Appendix N Indirect and Cumulative Effects
 N-1 June 2021 

Appendix N: Indirect, Cumulative, and Other Impacts 

N.1 INTRODUCTION 

This appendix provides additional detail on the methodology and assumptions FRA used to 

prepare the Indirect and Cumulative Impacts analysis of the Western Rail Yard Infrastructure 

Project (see Chapter 20, “Indirect, Cumulative, and Other Impacts”). This appendix also contains 

details of the updated analysis for resource categories that warranted additional analysis. 

N.2 AFFECTED ENVIRONMENT 

As discussed in Chapter 4, “Analysis Framework,” the Study Area includes numerous planned 

and ongoing development and transportation projects. In addition, as discussed in Chapter 1, 

“Introduction,” the Platform would enable the construction of the as-of-right development of the 

Overbuild, which is an indirect effect of the Preferred Alternative. The following section describes 

the indirect effects of the Preferred Alternative. 

N.3 INDIRECT OPERATIONAL IMPACTS OF THE 

PREFERRED ALTERNATIVE 

Throughout this section, references to the Overbuild are included in the context of that 

development being a previously approved project (as analyzed in the 2009 SEQRA/CEQR FEIS) 

that would be an indirect consequence of the Preferred Alternative, with associated indirect 

effects. 

LAND USE, LAND PLANNING, AND PROPERTY 

Local and Regional Plans and Policies 

Table N-1 provides a discussion of the consistency of the indirect effects of the Preferred 

Alternative with relevant local and regional plans and policies. 
June 2021 N-2 

Table N-1 

Local and Regional Plans and Policies- Indirect Effects 

Local and Regional Plans 

and Policies Description 

New York City Waterfront 

Revitalization Program 

(LWRP) 

The indirect impacts of the Preferred Alternative would be consistent with the 

LWRP by supporting policies related to encouraging commercial and residential 

development in appropriate Coastal Zones. 

ONENYC 

The indirect impacts of the Preferred Alternative would be consistent with 

OneNYC. In the future, the Project Site would be a mixed-use development that 

generates revenue for the MTA. The Overbuild Developer, the successful bidder 

of a competitive bid issued by MTA for the long-term ground leases with option 

to purchase severed fee parcels (for the development air rights over the Hudson 

Yards from MTA) would construct the Overbuild and would generate revenue for 

the MTA. This promotes OneNYC 2050’s initiative to modernize New York City’s 

mass transit network by helping fund the MTA capital plan. 

Vision 2020 

The indirect impacts of the Preferred Alternative would be consistent with the 

goals of Vision 2020 of improving the New York City waterfront. Although not 

constructed directly on the waterfront, the Project Site is close to the waterfront 

and thus supports ongoing initiatives to redevelop waterfront areas with active uses. 

Master Plan Caemmerer 

West Side Yard 

The indirect impacts of the Preferred Alternative would be consistent with the 

1989 MTA Master Plan. The construction of the Overbuild accomplishes the goal 

of the 1989 Master Plan to have development (Overbuild) constructed above the 

active rail yard. 

Northeast Corridor 

Infrastructure Master Plan 

There are no indirect impacts from the Preferred Alternative that relates to this 

plan. Therefore, this plan is not applicable. 

Amtrak’s Northeast 

Corridor Gateway Program 

There are no indirect impacts from the Preferred Alternative that relates to this 

plan. Therefore, this plan is not applicable. 

NYMTC’s Regional 

Transportation Plan 2045 

The indirect impacts of the Preferred Alternative includes building a transit 

oriented development above a functioning rail yard. NYMTC’s Regional 

Transportation Plan 2045 includes an initiative to plan for sustainability. A key 

component to achieving this initiative includes transit oriented development 

projects. The Overbuild can be categorized as a transit oriented development as 

it is a compact, mixed-use development near transit facilities and located within a 

high-quality walking environment. Therefore, the indirect impacts of the Preferred 

Alternative is consistent with NYMTC’s Regional Transportation Plan. 

FRA’S NEC FUTURE There are no indirect impacts from the Preferred Alternative that relates to this 

plan. Therefore, this plan is not applicable. 

TRANSPORTATION 

Traffic 

The indirect effects of the Preferred Alternative would include increasing vehicular traffic demand 

in the Study Area. FRA considered the three development scenarios examined in the 2009 

SEQRA/CEQR FEIS, as defining the Reasonable Worst-Case Development Scenario (RWCDS), 

including: the Maximum Residential Scenario, the Maximum Commercial Scenario (only for the 

weekday analyses) and the Maximum Residential Scenario-Hotel Option (only for the Saturday 

analysis). In addition, the Overbuild project proposed two changes to the roadway network: a 

northern upland connection from Eleventh Avenue that would align approximately with West 32nd 

Street and southern upland connection accessible from Eleventh Avenue that aligns 

approximately with West 31st Street. This remains the standing site plan. 

Total vehicle trips generated by each development scenario can be found in the 2009 

SEQRA/CEQR FEIS and remain applicable. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-3 June 2021

The 2009 SEQRA/CEQR FEIS identified measures to mitigate, either in part or in whole, the 

adverse traffic impacts of the Overbuild. Overall, the Overbuild would be included in the monitoring 

and mitigation program established by New York City to manage the larger area-wide Hudson 

Yards initiative (assessed in a 2004 FGEIS). With the Overbuild, it is expected that City’s 

monitoring program would be expanded to include traffic generated by the development such that 

mitigation could be adjusted, and area-wide measures expanded, as necessary, in order to 

minimize congestion in the Study Area. 

Overall, these area-wide and project-specific mitigation measures would include: 

 Elimination of on-street parking within 150 feet of intersections to add a limited travel lane, 

known as “daylighting”; 

 Enforcement of existing parking restrictions to ensure that traffic lanes are available to moving 

traffic; 

 Channelization and lane designation changes to make more efficient use of available street 

widths; and 

 Installation of traffic signals at unsignalized intersections if warranted. 

The environmental findings for the 2009 SEQRA/CEQR FEIS approved project identified that of 

the 64 intersections with impacts in AM peak hour, there would be 10 unmitigated impacts; in the 

Midday peak hour there would be 3 unmitigated impacts out of 60 intersections; 13 unmitigated 

impacts out of 75 intersections in the PM peak hour; and, 5 unmitigated impacts of 48 intersections 

during the Saturday peak hour. These effects have been disclosed and acknowledged as part of 

the completed City approval process for the Overbuild and would continue to be reasonable 

assessment of the potential indirect effect of the Preferred Alternative. 

Parking 

The indirect effects to parking of the Preferred Alternative, resulting from the Overbuild were 

identified in the findings adopted by the City as part of the 2009 SEQRA/CEQR FEIS, which 

indicated that the Overbuild would further exacerbate the weekday midday off-street parking 

shortfall in the parking Study Area, but not substantially. It is expected that the available off-street 

parking supply would be able to accommodate the increase in overnight demand generated by 

the Overbuild. While the midday shortfall was estimated to be as high as 460 parking spaces, the 

2009 SEQRA/CEQR FEIS noted that City policy establishes that for projects within the Manhattan 

Business District (defined as the area south of 61st Street), the inability of a proposed action or 

the surrounding area to accommodate projected future parking demands would be considered a 

parking shortfall, but is not deemed to be an adverse impact. The unsatisfied demand for parking 

spaces during the midday peak utilization period would result in vehicles parking outside of the 

parking Study Area and motorists walking greater distances to their destinations. As parking 

shortfalls do not constitute adverse impacts under the CEQR Technical Manual guidance, no 

mitigation was required in 2009 SEQRA/CEQR FEIS and there has been no change in City policy. 

As a result, the Overbuild would not result in any indirect parking effects of the Preferred 

Alternative. 
June 2021 N-4 

Traffic Safety 

The Preferred Alternative would indirectly increase pedestrian volumes given the features and 

function of the Overbuild. The transformation of the Hudson Yards is resulting in substantially more 

residents, workers, and visitors all translating into more traffic, more pedestrians, and more 

bicyclists. This increase in demand has been accompanied by improvements including the 

exclusive bus lanes on 34th Street which limit turns onto north-south avenues, a Class 1 Bicycle 

Path (separated on-street path) on Ninth Avenue from south of the Study Area to West 33rd Street 

and a Class 2 Bicycle Lane (on-street striped route) on Seventh and Eighth Avenues, signal timing 

and phasing modifications to include bicyclist priority, as well as other pedestrian safety programs 

including lead the Safe Streets for Seniors program. In addition, based on the large increase in 

pedestrian volumes generated by the Overbuild, the 2009 SEQRA/CEQR FEIS committed to a 

range of pedestrian circulation improvements including 15 new bulb outs and 17 crosswalk 

widenings. 

The measures that have been implemented by NYCDOT, in combination with the indirect benefits 

associated with the Overbuild improvements, indicates that there would be no additional indirect 

effects of the Preferred Alternative on traffic safety. 

Transit 

The 2009 SEQRA/CEQR FEIS analyzed the potential indirect effects on transit for the immediately 

adjacent No. 7 Subway line and its Hudson Yards station. The analysis in the 2009 SEQRA/CEQR 

FEIS also examined the potential additional demand at the 34th Street stations for both the Eighth 

and Seventh Avenue subway lines. The analysis indicated that the Maximum Commercial 

Scenario would generate the highest level of subway trips for all weekday peak periods. Among 

the three scenarios, there could be additional demand of peak hour subway trips of approximately 

3,410, 1,420, 4,150 total trips during the weekday AM, midday and PM peak hours, and 1,900 

total trips in the Saturday peak hour (from the Maximum Residential scenario). 

Because the identified mitigation measure identified in the 2009 SEQRA/CEQR FEIS has already 

been constructed (the staircase reconstruction was completed as part of the Phase I Moynihan 

Station Improvements, in combination with MTA’s Rapid Renewal Program), no additional indirect 

effects from the Preferred Alternative on subway station elements at these locations would be 

expected. 

Bus Routes 

The indirect effects of the Preferred Alternative are generated by the previously approved 

Overbuild, which would add considerable demand for bus ridership. The 2009 SEQRA/CEQR 

FEIS noted that the Maximum Commercial Scenario would generate the highest level of bus trips 

for all weekday peak periods, as well as midday. Both the Maximum Commercial Scenario and 

the Maximum Residential with Office Scenario would generate the highest level of bus trips on 

Saturdays. Among the three scenarios, there could be additional demand of peak hour bus trips 

of approximately 1,110, 810, 1,290 total trips during the weekday AM, midday and PM peak hours, 

and 490 total trips in the Saturday peak hour. 

The 2009 SEQRA/CEQR FEIS impact assessment looked at potential changes in bus service 

from this new demand for the following bus routes: M10, M11, M16, M20, M23, M34, and M42. 

The incremental demand from the Overbuild was estimated to result in adverse impacts on the 

M10/M20, M11, and M34 bus service and the 2009 SEQRA/CEQR FEIS identified the additional 

buses that would be necessary to mitigate the change. The 2009 SEQRA/CEQR FEIS also noted 

that New York City Transit’s general policy is to provide additional bus service where demand 

warrants taking into consideration financial and operational constraints. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-5 June 2021

It is noted that the implementation of the 34th Street SBS was implemented by the City and the 

MTA and SBS began operations in late 2011. It was not considered a No Action project in the 

2009 SEQRA/CEQR FEIS but was in its initial planning and, in part, was implemented based on 

the growth of transportation demand generated by the overall growth of Hudson Yards district 

(including the Western Rail Yard). The limits on turns, the provision of dedicated bus lanes and 

the increase in frequency in both articulated and regular buses has expanded the frequency of 

service in keeping with the 2009 SEQRA/CEQR FEIS findings, although bus headways have not 

yet reached the specific peak hour optimal headway conditions set forth in the 2009 

SEQRA/CEQR FEIS. 

Pedestrians 

The indirect effects of the Preferred Alternative are generated by the previously approved 

Overbuild and include the substantial increase in pedestrian activities on the Study Area sidewalks 

and crosswalks. As estimated in the 2009 SEQRA/CEQR FEIS, the Maximum Residential with 

Hotel scenario would generate the highest number of trips made solely by walking in the AM and 

PM peak periods. The Maximum Commercial Scenario would generate the highest number of 

made solely by walking in the midday peak as well as the Saturday peak. Among the three 

scenarios, there could be additional demand of peak hour pedestrian trips of approximately 3,790, 

8,750, 4,620 total trips during the weekday AM, midday and PM peak hours, and 5,160 total trips 

in the Saturday peak hour. 

Mitigation requirements established in the 2009 SEQRA/CEQR FEIS and carried into the findings 

and conditions for the approved project include improvements to sidewalks, street corners and 

crosswalks, including relocating planters or street vendors, creating corner bulb outs on the 

avenue side of key intersections, and widening crosswalks at impacted crosswalk locations. 

These mitigation measures remain applicable for the assumed 2030 completion of the Overbuild 

and would resolve most of the impacts identified in the 2009 SEQRA/CEQR FEIS. The 2009 

SEQRA/CEQR FEIS noted that certain pedestrian adverse impacts could not be mitigated without 

causing adverse impacts on traffic conditions beyond those identified in the traffic analysis. As 

part of the overall Hudson Yards traffic monitoring program, the City would continue, as 

appropriate, to identify potential improvement measures. 

AIR QUALITY, GREENHOUSE GAS EMISSIONS, AND 

RESILIENCE 

The previously approved Overbuild would proceed as the Preferred Alternative is built. As a result, 

FRA considers the potential increased pollutant emissions within the Study Area associated with 

the additional vehicular traffic, and building emissions of the Overbuild to be an indirect effect of 

the Preferred Alternative. FRA has summarized the anticipated indirect effects of the completed 

Overbuild primarily based on the completed 2009 SEQRA/CEQR FEIS air quality analysis, where 

applicable. 

Mobile Source Analysis 

The 2009 SEQRA/CEQR FEIS air quality analysis considered the potential air quality effects of 

the RWCDS of the Overbuild. The increases in vehicular traffic associated with the Overbuild 

would remain within the framework of the already approved project; therefore, projections of 

pollutant concentrations provide a conservative representation of indirect air quality effects of the 

Preferred Alternative. 
June 2021 N-6 

Development of the Overbuild would result in an increase of vehicular traffic volumes and 

consequently, increased pollutant concentrations in the Study Area. FRA considered the effects 

in the 2009 SEQRA/CEQR FEIS, finding that emissions from increased traffic or changed traffic 

patterns as an indirect effect of the Preferred Alternative would not cause or exacerbate a violation 

of NAAQS or cause an exceedance of NYSDEC/NYCDEP significant threshold values (STVs) for 

PM2.5 or of the DEP de minimis criteria for CO, and thus would not have a significant adverse air 

quality impact. 

Stationary Source Analysis 

FRA considered the effects associated with the emissions from the HVAC systems of the RWCDS 

of the Overbuild as discussed in the 2009 SEQRA/CEQR FEIS air quality analysis. The analysis 

concluded the indirect effects of the Preferred Alternative would not cause a violation of the 

NAAQS or an exceedance of the STVs—either from the impacts of the HVAC emissions of the 

buildings comprising the Overbuild on receptors at these buildings (project-on-project impacts) or 

on receptors at existing and future developments. In addition, the HVAC emissions of existing and 

future developments, as well as “major” existing emission sources, would not significantly affect 

the Preferred Alternative’s buildings. Therefore, the proposed HVAC systems would not result in 

an adverse air quality impact. 

The Overbuild would introduce new receptor locations within the Study Area of the air quality 

analysis performed to determine the air quality impact associated with the ventilation of dual-mode 

locomotive engine exhaust (see Chapter 7, “Air Quality, Greenhouse Gas Emissions, and 

Resiliency”). Therefore, FRA conducted an analysis to determine the potential air quality impacts 

at these receptors. 

As shown in Table N-2, the maximum predicted total concentrations are below the applicable 

NAAQS. PM2.5 and CO incremental concentrations are below the City’s de minimis criteria for 

these pollutants. Therefore, FRA has predicted that the indirect effects of the Preferred Alternative 

would not result in any adverse air quality impacts. Table N-2 shows the maximum indirect 

pollutant concentrations from the tunnel ventilation systems. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-7 June 2021

Table N-2 

Maximum Indirect Pollutant Concentrations from Tunnel Ventilation Systems 

Pollutant Averaging Period Units 

Maximum Modeled 

Impact(1)

Background 

Concentration(2) 

Total 

Concentration NAAQS 

NO2 1-hour μg/m3 N/A(3) N/A(3) 176.9 188 

Annual μg/m3 1.9 37.9 39.8 100 

CO 1-hour ppm 0.6 2.5 3.1 35(4)

8-hour ppm 0.1 1.2 1.3 9(4)

PM10 24-hour μg/m3 3.1 38 41.1 150 

PM2.5 

24-hour μg/m3 3.1 19.7 22.8 35(5)

Annual μg/m3 0.07 9.0 9.07 15(5)

Notes: 

N/A—Not Applicable 

(1) Modeled impacts represent projected concentrations at facades of the buildings comprising the Overbuild and 

newly introduced open space locations. 

(2) The background levels are based on the most representative concentrations monitored at NYSDEC ambient air 

monitoring stations. Due to the statistical form of the associated NAAQS background concentrations may differ 

from existing concentrations in Table 7-2. 

(3) The 1-hour average NO2 concentration represents the maximum of the total 98th percentile 1-hour concentration 

predicted at any receptor using seasonal-hourly background concentrations. Modeling impacts are added to 

background concentrations for each hour within the AERMOD model. Therefore, the maximum modeled impact 

and background concentration are not applicable. 

(4) While the Preferred Alternative is not required to utilize impact criteria from the CEQR Technical Manual, the 8-hour 

average CO de minimis incremental concentration threshold of 4.7 ppm is considered as one factor in 

determining whether the Preferred Alternative may result in significant environmental impacts. 

(5) While the Preferred Alternative is not required to utilize impact criteria from the CEQR Technical Manual, the 24-

hour and annual average PM2.5 de minimis incremental concentration thresholds of 7.7 μg/m3 and 0.3 μg/m3, 

respectively, are considered as one factor in determining whether the Preferred Alternative may result in 

significant environmental impacts. 

NOISE AND VIBRATION 

The previously approved Overbuild would proceed as the Preferred Alternative is built. As a result, 

FRA considers the additional vehicular traffic and associated potential for noise level increases in 

the Study Area to be indirect effect of the Preferred Alternative. This section summarizes the 

anticipated effects of the completed Overbuild primarily based on the completed 2009 

SEQRA/CEQR FEIS noise analysis. The 2009 SEQRA/CEQR FEIS noise analysis considered the 

potential noise effects of the RWCDS on the proposed Platform, and its noise level projections 

provide a conservative representation of indirect noise effects of the Preferred Alternative because 

the program of the Preferred Alternative and its associated increases in vehicular traffic would 

remain within the framework of the already approved project. 

The indirect impacts of the Preferred Alternative would include increases in vehicular traffic 

volumes and consequently increasing noise levels in the project Study Area as a result of the 

Overbuild. FRA considered the indirect effects in the 2009 SEQRA/CEQR FEIS, finding that 

resulting noise level increases would be imperceptible to barely noticeable and would not be 

considered significant according to CEQR Technical Manual noise impact criteria. The expected 

increases in vehicular traffic volumes in the future with the Preferred Alternative would be 

comparable to or lower than those studied in the 2009 SEQRA/CEQR FEIS and would result in 

comparable or smaller noise level increases. Consequently, the indirect effects on noise levels 

due to vehicular traffic associated with the Preferred Alternative would also not rise to the level of 

a significant impact. 
June 2021 N-8 

CULTURAL RESOURCES 

The findings adopted by New York City as part of the 2009 SEQRA/CEQR FEIS project approvals 

indicate that the Overbuild would result in significant adverse impacts to cultural resources. The 

effects disclosed and acknowledged in the 2009 SEQRA/CEQR FEIS continue to be a reasonable 

assessment of the potential indirect effect of the Preferred Alternative on cultural resources for 

this EIS. 

The Overbuild would directly affect the High Line—a resource previously determined eligible for 

the State and National Registers of Historic Places by NYSHPO, with a section located on the 

Project Site. This section of the High Line would be integrated into the overall site plan for the 

Overbuild as a passive open space resource and pedestrian pathway that would connect with the 

portion of the High Line on the Eastern Rail Yard and the 1.5 mile High Line Park to the south. In 

order to fully integrate the High Line with the planned open space network on the Project Site, 

some features—such as railings—of the High Line’s Twelfth Avenue section would be removed. 

This action is associated with the Overbuild and is not part of the Preferred Alternative, and would 

be conducted by the Overbuild Developer, a private developer, as part of a privately funded 

project. Since the final design of the Overbuild had not been determined at the time of the 2009 

SEQRA/CEQR FEIS, a LOR was executed among NYSHPO, the MTA, the New York City 

Planning Commission, and the Overbuild Developer, in compliance with Section 14.09 of the New 

York State Historic Preservation Act of 1980, requiring the Overbuild Developer to submit the 

relevant portions of the preliminary and pre-final design plans for the Overbuild that affect the High 

Line to NYSHPO for review and comment. The LOR and the RD for the previously approved 

project also require that a CEPP be developed in coordination with NYSHPO and LPC to protect 

the High Line from any potential construction-related adverse physical impacts, such as groundborne construction-period vibrations, falling debris, and damage from heavy machinery. 

