Brian's Stand on Coney Island Development

June 25, 2008

Rachel Belsky; Vice President; New York City Economic Development Corporation; 110 William Street; New York, NY 10038

Dear Ms. Belsky:

I write with regard to the revised Draft Scope of Work for an Environmental Impact Statement/Coney Island Rezoning (CEQR No. 08DME007K) (hereinafter "Draft Scope"). In order for any redevelopment plan to be successful, it must address the needs of the entire community rather than selected portions of it. The Draft Scope as it is currently constructed is flawed in that it will be impossible to accurately depict and measure the full effect of each variable it seeks to identify and measure. This is because it fails to incorporate the entire Coney Island community. Geographically speaking, the study area for each variable listed in the Draft Scope extends between a few hundred feet and half a mile from the boundaries of the proposed project area. At no time does it ever incorporate the entire community, and it completely ignores the western portion of Coney Island.

In order to secure accurate results, the Draft Scope must incorporate all of Coney Island, along with, inter alia, the development that is currently progressing in Brighton Beach and Sheepshead Bay; the proposed Marine Waste Transfer Station (at the site of the former southwest Brooklyn incinerator); and, Drier-Offerman Park -- which, thanks to the efforts of Councilman Recchia, will soon be the site of a $40 million renovation. It is imperative that this is done so that we may secure an accurate picture of how the Coney Island Rezoning Project will affect Coney Island.

INFRASTRUCTURE

By failing to take into account thousands of existing residents, the Draft Scope cannot and will not be able to provide accurate information relating to the subject of Coney Island's infrastructure. The creation of high rise condos, hotels and business will create an exorbitant amount of refuse before, during, and after construction which will necessitate the assignment of additional personnel and equipment to the Department of Sanitation's BK District 13 command. Also, Coney Island residents already suffer through multiple brownouts and blackouts each year. Unless major upgrades are made to accommodate the increased demand for power, this problem will increase exponentially in frequency and severity. The Draft Scope ignores this by only reviewing a small area surrounding the proposed project.

The same can be said with regard to the community's water/sewage lines. Rather than follow through on the long planned pumping station, it was decided that the problem would be resolved by simply cleaning out the antiquated sewage lines and installing a "liner" within them as a means of moving particles along. Given the size of the buildings that are to be constructed under the proposed plan, the plan to construct the Pumping Station, along with the replacement of the existing water/sewer lines, should be reinstated immediately to meet the needs of the entire community. Additionally, the Draft Scope should be expanded to take into account the effect of the proposed plan on the entire community, rather than those who reside a few hundred feet from the project's boundaries. The Draft Scope must also account for the flooding that occurs throughout the entire community as a result of sewer lines that are routinely clogged by sand and assorted debris.

FLOODING

As Coney Island is in an area that is prone to flooding, with very limited means of ingress and egress, the Draft Scope must take into account how the project will affect the community's status as a flood zone. Further, hurricane evacuation routes should be investigated and methods of how people will be evacuated from Coney Island in cases of emergency/disaster should be investigated and formalized.

EDUCATION

The Draft Scope fails to incorporate each of the schools within Coney Island and/or Community School District 21. Most schools within District 21 are already at or near capacity. The failure to take into account the ripple effect that would be created by the influx of children who will reside in the 4,650 units of housing that is called for by the proposed plan is nothing less than a recipe for disaster. It should also be noted that the Draft Scope fails to incorporate either Lincoln High School or any of the schools that are currently housed at Lafayette High School. In addition to investigating the feasibility of constructing new schools, the Draft Scope should also investigate the possibility of incorporating new schools into the lower levels of some or all of the new buildings that are proposed in the plan.

JOB CREATION / EMPLOYMENT

Pursuant to Chapter 3b of the CEQR Technical Manual, the socioeconomic analysis (Task 3) outlined in the Draft Scope must further investigate employment and local workforce trends. The Environmental Impact Study (EIS) will not adequately predict the impact of the proposed rezoning on these factors unless it specifically includes:

- A current population profile that analyzes percentage of the population in the labor force, workers per household, occupation and rates of unemployment;

- Estimates of new employment for the study area, with a detailed analysis of the quality/type of employment (i.e. part-time/seasonal versus full-time, availability of pension and health benefits, career growth potential, anticipated wages, accessibility of new employment for
local residents, etc.). I am requesting more detailed information than is usually calculated in an Environmental Impact Statement (EIS).

