City of White Plains Westchester County, NY. Final Generic Environmental Impact Statement

60 South Broadway Rezoning Project City of White Plains Westchester County, NY Final Generic Environmental Impact Statement

60 SOUTH BROADWAY CB-3 REZONING FINAL GENERIC ENVIRONMENTAL IMPACT STATEMENT (FGEIS) Submitted: Accepted: October 6, 2014

FINAL GENERIC ENVIRONMENTAL IMPACT STATEMENT (FGEIS) 60 SOUTH BROADWAY CB-3 REZONING 60 South Broadway City of White Plains, Westchester County, New York 10601 Lead Agency: City of White Plains Common Council City of White Plains 255 Main Street, White Plains, NY 10601 Contact: Hon. Thomas M. Roach, Mayor (914) 422-1411 Applicant: Urstadt Biddle Properties, Inc. 321 Railroad Avenue Greenwich, CT 06830 Contact: John Cannon (203) 863-8200 Prepared by: See following page Date DGEIS Accepted: July 7, 2014 Date of Public Hearing: August 4, 2014 and September 2, 2014 Closing Date of Comment Period: September 12, 2014 Date FGEIS Submitted: Date FGEIS Accepted: October 6, 2014 Web address for electronic copy of this FGEIS: cityofwhiteplains.com

LIST OF PREPARERS Planner BFJ Planning 115 5th Avenue New York, NY 10003 (212) 353-7474 Contacts: Sarah K. Yackel, AICP, Principal Isabel Aguirre-Martinez, Planner Georges Jacquemart, PE, AICP, Principal Lauren Rennée, Planner Legal Counsel Cuddy & Feder LLP 445 Hamilton Avenue, Fourteenth Floor White Plains, New York 10601 (914) 761-1300 Contact: William S. Null, Esq. Architect Perkins Eastman 422 Summer Street Stamford, CT 06901 (203) 251-7400 Contact: Stuart Lachs, Principal Socioeconomic Consultant Urbanomics 115 5th Avenue New York, NY 10003 (212) 353-7462 Contact: Tina Lund, AICP, Principal Civil Engineer The Chazen Companies 21 Fox Street Poughkeepsie, NY 12601 (845) 454-3980 Contact: Chris Lapine

TABLE OF CONTENTS 1.0 INTRODUCTION... 1 1.1 GENERIC ENVIRONMENTAL IMPACT STATEMENT 1.2 PROPOSED ACTION 2.0 CHANGES TO THE PROPOSED ACTION... 10 3.0 COMMENTS AND RESPONSES ON THE DRAFT GENERIC ENVIRONMENTAL IMPACT STATEMENT... 11 3.1 PUBLIC HEARING AND COMMENT PERIOD PROCESS 3.2 PUBLIC COMMENTS AND RESPONSES LIST OF FIGURES Figure 1-1: Figure 1-2: Figure 1-3: Figure 1-4: Regional Location Site Location Map Existing Zoning Map Proposed Zoning Map APPENDIX Appendix A: Zoning Petition Appendix B: Public Hearing Transcripts and Written Comment Letters iv

1.0 INTRODUCTION This document is the Final Generic Environmental Impact Statement (FGEIS) for the 60 South Broadway Rezoning project ( the Proposed Action ). Urstadt Biddle Properties, Inc., the owner of 60 South Broadway ( the Project Site ), is requesting an amendment to the City of White Plains Zoning Ordinance to re-map the property s zoning classification from the B-6 District to the CB-3 District and to extend the boundary of the Central Parking Area ( the CPA ) to include the Project Site. The Common Council is the State Environmental Quality Review (SEQR) lead agency for the Proposed Action. This FEIS addresses all substantive comments made on the Draft Generic Environmental Impact Statement (DGEIS) during the DGEIS public hearing and DGEIS comment period. Those comments are summarized and responded to in Chapter 3.0, Comments and Responses on the Draft Generic Environmental Impact Statement. At its July 1, 2013 meeting, the Common Council adopted an environmental findings resolution whereby the Common Council (a) designated itself Lead Agency for the environmental review of the Proposed Action; (b) determined that the Proposed Action is a Type I Action under SEQR regulations; and (c) determined that an Environmental Impact Statement must be prepared for the Proposed Action to systematically assess potential impacts, alternatives and measures to mitigate potential impacts. At its September 3, 2013 meeting, the Common Council adopted a resolution which: (a) reconfirmed that an EIS must be prepared for the Proposed Action, as modified by the August 19, 2013 communication from the Applicant s representative; (b) determined the revised Scoping Outline dated _ to be adequate for the purpose of commencing public review and comment regarding issues to be addressed in the DGEIS; and (c) scheduled a comment period to receive written comments regarding the Scoping Outline until September 27, 2013. At its October 7, 2013 meeting, the Common Council adopted the Scoping Outline as the Final Scope of Work for the Preparation of a Draft Generic Environmental Impact Statement for the 60 South Broadway Rezoning Project (the Final Scope of Work ). On July 7, 2014, the White Plains Common Council accepted the DGEIS dated July 2, 2014, as adequate for the purpose of commencing public review and comment regarding issues addressed in the Final Scope of Work for the Proposed Action. A public hearing regarding the DGEIS was held on August 4, 2014, adjourned to September 2, 2014 and, then, closed following public comment. Written comments regarding the DGEIS were 1

