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Research here assembled by Pratt students and faculty and then shared via Voices of the Watefront for comment. Subsequent editing by PortSide NewYork.
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In December 2025, the City completed two projects relevant to BMT:
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 1) NYC changed the CEQR technical manual after the BMT CEQR process started, issuing a new one. It will apply to this process. The 2nd tab refers to the updated CEQR manual sections. https://www.nyc.gov/site/oec/environmental-quality-review/technical-manual.page
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2) NYC released a new Industrial Plan. Maritime is mentioned throughout. The section "SOUTH BROOKLYN STRATEGIC PLANNING AREA" is mostly Red Hook and Sunset Park and starts on page 46. https://www.nyc.gov/assets/planning/downloads/pdf/our-work/plans/citywide/nyc-industrial-plan/nyc-industrial-plan-final.pdf
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Talking PointRelevant CEQR Chapter(s) and links
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Below in the blue shaded area are 3 ways to testify in support of PortSide NewYork. Below that is a long list of other issues. See tab 2 for info on the CEQR Technical Chapter Details
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The Mary A. Whalen, the historic ship home of PortSide NewYork, is a “historic and cultural resource” for being on the National Register with National Significance. Since PortSide is not promised a home in the BMT Vision Plan and is not mentioned there, and is not mentioned in the EDC’s maritime workforce study (NYC's Working Waterfront: a Blueprint for Blue Highways); it appears that the EDC plans to displace PortSide. To get a template for testimony addressing the 4 PortSide sections here, go to https://portsidenewyork.org/portsideneedsahome Historic and Cultural Resources
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PortSide NewYork ship and programs fall under categories "Community Facilities and Services" AND "Neighborhood Character." as we describe above, the EIS needs to study the negative impacts on both those criteria if the proposed Vision Plan that does not include the continuation of a home for us is implemented. We need testimony to say that to be sustainable, we need more space than a berth for the ship since the ship has such little interior space. We need building space, and ideally outdoor space ashore and additional pier space. Community Facilities and Services, Neighborhood Character
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The plan’s omission of PortSide amounts to “direct displacement” of a community-serving nonprofit that has been in Red Hook for 20 years. PortSide provides workforce pathways, CTE internships, and volunteer opportunities for local youth and unions. Loss of PortSide would reduce maritime career access for historically excluded groups.Socioeconomic Conditions – Direct Institutional Displacement
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re: PortSide NewYork and general maritime: Say that the EDC's BMT Vision Plan does not align with the 2016 Waterfront Revitalization Program (WRP) of the Department of City Planning which advocates for protection of SMIA (significant maritime industrial areas) and IBZs (industrial business zones) and calls out the Red Hook port as significant. Mention that within the WRP is a recommendation for "maritime hubs" (which must be based on PortSide proposals because no one else has been advocating this combination of B-to-B services to workboats and public maritime programs at the same times) that the EDC is not allowing PortSide to fulfill by displacing PortSide in their BMT Vision Plan. See POLICY TWO SUPPORT WATER-DEPENDENT AND INDUSTRIAL USES IN NEW YORK CITY COASTAL AREAS THAT ARE WELL-SUITED TO THEIR CONTINUED OPERATION; 2.1 Promote water-dependent and industrial uses in Significant Maritime and Industrial Areas: E. Promote the development of temporary and permanent maritime hubs to support maritime operations. Maritime hubs are sites which contain some of the following features: tie-up space, removal of bilges, grey water and sludge, refueling, water and electric connections, crew change capacity, proximity to groceries and restaurants, and proximity to transit. A hub could also integrate commercial, recreational, tourist, and/or educational uses within the same complex. Hubs should be located close to active maritime facilities, anchorage, and berthing locations to minimize travel distances. from https://www.nyc.gov/assets/planning/download/pdf/planning-level/waterfront/wrp/wrp-2016/nyc-wrp-full.pdf"Land Use, Zoning and Public Policy"SMIA info https://opdgig.dos.ny.gov/datasets/NYSDOS::nyc-waterfront-revitalization-program-wrp/about?layer=3
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All other issues below are sorted by relevant chapter of CEQR Technical Manual 2025. See Tab 2 for more info on the criteria.
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Expand study area beyond the 400' impact area proposed by the EDC. The transportation impact study should extend north to BEQ Tillary St exit and inland to 3rd avenue and south to Prospect Expressway. The resiliency study has to include all of Red Hook. Sewershed issues need to include the impact of the new Gowanus housing as what they flush comes through Red Hook on the way to the Red Hook Wastewater Treatment plant in the Navy Yard.
