Letter to Mayor's Office of Sustainability Regarding the DEIS for Citywide Ferry Service

1. CEQR No. 15DME009Y
Page 1 of 4
June 6, 2016
Denise Pisani
Senior Project Manager
Mayor’s Office of Sustainability
253 Broadway, 7th Floor
New York, NY 10007
Dear Ms. Pisani,
I write in regards to CEQR No. 15DME009Y in order to submit comments on the Draft
Environmental Impact Statement (DEIS) for the Citywide Ferry Service (CFS) set to launch
three routes (Rockaway, South Brooklyn and Astoria) in Spring/Summer 2017 and the remaining
two routes (Lower East Side and Soundview) in Spring/Summer 2018.
First and foremost, I agree that CFS has the potential of being a transformative expansion of
multi-modal transportation options in our city. Many of the initiatives in Mayor de Blasio’s
OneNYC plan seek to build a more sustainable and equitable city by focusing on how we move
8.4 million New Yorkers, and growing, around our five boroughs: from getting them where they
live, to where they work and where they recreate. The Administration recognized early on the
potential for commuter ferry service to address this focus. As a city founded in the South Street
Seaport because of its coastal identity, New York has a long history of embracing ferry service.
This history begins with the launch of the first ferry during Dutch occupation in 1647 and
continues today with the approximately 21 different ferry routes currently serving the NY-NJ
Metro region. There is a strong precedent of New York City’s reliance on the “blue way” for
assisting with the transportation of goods and people.
Ferries are proven to have various socio-economic impacts that range from direct benefits
experienced by the user of the service to emergency preparedness and continuity plans in case of
a disaster. Studies by the Port Authority and the Economic Development Corporation (EDC)
concur that an expanded ferry service would fuel greater efficiencies and synergistic
opportunities with existing public transit systems. A more robust complimentary ferry network
could facilitate new trip planning connections, reduce travel time and offer an alternative to
overcrowding at strategic passenger chokepoints.

2. CEQR No. 15DME009Y
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Mayor de Blasio’s plans to expand the city’s ferry service across the five boroughs—announced
in his 2015 State of the City address—will include new stops at Grand Street, 23rd Street, and
34th Street within the Central Business District on Manhattan’s East Side. I am supportive of
these expansion plans, but would encourage us to do even more. For instance, we should work to
create new routes along Manhattan’s west side, which is being ignored under current plans for
expansion. Additionally, the current plan’s lack of a provision to allow commuters free transfer
from ferries to subway and bus lines could easily discourage use, and should be remedied.
Lastly, our waterways can and should provide a welcome reprieve during the upcoming repairs
to the L-train, scheduled to begin in 2019. A free, direct ferry route connecting Williamsburg to
Manhattan’s East Side should be created for the duration of L-train repairs.
But as you would expect with a project of this scale and complexity, the public is concerned
about any adverse effects created from this new activity. One way to signal the seriousness of
your commitment to analysis and mitigation would be to go beyond the minimum analysis and
disclosure required by City Environmental Quality Review (CEQR). Additional environmental
and public health impact assessments should be done, if not as a component of the formal review
document then as a parallel assessment and listed as an appendix to the final environmental
impact statement (FEIS). The additional assessments could add more substance to issues such as
ferry infrastructure’s ecological impact on the adjacent lots to the landings, both above and
below the waterline, additional pedestrian and bicycle traffic upland of the landings, the
coordination of increased ferry services with other water-borne activities, human-powered or
otherwise, along these proposed routes, and impacts of air quality and noise.
Reiterating the points of the joint-elected officials’ letter dated December 2015 to Mayor de
Blasio regarding CFS, the pillars of the service model will need to be well-constructed and boast
efficiency, transparency, reliability and cost-effectiveness. A qualitative approach to community
engagement on these questions can help develop a series of benchmarks that can guide ferry
operations to hit the aforementioned service model.
As for the CEQR chapters themselves, though conversations are progressing with the Landmarks
Preservation Commission regarding the potential impacts on archaeological and architectural
resources in the affected areas, the absence of a final design leaves unanswered prior questions
my office has raised about the potential impact on increased wave and wake condition on historic
vessels along the East River. This concern should be thoroughly addressed in the final
environmental review.
Regarding issues related to Land Use, Zoning, and Public Policy, there is an outstanding
question of whether implementation of this plan will put at risk an important cultural and
educational anchor in Lower Manhattan, the South Street Seaport Museum. The Museum is the
keeper of our maritime history and of the historical identity of the City, State and National
Landmark District. In a March 2016 memo from NY Water Taxi it was stated that the CFS plan
will force them to shut down their service, thus presenting a major financial risk to the Museum.

3. CEQR No. 15DME009Y
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The Museum is currently generating close to $600,000 annually in revenue from the lease that
New York Water Taxi has on Pier 16, and the Museum informed my office that they were close
to finalizing a new lease that would generate $1 million annually. This would be an unacceptable
loss of revenue to the Museum, especially since, despite its stature, the Museum is expected to
continue paying rent and utilities on spaces it currently controls. Any final plan would need to
mitigate this city-generated adverse impact for the Museum.
In the DEIS, EDC acknowledged that ferry engines would result in significant adverse impacts to
air quality, particularly higher than recommended 1-hour levels of Nitrogen dioxide (NO2) per
the standards set by the National Ambient Air Quality Standard (NAAQS). Furthermore the
analysis states that these effects could not be mitigated at the present time. Despite a
commitment to use the most advanced clean technology available for fleet operations as newer
models become available, the FEIS should explore mitigation alternatives that discuss the
potential for offsets in other contributors’ emissions. Other negative contributors in the affected
areas could be approached about reducing their own NO2. In addition, both EDC and the
operator should be required to provide to the public a joint yearly assessment on the state of their
fleet. This assessment should include an emphasis on what efforts are being made to reach
neutral impact on 1-hour NAAQS readings and outfitting efforts to employ higher performing
green engine technology.
Thinking beyond the environmental review to implementation, it is important that CFS planning
be inclusive. It is important that we all hear more specifics about your community engagement
strategy for crafting the Standard Operating Procedures (SOPs). This document is important to
ensuring ferry operations are safe for recreational users of nearby waters and design elements do
not diminish waterfront view corridors. We expect that a process that allows affected
communities and knowledgeable contributors an opportunity to continue their collaboration with
your planning team through Phase 1 and Phase 2 of the route expansions.
In summary, I remain supportive of CFS however before we can be confident that it will be
successful and that the impacted communities are not adversely affected I urge you to consider
the following recommendations:
 Include supplementary impact assessments initiated concurrently with the finalizing of
the EIS,
 Include approaches for shielding the South Street Seaport Museum from any financial
risk as a result of this initiative,
 Expand your study to include the possibility of new routes along Manhattan’s west side,
 Provide additional analysis on the impact of increased wave and wake condition on
historic vessels along the East River,
 Study alternative strategies to tackling the problem of higher NO2 emissions in areas
where there is no migration options currently proposed, and

4. CEQR No. 15DME009Y
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 Include specific details for engaging community feedback when constructing the CFS’s
Standard Operating Procedures.
Our office looks forward to joining you in listening to and reflecting on the public feedback on
the DEIS. We hope these comments will contribute to New Yorkers being delivered the most
efficient, reliable and sustainable ferry service possible.
Sincerely,
Gale A. Brewer