ANDREW M.

CUOMO ROSE HARVEY

Governor Commissioner

October 19, 2017

Mr. Christos Tsiamis

Remedial Project Manager Gowanus Canal Site
U.S. Environmental Protection Agency, Region 2
290 Broadway, 20th Floor
New York, NY 10007

Re: EPA
Gowanus Canal Superfund Cleanup
Gowanus Canal Area, Brooklyn, NY
16PR02427

Dear Mr. Tsiamis:

Thank you for continuing to consult with the New York State Historic Preservation Office
(SHPO). We have reviewed the provided documentation in accordance with Section 106 of the
National Historic Preservation Act of 1966. These comments are those of the SHPO and relate
only to Historic/Cultural resources. They do not include other environmental impacts to New
York State Parkland that may be involved in or near your project.

We have reviewed the Draft Environmental Impact Statement (DEIS) that was submitted to our
office on September 18th, 2017. We understand that this DEIS is being prepared by the NYC
DEP for local environmental review, and we note that we will continue to provide our comments
and participate in consultation with the understanding that EPA is the lead agency under
Section 106.

Based on our review of the project details to date, it appears feasible to retain and incorporate
the historic former Gowanus Station building (234 Butler Street) into the project. This building,
which has a prominent street presence at the corner (and very edge of) the citys preferred site,
has overarching significance for the National Register eligible Gowanus Historic District. Its
demolition would adversely affect both the building and the National Register eligible Gowanus
Canal Historic District. To destroy this intact, architecturally distinctive example of Brooklyns
civic and industrial heritage would be a disservice to the Gowanus neighborhood and to the city
as a whole.

We offer the following comments on the text of the DEIS:

1. With respect to the possible effects to archaeological resources, we restate our previous
recommendation (Brazee, 3 July 2017) that for areas that have identified potential for deeply
buried archaeological deposits, preliminary stratigraphic investigation (a geoarchaeological
study) should be undertaken to assess the nature and extent of potentially culture-bearing
deposits within the APE. The results of this investigation would provide the basis for

Division for Historic Preservation

P.O. Box 189, Waterford, New York 12188-0189 (518) 237-8643 www.nysparks.com
 determining whether further archaeological studies are needed and, if so, the most
appropriate method for such work.

2. With respect to the status of 190 Butler Street, CRIS correctly shows that the building is a
non-contributing building in the State/National Register-eligible Gowanus Canal Historic
District (see page 7-13 of Chapter 7: Historic and Cultural Resources)

3. With respect to the Alternatives chapter, SHPO is of the opinion that the demolition of
contributing buildings (including the two Nevins Street properties as well as the above-
mentioned 234 Butler) at the Head End site would adversely affect the buildings and the
Historic District. We strongly encourage the project to take a hard look at retaining and
preserving the former Gowanus Station at 234 Butler Street. It remains unclear to us why
the construction of the facility would necessitate demolition of the Gowanus Station, whose
1914 section occupies a relatively small footprint at the very northeastern corner of the site.
We find this DEIS inadequate for purposes of Section 106 consideration of alternatives, so
we request a digital copy of the NYC DEP engineering analysis referred to therein. We may
request further consideration of alternatives under 106, beyond this engineering analysis.

4. With respect to the Alternatives chapter, we agree with some of the conclusions in the
Thomas Greene Park property analysis section, however we note that increasing waterfront
access at the expense of historic resources is not a valid consideration in this instance.
Historically the Gowanus Canal was lined with the industrial buildings and infrastructure that
it was built to serve, and this continues to be its character today. Therefore, we feel that
removing historic buildings along its edge is not at all justified by furthering citywide goals of
increased public waterfront access. It is SHPOs opinion that the Park property alternative
represents the least impact to historic resources, as well as the most opportunity to satisfy a
variety of land-use requirements and public benefits, and for that reason this alternative
should be more seriously considered.

5. We have no concerns with the demolition of the Owls Head properties (122 5th Street and 22
2nd Avenue) because, as stated in our previous letter, these structures do not contribute to
the historic district.

6. We note that the properties located at the 6th Street Alternate site are contributing resources
to the S/NR eligible Gowanus Canal Historic District (141 6th Street/aka 27-31 2nd Ave), and
therefore their removal would adversely affect the buildings and the historic district

We would appreciate if the requested information could be provided via our Cultural Resource
Information System (CRIS) at www.nysparks.com/shpo/online-tools/ Once on the CRIS site, you
can log in as a guest and choose "submit" at the very top menu. Next choose "submit new
information for an existing project". You will need this project number and your e-mail address.
If you have any questions, I can be reached at (518) 268-2182.

Sincerely,

Olivia Brazee
Historic Site Restoration Coordinator
olivia.brazee@parks.ny.gov via e-mail only

CC: Brian Carr, EPA

Charles Vandrei, NYS DEC
Danielle Adams, Ecology & Environment
John Vetter, Ecology & Environment
Rasheed Lucas, NYC DEP
Gina Santucci, NYC LPC