new brighton comfort station final scope of work …...1 february 26, 2014 new brighton comfort...

1 February 26, 2014

New Brighton Comfort Station Final Scope of Work

Targeted Environmental Impact Statement

A. INTRODUCTION This document is the Final Scope of Work outlining the issues to be analyzed in a targeted Environmental Impact Statement (EIS) for the installation of a modular comfort station near the eastern end of the Brighton Beach Boardwalk, approximately between Coney Island Avenue and Seacoast Terrace, in the neighborhood of Brighton Beach in Brooklyn (see Figure 1). The new comfort station would replace a previously existing comfort station that was damaged beyond repair by Superstorm Sandy in October 2012 and subsequently demolished. The replacement comfort station would be located predominantly within the footprint of the previously existing comfort station.

The preparation of an EIS for the New Brighton Comfort Station was directed by a New York State Supreme Court Justice sitting in Kings County in an order filed on August 27, 2013.1

A Draft Scope of Work for the project was issued on October 18, 2013. Oral and written comments were received during the public meeting held by the New York City Department of Parks and Recreation (NYCDPR) on November 18, 2013, from 6:00 PM to 8:00 PM at the Shorefront YM-YWHA of Brighton-Manhattan Beach at 3300 Coney Island Avenue in Brooklyn. Written comments were accepted from the issuance of the Draft Scope of Work through the public comment period, which ended at 5 PM on December 2, 2013.2

This Final Scope of Work reflects changes made in response to relevant public comments on the Draft Scope. Deletions are not shown in this document. However, where relevant and appropriate, new text and editorial changes to the Draft Scope have been incorporated into the Final Scope and are indicated by double-underlining.

B. PROJECT DESCRIPTION PROJECT SITE

The proposed project would install a replacement comfort station approximately 300 feet east of Coney Island Avenue and immediately to the south of the Brighton Beach Boardwalk (see Figure 2). The project site is located on Block 8725, which comprises the boardwalk—from Coney Island Avenue to the west and the boardwalk’s terminus to the east—and the waterfront

1 Oceana Homeowners Association v. City of New York, Ind. No. 6232-2013 (Sup. Ct. Kings County).

Specifically, the order directed that work on the New Brighton Comfort Station project be “stayed pending final decision by the Court on the Article 78 petition or publication of an environmental impact statement for New Brighton, whichever comes first.”

2 Comments received after this date were considered as well.

A T L A N T I C O C E A N

BRIGHTON BEACH AVE

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N1

5

ST

BRIGHTWATER CT

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BOARDWALK EAST

BRIGHTWATER AVE

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14

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OCEANA

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Project LocationFigure 1NEW BRIGHTON COMFORT STATION

SCALE

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LIFEGUARDSTATION

Proposed Comfort Station (Including Ramps and Stairs)

Previously Existing Comfort Station Footprint

BOARDWALK EAST

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Project Site Aerial PhotographFigure 2NEW BRIGHTON COMFORT STATION

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LIFEGUARDSTATION

Proposed Comfort Station (Including Ramps and Stairs)


New Brighton Comfort Station

February 26, 2014 2

portion of the beach from the boardwalk to the ocean. Block 8725, including the project site, is mapped parkland.

The proposed project would be constructed predominantly within the footprint of a comfort station that was severely damaged by Superstorm Sandy in October 2012 and subsequently demolished; portions of the stairs leading to the modular units would extend outside the footprint. The next nearest comfort station on this portion of the boardwalk is at Brighton 2nd Street, approximately 1/3-miles to the west of the project site. There is no comfort station to the east of the project site (see Figure 3).

The replacement comfort station is partially completed on the project site. Work began in April 2013 with the placement of 16 concrete pilings (wood pilings were also installed in the project area to support ramps and stairs from the boardwalk to the beach). Work on the project was halted when below-grade obstructions prevented further pile driving activities. In August 2013, DPR provided NYSDEC with drawings concerning a proposed method for installing the remaining twelve pilings that need to be placed at the proposed project site before the modular structures can be installed. The proposal is pending before NYSDEC. 3

PROPOSED REPLACEMENT COMFORT STATION DESIGN

The replacement comfort station would consist of two modular units—one serving as the women’s restroom and the other as the men’s—each approximately 15 wide, 12 feet high, and 60 feet long and totaling 1,710 square feet between the two units. The modular structures have been prefabricated off-site and were delivered to an area near the project site. The structures would be lifted onto the pilings via crane. The modular structures would be oriented in a perpendicular manner to the beach to expose less surface area to wind and wave action in future storms (see Figures 4 and 5). The modular structures are designed to provide an 8-foot under-clearance in order to allow boardwalk patrons to walk underneath and to provide views from the boardwalk to the ocean through the structural supports.

The structures have been designed in accordance with the 2008 New York City Building Code4 and to the standards of the American Society of Civil Engineers appropriate to structures located in flood zones5. The pile foundation and modular structures are designed to resist flotation, collapse, and lateral movement when subjected to wind and flood loads.

The materials for the modular structure have been designed to withstand conditions on the beachfront. The piles and foundations are made of concrete; concrete piles would also support the access walkways and ramps to the modular structures. Steel is used for the main frame, with the siding made of concrete fiber board and the interiors of tile and stainless steel. All

3 NYCDPR received permits for its proposed work efforts at Coney Island and Manhattan Beach from the

New York State Department of Environmental Conservation (NYSDEC) as per Article 34 of the Environmental Conservation Law (ECL) for new structures within the Coastal Erosion Hazard Area, Tidal Wetlands Permits as per Article 25 of the ECL, permission for excavation and fill or navigable waters as per Article 15 of the ECL for the repair of Steeplechase Pier, and Clean Water Act Water Quality Certification. The permits were renewed, though the proposed change in method for installing the 12 remaining piles at the site is pending before NYSDEC.

4 2008 New York City Building Code, Chapter 16, “Structural Design,” Section BC-1612, “Flood Loads,” and Appendix G “Flood Resistant Construction.”

5 American Society of Civil Engineers, Standard 24-05 “Flood Resistant Design and Construction.”

LIFEGUARD STATION

RAMP TO BEACH

BOARDWALK

STAIRS TOBEACH

12.31.13

N

Site PlanFigure 4NEW BRIGHTON COMFORT STATION

Proposed Comfort Station Including Stairs and Ramps


12.31.13

Illustrative Project RenderingFigure 5NEW BRIGHTON COMFORT STATION

NOTE: FOR ILLUSTRATIVE PURPOSES ONLY

ATLANTIC OCEAN

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NEW BRIGHTON COMFORT STATION

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Coney Island and Brighton Beach Comfort StationsFigure 3

1/3-MILE

NEW BRIGHTON

• Constructed in 1941• Demolished after Sandy

BRIGHTON 2ND STREET

• Constructed in 2002• Reopened after Sandy

W. 2ND STREET


W. 8TH STREET

• Damaged beyond repair• New modular comfort station opened in 2013

STILLWELL AVENUE

• Constructed in 2002• Reopened after SandyW. 16TH STREET

W. 22ND STREET TRAILERS (2)

W. 27TH STREET TRAILERW. 33RD STREET TRAILER


56A

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32 1

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components of the comfort station that are not part of the main structure (i.e., metal siding panels, skylights, photovoltaic panels, etc.) have been designed to exceed the performance requirements of the 2008 New York City Building Code for high wind loads.

The replacement comfort station would be compliant with the requirements of the American with Disabilities Act (ADA). Stairs and ADA accessible ramps would connect the structures to the boardwalk.

The stairs and ramps providing access to each modular structure have been designed to be built in pieces, with a frame that is welded to the base plate of each support column. The stairs and ramps would be supported by concrete piles that are separate from the concrete piles supporting the modular comfort station structures. Should the stairs and ramps be subject to wave forces, they have been designed to separate from the larger structure in a way that would allow the larger structure to remain stable during an extreme storm event. The stairs and ramps, which are made of metal and are welded and bolted to the underlying support columns, are not expected to float during a storm event.

PROPOSED OPERATIONS

The proposed replacement comfort station is planned to be open for public use between Memorial Day and Labor Day. The comfort station will be staffed by NYCDPR maintenance staff and patrolled by NYCDPR Enforcement Patrol officers.

C. PROPOSED ACTIONS AND APPROVALS PROJECT BACKGROUND

Superstorm Sandy, which struck New York City in late October 2012, damaged portions of the city’s infrastructure, including many of NYCDPR’s beaches and facilities. In the seven months after the storm, over $270 million was spent on restoring all 14 miles of New York City beaches, including Brighton Beach, in order to re-open them for the 2013 summer season. The restoration program repaired portions of damaged boardwalks, provided new access, and incorporated new resiliency measures. The proposed comfort station was one of 17 comfort and lifeguard stations to be installed in 15 locations throughout New York City; two modular comfort stations and two modular lifeguard stations, including the proposed New Brighton comfort station, were planned for the Coney Island-Brighton Beach boardwalk. Throughout the City, all but two of the 17 comfort and lifeguard stations have been installed and were in use during the 2013 beach season.

PROPOSED ACTIONS AND APPROVALS FOR THE CURRENT PROJECT

NYCDPR received permits for its work efforts at Coney Island, Brighton Beach, and nearby Manhattan Beach, including this proposed replacement comfort station, from NYSDEC as per Article 34 of the Environmental Conservation Law (ECL) for new structures within the Coastal Erosion Hazard Area and Tidal Wetlands Permits as per Article 25 of the ECL.6

6 NYCDPR also received approval from the New York City Public Design Commission and the New

York City Department of Small Business Services (“DSBS”) Waterfront Permits Unit. In addition, the Federal Emergency Management Agency (“FEMA”) issued its Record of Environmental Determination on the post-Sandy recovery work in Coney Island, including the replacement New Brighton comfort station, and the proposed replacement comfort station’s consistency with the New York City Waterfront Revitalization Program was evaluated and approved by the New York State Department of State (NYSDOS).


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Although the installation of the replacement comfort station was classified by the lead agency as a Type II action under the State Environmental Quality Review Act (SEQRA) and City Environmental Quality Review (CEQR), an EIS for the New Brighton comfort station is being prepared to comply with the above-mentioned court order; the EIS will follow the guidance of the 2012 CEQR Technical Manual and will be conducted in accordance with the more rigorous procedural requirements for an action designated as a Type I action pursuant to SEQRA/CEQR. There are no additional actions or approvals contemplated for this project.

PURPOSE AND NEED

The restoration of the City’s recreational facilities—including beaches, boardwalks, and amenities—is a key part of post-Sandy recovery efforts.7

The installation of the proposed replacement comfort station would restore permanent seasonal access to toilet and hand washing facilities to this portion of the Coney Island-Brighton Beach Boardwalk consistent with the New York State Public Health Law governing bathing beaches (10 NYCRR Part 6, Subpart 6-2), which requires that adequate toilet and hand washing facilities are provided at these public beaches.8

Furthermore, the proposed comfort station is specifically designed to be resilient against future storm surges and resulting damage by raising the structure well above the 100-year base flood elevation as indicated on the Preliminary Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps (FIRMs)9 and above the 500-year flood elevation as indicated on the FEMA Advisory Base Flood Elevation (ABFE) maps10. This proposed elevation of the comfort station would be consistent with (and exceed the recommendations of) the City’s June 2013 report on the Special Initiative for Rebuilding and Resiliency (SIRR), which aims to increase the resiliency of New York City, with a long-term focus on preparing for and protecting against the impacts of climate change. The report presents recommendations both for rebuilding the communities impacted by Superstorm Sandy and increasing the resilience of infrastructure and buildings citywide; the report notes the importance of providing replacement comfort station facilities that are more resilient than those that preceded them.

NYCDPR is seeking reimbursement of the costs for the proposed project through the Federal Emergency Management Agency (FEMA) funding for post-disaster rebuilding efforts. FEMA reimbursement is for “in-kind” repairs except where an applicant (in this case, NYCDPR), is required to adhere to new codes and standards as a result of the repair. While the comfort station could be constructed at the grade of the beach and still meet current NYC Building Code

7 Restoration of the City’s beaches is the first Parks Initiative outlined in the City’s Special Initiative for

Rebuilding and Resiliency (SIRR), the comprehensive plan for rebuilding after Superstorm Sandy and for increasing the City’s resilience.

8 The EIS will include a New York City Department of Health and Mental Hygiene (DOHMH) public health assessment of the New Brighton comfort station that examines the potential effect of not having a comfort station at the New Brighton location.

