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PUBLIC TESTIMONY
Testimony by Jim Wright, Representative of American Institute of Architects New York on Intro 1130
3:19:13
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3 min
Jim Wright, representing the American Institute of Architects New York, expressed strong support for Intro 1130, which aims to reduce emissions from freight delivery vehicles through an Indirect Source Rule (ISR). He emphasized the potential health and sustainability benefits of transitioning to zero-emission vehicles.
- Advocated for an all-agency approach to creating a sustainable freight network, including coordination between DEP and DCP on warehouse regulations
- Recommended applying the ISR to a broad range of warehouse facilities, not just large fulfillment centers
- Suggested a more flexible floor area threshold system starting at 25,000 square feet, tied to delivery vehicle trip volume, to capture more warehouse-related emissions
Jim Wright
3:19:13
Good afternoon, and thank you council members of the OS Holden, your staff, and other members of the committee for holding this hearing.
3:19:21
My name is Jim Wright speaking on behalf of the American Institute of Architects New York.
3:19:25
AIA New York strongly supports the need, purpose, and goals of intro 11:30 to reduce emissions from freight delivered vehicles, still mostly diesel powered medium and heavy duty trucks delivering goods to and from distribution warehouses operating in New York City.
3:19:43
The proposed indirect source rule to be administered administered by DEP is a tested and effective way to speed up the transition to zero emission vehicles By improving air quality in neighborhoods most affected by emissions, local public health outcomes will be improved.
3:20:00
And importantly, broader sustainability goals from reducing overall carbon emissions in the trans transportation sector can be advanced.
3:20:10
Our testimony today focuses on broad principles of the ISR enabling legislation by the council.
3:20:17
First, AIA New York supports an all agency approach to creating a more sustainable freight network across New York City.
3:20:25
In addition to implementing an ISR, the city is committed to address the impacts of large distribution warehouses on local residential areas with its zoning and land use tools.
3:20:38
Related to the ASR, consistent standards need to be adopted by DCP and referenced in the ISR that clarify relevant zoning use group definitions for various warehouse types and define clear criteria for floor area calculations in these buildings.
3:20:56
As DCP moves forward to develop a special permit process for new large distribution warehouses, DEP and DCP need to coordinate terminology and relevant elements of the regulations to avoid conflicts and or redundancy.
3:21:12
Second, the IRSR should apply to a broad range of warehouse facilities with high volume vehicle freight traffic.
Robert F. Holden
3:21:19
Time expired, thank you.
Alexa Avilés
3:21:22
You can complete your testimony.
Jim Wright
3:21:25
Thank you.
3:21:25
Not just the largest fulfillment centers and so called last mile distribution facilities, this could include facilities related to food deliveries from EDC's Hunts Point Food Distribution Center, food delivery services such as FreshDirect, home improvement deliveries such as Home Depot and IKEA and even construction material deliveries.
3:21:49
Lastly, the distribution warehouse floor area threshold of 50,000 square feet that would trigger the ISR seems overly rigid.
3:21:58
Extrapolating from DEP's data, existing warehouses exempting warehouses below this threshold would capture only 40% of in New York City's warehouse related vehicle emissions.
3:22:12
Alternatively, a step threshold starting at 25,000 square feet tied to delivery vehicle trip volume with increments up to a million square feet and above would capture more of these delivery vehicle emissions and give DCP, DEP more a larger arsenal of tools to regulate those emissions.
3:22:37
Incorporating these principles into enabling legislation will give DEP the flexibility to calibrate most effective set of regulations and incentives based on local data and results from other jurisdictions that have implemented their own version of an ISR.
3:22:53
Thank you for considering these recommendations.
3:22:57
We submitted our full written testimony to the council and I'm happy to answer any questions you may have.