CHAPTER 11 CULTURAL RESOURCES

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							MTA New York City Transit                                                            Fulton Street Transit Center DEIS




CHAPTER 11: CULTURAL RESOURCES
11.1 INTRODUCTION
11.1.1             CONTEXT AND KEY ISSUES
Cultural resources are an important part of the character of a community. Cultural resources may include
historic features, such as buildings, structures, sites, objects and districts, as well as archaeological
resources, which are physical remains, usually buried, of past activities on a site. Archaeological
resources can include remains from Native American people who used or occupied a site, including tools,
refuse from tool-making activities, habitation sites, etc. These resources are also referred to as
“precontact,” since they were deposited before Native Americans’ contact with European settlers.
Archaeological resources can also include remains from activities that occurred during the “historic
period” (the period beginning with European colonization of the New York area), and include remains
such as battle sites, foundations, wells and privies.

This chapter presents the potential impacts on cultural resources from the construction and operation of
the Fulton Street Transit Center (FSTC). The analysis of potential impacts was carried out in accordance
with the National Historic Preservation Act of 1966 (NHPA), 16 U.S.C Section 470f and the
implementing regulations under Section 106 that are codified at 36 C.F.R. 800. Section 106 and the Part
800 regulations require Federal agencies to consider the effects of their actions on historic properties,
which are defined in the regulations as resources listed on or determined eligible for the National Register
of Historic Places. Properties listed on or determined eligible for the National Register can include both
archaeological and historic resources. The National Environmental Protection Act (NEPA) (in accordance
with which this Draft Environmental Impact Statement (DEIS) is being prepared), also requires the
evaluation of impacts on cultural resources. The NHPA requires public outreach within the DEIS process
to ensure the environmental review of the FSTC is in compliance with the NHPA and NEPA. The New
York State Historic Preservation Act (SHPA) closely resembles the NHPA, and requires that State
agencies consider the effect of their actions on properties listed on or determined eligible for listing on the
State Register of Historic Places. Compliance with Section 106 satisfies the requirements of SHPA, set
forth in Section 14.09 of the New York State Parks, Recreation and Historic Preservation Law; therefore,
a separate analysis of effects under SHPA is not required.

Historic properties are also protected by Section 4(f) of the Department of Transportation Act of 1966 and
implementing regulations codified in 23 C.F.R. 771.135. Section 4(f) regulates actions by the Secretary
of Transportation that require the use of a historic property that is listed on or eligible for inclusion on the
National Register. Section 4(f) states: “The Secretary of Transportation may approve a transportation
program or project requiring the use of...land of a historic site of national, state or local significance (as
determined by the Federal, State or local officials having jurisdiction over the site), only if...a
determination is made that there is no feasible and prudent alternative to such use, and all possible
planning has been undertaken to minimize harm to the 4(f) property.” Section 4(f) also requires public
outreach. The Section 4(f) Evaluation for the FSTC is contained in Chapter 22.

The New York City Landmarks Preservation Commission (LPC) designates historically significant
properties in New York City as landmarks or historic districts. Properties designated as landmarks or
historic districts are protected under the New York City Landmarks Law, which requires LPC review and
approval before any alterations or demolition can occur. Although the New York City Landmarks Law is
not applicable to the Proposed Action, potential impacts to landmarks and historic districts have been
considered.

The condition and occurrence of archaeological and historic sites that are located in the study area, or
Areas of Potential Effect (APE), have not been substantially altered as a result of the events of September

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11. Archaeological deposits or features are not considered likely to be found in the APE given the extent
of construction disturbance that has historically occurred in the area, both pre- and post-September 11.

An initial APE for the FSTC was identified as part of the environmental analysis process and approved by
the New York State Office of Parks, Recreation, and Historic Preservation (NYSOPRHP), which serves
as the State Historic Preservation Office (SHPO), in its letter of February 13, 2004 (see Appendix H).
Subsequent to SHPO’s approval, the APE was expanded to the west to consider potential effects of the
RW - E Connector. Historic resources within the APE include the Corbin Building (192 Broadway),
the Fulton Street 45 Subway Station, the former AT&T Building (195 Broadway), the Bennett
Building (139 Fulton Street), the East River Savings Bank (25 Dey Street) and St. Paul’s Chapel and
Graveyard. Also included in the APE are a portion of the WTC site and a portion of the John Street-
Maiden Lane Historic District. This National Register-eligible District includes the National Register-
listed Corbin Building,which is located in the portion of the District within the APE, and the National
Register-eligible Hays Building at 21-23 Maiden Lane, which is in the portion of the District outside the
APE. The District also includes buildings that are not individually eligible for the National or State
Registers but which are considered contributing elements in the District, such as the Dennison Building at
15 John Street. The FTA, NYCT and SHPO will enter into a Memorandum of Agreement (MOA)
regarding the treatment of historic resources within the APE that may be affected by the Proposed Action.
The draft MOA is included in Appendix H.

These historic resources in the APE are evaluated in the context of Section 106 of the Historic
Preservation Act and Section 4(f) of the Department of Transportation Act. The analysis therefore
compares the construction and operation of the FSTC against the prevailing future conditions in the study
area for each of the analysis years, both with and without the project. As noted previously, the Section
4(f) Evaluation is contained in Chapter 22.

11.1.2             CONCLUSIONS
Under the No Action Alternative, the FSTC would not be constructed. Minor maintenance and
rehabilitation activities could occur, including typical station and transit infrastructure maintenance and
repair. The Existing Complex would remain in its current configuration and operational state. There
would not be any impacts on cultural resources associated with the FSTC. A number of other major
construction projects would be underway in the study area in 2005/2006, including the WTC Memorial,
the Permanent WTC PATH Terminal, South Ferry Subway Terminal, and Route 9A (see Chapter 20:
Cumulative Effects, for related impacts).

Under the Build alternatives, the FSTC would be constructed and operated as described in Chapters 3:
Alternatives, and 4: Construction Methods and Activities. The only substantial differences with respect to
cultural resources differ primarily with respect to the use of the Corbin Building.

Under Alternative 9, the Corbin Building would remain in private ownership. An underground slurry
wall or similar structure would structurally isolate the FSTC Entry Facility and Dey Street Passageway
from the Corbin Building. Depending on the findings of the geotechnical and structural investigations
that would be carried out during Final Design, Alternative 9 may require underpinning of the Corbin
Building. This would be determined based on whether or not there is a risk of excessive movement of the
Corbin Building during the construction of the Entry Facility. Such a risk could have implications for the
project cost and schedule and would necessitate the use of underpinning or a similar protective technique,
such as compensation grouting. Based on information available to date, NYCT would proceed with
underpinning of the Corbin Building in Alternative 9 to avoid risks related to public safety and damage to
the historic resources associated with unknown construction conditions. Underpinning, if used, would
remain permanently in place. This could require temporary displacement of tenants in the basement of the
Corbin Building. No other impacts to the Corbin Building are anticipated under this alternative, although
impacts related to vibration during construction could occur.


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Under Alternative 10, the Corbin Building would be acquired by New York City Transit (NYCT) and
underpinned and used as part of the FSTC Entry Facility and Dey Street Passageway. Tenants in the
building would be permanently displaced. While this alternative would directly impact the Corbin
Building, the intent of this alternative is to rehabilitate and adaptively re-use the building in a manner
consistent with its historic character. The MOA (see Appendix H) would ensure that adverse effects
arising under this alternative would be minimized and satisfactorily mitigated.

Other historic resources that would incur impacts as a result of the FSTC under both Build alternatives
include the Fulton Street 45 Subway Station and the American Telephone and Telegraph (AT&T)
Building. As with the Corbin Building, the MOA would ensure that adverse effects arising under these
alternatives would be minimized and satisfactorily mitigated.

Other historic sites that could incur vibration or soil settlement impacts from construction under both
Build alternatives are the East River Savings Bank, St. Paul’s Chapel and Graveyard, the Bennett
Building and some buildings located within the John Street-Maiden Lane Historic District (including the
non-designated Dennison Building at 15 John Street which is a contributing element in the historic
district, but not individually eligible for the National Register). Under Alternative 10, the Dennison
Building could also require underpinning. These impacts are not expected to compromise the structural
integrity of these buildings nor the characteristics that qualify them for inclusion on the National Register.
Appropriate measures will be taken during construction to avoid impacts to these historic resources,
including those related to vibration, through a formal consultation process, a Construction Environmental
Protection Program (CEPP) and related plans, and a Cultural Resources Management Plan (CRMP).
Although archaeological resources are not anticipated to be encountered during the construction of either
Build Alternative, the CRMP would include an Emergency Action Program (EAP), to address any
potential archaeological impacts outside the current archaeological APE. This would include the
requirement of an archaeologist certified by the Register of Professional Archaeologists (RPA) on the
preliminary engineering team to address any potential archaeological issues that may be relevant to the
final design of the FSTC. Measures for avoidance or minimization of effects to these other historic sites
or archaeological resources would be included in the MOA for the project (included in Appendix H).

