Robert Kulikowski
Office of the Deputy Mayor for Economic Development and Rebuilding
100 Gold Street
New York, NY 10038

Dear Mr. Kulikowski,

Below, please find Transportation Alternatives' comments on the Downtown Brooklyn Development Environmental Assessment Statement, CEQR# 03DME016K.

Transportation Alternatives is New York City's advocacy organization for pedestrians, cyclists and sensible transportation. We have more than 5,000 dues-paying members and have been active in Brooklyn transportation and development issues for many years now. We take a unique interest in this project as our most active corps of members live within a mile or two of Downtown Brooklyn.

It is no coincidence that T.A. has such a strong following in these neighborhoods. Downtown Brooklyn and the surrounding areas are an absolute traffic disaster. The surrounding communities are looking for relief and solutions to numerous transportation problems.

T.A. supports the growth and development of Downtown Brooklyn as a major regional commercial, academic, cultural and residential district. We are happy to see Mayor Bloomberg focusing on the area and injecting new energy and resources into Brooklyn. We have serious reservations, however, about the Economic Development Corporation's Draft Scope of the Environmental Impact Statement. We believe that it does not adequately assess the major traffic impacts of proposed land use changes and major new development in Downtown Brooklyn. This area simply cannot absorb more motor vehicle traffic and maintain a reasonable quality of life level either for residents, major employers, or visitors.

It is time to begin to think of new ways of dealing with the transportation problems of Downtown Brooklyn. The rezoning of Downtown Brooklyn, along with all of the other development projects currently underway - from Brooklyn Bridge Park to BAM to 4th Avenue to Red Hook to the Brooklyn Waterfront Greenway, and the Atlantic Avenue master plan - provide us with a real opportunity to deal with the transportation and land use issues of northern Brooklyn in a holistic way. If, however, EDC continues down the path it appears to be taking, we are concerned that Downtown Brooklyn will become even more choked and less healthy and appealing as a commercial, residential and cultural center.

We have a unique opportunity here. We urge EDC to seek out new land-use, zoning and transportation ideas from places where it is being done better than New York City - far-flung places like Portland, Oregon and Berlin, Germany. For whatever reasons, the ideas and methods that we have used to develop Downtown Brooklyn over the last 30 years have failed us significantly when it comes to transportation, traffic and public space. We sincerely hope that EDC will take this opportunity to do things differently.

The Draft Scope of the EIS, gives us the impression that the same mistakes are being made all over again. The Draft Scope does not take a "hard look" at potential traffic impacts. This is borne out by the New York City Department of Transportation announcement that it intends to independently undertake a comprehensive transportation study of the entire Downtown Brooklyn area, with extensive stakeholder involvement. If the scope of the EIS was adequate, such a study would be unnecessary. To this end, any major transportation study undertaken by the DOT in Downtown Brooklyn should be integrated into the EIS.

The DEIS is fatally flawed by its reliance on the obsolete and uninformative CEQR methods of intersection-by-intersection analyses and failure to adequately consider demand management measures and non-automobile travel alternatives. The Highway Capacity Manual 2000 methodology is not the correct standard to use to study the transportation issues of Downtown Brooklyn. To be meaningful, the DEIS must fully consider the effects of:

• Tolls on the Brooklyn, Manhattan and Williamsburg Bridges.
• Congestion and variable pricing of on-street parking. Also, residential permit-parking.
• Significant increases in transit service, including the use of bus rapid transit methods, improved bus circulation, and light rail.
• Pedestrian improvements, and more advanced modeling of pedestrian movements.
• Significant bicycle infrastructure improvements --- especially their effect on trips under 5 miles.

Without these, and other improvements detailed in our comments, the EIS will be a legal fig leaf, which does not adequately address troubling transportation questions posed by the proposed influx of many more people to already gridlocked Downtown Brooklyn.

Additional comments:

Widen the Area of Study
The scope of the EIS needs to be widened to encompass the neighborhoods around Downtown Brooklyn. The area of study is not big enough. People bringing cars to Downtown Brooklyn end up seeking parking spots in Brooklyn Heights, Carroll Gardens and even as far away as Red Hook! The neighborhoods surrounding Downtown Brooklyn will be massively impacted by the 17 million square feet of new office space projected to come online in this plan and in the current plans already underway. We have got to widen the scope.

