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MTA New York City Transit Fulton Street Transit Center DEIS May 2004 20.0 Cumulative Effects 20-1 CHAPTER 20: COORDINATED CUMULATIVE EFFECTS ANALYSIS 20.1 INTRODUCTION This chapter provides an overview of the methods, data sources, results and conclusions of the project’s cumulative effects analyses. The technical analyses supporting the discussion presented in this Chapter are included as part of each resource chapter and in appendices of this Draft Environmental Impact Statement (DEIS), in particular with regard to construction-related cumulative effects. Construction and operational impacts were assessed for all resource categories in the respective technical chapters of this DEIS. This cumulative effects chapter focuses on five (5) specific resource categories: Air Quality; Noise and Vibration; Pedestrian and Vehicular Access and Circulation; Cultural and Historic Resources; and, Business and Economic Interests. These resources have been analyzed for cumulative impacts because they have been identified as having the potential for interrelated effects, and the potential for being subject to cumulative effects associated with the FSTC in combination with other Lower Manhattan Recovery Projects. These resources are also most likely to be impacted during construction while benefiting most from long-term revitalization of Lower Manhattan. As such, they directly relate to the challenge of minimizing short-term environmental impacts during construction, while maximizing long-term revitalization of Lower Manhattan. 20.2 DEFINITION OF CUMULATIVE EFFECT AND GUIDANCE The Council on Environmental Quality (CEQ) regulations for implementing the National Environmental Policy Act (NEPA) define a cumulative effect (40 C.F.R. 1508.7) as “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of agency (Federal or non-Federal) or person undertaking such other actions” (CEQ, 1978). It should be noted that the terms “impacts” and “effects” as used in the CEQ regulations are synonymous (40 C.F.R. 1508.9). The CEQ subsequently produced a handbook entitled Considering Cumulative Impacts Under the National Environmental Policy Act (NEPA) (CEQ, 1997) to provide a framework for advancing environmental impact analysis by addressing cumulative effects in either an environmental assessment or an environmental impact statement. The handbook notes that cumulative effects may arise from single or multiple actions and may result in additive or interactive effects. The combination of two (2) kinds of actions with two (2) kinds of processes leads to four (4) basic types of cumulative effects, as follows: Type One – Repeated “additive” effects from a single proposed project; Type Two – Stressors from a single source that interact with receiving biota to have an “interactive” (non-linear) net effect; Type Three – Effects arising from multiple sources (projects, point sources or general effects associated with development) that affect environmental resources additively; and, Type Four – Effects arising from multiple sources that affect environmental resources in an interactive (i.e., countervailing or synergistic) fashion. The CEQ handbook’s focus on the “coincident effects (adverse or beneficial) on specific resources, ecosystems, and human communities of all related activities, not just the Proposed Action and

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Page 1: CHAPTER 20: COORDINATED CUMULATIVE EFFECTS ANALYSIS …web.mta.info/capital/fc_docs/deis/chapters/ch20.pdf · MTA New York City Transit Fulton Street Transit Center DEIS May 2004

MTA New York City Transit Fulton Street Transit Center DEIS

May 2004 20.0 Cumulative Effects 20-1

CHAPTER 20: COORDINATED CUMULATIVE EFFECTS ANALYSIS

20.1 INTRODUCTION This chapter provides an overview of the methods, data sources, results and conclusions of the project’s cumulative effects analyses. The technical analyses supporting the discussion presented in this Chapter are included as part of each resource chapter and in appendices of this Draft Environmental Impact Statement (DEIS), in particular with regard to construction-related cumulative effects. Construction and operational impacts were assessed for all resource categories in the respective technical chapters of this DEIS. This cumulative effects chapter focuses on five (5) specific resource categories:

• Air Quality; • Noise and Vibration; • Pedestrian and Vehicular Access and Circulation; • Cultural and Historic Resources; and, • Business and Economic Interests.

These resources have been analyzed for cumulative impacts because they have been identified as having the potential for interrelated effects, and the potential for being subject to cumulative effects associated with the FSTC in combination with other Lower Manhattan Recovery Projects. These resources are also most likely to be impacted during construction while benefiting most from long-term revitalization of Lower Manhattan. As such, they directly relate to the challenge of minimizing short-term environmental impacts during construction, while maximizing long-term revitalization of Lower Manhattan. 20.2 DEFINITION OF CUMULATIVE EFFECT AND GUIDANCE The Council on Environmental Quality (CEQ) regulations for implementing the National Environmental Policy Act (NEPA) define a cumulative effect (40 C.F.R. 1508.7) as “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of agency (Federal or non-Federal) or person undertaking such other actions” (CEQ, 1978). It should be noted that the terms “impacts” and “effects” as used in the CEQ regulations are synonymous (40 C.F.R. 1508.9). The CEQ subsequently produced a handbook entitled Considering Cumulative Impacts Under the National Environmental Policy Act (NEPA) (CEQ, 1997) to provide a framework for advancing environmental impact analysis by addressing cumulative effects in either an environmental assessment or an environmental impact statement. The handbook notes that cumulative effects may arise from single or multiple actions and may result in additive or interactive effects. The combination of two (2) kinds of actions with two (2) kinds of processes leads to four (4) basic types of cumulative effects, as follows:

• Type One – Repeated “additive” effects from a single proposed project; • Type Two – Stressors from a single source that interact with receiving biota to have an

“interactive” (non-linear) net effect; • Type Three – Effects arising from multiple sources (projects, point sources or general effects

associated with development) that affect environmental resources additively; and, • Type Four – Effects arising from multiple sources that affect environmental resources in an

interactive (i.e., countervailing or synergistic) fashion. The CEQ handbook’s focus on the “coincident effects (adverse or beneficial) on specific resources, ecosystems, and human communities of all related activities, not just the Proposed Action and

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alternatives” was also addressed by the Federal Highway Administration (FHWA) in its Interim Guidance: Questions and Answers Regarding Indirect and Cumulative Impact Considerations in the NEPA Process (FHWA, 2003). The FHWA interim guidance notes that a cumulative effect analysis is “resource specific and generally performed for the environmental resources directly impacted by a Federal action under study, such as a transportation project. However, not all of the resources directly impacted by a project would require a cumulative impact analysis. The resources subject to a cumulative impact assessment should be determined on a case-by-case basis early in the NEPA process, generally as part of early coordination or scoping” (FHWA, 2003). The FHWA interim guidance suggests nine (9) items for developing the scope of the cumulative effects analysis, as follows:

• Identification and agreement on the roles and responsibilities of participants and cooperating agencies in the project development process;

• Identification of appropriate project study area; • Complete inventory of resources of concern within the project study or influence area; • Clarification of major and important versus minor issues associated with the Proposed Action and

alternatives; • Identification of other actions impacting or potentially affecting the major resources; • Definition of assessment goals, techniques and methodology for analysis of identified potential

effects; • Establishment of appropriate resource geographic and temporal boundaries related to the

identified scope of analysis; • Identification of planning considerations in the local area, including direction and goals, land uses

and transportation plans for incorporation into the study; and, • Identification of initial alternatives to the proposal and to avoid and minimize harm to the

environment. 20.3 LOWER MANHATTAN APPROACH TO CUMULATIVE

EFFECTS ANALYSIS

20.3.1 OVERVIEW OF APPROACH

Due to the confluence of projects that are likely to be undertaken during the rebuilding of Lower Manhattan, a key issue in the consideration of environmental consequences during the NEPA review process for each project would be the evaluation of cumulative effects. The sponsoring agencies of the Lower Manhattan Recovery Projects – the Metropolitan Transportation Authority (MTA), the New York State Department of Transportation (NYSDOT), and the Port Authority of New York and New Jersey (PANYNJ) – coordinated the development and issuance of the Environmental Analysis Framework for Federal Transportation Recovery Projects in Lower Manhattan and the Lower Manhattan Federal Transportation Recovery Projects Common Environmental Performance Commitments (EAF) (MTA, et al., 2003). To guide the development and implementation of the analysis approach, the U.S. Department of Transportation, Federal Transit Administration (FTA) prepared the Approach to Cumulative Effects Analysis for the Lower Manhattan Recovery Effort (July 2003) to outline how the analysis of cumulative effects would be addressed during environmental review under NEPA for transportation restoration, reconstruction, and improvement projects in Lower Manhattan (included in Appendix A). The approach set out in FTA’s guidance ensures consistency among projects by ensuring the coordination of analysis assumptions and use of comparable technical analysis methodologies for all of the Lower Manhattan Recovery Projects. The “coordinated cumulative effects analysis” approach outlined by FTA is founded on two (2) important principles:

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• A commitment to the application of a single consistent framework, methodology, and set of assumptions for the evaluation of cumulative effects across projects; and,

• Adherence to Environmental Performance Commitments (EPCs) to reduce the potential for adverse impacts across projects and to lower the potential severity or magnitude of the adverse impacts.

In a coordinated effort, the Federal partners and Lower Manhattan Recovery Project sponsors initially identified the following critical environmental factors as resources of concern for cumulative effects: air quality; pedestrian and vehicular access and circulation; noise and vibration; historic and cultural resources; and, business and economic effects. During the project pre-scoping and scoping processes that followed, these factors were confirmed as those most likely to be subject to cumulative effects. The EAF also details the collective commitment of the agencies to the environment and communities of Lower Manhattan and specifies the elements of the coordinated cumulative effects analysis approach to be applied. This document includes common EPCs among the agencies, related to the five resources of concern. These EPCs are described at the beginning of the analysis of cumulative effects for each resource in this chapter. Key features of the cumulative effects analysis are presented below.

20.3.2 KEY FEATURES OF THE APPROACH

In addition to the focus on resources of concern, discussed in the previous section, the key features of the coordinated cumulative effects approach are described in the following discussion. Promoting Efficient Project Delivery and Environmental Stewardship – The avoidance and reduction of adverse impacts are proactively managed through the adoption of EPCs. EPCs include environmentally-friendly design features or construction practices that would preserve the capacity of the environment to accommodate implementation of all of the transportation Recovery Projects. EPCs are intended to sustain or enhance the long-term capacity of the resources of concern to absorb changes and impacts associated with transportation project delivery, and would maintain or improve their condition. The EPCs among all the Lower Manhattan Recovery Projects are intended to address cumulative effects, and may also include project-specific EPCs. As noted in the previous section, the Lower Manhattan Recovery Project sponsors collectively developed and committed to a consistent set common EPCs. In addition, project-specific EPCs are made, as appropriate, based on the results of each project’s cumulative effects analysis. Project-specific EPCs are based on an individual project’s adverse impacts in addition to cumulative impact areas. Advancing Each Project Independently, but in a Coordinated Manner – The coordinated cumulative effects analysis is a building block approach, managed to reduce redundancy and foster consistency across projects, and to ensure that opportunities for reductions in potential adverse cumulative effects are made on each and every project. This is achieved through the progressive completion of the cumulative effects analysis on a project-by-project basis using a consistent set of assumptions and methodologies in a common evaluation framework. Then, as each project matures through the NEPA process, the knowledge gained from a given project’s cumulative effects analysis would be incorporated as a “building block” into the cumulative effects analysis of each of the subsequent projects. This sequential building block approach was complemented over the Summer of 2003 with a more comprehensive approach, as more information became available on the other Lower Manhattan Recovery Projects than originally was anticipated. Coordination among the Lower Manhattan Recovery Projects in the Summer and Fall of 2003 resulted in the development of a comprehensive set of assumptions for each of the Lower Manhattan Recovery Projects and shared by all Lower Manhattan Recovery Projects. This enabled the project sponsors to proceed with the environmental analysis of their individual projects while including the data of the other Lower Manhattan Recovery Projects as part of the No Action condition. To establish the future background conditions, on-going and other anticipated private development construction activities and operations are added to the inventory of existing conditions. Projections are

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made of private and other projects expected to be under construction or in operation by each analysis year, using common land use projections among MTA New York City Transit (NYCT), PANYNJ, NYSDOT, and Lower Manhattan Development Corporation (LMDC), consistent or compatible with forecasts developed by the New York Metropolitan Transportation Council (NYMTC). The following projects are included in the No Action (baseline) Condition for the environmental review of cumulative construction impacts because of their anticipated overlapping construction schedules:

• South Ferry Terminal; • Permanent World Trade Center (WTC) Port Authority Trans-Hudson (PATH) Terminal; • Route 9A Reconstruction; and, • WTC Memorial and Redevelopment Plan.

Although not a transportation recovery project, the WTC Memorial and Redevelopment Plan is included in the coordinated approach because of its overlapping construction schedule and commitment by its sponsor, the LMDC, to support the coordinated cumulative analysis. In addition, New York City Department of Transportation (NYCDOT) street reconstructions in Lower Manhattan are included in the baseline because NYCDOT adjusted its street reconstruction sequencing, based on coordination with the project sponsors, to avoid spatial and temporal overlaps of street reconstruction with the projects. The analysis of the FSTC accounts for the potential impacts associated with the other Lower Manhattan projects in several ways. First, the No Action analysis is a key part of the assessment of the potential cumulative effects of all major Lower Manhattan Recovery Projects. By assuming the simultaneous or overlapping construction of the other projects, and evaluating the potential effects of these projects without the FSTC, based on the same or comparable background data and analysis methodologies amongst all the projects, the No Action analysis allows an accurate identification of impacts that are attributable to the other projects; this is the environmental background condition, or future, without the FSTC. The No Action analysis can be regarded as the cumulative impact analysis of all Lower Manhattan Recovery Projects, excluding the FSTC. Both the No Action and Build analyses allows the identification of potential interactions between projects which are under construction and which will be operational at the same time. Second, the Action, or Build analysis, which adds the FSTC to the future environmental background condition, is the cumulative impact analysis of all projects, including the FSTC. Adding the effects of the FSTC and the No Action (including the other Recovery Projects) in the Build Alternative or Action analysis, allows the identification of potential cumulative impacts that are attributable to the FSTC. For example, during construction, all of the Lower Manhattan Recovery Projects would generate increased traffic, air pollutant emissions and noise, resulting in cumulative levels which would be greater than those associated with any one of the individual project. However, it has been identified that noise and vibration is the only resource area where the FSTC could potentially cause adverse cumulative impacts. Further information on this, and the analysis of the other cumulative resources (business and economic conditions, air quality, cultural resources and transportation access and circulation) is presented in the technical resource chapters of this DEIS. Detailed information on the methodologies, data analysis and results is presented in the technical appendices of this DEIS. During operation, the transit projects (with the exception of the No Action Alternative for the Permanent WTC PATH Terminal) would not generate traffic and, therefore, emissions or increased noise levels on the major traffic routes to and from Lower Manhattan (Route 9A, Church Street and Broadway). Depending on the ultimate Build Alternative selected, Route 9A could result in impacts on traffic post-construction on these roadways. The redevelopment of the WTC site would also result in changes in traffic patterns and could have a long-term effect on these routes.

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Finally, cumulative effects of all the projects are also taken into account via the use of comparative methodologies and agreed and common baseline data, shared and common construction assumptions and coordination between project sponsors prior to, and during, the preparation of technical analyses (see below). Through coordination on the planned construction schedules and sequencing of construction activities among the project sponsors, 2005/2006 was identified as the peak activity year for construction for the Lower Manhattan Recovery Projects. To ensure consistency between the Lower Manhattan Projects, project sponsors provided information to allow development of a construction schedule for all five (5) projects. This information was used to develop an overall schedule which included all major phases of construction for each project, and which was used throughout the analysis of the Lower Manhattan Projects. Based on this overall schedule, 2005/2006 is used as the analysis year for cumulative construction impacts in this document. After the projects and year of analysis were identified, a cumulative construction scenario was developed. The procedure for developing the scenario consisted of the following steps: Define the Construction Plan – For each of the projects, the overall construction plan was broken down into a series of discrete major activities, e.g., relocate utilities, excavate subsurface, construct foundation, etc., for which typical equipment usage and construction vehicles could be assigned. Then, generally, major activities were disaggregated into a series of smaller sub-tasks until such point as it could be assumed that daily equipment usage and daily truck generation were approximately uniform throughout the duration of the task. The sub-tasks occur at different periods within the overall duration of the major activity. Derive Construction Assumptions – Assumptions regarding construction methods, staging and lay-down areas, and other project-specific details were established to derive realistic equipment and vehicle estimates. These assumptions were developed through observation of actual practices on previous and current projects and in coordination with relevant agencies, contractors and consultants involved in the projects. Information was shared among all project sponsors enabling the most current information on truck generation, equipment usage and placement to be used in the impact assessments of each project’s contribution to cumulative effects. Estimate the Equipment and Construction Vehicle Usage – Estimates were derived for each sub-task that would generate uniform daily usage of construction equipment and construction vehicles. The estimates were based on “bottom-up” sub-task level estimates so that on-going changes to a project’s construction schedule, and the addition of any new project elements, could be incorporated into the analysis without the need to revisit original assumptions. Construction equipment estimates were further refined through the use of a “percentage use” factor that describes the proportion of any day that a particular piece of equipment can be expected to be in operation. To ensure consistency and comparability of analysis, all project sponsors used the same set of baseline traffic, pedestrian and transit conditions to perform the impact assessment. Project sponsors also exchanged existing noise level measurement and air quality data in order to develop a complete representation of existing conditions in Lower Manhattan. With respect to cultural resources, a list of Lower Manhattan resources, including historic properties and archaeological resources, were developed and submitted to New York State Historic Preservation Office (SHPO) for concurrence. A comprehensive land use database was developed for existing Lower Manhattan conditions based on the NYC Real Property Assessment Database (RPAD), which was refined and updated based on field verification. Future development scenarios for Lower Manhattan were originally developed for the WTC Memorial and Redevelopment Plan Generic EIS (GEIS). This data was then used in the MTA’s Regional Forecasting Model and shared among the Lower Manhattan project sponsors.

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For the purposes of impact assessment, scheduling and sequencing assumptions for each project reflect reasonable peak assumptions in terms of type and number of equipment, as well as concurrent construction activities. For example, for the FSTC, the assumptions include major excavation/construction and deconstruction work occurring at four (4) locations concurrently during the 2005/2006 peak construction year (see Chapter 4: Construction Methods and Activities). The construction assumptions for all Lower Manhattan Recovery Projects are included in Appendix N, and detailed FSTC construction-related truck and equipment estimates are included in Appendix C. The construction assumptions were shared among the sponsors of Lower Manhattan Recovery Projects in the Fall of 2003 and formed the basis for the cumulative effects analysis in this DEIS. This ensures that the analysis includes potential interactions and overlaps between the construction of the other Lower Manhattan Recovery Projects. NYCT is continuing its construction coordination with the other Lower Manhattan Recovery Projects, and would update the construction assumptions as appropriate.

In addition to the construction assumptions described above, the following key analysis assumptions were made for the cumulative effects analysis for FSTC:

• Recognizing that Lower Manhattan would be in an atypical “recovery mode” for several years, the conditions present prior to September 11 conditions (i.e., September 10, 2001, or as close to this date as the available data permit), are used to provide a context for assessing impacts, in addition to the conventional No-Build/Build analysis;

• The “baseline” for environmental review of construction-related impacts are adjusted to reflect, where appropriate, conditions anticipated to be in effect at the time of construction; and,

• The geographic area of analysis is the area of Lower Manhattan south of Chambers Street (see Figure 20-1) but, where appropriate, the geographic area may be adjusted for the specific resources of concern.

Coordinate Analysis Results and Implementation of EPCs – As sponsors of Lower Manhattan Recovery Projects are completing their environmental analyses and results are shared, coordination is continuing regarding more specific implementation of EPCs, as described in Chapter 4: Construction Methods and Activities. 20.4 ANALYSIS OF CUMULATIVE EFFECTS ON RESOURCES

OF CONCERN The EPCs, specific technical analysis methodologies and other assumptions for each of the identified resources of concern, as well as the results and conclusion of the analyses, are summarized in the following section.

The detailed analyses supporting the summary are presented as part of the overall impact analysis for the key resources areas in other chapters of this DEIS.

20.4.1 AIR QUALITY

COORDINATED DEVELOPMENT OF THE CUMULATIVE AIR QUALITY EFFECTS ANALYSIS (See Chapter 12 for the Comprehensive Analysis)

Coordination on the development of the air quality analysis among NYCT, FTA and the other Lower Manhattan Recovery Projects sponsors occurred through several meetings in 2003 and 2004 during which potential issues, analytical methods to address the issues and data to support the analysis were discussed.

The potential that construction activities could lead to temporary but adverse cumulative effects was recognized by the agencies. Specifically, there would be pollutant emissions from multiple stationary and mobile sources needed to construct the projects, e.g., heavy construction equipment, off-road equipment used in construction, and on-road equipment (e.g., trucks) delivering materials to the projects and transporting waste from the project sites, as well as traffic diversions and lane restrictions, that would not

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Figure 20-1

Indirect and Cumulative

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otherwise exist. The fact that much of this equipment operates on diesel fuel is of concern, because of the content of emissions produced during the fuel’s combustion (e.g., sulfur and particulate matter (PM)). Additionally, deconstruction, earthwork and vehicle movements associated with the projects’ construction typically emit dust to the atmosphere. It was also recognized by the agencies that air quality could be worsened by the overlap of the projects’ construction activities, either temporally, spatially or both. Over the long-term, the increased potential for the use of transit modes resulting from the operation of the Proposed Action, in combination with the other Lower Manhattan Recovery Projects, may contribute to an overall reduction in vehicular traffic and associated emissions. More specifically, the long-term cumulative effects on air quality from these projects are expected to be beneficial. Therefore, no further quantitative analysis of the long-term cumulative effects related to the operational level is essential. The Proposed Action’s air quality analysis methodology, including the methodology for analyzing cumulative impacts on air quality during construction, was developed and refined through these discussions. The discussions also led to the development of common EPCs for air quality for all Lower Manhattan Recovery Projects. Specifically, these EPCs include:

• Use of ultra-low sulfur diesel (ULSD) fuel in off-road construction equipment with an engine horsepower (HP) rating of 60 HP or above1;

• Where practicable, use of diesel engine retrofit technology in off-road equipment to further reduce emissions. Such technology may include Diesel Oxidation Catalyst/Diesel Particulate Filters, engine upgrades, engine replacements or combinations of these strategies;

• Limiting unnecessary idling times on diesel-powered engines to three (3) minutes; • Locate diesel-powered exhausts away from fresh air intakes; and, • Controlling dust related to the construction site through an Construction Environmental

Protection Program (CEPP), including a Soil Erosion and Sediment Control Plan that includes, among other things, spraying of a suppressing agent (non-hazardous, biodegradable) on dust piles, containing fugitive dust, and adjusting construction activities to respond to meteorological conditions, as appropriate.

