Letter to NYC Planning: RE: Downtown Brooklyn Development Plan Draft Environmental Impact Statement

Amanda Burden
Chair, NYC Planning Commission
22 Reade Street
New York, NY 10007-1216
VIA FACSIMILE (212) 720-3219

Dear Ms. Burden,

Transportation Alternatives (T.A.) is New York City’s advocacy organization for pedestrians, cyclists and sensible transportation. We have more than 6,000 dues-paying members and have been active in Brooklyn transportation and development issues for a decade. T.A. and our Brooklyn Committee are key stakeholders in the Downtown Brooklyn Traffic Calming Project, the Gowanus Expressway MIS and other Brooklyn transportation initiatives.

Below, please find T.A.’s transportation-related concerns and recommendations to make Downtown Brooklyn’s transportation network a boon, not a bane, to the borough’s continued development. In particular, we urge the City of New York to immediately implement the specific traffic calming measures recommended in the Downtown Brooklyn Traffic Calming Project, institute a net reduction in parking spaces, create safe and convenient bicycle and pedestrian access to the Brooklyn and Manhattan Bridges and make "enclosed, accessible and secure" bike parking a requirement in new commercial developments.

However, all of these transportation improvements will be for naught if the City does not study and implement tolls on the East River bridges. Right now, 40% of motor vehicle traffic in Downtown Brooklyn is through-traffic traveling to Manhattan via the Brooklyn and Manhattan Bridges. Tolling these bridges would reduce the number of vehicles traveling through the area, as motorists would seek alternate routes, modes of travel and times of day to enter Manhattan.

Tolls are a prerequisite to development in Downtown Brooklyn. Downtown Brooklyn’s streets cannot accommodate any more traffic, and if the Downtown Brooklyn Development plan does not take serious measures to reduce motor vehicle traffic in the area, increased traffic could hamper the very development the plan aims to generate.

1. Increasing Pedestrian and Bicycle Safety and Creating Alternatives to Driving

A) Overall, pedestrian space needs to be preserved and enlarged. The City should use designed, metal bollards in streetscape improvements to increase pedestrian safety and comfort. This will save lives, reduce injuries and encourage more walking. The City should also maintain and expand "Leading Pedestrian Interval" (LPI) signals at crossings. Leading Pedestrian Intervals give pedestrians a three second head start before the traffic light turns green. This head start reduces conflicts between pedestrians and turning vehicles and makes crossing the street safer and easier. This will also save lives and reduce injuries.

B) Traffic Calming
Transportation Alternatives supports the Brooklyn President and the Downtown Brooklyn Coalition in their call to immediately implement the specific traffic calming measures recommended in the Downtown Brooklyn Traffic Calming Project. Furthermore, the Downtown Brooklyn Traffic Calming Plan should extend into DUMBO and Vinegar Hill. This should also include the acceleration of pedestrian and bicycle safety upgrades to Tillary Street and incorporate the Adams Street crosswalk.

The City should use unspent traffic mitigation funding from the Downtown Brooklyn Development Plan to accelerate the implementation of the Downtown Brooklyn Traffic Calming project. According to Chapters 14 and 20 of the Environmental Impact Statement, the projected growth in Downtown Brooklyn will significantly increase traffic in the area. However, the EIS proposes no substantial traffic mitigation measures, as there are few opportunities to increase traffic capacity. The funding for traffic mitigation should be used for traffic calming.

C) Improving the Flatbush Avenue median should not come at the expense of narrowing its sidewalks. Studies show that medians do slow down motorists, but all the options should be studied before Flatbush’s median is changed. Adams Street has both a median and a bike lane, but speeding is chronic on the main and carriage roads on Adams Street, and its bike lane is parked in almost 24-hours a day. These failures should not be repeated on Flatbush Avenue.

D) Build out the sidewalk at the intersection of Tillary and Flatbush, where the NYPD has barricaded off part of the roadbed. Traffic is moving through this intersection with ease, and the road space should be reclaimed for pedestrians.

2. Institute a net reduction in parking spaces.

If the City creates or allows for the creation more parking, either on-street, in garages, under new residential and commercial developments or at retail centers, it will create more traffic. More plentiful parking makes driving more convenient and further encourage people to drive, resulting in increased traffic congestion.

T.A. supports the Downtown Brooklyn Coalition’s package of parking measures, including a residential parking permit program, extending the "no authorized permit" zone, eliminating all on street parking for agency personnel and make provisions for off street parking for agency personnel, the use of variable pricing of muni meters to make more parking available to merchants and local businesses, reducing the number of planned parking garage spaces in the current rezoning by at least 25% and clean emissions from underground parking.

3. Cycling’s role in development and growth in Downtown Brooklyn.

The terrain and density of Downtown Brooklyn and surrounding neighborhoods are perfectly suited for short, utilitarian cycling trips. In fact, these neighborhoods boast some of the city’s highest bicycle volumes, and it can be said that the high number of cyclists improves quality of life there. Increased cycling will help ease congestion in Downtown Brooklyn.

We support Borough President Markowitz’s call to make bicycle and pedestrian connections between Downtown Brooklyn and the adjacent neighborhoods of Fort Greene, Boerum Hill, Cobble Hill, Brooklyn Heights, DUMBO and Vinegar Hill.

A) Safe and Convenient Bridge Access for Cyclists and Pedestrians
Transportation Alternatives broadens the Borough President’s call and urges the City to make access to the Brooklyn and Manhattan Bridge bicycle paths safe and convenient. These non-motorized arteries between Brooklyn and Manhattan already carry some 6,000 pedestrians and bicyclists between everyday.

The DOT should study and build a bicycle and pedestrian flyover ramp from the Brooklyn Bridge promenade to Cadman Plaza. It should also slow traffic on Jay Street and the Manhattan Bridge off-ramp onto Jay Street to make Manhattan Bridge access safer for bicyclists and pedestrians. The City should install bike boxes and bicycle/pedestrian signal phases at the intersections of Tillary and Adams Streets and Tillary and Flatbush Avenue. Both the Brooklyn and Manhattan Bridges have bicycle paths, connecting Manhattan with Downtown Brooklyn. Safe and convenient access to these paths will encourage more people to bike and walk over them and help make Downtown Brooklyn more appealing for development.

B) Secure Indoor Bicycle Parking
Downtown Brooklyn should have both long-term and short-term secure, indoor bike parking. We are glad to see that the plan requires indoor bike parking for new commercial developments. Indoor bike parking should also be required in garages. The City should also install bike parking in the new garage under Willoughby Park and at transit stations.

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

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.

C) The City should work with colleges and universities in Downtown Brooklyn to create bike parking, identify and mark bike routes and encourage bicycle commuting. Some 33,000 students attend Downtown Brooklyn’s colleges and universities. This is as many as Cambridge, Massachusetts which is regarded as one of America’s most bicycle-friendly cities. Both Cambridge and Chicago have City programs that reach out to students and help them commute by bike.

D) The City must stop the constant parking in the Adams Street bike lane. One option is to move the bike lane to the median side of the carriage road and remove the parking, install flexible plastic bollards to prevent motorists from parking in the bike lane and redesign the slip ramps and add stop signs to reduce conflicts with motorists driving on and off Adam Street’s main road.

Thank you for taking our comments and recommendations into consideration.

Noah Budnick
Projects Director

Testimony Old URL
Secondary Title
and Draft Supplemental Environmental Impact Statement