The City’s findings as part of the 2009 SEQRA/CEQR FEIS also note that the anticipated site plan 

for the Overbuild would result in several buildings located immediately adjacent to the High Line; 

therefore, in order to preserve the integrity of this architectural resource, a five-foot-wide set back 

would be located between the High Line and buildings fronting on the High Line. 

The Overbuild as currently contemplated is consistent with the massing envelope assumptions 

analyzed in the 2009 SEQRA/CEQR FEIS. The Overbuild is not expected to have any adverse 

effects on the context or setting of nearby historic properties. The Hudson Yards neighborhood is 

experiencing a wave of development of new tall and modern skyscraper buildings, and the historic 

properties in the APE already exist in a mixed built context of smaller, older and masonry clad 

buildings and these taller buildings of recent construction with metal and glass curtain walls. 

Specifically, the W & J Sloane Warehouse and Garage is flanked by new 31-, 33-, and 34-story 

developments directly to the north and south, and the West Chelsea Historic District buildings 

within the APE are across Eleventh Avenue and West 28th Street from the same 34-story 

development. Twelfth Avenue and the Hudson River Greenway provide visual separation between 

the Hudson River Bulkhead and the Project Site and surrounding new development. Therefore, 

the Overbuild would have no direct or indirect, physical, auditory, or visual effect on the W & J 

Sloane Warehouse and Garage, Hudson River Bulkhead, and the West Chelsea Historic District. 

The New York Improvements and Tunnel Extension of the Pennsylvania Railroad, as a subsurface 

feature, would have no visual relationship with the Overbuild, and FRA has concluded that the 

Overbuild would have no direct or indirect, physical, auditory, or visual effect on the Tunnel. 

The portion of the High Line on the Project Site would be directly adjacent to the multi-building, 

high-rise Overbuild; however, the resulting visual context would be consistent with portions of the 

High Line within the APE that are directly adjacent to the new high-rise buildings on the Eastern 

Rail Yard (including 10 Hudson Yards and 12 Hudson Yards) and at 500 West 30th Street 

(Abington House). 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-9 June 2021

FRA has concluded that the potential effects of the Overbuild are possible inadvertent effects to 

the High Line during construction of the Overbuild, and possible indirect physical and/or visual 

effects to the High Line related to construction and operation of the Overbuild. 

To ensure that the potential effects of the Overbuild are not adverse, as a condition of the ROD 

FRA would require the Project Sponsor (which includes the Overbuild Developer, a signatory to 

the LOR) to meet all of the conditions of the LOR, which as noted above includes review of 

Overbuild design by NYSHPO and New York City Landmarks Preservation Commission, as well 

as development of a CPP as a component of an overarching CEPP (see Chapter 22, “Mitigation 

Measures and Project Commitments”) to protect the High Line during construction of the 

Overbuild. 

PARKS AND RECREATION 

FRA finds that the Preferred Alternative would have no indirect effects on parks and recreation 

areas. The adopted findings by New York City as part of the 2009 SEQRA/CEQR FEIS project 

approvals are that the Overbuild would result in adverse impacts on parks and recreation areas. 

The impact would be due to anticipated decreases in the active and total open space ratios (the 

amount of active or total open space per 1,000 persons) in the surrounding area from the 

introduction of new workers and residents. Changes in open space ratios are not an impact 

threshold in this NEPA analysis. 

The creation of approximately 5.45 acres of new open space on the Project Site as part of the 

Overbuild would provide a considerable open space amenity for residents and workers and would 

serve as a link in the open space network that is being developed throughout the Hudson Yards 

area. In addition, the Interim Walkway portion of the High Line between West 30th and 34th Streets 

would be renovated as part of the Overbuild, to incorporate it into the overall High Line design. 

These elements associated with the Overbuild would be beneficial indirect effects of the Preferred 

Alternative. As detailed above, a CPP would be developed and implemented to protect the High 

Line open space during construction of the Overbuild. 

In New York State, temporary or long-term use of publicly owned parkland under the jurisdiction 

of a municipality (i.e., city, county, town, or village) for non-park purposes constitutes alienation, 

and requires the approval of the New York State Legislature. Parkland “alienation” occurs when a 

municipality wishes to sell, lease, or discontinue municipal parkland, including subsurface 

easements beneath parkland. The Overbuild would not require any use of publicly owned parkland 

under the jurisdiction of the local municipality (i.e., parkland controlled by the City of New York) 

that would constitute parkland alienation. 

AESTHETICS AND VISUAL QUALITY 

The Overbuild, which is an indirect consequence of the Preferred Alternative, was 

comprehensively analyzed in the 2009 SEQRA/CEQR FEIS and subsequently approved by New 

York City; the findings adopted by the City indicated that the Overbuild would not result in any 

significant adverse impacts on urban design and visual resources (i.e., aesthetics and visual 

quality). These effects have been disclosed and acknowledged as part of the completed City 

approval process for the Overbuild and would continue to be a reasonable assessment of the 

potential indirect effect of the previously approved project for this EIS. 
June 2021 N-10 

The Overbuild would have a beneficial effect on the Project Site. It would consist of up to eight 

mixed-use towers and a varied 5.45-acre open space network on the Project Site. The Overbuild 

would enliven the Project Site, its street frontages, and the surrounding area with active groundfloor retail and school uses, anticipated widened sidewalks, and a street-tree program for the 

interior of the site and the sidewalks that border the perimeter of the site. The Overbuild would 

provide access to the currently inaccessible site through the creation of two roadways roughly 

aligned with the formerly mapped West 31st and West 32nd Streets. A large open space network 

with a variety of elements would provide landscaped areas, including vantage points from which 

users could enjoy unobstructed views of the Hudson River. 

The Overbuild as currently contemplated is consistent with the massing envelope assumptions 

analyzed in the 2009 SEQRA/CEQR FEIS, and in terms of building uses, bulk, height, density, 

and setback, it be would be similar in scale and design to Hudson Yards. While viewer groups in 

the AVE would be sensitive to effects from the Overbuild, it would have a neutral effect on the 

visual quality of the AVE as it would be in keeping with the ongoing trend of development of new 

tall and modern skyscraper buildings in the AVE. 

The Overbuild would have a neutral effect on the two visual resources in the AVE. It would not 

block views to the Hudson River along West 30th and West 33rd Streets or from the High Line, 

and new views of the Hudson River, Hudson River Park, and the New Jersey skyline would be 

created across the Project Site from Eleventh Avenue along the two roadways aligned with the 

formerly mapped West 31st and West 32nd Streets. Currently, the concrete wall bordering the site 

on Eleventh Avenue obstructs views through the site from the avenue west to the Hudson River. 

In addition, the landscaped areas on the Project Site would provide new unobstructed views of 

the Hudson River, Hudson River Park, and the New Jersey skyline. While the Overbuild would 

block some views east of the Vessel from Twelfth Avenue and Hudson River Park, the Vessel 

would be visible along the new view corridors across the Project Site and from the new landscaped 

areas on the Project Site. The Vessel would also continue to be visible from Eleventh Avenue and 

from Bella Abzug Park. 

The High Line and the Hudson Yards plaza would provide views of the Overbuild, and users of 

those spaces would be sensitive to changes in visual quality from the Overbuild. While users of 

the High Line would have views of the Overbuild, their views of the Hudson River would not be 

affected, and users’ views of the Overbuild would be similar to views of Hudson Yards from the 

High Line. From the elevated plaza in Hudson Yards, viewers would clearly see the Overbuild, as 

would visitors to the Vessel. While the Overbuild would obstruct some views of the Hudson River 

and the Hudson River vista, the two roadways aligned with the formerly mapped West 31st and 

West 32nd Streets would provide views across the Project Site to the Hudson River. 

UTILITIES AND ENERGY 

This section presents an assessment of the potential indirect effects of the Preferred Alternative 

on utility infrastructure and services. Specifically, the assessment compares the projected demand 

of the Overbuild on utility services to the development analyzed in the 2009 SEQRA/CEQR FEIS, 

and determines whether the current development would result in significant additional demand 

that would have the potential to result in adverse impacts. The assessment uses the methodology 

and demand rates of the CEQR Technical Manual. 

Water Supply 

As discussed in Chapter 14 of the 2009 SEQRA/CEQR FEIS, “Infrastructure,” the Overbuild 

buildings would be supplied by NYCDEP mains located within West 30th and West 33rd Streets. 

Table N-3 presents the estimated water demand of the Overbuild. The 2009 SEQRA/CEQR FEIS 

estimated that the Overbuild would consume approximately 2 million gpd, including approximately 

1,025,000 gpd for domestic uses and approximately 989,400 gpd for air conditioning. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-11 June 2021

Table N-3 

Overbuild Water Consumption and Sanitary Sewage 

Use Size/Population Rate1 Consumption (gpd) 

Residential—Domestic 4,000 DU (6,800 

residents2) 0.10 gpd/sf 680,000 

Residential—Air Conditioning 3,300,000 sf 0.17 gpd/sf 561,000 

Hotel—Domestic 470 rooms 120 gpd/person/room3 112,800 

Hotel—Air Conditioning 250,000 sf 0.17 gpd/sf 42,500 

Commercial Office—Domestic 2,075,000 sf 0.10 gpd/sf 207,500 

Commercial Office—Air Conditioning 2,075,000 sf 0.17 gpd/sf 352,750 

Retail—Domestic 75,000 sf 0.24 gpd/sf 18,000 

Retail—Air Conditioning 75,000 sf 0.17 gpd/sf 12,750 

School—Domestic 750 seats 10 gpd/seat 7,500 

School—Air Conditioning 120,000 sf 0.17 gpd/sf 20,400 

Total Water Supply Demand 2,015,200 

Total Sewage Generation 1,025,800 

Notes: 1 Rates are from the CEQR Technical Manual Table 13-2 2 The Project Sponsor has estimated a lesser number of residential units, with a mix of renal and 

condominium units. FRA has estimated 4,000 residential units based on an average unit size of 825 

square feet, to present a conservative analysis that accounts for possible future changes to market 

conditions and resulting unit sizes. 3 Residential population estimate based on average household size of 1.7 persons per DU for Manhattan 

Community District 4 (2014–2018 ACS 5-Year Survey). 4 Hotel domestic consumption estimate assumes two guests per room. 

As shown in Table N-3, the water demand FRA calculated for the Overbuild (approximately 1.015 

mgd) is larger than the demand presented in the 2009 SEQRA/CEQR FEIS (approximately 1.5 

million gpd) and would be a substantial addition to water demand on the Project Site. However, 

the additional demand of the Overbuild represents a minor increase in demand (0.15 percent) on 

the City’s daily water supply of approximately one billion gpd. In addition, following the publication 

of the 2009 SEQRA/CEQR FEIS, NYCDEP has made improvements to the local water supply 

infrastructure in the area of the Project Site. In particular, the City has constructed Water Tunnel 

No. 3 and the portion of Water Tunnel No. 3 serving Midtown Manhattan, including the Project 

Site and the surrounding area, was completed and activated in 2013. Additional improvements 

have been made in the area in accordance with the NYCDEP Manhattan Trunk Main Master Plan 

(the “Trunk Plan”), which outlined water supply improvements necessitated by the Hudson Yards 

area, including connections to Water Tunnel No. 3. NYCDEP intended for the construction of the 

tunnel and related improvements to the water supply system to provide additional supply and 

enhance system pressure stability to the local area. In consideration of the recent system 

improvements, it is anticipated that NYCDEP can adequately provide for the increased demand 

required by the Overbuild. Therefore, the Overbuild would not result in adverse impacts on the 

City’s water supply system as an indirect result of the Preferred Alternative. 
June 2021 N-12 

Wastewater 

Sanitary sewage generated by the Overbuild is expected to discharge to the NYCDEP sewer 

system in the surrounding streets. NYCDEP developed an Amended Drainage Plan (ADP) as part 

of the approvals for the Overbuild, which identifies improvements to the existing storm and 

combined sewer system infrastructure that are necessary to accommodate the full build out of the 

Hudson Yards area. The improvements identified by the ADP include the replacement of the 

existing combined sewer in West 33rd Street, on the north side of the Project Site, with a separate 

storm sewer and sanitary sewer. Independent of the Preferred Alternative, the City is undertaking 

a project to reconstruct the West 33rd Street viaduct; this reconstruction project would include 

upgrading the utilities in the street, including constructing the new separated sanitary and 

stormwater sewers proposed by the ADP. In addition, there is a NYCDEP combined sewer in West 

30th Street, on the south side of the Project Site, which is available to convey sanitary sewage 

from the Overbuild on the southern half of the Project Site. Both the West 33rd Street and West 

30th Street sewers connect to the interceptor sewer in Twelfth Avenue, which conveys flow to the 

North River Wastewater Treatment Plant (WWTP). 

As shown in Table N-3, the Overbuild is estimated to generate approximately 1 million gpd of daily 

sanitary sewage, which would be a substantial increase in sanitary sewage generation beyond 

the sewage generated by the LIRR facilities that would be constructed with the Preferred 

Alternative (discussed in Chapter 13, “Utilities and Energy”). This estimate is comparable to the 

estimated sanitary sewage generation from the Overbuild presented in the 2009 SEQRA/CEQR 

FEIS (approximately 1.24 million gpd). The additional sanitary sewage generation of the Overbuild 

represents an increase in sewage generation to the North River WWTP of less than 1 percent (in 

comparison to the WWTP’s average monthly flow of 110 mgd), and this increase would not result 

in an exceedance of the WWTP’s permitted capacity of 170 mgd. As noted above, improvements 

to the sanitary sewage system in the area of the Project Site are expected to be constructed in 

accordance with the ADP, which are designed to provide capacity for the increased demand of 

the full Hudson Yards project; with the system improvements, it is anticipated that NYCDEP can 

adequately provide for the increased demand resulting from the Overbuild. In addition, in 

accordance with the New York City Plumbing Code (Local Law 33 of 2007), the Overbuild buildings 

would be required to utilize low-flow plumbing fixtures, which would reduce sanitary flows to the 

sewer system and the WWTP. Therefore, the Overbuild would not result in an adverse impact to 

the City’s sanitary sewage conveyance and treatment system as an indirect result of the Preferred 

Alternative. 

Stormwater 

The Overbuild buildings would share a stormwater management system with the Platform 

(discussed in Chapter 13, “Utilities and Energy”); specifically, stormwater collected on the Platform 

once the Overbuild is operational would primarily be detained on-site for reuse by the Overbuild 

developer as irrigation for the landscaping and open space areas to be created on the Platform. 

Any overflow of stormwater collected on the Platform would be conveyed to the sewer 

infrastructure in West 33rd Street, north of the Project Site, which includes a new storm sewer that 

is expected to be constructed by the City independent of the Preferred Alternative, in accordance 

with the ADP. Therefore, stormwater from the Overbuild would enter the NYCDEP combined 

sewer system, for treatment at the North River WWTP. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-13 June 2021

However, as discussed in the 2009 SEQRA/CEQR FEIS, the total sanitary flows into the combined 

sewer system would increase due to the Overbuild compared to existing combined flows from 

onsite sanitary sewage and stormwater runoff. This incremental increase, depending upon 

downstream and upstream conditions within the combined sewer system, could displace 

wastewater volumes from other sources and result in a greater volume of CSO discharge during 

rainfall events. Modeling of the incremental flows from the Overbuild was previously prepared in 

connection with the 2009 SEQRA/CEQR FEIS to determine the potential impact of the Overbuild 

on CSO discharges from the outfalls which serve the area of the Project Site. This modeling found 

that the Overbuild would have a minor impact on projected future CSO volumes and number of 

CSO events at several outfalls, and that water conservation measures expected to be 

implemented in the Overbuild and would result in reductions of CSO volumes (see Chapter 14 of 

the 2009 SEQRA/CEQR FEIS, “Infrastructure”). Therefore, in consideration of the stormwater 

management improvements that are expected to be made in the area of the Project Site as well 

as the stormwater management system expected to be constructed for the Platform and the 

Overbuild, the indirect impacts of the Preferred Alternative would not result in an adverse impact 

on the City’s stormwater management infrastructure. 

Solid Waste and Sanitation Services 

Table N-4 presents the estimated indirect solid waste generation of the Preferred Alternative from 

the Overbuild, utilizing the generation rates provided in the CEQR Technical Manual. As discussed 

in Chapter 13, “Utilities and Energy,” DSNY is the agency responsible for the collection and 

disposal of residential and institutional solid waste in New York City, while private carters collect 

solid waste from commercial and manufacturing uses. Table N-4 also provides subtotals for solid 

waste that would be collected by DSNY and that which would be collected by private carters. 

DSNY would collect residential and public school generated waste, while private carters would be 

responsible for collecting waste generated by office, retail, and hotel uses. 

Table N-4 

Overbuild Solid Waste Generation 

Use Floor Area (sf) Population/Units 

Solid Waste Generation 

Rate (lbs/wk) 

Solid Waste Generation 

(lbs/wk) 

Residential 3,300,000 4,000 households (DUs) 41 per household 164,000 

Office 2,075,000 8,300 employees 13 per employee 107,900 

Hotel 250,000 470 rooms / 157 employees 75 per employee 11,775 

Retail 75,000 225 employees 79 per employee 17,775 

School 120,000 750 seats 4 per seat 3,000 

Total Solid Waste Generation 304,450 

Solid Waste Handled by DSNY (residential and school uses) 167,000 

Solid Waste Handled by Private Carters (commercial uses) 137,450 

Notes: Solid waste generation is based on Citywide average waste generation rates presented in Table 14-1 of the 

CEQR Technical Manual, and estimates of workers by use, as follows: 

Residential use: 41 lbs/wk per DU. 

Office: 13 lbs/wk per employee; assumes 1 employee per 250 sf. 

Retail: 79 lbs/wk per employee; assume 3 employees per 1,000 sf. 

Hotel: 75 lbs/wk per employee; assumes 1 employee per 3 rooms. 

School: 4 lbs/wk per seat. 
June 2021 N-14 

As shown in Table N-4, the total solid waste generation of the Overbuild would be approximately 

304,450 pounds (approximately 152 tons) per week, which is slightly more than the estimated 

solid waste generation presented in the 2009 SEQRA/CEQR FEIS (Chapter 15, “Solid Waste and 

Sanitation Services”) of up to approximately 295,000 pounds per week. The commercial uses 

(office, hotel, and retail) would generate approximately 137,450 pounds (68.7 tons) of solid waste 

per week. Private commercial carters would collect solid waste generated by commercial and 

industrial uses, and the commercial buildings would be subject to mandatory recycling 

requirements for paper, metals, construction waste, aluminum foil, as well as metal, glass and 

plastic containers. The 68.7 ton increase in weekly solid waste handled by private carters would 

represent approximately 0.09 percent of the City’s anticipated future commercial waste 

generation, as it is estimated that private carters will carry 74,000 tons of solid waste per week by 

2025, as projected in the 2006 Solid Waste Management Plan (SWMP). Based on the typical 

commercial carter capacity of between 12 and 15 tons of waste material per truck, the Overbuild 

would require approximately 5 or 6 additional collection trucks per week. There are more than 

2,000 private carting businesses authorized to serve New York City, and it is expected that their 

collection fleets would be sufficiently flexible to accommodate this increased demand for solid 

waste collection. 

Residential and school uses would generate approximately 167,000 pounds (83.5 tons) of solid 

waste per week, which would be collected by DSNY trucks and would be served by existing DSNY 

collection routes. As a general practice, DSNY adjusts its operations to service the community. 

Residents will be required to participate in the City’s recycling program for paper, metals, and 

certain types of plastics and glass. The additional solid waste generation by residential and school 

uses in the Overbuild would represent approximately 0.07 percent of the City’s anticipated waste 

generation handled by DSNY (it is estimated that DSNY will manage 115,830 tons of solid waste 

for export, recycling compost, and refuse per week by 2025), as projected in the SWMP.1 Based 

on the typical DSNY collection truck capacity of approximately 12.5 tons, the new residential and 

school uses would be expected to generate solid waste equivalent to approximately 7 truckloads 

per week. This increase is not expected to overburden the DSNY’s solid waste handling services. 

Overall, the Overbuild would not conflict with the SWMP, or have a direct effect on a solid waste 

management facility. The incremental solid waste generated by the Overbuild would not 

overburden the City’s solid waste handling systems, and therefore the indirect impacts of the 

Preferred Alternative would not have an adverse impact on the City’s solid waste and sanitation 

services. 

1 Comprehensive Solid Waste Management Plan, September 2006; Attachment II, Table IV 2-2, p. 4. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-15 June 2021

Energy 

As shown in Table N-5, the estimated total indirect energy consumption of the Preferred 

Alternative from the Overbuild would be approximately 967,314 million BTUs per year, which is 

comparable to the estimated energy consumption presented in the 2009 SEQRA/CEQR FEIS. 