9 FEMA released Preliminary FIRMS for New York City on December 5, 2013. 10 FEMA released Advisory Base Flood Elevation Maps on January 28, 2013.

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standards,11 such construction would place the new structure at the same risk of flooding as the one that was damaged beyond repair by Superstorm Sandy.

D. CITY ENVIRONMENTAL QUALITY REVIEW The targeted EIS will be prepared in conformance with all applicable laws and regulations, including the State Environmental Quality Review Act (Article 8 of the New York State Environmental Conservation Law) and its implementing regulations found at 6 NYCRR Part 617, New York City Executive Order No. 91 of 1977, as amended, and the Rules of Procedure for the City Environmental Quality Review (CEQR), found at Title 62, Chapter 5 of the Rules of the City of New York. The EIS will follow the guidance of the 2012 CEQR Technical Manual and will be conducted in accordance with the more rigorous procedural requirements for an action designated as a Type I action pursuant to 6 NYCRR 617.

ANALYSIS FRAMEWORK

Each chapter of the targeted DEIS will assess whether the proposed project could result in significant adverse environmental impacts.

The differences between the future without the proposed project (the No Action condition) and the future with the proposed project (the With Action condition) will be assessed for whether such differences are adverse and/or significant; any significant adverse environmental impacts will be disclosed.

As detailed in the Draft Scope of Work, the No Action condition is assumed to be the rebuilt structure as it existed prior to being damaged beyond repair by Superstorm Sandy (No Action Condition 1). In response to comments received during the public comment period on the Draft Scope of Work, a second No Action condition will also be considered in the DEIS. In this second No Action condition (No Action Condition 2), it is assumed that a replacement comfort station is constructed near the project site at a location between Coney Island Avenue and Brighton 15th Street outside of both the Coastal Erosion Hazard Area (CEHA) and tidal wetland area. In both No Action conditions, a comfort station would be provided for the public beach at New Brighton since a comfort station is required to ensure compliance with the New York State Public Health Law requirements (see “Project Purpose and Need,” above, in Section C).

No Action Condition 2 assumes the installation of temporary restrooms on the boardwalk at approximately Coney Island Avenue. Under this second No Action condition, it is also assumed that the project site is cleared of the installed piles and re-graded as sandy beach without any structures. The DEIS will describe the factors guiding the location and design of No Action Condition 2.

The targeted DEIS will also identify and analyze appropriate mitigation for any identified significant adverse environmental impacts.

11 The Draft Scope of Work stated that a replacement comfort station at grade would not be compliant

with the NYC Building Code. However, upon examination of the FEMA Preliminary FIRMs, which were issued after publication of the Draft Scope of Work, it was determined that the elevation of the structure would be in compliance with the 100-year floodplain in the NYC Building Code; this is because the 100-year flood elevation in the Preliminary FIRMs is lower than it was in the ABFEs..


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The analysis year is 2014 since the New Brighton comfort station is proposed to be installed for use in the 2014 beach season.12 In the With Action condition, NYCDPR would construct the comfort station as described above in Section B, “Project Description.”

SCOPING

The CEQR scoping process is intended to focus the EIS on those issues that are most pertinent to the proposed action. The process at the same time allows other agencies and the public a voice in framing the scope of the EIS.

The Draft Scope of Work screened out those technical areas that would not have the potential for significant adverse environmental impacts (see Section E, “Environmental Impact Screening Assessment”) and set forth the analyses and methodologies proposed for the EIS (see Section F, “Scope of Work for the Targeted EIS”).

During the scoping period, those interested in reviewing the targeted EIS Draft Scope of Work and providing their comments to the lead agency were able to do so in writing or at a public scoping hearing that was held on Monday, November 18, 2013 from 6 PM to 8:00 PM at the Shorefront YM-YWHA of Brighton-Manhattan Beach located at 3300 Coney Island Avenue in Brooklyn, NY 11235. The meeting was extended to 8:30 PM to allow for all speakers to make comments.

Comments received during the public hearing and written comments received through the close of the comment period (which was held open a minimum of 10 days after the hearing) were considered and incorporated as appropriate into this Final Scope of Work.13 A summary of the comments received and responses to those comments, is provided in Appendix A. The Final Scope of Work was updated to identify an alternative No Action condition (see above), to describe the methodology to conduct an open space analysis, and to further outline the project alternatives (see below). The Final Scope of Work will be used as a framework for preparing the targeted Draft EIS (DEIS) for the proposed project.

E. ENVIRONMENTAL IMPACT SCREENING ASSESSMENT The screening assessment, provided in this section, demonstrates that the proposed replacement comfort station would not have the potential for significant adverse environmental impacts in the following areas when compared to either No Action condition: socioeconomic conditions; community facilities and services; historic and cultural resources; water and sewer infrastructure; solid waste and sanitation services; energy; transportation; air quality; greenhouse gas emissions; noise; and public health. Therefore, these analysis areas will not be discussed further in the targeted EIS.

SOCIOECONOMIC CONDITIONS

The socioeconomic character of an area includes its population, housing, and economic activity. According to the CEQR Technical Manual, a socioeconomic assessment should be conducted if a project may reasonably be expected to create substantial socioeconomic changes within the

12 Because it is anticipated that the proposed comfort station will not be installed by the start of the 2014

beach season, temporary bathrooms will be installed on the boardwalk near Coney Island Avenue to comply with the New York State Public Health Law requirements.

13 Comments received after the close of the comment period (December 2, 2013) were also considered.

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area affected by the project that would not occur in the absence of the project. Projects that would trigger a CEQR socioeconomic analysis include the following:

• Direct displacement of a residential population so that the socioeconomic profile of the neighborhood would be substantially altered.

• Direct displacement of more than 100 employees or the direct displacement of a business or institution that is unusually important.

• Introduction of substantial new development that is markedly different from existing uses, development, and activities within the neighborhood.

• Projects that are expected to affect conditions within a specific industry, such as a citywide regulatory change that could adversely impact the economic and operational conditions of certain type of businesses.

The proposed project would result in a replacement comfort station facility within a public park under the jurisdiction of the NYCDPR. The proposed project would not displace any residents or businesses, nor would it result in any residential or commercial development that could indirectly displace residents or businesses. In addition, the proposed project does not have the potential to affect conditions in a specific industry. Therefore, the proposed project would not result in any significant adverse impacts on socioeconomic conditions, and further analysis is not warranted.

COMMUNITY FACILITIES AND SERVICES

Under CEQR Technical Manual methodology, projects that would not add new residents to an area generally do not need to consider community facility impacts, unless a given project would have a direct effect on a community facility (e.g., demolition or relocation).

The proposed replacement comfort station would not result in the development of any residential units and therefore would not add demands on public education facilities, public child care facilities, or public libraries; nor significant added demands on health care facilities or police and fire services. The proposed project would not result in direct displacement of any existing community facilities. Therefore, the proposed project would not result in any development that would exceed CEQR Technical Manual thresholds for potential significant adverse impacts to community facilities and no further analysis is required.

HISTORIC AND CULTURAL RESOURCES

According to the CEQR Technical Manual, a historic and cultural resources assessment is required if a proposed project has the potential to affect either archaeological or architectural resources. Archaeological resources are the physical remains, usually subsurface, of the prehistoric (Native American) or historic periods. Architectural resources include designated New York City Landmarks; properties calendared for consideration as such; properties listed on or eligible for listing on the State and/or National Register of Historic Places (S/NR); and National Historic Landmarks.

ARCHAEOLOGICAL RESOURCES

As the replacement comfort station would be constructed predominantly within the footprint of the previously-existing comfort station, it is not anticipated that the proposed project would be developed in an area of any archaeological sensitivity. The New York City Landmarks Preservation Commission (LPC) confirmed that the proposed project would not result in any


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significant adverse impacts related to archaeological resources in a letter dated October 30, 2013 (see Appendix B).

ARCHITECTURAL RESOURCES

There are no known or potential architectural resources within the vicinity of the project site. Therefore, the proposed replacement comfort station would not have the potential to result in significant adverse impacts to architectural resources, and no further analysis is warranted. LPC confirmed this conclusion in its letter dated October 30, 2013.

WATER AND SEWER INFRASTRUCTURE

The CEQR Technical Manual outlines thresholds for analysis of a project’s water demand and its generation of wastewater and stormwater. A preliminary analysis of the proposed replacement comfort station’s effects on the water supply system is not warranted because the proposed project’s anticipated water demand would not be substantially different than the previously-existing comfort station or of a comfort station located nearby. Likewise, an assessment of the project’s effects on wastewater or stormwater infrastructure is not warranted because the proposed project would not result in new demand on sewer infrastructure, as compared to the reconstruction of the previously-existing comfort station or of a comfort station located nearby. Furthermore, the proposed comfort station would include NYCDPR water saving devices to minimize water demand and demand for sewer infrastructure.

Therefore, the proposed project would not result in any significant adverse water and sewer infrastructure impacts, and no further analysis is warranted.

SOLID WASTE AND SANITATION SERVICES

A solid waste assessment determines whether a project has the potential to cause a substantial increase in solid waste production that may overburden available waste management capacity or otherwise be inconsistent with the City’s Solid Waste Management Plan (SWMP) or with state policy related to the City’s integrated solid waste management system. The City’s solid waste system includes waste minimization at the point of generation, collection, treatment, recycling, composting, transfer, processing, energy recovery, and disposal.

The proposed replacement comfort station would not be expected to generate substantial new demand for solid waste and sanitation services, as compared to the reconstruction of the previously-existing comfort station or to a comfort station located nearby. Therefore, no further analysis is required and the proposed project would not result in a significant adverse impact related to solid waste and sanitation services.

ENERGY

According to the CEQR Technical Manual, a detailed assessment of energy impacts would be limited to actions that could significantly affect the transmission or generation of energy.

The proposed project would have a negligible effect on energy consumption, and some of the electricity required to operate the replacement comfort station would be provided by the photovoltaic panels installed on the roof. The proposed project would not significantly affect the transmission or generation of energy. Therefore, no further analysis is required and the proposed replacement comfort station would not result in a significant adverse impact related to energy.

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TRANSPORTATION

According to the CEQR Technical Manual, a transportation analysis should be conducted for projects when they have the potential to result in an increase in traffic, transit use, pedestrian activity, or parking demand. If a project is expected to result in fewer than 50 peak hour vehicle trips and fewer than 200 peak hour transit or pedestrian trips, quantified analyses are not warranted. The installation of the proposed replacement comfort station would restore permanent seasonal access to toilet and hand washing facilities to this portion of the Coney Island-Brighton Beach Boardwalk consistent with the New York State Public Health Law. The provision of a necessary beach amenity would not change the arrival and departure patterns or means of transportation of beach users. Therefore, no significant adverse transportation impacts with respect to changes in traffic patterns, transit usage, pedestrian patterns, or parking demand are expected from the proposed replacement comfort station, and no further analysis is warranted.

AIR QUALITY

According to the CEQR Technical Manual, an air quality analysis should be conducted for projects that may result in significant mobile source air quality impacts when they increase or cause a redistribution of traffic, create any other mobile sources of pollutants (such as diesel trains, helicopters, etc.), or add new uses near mobile sources (roadways, garages, parking lots, etc.). An air quality analysis should also be conducted for projects that may result in stationary source air quality impacts, such as projects that would create new stationary sources of pollutants that may affect surrounding uses (such as from emission stacks for industrial plants, hospitals, other large institutional uses, or even a building’s boilers); introduce certain new uses near existing (or planned future) emissions stacks that may affect the use; or introduce structures near such stacks so that the structures may change the dispersion of emissions from the stacks so that surrounding uses are affected.

The proposed replacement comfort station would not introduce any new mobile sources nor would it change existing vehicular patterns; therefore the project would not result in any mobile source air quality impacts. The proposed replacement comfort station would also not create a new stationary source of pollutants. Therefore, no significant air quality impacts are expected from the proposed project, and no further analysis is warranted.

GREENHOUSE GAS EMISSIONS

According to the CEQR Technical Manual, a greenhouse gas emissions (GHG) analysis is typically conducted for larger projects that have a greater potential to be inconsistent with the City’s GHG reduction goal to a degree considered significant. Examples of projects that warrant assessment include power generation projects, projects that result in development of more than 350,000 square feet, or projects that would fundamentally change the City’s solid waste management system.

The proposed replacement comfort station project would replace a previously-existing comfort station, and would not be the type of project that would have the potential to be inconsistent with the City’s GHG reduction goal as outlined in Executive Order 109 of 2007.

