THE HKNA Plan

Introduction

This document describes a plan for the Hell's Kitchen / Hudson Yards area devised by the Hell's Kitchen Neighborhood Association (HKNA). The HKNA plan was reviewed in the Hudson Yards EIS as a full, comprehensive alternative that satisfies the same city-wide goals as the Hudson Yards plan proposed by the City, although it does so in a much different, and better, way.¹

The HKNA plan was originally submitted to the Department of City Planning (DCP) in June, 2003. This updated version includes the evolution in HKNA's thinking over the past year. The document first describes the origin of the HKNA plan and then the key elements of the plan. In subsequent sections the document describes the proposed zoning, a discussion of a proposed open space system and required mapping, and a transportation plan. Finally the document presents a financial plan (to come) and a strategy to implement the HKNA Plan by modifying DCP's Hudson Yards proposal.

Background and HKNA Goals

The Hell's Kitchen Neighborhood Association (HKNA) is a nine-year-old community organization that addresses concerns about open space, traffic, air quality, the built environment, and affordable housing while striving to enrich the unique urban character in Hell's Kitchen South — 34th to 42nd Street, west of Eighth Avenue. Community participation is central to HKNA's mission and projects. HKNA has organized several projects in the neighborhood including a community garden and dog run on land leased from the Port Authority, and a painting project to humanize the blank walls of Port Authority ramps and parking areas along 39th Street.

Since 1995, HKNA has improved the urban environment through projects, both large and small. Over fifty trees have been planted throughout the area, contributed by HKNA and by the New York City Parks Department. Scores children and adults have been involved in HKNA "Adopt-A-Tree" program and summertime "Tree-Care Saturdays."

In 1995, HKNA's Urban Planning Committee investigated whether marginally used Port Authority properties could be converted to public spaces. Following the study, HKNA successfully negotiated a lease for three Port Authority-owned properties. As a result, the Hell's Kitchen Community Garden, Dog Run, and Bird Park opened on May 2, 1998.

In 2002 HKNA, Publicolor, and the Port Authority collaborated on project to paint the 900-foot-long walls and steel bridges adjacent to the Port Authority's bus ramps on West 39th Street between Ninth and Tenth avenues. The "Hell's Kitchen Painted Promenade" was painted by Hell's Kitchen residents and Publicolor's Paint Club.

HKNA Urban Planning Process

Aware of the growing interest in developing the far West Side, several years ago HKNA anticipated the need for a comprehensive plan for the area. HKNA, in collaboration with the Design Trust for Public Space, began a three-year urban planning process in 1998 that brought together the local community, property owners, developers, and planning professionals. HKNA sponsored local envisioning sessions and informational exhibits leading up to a community planning conference in June, 1999. The conference was followed by public symposia, exhibitions, and invited design proposals generated by eighteen multidisciplinary teams.

This multidisciplinary planning process culminated in the publication last year of "Hell's Kitchen South: Developing Strategies," a 160-page book that outlines community goals and documents various design options for future physical development of the Hell's Kitchen South neighborhood.

The Hell's Kitchen Flea Market, mentioned in "Hell's Kitchen South Developing Strategies," recently opened on West 39th Street between Ninth and Tenth avenues, creating a local and regional destination and reinforcing the community's goal to make West 39th Street a public throughway to the Hudson River.

An extension of "Developing Strategies," the HKNA plan described in this document is HKNA's response to the New York City Department of City Planning's "Hudson Yards Master Plan" for Manhattan's West Side between 28th and 42nd streets.

Intention of the HKNA plan

The HKNA plan was developed to ensure that the Hudson Yards rezoning is aligned with the community's goals, while meeting the City's goals as well. Community goals include expanding the residential core between Ninth and Tenth avenues north of 35th Street, with a substantial proportion of affordable housing; creating a new system of open spaces, particularly in mid-block locations, and enhancing waterfront access; confining large-scale development largely to the super blocks south of 35th Street; and minimizing environmental impacts of new development, particularly traffic impacts.

The plan was developed in collaboration with Manhattan Community Board 4 and the Hell's Kitchen / Hudson Yards Alliance, a coalition composed of numerous individual residents of the West Side and of the following organizations and representatives :

Clinton Association for a Renewed Environment Clinton Housing Association Clinton Housing Development Company Hartley House Hell's Kitchen Neighborhood Association Housing Conservation Coordinators Project Renewal West 27th Street Block Association West 44th Better Block Association West 47th/48th Street Block Association

Christine Quinn, City Council Member Gale Brewer, City Council Member Richard Gottfried, State Assembly Member Scott Stringer, State Assembly Member Thomas Duane, State Senator Liz Krueger, State Senator Eric Schneiderman, State Senator Jerrold Nadler, United States Representative Chelsea Reform Democratic Club Council of Chelsea Block Associations

Designed with previous Community Board resolutions in mind, the HKNA plan was endorsed by Manhattan Community Board 4 on December 3, 2003.²

Description of HKNA plan

Predicated on the community's concerns about traffic, air quality, open space, appropriate scale of development, and affordable housing, the HKNA plan balances the development goals of the local community with those of the City of New York.

