20-1 June 2021

Chapter 20: Indirect, Cumulative, and Other Impacts

20.1 INTRODUCTION

This chapter presents the analysis the FRA conducted of the potential indirect effects and 

cumulative impacts of the Preferred Alternative. Indirect effects are commonly referred to as 

“induced growth” effects and are those that are “caused by an action and are later in time or farther 

removed in distance, but are still reasonably foreseeable” (40 CFR § 1508.8). For the Preferred 

Alternative, this includes the construction and operation of an as-of-right mixed-use development 

above the Platform and Tunnel Encasement (Overbuild). The 2009 SEQRA/CEQR FEIS 

comprehensively analyzed the Overbuild, which New York City subsequently approved. In this 

chapter, FRA summarizes and describes the program as set forth in the 2009 approvals and the 

environmental findings from the 2009 SEQR/CEQR FEIS. Similarly, this chapter looked at the 

findings of the 2013 FRA EA/FONSI and the 2014 SEA/FONSI for the Concrete Casing in the 

Hudson Yards to determine indirect and cumulative effects associated with the Tunnel 

Encasement component of the Preferred Alternative. 

Cumulative impacts result from the incremental consequences of an action when added to other 

past and reasonably foreseeable future actions (40 CFR § 1508.7). The direct effects of an 

individual action may be negligible, but may contribute to a measurable environmental impact 

when considered cumulatively with other past and/or future projects. This chapter will identify and 

evaluate the potential for the Preferred Alternative to add to cumulative impacts on resources. 

Following the methodologies set forth in Chapter 18, “Indirect Effects and Cumulative Impacts,” in 

Appendix B, “Methodology Report,” FRA has analyzed the indirect effect and cumulative impacts 

of the Preferred Alternative for both construction and operation.

Section 20.3 provides a summary of the reasoning FRA used for the determination of identifying 

adverse or beneficial indirect impacts of the Preferred Alternative. Appendix N provides the 

documentation to support to the analyses of indirect impacts conducted resulting in the findings of 

this chapter. Section 20.4 provides a summary of the reasoning FRA used for the determination 

of identifying adverse or beneficial cumulative impacts of the Preferred Alternative.

An adverse impact can be defined as a negative impact on the resource category being analyzed. 

If measures to mitigate or reduce an impact have been committed to in the 2009 SEQRA/CEQR 

FEIS, 2013 FRA EA/FONSI and/or 2014 SEA/FONSI, they are noted in this chapter. A beneficial 

impact can be defined as a positive impact on the resource category being analyzed; these are 

also noted in the chapter. 

In accordance with NEPA and the CEQ implementing regulations, this chapter of the EIS also 

includes FRA’s analysis and description of any irreversible or irretrievable commitment of 

resources that would occur if the Preferred Alternative were to be constructed, and of the 

relationship between short-term uses of the environment and the maintenance and enhancement 

of long-term productivity. 
June 2021 20-2 

20.2 AFFECTED ENVIRONMENT

As discussed in Chapter 4, “Analysis Framework,” there are numerous planned and ongoing 

development and transportation projects in the Study Area. 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.

20.2.1 OVERBUILD CONSTRUCTION METHODS AND ACTIVITIES1

1 All information provided in this section is based on conceptual construction information 

developed by the Project Sponsor and incorporating the findings and commitments in the 2009 

SEQRA/CEQR FEIS. 

20.2.1.1 CONSTRUCTION SEQUENCING

With the Platform in place, some additional foundation forms would be installed and reinforced 

with steel, and concrete poured. Structural steel and concrete would then be erected forming the 

skeletal framework for the floors and walls. As the structural skeleton of each building rises, the 

tower crane and material/personnel hoists would be erected, with additional support sections

installed for the crane and hoists. The tower crane would be used to lift the structural steel and 

other heavy building elements to the top of each rising building, while hoists are used to deliver 

workers, tools and supplies, and other lighter building elements. 

As each building advances upwards, there would be simultaneous construction work several 

levels below consisting of the installation of mechanical, electrical, and plumbing systems. 

Furthermore, several levels below those systems, each building exterior would be attached to the 

skeleton. Once the exterior walls are installed and each building is watertight, the interior finishes 

are installed, including interior walls, plumbing and electrical fixtures, flooring, woodwork, and

painting. 

Construction activities for the Overbuild would typically occur between 7 AM and 3:30 PM, five 

days a week on weekdays. However, in order to complete certain critical tasks (e.g., finishing a 

concrete pour), the workday may occasionally be extended beyond normal work hours with added 

night shifts. Any such work that falls outside the construction timeframes allowed under the 

NYCNCC would require permits from the NYCDOB. Overbuild work would occur over 

approximately six years, with the construction of Site 1 and Site 2 (on the northernmost portion of 

the Project Site) expected to overlap with the construction activities for the Preferred Alternative. 

The anticipated completion date for each of the Overbuild is as follows: 

• Site 1: 2025

• Site 2: 2027

• Site 3: 2028 

• Site 4: 2026

• Site 5: 2029

• Site 6: 2027
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20-3 June 2021

During construction, approximately 150 to 700 workers would be on site at a time for each of the 

Overbuild buildings, depending on the activities occurring. In addition, there would be up to 

approximately 20 to 90 trucks distributed over the workdays. The number of workers and truck 

trips would typically be in the lower range during the beginning stages of construction for any given 

building and would steadily increase as construction progresses. 

20.3 INDIRECT IMPACTS OF THE PREFERRED 

ALTERNATIVE 

Indirect effects may occur if a project changes the extent, pace, and/or location of development 

and if this change in turn affects environmental resources. In order to identify the indirect effects 

of the Preferred Alternative, FRA first reviewed the past environmental review documents relevant 

to the Project Site, including the 2009 SEQRA/CEQR FEIS, the 2013 FRA EA/FONSI, and the 

2014 SEA/FONSI to see if the previous analysis was still applicable. This included review of the 

methodologies for each resource category discussed in this EIS, details related to previously 

analyzed program of the Overbuild, as well as the reported baseline conditions in the previous 

environmental review documents. If the previous environmental review documents were found to 

use outdated methodologies, cite considerably different baseline conditions, or considered 

different assumptions regarding the construction or operation of the Overbuild, FRA prepared 

updated impact evaluations for those resource categories, which include the following:

• Land Use, Land Planning, and Property

• Air Quality, Greenhouse Gas Emissions, and Resilience (Stationary)

• Utilities and Energy

• Socioeconomics

For all other resource categories, FRA re-evaluated the impact analyses and associated 

commitments from previous environmental review documents to still be applicable; therefore, 

updated impact evaluations were not prepared for the following resource categories:

• Transportation 

• Air Quality, Greenhouse Gas Emissions, and Resilience (Mobile)

• Noise and Vibration

• Cultural Resources

• Parks and Recreation

• Aesthetics and Visual Contaminated Materials

• Soils and Geology

• Water and Natural Resources

• Coastal Zone Consistency

• Public Health

• Environmental Justice
June 2021 20-4 

20.3.1 INDIRECT OPERATIONAL IMPACTS OF THE PREFERRED 

ALTERNATIVE 

The following section describes the indirect operational impacts of the Preferred Alternative for the 

resource categories discussed in this EIS. 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. 

20.3.1.1 LAND USE, LAND PLANNING, AND PROPERTY

The indirect effects of the Preferred Alternative would be consistent with land planning, zoning, 

and local and regional plans and policies. Similarly, the Preferred Alternative would have no 

adverse impact to property ownership. Although most of the land use, land planning, and property 

analysis from the 2009 SEQRA/CEQR FEIS is still applicable to the current proposed Overbuild 

program, additional analysis was warranted as a number of plans and policies that have been 

published since the 2009 SEQRA/CEQR FEIS needed to be analyzed. FRA considered these 

newer plans and policies in this section. Appendix N, Section N.3.1.1, contains details of the 

analysis.

20.3.1.1.1 Land Planning and Zoning 

The indirect impacts of the Preferred Alternative would result in a mixed-use Overbuild at the 

Project Site, including multiple multistory structures similar to the development on the Eastern Rail 

Yard. The Overbuild would be comprised of four residential buildings. Two residential buildings 

would be about 60 stories tall; one residential building would be 80 stories tall, and one residential 

building would be about 30 stories tall. The Overbuild would also include an office building that 

would be about 60 stories tall. The Overbuild includes a 30-story hotel, an approximately 40-story 

mixed-use building, a public school, and public open space, which would also be built on the 

Project Site. The Overbuild would have a beneficial effect on the Project Site as it would introduce

multiple mixed-use towers and open space on an otherwise vacant site. The development would 

also be consistent with the previous rezoning that was approved as part of the 2005 Hudson Yards 

rezoning and 2009 SEQR/CEQR FEIS. Therefore, the indirect effect of the Preferred Alternative 

would be consistent with the Hudson Yards Special District and would be consistent with 

surrounding land uses. 