NOISE

According to the CEQR Technical Manual, a noise analysis could be warranted for projects that generate mobile or stationary sources of noise or that would be located in areas with high ambient noise levels that could affect the proposed project’s uses.


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The proposed replacement comfort station would replace a previously-existing comfort station, would not result in any mobile or stationary sources of noise, and would not introduce any new receptors that would be sensitive to ambient noise levels. Therefore, the proposed project would not result in any significant adverse noise impacts, and no further analysis is warranted.

PUBLIC HEALTH

According to the CEQR Technical Manual, an analysis of public health is not warranted for projects where no unmitigated adverse impact is found in other CEQR analysis areas, such as air quality, water quality, hazardous materials, or noise. Since it is anticipated that there would be no significant adverse impacts in these areas (see the screening analyses above), a public health analysis is not warranted. If, in the course of preparing the EIS analyses, a potential adverse impact is disclosed for one of the areas that contribute to public health, a public health assessment will be performed.

As mentioned previously, adequate toilet and hand washing facilities at public bathing beaches are required by New York State Public Health Law. The EIS will include a New York City Department of Health and Mental Hygiene (DOHMH) public health assessment of the New Brighton comfort station that examines the potential effect of not having a comfort station at the New Brighton location.

F. SCOPE OF WORK FOR THE TARGETED EIS As set forth by the SEQRA regulations and the CEQR Technical Manual, the installation of a replacement comfort station at New Brighton does not warrant further study or analysis in any technical area. However, there are a number of claims raised by the public and the Petitioners in Oceana Homeowners Ass’n v. City of New York et al., the underlying Article 78 Petition for the above-referenced court order. Accordingly, NYCDPR has determined that the court-directed EIS will analyze the following technical areas: open space; shadows; urban design and visual resources; natural resources; hazardous materials; neighborhood character; and construction. Therefore, assessments of likely effects in those areas of concern will be prepared and disclosed in a targeted EIS. While there are no zoning or land use approvals for the proposed project, a land use, zoning, and public policy analysis will also be prepared to provide neighborhood context and to serve as a baseline for other sections.

Overall, the EIS will contain:

• A description of the proposed project and its environmental setting;

• A statement of the environmental impacts of the proposed project, including its short- and long-term effects and typical associated environmental effects;

• An identification of any adverse environmental effects that cannot be avoided if the project is implemented;

• A discussion of reasonable alternatives to the proposed project;

• An identification of irreversible and irretrievable commitments of resources that would be involved in the proposed project should it be implemented; and

• A description of mitigation proposed to minimize any identified significant adverse environmental impacts.

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The specific areas to be included in the targeted EIS, as well as their respective tasks, are described below.

PROJECT DESCRIPTION

The project description will introduce the reader to the proposed project, give a brief history of the beach use and describe the previous comfort station. Superstorm Sandy and its effects on the beach and beach infrastructure (i.e., the comfort station) will be described and NYCDPR’s efforts to rebuild and restore the City’s beaches following Sandy. A statement of the purpose and need for the project will be included. The project description will include a summary of the design guidelines and regulatory requirements that dictate the form, dimensions, and location of the proposed comfort station.

LAND USE, ZONING, AND PUBLIC POLICY

While there are no zoning or land use approvals for the proposed project, the EIS will include a land use, zoning, and public policy chapter to provide neighborhood context and to serve as a baseline for other sections.

For this task, land uses will be described for an area within approximately 400 feet of the New Brighton comfort station site. Public policies, including the Special Initiative for Rebuilding and Resiliency (which specifically outlines the restoration of the City’s beaches as the first initiative for increasing resiliency in parks), will also be discussed.

The proposed replacement comfort station’s consistency with the New York City Waterfront Revitalization Program (WRP) was evaluated and approved by the New York State Department of State (NYSDOS) on March 7, 2013. The EIS will provide a summary of the coastal consistency form and NYSDOS’s approval and will update the evaluation of the proposed New Brighton replacement comfort station’s consistency with the WRP policies.

OPEN SPACE

The CEQR Technical Manual recommends conducting a open space assessment if a proposed action would have a direct effect on an open space; would entail the use of parkland for a non-parkland purpose; would involve the termination of use for outdoor recreation of City-owned parkland that has received federal funds for acquisition or improvement; would involve the conveyance of municipal parkland; or would add 50-350 residents or 125-750 employees to an area, depending on whether the relevant area is considered under- or well-served by open space. The project area is considered neither under- nor well-served by open space, and thus the relevant threshold for analysis would be an increase of 200 residents or 500 employees. The proposed project would not add any new residents or employees to the area. Therefore, the analysis of open space will focus on the potential for the project to directly affect open space. Questions that will be examined in the EIS include whether the project would cause the physical loss of public open space; change the use of an open space so that it no longer serves the same user population; limit public access to an open space; or cause increased noise or air pollutant emissions, odors, or shadows that would affect its usefulness, whether on a permanent or temporary basis.

SHADOWS

The CEQR Technical Manual requires a detailed assessment of project-generated shadows when a proposed action would result in new structures (or additions to existing structures) greater than 50 feet in height, or of any height if located adjacent to a sunlight-sensitive resource. Such



resources include publicly accessible open spaces, important sunlight-sensitive natural features, or historic resources with sun-sensitive features.

While the proposed replacement comfort station would be less than 50 feet in height, and while it is not expected that the project would result in shadow impacts since it would occupy a smaller footprint than the previously existing comfort station, the EIS will include a shadows assessment to disclose the difference in shadow between the proposed project and No Action Condition 1 (the previously existing comfort station). The EIS will also examine the difference in shadows between the proposed project and No Action Condition 2, in which the project site is regraded at beach level. The assessment would involve developing a base map of the project site and surrounding area, using a computer model to determine the extent and duration of shadows in both No Action conditions and the extent of new shadows, comparing the difference in shadow between the No Action and With Action conditions, and assessing the significance of any shadow impacts.

URBAN DESIGN AND VISUAL RESOURCES

Typically, as described in the CEQR Technical Manual, an assessment of urban design is needed when a project would result in a physical alteration, observable to the pedestrian, beyond that allowed by existing zoning. While there are no zoning actions needed for the replacement comfort station given the location of the project, issues relating to urban design and visual resources will nevertheless be evaluated.

The EIS analysis will consider the differences in views for the public from the boardwalk and compare the effect of the project against both No Action conditions. The analysis will include a description of the existing project area, the future No Action Conditions 1 and 2, and future With Action conditions and would present photographs, photo simulations (from the pedestrian’s perspective), and project drawings.

NATURAL RESOURCES

According to the CEQR Technical Manual, if a project involves the disturbance of a natural resource but that disturbance has been deemed insignificant by a government agency with jurisdiction over that resource and conditions have not changed significantly since the permit was issued, a natural resources assessment is not warranted. As stated above, NYCDPR received permits for its work efforts at Coney Island and Manhattan Beach, including this proposed replacement comfort station, from NYSDEC as per Article 34 of the ECL for new structures within the Coastal Erosion Hazard Area and Tidal Wetlands Permits as per Article 25 of the ECL. Therefore, an assessment is not warranted. However, the EIS will include a discussion of natural resources within the vicinity of the New Brighton replacement comfort station, which include the beach, landscaped areas on the landward side of the boardwalk, and exterior structural habitat provided by the boardwalk.

The natural resources assessment will describe the existing natural resources within the vicinity of the proposed replacement comfort station (e.g., floodplains, beach as a natural protective feature, tidal wetland adjacent area, terrestrial habitat and wildlife) on the basis of existing information and a reconnaissance visit. The assessment will also evaluate the potential for the proposed modular design, supported on piles and caissons, to result in significant adverse impacts to natural resources, particularly with respect to the natural protective features of the beach due to beach erosion, and to existing erosion control structures that may be located in the vicinity of the project site. Measures incorporated into the design of the replacement comfort station to minimize losses due to damage from flood and erosion will be described.

Final Scope of Work


HAZARDOUS MATERIALS

The EIS will address the potential presence of hazardous materials on the project site since the piles for the replacement comfort station will be extended deeper than the piles of the previously existing comfort station. The EIS will summarize the Phase I Environmental Site Assessment (ESA) that will be prepared for the project site, and will include any necessary recommendations for additional testing or other activities that would be required either prior to or during construction and/or operation of the project, including a discussion of any necessary remedial or related measures.

NEIGHBORHOOD CHARACTER

According to the CEQR Technical Manual, neighborhood character is an amalgam of various elements that give neighborhoods their distinct “personality.” These elements may include a neighborhood’s land use, socioeconomic conditions, open space, historic and cultural resources, urban design, visual resources, shadows, transportation, and noise. Not all of these elements affect neighborhood character in all cases; a neighborhood usually draws its distinctive character from a few defining elements.

An analysis of neighborhood character is warranted if a proposed project has the potential to result in significant adverse impacts in any technical area (land use, socioeconomic conditions, open space, historic and cultural resources, urban design, visual resources, shadows, transportation, and noise) or if a project would result in a combination of moderate effects to several elements that could cumulatively impact neighborhood character. Because the court-directed EIS will include analyses of several of these analysis areas, a preliminary assessment of neighborhood character will be included in the EIS. The preliminary assessment will identify the defining features of the neighborhood and assess whether the project has the potential to impact these defining features, either through the potential for significant adverse impacts or a combination of moderate effects. If the preliminary assessment concludes that the proposed project has the potential to affect defining features of a neighborhood, a detailed assessment of neighborhood character will be undertaken.

CONSTRUCTION

The construction section of the EIS will describe the construction schedule and the anticipated construction activities that remain for the replacement comfort station. The EIS will qualitatively assess how construction activities could affect traffic conditions, noise levels, and air quality conditions at nearby locations during the limited construction period. In addition, temporary construction-related impacts to natural resources, such as the potential for increased noise levels and human activity during construction of the replacement comfort station to adversely affect wildlife, will be assessed.

ALTERNATIVES

The alternatives section will assess alternatives to the proposed project in the context of the New York State Public Health Law governing bathing beaches.

Two No Action Alternatives will be considered. The first will assume reconstruction of the previously existing comfort station on the project site. The second will assume construction of a comfort station outside of the CEHA and tidal wetland area; in this alternative, the comfort station would consist of a temporary trailer located on the boardwalk at Coney Island Avenue.



In addition to the two No Action Alternatives, two Elevation Alternatives will be considered. These elevation alternatives will consider the installation of the replacement comfort station at the project site but at two different elevations.

The EIS will also consider two Location Alternatives, which will consider the installation of the replacement comfort station at two different locations between Coney Island Avenue and Brighton 15th Street. For both Location Alternatives, two elevation variations will be considered.

MITIGATION

If significant project impacts are identified in the analyses discussed above, measures will be identified and assessed to mitigate those impacts. Where impacts cannot be mitigated, they will be described as unavoidable adverse impacts.

SUMMARY CHAPTERS

In accordance with CEQR Technical Manual guidelines, the EIS will include the following three summary chapters, where appropriate:

• Unavoidable Adverse Impacts—which summarizes any significant adverse impacts that are unavoidable if the proposed actions are implemented regardless of the mitigation employed (or if mitigation is impossible);

• Growth-Inducing Aspects of the Proposed Actions—which generally refers to “secondary” impacts of a proposed actions that trigger further development; and

• Irreversible and Irretrievable Commitments of Resources—which summarizes the proposed actions and their impacts in terms of the loss of environmental resources (loss of vegetation, use of fossil fuels and materials for construction, etc.), both in the immediate future and in the long-term.

EXECUTIVE SUMMARY

The executive summary will use relevant material from the body of the EIS to describe the proposed actions, their significant and adverse environmental impacts, measures to mitigate those impacts, and alternatives to the proposed actions.

Appendix A

1 February 26, 2014

Appendix A: Response to Comments on the Draft Scope of Work

A. INTRODUCTION

This document summarizes and responds to comments on the New Brighton Comfort Station

Draft Scope of Work for a Targeted Environmental Impact Statement, issued on October 18,

2013. Oral and written comments on the Draft Scope of Work were received during a public

scoping meeting held by the New York City Department of Parks and Recreation (NYCDPR) on

November 18, 2013, from 6 PM to 8:30 PM at the Shorefront YM-YWHA of Brighton-

Manhattan Beach at 3300 Coney Island Avenue in Brooklyn. Written comments were accepted

from the issuance of the Draft Scope of Work through the public comment period, which ended

at 5 PM on December 2, 2013.1

Section B lists the elected officials, organizations, and individuals who provided comments on

the Draft Scope of Work. All oral comments were delivered during the public scoping meeting

on November 18, 2013. Section C contains a summary of these relevant comments and a

response to each. These summaries convey the substance of the comments made but do not

necessarily quote the comments verbatim. Comments are organized by subject matter and

generally parallel the structure of the City Environmental Quality Review (CEQR) Technical

Manual. Where more than one commenter expressed similar views, those comments have been

grouped and addressed together.