NYCT has implemented an agency policy directing that contracts for capital construction projects use diesel emissions control for off-road equipment. The controls include use of the ULSD fuel and diesel particulate filters, and other retrofit technology to reduce diesel emissions. In addition, idling time for off-road and on-road equipment is limited to three (3) consecutive minutes, except in certain limited circumstances, such as the need for concrete mixing trucks to keep engines running while mixing concrete. This policy is recommended by New York State Department of Environmental Conservation (NYSDEC) and non-governmental organizations toward reducing pollutant emissions. ULSD fuel not only reduces emissions of sulfur dioxide (SO2) and related PM, but it also permits use of advanced pollution control technologies. According to the U.S. Environmental Protection Agency (EPA) implementation of a combination of both ULSD fuel and advanced pollution control technologies is expected to reduce emissions of particles from the combustion process. These EPCs are incorporated into the project’s cumulative air quality effects analysis. The potential effectiveness in reducing emissions (and improving air quality) of combining two (2) EPCs – use of ULSD fuel and diesel engine retrofit technology – is also estimated. In addition, NYCT would require the use of electrically powered equipment, where practicable. The selection of diesel retrofit technology and electrical equipment is currently being coordinated among NYCT, PANYNJ, NYSDOT and LMDC. For purposes of analysis an overall emission reduction of 50-85 percent was assumed practicable, using a range of retrofit technologies with and without electrification. A detailed description of retrofit

1 A rating of 60 HP was used, as most emissions are caused by construction equipment with a rating of 60 HP or greater. Construction equipment with a rating of substantially less than 60 HP cannot be practicably retrofitted in a cost efficient manner (e.g. the retrofit is more costly than the equipment).

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technologies considered is included in Appendix I. The need to incorporate additional project-specific measures beyond the EPCs outlined above is identified, as appropriate. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - NO ACTION ANALYSIS

There are a number of air pollutants that are of national, statewide, and regional concern. These pollutants are considered criteria pollutants and are regulated under the National Ambient Air Quality Standards (NAAQS). These pollutants include:

• Carbon Monoxide (CO); • Sulfur Dioxide (SO2); • Ozone (O3); • Lead (Pb); • Nitrogen Dioxide (NO2); and, • Particulate Matter (PM).

In New York City, ambient concentrations of CO, O3 and Pb are predominantly influenced by mobile source emissions; and emissions of NO2 come from both mobile and stationary sources. The study of pollutant emissions and air quality impacts from the FSTC project focuses on the following:

• Construction impacts of particulate matter (PM10, PM2.5, fugitive dust), CO, NO2 and other pollutants due to heavy-duty diesel vehicles or equipment, excavation and traffic diversions during the construction period;

• Stationary source effects; and, • Potential effects on mobile sources emissions.

The construction baseline for the project’s cumulative construction effects analysis consists of the estimated air quality at receptor locations in the vicinity of the FSTC site, taking into account the emissions of the other Lower Manhattan Recovery Projects in 2005/2006, excluding FSTC. Receptor locations were selected in the vicinity of the FSTC site, as this is where FSTC construction equipment and construction trucks would make the greatest contribution to pollutant concentrations. More remote locations, such as the intersection of Canal Street and Broadway, although part of the FSTC truck route, would see a contribution of only five (5) FSTC construction trucks per hour during hours of construction. The number of FSTC trucks added to Canal Street (a City approved truck route) is minor relative to the background volume of trucks at this intersection. The effects of FSTC construction trucks on the traffic flow at this intersection would, therefore, be minimal. Emissions associated with FSTC construction traffic would, therefore, not substantially affect air quality at that location or other remote (removed) locations and these locations were not analyzed. For each receptor location, the pollutant concentrations resulting from these other projects in Lower Manhattan were calculated and added to the background levels at these receptor locations. The background levels at the receptor locations were based on regional background concentrations monitored by the NYSDEC, as recommended by the New York City Department of Environmental Protection (NYCDEP). The total concentrations at the receptor locations were thus calculated for each pollutant. The use of ULSD fuel was assumed within the calculations; thus the results represent a 10 percent reduction in PM concentrations than if standard fuel were used. The emission reduction effects of other EPCs, such as engine retrofitting technologies, were not included in the initial calculations of concentrations to enable an assessment of the effects of implementing different retrofit technologies. Because the actual implementation of retrofit technologies is subject to the availability of retrofit technology at the time of construction procurement, ultimate emission reductions may vary. A detailed discussion of air quality analysis methodology and emission reduction assumptions is included in Chapter 12: Air Quality, and Appendix I.

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For each receptor location, the calculated pollutant concentrations were then compared to the NAAQS or impact thresholds to determine the potential for exceedance of these standards. The results of the analysis are summarized in Tables 12-3 through 12-6 in Chapter 12: Air Quality. The projected emissions represent both off-road/stationary and on-road mobile sources. The analysis results show that with the use of ULSD fuel, but without the use of engine retrofit technologies, the pollutant levels predicted for receptor locations within the study area would not exceed any of the NAAQS for CO (one (1)-hour and eight (8)-hour), NO2 (annual average), PM10 (PM of 10 microns or less) (24-hour and annual average) and SO2 (three (3)-hour, 24-hour, and annual average). These conditions include the emissions associated with changes in land use between 2003 and 2006 and also include the mobile and stationary source emissions associated with construction of the four (4) other Lower Manhattan Recovery Projects. As such, they represent the conditions for the No Action Alternative (without the FSTC being constructed). Air Toxics Air toxics became an air quality concern in Lower Manhattan following the events of September 11. The EPA, other Federal agencies, and New York City and New York State public health and environmental authorities, including the NYCDEP and NYSDEC, initiated numerous air quality monitoring activities to provide information on the potential air quality impacts of emissions associated with the events of September 11. The collapse of the WTC released a large amount of dust, primarily over Lower Manhattan, composed mainly of ground-up construction materials, including concrete, glass, fiberglass and asbestos. Levels of airborne dust and smoke decreased in the weeks following September 11 and the remaining concerns relate to the potential long-term health effects resulting from exposure to a range of toxic contaminants, including Pb and asbestos. EPA monitoring for numerous contaminants, including particulates, polychlorinated biphenyls (PCBs), dioxin, volatile organic compounds (VOCs), Pb and other metals, has indicated that, for most of these pollutants, monitored levels rarely exceeded protective standards. When levels did exceed the standards, they generally occurred only briefly. The City has set up a health registry to evaluate potential human health effects from September 11. As the construction of the FSTC includes the deconstruction of a number of properties and relocation of utilities which could contain PCBs, Pb and asbestos, the potential effects of these air toxics have been addressed. The assessment of the effects of PCBs, Pb and asbestos associated with the FSTC is presented in Chapter 16: Contaminated Materials and Waste Management. As described in Chapter 16, the deconstruction of properties and the relocation of utilities would be conducted in a systematic and organized manner in accordance with all applicable regulations and standards. Any hazardous substances potentially present would be identified, abated and/or managed. Any remedial activities would be conducted in accordance with EPA’s Final Rule to reduce air toxics emissions from facilities that conduct site remediation activities involving the removal of hazardous substances from contaminated media (EPA, August 20, 2003) Such activities would adhere to air toxic control measures using Maximum Achievable Control Technology (MACT) and would not result in adverse impacts. Air toxics are also present in gasoline and are emitted to air when gasoline evaporates through the engine as unburned fuel. Air toxics can also be formed as by-products of incomplete combustion from gasoline engines. Air toxics associated with construction diesel engines are mainly present in PM exhausted by such engines. The EPA implements specific control measure to minimize the emission of mobile source air toxics from gasoline engines. Such measures include fuel composition programs, such as removal of lead from gasoline, limits on gasoline volatility, and reformulated gasoline. With the implementation of these and other programs to reduce emissions of diesel particulates and hydrocarbons, overall emissions of air toxics are expected to continue to decrease. For the Lower Manhattan Federal Recovery Projects, the use of ULSD fuel is expected to reduce the emission of particulate matter and therefore also the emission of air toxics associated with such particulate matter. Emissions of air toxics would be further reduced by use of ULSD fuel in combination with EPCs that further reduce emissions of particulate matter and hydrocarbons. Given the various measures that will be implemented to reduce PM and hydrocarbon emissions on all Lower Manhattan

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Recovery projects, and by extension, the emission of diesel-related air toxics, no cumulative adverse impacts associated with air toxics are anticipated during construction of the FSTC. Air toxics may also be present in building materials such as glue, paint and floor coverings. It is anticipated that the FSTC would be constructed using low emission building materials, where practicable. Although the initial installation of such materials would release a minimal amount of pollutants, such emissions would be short-term and temporary and no adverse impacts to air quality as a result of building materials are anticipated. PM2.5 The combined construction activity of the Lower Manhattan Recovery Projects is anticipated to result in an increase of PM2.5 concentrations in the study area, resulting from emissions by construction equipment, including trucks. NYCT is committed to implementing measures to reduce PM2.5 emissions, consistent with its organizational philosophy of continuous improvement and environmental sustainability, as embodied in its ISO14001 certification (see Chapter 2: Analysis Framework), and in the spirit of the principles of the Environmental Analysis Framework for Lower Manhattan Recovery Projects; these principles were agreed upon by NYCT, PANYNJ and NYSDOT and are presented in Appendix A. To identify potential opportunities to reduce PM2.5 emissions, an analysis was conducted of the contributions of different types of nonroad construction equipment to PM2.5 concentrations in the vicinity of the FSTC. Concentrations of PM2.5 were modeled for FSTC construction activities and also for construction activities associated with the other Lower Manhattan Recovery Projects. This analysis approach provided for a primary focus on potential emission reduction measures specific to FSTC that could be directly implemented by NYCT. In addition, the analysis identified contributions to PM2.5 concentrations from other Lower Manhattan Recovery Projects, reductions of which could be developed by those projects. Notwithstanding the focus from NYCT on emission reduction measures directly applicable to FSTC, NYCT is also continuing its coordination with the other Lower Manhattan Recovery Project sponsors in developing emission reduction measures that would benefit all Lower Manhattan Recovery Projects. Construction of the FSTC would extend over a three (3)-year time frame with a peak in construction activity in 2005/2006. Intensity of the combined construction activities of the Lower Manhattan Recovery Projects is expected to peak over a relatively short period of approximately 12 months within the multi-year overall construction period. No standards are currently available for assessing the impacts of PM2.5 emissions during construction. In 1997, the EPA established NAAQS for fine particulates (PM2.5). The annual standard is 15 micrograms per cubic meter, and the 24-hour standard is 65 micrograms per cubic meter. EPA has been working with the States to collect and analyze air quality monitoring data for PM2.5 and the formal designations of nonattainment areas have not yet occurred. Formal designations are expected by the end of 2004, and States with areas so designated will have three (3) years thereafter to revise the State Implementation Plan (SIP) to address fine particulates. Therefore, at present, Federal requirements for addressing the PM2.5 as part of the SIP are not yet applicable. However, the public concern over air quality in Lower Manhattan in the aftermath of the events of September 11, 2001 has prompted the project sponsors to seek other means of assessing the PM2.5 effects of project construction. In the absence of standards for the analysis of PM2.5 emissions applicable to the New York Metropolitan Area, the values referenced in NYSDEC Commissioner’s Policy (CP)-33 (NYSDEC, 2003) were reviewed. The policy provides guidance to NYSDEC staff in the review of an application for a permit or major air permit modification under the State Environmental Quality Review Act (SEQRA). The policy defines certain de minimis thresholds for evaluating the potential for significant adverse impacts resulting from the emission of fine particulate matter. Although this guidance was developed for facility operations and not for the analysis of temporary construction activities, such as the FSTC construction, this

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guidance, in the absence of other guidance, can be used to provide a context for characterizing PM2.5 emissions from construction. The PM2.5 values included in Policy CP-33 (and similar values used by NYCDEP) are therefore presented in this chapter as a context for characterizing PM2.5 emissions from construction of the FSTC as well as cumulatively, in combination with the other Lower Manhattan Recovery Projects. If the maximum PM2.5 impacts of the project constitute more than two (2) percent of the annual NAAQS standard of 15 µg/m3, i.e., 0.3 µg/m3, or more than 5 µg/m3 on a 24-hour basis, operation of the project is considered according to CP-33 to have a potentially significant adverse impact and detailed modeling is recommended. For the PM2.5 analysis in this DEIS, the PM2.5 values were calculated as follows:

• Predicted incremental (No Build/Build) change in PM2.5 concentrations averaged over a 24-hour period at ground or elevated (above ground-level) locations (CP-33 value: incremental change greater than five (5) µg/m3;

• Predicted incremental ground-level (No Build/Build) change in PM2.5 concentrations on an annual average basis at any discrete ground-level or elevated (above ground-level) location (CP-33 value: incremental change greater than 0.3 µg/m3); and,

• Predicted incremental ground-level (No Build/Build) change in PM2.5 concentrations on an annual average neighborhood-scale basis averaged over receptors placed over a one (1) kilometer-by-one (1) kilometer grid. (NYCDEP value: incremental change greater than 0.1 µg/m3).

The changes in PM2.5 concentrations were calculated for 2005/2006, which is the peak of the combined construction activities for the Lower Manhattan Recovery Projects. These emission concentrations already reflect the reduction achieved by using only ULSD fuel for engines at 60 HP and above by the Lower Manhattan Recovery Projects. Changes in PM2.5 concentrations were calculated through computer modeling and are presented in Table 20-1. The changes in PM2.5 concentrations for the FSTC No Action condition reflect the emission contributions from the other Lower Manhattan Recovery Projects, but not the FSTC. Under No Action conditions, the change in 24-hour PM2.5 concentrations at ground level and at street-level locations would be less than the values referenced in CP-33. The change in annual PM2.5 values at ground level locations would be greater than the values referenced in CP-33 and by NYCDEP on a neighborhood-scale average. At locations above ground level, the change in annual PM2.5 concentrations would be less than or equal to the values referenced in CP-33. In the absence of standards for assessing the impacts of PM2.5 emissions during construction, the values referenced in CP-33 and by NYCDEP were included to provide a context for analysis. Implementation of construction equipment retrofit technologies by the Lower Manhattan Recovery Projects (other than the FSTC) in accordance with the EPCs would reduce the predicted values under No Action conditions. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - ESTIMATION OF CUMULATIVE CONSTRUCTION EFFECTS WITH FSTC BUILD ALTERNATIVES

Both Build Alternatives would be constructed as described in Chapter 4: Construction Methods and Activities. For the purposes of analyzing potential cumulative effects to air quality, there would not be any substantive differences between Alternatives 9 and 10. Potential impacts and mitigation measures would be similar for both Alternatives.

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Table 20-1

Predicted Increase in Ambient PM2.5 Concentrations in 2005/2006 No Action Alternative

(Includes all Lower Manhattan Recovery Projects using ULSD Fuel Only and Excluding FSTC)

24-Hour (µg/m3) Annual Avg. (µg/m3)

Increase in Ambient

Concentrations

CP-33 Value*

(NYSDEC)

Increase in Ambient

Concentrations

CP-33 Value*

(NYSDEC) (NYCDEP)

ID #: Ground Level Locations

Neighborhood-Scale Average (one (1) km x one (1) km)

--

Public Access and Sidewalk 3.0 5.0 0.4 0.1

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

1.5 0.3

B2 South of John Street (Between Broadway & Nassau Street)

0.9 0.3

B3 South of Fulton Street (Between Broadway & Nassau Street)

2.8 0.3

B4 NW Corner of Fulton Street & Nassau Streets

1.9 0.2

B5 East of Broadway (Between Fulton & Ann Streets)

2.1 0.1

B6 West of Broadway (Between Fulton & Ann Streets)

1.3 0.3

B7 West of Broadway (Between Dey & Fulton Streets)

1.6 0.0

B8 East of Church Street (Between Dey & Cortlandt Streets)

1.2 0.0

B9 West of Broadway (Between Liberty & Cortlandt Streets)

1.5 0.0

B10 East of Broadway (Between Liberty & Cedar Streets)

1.6

5.0

0.0

0.3

*Note: No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004. The cumulative construction effects analysis for the FSTC consists of the addition of FSTC construction emissions to the construction baseline emissions at the receptor locations in the vicinity of the project. These emissions are based on the detailed construction assumptions contained in Appendix C, including construction equipment usage, scheduling and construction traffic, and roadway diversions and lane closures described in Chapter 6: Traffic and Transportation. The methodology used for this analysis is the same methodology described in Chapter 12: Air Quality. The projected emissions represent both stationary and on-road mobile sources. The emissions were calculated assuming use of ULSD fuel in off-road equipment used for construction of FSTC as well as in off-road equipment used by the other Lower Manhattan Recovery Projects. The results of the air quality analysis are summarized in Tables 12-7 through 12-10 of Chapter 12 for CO, NO2, PM10 and SO2. The PM2.5 emissions are presented in Table 20-2 below.

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Table 20-2

Predicted Increase in Ambient PM2.5 Concentrations in 2005/2006 Alternative 9 / Alternative 10

(Assuming All Lower Manhattan Recovery Projects Use of ULSD Fuel Only)

24-Hour (µg/m3) Annual Avg. (µg/m3)

Increase in Ambient

Concentrations

CP-33 Value*

(NYSDEC)

Increase in Ambient

Concentrations

CP-33 Value*

(NYSDEC) (NYCDEP)

ID #: Ground Level Locations Neighborhood-Scale Average

1 km x 1 km 18.5

Public Access and Sidewalk 47.6 5.0 0.8 0.1

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

6.4 0.4

B2 South of John Street (Between Broadway & Nassau Street)

11.5 0.5

B3 South of Fulton Street (Between Broadway & Nassau Street)

12.5 0.5

B4 NW Corner of Fulton Street & Nassau Streets

15.4 0.4

B5 East of Broadway (Between Fulton & Ann Streets)

3.6 0.2

B6 West of Broadway (Between Fulton & Ann Streets)

16.5 0.5

B7 West of Broadway (Between Dey & Fulton Streets)

1.8 0.1

B8 East of Church Street (Between Dey & Cortlandt Streets)

1.8 0.1

B9 West of Broadway (Between Liberty & Cortlandt Streets)

1.9 0.1

B10 East of Broadway (Between Liberty & Cedar Streets)

2.1

5.0

0.1

0.3

* Note: No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004. As described in Chapter 12: Air Quality, the emissions from construction activities associated with Alternative 9 or 10, in combination with background emissions (including emissions of the other Lower Manhattan Recovery Projects), would not exceed any of the NAAQS for CO (one (1)-hour and eight (8)-hour), NO2 (annual average), PM10 (24-hour and annual average), and SO2 (three (3)-hour, 24-hour, and annual average). These predicted total ambient concentrations, including background concentrations, are all well below (within) the NAAQS. The analysis in Chapter 12 further shows that, despite the beneficial effects on emissions from the use of ULSD fuel, the 24-hour standard for PM10 (150.0 µg/m3) could still be exceeded at one (1) location on days with unfavorable meteorological conditions. As shown in Table 12-9, an exceedance of PM10 is predicted at the northeast corner of Broadway and Fulton Street (218.4 µg/m3). It should be noted that this modeling location is within the work zone during the widening of the AC mezzanine under Fulton

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Street and therefore not always in a publicly accessible area. To reflect a more publicly accessible location nearby, additional modeling was conducted for the location at the public sidewalk on the northwest corner of Broadway and Fulton Street. A near-exceedance of 148.9 µg/m3 was predicted for this location. PM2.5 Under Alternatives 9 and 10, the change in 24-hour PM2.5 concentrations (as shown in Table 20-2) at all ground level locations and at five (5) of the 10 above-ground level locations would be greater than the values referenced in CP-33. The change in annual PM2.5 concentrations at ground level locations would be greater than the values referenced in CP-33 and by NYCDEP on a neighborhood-scale average. At locations above ground level, the change in annual PM2.5 concentrations would be greater than the values referenced in CP-33 at five (5) of the 10 locations analyzed. In the absence of standards for assessing the impacts of PM2.5 emissions associated with construction activities, the values referenced in CP-33 and by NYCDEP were included to provide a context for analysis. The results presented above already reflect the emission reduction benefits of using only ULSD fuel in off-road construction equipment of 60 HP and above. Implementation of construction equipment retrofit technologies could reduce emissions further, as discussed below. Emission Reduction Scenarios for FSTC As described in Section 12-2, and consistent with the EPCs, NYCT is committed to implementing retrofit technologies where practicable, to further reduce emissions. This would entail requiring that all nonroad construction equipment of 60 HP and above on site be Tier 22 compliant and reduce PM2.5 emissions by as much as 85 percent of the Tier 2 emission standard, using technologies such as Diesel Particulate Filters (DPFs). These technologies have been demonstrated to achieve a reduction by more than 90 percent on certain construction equipment. Where it can be demonstrated that such reduction cannot be practicably achieved, a minimum reduction by 50 percent of the Tier 2 standard would be considered, for example, by using technologies such as Diesel Oxidation Catalysts (DOCs), or other technologies. NYCT would also require that electrically-powered equipment be used on site instead of diesel powered equipment, where practicable. A combination of these measures is expected to render substantial reductions in emissions of NO2 and PM. NYCT is committed to working with FTA, the other project sponsors and the construction industry to create opportunities for emission reduction. Other opportunities for emission reduction would be investigated by NYCT in coordination with the FTA and the sponsors of other Lower Manhattan Recovery Projects in the course of developing and constructing the project, e.g., in the event other technological advances are made, in an effort to minimize the construction effects on air quality. Specific measures would be translated into construction specifications for the FSTC to ensure that the goals identified during the environmental review are met during construction to the greatest extent practicable. To provide an indication of the potential benefits of emission reduction measures for the 24-hour PM2.5 concentrations, computer modeling was conducted to simulate the upper and lower range of the three (3) emission reductions scenarios: 1) Tier 2 Equipment with 85 percent reduction; 2) Tier 2 Equipment with 50 percent reduction and 3) Tier 2 Equipment with 50 percent reduction plus electrification of compressors, pumps, welding equipment and diesel generators. The three (3) scenarios above were first modeled for 24-hour PM2.5 with the assumption that retrofit technologies to reduce emissions would only be applied to the FSTC and South Ferry Terminal projects

2 On October 23, 1998, U.S.EPA issued the “Control of Emissions of Air Pollution From Nonroad Diesel Engines; Final Rule” (40 C.F.R. Parts 9, 86, and 89) that finalized the emissions standards for engines in two tiers (Tier 2 and Tier 3). The standards for engines become effective in the 2001 to 2006 time frame for Tier 2 levels and in the 2006 to 2008 time frame for Tier 3 levels.

