DEPARTMENTOFCITYPLANNING

CITYOFNEWYORK
ManhattanOffice

October 14, 2014

Lola Finkelstein, Chair
Multi-Board Task Force
450 Seventh Avenue, Suite 2109
New York, NY 10123

Dear Lola,
I am writing in response to the recent letter from Mr. Andrew Penson of Midtown Trackage LLC
to you at the Multi-Board Task Force. We at the Department of City Planning (DCP) welcome
an open dialogue among all stakeholders and we are committed to listening to parties with
different perspectives that advance a fair and productive conversation. In that spirit, we are
writing to correct any misimpressions you may have about the Citys zoning proposal stemming
from the Midtown Trackage letter, which contains many erroneous assumptions and assertions.
As you know, the City is proposing to add a new special permit, Special Permit for Grand
Central Public Realm Improvement Bonus, to the Grand Central Subdistrict. The proposed
special permit would be applicable to the five blocks along Vanderbilt Avenue, between East
42
nd
and 47
th
streets, and would allow a floor area bonus of up to 15 FAR for developments in
the Vanderbilt Corridor in exchange for significant improvements to the areas transit and
pedestrian network. In its letter to you, Midtown Trackage claims that the Vanderbilt Corridor
proposal breaks from precedent and represents a radical departure from current zoning
practice. To the contrary: the proposed special permit is based upon a long established and
practiced incentive zoning mechanism, the Subway Improvement Bonus.
The subway improvement bonus was introduced more than three decades ago when the City
instituted a floor area incentive in the Special Midtown District to encourage developers of sites
in the central business district to undertake improvements to adjacent subway stations. Since its
adoption in 1982, the subway improvement bonus program has evolved and has been expanded
to apply to other parts of the city. It has resulted in a multitude of physical improvements to
subway stations that materially improve the user experience. Stations that have benefitted from
the bonus program include, to name just a few, Columbus Circle (sponsor project: Hearst
Tower), Lexington 53
rd
and 51
st
Street (599 Lexington Ave), and Union Square (Zeckendorf
Tower). To date, ten development projects have earned floor area bonuses for subway
improvements via special permit or as-of-right processes. While the majority of past bonuses
have been in range of 3 FAR, three projects have achieved bonuses of 13 FAR where maximum
density for a development may be increased from 2 to 15 FAR through the provision of major
subway improvements. Moreover, four previously approved projects have received bonuses of at
least 480,000 square feet (one project received a bonus of more than 1.0 million square feet).
Midtown Trackage also incorrectly states that a doubling of floor area achieved through a
subway improvement floor area bonus is unprecedented when in fact zoning has allowed
2
bonuses that are more than six times the as-of-right density. For more information on the history
of the subway improvement bonus, please see the attached report which is also available on
DCPs website.
Nor does Midtown Trackages claim that the City is abandoning the landmark transfer
mechanisms of Section 81-635 of the Grand Central Subdistrict and Section 74-79 withstand
scrutiny. The City continues to strongly support the need to preserve the opportunity for
landmark owners to sell unused development rights. In fact, as part of our Vanderbilt Corridor
proposal, we have taken significant steps not only to retain, but to enhance, a landmark owners
ability to transfer unused development rights. Section 81-635 currently limits a receiving site
utilizing landmark TDRs in the Grand Central Subdistrict to a maximum of 21.6 FAR. As part of
our proposed text amendment, we raise the maximum FAR for a receiving site using Section 81-
635 in the Vanderbilt Corridor to 30 FAR, bringing it to the same maximum allowed in our
