After all, Atlantic Yards has been touted as "providing" affordable housing without any reference to the public funds behind the units or any analysis of whether they represent a good bang for the buck.
So the Municipal Art Society (MAS), in its comments to the Department of City Planning (DCP) on the New Domino draft scope, a prelude to the environmental impact statement, begins:
Discussion of irreversible and irretrievable commitments of resources to develop the project should, to the fullest extent possible, disclose the sources of the public funding that will be used to subsidize the affordable housing units; the total amount of the funding; and the percentage of that funding devoted to the projected site in relation to the total funding available citywide.
And Williamsburg architect Leah Kreger has started a blog, Domino Sugar Redux, and posted her comments on the draft scope. Among her requests:
Since the affordable component figures prominently, please have the applicant describe the strategy for financing the affordable component as they relate to tax and government subsidies.
There's no guarantee those questions will be answered. Last year, the MAS, in comments filed after the Atlantic Yards Final Environmental Impact Statement was issued, asked:
In order to accurately assess whether the Atlantic Yards proposal will result in a net gain of affordable housing units, there needs to be an accounting of the public expenditures on this project versus the total amount of public subsidies available in the same fiscal year so that decision makers can accurately assess the public costs versus the public benefits. What percentage of the city’s total funds for housing will be required to build the project’s 2250 units?
In response, the Empire State Development Corporation offered only generalities. (Only after the project was approved did details emerge.) Will DCP be more forthcoming? The EIS will be written by the same environmental consulting firm, the ubiquitous AKRF.
On height and open space
While a rezoning further north along the Williamsburg waterfront allows buildings that are 400 feet, the height of two proposed New Domino towers, the MAS points out that neighborhing structures are generally no taller than 50 feet. The organizations suggestes a 250-foot height limit "in order to better respect the adjacent inland neighborhoods."
Assemblyman Vito Lopez has recommended that each of the tallest planned towers, two at 300 feet and two at 400 feet, should be reduced by ten stories, or 100 feet.
The MAS also suggests that the analysis consider waiving parking requirements, "in order to deter car traffic to retail destinations," a restriction on construction of condo-hotels; and allowance of ground-floor manufacturing use for new development.
MAS, commenting on the proposed open space, warned, as it had with Atlantic Yards, that “publicly-accessible” but privately owned open space may not "be a meaningful public amenity." MAS suggested that the open space could be mapped as public parkland, handed over to a local conservancy, requiring commercial retail or a community facility at the base of the restored Domino refinery facing the water, to draw people, and requiring retail frontage along the base of all buildings facing the waterfront.
The New Domino project, as currently proposed, would mostly not be out of line with the height and density proposed for other areas of the Williamsburg waterfront. (An upland parcel would contain taller buildings than permitted upland elsewhere.)
But the Domino site was not rezoned, nor was it considered when the rest of the neighborhood was rezoned. So the MAS argues for consideration of cumulative impacts:
The Lead Agency must assess the impact the recent rezoning of a large section of Greenpoint/Williamsburg, in combination with the proposed rezoning here, will affect all the areas of concern. These two rezonings should not be examined independently of each other. In order to accurately analyze the significant environmental impacts of the proposed rezoning, this EIS should take into account the predicted and actual impacts resulting from the adjacent rezoning of Greenpoint/Williamsburg
Kreger comments similarly:
We hold the opinion that the proposed rezoning of Domino needs to be considered cumulatively with the effects of the zoning adopted in 2005 for the waterfront from N4th to Manhattan Avenue. The neigborhood needs assistance financial and otherwise to create a comprehensive plan instead of spot rezoning such as that proposed for Domino.