20.3.1.1.2 Local and Regional Plans and Policies 

FRA reviewed the indirect effects of the Preferred Alternative against the applicable local and 

regional plans and policies. The analysis indicated the indirect effects of the Preferred Alternative 

would be consistent or not applicable with all local and regional plans and policies. The local and 

regional plans and policies reviewed include New York City Waterfront Revitalization Program, 

OneNYC, Vision 2020, Master Plan Caemmerer West Side Yard, Northeast Corridor Infrastructure 

Master Plan, Amtrak’s Northeast Corridor Gateway Program, NYMTC’s Regional Transportation 

Plan 2045, and FRA’S NEC FUTURE. Appendix N, Section N.3.1.1, provides a discussion of the 

consistency of the Preferred Alternative’s indirect effects with relevant local and regional plans 

and policies. 

20.3.1.1.3 Property 

The indirect impacts of the Preferred Alternative would not require any property acquisition or 

displacements. Therefore, the indirect impacts of the Preferred Alternative would not result in any 

adverse impacts to property ownership. 
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20.3.1.2 TRANSPORTATION 

This section of the EIS summarizes the indirect impacts of the Preferred Alternative on

transportation. The information is primarily based on the 2009 SEQRA/CEQR FEIS transportation 

impact assessment as the program and transportation demand would remain within the framework 

of the approved project. The transportation commitments identified in the 2009 SEQRA/CEQR 

FEIS related to the indirect operational effects of the Preferred Alternative are summarized in the 

following sections.

20.3.1.2.1 Traffic

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

in the Study Area. Total vehicle trips generated by each development scenario analyzed for the 

Overbuild in the 2009 SEQRA/CEQR FEIS remain applicable. As described in the 2009 

SEQRA/CEQR FEIS, the City is carrying out an ongoing traffic monitoring program throughout the 

Hudson Yards area, as a result of the substantial new development taking place in that area since 

2009. As part of that monitoring program, the City will determine when it is appropriate to 

implement measures to alleviate traffic congestion at study area intersections. Additionally, as with 

any construction of a large-scale infrastructure project, implementation of an MPT plan is required. 

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

adverse traffic impacts identified. 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. Overall, these area-wide 

and project-specific commitments include the following: 

• 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.

Additional details concerning the analysis of this resource category is provided in Appendix N, 

Section N.3.1.2. 

20.3.1.2.2 Parking

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

indicate that the indirect effects of the Preferred Alternative, from the Overbuild, would further 

exacerbate the weekday midday off-street parking shortfall in the parking Study Area, but not 

substantially. As parking shortfalls do not constitute adverse impacts under the CEQR Technical 

Manual, no mitigation was required in 2009 SEQRA/CEQR FEIS which is still applicable. As a 

result, the Preferred Alternative would not result in any adverse indirect parking effects requiring 

mitigation. Additional details concerning the analysis of this resource category is provided in

Appendix N, Section N.3.1.2. 
June 2021 20-6 

20.3.1.2.3 Traffic Safety

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

function of the Overbuild. The 2009 SEQRA/CEQR FEIS committed to a range of pedestrian 

circulation improvements including 15 new bulb outs and 17 crosswalk widenings. NYCDOT has 

also implemented improvements in the Study Area. The remaining commitments made in the 2009 

SEQRA/CEQR FEIS would still apply. 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 from the Preferred Alternative on traffic safety.

Additional details concerning the analysis of this resource category is provided in Appendix N, 

Section N.3.1.2. 

20.3.1.2.4 Transit 

The 2009 SEQRA/CEQR FEIS analysis indicated that there could be additional demand of peak 

hour subway trips from the Overbuild, an indirect effect of the Preferred Alternative. Because 

mitigation measures identified in the 2009 SEQRA/CEQR FEIS have already been constructed or 

implemented, in combination with additional transit-related improvements that have been 

completed, no additional indirect effects from the Preferred Alternative on subway station elements 

in the Study Area are anticipated. Additional details concerning the analysis of this resource 

category is provided in Appendix N, Section N.3.1.2. 

20.3.1.2.5 Bus Routes

The impacts resulting from the Overbuild would constitute indirect effects of the Preferred 

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

FEIS noted the incremental demand from the Overbuild was estimated to result in adverse impacts 

on certain bus service routes and identified the additional buses that would be necessary to 

mitigate the change. NYCT has made system improvements based on the growth of transportation 

demand generated by the overall growth of Hudson Yards district (including projected growth from 

the Western Rail Yard Overbuild). These improvements have resulted in more bus service but 

have not yet reached the specific optimal headway conditions set forth in the 2009 SEQRA/CEQR 

FEIS. Section N.3.1.2 of Appendix N provides additional details of how FRA made this 

determination. 

The 2009 SEQRA/CEQR FEIS noted that the Preferred Alternative’s incremental indirect demand 

from the Overbuild was estimated to result in adverse impacts on the M10/M20, M11, and M34 

bus service, and the FEIS identified the additional buses that would be needed to mitigate the 

change (although the 2009 SEQRA/CEQR FEIS also notes that NYCT general policy is to provide 

additional bus service where demand warrants taking into consideration financial and operational 

constraints). The commitments made in the 2009 SEQRA/CEQR FEIS that relate to pedestrians

would still apply, and include the following:

• M10/M20 – Two additional regular or articulated buses would be needed to meet the projected 

demand during both peak hours.

• M11 – Three additional regular buses or two articulated buses would be needed to meet the 

projected demand during the AM peak hour. Four additional regular buses or three articulated 

buses would be needed during the PM peak hour.

• M34 – Thirteen additional regular buses or 10 articulated buses would be needed to meet the 

projected demand during the AM peak hour. A total of 15 additional regular buses or 11 

articulated buses would be needed during the PM peak hour.
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20-7 June 2021

New York City and MTA implemented the 34th Street SBS in late 2011, and was in part, 

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.

20.3.1.2.6 Pedestrians 

The Overbuild would constitute indirect effects of the Preferred Alternative, including a substantial 

increase in pedestrian activities on Study Area sidewalks and crosswalks. Mitigation requirements 

established in the 2009 SEQRA/CEQR FEIS and carried into the findings and conditions for the 

approved project remain applicable for the 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. The commitments made in the 2009 SEQRA/CEQR FEIS that 

relate to pedestrians would still apply, and include the following:

• Relocate planters or street vendors at two sidewalk locations on West 33rd Street;

• Create corner bulb outs on the avenue side of five intersections: the southwest corner at the 

Eight Avenue and West 33rd Street intersection, the southeast and southwest corners at the 

Ninth Avenue and West 33rd Street intersection, and at all four corners of the Ninth Avenue 

and West 31st Street intersection, Tenth Avenue and West 33rd Street intersection, and 

Eleventh Avenue and West 33rd Street intersection; and widen the crosswalks at 17 impacted 

crosswalk locations (primarily at intersections along West 31st and West 33rd Streets). 

Section N.3.1.2 of Appendix N provides additional details of this analysis. 

20.3.1.3 AIR QUALITY, GREENHOUSE GAS EMISSIONS, AND 

RESILIENCE 

This section of the EIS summarizes the air quality, greenhouse gas emissions and resiliency

consequences as anticipated indirect effects of the Preferred Alternative. FRA has summarized 

the anticipated indirect effects of the Preferred Alternative primarily based on the completed 2009 

SEQRA/CEQR FEIS air quality analysis for the Overbuild, where applicable. The RD resulting 

from the 2009 SEQRA/CEQR FEIS is still applicable, and details the following commitments by 

the Overbuild Developer relating to air quality, greenhouse gas emissions, and resiliency: 

• Operational Air Emissions Controls, including approval from NYCDCP prior to a New Building 

Permit;

• Energy Efficiency Measures with respect to fuel consumption and energy use; and

• Buildings designed to achieve Leadership in Energy and Environmental Design (LEED) Silver 

Certification. 

20.3.1.3.1 Mobile Source Analysis

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

the Overbuild, which represent the anticipated indirect effects of the Preferred Alternative. The 

increases in vehicular traffic associated with 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 20-8 

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 NYCDEP de minimis criteria for CO, and 

thus would not have an adverse air quality impact. More details concerning the analysis of this 

resource category are provided in Appendix N (see Section N.3.1.3).

20.3.1.3.2 Stationary Source Analysis

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

Overbuild as analyzed on the 2009 SEQRA/CEQR FEIS air quality analysis as an indirect effect 

of the Preferred Alternative. The indirect effect 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-onproject impacts) or on receptors at existing and future developments. Therefore, the proposed 

HVAC systems would not result in an adverse air quality impact. 

FRA conducted an analysis to determine the potential air quality impacts associated with the 

ventilation of dual-mode locomotive engine exhaust at the receptors proposed as part of the 

Overbuild. Based on the analysis results, indirect effects of the Preferred Alternative would not 

result in any adverse air quality impacts. Section N.3.1.3 of Appendix N provides additional details 

of how FRA came to this conclusion.

20.3.1.3.3 Greenhouse Gas Emissions and Resilience 

FRA considered the indirect effects of the Preferred Alternative on GHG emissions associated 

with the Overbuild as part of the 2009 SEQRA/CEQR FEIS air quality analysis. The site selection, 

the dense and mixed-use design, the sustainability commitments to achieve significant reductions 

in energy use for all buildings, and other measures incorporated in the Overbuild, would result in 

lower GHG emissions than would otherwise be achieved by similar residential and commercial 

uses, and, thus, would advance New York City’s GHG reduction goals. 

