Cornell Realty Improper Environmental Assessment
This page is organized in three parts.
- A brief review of the understanding of the Environmental Review Process for proposed developments requesting changes in the rezoning laws.
- The letter that was sent to the Mayor's Office of Environmental Coordination, who is suppose to oversee this process and ensure it is performed lawfully.
- What You Can Do and the link to our petition for you to sign to support our efforts.!
The Environmental Review Process
Anytime a developer is proposing to change the existing zoning regulation to build something, they must participate in an environmental review process. There are two major components to this process. The Environmental Assessment Statement (EAS) and an Environmental Impact Statement.
The Environmental Assessment Statement (EAS)
This is a generalized form that all developers must fill out. There is a list of categories that a developer must answer questions to and depending upon their answer, they may or may not have to do other actions.
For example, in the Cornell Realty’s application, under the catorgory of Shadows, a question was asked would the development be next to a sensitive green space. Cornell Realty stated yes, so they were obligated to do a Shadow Study analysis.
The way in which the analysis is performed is determined by the CEQR manual, which gives very clear guidelines on how to perform the analysis, the rational for the analysis, along with possible outcomes and diagrams (in the letter portion of this page, these images and descriptions are used and reproduced).
Once a developer conducts their EAS, this is given to the "lead agency", in the case of Cornell Realty this is the Department of City Planning (DCP), who has authority over rezoning applications on private land. If this project was being proposed on Park land the ead agency would have been the Department of Parks.
The DCP is suppose to review the application and then make a determination if this project needs an Environmental Impact Statement EIS, or not. If it does not need further review, because the it has been determined that no negative environmental effects will occur then it is given a “Negative Declaration”. The project then moves forward through the rezoning process without any further discussion regarding environmental issues. However, if DCP determines that there could be negative environmental impacts then an EIS must be performed for the categories that were identified in the EAS.
Environmental Impact Statement (EIS)
The EIS is again performed by the developer, in which they have to take a “hard look” at the environmental issues that could occur as a result of a development and proposed to “mitigate” (reduce) some of these issues.
A hearing is set up by the lead agency, in the Cornell Realty case it should have been done by DCP. At the hearing the community has the right to review in detail the proposed mitigating actions that the developer is willing to perform, to proposed mitigation actions they would like to see, produce evidence and to also challenge the developer's EIS.
Community Input
This EIS hearing process affords the community an opportunity to weight in on this development and to ensure that certain actions will be conducted by the developer, because the migrating actions are legally binding once a developer agrees to them.
Without the EIS and the hearing, the community has no other way of pushing back and mitigating negative environmental issues from the developer. In the case of Cornell Realty EAS application DCP gave them a "Negative Declaration", despite the developer lying on his EAS and not conducting his analysis according the CEQR manual. This is explored below in the letter to the Mayor’s office of Environmental Coordination.
Letter to NYC Mayor's Office of Environmental Coordination
Directions: Please click on the title and you will go right to that section. To return to the table of contents click on the link on the right that says "go back to top".
- Details of Cornell Realty Development
- Community Groups in Opposition to Cornell Realty Development
- Comments on Negative Declaration
- Conformance of Law
- Shadows
- Determining if a Shadow Study is Required
- Determining the Worst Case Scenario for Shadows
- Cornell Realty Worst Case Scenario Model
- Evaluation of Cornell Realty Shadow Assessment
- Shadow Time Frame Findings
- Water and Sewage Infrastructure
- Cornell Lies on Environmental Assessment Statement (EAS)
- Cornell Legal Requirement to do Water and Sewage Infrastructure Analysis
- Cornell Realty – A Combined Sewage System
- Determining an Infrastructure Assessment
- The Importance of Sewage Analysis be performed by Cornell Realty
- Socioeconomic Conditions
- The Higher Courts Determination on Negative Declarations
- Inquiry One
- Inquiry Two
- The Case of Cornell Realty
- Conclusion
Letter address to:
Hillary Semel, Director
Mayor's Office of Environmental Coordination
253 Broadway, 14th Fl., N.Y. N.Y. 10007
Winston R. Von Engel, Director
Office of City Planning for Brooklyn (the Lead Agency in the Cornell Realty application)
16 Court St., Suite 704, Brooklyn N.Y. 11214
Re: Cornell Realty Hearing Comments – Objections to Negative Declaration
CEQR # 17DCPO67K
ULURP# 180347ZMK and N180348ZRK
Details of Cornell Realty Proposed Project
Pursuant to the Section 5-07 of the Rules of Procedure of Environmental Review (CEQR) and 6 NYCRR 617.8 (State Environmental Quality Review), the New York City Department of City Planning (DCP), acting on behalf of the City Planning Commission (CPC) as CEQR lead agency, has determined that an Environmental Impact Analysis is not warranted for the Cornell Realty development.
