chapter 19: environmental justiceweb.mta.info/capital/fc_docs/feis/chapters/ch19.pdfoctober 2004...

MTA New York City Transit Fulton Street Transit Center FEIS and Section 4(f) Evaluation

October 2004 19.0 Environmental Justice 19-1

CHAPTER 19: ENVIRONMENTAL JUSTICE

19.1 INTRODUCTION

19.1.1 CONTEXT AND KEY ISSUES

This chapter presents an analysis of the Fulton Street Transit Center (FSTC) with regard to the goals of environmental justice. Presidential Executive Order (EO) 12898, issued in 1994, directs Federal and state agencies to incorporate environmental justice as part of their mission by identifying and addressing the effects of all programs, policies, and activities on minority and low-income populations. The fundamental principles of environmental justice are as follows:

• Ensure the full and fair participation by all potentially affected communities in the transportation decision-making process;

• Prevent the denial of, reduction in or significant delay in the receipt of benefits by minority and low-income populations; and,

• Avoid, minimize or mitigate disproportionately high and adverse human health and environmental effects, including social and economic effects, on minority populations and low-income populations.

In 1997, the U.S. Department of Transportation (USDOT) issued its Order to Address Environmental Justice in Minority Populations and Low-Income Population (USDOT Order) to summarize and expand upon the requirements of EO 12898 on environmental justice. The USDOT Order sets forth the transportation agency’s policy to promote the principles of environmental justice in all policies, programs and other activities that are undertaken, funded, or approved by the Federal Highway Administration (FHWA), the Federal Transit Administration (FTA) or other USDOT entities. As set forth in the order, FTA must take several steps to determine whether the project would have disproportionately high and adverse effects on minority and low-income populations. “Disproportionately high and adverse effects” are defined as adverse effects that are predominantly borne by a minority population and/or low-income population or will be suffered by the minority and/or low-income population and are appreciably more severe or greater in magnitude than the adverse effects that will be suffered by the non-minority or non-low-income population. In making determinations regarding disproportionately high and adverse effects on minority and low-income populations, mitigation and enhancement measures and all offsetting benefits to the affected minority and low-income populations may be taken into account. Additionally, the design, comparative impacts and relevant number of similar existing system elements in non-minority and non-low-income areas may be taken into account. FTA must ensure that any programs, policies or activities that will have a disproportionately high and adverse effect on minority or low-income populations will only be carried out if: 1) Further mitigation measures or alternatives that would avoid or reduce the disproportionately high and adverse effect are not practicable; and 2) A substantial need for the program, policy or activity exists, based on the overall public interest, and alternatives that would have less adverse effects on protected populations that would still satisfy that need would either have other adverse social, economic, environmental or human health impacts that are more severe, or would involve increased costs of extraordinary magnitude. Guidance on environmental justice issued by New York State Department of Environmental Conservation (NYSDEC) outlines similar goals and analysis considerations. This guidance defines environmental justice as, “the fair treatment and meaningful involvement of all people regardless of race, color or income with respect to the development, implementation and enforcement of environmental laws, regulations and policies” so that “no group of people, including a racial, ethnic, or socioeconomic group,



should bear a disproportionate share of the negative environmental consequences resulting from” an action.1 Issues that may be of particular importance to low-income and minority populations during the construction and operation of the Proposed Action include:

• Human health and quality of life effects related to construction at the project site and construction truck traffic off-site;

• Continued availability of community facilities, services and open space; • Preservation/enhancement of community character and cohesion; • Direct and indirect residential and business displacements arising from secondary development or

change in community character; and, • Economic vitality and job opportunities.

