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City Planning is holding their ULURP hearing on Domino today, without a new Chair to replace Amanda Burden. Kenneth Knuckles is acting chair. I am not able to make the hearing, but I submitted this testimony via fax yesterday. Most of it is drawn from previous blogs and writing.

Almost four years ago, in February 2010, I was at Brooklyn Community Board 1 when the Community Preservation Corporation held their first ULURP presentation on the Domino project. I was there as a graduate student in urban planning on the first shoot of a film project called “The Domino Effect” that would go on to document every one of those hearings. Now, nearly four years later, I am offering testimony on Two Trees’ proposal as an urban planner who has studied and worked on New York City land use issues in great detail, and as a local resident of Williamsburg with first-hand experience of how this neighborhood is being rapidly transformed by out-of-control development.

I continue to believe that 3 million+ square feet is far too much density for this site, and in an ideal world at Domino we would be considering creative alternatives that would find greater synergy with the local economy and community such as an industrial/creative business incubator, a new university branch, or a combination of such developments with 1,000 units of mixed-income housing. But for the purposes of this review process, let’s aside the issues of density and whether or not development dominated by high-density residential is the best use of this site.

If we simply evaluate the Two Trees proposal on the basis of its touted public benefits of “affordable housing” “jobs” and “open space,” it becomes clear that these measures fall short of truly benefitting the public and local community. If Two Trees and the City Planning Commission are truly interested in fostering development that benefits the long-term interest of Williamsburg and New York City as a whole, the proposed public benefits must be more clearly defined, strengthened, and locked into a binding restrictive deed.


In Brooklyn Community Board 1, the Area Median Income is only $41,540. Therefore, in order to have “affordable housing” that is actually affordable to the majority of community households in Community Board 1, it has to be targeted at 30% to 50% AMI. 60% AMI will be helpful to some in the community under pressure from displacement, but anything higher than 60% AMI and we really can’t consider it “affordable housing” for Community Board 1 in any meaningful sense of the term.

In 2010, the Community Preservation Corporation was promising 660 units broken down as follows:  100 apartments at 30% AMI, 100 senior housing units at 50% AMI, 310 apartments at 60% AMI, and 120 “affordable home ownership” units at 120% AMI. While only the 100 apartments at 30% AMI would reach the majority of those in need, at least 510 of the 660 units were for 60% AMI or lower.  Community Preservation Corporation was also promising a diverse mix of apartment sizes with significant numbers of larger 2 and 3 bedroom apartments.

In contrast, Two Trees has been noncommittal and extremely vague about both the affordability levels and the distribution of units sizes. Each of these factors has a critical impact on the degree to which the proposed “affordable housing” will actually benefit the public interest and justify the additional density and government subsidy. The City Planning Commission cannot adequately asses this project while lacking full understanding of the affordable housing program.

Additionally, Two Trees is requesting that only the residential floor area of the development be counted towards its allocation of affordable housing and is committing to allocate only 20% of it. Compared to the 2010 plan, Two Trees’ proposal reduces the residential square footage by 160,639 feet. Therefore, in regard to what is actually proposed to be locked in to the zoning, Two Trees is proposing less square footage of affordable housing than required under the existing zoning.

I strongly agree with the recommendation of the Brooklyn Borough President that the promise of 660 units (30% of the total units) of affordable housing – with enough square footage for reasonably sized two and three bedroom units — must be legally locked into the property. Such a promise should be a bedrock commitment of development at Domino and not be held hostage to additional subsidy or dependent on the status of the 421a tax break.


Open Space” is the second major selling point of the plan, and Two Trees is proudly proclaiming that their plan provides an additional 2 acres of open space compared to the 2010 plan. But looking at the details, the majority of this additional space would be taken up by the proposed extension of River Street through the site as a “private drive.” According to the technical memorandum, 1.31 acres of the claimed additional 1.98 acres is taken up by the additional street and sidewalks. Taking this into account, the Two Trees plan would do almost nothing to improve the abysmally low open space ratio on the Southside.

Then there are concerning issues of just how “public” the open space will be. Two Trees has been noncommittal on transferring the new River Street over to the City and is opposed to turning over the other public spaces at Domino to City Parks. This raises the question, why would the community prefer a slightly larger piece of private open space to the public open space promised by the 2010 CPC plan?

Moreover, renderings and diagrams Two Trees has created to illustrate uses at the proposed “Domino Square” (the large open parcel that is the company’s justification for building taller) depict flea markets, banquets, and cocktail parties where public access would clearly be restricted and curtailed. The constant occupation of East River Park by these private uses is spurring considerable controversy in Northside Williamsburg. It is completely unclear how often the proposed “Domino Square” will be occupied by this kind of event programing, how curtailed the public access will be when these events are taking place, and what kind of access local community organizations will have to hold events. And if the “public” spaces are privately owned and operated by Two Trees, will they have the right to establish their own rules and regulations governing access and uses? Will Two Trees have its own private security patrolling the “public space”?

Maintaining the public spaces in private hands is a dangerous precedent to set on the waterfront where public access and ownership has been a core promise of City government for decades. Two Trees should commit to turning over the public spaces to the City and be very clear in establishing how access to “Domino Square” will be decided and regulated.