A number of commenters submitted general comments in support or opposition to the proposed

replacement comfort station project but did not have specific comments related to the Draft

Scope of Work. This included comments related to the construction of the proposed replacement

comfort station to date. Since the aforementioned comment period and public meeting were

related to the Draft Scope of Work, these comments were given consideration but are not

itemized below.

B. LIST OF COMMENTERS

ELECTED OFFICIALS

1. New York State Assembly Member Steven Cymbrowitz, 45th Assembly District, oral

comments.

2. Congressman Hakeem Jeffries, 8th District, New York. Oral comments delivered by Stina

Skewes-Cox, District Director.

3. New York State Senator Diane Savino, 23rd Senate District. Oral comments delivered by

Alex Later.

1 Comments received after the close of the comment period on December 2, 2013 were also considered.

New Brighton Replacement Comfort Station

February 26, 2014 2

4. Council Member Elect Chaim Deutsch, 48th New York City Council District, oral

comments.

LOCAL ORGANIZATIONS

5. Brighton Neighborhood Association. Oral and written comments delivered by Pat Singer,

Founder and Executive Director, on November 18, 2013.

6. Chabad Lubavitch of West Brighton Beach. Oral comments delivered by Rabbi Moshe

Winner.

7. Chabad Lubavitch of Manhattan Beach. Written comments submitted by Rabbi Avrohom

Winner dated November 27, 2013.

8. Coney-Brighton Boardwalk Alliance. Oral comments delivered by Rob Burstein.

9. Natural Resources Protective Association. Written comments submitted by Ida Sanoff, on

December 1, 2013.

INTERESTED PUBLIC

10. Petition #1. Undated.

11. Alter, Yelena. Written comments dated November 30, 2013.

12. Badiner, George. Written comments dated November 29, 2013.

13. Bekker, Felix. Written comments dated November 30, 2013.

14. Bekker, Genia. Written comments dated November 28, 2013.

15. Berenstein, Kira and Leon. Written comments received on January 11, 2014.

16. Blikshteyn, Anna. Written comments dated December 2, 2013.

17. Borisov, Arnold. Written comments dated November 29, 2013.

18. Bromberg, Julia. Oral comments; written comments dated November 27, 2013.

19. Brusovanik, Mike. Written comments dated November 26, 2013.

20. Bubin, Benjamin. Written comments dated November 27, 2013.

21. Budnyatsky, Yuri. Written comments dated November 26, 2013.

22. Burstein, Rob. Oral Comments

23. Cooper, Liz. Oral comments.

24. Dubrovsky, Janet. Undated.

25. Dushina, Alla. Written comments dated November 27, 2013.

26. Dvorkin, Mike. Written comments dated November 17, 2013.

27. Fisher, Aleksandr. Written comments dated November 26, 2013.

28. Fishman, Aleksandr. Written comments dated November 29, 2013.

29. Fishman, Victoria. Written comments dated November 29, 2013.

30. Fiterson, Norman. Written comments dated November 29, 2013.

Appendix A: Response to Comments on Draft Scope of Work

3 February 26, 2014

31. Galbmillon Family. Written comments dated November 26, 2013.

32. Galbmillion, Lana. Oral comments;

33. Galbmillion, Mark. Written comments dated November 26, 2013 and November 28, 2013.

34. Galinsky, Serafima. Written comments dated November 27, 2013.

35. Geisler, Mordechai and Rita. Written comments dated December 2, 2013.

36. Geyber, Dmitry. Oral comments; written comments dated November 26, 2013.

37. Gofman, Elizabeth. Written comments dated November 29, 2013.

38. Golan, Yuval. Written comments dated November 29, 2013.

39. Goykhin, Galina. Written comments dated November 30, 2013.

40. Kantor, Boris. Written comments dated November 17, 2013; oral comments.

41. Karatchounov, Alexandre. Written comments dated November 27, 2013.

42. Karetsky, Ilya. Written comments dated November 20, 2013 and November 26, 2013.

43. Katsnelson, Joseph. Written comments received on December 19, 2013.

44. Khavulya, Anna. Written comments December 2, 2013.

45. Khavulya, Mirra. Oral comments.

46. Kitovsky, Leonid. Oral comments; written comments dated November 28, 2013.

47. Kolyachko, Mayya. Written comments dated December 2, 2013. General opposition

comment; no specific attribution is included in the comments listed below.

48. Kravis, Irina. Written comments dated December 2, 2013.

49. Kuperman, Max. Written comments dated November 30, 2013 and second set of undated

comments.

50. Makagon, Alla. Written comments dated December 2, 2013.

51. Makagon, Jane. Undated.

52. Makagon, Larisa. Written comments dated November 27, 2013.

53. Makagon, Osip. Undated.

54. Makchnin, Yelena. Oral comments.

55. Maksin, Natalie. Written comments dated November 28, 2013.

56. Medvedovsky, M. Written comments dated December 1, 2013.

57. Milter, Lenny. Written comments dated November 20, 2013.

58. Miskin, Karl. Written comments dated November 27 and November 30, 2013.

59. Miskina, Tamara. Written comments dated November 27 and November 30, 2013.

60. Natkovich, Anna. Written comments dated November 29, 2013.

61. Natkovitch, Boris. Oral comments; written comments dated November 28, 2013.


February 26, 2014 4

62. Natkovitch, Inna. Written comments dated November 29, 2013.

63. Natkovitch, Samuel. Written comments dated November 29, 2013.

64. Natkovich, Yuriy. Written comments dated November 27, 2013.

65. Oceana Homeowners Association, comments submitted by David Yudelson on December 2,

2013.

66. Oceana Voice. Written comments dated December 1, 2013; undated Petition #1; Petition #2,

dated September 2013.

67. Olson, Irene M. Oral comments.

68. Oudolsky, Peter. Written comments dated November 20 and November 29, 2013.

69. Oz, Shlomo. Written comments dated November 26, 2013.

70. Pallen, Fay. Written comments received December 5, 2013.

71. People of Oceana. Written comments dated November 17 and December 2, 2013.

72. Persits, Yelena. Written comments dated November 26, 2013.

73. Pichugov, Sergey. Written comments dated December 1 and December 2, 2013.

74. Plut, Raisa and Arkady. Written comments received 12/2/2013.

75. Podvisoky, Fima. Written comments dated November 28, 2013.

76. Podvisoky, Maria. Written comments dated November 28, 2013.

77. Polissky, Galina. Written comments dated November 26, 2013.

78. Rabinovich, Benjamin. Written comments dated November 28, 2013.

79. Rabinovich, Ella. Written comments dated November 28, 2013.

80. Rosen, Allan. Oral comments.

81. Sanoff, Ida. Oral comments.

82. Sattlar, Jerry. Oral comments.

83. Scott, Joe. Oral and written comments dated November 18, 2013.

84. Segal, Tatyana. Oral comments. Written comments dated November 21, 2013.

85. Senders, Michael. Written comments dated December 1, 2013.

86. Shaov, Stan. Written comments dated November 30, 2013.

87. Shaova, Lana. Written comments dated November 30, 2013.

88. Shapiro, Alla. Written comments dated December 2, 2013.

89. Shapiro, Victoria. Written comments dated November 30, 2013.

90. Sherbakova, Anna. Witten comments dated December 2, 2013.

91. Shevchenko, Liubov. Written comments dated November 29, 2013.

92. Shilkrot, Marina. Undated


5 February 26, 2014

93. Shilman, Dimitri. Written comments dated November 29, 2013.

94. Sikar, Felix. Oral comments.

95. Soroka, Dina. Written comments dated November 29, 2013.

96. Spivak, Irina, Written comments dated December 1, 2013.

97. Stalb, Elaine. Written comments dated November 23, 2013.

98. Suler, Vadim. Written comments dated November 17, 2013.

99. Surcov, Igor. Written comments dated November 30, 2013.

100. Tokarsky, Mordechai. Written comments dated November 27, 2013.

101. Trotta, Eileen L. Oral comments.

102. Usher, David. Written comments received December 5, 2013.

103. Usher, Mikhail. Written comments dated December 1, 2013.

104. Ustilovsky, Alex. Oral comments.

105. Vafakos, William. Oral comments; written comments dated November 26, 2013.

106. Vidal, Monique. Written comments dated November 25, 2013.

107. Vidal, Sara. Written comments received November 23 and November 26, 2013.

108. Vidal, Victor. Written comments dated November 25, 2013.

109. Voldman, Alex. Written comments November 29, 2013.

110. Vulakh, Alex. Oral comments.

111. Vulfsone, Emma. Written comments dated November 27, 2013.

112. Zeleny, Grigory. Oral comments; written comments dated December 2, 2013.

113. Zelyony, Adeline. Written comments dated November 29, 2013.

C. COMMENTS AND RESPONSES

ENVIRONMENTAL REVIEW PROCEDURES AND ANALYSIS FRAMEWORK

Comment 1: Contrary to the claims in the Draft Scope, “the preparation of [a] targeted EIS

for the New Brighton Comfort Station” was not “directed by [the] New York

State Supreme Court…” The Court’s Order makes no mention of a “targeted

EIS,” and does not direct the NYCDPR to do anything. The Court gave

NYCDPR a choice to either wait for the Court’s final decision or prepare an EIS

(a decision the Homeowners Association supports), in strict compliance with the

requirements set forth in the New York State Environmental Quality Review

Act (SEQRA), its implementing regulations, and the New York City

Environmental Quality Review (CEQR) rules. (Oceana Homeowners

Association)


February 26, 2014 6

Response: The Court directed that work on the New Brighton Comfort Station was “stayed

pending final decision by the Court on the Article 78 Petition or publication of

an environmental impact statement for New Brighton whichever occurs first.”

The Court has not issued a final decision on the Article 78 proceeding. For the

reasons set forth in the Draft and Final Scopes of Work, NYCDPR, as lead

agency, determined it was appropriate to conduct a targeted EIS based upon the

guidance of the CEQR Technical Manual, in accordance with both SEQRA and

CEQR.

Comment 2: The Draft Scope repeatedly asserts that the Proposed Project is exempt from

environmental review and “does not warrant further study or analysis.” The

Coastal Erosion Hazard Areas Act expressly requires that construction on the

beach undergo SEQRA review. (Oudolsky, Oz)

Response: NYCDPR has complied with the requirements of construction within the

Coastal Erosion Hazard Area (CEHA) by designing the structure to be suitable

for placement within the CEHA, and the proposed project has already received

authorization from NYSDEC under CEHA. Furthermore, as stated in response

to Comment 1, NYCDPR is conducting an EIS for the proposed replacement

comfort station pursuant to SEQRA, in accordance with the above-mentioned

Court Order. Utilizing the guidance of the CEQR Technical Manual, and with

the above understanding, the Draft and Final Scopes of Work provide the

reasoned basis for NYCDPR’s determination, in accordance with

SEQRA/CEQR, with regard to the areas that would and would not be analyzed

in the EIS prepared under this order from the Court. As noted in the Final

Scope of Work, the EIS will analyze the following technical areas:

Land Use, Zoning, and Public Policy

Open Space

Shadows

Urban Design and Visual Resources

Natural Resources

Hazardous Materials

Neighborhood Character

Construction

Comment 3: NYCDPR has proposed and NYSDEC must approve the proposed project.

Thus, both are involved agencies and a decision needs to be made on whether

NYCDPR or NYSDEC will be lead agency. Only after establishing the lead

agency can scoping commence. No notices of proposed lead agency have been

issued, no lead agency has been established and the coordinated review

provisions have not been complied with. NYCDPR cannot simply declare itself

the lead agency by unlawfully excluding NYSDEC and other agencies from the

Project’s environmental review. (Oudolsky, Oz, Oceana Homeowners

Association)


7 February 26, 2014

NYCDPR must restart the process with the designation of a lead agency, and

reissuance of a revised Draft Scope that incorporates the changes outlined in our

comments. (Oudolsky, Oz)

NYSDEC must be established as a lead agency. (Bromberg, Rabinovich,

Fishman, Golan, Galbmillion, Shaova, Pichugov, Bekker, Gofman, Voldman,

Vidal, M., Kahvulya, A., Makagon, A.)

