Creating A Blue Highway
- 18 hours ago
- 9 min read
Download the full report
Creating a Blue Highway Hub at Brooklyn Marine Terminal (2026)
Photo Credits Above: Panels, Richard Mason, Windmill, B.Y. Ken
About the Blue Highway...
February 9, 2026:
The City Club of New York released an updated all-maritime plan for the redevelopment of the Brooklyn Marine Terminal. “Creating a Blue Highway Hub at Brooklyn Marine Terminal” was developed with input from leading maritime professionals, logistics and transportation companies, marine engineers, environmental planners, local elected officials and community organizations and residents from Red Hook and the adjacent neighborhoods.
The update includes comments received by Resilient Red Hook subsequent to its initial release. The effort builds on decades of public commitment to preserving Red Hook's historic working waterfront, as outlined in the 197A Plan and reaffirmed through extensive community participation in many community planning studies over the years.
Comment From Victoria Alexander, Resilient Red Hook
Most recently, the community held a planning session to reaffirm our position and to
understand our shared values by having community members participate in the James Rojas planning exercise. An all-maritime alternative plan was requested by
community members and the Task Force throughout the EDC engagement but was
never provided. This plan acts as a catalyst for conversation for reimagining the
BMT as a vibrant maritime and logistics hub—a “Blue Highway” gateway that
expands commercial port activity, creates local jobs, and strengthens our
neighborhood’s climate resilience and emergency preparedness. It proposes
modernizing BMT without displacing critical industrial uses or endangering the
environmental and economic future of Red Hook. We invite all community members to view this presentation and share their feedback. Your voices are essential as we work together to ensure a resilient, inclusive, and sustainable future for our waterfront.
Mayor’s Office of Environmental Coordination
Public Comment Session on CEQR for BMT
March 16, 2026
Good evening. I am Tom Fox a Trustee of the City Club of New York. I appreciate the opportunity to comment on the BMT CEQR Scoping. An EIS must consider a range of reasonable and feasible alternatives to the project that have the potential to reduce or eliminate a proposed project’s impacts. The all-maritime plan for BMT developed by the City Club of New York has the potential to reduce, or eliminate, many of the proposed project's environmental impacts, and is also plainly reasonable and feasible.
For example, the Club’s plan eliminates the need for 11.17 acres of landfill in Buttermilk Channel and the resulting impacts. It will significantly reduce stormwater and sanitary sewage discharged into this waterway in times of heavy rainfall. This all-maritime plan will reduce both air quality and surface transportation burdens as well as the impacts on police, fire, schools, hospitals, and other essential municipal services in the adjacent communities that will result from the current plan being proposed.
Our all-maritime alternative was developed in consultation with, and has the support of, Resilient Red Hook, community organizations, maritime professionals, marine and environmental engineers, planners, transportation and logistics professionals, current and former government employees, elected officials, and local property owners.
Accordingly, it qualifies as an alternative the Lead Agency should consider as a part of its review. In addition to eliminating or reducing many of the proposed impacts environmental impacts, an analysis of the Club’s all-maritime plan will bring an understanding to the public of the wide array of trade-offs and impacts of the different uses and programming of the site under the different alternatives.
BMT is a unique site strategically located to support and grow the Maritime industry in New York City. Because it is unique, a careful analysis of all reasonable and feasible options is an important part of building consensus on what should be happening here. The implementation of a Blue Highway Hub at BMT will significantly benefit the city’s environmental quality.
That's part of what environmental review is for: to publicly disclose the benefits and the impacts of all the reasonable and feasible alternatives; disclosing the impacts and benefits in an apples-to-apples fashion so that New Yorkers can make an informed decision on the best way forward for us all. The Club’s plan was developed as an apples-to-apples alternative.
Thank you for the opportunity to comment.
Tom Fox
Chair of Waterfront Committee
City Club of New York
February 20, 2026
Jason Otaño
General Counsel
Office of the City Council
Brooklyn Marine Terminal
Dear Mr. Otaño:
I am an attorney representing the City Club of New York, a civic organization founded 134 years ago to promote sound urban policy in New York City. I write in opposition to the City’s current plan to redevelop the Brooklyn Marine Terminal (“BMT”) (the “Plan”). No one questions the necessity of redeveloping the site, but the Plan is both unwise and unlawful. In this letter, I will present its legal problems. They are significant, and the City Club is prepared to file a lawsuit to enjoin the Plan from moving forward unless the City and State dramatically improve it.
