June 19, 2007

Pete Grannis
New York State Department of Environmental Conservation
625 Broadway
Albany, NY 11223-1011

RE: Proposal to remove parking provisions from the State Implementation Plan

Dear Commissioner Grannis:

In its 1982 New York State Implementation Plan (SIP), the Department of Environmental Conservation (DEC) proposed limiting the number of parking spaces that could be attached to any residential, commercial or mixed-use development in Manhattan's Central Business District. The forward-looking Plan recognized that there is a relationship between available parking, vehicular traffic, and air quality, and understood the necessity of regulating the former to maintain control over the latter two.

I am writing to you in regard to DEC's proposed State Implementation Plan revision that would remove the reference to a limited off-street parking program imposed and enforced by the City of New York. It is my understanding that the DEC began the process of removing the parking provision before you were appointed Commissioner; I hope you will take steps to reverse the process now that you are in the position to do so. My concern is that if this change is made, the State will lose an important regulatory tool to protect our neighborhoods from dangerous gridlock and poor air quality.

Manhattan Community Board Four is particularly concerned about this change, given that the Hudson Yards rezoning, which was passed in 2005, includes a provision that is the antithesis of the DEC restrictions. Among other things, it actually requires residential developers to build parking garages with spaces for at least 33 percent of their residents, mandates that commercial buildings include one parking space for each 3,300 square feet of building area, and allows additional parking spaces well beyond these minimums. Since the Hudson Yards plan anticipates the construction of 13,600 apartments and 26 million square feet of commercial space, unless the SIP's parking provision remains, the result could be 20,000 new parking spaces. That this glut of parking will be in a neighborhood that suffers from some of the worst gridlock and air quality in the City is only made worse by the fact that these spots were originally mandated to serve a Stadium that never got built.

The current process of removing the parking provision from the SIP follows a 2001 study on carbon monoxide in the New York Metropolitan Area, commissioned by a predecessor of yours, which determined that Federal carbon monoxide standards have been met. Even if this study was executed adequately -- and I have serious concerns about the test samples used -- the parking program is still needed to address hydrocarbon and fine particulate emissions going forward. Granted, the quantity of parking that is appropriate for any given area is variable. But it is undeniable that it has a real effect on the health and safety of our neighborhoods, and regulation of that quantity should remain within the purview of the DEC.

Thank you for your attention to this matter. I would appreciate any further information you have about this proposed change.


Thomas K. Duane
29th Senate District

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