accepted for a total of 66 days, from July 7, 2014 to September 12, 2014, including a 10-day period following the close of the public hearing. This Final Generic Environmental Impact Statement (FGEIS) has been prepared pursuant to the State Environmental Quality Review Act (SEQR) and its implementing regulations (6 NYCRR Part 617). Under those regulations, the FGEIS serves as the basis for the Lead Agency Findings. This FGEIS has been prepared to respond to all significant environmental comments made on the Draft Generic Environmental Impact Statement (DGEIS). In accordance with Section 617.9(b) (7) of the SEQR regulations, this FGEIS incorporates by reference the DGEIS. The Proposed Action analyzed in the DGEIS is the request, on behalf of Urstadt Biddle Properties, Inc. ( Applicant ), for the following amendments to the City of White Plains Zoning Ordinance ( Proposed Action ): 1) Re-Mapping of premises located at 60 South Broadway known and designated on the Tax Assessment Map of the City of White Plains as Section 125.84, Block 3, Lot 1 (also known as the Westchester Pavilion ) from the B-6 (Enclosed Mall) District into the CB-3 (Core Business 3) District; and (2) Extension of the boundary of the Central Parking Area ( CPA ) to include the 60 South Broadway site ( Project Site ). This FGEIS is organized into three sections: Section 1.0 describes the Proposed Action and the purpose of the Generic Environmental Impact Statement. Section 2.0 describes any changes that have been made to the Proposed Action in response to concerns raised during the public comment period; and Section 3.0 contains a summary of all written comments and comments received at the public hearing and provides responses to each of those comments (public and agency comment letters and public hearing transcripts are located in Appendix B). 1.1 Generic Environmental Impact Statement Importantly, the Proposed Action is legislative and generic in nature, not project-specific, and does not directly result in physical changes to the environment. The proposed rezoning and extension of the CPA would affect the size, type and form of development permitted to be developed on the Project Site. As such, the Proposed Action is generic in nature in that it is not a specific development change, but rather a regulatory change that would alter the range of future development options for the Project Site. As a result, this Environmental Impact Statement (EIS) was prepared as a Generic Environmental Impact Statement (GEIS) in accordance with NYCRR Section 617.10. A GEIS, according to the New York State Department of Environmental Conservation (NYSDEC) SEQR handbook, is a type of EIS that is more general than a site-specific EIS, and typically is used to consider broad- based actions or related groups of actions that agencies are likely to approve, fund, or directly undertake A Generic EIS differs from a site or project specific EIS by being more general or 2

conceptual in nature The DGEIS presented estimates of a range of potential impacts utilizing alternative development scenarios that could result if the Proposed Action were adopted. It is important to note that the conceptual plans appended to the Zoning petition (see FGEIS Appendix A) are theoretical in nature and present alternative potential redevelopment options that could occur under the CB- 3 rezoning, but many potential development options exist and a final detailed site plan may be of a similar design or may have a different design as the CB-3 District allows for a range of potential development scenarios. As a result, the analysis in the DGEIS considered the maximum permitted development within the proposed zone (CB-3) for the Project Site and three maximum build-out scenarios. The DGEIS studied development impacts for various uses under the maximum build-out scenarios that present the worst-case scenario for each technical area of assessment (see DGEIS Chapter 3.0). Each technical section included a discussion of the scenario considered and why it constitutes the worst case for that specific development use or configuration. Finally, the DGEIS identified analyses that will be required at the time a sitespecific development project is proposed (see DGEIS Chapter 6.0: Future Actions). Upon approval of the Proposed Action, any future redevelopment of the 60 South Broadway site under the new zoning scheme will be subject to Site Plan review and approval by the Common Council of the City of White Plains, including project-specific review of any potential impacts associated with the proposed redevelopment project under SEQR. It is at this time that sitespecific review of environmental impacts will be required. 1.2 Proposed Action Project Location The Applicant is the owner of approximately 3.58 acres (156,016 square feet) of real property located at 60 South Broadway, a site commonly known as the Westchester Pavilion and referred to herein as the Project Site. The Project Site is bounded on the northerly side by land containing the Westchester One office building at 44 South Broadway, on the southerly side by Maple Avenue (with approximately 360 feet of frontage), on the easterly side by Hale Avenue (with approximately 400 feet of frontage), and on the westerly side by South Broadway (with approximately 500 feet of frontage). The Project Site is located in Downtown White Plains approximately one-mile southeast of the White Plains TransCenter, which provides access to mass transit, including the Metro-North railroad and Westchester County Beeline bus transportation, among other things. Please see Figure 1-1: Regional Location Map and Figure 1-2: Project Site Map. 3