proposed special permit. Further, we propose to modify Section 81-635 to make clear that the
public infrastructure improvements in connection with a Section 81-635 landmark transfer in the
Vanderbilt corridor would be at the discretion of the City Planning Commission, and could be
waived, rather than a mandatory component as currently required. These changes would make it
more appealing to potential developers to purchase development rights from Midtown Trackage
through the Section 81-635 mechanism.
Additionally, we are not proposing any change to the as-of-right 1 FAR increase in the Grand
Central Subdistrict that is available only by transfer from a landmark. We are also not proposing
changes to the Section 74-79 landmark transfer mechanism which allows unlimited FAR on the
receiving sites in certain high density commercial districts such as around Grand Central
Terminal, and as in the case of Section 81-635 also does not include the requirement for major
infrastructure improvements. Our proposed Grand Central Public Realm Improvement Bonus
mechanism simply represents an alternative, not a replacement, mechanism for developers to
seek additional floor area. Given the exposure of potential additional cost, time, and other risks
associated with the requirement to complete significant public infrastructure improvements, we
fully expect there will be developers who will readily opt to purchase landmark development
rights in order to avoid such exposure.
What Midtown Trackage is really suggesting is that there should be no alternative for a
developer to obtain greater density in the Grand Central area other than a purchase of
development rights at whatever the cost from Midtown Trackage itself. This would be a
radical departure from long established zoning policy which has provided developers with a
variety of avenues to achieve greater bulk, including but not limited to as-of-right bonuses,
purchase of air rights, zoning lot mergers, and special permits. There are many examples where
developers have purchased development rights from nearby landmarks even though other means
of achieving additional floor area were available to them.
With regard to infrastructure improvements, Midtown Trackage makes baseless claims regarding
the value of public improvements to be undertaken by SL Green as part of its One Vanderbilt
proposal. Its letter asserts that the value of the SL Green improvements to the Grand Central
station transit complex would be $65 million. To support its claim, Midtown Trackage refers to
work prepared by a third party consultant that is replete with inexplicable assumptions and
errors. First, the conceptual cost estimate prepared by a firm called Ellana Inc. is not based on
the actual program of improvements that is being proposed by SL Green. Strangely, the
3
conceptual cost estimate is dated September 8, 2014, after SL Green announced its proposed
program of improvements, yet in its own words is based on an MTAs presentation dated
October 2012. Moreover, the conceptual cost estimate assigns whole or portions of costs of
each line item to the MTA, even though the SL Green proposal makes it clear that SL Green will
be bearing the total cost of the improvement. Finally, the Ellana conceptual cost estimate fails to
take into account the series of proposed transit related improvements outside the station itself,
which again, contrary to Midtown Trackage comments, would not be required as part of an as-
of-right project.
Given the MTAs extensive experience with the Grand Central transit complex in particular, we
believe that the best judge of the cost of SL Greens proposed improvements is, obviously, the
MTA itself. The attached letter from the MTA clearly establishes what it believes the proposed
improvements cost. This private commitment not only saves the public taxpayer many millions
of dollars, but also puts the risk of cost overruns, time delays and unforeseen construction
conditions on the private developer, not on the MTA or the public.

