• Subways are so uncrowded now during rush hours that there will be enough capacity for the added riders from all new development in 2016 and the 83.000 subway riders a day that Atlantic Yards alone will add, so there’s no need to add any trains or buses during peak hours.
• Atlantic Yards will have an insignificant effect on buses, bus use will hardly grow at all, and there’s plenty of spare capacity, except on the B38. But can always add more buses when demand occurs.
• Pedestrians are better off (safer) with longer waits for green time and longer crossing routes. DEIS has no obligation to analyze pedestrian hazards or consider traffic calming measures.
• Currently, between 5-6 PM, 35% of on-street parking spaces within ¼ mile of Atlantic Yards site are available. By 7-8 PM, 53% of parking spaces are now available and in 2016, 51% (3,091) will be and because there are sufficient off-street spaces for Atlantic Yards parkers, few drivers will be circulating on local streets searching for free on-street parking.
• Traffic currently flows through the Atlantic/Flatbush/4th Avenue intersection at good to acceptable conditions in the PM peak hour and characterization is valid baseline for evaluating impacts.
• Trip generation characteristics based on 30-year old surveys in Manhattan are valid for Brooklyn. Can rely on 2000 Census data for travel patterns, even though discredited by NYMTC.
• Okay to only account for less than half the development in pipeline. Only need to consider certain-to-be-built projects within ¾ mile radius of Atlantic Yards, even if that leaves out much of DTB.
• DEIS can assign 30% of peak hour Atlantic Yards auto trips onto congested BQE and not assume they force any BQE traffic onto local streets. Can also add traffic onto roads that have no capacity.
• A $2 discount on a Metrocard pass when buying $85 or $105 tickets on line will achieve a 20% reduction in the 2,500 auto trips to Arena games, est. based on response to Metrocard discounts.
• The DEIS can continue to use the CEQR traffic analysis method that ignores spillback effects, even though the DEIS finally admits that adding more trips than the capacity of an intersection will cause long upstream traffic back ups.
• DEIS can take congestion mitigation credit even for one second transfers of green time from one movement to another, asserting that remaining delays of 5-10 minutes will are acceptable.
• The DEIS doesn’t have to make public its traffic simulation model for mitigating the Atlantic, Flatbush, 4th Avenue intersection, after years of insisting it was not allowed to be used under CEQR.
• No need to document assumptions, provide traffic analysis worksheets, demonstrate feasibility of mitigation.
• To accommodate Atlantic Yards, communities will just have to live with unmitigatable traffic. No other solutions are available.
• ESDC and FRC have no obligation of DEIS to consider ongoing plans, e.g.,, Bus Rapid Transit pilot program, DTB Traffic Calming project , Resident permit parking study, Flatbush Avenue Redesign, DTB Transportation Blueprint, NYS Energy Plan, and a NYMTC air quality plan conformity determination.

 REBUTTAL

•  In 2016, with realistic growth, 6 of 10 subway lines will be over capacity, 3 will have severe “crush loads.”
• With historic growth, 7 of 10 bus lines will be over capacity. No consideration of Bus Rapid Transit.
• Pedestrians will be penalized with longer waits, less crossing time, circuitous routes, no traffic calming, more crashes.
• Traffic baseline inaccurate; 7% lower than in 2002 with 6 million sq. ft. more development. Traffic volumes should be 10% higher in 2006 not 7% lower, a differential of 17%.
• Contrary to DEIS, trip generation by affluent condo owners is very different from old Manhattan survey data. Much higher auto ownership and use in Brooklyn, especially by affluent. Not reflected in DEIS.
• Census data unreliable to predict origins and destinations, due to skewed sample. DEIS should have used NYMTC model for trip assignments.
• Map and list of omitted development show their clear effect on project area. Some completed projects are listed because they were not included in baseline traffic counts.
• BQE will be used by Atlantic Yards drivers from north or south because there are few options. Will force other traffic onto local streets; not accounted for in volume diagrams. Simplistic traffic method that permits loading traffic onto already overloaded roads must be replaced with model that assigns overflow to alternate routes.
• 20% auto use reduction w $2 Metrocard discount a fantasy. Response to fare discounts is no gauge for buyers of $100 arena tickets. MTA riders should not subsidize arena patrons. Arena ticket discounts more effective.
• Even though NYCDOT, as of August 9th, is “finalizing” its review of the Atlantic Yards DEIS, the primary mitigation strategy, complex signal timing changes to optimize traffic flow have not been reviewed by NYCDOT’s director of signal timing, who usually approves (if convinced) the plan before a DEIS goes public.
•  Despite parking management strategies to divert drivers to more distant parking facilities, some drivers will circulate to find free on-street parking, and they are not accounted for. Only effective safeguard is not mentioned in the EIS, making non-residents pay high meter rates (due to a resident permit parking program).
• Use of traffic simulation model to demonstrate mitigation near site proves superiority of method and falsity of long contention that the model could not be used for CEQR. Now DEIS must be revised to use it for more accurate disclosure of LOS impacts, a central issue in the public decision-making. Must make model available to public and expand to entire DTB network, including BQE, as CCS has done using DTB FEIS traffic volumes. CCS model shows that even with optimized signals and without Atlantic Yards volumes, the system is breaking down. With Atlantic Yards, it will be network-wide gridlock. The proposed mitigation won’t work.
• No, we don’t have to live with unmitigatable congestion, in fact, we can’t. It will kill us, our economic development, the success of the Arena and condo sales, and payback of public subsidies. The hidden costs of traffic delay, accidents, health effects and other real costs unwittingly paid by everyone affected is $75 million a year. The bargain solution to Brooklyn gridlock is equal tolls of all entrances to Manhattan below 60th Street. It will clear DTB roads of the 40% pass thru cars and it’s the only remaining source of new funds to add transit service--in short, good for everyone, including the drivers who pay the tolls and get faster travel.
• Analysis of alternatives falsely makes it appear there are not significant differences between the proposed project and the lower density alternatives by combining Atlantic Yards trips with the trips generated by huge existing and planned future development, thus, camouflaging the significance of the Atlantic Yards increment.
• The DEIS must examine the project in the context of on-going plans. The proposed Flatbush Avenue BRT route goes to the Arena door. Resident parking permit revenues could fund traffic calming and other enhancements. Demonstrating compliance with the 2002 State Energy Plan would require designing the project to reduce energy by 15%, promote (and certainly not impede) renewable energy and cut greenhouse gases by about 8%. As Atlantic Yards has been designated by NYMTC a “regionally significant project,” it must be evaluated with NYMTC’s air quality conformity model. Using the NYMTC model to test tolls could achieve both goals. And, if CBD-entry tolls were implemented, they would make the desired density doable.