Objections to the Expedited Planning Process for the Redevelopment of the Brooklyn Marine Terminal: A City Club of NY Waterfront Position Statement
- Rachel Miller
- May 2
- 13 min read
APRIL 1, 2025
SUMMARY
The City Club of New York, founded in 1893, is one of the oldest civic organizations in New York City. Its mission is to promote sound urban policy and protect the city’s essential character and assets.
The City Club and its Waterfront Committee have hosted three panels (with plans for one more) and discussions with waterfront and maritime experts to better understand the New York City (NYC) Economic Development Corporation’s (EDC) proposals for the Brooklyn Marine Terminal (BMT and “the site”) in Red Hook. Links to the panels are provided at the end of this Executive Summary.
Based on the panels, additional research, and internal discussions, the Committee urges EDC and other Brooklyn political officials involved in the redevelopment of BMT to conduct a fresh and thorough public planning process without a preconceived notion of future land use and density. Moreover, the process should be for the entire Red Hook (*1); planning and protecting a future luxury enclave cheek-by-jowl with climate-at-risk public housing and blue-collar employers aggravates injustice and speaks to a double standard.
We therefore urge Task Force members to vote “no” until such a fresh, thorough, and neighborhood-wide planning process is pursued—ideally under the direction of an entity (such as the NYC Department of City Planning)
that is not directly an interested party in maximizing project revenue.
Our concerns are summarized here and detailed later.
The plan should, by definition, proceed with diligence and caution. The visioning process has been rushed into mere months. This is unfair to the Red Hook and civic communities and imprudent, if not reckless. The proposed BMT development, on 120 acres of industrially zoned land but with up to 9,000 housing units, would be among the city's most significant projects in 75 years.
The site should not be developed until a climate resiliency plan is adopted and funded for the entire neighborhood, not just where the City chooses to develop. The BMT (and virtually all of Red Hook) is in the current coastal floodplain and will be subject to more frequent and significant flooding due to climate change. We refer the reader to the accompanying City Club policy position calling for a pause to all upzoning in areas that will be underwater with sea level rise until plans are in place to protect these areas.
The City Club Waterfront Committee opposes alienating any of this much-needed maritime and industrial land before citywide analysis of and vetted plans for both sectors in the city. At 120 acres and with public land ownership, the BMT is a significant citywide resource for maritime and non-maritime industries—now and in the future, given predictions of greater reliance on intra-harbor shipping, ferries, etc. Why curtail that expansion potential? The burden of proof should not be on “why not such this or that amount of housing” but on “why there should be any housing on this site.”
Under no conditions should it be luxury housing. Building new luxury housing on an island of raised land on the BMT site before such a plan is in place is an environmental injustice. It is appalling that the Red Hook neighborhood does not yet have a funded plan to protect it from the multiple types of flooding it is subject to more than a decade after the devastation of Superstorm Sandy. Whatever plans move forward, redevelopment on the BMT site should be in lock-step with neighborhood improvements regarding transit access, energy, community services, and (especially) climate change.
Maritime and park uses should be integrated to create an exciting “blue/green” waterfront that provides the community with ecological, economic, and social benefits. The BMT’s waterfront can exemplify innovative park design with commercial/retail and community amenities and waterfront/in-water recreation design and programming.
Whatever is built on the BMT site other than as-of-right maritime and industrial uses should be determined with a neighborhood-wide not an opportunistic site-specific lens. The bypassing of ULURP and project sponsorship by EDC (not the NYC Department of City Planning) makes real estate development the driver—i.e., profit and speed. It should instead be comprehensive, policy-driven, and deliberate.
Maximizing the potential benefits and avoiding unintended negative consequences can only happen with an open, inclusive, and robust public planning and design process—not one in which participants feel bullied, artificial deadlines are imposed, the program is preconceived, and the City’s customary procedures are bypassed.
Below, we discuss our initial concerns and thoughts in greater detail, especially regarding missed opportunities that might be captured with a more thorough process. We submit these initial thoughts in response to the (unreasonable) EDC timetable with its April deadline. Our comments represent our best understanding of the project and context. We are sure that, following what we learn from the fourth panel and as the process unfolds, we will want to elaborate on and modify some of our thoughts.
We look forward to contributing to a meaningful and appropriate redevelopment proposal for the BMT.
Sincerely,
The Waterfront Committee of the City Club of New York
Alice Blank Clay Hiles Walter Rodriguez Meyer
Sally Bowman Sam Jackson John Shapiro, Co-chair
Rob Buchanan Klaus Jacob Tyler Taba
Aaron Ford Alex Miller John West
Tom Fox, Co-chair Gita Nandan
Note: The BMT spans two neighborhoods: Red Hook south of Hamilton Avenue and Columbia Street to its north. Columbia Street is sometimes called Red Hook but relates more to Carroll Gardens and Cobble Hill. We employ “Red Hook” to refer to Red Hook proper and Columbia Street.