The Cornell Realty Management LLC is seeking two discretionary actions in order to facilitate the redevelopment of two sites in the Crown Heights neighborhood of Brooklyn in Community Board 9 along the perimeter of the Brooklyn Botanic Garden.
- A zoning map amendment in Section 16d of the Zoning Map to rezone portions of Blocks 1188, 1189 and 1190, including two Applicant-owned projected development sites from R6A, R6A with C1-E overlay and R8A zoning districts to an R8x district and R8x with C2-4-overlay.
- A zoning text amendment to appendix F of the Zoning Resolution (ZR) to designate the northern and southern block ends of the Project Area as a Mandatory Inclusionary Housing (MIH).
In 1991, after a major renovation project was completed at the Brooklyn Botanic Garden which included three conservatories and redesign of their green houses, the Department of City Planning “DCP” sited three “soft sites” in which height limits were created. During the rezoning process the DCP declared that any structure above 13 plus stories would cause damage to the Brooklyn Botanic Garden due to shadows on these light sensitive structures and the plant life.
Community Groups in Opposition to Cornell Realty Development
The Movement To Protect the People (MTOPP) and Flower Lovers Against Corruption (FLAC) are groups of local leaders organizing and inspiring residents in the Crown Height/Flatbush Ave community and the surrounding communities to challenge the main issues directly and adversely impacting the current and future preservation of the Brooklyn Botanic Garden, residents homes, apartments, businesses, community organizations, clinics, senior centers, schools, published services and overall quality of life.
MTOPP and FLAC consider The Department of City Planning determination for Cornell Realty not to conduct an environmental impact statement, a violation of the SEQR provision of the state law. It is viewed as a continuation of the racist policies of the Department of City Planning to allow negative environmental consequences to occur in low to moderate income communities of color, whereas the more affluent white middle class communities are afforded the opportunity to be kept informed and to mitigate negative environmental impacts in their neighborhoods.
MTOPP and FLAC considers the Negative Declaration that was approved by the Department of city deficient in several key areas and provides the following comments regarding the demand for a full Environmental Impact Analysis to be performed.
Comments on Negative Declaration and Environmental Assessment Statement Cornell Realty Environmental Assessment Statement (CEQR No 17DCPO67K)
“Cornell Realty EAS”
Pursuant to Sections 5.03 and 5.05 of the City Environmental Quality Review Rules of Procedure, the (DCP), acting on behalf of the City Planning Commission (CPC), is assuming Lead Agency status for an application submitted by Cornell Realty to construct three luxury mega towers of 175ft (which excludes the bulkhead and FRESH program additional heights) residences along the eastern border of the Brooklyn Botanic Garden (BBG) in a 60/70 height limited zone.
Conformance of Law
The evaluation of potential environmental “impacts” included public identification, disclosure, and analysis of any aspect of the proposed project(s) subject to laws other than SEQRA, especially those that extend beyond the impact category and represent potential for violations of or compliance interference with laws, regulation, Order on Consent, Administrative Orders, or any other enforcement action issued by Federal, State, or municipal authorities covering the operation and management area of the project(s). In the case of Cornell Realty rezoning, these include (but are not limited to) the Clean Water Act, the Clean Air Act, the Comprehensive Environmental Response Compensation and Liability Act, and the Federal Emergency Response Act.
Shadows
Cornell proposed developments will create shadows that will have a significant detrimental impact on the surrounding areas, especially in regards to the Brooklyn Botanic Garden. The shadow study produced by Cornell Realty and approved by DCP is fraught with inconsistencies and a complete failure to abide by procedural standards to determine the negative shadow impact.
Determining Whether a Shadow Assessment is Required
CEQR Chapter 8 section 200 –
The shadow assessment considers projects that result in new shadows long enough to reach a sunlight-sensitive resource. Therefore, a shadow assessment is required only if the project either (a) results in a new structure (or additions to existing structures including the addition of rooftop mechanical equipment) of 50 ft. or more or (b) be located adjacent to or across the street from, a sunlight-sensitive resource.
