Down the EIS rabbit hole: Why does Fairway get counted for traffic impact but not Whole Foods?

Delving into the rabbit hole of traffic and transit projections for the Atlantic Yards project leads to a glaring discrepancy revealed only in the Final Environmental Impact Statement (FEIS) and not cited in the unsuccessful lawsuit challenging the AY environmental review.

The Empire State Development Corporation (ESDC) belatedly added the new Fairway market in Red Hook to its list of sites that should be analyzed regarding future travel demand in the area around the Atlantic Yards site. However, the ESDC continued to exclude the coming Whole Foods Market in Gowanus because it was deemed "distant from study area."

That's absurd. As the graphic shows, Fairway is about twice as far as the Whole Foods site from the westernmost point of the Atlantic Yards footprint, the corner of Fourth, Flatbush, and Atlantic Avenues.

Any impact?

Would this have made a difference had it been included in the lawsuit? (The issue was not raised by post-FEIS commenters.) It's doubtful, given that Supreme Court Justice Joan Madden punted on addressing the dubious crime statistics in the suit. But it's another sign that the volumimous ESDC review, conducted by ubiquitous consultant AKRF, still contains glaring omissions obvious to the layperson.

A selective response to comments

In response to the Draft Environmental Impact Statement, one Brooklyn resident raised the issue of Whole Foods, but the response was incomplete. See Comment 12-1 of the Response to Comments chapter of the Atlantic Yards FEIS:
Large projects such as the Brooklyn Bridge waterfront development and the expansion of the Red Hook Cruise Ship Terminal, IKEA in Red Hook, the new Fairway and the Whole Foods supermarket in Gowanus were not included. Large buildings such as those at 9 MetroTech, the new Federal Courthouse, and the Marriott Hotel Expansion were simply left out.

The ESDC's response:
In addition to background growth, the EIS transportation analyses include the travel demand from a total of 33 discrete No Build sites in and around the project site and Downtown Brooklyn that are expected to be developed by the proposed project’s 2016 analysis year. (For the 2010 analysis year, 14 discreet No Build sites were included.) These projects, which comprise approximately 6,254 dwelling units, 5.19 million sf of office space, 1.15 million sf of retail space and 2.43 million sf of other space (community facility, academic, hotel, court, etc.), include the anticipated development resulting from the Downtown Brooklyn Development project, Brooklyn Bridge Park, Pier 12, the new IKEA store in Red Hook, the Atlantic Center development, and the new Federal Courthouse and the Marriott Hotel expansion in Downtown Brooklyn. Three developments (a charter school on Waverly Avenue, residential development at 306-313 Gold Street, and the Fairway market in Red Hook) totaling 517 D.U. and 310,000 sf of office, retail and other space have been added to the transportation analyses in the FEIS in response to recent information and agency and public comments on the DEIS. Much of the additional development cited in the comments can be attributed to projects that (1) were completed prior to Fall 2005 and are therefore already reflected in the EIS 2006 traffic baseline condition; (2) fall below minimum threshold densities for inclusion as discrete No Build sites; (3) are distant from the Atlantic Yards project site (such as the Greenpoint-Williamsburg Rezoning project which includes sites located up to four miles from the project site); or (4) are speculative sites.
(Emphases added)

What about Whole Foods?

So why was Whole Foods excluded? It wasn't completed, nor too small, nor speculative. Rather, according to the background memo regarding "No Build" assumptions, Whole Foods would be "Distant from AY study area."
(Click to enlarge)

Though the distance is less than a mile, it's outside the study area, which was defined as "¾ mile of the project site," according to Chapter 2, Framework, of the FEIS.

However, Fairway is much farther away, so obviously "recent information and agency and public comments" caused some change in the ESDC's analysis. They just chose to be inconsistent when it came to Whole Fods.

Fair comparison?

Yes, Fairway is bigger, with nearly 120,000 square feet of retail, plus 91,500 square feet of office space, while Whole Foods would have 46,000 square feet, according to the FEIS memo. (Whole Foods says 52,000 sf.)

But the 60,500 sf Pathmark in the Atlantic Center mall already generates a lot of traffic. And Whole Foods, for now would have a bigger parking lot than Fairway. It recently rejected a request to reduce its 420-space parking lot, leaving it more than one-third larger than Fairway's 300-space lot.

So it's hard to disregard Whole Foods.