The Word Trade Center (WTC) site, a National Register-eligible historic resource, may be affected by the
construction and permanent operation of the RW - E Connector, which would be located beneath
Church Street near the Dey Street Passageway, and may require construction or be permanently located
within the eastern boundary of the WTC site, where a remnant foundation wall from the former Hudson &
Manhattan (H&M) railroad terminal exists. This wall is a remnant of the former H&M railroad facilities
that ultimately became the Port Authority Trans-Hudson (PATH) in association with construction of the
WTC. While realignment or removal of a portion of this wall would constitute a physical change in this
element of the historical site, it is not a contributing element and therefore would not diminish the
characteristics of location, setting, feeling, materials and association with the events of September 11 that
qualify the WTC site for inclusion on the National Register. The precise location of the RW - E
Connector would be determined as engineering advances and would be developed in cooperation with the
Port Authority of New York and New Jersey (PANYNJ) and the Lower Manhattan Development
Corporation (LMDC), as the Permanent WTC PATH Terminal and WTC site and Memorial is developed.
Construction of the RW - E Connector would not have any adverse effects on the WTC as a historic
resource, as construction of the RW - E Connector would not diminish the WTC site’s integrity of
location, setting, feeling, materials or association with the events of September 11.

As noted above, the National Register-eligible Hays Building at 21-23 Maiden Lane is located within the
John Street-Maiden Lane Historic District, but is outside the APE; it would not be affected by
construction activities as it is located more than two (2) city blocks from the closest area of proposed
construction of the FSTC.

The Federal Transit Administration (FTA) and NYCT have determined that the construction of the FSTC
will have adverse effects on historic properties under either Alternative 9 or Alternative 10.

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The FTA and NYCT would resolve adverse effects of the FSTC on historic properties through the MOA
referenced above (see Appendix H). To ensure maximum protection of the historic resources, NYCT
assumes in the draft MOA that there will be an adverse effect. FTA and NYCT will develop and
implement the MOA in consultation with the SHPO and the Advisory Council on Historic Preservation
(should it choose to participate in the consultation). The MOA would contain specific measures by which
identified impacts would be avoided, minimized or mitigated. The MOA would also set forth the process
and procedures for consultation, determination of effect and resolution of any as yet unidentified adverse
effects that would govern the planning, design and implementation of the project from the date of the
MOA’s execution.

Initial and full operation of the FSTC (selected study years 2008 and 2025), would not have any adverse
effects on historic resources in the APE. Under Alternative 9, the Corbin Building would remain in
private ownership and would not be a recipient of Federal preservation protection. Under Alternative 10,
the Corbin Building would be publicly owned and would be assured of Federal preservation protection
under the MOA between the FTA, MTA and SHPO (see Appendix H). The construction of the Entry
Facility and Dey Street Access Building would not require the removal of any buildings within the John
Street-Maiden Lane Historic District. The design of the FSTC would be compatible with its context and
historic setting and no adverse effects on the John Street-Maiden Lane Historic District are expected.
Table 11-1 summarizes potential cultural resources impacts associated with the FSTC.

11.2 GUIDELINES AND REGULATIONS
The NHPA and associated regulations establish procedures for the determination of impacts to cultural
resources and form the basis for the steps outlined below.

Step 1: Determine the APE

The APE is the geographic area in which the project may cause effects to significant cultural resources
directly through construction; indirectly through construction or operation; or cumulatively through other
past, present or future actions undertaken in the community. The APE is influenced by the scale and
nature of an undertaking and may be different for different kinds of effects caused by it (36 C.F.R.
800.16).

Step 2: Identify Historic Properties and the Possibility of Archaeological Resources Being Present
Within the APE

Section 106 of the National Historic Preservation Act (36 C.F.R. Part 800) defines a historic property as
“any prehistoric or historic site, building structure, or object included in, or eligible for inclusion in, the
National Register of Historic Places maintained by the Secretary of the Interior.” Properties listed on or
determined eligible for the National Register include archaeological resources.

Step 3: Determine Effects

The standard for determining effects of an action on historic properties is based on the Criteria of Adverse
Effect defined in 36 C.F.R. 800.5(a) (1). An adverse effect is found when an action may alter
characteristics of a historic property that qualify it for inclusion on the National Register in a manner that
would diminish the integrity of the property’s location, design, setting, materials, workmanship, feeling or
association. Adverse effects may include reasonably foreseeable effects caused by the action that may
occur later in time, be farther removed in distance, or be cumulative.

Consistent with these regulations, the analysis of the No Action and Build Alternatives’ effects on
archaeological and historic resources is being conducted in coordination with the SHPO. Consultation has
also been undertaken with the LPC.


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          MTA New York City Transit                                                                               Fulton Street Transit Center DEIS



                                                            Table 11-1
                                       Summary of Comparison of Alternatives: Cultural Resources

                                                                                                                                                        2025
                                        2005/2006                                 Planned Action                            2008
                                                                                                                                                        (Full
                                      (Construction)                          (for 2005/2006 Impact)                (Initial Operation)
                                                                                                                                                      Operation)
                                                                                                                 Corbin Building remains in
                                                                                                                 private ownership without
    No Action        No impacts.                                            N/A
                                                                                                                 benefits associated with long
                                                                                                                                                  As 2008
                                                                                                                 term public ownership.

                     No archaeological resources likely to be
                     encountered. CRMP implemented to address               N/A                                  No impacts.
                     potential design changes outside existing APE.
                                                                                                                                                  As 2008
                                                                                                                 Corbin Building remains in
                     Corbin Building structurally isolated and protected.                                        private ownership without
                                                                            N/A
                     Underpinning or similar support likely required.                                            benefits associated with long
                                                                                                                 term public ownership.
                                                                            Historic buildings protected
                     AT&T Building (195 Broadway) underpinned. No           subject to EPCs, CEPP and
                     alterations to historic features proposed.             Section 106 requirements,
                                                                            including the MOA.
    Alternative                                                             45 Station rehabilitation
         9                                                                  conforms to U.S. Department of
                     45 Station rehabilitated.                              the Interior (USDOI) Standards
                                                                            for the Rehabilitation of Historic
                                                                            Buildings and MOA.                                                    As 2008
                                                                                                                 No impacts.
                     RW-E Connector constructed between Dey
                     Street Passageway and WTC Site. No impacts on          N/A
                     National Register eligibility of WTC Site.

                     Potential vibration and ground settlement impacts
                                                                            Historic buildings protected
                     on Corbin Building, John Street- Maiden Lane
                                                          (1)               subject to EPCs, CEPP and
                     Historic District (Dennison Building) , East River
                                                                            Section 106 requirements,
                     Savings Bank, St. Paul’s Chapel and Graveyard,
                                                                            including MOA.
                     and Bennett Building.

                     No archaeological resources likely to be
                     encountered. CRMP implemented to address               N/A                                  No impacts.
                     potential design changes outside existing APE.

                                                                            Corbin Building adaptive reuse       Corbin Building acquired by
                                                                            conforms to USDOI Standards          MTA and integrated with
                     Corbin Building integrated with FSTC Entry             for the Rehabilitation of Historic   FSTC Entry Facility and is       As 2008
                     Facility.                                              Buildings and MOA.                   subject to benefits
                                                                                                                 associated with long term
                                                                                                                 public ownership.
                                                          (1)               Historic buildings protected
                     AT&T Building, (Dennison Building)
                                                                            subject to EPCs, CEPP and
                     underpinned. No alterations to                                                              No impacts.
                                                                            Section 106 requirements,
    Alternative      historic features proposed.
                                                                            including MOA.
        10
                                                                            45 Station rehabilitation
                                                                            conforms to USDOI Standards
                     45 Station rehabilitated.                                                                   No impacts.
                                                                            for the Rehabilitation of Historic
                                                                            Buildings and MOA.

                     RW-E Connector constructed between Dey
                     Street Passageway and WTC Site. No impacts on          N/A                                  No impacts.
                                                                                                                                                  As 2008
                     National Register eligibility of WTC Site.

                     Potential vibration and ground settlement impacts
                                                                            Historic buildings protected
                     on Corbin Building, John Street- Maiden Lane
                                                        1                   subject to EPCs, CEPP and
                     Historic District Dennison Building , East River                                            No impacts.
                                                                            Section 106 requirements,
                     Savings Bank, St. Paul’s Chapel and Graveyard,
                                                                            including MOA.
                     and Bennett Building.
1
 The Dennison Building is a contributing element in the John Street-Maiden Lane Historic District but is not individually eligible for the National Register.
Source: Louis Berger Group, Inc., 2004.



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Regulations implementing Section 106 of NHPA define the APE as the location(s) where “an undertaking
may directly or indirectly cause alterations in the character or use of historic properties (including
archaeology), if any such properties exist.” The regulations define “effect” as “alteration to the
characteristics of a historic property qualifying it for inclusion in or eligibility for the National Register of
Historic Places.” An adverse effect occurs “when an undertaking may alter, directly or indirectly, any of
the characteristics of a historic property that qualify the property for inclusion in the National Register in
a manner that would diminish the integrity of the property’s location, design, setting, materials,
workmanship, feeling or association” (36 C.F.R. 800.5(a)(1)).

The analysis identifies activities specific to the project that could affect historic properties or archaeology,
such as: ground disturbance; demolition of existing buildings or structures; alteration of existing buildings
or structures; introduction of new elements into an existing environment; or changes in land use. Some
projects may involve all these types of activities and more, while others may be limited to one (1) or two
(2) of these activities. The physical extent of the APE is, therefore, based on the known or reasonably-
predicted physical extent of the various activities that are expected to occur during or as a result of
implementation of the project.

11.3 ENVIRONMENTAL PERFORMANCE COMMITMENTS
     (EPCs)
The FSTC would be implemented with EPCs, which are measures that would be proactively implemented
to avoid or reduce potential impacts of the FSTC. With regard to cultural resources, they include the
following:

    •      Establish coordination among projects to avoid or minimize interruption in access to cultural and
           historic sites;
    •      Initiate public information and involvement outreach with sensitivity to local cultural resources;
    •      Identify public information outlets that would receive and provide current information about
           access during construction, to minimize interruption in access to cultural and historic sites;
    •      Consult with the SHPO and the LPC regarding potentially impacted, culturally significant sites to
           ensure that all potential impacts are identified and avoided or minimized to the greatest extent
           possible (see below); and,
    •      Monitor noise and vibration during construction at such sites as appropriate to ensure that such
           sites are not inadvertently damaged by adjacent or nearby construction.