Javits Center Expansion

The key to the HKNA plan is a southward expansion of the Javits Convention Center over the rail yards between Eleventh and Twelfth avenues. In addition to the convention center, the plan provides for commercial development on the Javits Center expansion site. Towers in the four corners of the site with lower commercial structures between them (except on the western side facing the Hudson River) would amount to about 6 million square feet. The flat roof of the new Javits Center expansion would be become a public park and community recreation area directly linked to Hudson River Park. A successful rooftop park is a main feature of the Moscone Center in San Francisco and of the Toronto Convention Centre.

The Javits Center would also be expanded north to 39th Street, completing the existing building. HKNA's proposed Javits Center space distribution, shown in Table 1, would provide the same total space as expanding the Javits Center north to 42nd Street. While some additional space would be contiguous to existing space, a desire expressed by the Javits Center management, most new space would be in a separate building, connected to the existing building by extending the existing pedestrian concourse under 34th Street. Dividing the space into separate buildings is advantageous in attracting medium-sized trade shows, which are the majority, while it does not seriously impede the ability to attract the largest shows.³ In addition, this configuration would provide much more premium exhibition space — nearly 1,000,000 square feet with a ceiling height of 35 feet and 90-foot column spacing.

Table 1. HKNA's Proposal for Expansion of the Javits Center (sq. ft.)

	Current	South Expansion	North Expansion	Total
Exhibit Space*	760,000	450,000	162,000	1,372,000
Meeting Space	28,000	240,500	131,500	400,000
Ballroom Space*	23,000	92,000		115,000
TOTAL*	788,000	782,500	293,500	1,864,000

* For the existing building the Galleria and River Pavilion Ballroom are included as exhibit space; the TOTAL includes the River Pavilion Ballroom only once.

The orientation of the Javits Center southward expansion would put the entrance along 34th Street and the loading docks along 30th Street. Taxi and bus drop-off would be located at existing grade in the block between 33rd and 34th streets. Escalators would connect the drop-off area, at level +5, to a lobby above, at level +32. The new lobby, with a grand entrance at the corner of 34th Street and Eleventh Avenue, would be at the same level as the Eleventh Avenue entrance to the existing building. The existing and new entrances could be connected by a pedestrian overpass crossing 34th Street, as well as at grade. This orientation would allow for retail stores along Eleventh Avenue and would provide sweeping views to the Hudson River from a pre-function lounge on the west side of the building, which could also be used for banquets, registration, or additional exhibit space. Floor plans for the expanded Javits Center are shown in Figure 1.

With an on-site hotel, over 240,000 square feet of meeting rooms, and a large ballroom, the southern expansion would be positioned to attract professional and trade conventions. The ballroom and meeting rooms would be located on the perimeter of the Javits Center rooftop park, an arrangement that would give the ballroom and meeting rooms access to the rooftop park and to views of the Hudson River. This new facility is exactly what the convention industry requires, as Chicago's McCormick Place convention center, New York's major competitor, has discovered. With a new addition conforming almost exactly to our proposed space distribution now under construction, McCormick Place is already signing up the type of conventions that the Javits Center seeks.⁴

In addition, the block between 29th and 30th streets, just south of the new loading docks, would be used for truck marshalling. A multi-level marshalling facility would also allow space for relocating the tow pound from Pier 76, and sanitation trucks currently occupying the Gansevoort peninsula. The roof of the multi-level facility would be used for sports fields, reserving the new Javits Center rooftop park for more passive uses.

Commercial Corridor

Given the large amount of commercial space to be developed along with the southward Javits Center expansion, the HKNA plan envisions the expansion of the Midtown Central Business District occurring primarily along an east-west corridor between 30th and 35th streets.

On the eastern rail yard site, an eight-acre, multi-level urban public open space, including gardens, cafes, and other public amenities, will form the commercial center of a new mixed-use district with links in all four cardinal directions — east to the new Penn Station and 34th Street retail corridor, to a series of open spaces proceeding northward through Hell's Kitchen, west to the Javits Center rooftop park, and south to the future High-Line promenade through Chelsea. The commercial center would also contain space for cultural activities.

The plan makes possible a pedestrian connection from Penn Station to the Hudson River, linking a number of public open spaces along a reintroduced 32nd Street Pedestrian Way. The plan also provides at-grade access from all directions to the central open space, allowing it to be fully functional while bridge connections to the High Line and Penn Station are added in phases.

32nd Street Pedestrian Way

At the center of the 30th to 35th Street commercial corridor, the HKNA plan envisions a 32nd Street Pedestrian Way. The Pedestrian Way, lined with stores and cafes, would lead from the new Penn Station to the commercial core on the eastern rail yard site, and continue to the Javits Center rooftop park and the Hudson River.

The 32nd Street Pedestrian Way would pass through a new commercial complex behind the new Penn Station, traverse the Schulweis/Brookfield site between Ninth and Dyer avenues, cross over both Dyer and Tenth avenues via the third floor of the West Yards building, and enter the central open space on the eastern rail yard site. From there a set of stairs, ramps, and an elevator would lead to the Javits Center rooftop park and the Hudson River. If Madison Square Garden is relocated to the Schulweis/Brookfield site, the arena would be elevated to allow the Pedestrian Way to pass underneath.