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The proposed study area is too small and needs to be expanded out further into the community. The "no action" measurements are not realistic without expanding the study area, and the increments are therefore not rationally calculated. Expand the project study area to extend further inland into Red Hook for a more comprehensive CEQR impact analysis. Recommended range is north to Tillary St exit of BQE, inland to 4th avenue, south to Prospect Expressway"Land Use, Zoning and Public Policy", Neighborhood Character, Socioeconomic Conditions
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Make sure that issues related to the City's Waterfront Revitalization Program and the NYS Coastal Zone Management Plan are fully addressed. You can point out that BMT is designated as a "Significant Maritime and Industrial Area (SMIA) so the process to alter that designation has to be thoroughly assessed over the LONG term in the EIS."Land Use, Zoning and Public Policy", Neighborhood Character, Socioeconomic Conditions
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Section on economic displacement caused by thousands of new market rate units has to be strong and convincing. What are the displacement effects to those who are not rent protected? Add displacement effect on m-zone businesses since, if the past 25 years shows that property owners will seek variances, illegally put non-m-zone uses in their buildings, and/or seek rezoning. Businesses (and jobs) stand to be displaced not just residents."Land Use, Zoning and Public Policy", Neighborhood Character, Socioeconomic Conditions
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The Alternatives section should address a full retention of maritime uses on Piers 7-12. "Land Use, Zoning and Public Policy", Neighborhood Character, Socioeconomic Conditions
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Evaluate air pollution from increased boats that are not electricAir Quality, Greenhouse Gas Emissions and Climate Change, Public Health
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The amount of public subsidy needed for raising infrastructure to support the (affordable?) housing units is going to be a lot higher than it would be if housing were not within this "BMT Vision Plan" siteAlternatives
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The time span currently being studied with a build year of 2038 is not sufficient, given the known knowns and also the known unknowns about sea level rise, groundwater rise, and other climate risks that aren't even being considered. The increments should be studied at 50 years, and beyond. There is modeling available for this. Should rely on cutting-edge climate modeling.Alternatives, Greenhouse Gas Emissions and Climate Change
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Cumulative construction + coordination (keep & strengthen). Study overlapping timelines and traffic detours with BQE Central and Red Hook Coastal Resiliency (RHCR), plus agency easements/approvals needed to coordinate worksites and temporary street closures so emergency access and bus speeds aren’t degraded. The City’s determination explicitly flags RHCR coordination and multi-agency approvals—use that to insist on real coordination plans in the DEIS.Construction
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The scope of work must include impacts of construction for this project area and the build period on the plans for BQE repair/constructionConstruction, Transportation
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electric grid capacity and renewable energy, like solar, should be looked at. Kedin Kilgore who ran FAC's solar program https://www.linkedin.com/in/kedin-kilgore-b83604296/ has a good understanding of the local electric grid. The BMT project is a unique opportunity to develop a community scale network of renewable and resilient energy. The landfill and massive earthwork proposed to raise the port and access roads provide low-cost path to build a thermal energy network (TEN,) most efficient renewable energy infrastructure solution available. This installation can deliver long-term affordable heating, cooling and hot water to the BMT buildings and surrounding communities and is supportive of building electrification & decarbonization; community-scale clean and resilient energy; and is compatible with flood control and sewer infrastructure. Solar+battery storage can support the 'all electric port' and be integrated with a community solar and microgrid network as well as an electric transporatation network to serve local emergency power and grid resilience functions.Energy
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Will climate-resilient infrastructure at the site be sea walls or a raised platform?
~ If sea walls, who will maintain them? Whose responsibility is it if a private development happens on this public land?