The events of September 11 resulted in residential vacancies in the study area (see Chapter 7: Social and Economic Conditions). While no post-September 11 data is available on the race/ethnicity composition of the population since the 2000 Census, it is assumed the events of September 11 did not have an impact on the population characteristics of the study areas and existing conditions in 2003 are considered to be representative of conditions that existed pre-September 11. Housing vacated post-September 11 has been reoccupied with assistance from agencies responsible for administering disaster recovery. Funds were provided to area residents of all income levels to cover costs associated with September 11 and its aftermath, as well as to provide financial assistance for the decision to remain in Lower Manhattan. Therefore, for the environmental justice analysis, future conditions with and without the FSTC were assessed against existing 2003 conditions. 19.1.2 CONCLUSIONS

Under the No Action Alternative, the Existing Complex would remain as is, except for routine maintenance measures and repair activities. No impacts on low income or minority communities would occur. Alternative 9 and Alternative 10 - the Preferred Alternative would not produce disproportionately high or adverse effects on low income or minority communities. The proportion of low income and minority residents in the primary study area is lower than that for Lower Manhattan, or New York County as a whole, indicating a low potential for disproportionate impacts to communities of concern in the immediate vicinity of the Proposed Action. In the secondary study area, the portion of Chinatown within the study area boundaries represents a community of concern for environmental justice because a portion of the truck route passes this area. This evaluation of environmental justice issues, based on impacts identified in other chapters of this Final Environmental Impact Statement (FEIS) including noise, air quality, traffic conditions, open space or community facilities and property acquisition, demonstrates that construction of FSTC would not result in disproportionately high or adverse impacts on low income or minority communities. The Build Alternatives would not result in disproportionately high or adverse human health or quality of life impacts to communities of concern related to construction truck traffic off-site. Routes necessary for construction-related truck traffic pass through neighborhoods with both high and low proportions of low-income and minority persons. Overall, the race, ethnicity and income characteristics of the secondary truck route study area are similar to those of Lower Manhattan as a whole. In addition, the increase in traffic along these established truck routes is not anticipated to be substantial or result in traffic, air or noise impacts, as defined by established impact threshold criteria.

1 New York State Department of Environmental Conservation, DEC Policy CP-29: Environmental Justice and

Permitting, March 19, 2003.



All property acquisition required for the Build Alternatives would be undertaken within the framework of the Federal Uniform Relocation Assistance and Real Property Acquisition Policies Act and would also conform to the New York State Eminent Domain Procedure Law. In the case of relocating displaced businesses, it is anticipated that adequate space is available for relocation elsewhere in Lower Manhattan and that relocation of these establishments would not result in an overall change in land use or community character in the adjacent neighborhood in the primary study area or in communities of concern in the secondary study area. No indirect business or residential displacements or overall change in land use or community character would be produced by the Build Alternatives in communities of concern or other neighborhood areas. The FSTC project would result in improvements to the overall transportation service in Lower Manhattan. Improved access to Lower Manhattan will not only make it an attractive business destination but also contribute to restoring Lower Manhattan to its pre-existing economic development potential. The project would benefit visitors, workers, and transit riders. Additionally, residents in the area will benefit from the transportation service improvements. No single racial, ethnic or income group will be denied the overall benefits anticipated by the project. The operation of the FSTC will not result in impacts to resources that would be borne disproportionately by low income or minority communities of concern. 19.2 METHODOLOGY, AFFECTED ENVIRONMENT, AND

ENVIRONMENTAL IMPACTS The environmental justice analysis for the FSTC follows the guidance and methodologies recommended in the Federal Council on Environmental Quality’s (CEQ’s) Environmental Justice Guidance under the National Environmental Policy Act (NEPA) (December 1997), and the USDOT’s Final Order on Environmental Justice, (April 1997). It is also consistent with the guidelines of the NYSDEC2. 19.2.1 ASSESSMENT PROCESS

The assessment of environmental justice for the FSTC was based on elements of the methodology described in the CEQ, USDOT and NYSDEC guidance. The major steps in this process are:

• Identify study area; • Compile population characteristics and identify locations with populations of concern for

environmental justice; • Conduct public outreach; • Identify adverse effects on populations of concern; and, • Evaluate project’s overall effects.