SL Greens One Vanderbilt proposal is of course a private application and subject to the full
discretionary review of ULURP, including the careful consideration and vote by the City
Planning Commission. Our discussion of the SL Green project herein does not represent a pre-
determination of action by the City Planning Commission. We raise it here only to address
misinformation within Midtown Trackages letter to you. It is in all our interests to make sure
reliable and accurate information is being used when discussing any ULURP project, public or
private.

We welcome the opportunity to discuss our Vanderbilt Corridor proposal with the Task Force
anytime before or during ULURP. We hope this letter has been helpful to you. We look forward
to our continued dialogue as we work together to ensure the preeminence of Midtowns Grand
Central area. Thank you.
Sincerely,

Edith Hsu-Chen
Director, Manhattan
NYC Department of City Planning

Attachments:
History of NYC Transit Bonuses 1982-2014, DCP, October 2014
Letter from MTA to DCP, 10/14/14

CC:
Hon. Gale Brewer, Manhattan Borough President
Hon. Daniel Garodnick, NYC Councilmember
Vikki Barbero, Manhattan CB 5 Chair
Sandro Sherrod, Manhattan CB 6 Chair

History of NYC Transit Bonuses
Department of City Planning
Page 2


Introduction
As part of the Citys ongoing planning work in the East Midtown area, the Department of City
Planning has received a number of inquiries about the history of the subway bonus
mechanism and the projects which have been developed using it. In response, DCP has
compiled the following information about the individual proposals that have received floor
area bonuses for transit improvements. In 1982, the City instituted a floor area bonus for
subway station improvements as part of its Special Midtown District proposal (N 820253 (A)
ZRM). Developers were then able to apply for a new special permit in order to obtain a floor
area bonus in exchange for improvements to the station which, upon approval, they were
then required to undertake. The development site had to be located adjacent to a Midtown
subway station and the maximum floor area bonus was limited to a 20 percent increase over
the zoning lots base FAR. However, the amount of bonus floor area for each proposal was
subject to approval of the City Planning Commission, based on findings relating to the type
and scale of the proposed improvements, as well as the overall benefits to the City.
This provision was expanded in 1984 to apply to subway stations in high-density commercial
districts throughout Manhattan as well as Downtown Brooklyn (N 840541 ZRY). In addition,
an as-of-right floor area bonus was instituted in the Court Square area of Queens in 1986 (N
860683 ZRQ). In Court Square, specific sites were required to develop identified
improvements to obtain the maximum permitted floor area.
In the over 30 years since these provisions have existed, they have led to a number of
improvements to the Citys subway stations. These have included new pedestrian
connections between formerly disconnected stations, new vertical accesses to and within
stations, as well as expanded mezzanines and platforms. To date, seven projects have
utilized the special permit subway bonus, all of which have been in Manhattan. In addition,
three projects have used the as-of-right transit bonus that exists in the Court Square area in
Queens.
Each improvement project is unique, but the following data attempts to put them in a
cohesive descriptive framework so that decision makers and the broader public can make
easy comparisons between them. To do so, each subway bonus project is broken down into
a series of general project types which appear in some or all of the proposals. Additional
information about each project including the total bonus floor area it received is also
included. The predominant source of this information is the City Planning Commission
reports which document the public review processes for the various projects, and each
project therefore includes a link to the web version of the corresponding Commission report.
In addition, DCP has also included information about three additional projects in the East
Midtown area for which the Department has received similar inquiries. These include the
current One Vanderbilt proposal, as well as the earlier Philip Morris and 383 Madison
projects that included transit improvements pursuant to other zoning mechanisms.

History of NYC Transit Bonuses
Department of City Planning
Page 3

Transit Bonus Projects
Transit Bonus Project Year Bonus FAR FAR sf Page
599 Lexington 1984 2.7 146,293 4
Hines Building 1984 2.7 71,544 5
Zeckendorf Towers 1985 2.0 153,006 6
Worldwide Plaza 1986 1.3 200,000 7
New Colisum Project 1986 3.0 448,260 8
Citicorp - Queens 1986 13.0 1,068,093 9
Hearst Tower 2002 3.0 120,000 10
Court Square 2 2006 13.0 533,273 11
45 Courthouse Sq 2010 13.0 147,147 12
15 Penn Plaza 2010 3.0 480,000 13



Other Project Year Bonus FAR FAR sf Page
One Vanderbilt (proposal) 2014 12.3 528,900 14-15
Philip Morris (Covered Pedestrian
Space bonus and landmark
transfer)
1979 3.0 62,000 16
383 Madison (landmark transfer) 1998 - - 17


Common Improvement Types
New or expanded connecting corridor Projects that provide corridors between stations or
station portions

Mezzanine expansion Projects that expand the mezzanine level of subway stations

Platform widening Projects that widen the platform area of subway stations

Public space Projects that include public space, in addition to transit improvements

Elevators Projects that include elevators, either from street level or within the subway station

Exterior access - Projects that include new or improved access between street and station

Interior access Projects that include new or improved access between levels of the station

Other interior work Other environmental improvements to the station, including token booths

Light wells Projects that permit natural light to enter into the station

Other Other types of improvement work, including design drawings for future projects
History of NYC Transit Bonuses
Department of City Planning
Page 4

