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Somehow my comment to ESD on Atlantic Yards review went to spam; now, no cost-benefit analysis expected, but there will be analysis of modular worker wages

Who would have guessed that the one commenter ignored by the state agency overseeing/shepherding Atlantic Yards would be the journalist who's followed and critiqued the project most closely: me.

When, on 2/7/14, I perused the Response to Comments document issued by Empire State Development, summarizing comments on the Draft Scope of Work for a Supplementary Environmental Impact Statement addressing a potential 25-year Atlantic Yards buildout, I noticed my comment was missing.

To get a better sense of potential outcomes, I'd asked for a cost-benefit analysis that took into account various various development scenarios, and asked the state to compare construction worker wages/tax revenues once assumed with those projected under Forest City Ratner's plans for modular construction.

The response from the state, issued yesterday, was no to the first request and yes (as previously stated) to the second.

Following up

I'd sent my email last March to the listed email address: So, earlier this month, I forwarded that email from my outbox to ESD, and got a response from agency spokeswoman Kay Sarlin Wright:
Thank you for bringing this to our attention. We discovered that your email with scope questions had been filtered to a junk mail box associated with the Atlantic Yards email address and had unfortunately not been received by our staff until now. We are currently reviewing your comments.
It's curious that my email--and only mine--would be sent to spam. I asked if that happened to others; Sarlin Wright responded:
We regret that your email was filtered into our spam file and have taken care to review that mailbox and other possibilities. No other emails pertaining to the SEIS were found. We have also made changes to our protocols to ensure this will not happen in the future.
Revision issued

Yesterday, ESD issued an Amended Response to Comments document. While there's no explanation on the ESD's Atlantic Yards web site as to why it was amended, an email to community members from Derek Lynch, the community/government relations manager for Atlantic Yards, stated:
The Amended Response to Comments includes 2 comments that were inadvertently omitted from the original RTC. They are comments #35 and #80 in the Amended RTC.
Those were from me.

Cost-benefit analysis coming?

ESD divided my request into two comments. The first concerned the cost-benefit analysis:
Comment 35: I request that the SEIS provide a cost-benefit analysis that incorporates all public costs/subsidies and contains a range of scenarios for an extended buildout, for example:
 full residential buildout of project with office tower built in 5/10/15/20/25 years
 full residential buildout of project, with no office tower(s)
 partial residential buildout of project, with full # of rental apartments but no/25%/50%/75% of promised condos
 partial residential buildout of project, as above, with office tower(s) built at different times. (Oder)
The response was no:
The SEIS is being undertaken pursuant to the Court Order to evaluate the effects of a prolonged construction schedule of Phase II of the Project. The type of cost-benefit analysis requested is outside the scope of this SEQRA analysis. As outlined in the Draft and Final Scope of Work, the SEIS will assess the potential for environmental impacts during the Phase II construction period through 2035 under the three illustrative construction phasing plans.
That wasn't a surprise. After all, as I wrote earlier this month, when a commenter suggested public benefits would be diminished by a delayed timetable, the ESD's response was that it's irrelevant, mostly:
The socioeconomic benefits resulting from an action—including project-generated jobs, wages and salaries, and total economic output—are not the subject of a CEQR [City Environmental Quality Review] analysis of potential significant adverse impacts, and in general, the delay in the provision of public benefits announced and/or promoted by a project sponsor is not a determining factor in assessing significant adverse environmental impacts. The socioeconomic analysis instead focuses on the potential for significant adverse impacts that may occur from the build-out of Phase II over an extended period of time. With respect to this analysis, “delayed benefits” as described by the commenter will be addressed in the SEIS if those benefits were mitigating factors precluding a significant adverse socioeconomic impact where one otherwise would have been disclosed.
(Emphasis added)

See if you can make sense of that one.

Delayed benefits count only if those benefits--meaning the jobs and tax benefits--were originally seen as mitigations. But they weren't mitigations. They were selling points.

Construction workers in the modular plan

I also asked about construction workers:
Comment 80: I request that the SEIS provide an analysis of the difference between the FEIS estimate of construction worker wages/tax revenues and the estimate of construction worker wages/tax revenues based on a plan for modular construction. (Oder)
The response:
Response: As indicated in Draft and Final Scope of Work, the SEIS will discuss the Phase II construction period’s economic benefits as compared to those reported in the FEIS for Phase II of the Project, as well as any potential changes in construction benefits due to the potential incorporation of modular construction techniques. This discussion will include reporting of the total worker wages and tax revenues under both a conventional and modular construction scenario for Phase II using the Regional Input-Output Modeling System (RIMS II), developed by the U.S. Department of Commerce, Bureau of Economic Analysis.
That wasn't a surprise, since in response to other comments ESD indicated it would examine those different economic benefits.

But an overall cost-benefit analysis, one that balances costs against benefits? They won't go there.


  1. Anonymous12:39 PM

    In the future, a suggestion is when emailing ESD you should cc:, to make sure your comments are shared with ALL the staff who they say work on the Atlantic Yards project.


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