The Draft Scope shuts out involved agencies, including but not limited to

NYSDEC, out of the SEQRA review process. Because NYSDEC is responsible

for the Proposed Project’s environmental permitting, it must be involved in the

Proposed Project’s SEQRA review. (Oceana Homeowners Association)

Response: NYCDPR has complied with SEQRA procedures. NYCDPR is the agency

“principally responsible” for carrying out and funding the proposed project and

is therefore the appropriate agency to serve as the lead agency for the

environmental review. The purpose of the regulations cited by the commenters

is to ensure that each agency that has an approval role in the project is aware of

the project and to inform them of which agency intends to serve as the lead

agency. NYSDEC is a party to the lawsuit under which preparation of this EIS

was ordered, and appeared in Court through its counsel at the Office of the

Attorney General of the State of New York. Accordingly, NYSDEC is aware of

the proceedings and order concerning the proposed replacement comfort station.

NYSDEC agreed that NYCDPR would act as the lead agency and NYCDPR

codified its determination in writing to NYSDEC when it issued its Draft Scope

of Work. It bears noting that NYCDPR is preparing the EIS pursuant to the

SEQRA procedures for a Type I action. NYSDEC has been provided, and will

continue to be provided, the opportunity to participate in the review of the EIS

as an involved agency in accordance with the SEQRA/CEQR regulations.

Comment 4: Parks has selected an improper baseline for its environmental analysis. Parks

has assumed that, in the absence of the proposed project, the bathrooms

destroyed by Tropical Storm Sandy would instead be reconstructed in their prior

location. Even if reconstruction of the previously existing bathrooms were not

prohibited by current codes and requirements, such construction could not occur

as-of-right within a Coastal Erosion Hazard Area. It therefore cannot be

considered the “no action” condition under CEQR which includes only

construction that “would occur under existing zoning on an as-of-right basis.”

(Oudolsky, Voldman, Oz, Vidal, Makagon, A., Oceana Homeowners

Association, Vulakh)

A no action alternative for SEQRA review must be the project site without any

new construction or improvements, and cleared of any construction materials or

piles associated with the proposed restrooms. (Oudolsky, Voldman, Oz, Vidal,

Makagon, A., Geyber, Bromberg, Rabinovich, Fishman, Golan. Galbmillion,

Oceana Homeowners Association, Vulakh)


February 26, 2014 8

Response: In response to comments received at the public scoping meeting, the EIS will

contemplate two No Action conditions for the 2014 analysis year. In both No

Action conditions, a comfort station would be provided for the beach at New

Brighton to ensure compliance with the New York State Public Health Law. The

two No Action conditions are as follows:

No Action Condition 1: In No Action Condition 1, it is assumed that the

comfort station that existed prior to being damaged beyond repair by

Superstorm Sandy would be reconstructed on the site at beach level.

No Action Condition 2: In No Action Condition 2, it is assumed that a

replacement comfort station is constructed near the project site at a location

between Coney Island Avenue and Brighton 15th Street outside of both the

Coastal Erosion Hazard Area (CEHA) and tidal wetland area. No Action

Condition 2 assumes the installation of temporary restrooms on the

boardwalk at Coney Island Avenue. Under this No Action condition, it is

also assumed that the project site is cleared of the installed piles and re-

graded as a sandy beach without any structures.

Both No Action conditions are consistent with the New York State Public

Health Law requirement that NYCDPR provide adequate toilet and

handwashing facilities at New Brighton beach, which is a bathing beach.

The Final Scope of Work will reflect the addition of this second No Action

alternative and the EIS will describe the factors guiding the location and design

of this and other alternatives.

Comment 5: Originally, proper notice was not given to the public for the first scoping

meeting, and this meeting is scheduled for a time that makes it very difficult for

the working people of the community to attend and have their voices heard.

(Savino)

Response: Notice of the public scoping meeting held on November 18, 2013 was given in

accordance with CEQR procedures which dictate that a public scoping meeting

be held no less than 30 and no more than 45 days after a draft scope of work is

published. The Draft Scope of Work has been posted on the NYCDPR website

since its release on October 18, 2013, a full 31 days in advance of the public

scoping meeting. The time and place of the public scoping meeting were

published in the City Record (the official publication of the City of New York)

on October 18, 2013, the New York Post (a New York City daily newspaper) on

October 18, 2013, and the Russian Baazar (a local Russian-language paper) on

October 17, 2013. The public scoping meeting took place in a public location

within the affected community and was scheduled from 6 PM to 8:00 PM, after

typical business hours; the meeting was extended to 8:30 PM to allow for all

speakers to make comments. Those wishing to submit comments on the Draft

Scope of Work did not have to attend the public scoping meeting. Public

comments were accepted via email, fax, or mail until December 2, 2013.


9 February 26, 2014

NYCDPR also considered comments received after the close of the comment

period.

Comment 6: Several commenters requested an extension of the comment period.

(Brusovanik, Galinsky, Chabad of Manhattan Beach, Tokarsky)

Response: The duration of the public comment period is consistent with CEQR procedures,

which dictate that the public comment period for a draft scope of work begins

when the draft scope is issued and extends for a minimum of 10 days after the

public scoping meeting. In this case, the public comment period began on

October 18, 2013 and extended until December 2, 2013, 14 days after the public

scoping meeting and for a total of 45 days. NYCDPR also considered comments

received after the close of the comment period.

Comment 7: Senior citizens, many of whom can’t read English, comprise a significant

portion of Oceana and Seacoast Terrace. We demand publication of the Draft

EIS in Russian, Hebrew, and Chinese. (Brusovanik, Galinsky, Chabad of

Manhattan Beach)

Response: NYCDPR will not be providing the DEIS in languages other than English, but is

cognizant of the prevalence of the Russian speaking population in particular,

located within Brighton Beach and near the project site. Parks will provide a

general project summary translated into Russian on its website at:

http://nyc.gov/parks/brighton-beach

and as was done for the issuance of the Draft Scope of Work and notice of

public meeting regarding the Draft Scope of Work, will provide a notice in a

Russian-language paper once the public meeting on the DEIS is scheduled.

PROJECT PURPOSE AND NEED

Comment 8: Who will come to this beach, who will use those toilets? (Milter)

Who approved those structures? Did somebody look at the pictures and specs

and say “Wait! Why do we need them? What is the purpose?” (Budnyadsky)

The restroom at this location is lightly used. I question the need for a restroom

here. (Stalb)

This facility and the process by which it has been built is completely counter to

many of NYCDPR’s own guidelines and regulations in locating and

constructing a facility such as this. (Savino)

Response: As discussed in the Draft Scope of Work and clarified in the Final Scope of

Work, the restoration of a comfort station at this location is a key part of

NYCDPR’s post-Sandy recovery efforts. In addition, the presence of a comfort

station to serve the beach area is required by New York State Public Health

http://nyc.gov/parks/brighton-beach



Law. Furthermore, the proposed replacement comfort station is replacing one

that operated for more than 70 years at this location until it was damaged

beyond repair by Superstorm Sandy. Replacing a facility in the same location is

compliant with NYCDPR’s guidelines and regulations.

The EIS will address the purpose and need for the project and will describe the

project approvals. The EIS will include information about beach visitors. The

EIS will also include information about the guidelines and regulations that have

informed the proposed design and location of the project, including a Public

Health Assessment conducted by the New York City Department of Health and

Mental Hygiene (DOHMH), which outlines the need for the proposed

replacement comfort to serve the Brighton Beach area.

Comment 9: NYCDPR made unauthorized changes to the initial design and in its own memo

stated that it expected its actions would incite major community opposition.

(Savino)

Response: This is not a comment on the Draft Scope of Work. The EIS will analyze the

New Brighton comfort station as proposed.

PROPOSED REPLACEMENT COMFORT STATION DESIGN, PLACEMENT, AND

OPERATIONS

Comment 10: When community residents inquired about alternate locations for the placement

of the comfort station, they were erroneously told that FEMA required the

station to be built at the original location in order to get reimbursed. This

representation appears to be inaccurate. A letter sent from the agency’s Federal

Coordinating Officer Willie G. Nunn on July 19, 2013 states that “FEMA does

not regulate a project’s design or location.” (Jeffries)

NYCDPR misrepresented a FEMA requirement to construct the elevated

bathrooms at the current location. (Rabinovich, Fishman, Golan, Shapiro,

Spivak, Podvisoky, Maksin, Zelyony, Natkovitch, B., Natkovich, Y., Pichugov,

Sherbakova, Bekker, Shevchenko, Miskin, Fiterson, Blickshteyn, Kravis,

Khavulya, A., Makagon, A., Makagon, J., Makagon, O., Dubrovsky, Senders,

Shilkrot, Usher, D.)

Response: While the commenters are correct that the Federal Emergency Management

Agency (FEMA) does not dictate the specific location of its funded projects,

locating the proposed replacement comfort station within its previous footprint

increases the likelihood for federal approval of the costs associated with the

proposed project.

Comment 11: This new facility will be open year around as opposed to only during the

summer. (Savino, Oceana Voice Petition #3)



Response: It is anticipated that the proposed replacement comfort station will not be open

year round, but during the following hours: Memorial Day to July 4th from

9AM to 7PM and July 4th to Labor Day from 9AM to 8PM. These hours are

similar to those for the comfort station at New Brighton that was damaged

beyond repair by Superstorm Sandy.

Comment 12: The location of the comfort station at the most narrow portion of the boardwalk

is inappropriate and unacceptable. (Rabinovich, B., Goykhin, Fishman, A.,

Fishman, V., Natkovich, A., Miskin, Kravis, Pichugov, Sherbakova, Khavulya,

A., Makagon, A., Blikshteyn, Dubrovsky, Shilkrot, Pallen)

Response: The proposed comfort station is replacing one that operated for more than 70

years at this location until it was damaged beyond repair by Superstorm Sandy.

As noted above, the EIS will also include information about the guidelines and

regulations that have informed the proposed design and location of the project,

including a Public Health Assessment conducted by the New York City

Department of Health and Mental Hygiene, outlining the need for the proposed

replacement comfort station at or near its current location. The EIS will evaluate

the location of the proposed replacement comfort station in relation to the

boardwalk, including any effects on the amenities and use of the boardwalk as

an open space resource.

Comment 13: Several commenters expressed concern about maintaining previously existing

direct access from the Oceana complex to the beach and ocean. This access has

been closed since the construction of the replacement comfort station began.

(Savino, Oceana Voice, Trotta)

This facility blocks the only direct route to the beach for disabled and elderly

individuals from the boardwalk by Coney Island Avenue and Seacoast Terrace.

Elderly and disabled individuals would have to walk a couple blocks down the

beach or down the boardwalk around this comfort station to get on and off the

beach, respectively. This is an unnecessary demand to place upon these

individuals when they want to use the beach. (Savino)

Response: Access to the beach from the boardwalk area immediately to the west of the

project site and private access under the boardwalk from the Oceana residential

development has been closed since the start of construction of the replacement

comfort station; these access points have been closed because of temporary

staging areas needed for the construction of the replacement comfort station and

for other post-Sandy beach restoration activities. Ramp access to the beach is

currently available to the east of the project site. Overall, access to the beach is

restricted in the project area during construction and would be restored after the

proposed replacement comfort station is completed. Upon completion of

construction, the proposed project would not affect access to the beach from the

boardwalk at any location, including the ones mentioned by the commenters.



ENVIRONMENTAL IMPACT SCREENING ASSESSMENT AND SCOPE OF WORK

FOR A TARGETED EIS

Comment 14: NYCDPR’s decision to screen out entire categories of impacts from

environmental review is inconsistent with SEQRA. All 19 impact categories

included in the City Environmental Quality Review Technical Manual must be

documented in the DEIS. (Geyber, Rabinovich, Fishman, Golan, Galbmillio n,

Shaova, Bekker, Gofman, Voldman, Vidal, M., Pichugov, Sherbakova,

Khavulya, A., Khavulya, M., Makagon, A., Oudolsky, Oz, Zeleniy, Oceana

Homeowners Association, Cooper, Ustilovsky)

Response: The scoping process for the proposed project is intended to focus the EIS on

those issues that are most pertinent to the project, consistent with the guidance

of the CEQR Technical Manual. SEQRA, implemented in New York City under

CEQR, does not require an EIS to analyze every impact category. As noted in

the CEQR Technical Manual (page 1-11), a lead agency is encouraged to target

a scope of work and exclude issues from the EIS that are unlikely to result in

potential significant adverse impacts. The Draft Scope of Work determined

whether or not an EIS assessment was appropriate for each of the 19 CEQR

Technical Manual impact categories, and provided a rationale for excluding

impact categories from the EIS due to their inapplicability to the proposed

project. The scoping process also allows other agencies and the public a voice in

framing the scope of the EIS. As a result, the EIS avoids conducting

unnecessary analyses and provides decision-makers and the public with a more

useful environmental review. In response to public comments, the Final Scope

of Work was updated to include an Open Space assessment in the EIS.