Project Site 60 South Broadway Rezoning FGEIS WHITE PLAINS NY Figure 1-1: Regional Location source: Urbanomics, 2013

60 South Broadway Rezoning fgeis Figure 1-2: site location map Westchester one White Plains, NY source: perkins eastman

Existing Zoning and Land Use The Project Site is mapped in the B-6 (Enclosed Mall) District and is improved with the Westchester Pavilion, an enclosed mall which contains approximately 209,874 gross square feet of retail and restaurant space (194,874 SF) and administrative office space (15,634 SF) and 634 parking spaces in a structured garage. The Westchester Pavilion covers 100% of the Project Site s land area. The Project Site is situated within Downtown White Plains in the designated Core Area, as defined in the City of White Plains 1997 Comprehensive Plan and 2006 Plan Update. It also abuts the Central Parking Area ( CPA ), which encircles the Core Area and continues south from the Project Site along South Broadway to Maple Avenue and then turns westerly toward Mamaroneck Avenue. Please see Figure 1-3: Existing Zoning Map, which shows the Project Site and the CPA boundary. Zoning Map Amendments The Applicant is requesting that the Common Council of the City of White Plains remap the Project Site from the existing B-6 (Enclosed Mall) District to the CB-3 (Core Business 3) District. The B-6 District permits a maximum Floor Area Ratio ( FAR ) of 2.5, outside of the CPA and an FAR of 6.00 within the CPA, whereas the CB-3 District would permit a maximum FAR of 5.5 if the proposed FAR for the development included fifty percent (50%) or more as residential uses, given the size of the Project Site and its frontage on two streets; an FAR of 3.0 is permitted for developments containing less than 50% residential. The change in District classification from the B-6 District to the CB-3 District would facilitate residential and hotel development, among other things, that currently are not permitted in the B-6 District. The Proposed Action would not only allow for a greater range of uses on the site, but would also allow for the development of taller (maximum of 280 in the CB-3 versus a maximum of 90 in the B-6) and lower coverage (85% lot coverage in the CB-3 versus 100% lot coverage in the B-6). The map of the Proposed Rezoning is included as Figure 1-4. In addition, the Applicant is requesting that the Common Council extend the boundary of the CPA to encompass the Project Site running easterly to Hale Avenue and then southerly to Maple Avenue (see Figure 1-4: Proposed Zoning). The location of the Project Site in the downtown core and in proximity to mass transit, as well as the provision of the required on-site parking supports the realignment of the CPA boundary to include the Project Site. Importantly, the Zoning Ordinance generally provides a lower requirement for parking and loading areas when properties are classified in the B-6 District with regard to the following uses: retail, restaurants, offices, personal services, theaters, real estate offices, consumer financial service establishments, bars, cabarets, and cafeterias. 6

60 South Broadway Rezoning fgeis Figure 1-3: Existing Zoning Map Project site study area boundary (1/4 mile) central parking area boundary.25 miles.5 miles White Plains, NY source: bfj planning

60 South Broadway Rezoning fgeis Figure 1-4: proposed Zoning Map CB-3 Project site study area boundary (1/4 mile) central parking area boundary White Plains, NY source: bfj planning

The Project Site is currently subject to the lower parking requirements applicable to the B-6 District (e.g., 3 spaces/1,000 square feet of gross floor area (GFA) for retail or restaurant for the B-6 District, as compared to 3.3 spaces/1,000 square feet in the CPA, or 5.7 spaces/1,000 square feet for retail outside of the CPA). The B-6 District also has lower requirements for loading. Thus, reclassifying the Project Site to the CB-3 District, without placing it within the CPA, would substantially increase its on-site parking burden, which would increase the cost of development and could detrimentally affect its redevelopment potential. The inclusion of the Project Site within the CPA also would encourage multi-use development thereon, including multiple dwellings, strengthening the urban environment and its economy and bringing pedestrian traffic and vitality to the downtown. With regard to residential uses, sites not located within the CPA have higher parking requirements sites in the CPA. The lower CPA parking requirement reflects both better access to public transportation options and the greater availability of public parking facilities in the downtown area 9

