement, and adverse effects on specific industries. The DSOW further clarifies that, “the proposed actions would not result in the direct displacement of any residents or businesses” (DSOW, Page 9). As part of the socioeconomic study, we ask that the Applicant include information on the number of new families anticipated in the neighborhood and the increase in school seats at the elementary, middle, and high school levels. We also ask that the Applicant include information on existing community centers, schools, and retail stores in the neighborhood. Should the proposed actions lead to their displacement, the Applicant must communicate relocation opportunities to those institutions and businesses.