I am also attaching a detailed reimagining of the site, “Creating a Blue Highway Hub at Brooklyn Marine Terminal,” prepared by Tom Fox, a City Club Trustee, who has been at the forefront of urban park and waterfront development in New York City for decades. (Web version: download is available at the top of the page)
1. ESD and ULURP
The Urban Development Corporation Act (the “UDC Act”) prohibits a municipality from transferring its property to Empire State Development (“ESD”), a State agency, for the sole purpose of circumventing the City’s land use laws. That is precisely what the City proposes to do here — skirt the requirements of the Uniform Land Use Review Procedure (“ULURP”) and Section 384 of the City Charter, which prohibits the City from selling, leasing, or exchanging its property without the approval of the Mayor, the City Planning Commission, and the City Council.
ESD would serve only as a straw man. The City would continue to fund all the
costs associated with "planning, review, public hearings and comments, authorizations, and approvals” and "design, construction, operation, and maintenance of the improvements.” It would assume all costs for staffing, compliance, and litigation related to the plan. And it would "defend and indemnify the State and any of its public authorities and their subsidiaries as it relates to their participation in the [plan].” (Memorandum of Understanding between the City, State, New York City Economic Development Corporation (“EDC”), and Port Authority of New York and New Jersey (“Port Authority”), dated April 17, 2024, Part G)
To be sure, the UDC Act does not require ESD to assume all the responsibilities the municipality would otherwise have assumed. But it must assume some active role, and it would not do that here.
2. SEQRA Segmentation
An environmental review that fails to properly consider a related project, for the purpose of minimizing the cumulative impacts of the two plans, is unlawful “segmentation” under the State Environmental Quality Review Act (“SEQRA”).
The SEQRA regulations define “segmentation” as “the division of environmental review of an action such that various activities or stages are addressed under this Part as though they were independent, unrelated activities, needing individual determinations of significance.” (6 N.Y.C.R.R. § 617.2(ah))
According to the Draft Scope of Work, the “study area” — the geographic area
where the Plan’s potential environmental impacts are studied — will be only 400 feet beyond the perimeter of the site. (Draft Scope of Work for the Environmental Impact Statement, Sept. 16, 2025, Figure 1) In other words, the review will exclude consideration of impacts on all adjacent neighborhoods — in particular, Red Hook to the south, where half of the residents live in public housing. The impacts on Cobble Hill to the east and Brooklyn Heights to the north must also be considered.
The Plan excludes, for example, consideration of the City’s climate plan for Red Hook, the Red Hook Resiliency Plan. But the BMT and Red Hook are part of a single coastline. As anyone familiar with climate issues understands, the weak link along a coastline will doom the entire area. No discussion of storm surges and rising sea levels here can fail to consider the climate plans for these two areas together.
3. The Developer’s Freedom Not to Build
A plan is arbitrary and capricious, by definition, when it fails to achieve the purposes for which it was created — in this case, providing funds for (1) port redevelopment and infrastructure and (2) affordable housing.
But the Plan includes no schedule for the construction of the proposed residential buildings; that will depend entirely on the whims of the developer, and on his or her unappealable assessment of when it would be most economically advantageous to proceed.
Building a state-of-the-art commercial maritime port facility will cost $1.2 billion, and building the public infrastructure necessary to support both the port and 18,000 new residents will cost another $2 billion. If, for whatever reason, the developer decides not to build, the City will be on the hook for the shortfall.
The other casualty would be the promised affordable housing. The history of ESD’s Atlantic Yards presents a troubling precedent: Nearly two decades after the project was announced, the developers have built only half the number of apartments they said they would build. Without a mandated construction schedule, the Plan’s benefits remain theoretical. (In addition, they propose now to (1) redefine “affordability” to allow wealthier residents into the so- called affordable units, and (2) increase the permitted floor area to make way for a super-tall tower.