In order for a determination to be made about the height and bulk of the building to be used in a shadow study determination CEQR had defined the requirement to perform the assessment phases using the “worst case” scenario model.
Determining the “worst case: scenario for shadows.
This image is taken from the CEQR manual Chapter 8 Section 314.2 (Figure 8-5)
"The three-dimensional model of the proposed project must depict a “worst case” scenario for shadows from the building resulting from the proposed project. Since the allowable building envelope generally allows for multiple configurations of a building with the same floor area, a “worst case” scenario is constructed for a shadows assessment that combines the worst possible features, in terms of casting shadows, of all possible configurations. This eliminates the need for multiple analyses and would allow for the eventual selection among these possible configurations."
"This “worst case” scenario is illustrated in Figure 8-5. If the proposed project includes special permits or similar actions that relate to the building envelope, the “worst case” should include such allowances or restrictions on the building form. The building envelope depicting the worst case scenario must include the maximum allowed floor area, all rooftop mechanical equipment, parapets and any other parts of the building."
Determining Cornell Realty Worst Case Scenario Model
In Cornell Realty's application cited above there are three proposed buildings to be built at 175 ft. each. Additionally, Cornell requested within their application the FRESH program (special permit) their development.
Thus the worst case scenario should include the maximum allowable allowance for a building of 175 ft., the bulkhead and the FRESH program.
The NYC Zoning Text section 24-51 defines the Bulkheads and their height allowances. "Permitted Obstructions (f) Elevator and stair bulkheads..(3) (ii)…Where the maximum permitted height of a #building# is 120 feet or greater, such obstruction are limited to a maximum height of 40 ft.”
In the Zoning Text Section Chapter 3 FRESH program it states in section 63-02 that Community Board 9 in Brooklyn has the FRESH Program.
In Section 63-22 of the same publication it allows developers to increase their building heights. "Authorization to Modify Maximum Building Height “authorizes modifications…to allow the applicable maximum building height to be increased by 15 ft.” Additionally, the application may be applied for after a Building Permit has been issued and must accompany a “signed lease from the prospective of the operator of the #FRESH food store”.
DCP stated at the Cornell Realty presentation on June 12, 2018 at the ULURP committee meeting in that Cornell Realty only used 190 ft. for their shadow study assessment. This included a 15 ft. bulkhead and did not include the FRESH program, despite Cornell Realty stating in their application of their intention to apply for this program (they can apply for the program after a building permit is issued).
*Evaluation of Cornell Realty Shadow Assessment
In this diagram is an overlay rendition of Cornell Realty Shadow study.
The grey area is Cornell Realty and the red is the 190 ft height.
Cornell Realty in their model did not depict the actual size of their renditions, thus this overlay was done to determine exactly what size was used. The small gray area is Cornell Realty'a shadow depiction at 175ft. In the outer layer is 190ft. in red. Thus, it is clear that Cornell Realty used the 175 ft. size of the building and not the 190ft. as reported by DCP.
*Note: Scalar/Terreform conducted these assessments, paid for by MTOPP, via an online fund-raising platform.
This is a comparison of Cornell Realty shadow study assessment in which they used 175ft for their assessment vs. the “worst case” scenario renditions which clearly show negative impact on the Brooklyn Botanic Garden.
According to Cornell Realty shadow study findings the shadows will only hit the garden for a maximum of five minutes.
However, using the worst case scenario that number rises drastically, from 5 minutes to in total 251 minutes.
Two independent shadow studies were performed by Scalar Architecture - Terrefrom Center for Advanced Urban Research and Pratt University School of Architecture. Both determined that the shadows cast by Cornell Realty would cause negative environmental impacts to the Brooklyn Botanic Garden.
Case law abounds regarding the requirement for Environmental Assessment statements to be done accurately to determine if an Environmental Impact Statement should be done. In this case it is not only clear that Cornell Realty did not use the proper procedural guidelines to determine if any negative impact would occur but in fact didn’t even use the 15ft. bulkhead in their renditions that the DCP made the claim that they did.
Water and And Sewer Infrastructure
Cornell Realty Lies on Environmental Assessment Statement Application
According to the CEQR Technical Manual, a water and sewer infrastructure assessment analyzes whether a proposed project may adversely affect New York City’s water Distribution or sewer system and, if so, assess the effects of such projects to determine whether their impact is significant, and present potential mitigation strategies and alternatives.