Compared with the approximately 388 trillion BTUs of energy consumed annually within Con 

Edison’s New York City and Westchester County service area, this incremental increase would be 

considered a negligible change. Therefore, the indirect impact of the Preferred Alternative would 

not have any adverse impacts on energy. Furthermore, the Overbuild would be consistent New 

York’s local energy laws. In 2005, New York City adopted Local Law 86 of 2005 (LL86), one of 

the nation's first green building laws. LL86 requires new buildings, additions, and substantial 

building reconstruction work in capital projects that receive city funds to be built in accordance 

with the standards of the Leadership in Energy and Environmental Design (LEED) green building 

rating systems developed by the U.S. Green Building Council (USGBC). It also requires that most 

of this work, as well as larger lighting, boiler, HVAC controls, and plumbing upgrade work, be 

designed to reduce the use of both energy and potable water well beyond that required by the 

current NYC building code.2 Since then, the City has adopted Locals Laws 84, 85, 87, 88, and 

most recently in 2019, Local Law 97. These laws regulate energy consumption and LL97 requires 

planned reductions in carbon emissions through 2050. Through auditing and mandated energy 

reports, building owners are required to demonstrate that new buildings and substantial building 

additions contribute to a decrease in energy consumption.3 

Table N-5 

Overbuild Annual Energy Consumption 

Use Size (sf)

Average Annual Energy 

Rate (Thousand BTUs/sf) 

Energy Consumption 

(Million BTUs/Year) 

Residential 3,300,000 126.7 418,110 

Office 2,075,000 216.3 448,823 

Hotel 250,000 216.3 54,075 

Retail 75,000 216.3 16,223 

School 120,000 250.7 30,084 

Total Energy Consumption 967,314 

Notes: sf = square feet. 

Totals may not sum due to rounding. 

Source: 2014 CEQR Technical Manual, Table 15-1, “Average Annual Whole-Building Energy Use in New 

York City.” 

SOCIOECONOMICS 

The previously approved Overbuild would proceed as the Preferred Alternative gets underway. As 

a result, the Overbuild’s socioeconomic effects in the Study Area are considered an indirect effect 

of the Preferred Alternative. 

2 https://www1.nyc.gov/site/oec/green-building/green-building.page 

3 https://www1.nyc.gov/html/gbee/html/plan/ll88.shtml 
June 2021 N-16 

This analysis considers the anticipated indirect effects of the completed Overbuild based on the 

completed 2009 SEQRA/CEQR FEIS socioeconomic conditions and community facilities and 

services assessments, as the program and population demand would remain within the framework 

of the already approved project. The Overbuild Developer is currently proposing 890 condominium 

units and 1,900 rental units, including 324 permanent affordable housing units. FRA has used a 

conservative estimate of 4,000 units based on the total square footage The Overbuild Developer 

is dedicating to residential space, and applying an average unit size of 825 square feet per unit, 

so the analyses represent conservative demand estimates from residential uses. The analyses 

incorporate updated demographic, socioeconomic, and community facilities data, as well as the 

methodologies of the CEQR Technical Manual. 

Indirect Residential Displacement 

Indirect (or secondary) residential displacement is the involuntary displacement of residents that 

may result from a change in socioeconomic conditions created by a project. As described in the 

CEQR Technical Manual, indirect residential displacement usually results from substantial new 

development that is markedly different from existing uses and activity in an area, which can lead 

to increased property values in the area. Increased property values can lead to increased rents, 

which can make it difficult for some existing residents to remain in their homes. The objective of 

this indirect residential displacement assessment is to determine whether the Overbuild would 

either introduce a trend or accelerate a trend of changing socioeconomic conditions that may 

potentially displace a vulnerable population to the extent that the socioeconomic character of the 

area would change. According to the CEQR Technical Manual, an adverse impact due to indirect 

residential displacement may occur if the study area contains a vulnerable population potentially 

subject to indirect displacement that exceeds five percent of the study area or relevant sub-areas 

and this population would not be similarly displaced under the no action alternative. 

According to the CEQR Technical Manual guidance (see Chapter 5, 332.1), an assessment of 

indirect residential displacement should be conducted for actions that result in the incremental 

development of more than 200 residential dwelling units. The Overbuild would introduce 

approximately 4,000 incremental residential dwelling units, warranting analysis of potential indirect 

effects. Generally, an indirect residential displacement analysis is conducted only in cases in 

which the potential impact may be experienced by renters living in privately held units unprotected 

by rent control, rent stabilization, or other government regulations restricting rents, and whose 

incomes or poverty status indicate that they may not support substantial rent increases. Residents 

who are homeowners or who are renters living in rent-restricted units would not be vulnerable to 

rent pressures. 

The study area is the area within which a proposed action has the greatest potential to indirectly 

affect population, housing, and economic activities. A study area typically encompasses a project 

area and adjacent areas within approximately 400 feet, quarter-mile, or half-mile, depending upon 

the project size and area characteristics. According to the CEQR Technical Manual, the larger 

half-mile study area is appropriate for projects that would potentially increase the quarter-mile area 

population by more than five percent. The incremental population introduced by the Overbuild 

would represent more than a five percent increase within a quarter-mile radius of the Project Site, 

warranting a half-mile study area. Because socioeconomic analyses depend on demographic 

data, it is appropriate to adjust the study area boundary to conform to the census tract delineation 

that most closely approximates the desired radius (in this case, a half-mile radius surrounding the 

Project Site). For this analysis, the census tracts that comprise the Study Area are shown in Figure 

N-1. The Study Area includes Census Tracts 93, 97, 99, 103, 111, 115, and 117, and is roughly 

bounded by West 43rd Street to the North, Eighth Avenue to the east, West 20th Street to the 

south, and the Hudson River to the west. For comparison purposes, the analysis also presents 

data for Manhattan (New York County) and New York City. 
W 20th St

W 34th St

W 25th St

W 35th St

W 17th St

W 31st St

W 15th St

W 26th St

Tenth Ave

Seventh Ave

W 22nd St

W 40th St

W 33rd St Dyer Ave

W 14th St

W 18th St

Ninth Ave

W 24th St

W 37th St

W 16th St

W 30th St

W 29th St

W 43rd St

Lincoln Tunnel

W 44th St

J

o

e

Di

maggio Hwy

W 38th St

W 27th Dr

W 19th St

W 21st St

W 41st St

W 36th St

W 42nd St

W 39th St

Eleventh Ave

Broadway

Eighth Ave

W 28th St

W 23rd St

W 27th St

HUDSON RIVER

Chelsea

Park

Hudson

River

Park

115

117

97

103

93

99

111

WESTERN RAIL YARD INFRASTRUCTURE PROJECT

Socioeconomics Study Area

Figure N-1

0 1,000 FEET

3.12.21

Project Site (Western Rail Yard) A

Half-mile Radius Surrounding Project Site

Socioeconomics Study Area

99 Census Tract
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-17 June 2021

Information used in the analysis of indirect residential displacement—including population, 

housing, rents, and incomes—were gathered from the U.S. Census Bureau’s 2006–2010 and 

2014–2018 American Community Survey (ACS) using Social Explorer and the NYCDCP 

Population FactFinder. Social Explorer is a demographic data visualization and research website 

that agglomerates a variety of data including data from the U.S. Census and ACS. FRA used the 

NYCDCP Population FactFinder online mapping tool to provide comparative census data between 

geographies and to determine the margin of error (MOE) for single variable ACS estimates 

presented for the Study Area.4 Study Area market-rate asking rents were researched using online 

real estate listing sites, including StreetEasy. StreetEasy is a searchable online database that 

uses web data extraction to compile an aggregated list of residential property listings from most 

of New York City’s largest brokerage firm and hundreds of small-scale brokers. FRA calculated 

data on the percentage of low-income renter households in the subareas using Public Use 

Microdata Sample (PUMS) files from the U.S. Census Bureau 2014–2018 ACS. PUMS provides 

a sample of untabulated housing unit- and population unit-level responses from the ACS, which 

can be used to create custom tables that are not available in ACS summary data. Estimates of 

protected rental units were determined using data from New York University (NYU) Furman Center 

CoreData, New York City Housing Preservation and Development (NYCHPD) Housing New York 

by Project file, and New York State Homes and Community Renewal (HCR) Rent Stabilized 

Buildings List. 

Following the CEQR Technical Manual guidelines, the analysis begins with a multi-step 

preliminary assessment. Preliminary assessments are conducted to learn enough about the 

potential effects of a proposed action to either rule out the possibility of adverse impacts or 

determine that a more detailed analysis is required to fully determine the extent of the impacts. 

The preliminary assessment works to determine if a proposed action would introduce a population 

with a higher average income than that of the study area population. If the new population is 

projected to have an average household income that is higher than that of the study area 

population, the assessment then considers whether the new population would result in an increase 

in population large enough to substantively affect the demographics of the study area. Based on 

the CEQR Technical Manual guidelines, if the population increase is less than 5 percent, no further 

analysis is warranted. If the population increase is more than 5 percent but less than 10 percent, 

the assessment considers rent trends in the study area to determine if the study area is already 

experiencing a trend toward increasing rents. If the population increase is more than 10 percent 

of the study area population, a detailed analysis of indirect residential displacement is conducted. 

The detailed analysis works to determine whether there is a low income population in the study 

area living within units not protected by rent stabilization, rent control, or other form of government 

regulations restricting rent, that may be at risk of indirect displacement by a proposed action, and 

the potential effects of a proposed action on any identified vulnerable population. 

Preliminary Assessment 

The CEQR Technical Manual’s step-by-step guide for a preliminary assessment of indirect 

residential displacement is presented in bold italics below. 

Step 1. Determine if the proposed action would add new population with higher average 

incomes compared with the average incomes of the existing populations and any new 

population expected to reside in the study area without the proposed action.

4 MOEs describe the precision of an estimate within a 90-percent confidence interval and provide an idea of 

how much variability (i.e., sampling error) is associated with the estimate. The larger the MOE relative to 

the size of the estimate, the greater potential for variability within the data. The MOE is partially dependent 

on the sample size, because larger sample sizes result in a greater amount of information that more closely 

approximates the population. 
June 2021 N-18 

Household income characteristics for the Study Area population are described using the average 

and median household incomes. The average household income is calculated by dividing the 

aggregate income by the total number of households in the Study Area. The presence of highincome households raises the average income, sometimes substantially higher than the median 

household incomes in an area. The median household income represents an estimate of the midpoint of all household incomes in the Study Area. 

As shown in Table N-6, in 2018 the estimated average household income in the Study Area was 

$155,324, which is slightly lower than that of Manhattan overall ($157,467), and over $50,000 

higher than that of New York City overall ($101,158). Average income in the Study Area has 

increased since 2010, as has the average household incomes in Manhattan (by 7.4 percent) and 

New York City (by 8.6 percent). 

The estimated median household income in the Study Area ($97,502) is over $10,000 greater 

than that of Manhattan ($85,424) and over $30,000 greater than that of New York City ($62,947). 

Median household incomes in the Study Area and comparison geographies follow similar trends 

as average household incomes. 

Table N-6 

Household Income Characteristics 

Average Household Income Median Household Income 

2006–2010 

ACS1

2014–2018 

ACS1

Change or 

Direction of 

Change %2 

2006–2010 

ACS1

2014–2018 

ACS1

Change or 

Direction of 

Change %2 

Study Area $132,734 $155,324 Increase $81,699 $97,502 Increase 

Manhattan $146,613 $157,467 +7.4 $77,684 $85,424 +10.0 

New York City $93,139 $101,158 +8.6 $60,125 $62,947 +4.7 

Notes:

1 All dollar figures have been adjusted to 2020 dollars based on the U.S. Department of Labor Consumer 

Price Index for all urban consumers in the New York-Newark-Jersey City, NY-NJ-PA region. 2 If the margin of error (MOE) of the difference between 2006–2010 and 2014–2018 ACS data is greater 

than the difference, a change cannot be reported with confidence; if the MOE of the difference is 

greater than one third of the difference, a change cannot be estimated with confidence and only the 

direction of the change can be reported (i.e., Increase/Decrease). 

Sources: 

U.S. Census Bureau, 2006–2010 and 2014–2018 American Community Survey (ACS) 5-Year Estimates. 

In 2018, the Study Area’s average and median gross rents were both substantially higher than 

those for Manhattan and New York City (see Table N-7). Unlike Manhattan and New York City as 

a whole, the Study Area’s average gross rent was lower than the median gross rent, a change 

since 2010 and suggesting that a relatively large proportion of market rate units with higher rents 

have been added to the Study Area inventory since 2010. Both the average and median gross 

rents in the Study Area have increased since 2010. Although the sample size in the Study Area is 

not large enough to report the percentage increases with statistical confidence, both the average 

and median gross rents appear to have increased at a faster rate than in Manhattan and New 

York City. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-19 June 2021

Table N-7 

Average and Median Gross Rents 

Area 

2006–2010 ACS 2014–2018 ACS 

Change or Percent 

Change 

Average1 Median1 Average1 Median1 Average3 Median3 

Study Area $1,904 $1,753 $2,357 $2,576 Increase Increase 

Manhattan $1,700 $1,475 $1,869 $1,742 +9.9 +18.1 

New York City $1,368 $1,280 $1,523 $1,446 +11.3 +13.0 

Notes: 1 All dollar figures have been adjusted to 2020 dollars based on the U.S. Department of Labor Consumer 

Price Index for all urban consumers in the New York-Newark-Jersey City, NY-NJ-PA region. 2 If the MOE of the difference between 2006–2010 and 2014–2018 ACS data is greater than the 

difference, a change cannot be reported with confidence; if the MOE of the difference is greater than 

one third of the difference, a change cannot be estimated with confidence and only the direction of 

the change can be reported (i.e., Increase/Decrease). 

Sources: U.S. Census Bureau, 2006–2010 and 2014–2018 ACS 5-Year Estimates. 

U.S. Census and ACS data do not provide specific rent information according to regulation status 

or unit size, but instead can paint a general picture about the rate at which housing costs are 

changing in a neighborhood. Markets comparable were therefore used (below) to provide a fuller 

understanding of where the market is today. Table N-8 summarizes online listings for apartments 

for the Study Area. The average rents presented in the table were calculated based on market 

rate rental units, and in general are higher than the data presented by the 2014–2018 ACS, for 

which estimates are based on both market rate and rent protected Study Area units. 

Table N-8 

Asking Rents in the Study Area 

Average Median 

Studio $2,504 $2,500 

1 Bedroom $3,387 $3,290 

2 Bedrooms $5,629 $4,964 

3+ Bedrooms $10,131 $5,875 

Source: StreetEasy (http://streeteasy.com) accessed in November 2020. 

A number of planned projects in the Study Area would introduce a variety of land uses including 

residential, retail, hotel, public facility and institution, and office space. In total, these projects 

would construct an estimated 5,254 residential dwelling units by the 2030 analysis year, which 

represents a 23.4 percent increase in the number of housing units compared to the Study Area 

housing stock in 2018 (22,497 units). Of the 5,254 planned residential units, an estimated 403 are 

expected to be designated as affordable. 

As identified in Table N-6, there is an existing trend of increasing average and median household 

incomes in the Study Area. As shown in Table N-7, there is a concurrent existing trend in the 

Study Area of increasing average and median gross rents. It is anticipated that the creation of 403 

affordable dwelling units (DUs) in the Study Area would slow these trends to a degree. However, 

this represents a small portion of the total development anticipated in the Study Area by 2030. 

Therefore, it is expected that existing trends would continue into the future, leading to even higher 

incomes and rents by 2030 as compared with existing conditions. 
June 2021 N-20 

The Overbuild would introduce approximately 4,000 DUs. Of the units, approximately 324 would 

be permanently affordable rental apartments. As the Overbuild would introduce a combination of 

market rate and affordable residential units, in order to estimate the new population’s average 

household income, it is necessary to estimate incomes for the new residents of both the market 

rate and affordable housing. 

Incomes of Market-Rate Unit Households 

As a new housing product, the Overbuild’s market rate DUs would be expected to rent on the 

higher end of the range of market rate asking rents in the Study Area. For purposes of analysis, 

the upper quartile of asking rents from StreetEasy listings were utilized to estimate market rate 

renters’ incomes, and it was assumed that households would pay 30 percent of their income 

toward rent.5 The resulting projected household incomes, shown in Table N-9, range from nearly 

$113,000 for households residing in studio units to nearly $500,000 for households in three-ormore-bedroom units. 

The overall average income for market-rate households would depend on the unit mixes on the 

Project Site, which is not currently known. For purposes of analysis a weighted average was 

calculated based on the proportional unit mix found within the Study Area, resulting in an average 

household income of $182,415 for households in market rate units, which is higher than the Study 

Area’s average household income in 2018 ($155,324). 

Table N-9 

Annual Household Income Projections for the 

Overbuild’s Market-Rate Residential Dwelling Units 

Unit Type Projected Monthly Rent Projected Annual Household Income 

Studio $2,820 $112,800 

One Bedroom $3,790 $151,600 

Two Bedroom $6,235 $249,400 

Three bedroom+ $11,798 $471,920 

Weighted Average Total1 $4,560 $182,415 

Note: 1 Total average monthly rent is a weighted total based on the proportional unit mix in the Study Area. 

Sources: 

AKRF, Inc. based calculations on rental data collected from StreetEasy.com, accessed in November 2020, 

and U.S. Census 2014–2018 American Community Survey (ACS) for distribution of unit types. 

Incomes for Permanently Affordable Unit Households 

For purposes of analysis, it is assumed that the households occupying the Overbuild’s affordable 

units would have household incomes that on average are 80 percent of the New York City Area 

Median Income (AMI). New York City AMIs and affordable monthly rents by AMI are shown in 

Tables N-10 and N-11. AMIs are calculated yearly by the U.S Department of Housing and Urban 

Development (HUD). 

5 Based on U.S. Housing and Urban Development (HUD) affordability guidance where rent is estimated to 

be approximately 30 percent of total income. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-21 June 2021

Table N-10 

2020 New York City Area Median Income (AMI) 

Family 

Size 

30% of 

AMI 

40% of 

AMI 

50% of 

AMI 

60% of 

AMI 

80% of 

AMI 

100% of 

AMI 

120% of 

AMI 

130% of 

AMI 

165% of 

AMI 

1 $23,880 $31,840 $39,800 $47,760 $63,680 $79,600 $95,520 $103,480 $131,340 

2 $27,300 $36,400 $45,500 $54,600 $72,800 $91,000 $109,200 $118,300 $150,150 

3 $30,720 $40,960 $51,200 $61,440 $81,920 $102,400 $122,880 $133,120 $168,960 

4 $34,110 $45,480 $56,850 $68,220 $90,960 $113,700 $136,440 $147,810 $187,605 

5 $36,840 $49,120 $61,400 $73,680 $98,240 $122,800 $147,360 $159,640 $202,620 

Source: U.S. Department of Housing and Urban Development (HUD)

Table N-11 

2020 New York City Affordable Monthly Rents by Area Median Income (AMI) 

Unit Size 

30% of 

AMI 

40% of 

AMI 

50% of 

AMI 

60% of 

AMI 

80% of 

AMI 

100% of 

AMI 

120% of 

AMI 

130% of 

AMI 

165% of 

AMI 

Studio $397 $567 $738 $909 $1,250 $1,643 $1,985 $2,155 $2,753 

1 BR $503 $717 $930 $1,143 $1,570 $2,060 $2,487 $2,700 $3,446 

2 BR $598 $854 $1,110 $1,366 $1,878 $2,467 $2,979 $3,235 $4,131 

3 BR $683 $978 $1,274 $1,570 $2,161 $2,841 $3,432 $3,728 $4,762 

Notes: Assumes tenant pays electricity. Rents are approximate and have been calculated at 30 percent of 

annual gross income of the target AMI. For low-income bands, rents are based on 30 percent of 27 

percent, 37 percent, 47 percent, 57 percent, and 77 percent of AMI. Studio rents are based on a 

household factor of 0.6. 

Source: HUD 

Average Household Income for All Overbuild Units 

As stated, at least 324 of the Overbuild’s 4,000 units (at least 8.1 percent) would be affordable at 

80 percent AMI ($72,800 for a family of 2). Table N-12 shows the average household income of 

both the affordable and market rate units. The average income of market rate units was multiplied 

by the total number of market rate units, and the average income of affordable units was multiplied 

by the total number of affordable units. These two numbers were added together to determine the 

aggregate income for all the units. This aggregate income was divided by the total number of units 

to determine the average income for all units of $173,536. 

Table N-12 

Weighted Average Income of Total With the Overbuild Population 

Income Units 

Aggregate Income 

(Income x Units) 

Market Rate $182,415 3,676 $670,557,540 

Affordable1 $72,8001 324 $23,587,200 

Total 4,000 $694,144,740 

Weighted Average Income With Overbuild Population 

(Aggregate Income ÷ Total Units) $173,536

Note: 

1 Affordable income is based on 80 percent AMI for a family of two (see Table N-10). 
June 2021 N-22 

With the Overbuild, the projected household income of the new population ($173,536) would be 

greater than the average household income of the existing population in the Study Area 

($155,324). As the percentage of affordable units introduced in the Study Area by 2030 is similar 

to the percentage that would be introduced in the Overbuild, the new population expected to reside 

in the Study Area without the Overbuild would have similar incomes to those introduced by the 

Overbuild. However, since the Overbuild’s incremental population would have an average income 

projected to exceed the existing Study Area population, in accordance with the CEQR Technical 

Manual, Step 2 of the preliminary indirect residential displacement assessment is warranted. 

Step 2. Determine if the proposed action’s increase in population is large enough relative 

to the size of the population expected to reside in the study area without the proposed 

action to affect real estate market conditions in the study area. 

According to the CEQR Technical Manual analysis thresholds, if the population increase is greater 

than five percent of a study area population, the incremental population may be large enough to 

affect real estate market conditions, and Step 3 of the preliminary assessment would be 

warranted. If the population increase is more than 10 percent of a study area population, a detailed 

analysis is warranted. 

Based on U.S. Census ACS estimates, in 2018 the Study Area was home to 34,833 residents. As 

shown in Table N-13, between 2010 and 2018 the Study Area population grew by 38.9 percent. 