Blocks North of the Javits Center

The two blocks north of the Javits Center, from 39th to 41st streets, would have a mixture of residential use on the Twelfth Avenue, river-front side and office use on the Eleventh Avenue side, similar to the pattern currently envisioned for the block between 41st and 42nd streets. The HKNA plan would preserve critical access to the Hudson River, particularly an easy 39th Street at-grade, pedestrian link between the residential community and the waterfront and between the future 39th Street ferry terminal and office uses on Eleventh Avenue. In addition, the HKNA plan would avoid extending the wall of loading docks facing the Hudson River at the back of the Javits Center by another five hundred feet between 39th and 41st streets, which would occur if the Javits Center is extended northward rather than primarily southward, as HKNA proposes.

An option for additional convention space in the blocks between 39th and 41st streets is discussed in the next section. Since the HKNA plan does not require relocating the MTA bus garage in order to expand the Javits Center to the full size required, the relocation can be deferred to reduce up-front costs.

HKNA-1: Space Distribution Based on EDC Assumptions

The Hudson Yards plan and the HKNA plan are both designed to accommodate 28 million square feet of office space and at least 12.6 million square feet of residential space, based on projections of the New York City Economic Development Corporation. Another 2.4 million square feet is divided between retail and hotels. To accommodate the 28 million square feet of office space, the HKNA plan provides for lower density commercial areas along Eleventh Avenue and higher density sites surrounding the Port Authority Bus Terminal, in addition to a major commercial corridor between 30th and 35th streets. We assume, along with the City, that office development will occur first along the 30th to 35th street corridor and on sites surrounding the bus terminal before moving to Eleventh Avenue.⁵ A diagram of the original plan, HKNA-1, is shown in Figure 2.

While the HKNA plan can accommodate the same gross amount of office and commercial space as the DCP plan, and somewhat more residential space, it does so in a much different way. In the DCP plan Eleventh Avenue would be a major office center; to facilitate this the plan allows up to 2.6 million square feet of development rights to be transferred from the eastern rail yard site to sites north of 35th Street. With the bulk transferred, there would be 3.3 million square feet more office development north of 35th Street than south.⁶

The HKNA plan, on the other hand, concentrates approximately 18 million square feet of office space in the 30th to 35th street corridor — almost 10 million square feet more office development would occur south of 35th Street than north. In fact, 70 percent of office development would take place south of 35th Street. This distribution allows lower-scale development, including affordable housing, in Hell's Kitchen north of 35th Street and in Chelsea south of 30th Street

HKNA-2: More Residential and Less Commercial Density

Along with others who have looked at the issue, HKNA questions the need for 28 million square feet of office space on the West Side.⁷ We much prefer additional housing, and have created a second version of the plan, HKNA-2, that would shift the balance toward less office and more residential development.

Even if the real estate market would prefer development of residential buildings, the Hudson Yards plan proposes to "guarantee" that office space is built by, for the first time, forbidding residential development in commercial zones. Zoning, however, cannot guarantee that anything is actually built. If the market is not prepared to build office space, under these circumstances nothing will be built. That is just what happened after the City rezoned Eleventh Avenue for commercial uses in 1989, and the failure of that previous rezoning is, in part, what led to the current Hudson Yards plan. Furthermore, there is substantial doubt, even among the real estate community, that major office development can be induced on Eleventh Avenue as an island disconnected from the Midtown office concentration east of Eighth Avenue.

We propose that restrictions to "guarantee" predominantly commercial use on Eleventh Avenue be removed. In that case, the market would determine the mix of office and residential uses on Eleventh Avenue (between 35th and 41st streets). We would also lift any such restriction on the two towers on the western rail yards site that front on Twelfth Avenue. In addition, we assume the lot on the corner of 40th Street and Tenth Avenue would be developed as a residential building (DCP lot 1050a).

The net result is that Eleventh Avenue, and the Twelfth Avenue towers, would likely be developed as a primarily residential, mixed-use area. The overall balance of office to residential space would shift from 2.3 to 1 in favor of office to approximately equal amounts of office and residential space. In this alternative we would expect that Eleventh Avenue sites closer to 42nd Street would be developed for largely residential uses, while sites two Eleventh Avenue sites between 35th and 37th streets would be developed for office use. A diagram of the new plan, HKNA-2, is shown in Figure 3.

We believe that the HKNA-2 alternative would provide a more vital, more realistic, more sustainable, and much less expensive plan that nevertheless contains a sufficient amount of office space — 20 million square feet — to satisfy the city's needs.

Other Elements of the HKNA plan

The Hell's Kitchen core residential area, between Ninth and Tenth avenues from 33rd to 41st streets, would be reserved primarily for infill housing, although cultural and other uses would be permitted. Preservation of existing residential buildings as well as a comprehensive open space plan are essential for this area and are discussed below. Plans for transportation, zoning, and open space are also described in the following sections.