EPCs for other resources, such as noise and vibration, and access and circulation, may also contribute to
avoidance or reduction of project impacts on cultural resources. A detailed discussion of those
commitments is provided in the respective chapters addressing those resources.

11.4 METHODOLOGY
11.4.1             AGENCY COORDINATION
Several activities were performed at the beginning of the cultural resource analyses to ensure that the
involved parties (consultants and agencies) were fully familiar and in agreement with the intended goals,
objectives and methodologies for this effort. These activities included the following:

    •      Participate in working sessions with the involved agencies, such as the SHPO, LPC, PANYNJ,
           New York State Department of Transportation (NYSDOT) and LMDC to coordinate on the
           methodologies proposed and to share available data, as appropriate;
    •      Provide opportunities for public comment and input via Community Board Meetings, American
           Institute of Architects (AIA) open public forums and the maintenance of the NYCT website; and,

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    •      Establish a study area and identification of resources (see Section 11.4.2).

11.4.2             ANALYSIS ELEMENTS AND STUDY AREA
The analysis of cultural resources is presented in two (2) sections: archaeological resources and
historic/architectural resources.

ARCHAEOLOGICAL RESOURCES

The APE for archaeological resources encompasses all areas subject to ground disturbance as a result of
implementation of the FSTC. A resource sensitivity assessment identified known archaeological
resources (i.e. resources recorded in the files of the SHPO and LPC) and resource types that could be
present based on an analysis of prehistoric and historic period land use within the APE.

This assessment also considered the extent to which such potential resources, if they exist, may be intact
or may have been damaged or destroyed by subsequent land use over time. For each area where research
indicated that archaeological resources might be present, further research was undertaken to determine
original site topography and any subsequent alterations through filling, grading, development, or other
activities. The objective of this assessment was to identify locations where any archaeological resources,
if originally present, may have survived later disturbances. Areas that may have archaeological resources
are considered to be archaeologically “sensitive.” Areas where it can be demonstrated that modern urban
development activities have disturbed the potential locations of archaeological resources are characterized
as “disturbed” and do not require further assessment for archaeological resource potential.

For archaeologically sensitive areas, professional archaeologists would outline a program of additional
documentary research, field testing and/or mitigation measures that would be undertaken prior to any
construction. Generally, the steps would include additional research and field testing to identify whether
any archaeological resources are actually present on the sites and, if so, whether the resources are eligible
for the National Register. Then, for any such resources, a range of possible mitigation measures would be
identified, including avoidance, data recovery and curation.

Delineation of the APE for archaeology for the FSTC began with the areas where ground disturbance
could affect archaeological resources if such resources are present (see Figure 11-1: Archaeological
Resources APE). These areas of ground disturbance are as follows:

    •      The Entry Facility, located between Broadway, Fulton and John Streets (Block 79, Lots 15, 16,
           18, 19 and 21);
    •      The Dey Street Passageway, to be constructed below Dey Street, connecting the RW line
           Cortlandt Street Station with the Existing Complex;
    •      The Dey Street Access Building at the south corner of Dey Street and Broadway. This building
           would include a stairway, escalator and ADA elevator;
    •      Improvements to the AC mezzanine that runs west below Fulton Street from and including
           William Street, in particular the proposed widening of that portion of the mezzanine lying west of
           Nassau Street;
    •      Improvements to the 23 Fulton Street Station at William Street; and
    •      The RW - E Connector below the west side of Church Street, south of Vesey Street.

The FTA and NYCT consulted with the SHPO concerning the initially proposed archaeological APE via
letter in December 2003. SHPO’s concurrence was received by letter dated February 13, 2004 (see
Appendix H). This APE was subsequently updated to include the RW - E connector listed above.




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                                                                                                                                                                                           New York City Transit

                                                                                                                                                                                       Fulton Street Transit Center
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Source: NYCE Map GIS                                        eet                                                                                                               Figure 11-2
MTA New York City Transit                                                           Fulton Street Transit Center DEIS

HISTORIC/ARCHITECTURAL RESOURCES

The APE for historic/architectural resources encompasses all locations where significant resources could
be directly or indirectly affected by the FSTC (see Figure 11-2; Historic Resources APE). The analysis
identified historic/architectural resources that are listed on or considered eligible for inclusion on the
National and State Registers.

Assessment of impacts to significant historic/architectural resources considers potential direct physical
impacts (destruction, damage, or physical alteration from construction or operation of the FSTC) and
indirect impacts. For the latter, the cultural resources analysis draws on information from other
environmental studies prepared for the DEIS to determine impacts under NEPA and adverse effects under
NHPA.

Construction of the Entry Facility would involve the deconstruction of existing buildings, specifically
buildings currently located at 194, 198, 200, 204 and 189 Broadway, so the APE includes the locations of
these buildings. The APE encompasses the Corbin Building at 192 Broadway, because it is adjacent to
buildings to be removed; it also extends west and includes the WTC site (see Figure 11-2), to address any
potential effects from construction of the RW - E Connector.

Removal of buildings and construction activities associated with the FSTC could affect adjacent buildings
that share party walls or foundations with the deconstructed buildings, have walls or foundations abutting
those buildings, or are close enough that construction-related ground vibration could damage their
foundations or structural systems. In accordance with the New York City Department of Buildings
Technical Policy and Procedure Notice No. 10/88 regarding potential construction-related damage to
historic structures, the APE includes locations of buildings contiguous to or within a lateral distance of 90
feet from the FSTC. The APE therefore encompasses approximately the locations of buildings at a
distance of 90 feet from 192 Broadway, 195 Broadway, 15 John Street, buildings flanking Dey Street
from Church to Broadway, buildings flanking Fulton Street from Broadway to William Street, buildings
flanking William Street from Ann Street to John Street, and on the northeast corner of John and William
Streets.

The geographic extent of visual impacts resulting from the introduction of new elements into an existing
historic built environment are typically linked to the extent to which the new element is visible from
various vantage points from within and outside of that environment. The proposed Entry Facility would
be up to five (5) stories high and would stand within the perimeter formed by the footprints of the
buildings now existing on the site. The APE, therefore, has been further expanded to include locations
from which the proposed FSTC and its adjacent built environment would be or could be visible. Such
locations would encompass properties on the west side of Broadway from approximately Barclay to
Cortlandt Streets, on the north side of Fulton Street east of Nassau Street and on John Street east of
Nassau Street. The built environment encompassed in views of the proposed Entry Facility would also be
included in the historic APE. This includes Broadway from approximately Barclay Street to Maiden Lane
and the south side of Fulton Street west of Nassau Street (see Figure 11-2).

The FSTC would not introduce a new land use to this area; rather, it involves the repair and enhancement
of a long-existing major public transportation facility and the building of a street-level focal point for that
facility in the form of the Entry Facility. For the purposes of this analysis, it is assumed that any land use
changes involving historic buildings that could reasonably be attributed to the FSTC would be confined to
the area heretofore described.

To place the historic APE of the FSTC in the overall context of historic resources in Lower Manhattan, a
larger secondary study area was defined. This area comprises Lower Manhattan below Chambers Street
(see Figure 11-3).



May 2004                                                                                     11.0 Cultural Resources
                                                     11-10
                                                       Tribeca West                   Tribeca East
      Approximate
      Project Location
      Study Area

Historic Resources, by Type:

     National Historic Landmark
     (see Table 11-2)                                            Tribeca                  African Burial
                                                                  South                   Grounds and
     Listed on the National or State Register of                                          the Commons
     Historic Places, Eligible for Listing on the
     National or State NYC Landmark
     (see Table 11-2)                                             Tribeca
     Historic Districts
                                                                   South
                                                                 Extension




                                                                   John Street/
                                                                   Maiden Lane




                                                                                               South
                                                                                               Street
                                                               Stone                          Seaport
                                                               Street




                                                    Fraunces
                                                     Tavern



                                                                                  ,.
                                                                                  Designated Historic Resources
                                                                                    in Secondary Study Area

Sources: Landbase, NYC DoITT; NYC DCP.                                                    Figure 11-3
MTA New York City Transit                                                           Fulton Street Transit Center DEIS

FTA and NYCT consulted with the SHPO concerning the historic APE via letter in December 2003.
SHPO’s concurrence with the initially proposed historic properties APE was received by letter dated
February 13, 2004 (see Appendix H). As preliminary planning progressed, FTA and NYCT subsequently
determined that the historic resources APE needed to be expanded to include the location of the proposed
RW - E Connector at the eastern edge of the WTC Site.

11.5 AFFECTED ENVIRONMENT
This chapter provides an overview of the Affected Environment, whereas a detailed background analysis
of cultural resource issues is presented in Appendix H.

11.5.1             PREHISTORIC CONTEXT
Three (3) major periods are commonly used to describe the prehistoric cultures of New York:
Paleoindian; Archaic; and Woodland. The Paleoindian period dates from approximately 11,000 to 10,000
BP1 (Curran, 1996; Fiedel, 1999), and its economy may have centered on the hunting of game. Although
other economic activities, such as the gathering of plant foods or maritime resources, may have been
equally important (Jones, et al., 2002, Roosevelt, et al., 1996; Sandweis, et al., 1998), they have left little
or no trace in the archaeological record. Given the absence of known Paleoindian remains in the area, the
potential for recovering cultural resources from the study area is low.

