GNCJ Comment Summary on the Draft Scope of Work for the Proposed Gowanus Neighborhood Rezoning

Introduction

The Gowanus Neighborhood Coalition for Justice is a racially and socioeconomically diverse coalition made up of groups focused on equity, inclusion, economic and environmental sustainability and justice. Our members include public housing residents, seniors, industrial business advocates, local community-based organizations, faith-based groups, and environmental advocates (see Appendix A for a list of members).

In March 2017, GNCJ announced our coalition’s detailed principles platform (Appendix B) and released Survive and Thrive: Towards a Justice-Focused Gowanus Neighborhood Plan, a report that sought to elevate the voices of our community that have not yet been heard in the City’s planning
process, and makes the case for a community plan based on principles of social, economic, environmental and racial justice.

We believe a just neighborhood rezoning must incorporate the following principles:

  1. Advance Racial & Economic Justice
  2. Respect, Protect & Connect Public Housing & its Residents
  3. Create Affordable Housing & Protect Tenants From Displacement
  4. Promote Environmental Justice
  5. Recognize & Celebrate the Culture & Community of Longtime Residents
  6. Protect Local Businesses & Industry Where We Shop & Work

Since our launch, GNCJ has participated in the Department of City Planning’s (DCP) “community engagement” process including the very time intensive working groups that occurred in the Spring of 2017 and subsequent community meetings since then. Despite our engagement and participation in the planning process, we have failed to see most of our priorities included in DCP’s framework and draft scope of work. The City actively excludes NYCHA and its residents by refusing to connect the preservation strategies in NYCHA 2.0 to this neighborhood rezoning.
Specifically, the following land use and zoning demands must be incorporated into the final scope of work to begin to adequately address our community’s most pressing needs:

  1. The City must ensure that public housing residents benefit from the rezoning. It must address the capital funding gap in the three local New York City Housing Authority (NYCHA) developments:
    Gowanus Houses, Wyckoff Gardens and Warren Street Houses as well as create increased opportunity for public housing residents. To be clear, the City must address the capital funding gap that will exist locally in Gowanus for NYCHA developments even after planned but not yet implemented infill at Wyckoff Gardens and PACT/RAD conversion at Warren Street Houses.
    To advance this goal, the Scope of Work should study and analyze the social and environmental impact of public value recovery tools. These could include:
    a. Transfer of development rights (TDR) program that would allow NYCHA to sell off-campus air rights from the three Gowanus public housing developments to private developers to create a revenue stream for local NYCHA campuses.
    b. Deep affordability Mandatory Inclusionary Housing options that would create housing at income levels that the majority of public housing residents can afford.
    c. Additional opportunities created by expanding the study area to include the aforementioned public housing developments.
    Improving NYCHA housing fundamentally aligns with the Mayor’s goal to preserve 180,000 units of affordable housing citywide by 2026. NYCHA residents make up 33% of renters in Gowanus and are longtime members of the community. Many live in substandard housing conditions that can, and should be addressed as part of this rezoning.

2.The City must strengthen the “Gowanus Mix” proposal by requiring industrial / art space instead of making it “optional” and must ensure enforcement through community oversight in the form
of a nonprofit, mission-driven steward.

The Gowanus Mix falls short of preserving the unique character and mix of uses in the neighborhood. Namely, it fails to truly provide mandatory mixed-use to ensure quality job generating uses such as light industry, manufacturing, and ensure that maker/artist spaces can stay in Gowanus. The current rezoning proposal will result in significant loss of industry/manufacturing uses – approximately 579,000 sf of space according to the DSOW. This will result in a loss of good paying jobs for workers without formal education, as the retail and other commercial uses that will
replace manufacturing do not offer the same economic mobility opportunities for workers in that sector. The City must strengthen the “Gowanus Mix” by making it mandatory throughout the entire
Gowanus Special District, including anywhere it is currently being proposed, all the Mx districts and the “preserved” M1-4 zoning districts.

3. The City must study the impacts of the neighborhood rezoning on the adjacent Industrial Business Zone (IBZ)
As the industrial areas outside the IBZ change to explicitly allow a wider range of uses, industries operating within the IBZ are bound to be impacted, especially through increasing land values and speculative real estate pressure. Many high-demand industrial sectors that are intimately tied to
and serve the local economy, are prevalent in Gowanus. Through a public process, IBZs were established by the Industrial Business Zone Boundary Commission “to protect existing manufacturing districts and encourage industrial growth citywide.” Therefore, industrial businesses in the IBZ comprise “a category of businesses that are subject to regulations to preserve, enhance, or otherwise protect it”.
GNCJ along with many neighborhood and city-wide advocates during this engagement process and the preceding Bridging Gowanus process have repeatedly called for implementation of use restrictions in the IBZ before any rezoning occurs. To fully inform the City’s current Gowanus IBZ
Vision Process and future plan, and to adhere to current citywide industrial policies, the EIS must study the impacts of this rezoning on the IBZ, including but not restricted to: direct or indirect business displacement due to cost of business and operational impacts; effects on industry
including on mobility; water and sewer infrastructure; and neighborhood character.

4. The City must expand the proposed Gowanus Special Mixed-Use District to an Environmental Special District that addresses the unique environmental conditions in Gowanus.
Gowanus is home to New York City’s first U.S. Environmental Protection Agency (EPA) Superfund site, the Gowanus Canal, three former Manufactured Gas Plant (MGP) sites, as well as a number of
other brownfield sites. Located in a former salt marsh, neighborhood residents and businesses are plagued by regular flooding and combined sewage overflow, higher rates of urban heat island effect due to a number of factors including a lack of urban tree canopy and open space. The City of
New York has a unique opportunity to establish New York City’s first ‘Eco-District’ or Environmental Special District, to advance climate adaptation and mitigation measures and equity as highlighted in OneNYC: The Plan for a Strong and Just City. See Appendix C for Environmental Special District
Demands. Components of the Environmental Special District must include goals that result in:
● Interagency coordination to ensure that the numerous neighborhood remediation and construction projects, in a relatively small area with limited east-west travel routes due to the Canal and a high concentration of vulnerable residents, manage and minimize impact on both the residential and business community.
● Development and implementation of an Equitable, Community-Driven Emergency Preparedness Plan for Gowanus
● Investment in health and social resilience through the development of community health and racial equity assessments and implementation of recommendations associated with those assessments.
● No net increase in combined sewage overflow resulting from additional development.
● Investment and policies to promote an equitable and vibrant public realm, including esplanades, parks and streetscapes.
● No net increase in carbon intensity and electricity demand.

While we understand that the draft scope of work is a document that specifically outlines proposed zoning and land use changes, the lived experiences of our community require that we address neighborhood priorities and issues holistically in this planning process.

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