The residents of the Two Bridges neighborhood in the Lower East Side find themselves in a predicament. Throughout the city, developers have targeted expired urban renewal areas originally governed by land-use controls that have ensured housing affordability for decades. The Two Bridges Large Scale Residential Development is one such target. Exploiting the site’s underlying high-bulk zoning allowances, a group of developers is proposing to build four new predominantly market-rate skyscrapers, ranging in height from 62 to 80 stories—four gleaming luxury megatowers that portend a storm of gentrification and displacement.
The proposal needs approval by the city administration. Many argue that the development requires a “Special Permit,” which would call for a Uniform Land Use Review Procedure (ULURP). In 2016, Carl Weisbrod, then Chair of the City Planning Commission, declared the project a “Minor Modification” requiring no ULURP. After public outcry, the Department of City Planning requested the developers to undertake an unprecedented joint Environmental Review. On October 17, 2018, the City Planning Commission held a public hearing regarding the proposal’s Draft Environmental Impact Statement (DEIS). The room was packed. About 100 people testified. The vast majority (myself included) raised serious objections to the project and the approval process. Only five were in favor: two members of a union advocating for 50 permanent building service jobs promised for the site; an advocate for the disabled, who supports all projects that add elevators to subway stops; the current Two Bridges commercial tenant, who is promised a long-term lease in the new complex; and the executive director of Settlement Housing Fund, who is selling air rights to the 80-story tower.
At the public hearing, questions about the appropriateness of the project’s scale were addressed by Gregg Pasquarelli of SHoP, the firm responsible for the 80-story tower, who showed examples of recent large-scale waterfront projects and said that the city has consistently approved this kind of development. In his presentation, Pasquarelli glossed over substantive issues of urban context. The audience was baffled if not offended. When Pasquarelli claimed that the project “will create a vibrant, beautiful, equitable, and appropriate skyline for the city and its residents,” the room actually burst into laughter. Commissioner Anna Hayes Levin pointed out that the projects of “tremendous scale” that Pasquarelli used to make his case were in manufacturing areas transitioning to a new use, while this expired urban renewal area was planned for, and still is, a low- and moderate-income residential development. Pasquarelli, showing what was at best was ignorance and at worst callousness, did not really respond and brought up the example of the American Copper Buildings, a SHoP-designed 800-unit residential development in an already affluent neighborhood, with nowhere close to the same risks of gentrification and displacement impending at Two Bridges.
Laughter also greeted Pasquarelli’s closing sentence: “the city is in a housing crisis, and this provides a huge amount of affordable housing for the neighborhood.” Indeed, a quarter of the new apartments (694 out of 2,775 units) will have a degree of affordability. But for whom? Surely not the current residents of Two Bridges, whose households’ median income ($30K) is below the threshold for renting in the new ‘affordable’ units ($37K). City-wide trends and the advent of Essex Crossing have already resulted in the loss of rent-regulated units as well as higher eviction rates in the area. The influx of 2,081 market-rate apartments cannot but exacerbate the situation and lead to residential and business displacement. Whose neighborhood will this be once bodegas are replaced by cafés selling five-dollar lattes?
The Environmental Review was meant to identify any adverse impact from the proposed development in 19 areas of analysis as defined by the City Environmental Quality Review (CEQR) Technical Manual guidelines. The review found negative impact in five areas—Transportation, Shadows, Open Space, Construction, and Community Facilities & Services—for which the developers are proposing some mitigation. No adverse impact was found in 14 areas, among them Socioeconomic Conditions and Neighborhood Character. How is this possible?
The CEQR guidelines are notoriously flawed. For instance, per the guidelines, no resident of a building with even one rent-regulated unit is vulnerable to indirect displacement. Even more troubling: the guidelines call for a “No Action” scenario to be used as a comparison when evaluating indirect displacement. The DEIS defines “No Action” as a condition “in which projects are expected to continue the trend towards market-rate development and rising residential rents in the study area. In accordance with the CEQR Technical Manual guidelines, since the vast majority of the study area has already experienced a readily observable trend toward increasing rents and new market rate development, further analysis is not necessary.”
The “No Action” scenario is one of several critical factors that make possible and seemingly inevitable what we might call the ‘dubaification’ of New York City. It is not a loophole: the developers and their compliant architects are going by the book, following the law to the letter. The problem is written in the law itself: once you accept the premise that the market is already conquering the city—that increasing rents and luxury developments are already the norm—no new project, no matter how big or in which urban context, can ever be held responsible for negatively affecting the socio-economic fabric of any area.
The question, in assessing this proposal as well as the spate of massive developments popping up all over the city, is not solely about scale. To be sure, height is a major concern. (I find it ironic that the tallest of the existing six housing complexes at Two Bridges is a 21-story building that everyone calls “The Tower.”) But what these megatowers portend is something more ominous: an ever more homogeneous and generic skyline; the disappearance of neighborhoods and their communities; apartments becoming phantom residencies for absentee investors; dwelling valued only as an investment, a commodity; a city of resplendent buildings towering over dead streets.
There is still time to do the right thing for Two Bridges. The City Planning Commission will be voting as early as November 14 on the “Minor Modification.” They must deny it. A ULURP must be granted, to allow the public and elected officials to negotiate for more significant community benefits, including greater and deeper affordability as well as height caps to truly tackle the adverse impact of the megatowers. More important, the Two Bridges debate is an opportunity to start imagining alternative visions for our city. The City administration must close zoning loopholes and fix the CEQR guidelines. Let’s build a city in which housing is not treated as a commodity but as a fundamental right.