The Archaic period (10,000 to 3000 BP, or 8000 to 1000 BC2) is divided into Early, Middle and Late sub-
periods, distinguished by differences in tool assemblages, projectile point types and preferred lithic
materials. Of the several Early-Archaic sites (8000 to 6000 BC) identified in the City, most are located
and now are identified in the primary study area.

The Woodland-period occupation (circa 700 BC to AD3 1500) in the City is characterized by the
introduction of ceramic technology. Several Woodland sites have been identified in the City, but only a
few sites on Manhattan have yielded Woodland period material. The end of the Woodland Period is
marked by the encounter between the indigenous Native American population occupying the metropolitan
region and European explorers. Evidence of this interaction between the native population and the
European explorers has been documented archaeologically in Staten Island (Skinner, 1909), the Bronx
(Skinner, 1919), and Manhattan (Skinner, 1920).

The principal Native American group in the area, the Munsee, had a settlement in Lower Manhattan just
north of New Amsterdam in proximity to the Collect and Little Collect, spring-fed freshwater ponds
located in what is now Foley Square (Geismar, 1993; Harris, et al., 1993). The area of City Hall Park
would have been a desirable location for Native American settlement as it was comparatively level and
close to the freshwater ponds, as well as swampland and the East River. Valentine (1856:426) noted that
the location of City Hall marked the former site of “a large Indian village.”

By the time of permanent Dutch settlement at Lower Manhattan in 1623, the Munsee way of life was
forever changed through the introduction of European items, including guns, metal, alcohol and glass.

11.5.2             HISTORIC CONTEXT
Europeans probably first set foot on Manhattan during Henry Hudson’s 1609 voyage up the river that
now bears his name (Burrows and Wallace 1999:15). Following Hudson’s travels in the New York City
area, Adriaen Block, sailing for the New Netherland Company, made four (4) trips to Manhattan. On the
fourth trip in 1613-14, his ship, the Tyjger, burned where it rested on the western shore of Manhattan. In
1
  BP = Before Present, taken as before 1950
2
  BC = Before Christ
3
  AD = Anno Domini

May 2004                                                                                     11.0 Cultural Resources
                                                     11-12
MTA New York City Transit                                                          Fulton Street Transit Center DEIS

1916, during construction of the IRT subway at the intersection of Dey and Greenwich streets, the charred
keelson of the Tyjger was uncovered. Although the remainder of the ship’s hull was left in place, no
further remains of the Tyjger were uncovered until the 1960s during construction of the WTC (Solecki,
1974). Block’s forced winter stay represents the first European settlement on Manhattan, with the Dutch
sailors relying on the local Munsee for food. The remains of the Tyjger represent the earliest
archaeologically documented European activity on Manhattan.

In May of 1623, the New Netherland sailed into New York Harbor with thirty Dutch families, mostly
French-speaking Walloons, representing around 120 people (Gilder, 1936). These settlers were sent by
the Dutch West India Company to create a permanent settlement to be called New Amsterdam. The New
Netherland landed at the southern shore of Manhattan, about where Greenwich Street and Battery Place
now intersect (Gilder, 1936:4), as Greenwich Street runs along what was then the western shore of
Manhattan. These colonists immediately began constructing a fort for their protection from the elements
and the local Munsee population.

These families settled at various locations in the metropolitan area, including parts of what are now Staten
Island, Brooklyn and Jersey City. This dispersed pattern was designed to strengthen the Netherland
Company’s territorial claims to the New York City area. When Peter Minuit assumed control of New
Amsterdam in 1626, he recognized the hazards of a dispersed population pattern and concentrated the
colonists on Manhattan after his famous purchase of the island from the Native American inhabitants. The
settlement on Manhattan grew slowly throughout the middle years of the 17th Century. The settlement on
Manhattan continued to be concentrated at the southern tip of the island for most of the 18th Century,
although farms and villages were located farther north. The location of the proposed FSTC was part of a
farm called the “King’s Farm”, property owned by the English crown. This farm had originally been
called the “Company’s Farm” by the Dutch, which they had set aside for use by the Company only.
When the English took over the Dutch territories in the New World, the Company’s Farm was handed
over to the Duke of York. When he ascended to the English throne, the land became known as the King’s
Farm and when Queen Anne came to power in 1702, it was known as the “Great Queen’s Farm”.
Governor Lord Cornbury granted the entire estate to the English Church of Manhattan Island in 1705
(Janvier, 1894). Eventually, this land came to be owned by a Thenius Dey, a Dutch gardener and miller
in the 18th Century (Feirstein, 2001:26). The modern Dey Street, which had also been known as “Batteau
Street”, is named for this Dutch gardener (Stokes 1915:997).

After the Civil War, various factors (in particular rapid population growth, increasing industrialization,
the domestic revolution with its consequent separation of the home and the workplace and construction of
roads) led to the expansion of Manhattan. Streets had been established within the project area by the end
of the war as the remainder of the Queen’s Farm had been divided up and sold off by the English crown.
Modern Fulton Street was known as Partition Street and Church Street did not continue northward past
Cortland Street until 1867 (Greenhouse Consultants 1985:10).

11.5.3             ARCHAEOLOGICAL RESOURCES
In 2003, NYCT commissioned a Phase IA literature search to assess the potential of the archaeological
APE (Figure 11-1) to contain prehistoric or historic-period archaeological resources that, if present, could
be affected by the FSTC Build Alternatives 9 and 10 (see Appendix H). Early 19th Century maps of the
project area indicated that residential structures had been constructed in the project area, but it was not
until the mid-19th Century that maps with sufficient detail were available to ascertain the types of
structures within the archaeological APE. The Dripps 1851 map of the project area indicates that the
location of the Entry Facility is entirely occupied by structures, demonstrating that the entire footprint of
the proposed Entry Facility has been disturbed.

The proposed Dey Street Passageway is located entirely within Dey Street, an area that lacks any
indication of historic period structures and therefore lacks potential historic archaeological resources that
could be expected from such development. The proposed RW - E connection does travel through the

May 2004                                                                                    11.0 Cultural Resources
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MTA New York City Transit                                                           Fulton Street Transit Center DEIS

foundations and backyards of structures fronting on both Dey and Fulton Streets. It was not until the late
19th Century, however, that Church Street was constructed through the blocks between Fulton, Dey and
Cortlandt Streets. The construction of the RW line in the early 20th century would, nevertheless, have
destroyed any potential archaeological resources within the proposed RW - E connection. Lastly, the
Dey Street Access Building at the south corner of Dey Street at Broadway is located within the limits of
the existing structure.

Historic maps consulted from the late 19th and early 20th Centuries confirm the observations made from
the Dripps map. The extension of Church Street through Cortlandt, Dey and Fulton Streets was the next
significant change to the project area, occurring in 1867. When this occurred, a large swath of structures
was destroyed along the path of the proposed RW - E connection.

The construction of the subway lines through the project area in the early 20th Century further disturbed
the project area and destroyed any potential archaeological resources within several portions of the
archaeological APE. Specifically, the construction of the RW line would have disturbed the portion of
the archaeological APE and the 45 line would have disturbed the location for the proposed Dey Street
Access Building at the south corner of Dey Street at Broadway and the two (2) proposed staircases at the
southwest and southeast corners of Broadway and Maiden Lane, as well as the location of other minor
project elements throughout the APE (see Chapter 4: Construction Methods and Activities, for full
description of project elements).

Further disturbances to the archaeological APE have occurred throughout the 20th Century with the
installation of utilities within the street bed of Dey Street. Additionally, the archaeological potential of
the proposed Dey Street Passageway is considered to be low as there were never any historic structures
within Dey Street that might have produced the residues conducive to creating significant historic
archaeological resources, i.e., Dey Street was not located in the backyards of residential structures where
privies or cisterns could have been filled in with historic period refuse. Therefore, the presence of utilities
within Dey Street greatly diminishes its archaeological resource potential. In summary, it is considered
that the potential for historic archaeological resources within the archaeological APE is extremely low.

11.5.4             HISTORIC RESOURCES
In late 2002, NYCT commissioned National Register of Historic Places evaluation reports for those
buildings (numbering eight (8)) on or immediately adjacent to lots that might be acquired by NYCT for
construction of the FSTC. These reports, prepared by consultant Mary Dierckx, were submitted to SHPO
in October 2002.

NYCT also compiled information about historic architectural resources in the APE and the secondary
study area that are on record at the SHPO and LPC. These included: resources listed in or formally
determined eligible for inclusion in the National Register of Historic Places; resources that have been
designated City Landmarks or that are under consideration for this designation; and resources that have
not yet been formally evaluated but have been identified by knowledgeable persons or groups (e.g.,
Lower Manhattan Cultural Council; Lower Manhattan Emergency Preservation Fund; Historic District
Council) as being of potential architectural or historical importance.

NYCT employed the public notice and scoping activities of the NEPA process related to this DEIS to
solicit views and comments from the community at large. Among these activities was a public scoping
meeting held in New York City on April 29, 2003. FTA and NYCT also met with SHPO staff to discuss
the FSTC and its potential effects on September 22 and October 9, 2003. By letter dated September 26,
2003, the SHPO provided its opinion that the Corbin Building and the John Street-Maiden Lane Historic
District are eligible for inclusion in the National Register of Historic Places (see Appendix H). The
Corbin Building has since been listed on the National Register.