There must be a commitment to job training and using union labor and minority owned businesses that will employ local residents. This is necessary so as to allow local residents to pursue careers with a future rather than a simple temporary job. This commitment must go beyond the construction phase of the project and each structure that is erected must be built in accordance with existing codes and regulations.

PUBLIC HEALTH

Due to its geographic limitations, the Draft Scope fails to accurately take into account the needs of and demands that will be placed on Coney Island Hospital. Rather than treat the project area as an isolated island, the Draft Scope should incorporate factors which include the closure of Victory Memorial Hospital and the explosion of development in the neighborhoods of Brighton Beach and Sheepshead Bay. Although these neighborhoods are obviously outside the scope of the proposed project, the demands that are placed on Coney Island Hospital - the only hospital in this portion of Brooklyn -- will skyrocket due to all of the people who will occupy the newly constructed units of housing in each neighborhood. As such, the demand placed on the infrastructure of Coney Island Hospital by these individuals, along with the closing of Victory Memorial Hospital, must be taken into account.

PARKING

The residents of Coney Island already suffer from a severe shortage of parking. Even though the proposed plan calls for the creation of additional parking spots, the number is insufficient to meet the needs of the community. Yet again, the Draft Scope, due to its geographic limitations, fails to take into account that fourteen out of the City's sixteen million beach goers come to Coney Island - and many of them drive to the beach; Brooklyn Borough President Markowitz's proposed amphitheater at Asser Levy Park; possible renovations to the Aquarium; and, other development projects within Coney Island. It should be investigated as to whether large parking lots and/or multi-level "park & ride" facilities could be constructed in order to ease the parking burden on residents and visitors alike.

EMERGENCY SERVICES

Once again, due to the aforesaid geographic limitations, the Draft Scope will fail to properly take into account the project's effect on the entire community. If the proposed project is approved, it will result in an increase in population, resident and visitor, throughout Coney Island. In order to assess the effects of this population increase, it is necessary to account for all of Coney Island. How will the increased number of housing units affect ambulance service to western Coney Island? How will the increased number of structures - as called for by the proposed project - affect the ability of the police and fire departments to respond to emergencies? What type of additional equipment, if any, will be needed to address any expected, and unexpected, emergency? Will it be necessary to construct additional police and/or
fire stations? Will emergency service vehicles have easy access throughout the entire community or will they be stretched too thin to respond in a timely manner?

EMINENT DOMAIN

Despite claims to the contrary, the attempt by the City of New York to have all or part of the amusement area mapped as park land effectively constitutes eminent domain. Although current property owners are not required to sell their property to the City, their options have become limited in that prospective purchasers are aware of the City's desire to oversee and manage - either directly or indirectly - the operation of the amusement area - something the City of New York has no experience in doing.

TRAFFIC CONCERNS

During the summer season, traffic into and out of Coney Island is overwhelming.

Motorists trying to enter/exit Coney Island via Surf / Neptune / Cropsey Avenues are faced with extensive traffic jams and delays. This is particularly true before and after Brooklyn Cyclones games and most events held at Keyspan Park. The Draft Scope fails to address or account for how traffic generated by the proposed project will affect the ability of residents - and emergency service vehicles - to enter or exit Coney Island. As Coney Island is a peninsula, there are limited means of travel into and out of the community. How will the mobility of community residents be affected by the proposed plan?

HOUSING

Of the 4,650 units of housing that has been proposed, 930 units, or 20%, have been designated as "affordable." Given that median income in the New York City metropolitan area is approximately $70,900, the resulting numbers for households with incomes up to 80% of AMI appear to be very high and unattainable by those who currently live in Coney Island. The Draft Scope must define and look at what is truly "affordable housing." Under the proposed plan, it is unlikely that many of Coney Island's current residents will be able to afford the rent and/or purchase price of one of these new units. As such, they will be forced to move out of the community because their rents will be increased as a result of the new "housing."

I submit that the Draft Scope not only define "affordable housing" as 30% of one's income, but that it should look at the effect of requiring developers - who are selected to construct portions of the project - to help rehabilitate and maintain the existing New York City Housing Authority (NYCHA) buildings and/or Boardwalk. Furthermore, at least half (50%) of the units to be constructed should be designated as reserved for affordable housing, with the condition that local residents be given the first opportunity to rent and/or purchase them.