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and not to the other Lower Manhattan Recovery Projects (except for the use of ULSD fuel). The results of these scenarios are presented in tables 20-3, 20-4 and 20-5. To reflect the potential benefits of coordinated emission reduction measures among the Lower Manhattan Recovery Projects, the same three (3) scenarios were then modeled for PM2.5 with the same assumptions for FSTC and the South Ferry Terminal projects, but assuming for modeling purposes a preliminary 50 percent Tier 2 emission reduction for each of the other Lower Manhattan Recovery Projects. The results of these scenarios are presented in tables 20-6, 20-7 and 20-8. Although this is an approximation, it does provide an indication of the relevance of emission reduction by the other projects for the emissions concentrations in the vicinity of the FSTC. NYCT is coordinating with the sponsors of other Lower Manhattan Recovery Projects on a routine basis to develop emission reduction measures, similar to the coordination efforts undertaken for the development of EPCs earlier in the Proposed Action. This coordination is undertaken from the perspective that the success of any of the Lower Manhattan Recovery Projects in reducing emissions can be substantially enhanced by coordination with the reduction measures of the other projects, to the greater benefit of the Lower Manhattan environment. The anticipated range of potential emission reduction for the other Lower Manhattan Recovery Projects is currently being investigated and coordinated and when established would be reflected in subsequent modeling for FSTC. An overview of the benefits of emission reduction for NO2, PM10 and PM2.5, with and without emission reduction by the other Lower Manhattan Recovery Projects, is presented in Table 20-9, Conditions A and B. This table shows the maximum concentration or – in the case of PM2.5 – the maximum change in concentration among all receptor locations modeled. The results of the modeling of each of the three (3) FSTC retrofit scenarios, for each condition, for the receptor locations with the maximum concentrations of NO2 PM10 and PM2.5 are discussed below. As indicated in Table 20-9, within publicly accessible areas, even for the receptors with the highest predicted pollutant concentrations (as calculated with the use of ULSD fuel only), concentrations of NO2 and PM10 would remain within NAAQS, under all scenarios examined. The emission reduction analysis results presented in Table 20-9 for various engine retrofit scenarios are described below. First the results of the three (3) scenarios are described for Condition A which assumes: no emission reduction by the Permanent WTC PATH Terminal, the Route 9A Project and the WTC Memorial and Redevelopment Plan (except for the use of ULSD fuel). This is followed by a discussion of the three (3) scenarios for Condition B which assumes: the other Lower Manhattan Recovery Projects would include 50 percent emission reduction. Condition A: Assuming no emission reduction by the other Lower Manhattan Recovery Projects (except South Ferry Terminal) Scenario 1- 85 percent Tier 2 FSTC retrofit:

• Annual NO2: Under an 85 percent Tier 2 FSTC retrofit scenario, a highest level of 74.7 µg/m3 is predicted at the Broadway & Fulton Street location. Other locations would be lower. The maximum concentration would be below the NAAQS of 100 µg/m3.

• 24-hour PM10: Under an 85 percent Tier 2 retrofit scenario, a highest level of 65.9 µg/m3 is

predicted at the Broadway & Fulton Street location work zone. Other locations would be lower. The maximum concentration would be below the NAAQS of 150 µg/m3.

• 24-hour PM2.5: Under an 85 percent Tier 2 retrofit scenario, a highest cumulative increase in

concentration of 13.6 µg/m3 is predicted at the Broadway & Fulton Street – Vesey Street location. Other locations would be lower. This maximum cumulative increase in concentration at the Broadway & Fulton Street – Vesey Street location would be higher than the CP-33 value of five

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Table 20-3

Predicted Increase in 24-hour Ambient PM2.5 Concentrations in 2005/2006 Scenario 1

FSTC & South Ferry Terminal 85% Reduction From Tier 2 Standard (All Lower Manhattan Recovery Projects Using ULSD Fuel)

(No Additional Emission Reduction for Other Recovery Projects)

Increase in Ambient Concentration From

FSTC.* (µg/m3)

Cumulative Increase in Ambient

Concentration. ** (µg/m3)

CP-33 Value (NYSDEC)***

(µg/m3)

ID #: Ground Level Locations G1 Broadway & Liberty Street 0.77 5.66 G2 Broadway & Cortlandt Street 2.89 8.21 G3 Broadway & John/Dey Streets 2.15 10.28 G4 Broadway & Fulton Street 4.07 8.68 G5 Broadway & Vesey Street 1.82 13.58 G6 Broadway & Barclay Street 1.04 12.60 G7 Nassau & Fulton Streets 1.31 5.45

5.0

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

0.34 3.15

B2 South of John Street (Between Broadway & Nassau Street)

0.79 4.27

B3 South of Fulton Street (Between Broadway & Nassau Street)

0.53 5.36

B4 NW Corner of Fulton & Nassau Streets 0.72 5.17

B5 East of Broadway (Between Fulton & Ann Streets)

0.31 2.52

B6 West of Broadway (Between Fulton & Ann Streets)

0.88 6.61

B7 West of Broadway (Between Dey & Fulton Streets)

0.21 1.07

B8 East of Church Street (Between Dey & Cortlandt Streets)

0.03 1.32

B9 West of Broadway (Between Liberty & Cortlandt Streets)

0.02 1.71

B10 East of Broadway (Between Liberty & Cedar Streets)

0.03 1.53

5.0

* NYCT would adopt engine retrofit and a policy that limits maximum PM emission rate from engines 60 HP and above not to exceed a rate of 85% reduction from EPA Tier 2 standard. ** No reduction beyond the use of ULSD fuel assumed for other Lower Manhattan projects (LMDC, PATH, 9A); Same emission reduction assumed for South Ferry Terminal as for FSTC. ***No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004.

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Table 20-4

Predicted Increase in 24-hour Ambient PM2.5 Concentrations in 2005/2006 Scenario 2

FSTC & South Ferry Terminal 50% Reduction From Tier 2 Standard (All Lower Manhattan Recovery Projects Using ULSD Fuel)

(No Additional Emission Reduction for Other Recovery Projects)

Increase in Ambient Concentration From

FSTC.* (µg/m3)

Cumulative Increase in Ambient

Concentration** (µg/m3)

CP-33 Value (NYSDEC)***

(µg/m3)

ID #: Ground Level Locations G1 Broadway & Liberty Street 2.01 5.67 G2 Broadway & Cortlandt Street 7.36 8.79 G3 Broadway & John/Dey Streets 6.30 14.43 G4 Broadway & Fulton Street 10.47 10.74 G5 Broadway & Vesey Street 4.86 13.70 G6 Broadway & Barclay Street 2.75 12.67 G7 Nassau & Fulton Streets 3.64 6.94

5.0

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

0.89 3.22

B2 South of John Street (Between Broadway & Nassau Street)

2.08 4.64

B3 South of Fulton Street (Between Broadway & Nassau Street)

1.35 6.15

B4 NW Corner of Fulton & Nassau Streets 1.93 6.10

B5 East of Broadway (Between Fulton & Ann Streets)

0.85 2.53

B6 West of Broadway (Between Fulton & Ann Streets)

2.22 6.66

B7 West of Broadway (Between Dey & Fulton Streets)

0.54 1.08

B8 East of Church Street (Between Dey & Cortlandt Streets)

0.09 1.37

B9 West of Broadway (Between Liberty & Cortlandt Streets)

0.05 1.73

B10 East of Broadway (Between Liberty & Cedar Streets)

0.08 1.58

5.0

* NYCT would adopt engine retrofit and a policy that limits maximum PM emission rate from engines 60 HP and above not to exceed a rate of 50% reduction from EPA Tier 2 Standard. ** No reduction beyond the use of ULSD fuel assumed for other Lower Manhattan projects (LMDC, PATH, 9A). ***No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004.

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May 2004 20.0 Cumulative Effects 20-19

Table 20-5

Predicted Increase in 24-hour Ambient PM2.5 Concentrations in 2005/2006 Scenario 3

FSTC & South Ferry Terminal 50% Reduction From Tier 2 Standard Plus Electric Equipment***

(All Lower Manhattan Recovery Projects Using ULSD Fuel) (No Additional Emission Reduction for Other Recovery Projects)

Increase in Ambient Concentration From

FSTC* (µg/m3)

Cumulative Increase in Ambient

Concentration** (µg/m3)

CP-33 Value (NYSDEC) ****

(µg/m3)

ID #: Ground Level Locations G1 Broadway & Liberty Street 1.67 5.66 G2 Broadway & Cortlandt Street 5.97 8.59 G3 Broadway & John/Dey Streets 4.80 12.92 G4 Broadway & Fulton Street 8.61 10.09 G5 Broadway & Vesey Street 3.99 13.66 G6 Broadway & Barclay Street 2.28 12.65 G7 Nassau & Fulton Streets 2.88 6.44

5.0

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

0.72 3.20

B2 South of John Street (Between Broadway & Nassau Street)

1.70 4.50

B3 South of Fulton Street (Between Broadway & Nassau Street)

1.11 5.89

B4 NW Corner of Fulton & Nassau Streets 1.57 5.83

B5 East of Broadway (Between Fulton & Ann Streets)

0.69 2.52

B6 West of Broadway (Between Fulton & Ann Streets)

1.82 6.64

B7 West of Broadway (Between Dey & Fulton Streets)

0.45 1.08

B8 East of Church Street (Between Dey & Cortlandt Streets)

0.07 1.35

B9 West of Broadway (Between Liberty & Cortlandt Streets)

0.04 1.72

B10 East of Broadway (Between Liberty & Cedar Streets)

0.07 1.56

5.0

* NYCT would adopt engine retrofit and a policy that limits maximum PM emission rate from engines 60 HP and above not to exceed a rate of 50% reduction from EPA Tier 2 Standard. ** No reduction beyond the use of ULSD fuel assumed for other Lower Manhattan projects (LMDC, PATH, 9A) *** Electrical Power For Welding Machine, Generator, Pump, and Compressor ****No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004.

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May 2004 20.0 Cumulative Effects 20-20

Table 20-6

Predicted Increase in 24-hour Ambient PM2.5 Concentrations in 2005/2006 Scenario 1

FSTC & South Ferry Terminal 85% Reduction From Tier 2 Standard (All Lower Manhattan Recovery Projects Using ULSD Fuel)

(50% Reduction From Tier 2 Standard for Other Recovery Projects)

Increase in Ambient Concentration From

FSTC* (µg/m3)

Cumulative Increase in Ambient

Concentration** (µg/m3)

CP-33 Value (NYSDEC) ***

(µg/m3)

ID #: Ground Level Locations G1 Broadway & Liberty Street 0.77 3.02 G2 Broadway & Cortlandt Street 2.89 4.51 G3 Broadway & John/Dey Streets 2.15 6.49 G4 Broadway & Fulton Street 4.07 5.10 G5 Broadway & Vesey Street 1.82 7.01 G6 Broadway & Barclay Street 1.04 6.42 G7 Nassau & Fulton Streets 1.31 3.95

5.0

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

0.34 1.69

B2 South of John Street (Between Broadway & Nassau Street)

0.79 2.36

B3 South of Fulton Street (Between Broadway & Nassau Street)

0.53 3.07

B4 NW Corner of Fulton Street & Nassau Streets

0.72 2.95

B5 East of Broadway (Between Fulton & Ann Streets)

0.31 1.33

B6 West of Broadway (Between Fulton & Ann Streets)

0.88 3.49

B7 West of Broadway (Between Dey & Fulton Streets)

0.21 0.58

B8 East of Church Street (Between Dey & Cortlandt Streets)

0.03 0.71

B9 West of Broadway (Between Liberty & Cortlandt Streets)

0.02 0.91

B10 East of Broadway (Between Liberty & Cedar Streets)

0.03 0.82

5.0

* Assumption: NYCT would adopt engine retrofit and a policy that limits maximum PM emission rate from engines 60 HP and above not to exceed a rate of 85% reduction from EPA Tier 2 Standard. ** Other Lower Manhattan projects (LMDC, PATH, 9A) would use 50% emission reduction ***No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004.

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May 2004 20.0 Cumulative Effects 20-21

Table 20-7

Predicted Increase in 24-hour PM2.5 Concentrations in 2005/2006 Scenario 2

FSTC & South Ferry Terminal 50% Reduction From Tier 2 Standard (All Lower Manhattan Recovery Projects Using ULSD Fuel)

(50% Reduction From Tier 2 Standard for Other Recovery Projects)

Increase in Ambient Concentration From

FSTC* (µg/m3)

Cumulative Increase in Ambient

Concentration** (µg/m3)

CP-33 Value (NYSDEC) ***

(µg/m3)

ID #: Ground Level Locations G1 Broadway & Liberty Street 2.01 3.15 G2 Broadway & Cortlandt Street 7.36 7.55 G3 Broadway & John/Dey Streets 6.30 10.64 G4 Broadway & Fulton Street 10.47 10.53 G5 Broadway & Vesey Street 4.86 8.89 G6 Broadway & Barclay Street 2.75 7.17 G7 Nassau & Fulton Streets 3.64 7.29

5.0

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

0.89 2.09

B2 South of John Street (Between Broadway & Nassau Street)

2.08 2.75

B3 South of Fulton Street (Between Broadway & Nassau Street)

1.35 3.87

B4 NW Corner of Fulton & Nassau Streets 1.93 3.89

B5 East of Broadway (Between Fulton & Ann Streets)

0.85 1.72

B6 West of Broadway (Between Fulton & Ann Streets)

2.22 4.03

B7 West of Broadway (Between Dey & Fulton Streets)

0.54 1.46

B8 East of Church Street (Between Dey & Cortlandt Streets)

0.09 0.97

B9 West of Broadway (Between Liberty & Cortlandt Streets)

0.05 1.05

B10 East of Broadway (Between Liberty & Cedar Streets)

0.08 1.04

5.0

* Assumption: NYCT would adopt engine retrofit and a policy that limits maximum PM emission rate from engines 60 HP and above not to exceed a rate of 50% reduction from EPA Tier 2 Standard. ** Other Lower Manhattan projects (LMDC, PATH, 9A) would use 50% emission reduction ***No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004.

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Table 20-8 Predicted Increase in Ambient PM2.5 Concentrations in 2005/2006

Scenario 3 FSTC & South Ferry Terminal 50% Reduction From Tier 2 Standard Plus Electrical Equipment

(All Lower Manhattan Recovery Projects Using ULSD Fuel) (50% Reduction From Tier 2 Standard for Other Recovery Projects)

Increase in Ambient Concentration From

FSTC* (µg/m3)

Cumulative Increase in Ambient

Concentration** (µg/m3)

CP-33 Value (NYSDEC) ***

(µg/m3)

ID #: Ground Level Locations G1 Broadway & Liberty Street 1.67 3.12 G2 Broadway & Cortlandt Street 5.97 7.32 G3 Broadway & John/Dey Streets 4.80 9.14 G4 Broadway & Fulton Street 8.61 9.83 G5 Broadway & Vesey Street 3.99 8.81 G6 Broadway & Barclay Street 2.28 7.15 G7 Nassau & Fulton Streets 2.88 6.89

5.0

Building Air Intakes and Elevated Receptors

B1 East of Broadway (Between John & Cortlandt Streets)

0.72 2.07

B2 South of John Street (Between Broadway & Nassau Street)

1.70 2.65

B3 South of Fulton Street (Between Broadway & Nassau Street)

1.11 3.67

B4 NW Corner of Fulton & Nassau Streets 1.57 3.61

B5 East of Broadway (Between Fulton & Ann Streets)

0.69 1.71

B6 West of Broadway (Between Fulton & Ann Streets)

1.82 4.00

B7 West of Broadway (Between Dey & Fulton Streets)

0.45 1.45

B8 East of Church Street (Between Dey & Cortlandt Streets)

0.07 0.95

B9 West of Broadway (Between Liberty & Cortlandt Streets)

0.04 1.04

B10 East of Broadway (Between Liberty & Cedar Streets)

0.07 1.02

5.0

* Assumption: NYCT would adopt engine retrofit and a policy that limits maximum PM emission rate from engines 60 HP and above not to exceed a rate of 50% reduction from EPA Tier 2 Standard and Electrical Power ** Other Lower Manhattan projects (LMDC, PATH, 9A) assumed to apply 50% emission reduction ***No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004.

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Table 20-9 Predicted Maximum Total Concentrations (µg/m3) for NO2,, PM10 and Maximum Increase for PM2.5

Under Emission Reduction Scenarios in 2005/2006

Emission Scenario Analyzed Assumptions for Other Projects***

Max. NO2 Annual

Max. PM10 24-Hour

Max. Increase in PM2.5 24-Hour Concentration

NAAQS 100.0

NAAQS 150.0

CP-33 Value (NYSDEC) ****

5.0 Background Concentration 70.0 49.0 N/A

No Action Alternative* ULSD fuel

No Retrofit for Other Lower Manhattan Recovery Projects

75.2 Broadway at

John

53.8 Broadway at

Vesey

3.0 Broadway at

Vesey

FSTC Build Alternatives (ULSD fuel only)** - public

sidewalk

ULSD fuel No Retrofit for Other Lower

Manhattan Recovery Projects

82.0

Broadway at Fulton

148.5

Broadway at Fulton

47.6

Broadway at Fulton

CONDITION A: FSTC Emission Reduction Scenarios - Without Retrofits for Other Recovery Projects

Scenario 1: FSTC Build Alternatives &

South Ferry Terminal with 85% Tier 2 Retrofit of FSTC**

ULSD fuel No Retrofit for other Lower

Manhattan Recovery Projects

74.7 Broadway at

Vesey

65.9 Broadway at

Vesey

13.6 Broadway at

Vesey

Scenario 2: FSTC Build Alternatives &

South Ferry Terminal with 50% Tier 2 Retrofit of FSTC**

ULSD fuel No Retrofit for Other Lower

Manhattan Recovery Projects

78.9 Broadway at

John

67.0 Broadway at

John

14.4 Broadway at

John

Scenario 3: FSTC Build Alternatives &

South Ferry Terminal with 50% Tier 2 Retrofit of FSTC and Selective Electrification**

ULSD fuel No Retrofit for Other

Lower Manhattan Recovery Projects

77.6 Broadway at

Vesey

66.1 Broadway at

Vesey

13.7 Broadway at

Vesey

CONDITION B: FSTC Emission Reduction Scenarios - Assuming Retrofits for Other Recovery Projects

Scenario 1: FSTC Build Alternatives &

South Ferry Terminal with 85% Tier 2 Retrofit of FSTC**

ULSD fuel Retrofit with 50% Reduction for

Other Lower Manhattan Recovery Projects***

72.9 Broadway at

Vesey

63.0 Broadway at

Vesey

7.0

Broadway at Vesey

Scenario 2:

FSTC Build Alternatives & South Ferry Terminal with 50%

Tier 2 Retrofit of FSTC**

ULSD fuel Retrofit with 50% Reduction for

Other Lower Manhattan Recovery Projects ***

77.0

Broadway at John

64.1

Broadway at John

10.6

Broadway at John

Scenario 3: FSTC Build Alternatives &

South Ferry Terminal with 50% Tier 2 Retrofit of FSTC and Selective Electrification**

ULSD fuel Retrofit with 50% Reduction for

Other Lower Manhattan Recovery Projects***

75.3 Broadway at

Fulton

63.2 Broadway at

Fulton

9.8

Broadway at Fulton

*: Receptor locations studied are near FSTC site **: Assume NYCT engine retrofit and emission reduction policy would apply to FSTC and South Ferry Terminal projects only ***: Retrofit emission reduction measures for other Lower Manhattan Recovery Projects are under coordination. For those projects, a preliminary 50% emission reduction was assumed for analysis purposes and subject to change. ****No standards for PM2.5 emissions from construction activities are currently available. The following values are included as a context for analysis: 1) predicted incremental increase of PM2.5 concentration greater than five (5) µg/m3 averaged over a 24-hour period at ground or elevated locations; 2) predicted incremental increase of PM2.5 concentration on an annual average basis greater than 0.3 µg/m3 at any elevated location. 3) NYSDEC/NYCDEP values: predicted incremental increase of PM2.5 concentration greater than 0.1 µg/m3 on an annual average basis calculated in New York City on a neighborhood–scale basis. Source: The Louis Berger Group, Inc., 2004.

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May 2004 20.0 Cumulative Effects 20-24

(5) µg/m3. The predicted highest increase in concentration resulting from FSTC construction is 4.07 µg/m3 and would be less than the CP-33 value of five (5) µg/m3. The CP-33 value was not developed for construction activities and is included for context only.

Scenario 2 - 50 percent Tier 2 FSTC retrofit:

• Annual NO2: Under a 50 percent Tier 2 FSTC retrofit scenario, a highest level of 78.9 µg/m3 is predicted at the Broadway & Fulton Street location. Other locations would be lower. The maximum concentration would be below the NAAQS of 100 µg/m3.

• 24-hour PM10: Under a conservative 50 percent Tier 2 retrofit scenario, a highest level of 67.0

µg/m3 is predicted at the Broadway & Fulton Street location work zone. Other locations would be lower. The maximum concentration would be below the NAAQS of 150 µg/m3.

• 24-hour PM2.5: Under a 50 percent Tier 2 retrofit scenario, a highest increase in concentration of

14.4 µg/m3 is predicted at the Broadway & Fulton Street – John Street location work zone. At other locations the increase in concentration would be less. The increase at the Broadway & Fulton Street – John Street location work zone would be higher than the value referenced in CP-33 (five (5) µg/m3). The CP-33 value was not developed for construction activities and is included for context only.

Scenario 3 - 50 percent Tier 2 plus Selective Electrification FSTC retrofit:

• Annual NO2: Under this FSTC retrofit scenario, a highest level of 77.6 µg/m3 is predicted at the Broadway & Fulton Street location. Other locations would be lower. The maximum concentration would be below the NAAQS of 100 µg/m3.

• 24-hour PM10: Under this retrofit scenario, a highest level of 66.1 µg/m3 is predicted at the

Broadway & Fulton Street location work zone. Other locations would be lower. The maximum concentration would be below the NAAQS of 150 µg/m3.

• 24-hour PM2.5: Under this retrofit scenario, a highest increase of 13.7 µg/m3 is predicted at the

Broadway & Fulton Street – Vesey Street location. Other locations would be lower. The maximum increase in concentration at the Broadway & Fulton Street – Vesey Street location would be higher than CP-33 value of five (5) µg/m3. The CP-33 value was not developed for construction activities and is included for context only.

Condition B: Assuming 50 percent emission reduction by the other Lower Manhattan Recovery Projects Scenario 1 - 85 percent Tier 2 FSTC retrofit:

• Annual NO2: Under an 85 percent Tier 2 FSTC retrofit scenario, a highest level of 72.9 µg/m3 is predicted at the Broadway & Fulton Street location. Other locations would be lower. The maximum concentration would be below the NAAQS of 100 µg/m3.