As discussed in Chapter 7, “Air Quality, Greenhouse Gas Emissions, and Resilience,” the Project 

Sponsor would construct the Platform at DBE of approximately +33 feet NAVD88 and would 

remain above the 1 percent annual chance BFE over the entire lifespan of the Preferred Alternative 

under all sea level rise projections. Therefore, additional protection for the Preferred Alternative 

resulting from the indirect effect of the Overbuild is not anticipated to be needed. 

20.3.1.4 NOISE AND VIBRATION

The Preferred Alternative would not result in an indirect impact to noise. FRA considered the 

additional vehicular traffic and associated potential for noise level increases in the Study Area 

from the Overbuild to be an indirect effect of the Preferred Alternative. The analysis in the 2009 

SEQRA/CEQR FEIS found that resulting noise level increases would be imperceptible to barely 

noticeable and would not be considered adverse according to CEQR Technical Manual noise 

impact criteria. This finding is still applicable as 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.

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. Section N.3.1.4 of Appendix N provides 

additional details of this analysis. 
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20-9 June 2021

The 2009 SEQRA/CEQR FEIS found that the cumulative noise exposure at the buildings included 

in the Overbuild would necessitate appropriate window/wall attenuation on all proposed building 

façades within the Overbuild to ensure acceptable interior noise levels according to CEQR 

Technical Manual noise exposure guidelines. The minimum window/wall attenuation requirements 

were included in the RD for the Overbuild. By adhering to these minimum attenuation 

requirements, the Overbuild Developer would ensure acceptable interior noise levels at each 

building; therefore, there would be no indirect adverse noise impacts of the Preferred Alternative. 

20.3.1.5 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 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 potential indirect effects of the Preferred Alternative resulting from the Overbuild are 

physical effects to the High Line related to operation of the Overbuild which includes connecting 

this portion of the High Line to other new open spaces and the renovation of the Interim Walkway 

portion of the High Line.

The Overbuild would 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. 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 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 NYCLPC, as well as development of an 

overarching CEPP, which would include a CPP as a component (see Chapter 22, “Mitigation 

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

Overbuild. These conditions would ensure that the effects to the High Line that are an indirect 

effect of the Preferred Alternative are not adverse. More details concerning the analysis of this 

resource category are provided in Appendix N in Section N.3.1.5. 

20.3.1.6 PARKS AND RECREATION

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 due to the 

anticipated decreases in the active and total open space ratios, which is a criterion under the 

CEQR Technical Manual. However, changes in open space ratios are not an impact threshold in 

this NEPA analysis.

Under NEPA, there is a beneficial indirect effect resulting from the Preferred Alternative. 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. As 

detailed above, a CEPP would be developed and implemented to protect the High Line open 

space during construction of the Overbuild. More details concerning the analysis of this resource 

category are provided in Appendix N, Section N.3.1.6. 
June 2021 20-10

20.3.1.7 AESTHETICS AND VISUAL QUALITY

The Preferred Alternative would not have an indirect adverse impact on urban design and visual 

resources (i.e., aesthetics and visual quality), but would result in beneficial effects. The beneficial 

effects of the Preferred Alternative from the Overbuild include enlivening the Project Site and 

surrounding area and improving the streetscape with active ground-floor retail and school uses, 

anticipated widened sidewalks, a public open space, and a street-tree program, which were 

disclosed and acknowledged as part of the 2009 SEQRA/CEQR FEIS. The current plans for the 

Overbuild are 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 and continue to be a reasonable assessment of 

the potential indirect effect of the Preferred Alternative. More details concerning the analysis of 

this resource category are provided in Appendix N, Section N.2.1.7. 

20.3.1.8 CONTAMINATED MATERIALS 

The anticipated indirect contaminated materials effects of the Preferred Alternative are primarily 

based on the 2009 SEQRA/CEQR FEIS analyses. The indirect effects of the Preferred Alternative 

from operation of the Overbuild are not expected to result in additional ground disturbance at the 

Project Site; therefore, no additional contaminated materials impacts are anticipated. The indirect 

effects of the Preferred Alternative from the potential disturbance of contaminated materials from 

the Overbuild would occur during construction, which would involve only minimal additional ground 

disturbance at the Project Site. Furthermore, with the implementation of remediation and

protective measures during construction similar to those listed in Chapter 12, “Contaminated 

Materials,” no additional indirect adverse contaminated materials impacts of the Preferred 

Alternative are anticipated from the Overbuild.

20.3.1.9 UTILITIES AND ENERGY

The Overbuild, an indirect consequence of the Preferred Alternative, would result in increased 

demands on New York City’s water supply and sanitary sewage treatment systems, which are 

beyond the negligible additional demand generated by the operation of the Preferred Alternative 

alone. Consequently, FRA performed an assessment comparing the indirect projected demand 

on utility services of the Preferred Alternative from the current proposal for the Overbuild, against 

the Overbuild analyzed in the 2009 SEQRA/CEQR FEIS, to identify whether the current proposed 

development would result in additional demand that would have the potential to result in indirect 

adverse impacts. The assessment used the methodology and demand rates of the 2014 CEQR 

Technical Manual whereas the 2009 SEQRA/CEQR FEIS used methodology and demand rates 

from a previous edition of the CEQR Technical Manual. Because the Overbuild program and 

associated assumptions have changed slightly; an updated evaluation was required for utilities 

and energy. The 2009 SEQRA/CEQR FEIS committed the Overbuild Developer to develop a 

SWPPP for post-construction stormwater management and prepare a NYCDEP-approved 

Drainage Plan to address stormwater management. As discussed in Chapter 13, “Utilities and 

Energy,” the ADP has been completed. Additionally, the 2009 SEQRA/CEQR FEIS committed the 

Overbuild buildings be designed to achieve LEED Silver Certification. With these measures from 

the 2009 SEQRA/CEQR FEIS in place, the additional indirect operational demand for utility 

infrastructure and services of the Preferred Alternative from the Overbuild would be negligible and 

would not result in adverse impacts to these systems. The analysis to support this conclusion is 

included in Appendix N, Section N.3.1.8. 
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20-11 June 2021

20.3.1.9.1 Water Supply

The Preferred Alternative would not result in indirect, adverse impacts on the City’s water supply 

system. The estimated indirect water demand of the Preferred Alternative resulting from the 

current Overbuild program 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, this additional indirect Overbuild demand represents a minor increase in demand 

(0.15 percent) on the City’s daily water supply of approximately one billion gpd. Following the 

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

supply infrastructure in the area of the Project Site. In consideration of the recent system 

improvements the analysis indicates that NYCDEP can adequately provide for the increased 

demand required by the Overbuild. Therefore, the indirect effect of the Preferred Alternative would 

not result in adverse impacts on the City’s water supply system. More details concerning the 

analysis of this resource category are provided in Appendix N, Section N.3.1.8. 

20.3.1.9.2 Wastewater

The Preferred Alternative would not result in an indirect adverse impact to the City’s sanitary 

sewage conveyance and treatment system. The additional indirect sanitary sewage generation of 

the current 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. 

Additionally, 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 development resulting from the full build-out of the Hudson Yards 

rezoning; with the system improvements, the analysis indicates that NYCDEP can adequately 

provide for the increased demand resulting from the Overbuild. More details concerning the 

analysis of this resource category are provided in Appendix N, Section N.3.1.8. 

20.3.1.9.3 Stormwater 

The Preferred Alternative would not result in an indirect adverse impact to the City’s stormwater 

management infrastructure. Modeling of the incremental flows from the Overbuild was completed 

for the 2009 SEQRA/CEQR FEIS and 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. More details concerning the analysis of this resource category are 

provided in Appendix N, Section N.3.1.8. 

20.3.1.9.4 Solid Waste and Sanitation Services

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

services. The incremental solid waste generated by the Overbuild, an indirect consequence of the 

Preferred Alternative, would not overburden the City’s solid waste handling systems. The solid 

waste generation was calculated based on the current assumptions of the Overbuild program; 

DSNY and private haulers would be able to accommodate this incremental increase in demand 

for solid waste collection. More details concerning the analysis of this resource category are 

provided in Appendix N, Section N.3.1.8. 

20.3.1.9.5 Energy 

The Preferred Alternative would not have an indirect adverse impact on energy. FRA estimated 

total energy consumption of the current Overbuild program and the incremental increase would 

be considered a negligible change on Con Edison’s service. Additionally, the Overbuild would be 

consistent New York’s local energy laws and regulate energy consumption. More details 

concerning the analysis of this resource category are provided in Appendix N, Section N.3.1.8. 
June 2021 20-12

20.3.1.10 SOILS AND GEOLOGY

The indirect effects of the Preferred Alternative are primarily based on the analysis presented in 

Chapter 14, “Soils and Geology,” which found the Preferred Alternative would have no adverse 

effects on this resource category. Furthermore, the indirect effect of the Preferred Alternative, the

Overbuild would result in minimal additional disturbance to soils at the Project Site and would not 

alter the geological character or integrity of the Project Site. Therefore, the indirect effect of the 

Preferred Alternative would not result in an adverse impact on soils and geology. 

20.3.1.11 WATER AND NATURAL RESOURCES

The indirect effects of the Preferred Alternative are primarily based on the 2009 SEQRA/CEQR 

FEIS analyses of the Overbuild. The following section summarizes these impacts.