19.2.2 IDENTIFICATION OF STUDY AREAS

Two (2) study areas were identified. A quarter-mile primary study area surrounding the project site was established for the analysis. The study area was enlarged to match the boundaries of Census block groups to facilitate data gathering and analysis (see Figure 19-1). This quarter-mile study area reflects the limits of potential adverse direct and indirect human health, economic and quality of life impacts on communities of concern that could result from either construction or operation of the FSTC. A secondary study area, comprised of all of Lower Manhattan south of Canal Street, was identified for purposes of describing the larger neighborhood context in which the primary study area is located. Within this FEIS, Lower Manhattan is generally defined as the area south of Chambers Street; however, for environmental justice analyses, Lower Manhattan is defined as the area south of Canal Street, to correspond with designated Census tracts. 2 NYSDEC, DEC Policy CP-29: Environmental Justice and Permitting, March 19, 2003.

EASTRIVER

HUDSONRIVER

Primary Study Area

Secondary Study Area

Fulton Street Transit Center

Figure 19-1i

Proportion of Minority Residents in

Lower Manhattan Census Blocks

Source: NYC DoITT Landbase; NYC DCP

US Census 2000

0 500 1,000 2,000Feet

Legend

ProposedProject Area

Share of Minority Population,Census Block, 2000

20% - 40%

Less than 20%

40% - 60%

60% - 80%

Greater than 80%

,.



The secondary study area also included truck routes expected to be utilized by construction traffic during the construction of the FSTC, and other Lower Manhattan Projects. For that analysis, all Census blocks immediately adjacent to construction truck routes leading to the Holland Tunnel or Manhattan Bridge, were selected. Truck routes evaluated include those to be employed for the FSTC and, for purposes of cumulative effects assessment, those expected to be utilized for other future actions proposed for Lower Manhattan by other project sponsors. These include the following:

• The WTC Memorial and Redevelopment Plan (construction expected mid-2004 to end 2014); • The Permanent WTC PATH Terminal (construction expected early 2005 to end 2008); • The West Street/Route 9A Reconstruction (construction expected mid-2004 to end 2008); and, • The Reconstruction of the South Ferry Subway Terminal (construction expected late-2004 to end

2006).

19.2.3 COMPILILATION OF POPULATION CHARACTERISTICS AND IDENTIFY POPULATIONS OF CONCERN FOR ENVIRONMENTAL JUSTICE

Population and income characteristics from the 2000 U.S. Census of Population and Housing were utilized to identify populations of concern for environmental justice. The following information was collected for specific block groups and aggregated to represent the study area:

• Data on racial and ethnic characteristics: Population in each of the block groups within the census tracts in the primary study area was characterized using the following racial categories: White (Hispanic and Non-Hispanic), Black or African American, American Indian and Alaska Native, Asian, Native Hawaiian and Other Pacific Islander, and “Other”;

• Percentage of Minority Population: In responses to questions on the Census, persons of Hispanic origin characterize themselves as White, Black or African American, American Indian and Alaska Native, Asian, Native Hawaiian and Other Pacific Islander, and “Other”. For purposes of this analysis, persons of Hispanic origin classifying themselves as White were included in the calculation of minority population (CEQ guidance indicates that areas where more than 50 percent of the total population is minority are considered minority communities). In addition, census tracts where the percentage of the population of a particular racial or ethnic group was “meaningfully greater” than Manhattan as a whole are noted; and,

• Low-income population: The percentage of persons living below the poverty level, as defined in the Census, was one of the indicators used to determine the low-income population in a given block group or census tract. The median household income was the second measure used to characterize the income levels.