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MTA New York City Transit                                                                 Fulton Street Transit Center DEIS

Table 11-2 catalogues National Historic Landmarks, State/National Register-listed historic districts and
buildings, and State/National Register-eligible historic districts and buildings4. The following identified
historic resources5 are located within the APE:

Corbin Building, 192 Broadway. National Register-listed. This eight (8)-story 1888 office building was
designed by Francis H. Kimball at the behest of Long Island Railroad president Austin Corbin. The
building features a brick, stone and terra cotta polychromy exterior and its interior vaulted ceilings
employ a Guastavino tile system. The building is significant for its association with Kimball and Corbin
and as a proto-skyscraper and a rare surviving example of its type.

Fulton Street IRT 45 Station, Fulton Street at Broadway. National Register-eligible and a New York
City Landmark. The Fulton Street Station is part of the Lexington Avenue IRT line and was built under
New York City’s second subway construction contract, which extended the line south from City Hall into
Brooklyn. The station was designed by Heins and LaFarge and features faience reliefs of the Clermont,
Robert Fulton’s steamboat. The Clermont was the first steamboat successfully put into use and its maiden
voyage was between New York and Albany on the Hudson River. The walls adjacent to the platforms,
encompassing the glazed and mosaic tile, faience and terra cotta plaques and moldings and marble
wainscoting, are included in the designation.

Former AT&T Building, 195 Broadway. National Register-eligible. Also known as the Kalikow
Building, the 25-story neoclassical office building was designed by William Welles Bosworth and
constructed 1912-1913, with additional work between 1921 and 1924. Bronze panels by New York
sculptor Paul Manship, best known for his classically and mythologically-inspired work, top the entrances
fronting on Broadway. The building is clad in Vermont granite and features colonnades and a tower
surmounted by a stepped crown patterned after that on the Mausoleum of Halicarnassus. The building
was the first home of the AT&T Company.

Former East River Savings Bank Building, between Dey and Cortlandt Streets at Church Street.
National Register-eligible. This monumentally-scaled bank building was constructed in 1933-34 from
designs by the architectural firm of Walker & Gillette. Clad with Alabama limestone, the building
features identical entrances on Dey and Cortlandt Streets. Each entrance consists of a rounded niche
filled with a monumental architrave of grey Quincy granite capped by a round seal flanked by stylized
eagles and incised with the name of the institution. The extremely large rectangular windows illuminate
an imposing banking hall stretching the full length of the building that is finished with a variety of
colored marbles and a mural of the former East River by artist Dale Stetson.

Bennett Building, 139 Fulton Street. National Register-eligible and a New York City Landmark.
Originally built in 1872-73, this building was enlarged to 10 stories between 1892 and 1894. With 10-
story cast iron façades that face Fulton, Nassau, and Ann Streets, it is believed to be the tallest cast iron
building ever erected. It was commissioned as a real estate investment by James Gordon Bennett, Jr.,
publisher of the New York Herald newspaper. When originally erected, it was a seven (7)-story French
Second Empire structure, designed by Arthur D. Gilman. The original mansard roof was removed and
four (4) stories were added in 1892-93 in a design by James M. Farnsworth that replicated the original
castings. In 1894, Farnsworth designed a 25-foot-wide section on Ann Street.

John Street-Maiden Lane Historic District. National Register-eligible. Approximately bounded by John
and Fulton Streets to the north, Liberty Street to the south, Broadway to the west and Dutch and Nassau
Streets to the east (see Figure 11-3). SHPO (September 2003) confirmed that the boundary of this district

4
    National Historic Landmarks are considered listed in the National and New York State Registers of Historic
    Places. Properties that are listed on or eligible for listing on the National Register of Historic Places are also
    considered listed on or eligible to be listed on the New York State Register of Historic Places.
5
    This includes National Historic Landmarks and State/National Register-listed or -eligible resources. If a building
    is also a New York City Landmark, it is so noted.

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                                                             Table 11-2 Fulton Street Transit Center
                                            Designated Federal and State Historic Resources in the Secondary Study Area



                                                                           STREET                                                                         SR/NR-        SR/NR-
                                   NAME                                                              STREET/ LOCATION                    NHL (1)
                                                                           NUMBER                                                                       LISTED (2)    ELIGIBLE (3)
       Historic Districts
                                                                                          Below Worth Street and bounded by
  1    African Burial Grounds and the Commons Historic District                                                                              X                X
                                                                                          Broadway, Duane Street, and Park Row
                                                                                          Between Pearl, Water and Broad Streets
  2    Fraunces Tavern Block Historic District                                                                                                                X
                                                                                          and Coentities Slip
                                                                                          Roughly bounded by Fulton Street to the
                                                                                          north, Liberty Street to the south,
  3    John Street-Maiden Lane Historic District                                                                                                                           X
                                                                                          Broadway to the west and Dutch and
                                                                                          Nassau Streets to the east
                                                                                          Bounded roughly by Fletcher, Front, Water
  4    South Street Seaport Historic District                                             Pearl and South Streets and the East River                          X
                                                                                          and the Brooklyn Bridge
                                                                                          Bounded by Stone, Pearl, South and
  5    Stone Street Historic District                                                                                                                         X
                                                                                          William Streets and William Lane
                                                                                          Warren Street, connecting with existing
  6    Tribeca South Historic District Extension                                          Tribeca South Historic District and                                              X
                                                                                          encompassing 41-56 Warren Street
       Buildings
  1    St. Peter's School                                                      16         Barclay Street                                                                   X
  2    St. Peter's Roman Catholic Church                                       22         Barclay Street                                                      X
  3    Castle Clinton                                                                     Battery Park                                                        X
  8    Delmonico's                                                             56         Beaver Street                                                       X
 16    United States Customs House                                                        Bowling Green                                      X                X

 17    New York Stock Exchange                                                8-18        Broad Street (a.k.a. 11 Wall Street Court)         X                X

 18    Broad Exchange Building                                                 25         Broad Street                                                        X
 23    American Bank Note Company                                              70         Broad Street                                                        X
       International Mercantile Marine Company Building/U.S. Lines
 27                                                                            1          Broadway                                                       X (SR) (4)
       Building
 28    Bowling Green Building                                                  11         Broadway                                                            X
 29    Cunard Building                                                         25         Broadway                                                            X
 30    Standard Oil Building                                                   26         Broadway                                                            X
 37    American Express Company                                                65         Broadway                                                            X
 38    Empire Building                                                         71         Broadway                                                            X
 39    American Surety Building                                               100         Broadway                                                            X
 40    Trinity Building                                                       111         Broadway                                                        X (SR)(5)        X
 41    U.S. Realty Building                                                   115         Broadway                                                            X
 42    Equitable Building                                                     120         Broadway                                           X                X
 47    Corbin Building                                                        192         Broadway (a.k.a. 11 John Street)                                    X
 48    AT&T Building                                                          195         Broadway                                                                         X
 53    Woolworth Building                                                     233         Broadway                                           X
 59    St. Paul's Chapel and Graveyard                                                    Broadway at Fulton Street                          X
 60    Trinity Church and Graveyard                                                       Broadway at Wall Street                            X                X
 61    Benett Building                                                        139         Fulton Street                                                                    X
       U.S. Post Office & Federal Office Building/Church Street
 77                                                                            90         Church Street                                                       X
       Station
 85    City Bank-Farmers Trust Company                                         20         Exchange Place                                                      X
 121 Hanover Bank/India House                                                  1          Hanover Square                                                      X
                                                                                          Hudson River at West Street and Battery
 123 Pier A                                                                                                                                                   X
                                                                                          Street
 131 John Street Methodist Church                                              44         John Street                                                         X
 138 Insurance Company of North America                                        99         John Street                                                         X
 143 Liberty Tower                                                             55         Liberty Street                                                      X
 144 Chamber of Commerce of the State of New York                              65         Liberty Street                                     X                X
 180 First Precinct Police Station                                            100         Old Slip                                                            X
 182                                                                           23         Park Place                                                                       X
 183                                                                           25         Park Place                                                                       X
 184 Dodge Building                                                            53         Park Place                                                                       X
 195 56-58 Pine Street Building                                              56-58        Pine Street                                                         X
 196 The Downtown Association Building                                         60         Pine Street                                                         X
 200 Battery Maritime Building                                                 11         South Street                                                        X
 201 James Watson House                                                        7          State Street                                                        X
 207 American Stock Exchange/New York Curb Exchange                          78-86        Trinity Place                                      X                X
 208 New York County Lawyer's Association                                      14         Vesey Street                                                        X
 209 Old New York Evening Post Building                                        20         Vesey Street                                                        X
 215 J.P. Morgan & Co.                                                         23         Wall Street                                                         X
 216 Federal Hall National Memorial                                            28         Wall Street                                                         X
 219 Manhattan Company Building                                                40         Wall Street                                                         X
 220 Bank of New York and Trust Company                                        48         Wall Street                                                         X
 266 The Little Woolworth Building                                             90         West Street                                                         X
       Other Resources
 267 World Trade Center Site                                                              Church Street                                                       X


S/R = State Register of Historic Places N/R = National Register of Historic Places NHL = National Historic Landmark
Notes 1. NHLs are automatically considered listed in the National and New York State Registers of Historic Places.
        2. Properties listed in the National Register are listed in the State Register automatically.
        3. Properties determined eligible for inclusion in the National Register are considered eligible for inclusion in the State Register.
        4. International Mercantile Marine Company Building (27) is listed in the State Register; no determination has been made on National Register eligibility.
        5. Trinity Building (40) is listed in the State Register, and has been determined eligible for the National Register.
MTA New York City Transit                                                           Fulton Street Transit Center DEIS

includes the Corbin Building at 192 Broadway (National Register-eligible), and other non-designated
historic buildings such as the Dennison Building at 15 John Street, and excludes the buildings fronting
Broadway to the north, the Girard Building at 194 Broadway, and 198 Broadway. The district is
significant as an area of late-19th and early-20th century skyscraper office buildings. Most of the
buildings pre-date the 1916 Zoning Resolution that established setback requirements and represent
experimental forms in early skyscraper design. The buildings were built speculatively based on their
proximity to Wall Street, and many originally housed aspects of the jewelry industry.

