Background

The applicant, River Street Partners LLC, seeks a Zoning Map Amendment, Zoning Text Amendments, Large-Scale General Development Special Permits, a change to the City map with regards to portions of Metropolitan Avenue and North First Street, Waterfront Certification and Authorizations, and a Landfill action to facilitate a new mixed-use development with approximately 1,050 residential units including 263 affordable units, commercial, community facility space, and waterfront public access areas in Williamsburg, Community District 1, Brooklyn.

RPA Supports River Ring

RPA fully supports the proposed River Ring development and the requested land use actions. We are particularly enthusiastic about the associated resiliency measures and innovative water management initiatives that are part of this project.

As a highly developed, dense waterfront city with 520 miles of shoreline, New York City is centered directly in the crosshairs of the climate crisis. In addition to the other climate impacts of heat and increased precipitation, the slow, steady, and accelerating rise of sea levels threatens to permanently inundate neighborhoods and infrastructure, while deepening the reach and destruction of more frequent and intense coastal storms. The COVID pandemic also vividly demonstrated the importance and benefits of having access to quality open space. But We also have a deficit of open space, only 66 percent of New Yorkers are within a five-minute walk to a park and Community District 1 in Brooklyn has one of the lowest amounts of parkland per capita within the city.

Faced with the worsening impacts of climate change, New York City must make critical decisions around existing and future development in flood hazard areas if it is to continue to thrive while safeguarding its residents. At the same time, there is an urgent need to address the lack of urban parks.

In RPA’s own Fourth Regional Plan, we called for a combination of resiliency strategies – including zoning changes, and investments in engineered and nature-based solutions – to adequately adapt to our changing coastline and provide access to new open space. In this regard the River Ring development could serve as a regional model. This project will help set new resiliency standards for future development projects in the city and beyond.

Proposed Resiliency Measures

With its novel shoreline design that includes a soft edge with nature-based features, River Ring could serve as a new regional model for rethinking the urban edge for greater resilience and waterfront accessibility.

The project will link the existing waterfront parks and esplanades along the East River shoreline in Brooklyn. The creation of a park at River Ring will enhance access for active and passive recreation activities for communities in North Brooklyn. The project would achieve this by connecting a string of public parks and open space that stretches from the Navy Yard to Newtown Creek. The proposal will also enhance the resiliency of these neighborhoods by reducing the impacts from storm surge. By increasing the linear distance of the shoreline, the waterfront park and protective cove will offer multiple touchpoints for dissipating energy and attenuating wave action.

The Draft Environmental Impact Statement (DEIS) concludes that the breakwaters and groin would reduce the energy of crashing waves on the shoreline, making flood waves break away from the shoreline. As a result, wave heights inside the protected area will be reduced to one foot or less along the shoreline. This will reduce the potential for shoreline erosion while also providing a partially enclosed, protected aquatic habitat. These features would further protect the public waterfront open space and upland residential buildings, including beyond the Proposed Development Site. Additionally, the Proposed Development would comply with applicable New York City Building Codes and FEMA requirements and would incorporate resiliency measures accounting for projected future sea-level rise. The Proposed Development would not impede floodwaters or raise the base flood elevation (BFE).

The Proposal is Aligned with Public Policy

The Proposed Actions would also promote the policies outlined in the New York City Waterfront Revitalization Program (WRP), facilitating new residential, commercial, and community facility development in an appropriate waterfront location and substantially improving waterfront access.

The proposal minimizes losses from flooding and erosion by employing non-structural and structural management measures. The Proposed Development would not impede floodwaters or raise the base flood elevation. As the Development Site is located within a 100-year flood zone, the development has been designed to incorporate flood mitigation measures with wet and dry floodproofing strategies. Entrances to the buildings, the parking garage, and all loading areas would utilize either wet or dry floodproofing measures in compliance with ​“Appendix G” of the New York City Building Code, ASCE 24, and FEMA guidelines. The residential uses at the ground floor of the building would be raised out of the flood zone to an elevation of approximately 12.1 feet above sea level, in compliance with ASCE 24. The non-residential uses at the ground floor of the building would utilize dry floodproofing measures in compliance with ASCE 24. In areas utilizing the wet floodproofing method, Mechanical equipment, electrical rooms, gas meter, water meter and pump rooms would be located above the DFE (design flood elevation) in compliance with ASCE 24-14. In the areas utilizing dry floodproofing measures, utility lines or systems will be protected by the dry floodproofing. Accordingly, the Proposed Development would not result in significant adverse floodplain impacts, and would promote the goals of the WRP.

The proposal integrates consideration of the latest New York City projections on climate change and sea-level rise. The elevation of the lowest ground floor of the Proposed Development’s two buildings, the lowest cellar level for community facility space, and cellar parking level are expected to be below the 2020 1 percent annual chance floodplain. If these areas were to fall below the elevation of the current 1 percent annual chance floodplain, it could result in a loss of building services, damage to property and cars, loss of inventory, or potentially increased flood insurance costs. However, the NPCC recommends that these projections not be used to judge site-specific risks as they are subject to change. Furthermore, the second floor and above (minimum elevation of 31’-9”) would be located well above the current and future 1 percent annual chance floodplain under high projections. Similarly, the lowest level of mechanical equipment is to be located on the 25th floor (287 feet in elevation - NAVD88), well above the current and future 1 percent annual chance floodplain under high projections.

The Proposed Development would be designed and constructed in accordance with all applicable state and city flooding and erosion regulations, including New York City Administrative Code, Title 28, Section 104.9 (“Coastal Zones and Water-Sensitive Inland Zones”). All new vulnerable or critical features would be protected through future adaptive actions that would incorporate flood damage reduction elements.

Additional Considerations

Several ideas have been proposed throughout the public review process, in particular two mentioned in the resolution of the Borough President’s Office should be further considered.

There is a general need to improve eligibility and participation in the affordable housing lottery process. Local groups in the area have capacity to increase participation. We agree that Northern Brooklyn local nonprofits should serve as the affordable housing administrator and/or marketing agent to promote lottery readiness. In addition, the selection process could be modified to factor housing cost burden. By incorporating housing cost burden as part of the eligibility criteria for households in the lowest income brackets, the development would maximize opportunities to secure affordable housing for those in greater needs.

Advancing the completion of Bushwick Inlet Park is very much in alignment with the goal of creating a more continuous accessible waterfront for northern Brooklyn. As such there is a tangible opportunity to help complete Bushwick Inlet Park in exchange for the land resulting from demapping portions of Metropolitan Avenue and North First Street (part of the proposed actions). This city owned land would provide 190,728 sq. ft. of development rights (at 7.2 FAR). It seems reasonable to transfer that land in exchange of the applicant depositing the proceeds of fair market value to NYC Parks and the city committing to complete Bushwick Inlet Park.

The feasibility of these considerations needs to be validated. We believe that the City Council can play an important role in facilitating discussions between the applicant and various city agencies, including but not limited to the Department of Housing Preservation and Development, Department of Parks and Recreation, and Department of Citywide Administrative Services.

Conclusion

We need to see more of this kind of innovation and forward-thinking along our urban coastlines. River Ring will serve as a regional model for rethinking resilience and waterfront access. This project will set new standards for future development projects in the city and beyond. RPA encourages the City Council to support and approve the requested actions that would facilitate this development.

Thank you for your time and consideration of this proposal.