19.2.4 STUDY AREA POPULATION AND ECONOMIC CHARACTERISTICS

PRIMARY AND SECONDARY STUDY AREAS In 2000, an estimated 7,816 people lived in the primary study area. Table 19-1 presents the population and economic characteristics for the primary study area and the surrounding regions, including the secondary study area. For purposes of socioeconomic analysis, the study areas are defined in terms of the Census tracts and block groups by which the relevant data is made available. Overall, the primary study area has a smaller proportion of minority residents than the secondary study area (Lower Manhattan) or New York County (Manhattan) as a whole. The percentage of minorities in the primary study area was 31.5 percent, compared with 68 percent for Lower Manhattan residents and 36 percent of New York County residents. Approximately 14.2 percent of the primary study area residents characterized themselves as Asian, and 7.5 percent as Hispanic.



The proportion of persons living under poverty in the primary study area was found to be 8.6 percent. The median household income in the primary study area was found to be $97,654 for 1999. Incomes in the primary study area are substantially greater than those in the secondary study area ($45,111) and New York County ($47,030). Given that the primary study area has proportions of low income and minority persons lower than Lower Manhattan and Manhattan as a whole, it does not constitute a community of concern for environmental justice evaluation. Other areas of Lower Manhattan below Canal Street that lie in the secondary study area, particularly the portion of Chinatown below Canal Street, do constitute a community of concern, given their higher proportions of low income and minority residents. An important issue in the consideration of environmental justice for the Build Alternatives is the effect of construction traffic on human-health and quality-of-life along travel routes. Figure 19-2 depicts the proportion of minority persons in census blocks immediately adjacent to the routes to be used by trucks servicing the FSTC site.3 Truck haul routes for the FSTC are described in Chapter 6: Transportation and Traffic. These truck routes pass mostly through neighborhoods with proportions of minority populations at or below the proportion for Manhattan as a whole. The exception is the portion of the route traversing Chinatown on Canal, Lafayette, and Kenmare/Delancey Streets and Pearl Street/St. James Place/Bowery. This portion of the secondary study area constitutes a community of concern for purposes of environmental justice evaluation. The map shows truck routes that were chosen based on:

• Coordination among the sponsors of Lower Manhattan Recovery Projects, as well as New York City Department of Transportation (NYCDOT), in Summer and Autumn 2003, with the objective of minimizing the impacts of truck traffic on the local roadway network;

• Consideration of only those major thoroughfares designated by NYCDOT as New York City Truck Routes;

• Consideration of those New York City Truck Routes that allow for the most direct truck access from the project site to major river-crossing points including the Holland Tunnel, Brooklyn Battery Tunnel; and,

• The Manhattan and Williamsburg Bridges, while limiting overlap of truck routes used by other Lower Manhattan Recovery Projects.

As part of common Environmental Performance Commitments (EPCs), Metropolitan Transportation Authority (MTA) New York City Transit (NYCT) and other sponsors of Lower Manhattan Recovery Projects will be engaged in regular discussions with NYCDOT on traffic and transportation issues related to construction and will participate in NYCDOT’s construction coordination efforts.

Overall, the proportion of minority persons in blocks adjacent to the FSTC truck routes (68.3 percent) is essentially similar to the proportion of minority residents in Lower Manhattan as a whole (68.2 percent). This indicates that the location of the truck routes is not disproportionate in relation to its proximity to minority populations in Lower Manhattan. Truck routes for FSTC will pass through neighborhoods with low proportions of low income and minority residents, and neighborhoods with high proportions of low income and minority residents. Although data on income and poverty is not available for Census blocks, an analysis of Census block groups found proportions of persons in poverty ranging from 20 percent to 50 percent along portions of the route in Chinatown (Canal Street east of Lafayette Street, Kenmare/Delancey Streets and St. James Place/Bowery). Block groups along other portions of the designated route have proportions of persons in poverty below that of Manhattan as a whole (19.4 percent). Lower Manhattan is characterized by areas of comparatively high income (primary study area), and areas with incomes at or below that of Manhattan as a whole (secondary study area). 3U.S. Census income and poverty data are not available at the block level. For purposes of this analysis it is

assumed that income characteristics along the truck routes are similar to that of the Primary Study area and Lower Manhattan as a whole.



