Would modular construction require a new environmental review? ESDC says there's no official plan, so speculation is unwise

On March 17, I asked this question publicly: Does modular construction mean a new environmental review is needed for Atlantic Yards?

I suggested it might, given that the delivery of 900 modules, "lifted into place by crane and bolted together at the corner of Flatbush Avenue and Dean Street," as the Times described it, could introduce a different set of impacts on traffic, or on street closures.

Querying the ESDC

I followed up by posing the question to the Empire State Development Corporation:

Would the introduction of modular construction at the Atlantic Yards site require a new environmental review or technical memo?

Spokeswoman Elizabeth Mitchell responded:

The fact that the building would be modular as opposed to conventional construction would merit another environmental review only if the design guidelines or any other MGPP [Modified General Project Plan] requirement could not be met using the modular approach. If such a decision would be made to adopt modular construction in lieu of conventional construction, ESD would first ascertain as to the modular building's ability to meet the design guidelines and fulfill any other applicable project requirements. If it was determined that the modular approach did not, then ESD would consider adopting modifications to the guidelines, or if necessary, the MGPP. In this case, an additional environmental review might be required, depending on the degree of the modifications.

Following up

I responded:

I understand that a variety of designs might fulfill the design guidelines and other MGPP requirements.

But issues in the EIS/Tech Memo/Tech Analysis go beyond the design guidelines and MGPP requirements. Presumably, modular construction would lead to differing--perhaps diminished, in some areas--impacts in terms of noise, traffic, vibration, etc. Wouldn't they have to be studied or analyzed in some way?

Michell responded:

ESD has not received any official submission from Forest City Ratner regarding modular construction. Therefore we are not inclined to speculate regarding a possible Design Guideline review, environmental review or GPP modification.

Sure, it may be unwise to speculate at this point. But it's a question worth asking, and it's still out there.