• 24-hour PM10: Under an 85 percent Tier 2 retrofit scenario, a highest level of 63.0 µg/m3 is

predicted at the Broadway & Fulton Street location work zone. Other locations would be lower. The maximum concentration would be below the NAAQS of 150 µg/m3.

• 24-hour PM2.5: Under an 85 percent Tier 2 retrofit scenario, a highest cumulative increase of

seven (7) µg/m3 is predicted at the Broadway & Fulton Street – Vesey Street location. Other locations would be lower. This maximum cumulative increase in concentration at the Broadway & Fulton Street – Vesey Street location would be higher than the CP-33 value of five (5) µg/m3.

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May 2004 20.0 Cumulative Effects 20-25

The predicted highest increase resulting from FSTC construction alone is 4.07 µg/m3. This would be below the CP-33 value of five (5) µg/m3. The CP-33 value was not developed for construction activities and is included for context only

Scenario 2 - 50 percent Tier 2 FSTC retrofit:

• Annual NO2: Under a 50 percent Tier 2 FSTC retrofit scenario, a highest level of 77.0 µg/m3 is predicted at the Broadway & Fulton Street location. Other locations would be lower. The maximum concentration would be below the NAAQS of 100 µg/m3.

• 24-hour PM10: Under a 50 percent Tier 2 retrofit scenario, a highest level of 64.1 µg/m3 is

predicted at the Broadway & Fulton Street location work zone. Other locations would be lower. The maximum concentration would be below the NAAQS of 150 µg/m3.

• 24-hour PM2.5: Under a 50 percent Tier 2 retrofit scenario, a highest increase of 10.6 µg/m3 is

predicted at the Broadway & Fulton Street – John Street location work zone. Other locations would be lower. The maximum increase in concentration at the Broadway & Fulton Street – John Street location work zone would be greater than the CP-33 value of five (5) µg/m3. The CP-33 value was not developed for construction activities and is included for context only

Scenario 3 - 50 percent Tier 2 plus Selective Electrification FSTC retrofit:

• Annual NO2: Under this FSTC retrofit scenario, a highest level of 75.3 µg/m3 is predicted at the Broadway & Fulton Street location. Other locations would be lower. The maximum concentration would be below the NAAQS of 100 µg/m3.

• 24-hour PM10: Under this retrofit scenario, a highest level of 63.2 µg/m3 is predicted at the

Broadway & Fulton Street location work zone. Other locations would be lower. The maximum concentration would be below the NAAQS of 150 µg/m3.

• 24-hour PM2.5: Under this retrofit scenario, a highest increase of 9.8 µg/m3 is predicted at the

Broadway & Fulton Street – Vesey Street location. Other locations would be lower. The maximum increase in concentration at the Broadway & Fulton Street – Vesey Street location would be greater than the CP-33 value of five (5) µg/m3.

Summary of Construction Condition Impact Analysis In summary, the impact analysis results show that the emissions from construction activities associated with the FSTC, in combination with background emissions, would not exceed any of the NAAQS for the following pollutants:

• CO (one (1)-hour and eight (8)-hour); • NO2 (annual average); • PM10 (24-hour and annual average), and; • SO2 (three (3)-hour, 24-hour, and annual average).

The increases in average 24-hour PM2.5 concentrations in the vicinity of the project can be reduced substantially during construction by using a combination of ULSD fuel and diesel engine retrofit technology and electrification for off-road equipment that are incorporated as part of the project. Conclusion Regarding Construction Cumulative Impacts: Air Quality The analysis shows that, cumulatively, regulated pollutant concentrations of CO, NO2, PM10 and SO2 would not exceed NAAQS. No standards are currently available for PM2.5 emissions from construction. In

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the absence of such standards, the values referenced in NYSDEC Policy CP-33 (developed for project operation) are included as a context for PM2.5 analysis. The maximum increase in PM2.5 concentrations would be greater than the 24-hour CP-33 value, but could be reduced by implementing a range of emission reduction measures. The combined use of ULSD fuel, diesel engine retrofit technology, and selective electrification for FSTC (and the South Ferry Terminal) would reduce PM and NO2 emissions of the FSTC construction equipment. The predicted maximum cumulative concentration for affected pollutants would be reduced accordingly. As PM2.5 emissions from the FSTC are reduced, the PM2.5 emissions from other Lower Manhattan Recovery Projects become the dominant contributors to PM2.5 concentrations at FSTC receptor locations. The PM2.5 levels at FSTC receptor locations can be further reduced when the other Lower Manhattan Recovery Projects are also assumed to include emission reduction measures, reflecting the cumulative benefit of these measures. It is anticipated that similar reductions would occur at receptor locations not near the FSTC but in the vicinity of the other Lower Manhattan Recovery Projects implementing combined emission reduction measures. In addition to the EPCs already incorporated in the project, other measures would be investigated by NYCT in coordination with the FTA and the other project sponsors in the course of developing and constructing the project, e.g., in the event other technological advances are made, in an effort to further minimize the construction effects on air quality. 2008 - SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

The main contributors to air quality at the receptor locations for the FSTC consist of the construction activities for the Permanent WTC PATH Terminal, south of Church Street and the construction of the WTC Memorial, further south toward Route 9A. By 2008, the Permanent WTC PATH Terminal would be past its 2005/2006 construction peak and the WTC Memorial would have been completed. As construction emissions (from construction trucks and construction equipment) in the immediate vicinity of the FSTC receptor locations would be reduced past its 2005/2006 peak, air quality is expected to improve over 2005/2006 conditions. 2008 - SHORT TERM OPERATIONAL CONDITIONS - ESTIMATION OF CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES

As discussed earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. Operation of the FSTC in 2008 would not generate vehicular traffic; therefore no further mobile source analysis for operational impacts is warranted. Operation of the FSTC would provide improved transit access to Lower Manhattan, thereby supporting economic growth while reducing the potential environmental burden associated with the increase in traffic typically associated with such growth. The FSTC would provide alternate environmentally-friendly transportation options for residents, visitors and workers. A flexible, safe, convenient and attractive transit system in Lower Manhattan would provide the capacity needed during peak hours to provide: an easy commute for workers to and from Lower Manhattan’s centers of commercial activity; a safe and reliable travel mode for residents (in particular families and residents with disabilities), during all times of the day and week; and an easily navigable system for visitors to Lower Manhattan’s many memorable sites. As described in Chapter 12: Air Quality, a screening analysis was conducted of stationary source emissions of the FSTC during operation, associated with heating, ventilation and air conditioning (HVAC) systems. The analysis indicated that operational emissions of the FSTC would be insubstantial and no further analysis was warranted. In 2008, several of the Lower Manhattan Recovery Projects would still be under construction, as described above, and construction truck traffic associated with these projects would affect the overall flow of traffic in Lower Manhattan, causing temporary congested conditions and thereby affecting local

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air quality. The FSTC, through its Dey Street Passageway and Entry Facility, would relieve pedestrian congestion at street-levels especially at key crossings at Church Street and Broadway. This would also reduce conflicts of pedestrian movement with traffic, including construction traffic associated with Lower Manhattan Recovery Projects still under construction in 2008 and especially during morning and evening rush hours. Reduced congestion would also contribute to a reduction in pollutants being emitted by vehicles. In summary, it is anticipated that compared to the condition without the FSTC in 2008, the FSTC would have a beneficial cumulative effect on air quality in Lower Manhattan in 2008, although this effect would be incremental and not measurable. 2025 SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

The baseline analysis assumes that by 2025 all the other Lower Manhattan Recovery Projects would have been constructed and operating for several years, but that the FSTC would not have been constructed and that the conditions at the Fulton Street - Broadway Nassau Station Complex (Existing Complex) would essentially remain as existing, with the exception of regular maintenance measures. By 2025, the area in the immediate vicinity of the Existing Complex area and beyond would have undergone substantial changes in land use compared to pre- and post-September 11 conditions, as described in Chapter 7: Social and Economic Conditions. Lower Manhattan by 2025 is expected to have returned to the economic growth levels projected that year pre-September 11. Land uses in Lower Manhattan are expected to have diversified, following the trend established pre-September 11 and accelerated post-September 11. The economic growth of Lower Manhattan through 2025 would have led to an increase in vehicular traffic (see Chapter 6: Traffic and Transportation), resulting in an increase in vehicular emissions over 2008. Pedestrian congestion at Broadway and Church Street, resulting from commuters crossing these streets during the morning and evening rush hour, is expected to increase further over 2008 conditions, as the WTC site by 2025 would have been fully developed and the Permanent WTC PATH Terminal would have been operational for many, resulting in greater numbers of commuters crossing these busy streets. This could result in more congested vehicular traffic conditions, resulting in greater emissions of pollutants through 2025 and beyond. Certain improvements to transportation functionality would have been realized by 2025, including the Permanent WTC PATH Terminal and the South Ferry Terminal Project, helping to reduce emissions from vehicular traffic. However, the congested conditions at the Existing Complex would be exacerbated further due to the increase in patronage expected as a result of economic growth through 2025 and the continued absence of a modern facility to accommodate this growth (see Chapter 6: Traffic and Transportation). Over a period of more than two (2) decades, Lower Manhattan would have continued to function with an increasingly congested and outdated transit connection to the major commute hubs and other parts of the subway system. As a result, opportunities to reduce vehicular emissions as a result of improved transit would not have been realized over a period of almost two (2) decades. 2025 - LONG TERM OPERATIONAL CONDITIONS - ESTIMATION OF OPERATION CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES

As discussed earlier, potential impacts and mitigation measures would be similar for both Build Alternatives. As a result, both Build Alternatives are presented under this discussion. The FSTC would not generate vehicular traffic; therefore no further mobile source analysis is warranted. With the FSTC in operation since 2008, Lower Manhattan would have been functioning with a modern, easily navigable transportation facility for almost two (2) decades, with excellent connections to the regional commuter hubs. Operation of the FSTC would have contributed during this period to reduced

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pedestrian congestion at sidewalks and street crossings, beneficially affecting the flow of traffic and thereby helping to reduce emissions associated with traffic congestion. It would also have contributed to the perception that Lower Manhattan is a location to work, live and enjoy recreation that is easily accessible via a public transportation system that is modern, easily navigable and in close proximity to key destinations. The availability of such a public transportation system would have contributed to economic growth through increased mobility and helped reduce the environmental burden associated with vehicular travel. As described in Chapter 12: Air Quality, a screening analysis was conducted of stationary source emissions of the FSTC during operation, associated with HVAC. The analysis indicated that operational emissions of the FSTC would be insubstantial and no further analysis was warranted. 20.4.2 PEDESTRIAN AND VEHICULAR ACCESS AND CIRCULATION

(See Chapter 6 for Comprehensive Analysis)

COORDINATED DEVELOPMENT OF THE CUMULATIVE ACCESS AND CIRCULATION EFFECTS ANALYSIS

Under this discussion, both Build Alternatives 9 and 10 would be constructed as described in Chapter 4: Construction Methods and Activities. For the purposes of analyzing potential cumulative effects to pedestrian and vehicular access and circulation, there would not be any substantive differences between Alternatives 9 and 10. Potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. Coordination on the development of the access and circulation analysis among NYCT, FTA and the other Lower Manhattan Recovery Project sponsors occurred through several meetings in 2003 and 2004 during which potential issues, analytical methods to address the issues, and data to support the analysis were discussed. As a result of these meetings, traffic, parking, transit, and pedestrian data, analyses results and methodologies were shared by the project sponsors to minimize redundant efforts and to promote consistency between the projects. In terms of construction, truck routes, truck assignment, truck quantities, construction schedules, Maintenance and Protection of Traffic (MPT) plans and EPCs proposed for each project were coordinated and compiled for the FSTC DEIS. These data were shared with the other project sponsors and provided consistency between the projects. As for potential issues, it was concluded through these discussions that the effects of the events of September 11 resulted in temporary impacts on access to and circulation within Lower Manhattan. As a result, Lower Manhattan is now faced with balancing the progression of previously planned transportation improvements with the actions required to reconstruct and replace damaged and destroyed transportation infrastructure. This circumstance has the potential to result in temporary, short-term construction impacts, including cumulative effects, on businesses and residents both in terms of reduced accessibility and mobility (e.g., from roadway, sidewalk, and subway station access restrictions) as well as the associated implications for air quality and economic vitality. The short-term potential for construction impacts is greatest in locations where projects would overlap in the same geographic area, or occur at the same or overlapping time periods. The traffic analyses performed for the construction condition considered changes that would result from the addition of construction vehicle traffic to the roadway network and associated construction activities (i.e., lane closures, street closures, detours, etc.) for each of the project sponsors. The NYCDOT’s roadway reconstruction projects were also considered as part of this analysis. The assignment of construction vehicles to the Lower Manhattan traffic network was based on coordination among the sponsors of Lower Manhattan Recovery Projects as well as NYCDOT, in Summer and Autumn 2003, with the objective to minimize impacts of truck traffic on the local roadway network. This was achieved by optimizing the use of existing NYCDOT truck routes and by limiting the overlap of truck routes for each project.

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It was also concluded through these discussions that, over the long-term, there would be an increased potential for the use of transit modes resulting from the project in combination with the other Lower Manhattan Recovery Projects. This circumstance has the potential to result in long-term beneficial impacts, including cumulative impacts, on businesses and residences in terms of improved accessibility and mobility in Lower Manhattan, as well as associated implications for businesses (e.g., from additional pedestrian traffic near transit facilities). More specifically, the long-term cumulative effect on access and circulation is expected to be lessened. No further analysis of this effect is necessary. The project’s traffic, transit and pedestrian analysis methodology, including the methodology for analyzing cumulative impacts on access and circulation during construction, was developed for these discussions and was refined through these discussions. The discussions also led to the development of common EPCs for access and circulation for the Lower Manhattan Recovery Projects. Specifically, these EPCs include:

• Establish a project-specific pedestrian and vehicular maintenance and protection plan; • Promote public awareness through such mechanisms as signage, telephone hotline, and web-site

updates; • Ensure sufficient alternate street building, and station access during the construction period; and, • Communicate regularly with the NYCDOT and participate in that agency’s construction

coordination efforts. The need to incorporate additional project-specific measures beyond the EPCs outlined above is identified and analyzed, as appropriate. Additional information on the MPT plans is included in the Chapter 4: Construction Methods and Activities. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - NO ACTION ANALYSIS

The cumulative construction baseline analysis for the No Action condition (without the FSTC) was performed using the following assumptions, which were developed in coordination with the other Lower Manhattan Recovery Project sponsors (see Appendix N). A 16-hour work day (7 AM to 11 PM) was assumed for the South Ferry Terminal Project. A 10-hour work day (7 AM to 5 PM) was assumed for the WTC Redevelopment Plan, Route 9A, and the Permanent WTC PATH Terminal reconstruction projects. The primary travel route used for the South Ferry Terminal Project would be Broadway and Church Street. For the WTC, Route 9A, and the Permanent WTC PATH Terminal reconstruction projects, the primary travel route would be Route 9A. Based on these work schedules and construction routes, the construction vehicles projected to be generated by the other Lower Manhattan Recovery Projects (South Ferry Terminal, WTC, Route 9A, and the Permanent WTC PATH Terminal reconstruction) in 2006 were added to the No Action traffic network, and balanced 2006 No Action traffic flow volumes were developed for the weekday AM and PM peak hours. This analysis is described in more detail in Chapter 6: Traffic and Transportation, and Appendix D. With regard to construction employee traffic, the Lower Manhattan Recovery Projects are not anticipated to provide parking for most workers and most construction employees would therefore be expected to travel to and from work by public transportation. Shift hours for construction employees typically fall outside the standard peak hours for background traffic and employee trips were therefore not included in the construction peak hour traffic volumes. Furthermore, based upon the high volume of truck trips that have been assumed to arrive and depart each construction site during the peak hours, an employee shift change occurring simultaneously would be unlikely. Consequently, the volume of construction truck traffic and their operating characteristics would have a greater influence on traffic Level of Service (LOS) than employee vehicle trips and, consequently, govern the traffic analyses. As most employees would be traveling by public transportation, parking is not anticipated to be an issue. NYCT’s preference for construction worker mass transit use would be expressed in construction contract bid processes.

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2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - ESTIMATION OF CUMULATIVE CONSTRUCTION EFFECTS WITH FSTC BUILD ALTERNATIVES

As discussed earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. Traffic The 2005/2006 cumulative condition was developed by adding the projected FSTC construction vehicles to the 2005/2006 construction baseline condition volumes. A 16-hour work day (7 AM to 11 PM) was assumed for the FSTC Project. The FSTC construction truck volumes account for approximately 15 percent of the total volume of daily peak construction vehicles projected for the Lower Manhattan Recovery Projects (including FSTC) in 2005/2006 (see Chapter 6, Table 6-12). Use of public transportation by construction workers for FSTC would be a contractual requirement. The primary travel routes to be used by the FSTC construction vehicles would be Broadway and Church Street. A total of 26 key intersections were identified to describe the existing transportation network and assess potential impacts. They were selected based on proximity to the proposed FSTC, roadway traffic volumes, the relationship to critical air quality receptor locations, and the potential effect of construction activities on each intersection. The locations of the intersections studied are presented in Chapter 6, Figure 6-1. The following 26 intersections (24 signalized and two (2) unsignalized) were selected for traffic analysis within the project study area: Signalized Intersections

• Chambers Street and Route 9A; • Chambers Street and West Broadway/Hudson Street; • Chambers and Church Streets; • Chambers Street and Broadway; • Church and Barclay Streets; • Church and Vesey Streets; • Church and Fulton Streets; • Church and Dey Streets; • Church and Cortlandt Streets; • Broadway and Barclay Street; • Broadway and Vesey Street/Park Row; • Broadway and Fulton Street; • Broadway and John/Dey Streets; • Broadway and Cortlandt Street/Maiden Lane; • Nassau and Fulton Streets; • Pearl and R. Wagner Streets; • Pearl and Frankfort/Dover Streets; • Pearl and State Streets; • Water and Fulton Streets; • Water Street and Maiden Lane; • Water and Broad Streets; • South Street and Old Slip; • Water Street and Old Slip; and, • Battery Place/State Street.

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Unsignalized Intersections

• South Street and Maiden Lane; and, • John and Nassau Streets.

This analysis is described in more detail in Chapter 6: Traffic and Transportation, and Appendix D. The analysis considers changes that would result from the addition of construction vehicle traffic to the roadway network. The cumulative effect on traffic, pedestrian and parking conditions was assessed by analyzing whether the effects on streets, pedestrian routes and parking facilities from FSTC construction activities could affect the use of streets, pedestrian routes and parking facilities by the other Lower Manhattan Recovery Projects, for example, whether FSTC construction activities would result in diversion of traffic to other streets, including those affected by other Lower Manhattan Recovery Projects. Delay increases are relatively minor and, with the exception of two (2) intersections, are all within the tolerance of 10 seconds. Two (2) of the intersections studied are projected to experience delays of more than 10 seconds, an initial threshold of potential impact as defined by NYSDOT. In 2006, the northbound through movement of the Church and Dey Streets intersection is projected to increase by more than 10 seconds during the AM peak hours, as a result of projected FSTC construction vehicles. However, the change from LOS “A” to “B” would not meet the threshold for an impact. The Broadway and Cortlandt Street intersection is projected to increase by more than 10 seconds during the PM peak hours, as a result of projected FSTC construction vehicles. Again, the change in LOS from “C” to “D” would not meet the threshold for an impact. In summary, none of the intersections is forecast to experience an adverse impact. Construction of either of the alternatives of the FSTC would directly affect traffic on Broadway, Fulton and Dey Streets. Fulton Street is an important retail corridor and pedestrian street in Lower Manhattan, connecting the South Street Seaport to the east with the WTC site to the west. Fulton Street has also increasingly seen conversions of commercial office buildings to residential use. Broadway is an important vehicular and pedestrian north-south route in Lower Manhattan and provides one of the few direct vehicular connections between Lower Manhattan and destinations to the north. It is also an important retail and commercial corridor. Dey Street is an important street as it provides a key pedestrian connection from Church Street to Broadway and destinations further east. It is also the location of Century 21, a major discount department store at Dey and Church Streets. John Street, which may incur some impacts from construction activities related to the Corbin Building, is becoming increasingly a residential street as a result of conversions of commercial properties to residential use. The construction of the FSTC requires the closure of Dey Street to through traffic and parking between Church Street and Broadway and the closure of Fulton Street between Broadway and Nassau Street. In addition, construction staging areas are proposed for the east side of Broadway between Fulton and John Streets, the north side of John Street between Broadway and Nassau Street, and the east side of Church Street between Cortlandt and Fulton Streets. Traffic projected to use Dey and Fulton Streets was reassigned to alternate routes in the study area. It was assumed that southbound Broadway and northbound Church Street between Vesey and Cortlandt Streets would be limited to two (2) travel lanes in each direction with no parking lane or exclusive bus lane. A vehicular travel lane would be provided on Dey and Fulton Streets in the construction zone for emergency access/local deliveries and sidewalks would be provided on the north side and south side of the street for building access/egress. The MPT plans for vehicular and pedestrian traffic during construction would be subject to review and approval by the NYCDOT Office of Construction Mitigation and Coordination (OCMC). Preliminary MPT plans are currently being developed and coordinated with NYCDOT and have been included in Appendix C of this DEIS. The construction of the Alternative 9 would eliminate most of the ground floor retail fronting on the east side of Broadway between Fulton and John Streets, limiting the need for truck access.