Planning Options

The Javits Convention Center currently dominates and cuts off the waterfront for five blocks north of 35th Street. The Hudson Yards plan would extend the Javits Center north, cutting off another three streets that now link the community to the waterfront. The HKNA plan, on the other hand, would expand the Javits Center primarily to the south, preserving waterfront access. The plan can also accommodate an additional expansion of the Javits Center while preserving waterfront access on 39th and 41st streets. Another option contemplates relocating the Javits Center to Long Island City in the future to better accommodate expansion, thereby opening up the Hell's Kitchen waterfront from 34th to 41st streets to additional residential development.

Future Expansion of the Javits Convention Center

Providing for future expansion has always been one of the main problems bedeviling New York City's convention and exhibition center. In the 1970's the difficulty of expanding the New York Coliseum, which was then New York's major exhibition site, led the City administration to propose a new convention center. At the urging of the City, the State Legislature approved a convention center site encompassing piers 84 and 86 in the Hudson River at 44th Street. Fortunately the convention center was never built in the Hudson River, both because a convention center at that location would have been a major imposition on the later Hudson River Park and because the site had no room for future expansion.

We are able to plan an expansion of the Javits Center today only because of the foresight of the Legislature and the local community. The community vigorously opposed the 44th Street convention center site and proposed, as a better and cheaper alternative, a site between 34th and 39th streets in the former New York Central rail yards. Ignoring that advice, the City persisted with the 44th Street site. Years later when it became clear that the 44th Street site was too expensive and even too small, the City turned to the rail-yard site, which in fact, was the only site available in Manhattan Central Business District that could accommodate not only the facility proposed, but also a future expansion. The Legislature, anticipating a later expansion, included the rail yard between 30th and 34th streets within the boundary of the Javits Center. That is the same location that the City, as shortsighted today as it has been in the past, wants to appropriate for a football stadium.

Future expansion of the Javits Center remains an important issue. If the current Husdson Yards plan goes forward, all land in the area will be fully programmed, so there will never be another Javits Center expansion (unless the Javits Center is rebuilt outside of the West Side). This means that the size of the Javits Center will forever be limited to 1.34 million square feet of exhibition space, while convention halls in other cities continue to expand. Unlike the current Javits Center plan, the HKNA plan could allow for one additional expansion.

Expanding the Javits Center to the south now, instead of building a stadium, would leave for a future decision the best use of the two blocks between 39th and 41st streets (both blocks are owned by the State). One possibility is to keep the two blocks essentially in their present use. The block between 39th and 40th streets, owned by the Javits Center Operating Corporation, could be modified for Javits Center truck marshalling; keeping the MTA's Quill bus garage in operation would save the $400 million that would otherwise be spent to relocate it. In the longer term the Quill bus garage could be relocated and both blocks could be sold for residential and commercial development. This option would enhance the emerging residential neighborhood, complement Hudson River Park, and the revenues generated would offset some of cost of public investment in the area.

Keeping the two blocks in their current use would also leave open an option for 400,000 square feet of additional exhibition space in the future, if later market studies show that a further expansion is warranted. (The recent Pricewaterhouse Coopers study only justifies an expansion to 1.34 million square feet.) Under this option, exhibition space would eventually total 1.75 million square feet, rather than be forever limited to 1.34 million square feet — and waterfront access along 39th Street could be preserved.

Relocated Convention Center and Additional Housing

To provide even an even larger expansion of the Javits Center, which might be needed in perhaps twenty or thirty years, it will be necessary to relocate the main building outside of Manhattan. The area around the Sunnyside rail yard in Long Island City, Queens, could be a viable alternate location.

The Javits Center Operating Corporation hopes to attract two distinct types of events — trade shows, the Javits Center's traditional market, and conventions, which the Javits Center has so far been unable to attract. A substantial part of the currently proposed building program — including the large amount of space devoted to meeting rooms, the large ballroom, and the subsidized convention hotel — is designed to attract conventions. Conventions need less space overall, but require an adjacent hotel and probably a location in close proximity to other hotels in midtown. Trade shows require large exhibition halls, which could probably be located farther from the concentration of midtown hotels. Boston, for example, recently constructed a larger exhibition center in South Boston at some distance from downtown, while maintaining the existing convention center in downtown Copley Square, a more suitable location for conventions and smaller trade shows.

The HKNA plan proposes a stand-alone convention-oriented facility over the rail yard between 30th and 34th streets. The new facility would have a large number of meeting rooms, a large ballroom, one or two hotels, and about 450,000 square feet of exhibition space. Added to the Javits Center, the new convention facility would provide flexible space that could host conventions and medium-sized trade shows, or large trade and public shows that require all the exhibition space at the Javits Center. If the Javits Center is later rebuilt in Long Island City, the convention facility would remain. The blocks north of 34th Street could then be devoted to residential uses and park space oriented to the Hudson River. Alternatively, the existing convention center building could be reused and reprogrammed.

Additional planning options include a Port Authority bus garage and possible reuse of the LIRR yard, if it can be relocated.