Comment 15: The EIS must include an analysis of whether the bathrooms can withstand a

storm or rising sea level without becoming dislodged and floating or crashing

into the adjoining property and buildings and what would the impacts be if it

happened. The same holds true for its exterior sheathing and components. The

EIS must consider:

what conditions would lead to the detachment of the ramp and/or stairs;

what are the potential impacts to the beach environment, surrounding

property, or public safety should the ramps/stairs become dislodged;

the extent to which such impacts could be mitigated by an alternative project

design or location; and

what happens if the ramp and or stairs fail to dislodge.

The EIS must also consider scientific, test and field data establishing the ability

of the structures to withstand wind, waves, inundation and projectile debris

(Oudolsky, Oz, Oceana Homeowners Association)



If the staircases and ramps to the bathrooms break away during a future storm

event – as they have been designed to do – they will damage property and injure

people. (Oudolsky, Cymbrowitz, Maksin, Bromberg, Rabinovich, Karetsky,

Segal, Kuperman, Surcov, Shapiro, A., Shapiro, V., Usher, Oceana Voice,

Spivak, Bekker, F., Bekker, G., Kitovsky, Miskina, Alter, Badiner, Gofman,

Dushina, Voldman, Soroka, Borisov, Oz, Vidal, M., Stalb, Kravis, Pichugov,

Sherbakova, Khavulya, A., Makagon, A., Vulfsone, Plut, Medvedovsky,

Natkovitch, I., Natkovitch, S., Shaov, Shilman, Katsnelson, Berenstein)

Response: The EIS will describe the design of the modular units, their piling system, and

that of the stairs and ramps with respect to the NYC Building Code and

American Society of Civil Engineers standards for Flood Resistant Design and

Construction. The description will also include the Federal Emergency

Management Agency (FEMA) Best Available Flood Hazard Data for the project

site in evaluating whether the proposed replacement comfort station has the

potential to alter flood levels, flood risk, or the flow of flood waters in the

surrounding area.

PROJECT DESCRIPTION

Comment 16: The Project Description section of the EIS must include:

A description of the previously existing restrooms on site, and other

restrooms that existed along the Coney Island beach prior to Tropical Storm

Sandy;

A detailed description of the specific impacts of Tropical Storm Sandy on the

previously existing restroom and other restrooms along the Coney Island

beach, with photographs and post-Sandy engineering/inspections reports

appended to the EIS;

An estimate of how much repairs to restore the previously existing restroom

to service would have cost, and a description of what such repairs would

have entailed;

A detailed description of any engineering or geological obstacles

encountered during prior construction activities associated with the proposed

project, and any response thereto;

A description of any regulatory provisions that preclude the reconstruction of

the previously existing restroom beneath the Coney Island Boardwalk;

The precise distance between the proposed project and the existing restroom

at Brighton 2nd Street;

The location of and maximum distance between restrooms along the

westernmost part of the Coney Island beach (west of Steeplechase Pier);

The number of operational restrooms on the Coney Island beach, before and

after Tropical Storm Sandy. (Oceana Homeowners Association)



Response: The EIS will include a description of those issues relevant to this environmental

review, including the previously-existing comfort station; a map showing the

location of the Coney Island beach comfort stations with information about how

they fared during Superstorm Sandy; a description of the damage sustained by

the previously-existing comfort station; the geotechnical report undertaken for

the project site; and a description of the regulations, including those

promulgated by the New York City Department of Health and Mental Hygiene,

that informed the location and design of the proposed replacement comfort

station.

LAND USE, ZONING, AND PUBLIC POLICY

Comment 17: NYCDPR falsely claims that “there are no zoning or land use approvals for the

proposed project,” when under state law all construction on a beach requires a

permit under the Coastal Erosion Hazard Areas Act. (Oudolsky, Oceana

Homeowners Association)

Response: The Draft Scope of Work correctly states that no additional zoning or land use

approvals are required for the proposed project. Potential impacts from the

proposed project on the New York State Department of Environmental

Conservation (NYSDEC) Coastal Erosion Hazard Areas (CEHA) will be

evaluated in the Natural Resources chapter of the EIS. NYCDPR received

permits for work at Coney Island and Manhattan Beach from NYSDEC for new

structures within the CEHA; permits for the work in Coney Island were

renewed, though the proposed change in method for installing the 12 remaining

piles at the site remains pending before NYSDEC.

Comment 18: This construction violates NY State Coastal Policies. It detracts from

surrounding community and creates odors, noise, and traffic (Policy 2); detracts

from views of the water (Policy 1, 4); creates risk of damage to property and

endangering human life (Policy 11); adversely impacts economic/social interests

of adjacent community (Policy 18); and closes existing access to the beach

(Policy 20). (Geyber, Voldman)

Response: The proposed replacement comfort station is not new. It is replacing a comfort

station that operated for more than 70 years at this location until it was damaged

beyond repair by Superstorm Sandy. The proposed project was evaluated and

approved by the New York State Department of State (NYSDOS) on March 7,

2013 as part of NYCDPR’s larger beach restoration program; however, the EIS

will include an evaluation of the proposed project’s consistency with the

applicable policies of the New York City Waterfront Revitalization Plan, the

Local Waterfront Revitalization Program (LWRP) approved by the New York

State Department of State, Office of Planning and Development, for New York

City.



SOCIOECONOMIC CONDITIONS

Comment 19: We paid top dollars for our community. We’re dealing with a problem where

our property values are being destroyed. (Vulakh)

I’m paying a lot of taxes to New York City. But my windows are facing this

possible bathroom that you’re about to build. And if that will take place, I will

have no choice, since you’re trying to change my quality of life, I’ll have no

choice but to move to the State of New Jersey. (Kitovsky)

By building a three-story-high bathroom right in front of the Oceana residents’

bedroom windows, the City is blatantly disregarding and violating this

paramount covenant that private property owners are supposed to have. It takes

time and effort to build a prosperous and thriving development right in the

middle of the City, but it is very easy to bring it to a deteriorating state when

homeowners start selling their apartments and move away to other places.

(Segal)

Response: A project’s effects on views from private property and on individual property

values are not within the purview of environmental review under CEQR. The

purpose of the EIS is to analyze environmental impacts and to identify

alternatives and mitigation measures to avoid or lessen those impacts. Since the

definition of “environment” includes community character, the EIS will include

an assessment of the project’s potential impact on those elements that help

define neighborhood character (e.g., land use patterns, urban design, visual

resources) and that may relate to quality of life concerns. From a socioeconomic

conditions perspective, as described in the screening assessment included as part

of the Draft and Final Scopes of Work, the proposed project does not meet

criteria warranting assessment; the proposed project, which replaces a facility

that was damaged beyond repair by Superstorm Sandy, would not introduce a

substantial new residential or commercial use that would offset positive trends

in the study area, to impede efforts to attract investment to the area, or to create

a climate for disinvestment.

OPEN SPACE

Comment 20: NYCDPR falsely claims that constructing 1,710 square feet of new bathroom

facilities on the beach “would not have a direct effect on open space,” when the

CEQR Technical Manual provides that if a project “result[s] in a physical loss

of public open space (by encroaching on an open space or displacing open

space)” then at the very least “a preliminary [open] space assessment is

warranted and, depending on the results of that assessment, a more detailed

analysis may also be required.” (Oudolsky, Oz, Oceana Homeowners

Association)



Response: The proposed replacement comfort station is not a new facility, but is replacing

a comfort station that operated at the same location for over 70 years.

Nevertheless, based on public comments, an analysis of Open Space will be

undertaken in the EIS. The Final Scope of Work will reflect this addition.

SHADOWS

Comment 21: In its proposed analysis of the proposed project’s shadow and visual resource

impacts, the Draft Scope compares the impacts of the Proposed Project to the

previously existing restroom. The proposed project’s impacts must be compared

to the site as it currently stands (and cleared of any construction materials).

(Oceana Homeowners Association)

Response: See response to Comment 4, which notes that in response to comments received

at the public scoping meeting, the EIS will contemplate two No Action

conditions for the 2014 analysis year. In No Action Condition 2, it is assumed

that temporary restrooms would be installed on the boardwalk at Coney Island

Avenue and that the project site would be cleared of the installed piles and re-

graded as sandy beach with no structures. The shadows analysis will examine

the difference in shadow increments between the proposed project and both No

Action conditions, including No Action Condition 2 as the commenter suggests.

HISTORIC AND CULTURAL RESOURCES

Comment 22: The Draft Scope screens out potential impacts on architectural resources in

violation of the CEQR Technical Manual, which provides “architectural

resources should be surveyed and assessed if the proposed project would result

in any of the following, whether or not any known historic resources are located

near the site of the project: New construction, demolition, or significant physical

alteration to any building, structure, or object...A change in scale, visual

prominence, or visual context of any building, structure, or object or landscape

feature ... Screening or elimination of publicly accessible views.” (Oudolsky,

Oz, Oceana Homeowners Association)

Response: According to the CEQR Technical Manual, for projects that may affect historic

and cultural resources—such as the types of projects defined in the comment—

the first step in evaluating a project’s potential effects on historic resources is to

consider what area the project might affect and then identify historic

resources—whether officially recognized or eligible for such recognition—

within that area. Historic and cultural resources include both archaeological and

architectural resources. As described in the Final Scope of Work, the project’s

area of potential effect for archaeological resources was defined as the footprint

of the proposed replacement comfort station. As written in an Environmental

Review Letter dated October 30, 2013, the New York City Landmarks

Preservation Commission (LPC) has determined that the project site has no



archaeological significance. Therefore, no further consideration of

archaeological resources is warranted.

For architectural resources, the CEQR Technical Manual notes that a 400-foot

study area around the project site is adequate for most proposals. Following the

guidelines of the CEQR Technical Manual, architectural resources include:

designated New York City Landmarks, Interior Landmarks, Historic Districts,

Scenic Landmarks, properties that have been considered for designation

(“heard”) by LPC at a public hearing or calendared for consideration at such a

hearing (these are “pending” landmarks), and properties LPC has determined to

be appear eligible for designation; properties listed on the State and National

Registers of Historic Places (S/NR) or properties determined eligible for S/NR

listing; resources recommended by the New York State Board for S/NR listing;

National Historic Landmarks (NHLs); and other properties that meet the

eligibility requirements for Landmark designation or S/NR listing (these are

“potential” architectural resources). There are no known or potential

architectural resources within 400-feet of the project site, and LPC concurred

within this fact in the Environmental Review letter dated October 30, 2013.

Therefore, as described in the Final Scope of Work, the proposed project would

not have the potential to result in significant adverse impacts to architectural

resources, and no further analysis is warranted.

The EIS will consider the project’s potential impact on public views in the urban

design and visual resources analysis.

URBAN DESIGN AND VISUAL RESOURCES

Comment 23: I oppose this facility because it is not in line with the character and personalities

of the buildings around it. The facility does not look like it belongs in the

neighborhood in which it is located. (Savino)

When I saw the modules, I thought that they do not belong in this neighborhood.

(Sattlar)

Response: The urban design and visual resources analysis will consider whether the

proposed project would significantly adversely affect any elements of the urban

design or the visual character of the project site and surrounding area.

Comment 24: If elevated bathrooms are installed in their proposed location, they will obstruct

public views of the Atlantic Ocean and Gateway National Recreation Area.

(Oceana Voice, Oceana Homeowners Association)

Response: The urban design and visual resources analysis will consider the project’s

potential impact on public views of the Atlantic Ocean and the Gateway

National Recreation Area.



Comment 25: The new comfort station would produce light pollution when its bright lights

shine into residential apartment windows at night. (Pichugov, Sherbakova)

Response: There would be no external lights planned for the proposed replacement comfort

station. The Project Description in the EIS will reflect this fact.

Comment 26: Aesthetic considerations are very important when designing public parks and

recreational areas and absolutely cannot be ignored in this case. (Pichugov,

Sherbakova)

Response: The EIS will include an urban design and visual resources analysis. Under

the CEQR Technical Manual, an analysis of urban design and visual resources

analysis includes consideration of aesthetic issues.