St. Paul’s Chapel and Graveyard, Broadway at Fulton Street. A National Historic Landmark and a New
York City Landmark. One of a handful of pre-Revolutionary War buildings still standing in Lower
Manhattan, St. Paul’s Chapel was built 1764-1766 and designed by Thomas McBean. The building is
constructed of rough-faced schist with a brownstone trim. A five (5)-story tower designed by James C.
Lawrence was added in 1794. French architect Pierre L’Enfant, best known as the author of the city plan
for Washington, D.C., designed much of the ornate, classical interior. A graveyard surrounds the chapel
on three (3) sides. St. Paul’s was constructed as a chapel-of-ease for Trinity Church parishioners who
lived too far away to attend services at the mother church and is New York City’s oldest public building
in continuous use and only remaining colonial-era church.

WTC Site, bounded by West, Liberty, Church and Vesey Streets. National Register-eligible. This
approximately 16-acre site is significant for its association with the events of September 11, which caused
the death of what is currently estimated to have been nearly 2,800 people from the collapse of the two (2)
110-story towers of the WTC. The site as it exists today is the result of the massive search, rescue and
recovery efforts that concluded with the New York City’s return of the site to PANYNJ control and the
subsequent revival of public transit services on the 19 subway and PATH in temporary facilities on the
site.

11.6 ENVIRONMENTAL IMPACTS
11.6.1             INTRODUCTION
The assessment of potential impacts assumes that the FSTC would comply with applicable Federal, State
and other regulations concerning the protection of cultural resources.

Potential effects on cultural resources can be either physical or contextual. Direct physical effects can
occur as a result of removal, damage or alteration of an archaeological or historic resource. Contextual
effects can arise when the setting of a resource is altered as a result of the introduction of visual, audible,
or atmospheric effects which adversely affect the resource and its setting.

11.6.2             PRE-SEPTEMBER 11 REFERENCE CONDITION
For the purposes of the analysis, the existing conditions in 2003 in the project study area with respect to
cultural resources were considered to be representative of conditions that existed prior to the events of
September 11 (see Chapter 2: Analysis Framework). The events of September 11 were not considered to
have significantly affected cultural resources in the study area as they relate to the environmental review
of the FSTC, with the exception of the WTC site, which is now deemed eligible for the National Register.
Therefore, for cultural resources, the future conditions with and without the FSTC were assessed against
existing 2003 conditions, projected forward to each of the three (3) analysis years.




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MTA New York City Transit                                                         Fulton Street Transit Center DEIS


11.6.3             ANALYSIS YEAR 2005/2006 (CONSTRUCTION)
ARCHAEOLOGICAL RESOURCES

As a result of modern urban construction activities or lack of historic period occupation, intact
archaeological deposits or features are unlikely to be encountered in the areas of proposed construction
and ground disturbance within the archaeological APE. This analysis, therefore, concludes that neither
the No Action nor either of the Build Alternatives would affect any archaeological resources.

HISTORIC RESOURCES

No Action Alternative

Under the No Action Alternative in 2005/2006, the character of historic resources in the historic resources
APE would remain unchanged. As the FSTC would not be constructed, the Corbin Building would
remain in private ownership.

Alternative 9

Corbin Building

Under Alternative 9, the Corbin Building would not be structurally and functionally associated with the
Entry Facility except for possible retention of existing entranceways and easements that may be required
during construction. Construction of the Entry Facility requires a slurry wall on the northern property line
of the Corbin Building, which would not affect the structural integrity or historic features of the Corbin
Building.

Depending on the findings of the geotechnical and structural investigations that would be carried out
during Final Design, Alternative 9 may require underpinning of the Corbin Building. This will be
determined based on whether or not there is a risk of excessive movement of the Corbin Building during
the construction of the Entry Facility. Such a risk could have implications for the project cost and
schedule and would necessitate the use of underpinning or a similar protective technique, such as
compensation grouting. Based on information available to date, NYCT would proceed with underpinning
of the Corbin Building in Alternative 9, to avoid risks related to public safety and damage to the historic
resources associated with unknown construction conditions.

FTA thresholds for vibration impacts are 0.20 inch/sec. for fragile buildings and 0.12 for extremely
fragile buildings. For the purposes of the analysis, the historic buildings in the study area are assumed to
be fragile buildings. The FTA threshold for fragile buildings would potentially be exceeded for the
Corbin Building. This could occur during the deconstruction of adjacent buildings, if improperly
performed, during the installation of slurry walls or secant piles for the Dey Street Passageway and the
Entry Facility. Such damage could constitute an adverse effect to this historic building due to loss or
diminution of characteristics of design, materials, or workmanship that qualify the Corbin Building for
inclusion in the National Register.

During construction, appropriate measures would be taken to avoid impacts on this building. These
mitigation and avoidance strategies would be detailed in the MOA and CEPP, and are described further in
Section 11.7 and in Appendix H.

Implementation of Alternative 9 would not be anticipated to cause an adverse effect on the Corbin
Building as it is assumed that construction would be designed and implemented to be consistent with the
Secretary of the Interior’s standards for treatment of historic properties (36 C.F.R. 68) and applicable
guidelines. This would be determined through ongoing consultation carried out with SHPO and other
appropriate agencies during the environmental review process and would be reflected in the MOA.

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Construction of Alternative 9 could affect the Corbin Building as a result of the following:

    •      Construction activities associated with the Entry Facility immediately adjacent to the Corbin
           Building;
    •      Temporary displacement of tenants in the basement of the Corbin Building; and,
    •      Construction activities associated with the Dey Street Access Building, Dey Street Passageway
           and other project elements in the vicinity of the Corbin Building.

The foundations of the Corbin Building could also be affected by subsurface excavation and construction
that could make adjacent soils or structures unstable, thereby constituting adverse effect on such historic
properties. During construction, appropriate measures would be taken to avoid impacts on these buildings.
These mitigation and avoidance strategies would be detailed in the MOA and CEPP, and are described
further in Section 11.7.

Other Historic Resources in the APE

Under Alternative 9, adverse construction effects on other historic resources in the APE would be limited.
This alternative would require extensive below-ground excavation and construction, including but not
necessarily limited to excavations for the new Dey Street Passageway and widening of the AC
mezzanine; and demolition, excavation and foundation work for the new Entry Facility building and the
new Dey Street Access Building.

Building construction noise levels at 195 Broadway and in those areas of the John Street-Maiden Lane
Historic District adjacent to the project are anticipated to rise above FTA threshold criteria during
construction. These elevated noise levels, however, would not alter or diminish any characteristics that
qualify these resources for inclusion in the National Register.

Construction-induced ground vibration, if not managed appropriately, could potentially damage building
foundations or structural systems, resulting in diminution of the buildings’ integrity with respect to
materials and workmanship. FTA thresholds for vibration impacts are 0.20 inch/sec. for fragile buildings
and 0.12 for extremely fragile buildings. For the purposes of the analysis, the historic buildings in the
study area are assumed to be fragile buildings. The FTA threshold for fragile buildings would potentially
be exceeded at the former East River Savings Bank Building, the Bennett Building at 139 Fulton Street
and the AT&T Building at 195 Broadway. This could occur during the deconstruction of adjacent
buildings, if improperly performed, during the installation of slurry walls or secant piles for the Dey
Street Passageway and the Entry Facility. Damage associated with vibration impacts could constitute an
adverse effect to these historic buildings and on the John Street-Maiden Lane Historic District, of which
they form part, due to loss or diminution of characteristics of design, materials, or workmanship that
qualify the buildings for inclusion on the National Register.

The foundations of the Corbin Building, St. Paul’s Chapel and Graveyard, the Bennett Building, and
those of buildings in the proposed historic district located on Fulton Street west of Nassau Street, could
also be affected by subsurface excavation and construction that could make adjacent soils or structures
unstable, thereby constituting adverse effect on such historic properties. During construction, appropriate
measures would be taken to avoid impacts on these buildings. These mitigation and avoidance strategies
would be detailed in the MOA and CEPP, and are described further in Section 11.6.

The Entry Facility and Dey Street Access Building would introduce new architectural elements into the
existing setting of the John Street-Maiden Lane Historic District, in the vicinity of the Corbin Building,
the AT&T Building, the Bennett Building and, potentially, St. Paul’s Chapel and Graveyard. The
alteration to the existing setting of the historic district would involve the removal of several buildings that
lack historic or architectural significance, lack integrity, or both. The new buildings’ respective scale and
massing would be consistent with those of the structures they replace and with the surrounding built
environment, which includes: non-historic as well as historic buildings; stone and brick masonry facades

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as well as contemporary face brick, metal and glass facades and building heights from two (2) to 20
stories. The design approach for the new Entry Facility and Dey Street Access Building is, and would
continue to be, receptive to and committed to achieving a design that respects the historic properties
around it. The FSTC would not introduce, in the form of the new Entry Facility and Dey Street Access
Building, visual elements that would diminish the integrity of these properties’ significant historic
features. There would therefore be no adverse visual effects on historic properties.