LINKS TO THE THREE CITY CLUB PANELS TO DATE
Panel 1. Brooklyn Marine Terminal: Planning for the Waterfront Future of NYC or Missing the Boat?
Panel 2. Can We Pull Off a Climate Resilient Brooklyn Marine Terminal
Panel 3. Brooklyn Marine Terminal: How Do We Plan the Port of the Future?
ATTACHMENTS
City Club’s position on development in places at risk from sea rise and increased/more intense storms.
New York Daily New op-ed on development in climate at-risk places.
DETAILED THOUGHTS
The Process
This is truly a once-in-a-lifetime opportunity. As financial stewards of our city, the EDC should take the time to plan, develop, and manage the project properly.
We are baffled by the inappropriate timeframe for public input and proper study of the site and neighborhood, especially its resilience and maritime components. We urge the EDC to pause and open the development and design to a more deliberative and inclusive process.
The future of Brooklyn Piers 7-12 was discussed as Piers 1-6 became Brooklyn Bridge Park in the late 1990s. EDC’s 2007 Atlantic Basin Request for Expressions of Interest (RFEI), later withdrawn, envisioned a mixed-use maritime/commercial development on Piers 10-12. After 25 years of debate and kicking the can down the road, why the sudden urgency? There are
also the NYC Department of City Planning’s waterfront plans, the Community Board’s approved 197a plan, and more planning to be considered; how does the BMT plan comply with these? Such consideration includes recognition that this is an “environmental justice” neighborhood due to the concentration of low-income housing residents (the largest in Brooklyn) cheek-by-jowl with highways, high-intensity trucking, and pollution.
EDC’s effort to expedite the public planning process while demanding a particular outcome undermines the project’s ultimate success and purposes. Public review and input are appropriate when devising a plan initially, not after EDC has decided on the project scope. Meaningful and robust community participation makes any public project more relevant to its purposes and surroundings and more socially and economically viable. Debate and discussion can improve development.
Purportedly, the planning is being rushed due to time-sensitive opportunities to obtain federal and State dollars. This funding is for basic infrastructure—surely, it can be secured even as the project progresses more carefully.
This is also smart from a scenario perspective; given DOGE and new federal disdain for addressing climate change, it is doubtful that timeliness determines whether federal funding will be forthcoming in the foreseeable future. The City is already exploring other options for financing climate change adaptation. Besides, the vision planning will yield a “vision”—not the plan. Contrary to what may be presumed, it will not be binding in any respect.
We urge that the project be subject to the City government's standard procedure for changing zoning: the Uniform Land Use Review Procedure (ULURP). At 120 acres, the proposal is the equivalent of a substantial change to the City’s Zoning Map, which the NYC Department of City Planning represents as the equivalent of the City’s comprehensive plan map. The BMT is also in the Southwest Industrial Business Zones (IBZ) and Significant Maritime Industrial Area (SMIA); residential would undermine both.
EDC’s apparent intent is to bypass ULURP through convoluted arrangements with the Port Authority of New York and New Jersey (as the current owners) and the Empire State Development Corporation (as the project leader of record, but not in fact; that’s EDC). The bypassing of rezoning and ULURP and ignoring IBZ and SMIA policy intentions are egregious given the scale of the development and the alienation of precious industrial/maritime land area, compounded by the risks involved (discussed next).
Resiliency
Adaptation to climate change needs to be addressed before the development program is decided. The City Club’s recently released “partial moratorium” letter to elected officials and our Daily News op-ed (attached) state that no area within the flood zone should be upzoned unless and until its resiliency is assessed and measures to protect it are implemented.
The BMT and Red Hook face compounding flood problems. These include storm surges like Superstorm Sandy, stormwater events like Hurricane Ida, groundwater intrusion from the area’s elevated water table, reverse flow through the combined stormwater/sewage lines that connect to outfalls, and erosion and damage in the Velocity Zone where water is moving, not just inundating—compounded by with the higher sea levels and more frequent and intense storms due to climate change. Indeed, without a sea wall system, the BMT and the neighborhood will be inundated by sea level rise by 2100, if not decades sooner.
Responsibly, the current EDC rendering shows the BMT residential and park area being raised 16+ feet. But we are not reassured. We wonder how exactly this will work, e.g., how the BMT plateau would meet the current grade of the neighborhood. We also point out that the 22nd-century version of Superstorm Sandy will overtop the plateau. Sandy put much of Red Hook 14 feet underwater, and sea level rise is reasonably expected to be 6 feet by 2100.