Anticipated growth by 2030 from planned projects would increase the Study Area population by 

an estimated 8,932 residents, an approximate 26 percent increase. 

Table N-13 

Study Area Population Estimates and Projections 

Existing Conditions and Future Without the Overbuild 

2006–2010 

ACS 

2014–2018 

ACS 

Percent Change 

2010–2018 

2030 Population 

Projections 

Percent Change 

2018–2030 

Study Area 25,078 34,833 +38.9 43,765 +25.6 

Source: U.S. Census Bureau 2006–2010, 2014–2018 ACS, Year 2030 population projection based on No 

Build Development Projects and the average household size of 1.7 persons per household for 

Community Districts 4 and 5. 

With the Overbuild, the Study Area would experience substantial population growth compared with 

the No Action Alternative (see Table N-14). The Overbuild would introduce an estimated 6,800 

residents, representing an estimated 15.6 percent over the No Action Alternative. As population 

growth with the Overbuild would exceed 10 percent, detailed analysis of indirect residential 

displacement is warranted (see Section N.3.1.9.3, below). 

Table N-14 

With Overbuild Population 

 

2030 Population 

Projection 

Number of 

Incremental 

Dwelling Units 

Projected Population 

Increase With Overbuild 

Dwelling Units 

Percent Change 

from With 

Overbuild 

Condition 

Study Area 43,765 4,000 6,800 15.5 

Sources: U.S. Census Bureau 2014–2018 ACS. Year 2030 population projections based on No Build 

Development Projects, anticipated Overbuild program, and the estimated average household size of 

1.7 persons per household for Community Districts 4 and 5.
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-23 June 2021

Detailed Analysis 

Following the CEQR Technical Manual guidelines, this analysis describes existing and anticipated 

future conditions to a level necessary to understand the relationship of the Preferred Alternative 

to such conditions. The analysis assesses the change that the Overbuild would have on these 

conditions and identifies any changes that could be significant and potentially adverse. The 

analysis begins with a presentation of existing conditions and trends in the Study Area, and then 

works to identify whether there is an existing population potentially vulnerable to indirect residential 

displacement. The analysis then considers future trends without and with the Preferred Alternative 

to determine whether the Preferred Alternative could lead to the displacement of any identified 

vulnerable population, and if so, whether the displacement would be large enough to substantively 

alter the Study Area’s neighborhood character. 

Existing Conditions and Trends 

As shown in Table N-15, in 2018 the Study Area’s average household income was an estimated 

$155,324 (in year 2020 dollars). This was comparable to the 2018 average household income for 

Manhattan ($157,467) and over $50,000 greater than the average household income for New York 

City households ($101,158). The Study Area’s average household income has increased (in 

constant 2020 dollars) since 2010. While the percent change over time in Study Area average 

household income cannot be reported with statistical confidence, it is likely to have increased at a 

faster rate than in Manhattan and the City as a whole. 

Table N-15 

Average Household Income (2010–2018) 

 2010 2018 

Change 

2010–2018 % 

Study Area $132,734 $155,324 Increase1

Manhattan $146,613 $157,467 +7.4 

New York City $93,139 $101,158 +8.6 

Notes:

All dollar figures have been adjusted to 2020 dollars based on the U.S. Department of Labor Consumer 

Price Index for all urban consumers in the New York-Newark-Jersey City, NY-NJ-PA region. 1 The margin of error (MOE) of the difference is greater than one third of the difference, and therefore a 

change cannot be estimated with confidence and only the direction of the change can be reported 

(i.e., Increase/Decrease). 

Sources: U.S. Census Bureau, American Community Survey (ACS) 2006–2010 and 2014–2018 5-Year 

Estimates. 

The Study Area’s median household income in 2018 was an estimated $97,502 (in 2020 dollars), 

higher than the median household incomes for Manhattan and New York City (see Table N-16). 
June 2021 N-24 

Table N-16 

Median Household Income (2010–2018) 

 2010 2018 

Change 

2010–2018 % 

Study Area $81,699 $97,502 Increase1

Manhattan $77,684 $85,424 +10.0 

New York City $60,125 $62,947 +4.7 

Notes:

All dollar figures have been adjusted to 2020 dollars based on the U.S. Department of Labor Consumer 

Price Index for all urban consumers in the New York-Newark-Jersey City, NY-NJ-PA region. 1 The margin of error (MOE) of the difference is greater than one third of the difference, and therefore a 

change cannot be estimated with confidence and only the direction of the change can be reported 

(i.e., Increase/Decrease). 

Sources: U.S. Census Bureau, American Community Survey (ACS) 2006–2010 and 2014–2018 5-Year 

Estimates. 

Figure N-2 illustrates the Study Area’s household income distribution as compared to Manhattan 

and New York City. In 2018 nearly one in four Study Area households earned $200,000 or more, 

a larger proportion than in Manhattan (21.3 percent) and New York City (10.2 percent). 

Conversely, the Study Area had a lower proportion of Study Area households in the lowest income 

brackets (below $35,000). 

The relatively low proportion of Study Area households with very low incomes is due to the 

relatively few numbers of New York City Housing Authority (NYCHA) public housing complexes. 

As shown in Table N-17, there are only nine NYCHA public housing buildings in the Study Area, 

all of which are concentrated in a two-block area between West 25th and West 27th Streets and 

Ninth and Tenth Avenues. Collectively, the Chelsea-Elliott Houses have 1,129 units and an 

estimated 2,434 residents, who represented approximately seven percent of the 2018 Study Area 

population (34,833 residents). 

Table N-17 

NYCHA Developments in the Study Area 

Development No. of Buildings Units Total Population 

Elliot 4 608 1,393 

Chelsea 4 425 927 

Chelsea Addition 1 96 114 

Total 9 1,129 2,434 

Source: http://nycha.maps.arcgis.com. 

Immediately east of the Chelsea-Elliott Houses, between Eighth and Ninth Avenues from 23rd to 

29th Streets, is Penn South, a limited equity affordable cooperative maintained under the 

supervision of the NYCHPD. Penn South receives a substantial tax abatement in exchange for 

providing affordable apartments for moderate-income residents. According to the Penn South web 

site, there are 2,820 units in the complex, and close to 5,000 residents.6

6 https://www.pennsouth.coop/faq---general-information-about-penn-south.html 
3.12.21

Figure N-2

7.7%

3.9% 3.8%

4.5%

2.9%

1.9%

2.9%

3.1%

1.8%

3.3%

6.9%

9.3% 9.3%

8.1%

7.3%

23.5%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

Less than

$10,000

$10,000 to

$14,999

$15,000 to

$19,999

$20,000 to

$24,999

$25,000 to

$29,999

$30,000 to

$34,999

$35,000 to

$39,999

$40,000 to

$44,999

$45,000 to

$49,999

$50,000 to

$59,999

$60,000 to

$74,999

$75,000 to

$99,999

$100,000 to

$124,999

$125,000 to

$149,999

$150,000 to

$199,999

$200,000 or

More

Study Area Manhattan New York City

Household Income Distribution (2018)

WESTERN RAIL YARD INFRASTRUCTURE PROJECT
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-25 June 2021

As detailed in Table N-18, in 2018 approximately 13.0 percent of the Study Area residential 

population was living in poverty, which was lower than the percentage for Manhattan (16.6 

percent) and New York City (18.9 percent). The percentage of Study Area families living in poverty 

(7.2 percent) also was lower than the rates for Manhattan and New York City. The population 

under 18 years of age who were living in poverty (12.5 percent) was notably lower than the rates 

for Manhattan (22.3 percent) and New York City (26.8 percent). 

Table N-18 

Poverty Status in 2018 

Study Area Manhattan New York City 

Number Percent Number Percent Number Percent 

Population Living in Poverty 4,534 13.0 263,413 16.6 1,570,754 18.9 

Families Living in Poverty 442 7.2 40,922 12.7 294,980 15.6 

Population Under 18 Years 

Living in Poverty 351 12.5 51,805 22.3 465,069 26.8 

Population Age 18 to 64 

Living in Poverty 3,555 13.2 167,246 15.2 893,833 16.5 

Population Age 65 and Over 

Living in Poverty 628 12.5 44,362 17.6 211,852 18.3 

Source: U.S. Census Bureau, American Community Survey (ACS) 2014–2018 5-Year Estimates. 

Although the percent change over time for those Study Area residents living in poverty cannot be 

reported with statistical confidence, it appears to have decreased since 2010 (see Table N-19). 

Table N-19 

Study Area Poverty Status Trends (2010–2018) 

2010 2018 

Number Percent Number Percent 

Population Living in Poverty 4,193 17.0 4,534 13.0 

Families Living in Poverty 367 10.4 442 7.2 

Population Under 18 Years Living in Poverty 624 28.5 351 12.5 

Population Age 18 to 64 Living in Poverty 3,041 16.2 3,555 13.2 

Population Age 65 and Over Living in Poverty 528 14.3 628 12.5 

Sources: 

U.S. Census Bureau, American Community Survey (ACS) 2006–2010 and 2014–2018 5-Year Estimates. 

As shown in Table N-20, in 2018 there were 22,497 housing units in the Study Area, of which 

approximately 88.1 percent were occupied. There were approximately 15,331 housing units in the 

Study Area in 2010, of which approximately 86.3 percent were occupied. The Study Area’s 

occupancy rate (88.1 percent) and rate of renter-occupied units (75.6 percent) are similar to rates 

in Manhattan overall. 
June 2021 N-26 

Table N-20 

Housing Units, Vacancy, and Tenure 

Total Housing Units Percent Occupied 

Percent RenterOccupied Units 

2010 2018 2010 2018 2010 2018 

Study Area 15,331 22,497 86.3 88.1 69.4 75.6 

Manhattan 839,013 874,237 87.3 86.7 77.2 75.9 

New York City 3,343,424 3,472,354 91.1 90.8 67.0 67.4 

Sources: 

U.S. Census Bureau, American Community Survey (ACS) 2006–2010 and 2014–2018 5-Year Estimates.

In 2018, over 40 percent of the Study Area’s housing units were in structures built in 2000 or later 

(see Table N-21). This is a substantially higher percentage than in Manhattan (9.2 percent) and 

New York City (7.9 percent). To put this recent growth rate in context, over one of every 10 DUs 

built in Manhattan since 2000 are located in the Study Area. According to MapPLUTO data, over 

6,000 dwelling units were built in the Study Area in just a five-year period between 2013 and 2017. 

In terms of older housing stock, just over one-quarter of the Study Area’s housing units are in 

buildings built before 1950, compared to over half of the units in Manhattan and New York City. 

Table N-21 

2018 Housing Units by Year Structure Built 

Study Area Manhattan New York City 

Number Percent Number Percent Number Percent 

Total Housing Units: 22,497 100.0 874,237 100 3,472,354 100.0 

Built 2000 or Later 9,591 42.7 80,541 9.2 275,466 7.9 

Built 1950 to 1999 6,714 29.8 355,093 40.6 1,428,593 41.2 

Built 1949 or Earlier 6,192 27.6 438,603 50.2 1,768,295 50.9 

Source: U.S. Census Bureau, American Community Survey (ACS) 2014–2018 5-Year Estimates.

As shown in Table N-22, in 2018 in the Study Area, more than three out of four housing units (75.8 

percent) were in structures with 50 or more units. This is a greater proportion than in Manhattan 

(55.9 percent) and New York City (31.8 percent). Conversely, there were very few units in small 

buildings; only 6.3 percent of Study Area units were in buildings with less than 10 dwelling units. 

Table N-22 

2018 Units in Structure 

Units in Structure 

Study Area Manhattan New York City 

Number Percent Number Percent Number Percent 

1 to 2 605 2.7 26,012 3.0 1,017,510 29.3 

3 to 4 173 0.8 18,994 2.2 333,505 9.6 

5 to 9 628 2.8 46,573 5.3 228,415 6.6 

10 to 49 4,047 18.0 293,367 33.5 780,781 22.5 

50 or more 17,044 75.8 488,398 55.9 1,105,727 31.8 

Total 22,497 100 874,237 100 3,472,354 100 

Source: U.S. Census Bureau, American Community Survey (ACS) 2014–2018 5-Year Estimates.

Table N-23 shows gross rent as a percentage of household income for renter-occupied units. If a 

household is paying more than 30 percent of gross income toward rent, that household is 

considered rent-burdened. If the household is paying over 50 percent of gross income toward rent, 

the household is considered severely rent-burdened. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-27 June 2021

In the Study Area, in 2018 approximately 42.7 percent of households were rent-burdened, of which 

nearly half were severely rent-burdened (19.5 percent). Manhattan and New York City had higher 

proportions of rent-burdened and severely rent-burdened households. 

Table N-23 

Renter-Occupied Housing Units by Gross Rent 

as Percentage of Household Income 

29 or less 

(Not Rent-Burdened) 

30 or more 

(Rent-Burdened) 

50 or more 

(Severely Rent-Burdened) 

2006–2010 2014–2018 2006–2010 2014–2018 2006–2010 2014–2018 

Study Area 55.2 57.3 44.8 42.7 22.0 19.5 

Manhattan 55.0 54.3 45.0 45.7 22.7 22.4 

New York City 48.7 46.5 51.3 53.5 27.7 29.0 

Sources: U.S. Census Bureau 2014–2018 ACS 

As discussed above, gross rents reported by ACS are often lower than advertised market-rate 

rents. Table N-24 shows average market rents by number of bedrooms, gathered from online 

rental listings. Average market rents in the Study Area range from $2,504 for a studio to over 

$10,000 for units with three or more bedrooms. The median rents are slightly lower, ranging from 

$2,500 for a study to $5,875 for a unit with three or more bedrooms. 

Table N-24 

Asking Rents in the Study Area 

Average Median 

Studio $2,504 $2,500 

1 Bedroom $3,387 $3,290 

2 Bedrooms $5,629 $4,964 

3+ Bedrooms $10,131 $5,875 

Source: StreetEasy (http://streeteasy.com) accessed in November 2020. 

Estimates of Potentially Vulnerable Population in Unprotected 

Units 

A key objective of the detailed indirect residential displacement analysis is to characterize existing 

conditions of residents and housing in order to identify populations that may be vulnerable to 

displacement. Vulnerable populations are defined as people living in privately held units that are 

unprotected by rent regulations, whose incomes or poverty status indicates that they could not 

pay substantial rent increases. The following analysis estimates the percentage of low-income 

renters and the protected and unprotected housing stock in the Study Area. 

Low-income households are defined as those households making 80 percent AMI or less. AMI is 

set by HUD and is based on the median income of the New York City region and household size 

(see Table N-25). Data on household income by subarea and by tenure can only be tabulated 

using PUMS data for Public Use Microdata Area (PUMA) geographies. The Study Area falls within 

the Chelsea, Clinton & Midtown Business District PUMA (PUMA 3807). The boundaries of PUMA 

3807 closely align with the combined area of Community Districts 4 and 5. As shown in Table 

N-25, approximately 37.3 percent of renter households in the PUMA 3807 have household 

incomes at or below 80 percent AMI. 
June 2021 N-28 

Table N-25 

Low-Income Renters, PUMA 3807 

Household Size HUD 80% AMI Income Limit Renter Occupied Households at or Below 80% AMI 

1 $63,680 18,254 

2 $72,800 4,535 

3 $81,920 1,051 

4 $90,960 811 

5 $98,240 261 

6 $105,520 120 

7 $112,800 35 

8+ $120,080 - 

Total Low-Income Renter-Occupied Households 25,067 

Total Renter-Occupied Households 67,223 

Percent Low-Income Renters 37.3 

Sources: 2014–2018 Public Use Microdata Sample; U.S. Department of Housing and Urban Development 

2020; U.S. Census Bureau 2014–2018 ACS 

The 2018 ACS estimates that 19,829 occupied housing units were in the Study Area, of which 

14,989 (75.6 percent) were renter-occupied. Applying the percentage of low-income renter 

households in the PUMA to the Study Area results in an estimated 5,591 low-income renter 

households in the Study Area. Based on data from the NYU Furman Center, the HCR Rent 

Stabilized Buildings List, and the NYCHPD Housing New York by Project file, there is an estimated 

total of 6,098 protected rental units in the Study Area (see Table N-26). 

The majority of the Study Area’s rent-protected units are income-restricted, including over 1,000 

units within the combined Chelsea-Elliott NYCHA development projects.7 Nearly 800 more 

income-restricted units are located in 100 percent affordable buildings that were developed or 

operate under various federal housing programs. The French Apartments, at 324 West 39th 

Street, is the largest building in this category with 174 rental units. Almost all of the additional 

income-restricted rental units in the Study Area were developed with 421-a tax incentives along 

with market rate housing.8 In total, there are 3,966 income-restricted protected rental units in the 

Study Area. 

Other rent-protected units are non-income-restricted, such as units stabilized under the 

Emergency Tenant Protection Act (EPTA, 1974), meaning that residents do not have to be low 

income to live in the units. According to HCR data, the majority of this type of unit is distributed 

among approximately 100 pre-war buildings, concentrated between Eighth and Tenth Avenues, 

that each have one or more stabilized units.9 MapPLUTO data indicate 2,132 residential units are 

within buildings in this category. 

7 The Chelsea-Elliott developments include the Chelsea, Chelsea Addition, and Elliott housing projects. 

8 When not available from Furman NYC CoreData, the number of income-restricted units in 421-a 

developments was estimated to be 20 percent of the total residential units indicated in mapPLUTO, 20v6. 

9 HCR data indicates that additional stabilized units are within cooperative-owned buildings that have 

converted from rentals. It is assumed that these units account for a small proportion of the total Study Area 

protected units, and are conservatively excluded in the analysis. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-29 June 2021

To estimate how many low-income renters in the Study Area reside in units without rent protection, 

the following methodology was employed: Income-restricted protected units are assumed to be 

occupied by low-income households. The remaining low-income renter households are 

proportionally allocated between non-income-restricted protected units and unprotected units 

based on the ratio of non-income restricted units to unprotected units. As shown in Table N-26, in 

the Study Area there are an estimated 3,966 protected rental units that are income-restricted. The 

analysis assumes that those units are occupied by low-income households, accounting for over 

half of the 5,591 low-income renter households in the Study Area. The remaining 1,625 lowincome renter households live in non-income-restricted rent stabilized units or in unprotected units. 

This analysis conservatively assumes that approximately 19 percent (314 households) live in nonincome-restricted rent-protected units, leaving 1,311 low-income households renting unprotected 

units. Assuming an average household size of 1.75 persons per unit (the average for renteroccupied housing in the Study Area), there are an estimated 2,294 residents that are low-income 

and that live in unprotected rental units, and who would be potentially vulnerable to indirect 

residential displacement if their rents were to increase. In 2018, the Study Area had a total 

population of 34,833 residents; therefore, the potentially vulnerable population would be 

approximately 6.6 percent of the existing Study Area population. 

Although the analysis estimates that over 5 percent of the population may be vulnerable to indirect 

residential displacement, the population of low-income renter households in unprotected rental 

units is very likely smaller than estimated using the above-described methodology. The 

methodology assumes that only 15 percent of non-income-restricted rent-stabilized units are 

occupied by low-income households. According to a Furman Center fact brief, Profile of Rent 

Stabilized Units and Tenants in New York City (2014), Citywide, approximately 66 percent of 

tenants living in units protected by EPTA are low-income (less than 80 percent AMI in 2011). In 

Manhattan alone, 52 percent are low income.10 In addition, market rate rents in the Study Area 

are well in excess of what is affordable to low-income households. Therefore, it is expected that a 

vast majority of low-income renter households in the Study Area reside in rent-protected units. 

Table N-26 

Allocation of Low-Income Households 

Renter-Occupied Housing Units Low-Income Renter Households 

Total Protected 6,098 Total 5,591 

Income-Restricted 3,966 in Income-Restricted Protected Units 3,966 

Non-Income-Restricted 2,132 in Non-Income-Restricted Protected Units 314 

Unprotected 8,891 in Unprotected Units 1,311 

Total Potentially Vulnerable Population in Unprotected Units (HH Size 1.75) 2,294 

Total Potentially Vulnerable Population in Unprotected Units as Percentage of Total Population 6.6 

Sources: NYU Furman Center, CoreData, June 30, 2020; New York State Homes and Community 

Renewal (HCR) Rent Stabilized Buildings List, Manhattan 2018; NYCHA Development Data Base, 

January 2020; U.S. Census Bureau, American Community Survey (ACS) 2018 1-Year Estimates; 

AKRF, Inc.

10 If the 52 percent estimate from Furman Center data were applied to this methodology, rather than 15 

percent, an estimated 2.6 percent of the population would be vulnerable to displacement. 
June 2021 N-30 

Future Conditions in the Study Area 

As shown in Table N-27, there are 21 planned projects that include a residential component and 

that will be developed by the 2030 analysis year irrespective of the Preferred Alternative. These 

projects would result in an estimated 4,851 new market rate dwelling units and 403 affordable 

dwelling units. A vast majority of the projects introducing residential DUs are mixed-use projects 

with ground-floor retail. 