599 Lexington
Address: 599 Lexington Avenue
Station: Lexington/53
rd
and 51
st
Street
Year: 1984
Project Type: Subway Improvement Bonus
ULURP: C 840045 ZSM
FAR: 2.7 FAR
Bonus floor area: 146,293 sf
Status: Built


New or expanded connecting corridor
New corridor between 52
nd
Street and station at
53
rd
Street

Mezzanine expansion
-

Platform widening
-

Public space
-

Elevators
New elevator from street to concourse level

Exterior access
New stairway entrance at 52
nd
Street

Interior access
New escalator and stairway from concourse to underpass level

Other interior work
New token booth and turnstiles

Light wells
New light well to corridor

Other
Excavation and footings for future mezzanine enlargement by MTA
Preparation of drawings and documents for future mezzanine enlargement by MTA



History of NYC Transit Bonuses
Department of City Planning
Page 5

Hines Building
Address: 885 Third Avenue
Station: Lexington/53
rd

Year: 1984
Project Type: Subway Improvement Bonus
ULURP: C 840379 ZSM
Bonus FAR: 2.7 FAR
Bonus floor area: 71,544 sf
Status: Built


New or expanded connecting corridor
-

Mezzanine expansion
New westward expansion of E and M line station
mezzanine

Platform widening
-

Public space
-

Elevators
-

Exterior access
New stairway entrance

Interior access
New escalator from platform to expanded mezzanine level

Other interior work
-

Light wells
New light well to mezzanine

Other
-



History of NYC Transit Bonuses
Department of City Planning
Page 6

Zeckendorf Towers
Address: 1 Irving Place, Manhattan
Station: 14
th
Street/Union Square
Year: 1985
Project Type: Subway Improvement Bonus
ULURP: C 850001 ZSM
Bonus FAR: 2.0 FAR
Bonus floor area: 153,006 sf
Status: Built


New or expanded connecting corridor
-

Mezzanine expansion
New mezzanine expansion between control area
and station entrance
New mezzanine connection over 4, 5, 6 line
tracks

Platform widening
-

Public space
-

Elevators
-

Exterior access
New escalator and stairway entrance at 14
th
Street
New stairway entrance at 15
th
Street

Interior access
-

Other interior work
Relocated various MTA facilities including token booths and improved finishes

Light wells
-

Other
-




History of NYC Transit Bonuses
Department of City Planning
Page 7

Worldwide Plaza
Address: 1 Worldwide Plaza, Manhattan
Station: 50
th
Street
Year: 1986
Project Type: Subway Improvement Bonus
ULURP: C 860305 ZSM
Bonus FAR: 1.3 FAR
Bonus floor area: 200,000 sf
Status: Built


New or expanded connecting corridor
-

Mezzanine expansion
New mezzanine expansion adjacent to building

Platform widening
-

Public space
-

Elevators
New elevator from street to mezzanine
New elevator from mezzanine to lower level platform

Exterior access
New stairway entrance at 49
th
Street
New stairway entrance at 50
th
Street
Two reopened stairways at 49
th
street

Interior access
Two new stairs and one escalator from mezzanine to lower level platform

Other interior work
Mezzanine improvements including new control area, finishes, and lighting
New MTA storage and scrubber room

Light wells
New light wells at 49
th
and 50
th
streets from street to lower level platform

Other
-



History of NYC Transit Bonuses
Department of City Planning
Page 8

New Coliseum Project
Address: 10 Columbus Circle, Manhattan
Station: 59
th
Street / Columbus Circle
Year: 1986
Project Type: Subway Improvement Bonus
ULURP: C 860777 ZSM
Bonus FAR: 3.0 FAR
Bonus floor area: 448,260 sf
Status: Unbuilt


New or expanded connecting corridor
New corridor between south and northbound #1
line platforms

Mezzanine expansion
Reconfigured northbound mezzanine adjacent to
G&W Building
Reconfigured 58th Street entrance and control area

Platform widening
Widened southbound #1 line platform
Widened northbound #1 line platform

Public space
-

Elevators
-

Exterior access
New stairway entrance at 60
th
Street

Interior access
-

Other interior work
Other mezzanine and platform improvements including finishes, lighting and signs
New token booth and fare array at Central Park South entrance