The U.S. Army Corps of Engineers most recently proposed a seawall system circumventing Red Hook to which the BMT plateau could connect. Seawalls (whether concrete, a berm, a raised park, etc.) can keep rising seawater out, but stormwater will accumulate behind it (often called a “bathtub” effect). So far, all the Army Corps, City, and other public proposals fall short of protecting against a 22nd-century version of Sandy. With sea rise, once the combined stormwater/sewage outfalls are over-topped, there will be constant reverse seawater flow through combined stormwater/wastewater lines into basements and onto the streets. Particular to Red Hook and a handful of other New York City neighborhoods, seawater will percolate up through basements and open spaces due to Red Hook’s underlying marsh-like conditions and a water table already just below the surface. The high water table also means landscaped green infrastructure won’t work. Outside the sea walls, the proposed maritime industry area will confront destructive, fast-moving currents and storm surges associated with Velocity Zones (“V-zones”), on top of the fact that the adjoining Buttermilk Channel already has among the fastest currents in the harbor. (The Army Corps is purportedly revisiting their plans to consider these multiple sources of flooding. But that is not certain, let alone transparent, given the news from Washington, DC.)
It's not just about engineering and the science of water. If there is a sea wall, who will build it? Who will maintain it? (New Orleans had sufficient sea walls; they were not fully maintained. It takes only one breach to render a flood wall system obsolete.) What are the maintenance and operating costs? Who will be responsible for the integrated construction, maintenance, and operation of the different components– the developer(s), the City, the State, or the federal government (if only)? A Park Improvement District such as that in the works for Gowanus? When—before, after, or as development takes place? If after, with what guarantees?
If there is no sea wall, does the plan include relocation (“managed retreat”) in the face of rising tides and worse storms? To where? How does that work for affordable housing tenants, who are definitionally squeezed out of the New York City housing market? What plans are there for the public housing residents? (Red Hook Houses is among the city’s most significant public housing developments.) How does the BMT figure in this? Is it right to build and protect new luxury housing in the same neighborhood that tens of thousands of affordable housing tenants would be required to leave, likely under duress?
These are complicated, compelling, yet unaddressed questions. They are not about project impacts subject to the Environmental Quality Review Act, whether City or State (CEQRA and SEQRA). They are basic conditions and should not be left to later analysis.
Commercial Maritime
Given the metamorphosis of maritime commerce, waterborne transportation, and package movement in the Harbor, EDC’s current proposal for commercial maritime activity at the site misses significant opportunities.
EDC has proven to be a leader in promoting maritime New York. Ridership on the NYC Ferry, with its 38 aluminum catamarans docking at 25 landing facilities, continues to increase year after year. EDC recently built a second homeport for the NYC Ferry at Atlantic Basin. It will contain travel lifts, washdown, and fuel facilities to maintain the fleet. Since its inception, the NYC Ferry has expanded passenger movement around the Harbor and has the potential to serve more areas of the city.
We also applaud EDC’s “Blue Highway” initiative to animate the waterfront with multiple types of waterborne transportation as a freight alternative to large-scale trucking, with its pollution and congestion impacts. We strongly support EDC’s call for rethinking the BMT as a place for “modern maritime jobs.”
But that’s not what the current plan truly accomplishes.
EDC's proposal for maritime commerce at BMT is rooted in the last great commercial cargo invention of the 20th Century: using containers to transport cargo to the city. We maintain that EDC is missing the site's tremendous potential to host critically needed support, repair, maintenance, and logistics facilities for the Blue Highway, which moves cargo through the city.
The missing components are in-water and upland facilities to support private passenger ferries, charter and tour boats, package delivery vessels, police, fire and emergency craft, visiting ships, and the adjacent NYC Ferry Homeport. Few places exist for overnight wharfage, bunkering, repair, and maintenance for the aluminum and smaller steel vessels currently operating in the New York Harbor and those planned for new passenger and package delivery services. Refueling facilities, travel lifts, small boat yards with aluminum welding facilities, prop shops, engine repair, in-water and dry stack marinas, logistics, and other such facilities are critically needed.
While steel vessels have a range of repair facilities along Kill van Kull on Staten Island’s North Shore, commercial ferries and other aluminum vessels in New York Harbor are serviced and repaired in New Jersey, Connecticut, Massachusetts, and further up the Hudson River at sites that are also (in the long run) endangered by development or sea level rise. Such facilities are critical to expanding the movement of passengers and freight around the Harbor.