2.0 CHANGES TO THE PROPOSED ACTION No changes have been made to the Proposed Action (as described above) since acceptance of the DGEIS by the City of White Plains Common Council on July 7, 2014. 10

3.0 COMMENTS AND RESPONSES ON THE DRAFT GENERIC ENVIRONMENTAL IMPACT STATEMENT 3.1 Public Hearing and Comment Period Process The public comment period on the DGEIS opened on July 7, 2014 and extended through September 12, 2014. Written comments were received from the public during this time and submitted to the White Plains Common Council. A public hearing on the DGEIS was also held on August 4, 2014 and continued to and closed on September 2, 2014 in the Common Council Chambers, White Plains Municipal Building, 255 Main Street, White Plains, New York. Concurrent with the DGEIS public hearing, the public hearing on the Zoning petition (see Appendix A) was also opened on August 4, 2015 and continued to and closed on September 2, 2014. No public comments were made on the Proposed Action during the concurrent DGEIS or Zoning public hearings held on September 2, 2014. This FGEIS includes responses to comments received during both the DGEIS and Zoning public hearings and to written comments received during the comment period. 3.2 Comments and Responses The following summarizes and responds to substantive comments received on the DGEIS and Proposed Action; copies of all DGEIS comments received, including transcripts from the public hearing, are provided in Appendix B. A summary of the substantive comments made in each of the referenced comment letters and public testimony is presented in this section, where applicable, and a response to each substantive comment is also provided. Table 3-1: Commenters at the Public Hearing on August 4, 2014 and September 2, 2014 Speaker Affiliation Date of Comments 1. Claudia Murphy Resident of 60 DeKalb Avenue and Small Business Owner 2. Ken Kristal President, Resident of 24 Carhart Avenue and Carhart Neighborhood Association DGEIS public hearing, August 4, 2014 Zoning public hearing, August 4, 2014 3. Claudia Murphy Resident of 60 DeKalb Avenue and Small Business Owner Zoning public hearing, August 4, 2014 11

Table 3-2: Written Comments Received on the DGEIS Letter Author Author Affiliation Date of Letter 1. Edward Buroughs, AICP Westchester County Planning Board August 12, 2014 2. David Chong City of White Plains Department of Public Safety July 29, 2014 3. Kent Johnsson City of White Plains Design Review Board August 4, 2014 4. Damon Amadio, PE City of White Plains Department of Building August 21, 2014 5. Elizabeth Cheteny, AICP City of White Plains Department of Planning August 21, 2014 6. Thomas Soyk, PE, PTEO City of White Plains Department of Parking, Traffic Division August 21,2014 7. Michael Quinn City of White Plains Planning Board August 21,2014 8. Thomas Soyk City of White Plains Transportation Commission August 21, 2014 9. John Larson City of White Plains Department of Parking September 2,2014 Verbal Comments 1. Claudia Murphy, Resident of 60 DeKalb Avenue and Small Business Owner, Comment made during DGEIS Public Hearing, August 4, 2014 1-1 Comment: One concern is I know that the City has already taken care of the storm drain issue on Maple around the Westchester Mall area to Bloomingdale Road. I have noticed in the past few storms that the water issue continues up Maple towards Mamaroneck; you see the water coming up through the sewer covers, as well as in my building. You know we constantly are clearing out our drainage into our garage, but when there is a storm like we've had in the past few weeks, we get a wash-up into our garage, and into our courtyards. So I'm hoping that this project is passed at some capacity and that the zoning is changed, but also, that those situations would be mitigated if it is going to be a large residential-type place. 1-1 Response: The Applicant will be required to prepare a Storm Water Pollution Prevention Plan (SWPPP) as well as to mitigate all impacts identified due to the construction or ongoing operation of the project, as directed by the City of White Plains and/or the Westchester County Department of Health. This will include, but not be limited to storm water, sanitary sewer, potable water, etc. to prevent an increased risk of flooding to surrounding and downstream properties. Any attempt to construct building levels below grade, beneath the water table, cannot result in active pumping or a gravity transfer of groundwater into the City s storm drainage system. Further, the applicant utilized 24-hour rainfall data (in inches) from 1961. The latest informal New York State data (soon-to-be-adopted) informs design engineers to expect more rainfall, reflecting the increases and intensity of storms associated with climate change. In addition, in contrast to the 1961 statewide data, the new data is tailored to Westchester County. 12

