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Reduced local impact? With no environmental study of Atlantic Yards modular plan, overnight deliveries weren't disclosed, analyzed

According to the 12/12/13 press release accompanying the media event in which Forest City Ratner hoisted three "mods" for the cameras, modular construction for the first Atlantic Yards tower, B2, would result in both "Reduced On-Site Construction Traffic" and "Reduced Neighborhood Impact."

Those claims may well be correct, but they were never vetted by any oversight agency, as modular construction was not addressed in the 2006 environmental review nor the 2009 and 2010 memoranda issued by Empire State Development, the state agency overseeing and shepherding the project.

That means some distinct impacts never disclosed until 12/4/13, namely four overnight deliveries that may prove to be quite noisy for neighbors, at least as shown with the first delivery. (The plan announced a year earlier was for one overnight delivery, though that wasn't studied, either.)

Deliveries resume next week.

The claim

From the press release:
The on-site construction traffic to the project site is dramatically reduced through the modular construction process. As the apartment modules for B2 will be fabricated off-site at the Brooklyn Navy Yard, there are significantly fewer construction deliveries and thus total truck trips required to the project site. While the excavation and foundation portion of the project will require the same number of trucks as would any conventional building of a similar size, during the module erection and closeout phases of the construction process, significantly fewer total truck trips will be required.
From Final EIS, Construction Impacts
Fabrication of the apartment modules takes place in an off-site location and, as a result of this reduced on-site activity, many of the typical disruptions of a conventional construction site noise, dust, trash, traffic, truck deliveries, etc. are greatly reduced.
From the Final EIS

As shown in the chart at right, from the Final Environmental Impact Statement (EIS), the analysis of construction and operational traffic was limited to work hours, pretty much, from 6 am to 6 pm.

There was no disclosure of overnight trips.

At a meeting earlier this month, neighborhood activist Peter Krashes asked what the Final EIS had said about after-hours construction work.


“This is not construction work, these are deliveries,” Marshall said. Even those weren't disclosed.

At the Council 

"This project was subject to a state environmental review process," Council Member Letitia James noted, at a City Council hearing last January regarding the modular plan. "Was there any environmental review with respect to modular housing"

"Not that I'm aware of," responded Forest City Ratner executive Ashley Cotton. "The environmental. review was done many years ago. At that time, we weren't planning this tower this way."

Forest City's plans to not use concrete drew critical testimony from Joseph Kaming, representing the Cement League, an associations of union contractors that put in place structural concrete. (His testimony was seconded by the United Cement Masons' Union.)

"All can celebrate new thinking," he stated, but argued that tall modular buildings exacerbate some of the problems--fire safety, durability--seen in smaller modular buildings.

The city, Kaming said, "should thoroughly review and establish specific individualized standards for tall modular buildings if they are to be permitted. Such construction is unique and does not fit into the existing Building Code."

He said toxic, fire, and electrical testing was needed, as would be "fire channeling or chimney effects peculiar to stacked construction." He requested an environmental impact statement as a precondition to any application or permit approval, full compliance with existing code, and a new Building Code section regarding modular construction.

"We do not believe the Buildings Department has conducted a legal and proper review of the Atlantic Yards' 32-story residential tower which would justify its approval," he said.

Questions about wind

"When you start transporting something that is 14 feet wide and 35 feet long," Kaming said of the modules, "and begin to lift it in a structure, with wind considerations, that is an entirely different matter. You probably are aware Forest City Ratner has specifically identified the dimensions of the system so they don't have to hire a licensed rigger... because a licensed rigger would add to their cost."

Kaming acknowledged that modular units have their place, but deserved an independent review. "That's why an environmental impact statement, if in fact they had been honest and talked about modular housing," he said, "would have had to include modular housing at the outset. Because it's a different category of structure."

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