In Cornell Realty application they did not do the initial analysis of the Water and Waste Sewer Infrastructure despite the requirement to do so
Cornell Realty Lied On their Application Concerning Number of Residential Units To Be Created.
According to the documents Cornell Realty’s proposed developments will be in an R8x district, with a lot size of 81,165, which includes all three development sites identified within the rezoning parameters, and a FAR of 7.02 (MIH designation). The formula to make the determination of the number of residential units that will be created is the lot size, times the FAR and divided by factor of the Zoning Regulation which is the average square footage of a residential unit.
The FAR is determined by the MIH program, in an R8x zone which is 7.02,
The Factor is decided by a table in section 23-22 of the NYC Rezoning Resolution.
Calculate Residential Units Development in R8x zone
Multiply the lot size (81,165 ft) by the FAR (7.02),
Divide the applicable factor of 680 (according to NYC Zoning Resolution) and you get
839 Residential units.
Cornell’s EAS states that the proposed three developments will only create 565, which would create an additionally 274 residential units after the non-action developments are considered. We determined that Cornell Realty actually used 1000 for their factor and not the 680. Thus allowing them to state that their development will actually create a smaller number of units.
Calculate non-action Residential Units development in an R6A zone
Multiply the lot size (81,165 ft) by the FAR (2.70),
Divide that number by 680
Total Number of Units equal 322.
Thus the total number of additional units on top of the non-action, that will be produced by these three developments is 517 residential units. According to the CEQR manual 400 or more residential units created in Brooklyn warrants an EAS to be performed regarding the Water and Sewage.
This image is a copy of the actual Cornell EAS application.
The boxes on right are for the No Column.
Establishing Cornell Realty Legal Requirement to do Water and Sewage Infrastructure Analysis
CEQR Chapter 13 Infrastructure
"Generally, only projects that increase density or change drainage conditions on a large site require infrastructure analysis. In addition to waster supply, conveyance and waste water treatment (WWTP) assessments, stormwater management is an integral component of an infrastructure analysis due to potential environmental impacts related to how much the built sewer and conveyance system can handle, and related effects such as street flooding, surcharging sewers downstream, sewer back-ups (SBUs), increases in CSOs, and pollutant loadings contained in CSOs or direct stormwater discharges to the City’s surrounding water bodies. Stormwater drainage is also a central element of the natural resources analysis described in Chapter 11, “Natural Resources” since stormwater is a substantial contributor of water into natural system such as wetlands and adjacent water bodies. Disruption of water and sewer services during construction should be addressed in Chapter 22, “Construction”."
Establishing Cornell Realty Location – A Combined Sewage System
CEQR Chapter 13, 121.1 Combined Sewer Systems
About 50 percent of the City's land area is served by a combined sewer system in which the system collects both "dry-weather" wastewater (primarily sanitary sewage as well as wastewater from industries and stormwater). During dry weather, combined sewers function as sanitary sewers, conveying all flows to the treatment plants for treatment. During wet weather, however, large volumes of rainfall runoff can enter the system from building connections and through catch basin along the City's streets. If this water were conveyed to the treatment plans, it would exceed their design capacity. Areas served by "separate sewers include certain areas of Queens and Staten Island. Thus Brooklyn is served by a combined Sewage System".
CEQR Chapter 13 121.3. states: Stormwater is of concern if it exceeds the capacity of the City’s sewers or wastewater conveyance systems and transmits new or increased levels of pollutants in the City’s water bodies. This is an issue for developments that would increase residential density….
Chapter 13 Section 200 Determining Whether an Infrastructure Assessment is Appropriate
220 Waste and Stormwater Conveyance and Treatment.
The thresholds below related to a project’s potential to result in a significant adverse impact to the environment. A preliminary infrastructure analysis would be needed if the project: Is located in a combined sewer area and would exceed the following incremental development of residential units or commercial, public faculty or institution and/or community facility space above the predicted
400 residential units or 150, square ft. of commercial, public facility and institution and/or community facility space or more in the Bronx, Brooklyn…
Cornell Realty application states their development will produce a total of 518 residential units, but according to NYC Zoning Resolution using their factor, 839 residential units can be built in total. The non-action residential units are 322. So they will create 517 additional residential units above the threshold. These number clearly exceed the require threshold to demand an Infrastructure Assessment.