4. Port Size and the Blue Highway
The plan to reduce the size of the port area from 122 to 60 acres would eviscerate what the Draft Scope identifies as one of the project’s primary goals: “supporting the nascent Blue Highways initiative.” (Draft Scope, p. 6) For two decades, EDC has advocated for moving as much freight as possible — packages, produce, building material — on the City’s waterways, not highways.
We agree with EDC’s endorsement of the Blue Highways, but the BMT is an essential stop on any Blue Highway, and a diminished, 60-acre port cannot achieve this goal. Again, a plan that does not achieve its stated purposes is, by definition, arbitrary and capricious.
The BMT is the only remaining large commercial maritime port east of the Hudson River. The City’s Waterfront Revitalization Program (“WRP”) has designated the site as a “Significant Maritime and Industrial Area” to promote water-dependent and industrial uses.
The “guiding principle” of the WRP is “to maximize the benefits derived from
economic development, environmental conservation, and public use of the waterfront” — not luxury housing. (New Waterfront Revitalization Program, pp. 3, 42) Moreover, the WRP is authorized by the State Secretary of State and federal National Oceanic and Atmospheric Administration’s Office for Coastal Management. ESD cannot simply override it, as it can with City laws and regulations.
SEQRA requires that the City consider “reasonable” and “feasible” alternatives
for developing the port. (6 N.Y.C.R.R. 617.9(b)(5)(v)) The City Club has developed the attached comprehensive alternative commercial and industrial plan for the BMT, using all 122 acres to create a port of the future: inbound containers; cold storage, warehouse, and logistics facilities; outbound ferries for distribution; and shipyard, repair, and refueling facilities, among other services. Without a port on this scale, the Blue Highway will never be able to serve Brooklyn and Queens.
5. Self-Created Blight
The Plan cannot qualify as a “Land Use Improvement Project” under the UDC
Act because the BMT is not a “blighted” area — that is, “a substandard or insanitary area, or [ ] in danger of becoming a substandard or insanitary area and tends to impair or arrest the sound growth and development of the municipality.” (UDC Act § 6, Unconsol. Laws § 6256; id. § 10(c)(1), Unconsol. Law § 6260)
Whatever blight there may be is a direct result of EDC and the Port Authority’s own inattention. EDC’s leasing has been haphazard and negligent. The Port Authority remains contractually obligated to maintain the piers in good condition, and it has not done so. A governmental project cannot qualify as a Land Use Improvement Project when the blight is the government’s own doing.
6. The Land Swap and Fair Market Value
The unfairness of the land swap between the City and the Port Authority may violate Public Authorities Law § 2897. It certainly disregards the most basic duty of municipalities engaged in property transactions — to acquire property at no more than fair market value, and to dispose of it at no less than fair market value.
The trade here is laughably one-sided: The City would give the Port Authority a
jewel: the 187-acre Howland Hook Marine Terminal in Staten Island, equipped with six post-Panamax cranes, road and rail connections to the entire nation, 3,000 linear feet of 50-foot-deep wharfage, and an adjacent 127-acre expansion site. In exchange, the City would acquire the unimproved and mostly vacant 122-acre BMT, without rail access, without operational cranes, with only limited road access, and more than $1 billion in deferred maintenance. The trade the City seeks would be a travesty of good government.
7. The Open Meetings Law and the Task Force
The meetings held by the Brooklyn Marine Terminal Task Force (the “Task Force”) — neighbors and elected officials who were handpicked by EDC — violated the Open Meetings Law (“OML”). The Task Force plainly qualified as a “public body” subject to OML, and its sessions qualified as “meetings,” construed by courts to include “work sessions,” “agenda sessions,” “conferences,” and “organizational meetings,” even if no formal action was taken at them. (Public Officers Law § 102;
see, e.g., Thomas v. NYC Department of Education, 145 A.D.3d 30, 35-36 (1st Dep’t 2016).)
The Task Force disdained these rules. It did not invite the public to any of its meetings, including the one in which the members cast their final votes. Nor did it provide recordings or transcripts of any meetings. It seems clear that the Task Force’s intention was to conceal its deliberations from the public, whatever the law may have required.
We hope to discuss these issues with your office soon. The Plan is not only bad public policy; it is illegal. As I said, we will take whatever action is necessary to prevent it from going forward in its current form.
Sincerely,
Charles Weinstock
Letter available for download below