20.3.1.11.1 Floodplains 

The indirect effects of the Preferred Alternative would not adversely affect flooding of areas 

adjacent to the Project Site. As discussed in Chapter 15, “Water and Natural Resource,” and 

Chapter 11, “Natural Resources,” of the 2009 SEQRA/CEQR FEIS most of the Project Site is 

located within the 100-year floodplain. Commitments established in the 2009 SEQRA/CEQR FEIS

and carried into the findings and conditions for the approved project remain applicable. A majority 

of the Overbuild would be constructed above the 100-year floodplain on the Platform and the 

remaining Overbuild components would be developed with the elevation of the lowest floor set 

forth in the RD for the Overbuild site. Therefore, the indirect effect of the Preferred Alternative

would not have an adverse impact on floodplains to the one percent or 0.2 percent annual chance 

floodplains. 

20.3.1.11.2 Wetlands 

The indirect effects of the Preferred Alternative would not result in adverse impacts on designated 

NYSDEC littoral zone tidal wetlands in the Hudson River. The 2009 SEQRA/CEQR FEIS

committed the Overbuild Developer to develop a SWPPP for post-construction stormwater 

management and would decrease the rate and quantity and improve the quality of stormwater 

discharged from the Project and conveyed to the Hudson River. Commitments established in the 

2009 SEQRA/CEQR FEIS and carried into the findings and conditions for the approved project 

remain applicable. Therefore, the indirect effect of the Preferred Alternative would not result in an 

adverse impact on wetlands. 

20.3.1.11.3 Groundwater 

The indirect effects of the Preferred Alternative would not result in adverse impacts on

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

approvals indicated no adverse impacts on groundwater and would remain within the framework 

of the already approved project. Groundwater is not used as potable water in Manhattan and the 

indirect effects of the Preferred Alternative would not affect drinking water supplies. Therefore, the 

indirect effect of the Preferred Alternative would not result in an adverse impact on groundwater. 
Chapter 20: Indirect, Cumulative, and Other Impacts

20-13 June 2021

20.3.1.11.4 Terrestrial Resources 

The indirect effects of the Preferred Alternative would not result in an adverse impact to terrestrial 

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

approvals indicated no adverse impacts on terrestrial resources and would remain applicable. The 

loss of the existing vegetation and wildlife at the Project Site are primarily composed of common 

species tolerant of urban ecosystems. This includes native species such as the Eastern gray 

squirrel and non-native species European starling. The loss of existing vegetation and wildlife 

would not result in a significant adverse impact on terrestrial resources to the region. The 

Overbuild would result in the creation of 5.45 acres of open space with a variety of plantings 

anticipated to result in habitat enhancement of the Project Site. Therefore, the indirect effect of 

the Preferred Alternative would not result in an adverse impact on terrestrial resources. 

20.3.1.11.5 Threatened and Endangered Species 

The indirect effects of the Preferred Alternative would not result in an adverse impact to threaten 

and endangered species. The adopted findings by the City as part of the 2009 SEQRA/CEQR 

FEIS project approvals indicated no adverse impacts on threatened and endangered species and 

would remain applicable. As discussed in Chapter 15, the USFWS IPaC system (2020) did not 

identify any federally listed species with the potential to occur within the Study Area. Species 

identified were limited to aquatic species that are likely transient and water quality is not anticipated 

to be impacted by the Overbuild. Based on the analysis, the indirect effect of the Preferred 

Alternative would have no effect on federally listed species or critical habitat.

20.3.1.11.6 Aquatic Resources 

The indirect effects of the Preferred Alternative would not result in an adverse impact to aquatic 

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

approvals indicated the additional discharge of sanitary sewage would not exceed the North River 

WWTP’s permitted capacity. This conclusion is still applicable. As stated in Section 20.3.1.9.2, the 

additional sanitary sewage generation anticipated from the updated Overbuild program would still 

not exceed the North River WWTP’s permitted capacity and is not anticipated to impact water 

quality and the discharge of stormwater from the Project Site. The discharge of sanitary sewage 

resulting from the Overbuild would be handled by the City’s infrastructure. Therefore, the indirect 

effect of the Preferred Alternative would not result in adverse impacts to aquatic resources. 

20.3.1.12 COASTAL ZONE CONSISTENCY

The indirect effects of the Preferred Alternative would be consistent with the LWRP by supporting 

policies related to encouraging commercial and residential development in appropriate coastal 

zones; reducing damage from flooding and other water-related disasters; protecting water quality, 

sensitive habitats, and the aquatic ecosystem; and promoting development with appropriate land 

uses. The indirect effects of the Preferred Alternative are primarily based on the 2009 

SEQRA/CEQR FEIS analyses of the Overbuild and remain applicable as the concept of the 

Overbuild has not changed. The Overbuild would still be a mixed-use development located on the 

Project Site, near the Hudson River.
June 2021 20-14

20.3.1.13 SOCIOECONOMICS 

The previously approved Overbuild will 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. The Overbuild Developer is currently proposing 890 condominium 

units and 1,900 rental units, including 324 permanent affordable housing units. This section of the 

EIS summarizes the anticipated indirect effects of the Overbuild based on the 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 approved project., In 

addition to reviewing the 2009 SEQRA/CEQR FEIS, 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 updated socioeconomic analyses of 

the indirect effects of the Preferred Alternative form the Overbuild performed for this EIS 

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

updated methodologies of the CEQR Technical Manual. The Study Area for the socioeconomic 

analysis is the shown in Figure 17-1. Full socioeconomic and community facility assessments are 

presented in Appendix N, Section N.3.1.9. 

20.3.1.13.1 Indirect Residential Displacement 

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 indirect residential displacement assessment presented in Appendix N considers 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. 

The assessment finds that the indirect effects of the Preferred Alternative, the Overbuild, would 

not result in adverse impacts due to indirect residential displacement. A substantial amount of 

market rate housing has recently been built and planned within the Study Area. Irrespective of the 

Preferred Alternative and Overbuild, the area is expected to maintain its long-term trends toward 

increasing residential population, household incomes, residential property values, and rents. 

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 Overbuild 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 the Preferred 

Alternative and 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. 
Chapter 20: Indirect, Cumulative, and Other Impacts

20-15 June 2021

20.3.1.13.2 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. The indirect effect of the Preferred 

Alternative, the Overbuild, would introduce 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. 

Independent of the Overbuild, the Study Area has a significant number of planned projects that 

will add the same mix of uses as the Overbuild. Given the trend toward the development of mixeduse 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 will continue irrespective of the Overbuild. Overall, the Preferred Alternative would not result 

in an adverse indirect impact due to indirect business displacement within the Study Area, and 

would not adversely affect any specific industries. 

20.3.1.14 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 of the Preferred Alternative 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.

Based on CEQR Technical Manual screening criteria, detailed analyses of potential indirect 

impacts on public schools (elementary and intermediate schools), public libraries, and publicly 

funded child care centers were conducted. The full analyses are presented in Appendix N. 

Appendix N also identifies Study Area health care facilities, and fire and police protection 

services. These analyses find that the new population that would indirectly result from the 

Preferred Alternative would not adversely affect public schools, public libraries, police, fire, EMS, 

or health care facility services in the Study Area. The projected increase in demand for publicly 

funded child care services associated with the Overbuild could adversely affect services, but would 

be mitigated through the RD that would require the Overbuild Developer provide additional 

capacity, or provide program or physical improvements to existing facilities. With this measure in 

place, the Preferred Alternative would not result in an indirect adverse impact to child care

services.

20.3.1.15 PUBLIC HEALTH

The indirect effects of the Preferred Alternative are not anticipated to result in any adverse effects 

to air quality, noise, contaminated materials, or water quality, and as a result would not result in 

any indirect adverse public health impacts. This conclusion is based on the 2009 SEQRA/CEQR 

FEIS and the analysis completed for this EIS. The 2009 SEQRA/CEQR FEIS findings are still 

applicable as the current Overbuild still fits within the framework of the already approved project.

As discussed in Section 20.3.1.3.2, additional stationary source analysis was completed and 

determined the indirect effects of the Preferred Alternative would not result in any adverse air 

quality impacts; therefore, the indirect effect of the Preferred Alternative would not result in 

adverse public health impacts. Implementation of commitments described above for noise, air 

quality, and contaminated materials would mitigate, either in part or in whole, the adverse impacts 

identified. 
June 2021 20-16

20.3.1.16 ENVIRONMENTAL JUSTICE

The indirect effect of the Preferred Alternative would not result in disproportionately high and 

adverse effects on environmental justice populations. The 2009 SEQRA/CEQR FEIS concluded 

that the Overbuild could result in potential significant adverse impacts under CEQR and SEQRA 

impact criteria with respect to: 

• Child care, due to increased demand and limited capacity of facilities in the Study Area, which 

could be mitigated through parents choosing to use child care outside of the Study Area or 

through New York City Administration for Children’s Services’ (NYCACS) initiatives to expand 

capacity;

• Open space, due to increased residential population relative to the amount of open space 

acreage in the Study Area and shadows from the new buildings2

2 Changes in open space ratios are not considered under NEPA, they represent an impact 

threshold considered under the CEQR Technical Manual analysis guidelines; changes in open 

space ratios are not considered in this analysis for purposes of identifying impacts under NEPA. 