Fulton Street 45 Station:

As part of Alternative 9, the following modifications would be made to the Fulton Street 45 Station:

    •      Closure of the north underpass to the AC;
    •      Relocation of the wall behind the control booth at the Dey Street entrance and the stairs at the
           south side of Dey Street to an access building;
    •      Closure of the existing John Street entrance;
    •      Creation of openings in the existing northbound platform wall at the north and south ends of the
           platform; and,
    •      Creation of openings within the existing southbound platform wall between the Fulton and Dey
           Street entrances.

These improvements would affect the National Register-eligible Fulton Street 45 Station as a result of
changes to the existing historic fabric of the station, in particular the tiled and marble wainscoted walls
adjacent to the platforms. Creation of new wall openings would involve the removal of sections of
existing plain tile and wainscoting; however, the associated marble column facings, frieze and terracotta
elements at these locations would be retained in place. New walls adjacent to historic walls would have
treatments in keeping with the surrounding historic decorative treatments. These actions would have
adverse effects. These effects will be minimized and mitigated as described in the MOA (see Appendix
H) and the actions will be undertaken in a manner consistent with the Secretary of the Interior’s Standards
for Treatment of Historic Properties. This would minimize and mitigate impacts on the characteristics of
design, materials and ornamentation that qualify the station for inclusion on the National Register.

AT&T Building

Construction of a new set of escalators and stairs linking the new Entry Facility with the southbound
45 Fulton Street Station platform would require space within and access to portions of three (3)
basement levels in the former AT&T Building at 195 Broadway. Construction would involve partial
removal of floor framing in basements A and B and reinforcement of remaining floor framing in those
basements; it would also require underpinning of one façade column and partial removal of steel grillages
from two (2) adjacent columns.

These construction activities do not involve any purposeful alteration of any of the exterior architectural,
design or structural characteristics that may qualify this building for inclusion in the National Register.
However, if improperly performed, construction activities could potentially affect the portion of the
façade associated with the column to be underpinned and/or the building’s structural stability and thus
affect the building’s historic integrity, thereby resulting in adverse effects to the AT&T Building. During
construction, all appropriate and practicable precautions would be taken to avoid impacts on this property.
These would be detailed in the MOA and CEPP, and are described further in Section 11.7.

WTC Site

Construction of the RW - E connector would require realignment or removal of a portion of a concrete
foundation wall that separates the Church Street station from the WTC site. This wall is a remnant of the
former H&M railroad facilities that ultimately became PATH in association with construction of the

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WTC. While realignment or removal of a portion of this wall would constitute a physical change in this
element of the historic site, it would not diminish the characteristics of location, setting, feeling, materials,
and association that qualify the WTC Site for inclusion on the National Register.

Alternative 10

Corbin Building

Under Alternative 10, the Corbin Building would be acquired by MTA and would be structurally and
functionally integrated into the FSTC Entry Facility. This integration would be achieved by the
underpinning of the Corbin Building (see Chapter 4: Construction Methods and Activities for full
description), construction of a temporary structural support for the façade of the Corbin Building and the
eventual physical integration of the ground floor and second floor of the Corbin Building with the Entry
Facility (see Chapter 3: Alternatives, for full description). It is intended that the Corbin Building would be
integrated into the Entry Facility in a way that is both functionally and visually compatible with the
historic character of the building itself and its role in the John Street-Maiden Lane Historic District.

At this point in the conceptual design, the methods by which the Corbin Building’s basement and ground
floor areas would be integrated into the Entry Facility have not yet been determined. It is likely, however,
that portions of some basement and upper story walls may need to be modified to incorporate new
connecting access routes. As the FSTC basement is proposed to be located almost 20 feet deeper than the
existing basement level of the Corbin Building, underpinning would be needed to provide temporary
construction support and permanent foundations once the Building is integrated into the Entry Facility.
This would require a 20-foot deep excavation beneath the Corbin Building.

The incorporation of the Corbin Building into the Entry Facility would require substantial alterations to
the existing structure of the Corbin Building. These alterations would be large new openings in the north
wall of the Corbin Building, which could cause structural members in the existing Corbin Building to be
overstressed, triggering a seismic upgrade incompliance with relevant State and City codes. The upgrade
will consist of strengthening the building lateral load system and floor diaphragms.

In certain locations, removal of portions of floors or of exterior walls may be beneficial to the new use to
accommodate the movement of the public through the Entry Facility to the various levels of the new
building. Rehabilitation and code compliance upgrading for other NYCT uses (e.g. office support) or
other suitable business tenants may also require the alteration of existing historic features.

Construction of the FSTC would affect the Corbin Building as a result of the following:

    •      Adaptive reuse of the Corbin Building within the FSTC Entry Facility (see Chapter 3:
           Alternatives and Chapter 4: Construction Methods and Activities, for full description);
    •      Location of the Entry Facility immediately adjacent to the Corbin Building; and,
    •      Construction activities associated with the Dey Street Access Building, Dey Street Passageway
           and other project elements in the vicinity of the Corbin Building.

FTA thresholds for vibration impacts are 0.20 inch/sec. for fragile buildings and 0.12 for extremely
fragile buildings. For the purposes of the analysis, the historic buildings in the study area are assumed to
be fragile buildings. The FTA threshold for fragile buildings would potentially be exceeded for the
Corbin Building. This would occur during the deconstruction of adjacent buildings, if improperly
performed, during the installation of slurry walls or secant piles for the Dey Street Passageway and the
Entry Facility. Such damage would constitute an adverse effect to this historic building due to loss or
diminution of characteristics of design, materials, or workmanship that qualify the Corbin Building for
inclusion in the National Register.



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The foundations of the Corbin Building would also be affected by subsurface excavation and construction
that could make adjacent soils or structures unstable, thereby constituting adverse effects on such historic
properties. During construction, appropriate measures would be taken to avoid impacts on these buildings.
These mitigation and avoidance strategies would be detailed in the MOA and CEPP, and are described
further in Section 11.7.

Other Historic Resources in the APE

Under Alternative 10, adverse construction effects on other historic resources in the APE would be
limited. This alternative would require extensive below-ground excavation and construction, including
but not necessarily limited to excavations for the new Dey Street Passageway and widening of the AC
mezzanine; and demolition, excavation and foundation work for the new Entry Facility building and the
new Dey Street Access Building.

Construction-induced ground vibration, if not managed appropriately, could potentially damage building
foundations or structural systems, resulting in diminution of the buildings’ integrity with respect to
materials and workmanship. FTA thresholds for vibration impacts are 0.20 inch/sec. for fragile buildings
and 0.12 for extremely fragile buildings. For the purposes of the analysis, the historic buildings in the
study area are assumed to be fragile buildings. The FTA threshold for fragile buildings would potentially
be exceeded at the former East River Savings Bank Building, the Bennett Building and the AT&T
Building. This could occur during the deconstruction of adjacent buildings, if improperly performed,
during the installation of slurry walls or secant piles for the Dey Street Passageway and the Entry Facility.
Such damage would constitute an adverse effect to these historic buildings and on the John Street-Maiden
Lane Historic District, of which they form part, due to loss or diminution of characteristics of design,
materials, or workmanship that qualify the buildings for inclusion on the National Register.

The foundations of St. Paul’s Chapel and Graveyard, the Bennett Building and those of buildings in the
proposed historic district located on Fulton Street west of Nassau Street, could also be affected by
subsurface excavation and construction that could make adjacent soils or structures unstable, thereby
constituting adverse effects on such historic properties. During construction, appropriate measures would
be taken to avoid impacts on these buildings. These mitigation and avoidance strategies would be detailed
in the MOA and CEPP, and are described further in Section 11.7.

The Entry Facility and Dey Street Access Building would introduce new architectural elements into the
existing setting of the John Street-Maiden Lane Historic District, in the vicinity of the Corbin Building,
the AT&T Building, the Bennett Building and, potentially, St. Paul’s Chapel and Graveyard. The
alteration to the existing setting of the historic district would involve the removal of several buildings that
lack historic or architectural significance, lack integrity, or both. The new buildings’ respective scale and
massing would be consistent with those of the structures they replace and with the surrounding built
environment, which includes: non-historic as well as historic buildings; stone and brick masonry facades
as well as contemporary face brick, metal and glass facades and building heights from two (2) to 20
stories. The design approach for the new Entry Facility and Dey Street Access Building is, and would
continue to be, receptive to and committed to achieving a design that respects the historic properties
around it. The FSTC would not introduce, in the form of the new Entry Facility and Dey Street Access
Building, visual elements that would diminish the integrity of these properties’ significant historic
features. There would therefore be no adverse visual effects on historic properties.

Fulton Street 45 Station:

Under this alternative, the following modifications would be made to the Fulton Street Station:

    •      Closure of the north underpass to the AC;
    •      Relocation of the wall behind the control booth at the Dey Street entrance and the stairs at the
           south side of Dey Street to an access building;

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    •      Closure of the existing John Street entrance;
    •      Creation of openings in the existing northbound platform wall at the north and south ends of the
           platform; and,
    •      Creation of openings within the existing southbound platform wall between the Fulton Street and
           Dey Street entrances.

These improvements would affect the National Register-eligible Fulton Street 45 Station as a result of
changes to the existing historic fabric of the station, in particular the tiled and marble wainscoted walls
adjacent to the platforms. Creation of new wall openings would involve the removal of sections of
existing plain tile and wainscoting; however, the associated marble column facings, frieze and terracotta
elements at these locations would be retained in place. New walls adjacent to historic walls would have
treatments in keeping with the surrounding historic decorative treatments. These actions would have
adverse effects. These effects will be minimized and mitigated as described in the MOA (see Appendix
H) and the actions will be undertaken in a manner consistent with the Secretary of the Interior’s Standards
for Treatment of Historic Properties. This would minimize and mitigate impacts on the characteristics of
design, materials and ornamentation that qualify the station for inclusion on the National Register.

