The Real Estate Board of New York to The City Planning Commission Concerning Application Nos. N 210439 ZRM, N 210441 ZAM, M 130053B ZSM, N 210445 ZAM, C 210438 ZSM (CEQR No. 21DCP084M) - 250 Water Street

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The Real Estate Board of New York (REBNY) is the City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY supports the approval of the ULURP and non-ULURP actions (Application Nos. N 210439 ZRM, N 210441 ZAM, M 130053B ZSM, N 210445 ZAM, C 210438ZSM – CEQR No. 21DCP084M) to facilitate the development of a mixed-use building at 250 Water Street, Community Board 1, in the Borough of Manhattan.

250 Water Street is located in the South Street Seaport within the Special Lower Manhattan District. The site is currently occupied by an at grade parking lot that lies on the edge of, and within, the Seaport Historic District. Any development at this site requires both City Planning and Landmarks review to ensure its appropriateness to the historic district in terms of use, bulk, and programmatic nature. This level of review is appropriate given its proximity to Peck Slip and key historic assets and with the size of the site, the opportunity to bring significant new residential and commercial tenants to a vibrant neighborhood.

The Landmarks Preservation Commission has already determined that the design of the proposed project and its relationship to these historic assets is complementary and appropriate. The City Planning Commission (CPC) should also affirm the positive relationship the proposed building will have to its surroundings with a planning and land use lens. The requirements for the granting of a special permit are met by this application, including a better site plan and a better relationship among buildings, and a benefit to the City as a whole. The taller portions of the building are appropriate within the historic district and consistent with the built environment outside the historic district; the design maintains a consistent and appropriate streetscape in terms of height and setbacks; and the proposal fills a major gap in the surrounding neighborhood that significantly improves the streetscape. The setback waivers sought will not sacrifice access to light and air, so that the occupants and users of buildings in the area and people using the public streets will continue to enjoy the streets’ cobblestones and view corridors to the water.

The principal purpose of the Seaport subdistrict of the Special Lower Manhattan District is to preserve and protect the character of the South Street Seaport. The best way to do that is by protecting the South Street Seaport Museum, which serves as the steward of the district’s history and caretaker of the ships that allow that history to be present and tangible. The proposed development will enable the long-term stability of the South Street Seaport Museum and the preservation of the district’s cultural history through a $50 million commitment to fund a secure, recurring revenue stream, and the expansion, restoration, and rehabilitation of the Museum property. Greater access to the historic district and its amenities, therefore supporting its commercial assets beyond tourism cycles, is important to the continued vitality of this neighborhood as well.

Proposals for development such as the one before the commission today are critical for the continued and future prosperity of the City, heightened by the need for economic recovery from the COVID-19 pandemic. The application at 250 Water Street will assist in the City’s recovery by providing $1.8 billion in economic impact, 2,500 permanent jobs, and 2,000 construction jobs. Importantly, the inclusion of over 100 affordable apartments at 250 Water Street for those earning up to 40% of Area Median Income would be the first affordable housing built in Lower Manhattan in recent decades. These permanently affordable units will provide opportunities for education and job access in one of the wealthiest zip codes in the entire country.

This development will provide funding for the South Street Seaport Museum, ensuring the preservation of the neighborhood’s cultural history, and new housing, including affordable housing, aligned with the general purposes of the district and consistent with the goals of the Commission for the development of the city. We respectfully ask that the City Planning Commission approve the application package to facilitate the development of 250 Water Street. Thank you for the consideration of these comments.