, which could be mitigated 

through additional open space programming in the Overbuild and partially mitigated through 

establishment of an Open Space Fund, with contributions from the Developer to be used by 

New York City for open space programs or improvements;

• Traffic, due to poor level of service (LOS) at many Study Area intersections, most of which 

(but not all) could be mitigated through modifications to traffic signals and street designs;

• Transit, due to increase in demand on bus services, which would likely be addressed as part 

of NYCT’s ongoing operations planning; and

• Pedestrians, due to increased crowding of sidewalks and crosswalks, which could be 

mitigated with improvements such as removal or relocation of obstacles (e.g., planters), bulb 

outs at affected intersections, and crosswalk widening. 

These conclusions from the 2009 SEQRA/CEQR FEIS would remain applicable as the program 

and transportation demand would remain within the framework of the approved project. The 

Preferred Alternative would also result in substantial indirect benefits to the Study Area from the 

Overbuild. The new residential, commercial, and office development would increase the economic 

activity of this area and would be consistent with local plans and development trends. Additionally, 

as described in Section 20.3.1.13, the Overbuild would be consistent with long-term trends and 

not result in adverse impacts with respect to indirect residential or business displacement. 

As shown in Figure 19-1, minority and low-income populations (collectively referred to as 

environmental justice populations) are located in the eastern portion of the Study Area. The 

adverse impacts described above would affect environmental justice populations but would also 

affect non-environmental justice populations. Additionally, environmental justice populations 

would benefit from the Preferred Alternative’s indirect increased economic activity associated with 

the Overbuild. The Overbuild also incorporates at least 324 units of affordable housing, which 

would serve low-income populations. Therefore, the indirect effect of the Preferred Alternative

would not result in disproportionately high and adverse effects on environmental justice 

populations.
Chapter 20: Indirect, Cumulative, and Other Impacts

20-17 June 2021

20.3.2 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. 

20.3.2.1 LAND USE, LAND PLANNING, AND PROPERTY

The construction of the Preferred Alternative would have no indirect effects on land use, land 

planning, and property. The 2009 SEQRA/CEQR FEIS analyses determined that construction of 

the Overbuild would not displace any land uses and the LIRR. This still remains to be the case as 

throughout construction of the Overbuild, the LIRR rail yard would be operational. All construction 

activities would be confined on the Project Site and within portions of the sidewalk and adjacent 

streets. Therefore, the indirect construction effects of the Preferred Alternative would not have an 

adverse impact on land use.

20.3.2.2 TRANSPORTATION 

There would be indirect construction effects to transportation systems of the Preferred Alternative 

related to the construction of the Overbuild. 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. The findings from 

the 2009 SEQRA/CEQR FEIS remain applicable to the 2030 completion of the Overbuild and 

reflect the indirect construction effects of the Preferred Alternative as 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. The approved 2009 SEQRA/CEQR FEIS project 

had a higher peak hour trip generation than the estimates from the Overbuild Developer for the 

2030 completion of the Overbuild. As described in the 2009 SEQRA/CEQR FEIS, the City is 

carrying out an ongoing traffic monitoring program throughout the Hudson Yards area, as a result 

of the substantial new development taking place in that area since 2009. As part of that monitoring 

program, the City will determine when it is appropriate to implement measures to alleviate traffic 

congestion at study area intersections. More details concerning the analysis of this resource 

category are provided in Appendix N (see Section N.4.1.1).

As with any construction of a large-scale infrastructure project, development and implementation 

of an MPT plan is required by NYCDOT’s OCMC. The 2009 SEQRA/CEQR FEIS and the 

associated resulting RD requires MPT plans to be developed and submitted to NYCDOT by the 

Overbuild Developer for review and approval. Such plans would provide diagrams of proposed 

temporary lane and sidewalk alterations, including the width and length of affected sidewalk and 

lane segments, and the duration of Overbuild construction affecting these locations. 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. Review of the plans and 

implementation of the best practices highlighted in the MPT would be coordinated with NYCDOT’s 

OCMC. After NYCDOT has approved the MPT plans, the Project Sponsor and its contractors 

would be responsible for maintaining the provisions of the plans. The MPT Plans to be 

implemented for the Preferred Alternative during the construction period as described in Chapter 

6, “Transportation,” would continue throughout the construction for the Overbuild, with 

modifications as necessary to reflect construction conditions at any given time. 
June 2021 20-18

20.3.2.3 AIR QUALITY, GREENHOUSE GAS EMISSIONS, AND 

RESILIENCE 

The indirect construction impacts of the Preferred Alternative would not have an adverse impact 

on air quality. Construction of Overbuild Sites 1 and 2 is anticipated to overlap with the construction 

activities for the Preferred Alternative, so additional analysis was completed to determine if the 

current construction program would have the potential to cause adverse air quality impacts not 

identified in the 2009 SEQRA/CEQR FEIS. The analysis indicated a lower maximum annual 

average emission rate than what was reported in the 2009 SEQRA/CEQR FEIS. Therefore, the 

indirect construction impacts of the Preferred Alternative would not have an adverse impact on air 

quality. More details concerning the analysis of this resource category are provided in Appendix 

N, Section N.4.1.2. Mitigation measures associated with the Overbuild ensure that construction 

would implement a state-of-the-art emissions reduction program for construction activities

resulting in the lowest practicable diesel PM emissions. 

20.3.2.4 NOISE AND VIBRATION

The indirect construction impacts of the Preferred Alternative would not result in adverse impacts 

related to noise and vibration. A review of the current construction duration, logistics, and activities 

for each of the Overbuild buildings remain similar to those analyzed in the 2009 SEQRA/CEQR 

FEIS. The analysis of the Overbuild construction included in the 2009 FEIS predicted worst-case 

noise levels at nearby receptors between 56 and 74 dB(A). At each receptor, construction was 

predicted to result in noise level increases not greater than 3 dB(A). Since the construction of the 

Overbuild would not be substantially different from what was analyzed in the 2009 FEIS, and 

baseline noise levels are comparable or greater now than those used in the 2009 FEIS analysis, 

these values are expected to be representative of those resulting from construction of the 

Overbuild as an indirect result of the Preferred Alternative. These construction noise levels and 

associated noise level increases would not exceed the FTA construction noise impact criteria nor 

the CEQR Technical Manual noise impact criteria. Consequently, the Preferred Alternative would 

not have indirect adverse noise impacts from the Overbuild construction. 

A construction vibration assessment was performed in the 2009 SEQRA/CEQR FEIS for the 

existing elevated High Line historic rail structure (other vibration-sensitive structures further away 

from the construction work areas would not have the potential to experience significant adverse 

effects from construction vibration). The analysis determined that by avoiding the use of high 

vibration-producing equipment (i.e., hoe rams and pile drivers) within critical distances of the High 

Line structure, vibration levels at the High Line would not exceed the acceptable 0.5 inches/second 

peak particle velocity threshold for a historic structure as set forth in TPPN #10/88. Mitigation 

measures and construction procedures, such a vibration limits and monitoring, are required as 

result of the 2009 SEQRA/CEQR FEIS to ensure construction of the Overbuild would not result in 

adverse impacts. The CEPP would meet the guidelines set forth in 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 NYCLPC, 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. A Noise Mitigation Plan would require compliance with the City’s Local Law 113, 

and with Chapter 28 of the NYCNCC. With these measures, the 2009 SEQRA/CEQR FEIS

concluded that there would not be an adverse impact to the High Line because of construction of 

the Overbuild. Therefore, the Preferred Alternative would not have indirect adverse construction 

impacts on the High Line from construction of the Overbuild. More details concerning the analysis 

of this resource category are provided in Appendix N, Section N.4.1.3.
Chapter 20: Indirect, Cumulative, and Other Impacts

20-19 June 2021

20.3.2.5 CULTURAL RESOURCES 

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

indicate that the construction of the Overbuild, which is an indirect consequence of the Preferred 

Alternative, would result in 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 construction effect of the Preferred Alternative on cultural resources for this EIS. 

The potential effects of the construction of the Overbuild are possible inadvertent effects to the 

High Line during construction. As a condition of the ROD FRA would require the Project Sponsor 

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

by NYSHPO and NYCLPC, as well as development of a CEPP to protect the High Line during 

construction of the Overbuild. These conditions would ensure that the effects to the High Line, 

which are an indirect construction effects of the Preferred Alternative, are not adverse. More 

details concerning the analysis of this resource category are provided in Appendix N, Section 

N.4.1.4.

20.3.2.6 PARKS AND RECREATION

The indirect construction impacts of the Preferred Alternative would not have an adverse impact 

on parks and recreation with the implementation of mitigation measures required as a result of the 

2009 SEQRA/CEQR FEIS. The CEPP would specify measures and construction procedures, such 

as noise mitigation, vibration limits and monitoring that would be implemented during construction 

of the Overbuild. As stated, 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. Nearby 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 adverse. Mitigation measures would be in place 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. More details concerning the analysis 

of this resource category are provided in Appendix N, Section N.4.1.5.