Table 19-1

Population and Economic Characteristics for Impact Study Areas Comparison of Study Area with Surrounding Region

Primary Study Area1 Secondary Study

Area2 (Lower Manhattan)

New York County/Manhattan

Number Percent Number Percent Number Percent Race White alone 5,664 72.5 32,331 38.8 835,298 54.3 Non-Hispanic White 5,356 68.5 26,441 31.8 703,462 45.8 Hispanic-White 308 3.9 5,890 7.1 131,836 8.6 Non-white alone3 2,152 27.5 50,908 61.2 415,728 27.0 Black or African American alone 380 4.9 5,642 6.8 233,383 15.2 American Indian and Alaska Native alone 27 0.3 174 0.2 2,319 0.2 Asian alone 1,111 14.2 37,414 44.9 143,028 9.3 Native Hawaiian and Other Pacific Islander 0 0.0 26 0.03 354 0.0 Other 634 8.1 7,652 9.2 36,644 2.4 Total Population 7,816 100.0 83,239 100.0 1,537,198 100.0 Minority Population4 2,460 31.5 56,798 68.2 547,564 35.6 Hispanic Origin5 590 7.5 12,314 14.8 418,008 27.2 Age (Years) 0-5 395 5.1 4,868 5.8 89,694 5.8 6-12 360 4.6 4,649 5.6 101,582 6.6 13-18 290 3.7 4,793 5.8 81,309 5.3 19-24 1,336 17.1 9,250 11.1 138,623 9.0 25-34 2,600 33.3 14,768 17.7 332,210 21.6 35-49 2,040 26.1 20,122 24.2 369,132 24.0 50-64 730 9.3 12,375 14.9 237,997 15.5 65 years or older 65 0.8 12,414 14.9 186,648 12.1 Total 7,816 100.0 83,239 100 1,537,195 100.0 Number of Households 3,623 33,404 738,644 Poverty Population for whom poverty status determined 7057 77,971 Persons below Poverty 604 8.6 17,872 22.9 19.4 Median Household Income (1999)6 $97,654 $45,111 $47,030 Notes: 1 The Primary Study Area is comprised of the following 2000 Census Block Groups: Tract 7, Block Groups 2 and 3; Tract 13, block

groups 1, 2, 3, and 4; Tract 15.01, Block Group 2; Tract 15.02, Block Group 2; Tract 21, Block Groups 1 and 2; Tract 31, Block Group 2. Lower Manhattan includes all census tracts south of Canal Street.

2 The Secondary Study Area is comprised of all 2000 Census Block Groups south of Canal Street. 3 Includes persons of Hispanic origin (see note 4). The “Other” category includes census categories “some other race alone” and

“two (2) or more races.” 4 The total minority population includes all those who are not non-Hispanic White---those listing race as Black, American Indian and

Alaskan Native, Asian, Native Hawaiian, Other Pacific Islander, “some other race alone” and “two (2) or more races,” as well as persons of Hispanic origin classifying their race as White.

5 The Hispanic Origin category consists of those respondents who classified themselves in one of the several Hispanic Origin categories on the Census form. Persons in this ethnic classification may be of any race.

6 The median household income was calculated by taking the weighted average of the median incomes of all the census tracts in a given study area.

Source: U.S Department of Commerce, Bureau of Census, U.S. Census of Population and Housing, 2000.

EASTRIVER

HUDSONRIVER

Share of Minority Population, Census Block, 2000

Fulton Street Transit Center

Figure 19-2

Proportion of Minority ResidentsAlong FSTC Truck Route


US Census 2000

0 500 1,000 2,000Feet

Legend

FSTC Truck Route



20% - 40%

Less than 20%

Block not Adjacentto Routes

40% - 60%

60% - 80%

Greater than 80%

,.



