PS 133's Most Desperate Hour

The public comment period doesn’t expire until Tuesday, but the city’s already acting like the demolition of historic gothic-style public school building at 375 Butler Street in Park Slope that currently houses PS 133 is a foregone conclusion: Several contractors were on site last weekend doing test borings related to developing a safety plan for the demolition. (The New York State Office of Parks, Recreation and Historic Preservation found in 2007 that the building meets the criteria for being listed in the National Register of Historic Places. Unfortunately, that doesn’t mean diddly to the city.) A group of concerned area residents has tried to present an alternative vision for the site that would enable the SCA to achieve its goal of increasing the number of seats on the site while avoiding the destruction of the existing building. A drawing of the alternative plan is above at right. They’ve also detailed their opposition and alternative proposal in a lengthy letter to the SCA which we’ve included on the jump. It’s much too extensive for us to summarize here (plus, we’re trying to pack!), so we suggest taking a look—and signing the petition they just started yesterday to demonstrate community and borough-wide opposition to the demolition. Check it out here.
New PS 133 Plans Revealed [Brownstoner]
SCA To Build New P.S. 133, Tear Down Old Building [Brownstoner] GMAP
Proposed School Replacement Facility for P.S. 133 [DOE]

May 14, 2009

To: School Construction Authority
NYC Department of Education

Subject: Request for Comment on Draft Environmental Impact Statement regarding
Primary School Replacement Facility for PS 133, Brooklyn, Kings County

My name is SJ Avery and I live at 392 Butler Street, just down the street from PS 133. I have lived in my current home for 25 years and, on behalf of a group of twenty homeowners on Baltic and Butler Street, I am presenting a summary of our concerns about the environmental impact of the primary school replacement facility as proposed by the School Construction Authority. There have been several neighborhood meetings, as well as exchanges of email, since the Community Board 6 subcommittee meeting at which designs for the proposed replacement school were first shown to the public. Unfortunately, contrary to statements made by SCA representatives at that meeting, the SCA did not make material presented at that meeting available to Community Board 6 for placement on their website. The lack of material specific to the proposed design has somewhat limited our ability to evaluate the environmental impact of the proposed project.
Nonetheless, since that time, homeowners and residents on the immediately effected blocks have discussed their major concerns related to the proposed construction. Those issues are summarized below. Additional concerns were raised by the release of the SCA’s DEIS, which was placed on the SCA website during the last week in April. Because this document is being prepared prior to the public meeting on the DIES, and many unanswered questions about the impact of the proposed construction remain, the summary of concerns/recommendations in this memo should not be considered complete.

We wish to reiterate that we are not opposed to building new seats, although we are puzzled by the fact that in the DEIS the SCA states that the four elementary schools closest to the site are all operating under capacity (with utilization rates of 84%, 34%, 77% and 69%1). We also note that it is not clear what the capacity of PS 133 is and whether or not it is being fully utilized. And while we are very aware of the apartment construction that is going on along 4th Avenue, which is also cited in the DEIS, we suggest that an analysis of tenant occupancy would be helpful in projecting school needs for all of the school districts proposed to be served by an expanded school. Finally, we must observe that the current system of building a new school, and then creating a program for it, seems a bit backwards to us.

We believe that , with community dialogue and a willingness to look beyond the dated, and largely discredited, strategies of raze a site and then just build the biggest building you possibly can on that site, there are many ways to create new seats and still build smart and in scale.

Concerns about the proposed construction and proposed suggestions

Summary of Issues of Concern:

1. Size and Mass

Loss of open space buffers around school

Negative impact on neighborhood

2. Traffic

3. Construction Concerns

No safety plan for demolition

Construction on contaminated soil
1.) Size and Mass of proposed construction

The size and mass of the proposed facility is at the heart of our concerns. The proposed structure is simply too big for the site and for the neighborhood. It dwarfs the homes on Butler and Baltic and, if constructed, would present views of a large box to residents on both blocks; according to the SCA drawings, any architectural reference to the original building is only visible on 4th Avenue. While the proposed school may be in scale with the (largely undistinguished) structures being developed on 4th Avenue, it significantly intrudes on both Baltic and Butler, where it overwhelms the scale of buildings. This very problem with the mass of the proposed structure is noted in the SCA DEIS while the 4th Avenue side of the building complies with recent rezoning, the proposed project would not comply with all of the zoning’s bulk regulations and portions of the building would exceed the zoning lot’s height, setback, sky exposure plane and street wall restrictions, requiring a zoning override2.