EDC should explore the BMT as an ideal location to create critically needed facilities for the growth of commercial maritime in the Harbor in a public-private partnership with current and future maritime operators. The BMT is on a heavily used waterway at a central location in the harbor and is a good location for these critical facilities. These facilities must withstand sea level rise and storm surges to service the city’s growing fleet of private vessels and ensure the Blue Highway is realized over the next decade and supported for the remainder of the 21st Century. Unless addressed, this missed opportunity adds cost to the development and operation of the Blue Highway and would eventually jeopardize the maritime community in New York.
EDC should also include programs and facilities that support the development of “modern maritime jobs.” The city’s future maritime workforce depends on educational institutions such as the New York Harbor School, which is located directly across the Buttermilk Channel on Governors Island. Small vessel support and repair facilities at BMT could provide educational opportunities, meaningful apprenticeships, and job opportunities for students and graduates. Without building a local workforce to operate the vessels needed to implement the Blue Highway, our city will miss a tremendous opportunity to grow the system.
A further consideration is that more energy infrastructure will be needed as we move away from fossil fuels to renewable energy production and storage, perhaps but not limited to offshore wind. Such basic infrastructure must be on publicly owned, industrially zoned waterfront sites—a limited resource. Is the BMT one of the few sites that will need to be recruited for this purpose, not in the current mayoralty but within the project's life? This, too, requires a citywide perspective.
We also have questions about a container port as part of the plan; while not necessarily “deal breakers,” they must be fully considered. We wonder whether the $800 million site preparation cost estimate driven by “port reconfiguration” is necessary for a container operation (and the proposed housing?) but not the wharfage, repair, maintenance, and logistics option.
We strongly feel that any plan for the BMT’s maritime uses requires a careful study of these resources citywide. That study should include the need to reserve upland for maritime uses. The proof is at the South Brooklyn Marine Terminal, where plans have evolved over time, yielding greater (not lesser) demand for space.
Non-Maritime Uses and Infrastructure
We do not support housing on the site, period. The development is premised on housing for wealthy white-collar workers at the expense of blue-collar maritime and industrial jobs. (The proposed container port does not and would not generate plentiful employment. The hotel has dubious prospects.) In effect, the City is contributing to environmental injustice in arriving at plans to protect its luxury housing enclave from sea level rise in the absence of funded, let alone adopted plans, to protect the entire neighborhood (with its majority of low- and moderate-income residents of color) from the dangers of climate change 50+ years out, when sea rise and frequent intense storms will endanger Red Hook far, far more than most parts of the city.
Vertical mixed-use of housing above industry: Brava, but not at the BMT. After decades of rezoning, the amount of industrially zoned land (excluding airports and rail yards) approximates a marginal percent of the city’s land mass. Industrial uses may not be worth much as real estate, but they are essential to keeping the city’s cost of living and doing business within reason, and they provide good working-class jobs. On waterfronts, ground-floor industry is preferred for resiliency reasons; industrial uses are more easily flood-proofed than housing, putting far fewer people and investments at risk. However, vertical mixed-use is inappropriate at the BMT because housing is not. There are ample other opportunities for housing, especially now that the City of Yes has been adopted. Like the City-owned Brooklyn Navy Yard and Brooklyn Army Terminal, other important land use and economic priorities can only be addressed here on centrally located, waterfront, publicly-owned land.
The site will require significant infrastructure improvements; these should benefit the entire community, not just one development. For instance, parts of Red Hook experience reduced power supply at various times during the year. For sure, the Red Hook neighborhood south of Hamilton Avenue lacks subway access. More consideration should be given to viable energy and transit solutions for the future of BMT and the neighborhood, together. This planning is needed upfront. Infrastructure improvements should be integral to the plan and not left to the vagaries of what might be done in response to the CEQRA/SEQRA studies.
We support the inclusion of a significant park on the south end of the development. We suggest drawing inspiration from successful parks on other industrial waterfronts. In Brooklyn, the Newtown Creek Nature Walk shows how even a narrow strip adjoining industry can be designed as a significant amenity. In the Bronx, Concrete Plant Park shows how industrial artifacts can be part of a park experience. The nearby Music Barge, Red Hook’s own Waterfront Museum, and the Mary K. Whalen tanker already at the BMT all show the value of using historic vessels for public education, recreation, and interpreting waterfronts’ past and future. The Lower East Side Coastal Resiliency Project demonstrates how a park can substitute for a wall vis-a-vis protection from storms and sea level rise and accommodate temporary runoff stormwater storage. As further sources of inspiration, the community and City should consider “Blue/green” projects worldwide. At the BMT, the basin, piers, and embayment between the piers provide an extra opportunity for ecological restoration, recreational boating, small boat building, marinas, and other recreational maritime uses. These uses would provide much-needed in-water recreation for city residents.