A Port Authority Bus Garage

HKNA advocates construction of a garage to house busses that currently lay over during the day in surface lots around the Port Authority Bus Terminal. DCP intended its Hudson Yards plan to include such a garage. Both DCP's proposed zoning map and DCP's "Illustrative Open Space Diagram" in the Draft Scoping Document show the garage over the Lincoln Tunnel exit plaza between 38th and 39th streets, east of Tenth Avenue. However HKNA does not favor that solution. The Lincoln Tunnel exit plaza, which is located between the existing residential community and 39th Street, the main corridor to the Hudson River, should be covered by a large green park, as described below.

HKNA has been told that a new study of possible garage sites is needed. But the Port Authority has already examined nineteen sites in a study it conducted in 1986.⁸ Aside from the Lincoln Tunnel exit plaza suggested by DCP, only two sites would be consistent with current plans for the West Side. One of those sites is the Lincoln Tunnel entrance plaza between Tenth and Eleventh avenues; the other site is the top of the Port Authority Bus Terminal. Preliminary plans were drawn up for both sites, as part of the 1986 study, along with cost estimates. The Port Authority should make a choice without further delay.

The LIRR Storage Yard

The HKNA plan would expand the Javits Center southward over a vast open structure used by the MTA for midday train storage. If the LIRR West Side storage yard could be eliminated or reduced in size, any space thus made available could be used for a future Javits Center expansion.⁹

Proposed Zoning

To effectuate the development plan described above, HKNA has devised a zoning plan, shown in Figure 4. The intent of the zoning plan is to keep building bulk between 35th and 40th streets to a moderate level, while directing more intense development to the 30th to 35th street and 42nd Street corridors.

In general, between 35th and 40th streets commercial districts would not exceed an FAR of 12, while residential districts would not exceed and FAR of 7.5 (R9 equivalent). Between 40th and 42nd streets commercial districts would generally have an FAR of 12; the northeast corner of 42nd Street and Eighth avenue would be rezoned to an FAR of 18.

In the 30th to 35th street corridor, the HKNA plan would continue a 12 FAR zone on 34th street from Eighth to Tenth avenues, while allowing 15 FAR between Tenth and Eleventh Avenues from 30th to 35th streets, and 10 FAR on the western rail yard site.

GLSD and Bulk Transfer

The HKNA plan, similar to the DCP plan, would provide for a General Large-Scale Development (GLSD) district between Tenth and Eleventh avenues, with bulk transfer permitted from the eastern rail yard site to other development sites. However, unlike the DCP plan, the GLSD district in the HKNA plan would not extend north of 35th Street. The HKNA plan would allow approximately 2.6 million square feet to be transferred from the eastern rail yard site to the blocks between 33rd and 35th streets.

Protections for Existing Residential Areas

Three existing residential areas will be subject to development pressure as a result of this plan. The vulnerable areas are 33rd to 41st streets between Ninth and Tenth avenues, 29th and 30th streets between Eighth and Ninth avenues, and areas of Clinton north of 43rd Street.

To protect the residential uses, these blocks should be zoned with an FAR that matches the bulk of existing buildings, in order to reduce incentives to demolish and rebuild. Existing buildings in the vulnerable areas have FAR's of approximately 4 to 6. The preservation area of the Special Clinton District limits FAR north of 43rd Street to 4.2. The recent Chelsea rezoning changed the 29th and 30th Street blocks to R8B, which limits FAR to 4.0. Thus two of the three vulnerable areas are protected with respect to FAR. The HKNA plan would rezone the blocks from 35th to 41st streets between Ninth and Tenth avenues (except 40th to 41st streets between Tenth and Dyer avenues) to limit FAR to 6.0 in the mid-blocks and to permit residential use. The blocks between 33rd and 35th streets, which have larger structures, would be zoned at an FAR of 10 to 12.

Second, the non-demolition and anti-harassment provisions currently in the Special Clinton District (§§96-108–110) would be included in a Special Hudson Yards District and would be applied to those same vulnerable blocks. Those provisions would also be applied to the remaining buildings on Tenth Avenue and to buildings on both sides of Ninth Avenue. Nevertheless, a higher FAR would be allowed for new construction on Tenth Avenue (7.5 FAR, or R9 equivalent).

Height Limits

Height limits on buildings are important for contextual reasons as well as to ensure that light, air, and ventilation are maintained in the area. HKNA proposes that building heights conform to the limits shown in Table 2, which was adapted from the current zoning ordinance (§23-633). In addition towers would be required in R10-equivalent districts above the maximum base height. Towers would be limited to a floor plate of 8,000 square feet, and the maximum tower width facing an avenue would be 80 feet.

Table 2. Building Heights

District	Minimum Base Height	Maximum Base Height	Maximum Building Height
R8 equivalent	60	80	105
R9 equivalent	60	95	135
R10 equivalent	100	135	350

Zoning Bonus Provisions

HKNA believes that zoning bonuses should be used to finance inclusionary housing as a first priority. A modified inclusionary housing bonus structure that would apply within the Clinton and Hudson Yards districts is described in the next section.