a.) Absence of school buffers

The mass of the proposed construction also effectively removes open space around the school. To compare the proposed design to other schools already in the districts to be served by the new school, one can take a Sanborne Map and look at the blocks where PS 133 and PS 282 (both in Dist. 13) are sited, and also the blocks where PS 321 and PS 261 (both in Dist. 15) are sited. The most obvious difference between the PS 133 site and the others is that, if the proposed building is built, the new school will have substantially less open space surrounding it than the others. In the cases of PS 282 and PS 261 there are Parks Dept. playgrounds immediately adjacent to the school playgrounds, which not only add play space, but which act as a buffer between the school playgrounds and nearby residential properties.
b.) The size of the new structure, combined with tearing down the old PS 133, has a serious negative impact on neighborhood

New York City is built on neighborhoods; they are the small venues where we can establish a sense of place in a city of millions. In the immediate neighborhood of PS 133, there is a strong feeling of being connected. About a third of us have lived here since the new houses on Baltic and Butler were built, over 25 years ago. The majority of the houses are still owner-occupied; one of the requirements for original ownership was that we were first time homeowners. Insideschools.org described PS 133 with the opening sentence, Tucked away in a quiet cul-de-sac in a changing area of Park Slope, PS 133 is a lively school that takes itself very seriously but does not forget to have fun.3 We have appreciated that relative quiet of our neighborhood and enjoyed living on a block with a beautiful school of historic significance. The reality of that historic significance has been established by the State Office of Parks, Recreation and Historic Preservation, regardless of whether or not the building was placed on the National Register it is eligible, in two categories, to be included. 4. We are deeply concerned about what will happen to our neighborhood if the lovely old school is demolished and a school three times the size of the old one is built.

One way to understand the impact of the proposed demolition and new construction is to go to Google Maps and look at the neighborhood from an aerial view. Between 4th Avenue and 3rd Street (Byrne Park) and somewhere along 4th far beyond Flatbush, the playground area and the community garden between Butler and Baltic are the only open, and partially green, spaces along 4th Avenue. With the exception of the trees along the existing playground, it is hard to even find one tree along that stretch. From the perspective of the SCA, the existing barren landscape of 4th Avenue appears to be justification to remove the one green space along it they actually go so far as to state that project would be an improvement, since the proposed construction would establish a strong street wall presence along 4th Avenue. The SCA does acknowledge that the project would result in an adverse impact to existing visual quality, but deems that impact not significant.5 It is significant if you live here.

What the SCA fails to understand is that for residents on Butler and Baltic streets (and beyond) the refreshing space on 4th Avenue between the two blocks is a valuable part of the neighborhood. The SCA’s lack of understanding of the neighborhood is further illustrated by an attempt to suggest that the existing school is what is out of place with the neighborhood. Its dramatic steeply pitched gabled roof is created by various gabled dormers on the fourth floor and a prominent end chimney and (sic) visible from various vantage points to the immediate south and east, particularly from Butler Street and 4th Avenue. Its dramatic design and massing contrasts strongly with the neighboring pink and cream-colored contemporary row houses…that are significantly shorter and setback from the lot lines6 (emphasis added). The row houses, constructed twenty five years ago, were deliberately designed with pitched roofs (very atypical in the neighborhood) and given a faux terra cotta finish to reflect the design of PS 133 and add a cohesive element to the Baltic/Butler blocks7. The existing PS 133 is, with its vistas of gabled dormers, pitched roof and dramatic design, held in great esteem by residents on the block (and many others see http://brownstoner.com/brownstoner/archives/2009/03/sca-to-build-ne.php) and is an architectural anchor. If the school is demolished, the houses adjacent to the school lose that architectural anchor for a view of the box-like back of the proposed new structure.
2.) Traffic

Major increase in neighborhood traffic

The second problem relates to the first. The amount of traffic (pedestrian and vehicle) associated with a 960 seat school will overwhelm the half block on which it is forced by the proposed design. The design creates serious congestion and a dangerous traffic situation for the block residents, for school children entering and exiting the school, and for pedestrians. The mix of gridlocked traffic, impatient drivers and small children suggests significant safety problems.