ENVIRONMENTAL CONCERNS

The Draft Scope also fails to take into account the aforementioned Marine Waste Transfer Station. Although the proposed station is not physically located in Coney Island, its proximity makes Coney Island vulnerable to any incident that occurs at the station. Like the
incinerator that preceded it, the Marine Waste Transfer Station has the potential to wreak environmental havoc on Coney Island and its residents. In the event an accident occurs at this station, it is likely that any debris - including toxic chemicals - will adversely affect Coney Island's beaches and water(s) - which are the cleanest they have been in years. The Draft Scope must look at how Coney Island is affected - health-wise and environmentally - by this station.

TRANSIT

The turning of Coney Island into a year round destination and the increase of 4,650 units of housing will put a huge strain on all Coney Island residents. This serves to make improved mass transit even more of a priority than it already is. The people of Coney Island must be provided with alternate means of transportation. This includes increased express bus service and the reinstatement of express service on the Culver (F train) and Brighton Lines (Q train) from the Coney Island-Stillwell Avenue station. Residents must also be provided with increased parking facilities at or near the subway station so that they may be able to take advantage of "park & ride" opportunities. The Draft Scope should also investigate the effect of a trolley system transporting motorists from their vehicles (parked in off site parking lots) to locations within Coney Island.

PARKS

As a result of the increased population in Coney Island, the ability of the community's parks and playgrounds to accommodate residents will be taxed. The Draft Scope should investigate new possibilities of improving/expanding/rehabilitating existing parks and creating new ones throughout the community. Repairs must also be effectuated to the Boardwalk, which seems to be ignored by the proposed project to enhance the amusement area. Due to a variety of factors, the boardwalk has fallen into a state of disrepair and the potential for an ever increasing number of accidents - and lawsuits stemming from them - exists. It should also be noted that the City has recently announced that Drier-Offerman Park will receive a $40 million renovation. How will the increased usage of this park affect Coney Islanders? Conversely, how will the proposed project affect Drier-Offerman?

CONEY ISLAND AMUSEMENT AREA

It is undisputed that Coney Island occupies a special place in the hearts of millions of people throughout our city, state and country. It is also undisputed that historically speaking, Coney Island and its amusement area have been known as a "Poor Man's Paradise." Specifically, a place where someone can take their family for a day of fun and thrills without having to pay the skyrocketing prices of parks like Great Adventure, Action Park and Dorney Park. As such, the existing amusement area should be enhanced and expanded in conjunction with the addition of new rides, amusements and attractions. Rather than doing this, the revised plan and draft scope downsizes the existing amusement area to the point of non-existence by cutting its size by more than fifty percent.

ABE STARK ICE SKATING RINK

What are the plans for this facility? Under the current plan, the rink is scheduled to be demolished and an ice skating rink is to be built at the base of the Wonder Wheel. I fail to see how this is logistically possible, and the demolition of the Abe Stark Ice Skating Rink will adversely affect hundreds of community residents who participate in various ice hockey and skating programs at the rink.

PROPOSED AMPHITHEATER AT ASSER LEVY PARK

Although plans for this project have yet to be finalized, it must be taken into account. Residents on the eastern end of Coney Island - specifically those who live in Trump Village, Brightwater Towers, Amalgamated Warbasse and Luna Par - are frequently faced with traffic jams/delays as people try to enter and/or exit Coney Island's amusement area. This also leads to a deprivation of parking spots for local residents and their guests as people park their vehicles on West 5 Street / West 8 Street / Neptune Avenue and the area surrounding Asser Levy Park - which is across the street from two synagogues - and walk to the amusement area. Steps must be taken to address the impact of both of these projects as they relate to the residents of Trump Village, Brightwater Towers, Amalgamated Warbasse and Luna Park. At no point are these residents addressed in the Draft Scope, even though they do reside in Coney Island.

QUALIFICATION

The analysis of the Draft Scope must be qualified so as to explain how each number/result was obtained, calculated and identified.

While it is understood that the proposed project only occupies a portion of the Coney Island peninsula, it should not be treated as though it were an island amongst itself. In order to accurately measure each variable, the Draft Scope must encompass the entire community and incorporate, to the extent possible, outside factors that will affect each variable at the same time. Finally, in light of the foregoing, I think it is both shameful and irresponsible to proclaim that the Draft Scope (and the proposed Rezoning Plan) - in their current formats - will provide full and complete answers to one and all when both leave out significant portions of the Coney Island community.

Thank you for your time in this matter.

Sincerely,
Brian L. Gotlieb