20.3.2.7 AESTHETICS AND VISUAL QUALITY

The indirect construction impacts of the Preferred Alternative would have a neutral effect on visual 

quality in the AVE. All construction staging and activities for the Overbuild would occur within the 

Project Site and within portions of the sidewalk and adjacent streets. Construction activities and 

equipment for the Overbuild would result in temporary visual obstructions; however, there are 

multiple construction projects currently underway within the AVE, and thus construction activities 

and equipment associated with the Overbuild would be difficult to distinguish from these other 

activities and would be in keeping with the ongoing trend of tower construction in the AVE. 

Therefore, the indirect construction impacts of the Preferred Alternative from Overbuild 

construction would not result in any adverse indirect impacts to aesthetics and visual quality. 
June 2021 20-20

20.3.2.8 CONTAMINATED MATERIALS

The indirect construction impacts of the Preferred Alternative would not have an adverse impact 

on contaminated materials with the implementation of appropriate health and safety precautionary 

and remedial measures. The indirect effects of the Preferred Alternative from construction of the 

Overbuild would result in only minimal additional ground disturbance at the Project Site; therefore, 

no additional impact to hazardous materials is anticipated. Further, Chapter 21, “Construction 

Impacts,” of the 2009 SEQRA/CEQR FEIS found that construction of the Overbuild, which is an 

indirect consequence of the Preferred Alternative, would not have an adverse impact on 

contaminated materials with the implementation of appropriate health and safety precautionary 

and remedial measures. The health and safety precautionary and remedial measures are outlined 

in Chapter 12 in detail and include the implementation of a site-specific RAP and CHASP in 

accordance with the RD with NYCOER approvals, as required.

20.3.2.9 UTILITIES AND ENERGY

The indirect construction impacts of the Preferred Alternative are not anticipated to impact 

provision of utility services to the Project Site, including water supply, wastewater, and stormwater 

services; solid waste and sanitation services; and energy. The 2009 SEQRA/CEQR FEIS came 

to the same conclusions which are still applicable for the current Overbuild assumptions and 

construction practices. All of the utility and energy services, including the discharge of stormwater 

from the Overbuild site would be provided by or handled by the City’s existing infrastructure 

systems. Private carters would remove construction debris from the Project Site during 

construction. 

20.3.2.10 SOILS AND GEOLOGY

The indirect construction impacts of the Preferred Alternative would have no adverse effects on 

soils and geology. This finding is primarily based on the analysis presented in Chapter 14, which 

found the construction of the Preferred Alternative would have no adverse effects on soils and 

geology. The Overbuild would result in minimal additional disturbance to soils at the Project Site 

and would not alter the geological character or integrity of the Project Site. Therefore, the Preferred 

Alternative would not result in indirect adverse impacts on soils and geology. 

20.3.2.11 WATER AND NATURAL RESOURCES 

This section of the EIS summarizes the anticipated indirect construction effects of the Preferred 

Alternative using the analysis Chapter 11, “Natural Resources,” of the 2009 SEQRA/CEQR FEIS. 

Based on the findings of the 2009 SEQRA/CEQR FEIS, construction of the Overbuild, which is an 

indirect consequence of the Preferred Alternative, is not anticipated to result in an adverse impact

to natural resources, and no additional indirect effects are anticipated. Therefore, the indirect

construction impacts of the Preferred Alternative would not result in an adverse impact on natural 

ecological resources and water quality. 
Chapter 20: Indirect, Cumulative, and Other Impacts

20-21 June 2021

20.3.2.11.1 Wetlands 

The indirect construction impacts of the Preferred Alternative would not result in adverse impacts 

on designated DEC littoral zone tidal wetlands in the Hudson River. The 2009 SEQRA/CEQR 

FEIS analysis came to the same conclusion which is still applicable as the Overbuild program and 

activities for each of the Overbuild buildings are anticipated to be similar to those analyzed in the 

2009 SEQRA/CEQR FEIS. Construction of the Overbuild would not result in in-water activities and 

construction activities would follow a NYSDEC approved SWPPP as indicated in the 2009 

SEQRA/CEQR FEIS. The 2009 SEQRA/CEQR FEIS also committed the Overbuild Developer to 

develop a dewatering plan as part of the CEPP which would require testing of groundwater 

recovered during dewatering and proper disposal in compliance with applicable NYCDEP and 

NYSDEC discharge requirements. Therefore, the indirect construction impacts of the Preferred 

Alternative would not result in an adverse impact on wetlands. 

20.3.2.11.2 Groundwater 

The indirect construction impacts of the Preferred Alternative are not anticipated have an adverse 

impact on groundwater as groundwater is not used as potable water in Manhattan and the

construction of the Overbuild would not affect drinking water supplies. The 2009 SEQRA/CEQR 

FEIS came to this conclusion which is still applicable for the current Overbuild program. Therefore, 

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

on groundwater. 

20.3.2.11.3 Terrestrial Resources 

The indirect construction impacts of the Preferred Alternative would not result in an adverse impact 

to terrestrial resources. The adopted findings by the City as part of the 2009 SEQRA/CEQR FEIS

project approvals indicated no adverse impacts on terrestrial resources and would remain 

applicable. As discussed above in Section 20.3.1.11.4, construction on the Project Site would 

result in the loss of the existing vegetation and wildlife at the Project Site primarily composed of 

common species tolerant of urban ecosystems. This includes native species such as the Eastern 

gray squirrel and non-native species European starling. The loss of existing vegetation and wildlife 

would not result in a significant adverse impact on terrestrial resources to the region. The 

Overbuild would result in the creation of 5.45 acres of open space with a variety of plantings 

anticipated to result in habitat enhancement of the Project Site. Therefore, the indirect construction 

impacts of the Preferred Alternative would not result in any adverse impacts to terrestrial 

resources. 

20.3.2.11.4 Threatened and Endangered Species 

The indirect construction impacts of the Preferred Alternative would not result in an adverse impact 

to threaten and endangered species. The adopted findings by the City as part of the 2009 

SEQRA/CEQR FEIS project approvals indicated no adverse impacts on threatened and 

endangered species and would remain applicable. As discussed in Chapter 15, the USFWS IPaC 

system (2020) did not identify any federally listed species with the potential to occur within the 

Study Area. Species identified were limited to aquatic species that are likely transient and water 

quality is not anticipated to be impacted by construction of the Overbuild. Additionally, construction 

of the Overbuild would not require in-water work. Based on the analysis, the indirect effect of the

Preferred Alternative would have no effect on federally listed species or critical habitat.
June 2021 20-22

20.3.2.11.5 Aquatic Resources 

The indirect construction effects of the Preferred Alternative would not result in an adverse impact 

to aquatic resources. The adopted findings by the City as part of the 2009 SEQRA/CEQR FEIS

project approvals would still be applicable. Construction of the Overbuild would not result in inwater activities and construction activities would follow a NYSDEC approved SWPPP as indicated 

in the 2009 SEQRA/CEQR FEIS. Therefore, the indirect construction effects of the Preferred 

Alternative would not result in adverse impacts to aquatic resources. 

20.3.2.12 COASTAL ZONE CONSISTENCY

The indirect construction effects of the Preferred Alternative would be consistent with the LWRP 

by supporting policies related to encouraging commercial and residential development in 

appropriate coastal zones; reducing damage from flooding and other water-related disasters; 

protecting water quality, sensitive habitats, and the aquatic ecosystem; and promoting 

development with appropriate land uses. The indirect construction effects of the Preferred 

Alternative are primarily based on the 2009 SEQRA/CEQR FEIS analyses of the Overbuild and 

remain applicable as the concept of the Overbuild’s construction has not changed. The Overbuild 

would still be a mixed-use development located on the Project Site, near the Hudson River. As 

discussed in previous section in this chapter, the 2009 SEQRA/CEQR FEIS resulting in a variety 

of commitments related to construction practices. During construction, the Overbuild Developer 

would implement erosion and sediment control measures listed in the SWPPP which was 

prepared in accordance with a SPDES permit. As stated above, construction of the Overbuild 

would not have an adverse impact on contaminated materials with the implementation of 

appropriate health and safety precautionary and remedial measures. With implementation of these 

commitments, the indirect construction effects of the Preferred Alternative would be consistent 

with the LWRP.

20.3.2.13 SOCIOECONOMICS 

The indirect construction effects of the Preferred Alternative would result in temporary disruptions 

in the surrounding area. However, such disruptions would not adversely affect socioeconomic 

conditions. No indirect residential displacement is anticipated. Additionally, impacts to community 

facilities and services from traffic changes due to the Overbuild would be mitigated and 

construction activities related to the Overbuild would comply with federal, state, and local 

requirements necessary to ensure a safe construction zone for workers and pedestrians including 

the elderly and persons with disabilities. Indirect beneficial construction impacts of the Preferred 

Alternative are expected on local businesses. Therefore, the indirect construction effects of the 

Preferred Alternative would not result in adverse impacts to socioeconomic resources. Details 

concerning the analysis of this resource category are provided in Appendix N, Section N.4.1.6. 
Chapter 20: Indirect, Cumulative, and Other Impacts

20-23 June 2021

20.3.2.14 PUBLIC HEALTH

The indirect construction effects of the Preferred Alternative would not result in adverse public 

health impacts. The 2009 SEQRA/CEQR FEIS indicated such findings and would still be 

applicable as 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. During 

construction, the Overbuild Developer has committed to implementing a state-of-the-art emissions 

reduction program for all construction activities to ensure that the construction of the Project Site 

would result in the lowest practicable diesel PM emissions. Although the 2009 SEQRA/CEQR 

FEIS concluded that the construction of the Overbuild could result in increased noise levels from 

construction related activities, the Reasonable Worst-Case Development Scenario (RWCDS) 

analyzed predicted noise levels to not exceed the CEQR impact criteria, and therefore did not 

result in an adverse noise impact. The 2009 SEQRA/CEQR FEIS concluded that construction of 

the Overbuild would not have an adverse impact on contaminated materials with the 

implementation of appropriate health and safety precautionary and remedial measures and 

therefore, would not have an adverse impact on hazardous materials. Therefore, the construction 

Preferred Alternative would not result in adverse indirect impacts to public health with 

implementation of the previously indicated commitments.