NATURAL RESOURCES

Comment 27: With respect to natural resources, the Draft Scope states: “the natural resources

assessment will describe the existing natural resources within the vicinity of the

proposed project ... on the basis of existing information and a reconnaissance

visit.” This is not the methodology set forth in the CEQR Technical Manual,

which recommends “at least two seasonal (late spring/early summer and early

fall) surveys” to determine existing natural resource conditions. “Additional

seasonal surveys may be warranted as determined by the information generated

from these seasonal surveys.” A full natural resources assessment, including at

least two seasonally appropriate field surveys, must be conducted to properly

identify wildlife and other natural resources that may be adversely affected by

the proposed project. Such an analysis is particularly necessary in light of the

potentially cumulative impacts on natural resources, and specifically flora and

fauna, from the numerous other elevated bathrooms that were constructed on

New York City beaches following Tropical Storm Sandy. (Oceana Homeowners

Association)

Response: Section 300 (Assessment Methods) of Chapter 11 (Natural Resources) of the

CEQR Technical Manual recommends that at least two seasonal surveys should

be conducted, depending on the habitat type, as demonstrated by the uniqueness,

variety, and density of its species; its use for recreation, open space or

commerce; its relationship to neighboring resources and to the overall area

ecosystem; or its role in promoting ecosystem services or storm and flood

management. On the basis of the nature of the existing habitat as an urban

bathing beach consisting of sand with limited vegetation located adjacent to an

existing boardwalk, and the high level of disturbance of this setting, the natural

resources are limited, and it was determined that the results of one survey,

combined with information from additional sources (see CEQR Technical

Manual, Chapter 11, Section 320), would be sufficient to characterize the

existing natural resources within and adjacent to the project site.



As discussed in the response to Comment 49, the preparation of an EIS for the

proposed replacement comfort station was mandated by an order of the New

York State Supreme Court. The order directs that an EIS be prepared for the

proposed replacement comfort station at New Brighton. The other comfort

stations noted by the commenters have already been constructed as

replacements for damaged comfort stations at those locations. The natural

resources within the project site, including fauna and flora, are limited due to the

urban nature of the beach, location next to the boardwalk, and the high level of

pedestrian traffic; in addition, the area of disturbance for the project is small in

comparison to the total area of beach on Coney Island and the intervening area

of beach between the New Brighton comfort station and the next closest station

(i.e., West 8th Street, approximately 1 mile away). Consequently, the proposed

project would not have the potential to result in cumulative impacts on natural

resources.

WATER AND SEWER INFRASTRUCTURE

Comment 28: The EIS must assess the increased demands on water supplies and sewer

infrastructure associated with the proposed project. (Oceana Homeowners

Association)

Response: As described in the Draft Scope of Work, a preliminary analysis of the proposed

replacement comfort station’s effects on the water supply system is not

warranted because the proposed project’s anticipated water demand would not

be substantially different than the previously-existing comfort station or a

nearby comfort station. Likewise, an assessment of the project’s effects on

wastewater or stormwater infrastructure is not warranted because the proposed

project would not result in additional demand on sewer infrastructure. The

proposed replacement comfort station would use existing sewer connections at

the project site and will incorporate best management practices to minimize

water demand and demand for sewer infrastructure capacity. With respect to

best management practices, the design of the proposed replacement comfort

station incorporates NYCDPR standard water saving devices, which include

sensor activation for sinks and low-flow toilets that use less water than standard

plumbing fixtures.

SOLID WASTE AND SANITATION SERVICES

Comment 29: The EIS must assess the amount of solid waste and increased demands on

sanitation services associated with the proposed project. (Oceana Homeowners

Association)

Response: As described in the Draft Scope of Work, a solid waste assessment under CEQR

determines whether a project has the potential to cause a substantial increase in

solid waste production that may overburden available waste management



capacity or otherwise be inconsistent with the City’s Solid Waste Management

Plan (SWMP) or with relevant state policies. The proposed replacement comfort

station is expected to take the place of a comfort station that existed at the site

for more than 70 years and would not be expected to generate substantial new

demand for solid waste and sanitation services. Therefore, a solid waste and

sanitation services analysis is not warranted.

ENERGY

Comment 30: The Draft Scope asserts that the proposed project would have a negligible

impact on energy consumption and air quality, but it never states how much, or

what type of energy the project is anticipated to consume. (Oudolsky, Oz,

Oceana Homeowners Association)

Response: According to the CEQR Technical Manual, a detailed assessment of energy

impacts is warranted for actions that could significantly affect the transmission

or generation of energy. Since the proposed project replaces a previously

existing comfort station, it would not significantly affect the transmission or

generation of energy, and accordingly, no further analysis is warranted. As will

be discussed in the Project Description chapter of the EIS, the proposed

replacement comfort station would utilize electricity for internal lighting and to

power heating, ventilation, and air conditioning (HVAC) and other mechanical

systems such as water and sewer pumps. Some of the electricity required to

operate the proposed replacement comfort station will be provided by the

photovoltaic panels installed on the roof. The proposed replacement comfort

station is designed to meet modern building and electrical codes, is smaller than

the one that existed at the site and will replace a much older, larger facility that,

at best, included few of the energy saving devices that are part of the project.

TRANSPORTATION

Comment 31: The EIS must assess the number of vehicles and pedestrians that the proposed

project is anticipated to attract to the beach, and the impacts of that increased

traffic on local streets and transit systems, noise, and air pollution. (Oceana


Response: The proposed project replaces a comfort station that operated in this location for

more than 70 years. The commenters provide no basis for their assumption that

a replacement bathroom in the same location would attract more vehicles or

pedestrians to the area than the one that it replaces. Even if the proposed

replacement comfort station were not replacing one that previously existed at

the site, it would continue to serve the same population of beach and boardwalk

users, and there remains no basis for concluding that it would cause additional

vehicles and pedestrians to come to the area such that it would trigger a

transportation analysis. As described in the Final Scope of Work, the proposed



replacement comfort is not expected to change traffic patterns, transit usage,

pedestrian patterns, or parking demand compared to either the previously-

existing comfort station or to a replacement comfort station construction nearby.

No significant transportation impacts are expected from the proposed

replacement comfort station, and therefore no further analysis is warranted.

AIR QUALITY

Comment 32: The Draft Scope unlawfully excludes any assessment of air quality impacts from

the proposed project’s SEQRA review, in violation of the CEQR Technical

Manual’s direction that an air quality analysis is required for projects that would

result in potentially significant odors. An elevated public restroom located in a

breezy location, 90 feet away from a residential building, cries out for such an

analysis. (Oceana Homeowners Association)

NYCDPR’s claim that the proposed replacement comfort station would not

create a new stationary source of pollutants is also untrue. The malodorous

emissions from the proposed project fall well within the regulatory definition of

“air pollutant.” The impacts of such odors and emissions must be assessed in the

EIS. Potential air quality impacts caused by heat and hot water generation, to the

extent applicable, also must be assessed. (Oceana Homeowners Association)

The new comfort station will result in odor impacts since it will be high up in

the air and the wind coming predominantly from the ocean will carry the smell

right into people’s dwellings. (Pichugov, Vafakos)

Should the elevated facility be completed, we are virtually assured of long

distance dispersion of the smells and the fluids, with the wind. (Karetsky)

Response: The proposed project would replace a facility that operated in the same location

for over 70 years before it was damaged beyond repair by Superstorm Sandy.

Accordingly, the proposed replacement comfort station does not represent a new

stationary source and an air quality analysis is not warranted; furthermore, the

proposed comfort station does not contain any heating or air conditioning

systems. However, the EIS will provide information on the project’s potential to

introduce odors to the area, including the fact that the proposed replacement

comfort station would be maintained consistent with a cleaning and

maintenance schedule set forth by NYCDPR.

NOISE

Comment 33: The EIS must assess the increase in noise impacts associated with the Proposed

Project on Oceana residents, and whether such impacts could be mitigated

through the selection of an alternative location further from the nearest

residential receptors. (Oceana Homeowners Association)



Response: The proposed replacement comfort station would replace a previously-existing

comfort station and would not result in any permanent mobile or stationary

sources of noise (as noted in response to Comment 32, the comfort station

would not contain any heating or air conditioning systems). In addition, the

project would not introduce any new receptors that would be sensitive to

ambient noise levels. Therefore, no significant noise impacts are expected from

the proposed comfort station, and no further analysis is warranted.

The potential for construction of the comfort station to result in significant

adverse noise impacts will be assessed in the EIS construction analysis.

PUBLIC HEALTH

Comment 34: The Draft Scope excludes an analysis of public health impacts based upon the

unsupported and false assumption that “no unmitigated adverse impact is found

in other CEQR analysis areas, such as air quality, water quality, hazardous

materials, or noise.” To date, NYCDPR has not determined whether the

Proposed Project will pose any unmitigated adverse impacts relating to

hazardous substances or water quality, both of which will be analyzed in the

EIS. The exclusion of air quality and noise impacts was improper for the

reasons stated above (See comments 31 and 32). Moreover, the Draft Scope

fails to consider any water quality, public health, or other environmental impacts

associated with the new outdoor showers constructed as part of the Proposed

Project, which discharge untreated wastewater to the beach below (Oceana

Homeowners Association, Karatchounov)

Response: As discussed in the Draft Scope of Work, potential impacts to air quality and

from noise were screened out in the Draft Scope of Work. The EIS will evaluate

potential hazardous materials and water quality impacts (the latter as part of the

natural resources analysis), in addition to construction impacts from the

proposed replacement comfort station. If these technical analyses determine that

the proposed replacement comfort station would result in any unmitigated

significant adverse impacts, a public health analysis will be undertaken with

respect to such impacts. This approach will be clarified in the Final Scope of

Work.

Outdoor showers are not part of the proposed project. There are outdoor

showers located between the proposed project site and the lifeguard station to

the west; these showers were installed in 2013 to replace the previously-existing

showers at the comfort station.

Comment 35: The odors, insects, potential contamination, broken glass, and other unsafe

elements will cause dangerous living conditions for our families, including

children and elderly people. (Rabinovich, B., Fishman, Golan.)



Response: The comfort station will be maintained consistent with a maintenance schedule

set forth by NYCDPR and staffed by attendants (one in the women’s restroom

and one in the men’s as well as a job training participant in each restroom). Both

NYCDPR and DOHMH inspect both the beaches and comfort stations on a

regular schedule. See also response to Comment 38.

NEIGHBORHOOD CHARACTER

Comment 36: The proposed new structure threatens to significantly alter the quality of life for

many of the residents I represent. (Jeffries)

We need to work with NYCDPR, with our administration, to make sure that we

get what we deserve. Do not ruin our quality of life. (Deutsch)

My father, my mother gave me the special opportunity of living on the shores of

Brighton Beach. Will we be able to give our kids the same opportunity? Will

our kids be able to go on the boardwalk and have a good time? (Chabad of

Brighton Beach)

Response: Comment noted. The proposed replacement comfort station would replace a

comfort station that operated on the project site for over 70 years. Nonetheless,

as described in the Draft and Final Scopes of Work, the EIS will examine the

project’s potential to result in significant adverse impacts on neighborhood

character during both construction and operation of the project. In addition, the

open space analysis will examine the potential for impacts to users of the beach

and boardwalk.

Comment 37: The structure is not compatible with life in Brighton Beach or any other urban

community. (Cymbrowitz, Bubin)

By building a three-story-high bathroom right in front of the Oceana residents’

bedroom windows, the City is blatantly disregarding and violating the covenant

of quiet enjoyment of their properties that private property owners are supposed

to have. (Segal)

Response: The EIS will include an assessment of neighborhood character, as described in

the Draft Scope of Work. The assessment will identify the elements of the study

area that contribute to neighborhood character (i.e., the waterfront setting,

destination open space resources—i.e., Coney Island Beach and Riegelmann

Boardwalk—and the residential and community facility uses located north of

the boardwalk) and will evaluate whether the proposed replacement comfort

station would affect those defining and supporting features, as compared to the

No Action conditions.

Comment 38: You mentioned the homeless and I’m concerned about the homeless. I don’t

want them living under the comfort station. (Olson)



Response: Remaining in New York City parks overnight is not permitted and patrols by the

New York City Police Department and/or NYCDPR enforcement officers would

monitor the beach, boardwalk area, and underneath the proposed replacement

comfort station as they have historically done in this and other areas along the

waterfront.

