Petition Against the Hudson River Park Neighborhood Improvement District

To the Department of Small Business Services, Local NYC & NYS Government Officials and Community Boards 1, 2 and 4:

As a business owner (commercial property owner or commercial tenant), I object to the establishment of the Hudson River Park Neighborhood Improvement District (HRP NID) on the grounds that it is an abuse of the Business Improvement District law:

• The HRP NID will not "provide for district improvements ... which will restore or promote business activity in the district", as is required by the NY BID law. The only business-related program suggested by the draft District plan is a possible online map or discount website to "jointly promote" businesses near the Park. The draft budget does not contain any line items for programs to promote businesses.

• The establishment of the HRP NID will reduce the likelihood that legitimate BIDs in the retail districts scattered throughout the HRP NID District will be established. Local businesses should be free to establish a local BID with traditional BID goals without double assessment if they desire.

• Assessments will not be made in proportion to the benefit received, as required. Businesses that do not rely on walk-in customers will pay the same as those that do. Retail businesses immediately adjacent to the Park, which may benefit from increased trade from HRP Park visitors, will be assessed comparably to retail businesses up to 1/3 mile away, which will not benefit. Commercial tenants located in commercial buildings will pay an assessment at twice the rate of commercial tenants located in residential buildings.

• The District Plan is silent as to the make-up of the DMA Board and the number of Board seats for commercial property owners and commercial tenants. The sponsors have said that residential tax lots outnumber commercial tax lots by 6:1 yet commercial properties will pay a majority of the assessment. How this disparity will be fairly reflected in the DMA Board must be solved before the establishment of the District, not by the appointed interim DMA Board.

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