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From the Response to Comments: modular construction, jobs, extended hours will be analyzed--but only for Phase 2

I've been going through the Response to Comments document produced by Empire State Development to accompany the release last month of the Final Scope for a Supplementary Environmental Impact Statement. (The SEIS is coming in the spring.)

There were a lot of questions and concerns about modular construction, since it was not studied in the original environmental review and is being used for the project, including Phase 1, which is not part of the SEIS.

The first set of comments drew the response that only the impact of modular construction in Phase 2 will be studied.

The comments:
Comment 71: The use of modular construction was not detailed or assessed in the 2006 FEIS or the 2009 and 2010 Technical Memorandums. FCRC has already disclosed numerous changes to the construction plan including situating a factory off-site, and delivering large modular units through the course of the early morning and work day for installation on site. Both the height and number of buildings proposed to be constructed at Atlantic Yards using modular techniques is unprecedented in the United States. Although the court order for the SEIS specifies an analysis of Phase II construction, in July of 2011, the court would have had no way of knowing a decision to use modular construction techniques for the Atlantic Yards project would later be made. Therefore, a thorough study of the impact of the developer's decision to use modular techniques must be included in the SEIS. (Brooklyn Speaks)
The construction method now differs from what has been analyzed. There’s no meaningful construction plan detail for modular construction, even though it may have very different implications for side walk and street corner and travel lane access. (Krashes)
The response:
Response: The use of modular techniques to construct the Phase II project buildings would not alter the requirement that the buildings comply with the Design Guidelines and the New York City Building Code. As described in the Draft and Final Scope of Work, the construction analysis for Phase II of the Project will, where relevant, discuss differences in potential impacts related to on-site standard and modular construction techniques.
Potential extended hours

Potential extended hours will be studied, but, again, only involving Phase 2. (There are already overnight deliveries of modules for Phase 1.)

The comments:
Comment 72: The extended hours of construction: The construction occurred virtually 24/7. So a lot of the premises upon which the FEIS did the study in fact were not effectuated. And we need to look at better studying those, making sure that construction does not happen 24/7, reducing the number of hours and the type of construction that happens at various times of day. (Simon)
Given the significant impact that extended construction can have on the quality of life of neighborhood residents, the SEIS should identify and assess measures to reduce, monitor and mitigate extended hours of construction. It is critical that the SEIS revise the MEC to provide stricter requirements, including: reducing the incidence of extended hours, particularly the scheduling of construction for 24 hours per day; limiting the number of consecutive days when extended construction hours, particularly 24-hour construction work, is permissible; and requiring that construction periods with extended hours, particularly activities carried out 24/7, be followed by at least 7 days of normal construction hours. (George)
Of greatest importance, the SEIS should seek and obtain more stringent commitments regarding extended hours work, including:
 Reducing the incidence of extended hours, particularly the scheduling of construction for 24 hours per day
 Limiting the number of consecutive days when extended construction hours, particularly 24-hour construction work, is permissible.
 Requiring that construction periods with extended hours, particularly activities carried out 24/7, be followed by at least 7 days of normal construction hours. (Brooklyn Speaks)
The response:
Response: The SEIS will discuss the anticipated hours of work during construction. To the extent that certain construction activities may result in extended work hours beyond 6:00 PM, the SEIS will describe the purpose and anticipated duration of such activities. If construction of Phase II under the Extended Build-Out Scenario results in any significant adverse impacts not disclosed in the FEIS, the SEIS will seek to identify practicable mitigation measures to address those impacts.
The impact on sidewalks

The comment:
Comment 73: The use of the modular construction method, as well as the phasing of property control have increased the likelihood that construction staging will be located on sidewalks instead of inside property lines as originally planned. The SEIS must study pedestrian facilities taking into account changes to the construction schedule and construction method in terms of pedestrian LOS [levels of service], neighborhood character, economic development and visual resources. (George)
The response:
Response: The SEIS construction analysis for Phase II will, where relevant, discuss differences in potential impacts related to on-site standard and modular construction techniques. The construction analysis will also assess the environmental impacts of any anticipated staging on sidewalks associated either with the use of modular construction or with any anticipated changes to the construction sequence since preparation of the FEIS. Consistent with the FEIS, the SEIS assessment of pedestrian conditions resulting from construction will be qualitative and will not include a quantitative LOS analysis.
How many jobs?

Modular construction involves lower-paying factory jobs and, likely, fewer overall jobs. Again, there will be a limited analysis, of economic benefits (rather than a cost-benefit analysis) limited to Phase 2.

The comments:
Comment 78: Job creation was a major public incentive leading to the approval of the Atlantic Yards project. It has been reported that a large percentage of construction tasks will be transferred to the module factories, and that workers in the module factories will earn less than counterparts working on site. The SEIS must study how the decision to use modular construction techniques will affect the number of jobs created by the project and the pay scale of those jobs, and the impact of any change on the local economy. (Brooklyn Speaks)
The ESD should study and publish the economic consequences of the commitment to union construction jobs in standard building techniques versus modular. (Vogel)
The response:
Response: As indicated in Draft Scope of Work, the SEIS will discuss the Phase II construction period’s economic benefits, as well as any potential changes in construction benefits due to the potential incorporation of modular construction techniques.
Impacts from the factory?

Again, the analysis of delivery impacts is limited to Phase 2.

The comment:
Comment 90: The SEIS must study whether any new construction impacts have been created by locating a module factory in the Brooklyn Navy Yard. (Brooklyn Speaks)
The response:
Response: The construction analysis in the SEIS will, where relevant, discuss differences in potential impacts related to modular construction techniques on some or potentially all of the Phase II buildings. This analysis will account for the potential use of the existing module factory in the Brooklyn Navy Yard as the origin of modules delivered to the Phase II site, but the environmental impacts of the existing factory at the Brooklyn Navy Yard are outside the scope of the SEIS.
Unanticipated impacts from deliveries

The comment:
Comment 100: Arena construction showed that even with the best-laid plans, coordinating construction deliveries so that they occur as planned and without unanticipated impacts is difficult. The oversized loads transporting modules from the factory in the Brooklyn Navy Yard to the Atlantic Yards site clearly have the potential to be disruptive to traffic along the entire route. The SEIS' transportation analysis must detail the route and timing of these deliveries, plans for staging and dispatching them, and control procedures for overseeing that the plans are followed, together with the expected impacts of module deliveries on the local transportation network.
The SEIS must also study the potential for the use of modular construction to increase the demand for sidewalk and travel lane closures, and/or the implementation of temporary sidewalks. (Brooklyn Speaks)
The response:
Response: The SEIS will include a qualitative discussion of the potential use of modular construction including the potential impacts due to temporary sidewalk and travel lane closures. The SEIS will discuss the anticipated delivery truck routing and timing of modular deliveries as well as the plans for staging and dispatching these deliveries.

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