From a cumulative perspective, other construction projects in Lower Manhattan are expected to require additional routes for use by construction trucks (see Chapter 6: Traffic and Transportation). Figure 19-3 illustrates the truck routes required for all major projects anticipated for Lower Manhattan during the term of construction at the FSTC site and the proportions of minority populations along those routes. As with the FSTC route, truck routes required for other projects pass through areas with low proportions of low income and minority residents, and areas with high proportions of these communities of concern. Overall, the proportion of minority persons in blocks adjacent to all project truck routes (65 percent) is slightly below the proportion for Lower Manhattan as a whole (68 percent). 19.2.5 PUBLIC OUTREACH

Applicable guidance on environmental justice emphasizes public participation and a variety of outreach strategies to encourage involvement. This public outreach process, if comprehensive and inclusive, can be an important component in addressing environmental justice issues. As part of the planning and environmental review process, a public outreach program was developed to encourage participation from the public and other interested parties, including low-income and minority populations. The general public and interest groups were invited to participate in the Scoping Process via a variety of advertising and outreach mechanisms, including newspaper notices and the MTA’s web site. In order to reach all community members (including minority and low-income populations, residents, employees, and commuters) meeting notices associated with the FSTC were posted in English, Chinese and Spanish. Presentations were also made to Community Board #1 (see Chapter 5: Public Outreach for further details). Meeting notices and information posters were also displayed in subway stations throughout the Existing Complex, and published in the New York Post, the Daily News, the Amsterdam News and El Diario. 19.2.6 IDENTIFICATION OF ADVERSE EFFECTS ON POPULATIONS

OF CONCERN

PRIMARY AND SECONDARY STUDY AREA Under the No Action Alternative, the Existing Complex would remain as is, except for routine maintenance measures and repair activities. No impacts on low income or minority communities would occur. Potential adverse impacts identified in other chapters are related primarily to construction activities for Alternative 9 and the Preferred Alternative that would generate noise impacts as outlined below. These temporary effects would be limited to the primary study area in the immediate vicinity of the project site - a substantial distance from the communities of concern identified in the secondary study area, where no effects are anticipated. The Build Alternatives are not anticipated to produce traffic, circulation, or air quality impacts during the period of construction or operation. Similarly, the Build Alternatives are not anticipated to produce adverse impacts to other resources such as community facilities, open space or community character that would be borne disproportionately by communities of concern. Analysis of noise and vibration conditions indicates the potential for adverse impacts in the primary study area in the immediate vicinity of the projects site under both Build Alternatives (see Chapter 13: Noise and Vibration). NYCT is committed to developing mitigation measures that would reduce and, where practicable, eliminate adverse impacts due to construction in accordance with FTA criteria. All property acquisition required for the Build Alternatives would be undertaken within the framework of the Federal Uniform Relocation Assistance and Real Property Acquisition Policies Act and would also conform to the New York State Eminent Domain Procedure Law. In the case of relocating displaced businesses, the financial burdens associated with relocation will be addressed by NYCT within the framework of these applicable laws.

EASTRIVER

HUDSONRIVER

0 Fulton Street Transit Center

Figure 19-3

Proportion of Minority ResidentsAlong All Truck Routes


US Census 2000

0 500 1,000 2,000Feet

Legend

FSTC Truck Route


All Other Truck Route


20% - 40%

Less than 20%

Block not Adjacentto Routes

40% - 60%

60% - 80%

Greater than 80%

,.