20.3.2.15 ENVIRONMENTAL JUSTICE

The indirect construction effects of the Preferred Alternative could result in potential adverse 

impacts with respect to: 

• Construction-related traffic, due to temporary increases in construction vehicles, which 

could be mitigated at most (but not all) intersections with measures such as signal timing 

modifications and lane channelization.

The 2009 SEQRA/CEQR FEIS indicated the same conclusion and would remain applicable to the 

2030 completion of the Overbuild and reflect the indirect construction effects of the Preferred 

Alternative as 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. 

The adverse impacts described above would affect environmental justice populations but would 

also equally affect non-environmental justice populations. Therefore, the construction of the 

Overbuild, which is an indirect effect of the Preferred Alternative, would not have a

disproportionate adverse impact on environmental justice populations. 
June 2021 20-24

20.4 CUMULATIVE IMPACTS OF THE PREFERRED 

ALTERNATIVE 

Cumulative impacts result from the incremental consequences of an action when added to other 

past, present, and reasonably foreseeable future actions. Past actions provide a baseline of 

existing conditions. In New York City, many resource areas (e.g., transportation, air quality, noise) 

have been affected by past actions with the result that the baseline for these resources represent 

conditions that would be considered diminished or deteriorated beyond what would be expected 

in less densely populated areas of the country and region. These diminished baseline conditions 

have resulted in extensive planning and regulations to help avoid exacerbating these conditions, 

and preserve baseline conditions and existing quality of life, as new development continues to 

advance in the area. One readily seen example of this phenomenon is the nearly universal traffic 

congestion that can be found in most parts of Manhattan before, during, and after work hours. As 

a result of the unique environment found in the densely developed midtown Manhattan 

environment, more stringent environmental impact analyses and impact criteria, like those found 

in the CEQR Technical Manual, have been developed and implemented to add an extra level of 

protection for resources in the urban environment. Some of the relevant guidelines and protections 

developed for the New York City urban environment are discussed briefly below.

In New York City, sensitive receptors that are anticipated to experience interior noise levels of 45 

dB(A) or greater are required to receive appropriate window/wall attenuation according to the

CEQR Technical Manual noise exposure guidelines. Developers have been required to upgrade 

windows in existing buildings as well as construct buildings with double pane windows to reduce 

interior noise levels. 

Additionally, many local governments worldwide, including New York City, are participating in the 

Cities for Climate ProtectionTM campaign, and have committed to adopting policies and 

implementing quantifiable measures to reduce local GHG emissions, improve air quality, and 

enhance urban livability and sustainability. New York City’s long-term comprehensive plan for a 

sustainable and resilient New York City, which began as PlaNYC 2030 in 2007, and continues to 

evolve today as OneNYC 2050, includes GHG emissions reduction goals, many specific initiatives 

that can result in emission reductions, and initiatives aimed at adapting to future climate change 

impacts. The goal to reduce citywide GHG emissions to 30 percent below 2005 levels by 2030 

(“30 by 30”) was codified by Local Law 22 of 2008, known as the New York City Climate Protection 

Act (the “GHG reduction goal”).3

3 Administrative Code of the City of New York, §24‐803.

The City has also announced a longer-term goal of reducing 

emissions to 80 percent below 2005 levels by 2050 (“80 by 50”), which was codified by Local Law 

66 of 2014, and has published a study evaluating the potential for achieving that goal. More 

recently, as part of OneNYC 2050, the City has announced a more aggressive goal for reducing 

emissions from building energy down to 30 percent below 2005 levels by 2025. In May 2019, the 

New York City Council enacted Local Law 97 of 2019—the Climate Mobilization Act. For most 

buildings that exceed 25,000 gsf (excluding electricity/steam generation facilities, rent-regulated 

accommodations, places of public worship, and city-owned properties), the City has established 

annual building emission limits beginning in 2024 and would require the owner of a covered 

building to submit annual reports demonstrating the building is in compliance with the current GHG 

emission limits. For buildings not covered under the GHG emissions limits, owners may either 

demonstrate compliance with the current limits or implement specified energy conservation 

measures where applicable.
Chapter 20: Indirect, Cumulative, and Other Impacts

20-25 June 2021

In general, while the direct effects of an individual action may be negligible, they could contribute 

to a measurable environmental impact when considered cumulatively with other past and/or future 

projects. The analysis follows the methodology outlined in detail in Appendix B. 

Construction of the Preferred Alternative would overlap with other construction projects within the 

Study Area. FRA looked at the construction analysis completed for the Preferred Alternative and 

analyzed if there would be any cumulative impacts resulting from simultaneous construction of 

other projects in the Study Area. Cumulative impacts from past, present, and reasonably 

foreseeable projects are described below for Transportation, Noise, and Air Quality. Other 

resource areas are not anticipated to result in contributions to cumulative effects. 

Based on the analysis performed in the previous chapters of this EIS, the Preferred Alternative 

would not have a direct construction effect on the following resource categories, and thus, a 

cumulative analysis would not be appropriate for the construction of the Preferred Alternative. 

• Land Use, Land Planning, and Property

• Aesthetics and Visual Quality

• Contaminated Materials

• Utilities and Energy

• Soils and Geology

• Water and Natural Resources

• Coastal Zone Consistency

• Socioeconomics

• Environmental Justice

• Public Health 

The potential construction effects of the Preferred Alternative, along with other projects being 

constructed within, near, or that could affect the Study Area using overlapping construction 

timeframes, has been cumulatively assessed for resource categories that were studied.

The projects included in the cumulative analysis are listed on Table 20-1 and on Figure 20-1. This 

section identifies and evaluates the potential for cumulative impacts on any given resource 

category analyzed in this EIS. 

The Preferred Alternative and the transportation and development projects listed in Table 20-1

and Figure 20-1 would help achieve New York City’s goal of increasing development on the Far 

West Side of Manhattan. As discussed in previous chapters, the area near the Project Site has 

been the subject of various planning, rezoning, and redevelopment efforts by the City, MTA, and 

other entities. The City and MTA rezoned the Eastern and Western Rail Yard to accommodate 

high density, mixed-use development as part of the 2005 Hudson Yards rezoning project. The 

2005 Hudson Yards rezoning project instituted a major rezoning of the entire Hudson Yards area, 

including the Eastern and Western Rail Yards, to accommodate a mix of uses and increased 

densities throughout the Far West Side. MTA most recently extended the No. 7 subway line to 

34th Street making it easier to get passengers to and from this area of the City. The City and MTA 

have planned for this additional capacity in the Study Area. Additionally, as described in the 2009 

SEQRA/CEQR FEIS, the City is carrying out an ongoing traffic monitoring program throughout the 

Hudson Yards area, as a result of the substantial new development planned and taking place in 

that area since 2009. As part of that monitoring program, the City will determine when it is 

appropriate to implement measures to alleviate traffic congestion at study area intersections. 
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WESTERN RAIL YARD INFRASTRUCTURE PROJECT

Ongoing Projects Included

in the Cumulative Assessment

Figure 20-1

4.21.21 Data source: NYC Dept. of City Planning

Project Site (Western Rail Yard) A

Study Area (1/2-mile perimeter)

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1 Ongoing Project Included in the Cumulative Assessment 0 1,000 FEET
June 2021 20-26

Table 20-1 

Projects Included in the Cumulative Assessment 

Map ID 

No.* Address/Name Block Lot Program

Build 

Year1

1 High Line—Tenth Avenue 

Spur N/A N/A Completion of repurposed High Line with open space amenities 2030 

2 Hudson River Park N/A N/A Park improvements, 29th-34th Streets 2030

3 

New York Penn Station 

Infrastructure Renewal 

Project

781 1 

Accelerated maintenance and repairs to existing 

tracks and systems to strengthen and improve 

operations and reliability at New York Penn Station

2030 

4 Penn Station Access N/A N/A Rerouting certain Metro-North Railroad New Haven 

Line commuter trains to Penn Station 2030 

5 Empire Station Complex 780 All Multiple transit improvements to Penn Station 2032/2042

6 432 West 31st Street 728 55 220 hotel rooms 2027

7 542 West 22nd Street 693 56 36,783 gsf office 2027

8 545 West 37th Street 709 14 131 DU, 258 hotel rooms, 82 parking spaces 2027

9 99 Hudson Boulevard 708 1, 62 1,495,000 gsf office 2027

10 349-355 West 37th Street 761 5,7 136 DU, 11,355 gsf retail 2027

11 Hudson Yards Site 24 735 25,27,30,

31,35

448 DU, 8,579 gsf community facility, 170 parking 

spaces

2027

12 260 Eleventh Avenue 698 1,6 23,236 gsf retail, 314,606 gsf office 2027

13 Western Rail Yard 

Overbuild 676 1,5 4,000 DU, 470 hotel rooms, 2,075,000 sf office, 75,000 sf retail, 750-seat school 2030 

14 Hudson Tunnel Project N/A N/A New rail tunnel, associated ventilation infrastructure, 

and full rehabilitation of the NRT 2030/2032

Notes: 

Some program data was updated in July 2020, based on updated project information from NYCDCP. 