Pedestrian traffic: The proposed school has two main entrances – one on the corner of Baltic near 4th, the other on Butler, near 4th. The building will be sized for 960 children (the number of children to be served by the school appears to increase with each release of information by the DOE at a January CEC meeting the enrollment was projected at about 800 students) and those children are going to be concentrated in a very small area when entering and leaving – the proposed school is built right up to the sidewalks on Butler, Baltic and 4th. Given the fact that the (two? three?) schools in the proposed building are pre-K through 5th grade, most of the children who do not come on busses are accompanied by an adult. We note that the DEIS pedestrian trip projections have only 77 parents or guardians accompanying a total of 612 students to school (which suggests one in eight pre-K to 5th grade children8 will be accompanied by an adult), an average we suggest is very low, regardless of the actual number of students walking to school an issue we will address later. Pedestrian traffic by the entrances will jump to well over 1200 twice a day.

Vehicular traffic: Most of the children who fall into the new student category will be coming from District 15 (there are 696 new students and 264 current students9), as well as 84 special needs children from district 75. We know the special needs children will be bussed in and out and the SCA projects 8 bus trips in and 8 out on a daily basis. However, in an amazing stretch of fancy, the SCA projects that half of the new students Pre-K to 5th graders from District 15, will walk to school10. At the public hearing on school siting, the Superintendent of District 15 said that there was not yet a plan for which District 15 children would be selected to attend the proposed school. District 15 is a huge district covering the area from Red Hook to Prospect Park West, with boundaries stretching as far south as 54th Street and zig-zaggin down Union, along Third and past Atlantic and the closest boundaries to the proposed school site are 5 blocks away and equally close to underutilized schools identified earlier. It seems far likelier that the majority of new students will be bussed or dropped off in cars by parents.
SCA estimates that 61 students will be dropped off by parents in cars each day, and 41 will be picked up each day.11 (We have no idea of why that number changes). If this number is accurate (and we suggest that it may be understated, as noted above) that puts between 3 and 4 times the current number of parent driven vehicles on Baltic and Butler Streets.
Using its half will walk scenario, SCA traffic projections for the new school show 7 additional school bus/van trips each morning and each afternoon for new students12 : these estimates are based on 30% of new students taking the bus. As noted, we suggest the number of new student who will be bussed will be more like 50% (at minimum), which would be closer to 12 new bus trips. So, bus trips to the school are likely to increase from the current five busses (which even now can bring traffic to a standstill see attached photos) to a total of twenty five bus trips each morning and evening (5 current, 12 new for regular students and 8 new for special ed students).

It is key to remember that, because the streets are one way and Butler is not a through street between 4th and 5th, the only way to get to the Butler Street entrance is to go down Baltic Street and, before reaching 5th, turn on Gregory Place (behind the Key Food). Consequently, traffic is being forced to circle around an area that is less than a full block long, and the circling includes waiting in line while busses ahead are filled and move on. It is close to impossible to speculate on how this can be safely done at the Baltic Street side, which is the gate for traffic headed toward Butler. We doubt that busses will be allowed to pass each other when children are being loaded or discharged. Even if children were being discharged and picked up on Fourth Avenue, traffic would be forced to wait until each bus was emptied or filled — and 4th Avenue is very heavily trafficked in the mornings, especially when the BQE is backed up (which happens frequently) and cars exit onto 4th Avenue in the 30’s to bypass the backup
Add the narrowness of Baltic and the fact that it is a though street from Court to 5th, and it becomes clear that the SCA acknowledged traffic problems at the corner of Baltic and 4th 13are significantly understated. The DEIS also fails to consider increased traffic related to expanded deliveries and garbage pick-up associated with a school serving three times the number of students who are served now.
Most astonishingly, the only traffic mitigation put forth by the SCA is that it will ask the DOT to add seconds on the ‘lead times of lights at the corner of 4th and Baltic and if the NCYDOT determines that the proposed mitigation measures are not practicable, the project’s traffic impact at the intersection of Fourth and Baltic would be unmitigated14 In effect, the SCA has significantly underrepresented the traffic impact associated with building the new school, and acknowledges that it has not yet discussed traffic with the department of Transportation, yet throws the problem in their lap. This is a totally unacceptable response. The traffic jams created by the proposed new school create an unsafe environment for the children attending the school and for the area residents. We already have serious traffic problems around schools in Brooklyn and other parts of the City; does the SCA’s shrug of its shoulders mean that they won’t even try to avoid such problems in schools that are not yet built? The apparent position that the SCA has no design or siting responsibility to avoid dangerous traffic situations is both reckless and irresponsible.
3. Construction Concerns
As those who attended the only other public presentation on the proposed project design are aware, a number of area residents raised concerns related to construction, including the impact of major pile driving (during excavation for a large new building) on the wood frame houses, rodent problems frequently associated with major excavations, noise associated with construction and construction traffic concerns. The DEIS tells us, repeatedly, that this will only be for a short time four years – so it is not considered significant. A four year building and demolition period may seem like a short time to someone in Long Island City, but it sounds like a pretty long time to us.