1-2 Comment: We've spoken in the past about the parking in our neighborhood. A lot of people don't want to pay to park in the malls and the stores like that, so we just want to make sure that the island is maintained down the center of Maple Avenue, so that you cannot make that left-hand turn up to DeKalb and park for free on our street. 1-2 Response: Following the adoption of the Proposed Action, any specific development plans proposed for the Project Site would be subject to Site Plan review by the City of White Plains Common Council and project-specific review under SEQR. As such, any alteration to area roadways or intersections, and any associated impacts, would be assessed during this future review process and will require approval from the City Department of Public Works, as well as the Westchester County Department of Public Works. Both the Site Plan review process and the SEQR process include opportunities for public comment. 2. Ken Kristal, Resident of 24 Carhart Avenue and President, Carhart Neighborhood Association, Zoning Public Hearing, August 4, 2014 2-1 Comment: I'm the President of the Carhart Neighborhood Association. We held a board meeting recently on this particular topic, because we ve known that it was coming before you. And then we polled the members of the Carhart Association, and there was virtual unanimity in terms of being in favor of changing the zoning from the current enclosed mall to the central CB-3 district multiple use. You know we have our normal concerns, particularly about traffic, pollution, parking and the aesthetic in terms of the height, because we understand from the DGEIS that the heights can go from 90 feet up to 280 feet. We're not particularly convinced of the tentative plans that were shown, so the aesthetic in terms of how the final site plan will be presented, you know, we will follow it. And we trust that it would be adequately addressed at that time, and that we would have an opportunity to speak when a final plan is presented. 2-1 Response: Following the adoption of the Proposed Action, any specific development plans proposed for the Project Site would be subject to Site Plan review by the City of White Plains Common Council and project-specific review under SEQR. The Site Plan review process will include a public review and will allow the public time to comment on any detailed site plan for redevelopment of the Project Site. Regarding the specific impact areas listed by the commentator, any future development proposed on the site under the new zoning would be subject to Site Plan review under Section 7 of the Zoning Ordinance, and would be required to meet the following standards: Section 7.5.2. Safe, adequate and convenient vehicular and pedestrian traffic 13

circulation both within and without the site, as well as adequate parking and loading facilities, Section 7.5.4. A quality of building and the overall site design which will enhance and protect the character and property values of the adjacent neighborhood. 3. Claudia Murphy, Resident of 60 DeKalb Avenue and Business Owner, Comment made during Zoning Public Hearing, August 4, 2014 3-1 Comment: I would like to speak as a resident and a small business owner. As a resident, when I bought my apartment in 1999, the Border Books mall was a pretty thriving place, and you could walk down to Border Books on a Friday night, get a cup of coffee, have a cappuccino, listen to a jazz band. It was a whole different dynamic. And since a lot of the stores have moved out of that mall, it changes the dynamic of our neighborhood and the walking destinations that we have. 3-1 Response: Consistent with this comment, the proposed CB-3 zoning would allow for residential, hotel, mixed-use and development not currently permitted on the site. 3-2 Comment: As a small business owner, I will tell you that the last four to five new clients that I have gotten over the past few months have been young professionals from Manhattan renting in various apartment buildings in White Plains. I'd say like midthirties to mid-forties, either they have small children or they're going to have small children, and they're looking to White Plains as an alternative from Manhattan. For me, this is great for my business; you know, I can create jobs. If a project like this gets passed, and the zoning gets changed, and there are residential units included in this, I could maybe expand my company, hire a few more employees, or make some of my part- time people full-time. And I'm sure I'm not the only business that would benefit from something like this. I know some of the small business owners on Post Road have been waiting for a project like this to come along for a while. So I'm hoping that you all vote to change the zoning for this, and that we can proceed as soon as possible to get something viable in that space. 3-2 Response: The current zoning limits redevelopment options for the site to predominantly retail and commercial uses. The proposed zoning would allow for a much wider range of uses to be built on the site, including residential, hotel, and mixed-use development. If developed on the site, residential and hotel uses would add a 24/7 population that would enliven the area and support businesses providing goods and services. Written Comments 14

