We are deeply concerned by the emergence of individual private ULURP applications for Atlantic Avenue and we call on the City Planning Commission to reject them.
The use of individual private applications to unlock development potential on Atlantic Avenue undercuts the community’s leverage to develop a holistic plan that addresses an eventual near-doubling of Prospect Heights’ population. There are already 6,450 new units of housing approved for Atlantic Yards/Pacific Park. The progression of proposed new developments on Atlantic Avenue will add thousands more residents and the impact on infrastructure must be considered comprehensively. The consideration of individual applications also fails to address the implications of indirect displacement caused by the introduction of such a large number of new market rate units.
These proposals should be rejected and we ask our next City Council Member, Borough President and Mayor to work with us to deliver a better plan.
THE COST OF NO COMPREHENSIVE PLAN
The absence of a transparently developed comprehensive plan lets city agencies and our elected officials off the hook, and leaves the community with changes that can in reality contradict declared goals.
While imperfect, neighborhood-wide plans have far broader scope, including programs and funding for displacement mitigation and infrastructure improvements, and they are a rare opportunity to connect normally siloed city agencies inside a public process.
Individual applications cannot contribute in the same way to building a vital and healthy neighborhood. With individual applications, any benefits must be delivered within the property lines that are controlled by the developer. This is compounded by approval of districts that include property outside of any agreement because the property is not controlled by the applicant, and the need for the Community Board to offer development bonuses in exchange for benefits which have been defined by a few behind closed doors.
Just look at the environmental study for each of these individual developments. Across numerous categories of study – schools, displacement, open space – the impact of each individual development does not meet the threshold for study. Yet we know that, in aggregate, the combined impact of these developments will be significant.
This is why we say the City is letting the community down, and itself off the hook. And it is not the first time we’ve gone through this. With Atlantic Yards, the City let a private developer use a State process to escape any enforceable obligations it did not choose to meet. So we already have shortfalls like 1877 elementary school seats if the project is built in full, regularly congested intersections, and poor sanitation. Looking forward, the obvious context here is that the much-ballyhooed public transit access said to accompany these upzonings on Atlantic Avenue is missing. Public transit access may be sufficient for a certain degree of density, but Atlantic Avenue simply does not have the equivalent public transit of similarly wide avenues nearby like 4th Avenue or Eastern Parkway.
Failure to address these conditions within a transparent public process that publishes the goals it defines, and sets clear commitments will likely produce an acceleration of exactly the demographic changes the Department of City Planning says it is trying to address in its presentation “M-Crown Population and Demographic Trends.”
Over the course of the last twenty years Prospect Heights has changed dramatically. Much of the neighborhood is whiter and richer. Its expensive shops and restaurants alienate many longtime residents of the neighborhood. But DCP is using urgent observations about demographic changes in our neighborhood to justify actions which only further enhance and speed up the effects of displacement.
One cannot introduce so much market rate housing into a neighborhood and expect to compensate for the effects of displacement using existing MIH options. The developer’s use of simulated negotiations with the Community Board over MIH options is a sleight of hand which trades away little if any of the amount of square footage dedicated to unaffordable housing. And by breaking apart environmental analysis into individual pieces even though a wide area is clearly being up-zoned, the city is playing a trick. It avoids identifying the cumulative effects of all of the new developments when looked at together.
Approval of these projects will complete the upzoning of much of Atlantic Avenue in Prospect Heights. Without a comprehensive public planning effort, the greater density and large number of non-affordable units ushered in by these applications will increase adverse impacts on the community – even as they diminish the community’s leverage to address those impacts moving forward.
In 2018, Borough President Adams, Majority Leader Laurie Cumbo and Community Board 8 all called for a neighborhood-wide plan and a specific zoning framework. Both goals are being brushed aside with these individual applications. In her campaign Council Member Crystal Hudson called for the ULURP application process to be centered on racial equity and she made numerous positions relative to development that these projects do not address.
Why not allow the imprint of our new Council Member and our new Mayor on these developments? These proposals should be rejected, and we ask our next City Council Member and Mayor to work with us to deliver a better plan.