Table N-27 

Development Projects Expected by 2030 Build Year 

(Projects with Residential Development Indicated in Bold) 

Address/Name Block Lot Program 

Build 

Year1

220 Eleventh Avenue 697 1 170,311 gsf office 2021 

400 Eleventh Avenue 706 1 520,740 gsf office 2021 

509 West 34th Street 706 17 2.55 million gsf office 2022 

432 West 31st Street 728 55 220 hotel rooms 2030 

431 West 33rd Street 731 22 24 DU, 6,280 gsf retail 2030 

542 West 22nd Street 693 56 36,783 gsf office 2030 

545 West 37st Street 709 14 131 DU, 258 hotel rooms, 82 parking spaces 2030 

500 West 22nd Street 693 37 10 DU, 4,278 gsf retail, 25,307 gsf community facility 2030 

430 West 37th Street 734 16 304 DU, 14,580 gsf retail 2030 

517 West 29th Street 701 24 60 DU, 10 parking spaces 2030 

495 Eleventh Avenue 685 38 275 DU, 16,879 gsf retail, 755 hotel rooms, 49,748 gsf 

community facility, 25,168 gsf office, 55 parking spaces 2024 

Hudson Yards Site 7 707 20, 26, 45, 

41, 31 and 39 255 DU, 22,011 gsf retail, 1.66 million gsf office 2025 

99 Hudson Boulevard 708 1, 62 1,495,000 gsf office 2030 

162 Eleventh Avenue 694 1 13 DU, 242 gsf retail 2030 

319 West 35th Street 759 29 166 DU, 3,909 gsf retail 2030 

550 West 41st Street 1069 1 499 DU, 72,552 gsf retail 2030 

Moynihan Station 

Development Project 755 40 123,000 gsf retail, 228,242 gsf community facility, 672,524 gsf office 2030 

349-355 West 37th Street 761 5,7 136 DU, 11,355 gsf retail 2030 

351 West 38th Street 762 6 490 hotel rooms 2025 

338 West 39th Street 762 61 177 hotel rooms 2030 

355 West 39th Street 763 7501 25 DU, 1,843 gsf retail, 723 gsf community facility 2030 

460 West 41st Street 1050 1 60 DU, 62,607 gsf community facility 2030 

555 West 38th Street 710 1 591 DU, 1,886 gsf retail 2030 

450 11th Avenue 708 65 379 hotel rooms 2030 

Hudson Yards Site 24 735 25, 27, 30, 

31, and 35 

448 DU, 8,579 gsf community facility, 170 parking 

spaces 

2030 

415 Tenth Avenue 705 39 2,581,748 gsf office 2030 

610 West 30th Street 675 39 277 DU, 160,906 gsf retail, 61 parking spaces 2030 

601 West 29th Street 675 12 931 DU, 10,920 gsf retail, 186 parking spaces 2030 

442 West 33rd Street 729 61 164 hotel rooms 2030 

401 West 31st Street 729 51 790 DU, 4,053,312 gsf office 2030 

300 West 30th Street 753 42 80 DU, 5,750 gsf retail 2030 

555 West 22nd Street 694 5 145 DU, 49,160 gsf retail 2030 

540 West 21st Street 692 53 34 DU, 50,041 gsf retail 2030 

260 Eleventh Avenue 698 1,6 23,236 gsf retail, 314,606 gsf office 2030 

Notes: 

Some program data was updated in July 2020, based on updated project information from NYCDCP. 

DU= Dwelling Units 

UC = Under Construction 

1

 Projects for which an expected date of completion is not available are assumed to be complete by 2030. 2

 Gross square footage (gsf) was calculated off of the zoning square footage by using a factor of 1.15. 

Sources: New York City Department of City Planning, Department of Buildings; AKRF, Inc. research; media coverage. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-31 June 2021

Future with the Preferred Alternative 

The Preferred Alternative would allow for the development of housing, commercial, community 

facility, and open space upon the Platform over the Project Site. By 2030, the Overbuild would be 

constructed with up to 4,000 residential DUs, of which at least 324 would be permanently 

affordable. The market rate units would be offered at rents and sales prices comparable to other 

modern, newly constructed market rate units in the surrounding area, and comparable to the high 

rents and sales prices for market rate units expected to be development in the future without the 

Preferred Alternative. 

Assuming an average household size of 1.7 persons per household, the 4,000 residential units 

would introduce an estimated 6,800 residents to the Study Area by 2030 (conservatively assuming 

100 percent occupancy). The 6,800 residents introduced to the Study Area would represent about 

13.4 percent of the 2030 Study Area population in the future with the Preferred Alternative; the 

total Study Area residential population with the Preferred Alternative would be 50,565. 

According to the CEQR Technical Manual, if a proposed action increases the population in a study 

area by less than five percent, it would not be large enough to affect socioeconomic trends 

significantly. While the indirect effect of the Preferred Alternative, the Overbuild, would add a 

substantial new population, increasing the Study Area population by approximately 15.5 percent, 

the demographic characteristics of the resulting residential population would not differ substantially 

from that of Study Area population in the future without the Preferred Alternative. By 2030, housing 

prices and rents are expected to continue to rise in the in the Study Area with or without the 

Preferred Alternative. As shown in Table N-24, current rents for available new or renovated 

apartments in the area are higher than the median affordable rents of current residents. Monthly 

rents for units in new, highly amenitized buildings are even higher; for example, monthly asking 

rents for 1-bedroom units at 15 Hudson Yards range from $5,995 to $8,200; 2-bedroom units 

range from $9,000 to $16,000; while listed 3-bedroom units over $20,000 per month.11 

Any demographic changes resulting from the indirect effect of the Preferred Alternative would 

mirror socioeconomic trends (population growth and increasing affluence) that have taken hold in 

the area; the Preferred Alternative would not alter or substantially accelerate these trends. 

Between 2000 and 2018, the Study Area experienced growth of over 9,500 housing units. 

Between 2020 and 2030, another 5,254 units will be constructed in the Study Area, resulting in a 

substantial population gain in the absence of the Preferred Alternative. 

As explained above, a large percentage of the Study Area’s rental housing stock is covered by 

rent control or rent stabilization, which affords a high degree of protection against market-driven 

displacement pressures. Economic trends have already placed unregulated rents out of reach of 

low- and moderate-income households; those low- to moderate-income households that remain 

in the Study Area owe their continued tenure to rent regulation and participation in other 

government programs that limit rents and tenant incomes. The population potentially vulnerable 

to indirect residential displacement within the Study Area is limited, and would likely experience 

increased rent pressures in the future without the Overbuild. The indirect effect of the Preferred 

Alternative would not significantly alter or substantially accelerate the Study Area’s long-term trend 

of increasing residential development, affluence, and residential desirability. Through the provision 

of housing, the Overbuild would add to the Study Area’s housing supply and may serve to keep 

prices from rising as quickly as they would absent of the Overbuild. Furthermore, the addition of 

at least 324 new, permanently affordable housing units would potentially slow this trend and could 

serve to maintain a wider range of household incomes within the Study Area over the long term 

as compared to conditions in the future without the Overbuild. 

11 Asking rents from StreetEasy accessed in November 2020. 
June 2021 N-32 

In summary, due to the substantial amount of market rate housing that has recently been built and 

that is planned, irrespective of the Preferred Alternative and Overbuild, the Study Area is expected 

to maintain its long-term trends toward increasing residential population, household incomes, 

residential property values, and rents. The Overbuild would reflect, rather than alter, these 

residential trends. Therefore, no adverse impact from indirect residential displacement would be 

expected to result from the Preferred Alternative. 

Indirect Business Displacement 

Similar to indirect residential displacement, the concern with respect to indirect business 

displacement is whether a project could lead to increases in property values, and thus rents, 

making it difficult for some businesses to afford their rent. In most cases, indirect displacement of 

businesses occurs when a project would markedly increase property values and rents throughout 

a study area, making it difficult for some categories of businesses to remain in the area. An 

example would be industrial businesses in an area where land use change is occurring, and the 

introduction of a new population would result in new commercial or retail services that would 

increase demand for services and cause rents to rise. Additionally, indirect displacement of 

businesses may occur if a project directly displaces any type of use that either directly supports 

businesses in the area or brings a customer base to the area for local businesses, or if it directly 

or indirectly displaces residents or workers who form the customer base of existing businesses in 

the area. 

The Study Area is the area within which the Preferred Alternative has the greatest potential to 

indirectly affect population, housing, and economic activities. As with the analysis of indirect 

residential displacement, the Study Area is an approximate half-mile area surrounding the Project 

Site. Because socioeconomic analyses depend on demographic data, it is appropriate to adjust 

the Study Area boundary to conform to the census tract delineation that most closely approximates 

the desired radius (in this case, a half-mile radius surrounding the Project Site). For this analysis, 

the census tracts that comprise the Study Area are shown in Figure N-1. The Study Area includes 

Census Tracts 93, 97, 99, 103, 111, 115, and 117, and is roughly bounded by West 43rd Street 

to the North, Eighth Avenue to the east, West 20th Street to the south, and the Hudson River to 

the west. For comparison purposes, the analysis also presents data for Manhattan (New York 

County) and New York City. 

According to the CEQR Technical Manual, an adverse impacts due to indirect business 

displacement may occur if a proposed action would create a trend that would result in the 

displacement of businesses that provide products or services essential to the local economy that 

would no longer be available in its “trade area” to local residents or businesses due to the difficulty 

of either relocating the business or establishing new, comparable businesses. Impacts may also 

be identified in a proposed action could displace businesses that are the subject of regulations or 

publicly adopted plans to preserve, enhance, or otherwise protect them, and if a proposed action 

would add retail uses that draw substantial sales from existing businesses. 

Preliminary Assessment 

The analysis of indirect business displacement begins with a preliminary assessment that 

describes and characterizes conditions and trends in employment and businesses within a study 

area, using the most recent available data from such sources as the U.S. Census Bureau, as well 

as private sources such as Esri Business Analyst and real estate brokerage firms, as necessary. 

This information is used to consider: 

 whether a proposed action would introduce enough of a new economic activity to alter existing 

economic patterns; 

 whether a proposed action would add to the concentration of a particular sector of the local 

economy enough to alter or accelerate existing economic patterns; and 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-33 June 2021

 whether a proposed action would directly displace any type of use that either directly supports 

businesses in the area or brings a customer base to the area for local businesses, or if it 

indirectly displaces residents, workers, or visitors who form the customer base of existing 

businesses in the area. 

A preliminary assessment for the indirect effect of the Overbuild was sufficient to rule out the 

potential for adverse impacts due to indirect business displacement as an indirect effect of the 

Preferred Alternative. 

Conditions and Trends in Study Area Employment and 

Businesses 

The Study Area is located on the Far West Side of Midtown Manhattan and extends into the area 

known as Midtown South. Midtown Manhattan is the core of the New York region’s economic 

strength and is renowned for its supply of high-quality office space. At the end of 2019 there was 

approximately 286 million square feet of office space in Midtown, with approximately 9.7 million 

square feet under construction in the Hudson Yards/Manhattan West submarket.12 The majority 

of that inventory is located in Class A office buildings, typically in demand by prestigious national 

and international firms, particularly in the business, legal, and professional services and the 

Finance, Insurance, and Real Estate (FIRE) sectors and more recently in the Information (or 

“Tech”) sector. Midtown South has another approximately 79 million square feet of office space.13 

The Study Area has experienced tremendous recent growth in the number of jobs and 

businesses—particularly in office-based industry sectors—facilitated by development resulting 

from the Hudson Yards Rezoning. In 2019, there were an estimated 4,272 businesses located in 

the Study Area, collectively employing an estimated 71,535 workers (see Table N-28). According 

to U.S. Census OnTheMap data, the number of primary jobs held within the Study Area grew by 

approximately 41.8 percent between 2010 and 2017, far outpacing job growth in Manhattan (16.4 

percent) and New York City (16.7 percent) over the same period. 

As shown in Table N-28, apart from businesses in unclassified industry sectors, the largest 

proportions of Study Area businesses were in the Professional, Scientific and Technical Services 

industry sectors (646 businesses, representing 15.1 percent of all Study Area businesses), 

followed closely by establishments in the Retail Trade sector (639 businesses, representing 15.0 

percent of total businesses). These sectors also had the highest numbers of workers—an 

estimated 14,103 in Retail Trade (19.7 percent of all jobs) and 9,824 jobs in Professional, Scientific 

and Technical Services industries (13.7 percent of all jobs). 

Industrial-based sectors (Construction, Manufacturing, Transportation and Warehousing, and 

Wholesale Trade) represent about 10.3 percent (7,386 jobs) of the total employment in the Study 

Area, which is a substantial decline in both the total amount and proportion since 2000, when 

these sectors represented 35.8 percent of Study Area employment and employed an estimated 

17,340 workers. The trend toward losses in manufacturing employment was not isolated to the 

Study Area; in Manhattan as a whole, the share of jobs in industrial-based sectors has dropped 

from 15.7 percent of all jobs in 2000 to 7.7 percent of jobs in 2017. 

12 Avison Young Fourth Quarter 2019 Office Leasing Report. The Hudson Yards/Manhattan West submarket 

is defined by Avison Young as West 36th Street to the north, the Hudson River on the west, West 12th 

Street on the south and Fifth Avenue on the east. 

13 Ibid. 
June 2021 N-34 

Table N-28 

Study Area Business and Jobs by Industry Sector (2019) 

Businesses Jobs 

Number Percent Number Percent 

Total 4,272 100.0 71,535 100.0 

Agriculture, Forestry, Fishing and Hunting 3 0.1 8 0.0 

Mining 1 0.0 10 0.0 

Utilities 1 0.0 2 0.0 

Construction 149 3.5 3,071 4.3 

Manufacturing 137 3.2 1,407 2.0 

Wholesale Trade 100 2.3 1,187 1.7 

Retail Trade 639 15.0 14,103 19.7 

Transportation and Warehousing 66 1.5 1,721 2.4 

Information 212 5.0 6,831 9.5 

Finance and Insurance 117 2.7 4,635 6.5 

Real Estate, Rental and Leasing 204 4.8 1,959 2.7 

Professional, Scientific and Technical Services 646 15.1 9,824 13.7 

Management of Companies and Enterprises 13 0.3 160 0.2 

Administrative and Support and Waste Management Services 182 4.3 1,853 2.6 

Educational Services 71 1.7 845 1.2 

Health Care and Social Assistance 159 3.7 5,944 8.3 

Arts, Entertainment, and Recreation 187 4.4 2,628 3.7 

Accommodation and Food Services 309 7.2 5,726 8.0 

Other Services, Except Public Administration 366 8.6 8,123 11.4 

Public Administration 16 0.4 1,128 0.2 

Unclassified Establishments 694 16.2 370 1.6 

Source: Esri Business Analyst. 

As shown in Table N-28, in 2019 the Study Area had a disproportionately large percentage of jobs 

in the Retail Trade sector (19.7 percent) as compared to Manhattan (9.1 percent) and New York 

City (10.1 percent). This is due to its location within the Midtown Manhattan Central Business 

District, where ground-floor retail uses dominate, as well as the concentration of major retail 

destinations including the recently opened Shops and Restaurants at Hudson Yards. The 

proportion of Study Area jobs in the Information sector (9.5 percent) is also higher than in 

Manhattan (7.4 percent) and New York City as a whole (5.1 percent). The growth in Information 

sector jobs in the Study Area is due in part to large tech companies—including Amazon, Apple, 

Facebook, and Google—seeking to occupy space along the Hudson River, including within the 

Study Area.14 

14 New York Times, January 5, 2020. Website link: https://www.nytimes.com/2020/01/05/nyregion/nyc-techfacebook-amazon-google.html (accessed, November 5, 2020) 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-35 June 2021

The 2019 employment estimates presented in Tables N-28 and N-29 do not fully capture the 

Study Area business and employment growth resulting from the first phase of Hudson Yards, 

which opened in March 2019. The development over the Eastern Rail Yard is comprised of six 

buildings offering a combined total of over 10.6 million gsf, including approximately 8.9 million gsf 

of office space. The complex also features a 1 million gsf retail mall, a six-acre park, a 200,000-

gsf cultural venue known as The Shed, and the Vessel. Late in 2019, Facebook finalized a lease 

agreement to occupy over 1.5 million square feet of office space in Hudson Yards—including 

about 1.2 million square feet at 50 Hudson Yards, 265,000 square feet at 30 Hudson Yards, and 

57,000 square feet at 55 Hudson Yards.15 

Table N-29 

Jobs by Industry Sector 

Study Area, Manhattan, and New York City (2019) 

Study Area Manhattan New York City 

Number Percent Number Percent Number Percent 

Total 71,535 100.0 2,069,586 100.0 3,570,213 100.0 

Agriculture, Forestry, Fishing and Hunting 8 0.0 386 0.0 1,239 0.0 

Mining 10 0.0 311 0.0 682 0.0 

Utilities 2 0.0 5,746 0.3 8,656 0.2 

Construction 3,071 4.3 37,548 1.8 111,102 3.1 

Manufacturing 1,407 2.0 51,499 2.5 108,312 3.0 

Wholesale Trade 1,187 1.7 36,206 1.7 83,825 2.3 

Retail Trade 14,103 19.7 188,530 9.1 359,283 10.1 

Transportation and Warehousing 1,721 2.4 30,586 1.5 91,171 2.6 

Information 6,831 9.5 152,161 7.4 180,962 5.1 

Finance and Insurance 4,635 6.5 289,907 14.0 323,744 9.1 

Real Estate, Rental and Leasing 1,959 2.7 102,459 5.0 167,176 4.6 

Professional, Scientific and Technical 

Services 9,824 13.7 330,468 16.0 405,950 11.4 

Management of Companies and 

Enterprises 160 0.2 22,963 1.1 25,008 0.7 

Administrative and Support and Waste 

Management Services 1,853 2.6 77,550 3.7 116,822 3.3 

Educational Services 845 1.2 89,009 4.3 255,295 7.2 

Health Care and Social Assistance 5,944 8.3 223,147 10.8 579,904 16.2 

Arts, Entertainment, and Recreation 2,628 3.7 64,585 3.1 96,071 2.7 

Accommodation and Food Services 5,726 8.0 183,623 8.9 298,292 8.4 

Other Services, Except Public 

Administration 8,123 11.4 117,253 5.7 226,193 6.3 

Public Administration 1,128 0.2 54,350 2.6 114,949 3.2 

Unclassified Establishments 370 1.6 11,299 0.5 19,577 0.5 

Source: Esri Business Analyst. 

15 https://therealdeal.com/2019/11/14/its-official-facebook-is-taking-1-5m-sf-in-hudson-yards 
June 2021 N-36 

Trends in Real Estate Values and Rents 

Due to the ongoing coronavirus disease 2019 (COVID-19) public health emergency and 

associated economic recession, real estate values and rents in New York City are experiencing a 

downturn. In fourth quarter 2019, prior to the onset of COVID-19, overall vacancy in the Midtown 

South office market was approximately 8.3 percent, with average asking rent for Class A space 

exceeding $100 per square foot. As of the third quarter 2020, vacancy in Midtown South has 

increased to approximately 12.8 percent.16 

Manhattan has repeatedly overcome record vacancies following economic recessions. The overall 

office vacancy rate in Manhattan hit a record low of 3.5 percent in third quarter 2000, just before 

the recession that began after the September 11, 2001 terrorist attacks. In Midtown, the vacancy 

rate was even lower, down to 3.2 percent in third quarter 2000, leaving a relatively small amount 

of space available for lease. In third quarter 2003, office vacancy in Manhattan was about 12.5 

percent, with Midtown faring better at 11.9 percent. Office vacancies in Midtown South and Lower 

Manhattan were slightly higher at 13.7 and 13.0 percent, respectively. Traditionally, office vacancy 

rates between 7 and 9 percent indicate that the market is in equilibrium, providing space for 

expansion without extraordinary increases in rents. 

CEQR Assessment Criteria 

This section follows the methodology of the CEQR Technical Manual in analyzing the criteria 

indicated in bold italics, below. 

Would the proposed action introduce enough of a new economic activity to alter existing 

economic patterns? 

The Preferred Alternative would enable the Overbuild to introduce approximately 3.3 million gsf of 

residential use (up to 4,000 units); up to 3.5 million gsf of commercial office and hotel; 75,000 gsf 

of retail; a 120,000-gsf public school; 5.45 acres of open space; and 1,600 parking spaces. As 

detailed below, none of these uses would be new activities within the Study Area: 

 Residential - In 2018, the Study Area had an estimated 22,497 residential DUs, and there are 

5,254 residential units expected to be built in the future without the Overbuild by 2030. 

 Commercial Office – Based on MapPLUTO data, currently there is approximately 42 million 

gsf of commercial office space in the Study Area, and an additional 14 million gsf of office 

space that is expected to be built in the Study Area by 2030 the future without the Overbuild. 

 Retail – The Study Area currently has approximately 4.1 million gsf of retail space, and over 

575,000 gsf of retail that is expected to be built in the future without the Overbuild by 2030. 

 Hotel – There are numerous hotels in the Study Area, including the Equinox Hotel New York 

at 33 Hudson Yards, Courtyard by Mariott at 461 34th Street, Best Western Convention Center 

Hotel at 522 West 38th Street, and the Clarion Collection Hotel-GEM Hotel on 449 West 36th 

Street. In addition, approximately 2,280 hotel rooms will be added to the Study Area in the 

future without the Overbuild by 2030. 

 Public Schools – There is one public school within a 1⁄2-mile radius of the Project Site (P.S. 33 

Chelsea Prep). 

 Open Space – There are approximately 38.5 acres of publicly accessible open space in the 

Study Area, including an approximately 6-acre park at Hudson Yards. 

 Parking – Based on MapPLUTO data there is approximately 745,000 sf of off-street parking 

in the Study Area. 