We also note that there is no reference at all to the demolition of the existing PS 133 building in the DEIS except for the statement that construction and demolition on the site would require careful planning and staging to minimize physical and environmental intrusions on the existing school building and its students.15 We’d like to know what those plans are in fact, we insist that there be an explicit plan to keep both the students and the neighbors safe. Obviously, we all have concerns about safety, about noise and about air quality if a building of this size and substance was to be demolished. The DEIS is totally silent on this issue. The silence may be due to one of those bureaucratic twists where the SCA says it only has to talk about construction, not demolition but why not have all the facts and plans in place before beginning the project in order to better assess it?
And, another one of the sections of the DEIS has given us pause.

Hazardous materials

While the DEIS states that the proposed project would not result in impacts from contaminated media and building materials, it notes that in the case of excavated soil, Based on the results of waste characterization analysis, material should be disposed as hazardous waste.16 While we lack the chemistry background (and specific readings from the SCA surveys) to understand just how contaminated with PCE, TCE, SVOCs, PID and petroleum and concentrations of lead the soil is, and the extent to which VOS, SVOC, metals and formaldehyde have contaminated groundwater that was sampled17, this is an alarming statement. As we are sure the agency is aware, recently there have been a number of cases where the City, and the SCA in particular, has come under fire for building schools on contaminated land. The SCA’s assurance that the contractor will be required to prepare plans for excavated soil management….. is a disquieting echo of a story from the Daily News that is reprinted below.

Just a toxic mixup – city Schools site ‘violated’ state law
BY BILL EGBERT
Tuesday, November 18th 2008, 4:00 AM

City lawyers are now calling it all a big misunderstanding after a judge ruled the city violated state law by building schools on a toxic South Bronx site.
Acting Bronx state Supreme Court Justice Patricia Anne Williams ruled last month that the School Construction Authority violated the State Environmental Quality Review Act by approving the contaminated Mott Haven Schools Complex at Concourse Village West between 153rd St. and 157th St. without first detailing a long-term plan to protect students and faculty from remaining toxins.

But the city said it followed a different state law for cleaning up brownfield sites.
“There’s a bit of a disconnect,” said city lawyer Carrie Noteboom, “between the state environmental review process and the brownfield cleanup regulations.”
The 6.6-acre tract was home to a railyard and machine shops for 73 years, and contains harmful chemicals including mercury, lead, benzene and tetrachloroethylene.
The $230 million campus, still under construction, will be shared by two high schools, a combination high school/intermediate school, and a charter school for grades five through eight.

The state Department of Environmental Conservation’s rules for cleaning up brownfields allow for long-term monitoring plans to be submitted for review after work is underway, Noteboom said, while the SEQRA process requires that all of the environmental evaluation, including maintenance plans, be completed and reviewed before any work begins.

“The SCA was always planning to do a long-term maintenance plan for the site,” she said, with the only issue the timing.

But the timing is crucial, argued Dawn Philip of New York Lawyers for the Public Interest, which filed suit in April 2007 on behalf of the Bronx Committee for Toxic Free Schools.

Requiring the SCA to produce a detailed, long-term monitoring plan for a toxic site in the initial phase forces the city to take those costs into account before it approves the site for a school.

“How the SCA plans to monitor their controls over the long term will impact the viability of the site and whether they should put a school there in the first place,” said Philip.