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Parking All of the roadway and lane closures proposed as part of the FSTC construction activities would remove curb loading and unloading from the study area. However, no on-street parking spaces for vehicles would be lost as a result of these curb closures. The closure of Dey Street for the passageway project element between Church Street and Broadway to through vehicles eliminates truck access to Century 21 and other businesses. A portion of the total Dey Street right-of-way would be used to maintain a vehicular travel lane for emergency access/local deliveries. Alternative loading areas could also be established on the west side of Broadway or the north side of Cortlandt Street during construction. Access to Dey Street could also be provided at the extreme east or west end of Dey Street during the various stages of construction. On-street parking is not permitted for private vehicles on the section of Fulton Street between Broadway and Nassau Street. Some of the curb activity would continue to park illegally in the future without the FSTC construction. Because only illegal parking would be eliminated along this section of Fulton Street during construction, there would be no impact to parking as a result. The closure of Fulton Street between Broadway and Nassau Street would also disrupt truck access to the local businesses. A portion of the total Fulton Street right-of-way would be used to maintain a vehicular travel lane for emergency access/local deliveries. Access to Fulton Street could also be provided at the extreme east or west end of the street during the various stages of construction. The construction of Alternative 9 would eliminate most of the street-level retail fronting on the east side of Broadway between Fulton and John Streets, limiting the need for truck access. The curb activities conducted on the north side of John Street between Broadway and Nassau Street and the east side of Church Street between Cortlandt and Fulton Streets could be relocated to adjacent curb locations. (The construction of the Alternative 9 would eliminate most of the street-level retail fronting on the east side of Broadway between Fulton and John Streets, limiting the need for truck access). As indicated above, construction of the FSTC is not expected to result in adverse impacts on parking conditions. The curb activity projected during construction in 2006 is depicted in Figure 6-8, in Chapter 6: Transportation and Traffic, at the WTC site for the Permanent WTC PATH Terminal; the WTC Memorial and Redevelopment Plan would be largely self-contained due to the size of the site and opportunities for parking. In addition, based upon off-street parking projections for the FSTC study area, there would be a midday surplus of approximately 378 spaces. These spaces would be able to accommodate construction workers for the Permanent WTC PATH Terminal, WTC Memorial and Redevelopment Plan, and Route 9A Reconstruction projects that elected to drive their vehicles to the area to work that could not be accommodated on site. None of the parking activities associated with these three (3) projects would create cumulative effects on parking in combination with the FSTC. Transit Operations and Station Elements Without the FSTC, transit conditions and pedestrian flow inside the Existing Complex in 2006 would continue to be problematic with several of the station elements (stairs, platform, etc.) operating at LOS E or F even with lower than pre-September 11 levels of patronage in 2006. Partial and intermittent closures of some stations, existing pedestrian pathways, fare control areas and stairways would occur even with careful selection of the method and phasing of construction. Where new routes cannot be constructed in advance, temporary pedestrian pathways would be provided. Some existing, part-time fare control areas and stairways may require temporary conversion to full time. Substantial planning would also be required to direct passengers safely around construction and public outreach is needed to alert them to alternative transit options. Temporary transfer paths through existing spaces that are undergoing substantial reconstruction would be provided through protected corridors. Additionally, opportunities to open new spaces before they are finished to provide temporary pedestrian pathways would be investigated. For example, after deconstruction of the buildings between John and Fulton Streets, the newly constructed basement of the Transit Center building is being investigated for use

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as a key temporary transfer between the AC and the 45. Temporary corridors through this basement would be developed to protect the patrons from the continuing construction overhead. This temporary transfer would eliminate the heavy congestion at the north end of the 45 platform and facilitate its reconfiguration and rehabilitation. During the construction period, some station elements may accommodate diverted flows from partial or complete closures of other station elements. The effect is that some station elements would operate with higher congestion then projected in the 2006 No Action Alternative. NYCT would develop MPT plans that would minimize congested conditions to the greatest extent possible. Construction work would be scheduled and performed as part of NYCT’s regular program for scheduling service diversions for construction projects. Some customers may experience slightly longer travel times on nights and/or weekends as a result of the construction at FSTC. Pedestrians Because pedestrian flows are anticipated to shift from Dey Street (which is projected to be under construction in 2006) to Cortlandt and Fulton Streets, some crosswalk flows are projected to increase and some are projected to decrease as a result. During the AM peak period, four (4) crosswalks are projected to worsen in terms of pedestrian flow while five (5) are projected to improve. Since the congestion increases projected at some crosswalk locations in 2006 (as a result of pedestrian diversions during the construction period) would be temporary and are offset by improvements at other crosswalk locations, the increases in congestion are not considered adverse. Pedestrian flow along Fulton and Dey Streets would be maintained throughout the duration of construction. However, these streets would be closed to through vehicular traffic. In absence of through vehicular traffic, adequate accommodations could be made through construction site layout to provide space for pedestrian circulation functionally equivalent to the No Action Alternative. During the AC mezzanine widening under Fulton Street, sidewalk pedestrians would be affected. Because of the small lot buildings and heavy street-level retail, it is necessary to provide continuous access to all of the adjacent uses. Through pedestrians can divert to either Ann Street to the north or to Maiden Lane to the south. The construction and staging activities proposed along the west side of the proposed FSTC Entry Building between Fulton and John Streets would require the use of a portion of the existing east side sidewalk on Broadway. To offset the loss of sidewalk space at this location, the eastern curb lane on Broadway between Fulton and John Streets would be used to provide the requisite pedestrian flow. A MPT plan would be developed to separate traffic flows and pedestrian flows. Access to the NYCT Subway stations would also be maintained throughout the duration of construction. During construction, special accommodations would be made to not encumber Americans with Disabilities Act (ADA) access on Broadway, Fulton or Dey Streets by providing ADA compliant ramp systems and sidewalk surface treatment. It is possible that pedestrians (and especially PATH patrons) choose Fulton Street (between Church Street and Broadway) and John Street (between Broadway and Nassau Street) over Dey and Fulton Streets to travel east-west during the morning rush hour. Because economic activity in Lower Manhattan is still below pre-September 11 conditions in 2005/2006 it is not anticipated that any overflow to these streets would result in conditions worse than pre-September 11 conditions. NYCT would address safety issues associated with pedestrian circulation in 2006 by developing detailed MPT Plans in coordination with PANYNJ, LMDC, NYSDOT, NYCDOT and the New York City Department of Design and Construction (NYCDDC) to minimize interruption of vehicular and pedestrian circulation. A key aspect of these efforts would be pedestrian safety. Measures to be considered during the development of the detailed MPT plans would include a clear pedestrian signage system, physical demarcations and/or barriers for dedicated pedestrian zones, Traffic Enforcement Agents (TEA) to direct vehicular and pedestrian circulation, especially during peak hours, management of truck delivery

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schedules, both associated with construction activities and operation of existing businesses in the area and strict enforcement of parking rules to minimize crowding of narrower east-west streets. NYCT would require from its contractors that sheds be constructed over temporary sidewalks to ensure pedestrian safety. Pedestrian access to, from and between all modes of travel, including subway and bus in the vicinity of the project would be maintained throughout the duration of construction. Access to the subway system would be maintained during construction through minor schedule adjustments of subway lines as is commonly done for NYCT rehabilitation projects. Most schedule adjustments would be temporary and limited to weekends when subway volumes are low. Conclusion Regarding Construction Cumulative Impacts: Pedestrian and Vehicular Access and Circulation The analysis shows that, cumulatively, construction-related traffic is not expected to adversely affect access and circulation in the vicinity of the project during construction. Implementation of the common EPCs would further improve access and circulation above the levels estimated in the analysis. Project specific EPCs would be investigated by NYCT in the course of developing, constructing and monitoring the project in an effort to minimize the construction effects on access and circulation. 2008 - SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

Traffic Under No Action conditions, no traffic would be generated by the Existing Complex. Changes in land use by 2008 and an overall rebound of development in Lower Manhattan are expected to result in increases in background traffic volumes, as described in Chapter 6, Section 6A: Traffic and Parking. However, by 2008, the construction of several of the other Lower Manhattan Recovery Projects would have been completed, while the remainder would be past their construction peaks. As a result, the congestion associated with the construction of the other Lower Manhattan Recovery Projects would decrease compared to the congestion experienced in 2005/2006, when these projects were at their combined construction peak. As described in Chapter 6A: Traffic and Parking, the number of signalized intersections analyzed that are projected to operate at an unacceptable LOS E or F would decrease from 17 percent in 2006 to 15.5 percent in 2008 during the morning peak hour and from 10.2 percent to 5.1 percent during the evening peak hour. Parking In 2008, without the FSTC, the number of off-street facilities located in the vicinity of the Existing Complex would have sufficient reserve capacity to accommodate the projected background parking growth in the study area. Transit Operations and Station Elements Without the FSTC, transit conditions and pedestrian flow inside the Existing Complex in 2008 would remain as problematic as in 2006, with almost 13 percent of the station elements (stairs, platform, etc.) operating at LOS E or F even with lower than normal levels of patronage, as Lower Manhattan would not yet be fully redeveloped by 2008. Surface Pedestrians In absence of the FSTC, pedestrian conditions are expected to further deteriorate in the vicinity of the Existing Complex in 2008, compared to conditions in 2005/2006. Without the FSTC, the number of intersections analyzed with a pedestrian LOS of E or F during the AM or PM peak periods would increase

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from eight (8) to nine (9), indicating increased congestion. The west approach at the Church and Vesey Streets intersection is projected to operate at LOS F during the PM peak hour. 2008 - SHORT TERM OPERATIONAL CONDITIONS - ESTIMATION OF CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES

As discussed earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. Traffic Construction of the FSTC would be completed by 2007, and in 2008 the FSTC would have been in operation for its first full year. No vehicular traffic is projected to be generated by both build alternatives in 2008, and neither one would therefore create adverse impacts on traffic conditions in 2008. Operation of the FSTC in 2008 would provide improved transit access to Lower Manhattan, thereby supporting economic growth while reducing the potential environmental burden associated with the increase in traffic typically associated with such growth. The FSTC would provide alternate transportation options for residents, visitors and workers. A flexible, safe, convenient, and attractive transit system in Lower Manhattan would provide the capacity needed during peak hours to provide an easier commute for workers to and from Lower Manhattan’s centers of commercial activity; a safe and reliable travel mode to for residents, and in particular families and residents with disabilities, during all times of the day and week; and an easily navigable system for visitors to Lower Manhattan’s many attractions and tourist destinations. Parking In 2008 with the FSTC, off-street facilities in the vicinity of the Existing Complex are projected to have sufficient capacity in 2008. Neither one of the Build Alternatives would create an increase in parking demand. Transit Operations and Station Elements With the FSTC, transit conditions and pedestrian flow would improve substantially. Without the FSTC almost 13 percent of the station elements (stairs, platform, etc.) would operate at LOS E or F in 2008. As described in more detail in Chapter 6B: Transit and Pedestrians, both Build Alternatives would eliminate all LOS E and F conditions through the entire FSTC, reflecting a major improvement in pedestrian flow. By 2008, full realization of the benefits would not yet be achieved, as Lower Manhattan would not yet be fully redeveloped and the subway system would continue to operate with lower than normal levels of patronage. However, patrons would enjoy a much improved subway system that is more easily navigable, safer and much more accessible, resulting in the reduction of travel time. In particular, the FSTC would be better accessible for people with disabilities, via new ADA-compliant elevators from the street to the subway system, as well as ADA-compliant platform connections within the system. Pedestrians In 2008, a portion of the pedestrians currently traversing Broadway and Church Street would be expected to use the Dey Street Passageway. As the amount of pedestrian traffic crossing these streets would be reduced, relative to the 2008 baseline, circulation conflicts between pedestrian and vehicular traffic are less likely to occur, especially because the subsurface Dey Street Passageway substantially reduces the number of street-level pedestrians during the morning and evening rush hour and thereby improves crosswalk LOS in the study area. This would also contribute to a better flow of vehicular traffic, including construction traffic associated with the Lower Manhattan Recovery Projects that would still be

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under construction in 2008. As street-level pedestrian congestion would be reduced, this would create a more pleasant and safer pedestrian environment, especially for children and people with disabilities. In summary, it is anticipated that compared to the condition without the FSTC, the FSTC would have a beneficial cumulative effect on access and circulation in Lower Manhattan in 2008. 2025 SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

The baseline analysis assumes that by 2025 all the other Lower Manhattan Recovery Projects would have been constructed and operating for several years, but that the FSTC would not have been constructed and that the physical conditions at the Existing Complex would essentially remain as they are today, with the exception of regular maintenance measures. Traffic By 2025, the area in the immediate vicinity of the Existing Complex area and beyond would have undergone substantial changes in land use compared to pre- and post-September 11 conditions, as described in Chapter 7: Social and Economic Conditions. Lower Manhattan by 2025 is expected to have returned to the economic growth levels projected for that year pre-September 11. Land uses in Lower Manhattan are expected to have diversified, following the trend established pre-September 11 and accelerated post-September 11. The economic growth of Lower Manhattan through 2025 would have led to a substantial increase in vehicular traffic (see Chapter 6A: Traffic and Parking). As described in Chapter 6A: Traffic and Parking, the number of signalized intersections analyzed with an unacceptable LOS “E” or “F” would increase from 5.1 percent during the evening peak hour in 2008 to 14.3 percent during the evening peak hour in 2025. Parking In 2025 without the FSTC, off-street facilities in the vicinity of the Existing Complex are projected to have sufficient capacity. Transit Operations and Station Elements Without the FSTC, transit conditions and pedestrian flow inside the Existing Complex in 2025 would continue to deteriorate, as the Existing Complex would be increasingly inadequate to accommodate the increase in pedestrian flow associated with the full revitalization and renewed economic growth of Lower Manhattan. Without the FSTC, approximately 17 percent of the station elements (stairs, platform, etc.) would operate at LOS E or F in 2025 during the morning peak period. Pedestrians Pedestrian congestion at Broadway and Church Street associated with commuters crossing these streets during the morning and evening rush hour, is expected to increase further over 2008 conditions, as the WTC site by 2025 would have been fully developed and the Permanent WTC PATH Terminal would have been operational for many years, resulting in greater numbers of commuters crossing these busy streets. As described in more detail in Chapter 6B: Transit and Pedestrians, this is likely to result in more congested vehicular traffic conditions through 2025 and beyond. Among the intersections analyzed in the vicinity of the Existing Complex, approximately 42 percent were found to have at least one (1) crosswalk approach operating at LOS E or F during the AM and 50 percent during the PM peak periods in 2025 without the FSTC. The west approach at the Church and Vesey Streets intersection is projected to operate at LOS F during the AM and PM peak hours. Certain improvements to transportation functionality would have been realized by 2025, including the Permanent WTC PATH Terminal and the South Ferry Terminal Project, helping to reduce vehicular

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traffic congestion. However, the congested flow conditions at the Existing Complex would be exacerbated further due to the increase in patronage expected as a result of economic growth through 2025 and the continued absence of a modern facility to accommodate this growth (see Chapter 6B: Transit and Pedestrians). Over a period of more than two (2) decades, Lower Manhattan would continue to function with an increasingly congested and outdated transit connection to the major commute hubs and other parts of the subway system. As a result, opportunities to improve mobility associated with the FSTC would not have been realized over a period of almost two (2) decades. 2025 - LONG TERM OPERATIONAL CONDITIONS - ESTIMATION OF OPERATION CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES

As discussed earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. Traffic By 2025, the area in the immediate vicinity of the Existing Complex area and beyond would have undergone substantial changes in land use compared to pre- and post-September 11 conditions, as described in Chapter 7: Social and Economic Conditions. Lower Manhattan by 2025 is expected to have returned to the economic growth levels projected for that year pre-September 11. Land uses in Lower Manhattan are expected to have diversified; following the trend established pre-September 11 and accelerated post-September 11. The economic growth of Lower Manhattan through 2025 would have led to an increase in vehicular traffic (see Chapter 6A: Traffic and Parking), as described for the baseline conditions above. The FSTC Build Alternatives in 2025 would have been providing improved transit access to Lower Manhattan, thereby supporting economic growth while reducing the potential traffic congestion associated with such growth. The FSTC would provide alternate transportation options for residents, visitors and workers. A flexible, safe, convenient and attractive transit system in Lower Manhattan would provide the capacity needed during peak hours to provide an easier commute for workers to and from Lower Manhattan’s centers of commercial activity; a safe and reliable travel mode to for residents, and in particular families and residents with disabilities, during all times of the day and week; and an easily navigable system for visitors to Lower Manhattan’s attractions and tourist destinations. Parking In 2025 with the FSTC, off-street facilities in the vicinity of the Existing Complex are projected to have sufficient capacity. Neither one of the Build Alternatives would create an increase in parking demand. Transit Operations and Station Elements With the FSTC, transit conditions and pedestrian flow inside the Facility Entry would have been operating at substantially improved levels for almost two (2) decades. Without the FSTC, approximately 17 percent of the station elements (stairs, platform, etc.) would operate at LOS E or F in 2025 during the morning peak period. As described in more detail in Chapter 6B: Transit and Pedestrians, both Build Alternatives would eliminate all LOS E and F conditions throughout the entire Existing Complex, indicating a major improvement in pedestrian flow. By 2025 Lower Manhattan would have been fully redeveloped and would have resumed the economic growth projected pre-September 11. The economic growth of Lower Manhattan during the preceding decades would have been supported by a much improved subway system that is more easily navigable, safer and much more accessible. This would result in the reduction of travel time by an estimated 900,000 hours per year for all commuters combined using the FSTC. In particular, the FSTC would have been providing better accessibility for people with disabilities, via new ADA-compliant elevators from the street to the subway system, as well as ADA-compliant platform connections within the system. ADA

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access, where none now exists, would be provided among all stations (45, AC, 23, JMZ) in one of the system’s busiest station complexes. This would facilitate fullest participation in Lower Manhattan’s economic and cultural resources, and increased ability for all to reside in Lower Manhattan. Surface Pedestrians By 2025, a portion of the pedestrians currently traversing Broadway and Church Street would have been using the Dey Street Passageway for almost two (2) decades. The Dey Street Passageway is adequately sized to accommodate the substantial increase in pedestrian traffic associated with the redevelopment of the WTC site and PATH commuters. As an unpaid passageway, the Dey Street Passageway would benefit both patrons of the subway system and other pedestrians traveling east or west between Church Street and Broadway. The diversion of pedestrians using the crosswalks in the No Action condition to the subsurface Dey Street Passageway substantially reduces the number of street-level pedestrians during the morning and evening rush hour and thereby improves crosswalk LOS in the study area. This would also contribute to a better flow of vehicular traffic, expected to increase in volume as a result of continued economic growth in Lower Manhattan through 2025. As street-level pedestrian congestion would be reduced, this would create a more pleasant and safer pedestrian environment, especially for children and people with disabilities. In summary, it is anticipated that, compared to condition without the FSTC in 2025, the FSTC would have a beneficial cumulative effect on access and circulation in Lower Manhattan in 2025. 20.4.3 NOISE AND VIBRATION

(See Chapter 13 for Comprehensive Analysis)

COORDINATED DEVELOPMENT OF THE CUMULATIVE NOISE AND VIBRATION EFFECTS ANALYSIS

Build Alternatives 9 and 10 would be constructed as described in Chapter 4: Construction Methods and Activities. For the purposes of analyzing potential cumulative effects to noise and vibration levels, there would not be any substantive differences between Alternatives 9 and 10. Potential impacts and mitigation measures would be similar for both Alternatives and the discussion below applies to both Build Alternatives, unless otherwise indicated. Coordination on the development of the noise and vibration analysis among NYCT, FTA and the other Lower Manhattan Recovery Project sponsors occurred through several meetings in 2003 and 2004 during which potential issues, analytical methods to address the issues, and data to support the analysis were discussed. As for potential issues, it was concluded through these discussions that reconstruction and Recovery Projects associated with transportation infrastructure could potentially cause changes to existing noise and vibration levels, and could result in both short-term and long-term cumulative effects. Construction activities in the same geographic vicinity or occurring at the same time, or both, could result in short-term cumulative effects to noise- and vibration-sensitive receptors, e.g., residences. Long-term cumulative effects could result either directly from enhanced service (whether buses or rapid transit) or indirectly from changes in traffic patterns in the area. None of these impacts are anticipated for the FSTC, since there are no proposed changes to bus or subway services in the immediate vicinity as part of the FSTC. The existing bus and subway services have been incorporated into this cumulative effects analysis. Based on information discussed under Access and Circulation, the traffic and pedestrian flows in the area would be substantially improved over the No Action condition. It is anticipated that the total traffic volumes in the future would return to “normal” level that is similar to those of pre-September 11, due to

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the redevelopment and economic growth of the Lower Manhattan area over time under both the No Action and Action Alternatives. Since the noise would be mostly attributable to traffic on the streets in Lower Manhattan, the long-term noise levels in the area would be identical between the No Action and Action Alternatives. Consequently, there would be no long-term cumulative adverse effects as a result of the Proposed Action. The project’s noise and vibration methodology, including the methodology for analyzing cumulative impacts from noise and vibration during construction was developed and refined through these discussions. The discussions also led to the development of common EPCs for noise and vibration for the Lower Manhattan Recovery Projects. Specifically, these EPCs include:

• Where practicable, schedule individual project construction activities to avoid or minimize adverse impacts;

• Coordinate construction activities with projects under construction in adjacent and nearby locations to avoid or minimize impacts;

• Consider condition of surrounding buildings, structures, infrastructure, and utilities, where appropriate; and,

• Prepare contingency measures in the event established limits are exceeded. These EPCs are incorporated into the project’s cumulative noise and vibration effects analysis, where practicable. The need to incorporate additional project-specific measures beyond the EPCs outlined above is identified and analyzed, as appropriate. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - NO ACTION ANALYSIS

Noise Based on existing noise level measurements conducted in the area adjacent to the proposed FSTC site, existing noise levels ranged between 63 and 85 dBA. Existing noise levels are consistently above 65 dBA during most of the daytime and evening hours and represent typical urban conditions. The major noise sources are vehicular traffic, including commuter buses, delivery and garbage trucks, helicopters, emergency sirens and human voices. In 2003, 24-hour noise measurements were conducted at the following locations:

• Site No. 1: Historical church, northwest corner of Broadway & Fulton Street. • Site No. 2: Commercial/Office Historical building, 195 Broadway. • Site No. 3: Hotel, Hilton Millenium Hotel-Dey Street. • Site No. 4: Commercial building, Century 21– Cortlandt Street entrance. • Site No. 5: Residences, 180 Broadway. • Site No. 6: Residences, Fulton Street between Broadway & Nassau Street. • Site No. 7: Residences, 80 Nassau Street. • Site No. 8: Residences, 118 Fulton Street. • Site No. 9: Residences, 10 John Street.

These sites were selected for noise measurements based on existing and anticipated future land use conditions (see Chapter 13, Figure 13-1 and Table 13-6). Generally, the sites were chosen on the basis of proximity to the proposed FSTC site (i.e. Broadway, Fulton Street, Dey Street, John Street and Nassau Street), and proximity to sensitive land uses and potential increase in future noise levels. These sites are primarily located at mid-block, rather than intersections, in order to better represent residential, institutional, and other representative receptors in the project area. Detailed descriptions of each noise measurement site are presented in Appendix J, Part I.