1. Edward Buroughs, AICP, Commissioner, Westchester County Planning Board August 12, 2014 letter to City of White Plains 1-1 Comment: The rezoning of this downtown site to change it from a district specific to enclosed malls to another existing zoning district which permits a wider range of uses and development configurations is consistent with the County Planning Board's longrange planning policies set forth in Westchester 2025-Context for County and Municipal Planning and Policies to Guide County Planning, adopted by the County Planning Board on May 6, 2008, amended January 5, 2010, and its recommended strategies set forth in Patterns for Westchester: The Land and the People, adopted December 5, 1995. The allowance for residential units and the creation of more mixeduse development in downtown White Plains would continue the trend of directing new development to existing centers, where infrastructure can support growth, where public transportation can be provided efficiently and where redevelopment can enhance economic vitality. 1-1 Response: See response 3-2, above. 1-2 Comment: The subject site has frontage on South Broadway (County Road 87) at its intersection with East Post Road (County Road CR 108). We note that the conceptual site plan shows a proposed roundabout at this intersection (which is currently signalized); however, there is no discussion of this treatment in the draft generic EIS. Any alteration to this intersection will require an approval from the County Department of Public Works and Transportation under Section 239F of the General Municipal Law and must adequately address vehicular capacity, the turning requirements of trucks and buses and the crossing of the streets by pedestrians. We recommend that this approval process and the need for Section 239F submittal be noted in the final generic EIS. 1-2 Response: Following the adoption of the Proposed Action, all actions coming before the City of White Plains Common Council, Planning Board, and Zoning Board of Appeals for redevelopment of the Project Site will be required to follow a project-specific SEQR process. Any future redevelopment activities proposed on the project site would be subject to project-specific approvals, including Site Plan Review and project-specific review under SEQR. As such, any alteration to area roadways or intersections would be subject to the review processes of the appropriate governing jurisdiction. Specifically, should alterations to the intersection of South Broadway and East Post Road (County Road CR 108) be proposed as part of a specific development plan proposed for the site, any such alteration will require an approval from the County Department of Public Works and Transportation under Section 239F of the General Municipal Law and must adequately address vehicular capacity, the turning 15

requirements of trucks and buses and the crossing of the streets by pedestrians. 1-3 Comment: In 2013, a Mass Transit Task Force examined the potential to create bus rapid transit (BRT) service across the I-287 corridor and concluded with a set of recommendations for both east-west and north-south services that would intersect in White Plains. Although full detailed routing was not included in the final recommendations, conceptual plans presented a BRT route along South Broadway and Maple Avenue, directly along the frontage of the subject site. The draft generic EIS does not discuss this transit planning process and its potential relationship to development on the site. In fact, the transit discussion is limited to the comment, "it is assumed that the property owner would provide a shuttle service to the White Plains train station." We recommend that the final generic EIS include a discussion of BRT planning, current to the time of its drafting. The document should also include a conceptual discussion of how transit infrastructure (e.g. a new BRT station) and enhanced transit services could, or should, be incorporated into future development plans for the site. 1-3 Response: The New NY Bridge Mass Transit Task Force has recommended a new Bus Rapid Transit (BRT) system as a component of the New NY Bridge, the planned replacement for the Tappan Zee Bridge. The BRT system would improve and expand existing transit system serving Westchester and Rockland Counties with enhanced routing and transit infrastructure. Of the seven proposed alternative routes, four would terminate in Downtown White Plains. Three of these routes, the Red, Navy, and Gold lines, would terminate at The Westchester, located within 1,500 feet of the Project Site. The task force has recommended these routes to travel along South Broadway and Maple Avenue when traveling between The Westchester and TransCenter stations. The routes are expected to operate at 15-minute headways during peak hours. If the BRT system is implemented as recommended, stations will be larger in size than existing bus stops and will be equipped with pre-boarding payment machines and enhanced amenities. The current plan does not propose the construction of dedicated bus lanes or use of Transit System Priority (TSP) technology within the study area. The BRT system, would be developed in phases, with the first phase having an eastern terminus at the former County bus terminal site on Bronx Street on the west side of the railroad tracks. The portion of the BRT east of the Harlem line railroad tracks will likely require a new tunnel under the rail line. A more detailed feasibility study is expected to be conducted by the County within the next five years. The provision of a BRT station adjacent to the Project Site would be beneficial to the project accessibility and would probably reduce its traffic impacts. The implications of a BRT route along South Broadway and Maple Avenue in the area of the Project Site would be reviewed during the site plan approval phase, and, if appropriate, the site plan may maintain sufficient space for a BRT station on one of its sides. 16