The Importance of a Sewage Analyses to be preformed by Cornell Realty.
When it rains in New York City, raw sewage bypasses treatment plants and flows directly into city waterways. Even a relatively small amount of storm water—one twentieth of an inch of rainfall—can overwhelm aging and clogged system components and trigger the Combined Sewer Overflow (CSO) system.
The New York State Department of Environmental Conservation (DEC) has identified Combined Sewer Overflows (CSOs) as the single largest source of pathogens to the New York Harbor system, due to their contribution of fecal coliform. Besides the human waste, any oil, industrial waste or household garbage that happens to be on the street when a rainstorm begins are swept by the flowing street water into the CSO system as well. The toxic soup flows untreated out of pipes that feed directly into the waterways.
The New York State Department of Environmental Conservation administers the State Pollutant Discharge Elimination System ("SPDES") permit program (ECL §17-0801, et seq.) to which New York City is jurisdictionally subject. New York City operates under multiple SPDES permits for its wastewater treatment plants, and for its Municipal Separate Storm Sewer Systems (MS4). In general, the SPDES program prohibits any discharge of pollutants to the waters of the State without a permit establishing pollutant limitations and treatment requirements.
Thus SPDES permits set certain effluent limitation parameters, determined according to ECL §17-0809 and 6 NYCRR Part 750-1.11, in order to avoid contravention of mandated federal water pollution control requirements and water quality standards ("WQS"). Those conditions address not only the allowable parameters for discharge of pollutants to waters of the State, but also the manner in which the permittee is to operate, maintain, monitor and report on its regulated facilities and activities.
The proposed Cornell development will be located in the drainage area that feeds to the Coney Island Wastewater Treatment Plant (CIWTP). The Combined sewage and rainwater of Bedford Union Armory, and all of the new development that has accrued in the past ten years in the area of Brooklyn covered by this plan, will increase the pressure and stress on the CIWTP.
Major zoning changes and large scale development continues unabated throughout the CIWTP basin. The addition of Cornell Realty developments in an already dense area with a high volume of, education and health care facilities, as well as residences affects the capacity and flow control of the entire CIWTP drainage system and adds to the likelihood of continued CSOs.
Cornell Realty must assess the full impacts to pipe and plant loading, as well as the adverse impacts from ongoing CSO overflow to the public waters. This however can not be done unless Cornell first does the initial analysis required in the Environmental Assessment statement.
Socioeconomic Conditions
“The socioeconomic character of an area includes its population, housing, and economic activity. Socioeconomic changes may occur when a project directly or indirectly changes any of these elements. Although socioeconomic changes may not result in impacts under CEQR, they are disclosed if they would affect land use patterns, low-income populations, the availability of goods and services, or economic investment in a way that changes the socioeconomic character of the area.”
However, because this proposed construction affects a Large Scale Residential Development Zoning Area, the assessment is not limited to the categories outlined in the CEQR Technical manual, but must also evaluate outcomes and long term effects under the standards set forth in Section 78-01 of the Zoning Resolution of the City of New York which states:
- For large-scale residential developments involving several zoning lots but planned as a unit, the district regulations may impose unnecessary rigidities and thereby prevent achievement of the best possible site plan within the overall density and bulk controls. For such developments, the regulations of this Chapter are designed to allow greater flexibility for the purpose of securing better site planning for development of vacant land and to provide incentives toward that end while safeguarding the present or future use and development of surrounding areas and, specifically, to achieve more efficient use of increasingly scarce land within the framework of the overall bulk controls, to enable open space in large-scale residential developments to be arranged in such a way as best to serve active and passive recreation needs of the residents, to protect and preserve scenic assets and natural features such as trees, streams and topographic features, to foster a more stable community by providing for a population of balanced family sizes, to encourage harmonious designs incorporating a variety of building types and variations in the siting of buildings, and thus to promote and protect public health, safety and general welfare.
Cornell Realty project is being propose in a low income community, in which the proposed population will increase by over 5%, and rental properties will be way over the top portion of the current community. Even the “affordable” categories will far surpass the community’s average medium income which is $40,000 compared to the average medium income of $104,000 for affordable units.
The Higher Courts Determination on Negative Declarations.
There is a body of law from the higher courts of negative declaration being declared null and void because of applicants’ failure to conduct proper EASs.