Regardless of the ruling’s future impact, it came too late to affect three schools the SCA announced last May that it plans to build on contaminated sites in Queens, ranging from an old auto storage lot to a former dry cleaner.
“I don’t think this ruling provides a basis to revisit past decisions,” Noteboom said of the other sites.

wegbert@nydailynews.com
We insist that the SCA present at minimum a basic safety plan related to the excavation soil considered to be hazardous material, as we understand is required by New York State Law, and not shift all responsibility to an unnamed contractor. We also assert that the SCA should identify costs associated both with removal and remediation of soil considered to be hazardous material and with the future monitoring of identified water contaminants. We support the idea of using outside consultants to undertake this task. The proposed extensive excavation and trucking of soil considered to be hazardous material certainly raises a specter for area residents and for parents of PS 133 students. The SCA DEIS admits that a construction-related effect of the project on air quality includes increased fugitive dust, which is defined as airborne particulate matter that is kicked up by haul trucks, concrete trucks, delivery trucks and other earth-moving vehicles operating around the constructions site and from material blown from uncovered haul trucks18 If hazardous material is being dug up, we assume that that it will be a component of such fugitive dust.

We realize that the old school site precedes the industry that may have resulted in soil contamination; we also are aware that, aside from possible leaching effects, the existence of contaminated soil is much more of an issue when it is uncovered and broken up, as in digging a very large foundation for a very large school.
Recommendations:

Build smaller and make use of existing resources

We were surprised and pleased to see that one of the alternatives presented by the SCA in their DEIS was to rehab the existing PS 133 structure and build an addition to it19. This solution would preserve the existing school, which would continue to act as an architectural anchor for the adjacent blocks. However, in the alternative suggested by the SCA, a large addition runs the length of Baltic Street and the SCA notes that there would not be space for a community garden. We have not been presented with any cost comparisons between renovation and demolishing/rebuilding, but we do note that renovation of old schools (typically, constructed before the 1950’s), can actually be more cost effective than the raze and rebuild approach and is being embraced in states such as Maryland, Pennsylvania, Massachusetts and Connecticut. The National Clearinghouse for Educational Facilities has a 16 page list of resources on assessing whether to renovate and modernize existing school buildings in need of repair or construct new ones on it’s website, and the articles there include many reports of successful adaptive reuse.
An alternative suggestion to the one put forth by the SCA would be to renovate the old school and build an addition that would run parallel to 4th Avenue, built on slab, for approximately the length of the existing school, with the first floor used as a low ceilinged mechanical area. This would minimize exposing contaminated soil and would put a floor between the slab and classrooms. If the addition was sited close to 4th Avenue, a courtyard space could be created between the two buildings (which could be connected by a bridge on the second story level). This courtyard space, which would be entered on Baltic and exited on Butler, could serve as a secure drop off space for school busses, monitored by crossing guards at either end, resulting in a safer space for discharging and picking up students and alleviating some of the traffic impact on Baltic and Butler. There would still be space for the community garden at the corner of Baltic and 4th Avenue. We are attaching a schematic representation that contrasts this approach to the one presented by the SCA; it is a rough draft, but it illustrates the fact that we can think smart when designing for an increase in student numbers.
We are not convinced that it is possible or supportable (in terms of impact) to triple the number of seats available at PS 133, but such a strategy could at least double the available seats. We also believe that it may be possible to gain seats in the existing building through a thoughtful renovation the school did, at one time, have a larger student population than it does now. Again, there are many successful and cost effective examples of old school renovations which resulted in much needed increased space and mitigated impact on the surrounding neighborhood. A renovation, combined with a reduced excavation new build also could be completed in significantly less time than the 4 years projected for the SCA design. Under separate cover we would be happy to send the SCA materials related to this issue, such as some case study analyses of new building vs. renovation and the importance of historic schools to neighborhoods.

In summary, we are opposed to the replacement plan as presented as the primary option in the DEIS because of the many problems it creates ranging from the irreparable loss of an historic, and lovely, building that anchors our neighborhood to problems associated with the mass of the proposed building, such as lack of scale in the neighborhood, loss of green space, traffic problems and construction problems. We are particularly concerned about the lack of a safety plan related to the treatment of excavated hazardous material and the similar absence of any safety plan for the proposed demolition of the old school. We are supportive of examining a combination of renovation and new building, but think it can be done in a better way than proposed in the DEIS. We believe that a reexamine of design could help alleviate potential environmental problems related to traffic and contaminated soil.
We urge that the SCA make design staff, and detailed materials about the site such as the actual soil and water testing reports – available for collaborative community discussions about how to best develop a plan for a smart and safe school. We are positive that the time spent in such design discussions will reap significant benefits in the environmental quality of the school that is build and in the time it actually takes to complete the project. We believe we have the opportunity to create a showcase project, using the talents of the SCA staff, the expertise of community (parents and neighbors) input, and a willingness to think outside of the proposed box for PS 133.