~ If the raised platform, How expensive will it be to build it strong enough hold the housing? On the Socioeconomic impacts and community character side, how will this platform be integrated into the existing neighborhood? How will the existing neighborhood be protected from waters circumventing this raised space?		Greenhouse Gas Emissions and Climate Change, Socioeconomic Conditions, Water and Sewer Infrastructure
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All available records of spills, leaks, or previous remediation activities should be disclosed and evaluated.Hazardous Materials
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Model how sea-level rise, storm surge, and heavy precipitation events could mobilize contaminants in soil, sediments, and groundwaterHazardous Materials
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Identify and characterize any historic fill materials used on-site that may contain legacy contaminantsHazardous Materials
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Develop a detailed soil management plan addressing safe handling, storage, and off-site disposal of contaminated soilHazardous Materials
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The study must also address health and safety concerns during construction. Specific measures are needed to protect residents and workers if hazardous materials are uncovered during excavation or demolition.Hazardous Materials, Construction
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Controls for dust, vapors, runoff, and other potential exposure pathways must be clearly described. This is particularly important given proximity to homes and the waterfront.Hazardous Materials, Construction
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Since the site of the BMT is a brownfield, the Human Health Risk Assessment should be done to evaluate if the site is safe for residential use. (https://www.epa.gov/risk/conducting-human-health-risk-assessment ) Hazardous Materials, Construction, Public Health, "Land Use, Zoning and Public Policy"
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Evaluate the cumulative exposure risks to nearby residents and workers, referencing NYSDEC's Environmental Justice Siting LawHazardous Materials, Public Health
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The proposed study area is not sufficient to measure construction impacts on historic resources in the community, and existing homes in the area. (Reference how the concrete facility had already damaged foundations of homes on the street). Other impact on historic & cultural resources is displacement of historic ship Mary A. Whalen and related nonprofit PortSide NewYork. Historic and Cultural Resources, Construction
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What will be the impact on marine life (fish, oysters, whales, dolphins) from the infills that will be needed to build all that housing?Natural Resources
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Natural resources and in-water work. Require full assessment of in-water fills, pile driving, turbidity, and habitat impacts to fish, oysters, marine mammals, and benthic communities, plus mitigations and monitoring during each marine phase. “Natural resources” is already listed as a significant impact area—use that to insist on robust in-water modeling and seasonal work windows.Natural Resources
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Since the site of the BMT is a brownfield, the Ecological Risk Assessment should be performed to evaluate possible effect of construction on the New York Harbor ecosystem. (https://www.epa.gov/risk/ecological-risk-assessment )Natural Resources, Hazardous Materials, Construction
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The study of noise needs to include considering how port/maritime operation and cruise noise will impact residents, since housing is being built right next to the operationsNoise, Public Health
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Evaluate noise pollution from construction and for residents after the project in completedNoise, Public Health, Construction
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Ask that the EIS evaluate temporary loss of access or quality of open spaces during the 12-year build-out and propose interim or replacement public spaces.Open Space
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Have the EIS measure tree canopy coverage, shade, and heat-mitigation value of new green areas, tying open space design to the city’s climate resilience goals.Open Space, Public Health
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If parts of the “29 acres” of open space in vision plan are privately managed plazas, rooftops, or limited-hour spaces, they shouldn’t count fully toward the ratio.Open Space, Public Health, Greenhouse Gas Emissions and Climate Change
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Community Health & Safety Plan (keep). Require a CEQR-tier health & safety plan with real-time public dashboards on air/toxics monitoring, soil/groundwater remediation updates, and construction schedules—available in English/Spanish and pushed by SMS/email to residents at Red Hook Houses and nearby blocks.Public Health
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Establish a Community Health and Safety Plan to keep nearby residents informed of remediation activities, air monitoring results, and construction schedulesPublic Health, Air Quality, Greenhouse Gas Emissions and Climate Change, Hazardous Materials
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Require the EIS to show a 15-minute walk-shed map and identify any “open space deserts” within Red Hook.Public Health, Open Space
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The EIS should include both existing and new residents and workers in the denominator so the open space ratio reflects total neighborhood load, not just the project’s internal residents.Public Health, Open Space, Greenhouse Gas Emissions and Climate Change
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Evaluate displacement to community members, businesses, and nonprofits (including PortSide)Socioeconomic Conditions
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The study does not explicitly address existing City policies, such as Industrial Business Zones. The EIS must study how much of the City's industrial base will disappear over the project build period and beyond.Socioeconomic Conditions, Community Facilities and Services, Other
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How will adding 27,000 new residents change the character of the neighborhood? This has to be measured beyond 400 feet.Socioeconomic Conditions, Neighborhood Character
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There needs to be more attention paid to environmental and racial justice, especially as the entire study area falls within the EJNYC Designated Disadvantaged Communities list. This should include gentrification and displacement, raised costs of living in surrounding neighborhoods, and unequal flooding impacts of investments in resilience of the new builds rather than resilience planning for the neghborhood as a whole.Socioeconomic Conditions, Other, Greenhouse Gas Emissions and Climate Change
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Evaluate pedestrian saftey from increased traffic Transportation
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How will this plan will coordinated with existing and developing BQE plans. Will this plan raise the price of reconstructing the BQE? What will the cumulative impact on traffic be?Transportation
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Freight, Blue Highways, and induced truck traffic. Because BMT is proposed as a key Blue Highways node with barges/fast ferries and “zero-emission vehicles,” the DEIS must test whether freight re-routing actually reduces or induces truck VMT in and around Columbia/Van Brunt/Hamilton and BQE ramps—and require intersection fixes at Hamilton Ave and Ferris/King/Clinton Wharf to be built before trip growth.Transportation
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How will the backflow of CSO and underground water be stopped from entering the bathtub of low-lying Red Hook as sea level rises? What will be the impact of thousands of new, protected, presumably raised buildings on this already-existing problem? Include mention of high water table near BMT (4-5' just outside the Atlantic Basin gate) and likely similar in parts of Red Hook that are landfill.Water and Sewer Infrastructure
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Sewers, CSO, heat, and public open space performance. Test whether 8.6M gsf and ~6,000 units overwhelm water/sewer infrastructure and worsen CSO in Buttermilk Channel/Gowanus Bay; and whether promised ~29 acres of open space actually cools/delivers health benefits near Red Hook Houses. Water/sewer and public health are already flagged as significant issues—push for green-infrastructure requirements and heat-mitigation metrics.Water and Sewer Infrastructure
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The water table in Red Hook around BMT is very high at 4-5' below the surface at Pioneer and Conover. How will foundations be installed without displacing water into the community in a way that causes damage. This is a different impact from the vibrations of driving pilings which is another concern given the history of cracking facades and building collapes in Red Hook and the Columbia Waterfront District due to the land being 19th century shoreline fill.
