March 22, 2006 Sign-On Letter to City Council Speaker Christine Quinn
 

ENVIRONMENTAL DEFENSE

GOOD JOBS NEW YORK

MUNICIPAL ART SOCIETY

NEW YORK CITY AUDUBON

NEW YORKERS FOR PARKS

NEW YORK LEAGUE OF CONSERVATION VOTERS

NYPIRG STRAPHANGERS CAMPAIGN

REGIONAL PLAN ASSOCIATION

RIVERKEEPER

SIERRA CLUB

TRI-STATE TRANSPORTATION CAMPAIGN

  

March 22, 2006

Re: Yankee Stadium ULURP Application


Dear Speaker Quinn:

 As members of the city and region’s environmental, planning and fiscal policy community, we write to draw your attention to a serious problem in the proposal for the new Yankee Stadium. 

We are strong supporters of the Yankees’ plan to remain in the South Bronx – as such, we call on the Council to take action to address our concern about the large amount of new parking capacity the plan will locate on existing parkland, and allow the stadium redevelopment project to proceed with less controversy.  We urge that the redevelopment plan proceed with no net addition to parking capacity, and with inclusion of a new Metro-North Railroad station. 

The current plan is neither equitable nor environmentally sustainable. Here is why:  

  • The Massive Increase in the Amount of Parking Will Lead to More Traffic and Air Pollution

The project includes the construction of four new parking garages to be built on top of public parkland. The capacity of the new garages represents a nearly 75% increase in parking availability in the vicinity of the stadium. This new parking will only encourage fans to drive to games. More traffic will worsen already bad game-day traffic congestion and air pollution in the South Bronx. 
 

  • This Plan Prioritizes Parking Garages Over Parks

These new parking garages will actually be built on top of the community’s parkland. The plan calls for much of the replacement “parkland” to actually be constructed on top of the parking garages. Some of the replacement parkland is also going to be built over a mile away, and community residents will have to cross the Major Deegan Expressway to access it. Natural park space not only contains vegetation that improves air quality but also helps attenuate the discharge of stormwater and raw sewage runoff – a multi-billion dollar, citywide problem that continues to destroy the Harbor's water quality.

  • The Plan Contains No Improvement to the Mass Transit System

Plans for a stadium Metro-North station have been languishing for years and are not part of the current plan. The Yankees have said that they “support” a Metro-North station, but have not offered to provide any sort of financial assistance, nor has the Mayor sought to amend the MTA capital program to include the project. Instead, the Yankees and the City continue to insist that all of the parking is necessary. 
 

  • The South Bronx is an Environmental Justice Community

The South Bronx is a low-income, minority community. It has one of the lowest rates of car ownership in the City, but one of the highest asthma rates in the country. The last thing its residents need is more congestion-generated pollution. The poorest congressional district in the country should not be losing its parkland for the construction of parking garages. 
 

  • Legal Requirements Have Not Been Met

The State Environmental Quality Review Act (SEQRA) requires the lead agency, in this case the New York City Parks Department, to take a “hard look” at all potential environmental impacts caused by a project. However, the environmental impact statement prepared for this project, and its accompanying Uniform Land Use Review Procedure (ULURP) application, fails to even acknowledge that a massive increase in the amount of parking will lead to more fans driving to games – a major analytical and legal flaw.

In addition, it is not clear what the status is of the ULURP application – and which plan the City Council will be voting on. The City Planning Commission approved the original plan, but since that approval, the final environmental impact statement contains a new park configuration called the “New Alternative Plan,” which is said to be the plan favored by the Yankees and the City Parks Department.

And let’s not forget the federal government’s involvement. Macomb’s Dam Park received federal funding for improvements under the federal Land and Water Conservation Fund Act (LWCFA). Therefore, the federal government has to approve the conversion of the parkland to a stadium site. The LWCFA contains strong provisions to protect parkland from being converted into non-park uses. Among other things, it requires the parks to be replaced with property “of at least equal fair market value and of reasonable equivalent usefulness and location.” However, in the case of this project, much of the replacement “parkland” is going on top of parking garages, and some of it is going to be built over a mile away from its current location.

 Immediate Action is Needed:
 

  • Eliminate All New Parking Garages While Saving Parks

The Yankees and the City have simply not made the case for all this park-destroying parking capacity. The new stadium will have fewer seats.  They claim that all of the parking is needed, yet last year the Yankees set a record for American League attendance, under the stadium’s current transportation arrangements. Instead of destroying valuable parkland and publicly subsidizing parking garages, the City and State could invest in the mass transit system.
 

  • Build a Yankee Stadium Station for Metro-North

It has been project that between 4,000 and 10,000 Yankees fans would utilize a stadium Metro-North station on any single game day. A station at Yankee Stadium would provide real congestion relief and benefit the entire South Bronx, not just the Yankees. Public money going toward the parking garages could be going toward the station. The Council could pass a resolution urging Mayor Bloomberg to amend the MTA capital program to include this project.

As groups working to improve mass transit infrastructure, protect valuable parkland and open space, and improve the region’s air quality and overall environment, we would emphatically support any effort to improve this project. 

Thank you for your attention and consideration of our views.

 

Sincerely,

 

Jim Tripp
General Counsel
Environmental Defense
257 Park Avenue South, 16th Floor
New York, NY  10010

Kent Barwick
President
Municipal Art Society
457 Madison Avenue
New York, NY 10022

E.J. McAdams
Executive Director
New York City Audubon
71 West 23rd Street, Suite 1523
New York, NY  10010

Christian DiPalermo
Executive Director
New Yorkers for Parks
355 Lexington Ave., 14th Floor
New York, NY  10017

Bettina Damiani
Project Director
Good Jobs New York
11 Park Place 7th Floor
New York, NY  10007

Timothy J.W. Logan, Chair
Sierra Club NYC Group
40 Exchange Place, Suite 2010
New York, NY 10005

Gene Russianoff
Senior Attorney
NYPIRG Straphangers Campaign
3 Murray Street 3rd Floor
New York, NY  10007

Robert D. Yaro
President
Regional Plan Association
4 Irving Place, 7th Floor
New York, NY 10007

Alex Matthiessen
President
Riverkeeper, Inc.
828 South Broadway
Tarrytown, NY  10591

Jon Orcutt
Executive Director
Tri-State Transportation Campaign
350 W. 31st St., Suite 802
New York, NY 10001

Marcia Bystryn
Executive Director
New York League of Conservation Voters
29 Broadway, Suite 1100
New York, New York 10006