"We Do Not Want The Cart Put Before The Horse": Carroll Gardens Coalition For Respectful Development Comments On NYC's Gowanus Environmental Impact Statement

Toxins, raw sewage and a flood zone.

Gowanus!

Gowanus area residents and groups had till yesterday, May 27th, 2019 to send NY City Department of City Planning (DCP) their comments on the Gowanus Neighborhood Rezoning Draft Scope of Work for an Environmental Impact Statement.(DSOW).

DCP had asked the community for input on the Gowanus Draft Scope of Work at a public meeting on April 15th, and accepted written comments until last night.  A DSOW is a "technical document that lays out proposed methodologies and assumptions and that identifies the project and the types of environmental analyses that may be performed. The DSOW helps the public understand and participate in the CEQR review from the start and a necessary precursor to preparing a Draft Environmental Impact Statement."

We are posting below the comments that Carroll Gardens Coalition for Respectful Development sent to City Planning regarding the Gowanus Rezoning because we agree with CORD and support their assessment of the rezoning.

NYC Delivers a Gowanus Environmental Impact Statement but Leaves Out a Whole Lot of Impact

To: The NYC Department of City Planning
From: CG CORD Carroll Gardens Coalition for Respectful Development

When digesting the framework and plan to rezone the Gowanus and this Environmental Impact Statement, the one phrase that continually comes to mind is, "putting the cart before the horse".

The Gowanus Canal is a Superfund site. Her waters are classified as industrial which legally allow for a certain level of toxins and pathogens to remain in the water.

Under the EPA's Record of Decision , two retention tanks of different sizes are to be constructed in order to reduce the CSO emitted pathogens and the resulting "attached" toxins. ( We note here that we are aware of NYC's continuously and deliberately keeping this plan in flux, but that is, nevertheless, the mandate issued by the Record of Decision.)

If no rezoning of the Gowanus were taking place, then, ideally after the Superfund cleanup, we reach acceptable levels of toxins and pathogens for an industrial waterway.

This is definitely an improvement to the health and safety of all Gowanus, Carroll Gardens, Cobble and Boerum Hill, Red Hook and Park Slope residents and the very aim and purpose of the EPA/Superfund will have been successfully achieved.\

With the proposed Gowanus rezone, this EIS does not insist or even recommend the classification of the Gowanus Canal to be upgraded to the more appropriate CERCLA standards for RESIDENTIAL classification.

It does not even suggest the inadvisability of residential development along the banks of any industrially classified waterway. Nor does it suggest or even hint at the inadvisability of building ANYTHING residential in an area that is classified as a flood zone. WHY NOT?

In addition, this EIS does not effectively model how new developments in the Gowanus neighborhood would naturally increase CSO discharges into the Canal.

It is bewildering that this topic is not more thoroughly addressed within this EIS.

While these glaring omissions by this EIS have us questioning the very purpose of what purports to be an ENVIRONMENTAL IMPACT STATEMENT, it also has us questioning how our other city, state and federal agencies are going to cope with what we have heard as described "the largest rezoning" of an area in New York City ever.

We wonder if the FDNY, the NYPD, OEM, EMT SERVICES, DSNY, DOE, DOT, NYCT, DCP, DEP, PARKS, DEC, MTA and FEMA are taking any steps to prepare for the estimated nineteen thousand (19,000) new residents occupying approximately eight thousand two hundred (8200) new apartments- - which by the way, works out to 2.3 people per apartment - a number representing complete fantasy.

We wonder where all the .3 people will go to school? How will all of the 2's fit on trains and busses? Where will all of the automobiles owned by the conservatively estimated 19,000 residents be? What, if any, hospital emergency facilities will be added? What tentative plans are being made to accommodate this huge increase in population in the event of an emergency/natural disaster?

We seem to recall that the "evacuation route" for Carroll Gardens takes us down to Bond Street. Will all of us be directed there and provided with canoes in the event of an evacuation scenario?

During Hurricane Sandy, this "escape route" was completely flooded by many feet of awful smelling water with our neighbors parked cars freely floating within it.

How is the current evacuation "plan" being adjusted? Is it even being considered?

So, since the apparently acceptable bunch of words that substitute for an Environmental Impact Statement, do not seem to address any of the truly important impacts this rezoning will inflict upon all of us actually living here, we add to our above comments the following:

A panel of all of the above mentioned agencies along with our EPA Region 2 team, be brought together for a minimum of two (2) TOWN HALL conversation/question answer periods as to how these agencies plan to address and resolve the REAL environmental impact of this very poorly thought out rezoning.

These meetings are to be organized, held and hosted by our COMMUNITY BOARD 6 and announced widely throughout the district.

This panel must be assembled and the town hall meetings MUST TAKE PLACE WELL BEFORE THE ULURP Community Board 6 Land Use Committee vote on the Gowanus Rezoning proposal in order to give the community the time to understand what is being presented and how it will affect them.

Right now there are no meetings scheduled or being held by our Community Board to discuss this EIS, neither what it says nor what it doesn't.

It is unreasonable for any community to attend one land use meeting for a proposal of this proportion and be expected to digest and comment intelligently without all of the players involved being there to answer questions.

Our Community Board may not be "required" to do this, but they should do it anyway-- in the spirit of being good neighbors and community guardians.

If meetings of this type are not required by NYC procedure or law-- then set some precedent here. This is an extremely ambitious rezone. It is not the same as many others before it. Let's do some things differently and better than before not just the same.

We do not want the cart put before the horse.

We want answers to our questions.