16 4Q2019 reporting from ABS Partners Real Estate; 3Q2020 reporting from Newmark Knight Frank. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-37 June 2021

Would the proposed action add to the concentration of a particular sector of the local 

economy enough to alter or accelerate an ongoing trend to alter existing economic 

patterns? 

The Preferred Alternative would enable the Overbuild, a substantial mixed-use development at 

the Project Site with a wide range of allowable uses that already are well-established in the Study 

Area. As discussed above, the Study Area already includes the uses that would be added by the 

Overbuild. Independent of the Overbuild, the Study Area has a significant amount of planned 

projects that will add the same mix of uses as the Overbuild. Given the trend toward the 

development of mixed-use projects within the Study Area, the Preferred Alternative would not 

indirectly change economic patterns. The Overbuild mirrors the long-term trend toward a greater 

mix of uses in the Study Area, which would continue irrespective of the Overbuild. 

The approximately 75,000 gsf of retail space that would be introduced by the Overbuild would not 

be an amount that could result in indirect business displacement due to retail market saturation. 

As noted in the CEQR Technical Manual, projects resulting in less than 200,000 square feet of 

retail on a single development site would not typically result in socioeconomic impacts. 

Would the proposed action directly displace uses of any type that directly support 

businesses in the area or bring people to the area that form a customer base for local 

businesses? 

As detailed in Chapter 17, “Socioeconomics,” the Preferred Alternative would not directly displace 

any business that support businesses in the area or bring people to the area that form a customer 

base for local businesses. Rather, the uses developed on the Project Site would be expected to 

attract new visitors to the Study Area, some of whom would form a customer base for local 

businesses. 

Would the proposed action directly or indirectly displace residents, workers, or visitors 

who form the customer base of existing businesses in the study area? 

As detailed in Chapter 17, “Socioeconomics,” the Preferred Alternative would not directly displace 

residents or workers. The detailed analysis of indirect residential displacement finds that the 

Preferred Alternative would not result in significant indirect residential displacement, and the 

Overbuild would introduce substantial new residential, worker, and visitor populations who would 

add to the area’s existing customer base. Therefore, the Preferred Alternative would not directly 

or indirectly displace residents, workers, or visitors who form the customer base of existing 

businesses in the area. 

Would the proposed action introduce a land use that could have a similar indirect effect, 

through the lowering of property values if it is large enough or prominent enough or 

combines with other like uses to create a critical mass large enough to offset positive 

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

climate for disinvestment? 

The Overbuild would not offset positive trends in the Study Area, impede efforts to attract 

investments to the area, or create a climate for disinvestment. The Overbuild would advance longstanding policy goals of both the City of New York and MTA to encourage the development of new 

residential, commercial, community facility, and open space uses within the largely underutilized 

Far West Side of Midtown Manhattan. The Overbuild is intended to enhance the vitality of the 

Hudson Yards area, build the City’s tax base, and help create a new 24-hour neighborhood that 

complements the emerging developments in the Special Hudson Yards District and the Special 

West Chelsea District, as well as areas of Midtown and Chelsea more broadly. 
June 2021 N-38 

Overall, this preliminary assessment finds that the Preferred Alternative would not result in an 

adverse impact due to indirect business displacement within the Study Area. Therefore, no further 

analysis of this issue is required. 

ADVERSE EFFECTS ON A SPECIFIC INDUSTRY 

An adverse impact may occur if an action would measurably diminish the viability of a specific 

industry that has substantial economic value to the City’s economy. An example as cited in the 

CEQR Technical Manual would be new regulations that prohibit or restrict the use of certain 

processes that are critical to certain industries. As set forth under the CEQR Technical Manual 

guidelines, the preliminary assessment of a proposed actions’ potential to affect the operation and 

viability of specific industries (not necessarily tied to a study area) is not based on set criteria or 

the identification of specific economic variables. The CEQR Technical Manual indicates that a 

more detailed examination is appropriate if the following questions cannot be answered with a 

clear “no.” 

Would the proposed action significantly affect business conditions in any industry of any 

category of business within or outside the study area? 

The Overbuild would not introduce any regulations or policies that would restrict any business or 

process from continuing to function within or outside the Study Area. Nor would the Overbuild 

result in an adverse impact from the direct displacement of uses on the Project Site. Therefore, 

the Overbuild would not have any direct effects on business conditions in any industry or category 

of business within the Study Area or New York City more broadly. The potential indirect effects of 

the Preferred Alternative on business conditions are addressed in the question below. 

Would the proposed action indirectly substantially reduce employment or impair the 

economic viability in the industry or category of businesses? 

As described in the analysis of indirect business displacement, the Preferred Alternative would 

not result in an adverse impact due to indirect business displacement, and would not indirectly 

displace a substantial amount of employment or impair the economic viability in any one industry 

sector or category of businesses. The Study Area includes a mix of commercial office, retail, 

residential, industrial, and transportation uses. According to data from the U.S. Census Bureau, 

there is not a substantial concentration of any one category of business or industry within the 

Study Area. Therefore, any potential indirect business displacement resulting from the Preferred 

Alternative would not have the potential to impair the economic viability of any industry or category 

of business. 

A small portion of the Special Garment Center District (about a quarter of the blocks bounded by 

West 35th and West 37th Streets between Eighth and Ninth Avenues) is located in the Study Area. 

The District was created in 1987 to protect and enhance the apparel industry’s employment base 

in apparel manufacturing as well as wholesaling, design and showrooms, retail, and related 

businesses that support the industry. While remaining the vital center of New York’s apparel 

industry, the Garment Center has been significantly changing over the past decades. Its traditional 

base in manufacturing employment has been dramatically reduced, and the current employment 

base is a broader mix of commercial, wholesaling, and related uses. Citywide apparel 

manufacturing has been on the decline for over 30 years, and there is a prevailing and ongoing 

trend in the Special Garment Center District and Citywide toward the conversion of apparel 

manufacturing space to showrooms and other non-apparel-related uses. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-39 June 2021

In recognition of this long-term trend, the Hudson Yards FGEIS included a rezoning of the P-2 

Preservation Area of the Special Garment Center District (generally between West 35th and 39th 

Streets from Eighth to Ninth Avenues from M1-5 and M1-6 to C6-4M), allowing for new 

construction of residential, commercial, or community facility uses, as well as as-of-right 

conversions to residential, commercial, or community facility uses if the building is less than 70,000 

sf of floor area. This zoning change, enacted in 2005, has led to number of new developments 

and planned developments in the area, including hotels and residential conversions. For instance, 

a 24-story apartment building is being constructed on West 38th Street between Eighth and Ninth 

Avenues on a site that was formerly a parking facility. 

Overall, the preliminary assessment finds that there would be no adverse impact on specific 

industries as an indirect result of the Preferred Alternative. In the future, the apparel industry is 

likely to continue its current pattern of consolidation towards the showroom, design, wholesale, 

and retail focus, while apparel manufacturing is expected to continue to diminish throughout the 

City, including activities within the Garment Center and in the Study Area. These trends are 

expected to continue with or without the Preferred Alternative; the Preferred Alternative would not 

indirectly affect these trends. No further analysis of this issue is required. 

COMMUNITY FACILITIES AND SERVICES 

This section assesses the potential for the Preferred Alternative to indirectly effect community 

facilities and services, which are defined in the CEQR Technical Manual as public or publicly 

funded schools, child care centers, libraries, health care facilities, and fire and police protection 

services. Indirect effects can result from increased demand for community facilities and services 

generated by new users, such as the new population that would result from the Overbuild in the 

future with the Preferred Alternative. 

Pursuant to the CEQR Technical Manual guidelines, the analysis begins with a preliminary 

screening is to determine whether a community facilities assessment is warranted. Depending on 

the size, income characteristics, and age distribution of the new population, there may be effects 

on public schools, libraries, or child care centers. The CEQR Technical Manual provides 

thresholds for guidance in making a determination of whether a detailed analysis is necessary to 

determine potential indirect impacts (see Table N-30). If a project exceeds the threshold for a 

specific facility type, a more detailed analysis is warranted. 

Applying the average household size of 1.7 persons per household (the average household size 

for Manhattan Community Districts 4 and 5 according to 2014–2018 ACS Data) to the number of 

incremental DUs, the Overbuild would introduce an estimated 6,800 new residents to the Study 

Area. 

Based on the screening criteria in Table N-30, detailed analyses of potential indirect impacts on 

public schools (elementary and intermediate schools), public libraries, and publicly funded child 

care centers were conducted. Qualitative lists of health care facilities, and fire and police protection 

services were also prepared. Following CEQR Technical Manual guidelines, the study areas for 

analysis are different for each type of facility and are described in the sections below (see also 

CEQR Technical Manual, Chapter 6, Sections 311-316). 
June 2021 N-40 

Table N-30 

Preliminary Screening Analysis Criteria: Manhattan 

Community Facility Threshold For Detailed Analysis 

Public schools 

More than 50 elementary/intermediate school or 150 high school 

students. The minimum number of DUs that trigger a detailed analysis is 

1,049 and 7,500 for elementary/intermediate schools and high schools, 

respectively in Manhattan CSD 2. 

Libraries Greater than 5 percent increase in ratio of DUs to libraries in borough. 

The minimum number of DUs that trigger a detailed analysis is 901. 

Health care facilities (outpatient) Introduction of sizeable new neighborhood where none existed before1

Child care centers (publicly 

funded) 

More than 20 eligible children based on number of low- and 

low/moderate-income DUs by borough. The minimum number of 

affordable DUs that trigger a detailed analysis is 170. 

Fire protection Introduction of sizeable new neighborhood where none existed before.1

Police protection Introduction of sizeable new neighborhood where none existed before.1

Note:

1 The CEQR Technical Manual cites the Hunter’s Point South project as an example of a project that 

would introduce a sizeable new neighborhood where none existed before. The Hunter’s Point South 

project would introduce approximately 5,000 new DUs to the Hunter’s Point South waterfront in Long 

Island City, Queens. 

Source:

CEQR Technical Manual Chapter 6, Table 6-1. 

Potential Indirect Effects on Public Elementary and 

Intermediate Schools 

Following the methodologies in the CEQR Technical Manual, the School District Study Area for 

the analysis of elementary and intermediate schools is the school districts’ “subdistrict” (also 

known as a “region” or “school planning zone”) in which the Project Site is located; the subdistricts 

are used for capital planning purposes and do not necessarily reflect individual school zones; 

therefore students are not limited to attending schools based on their subdistrict. The Overbuild 

would be located in Subdistrict 3 of Community School District (CSD) 2 (see Figure N-3). 

In accordance with the CEQR Technical Manual, this schools analysis uses the most recent New 

York City Department of Education (NYCDOE) data on school capacity, enrollment, and utilization 

rates for elementary and intermediate schools in the subdistrict Study Area. Specifically, the 

existing conditions analysis uses data provided in the NYCDOE’s Utilization Profiles: 

Enrollment/Capacity/Utilization, 2018–2019 edition. Future conditions are then predicted based 

on Statistical Forecasting’s enrollment projections and data obtained from New York City School 

Construction Authority’s (SCA’s) Capital Planning Division on the number of new DUs and 

students expected at the subdistrict level. The future utilization rate for school facilities is 

calculated by adding the estimated enrollment from proposed residential projects in the schools’ 

Study Area to Statistical Forecasting’s projected enrollment, and then comparing that number with 

projected school capacity. Charter school enrollment is not included in enrollment projections. 

Statistical Forecasting’s enrollment projections for years 2018 through 2028, the most recent data 

currently available, were provided by NYCDCP. These enrollment projections are based on broad 

demographic trends and do not explicitly account for discrete new residential projects planned for 

the Study Area. The estimated student population from the other new projects expected to be 

completed within the Study Area has been obtained from SCA’s Capital Planning Division and are 

added to the projected enrollment to ensure a more conservative prediction of future enrollment 

and utilization. In addition, new capacity from any new school projects identified in the NYCDOE 

Five-Year Capital Plan are included if construction has begun or if deemed appropriate to include 

in the analysis by the lead agency and the SCA. 
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Joe Dimaggio Hwy Twelfth Ave

Lincoln Tunnel

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Avenue of the Americas

W 58th St

Park Ave S

Eighth Ave

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Lexington Ave

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Irving Pl

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WESTERN RAIL YARD INFRASTRUCTURE PROJECT Figure N-3

0 2,000 FEET

3.12.21 Data source: NYC Dept. of City Planning Selected Facilities and Program Sites

A

Public Schools in the Study Area

Project Site (Western Rail Yard)

School District 2 Boundary

School Subdistrict 3 Boundary

!

1 Public School in the Study Area
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-41 June 2021

The effect of the new students introduced by the Overbuild on the capacity of schools within the 

Study Area is then evaluated. According to the CEQR Technical Manual, an adverse impact may 

occur if the Overbuild would result in both of the following conditions: 

1. A utilization rate of the elementary and/or intermediate schools in the subdistrict Study Area 

that is equal to or greater than 100 percent in the With Action scenario; and 

2. An increase of 5 percentage points or more in the collective utilization rate between the No 

Action and With Action scenarios. 

It should be noted that the 2009 SEQRA/CEQR FEIS identified mitigation (i.e., proposed school 

on-site) for the Overbuild’s impact to elementary schools. The Restrictive Declaration (RD) 

included provisions for the Overbuild Developer to work with the SCA upon completion of a 

threshold number of residential units in order to pursue action on the new school in the early phase 

of build-out of the Overbuild. 

Existing Conditions 

As shown in Table N-31, seven elementary schools serve Subdistrict 3/CSD 2. According to 

NYCDOE’s 2018–2019 school year enrollment figures, elementary schools in the subdistrict have 

a total enrollment of 3,190 students and are currently operating at 95 percent utilization, with a 

surplus of 183 seats. 

As shown in Table N-31, five intermediate schools serve Subdistrict 3/CSD 30. Total enrollment 

at these intermediate schools is 1,216 students, or 92 percent of capacity, with a surplus of 102 

seats. 
June 2021 N-42 

Table N-31 

Public Schools Serving the Study Area 

Enrollment and Capacity Data, 2018–2019 School Year 

Map 

No. Name Address Enrollment Capacity 

Available 

Seats 

Utilization 

% 

Elementary Schools 

Subdistrict 3 of CSD 2 

1 P.S. 011 William T. Harris 320 West 21st Street 888 801 -87 111 

2 P.S. 033 Chelsea Prep 281 Ninth Avenue 632 576 -56 110 

3 P.S. 051 Elias Howe 525 West 44th Street 481 501 20 96 

4 P.S. 111 Adolph S. Ochs 440 West 53rd Street 413 718 305 57 

5 P.S. 212 / I.S. 17 Midtown West 328 West 48th Street 363 314 -49 116 

6 Sixth Avenue Elementary School 64 West 17th Street 339 387 48 88 

7 Ballet Tech, NYC Public School for 

Dance 890 Broadway 74 76 2 97 

Subdistrict 3 of CSD 30 Total 3,190 3,373 183 95 

Intermediate Schools 

Subdistrict 3 of CSD 2

8 The Clinton School 10 East 15th Street 294 293 -1 100 

9 I.S. 70 – New York City Lab Middle 

School for Collaborative Studies 333 West 17th Street 563 635 72 89 

10 I.S. 17 / Professional Performing 

Arts High School 328 West 48th Street 123 118 -5 104 

11 Quest to Learn – Bayard Rustin 

Educational Comp. 351 West 18th Street 167 207 40 81 

12 Ballet Tech, NYC Public School for 

Dance 890 Broadway 69 70 1 99 

Subdistrict 3 of CSD 30 Total 1,216 1,323 107 92 

Note: See Figure N-3. 

Source: NYCDOE Enrollment/Capacity/Utilization for the 2018–2019 School Year. 

Future without the Overbuild 

The latest available enrollment projections for Subdistrict 3/CSD 2 were used to form the baseline 

enrollment, shown in Table N-32 in the column titled “Projected Enrollment.” This data projects 

elementary and intermediate enrollment through 2028. Since the Preferred Alternative’s analysis 

year (2030) is beyond 2028, the 2028 projections are used as a baseline. The students projected 

to be introduced by planned projects are added to this baseline projected enrollment using SCA 

student numbers for Subdistrict 3/CSD 2 (derived from the SCA’s Projected New Housing Starts), 

as shown in the column titled “Students Introduced by Planned Residential Development” in Table 

N-32. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-43 June 2021

Table N-32 

Utilization in CSD 2/Subdistrict 3 

Study Area 

Projected 

Enrollment1

Students Introduced by 

Planned Residential 

Development 

Total Future 

Enrollment Capacity2

Available 

Seats 

Utilization

% 

Elementary Schools 

Subdistrict 3 of 

CSD 2 3,650 370 4,020 3,373 -647 119 

Intermediate Schools 

Subdistrict 3 of 

CSD 2 945 30 975 1,323 348 74 

Notes: 

1 2028 enrollment projections were used, the latest year available. Elementary and intermediate school 

enrollment in each subdistrict Study Area was calculated by applying SCA supplied percentages for 

each subdistrict to the relevant district enrollment projections. 

Sources: 

Enrollment Projections 2018 to 2028 New York City Public Schools by Statistical Forecasting; NYCDOE, 

Utilization Profiles: Enrollment/Capacity/Utilization 2018–2019 School Year; NYCDOE 2020–2024 

Proposed Five-Year Capital Plan; SCA. 

Table N-32 shows that the total future Study Area enrollment is projected to be 4,020 elementary 

students and 975 intermediate students. 

According to the CEQR Technical Manual methodologies, new capacity from new school projects 

identified in the NYCDOE Five-Year Capital Plan are included if construction has begun or if 

deemed appropriate to include in the analysis by the lead agency and the SCA. According to 

NYCDOE’s 2020–2024 Proposed Five-Year Capital Plan, there is one change that will add new 

school capacity anticipated for Subdistrict 3/CSD 30. A new school is proposed for the Western 

Rail Yard Site that would add 420 elementary and 330 intermediate school seats. However, this 

school is contingent on the Overbuild being constructed, and is therefore analyzed as an indirect 

effect of the Preferred Alternative. 

In addition, according to NYCDOE’s Panel for Educational Policy, there are no planned changes 

in utilization in existing schools, aside from the proposed re-siting and temporary co-location of 

City Knoll Middle School (02M933) with P.S. 111 Adolph S. Ochs (02M111) in Building M111 for 

three years beginning in the 2019–2020 school year. 

As shown in Table N-32, elementary schools in the subdistrict Study Area would operate over 

capacity (119 percent utilization) with a deficit of 647 seats in the No Action Alternative. As shown 

in Table N-32, intermediate schools in the subdistrict would operate well under capacity (74 

percent utilization) with a surplus of 348 seats. 

Future with the Overbuild 

According to the multipliers contained in the CEQR Technical Manual, with an incremental 

increase in DUs of 4,000, the Overbuild would introduce approximately 150 elementary students 

and 42 intermediate students to Subdistrict 3/CSD 2 (see Table N-33). 

As noted above, an adverse impact may occur if a project would result in both of the following 

conditions: (1) a utilization rate of the elementary or intermediate schools in the subdistrict Study 

Area that is equal to or greater than 100 percent in the With Action scenario; and (2) an increase 

of 5 percentage points or more in the collective utilization rate between the No Action and the With 

Action conditions. 
June 2021 N-44 

Table N-33 

With Overbuild Condition—Utilization in CSD 2/Subdistrict 3 

(With Proposed School) 

Study Area Enrollment 

Students 

Introduced by 

the Overbuild 

Total with 

Overbuild 

Enrollment Capacity 

Available 

Seats 

Utilization 

% 

Percentage Point Change in 

Utilization 

Elementary Schools 

Subdistrict 

3 of CSD 2 4,020 150 4,170 3,793 -377 110 -9.24 

Intermediate Schools 

Subdistrict 

3 of CSD 2 975 42 1,017 1,653 636 62 -12.18 

Sources: 

Enrollment Projections 2018 to 2028 New York City Public Schools by Statistical Forecasting; NYCDOE, Utilization 

Profiles: Enrollment/Capacity/Utilization 2018–2019 School Year; NYCDOE 2020–2024 Proposed Five-Year 

Capital Plan; SCA.

With the Overbuild, the total elementary school enrollment of Subdistrict 3/CSD 2 would increase 

to 4,170; accounting for the proposed new school that is part of the Overbuild’s program, capacity 

would increase to 3,793 seats. Therefore, elementary schools would operate at 110 percent 

utilization with a deficit of 377 seats (see Table N-33). Elementary school utilization would 

decrease by 9.24 percentage points with the Overbuild. Since this would be below the 5-

percentage point increase threshold used in the CEQR Technical Manual to determine an adverse 

impact, the Overbuild would not result in an adverse impact on elementary schools in the Study 

Area and therefore would not result in an indirect adverse impact of the Preferred Alternative. 

With the Overbuild, the total intermediate school enrollment of Subdistrict 3/CSD 2 would increase 

to 1,017; accounting for the proposed new school, capacity would increase to 1,653 seats. 

Therefore, elementary schools would operate at 62 percent utilization with a surplus of 636 seats 

(see Table N-33). With the Overbuild, intermediate school utilization would decrease by 12.18 

percentage points. Since this would be below the 5-percentage point increase threshold used in 

the CEQR Technical Manual to determine an adverse impact, the Overbuild would not result in an 

adverse impact on intermediate schools in the Study Area and therefore would not result in an 

indirect adverse impact of the Preferred Alternative. 

