NAG Delivers Testimony on Domino Sugar Development


Domino Sugar Building
Last night, Community Board 1 voted “No with modifications” on Community Preservation Corporation’s proposed redevelopment plan for the Domino Sugar site in South Williamsburg.

Neighbors Allied for Good Growth (formerly Neighbors Against Garbage) is a volunteer-based community planning and environmental justice organization that has been performing grassroots organizing, advocacy and outreach/education to the North Brooklyn waterfront community of Williamsburg/Greenpoint since 1994.

NAG supports the ULURP committee’s recommendation of “NO with MODIFICATIONS”. We do not believe that this plan, as it currently exists, is sustainable or can be considered good growth.

North Brooklyn desperately needs more affordable housing; especially low-income housing, middle-income housing, homeownership opportunities, and housing for families. A disappointing side effect of the 2005 rezoning of our waterfront is that many affordable tenants have been displaced. We also desperately need more open space, especially for exercise and safe play, access to our waterfront, bike parking, community meeting space, and sustainable historic preservation and planning. CPCR’s plan for the New Domino includes a number of elements that would have a positive impact on the neighborhood. However, we are concerned about the detriment to the community that may be caused by this project’s massive scale, and have a number of recommendations for improvements and changes.

Most importantly, the 660 planned units of affordable housing MUST be permanently affordable and guaranteed in a restrictive declaration. The timeframe for this project’s buildout is quite long, and as we all know, the market is unstable. Without any legal requirement to build the affordable housing levels proposed by CPCR, any owner of the site would be bound only to build what is required by the 421-a tax credit program. Should CPCR need to sell the property for any reason, the community needs assurance that a new developer will not take advantage of the high density of the rezoned area to build a luxury compound on our waterfront. In addition, CPCR needs to commit to an open and transparent affordable housing lottery. Far too many complaints have been lodged against waterfront developers in regards to the secretive and closed manner in which these lotteries are conducted. In order to combat these same problems, CPCR needs to work closely with all the community groups in the neighborhood, hold educational seminars about the applications, and release the floorplans of the units during the application process so there is no confusion about issues such as size or lighting in these affordable units.

On the subject of density, the rezoning of this site should be limited to the height/density outlined in the 2005 Williamsburg Waterfront rezoning. It is our belief that CPCR can still create a viable, mixed-use development that includes all the planned affordable housing within this zoning framework. CPCR has claimed that they must build taller and more dense, but their lack of willingness to share their books and planned profit margin with the community makes this claim suspect. What’s planned is simply too tall and too dense. The proposed 22% population increase to the south side of Williamsburg would have a negative impact on the area’s infrastructure, transportation, open space, and general quality of life. Even with the addition of four acres of publicly accessible open space planned, this development will actually decrease the per-capita open space in our already green-starved neighborhood. In a community that ranks near the bottom in city-wide open space rankings, that is simply not acceptable. Also not acceptable are the significant shadow impacts on Grand Ferry Park; Domino will put the park into shadow for an additional 4 to 6 hours per day, year round. In order to help balance the population increase with our neighborhood’s low open space ratio, CPCR and the City should include the DOT Carpenters Shop lots @ 390 Kent as additional waterfront park space in the rezoning plans. In addition, the upland site should be zoned R6A. We are concerned about the precedent that this site will set for future development on the upland neighborhood’s low-rise side streets.

Of more concern than the built fabric surrounding the Domino site is the future of nearby tenants. The Domino project will completely change the landscape of the Southside, leading to an influx of market-rate units. Without a real commitment to helping the community maintain the stabilized housing stock and low rent unstabilized units that currently exist, this project could mean displacement for Williamsburg’s most vulnerable neighbors. In order to protect the surrounding low income and working class community from illegal evictions and landlord harassment, CPCR should acknowledge the high risk of displacement that will arise due to their project and request that the City implement protections similar to those enacted on the Northside during the 2005 rezoning. Due to the large impact that this project will have on the neighborhood, CPCR should be campaigning for the City to extend the Greenpoint-Williamsburg Anti-Harrassment zone to cover the entire CB1 area and asking both HPD and DOB to devote resources for its implementation and neighborhood education. The anti-harassment zone is one of the few protections that residents in the shadow of waterfront development have had to stop unfair displacement; it is time for developers to recognize the secondary displacement caused by the luxury towers on the waterfront and to help the community build in safeguards against this. In the end, 660 units of affordable housing will mean nothing if thousands of residents are displaced.