We do not need to hear how all of the appropriate boxes have been checked off.

We want a responsible rezoning.

Thank you. We welcome your comments and letters at cgcord@gmail.com

Sincerely,
CG CORD Co-founders:
Lucy DeCarlo
Rita Miller
Triada Samaras

We join CORD's call for an inter-agency panel discussion on the rezoning of the Gowanus Canal to be held by Community Board 6, so that the community can assess for itself if the City has the means, the resources and the will to TRULY plan for the impact of about 8,2oo new housing units and an estimated 20,000 new residents. After all, WE will have to live with the consequences of the rezoning.

If you agree, send an email to Community Board 6 at  Info@BrooklynCB6.org and to Jonathan Keller of City Planning at JKeller@planning.nyc.gov .
Please copy CORD cgcord@gmail.com, so the group has a record of the ask,

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Gowanus Activists Holding Press Conference Today To Call For Landmarks Designation For Key Neighborhood Structures Ahead Of Proposed Rezoning

Gowanus Flushing Tunnel Pumphouse

ASPCA Memorial Building and horse trough 

 Eureka Garage

American Can Building 

A coalition, which includes Friend and Residents of Greater Gowanus (FROGG), Historic Districts Council, Old Stone House, Park Slope Civic Council, CG CORD (Carroll Gardens Coalition for Respectful Development), as well as many Gowanus residents, will be holding a press conference this morning at 9:30 am on the Union Street Bridge to advocate for the landmarking of specific historic buildings that add significantly to the character of the neighborhood.
The hope of the coalition is to draw attention to these structures ahead of the proposed rezoning of the Gowanus Canal corridor, which is being pushed forward by Council Members Stephen Levin and Brad Landers, and by real estate speculators, who want to open the mostly industrial neighborhood to more residential development.

Here is the Coalition's press release and a list of structures that its members would like to see landmarked, before it is to late to save them.

COALITION: DESIGNATE GOWANUS LANDMARKS BEFORE EXPECTED REZONING
Press Conference Slated for May 22, 2018 

GOWANUS - With rezoning imminent, a coalition of Gowanus-area individuals and
organizations announced a press conference calling for landmarking of key historical and
architectural structures in the vicinity of the Gowanus Canal.
“Rezoning plans may be announced for Gowanus any day now,” said Linda Mariano of Friends
and Residents of Greater Gowanus (FROGG), “and while this coalition proposed a group of
landmarks last summer during the Gowanus Places Study, it’s more important than ever to
reiterate our call. Without landmark protection, our neighborhood is vulnerable to losing its
most defining features.”

The Coalition’s “Coffee and a Press Conference” is slated for Tuesday, May 22 at 9:30 a.m. at
the door to the Union Street Bridge operator’s house. The full list of proposed Gowanus
landmarks will be handed out at the press conference.
“Citywide, we’ve seen that it’s critically important for neighborhoods to stand up for what’s
important to them before rezoning arrives,” said Kelly Carroll of Historic Districts Council. “East
New York is a perfect example. Designating the proposed Gowanus landmarks at the city level
will ensure that Gowanus does not become ‘just another place’ as rampant development
moves in.”

Numerous residents who have filed requests for evaluation of potential landmarks in Gowanus
have been informed that the City’s Landmarks Preservation Commission is currently conducting
a study of potential landmarks in the area.

“It’s encouraging to hear that a survey is underway,” said Peter Bray of the Park Slope Civic
Council, “But we have not heard encouraging things about how many landmarks the survey is
likely to turn up. We hope the LPC will take a real, meaningful look at the sites this Coalition is
proposing for designation - and recognize the multi-faceted industrial history of Gowanus.”

Many of the buildings on the Coalition’s list were deemed eligible for inclusion in a national
register historic district. The sites range from the neighborhood’s flushing tunnel pumphouse
to the former Brooklyn offices of the ASPCA - and the well-known “Bat Cave” building that was
once home to the Brooklyn Rapid Transit Powerhouse.

“Gowanus is really unique - and so is this list of proposed landmarks,” said Kim Maier, Executive

Director of the Old Stone House. “The neighborhood has very few officially-designated
landmarks at present, and designating these additional structures allows the neighborhood to
keep telling its stories well into the future.”

The Coalition specifically seeks designation of more than a token few individual landmarks as
re-zoning looms.
“Rezoning tends to induce a major set of changes in an historic neighborhood,” said Gowanus
resident Brad Vogel, “and landmarking more than a few token buildings in Gowanus is
necessary to keep those changes from having a ‘scorched earth’ feel that leaves the
neighborhood feeling entirely unfamiliar.”

Coalition members include but are not limited to: Friend and Residents of Greater Gowanus
(FROGG), Historic Districts Council, Old Stone House, Park Slope Civic Council, CG CORD (Carroll Gardens Coalition for Respectful Development)

A sampling of some of the proposed Gowanus landmarks (full list available at press conference):
- Gowanus Flushing Tunnel Pumphouse (1905 - 1911)
- ASPCA Memorial Building and horse trough (1913, later additions 1922)
- American Can Building (Somers Brothers Tin Box Factory) (chiefly 1886)
- S.W. Bowne Grain Storehouse (1880s)
- Union Street Bridge operator’s house (mid 20th Century)
- Eureka Garage (1923)
- Belgian Block street-ends abutting Gowanus Canal (late 19th Century)
- T. H. Roulston Inc. buildings (c. 1910)


Update:

Here are a few photos of today's press event on the Union Street Bridge taken by Gowanus resident “The Gas Drip Bard.” Thanks for sharing, Bard!

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