CONSTRUCTION

Comment 39: If the bathrooms are constructed in their proposed location, the residents of

Oceana will hear and feel the construction impacts more directly than anyone

else. (Oudolsky)

Several commenters expressed concern over lighting, noise, and vibration issues

experienced at the Oceana complex during the construction of the comfort

station to date. (Galbmillion, M., Miskina)

Response: The construction section of the EIS will describe the construction schedule and

the anticipated construction activities that remain for the proposed replacement

comfort station. The EIS will qualitatively assess how construction activities

could affect traffic conditions, noise levels, and air quality conditions at nearby

locations during the limited construction period. In addition, temporary

construction-related impacts to natural resources, such as the potential for

increased noise levels and human activity during construction of the proposed

replacement comfort station to adversely affect wildlife, will be assessed.

Finally, the assessment also describes methods that may be employed to

minimize construction-period impacts.

ALTERNATIVES

Comment 40: To satisfy SEQRA and CEQR, NYCDPR must fully analyze, at a minimum, the

following alternatives to the Proposed Project:

A true “no action” alternative, without any new construction or

reconstruction;

A “reconstruction” alternative which analyzes the reconstruction of the

previously existing restroom, or identifies the specific code provisions that

would preclude such construction. (Oudolsky, Oceana Homeowners

Association)

Response: Please see the response to Comment 4. As noted in that comment, in response to

comments received at the public scoping meeting, the EIS will contemplate two

No Action conditions for the 2014 analysis year. In both No Action conditions,

a comfort station would be provided for the beach at New Brighton since a

comfort station is required to ensure compliance with the New York State

Public Health Law requirements. The two No Action conditions are as follows:



No Action Condition 1: In No Action Condition 1, it is assumed that the

comfort station that existed prior to being damaged beyond repair by

Superstorm Sandy would be reconstructed on the site at the level of the

beach.

No Action Condition 2: In No Action Condition 2, it is assumed that a

replacement comfort station is constructed near the project site at a location

between Coney Island Avenue and Brighton 15th Street outside of both the

Coastal Erosion Hazard Area (CEHA) and tidal wetland area. No Action

Condition 2 assumes the installation of temporary restrooms on the

boardwalk at Coney Island Avenue. Under this No Action condition, it is

also assumed that the project site is cleared of the installed piles and re-

graded as sandy beach with no structures.

Both No Action conditions are consistent with the New York State Public

Health Law requirement that NYCDPR provide adequate toilet and hand-

washing facilities at New Brighton beach, which is a bathing beach.

The Final Scope of Work will reflect the addition of this second No Action

alternative, and the EIS will describe the factors guiding the location and design

of this and other alternatives.

Comment 41: To satisfy SEQRA and CEQR, NYCDPR must fully analyze a “temporary

restroom” alternative which analyzes the provision of temporary restroom

facilities in an alternative location, as the NYCDPR proposed last summer.

(Oudolsky, Oceana Homeowners Association)

The beach surrounding the project site was open this past summer, and the

NYCDPR proposed temporary restroom facilities in an alternate location that

did not require disturbance of a coastal erosion hazard area. NYCDPR must

evaluate the impacts of those temporary restroom facilities as an alternative to

the Proposed Project. (Oudolsky)

There is over a mile on the west end of the beach without a permanent

bathroom, and they’ve used temporary bathrooms there for years. We used

portable bathrooms this past summer with no problems, and can do so until the

plan is done right. (Scott)

The use of temporary toilets for the summer period should be considered.

(Polissky, Vidal, M.)

Some have suggested using portable restrooms at this location instead of

building a permanent structure. However, installing and removing such units at

the beginning and end of the season and maintaining them may require heavy

vehicles. This would damage the wooden Boardwalk. How would this be

addressed? (Natural Resources Protective Association)

Response: As noted above, No Action Condition 2 assumes the installation of temporary

restrooms on the boardwalk at Coney Island Avenue.



Comment 42: Despite the obvious need for a public bathroom in the eastern part of Brighton

Beach, we strongly disagree with the idea of using portable bathrooms for this

purpose. (Dvorkin, Kantor, People of Oceana)

Response: Comment noted.

Comment 43: To satisfy SEQRA and CEQR, NYCDPR must fully analyze “Design”

alternatives intended to mitigate the proposed project’s adverse impacts,

including but not limited to a design without breakaway ramps and stairs.

(Oudolsky, Oceana Homeowners Association)

NYCDPR should consider alternative designs of the restrooms that would

mitigate their potential impacts on visibility, and whether there are other

improvements to Brighton Beach that would also qualify for FEMA

reimbursement while avoiding the proposed project’s adverse impacts.

(Oudolsky)

Another option is to work with FEMA to find a better design for a comfort

station—one that falls within their guidelines for storm protection. Maybe

FEMA can come up with a design that can withstand storm conditions and be

lower to the ground. (Cymbrowitz)

We think the only plausible option at the current location is to build no higher

than the current boardwalk level. (Karetsky, Rosen.)

We support the idea of restoring a low-profile, one-level public lavatory in the

footprint of the bathroom destroyed by Superstorm Sandy. (Dvorkin, Kantor,

People of Oceana)

Yes, we need public bathrooms, but why at the level of a 4-story building? Why

not just 5 feet higher, so that the water goes under it in case of flood?

(Budnyatsky)

Response: In addition to the two aforementioned No Action Alternative conditions, the EIS

will include an evaluation of the following alternatives to the proposed

replacement comfort station:

Two Elevation Alternatives, which will consider the installation of the

replacement comfort station at the project site but at two different elevations.

Two Location Alternatives, which will consider the installation of the

replacement comfort station at two different locations between Coney Island

Avenue and Brighton 15th Street. For both Location Alternatives, two

elevation variations will be considered.

The Final Scope of Work will reflect the addition of these alternatives.

Comment 44: We propose a way of protecting Oceana complex from future flooding by

building a 200-foot long sea wall along the boardwalk and parallel to the

Oceana’s Great Lawn. We believe that the sea wall and the one-level public



bathroom can be designed as one architectural structure, serving as a water

barrier for the Oceana community and as a sanitary facility for the public.

(Dvorkin, Kantor, People of Oceana, Milter)

Putting the public bathrooms here may limit our options for flood prevention

projects in the future. We would like to identify with the City a flood prevention

solution and to work with them to get those installed and to delay the bathroom

until that can be done. (Scott)

Response: The proposed project involves the provision of public restrooms for a public

beach. The proposed project will not affect the boardwalk structure and would

not necessarily preclude future flood prevention measures. The No Action

conditions, against which the proposed project will be compared, will account

for planned and funded projects to occur by the 2014 build year.

Comment 45: We are strongly against any alternative location that will involve obstruction of

the historic Coney Island Avenue entrance to the boardwalk and the beach with

either temporary or permanent bathroom facilities. We strongly oppose the

proposal to move these bathroom facilities further west if that results in placing

these raised bathrooms at the end of Coney Island Avenue or in front of

Shorefront YMHA. (Dvorkin, Kantor, People of Oceana)

I strongly oppose the relocation of the new comfort station from its original

footprint in front of the Oceana complex toward the Shorefront Y community

center and Brighton 6th Street. (Suler)

Response: Comment noted.

Comment 46: To satisfy SEQRA and CEQR, NYCDPR must fully analyze “Location”

alternatives which analyze alternate locations on the beach, on public property

at the termini of City streets, and other possible locations that are further

removed from residential dwellings; (Oudolsky, Oceana Homeowners

Association)

There is a valid alternative location for a comfort station that would be a sound

compromise between the needs of the Oceana residents and needs of beachgoers

visiting Brighton Beach in summer. Since one of the new comfort stations along

the Brighton Beach boardwalk is utilized as a lifeguard station, the old lifeguard

station at the intersection of Coney Island Avenue and the boardwalk can be

converted into a public restroom. Move the bathroom site to Coney Island

Avenue and while litigation continues, install a row of temporary bathrooms.

(Singer, Segal)

Response: As noted above, the EIS will include an evaluation of two location-related

alternatives which will consider the installation of the replacement comfort

station at two different locations between Coney Island Avenue and Brighton

15th Street. For both Location Alternatives, two elevation variations will be



considered. The Final Scope of Work will reflect the addition of these

alternatives.

Comment 47: I demand that your department roll back everything that has been done toward

the so called “New Brighton Comfort Station” across from Oceana. (Fisher,

Persits)

The previous bathroom was not destroyed by hurricane and can be rebuilt.

(Galbmillion)

We had before a small restroom on the beach and this restroom was enough for

people on the beach. This bathroom still exists and what is necessary is only to

put a little money to restore this restroom. (Miskina)

Response: The comfort station that was previously located on the project site was located

within a 5,000 square foot area and was severely damaged by Superstorm Sandy

in October 2012; it was subsequently demolished in March 2013.

CUMULATIVE IMPACTS

Comment 48: There has been no discussion of the cumulative impacts of the above project

when combined with the concrete slab Boardwalk section proposed for the same

area. We have evidence of increased storm surge damage near an existing

concrete section near Ocean Parkway. Damage from the breakway ramps in a

storm surge may be exacerbated by increased wave energy from concrete slab

Boardwalk sections. This needs to be addressed in the EIS. (Natural Resources

Protective Association)

Response: The EIS impact analyses will account for relevant background projects expected

to occur independent of the proposed project; the Boardwalk project will be

considered where appropriate. Damage assessments conducted by NYCDPR

after Superstorm Sandy do not indicate evidence of increased storm surge

damage near the existing concrete boardwalk sections. As noted in the Draft and

Final Scopes of Work, and as will be described in the EIS, the modular units and

their piling system, and that of the stairs and ramps, have been designed in

accordance with all standards applicable to structures placed within the

floodplain, including the NYC Building Code and American Society of Civil

Engineers standards for Flood Resistant Design and Construction. The EIS will

also describe the Federal Emergency Management Agency (FEMA) Best

Available Flood Hazard Data for the project site in evaluating whether the

proposed replacement comfort station has the potential to alter flood levels,

flood risk, or the flow of flood waters in the surrounding area.

Comment 49: The Draft Scope unlawfully treats the New Brighton Comfort Station as if it

were the only bathroom on the beach, ignoring the other restrooms that were



constructed over the last year and those that survived Tropical Storm Sandy and

remain open in their prior location under the boardwalk. These facilities are all

part of the baseline for the environmental analysis, and the City must consider

the cumulative impacts of the new restrooms combined with all of its recent

construction, as well as the need for a restroom in this particular location given

the facilities that have already been erected elsewhere. (Oudolsky, Oz, Oceana


Response: The preparation of an EIS for the proposed replacement comfort station was

mandated by an order of the New York State Supreme Court. The order directs

that an EIS be prepared for the proposed replacement comfort station at New

Brighton. The other comfort stations noted by the commenters have already

been constructed as replacements for damaged comfort stations at those

locations. As described in the Final Scope of Work, within Coney Island Beach

and Boardwalk (which extends approximately 2.5 miles from W. 37th Street to

the west to Corbin Place), two replacement modular comfort stations and two

replacement modular lifeguard stations were planned. The nearest replacement

lifeguard station is approximately 1/3-mile to the west of the project site, and

the nearest replacement comfort station is at West 8th Street, approximately 1

mile to the west of the project site. Both of these have been constructed, and

their construction and operation do not have a potential consequence with

respect to the assessment of impacts due to the proposed project. As noted

previously, the EIS will explain the purpose and need of the proposed project

and the reasons for constructing the proposed replacement comfort station at the

proposed location.

D. NON EIS COMMENTS

Comment 50: Several comments addressed the design of the other three modular comfort

stations installed throughout the Coney Island-Brighton Beach Boardwalk.

(Sanoff)

Response: Comments on the other modular comfort stations installed in Brooklyn are

outside the scope of this targeted EIS.

Comment 51: Several comments addressed the replacement of the wooden boardwalk surface

with concrete (Burstein, Sanoff, Makchin)

Response: The replacement of the boardwalk surface is not part of this project and, thus,

outside of the scope of this targeted EIS.

Appendix B

ENVIRONMENTAL REVIEW

Project number: NYC PARKS DEPARTMENT / 14DPR005K Project: NEW BRIGHTON COMFORT STATION Address: 3317 CONEY ISLAND AVENUE, BBL: 3087250001 Date Received: 10/21/2013 [X] No architectural significance [X] No archaeological significance [ ] Designated New York City Landmark or Within Designated Historic District [ ] Listed on National Register of Historic Places [ ] Appears to be eligible for National Register Listing and/or New York City Landmark Designation [ ] May be archaeologically significant; requesting additional materials

10/30/2013 SIGNATURE DATE Gina Santucci, Environmental Review Coordinator File Name: 28897_FSO_GS_10302013.doc

new brighton comfort station final scope of work …...1 february 26, 2014 new brighton comfort...

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