March 11, 2008

Douglas Sussman
Director, Community Affairs
Metropolitan Transportation Authority
347 Madison Avenue, 9th Floor
New York, NY 10017

RE: Comments on the Draft Environmental Impact Statement for the Emergency Ventilation Plant for the Seventh and Eighth Avenue Subway Lines

Dear Mr. Sussman:

As the State Senator whose district includes Mulry Square, I would like to comment on the recently published Draft Environmental Impact Statement (DEIS) on the proposed Emergency Ventilation Plant ("fan plant') at Mulry Square, and to echo many of the concerns expressed in Community Board Two's (CB2) thoughtful testimony on the document.

This is not a project that our community would hope to see in the midst of the Greenwich Village Historic District, and certainly not so close to the much-delayed and particularly obtrusive fan plant construction project that was finally completed last year at 13th Street and Sixth Avenue. CB2 clearly articulated the vast, negative impacts that the DEIS acknowledges this project will have on the neighborhoodfs environment, quality of life and historic resources. It is incumbent upon NYCT to continue to work with CB2, my colleagues in government and the community to create a implementable plan that better mitigates these adverse impacts and is more responsive to the communityfs needs.

In particular, I share CB2's belief that NYCT should offset the negative impacts of the project by maximizing public open space at 61 Greenwich Avenue (P1). As you are well aware, this address is home to a lot lined with 9/11 memorial tiles on a busy corner of a park-starved community. While I appreciate that in the proposed P1 alternative, NYCT honored its promise to incorporate an area for public use by designating about 17% of the site to open space, I believe NYCT can do more to address the community's concerns.

If Mulry Square is, in fact, deemed the most appropriate location for this fan plant, NYCT should alter its design for the P1 site to allow the property to be converted into a public park. As CB2 detailed in its testimony, and also discussed at a recent meeting that I convened with NYCT, other elected officials, and CB2 representatives, this could be accomplished by sinking the proposed above-ground structure at P1 below-ground I understand that this alternative would cost more and add to the construction timeline, however, the short-term costs are greatly outweighed by the long-term benefits of eliminating an unsightly above-ground structure, and adding desperately needed park space.

In the event this scenario is deemed unfeasible, I strongly encourage NYCT to explore creative ideas and consult with the community to expand the amount of open space proposed at this site. I appreciate that the DEIS states that NYCT will consult with the community in regards to the most appropriate incorporation of the 9/11 memorial tiles into the P1 site, and that input would be also be sought from the community, the New York State Historic Preservation Office and the New York City Landmarks Preservation Commission for the design of any above-ground structure built if the P1 site were selected. Such an above-ground facility has the potential to disrupt the character of this area, which is marked by low-rise residences, including many historic structures, as well as small and informal ground-floor commercial establishments. As I have stated, a below-ground structure is preferable, however, it is essential that any above-ground structure be appropriate for the Greenwich Village Historic District.

Based upon the DEIS, I must express my firm opposition to the use of the proposed Perry Street site, between 7th Avenue and Greenwich Avenue. This tiny, tree-lined street with a multitude of historic buildings is not an appropriate site for the huge disruption that the construction would cause. The disruption to the lives of residents, the underpinning of these buildings, the full closing of the street to pedestrians and traffic and the removal of mature trees are all serious concerns that render this site grossly inappropriate.

While the DEIS lays out general guidelines for all the sites on how the underpinnings of historic buildings will be ensured, how vehicular and pedestrian safety will be addressed, and how traffic, debris, noise, and vibrations will be mitigated, I expect that NYCT's Final Environmental Impact Statement (FEIS) will include substantial and detailed explanations of these important safety and environmental mitigations. These are legitimate and serious concerns and the community deserves detailed and thoughtful assurances that they will be mitigated appropriately.

I appreciate the open line of communication that NYCT has already established with the community, and that communication should continue and grow as this project progresses. However, it is of the utmost importance that in addition to having an open line of communication, that the extraordinarily valid concerns that have been and continue to be raised by the community and its representatives are addressed.

Thank you for the opportunity to present these comments.


Thomas K. Duane
New York State Senate
29th District

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