Other actions that Two Trees could take in support of open space in Williamsburg include making a financial contribution to the development of “Williamsburg Bridge Park” on the city-owned lots under and adjacent to the bridge. Two Trees has already claimed they will “support” such efforts but they have not committed to financially contributing. Two Trees could also make a financial contribution to the further development of Bushwick Inlet Park just up Kent Avenue from Domino. Both of these actions would be true “win wins” – increasing Two Trees’ property value at Domino while contribution to meaningfully expanding open space in Williamsburg.


One of Two Trees major selling points is the provision of an additional 405,570 square feet of commercial office space in the development that will help create“3,000 new jobs.” But just as we must ask “affordable housing for whom?” we must also ask “jobs for whom?”

All of the public comments Two Trees has made about the proposed office space indicates that it is intended for companies in the tech and new media sectors. The developer holds up Vice Media as an example of the kind of company it’s office space will be geared for. So who will be holding these promised 3,000 new jobs? Without a concerted effort at job training and local hiring, the answer is mostly young white men. American Community Survey data tells us that more than two thirds of workers in the tech and media sectors in the New York City area are white. Only 8% are Hispanic/Latino.

Community Preservation Corporation had committed to job training programs in the 2010 plan. According to the Borough President’s report, Two Trees is considering working with St. Nick’s Alliance on a job training program. This is a welcome improvement from earlier in the process when there was no mention of job training, but we are once again lacking a concrete proposal. I agree with the Borough President’s recommendation that Two Trees outline and submit its job-training and local-hiring proposals in writing and that they be memorialized in a legally-binding mechanism.

In addition to job training, access to affordable broadband access is a major issue for working class-communities. Two Trees could make a valuable contribution by offering free- wi-fi access throughout Domino’s public spaces and community facilities.

Two Trees has also emphasized that they will look to provide commercial and retail space for local businesses at Domino, including businesses engaged in light manufacturing and the arts. But the developer’s record in DUMBO raises concerns that many local businesses and artists will be cast aside for higher profile commercial tenants once the market permits.

The Brooklyn Borough President’s suggestion for a “a lease protection mechanism that provides for the continued use of such retail for artisans and start-up office space, in order to provide protection from future market based rents, which may include the achievement of stabilized rents by providing leases through a designated not-for-profit or some equivalent entity” is an excellent idea.


The redevelopment of Williamsburg spurred by the 2005 rezoning has had profound effects on the character and composition of the neighborhood. As a local resident who has studied land use in the area for many years, I am convinced that rapid re-development dominated by luxury residential is killing the dynamic mixed-use, mixed-income, mixed-ethnicity character of Williamsbur

  • According to American Community Survey data, from 2000 to 2010 Community Board 1 lost nearly 16,000 affordable apartments that had rents less than $1,000 a month. In 2000, there was hardly a single apartment that cost over $2,000 a month; in 2010 there were over 6,000 such apartments in Community Board 1
  • From 2000 to 2010, the Hispanic population in CB1 dropped 24%
  • From 2000 to 2010, the 11211 zip code lost nearly two thirds of its industrial jobs.
  • No doubt all of these figures have gotten much worse since 2010.

The density of the proposed Domino project is immense – it will double the population of the waterfront area of the Southside (bounded by Kent Ave, Grant St, Driggs Ave, and South 5th St.), adding thousands of wealthy residents and workers. If community benefits and mitigation measures are not smartly done, this project is a displacement time-bomb. Two Trees and other major developers in Williamsburg should commit to funding local community organization to engage in anti-displacement work. This is by far the most cost-effective way to preserve existing affordable (rent-stabilized) housing units.

As for industrial jobs, earlier this month, Crain’s New York Business reported on skyrocketing rents and bidding wars for industrial properties throughout the five boroughs, but especially in North Brooklyn and the Long Island City area of Queens. One of the primary reasons?The “rampant erosion of industrial locations in recent years, owing to residential rezonings and growth in competing uses such as retailing and hotels.”

In contrast to tech and media jobs, the workforce for industrial jobs is majority people of color and foreign born, and industrial jobs pay nearly twice as much on average as retail work in New York City. By Two Trees’ own data in the technical memorandum, there are still 24 manufacturing and 30 wholesale trade firms amounting to nearly 900 jobs within a quarter-mile of the Domino site. But without concerted action by Two Trees and the City, it is hard to envision these businesses continuing once the proposed Domino development is built. Two Trees should commit to preserving a portion of the commercial space at Domino for light industrial businesses, and the City should seek to protect the existing lots directly north and inland from Domino that remain zoned M-3 for industrial uses. The vacant properties north of the Con Ed substation on the waterfront, currently zoned M-3, offer a particularly rich opportunity for creative industrial development, but this will never happen unless the City sends a firm signal that the land will not be rezoned for residential.

Looking at how Williamsburg has transformed since the 2005 rezoning, it is abundantly clear that a course correction is necessary to facilitate development that lives up to a higher standard of “good growth” that encourages broadly-shared long-term prosperity.

Although more creative alternatives with a greater emphasis on industrial and commercial space would be ideal in a perfect world, I nevertheless believe Two Trees’ Domino project has the potential to improve on previous waterfront development in Williamsburg – but only if the public benefits are more clearly defined, strengthened, and locked into a binding restrictive deed, and if the developer and City take additional measures to prepare for and mitigate secondary impacts as outlined above.


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