Comments On The Penn Station General Project Plan
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State Senator Liz KruegerComments On The Penn Station General Project Plan
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State Senator Liz KruegerTestimony on the Adoption of Findings, Affirmations and Authorizations Relating to
the General Project Plan for the Pennsylvania Station Area Civic and Land Use
Improvement Project
U.S. Representatives Jerrold Nadler & Carolyn Maloney
Manhattan Borough President Mark Levine
State Senators Brad Hoylman, Robert Jackson, & Liz Krueger
Assembly Member Richard Gottfried
Councilmember Erik Bottcher
July 20, 2022
We appreciate the opportunity to submit comments regarding the adoption of findings,
affirmations and authorizations relating to the General Project Plan for the
Pennsylvania Station Area Civic and Land Use Improvement Project.
Our districts, which cover Penn Station and the neighborhoods around it, including the
proposed expansion and development areas, have seen enormous growth in residential
and commercial development and the associated congestion in our transit system and
on our streets over the last two decades. The increase in scale and density on
Manhattan’s West Side as a result of rezonings and development has led to a dramatic
increase in the number of people who live and work around Penn Station and who rely
on this transit hub.
The Empire Station Community Advisory Committee Working Group (CACWG)
released its initial response to Empire State Development’s proposed General Project
Plan for Pennsylvania Station and its surrounding area in August of 2021. The report
reflected input from two town halls, and a series of issue-focused meetings ranging
from transportation to financing to public space, with significant engagement and
support from ESD, the Metropolitan Transportation Authority, and Amtrak on technical
details of the proposal.
We are thankful for the improvements that have been included as a result of the
CACWG’s work:
● Required residential use and community facility space, including significant
increases in affordable and supportive housing.
● The guarantee of new affordable housing at site 4 which can be built before any
potential southern expansion, ensuring new affordable housing for displaced
tenants to relocate to.
● The creation of a Public Realm Task Force to continually engage the community
who lives in and around Penn Station, along with 100% of the funding sources
defined.
● The creation of a Development Corporation to oversee the public realm
improvements, coordinate agencies, and audit all records related to the
collection, distribution, accounting, and/or utilization of PILOT Revenue,
● Reductions in floor areas, bulk and massing, from 20 million gross square feet to
18 million, something that will greatly improve the sightlines and light in the
area.
● Required fully electric buildings and equivalent LEED in effect at the time of
design.
● Consideration of additional shared streets and protected bike lanes.
● Increased public space requirements on each GPP site and replacement of any
loss of existing Privately Owned Public Space.
● More active, diversified street frontages.
● Reduction of allowable parking and increase of in-building bicycle parking.
● Preservation of the City’s existing tax revenue in this district.
● An updated neighborhood conditions study including public realm conditions
and conditions of study area properties.
● The protection of a key historic resource, the Gimbels Skybridge, by requiring a
thorough alternatives study for any development at site 8 stating there must be
no feasible alternative to preserving it.
● Safe Options Support teams to use evidence-based Critical Time Intervention
approach to provide intensive outreach, engagement and care coordination
services to street homeless individuals in the project area.
● Required project labor agreements on the construction of each site.
Our comments submitted on the FEIS raised outstanding questions and concerns.
Additionally, as the communities most impacted by Penn Station and its operations, we
request your thorough review of the testimonies submitted by Manhattan Community
Boards 4 and 5.
Remaining Concerns
Governance
We are pleased to see that the City and State have agreed to create a Development
Corporation to oversee the public realm improvements and ask that the Development
Corporation oversee all aspects of the plan including above ground development and
below ground infrastructure upgrades to maximize agency coordination and
accountability.
We are grateful for the $50 million commitment towards the public realm fund from
early project revenues. Additionally, we recommend that a formula be established to
ensure that revenue from the PILOTs is regularly and equitably dedicated towards the
public realm improvements. There have been concerns raised that an undue share of the
revenue will go towards the Transit Improvements and Penn Reconstruction and
Expansion, and funding the public realm improvements beyond the initial $50 million
will not be prioritized.
Madison Square Garden
We maintain that moving Madison Square Garden is in the best long term interests of
our city: the ability to provide for a grand above-ground train hall, enable the
construction of wider platforms and realigned tracks, allow for track expansion without
displacing residents, facilitate ease of public realm improvements, and provide for the
addition of through running. We request that a group of stakeholders be convened to
explore alternative locations for MSG and that design guidelines be left flexible to
contend with the possibility of moving MSG.
Disclosure of Financial Information
We remain concerned that important questions regarding the financing of the project
remain unanswered in the GPP. Some of the questions we raised in our comments on
the FEIS have been answered with the release of the Letter of Mutual Agreement
between New York City and New York State. However, we urge additional disclosure of
financial information in the following areas.
● Fundamental questions related to the assumptions regarding projected revenue
from PILOTs and the impact of changing work patterns on the need for office
space in New York City still have not been shared with the public or with the
ESD board.
● ESD should provide a detailed timeline for when revenues are expected,
information on how those projections were developed, and how the analysis
factored in changing work patterns
● The lack of clarity regarding the potential level of tax abatements that could be
attached to developments authorized by this project is troubling, as outside
analysis of the levels of potential abatements currently authorized by the
agreement with the city suggest abatements could top $2 billion. Any abatements
issued to developers reduce the amount of revenue available to fund critical
transportation and public realm improvements. Given the unique desirability of
this location for commercial development, there is no justification for tax
abatements.
● We urge ESD to provide specific details on these issues to the ESD Board before
the vote. In addition, given that the role of the PACB is to evaluate the financing
of the project, it is essential that it has all financial information prior to this
matter being brought before them for a vote.
CACWG and Community Concerns
It is worth noting that there is significant opposition to this project among our
constituents as well as within the CACWG. While there is agreement on the need to
improve Penn Station, there are many who feel that the GPP is not the right plan to do
so. Some members of the CACWG believe that the most significant changes requested
by the CACWG have not been incorporated. We appreciate ESD’s prolonged
engagement with the community and changes that have been made to the plan and
look forward to continued engagement. As representatives, however, we want to ensure
that we document and institutionalize the many concerns about ESD’s approach to this
project that have been brought to us.