1-3 Comment: Additional development on the site wills most likely increase sewage flows from the site into the existing infrastructure and will add to the volume requiring treatment at the Mamaroneck Wastewater Treatment Plant operated by Westchester County. As a matter of County Department of Environmental Facilities policy, the County recommends that municipalities require development applicant to offset the projected increase in flow through reductions in inflow/infiltration (I&I) at a ratio of three for one. While the draft generic EIS discusses other improvements that may need to be made to add capacity to existing City-owned infrastructure to allow for additional development on the site, the document does not detail any I&I mitigation. We recommend the County policy on I&I be discussed in the final generic EIS and that the document present conceptual details on how implementation of I&I improvements may be accomplished. For example, will the applicant be required to place funds into a dedicated account for I&I work based on a per gallon cost of removal of flow through I&I? How will I&I projects to be identified? Who will conduct the work and in what timeframe? 1-4 Response: The City of White Plains has not yet identified specific locations for off-site mitigation of inflow and infiltration (I & I) as part of the project. The City of White Plains Department of Public Works has identified areas where improvements will be needed to increase capacity of the existing sanitary sewer infrastructure. As the City s infrastructure is generally in very good condition, (e.g., manholes, pipes/joints, sealed manhole covers), not much infiltration benefit is likely to be derived from replacement pipes. Of course, any development of the Project Site will comply with I & I requirements and attempt to address County goals. 1-5 Comment: The NYC Department of Environmental Protection (NYC DEP) has introduced a demand management program to conserve water. We recommend that the Final Generic EIS reference this program and include a conceptual discussion on water conservation measures that could be considered as part of additional development on the subject site. 1-5 Response: The New York City Department of Environmental Protection (NYC DEP) released its Water Demand Management Plan in 2013, which outlined NYCDEP s plan for implementation of water demand management projects to conserve water between now and 2021. As noted in the DGEIS, there are currently no specific development plans for the Project Site and the exact mix of future uses is unknown. Rather, the DGEIS provided analysis for each of the potential impact categories (DGEIS Chapter 3.0) for three potential scenarios: 1) a Maximum Residential Development Scenario; 2) a Maximum Commercial Development Scenario; and 3) a Maximum Mixed-Use Development Scenario. Following the adoption of the Proposed Action, any project-specific development plans for the Project Site would be subject to Site Plan 17

review by the City of White Plains Common Council and project-specific review under SEQR. As part of these review processes, the City Department of Public Works would provide recommendations (in the spirit of the NYCDEP water conservation program and similar LEED protocol) related to water conservation measures, including the use of high efficiency toilets, showerheads, faucets, appliances, and other fixtures. 2. David Chong, Commissioner, City of White Plains Department of Safety July 29, 2014 letter to City of White Plains 2-1 Comment: The Department of Public Safety has reviewed these plans. There are no objections. 2-1 Response: The statement of no objection is directed solely to the proposed zoning ordinance amendments. It is important to note that any future development proposed on the site under the new zoning would be subject to Site Plan review under Section 7 of the Zoning Ordinance, including the review of vehicular and traffic safety conditions under Section 7.5.2.7, the adequacy of fire lanes and other emergency zones under Section 7.5.2.10, and project-specific SEQR review. 3. Kent Johnsson, Member, City of White Plains Design Review Board August 4, 2014 letter to City of White Plains 3-1 Comment: The Design Review Board reviewed this application and had no comment until Site Plan application has been submitted. 3-1 Response: This statement is directed solely to the proposed zoning ordinance amendments. It is important to note that any future development proposed on the site under the new zoning would be subject to Site Plan review under Section 7 of the Zoning Ordinance, including a review under Section 7.5.4, which addresses project design. Specifically, a proposed project must meet the following standard: A quality of building and the overall site design which will enhance and protect the character and property values of the adjacent neighborhood. 4. Damon Amadio, Commissioner, City of White Plains Department of Building August 21, 2014 letter to City of White Plains 4-1 Comment: We have reviewed the zoning amendment, including the latest text referred to the Building Department on July 23, 2014, and the DGEIS dated July 2nd 2014 and have no objection to the request being granted. 4-1 Response: The statement of no objection is directed solely to the proposed zoning 18

ordinance amendments. It is important to note that any future development proposed on the site under the new zoning would be subject to Site Plan review under Section 7 of the Zoning Ordinance, including a detailed review by the Building and Planning Departments to ensure compliance with all zoning requirements, including site plan standards. 5. Elizabeth Cheteny, Commissioner, City of White Plains Department of Planning August 21, 2014 letter to City of White Plains 5-1 Comment: The expansion of permitted uses on the Project Site, as well as additional height and bulk, with limited coverage, would provide the City with opportunities for productive re-use of the Project Site that are in line with the goals of the Comprehensive Plan. The expanded range of permitted uses on the site will give future redevelopments the ability to better respond to market conditions and provide for the type of development that is consistent with development patterns in the downtown and have been expressly stated in the Comprehensive Plan. The Planning Department recommends that the Common Council approve the proposed amendment to the Zoning Ordinance. 5-1 Response: The statement of no objection is directed solely to the proposed zoning ordinance amendments. It is important to note that any future development proposed on the site under the new zoning would be subject to Site Plan review under Section 7 of the Zoning Ordinance, including a detailed review by the Building and Planning Departments to ensure compliance with all zoning requirements, including site plan standards. In addition, project-specific SEQR review will be required. 6. Thomas Soyk, PE, PTOE, City of White Plains Deputy Commissioner, Department of Parking, Traffic Division August 21, 2014 letter to City of White Plains 6-1 Comment: The major traffic concern of allowing a change in zoning for this site would be that future maximum build outs could result in traffic conditions that could not be handled by the existing roadway infrastructure. For the maximum residential and commercial scenarios, the majority of the intersections operate better than under an existing zoning full build out and any negative traffic impacts are minimal and easily mitigated for. 6-1 Response: For all maximum development scenarios, the DGEIS identified potential impacts at various intersections, days, and times. Some or all of such impacts may require mitigation such as changes in signal timing, new roadway infrastructure, or other measures to minimize delays. Any application for site plan approval will require a project-specific traffic study to evaluate the impacts and mitigation measures which 19