Light wells
-

Other
New underplatform padding and ceiling treatment for #1 line tracks
New underplatform padding and ceiling treatment for A, C, E, line tracks


History of NYC Transit Bonuses
Department of City Planning
Page 9

Citicorp Queens
Address: One Court Square, Queens
Station: Court Square
Year: 1986
Project Type: Court Square Subway Improvement
ULURP: N 860683 ZRM
Bonus FAR: 13.0 FAR
Bonus floor area: 1,068,093 sf
Status: Built


New or expanded connecting corridor
New corridor between the E, F, and G lines

Mezzanine expansion
-

Platform widening
-

Public space
-

Elevators
-

Exterior access
-

Interior access
-

Other interior work
-

Light wells
-

Other
Preparation of plans for a connection between G and #7 lines




History of NYC Transit Bonuses
Department of City Planning
Page 10

Hearst Building
Address: 300 West 57
th
Street, Manhattan
Station: 59
th
Street / Columbus Circle
Year: 2002
Project Type: Subway Improvement Bonus
ULURP: C 020397 ZSM
Bonus FAR: 3.0 FAR
Bonus floor area: 120,000 sf
Status: Built


New or expanded connecting corridor
-

Mezzanine expansion
-

Platform widening
-

Public space
-

Elevators
Three new station elevators

Exterior access
New station entrance

Interior access
New stair between uptown A, C, E line platform and mezzanine
New stair between #1 line downtown platform and downtown A, C, E line platform
Three relocated stairs between #1 line platforms and lower mezzanine
Three relocated stairs between A, C, E line platform and mezzanine

Other interior work
Reconfigured control area 58
th
Street

Light wells
-

Other
-



History of NYC Transit Bonuses
Department of City Planning
Page 11

Court Square 2
Address: 23-29 44
th
Drive, Queens
Station: Court Square
Year: 2006
Project Type: Court Square Subway Improvement
ULURP: N 060246 ZCQ
Bonus FAR: 13.0 FAR
Bonus floor area: 533,273 sf
Status: Built


New or expanded connecting corridor
New corridor between G and #7 lines

Mezzanine expansion
-

Platform widening
-

Public space
-

Elevators
-

Exterior access
-

Interior access
-

Other interior work
-

Light wells
-

Other
-



History of NYC Transit Bonuses
Department of City Planning
Page 12


45
th
Road Courthouse Square
Address: 45
th
Road Courthouse Square, Queens
Station: Court Square
Year: 2010
Project Type: Court Square Subway Improvement
ULURP: N 100062 ZCM
Bonus FAR: 13.0 FAR
Bonus floor area: 147,147
Status: Incomplete


New or expanded connecting corridor
-

Mezzanine expansion
New improvements to station mezzanine

Platform widening
-

Public space
-

Elevators
-

Exterior access
New entrance to station platform

Interior access
-

Other interior work
-

Light wells
-

Other
-



History of NYC Transit Bonuses
Department of City Planning
Page 13



15 Penn Plaza
Address: 15 Penn Plaza, Manhattan
Station: 34
th
/ Herald Square and 34
th
/ Penn
Year: 2010
Project Type: Subway Improvement Bonus
ULURP: C 100049 ZSM
Bonus FAR: 3.0 FAR
Bonus floor area: 480,000 sf
Status: Unbuilt

New or expanded connecting corridor
Reopened corridor between Seventh Avenue and
Sixth Avenue/Broadway subway lines

Mezzanine expansion
-

Platform widening
Widened northbound #1 line platform between 32
nd
and 33
rd
streets

Public space
-

Elevators
New elevator between street and concourse level at 33
rd
Street

Exterior access
New escalator and stairway entrance to PATH station at 33
rd
Street
Reconfigured escalator and stairway entrance to PATH station at 32
nd
Street

Interior access
New stair between #2, 3 line platform and 32
nd
Street underpass
New stair between PATH mezzanine and subway mezzanine at 32
nd
Street
New stair between PATH mezzanine and subway mezzanine at 33
rd
Street
Widened stair between downtown #1 line platform and 32
nd
Street underpass
Widened stair between uptown #1 line platform and 32
nd
Street underpass