It is anticipated that adequate space is available for relocation elsewhere in Lower Manhattan and that relocation of these establishments would not result in an overall change in land use or community character in the adjacent neighborhood in the primary study area or in communities of concern in the secondary study area. No indirect business or residential displacements or overall change in land use or community character would be produced by the Build Alternatives in communities of concern or other neighborhood areas. These effects identified for the primary study area would not be predominantly borne by minority or low-income populations, nor would the effects be appreciably more severe or greater in magnitude than the adverse effects for other groups in the population. The primary study area, where most of these construction related impacts would occur, contains a smaller proportion of low-income and minority residents in comparison to Lower Manhattan, and Manhattan as a whole and does not constitute a community of concern for environmental justice analysis. The project’s effect during the operational period will be beneficial, and low-income and minority groups will share in the use of and will benefit from the access and circulation improvements of the FSTC. No ethnic or low-income group will be denied the overall benefits anticipated by the project. The impact of construction truck traffic along the route designated is not expected to produce adverse human-health or quality-of-life/community-cohesion impacts to any population group including low-income or minority populations. Construction truck traffic will be limited to designated NYCDOT Truck Routes which provide the most direct access to major river-crossings. The volumes would vary throughout the construction period based on the origin and destination of the trips and requirements of work on the site. Overall, the number of trucks generated during the peak of construction activities would not represent a substantial increase to existing traffic volumes as determined by existing impact threshold criteria (see Chapter 6: Traffic and Transportation), and is not expected to produce substantial adverse air quality or noise/vibration impacts, in communities of concern or elsewhere in the supplemental truck route study area. Truck volumes would be similar for both Build Alternatives. As with the number of trips related to the FSTC, the cumulative number of trucks generated by the construction activities in the secondary study area is not expected to represent a substantial increase to existing traffic volumes or result in a substantial change in the level of service on local roadways (see Chapter 6: Traffic and Transportation). 19.2.7 EVALUATION OF THE PROJECT’S OVERALL EFFECTS

The potential of the FSTC to create adverse impacts on low-income and minority populations in the primary and secondary study area was compared to those impacts likely to be experienced by all population groups in those areas. This permits a determination of whether such impacts disproportionately affect low-income and minority groups. The proportion of low-income and minority residents in the primary study area is lower than that for Lower Manhattan, or New York County as a whole, indicating a low potential for disproportionate impacts to communities of concern in the immediate vicinity of the Proposed Action. The No Action Alternative will not impact low-income or minority populations as no construction would occur. Construction and operation of the FSTC will not produce disproportionately high or adverse effects on low-income or minority communities. This evaluation of environmental justice issues, based on impacts identified in other chapters of this FEIS, demonstrates that:

• The Build Alternatives would not result in disproportionately high or adverse human health or quality of life impacts to communities of concern in the secondary study area. Temporary noise impacts during the construction period are limited to the primary study area in the immediate vicinity of the project site, an area that does not constitute a community of concern for environmental justice evaluation. Impacts to traffic conditions and air quality are not anticipated under either Build Alternative in the secondary study area.



• The Build Alternatives would not result in disproportionately high or adverse human health or quality of life impacts to communities of concern related to construction truck traffic off-site. Routes necessary for construction-related truck traffic pass through neighborhoods with both high and low proportions of low-income and minority persons. Overall, the race, ethnicity and income characteristics of the secondary truck route study area are similar to that of Lower Manhattan as a whole. In addition, the increase in traffic along these established truck routes is not anticipated to be substantial or result in traffic, air or noise impacts, as determined by existing threshold criteria.

• The Build Alternatives would not result in impacts to open space or community facilities and

services in communities of concern.

• The FSTC project would result in improvements to the overall transportation service in Lower Manhattan. Improved access to Lower Manhattan will not only make it an attractive business destination but also contribute to restoring Lower Manhattan to its pre-existing economic development potential. The project would benefit visitors, workers and transit riders. Additionally, residents in the area will benefit from the transportation service improvements. No single racial, ethnic or income group will be denied the overall benefits anticipated by the project. The operation of the FSTC will not result in impacts to resources that would be borne disproportionately by low income or minority communities of concern.

19.3 SUMMARY OF ADVERSE IMPACTS AND MITIGATION MEASURES

No adverse impacts with the potential to disproportionately affect low income or minority communities would occur as a result of construction or operation of the FSTC under Alternatives 9 or 10. As no adverse impacts are identified, no mitigation measures would be required.

chapter 19: environmental justiceweb.mta.info/capital/fc_docs/feis/chapters/ch19.pdfoctober 2004...

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