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Because the predominant noise sources in the project area are traffic on adjacent streets, the existing noise levels were proportionally adjusted based on traffic volume differences between existing 2003 and pre-September 11 conditions in order to estimate the noise levels of pre-September 11 condition. As a result of the proportional study, the pre-September 11 noise levels were estimated ranging between 64 and 85 dBA. The cumulative construction baseline analysis consists of the estimated noise levels at receptor locations in the vicinity of the project attributed to the other Lower Manhattan Recovery Projects in 2005/2006, not including the FSTC. Noise levels from background construction activities, including both mobile and stationary sources, were evaluated based on detailed construction methods and schedules developed for those projects (see Chapter 4: Construction Methods and Activities and Appendix C). All traffic-related sources, including traffic rerouting/diversion, were evaluated as part of the mobile sources. All construction equipment at the construction site was evaluated as stationary sources. Noise level increases are presented under mobile sources and stationary sources sections below. Noise from Mobile Sources Noise levels from mobile sources (including both commuter and construction related traffic on adjacent streets, e.g. truck hauling, vehicles driving to/from construction site, traffic detouring and diversions, etc.) under No Action conditions in 2005/2006 would increase over existing 2003 levels due to increased traffic associated with construction of the other Lower Manhattan Recovery projects and new development in the study area. The increase in Passenger Car Equivalents (PCEs) between 2003 and the No Action Alternative in 2006 would range between four (4) and 64 percent at all nine (9) receptor locations. The increases in PCEs translate to imperceptible dBA increases between 0.2 dBA and 2.1 dBA, all of which are less than the FTA criteria of 90 dBA. Compared to pre-September 11 levels, traffic volumes (PCEs) and associated noise levels in 2005/2006 would decrease or remain unchanged at five (5) of the nine (9) receptor locations. The four (4) remaining sites (ID Nos. 2, 5, 7, and 9 in Appendix J, Part II) would have PCE increases ranging from less than one (1) percent to over 43 percent. The PCE increases translate to imperceptible increases of up to 1.6 dBA from pre-September 11 condition. Since the noise levels of pre-September 11 condition were less than 85 dBA, it is, therefore, estimated that the noise levels associated with mobile sources under No Action would be less than 86.6 dBA, which is less than FTA criteria of 90 dBA, at all nine (9) receptor sites evaluated. In conclusion, there would be no adverse airborne noise impacts from mobile sources under 2005/2006 No Action conditions. Noise from Stationary Sources Noise levels from stationary sources (including all construction equipment, mobile or stationary, located on-site, e.g. cranes, jackhammers, loaders, compressor, generator, excavators, on-site dump and concrete trucks, etc.) were also estimated for baseline construction activities. Because of the proximity of the WTC Memorial and Redevelopment Plan and the Permanent WTC PATH Terminal, the construction activities associated with these Lower Manhattan Recovery Projects were explicitly taken into account. The Route 9A Reconstruction project is also included in the construction noise evaluation, since it is located at an intermediate distance from the Existing Complex and may affect the project area, especially at receptor sites on Church, Dey and Cortlandt Streets, where there are direct line-of-sight between the receptors and construction activities. Other Lower Manhattan Recovery Projects, such as the South Ferry Terminal Project, are located at considerable distance and/or separated by intervening buildings from the project site. Because of this, and the presence of considerable background noise at the project area, the South Ferry Terminal Project would not be considered a substantial contributor to the noise levels in the vicinity

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of the Existing Complex, nor is the Existing Complex is likely to contribute to the noise generated at the South Ferry location. The analysis of stationary noise is described in detail in Chapter 13. As indicated in Appendix J, peak one (1)-hour noise levels without the construction of the FSTC would exceed FTA criteria of 90 dBA at one (1) site:

• Site No. 3: Hilton Millenium Hotel-Dey Street - 93 dBA. The peak eight (8)-hour noise levels without the construction of the FSTC would be either at, or in exceedence of FTA criteria of 80 dBA at the following sites with maximum eight (8)-hour period noise levels of:

• Site No. 3: Hilton Millenium Hotel-Dey Street - 92 dBA; and, • Site No. 4: Century 21 - Cortlandt Street entrance - 81 dBA.

The peak 30-day Ldn noise levels without the construction of the FSTC would meet the FTA impact criteria of 87 dBA (10 dBA above existing noise level of 77 dBA) at all nine (9) receptor locations. In conclusion, there would be adverse airborne noise impacts at two (2) sites from stationary sources in the 2005/2006 No Action Alternative, based on FTA criteria. Of the two (2) Lower Manhattan Recovery Projects located in the vicinity of the Existing Complex, the WTC Memorial and Redevelopment Plan employs the methodology described in the City Environmental Quality Review (CEQR) Technical Manual to describe noise and vibration conditions. The Permanent WTC PATH Terminal utilizes the same methodology as the FSTC. The Route 9A project, which uses a FHWA methodology, is located too far from the FSTC to have a discernable effect on cumulative noise conditions near the FSTC site. Specifically, the noise levels attributable to Route 9A Reconstruction would be at least 15 dBA less than the noise levels attributable to the construction of the WTC Memorial and Redevelopment Plan or Permanent WTC PATH Terminal projects. In the context of data and methodology compatibility among Lower Manhattan Recovery Projects, NYCT also characterized the noise conditions based on the CEQR Technical Manual, which indicated that noise levels under the No Action Alternative would exceed the CEQR construction noise threshold criteria of three (3) dBA as defined in CEQR Technical Manual at two (2) sites (ID Nos. 3 and 4). Appendix J provides additional information on the noise analyses conducted based on CEQR guidelines. Therefore, there would be adverse airborne noise impacts at two (2) sites from stationary sources under the No Action Alternative in 2006, based on CEQR criteria. Vibration Vibration levels from mobile sources and stationary sources were estimated and analyzed for the 2005/2006 period. Mobile sources within Lower Manhattan are expected to generate a minimal amount of vibration on streets with relatively good condition. As a result, no adverse vibration impacts are expected from mobile sources. Vibration and ground-borne noise from stationary sources associated with construction activities were estimated for the No Action Alternative. Other Lower Manhattan Recovery Projects were explicitly taken into account. Unlike airborne noise impacts, cumulative impacts from vibration and ground-borne noise are evaluated differently. Vibration levels from construction events degrade rapidly over distance and time. Two (2) vibration motions, which typically last less than 0.1 second, from different sources, would have to arrive at almost the exact same moment to affect the receptor location cumulatively. However, certain pieces of equipment, such as vibratory pile drivers, could produce cumulative effects by

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continually driving or shaking the pile into the ground. None of the other Lower Manhattan Recovery Projects are expected to use pile driving. Recent research indicates that structures respond differently to vibration depending upon their construction and upon the frequency of the vibration. Guidelines from the New York City Department of Buildings (NYCDOB) and the FTA include the following thresholds for potential vibration damage:

• 0.50 inches per second (ips) for historic structures (NYCDOB); • 0.20 ips for fragile buildings (FTA); and, • 0.12 ips for extremely fragile historic buildings (FTA).

The status of historic buildings in the study area with respect to fragility would be determined as engineering for the FSTC advances. Structural conditions of historic building would not be known until the final design stage; however, for purposes of conservative analysis it was assumed that historic buildings potentially affected by vibration would be considered fragile to extremely fragile. The peak vibration levels at each of the receptor sites were estimated for each month in the peak 2005/2006 period based on construction plans and schedules as described in Chapter 4: Construction Methods and Activities. Vibration levels were calculated for both singular and repetitive events. It is noted that calculating repetitive events is a conservative approach since not all construction elements would be expected to be occurring continuously at the same location within this time period. The peak vibration levels would not exceed 0.12 ips, the FTA threshold criteria for extremely fragile historic buildings. The maximum vibration levels are included in Appendix J. In conclusion, there would be no adverse vibration impacts at the receptors in the FSTC project area under the 2006 No Action Alternative. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - ESTIMATION OF CUMULATIVE CONSTRUCTION EFFECTS FOR FSTC BUILD ALTERNATIVES 9 AND 10

The cumulative construction effects analysis for the Proposed Action consists of the addition of FSTC construction noise to the construction baseline noise levels at receptor locations in the vicinity of the project. Noise from all construction activities, including both mobile and stationary sources, is evaluated based on construction methods and schedules developed for those projects (see details in Chapter 4: Construction Methods and Activities and Appendix C). Both Build Alternatives would be constructed as described in Chapter 4: Construction Methods and Activities. For the purposes of analyzing potential cumulative effects to noise and vibration, there would not be any substantive differences between Alternatives 9 and 10. Potential impacts and mitigation measures would be similar for both Alternatives. Noise from Mobile Sources PCEs and noise levels from mobile sources (including both commuter and construction related traffic on adjacent streets, e.g. truck hauling, vehicles driving to/from construction site, traffic detouring and diversions, etc.) under the Build Alternatives during the peak construction year of 2005/2006 would be higher over existing 2003 levels at seven (7) of the nine (9) receptor locations due to increased traffic associated with construction of major development projects and the FSTC in the study area. The increase in PCEs between 2003 and the Build Alternatives in 2006 would range between three (3) and 47 percent at six (6) of the seven (7) receptor locations that would experience increased PCEs. The increases in PCEs at the six (6) locations translate to imperceptible dBA increases between 0.1 dBA and 1.7 dBA. A seventh location with an increase of 376 percent in PCEs in 2005/2006 period, Site 4 - Century 21 Cortlandt Street entrance, would experience a perceptible dBA increase of 6.8 dBA. The projected increase would still not exceed the FTA criteria of 90 dBA.

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Compared to pre-September 11 levels, traffic volumes (PCEs) and associated noise levels in 2006 would decrease or remain unchanged at four (4) of the nine (9) receptor locations. The five (5) other sites (ID Nos. 2, 4, 5, 7, and 9 in Appendix J, Part II) would have PCE increases ranging from less than one (1) percent to over 43 percent. The PCE increases translate to imperceptible increases up to 1.5 dBA from pre-September 11 condition. Since the noise levels of pre-September 11 condition were less than 85 dBA, it is, therefore, estimated that the noise levels associated with mobile sources under No Action would be less than 86.5 dBA, which is less than FTA criteria of 90 dBA, at all nine (9) receptor sites evaluated. In conclusion, there would be a perceptible increase in noise levels from mobile sources only at the Century 21 Department Store – Cortlandt Street entrance (Site No. 4) when compared with existing 2003 levels. However, the dBA levels would still be within the FTA criteria of 90 dBA for mobile sources. No other substantial impacts would occur at any other receptor locations under the Build Alternatives. Noise from Stationary Sources As previously stated, construction activities associated with other Lower Manhattan Recovery Projects that contribute to noise impacts caused by the FSTC are limited to the Permanent WTC PATH Terminal and the WTC Memorial and Redevelopment Plan. These projects only affect the immediate interface with the FSTC project area at Dey Street. Areas of FSTC construction further east would be shielded by intervening buildings from the noise contributions from these two (2) other Recovery Projects. Furthermore, existing urban background noise most of the time would mask construction baseline noise. Peak-hour noise levels without mitigation would exceed FTA criteria of 90 dBA for residential land uses at the four (4) sites. The maximum peak-hour noise levels at these four (4) locations are:

• Site No. 3: Hilton Millenium Hotel-Dey Street - 97 dBA; • Site No. 6: Fulton Street between Broadway & Nassau Street – 100 dBA; • Site No. 8: 118 Fulton Street – 100 dBA; and, • Site No. 9: 10 John Street – 90 dBA.

The eight (8)-hour noise levels without mitigation would exceed FTA criteria of 80 dBA for residences and church or 85 dBA for commercial building and offices at seven (7) of the nine (9) sites. The maximum, eight (8)-hour noise levels at these seven (7) locations are:

• Site No. 1: Historical church - Northwest corner of Broadway & Fulton Street – 85 dBA; • Site No. 2: Commercial/Office Historical building, 195 Broadway – 89 dBA; • Site No. 3: Hotel, Hilton Millenium Hotel-Dey Street - 98 dBA; • Site No. 6: Residences, Fulton Street between Broadway & Nassau Street – 98 dBA; • Site No. 7: Residences, 80 Nassau Street – 81 dBA; • Site No. 8: Residences, 118 Fulton Street – 98 dBA; and, • Site No. 9: Residences, 10 John Street – 89 dBA.

The 30-day Ldn levels were also calculated using two (2) methods, the Minimum Distance Method and the Average Distance method. The Minimum Distance Method presents the most conservative analysis in determining the closest point that pieces of moveable equipment could be located to the receptor. (Stationary equipment would be placed as far away as possible within the work zone.) While construction could occur as close as five (5) feet from a building façade, it should be noted that activities would not occur continuously at such proximities, especially for small distances (less than 20 feet). Rather, equipment at such distances would continuously move within different areas of the work site. A second method, Average Distance Method, was also analyzed to better reflect the fact that actual locations of the construction equipment would move around throughout the construction zones over an

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extended period. When 30- day Ldn levels were calculated using the Average Distance Method at all nine (9) locations, the 30-day Ldn levels were substantially reduced with all sites staying below FTA threshold criteria. The 30-day Ldn levels without mitigation using the Minimum Distance Method would exceed FTA impact criteria of an increase 10 dBA or more over those of pre-September 11 at five (5) sites. The maximum 30-day peak noise levels are:

• Site No. 2: 195 Broadway – 92 dBA (85 dBA threshold); • Site No. 3: Hilton Millenium Hotel-Dey Street - 93 dBA (87 dBA threshold); • Site No. 6: Fulton Street between Broadway & Nassau Street – 94 dBA (89 dBA threshold); • Site No. 8: 118 Fulton Street – 94 dBA (88 dBA threshold); and, • Site No. 9: 10 John Street – 88 dBA (87 dBA threshold).

When 30- day Ldn levels were calculated using the Average Distance Method at all nine (9) locations, the 30-day Ldn levels were substantially reduced with all sites staying below FTA threshold criteria. In conclusion, there would be adverse airborne noise impacts from stationary sources at seven (7) receptor locations due to exceedances of FTA one (1) and eight (8)-hour peak criteria under Alternatives 9 or 10. Furthermore, noise levels under Alternatives 9 or 10 would exceed the CEQR construction noise threshold criteria of 3 dBA increase as defined in CEQR Technical Manual at nine (9) locations, all of which except for Site No. 1 would be considered a adverse impact under CEQR Technical Manual (see Appendix J). Vibration Maximum vibration levels and associated construction activities and equipment at each receptor site in 2005/2006 are discussed in detail in Chapter 13: Noise and Vibration, and the analysis results are summarized in Tables 13-12 and 13-13 in that chapter. Construction vibration at all sites during the eight (8) month period in 2006 would be less than 0.5 inch/sec., which is the U.S. Bureau of Mines (USBM) threshold for potential cosmetic damage of buildings and the NYCDOB threshold for historic structures. Vibration levels at most sites would be less than 0.12 inch/sec, which is the FTA impact threshold for extremely fragile buildings. Vibration levels at Sites 6 and 8 would reach 0.12 inch/sec at times during the peak 2005/2006 construction period. Vibration levels at these two (2) sites would be 0.331 inch/sec. for a four (4) month period, exceeding the FTA threshold of 0.20 inch/sec. for fragile buildings. Since the receptor sites evaluated are not considered to be fragile or extremely fragile buildings, vibration impacts during the construction would not be substantial. In addition to the nine (9) receptor locations evaluated, anticipated construction-related vibration levels were calculated for five (5) nearby historical buildings (see Figure 13-2 and Table 13-14). Use of either a crawler crane with clam shell shovel for excavation in construction of a slurry wall or an auger drill for secant pile wall construction would result in impacts exceeding FTA criteria at four (4) of the five (5) historical buildings including: American Telephone and Telegraph (AT&T) Building (Site B - 195 Broadway), East River Savings Bank (Site C - 25 Dey Street/24 Cortlandt Street), Bennett Building (Site D - 139 Fulton Street), and the Corbin Building (Site E - 192 Broadway). The buildings would be subject to maximum vibration levels of 2.258 ips if clam shells were utilized in slurry wall construction, exceeding the FTA criteria of 0.12 ips for extremely fragile buildings and 0.20 ips for fragile buildings. It is noted that the vibration levels would be substantially lower than above mentioned levels if pile drilling rigs were employed to construct a secant pile wall instead of slurry wall. Specifically, the vibration levels at the four (4) historical buildings would be 0.995 ips with secant pile wall construction instead of 2.258 ips, which would occur as a result of slurry wall construction.

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Conclusion Regarding Cumulative Impacts: Noise and Vibration The analysis shows that, cumulatively, there would be noise impacts from mobile sources due to construction of the FSTC. There would also be cumulative noise and vibration impacts from stationary construction sources (i.e., WTC Memorial and Redevelopment Plan and the Permanent WTC PATH Terminal). These impacts would occur at the same receptors that would be affected by construction noise and vibration from the FSTC project alone. Noise For noise exposure, it should be noted that individuals at the receptor locations do not experience the relatively prolonged noise exposure, specifically, eight (8)-hour or 30-day exposure, reflected in the FTA methodology. Targeted implementation of mitigation measures would proactively minimize noise impacts on periodic receptors (e.g., users of the Millenium Hotel) to acceptable levels. Mitigation measures for noise impacts that would accomplish this minimization include scheduling individual project construction activities to avoid or minimize noise impacts during nighttime, and coordinating the sequencing of construction activities with those of the Permanent WTC PATH Terminal and the WTC Memorial and Redevelopment Plan to achieve further noise reductions by scheduling noisy operations to occur at the same time or by spreading them out. The FSTC is located within a dense metropolitan area in close proximity to sensitive land uses. This limits opportunities for developing feasible, cost-effective mitigation. Despite these constraints, NYCT, however, is committed to developing other EPCs and mitigation measures that would reduce and, where practicable, eliminate adverse impacts due to construction in accordance with FTA criteria. These measures would be investigated by NYCT in coordination with the other project sponsors and the FTA in the course of engineering, constructing and monitoring the project. Table 13-16 of Chapter 13: Noise and Vibration provides a range of potential mitigation measures that could be implemented. NYCT would evaluate the effectiveness and feasibility of the proposed mitigation measures. In addition, NYCT would coordinate with the local business and residential community to minimize disruptions through the development of a Public Involvement and Governmental Entities Coordination Plan. Development of such a plan is a component of the Environmental Analysis Framework signed by NYCT, PANYNJ and NYSDOT. This Plan would describe how the environmental community, relevant governmental entities, and the general public would be involved as the NYCT proceeds with the implementation of the FSTC. The Plan would be coordinated with the public and governmental entity involvement plans for other Lower Manhattan projects. A key goal of the coordination would be to avoid or minimize adverse effects on the environment, particularly during construction. In addition, this Plan would identify a protocol by which comments received during the construction phase would be addressed; appropriate current information would be provided to the public, including project implementation schedules; and coordination with other projects would occur. The process would build on an existing construction coordination protocol among parties already involved in rebuilding Lower Manhattan. The Plan would be developed in consultation with LMDC, PANYNJ and NYSDOT and in coordination with the efforts already undertaken by NYCDOT and NYCDDC and with input from NYCDEP, utility and telecommunication companies. Public outreach efforts may also be coordinated through a Downtown Construction Command Center, or equivalent entity, as proposed by Governor Pataki. Businesses and residents would be notified via email, advertisements in neighborhood and local newspapers and regularly scheduled meetings with neighborhood associations, community boards and Business Improvement Districts, such as the Downtown Alliance. A process would be established to obtain input from the community and other stakeholders regarding the noise mitigation measures and EPCs, as it is recognized that desirability of mitigation measures may vary among interested parties. Based on input from the community and other stakeholders, the EPCs and other mitigation measures would be adjusted, so that the rebuilding of Lower Manhattan can continue with minimal disruption to businesses, residents and visitors.

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Noise Control Approaches: In addition to the processes currently being pursued by NYCT, several noise control approaches are being explored including: design considerations and project layout; sequence of operations; alternative construction methods; emission limits and performance standards; noise monitoring; and, receptor management. Design Considerations and Project Layout Design considerations and project layout approaches include such measures as constructing noise barriers, rerouting traffic, placing construction equipment farther from noise-sensitive receptors (NSRs), constructing walled enclosures around especially noisy activities and the use of equipment with noise attenuation features. For the FSTC, there are two (2) such measures that have the potential to substantially reduce project impacts: the use of acoustic barriers and walled enclosures around certain construction activities; and, the placement of construction equipment in shielded locations, such as underground. It may be possible to place some compressors, generators and other noisy equipment subsurface where they would be either partially or completely shielded from nearby residences or other sensitive land uses. Sequence of Operations Mitigation measures also include use of construction sequencing to reduce noise impacts. This can be achieved by either combining noisy operations to occur in the same time period, reducing impact duration, or by sequencing activities over a longer period, reducing impact intensity. NYCT would explore which construction operations can be limited to daytime operations only, without substantially affecting schedule and costs. At this time, NYCT is committed to restricting the timing of most surface activity related to cut-and-cover construction, such as building slurry walls, pile drilling and surface excavation. Such activities would not occur during the late evening and early morning hours (10 PM to 7 AM) unless these activities were enclosed or adequately distant from sensitive land uses, such as residences. However, it is possible that some relatively quiet activities could occur overnight. One general exception to the policy of avoiding overnight activities would involve utility work. Because utility work requires the complete closure of the roadway and shutting of utility service for several hours, utility work is normally undertaken at night. Some cut-and-cover construction would be needed, and noisy equipment, such as jackhammers, would at times be required. Where practicable, work would occur during the day. The feasibility of limiting certain types of construction operations such as utility relocations to daytime periods is being examined by NYCT. Alternative Construction Methods Alternative construction methods, including such measures as avoiding impact pile driving in noise-sensitive areas, using special low noise emission level equipment, and selecting and specifying quieter demolition methods are also being considered by NYCT. Similarly, NYCT would examine the use of infrared lighting and/or flagmen, instead of backup horns for trucks. Backup horns, which are designed to attract attention, tend to produce noise that is generally annoying and disturbing to nearby residents, particularly late at night. In addition, NYCT would explore opportunities to use alternative quieter construction techniques, and specially quieted equipment would be specified where feasible, economical and effective. Emission Limits and Performance Standards Construction of the Proposed Action would be limited to between 7 AM and 6 PM, Monday through Saturday, as practicable. Noise from construction equipment is regulated by EPA noise emission standards and also specified in the New York City Noise Code. These mandate that certain classifications

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of construction equipment, e.g. air compressors, pavement breakers, and heavy trucks, meet specified noise emission standards. NYCT would ensure that this regulation would be carefully followed. In addition, construction noise performance standards may be established by NYCT for locations of sensitive receptors adjacent to the Project Site. Such standards would be included with contract documents that would be met by all contractors during construction. Performance standards may include construction noise level thresholds for daytime, evening, and nighttime hours at sensitive land uses at and/or adjacent to the Project Site. These threshold criteria would include hourly Leq and Ldn during three (3) time periods, and may also include eight (8)-hour Leq and 30-day Ldn levels, consistent with FTA guidelines for construction noise. Noise Monitoring Ambient noise measurements were taken at noise-sensitive locations as part of this environmental review process. After construction begins, representative 24-hour noise monitoring stations may be established: these stations would provide NYCT with the ability to monitor its contractors to ensure that the performance standards established by NYCT are met. Throughout construction, all contractors working on the Project Site may be required to meet the performance standards, procedures and conditions specified by NYCT. Vibration Vibration impacts are usually associated with instantaneous impacts of the construction equipment in operation; vibration spreads through the ground and diminishes in strength with distance and over time after impact. High vibration equipment would generate strong vibrations only at the moment of impact, which generally lasts for one tenth of one (1) second in time. Therefore, cumulative effects of ground-borne construction vibration would not usually generate substantial impacts unless the equipment was operated simultaneously. Vibration values were calculated taking into account the construction activities of other projects, such as the construction of the Permanent WTC PATH Terminal and the construction of the WTC Memorial and Redevelopment Plan, south of Church Street. As noted previously, NYCT would closely coordinate construction of the FSTC with the Permanent WTC PATH Terminal and the WTC Memorial and Redevelopment Plan, to minimize such construction-related impacts. Due to the distance of the construction activities of the other Lower Manhattan Recovery projects to the construction zone of the FSTC, none of the historic structures in the vicinity of the FSTC project are anticipated to incur cumulative vibration impacts form the other projects, with the exception of the former East River Savings Bank on Church Street. Although ground vibration associated with the construction of the Dey Street Access Building and Dey Street Passageway would not reach the FTA threshold of 0.20 ips for fragile buildings, the former East River Savings Bank is located within 90 feet of not only the Dey Street Passageway, but also the WTC Memorial and Redevelopment Project, and portions of the Permanent WTC PATH Terminal. The former East River Savings Bank could therefore experience cumulative vibration effects arising from construction-related ground vibrations that may occur simultaneously or consecutively and, if not properly managed, could potentially result in foundation or structural damage to the building. NYCT will coordinate closely with LMDC and the PANYNJ to ensure that construction activity in the vicinity of the former East River Savings Bank is appropriately managed to avoid adverse cumulative vibration impacts. No cumulative vibration impacts are anticipated to the Corbin Building or any of the historic structures. As described in Chapter 13: Noise and Vibration, possible mitigation would include a monitoring program to protect historic resources from increased vibration levels. NYCT, through its construction contractors, would implement special vibration protection measures that may include:

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• Inspection and report on current foundation and structural conditions of historic resources; • Develop a monitoring program to measure vertical and lateral movement and vibration to historic

structures near construction activities. Details of the frequency and duration of the monitoring program would be determined as part of the project’s ongoing consultation with the SHPO;

• Establish and monitor construction methods to limit vibrations to levels that would not cause structural damage. Such methods may include underpinning or expansion grouting as alternative construction equipment; and,

• Issue “stop work” orders to the construction contractor, as required, to prevent damage to the structures, based on any vibration levels that exceed the design criteria in lateral or vertical direction. Work would not begin until steps proposed to stabilize and/or prevent further damage to the designated buildings were approved.