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Study of shadows, loss of daylight, wind exacerbation ie. downdraught effect and channeling (or funneling) effects of highrises espiecially along the Columbia St BMT North section
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Segmentation vs comprehensive plan - timing - major issue in EIS- cumaltive impacts - not looking at things holistically
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Point out that this EIS provides the needed disclosures of the actual plan's potential impacts. We welcome the start of the environmental review process will provide the needed assessment of what effects the BMT project will have on our community and the environment. This work should have been undertaken at least in part during the planning process informing the Task Force. Hopefully, the information gleaned during formal environmental review will shed light on how the proposed land use changes will impact Red hook. We hope that these findings will provide the basis upon which decision makers can approve a project that benefits the neighborhood, the borough and the city.
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Look at the project "purpose and need" to make sure that this fully addresses the need for long-term promotion of maritime commerce
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Make sure that the traffic section fully assesses the intersections that are currently operating poorly in the neighborhood, especially on cruise days.
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Not sure how to treat this, but the container barge service likely will be addressed in the traffic section. I think calling it out as a policy decision supported for many years to reduce truck traffic in the community. It's continued use has to be acknowledged as part of existing conditions in the traffic, air and noise sections: https://www.fhwa.dot.gov/Environment/air_quality/cmaq/policy_and_guidance/retrofitfunded.cfm
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Infrastructure and utilities need a thorough assessment because of the age of water, sewer, electric, gas systems AND the lack of much sewer and water piping in the BMT footprint at all since there are few buildings on site.
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Schools and public facilities need to account for the reasonable worst case conditions with thousands of new units.
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Alternatives that need to be explored (not just a "no build scenario": what would the impact be of building just the port and maritime industries now with the money that already exists? Could that be made climate resilient at a lower cost? Would it be cheaper and more sustainable to build housing at an alternative, non-waterfront location?
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What would be the economic impact of a full buildout of a Blue Highway system without housing?
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“The Draft Scope proposes analyzing a single ‘Build Year’ of 2038 and frames the buildout over roughly a 10–15-year window (construction starting in 2026 and substantially operational in 2038). We appreciate the clarity, but this horizon is too short to capture the project’s long-term environmental risks and obligations. The DSOW itself requires the EIS to disclose both short- and long-term effects, and it cites New York City Panel on Climate Change projections of sea-level rise out to the 2050s, 2080s, and 2100. Therefore, we request that the DEIS include additional analysis years beyond 2038—specifically at least 2050 and 2080—for coastal flooding, utilities/CSO performance, energy resilience, open-space usability, and public health exposure, and that it commit to adaptive mitigation triggers tied to those futures. This is consistent with the DSOW’s purpose to assess long-term effects and with the project’s own climate-resilience rationale.” NPCC sea-level rise projections to 2050s/2080s/2100 referenced in the DSOW.
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“Establish a Community Health and Safety Plan to keep nearby residents informed of remediation activities, air monitoring results, and construction schedules”
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talk to Gowanus Canal Conservancy and DEP (Alicia) directly to understand the NYC Storm Water capture rules,the understanding from meetings with GOTF is that there might be some bypassing of the more stringent NYC rules by developers opting for the state regs, so I would encourage us to be vigilant and to learn from that so that there can be no loopholes on storm water capture.

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This applies to Red Hook because it focuses on how projects may affect disadvantaged neighborhoods, which is relevant to BMT and surrounding communities. This is a new section in the December 2025 CEQR manual.Effects on Disadvantaged Communities
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