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
TRI-STATE TRANSPORTATION CAMPAIGN
March 22, 2006
Re: Yankee Stadium ULURP Application
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:
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
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.
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 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.
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.
Action is Needed:
Robert D. Yaro