We also have a number of concerns about the impact that this project will have on the neighborhood’s transportation infrastructure. We strongly encourage CPCR to consider adding even fewer than the 40% parking spaces required under the zoning. The addition of thousands of cars to Williamsburg is not only unsustainable and counter to the City’s goals as outlined in PlaNYC 2030, it would create an undue burden on a neighborhood that already suffers from traffic congestion, high levels of asthma, and heavy truck traffic. The developers claim that their parking plan is based on demand for car ownership in the area, but this claim is based on 10-year-old data, and data that is heavily skewed by the nearby census tracts, where the Hasidic community has high car ownership. Updated numbers from the surrounding area would likely show fewer car owners and more people who depend on public transportation. Rather than accommodating personal vehicle use, we encourage CPCR to work with the MTA and the DOT to increase public transportation options for this underrepresented area of Williamsburg.

Because the proposed development is not located in close proximity to the subway, CPCR should work with the MTA and the DOT to implement a Bus Rapid Transit plan that would link the site to other parts of Brooklyn and Manhattan. A proposed BRT plan is currently being considered that will run north on Bedford Avenue and end at Williamsburg Plaza. If this line were to have branches that ran along the North Brooklyn waterfront and over the Williamsburg Bridge, the entire community would benefit, and this would help mitigate the doubling in bus ridership expected to result from the Domino development. We encourage CPCR to work with the MTA, and to not promise the community any public transportation improvements that fall under the MTA’s jurisdiction without a guarantee from the agency that they will be implemented. Ultimately, Community District 1 needs a comprehensive, community based transportation study. CPCR could help mitigate its transportation impact on the neighborhood by contributing to this effort; however, this alone will not solve the area’s major transportation problems, which will only be made worse by this project.

Regarding the retail component included in this plan, we support CPCR when they say that they want to include local, neighborhood-serving retail that will be affordable to all the new tenants. However, we have yet to hear any information about how they plan to accomplish this, and therefore are concerned that the development will include high-end retail and/or big-box stores that provide few economic benefits to the community. Our neighborhood has recently witnessed a steady shift from locally based, independently run storefronts to large-scale chain stores. These chains detract from our neighborhood’s character, take their profits out of the community (and at times even the city or state), and their low wages cripple employees’ ability to be self-sufficient. To encourage local retail, discourage big-box stores and complement the Department of City Planning’s urban design goals set forth in other projects, we ask that retail floorplates be limited to 3,000-5,000 sq. ft. DCP implemented a similar measure in much of the 2005 rezoning, and we encourage them to follow suit here. Stores should also have a limited frontage on Kent Ave and sidestreets to encourage active streetscapes. The last thing we need is another Duane Reade, like the one taking up much of the block in the Palmers’ Dock building. The exception to this would be the 30,000 sq. ft. supermarket on the upland site, which should meet the DCP’s new “fresh” standards, providing an assurance that tenants will have access to quality fresh produce.

We also encourage CPCR to include a 10-foot setback from Kent Avenue, in order to facilitate the development of the Brooklyn Waterfront Greenway. The Kent Avenue bike lane is a precursor to what will one day be a protected greenway connecting Greenpoint to Bay Ridge. This will benefit all community residents, and its implementation should be a priority for all developers along Kent Avenue. Another important aspect is to continue reflecting the unique community culture that Williamsburg has become globally recognized for– our arts-based community. CPCR has mentioned that the open space will include public art– we ask that all art be locally designed and built.

Finally, we support Community Board 1’s ask that they have review of any design changes to the project moving forward. Recent history shows us the very real nature of private alterations effecting community satisfaction. For example, the early planning stages of the Atlantic Yards development sold the community on high-end design and a list of public benefits and amenities, which were later amended to meet changes in the project’s financing. We need written reassurance that if amendments are necessary, the community will again be included in the alterations.

Thank you for your time and consideration.

Sincerely,

Neighbors Allied for Good Growth

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