1. For any station to which there are expected to be 200 or more trips in the AM or PM peak hour, the capacity of stairways, turnstiles and platforms to absorb the peak 15 minute volume of people entering or leaving the station. The adequacy is expressed in Level of Service (LOS) from A to F, with F exceeding 1.0 v/c (the ratio of volume to capacity). Not unexpectedly, with the proposed new direct connection from the Atlantic Avenue/Flatbush Avenue subway/LIRR complex to the arena and a few stairway improvements, everything in the AM and PM peak hour rates an A, even in 2016, except for two turnstile areas, which are accorded a B, suggesting that even if the added volumes were doubled, the stations would not be a constraint. And the DEIS takes no account of the likelihood of “smart cards” which would eliminate swiping and most of the delay. In 2010, when the arena goes into operation, in the 7-8 PM pre-game period, there will be an LOS E on one new entry escalator to the “Urban Room” entrance to the arena and in the post-game period.
   
2. The adequacy of the subway cars on each line in the AM and PM peak hour at their peak load points, inbound 8-9AM (Manhattan bound) and outbound (Brooklyn bound) 5-6 pm. This is called the line haul analysis. These are presented only as totals including existing and background riders so they camouflage the relative significance of each element and examine the reasonableness of the assumptions (to the extent they can be dug out of the DEIS—most are not reported at all).

In order to identify the impact of Atlantic Yards, one must subtract the Future Without the Project (a.k.a., the No Build) from the Future With the Project (the Build) and from these has to be deducted the Existing 2005 condition. Then it is necessary to determine how much of the No Build ridership is due to the assumed 0.5% a year background growth and how much to other development in the study area. The attached analysis of line haul conditions with correction of the flawed assumptions in the DEIS concludes that, without more subway service, at least, seven lines will experience severe “crush loading.” This contrasts with the DEIS finding that all subway lines in Brooklyn will have adequate capacity for all riders in 2016 and, thus, no mitigation (no increase of service on any line) is needed.

Subway Crowding (Line Haul Analysis). The justification for the highly profitable density of Atlantic Yards is the much trumpeted confluence of 12 subway lines within or near the project site. However, there is a paucity of information about what people really care about: the adequacy of subway service to handle the added passengers. The mere 9 pages on this (out of 100 in the chapter) is buried in a blizzard of minutiae about stairway crowding, rarely a significant constraint and less so at this site due to a new subway connection to the “Urban Room” arena entrance. Potentially hazardous post-game platform crowding is proposed to be reduced by more frequent post-game trains, the only transit mitigation proposed.

When it comes to the most intractable issue, one that has system wide impacts, the intensity of crowding on subways, the transit section of the DEIS presents only conclusions with no supporting data or analysis. Readers are asked to take on faith that the unreported underlying assumptions are reasonable, or forced to ferret them out and re-examine them in the context of external official, but difficult to obtain, data.

Contrary to the DEIS’s conclusion that in 2016, with the full build out of Atlantic Yards, no subway route would be overcrowded, a realistic reconstruction of the analysis finds that, at least six lines would greatly exceed NYC Transit’s “crush load.”

This occurs in both the Build and the No Build in 2016 on the 2, 3, 5, A, B, N and R lines and, nearly so on the 4 and the Q. These realistic impacts are not evident because the DEIS spells out no assumptions for the single summary table to support the finding that, with Atlantic Yards in 2016, “all routes would continue to operate below capacity in the peak direction in the AM and PM at their maximum loadpoints” (p.13-87). The core of the inaccuracy is that the same finding was erroneously made for the No Build (p. 13-66).

Reconstructing the analysis reveals how the subway impact of Atlantic Yards and other development is miscalculated Table 1):

• By severely underreporting (as does the traffic analysis) the future growth in riders without the project (the No Build scenario), the DEIS gives Atlantic Yards an unrealistically generous margin of available subway capacity for added project trips (the Build scenario).
• The DEIS assumes an annual growth of subway ridership of only 0.5% per year, the standard citywide for background growth in average times, or 6,512 over the 10 years from 2006 to 2016.
• NYC Transit Subway and Bus Rider Surveys report average weekday subway entries has grown in the last five (pre-boom) years at close to 2% a year from Brooklyn outside Downtown, and in 2004 to 2005 began an upward trajectory of 3.3%, which averages 3% for all Brooklyn.
• The DEIS at the 0.5% annual passenger growth rate projects a No Build growth of subway ridership due to development or 6,475 inbound trips in the AM peak hour in 2016.
• In the other element of No Build growth, the DEIS accounts for only 47% of identified approved and/or planned development in Downtown Brooklyn (DTB). Adding the uncounted 53% would add 7,300 more AM peak hour inbound trips in 2016 for a total of 13,800 trips due to development in DTB.
• The DEIS leaves out demand created by the 500,000 new jobs projected by NYMTC for 2025. For Brooklyn to maintain just its historic 20% share (and with changing demographics, it should go up), there would be 15,000 added inbound riders on lines through DTB in the AM peak hour in 2016 (Table 2)
• Accounting for the 27,800 total new trips generated by development in DTB and Manhattan, ridership would continue to grow at the 2004-2005 rate of 3% a year.
• Applying this 3% over the 10 year period analyzed in the DEIS would add up to a 30% background growth of passengers entering Downtown Brooklyn, not 5% as assumed in the DEIS.
• Each of the DEIS reported ridership assumptions and their corrections are spelled out in Table 3. These show the ratio of passenger volume compared to NYC Transit’s capacity guideline for adding service, based on passengers per car for each car model, generally equal to 4 square feet per passenger (SF/P). The “crush load” of 3.8 SF/P is a v/c of about 1.05.
• ESDC/FCR cannot refute these numbers unless it reports:
  
        - Brooklyn-based trip generation factors
       - Intra-borough trip origins by Census tract
       - assignment of riders per train route for Build and No Build trips
       - passenger load into and out of each stop by route with entries and exits by direction.

This information was requested of ESDC on July 26, 2006.

All these are contained in the planning model that NYC Transit maintains, was requested by the community boards to make transparently available for the DEIS, and for which they, as the agency that selected FRC for $100 million less than its lower density competitor, have a compelling obligation to do so. Alternately, the NYC transit model can be recalibrated with the latest Brooklyn data and elimination of an arbitrary ceiling for each borough of growth of jobs and population.

The consequences of failure to disclose subway needs will be even more severe than the DEIS’s under reported traffic analysis. The feasibility of Atlantic Yards and the success of the development of Downtown and, indeed, of all of Brooklyn depend on adequate transit.

Brooklyn can’t wait until 2016 to find out that the DEIS was wrong. While unbearable traffic congestion could be solved relatively quickly with road and parking pricing, adding new rail transit capacity takes 20-30 years and must begin now.