Parking Requirements

The Hudson Yards zoning proposal requires that new buildings include a large number of off-street parking spaces. In addition the City propose to build about 1,500 parking spaces under the Mid-block boulevard and on the eastern rail yard plaza. Together this would encourage a huge number of parking spaces — somewhere between 13,000 and 30,000 spaces — to be built in the area. This is an enormous number, considering that there are only about 140,000 off-street spaces in all of Manhattan south of 60th Street. More parking means more commuter traffic entering and leaving the area. And traffic in this area around the Lincoln Tunnel is already at the breakdown point.

The proposed parking requirement, along with construction of new public garages, would reverse a twenty-year policy originally adopted for traffic control and environmental reasons.¹⁰ Since its adoption in 1982, the current policy allows a limited number of accessory spaces in the Manhattan Central Business District south of 60th Street, with no minimum requirement. The rationale for the current parking policy is the conviction that requiring more parking spaces would simply encourage more traffic to enter the Central Business District, an undesirable result.

How undesirable is detailed in the current DGEIS, which shows that full build-out of the Hudson Yards plan would result in significant adverse traffic impacts at numerous locations during peak commuter and special event hours. At most locations, traffic engineering "improvements" such as signal timing changes and adding traffic lanes by removing on-street parking, both of which will make crossing the street more difficult and dangerous for pedestrians.

Many of the locations requiring mitigation have a high accident rate. For example, the DGEIS shows a total of 44 pedestrian and bicycle accidents, one of which was fatal, on Ninth Avenue at the 41st and 42nd Street intersections. These intersections are dangerous now and with more traffic in the future, conditions could be frightening. Programs for improving the efficiency of vehicular traffic (such as the changes in signal timing and increasing the number of traffic lanes) should not be implemented at the cost of creating more hazards for pedestrians.

As shown in the DGEIS, many vehicle trips either begin or end at parking lots and garages, confirming the notion that more parking spaces means more traffic. Although the Department of City Planning has attempted in the past to investigate the relationship between parking availability and trips to and from Manhattan, a study was never completed. We agree with the underlying assumption of the existing Midtown parking regulation, which recognizes a positive correlation between parking availability and trip generation. By requiring parking, the City is creating destinations for more cars, which, in fact, will attract more traffic.

The amount of accessory parking spaces allowed in the Hudson Yards area should be no greater than that amount currently allowed by the Zoning Resolution for developments south of 60th street. Current rules would allow up to 7,500 parking spaces,¹¹ which is more than sufficient, especially given the 25,000 parking spaces already in the area. Additional parking garages, if needed, are allowed by special permit. To ensure that parking uses do not cause the removal of sound buildings in the Hell's Kitchen Subdistrict, a special permit should be required, modeled on Section 96-111 of the Special Clinton District.

Sustainable Development

HKNA's proposed zoning will include requirements for "green" building techniques to mitigate impacts on water consumption, sewer systems, storm water drainage, solid waste and sanitation services, and energy consumption. These techniques should follow the Leadership in Energy and Environmental Design (LEED) Green Building Rating System, a voluntary, consensus-based national standard for developing high-performance, sustainable buildings. The zoning should require LEED-certified gold level for new commercial buildings and LEED-certified silver level for residential buildings.

Blocks East of Ninth Avenue

HKNA included zoning changes for the blocks east of Ninth Avenue merely to be consistent with the DCP zoning plan outside our area of main concern, and so that the overall plan meets DCP goals for new residential housing. The HKNA plan does not address zoning changes advocated by DCP for the blocks of the Garment Center between Eighth and Ninth avenues and the blocks south of Penn Station.

A substantial quantity of affordable housing is a major goal of the Hell's Kitchen Neighborhood Association. HKNA subscribes to the policy of Manhattan Community Board 4 that a minimum of 30% of all new units should be affordable at a variety of income levels. To achieve this goal, HKNA proposes a mix of programs. Assuming the 14,600 units projected for this area by the City over the next twenty years, a potential mix of programs is as follows:

• Twelve percent of all market rate housing units to be permanently affordable, using 80/20 financing or other mechanisms:

14,600 total units

12% of 14,600 units = 1,750 units

• 2 FAR housing bonus in all commercial districts (10–12 FAR)

3,169,000 square feet of bonus floor area at an average of 2.12 square feet of bonus per square foot of affordable housing = 1,567,000 square feet of affordable housing;

or 1,567 units

• Additional housing programs from HPD:

2,600 units over ten years.

Total: Approximately 6,000 units, or 300 units per year over 20 years.
          Affordable housing represents about 30% of all units.

Split of permanently affordable housing:

   50 –  80% of AMI ¹²   20% of affordable units
  80 – 125% of AMI       50% of affordable units
125 – 165% of AMI       30% of affordable units

There is precedent for mandatory affordable housing in recent Planning Commission and City Council actions on a major development project known as Riverside South (on the former Penn Central rail yard between 60th and 72nd streets). In approving Riverside South the Planning Commission required a substantial affordable housing program because "When a rezoning and authorization of large scale development has the effect of creating a new community, as is the case with this application, it is necessary and appropriate to include a component of affordable housing."¹³

The developer of Riverside South agreed to seek government affordable housing assistance for a minimum of 20% of the units. Furthermore, at the insistence of the Commission, the developer guaranteed that regardless of the availability of public subsidies, at least 12% of the 5,700 units would be affordable to low, moderate, and middle income tenants. As its report explained: "The Commission believes that a meaningful affordable housing program must include a mandatory component."¹⁴

While the Riverside South agreement is a valuable precedent, two loopholes should be corrected. First the mandatory requirement should apply for the life of the building, even after government subsidies expire. Second, a mixed income distribution in the affordable units should be a requirement, not an option.