Furthermore, NYCT would make all efforts, via the use of alternative construction methods and activities, to avoid potential vibration impacts. A detailed description of such efforts is provided in Chapter 4: Construction Methods and Activities. 2008 - SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

As of 2008, land uses in the study area would have continued to evolve and follow established trends, as described in Chapter 7: Social and Economic Conditions. Through 2008, the trend of conversion of commercial buildings to residential uses and the transformation of existing retail/service establishments to cater to the needs of the residential population is expected to continue. No substantial land use changes are expected to occur by 2008 in the immediate vicinity of the FSTC site and no new noise-sensitive receptors would exist in the vicinity of the Existing Complex, compared to conditions in 2005/2006. Changes in land use by 2008 and overall rebound of development in Lower Manhattan are expected to result in increases in traffic volumes, as described in Chapter 6, Section 6A: Traffic and Parking. The increase in traffic associated with land use changes would increase noise levels. However, by 2008, the construction of several of the Lower Manhattan Recovery Projects would have been completed, and several of them would be past their construction peak. As a result, the noise emissions associated with the construction of the Lower Manhattan Recovery Projects would have decreased compared to those in 2005/2006, when those projects were at their combined construction peak. The main contributors to noise at the receptor locations for the FSTC in 2008 consist of the construction activities for the Permanent WTC PATH Terminal, west of Church Street and the construction of the WTC Memorial, further west towards Route 9A. By 2008 the Permanent WTC PATH Terminal would be past its 2005/2006 construction peak and the WTC Memorial would have been completed. As construction activities associated with both mobile and stationary sources in the immediate vicinity of the FSTC receptor locations would decrease from its 2005/2006 peak, noise levels are expected to reduce over 2005/2006 conditions. Vibration levels in 2008 would be similar to those present prior to September 11, since no modifications to the Existing Complex would have occurred. Vibration associated with construction activity at the WTC site is expected to decrease from 2005/2006 peak. Since it is not estimated that there would be any adverse vibration impacts at FSTC area as the result of construction activities at the WTC site in 2005/2006 (see discussion in No Action section), any vibration impacts from WTC construction would not occur in 2008 either. Therefore, there would be no adverse vibration levels affecting the FSTC project area under No Action in 2008.

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2008 - SHORT TERM OPERATIONAL CONDITIONS - ESTIMATION OF CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES 9 AND 10

During operation, the FSTC would not generate any vehicular traffic. To the extent that the FSTC would contribute to a reduction in traffic as a result of alternative transit options, the operation of the FSTC may contribute to a reduction in traffic-generated noise; thereby improving ambient noise conditions for residents, workers and visitors to Lower Manhattan. The only potential mobile source associated with operation of the FSTC would be the existing subway station and subway trains. As stated in the FTA’s assessment guidelines, subway noise is generally not a problem for surrounding sensitive receptors because the ground acts as a barrier to noise transmission. The subway lines and stations are underground and fully covered, with the exception of ventilation gratings and shafts. As a result, the noise from underground fixed-rail operations propagates through these openings to reach the surface. The project alternatives would not result in substantial increases in train operations, and operational noise impacts are not anticipated. With operation of the FSTC in 2008, the only potential sources of noise would be the HVAC system. The HVAC system would be fully enclosed and would not generate detectable noise. Noise associated with the air tempering equipment and ventilation shafts would be insignificant and be masked by the background noise from street traffic and other noises, which are typical for an urban environment. Therefore, cumulative adverse effects on noise conditions from stationary sources would not be expected in 2008 with the FSTC. Operation of the FSTC in 2008 would not result in any changes to the existing subway alignments and profiles, in the type of trains using the track (i.e., suspension and wheel conditions would remain the same), and track structure. Therefore, this operation of the FSTC in 2008 is not anticipated to result in a change in vibration levels at adjacent sensitive receptors, and there would not be any adverse cumulative adverse vibration effects associated with the operation of the FSTC in 2008. 2025 LONG TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

The No Action analysis assumes that by 2025 all Lower Manhattan Recovery Projects would have been constructed and operating for several years, but that the FSTC would not have been constructed and that the conditions at the Existing Complex would essentially remain as existing, with the exception of regular maintenance measures. By 2025, the area in the immediate vicinity of the Existing Complex area and beyond would have undergone substantial changes in land use compared to pre- and post-September 11 conditions, as described in Chapter 7: Social and Economic Conditions. However, no new sensitive receptors would have been generated in the vicinity of the Existing Complex. Lower Manhattan by 2025 is expected to have returned to the economic growth levels projected to the year prior to September 11. Land uses in Lower Manhattan are expected to have diversified, following the trend established prior to September 11 and accelerated after September 11. The economic growth of Lower Manhattan through 2025 would have led to an increase in vehicular traffic (see Chapter 6A: Traffic and Parking), resulting in an increase in vehicular noise levels over 2008. However, by 2025, the construction of several of the Lower Manhattan Recovery Projects would have been completed for several years and noise generated by construction activities associated with these projects would no longer occur. With the development of the WTC site, new buildings would be present west of Church Street and result in changes of ambient noise conditions; the dominant noise source at this location would be the traffic on Church Street and other adjacent streets in the area. Vibration levels in 2025 would be similar to those present prior to September 11. The operation of FSTC or any other Lower Manhattan Federal Recovery Projects, including WTC and Permanent WTC PATH

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Terminal projects, are not expected to have an impact individually or cumulatively upon vibration levels in the area. 2025 - LONG TERM OPERATIONAL CONDITIONS - ESTIMATION OF OPERATION CUMULATIVE EFFECTS WITH FSTC

As described earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. During operation, the FSTC would not generate any vehicular traffic and therefore would not result in traffic-generated noise. To the extent that the FSTC would contribute to a reduction in traffic as a result of providing alternative transportation options, the operation of the FSTC may contribute to a reduction in traffic-generated noise, thereby improving ambient noise conditions for residents, workers and visitors to Lower Manhattan. The only potential mobile source associated with operation of the FSTC would be the existing subway station and subway trains. No new sensitive receptors are expected to be located in the vicinity of the Existing Complex. As stated in the FTA’s assessment guidelines, subway noise is generally not a problem for surrounding sensitive receptors because the ground acts as a barrier to noise transmission. The subway lines and stations are underground and fully covered, with the exception of ventilation gratings and shafts. As a result, the noise from underground fixed-rail operations propagates through these openings to reach the surface. Operation of the FSTC in 2025 would not result in substantial increases in train operations, and operational noise impacts are not anticipated. With operation of the FSTC in 2025, the only potential sources of noise would be the HVAC system. The HVAC system would be fully enclosed and would not generate detectable noise. Noise associated with the air tempering equipment and ventilation shafts would be insubstantial and be masked by the background noise from street traffic and other noises, which are typical for an urban environment. Therefore, cumulative adverse effects on noise conditions from stationary sources would not be expected in 2025 with the FSTC. Operation of the FSTC in 2025 would not result in any changes to the existing subway alignments and profiles, in the type of trains using the track (i.e., suspension and wheel conditions would remain the same), and track structure. Therefore, this operation of the FSTC in 2025 is not anticipated to result in a change in vibration levels; there would not be any adverse cumulative adverse vibration effects associated with the operation of the FSTC in 2025. 20.4.4 CULTURAL RESOURCES

(See Chapter 11 for Comprehensive Analysis)

COORDINATED DEVELOPMENT OF THE CUMULATIVE CULTURAL AND HISTORIC RESOURCES EFFECTS ANALYSIS

The cultural and historic resources effects analysis was developed through coordination among the NYCT, FTA and the other Lower Manhattan Recovery Project sponsors. Potential issues, analytical methods to address the issues, and data to support the analysis were discussed in meetings held in 2003 and 2004. In addition, the analysis of the FSTC’s effects on architectural and historic resources is being conducted in coordination with the New York State Office of Parks, Recreation and Historic Preservation (NYSOPRHP) and the New York City Landmarks Preservation Commission (LPC). The potential that construction activities could lead to temporary but adverse cumulative effects was recognized by the agencies. Specifically, these potential impacts could include visual impacts to historic structures or historic context; excavation and compaction damage to archaeological resources; direct

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physical effects such as demolition or alteration; damage from construction activities (such as traffic, noise and air pollution increases) or traffic-induced vibrations; and, changes in access. The analysis methodology for cumulative effects on cultural resources was refined through these discussions among the project sponsors, and includes the following steps: Determine Area of Potential Effect (APE) for cumulative effects (construction and operational) on both archaeological and historic resources.

• Identify archaeological and historic resources present within the cumulative APE that have the potential to be affected by other reasonably foreseeable actions;

• Determine the combined effect on the resource of the Proposed Action in combination with the effects of other reasonably foreseeable actions; and,

• Identify mitigation measures, if appropriate. The discussions also led to the development of common EPCs for cultural and historic resources for all Lower Manhattan Recovery Projects. Specifically, these EPCs would be incorporated into the FSTC and include:

• Establish coordination among projects to avoid or minimize interruption in access to cultural and historic sites;

• Initiate public information and involvement outreach with sensitivity to local cultural resources; • Identify public information outlets that would receive and provide current information about

access during construction; • Consult with the SHPO and the LPC regarding potentially impacted, culturally significant sites;

and, • Monitor noise and vibration during construction at such sites as appropriate.

2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - NO ACTION ANALYSIS

Under the No Action conditions in 2005/2006, the character of historic resources in the vicinity of the Existing Complex would not be affected by the FSTC as the project would not be constructed. Maintenance activities of the Existing Complex would not affect historic resources. As a result of modern urban construction activities or lack of historic period occupation, intact archaeological deposits or features are unlikely to be present at the site of the Existing Complex. Maintenance activities would not affect archaeological resources. As no impacts would occur to historic or archeological resources, there would also be no cumulative impacts to such resources under No Action Conditions. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - ESTIMATION OF CUMULATIVE CONSTRUCTION EFFECTS WITH FSTC BUILD ALTERNATIVES

Under this discussion, both Build Alternatives 9 and 10 would be constructed as described in Chapter 4: Construction Methods and Activities. For the purposes of analyzing potential cumulative effects to cultural and historic resources, there would not be any substantive differences between Alternatives 9 and 10. Potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. As indicated in Section 11.5 of the DEIS, the FSTC has the potential to directly affect eight (8) cultural resources reflecting seven (7) properties and one (1) historic district:

1. Corbin Building at 192 Broadway; 2. Fulton Street IRT Station at Fulton Street and Broadway; 3. AT&T Building at 195 Broadway; 4. Bennett Building at 139 Fulton Street;

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5. Former East River Savings Bank Building, between Dey and Cortlandt Streets at Church Street;

6. St. Paul’s Chapel and Graveyard, Broadway at Fulton Street; 7. WTC site; and, 8. John Street-Maiden Lane Historic District, roughly bounded by John and Fulton Streets to the

north, Liberty Street to the south, Broadway to the west, and Dutch and Nassau Streets to the east.

Several of the other Lower Manhattan Recovery Projects have the potential to affect the same historic resources that would or may be affected by the FSTC. A discussion of the archeological and historic resources within the APEs of the FSTC is presented in Chapter 11: Cultural Resources. The potential for cumulative effects assessed potential overlaps of the APEs of FSTC with those of other projects. The Broadway Corridor portion of the “Primary APE” for historic resources for the WTC Memorial and Redevelopment Plan encompasses a substantial portion of the historic resources APE for the FSTC. The historic resources APE for the Permanent WTC PATH Terminal overlaps the historic resources APE for the FSTC in the area between Church Street and Broadway. No archaeological resources were identified within the project’s construction zone; therefore impacts to archaeological resources are not anticipated and no cumulative effects are expected to occur. Cumulative effects of the FSTC on cultural resources are described below. Ground vibration associated with the construction of the Dey Street Access Building and Dey Street Passageway would not reach the FTA threshold of 0.20 ips for fragile buildings. However, the former East River Savings Bank is located within 90 feet of the Dey Street Passageway, the WTC Memorial and Redevelopment Plan, and portions of the Permanent WTC PATH Terminal. The former East River Savings Bank could therefore experience cumulative vibration effects arising from construction-related ground vibrations that may occur simultaneously or consecutively and, if not properly managed, could potentially result in foundation or structural damage to the building. Construction of the RW - E connector would require realignment or removal of a portion of the northern end of a retaining wall that separates the Church Street RW station from the National Register-eligible WTC site. This retaining wall may also be subject to impacts from the Permanent WTC PATH Terminal and the WTC Memorial and Redevelopment Plan. This element of the WTC site could therefore experience cumulative effects arising from several simultaneous or consecutive construction projects. However, as this wall is not a contributing element to the historic nature of the WTC site, no adverse cumulative effects would occur. Both the FSTC Entry Facility and the FSTC Dey Street Access Building would be similar in height to or lower than the structures currently occupying those sites and no shadow impacts are anticipated on any of the historic resources within the FSTC historic APE. The FSTC is not anticipated to result in shadow impacts on St. Paul’s Chapel and graveyard, as its height would be similar or less than existing structures that it would replace. However, because of the proximity of St. Paul’s Chapel to the FSTC, the extent to which shadows from other Lower Manhattan Recovery Projects could affect this historic resource in combination with other potential effects from FSTC was assessed. The graveyard at St. Paul’s Chapel would receive incremental shadows from the WTC Memorial and Redevelopment Plan, as described in Chapter 7 of the DGEIS for the WTC Memorial and Redevelopment Plan (LMDC, 2004). These incremental shadows would occur during the March/September, May/August and June analysis periods during the mid- to late-afternoon hours. In March/September, the first incremental shadow would occur on the northwest corner at 3:30 PM from the base of Tower 2. The incremental shadow would start out small and move slowly to the east, covering slightly more of the graveyard as the afternoon continues. By 4:29 PM, the end of the analysis period, the incremental shadow would be mostly covered within

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existing shadows and there would be only a small incremental shadow on the northwest corner. In May/August, beginning at 4:45 PM, the base of Tower 2 would again be casting an incremental shadow on the graveyard. The shadow would again be small as it would begin to fall on the northwest corner. By 6 PM, shadows from existing buildings would cover the portion of the graveyard that was previously receiving incremental shadow from the base of Tower 2. Incremental shadows from the base of Tower 2 would fall on the graveyard from 5 PM to 7:01 PM in the June analysis period. The first incremental shadow would occur on the northwest corner of the plaza and continue farther east, covering the northern two-thirds of the graveyard by the end of the analysis period at 7:01 PM. The shadow effects on St. Paul’s Chapel and Graveyard from other Lower Manhattan Recovery Projects, would not result in cumulative impacts with any effects from FSTC. Without mitigation, the historic structure at 195 Broadway would incur noise impacts as result of cumulative construction noise, including noise generated by the construction of the Permanent WTC PATH Terminal and the WTC Memorial and Redevelopment Plan. However, as described above in the discussion of cumulative noise and vibration effects, EPCs and mitigation measures would be implemented by NYCT to minimize impacts. Vibration associated with construction truck traffic for the FSTC, in combination with construction truck traffic for the other Lower Manhattan Recovery Projects, is not anticipated to affect historic and cultural resources, as described in Chapter 13. The Fulton Corridor Retail and Arts/Entertainment District project seeks to revitalize Fulton Street east of Broadway with retail and other land uses (see Chapter 7: Social and Economic Conditions). Historic resources potentially affected by that project would include the Bennett Building at 139 Fulton Street and the John Street-Maiden Lane Historic District, whose northern boundary is generally formed by the south façade of Fulton Street. The Fulton Street Revitalization proposal, however, is still under study by LMDC; NYCT would coordinate with LMDC and other involved parties to ensure that the design and operation of the FSTC would be compatible with future revitalization efforts for Fulton Street and would respect the collective historic context of Lower Manhattan. The WTC Memorial and Redevelopment Plan and the Permanent WTC PATH Terminal would be under construction at the same time as the FSTC, as described in Chapter 4: Construction Methods and Activities. However, as these projects are being constructed in an area physically removed from the FSTC, they would not affect access conditions to the historic and cultural resources in the vicinity of the FSTC. As noted in the Access and Circulation section above, NYCT has committed to the establishment of an MPT plan that would accommodate traffic and pedestrian flow throughout the project. For example, pedestrian access would be maintained to the greatest extent possible on all streets surrounding the FSTC, including Dey Street, Broadway, Fulton Street and John Street and especially with regard to historic resources, such as St. Paul’s Chapel and Graveyard. In addition to the MPT plan, construction techniques such as decking and phasing/coordinating work with other agencies would eliminate redundant operations (e.g., excavation and utility relocation) by other projects (e.g., roadway reconstruction at Broadway by NYCDOT). This would ensure that inconvenience to the traveling public would be kept to a minimum. Pedestrian access to, from and among all modes of travel, including subway and bus in the vicinity of the project, would be maintained throughout the duration of construction. In addition, pedestrian access to major destinations in the vicinity of the project would also be maintained. Conclusions Regarding Construction Cumulative Impacts: Cultural Resources Based on the foregoing analysis, the FSTC, in combination with other reasonably foreseeable future actions, would potentially result in cumulative effects on cultural and historic resources. As indicated above, the Proposed Action would be implemented with cultural and historic resources EPCs.

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Implementation of these EPCs, especially those involving coordination among projects to avoid or minimize ground vibration and interruption in access to cultural and historic sites, would effectively reduce the potential for adverse cumulative impacts to cultural resources. Other EPCs would be investigated by NYCT in coordination with FTA and the other project sponsors in the course of developing, constructing and monitoring the project in an effort to minimize the construction effects on cultural and historic resources. 2008 - SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

As of 2008, land uses in the study area would have continued to evolve and follow established trends, as described in Chapter 7: Social and Economic Conditions. Through 2008, the trend of conversion of commercial buildings to residential uses and the transformation of existing retail/service establishments to cater to the needs of the residential population is expected to continue. No substantial land use changes are expected to occur by 2008 in the immediate vicinity of the FSTC site, nor are any changes anticipated to the cultural resource context by 2008. Operation of the FSTC in 2008 is not anticipated to affect that resource and no vibration, noise or other adverse effects are anticipated on that resource from the operation of the FSTC in 2008. 2008 - SHORT TERM OPERATIONAL CONDITIONS - ESTIMATION OF CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES

As described earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. During operation, the FSTC is not anticipated to adversely affect any cultural resources in the area, as described in more detail in Chapter 11: Cultural Resources, Chapter 13: Noise and Vibration and Chapter 9: Urban Design and Visual Resources. A Criteria of Effects Report (NYCT, 2003) for Alternatives 9 and 10 was submitted to SHPO in December 2003 and concurred with by SHPO in its correspondence with NYCT of February 2004 (see Appendix H). The Corbin Building under either one of the alternatives would have been either avoided (Alternative 9) or actively preserved (Alternative 10) through an adaptive reuse program that would restore the visibility of the building’s defining elements to the public. Under either alternative, adverse effects to any cultural resources within the APE would be addressed through the Memorandum of Agreement between the SHPO, FTA and NYCT. Operation of the FSTC in 2008 would improve access to cultural resources in Lower Manhattan, including the Corbin Building and the John Street-Maiden Lane Historic District, thereby contributing to a greater enjoyment of these resources. 2025 LONG TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

As of 2025, land uses in the study area would have continued to evolve and follow established trends, as described in Chapter 7: Social and Economic Conditions. Through 2025, the trend of conversion of commercial buildings to residential uses and the transformation of existing retail/service establishments to cater to the needs of the residential population is expected to be complete. No substantial changes are anticipated to the cultural resource context by 2025. 2025 - LONG TERM OPERATIONAL CONDITIONS - ESTIMATION OF OPERATION CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES

As described earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. During operation, the FSTC is not anticipated to adversely affect any cultural resources in the area, as described in more detail in Chapter 11: Cultural Resources, Chapter 13: Noise and Vibration and Chapter 9: Urban Design and Visual Resources. A Criteria of Effects Report (NYCT, 2003) for Alternatives 9 and

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10 was submitted to SHPO in December 2003 and concurred with by SHPO in its correspondence with NYCT of February 2004 (see Appendix H). The Corbin Building under either one of the alternatives would have been either avoided (Alternative 9) or actively preserved (Alternative 10) through an adaptive reuse program that would restore the visibility of the building’s defining elements to the public. Under either alternative, adverse effects to any cultural resources within the APE would be addressed through the Memorandum of Agreement between the SHPO, FTA and NYCT. Long term Operation of the FSTC through 2025 would have resulted in improved access to cultural resources in Lower Manhattan, including the Corbin Building and the John Street-Maiden Lane Historic District, thereby contributing to a greater enjoyment of these resources. 20.4.5 BUSINESS AND ECONOMIC INTERESTS

(See Chapter 7 for Comprehensive Analysis)

COORDINATED DEVELOPMENT OF THE CUMULATIVE BUSINESS AND ECONOMIC FACTORS ANALYSIS

The cumulative business and economic factors effects analysis was developed through coordination among the NYCT, FTA and the other Lower Manhattan Recovery Project sponsors in 2003 and 2004. Potential issues, analytical methods to address the issues, and data to support the analysis were discussed. An overview of the methodologies, assumptions and coordination is included in Appendix N: Environmental Analysis Framework. A detailed discussion of the effects on business and economic interests is presented in Chapter 7: Social and Economic Conditions. Construction activities that have the potential to cause short-term economic impacts include: utility disruptions on business activities; limitations on pedestrian, vehicular, and transit access to businesses; restricted visibility of businesses; losses or increases in jobs; potential increases or losses in retail sales; effects on the tax base; temporary and permanent displacements and relocations; and effects on property valuations. An intended long-term effect of the reconstruction and recovery efforts is to restore Lower Manhattan to its role as an important economic engine for the region, and position Lower Manhattan for an appropriate share of the region’s growth. In addition, the Recovery Projects would also improve the accessibility, livability and economic vitality of Lower Manhattan. These factors typically lead to improved economic activity across various sectors, improved property values, and greater demand for living, shopping and working in an area. The cumulative net effect of the Recovery Projects over the long-term is expected to be beneficial. During its operation, the FSTC would aid in transforming the area into a viable mixed-use community, which supports the downtown revitalization goals of the City and State. The project’s analysis of business and economic factors impacts from cumulative construction activities was also developed from and refined through discussions among NYCT, PANYNJ, LMDC, NYSDOT and FTA, and other agencies involved in the Lower Manhattan recovery effort. These discussions also led to the development of common EPCs for business and economic factors related to the Lower Manhattan Recovery Projects. Specifically, these EPCs include:

• Coordination through consultation with the LMDC, the Downtown Alliance, and other entities to minimize residential and retail impacts; and,

• Appropriate signage for affected businesses and amenities to maintain their visibility, when obscured as a result of construction activities. It is anticipated that further refinement, including implementation procedures, of the EPCs are to be addressed by Lower Manhattan Recovery project sponsors or may be addressed in the MPT plan.