Other interior work
Reconfigured fare array at Sixth Avenue/Broadway subway lines

Light wells
-

Other
-


History of NYC Transit Bonuses
Department of City Planning
Page 14


Proposal - One Vanderbilt
Address: One Vanderbilt Avenue, Manhattan
Station: Grand Central Terminal complex
Year: 2014
Project Type: Grand Central Public Realm
Improvement Bonus
ULURP:
Bonus FAR: 12.3 FAR
Proposed Bonus floor area: 528,900 sf
Status: Proposal


New or expanded connecting corridor
New corridor between GC subway station and
GCT concourse
Reopened Mobile corridor between GC subway
station and Mobil Building

Mezzanine expansion
Expanded mezzanine in northern section of GC subway station
Expand mezzanine in central section of GC subway station

Platform widening
-

Public space
New ground-level indoor public space and waiting area at 43
rd
Street
New improvements to public place at Vanderbilt Avenue

Elevators
New elevator between street and GC subway station shuttle platform level at 42
nd
Street
New elevator between street and GCT concourse level at 43
rd
Street
New elevator between GCT concourse level and East Side Access
New elevator between street and GC subway station at Lexington and 42
nd
Street

Exterior access
New escalator and stairway entrance to GC subway station and new corridor at 42
nd
Street
New stairway entrance in indoor public space to new corridor at 43
rd
Street
Two new on-street stairway entrances to Mobil corridor at Lexington and 42
nd
Street
Expanded stairway entrance to GC subway station at Lexington and 42
nd
Street

Interior access
New escalator and stairs between new corridor and East Side Access
Two new stairs between GC subway station mezzanine and downtown platform
New stair between GC subway station mezzanine and uptown platform
Five reconfigured stairs between GC subway station mezzanine and downtown platform
Six reconfigured stairs between GC subway station mezzanine and uptown platform

(Continued on next page)
History of NYC Transit Bonuses
Department of City Planning
Page 15

Other interior work
Expanded control area in western section of GC subway station (shuttle platform area)
Reconfigured control area in northern section of GC subway station
Other GC subway station mezzanine finishing improvements

Light wells
New light wells to new corridor

Other
-

History of NYC Transit Bonuses
Department of City Planning
Page 16

Philip Morris
(Covered Pedestrian Space bonus and 74-
79 floor area transfer, not subway
improvement bonus)
Address: 120 Park Avenue, Manhattan
Station: Grand Central Terminal complex
Year: 1979
Project Type: Covered Pedestrian Space bonus and
floor area transfer from landmark
ULURP: C 780404 ZSM
Bonus FAR: 3.0 FAR through Covered Pedestrian
Space bonus
Bonus floor area: 62,000 sf
Status: Built


New or expanded connecting corridor
-

Mezzanine expansion
-

Platform widening
-

Public space
New ground-level indoor public space at Park Avenue (pursuant to Covered Pedestrian Space
bonus

Elevators
-

Exterior access
New escalator and stairway entrance to GC subway at Park Avenue and 42
nd
Street

Interior access
-

Other interior work
-

Light wells
-

Other
-
History of NYC Transit Bonuses
Department of City Planning
Page 17


383 Madison Avenue
(81-635 floor area transfer, not subway
improvement bonus)
Address: 383 Madison Avenue, Manhattan
Station: Grand Central Terminal complex
Year: 1998
Project Type: Floor area transfer from landmark
ULURP: C 980682 ZSM
Bonus FAR: 0
Bonus floor area: 0 sf (required pursuant to transfer)
Status: Built


New or expanded connecting corridor
-

Mezzanine expansion
-

Platform widening
-

Public space
New ground-level public passageway along Vanderbilt Avenue

Elevators
-

Exterior access
New stairway entrance to North End Access passageway at 47
th
Street

Interior access
-

Other interior work
Enclosed North End Access passageway


Light wells
-

Other
-