DU= Dwelling Units 

* See Figure 20-1 1

 Projects for which an expected date of completion is not available are assumed to be complete by 2030. 

2

 Gsf was calculated off of the zoning square footage by using a factor of 1.15. 

Sources: NYCDCP, NYCDOB; AKRF research; and media coverage.

The incremental impacts of the Preferred Alternative as well as the projects listed in Table 20-1

are anticipated to exacerbate the non-attainment status of the New York New Jersey Long Island 

Area. However, New York State has a SIP that was developed to improve air quality and move 

toward reducing air pollutants and complying with the NAAQS. The Preferred Alternative as well 

as projects in Table 20-1 may introduce stationary sources of noise in the form of mechanical 

equipment; however, each would be required to comply with the restrictions of the NYCNCC, 

which would ensure that they do not produce noise levels exceeding applicable noise 

impact thresholds. Noise associated with traffic traveling to and from these projects would also not 

exceed applicable impact thresholds, since the surrounding roadways are already heavily 

trafficked and would not have the potential to experience a doubling of traffic, which would be 

necessary to result in a perceptible increase in noise levels. Consequently, the combined effects 

of the Preferred Alternative and the projects listed in Table 20-1 would not have the potential to 

result in a noticeable increase in noise levels at any noise-sensitive receptors within the Study 

Area.

20.4.1 CUMULATIVE OPERATIONAL IMPACTS OF THE PREFERRED 

ALTERNATIVE 

This EIS concluded that the operation of the Preferred Alternative would not result in adverse 

impacts on any resource categories (see detailed descriptions of analyses in Chapters 5 through 

19). Therefore, the Preferred Alternative would not contribute to the incremental effects with other 

present, or reasonably foreseeable projects in the study area. 
Chapter 20: Indirect, Cumulative, and Other Impacts

20-27 June 2021

20.4.2 CUMULATIVE CONSTRUCTION IMPACTS OF THE PREFERRED 

ALTERNATIVE 

20.4.2.1 TRANSPORTATION 

As discussed in Chapter 6, the Preferred Alternative would not have adverse construction impacts 

on transportation infrastructure based on CEQR Technical Manual guidance. However, the 

Preferred Alternative is in an area with baseline congestion, and with several new projects under 

construction or expected to be operational in the 2023 Peak Construction Year, and would 

contribute to localized traffic congestion in the Study Area during construction, particularly during 

construction shift changes. Therefore, construction of the Preferred Alternative would be expected 

to temporarily exacerbate traffic congestion in the area. It can be assumed that the projects listed 

in Table 20-1 would result in construction worker and construction vehicle trips. As described in 

the 2009 SEQRA/CEQR FEIS, the City is carrying out an ongoing traffic monitoring program 

throughout the Hudson Yards area, as a result of the substantial new development taking place in 

that area since 2009, and the anticipated additional congestion that would result from construction 

activities and operation of these developments. The intent of the traffic monitoring plan is to identify 

new or worsening areas of congestion in the area, and to determine the appropriate measures to 

implement to address congestion and endeavor to optimize traffic flow. As part of that monitoring 

program, the City will determine when it is appropriate to implement measures to alleviate traffic 

congestion at study area intersections. Additionally, as with any large-scale construction project 

fronting New York City public rights-of-way, implementation of an MPT plan is typically required 

and implements Best Management Practices. In this instance, the MPT is also part of the RD and 

CEPP for both Platform and subsequent Overbuild construction (see Section 20.3 above). The 

developers for all the projects listed in Table 20-1 would develop MPT plans for submission to 

NYCDOT for review and approval. MPT plans would provide diagrams of proposed temporary 

lane and sidewalk alterations, including the duration, and the width and length of affected 

segments, as well as safety signs and the locations of safety barriers and construction fencing. 

Provisions of the MPT plans may also 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’s OCMC has approved the MPT plans, the developers and their contractors would be 

responsible for maintaining the provisions of the plans. It can be assumed that with the 

implementation of MPT plans for all the planned construction projects listed on Table 20-1 adverse 

traffic impacts would be mitigated. 
June 2021 20-28

20.4.2.2 AIR QUALITY, GREENHOUSE GAS EMISSIONS, AND 

RESILIENCE 

Construction of the Preferred Alternative as well as the projects in Table 20-1 would result in 

increased regional emissions of criteria pollutants within the New York New Jersey Long Island 

Non-Attainment Area. New York State has a SIP that was developed to improve air quality and 

move toward reducing air pollutants and complying with NAAQS and considers anticipated growth 

in both construction activities as well as operational emissions. Projects subject to conformity are 

assessed on an individual basis to determine if an action would result in emissions that would not 

conform to the SIP emissions accounting. As discussed in Chapter 7, construction of the Preferred 

Alternative would result in annual pollutant emissions below the federal de minimis thresholds. 

Therefore, the Preferred Alternative is assumed to conform with New York State’s SIP and would 

not impact the State’s plan to achieve attainment of the NAAQS. Both New York City and New 

York State requires identification of measures to reduce both criteria pollutant and GHG emissions 

during construction in accordance with all applicable laws, regulations, and building code to 

minimize the air quality effects from construction. This is the main goal of the SIP, which was 

developed by New York State, to improve air quality and move toward reducing air pollutants and 

complying with NAAQS in this non-attainment area.

20.4.2.3 NOISE AND VIBRATION 

Construction of the Preferred Alternative would not exceed FTA construction noise impact 

thresholds; however, the construction noise levels would be audible outside the project site and

would be heard by passersby. It is anticipated that similar nuisance noise from other projects listed 

in Table 20-1 would result in similar nuisance noise in the immediate areas during construction. 

Construction operations for all the projects on Table 20-1 are anticipated to comply with the 

NYCNCC construction noise regulations with respect to equipment noise emission levels, but are 

still anticipated to cumulatively result in a noticeable noise increases for the general public. 

20.5 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT 

OF RESOURCES 

An irreversible or irretrievable commitment of resources results from the use of a resource that 

cannot be replaced or recovered, and results in the permanent loss of the resource for any future 

or alternate use.

Construction of the Preferred Alternative would require the irreversible and irretrievable commitment 

of building materials, including construction materials such as concrete, steel, and aggregate. The 

Preferred Alternative would also consume energy in the form of fossil fuels and electricity during 

the construction and operation of the Platform, its associated infrastructure, and Tunnel 

Encasement. These materials are available and their use for the Preferred Alternative would not 

have adverse impacts on their continued availability for other purposes. In addition to materials, 

funding and human labor would be required to design and build the Preferred Alternative.

The previous chapters of this EIS describe the measures to be implemented to avoid, minimize, 

and mitigate adverse impacts to resources. As discussed in Chapter 7, this includes the use of 

sustainable approaches to conserve and reuse resources whenever possible.
Chapter 20: Indirect, Cumulative, and Other Impacts

20-29 June 2021

20.6 RELATIONSHIP BETWEEN SHORT-TERM USES OF THE 

ENVIRONMENT AND THE MAINTENANCE AND 

ENHANCEMENT OF LONG-TERM PRODUCTIVITY

Short-term effects on the environment typically result from construction impacts. Long-term effects 

relate to the maintenance and enhancement of long-term productivity, including consistency of a 

project with local and regional economic, social, planning, and sustainability objectives. This 

section compares the short-term uses of the environment with the Preferred Alternative’s longterm productivity.

20.6.1 SHORT-TERM USES

Construction of the Preferred Alternative would have greater short-term effects on the environment 

than the No Action Alternative; however, these effects would be temporary, and any constructionrelated environmental impacts would be avoided, minimized, and mitigated wherever practicable. 

20.6.2 LONG-TERM PRODUCTIVITY

The No Action Alternative would likely result in negative effects to long-term productivity as it would 

not support the creation of additional new capacity for real estate development, nor would it 

preserve the right-of-way through the Western Rail Yard to support the future construction of a 

trans-Hudson passenger connection into New York Penn Station. In contrast, the Preferred 

Alternative would support the provision of developable land area that would generate revenue and 

modernize state-of-the-art life safety systems for the entire Western Rail Yard, in addition to 

preserving the right-of-way. Therefore, the Preferred Alternative would result in benefits to longterm productivity.

20.6.3 SHORT-TERM USES VERSUS LONG-TERM PRODUCTIVITY

Based on the information presented above, the localized short-term impacts that would result from 

construction of the Preferred Alternative would be temporary during the construction period. The 

long-term benefits to productivity of the Preferred Alternative are greater than the short-term

effects on the environment. 