In addition to these EPCs, which are specifically tailored to socioeconomic conditions, potential effects on socioeconomic conditions have also been proactively addressed through other EPCs and mitigation measures intended to avoid or minimize effects on access and circulation, noise and vibration, air quality, and cultural and historic resources, all of which may indirectly affect socioeconomic conditions.

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Discussions of the aforementioned EPCs are presented in their respective sections in this chapter for air quality, noise and vibration, access and circulation and cultural and historic resources. Methodologies and project issues were also discussed by NYCT with resource agencies in Technical Advisory Committee (TAC) meetings. A discussion of public outreach activities and agency coordination is included in Chapter 5: Public Outreach. Implementation of the EPCs would be formalized through a Public Involvement and Governmental Entities Coordination Plan. Development of such a plan is a component of the Environmental Analysis Framework signed by NYCT, PANYNJ and NYSDOT. This plan would describe how the sponsors of Lower Manhattan Recovery Projects would coordinate with one another, resource agencies (including NYCDOT, NYCDDC, NYCDEP and NYSDEC) and local community organizations and business interests regarding the implementation of the construction process, and development of more detailed EPCs and implementation of EPCs for all Lower Manhattan Recovery Projects. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - NO ACTION ANALYSIS

Under No Action conditions, the Existing Complex would essentially remain as is and the FSTC would not be constructed. The other Lower Manhattan Recovery projects would still be under construction during the 2005/2006 analysis period and would generate both adverse impacts on business and economic interests, due to disruption, and beneficial impacts due to construction spending. Although the temporary disruption that would occur as a result of construction of the FSTC would not occur, neither would the benefits to local business that would result from construction spending. It should be noted that even under the No Action Condition some degree of access disruption would still occur in the vicinity of the Existing Complex, as a result of the street reconstruction program implemented by NYCDOT. This program involves extensive street reconstruction and relocation of utilities. Although such street reconstruction would also occur under the Build Alternatives, the street reconstruction would be integrated with the construction of the FSTC. 2005/2006 TEMPORARY CONSTRUCTION CONDITIONS - ESTIMATION OF CUMULATIVE CONSTRUCTION EFFECTS WITH FSTC BUILD ALTERNATIVES

Under this discussion, Build Alternatives 9 or 10 would be constructed as described in Chapter 4: Construction Methods and Activities. For the purposes of analyzing potential cumulative effects to economic and business interests, there would not be any substantive differences between Alternatives 9 and 10. Potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. Alternative 9 would involve the demolition of five (5) existing buildings and the relocation of approximately 16 retail tenants, 72 commercial/office tenants, and 10 vacant offices (see Chapter 10: Displacement and Relocation). As such, land use on the site would change from a mixture of commercial and institutional space with street-level retail establishments, into a dedicated public space containing transit facilities that incorporates new retail and cultural spaces. Alternative 10 would require the relocation of 44 additional tenants (11 retail and 33 commercial/office) and loss of eight (8) vacant spaces with the acquisition of 192 Broadway. As discussed in Chapter 7: Social and Economic Conditions, although the City property tax base would be reduced by approximately one (1) million dollars under Alternative 9 and $1.2 million under Alternative 10 with the acquisition of properties by NYCT, it is expected that most businesses would have the opportunity to relocate within the City. As a result there would be little or no loss in retail and business tax revenues. Moreover, the FSTC would provide additional tax revenues from the new retail businesses on the site. Even though there is little vacant land in the vicinity of the FSTC, the FSTC is expected to assist in the recreation of the conditions that would foster the redevelopment of Lower Manhattan as well.

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The components of the FSTC that have the potential to overlap with activities at the WTC site are the construction of the Dey Street Passageway between Broadway and Church Street and the widening of the AC mezzanine at Fulton Street, between Broadway and Nassau Street. The construction at Dey Street would affect deliveries to Dey Street and in particular Century 21, a major department store in the area. Access to Century 21 could also be affected by construction truck traffic associated with the FSTC, the Permanent WTC PATH Terminal and the WTC Memorial and Redevelopment Plan as well as the proposed reconstruction of Broadway and Church Street by NYCDOT. As discussed under cumulative effects on traffic and transportation, no adverse cumulative effects are anticipated on parking conditions and no adverse effects on business and economic conditions associated with parking are anticipated. To address the potential for cumulative construction impacts to adjacent properties, the construction plan for the FSTC would be coordinated by NYCT with NYCDOT, PANYNJ and LMDC. As described in Chapter 6: Traffic and Transportation, pedestrian and vehicular access along Dey Street, Fulton Street, and Broadway in the vicinity of the projects would be maintained during most of the construction period. Street reconstruction planned by NYCDOT during this period will be coordinated with the construction of the FSTC to avoid cumulative impacts. Through traffic on Dey and Fulton Streets would be temporarily disrupted during construction. However, pedestrian access would be maintained at all times on Fulton and Dey Streets. Pedestrian and vehicular access for deliveries to portions of Dey and Fulton Streets in certain locations would be restricted during construction; however alternate access points would be made available for pedestrian access, service and deliveries, as discussed under cumulative effects on traffic and transportation, earlier in this Chapter and in Chapter 6: Traffic and Transportation. Maintaining access would be a part of the MPT plan, as described in Chapter 6 of the DEIS. This MPT plan is currently under development in coordination with NYCDOT. Illustrative maps of MPT planning efforts in progress are included in Appendix C: Construction. NYCT would consult with businesses and property prior to and throughout the construction period and in drafting and implementing the MPT plans, as more information becomes available regarding construction specifics. Based on the MPT plans currently under development it is not anticipated that these commercial operations would be substantially affected by cumulative construction activities. The projects would implement the EPCs, which require appropriate signage for affected businesses and amenities to maintain their visibility, when obscured as a result of construction activities. As mentioned earlier, issues related to signage and temporary closures may also be addressed in the MPT plans. Beneficial cumulative effects would result during construction as a result of increased demand for goods and services generated by the large numbers of construction workers and construction activity at and in the immediate vicinity of the project site. The combined construction spending of the FSTC and the other Lower Manhattan Recovery Projects will create a stable demand that will support various economic activities while Lower Manhattan is under construction. As portions of the FSTC are completed such areas will be positioned to take advantage of this demand for services. Due to the proximity of other large-scale construction projects such as the WTC Memorial and Redevelopment Plan and the Permanent WTC PATH Terminal, the construction spending would directly benefit the most local economic and business interests. Conclusions Regarding Construction Cumulative Impacts: Business/Economics Based on the foregoing analysis, the FSTC, in combination with other reasonably foreseeable future actions, would not result in substantial adverse cumulative construction effects on business and economic factors. Utility relocations would be coordinated to minimize disruptions on business activities; pedestrian, vehicular, and transit access would be maintained to businesses and other land uses; visual access to businesses would not be restricted; and, there would be minimal effects on retail sales, the tax base, and property valuations during construction.

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Coordination with economic development interests on maintaining the attractiveness of Lower Manhattan as a place to live, work and enjoy recreation, while maintaining a level of accessibility commensurate with that attractiveness, would serve to minimize cumulative business and economic effects. As stated earlier, there are no anticipated adverse cumulative effects on business or economic conditions during construction activities. From a cumulative perspective, none of the other Lower Manhattan Recovery Projects would result in substantial relocation to the extent that it could affect the relocation of tenants and owners currently occupying the properties at Broadway proposed for deconstruction to enable construction of the Entry Facility and the Dey Street Access Building. It is anticipated that local retail and other revenue-generating land uses will experience cumulative benefits as a result of the influx of construction activity from FSTC and adjacent Lower Manhattan Recovery Projects. Beneficial cumulative effects during construction would occur as a result of the construction spending for FSTC as well as the other Lower Manhattan Recovery projects. As the construction in Lower Manhattan will continue over several years, the benefits of such construction spending for local business and economic interests will continue to accrue. This includes both localized spending by construction workers and firms on services in the vicinity of the projects, as well as over a larger geographic area. Such direct spending and demand for services is expected to substantially benefit businesses and the local tax revenue. 2008 - SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ANALYSIS

In 2008 the existing properties would remain and would be occupied by a similar mix of retail and commercial uses. As with many locations in Lower Manhattan, the parcels on this site are not built-out to the full capacity of their zoned Floor Area Ratio (FAR). Given the current higher than average commercial vacancy rates and the amount of office and commercial space in development in Lower Manhattan, it is anticipated that this condition would continue through 2008. Through 2008, the trend of conversion of commercial buildings to residential uses and the transformation of existing retail/service establishments to cater to the needs of the residential population is expected to continue, assisting the area’s transformation into a 24-hour community. A review of potential development projects and land use changes indicates no additional major projects scheduled for completion during the period from 2006 to 2008 in the primary study area (the area bounded by Chambers Street, Pearl Street, West Street and Exchange Place). At the WTC site, construction of the Memorial is scheduled to be complete, along with many of the subsurface elements such as the slurry walls, tunneling and underpinning. Still under construction at the site would be: the cultural space; open space elements (Heroes Park, September 11 Place, Liberty Park); the Freedom Tower; and, Towers 2, 3, 4 and 5 with associated retail space at the base. For the remainder of Lower Manhattan, several major residential development projects are projected for completion from 2006 to 2008. Taken together, residential development on these sites would produce over 1,650 units and 40,000 square feet of retail space. In addition, residential conversion is proposed for 23 Wall Street (the site originally assembled for the New York Stock Exchange relocation) and could be completed as early as 2007 adding an additional 1,300 units of residential space to the Financial District. Continued operation of the Existing Complex in its current condition would not as readily support the revitalization of Lower Manhattan, as it would not improve access to Lower Manhattan and thereby would not support economic development. Because of the magnitude of development expected, continuation of the Existing Complex would have an adverse cumulative effect on the continued revitalization of Lower Manhattan.

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2008 - SHORT TERM OPERATIONAL CONDITIONS - ESTIMATION OF CUMULATIVE EFFECTS WITH FSTC BUILD ALTERNATIVES

As described earlier, potential impacts and mitigation measures would be similar for both Alternatives. As a result, both Build Alternatives are presented under this discussion. The FSTC would involve the demolition of five (5) existing buildings and the relocation of business tenants (see Chapter 10: Displacement and Relocation). As such, land use on the site (except for 192 Broadway) would change from a mixture of commercial and institutional space with street-level retail establishments, into a dedicated public space containing transit facilities that incorporates new retail and cultural spaces. Between the two (2) alternatives, Alternative 10 would provide the greatest contribution to revitalization and consistency with stated Federal, State and City public policy promoting revitalization, as it would also make the cultural resource more attractive to the public through rehabilitation and revitalization, both in terms of access and visibility. As discussed in Chapter 7: Social and Economic Conditions, although the City property tax base would be reduced by the displacement of businesses in the Build Alternatives, it is expected that most businesses would be relocated within the City. As a result there would be little or no loss in retail and business tax revenues. Moreover, the FSTC would provide additional tax revenues from the new retail businesses on the site. Even though there is little vacant land in the vicinity of the FSTC, the FSTC is expected to assist in the recreation of the conditions that would foster the redevelopment of Lower Manhattan as well. The operation of the FSTC would be directly responsive to Federal, State and City-stated public policy in that it would improve accessibility to Lower Manhattan, and facilitate the movement of pedestrians between destinations within Lower Manhattan. Operation of the FSTC from 2008 onward would provide immediate benefits in terms of wayfinding and mobility to and within Lower Manhattan, both of which are expected to immediately contribute to the revitalization of Lower Manhattan and may help offset some of the temporary construction impacts of other Lower Manhattan Recovery Projects. During the initial years of operation of the FSTC, other parts of Lower Manhattan would still be under construction (in particular at and in the immediate vicinity of the WTC site). Construction in these areas would temporarily affect pedestrian and vehicular access and circulation in Lower Manhattan and thereby could temporarily affect economic activity. However, these construction activities from other Lower Manhattan Recovery Projects would also continue to generate a demand for goods and services that would benefit local business and economic interests. The FSTC upon its opening (expected at the end of 2007) would immediately start to provide improved transit access and street circulation in Lower Manhattan, thereby helping to reduce the temporary inconvenience to access and circulation caused by the construction of other Lower Manhattan Recovery Projects. Furthermore, as the first transportation recovery project expected to be completed in Lower Manhattan, the operation of the FSTC as a major public investment would signal the recovery of Lower Manhattan. It would improve transit access to Fulton Street, envisioned as a future retail corridor by LMDC and through its entrances on John Street via the Entry Facility and the Dey Street Passageway would also improve access to the new John Street-Maiden Lane Historic District, thereby making this cultural resource more attractive for visitors to Lower Manhattan. In addition, operation of the Dey Street Passageway would provide an underpass beneath the busy Broadway/Dey Street intersection and provide commuters immediately with the benefits of improved pedestrian access to destinations east of Broadway, thereby contributing to the revitalization of the business environment. In addition, the Dey Street passageway would provide improved subway access to anchor retail operations and hotels such as Century 21 and the Millenium Hotel. As Church Street may still be used as a staging area for construction at the WTC site, alternate and improved access via Dey Street to the Century 21 department store and the Millenium Hotel would also help reduce potential effects of inconvenience to access and circulation on Church Street. People with disabilities may be

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especially sensitive to the effects on access and circulation from construction activities due to rerouting of pedestrian routes, crowded sidewalks and other temporary construction conditions that affect pedestrian circulation. In this regard it is important to note that the FSTC would provide substantially improved access for people with disabilities, not just at the Entry Facility itself but also through the installation of ADA compliant elevators at various locations, including near the Millenium Hotel and Century 21 on Dey Street. In summary, operation of the FSTC would have a beneficial cumulative effect on business and economic interests in 2008, and is not expected to induce indirect or secondary land use changes within the study areas. 2025 SHORT TERM OPERATIONAL CONDITIONS - NO ACTION ALTERNATIVE

By 2025, the primary study area would have undergone substantial changes in land use compared to pre- and post-September 11 conditions. Overall, with developments at the WTC site and elsewhere within Lower Manhattan, it is anticipated that roughly 13 million square feet of commercial space would be added below Canal Street by 2025. Like the primary study area, the vast majority of anticipated commercial space is for office use, but substantial additions of both retail and institutional space are also expected, including a mixed-use New York University (NYU) Downtown Hospital and developments at 79 Maiden Lane and 10 Barclay Street. For all of Lower Manhattan, it is anticipated that over 16,000 new residential units would be completed by 2025, resulting in an increase of approximately 24,000 residents to the area south of Canal Street. Without the FSTC, the substantial economic redevelopment of Lower Manhattan, as indicated above, would continue to be hampered by an inadequate, inefficient and outdated subway system. Because accessibility limitations associated with this outdated system would detract from the overall revitalization of Lower Manhattan, this would have a negative cumulative effect on business and economic interests in 2025. 2025 - LONG TERM OPERATIONAL CONDITIONS - ESTIMATION OF OPERATION CUMULATIVE EFFECTS WITH FSTC

With operation of the FSTC through 2025, four (4) of the five (5) existing buildings would have been removed with the historic Corbin Building remaining, either as a separate structure (Alternative 9) or integrated with the Entry Facility (Alternative 10). For the purposes of analysis of potential cumulative effects on economic and business interests, there would not be any substantive differences between Alternatives 9 and 10. Business tenants in all six (6) buildings (approximately 100 to 150 tenants, depending on the alternative) would have been relocated and would have re-established themselves elsewhere in Lower Manhattan or would have been compensated in accordance with State and Federal regulations. As such, land use on the site would change from a mixture of commercial and institutional space with ground-floor retail establishments into a public space housing transit facilities that incorporates new retail and cultural spaces. While the FSTC is expected to contain new retail space inside the facility, the overall floor area of retail space would be less than that displaced from the existing buildings. However, it is anticipated that most displaced businesses would relocate within the City, so the tax revenue should remain relatively constant. Additional tax revenue is expected to be generated from the new retail space in the FSTC. Overall, the FSTC would contribute to the vitality of existing and future retail activity anticipated for Fulton Street and Broadway. The improved accessibility of businesses in the vicinity of the FSTC would enhance their economic vitality and would help generate additional sales taxes and other revenues. With its central location at the intersection of two (2) major pedestrian arteries Lower Manhattan (Fulton Street and Broadway), the FSTC would make the retail activities along these streets better accessible. In addition, it would contribute to improved access to Lower Manhattan resulting in the reduction of travel time by an estimated 900,000 hours per year for all commuters combined using the FSTC. In addition to

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these direct productivity benefits, this would help create a more attractive environment to live, work and enjoy recreation. As an unpaid passageway, the Dey Street Passageway would benefit both patrons of the subway system and other pedestrians traveling east or west between Church Street and Broadway. The Dey Street Passageway would reduce pedestrian congestion on Dey Street and at the intersections of Dey Street and Broadway and Dey and Church Streets during the rush hours, thus creating a safer and more inviting retail environment. In addition, the Dey Street Passageway would provide better subway access to retail and hotels on Dey and Church Streets and also to the proposed new commercial and institutional development at the WTC site. This would also contribute to a better flow of vehicular traffic, expected to increase in volume as a result of continued economic growth in Lower Manhattan through 2025. As street-level pedestrian congestion would be reduced, this would create a more pleasant and safer pedestrian environment, especially for children and people with disabilities. In the long term, i.e. post-construction, the FSTC would be a contributor to business and economic growth in the area. The long-term beneficial effect of the FSTC would be enhanced by the intended long term revitalization benefits of the other Lower Manhattan Recovery Projects. The Lower Manhattan Recovery Projects with the highest potential to have long-term beneficial cumulative economic impacts in combination with the FSTC are the Permanent WTC PATH Terminal, the WTC Memorial and Redevelopment Plan and the Fulton Corridor Revitalization Study. Of these projects, the latter is still under study by LMDC. The stated intent of these projects is to revitalize Lower Manhattan and it is assumed that the long-term cumulative effects of these projects would be beneficial. 20.5 SUMMARY OF CUMULATIVE EFFECTS In summary, construction of the FSTC would create temporary cumulative adverse effects on access and circulation, traffic, air quality and noise, cultural resources and business and economic interests. Further details of these temporary impacts are provided in the technical sections of this chapter, and in the technical resource chapters and appendices of this DEIS. However, such effects would be temporary and short-term. Construction spending associated with the FSTC, as well as the other Lower Manhattan Recovery Projects, however, will have a cumulative beneficial effect on local business and economic interests due to increased demand for goods and services generated by construction workers, contractors and other indirect spending associated with construction activities. Economic benefits associated with construction spending will not be limited to the immediate vicinity of the Project Site but would extend over a larger are, generating a demand for a broad range of services associated with construction activities. Long-term cumulative benefits of the FSTC with regard to business and economic interests would start to be realized immediately from the FSTC’s opening at the end of 2007 and continuing throughout its operation. Analyses conducted for 2025 operational conditions indicate that the benefits of improved transit access to Lower Manhattan in the form of the FSTC would have accumulated over almost two decades and would have made a substantial positive contribution to the revitalization of Lower Manhattan over that that period. Operation of the FSTC would provide the long-term basis for sustained economic growth in Lower Manhattan and would enable such growth to occur in an environmentally sustainable way by providing environmentally-friendly transportation opportunities to residents, workers and visitors to Lower Manhattan for decades to come. 20.6 COMMITMENTS TO MITIGATING ADVERSE EFFECTS –

MAXIMIZING LOWER MANHATTAN RECOVERY NYCT is committed to an ongoing process with FTA and the other Lower Manhattan Recovery Projects sponsors to minimize adverse effects and maximize Lower Manhattan recovery. The NYCT commitment is evidenced by the success of its past and ongoing Lower Manhattan recovery efforts, including:

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• Implementing design and construction practices consistent with the NYCT ISO 14001

certification; • Developing effective EPCs to be implemented in concert with the other Recovery Projects and

Federal partners; • Developing the Lower Manhattan Environmental Analysis Framework, co-signed by the

Recovery Projects sponsors; and, • Actively participating in ongoing coordination with the other Recovery Projects on their projects’

development, effects and commitments. NYCT will continue to develop, document, broadcast, and implement practicable methods, practices and procedures to manage the environmental effects of its actions, individually and cooperatively with the other recovery sponsors. This process will be managed through monitoring and continuous improvement.