East Midtown Rezoning - City Planning Commission hearing

East Midtown Rezoning
City Planning Commission, City of New York
Testimony by Christopher Jones, Vice President for Research, Regional Plan Association

The proposed rezoning is unlike any the City of New York has pursued in decades. Unlike the plans that are transforming waterfront and industrial areas such as Hudson Yards and Williamsburg, or helping to fulfill the potential of mixed-use communities like Jamaica, this action is attempting to ensure the continued success of one of the highest value concentrations of commercial activity anywhere. By almost any measure—jobs, office space, salaries, taxes, rents—East Midtown has few rivals across the globe. It is the heart of the central business district that fuels the economy of the city and the New York region. It is also a dense, 24-hour neighborhood with some of the world’s most iconic buildings and a critical transportation hub at Grand Central Terminal, as well as some of the city’s most crowded streets and subway lines.

Given East Midtown’s economic vitality, as well as its pedestrian and transportation challenges, the proposed rezoning raises a number of legitimate concerns. If East Midtown is already a vibrant but crowded job center, why create incentives for additional development? If the streets and subways are overcrowded, shouldn’t we be focused on fixing those instead? And with millions of square feet of new office space being added in Lower Manhattan and West Midtown, is there a need for even more office towers?

Yet in spite of East Midtown’s success, the rezoning addresses a critical need that might not become fully apparent for several years. The proposal isn’t as much about adding more office space as it is about ensuring that the district continues to evolve and adapt in a rapidly changing world. East Midtown already has several unremarkable and outdated structures whose low ceilings and heavy interior columns deter potential activities and tenants. Businesses are increasingly moving toward open floor plans and amenities that these structures don’t provide.

Under current zoning, the district will continue to age and gradually decline. The proposed rezoning would enable the district to replenish its building stock to respond to changing market demands. No one knows how many new structures will be built or when they will be constructed, but it is likely to be fewer than two dozen buildings over the next three decades. The new structures would be concentrated on corner and avenue-facing lots, allowing light to continue to reach into mid-blocks and not crowd out smaller structures.

The text amendments permitting 20% of buildings to be residential gives the district greater flexibility to respond to changing preferences for mixed-use districts, and can enhance the 24-hour character of midtown. But care must be taken in evaluating applications for higher amounts of residential development to maintain the high concentration of jobs and business activity that drives economic growth throughout the city.

Just as important is how to address the transportation and public space needs of the area. Even the modest increases in density projected from the rezoning will add to the congestion at Grand Central, on the subway and on sidewalk corridors and intersections. Mayor Bloomberg’s commitment to provide upfront capital to improve the Lexington Avenue line and other needs in anticipation of revenue from the District Improvement Fund is an important action that will not only help mitigate any increase in congestion, but will also address a longstanding transportation bottleneck that needs to be solved regardless of the rezoning. We look forward to hearing the details of the funding mechanism, most importantly how the mayor’s commitment will be carried out under future administrations.

Still, the existing transportation and circulation needs of the district go well beyond the dollars that would come from the fund under even the most optimistic assumptions. Future mayors, the governor, legislators and the MTA will need to maintain a focus on improving transportation along the entire East Side beyond the actions specified in the proposed rezoning.

Specific priorities that will need to be addressed include both actions already anticipated in the proposal and others that go beyond its scope. We recommend the following as priorities for both the District Improvement Fund and future funding from both city and MTA capital plans:


·      Interventions to address congestion at the surface and in existing subway stations are the critical near-term priorities. Expanding the mezzanine for the Lexington Avenue subway, adding new connections and a mezzanine for the Flushing line, and constructing a passageway connecting to Metro-North’s lower-level platforms and Long Island Rail Road’s East Side Access concourse to the subway will make a substantial difference in the commuter experience, as will circulation improvements at the two crosstown 53rd Street stations. 

·      The full buildout of the Second Avenue subway, both Phase 2 extending to 125th Street and Phase 3 to Lower Manhattan, is essential to relieving congestion on the Lexington subway and at Grand Central Terminal, as well as providing the capacity for job growth along the entire East Side. A priority for future MTA capital plans should be to complete Phase 2 by the mid-2020s and getting Phase 3 underway as more space comes under the rezoning.

·       The proposal to close Vanderbilt Avenue to auto traffic from 42nd to 46th streets, allowing for emergency and overnight truck delivery access, would serve as a buffer for pedestrians at Grand Central, allowing the spreading of pedestrian flows among the various side streets for commuters heading to 5th and 6th avenues.

·      A broader pedestrian circulation study for the district should be conducted, with special consideration given to pedestrian issues along Lexington and Madison avenues and the potential closing of parts of discontinuous cross streets like 41st and 43rd streets.

·      Additional station entrances for East Side Access should be developed as new buildings are constructed above the Madison Avenue concourse. Improved access to the east also should be explored as new buildings are constructed on the eastern side of Park Avenue.

It must be acknowledged that new office construction in East Midtown will create some additional competition to locations elsewhere in the city, particularly Hudson Yards and the World Trade Center, which combined could provide as much as 35 million square feet of new office space over the next 30 years. But this competition should be minimal. If the city’s forecasts are accurate, the rezoning will result in only 4.5 million square feet of net new space. 

In addition, there is a differentiation among office districts that both mitigates the competition and is healthy for the city and the region. East Midtown has a unique ecology that includes large and small companies with many top banks, law firms and media businesses mingling with technology and service firms, as well as hotels and tourist activities. It is unlikely to compete with Hudson Yards or downtown Brooklyn for newer technology companies seeking a particular type of work environment.  East Midtown will attract a different type of tenant that wants a premium Midtown address and access to Grand Central. Having healthy office districts that appeal to different markets is good for the city overall. Businesses attracted or retained in Midtown rather than a non-city location will stimulate job growth, some of which will end up in other parts of the city

Even if competition proves more significant, it is far more important to allow the city’s premier office district to modernize and compete with other global centers. It is difficult to predict the amount and type of workspace that New York City will need over the next 30-50 years, but the ability to provide a range of choices in different locations will maximize job growth potential. Whether we create too much office space for one or two business cycles is less of a concern than whether we will have the flexibility to respond to demand over several decades.

In summary, Regional Plan Association supports the proposed rezoning to help ensure New York's continued competitiveness.  Other actions, including investments in the transit network, public spaces and pedestrian circulation, are equally important. The commitment to fund some of these improvements in advance of the development that will occur as a result of the rezoning will make a significant difference, but securing additional funding and maintaining a focus on the public realm are essential to the future of East Midtown, the city and the region.