Potential Indirect Effects on Public Libraries 

According to the CEQR Technical Manual, a libraries analysis should focus on branch libraries 

and not on the major research or specialty libraries that may fall within a study area. Service areas 

for neighborhood branch libraries are based on the distance that residents would travel to use 

library services, typically not more than 3⁄4-mile (the library’s catchment area). This libraries 

analysis compares the population generated by the Overbuild with the catchment area population 

of libraries available within an approximately 3⁄4-mile area around the Muhlenberg Library, which 

is the closest branch library to the Project Site. 

To determine the existing population of the library’s catchment area, 2014–2018 ACS 5-Year 

Estimates data were assembled for all census tracts that fall primarily within 3⁄4-mile of the library. 

The catchment area population was estimated by multiplying the number of new DUs in projects 

located within the 3⁄4-mile catchment area that are expected to be complete by 2030 by an average 

household size of 1.7 persons (the average household size for Manhattan Community Districts 4 

and 5 according to 2014–2018 ACS data). The catchment area population with the Overbuild was 

estimated by adding the anticipated population that would result from the Overbuild. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-45 June 2021

New population without and with the Overbuild were added to the existing catchment area 

population. According to the CEQR Technical Manual, if a project would increase the library’s 

catchment area population by 5 percent or more, and this increase would impair the delivery of 

library services in a study area, a significant impact could occur. 

L.1.1.1.1 Existing Conditions 

The Study Area is served by the Manhattan Library (ML) system, also known as the New York 

Public Library (NYPL). Libraries within the NYPL system provide free and open access to books, 

periodicals, electronic resources, and non-print materials as well as reference, career services, 

Internet access, and educational, cultural and recreational programming for adults, young adults, 

and children. 

The Overbuild falls within the area of one library location (see Figure N-4). The Muhlenberg 

Library branch is located at 209 West 23rd Street. The Muhlenberg Library branch features 

computers, workstations with free internet access, printers, children’s areas, and a meeting room 

for programs and community events. The branch serves a catchment area population of 114,522 

with approximately 69,673 holdings, resulting in a ratio of 0.61 holdings per person as shown in 

Table N-34. Users of the Muhlenberg Library branch can request a volume from any of the other 

libraries in the NYPL system through inter-library loan. 

Table N-34 

Public Libraries Serving the Overbuild 

Library Name1 Address Holdings2 Catchment Area Population3 Holdings per Resident 

Muhlenberg Library 209 West 23rd Street 69,673 114,522 0.61 

Notes: 

1

 See Figure N-4. 2

 Holdings include books, CD-ROMs, DVDs, and videotapes. 

3

 2014–2018 American Community Survey 5-Year Estimates for census tracts primarily within the library’s 3⁄4-mile 

catchment area (Census Tracts 99, 50, 63, 111, 71, 68, 74, 77, 52, 109, 101, 56, 95, 81, 54, 83, 76, 97, 103, 58, 

87, 89, 93, and 91) 

Sources: 

NYPL (2014); 2014–2018 American Community Survey 5-Year Estimates; NYCDCP Selected Facilities and Program 

Sites.

Future Conditions 

By 2030, the catchment area population of the library will increase as a result of new development 

projects completed by 2030. Approximately 7,030 new residents will be added to the Muhlenberg 

Library branch catchment area, increasing its catchment area population to 121,552. The 

holdings-per-resident ratio will decrease to 0.57 in the branch catchment area (see Table N-35). 

Table N-35 

Catchment Area Population in 2030 

Library Name 

Existing Catchment 

Area Population New Residents1

New Catchment 

Area Population Holdings Total 

New Holdings 

per Resident 

Muhlenberg Library 114,522 7,030 121,552 69,673 0.57 

Note: 

1

 This number was calculated by multiplying the number of planned No Action developments (4,135 DUs) by the 

Average Household Size (1.7) for Manhattan Community Districts 4 and 5 according to 2014–2018 ACS Data. 

Sources:

NYPL (2014); 2014–2018 American Community Survey (ACS) 5-year Estimates; NYCDCP Selected Facilities and Program 

Sites. 
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W 33rd St

Dyer Ave

Eighth Ave

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WESTERN RAIL YARD INFRASTRUCTURE PROJECT Figure N-4

0 2,000 FEET

3.12.21 Data source: NYC Dept. of City Planning Selected Facilities and Program Sites

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Public Library in the Study Area

Project Site (Western Rail Yard)

Study Area (3/4-mile perimeter)

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Muhlenberg Library
June 2021 N-46 

Future with the Overbuild 

According to the CEQR Technical Manual, if a project increases a study area population by 5 

percent or more as compared to without a proposed action, this increase may impair the delivery 

of library services in a study area, and an adverse impact could occur. 

The Overbuild would result in an increment of approximately 4,000 DUs compared to a scenario 

without the Overbuild. Using an average household size of 1.7 persons, the Overbuild would result 

in an increment of approximately 6,800 residents. 

With this additional population, the Muhlenberg Library branch would serve 128,352 residents, 

which represents a population increase of 5.59 percent. The holdings-per-resident ratio for the 

Muhlenberg Library branch would decrease from 0.57 to 0.54 with the Overbuild (see Table N-36). 

Table N-36 

With Overbuild Scenario: Catchment Area Population 

Library Name 

Catchment Area 

Population Without 

the Overbuild 

Population 

Increase due to 

the Overbuild 

New Catchment Area 

Population With the 

Overbuild Scenario 

Population 

Increase % 

New Holdings 

per Resident 

Muhlenberg Library 121,552 6,800 128,352 5.59 0.54 

Sources: 

NYPL (2014); 2014–2018 American Community Survey 5-Year Estimates; NYCDCP Selected Facilities and Program Sites. 

Although this is greater than the five-percent change threshold, this change would not impair the 

delivery of library services within the Study Area. Residents of the Muhlenberg Library branch 

catchment area would have access to the entire NYPL through the inter-library loan system and 

could have volumes delivered directly to their nearest library branch. Residents would also have 

access to libraries near their place of work. Therefore, there would not be an adverse impact on 

library services in the Study Area as a result of the Overbuild and therefore would not result in an 

indirect adverse impact of the Preferred Alternative. 

Potential Indirect Effects on Publicly Funded Child Care 

Centers 

The New York City Administration for Children’s Services (NYCACS) provides subsidized child 

care in center-based group child care, family-based child care, informal child care, and Head Start 

programs. Publicly funded child care services are available for income-eligible children through 

the age of 12. In order for a family to receive subsidized child care services, the family must meet 

specific financial and social eligibility criteria that are determined by federal, state, and local 

regulations. In general, children in families that have incomes at or below 200 percent of the 

Federal Poverty Level (FPL), depending on family size, are financially eligible, although in some 

cases eligibility can go up to 275 percent FPL. NYCACS has also noted that 60 percent of the 

population utilizing subsidized child care services are in receipt of Cash Assistance and have 

incomes below 100 percent FPL. To receive subsidized child care services, a family also must 

have an approved “reason for care,” such as involvement in a child welfare case or participation 

in a “welfare-to-work” program. Head Start is a federally funded child care program that provides 

children with half-day or full-day early childhood education. Program eligibility is limited to families 

with incomes at 130 percent or less of the FPL. 

As described in the CEQR Technical Manual, the City’s affordable housing market is fixed to the 

AMI rather than FPL. Since family incomes at or below 200 percent FPL fall under 80 percent AMI, 

for the purposes of a CEQR analysis, the number of DUs expected to be subsidized and targeted 

for incomes of 80 percent AMI or below provides a conservative estimate of the number of DUs 

with children that are eligible for publicly funded child care services. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-47 June 2021

Most children are served through enrollment in contracted Early Learn programs or by vouchers 

for private and non-profit organizations that operate child care programs throughout the City. 

Registered or licensed providers can offer family-based child care in their homes. Informal child 

care can be provided by a relative or neighbor for no more than two children. Children aged 6 

weeks through 13 years old can be cared for either in group child care centers licensed by the 

New York City Department of Health and Mental Hygiene (DOHMH) or in homes of registered 

child care providers. NYCACS also issues vouchers to eligible families, which may be used by 

parents to pay for child care from any legal child care provider in the City. 

Consistent with the methodologies of the CEQR Technical Manual, this analysis of child care 

centers focuses on services for children under age 6, as older eligible children are expected to be 

in school for most of the day. Publicly funded child care centers, under the auspices of the Early 

Care and Education (ECE) within NYCACS, provide care for the children of income-eligible 

households. Space for one child in such child care centers is termed a “slot.” These slots may be 

in group child care or Head Start centers, or they may be in the form of family-based child care in 

which up to 16 children are placed under the care of a licensed provider and an assistant in a 

home setting. 

Since there are no locational requirements for enrollment in child care facilities, and some parents 

or guardians choose a child care center close to their employment rather than their residence, the 

service areas of these facilities can be quite large and not subject to strict delineation to identify a 

Child Care Study Area. However, according to the CEQR Technical Manual methodology for child 

care analyses, the locations of publicly funded group child care facilities within approximately 1.5 

miles of a project site should be shown, reflecting the fact that the facilities closest to a project site 

are more likely to be subject to increased demand from new residents introduced by an action. 

Therefore, the Child Care Study Area for the analysis of child care centers is the area within 1.5 

miles of the Project Site. As shown on Figure N-5, the 1.5-mile Child Care Study Area covers 

Manhattan. Current enrollment data for the child care and Head Start facilities closest to the 

Project Site were gathered from NYCACS. 

Child care enrollment was estimated by multiplying the number of new low- and low/moderateincome (i.e., affordable, non-senior) DUs expected in the 1.5-mile study area by the CEQR 

multipliers for estimating the number of children under age 6 eligible for publicly funded child care 

services. For Manhattan, the multiplier estimates 0.115 public child care-eligible children under 

age 6 per low- and low/moderate-income DUs. As noted above, the CEQR analysis focuses on 

services for children under age 6 because eligible children aged 6 to 12 are expected to be in 

school for most of the day. 

The child care-eligible population introduced by the Overbuild was also estimated using the CEQR 

Technical Manual child care multipliers. The population of public child care-eligible children under 

age 6 was then added to the child care enrollment calculation. According to the CEQR Technical 

Manual, an adverse impact on publicly funded child care may result if there would be a demand 

for slots greater than the remaining capacity of child care facilities (i.e., more than 100 percent 

utilization), and if a proposed action would generate demand constituting an increase of 5 

percentage points or more of the collective capacity of the child care facilities serving a study area. 

Existing Conditions 

There are three publicly funded child care facilities within the 1.5-mile Study Area, all in Manhattan 

(see Figure N-5). As shown in Table N-37, these child care centers have a total capacity of 110 

slots and an enrollment of 135 children with 25 available slots (81.5 percent utilization). 
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Mott St

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Avenue of the Americas

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E 53rd St

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W 19th St

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Washington St

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14thSt Loop

E 23rd St

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Eleventh Ave

Park Ave

Horatio St

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W 27th St

Gansevoort St

E 11th St

E 43rd St

Seventh Ave SOUTH

E 4th St

E 14th St

West End Ave

Morton St

W 13th St

Greenwich St

E 9th St

East Dr

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We

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Jane St

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Gr ove St

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Park Ave S

Bedford St

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Free

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Waverly Pl

W 47th St

University Pl

W 32nd St

Central Park S

W 28th St

W 23rd St

Bank St

W 53rd St

Lexington Ave

W 45th St

W 11th St

W 3rd St

Vanderbilt Ave

Sutton Pl S

E 33rd St

St Marks Pl

De Pew Pl

EAST

RIVER

HUDSON RIVER

Bryant Park

Central Park

HUDSON

GUILD INC

HUDSON

GUILD INC

YWCA OF THE

CITY OF NY

WESTERN RAIL YARD INFRASTRUCTURE PROJECT Figure N-5

0 3,000 FEET

3.12.21 Data source: NYC Dept. of City Planning Selected Facilities and Program Sites

A

Child Care Facilities in the Study Area

Project Site (Western Rail Yard)

Study Area (1.5-mile perimeter)

! Child Care Facility
June 2021 N-48 

Table N-37 

Publicly Funded Child Care Facilities Serving the Study Area 

Map 

No. Contractor Name Address Enrollment Capacity 

Available 

Slots 

Utilization 

Rate % 

1 Hudson Guild Inc. 459 West 26th Street 56 73 17 76.7 

2 Hudson Guild Inc. 410 West 40th Street 11 12 1 91.7 

3 YWCA of the City of NY 538 West 55th Street 43 50 7 86.0 

Total 110 135 25 81.5 

Note: See Figure N-5. 

Source: NYCACS, October 2020. 

Future without the Overbuild 

FRA identified planned or proposed development projects in the child care study area (1.5 miles 

from the Project Site) that will include affordable DUs utilizing data provided by the NYCHPD. 

These projects are summarized on Table N-38. 

As shown on Table N-38, these projects will introduce approximately 746 new affordable DUs by 

the 2030 build year. Based on the CEQR Technical Manual generation rates for estimating the 

number of children eligible for publicly funded day care, this amount of development would 

introduce approximately 86 new children under the age of 6 who would be eligible for publicly 

funded child care programs. 

Based on the projected increase in demand for child care facilities, the number of available slots 

would markedly decrease. As described above, there are currently 25 available slots and a 

utilization rate of 81.5 percent. When the estimated 86 children under age 6 introduced by planned 

development projects are added to this total, assuming no addition of capacity to accommodate 

the additional eligible children, child care facilities in the Study Area would operate with a deficit 

of 61 slots (a 145.2 percent utilization rate). 

Table N-38 

Affordable Housing Projects in the Study Area 

Project Name/Address Project Description/Program Affordable Dwelling Units1

400 West 61st Street 

All Residential 

156 

675 West 59th Street 64 

663 West 59th Street 49 

211 West 28th Street 37 

225 West 28th Street 35 

39 West 23rd Street 2 

601 West 29th Street 234 

371 Ninth Avenue 169 

Total 746 

Notes:

1 Number of affordable dwelling units identified on NYCHPD Housing New York map. 

Source:

NYCHPD Housing New York Map 

Future with the Overbuild 

The Overbuild currently assumes 324 affordable units would be available to households with 

incomes at or below 80 percent AMI. Based on the CEQR Technical Manual child care multipliers, 

the development of 324 affordable units would result in approximately 37 children under the age 

of 6 who would be eligible for publicly funded child care programs. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-49 June 2021

With the addition of these children, enrollment at child care facilities in the Study Area would 

increase to 233 children, compared to a capacity of 135 slots with a deficit of 98 slots (see Table 

N-39). This demand would represent 172.6 percent of the existing facilities’ capacity, which 

represents an increase in the utilization rate of 27.4 percentage points. 

Table N-39 

Estimated Child Care Facility Enrollment, Capacity, and Utilization 

 Enrollment Capacity 

Available 

Slots 

Utilization 

Rate % 

Percentage Point 

Change in Utilization 

Without the Overbuild 196 135 -61 145.2 N/A 

With the Overbuild 233 135 -98 172.6 27.4 

Sources:

NYCACS, October 2020; NYCHPD 

As noted above, the CEQR Technical Manual guidelines indicate an adverse impact on publicly 

funded child care services could result when both of the following criteria are met: (1) a demand 

for slots greater than the remaining capacity of child care facilities; and (2) an increase in demand 

of 5 percentage points of the study area capacity. With the Overbuild, child care facilities in the 

Study Area would operate over capacity and the increase of 27.4 percentage points in the 

utilization rate (demand to existing capacity ratio) would exceed 5 percentage points. Therefore, 

the Overbuild would result in an adverse child care impact. To increase this ratio by less than 5 

percentage points, the number of affordable DUs introduced by the Overbuild would need to be 

reduced to 56, which would generate 6 children eligible for public child care services. With the 

assumption of 324 affordable units, the Overbuild would generate 37 eligible children, a difference 

of 31 child care slots above the number of slots associated with an increase in utilization in the 

Study Area of less than five percent. 

This expected increase in demand could be offset by a number of factors. Private child care 

facilities and child care centers outside of the Study Area are not included in this analysis. Some 

of the increased child care demand would likely be offset by parents who choose to take their 

children to child care centers outside of the Study Area (e.g., closer to work). Some of the Family 

Day Care Networks serve children residing in the Study Area and could potentially absorb some 

of the demand. This new demand may also be considered in future Request for Proposal planning 

for contracted services. 

As indicated in the 2009 SEQRA/CEQR FEIS, new capacity could potentially be developed as 

part of NYCACS’ public-private partnership initiatives. As partial mitigation for this impact, 

NYCACS will monitor the demand and need for additional capacity and implement change to the 

extent practicable. The RD will require the Overbuild Developer to offer NYCACS 10,000 square 

feet of space for use as a day care facility, at a rate affordable to NYCACS providers, in the event 

that NYCACS determines that development of the Overbuild would result in a need for additional 

day care capacity. In the event NYCACS declines the offer of space, NYCACS may request 

implementation of alternative measures to make program or physical improvements that would 

support additional day care capacity. The Overbuild Developer would consider such alternative 

measures, when identified. With the above measures in place, the Preferred Alternative would not 

indirectly result in an adverse impact to child care services. 
June 2021 N-50 

Police Services 

The CEQR Technical Manual threshold for an analysis of police services is if a proposed action 

would affect the physical operation of, or access to and from, a facility or where a proposed action 

would create a sizeable new neighborhood where none existed before. As detailed in Chapter 17, 

“Socioeconomics,” the Preferred Alternative would not directly displace any police facilities and, 

therefore, would not adversely affect the physical operation of, or access to and from, such facilities. 

With respect to potential indirect effects, the Preferred Alternative would not create a sizeable new 

neighborhood as defined by the CEQR Technical Manual. Therefore, there would be no adverse 

indirect impact on police services. Following CEQR Technical Manual guidelines, this section 

identifies and describes health care facilities within approximately 1⁄2-mile of the Project Site. 

As shown on Figure N-6 and in Table N-40, the Project Site is officially served by the 10th Precinct 

of the New York City Police Department (NYPD), which is located at 230 West 20th Street. The 

10th Precinct serves an area of approximately 0.93 square miles generally bounded by West 43rd 

Street on the north, Ninth and Seventh Avenues on the east, West 14th Street on the south, and 

the Hudson River on the west. It serves the Chelsea residential neighborhood; the Hudson Yards 

district; notable large attractions, such as Chelsea Piers and the Jacob K. Javits Convention 

Center; and major transportation routes, such as the Lincoln Tunnel and West Side Highway. 

Table N-40 

Police Facility Serving the Project Site 

Map No. Police Facility Address 

P1 10th Precinct 230 West 20th Street 

Note: See Figure N-6. 

Fire Protection and Emergency Services 

The CEQR Technical Manual threshold for an analysis of fire protection and emergency services 

is if a proposed action would affect the physical operation of, or access to and from, a facility or 

where a proposed project would create a sizeable new neighborhood where none existed before. 

As detailed in Chapter 17, “Socioeconomics,” the Preferred Alternative would not directly displace 

any fire protection and emergency service facilities and, therefore, would not adversely affect the 

physical operation of, or access to and from, such facilities. With respect to potential indirect 

effects, the Preferred Alternative would not create a sizeable new neighborhood as defined by the 

CEQR Technical Manual. Therefore, there would be no adverse indirect impact on fire protection 

and emergency services. Following the CEQR Technical Manual guidelines, this section identifies 

and describes health care facilities within approximately 1⁄2-mile of the Project Site. 

Citywide, New York City Fire Department (FDNY) engine companies carry hoses; ladder 

companies provide search, rescue, and building ventilation functions; and rescue companies 

respond to fires or emergencies. In addition, FDNY operates the City’s Emergency Medical 

Services (EMS) system. As shown on Figure N-6 and in Table N-41, the Project Site is served by 

Engine 34/Ladder 21, located at 440 West 38th Street and The High Line/EMS Station 7, located 

at 512 West 23rd Street. 

Table N-41 

Fire and EMS Facilities Serving the Project Site 

Map No. Fire/EMS Facility Address 

F1 Engine 34/Ladder 21 440 West 38th Street 

F2 The High Line/EMS Station 7 512 West 23rd Street 

Note: See Figure N-6. 
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W 20th St

W 34th St

W 25th St

W 35th St

W 17th St

W 31st St

W 15th St

W 26th St

Tenth Ave

Seventh Ave

W 22nd St

W 40th St

W 33rd St

D

y

er Ave

W 18th St

Ninth Ave

W 24th St

W 37th St

W 16th St

W 30th St

W 29th St

W 43rd St

W 44th St

Joe

Di

maggio Hwy Twelfth Ave

Lincoln Tunnel

W 38th St

W 27th Dr

W 19th St

W 21st St

W 41st St

W 36th St

W 42nd St

W 39th St

Eleventh Ave

Broadway

Eighth Ave

W 28th St

W 23rd St

W 27th St

Hudson Blvd E

W 32nd St

HUDSON RIVER

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2

3

4

5

6

7

8

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12 11

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F1

F2

P1

WESTERN RAIL YARD INFRASTRUCTURE PROJECT Figure N-6

0 1,000 FEET

3.12.21 Data source: NYC Dept. of City Planning Selected Facilities and Program Sites

A

Police, Fire, EMS, and Health Care Facilities

in the Study Area

Project Site (Western Rail Yard)

New York Police Department 10th Precinct

!

1 Police, Fire, EMS, and Health Care Facility in the Study Area
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-51 June 2021

Units responding to a fire are not limited to ones closest to it. Typically, a total of three engine 

companies and two ladder companies respond to each call. Each FDNY squad is capable of 

operating as an engine, ladder, or rescue company, making them versatile for incident 

commanders. Each squad is also part of the FDNY HazMat Response Group and has a HazMat 

Tech Unit within each company. FDNY can call on units in other parts of the City as needed. 