AT&T Building

Construction of a new set of escalators and stairs linking the new Entry Facility with the southbound
45 Fulton Street Station platform would require space within and access to portions of three (3)
basement levels in the AT&T Building at 195 Broadway. Construction would involve partial removal of
floor framing in basements A and B and reinforcement of remaining floor framing in those basements; it
would also require underpinning of one (1) façade column and partial removal of steel grillages from two
(2) adjacent columns.

These construction activities do not involve any purposeful alteration of any of the exterior architectural,
design or structural characteristics that may qualify this building for inclusion in the National Register.
However, if improperly performed, construction activities could potentially affect the portion of the
façade associated with the column to be underpinned and/or the building’s structural stability and thus
affect the building’s historic integrity, thereby resulting in adverse effects to the AT&T Building. During
construction, appropriate measures would be taken to avoid impacts on this property. These would be
detailed in the MOA and CEPP, and are described further in Section 11.8.

Building construction noise levels at the AT&T Building and in those areas of the John Street-Maiden
Lane Historic District adjacent to the project are anticipated to rise above FTA threshold criteria during
construction. These elevated noise levels, however, will not alter or diminish any characteristics that
qualify these resources for inclusion on the National Register.

Dennison Building

The Dennison Building at 15 John Street, although not eligible for the National Register as an individual
resource, is a contributing element to the John Street-Maiden Lane Historic District. Under Alternative
10, this building may require underpinning. It is not anticipated that this would result in any adverse
effects on this building, or on the characteristics that qualify it for inclusion as a contributing element in
the Historic District. It is also not anticipated that this would result in any adverse impacts on the Historic
District itself.

WTC Site

Construction of the RW - E connector would require realignment or removal of a portion of a concrete
foundation wall that separates the Church Street station from the WTC site. This wall is a remnant of the
former H&M railroad facilities that ultimately became PATH in association with construction of the
WTC. While realignment or removal of a portion of this wall would constitute a physical change in this

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element of the historic site, it would not diminish the characteristics of location, setting, feeling, materials,
and association with the events of September 11 that qualify the WTC site for inclusion on the National
Register.

11.6.4             ANALYSIS YEAR 2008 (INITIAL OPERATION)
ARCHAEOLOGICAL RESOURCES

As a result of modern urban construction activities or lack of historic period occupation, intact
archaeological deposits or features are unlikely to be encountered in the areas of proposed construction
and ground disturbance within the archaeological APE. This analysis, therefore, concludes that neither
Alternative 9 nor Alternative 10 would affect any archaeological resources during operation of the FSTC.

HISTORIC RESOURCES

No Action Alternative

Under this alternative, the FSTC would not be constructed or operational in 2008 and the character of
historic resources in the APE would remain unchanged. As the FSTC would not be constructed, there
would be no effect on the Corbin Building under this alternative.

Alternative 9

Under this alternative, the FSTC would be operational in 2008. The Corbin Building would not be
acquired by the Metropolitan Transportation Authority (MTA) and would remain in private ownership.
During operations, the FSTC would not have any adverse effects on historic resources in the APE.
Underpinning or similar support at this time is assumed to be necessary by NYCT to manage the risks to
public safety and the historic resource resulting from uncertain construction conditions associated with
the Corbin Building. Underpinning piles remaining permanently in place beneath the Corbin Building
would not be expected to have any adverse effects on the Corbin Building.

Alternative 10

Under this alternative, the FSTC would be operational in 2008. As a result of acquisition of the Corbin
Building by MTA, its historic character would be protected by applicable regulations and standards. Any
structural upgrades and other measures to maintain the building in code compliance would therefore have
been implemented in accordance with applicable preservation requirements, which would reduce impacts
on the building’s historic characteristics, including those associated with its location within the John
Street-Maiden Lane Historic District. In addition, measures undertaken during construction of the Entry
Facility to preserve the Corbin Building’s historic character and integrate it with the Entry Facility would
have provided the building with permanent safeguards for historic preservation, such as:

    •      Repointing of masonry;
    •      Cleaning of the façade;
    •      Replacement of worn/defective windows; and,
    •      Installation of new appropriate and historically compliant storefronts.

As a result, the Corbin Building would have experienced an adaptive reuse enabling it to function as a
publicly accessible building with improved opportunity by the public and the community to experience its
historic character and new role in the transit system. No other impacts on historic resources in the APE
would be caused as a result of operation of the FSTC.




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11.6.5             ANALYSIS YEAR 2025 (FULL OPERATION)
ARCHAEOLOGICAL RESOURCES

As a result of modern urban construction activities or lack of historic period occupation, intact
archaeological deposits or features are unlikely to be encountered in the areas of proposed construction
and ground disturbance within the archaeological APE. This analysis, therefore, concludes that neither
Alternative 9 nor Alternative 10 would affect any archaeological resources during operation of the FSTC.

HISTORIC RESOURCES

No Action Alternative

Under this alternative, the FSTC would not be constructed or operational in 2025. The character of
historic resources in the APE would remain unchanged. As the FSTC would not be constructed, the
Corbin Building would not be affected.

The extent of any future exterior and interior modification to the Corbin Building during this 20-year
period cannot be predicted. Without major rehabilitation, by 2025, the exterior and interior public spaces
features of the Corbin Building will have been subject to the incremental effects of wear and aging. It is
possible that modifications to office space, public signage and repairs to public lobbies and the elevators
may take place, as such modifications have been undertaken in the past. Conversion of the Corbin
Building to other use, such as residential, would require compliance with relevant City codes.
Restrictions and requirements of LPC would apply only if the building were designated a New York City
Landmark.

Alternative 9

Under this alternative, the FSTC would be fully operational in 2025. During operations, the FSTC would
not have any adverse effects on historic resources in the APE. The Corbin Building would have been in,
it is assumed, continued private ownership during the preceding twenty years. Its maintenance and
continued use would be the responsibility of the private owner. The building would be subject to relevant
City codes, but not to any particular preservation restrictions unless the LPC designated it a New York
City Landmark.

Alternative 10

As a result of acquisition of the Corbin Building by MTA, the property would have been in public
ownership during the 20 years and its historic character, therefore, would have been protected by
applicable regulations and standards. Any structural upgrades and other measures to maintain the building
in code compliance would therefore have been implemented in accordance with applicable preservation
requirements, which would reduce impacts on the building’s historic characteristics, including those
associated with its location within the John Street-Maiden Lane Historic District. In addition, measures
undertaken during construction of the Entry Facility to preserve the Corbin Building’s historic character
and integrate it with the Entry Facility would have provided the building with permanent safeguards for
historic preservation, such as:

    •      Repointing of masonry;
    •      Cleaning of the façade;
    •      Replacement of worn/defective windows; and,
    •      Installation of new appropriate and historically compliant storefronts.

As a result, the Corbin Building over the preceding 20 years would have functioned as a publicly
accessible building with improved opportunity by the public and the community to experience its historic

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character and new role in the transit system. No other impacts on historic resources in the APE would be
caused as a result of operation of the FSTC.

11.7 SUMMARY OF ADVERSE IMPACTS AND MITIGATION
     MEASURES
FTA and NYCT have determined that the construction of the FSTC will have adverse effects on historic
properties under either Alternative 9 or Alternative 10. The FTA and NYCT, therefore, propose to
resolve adverse effects of the FSTC on historic properties through a Memorandum of Agreement (see
Appendix H). FTA and NYCT would develop and implement this MOA in consultation with the SHPO
and the Advisory Council on Historic Preservation (should it choose to participate in the consultation).
The MOA will contain specific measures by which identified impacts would be avoided, minimized or
mitigated. The MOA will also set forth the process and procedures for consultation, determination of
effect and resolution of any as yet unidentified adverse effects that would govern the planning, design and
implementation of the project from the date of the MOA’s execution.

Measures include, but may not be limited to, the following:

    •      Recordation of the Corbin Building and Fulton Street 45 station to Level II Historic American
           Buildings Survey/Historic American Engineering Record (HABS/HAER) standards prior to any
           alteration.
    •      Photorecordation of existing exterior and (with owners’ permission) interior conditions of the
           AT&T Building, Bennett Building, East River Savings Bank, Dennison Building, and Fulton
           Street portion of the John Street-Maiden Lane Historic District prior to any construction in their
           vicinity.
    •      Development and implementation of a milestone review process in which the ultimate treatment
           and use of the Corbin Building is determined through consideration of the property’s historic
           character and of the construction and operational feasibility of possible treatment and use
           alternatives;
    •      Consultation with the SHPO concerning proposed alterations to the historic 45 Fulton Street
           station; development of designs and specifications consistent with the Secretary of the Interior’s
           Standards for Rehabilitation, including appropriate re-use of historic decorative elements such as
           wall finishes, railings and other features of the street level entrances;
    •      Development and implementation of a CEPP to avoid construction impacts on potentially
           vulnerable historic buildings within 90 feet of the construction activities. Special provisions
           would be necessary for the Corbin Building and, possibly, the Dennison Building, because both
           buildings directly abut the area in which deconstruction and construction would occur and are
           physically attached to buildings that would be removed. The CEPP would include protective
           measures such as monitoring of historic buildings during construction to detect vibration or other
           physical impacts; and,
    •      In anticipation of possible modifications to the designs for the FSTC, design and implementation
           of a CRMP, including an Emergency Action Program (EAP) to address any potential
           archaeological impacts outside the current archaeological APE. This would include the
           requirement of an archaeologist certified by the RPA on the preliminary FSTC.




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