In addition to a mandatory component, the HKNA plan would provide a substantial number of affordable units through a modified inclusionary housing bonus. Since commercial buildings create a demand for housing, it is essential that they, too, provide some of the necessary affordable units. As in the Special Clinton District, the bonus would also apply in all commercial districts to all buildings, whether commercial or residential.

Within both the Clinton and Hudson Yards special districts, the inclusionary housing bonus program would be modified to encompass a greater range of incomes and to relax unnecessary restrictions, in line with the recommendations of the Citizens Housing and Planning Council.¹⁵ Based on the current inclusionary housing bonus structure,¹⁶ the modification would result in the scale of bonuses shown in Table 3.

Table 3. Modified Inclusionary Housing Square Foot Ratios

	< 80% of AMI	80–125% of AMI	125–165% of AMI
On-site New Construction	3.7	2.8	2.1
On-site Substantial Rehab.	3.2	2.3	1.6
Off-site New Construction (Private Site)	4.0	3.1	2.4
Off-site New Construction (Public Site)	2.5	1.6	0.9
Off-site Substantial Rehab. (Private Site)	3.7	2.8	2.1
Off-site Substantial Rehab. (Public Site)	2.2	1.3	0.6
Preservation	2.0	1.1	0.4

For each square foot of affordable housing provided by the method in the first column, the floor area of the new development may be increased by the amount in the second, third, or fourth columns.

It may also be desirable to apply the inclusionary housing bonus to all areas being up-zoned. The Hudson Yards zoning proposal contains the most extensive use of zoning bonuses ever. And for the first time the Department of City Planning proposes that bonuses start at an FAR less than 10 — in the 34th Street Corridor subdistrict between Eighth and Tenth avenues, bonuses for residential buildings would start at an FAR of 7.5. This proposal suggests that bonuses, possibly for inclusionary housing, could start at an FAR of 7.5 for commercial buildings, as well, and that such a bonus structure could be extended to other subdistricts of the Special Hudson Yards District. Since the current zoning in most areas west of Ninth Avenue has an FAR of 5, starting the bonus structure at an FAR of 7.5 can easily be justified.

The current Hudson Yards plan represents the realization of the City's efforts, beginning with the 1969 Master Plan, to expand Midtown into the Far West Side. Approval in the early 1970's of the first phase of the redevelopment of the Far West Side — the construction of a new convention center — was facilitated by the City's promise to provide affordable housing in the area. While City policy and HPD programs subsequently helped to develop a mix of new housing in Clinton, the amount of affordable housing has been decreasing in recent years. A substantial HPD and HDC commitment to affordable housing in Hell's Kitchen is necessary to fulfill the 1973 promise made to the community that "rehabilitation and new construction within the area [would be] in character with the existing scale of the community and at rental levels which will not substantially alter the mixture of income groups presently residing in the area."¹⁷

For this reason, perhaps the most important element of the HKNA affordable housing plan is the provision of 2,600 units through HPD and HDC programs. Inclusionary housing, either mandatory or optional, is an adjunct to new construction. Because we cannot be sure about pace of new construction, or indeed whether developers would make use of an optional inclusionary housing bonus, a large proportion of the affordable units should be provided by HPD and HDC programs, particularly in the early years.

Opens Space and Mapping

The HKNA plan contemplates an extensive and varied system of open spaces. These include the eight-acre central open space on the eastern rail yard site, the ten-acre rooftop park on the western rail yard site, the rooftop recreation area on top of a multi-level marshalling yard, and mid-block open spaces next to Dyer avenue between Ninth and Tenth avenues and between Tenth and Eleventh avenues. The plan anticipates development of the High Line promenade by providing for a direct connection from the High Line to the central open space on the eastern rail yard site, leading from there to the Javits Center rooftop park and the waterfront.

Mid-block Parks

From 35th to 38th streets, between Tenth and Eleventh avenues, the HKNA plan proposes a primarily commercial district west of a new mid-block boulevard and a residential (R9) district east of the boulevard. Given that configuration, we find that a string of parks between lanes of traffic is less useful than attaching the parks to the residential area. Consequently for the original plan, HKNA-1, we proposed to map an 80-foot-wide boulevard with a set of mapped public park spaces on its eastern edge. The public parks could be developed and maintained by the adjacent property owners, under guidance of special district regulations, reducing the cost of acquiring the boulevard right-of-way. To avoid unnecessary loss of jobs, condemnation, if required, should be deferred until the boulevard is actually needed to serve imminent development.

Under the HKNA-2 plan office sites are probably not required on Eleventh Avenue north of 35th Street, and consequently the mid-block boulevard would not be built. Rather the Amtrak right-of-way would be covered in those blocks with parks that would serve the emerging residential community. Thus condemnation of existing businesses would also not be required, reducing the cost of the plan in terms of both dollars and lost jobs.