In the matter of Village of Chestnut Ridge v. Town of Ramapo, 99 A.D. 3d 918, a negative declaration adopted without reference to any empirical or experimental data, scientific authorities, or any explanatory information, and consisting of conclusory statements may be annulled, and strict compliance with the procedural requirements of the State Environmental Quality Review Act (SEQRA), ECL art. 8, is mandated..” (emphasis added)
In the matter of Kahn v. Panik, 90 N.Y. 2d 256 stated A court's authority to examine a State Environmental Quality Review Act (SEQRA) review conducted by an entity that is required to do so is limited to reviewing whether the determination is made in violation of lawful procedure, is affected by an error of law, or is arbitrary and capricious or an abuse of discretion. The relevant question before the reviewing court is whether the agency identified the relevant areas of environmental concern, took a "hard look" at them, and made a "reasoned elaboration" of the basis for its determination.
In the matter of Merson v. McNally, 90 N.Y. 2d 742 regarding the State Environmental Quality Review Act's (SEQRA), 6 N.Y. C.R.R. § 617 et seq., speaks closest to the issues being presented in regards to Cornell Realty’s negative declaration.
In the Cornell case, the lead applicant DCP, engaged in a private agreement to mitigate the negative impacts of a proposed project which then resulted in a negative declaration; the reduction of the allowable allowance of bulkheads from 40 ft. to 15 ft. for a project that is over 100 ft.
The courts however created a twofold inquiry to assess these agreements to examine whether a negative declaration has been impermissibly conditioned:
Inquiry One
Whether the project, as initially proposed, might result in the identification of one or more significant adverse environmental effects; and (2) whether the proposed mitigating measures incorporated into the Environmental Assessment Form were identified and required by the lead agency as a condition precedent to the issuance of the negative declaration.
"..where the lead agency has identified potentially significant impacts, or where the record supports an inference that the identified impacts would have to be considered potentially significant, or where the identified impacts fall within typically environmentally sensitive areas or locations.."
Inquiry Two
The second prong of the test must be examined at the second phase of analysis of the twofold inquiry to examine whether a negative declaration has been impermissibly conditioned, a court must examine whether the proposed mitigating measures, incorporated as part of an open and deliberative process, negated the project's potential adverse effects.
The Case of Cornell Realty
In the case of Cornell Realty the lead agency DCP already has sited, in their previous determination to place height limits on the area that is now being considered for upzoning, with a statement on the record, that any building being built above 13 plus stories would be detrimental to BBG, due to the shadows cast on garden. Thus the first inquiry has been met; there is an issue that has been identified as a significant adverse environmental effect.
During the presentation of the Cornell Realty application at Community Board ULURP committee meeting, when the issue of how Cornell Realty came up with their parameters for the shadow study, Cornell Realty stated that DCP had advised them regarding the 15ft bulkhead dimensions.
Thus it is clear that the reduction of the bulkhead requirement from 40ft to 15 ft. was not done in an open and deliberative process, nor was it ever discussed as a lawfully binding condition to mitigate the negative impacts on the garden. It was used to hide and deceive the public and to allow the lead agency DCP to declare a negative declaration.
Finally, the courts summarized their position regarding behind the door negotiations with developers.
"The State Environmental Quality Review Act's (SEQRA), 6 N.Y. C.R.R. § 617 et seq., fundamental policy is to inject environmental considerations directly into governmental decision making. This policy is effectuated, in part, through strict compliance with the review procedures outlined in the environmental laws and regulations. A SEQRA review process conducted through closed bilateral negotiations between an agency and a developer would bypass, if not eliminate, the comprehensive, open weighing of environmentally compatible alternatives both to the proposed action and to any suggested mitigation measures." (Merson v. McNally, 90 N.Y. 2d 742, 1997 )
Conclusion
It is clear that a proper EAS has not been performed by the Cornell Realty and thus the need for them to redo their EAS and to have a EIS done to ensure that all negative environmental effects are disclosed and mitigated to protect the community, the people and the public resources.
Sincerely,
Alicia Boyd, MTOPP
Cc:
Senator Jesse Hamilton
Borough President Eric Adams
Assemblyman Walter Mosely
Congresswoman Evette Clark
Councilwoman Laurie Cumbo
Robert Dobrushkin, Chair of City Planning Commission
Chairperson of Community Board 9
What Can You Do?
Please go Sign Our Petition demanding that Cornell Realty do their Environmental Assessment Over!
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