Car-Free Downtown Brooklyn
Once you do widen the scope you begin to see that there are exciting possibilities for transportation in this part of Brooklyn. We are dealing with an area that is truly the ideal size and scale for bicycling, pedestrians, and streetcars -- ideas that work very well in other big cities but are largely not promoted in New York City. Downtown Brooklyn could be a model for the rest of the city with dedicated bicycle lanes with their own traffic signals, street level light rail, and GPS-controlled bus rapid transit from the outer reaches of the borough.

The most intriguing idea of all is that of a Car-Free Downtown Brooklyn. Other cities, particularly in Northern Europe, have had great success in closing significant parts of cities to private automobile traffic. It is a proven technique for creating extremely valuable commercial, residential and cultural space. We urge EDC to consider making a significant portion of the new Downtown Brooklyn closed completely to automobile traffic.

At first glance, it is easy to scoff at this idea as radical. The car-oriented NYC DOT will certainly say it is impossible and there study methods will invariably show that it creates a traffic disaster. This, however, is the opposite experience of cities all around the world that have made significant parts of their downtowns car-free.

A Car-Free Downtown Brooklyn would appeal to virtually every party involved in this process - developers, corporations we wish to lure to the area, BAM, area residents, and local businesses. The best way to connect our businesses, cultural institutions and local residents is to take the cars out of the area and make it easier for people to get around on foot, by bike, by streetcar and bus.

Being as how the area bounded by Fulton, Adams, Tillary and Flatbush is essentially impossible to use already for through-traffic (with the exception of Jay Street), this idea is doable. We urge EDC to put some resources into brainstorming and studying possibilities such as this. Due to global circumstances, in the coming 20, 50, 75 years it will be increasingly expensive and difficult to for individual New Yorkers to afford to maintain automobiles and for the City to maintain its vast and expensive automobile infrastructure. This is a difficult and looming fact that is largely not being dealt with by New York City, New York State or the Federal Government on any level. Let's take this opportunity to plan for a future of fewer automobiles, and make Brooklyn a model for the transportation future of New York City and, perhaps, the entire country. Building the new Downtown Brooklyn around automobile traffic and copious parking is a recipe for disaster, failure and a dysfunctional future.

Secure Indoor Bicycle Parking Towards encouraging alternatives to driving, we urge you to make "enclosed, accessible and secure" bike parking a requirement in new commercial developments in Downtown Brooklyn. This is easy, inexpensive and has been done in New York City with great success in the City Planning Board's 2001 re-zoning of Long Island City, Queens. Enclosed, accessible and secure bike parking should be required in all new commercial developments and major renovations in Downtown Brooklyn. Downtown Brooklyn's proximity to the Brooklyn and Manhattan Bridge bike paths and network of neighborhood streets make it a popular cycling destination. According to the Department of City Planning's 1999 "Bicycle Survey Report," the lack of secure bike parking is the largest obstacle to potential bike commuters. Thus, guaranteeing secure bike parking is the most effective way to get more people to bike to work. Bike commuting is good for individuals and for the city. Biking does not contribute to traffic congestion or air and noise pollution. It's attendant health benefits cannot be denied, and commuters who bike to work arrive energized.

NYC DCP Indoor Bike Parking Zoning Regulations For Long Island City, Queens Special Zoning District

117-541 Indoor bicycle parking A designated area for bicycle parking shall be provided in Areas A-1 and A-2 for commercial developments or enlargements with a minimum floor area ratio of 5.0, except where more than 50 percent of the floor area of such development or enlargement is occupied by a use listed in Use Groups 16 or 17. Such designated area shall be provided at a ratio of one square foot per 1,000 square feet of floor area. Such facility must be enclosed, accessible and secure. Up to 25 percent of the designated bicycle parking area may be used for accessory facilities.

Thank you for taking the time to read these comments. Please feel free to call us if you would like to discuss anything further. We would very much like to be included in the ongoing planning process and will work hard to ensure that the City does all that it can to plan for proper transportation and take automobile traffic impacts into account.

Sincerely,

Aaron Naparstek
Brooklyn Coordinator
Transportation Alternatives