would be required for that specific future development project. 6-2 Comment: The mixed use scenario has more significant impact during the AM peak than the existing zoning build out but the area roadways are best able to accept traffic during this time period due to the presence of mostly retail development (which does not generate much traffic in the AM) in the immediate vicinity. The mixed use scenario has the benefit of creating more internal trips (residential to commercial) that will reduce impact on local streets. The potential for residents to walk to and from downtown sites, for both the mixed use and full residential scenarios, reduces the potential for increased vehicle trips. The mixed use scenario has the greatest potential for shared parking which allows for reduced provision of structure parking spaces. 6-2 Response: If the Proposed Action is approved, future development proposed on the Project Site under the CB-3 zoning would be subject to project-specific approvals, including Site Plan review and project-specific SEQR review. See Response 6-1, above. This review may include a project-specific analysis of traffic and transportation related impacts, if determined necessary by the City. 6-3 Comment: While traffic impact mitigation was not required for all of the proposed action scenarios, mitigation for an existing zoning full build would consist of changes in signal timing and phasing at numerous locations and more significant improvements necessary at several key intersections. The Department of Parking/Traffic Division recommends approval of the proposed changes. 6-3 Response: See Responses 6-1 and 6-2 above. 7. Michael Quinn, Chairman, City of White Plains Planning Board August 21, 2014 letter to City of White Plains 7-1 Comment: The Board recommends acceptance of the DGEIS, and supports rezoning the property. The Board notes that in any development proposal, it will be looking for public open space and residential development that appeals to families by providing larger units. 7-2 Response: Comment noted. It should be noted that the Zoning Ordinance requires Usable Open Space to be provided in developments, but the Zoning Ordinance does not require dedication of public open space. Usable Open Space is a defined term in the Zoning Ordinance that includes private space that may be located either indoors or outdoors and is not required to be made accessible to the public. Specifically, the Zoning Ordinance defines Usable Open Space as follows: An outdoor area or areas, each containing not less than 250 square feet and with a 20

minimum dimension of 10 feet, designed, constructed and maintained for active and passive pedestrian "use." It may include plazas, "courts," lawns, gardens sitting areas and similar types of areas, and shall be provided with such paving, planting beds, fountains, sculptures and works of art, seating, and comparable facilities as may be appropriate to the location. The design shall complement the architecture of the "building" or "buildings" on the same "lot." Up to 50 percent of the required "usable open space" may be beneath a "building" or overhang, canopy, arcade or similar projection at least 12 feet above such "space" provided it is fully open along at least 40 percent of its perimeter. All "usable open space" shall be designed, constructed and maintained so as to be readily accessible. (White Plains Zoning Ordinance Section 2.4) 8. Thomas Soyk, Acting Chairman, City of White Plains Transportation Commission August 21, 2014 letter to City of White Plains 8-1 Comment: The Transportation Commission has no objection to approving this amendment. 8-2 Response: The statement of no objection is directed solely to the proposed zoning ordinance amendments. It is important to note that any future development proposed on the site under the new zoning would be subject to Site Plan review under Section 7 of the Zoning Ordinance, including the review of transportation and parking conditions under Section 7.5.2. and project-specific SEQR review. (See responses, above, to Comments 6-1 to 6-3 from the Deputy Commissioner of Parking). 9. John Larson, Commissioner, City of White Plains Department of Parking September 2, 2014 letter to City of White Plains 9-1 Comment: The Department of Parking has no objection to this proposed Zoning Ordinance and Zoning Map Amendment. 9-2 Response: The statement of no objection is directed solely to the proposed zoning ordinance amendments. It is important to note that any future development proposed on the site under the new zoning would be subject to Site Plan review under Section 7 of the Zoning Ordinance, including the review of transportation and parking conditions under Section 7.5.2. and project-specific SEQR review. (See responses, above, to Comments 6-1 to 6-3 from the Deputy Commissioner of Parking). 21