The HKNA plan would also map a series of parks next to Dyer Avenue that are currently in parking or parking-related uses, as shown in Figure 5. Most of these park spaces would be on grade, although to provide continuity one deck would be required over Dyer Avenue between 36th and 37th streets. Below grade portions of the Lincoln Tunnel access roads could be decked over for residential development, if feasible. These sites should be acquired and developed as parks by the Hudson Yards Infrastructure Corporation and turned over the New York City Parks Department. Those lots that are owned by the Port Authority, and used for bus parking, should be transferred to the New York City Parks Department after the Port Authority builds the bus garage described above.

Design studies conducted for the Regional Plan Association suggest decking the Lincoln Tunnel exit plaza, which occupies a critical location between the existing residential community and the 39th Street corridor to the Hudson River.¹⁸ A large park at that location would be a great benefit to the current and future community, and we enthusiastically endorse the proposal.

39th Street Promenade

An enhanced 39th Street promenade to the waterfront is a central element of the HKNA Plan.

The waterfront is clearly the major public amenity on the West Side. With the Lincoln Tunnel, Port Authority bus ramps, rail cuts, and parking lots defining the current image of the area, attracting new housing development depends on enhancing connections to the waterfront. Attracting office development on Eleventh Avenue — the centerpiece of the City's plan and a potential outcome, if supported by the market, in the HKNA Plan — also depends on maintaining an open, easy connection to and from the 39th Street ferry terminal, which will be a major commuter portal.

The principal access route to the waterfront should be 39th Street. It is the first street north of 34th Street that remains open to the river; north of 39th Street Lincoln Tunnel access ramps act as a psychological barrier. A 39th Street promenade should be open, at-grade and tree-lined.

Street Mapping

To accommodate the southward expansion of the Javits Center, 33rd Street would be demapped between Eleventh and Twelfth avenues. In addition, 30th Street between Ninth and Twelfth avenues will probably need to be widened to provide greater capacity for vehicular access to future parking garages under the deck of both rail yard sites, from 30th and 31st streets, and to the truck marshalling structure between Eleventh and Twelfth avenues.

HKNA has long complained about the fact that Dyer Avenue is an unmapped street, complicating housing development on adjacent sites. Portions of Dyer Avenue that residential building would face, should be mapped to permit legal lot-line windows, as shown in Figure 6.

Mass Transportation

Since the HKNA plan proposes a 30th to 35th street east-west corridor as the main locus for development, mass transit access should be oriented in a parallel fashion. An east-west orientation has the advantage of connecting mass transit serving the West Side to Penn Station, a major regional transit hub.

To serve this east-west development corridor, we initially adopted the MTA's proposal for a 33rd Street shuttle connecting Eighth Avenue, Penn Station, and the subway system to a stop between Tenth and Eleventh avenues. The MTA's studies, conducted for a 1987 development scheme over the rail yards, recommended a shuttle to serve a development consisting of 12.5 million square feet of office, hotel, and residential space. The proposed shuttle would serve surrounding development and the Javits Center as well.¹⁹  The cost of a shuttle, according to a 1989 review by DCP, would have been $135 million in 1987 dollars.

The Hudson Yards DGEIS examined the shuttle alternative, but claimed it would be impractical for various reasons (including a cost 15 times higher than the previous estimate).  However the DGEIS proposed an additional alternative consisting of a set of moving walkways in essentially the same underground configuration as the shuttle.  Moving walkways have the advantages of lower cost and better service to intermediate locations along 33rd Street. 

Flushing Line Extension

While moving walkways should be sufficient to support development in the short and medium term, better transit access will be required to achieve full build-out. The current proposal to extend the Flushing (No. 7) subway line conceives of a 42nd Street cross-town route, extended west to Eleventh Avenue and then south to 34th Street.

Since commercial development would be expected to occur first in the 30th to 35th street corridor, extension of the Flushing Line could take place in a later phase, shown on Figure 7. Conceiving of the Flushing Line extension as part of a phased project would greatly reduce the overall cost, since delaying major construction would avoid the accumulation of bond carrying charges that would otherwise occur. The HKNA plan is better able to take advantage of such cost savings because the plan concentrates so much of total office development in the 30th to 35th street corridor.

Light Rail

Light rail could provide additional transit capacity to the West Side. Several variations of a light rail system have been proposed by others. The Institute for Rational Urban Mobility proposed "Vision 42," an auto-free 42nd Street pedestrian and transitway. An analysis of both the Flushing Line extension and a 42nd and 34th streets light rail loop by consultants to the Borough President of Manhattan argued that either would have about the same available capacity to deliver riders to the West Side, while the cost of a light rail system would be a small fraction of the cost of a subway extension.²⁰ The Regional Plan Association has proposed a "Midtown Crossing" light rail route along 42nd Street, Twelfth Avenue, 34th Street, and Broadway, ending at Lincoln Center. DCP itself endorsed a light rail system in 1989, proposing a "J" configuration ending at Penn Station, with 42nd Street forming the main cross-town arm.²¹ These light rail alternatives should all be considered.

Implementation