There are two types of ambulances in the City—911 providers and those providing inter-facility 

transport. Municipal FDNY and hospital-based ambulances are the sole providers of 911 service 

and operate on that system via contract with EMS (inter-facility transports are carried out by private 

contractors and do not participate in the 911 system). All hospital-based ambulances that operate 

in the 911 system do so by contractual agreement with the EMS. All ambulances in the 911 system 

are dispatched by FDNY under the same computer-based system, regardless of hospital affiliation. 

The dispatch system divides the City into geographic areas, based loosely on NYPD precinct 

sectors, with a number of areas located within each precinct, and assigns the nearest unit to an 

emergency call based on its current location. All units are assigned a permanent cross-street 

location where they await a service call; units return to this location once service is complete. These 

locations are determined by FDNY based on historical call volumes by location and time of day. 

Heath Care Facilities 

The CEQR Technical Manual threshold for an analysis of outpatient health care facilities is if a 

proposed action would affect the physical operation of, or access to and from, a facility or where 

a proposed action would create a sizeable new neighborhood where none existed before. As 

detailed in Chapter 17, “Socioeconomics,” the Preferred Alternative would not directly displace 

any outpatient health care facilities and, therefore, would not adversely affect the physical 

operation of, or access to and from, such facilities. With respect to potential indirect effects, the 

Preferred Alternative would not create a sizeable new neighborhood as defined by the CEQR 

Technical Manual. Therefore, there would be no adverse indirect impact on health care facilities. 

Following CEQR Technical Manual guidelines, this section identifies and describes health care 

facilities within approximately 1⁄2-mile of the Project Site. 

Table N-42 includes an inventory of approximately 16 health care facilities located within the 1⁄2-

mile Study Area, as inventoried in NYCDCP’s Selected Facilities and Program Sites in New York 

City, 2020 Edition (see Figure N-6). These health care facilities offer general medical care, mental 

health services, and treatment centers. 
June 2021 N-52 

Table N-42 

Other Health Care Facilities Serving the Project Site 

Map No. Facility Name Address Facility Type 

1 Covenant House 460 West 41st Street Diagnostic and Treatment Center 

2 Sidney R. Baer, Jr. Health Center 347 West 37th Street Diagnostic and Treatment Center 

3 Housing Works Inc. HIV Testing 

Services 301 West 37th Street Diagnostic and Treatment Center 

4 West Midtown Medical Group 311 West 35th Street Diagnostic and Treatment Center 

5 Premier Healthcare D & T Center 460 West 34th Street Diagnostic and Treatment Center 

6 Gay Men’s Health Crisis Inc. HIV 

Testing Services 446 West 33rd Street Diagnostic and Treatment Center 

7 Lower Manhattan Health District 303 Ninth Avenue Diagnostic and Treatment Center 

8 BIMC Geriatrics Senior Health Center 275 Eighth Avenue Hospital Extension Clinic 

9 Urban Pathways Inc. 575 Eighth Avenue Mental Health Treatment 

10 ACMH – HH Nonmed CM 545 Eighth Avenue Mental Health Treatment 

11 National Alliance for the Mentally Ill of 

New York City Inc. 505 Eighth Avenue Mental Health Treatment 

12 On-Site Rehabilitation 454 West 35th Street Mental Health Treatment 

13 Hudson Guild Paula B. Balser 

Counseling Service 441 West 26th Street Mental Health Treatment 

14 WSFHH NYC DMH NY/NY I-Fleming 443 West 22nd Street Mental Health Treatment 

15 GMHC OP 307 West 38th Street Chemical Dependency Outpatient 

Clinic 

16 West Midtown Management Group 

OTP 1 331 West 35th Street Chemical Dependency Outpatient Clinic 

Note: See Figure N-6. 

Source: NYCDCP, Selected Facilities and Program Sites, 2020 Edition

ELDERLY AND PERSONS WITH DISABILITIES 

The Overbuild, which is an indirect consequence of the Preferred Alternative, would introduce an 

incremental population that would include elderly individuals as well as persons with disabilities. 

It would be speculative to project the proportion of the incremental population that would fall within 

one or both of these categories. However, as detailed in Chapter 17, “Socioeconomics,” the Study 

Area does not contain a disproportionately large number of elderly or persons with disabilities, and 

the Preferred Alternative would not directly displace any facilities that serve these populations. 

The addition of elderly and persons with disabilities with the Overbuild is not expected to 

substantively affect the demographic composition of the Study Area, or adversely affect the 

mobility or availability of services for these populations. Therefore, the Preferred Alternative is not 

expected to substantively affect the demographic composition of the Study Area indirectly, or 

adversely affect the mobility or availability of services for these populations. 

N.4 INDIRECT CONSTRUCTION IMPACTS OF THE 

PREFERRED ALTERNATIVE 

Throughout this section, references to the construction of the Overbuild are included in the context 

of that development being a previously approved project (as analyzed in the 2009 SEQRA/CEQR 

FEIS) that would be an indirect consequence of the Preferred Alternative, with associated indirect 

construction effects. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-53 June 2021

TRANSPORTATION 

The indirect construction effects of the Preferred Alternative would be related to the construction 

of the Overbuild. As established by the current construction phasing and sequencing plan for the 

Platform and Overbuild provided by the Project Sponsor, the peak indirect construction activities 

generated by the approved Overbuild occur in late 2025 into early 2026, about five years into the 

overall 10 year construction effort (see Section 20.2 for a more complete description of the 

construction and phasing plan). The MPT Plan to be implemented in coordination with NYCDOT 

during the construction period as described in Chapter 6, “Transportation,” and would continue 

throughout the construction for the Overbuild. 

The levels of daily construction workers and truck trips generated by construction activity 

anticipated during this peak construction period reach an estimated 1,207 daily construction works 

over two shifts and about 2010 daily truck trips. There would be an estimated 254 auto trips 

generated by construction workers. Using the same trip construction activity trip generation 

characteristics as with the proposed Platform construction (see Chapter 6, “Transportation”), this 

would yield peak 6 to 7 AM traffic demand of about 102 arriving auto trips and 53 truck arrivals 

and 53 truck departures. There would be no auto trips and about 11 trucks arriving and departing 

during the peak analysis morning, midday, and evening peak periods. 

This is consistent with, but somewhat lower peak hour trip generation than, estimates were 

determined for the approved 2009 SEQRA/CEQR FEIS project. As established in the 2009 

SEQRA/CEQR FEIS, there could be adverse impacts during the Overbuild’s temporary 

construction period, and the approved Overbuild project includes mitigation commitments that the 

Overbuild Developer would carry forward and implement during the peak construction period. 

These measures would also be considered in the City’s overall monitoring and mitigation program. 

These improvements would be similar to those described for the permanent operations condition 

of the approved Overbuild project, including signal timing modifications and lane channelization. 

The 2009 SEQRA/CEQR FEIS identified six intersection movements in the AM and Midday peak 

hours and seven movements in the PM peak hour that would remain unmitigated during the 

Overbuild construction period. These findings remain applicable to the 2030 completion of the 

Overbuild and reflect the indirect construction effects of the Preferred Alternative. 

AIR QUALITY, GREENHOUSE GAS EMISSIONS, AND 

RESILIENCE 

The indirect construction impacts of the Preferred Alternative would not have an adverse impact 

on air quality. The current construction duration, logistics, and activities for each of the Overbuild 

buildings are anticipated to be similar to those analyzed in the 2009 SEQRA/CEQR FEIS. In 

addition, consistent with the 2009 SEQRA/CEQR FEIS, the Overbuild Developer is expected to 

implement an emissions reduction program to minimize the air quality effects from construction of 

the Overbuild. These measures would include clean fuel, diesel equipment reduction, dust control 

measures, idling restriction, engine retrofits, and utilization of newer equipment that meets specific 

USEPA standards. 
June 2021 N-54 

As discussed, the Overbuild Developer expects construction of Overbuild Sites 1 and 2 to overlap 

with the construction activities for the Preferred Alternative. Therefore, in order to determine if the 

current construction program would have the potential to cause significant adverse air quality 

impacts not identified in the 2009 SEQRA/CEQR FEIS, construction-related PM2.5 emissions were 

calculated for each calendar year when construction of the Preferred Alternative would overlap 

with the construction activities for the Overbuild. PM2.5 is selected for determining the worst-case 

periods for all pollutants analyzed, because the ratio of predicted PM2.5 incremental concentrations 

to impact criteria is anticipated to be higher than for other pollutants. Based on this calculation, 

the Preferred Alternative would result in a maximum annual average emission rate of 0.2 tons of 

PM2.5 per year for the calendar year 2025, compared to 0.8 tons of PM2.5 for the peak construction 

year analyzed in the 2009 SEQRA/CEQR FEIS. Accordingly, since the 2009 SEQRA/CEQR FEIS 

concluded that no significant adverse air quality impacts would be expected at any sensitive receptor 

locations from the proposed construction activities of the Overbuild, it is not expected that the current 

construction program would result in any significant adverse air quality impacts from construction. 

Therefore, the indirect construction impacts of the Preferred Alternative would not have an adverse 

impact on air quality. 

NOISE AND VIBRATION 

The indirect construction impacts of the Preferred Alternative would not result in adverse impacts 

related to noise and vibration. Construction-related noise impacts can result from noise generated 

on the Overbuild by construction equipment operation, and from construction vehicles and delivery 

vehicles traveling to and from the site. The current construction duration, logistics, and activities 

for each of the Overbuild buildings are anticipated to be similar to those analyzed in the 2009 

SEQRA/CEQR FEIS. Therefore, the results of the 2009 SEQRA/CEQR FEIS evaluation of 

potential worst-case construction noise conditions for the Overbuild are expected to represent 

expected impacts from construction of the Overbuild that would now occur later in time than the 

timeframe examined in the 2009 SEQRA/CEQR FEIS. The 2009 SEQRA/CEQR FEIS concluded 

that no significant adverse noise impacts would occur at any analysis location because of the 

construction of the Overbuild. This is because predicted noise levels would be below acceptable 

CEQR impact criteria. Construction operations and noise levels are also expected to comply with 

the New York City Construction Noise Regulations with respect to equipment noise emission 

levels. 

A construction vibration assessment was performed in the 2009 SEQRA/CEQR FEIS for the 

existing elevated High Line historic rail structure. It was determined that the use of certain highvibration-producing equipment within one foot of the High Line should be limited in order to 

minimize the potential of damage to the structure. Therefore, the Overbuild Developer would 

establish a CEPP, as is stipulated in the LOR executed among the coleads for the 2009 

SEQRA/CEQR FEIS (MTA and CPC), the OPRHP, and the Overbuild Developer. The CEPP 

would meet the guidelines set forth in the NYCDOB’s TPPN #10/88, concerning procedures for 

the avoidance of damage to adjacent historic structures from nearby construction, the Protection 

Programs for Landmarked Buildings guidance document of the LPC, and the National Park 

Service’s Preservation Tech Notes, Temporary Protection #3: Protecting a Historic Structure 

during Adjacent Construction. As described in the 2009 SEQRA/CEQR FEIS, the CEPP would 

specify measures and construction procedures, such as vibration limits and monitoring that the 

Overbuild Developer would implement during construction. With these measures, the 2009 

SEQRA/CEQR FEIS concluded that there would not be a significant adverse impact to the High 

Line because of construction of the Overbuild. Therefore, the indirect construction impacts of the 

Preferred Alternative would not have an adverse impact on the High Line. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-55 June 2021

CULTURAL RESOURCES 

The NRT and the High Line, both of which were previously determined eligible for listing on the 

State and National Register of Historic Places, are located within 90 feet of Overbuild construction. 

To avoid the potential for damage to the NRT from vibration produced by caisson drilling, the 

caissons will be located outside of Amtrak's influence line exclusion zone, and as part of the 

permitting process, the foundation drawings would be submitted to Amtrak for review and 

confirmation of no potential impact from construction vibration. As part of the 2009 SEQRA/CEQR 

FEIS, a construction vibration assessment was performed for the historic High Line rail structure. 

As discussed in Section 20.3.2.4, it was determined that the use of certain high-vibrationproducing equipment within one foot of the High Line should be limited in order to minimize the 

potential of damage to the structure. As described above, the LOR and the RD for the previously 

approved project require that a CEPP be developed in coordination with NYSHPO and LPC to 

protect the High Line from any potential construction-related adverse physical impacts, such as 

ground-borne construction-period vibrations, falling debris, and damage from heavy machinery. 

The CEPP would meet the guidelines set forth in the NYCDOB’s TPPN #10/88, concerning 

procedures for the avoidance of damage to adjacent historic structures from nearby construction, 

the Protection Programs for Landmarked Buildings guidance document of the LPC, and the 

National Park Service’s Preservation Tech Notes, Temporary Protection #3: Protecting a Historic 

Structure during Adjacent Construction. The CEPP would specify measures and construction 

procedures, such as vibration limits and monitoring that would be implemented during construction 

of the Overbuild. Construction procedures to protect the High Line would be developed and 

monitored by structural and foundation engineers. The CEPP also would empower the structural 

and foundation engineers to issue stop work orders to prevent damage to the High Line. With 

these measures, there would not be a significant adverse impact on the High Line due to 

construction of the Overbuild. No other historic properties are located within 90 feet of Overbuild 

construction. FRA has concluded that the potential construction and operational effects of the 

Preferred Alternative are: inadvertent effects to the NRT and High Line during construction of the 

Platform and Tunnel Encasement. FRA would include conditions as part of its environmental 

decision regarding the Preferred Alternative, i.e., in the ROD for the EIS in accordance with NEPA, 

and in any loan agreement to be negotiated between the Bureau and the Project Sponsor, to 

ensure that these potential effects to historic properties are not adverse. These conditions include 

requiring the Project Sponsor to develop a CEPP for the construction of the Platform and Tunnel 

Encasement in order to protect the NRT and High Line. 

Therefore, the indirect construction impacts of the Preferred Alternative would not have an adverse 

impact on cultural resources. 

PARKS AND RECREATION 

The adopted findings by New York City as part of the 2009 SEQRA/CEQR FEIS project approvals 

are that construction of the Overbuild would not result in significant adverse impacts to parks and 

recreation areas. Portions of the open space associated with the Overbuild would be completed 

in advance of the full build-out of the Overbuild. This open space would be developed in areas 

surrounding completed buildings that are no longer needed for construction materials laydown or 

other construction purposes, and where the welfare of users of the open space would not be 

compromised by nearby construction activity. No lanes or sidewalks are expected to be closed in 

order to construct the open space associated with the Overbuild. 
June 2021 N-56 

Temporary construction activities for the Overbuild would occur in proximity to the High Line and 

Hudson River Park, as well as the Hudson Yards Public Square and Garden and Bella Abzug Park 

and could be visible from these open spaces; however, the Overbuild construction would not be 

staged from or result in physical alterations to or occupation of any park or recreation area. 

Construction activities for the Overbuild would be noticeable to people on nearby portions of these 

parks—in particular the portion of the High Line located on the Project Site—and could be 

temporarily disruptive; however, in the future, in the same period while the Overbuild is under 

construction, extensive construction would also be occurring in the surrounding area for other 

projects. 

These parks and recreation areas would likely experience increased levels of noise, and under 

dry and windy conditions during the early stages of construction, dust from demolition and 

excavation activities associated with construction of the Overbuild. These conditions would be 

temporary, and with implementation of noise and air quality control measures, are not anticipated 

to be significant and adverse. Any noise increases from Overbuild construction activities would 

affect only a small portion of the 1.5-mile-long High Line or the 4-mile long Hudson River Park at 

any one time, leaving the rest of these linear parks available for recreation without increased noise. 

In addition, the High Line and Hudson River Park both have active recreational uses that are not 

noise-sensitive, and therefore any increases in noise would not substantially affect the use of the 

park for active recreation during the period when the increased noise from construction would 

occur. These resources also are located in close proximity to the West 30th Street Heliport, which 

contributes to existing noise levels in the surrounding area. Construction of the Overbuild also 

would normally not occur on weekends, which is the time when the High Line and Hudson River 

Park have the greatest demand. 

The existing concrete wall surrounding the Project Site along Twelfth Avenue would remain in the 

future with the Preferred Alternative; this wall, as well as the traffic and trees in the landscaped 

median along the avenue, would limit views from Hudson River Park to Overbuild construction 

activities within the Project Site. Other parks and recreation areas located farther from the Project 

Site would not be affected by visual changes or increases in noise or dust during construction of 

the Overbuild. It is possible that during the construction period for the Overbuild, construction 

workers may choose to use the parks and recreational areas in close proximity to the Project Site. 

The LOR and the RD for the previously approved project require that a CEPP be developed in 

coordination with NYSHPO and LPC to protect the High Line from any potential constructionrelated adverse physical impacts, such as ground-borne construction-period vibrations, falling 

debris, and damage from heavy machinery. 

Therefore, construction of the Overbuild would not have an adverse impact on parks and 

recreational areas as an indirect result of the Preferred Alternative. 

SOCIOECONOMICS 

The following section describes the indirect construction impacts of the Preferred Alternative on 

Socioeconomics. 
Appendix N: Indirect, Cumulative, and Other Impacts 

 N-57 June 2021

Indirect Residential Displacement 

As is typical with large construction projects, construction of the Overbuild would result in 

temporary disruptions in the surrounding area. However, such disruptions would not adversely 

affect the desirability of the Study Area as a residential neighborhood. The construction analysis 

in the 2009 SEQRA/CEQR FEIS found that construction activities associated with the Overbuild 

would not have any adverse impacts to socioeconomic conditions or neighborhood character 

within the Study Area. As the Overbuild program would remain with the framework of the already 

approved project, indirect construction impacts of the Preferred Alternative would not result in 

indirect residential displacement. 

Indirect Business Displacement 

As compared to other large construction sites in the Midtown Central Business District, there are 

relatively few businesses within immediate vicinity of the Project Site; they include paid parking 

facilities, the Jacob K. Javits Convention Center, and businesses and storefronts east of Eleventh 

Avenue that are part of Hudson Yards. Although sidewalk and lane closures are anticipated 

adjacent to the Project Site, at no time during the construction period would sidewalk or lanes be 

closed in front of any business. The construction activities associated with the Overbuild would 

not inhibit access to or affect the viability of businesses located in the vicinity of the Project Site, 

and therefore, indirect construction impacts of the Preferred Alternative are not expected to have 

any adverse impacts on these businesses. Positive effects are expected as construction of the 

Overbuild would bring construction workers to the areas surrounding the Project Site, workers who 

would patronize local eating and drinking establishments, convenience stores, neighborhood 

services, and other local businesses. Therefore, indirect beneficial construction impacts of the 

Preferred Alternative are expected. 

Adverse Effects on a Specific Industry 

Indirect construction impacts of the Preferred Alternative would not directly or indirectly displace 

businesses or businesses uses outside of the Project Site. Therefore, indirect construction impacts 

of the Preferred Alternative would not adversely affect any industries within or outside of the Study 

Area. 

Community Facilities and Services 

There are no community facilities within immediate proximity of the Project Site. Therefore, 

sidewalks and lane closures surrounding the Project Site would not impede access to community 

facilities. While construction activities would result in significant traffic impacts during the peak 

construction year, mitigation measures were identified that would mitigation, either in part or in 

whole, the adverse impacts. Therefore, access to and from community facilities, and the provision 

of police, fire, and emergency services, would not be significantly affected. In addition, emergency 

service vehicles can maneuver around and through congested areas because they are not bound 

by standard traffic controls. Therefore, indirect construction impacts of the Preferred Alternative 

would not have an adverse impact on community facilities and services. 
June 2021 N-58 

Elderly and Persons with Disabilities 

Construction activities would comply with all code requirements necessary to ensure a safe 

construction zone for workers and surrounding pedestrians, including elderly and persons with 

disabilities. In areas where temporary sidewalk closure is required, the sidewalk would be 

relocated to the curb lane and a barrier would be erected to separate motor vehicle traffic from 

pedestrian traffic. In areas where access to bordering lots is not needed—along segments of the 

streets and avenues bordering the Project Site—the sidewalk and/or curb lane may be closed. In 

such instances, pedestrians would be routed to the opposite side of the street at the nearest 

crosswalk. Sidewalk modification may include the construction of a protective shed over segments 

of sidewalk bordering construction sites. The width of any relocated or modified sidewalks would 

be at least five feet. Maintenance and Protection of Traffic (MPT) plans would be developed and 

submitted to NYCDOT. Such plan would provide diagrams of proposed temporary lane and 

sidewalk alterations, including the duration, and the width and length of affected segments. 

Provisions of the plans may include requirements for the stationing of flagmen, and may limit the 

hours of the day and/or days of the week when changes can be implemented. After NYCDOT has 

approved the MPT plans, the Overbuild Developer contractors would be responsible for 

maintaining the provisions of the plans. With such measures in place, the construction of the 

Overbuild would not result in adverse effects to the elderly or persons with disabilities as an indirect 

result of the Preferred Alternative. 

N.5 CUMULATIVE IMPACTS OF THE PREFERRED 

ALTERNATIVE 

No additional information related to FRA’s analysis of the cumulative effects of the Preferred 

Alternative is contained in this appendix. All of the analysis of cumulative effects of the Preferred 

Alternative and the corresponding analysis results and conclusions is presented in Chapter 20, 

“Indirect and Cumulative Impacts.” 