Center for Rethinking Development at the Manhattan Institute

Power to the People!

Hope Cohen, January 2009

Thanks to the money and politics involved, building the unnoticed systems that carry people, water, and electrons is never easy. In New York—despite its heritage as the hometown of electrical distribution—substations confront the additional obstacle of the city's 1961 zoning resolution (ZR), which imposes siting restrictions that reflect a distant technological era.

New York's regulations allow substations, the neighborhood-level distribution hubs for electricity, as-of-right on industrially zoned land (M or manufacturing). Con Edison, the utility responsible for distributing electricity in the five boroughs and Westchester, must undertake a costly, risky, time-consuming special-permit process to locate all but the smallest substations anywhere else. More and more, "anywhere else" in the city means residential and commercial neighborhoods.

WHERE SUBSTATIONS NEED TO BE
As the last stop before electricity gets to homes and businesses, substations need to be very local. The engineering goal is to deliver electricity from generating station to wall outlet with the least possible "line loss." The bigger the loss, the more money that must be wasted on the extra fuel needed to pump more electricity into the transmission system.

Such losses are least tolerable in the New York metropolitan area. That's because with greater population density comes greater "power density," in Con Edison's words. Manhattan has the highest power density in the world. "You have to get a lot of power into a small piece of geography," points out Ron Bozgo, the utility's vice president for engineering.

Thus, for New Yorkers to get the electricity they need, and for Con Edison to deliver it as efficiently as possible, substations must be in residential and commercial zones. Some substations do exist in such places—but only if their construction predated the 1961 zoning code, they were built on land that was M at the time, or if Con Edison successfully navigated a lengthy and expensive approval process to put them there.

WHERE THE ZONING CODE CONSIGNS THEM
Today, there is still no problem in siting substations in M zones, but so what? Residential and commercial areas require far more electricity than do the manufacturing zones of the mid-20th century.

In Thomas Edison's day, power density wasn't the reason substations had to be near users. Rather, the early technology of the direct current distribution system he invented and that New York City adopted (eventually replaced with the alternating current we plug into today) enabled transmission over short distances only. At the time, utility and transit substations could be built anywhere in the city. But New York's first zoning code, adopted in 1916, excluded new installations from residential districts. The 1961 rules pushed the ban into commercial districts.

By then, the Beaux Arts age had long passed when the IRT, BMT, and IND subway companies built substations as Renaissance palazzos, many with exteriors of the finest materials to disguise equipment delivering third-rail power to train track throughout the city. Too many utility substations, however, were left unenclosed, their electrical equipment naked to the elements—and the eye. For years, enclosed substations were only marginally better—hostile, windowless concrete or brick bunkers surrounded by chain link and razor wire. New Yorkers, in short, had good reason not to want substations in their neighborhoods.

In the early days, like so much other industry, power generation required access to the water. Transformers needed to be near the generating stations, so major substations often landed along the shoreline as well. The 1961 ZR then froze that moment of technological history in its regulations by designating waterfront land as M. Although power facilities no longer require proximity to water, zoning maps and existing facilities serve to keep—and, in some cases, entice—them there, cutting off the waterfront from active, people-friendly uses.

Meanwhile, the city has evolved from manufacturing center to service economy, leaving much industrially zoned land underutilized and derelict. Recognizing this, the Bloomberg administration has rezoned more than one-sixth of New York's landmass, much of it from industrial to some combination of residential and commercial. It will be harder and harder for Con Edison to find M land to buy as time goes on.

WHERE SMALL SUBSTATIONS CAN BE
Even the 1961 regulations recognized that substations were not factories. Indeed, if a substation could fit onto a parcel smaller than 10,000 square feet, the ZR called it a "public service establishment" and allowed it in some commercial areas. (Public service establishments include court houses, police and fire stations, and telephone exchanges.) Unfortunately, most Con Edison substations require a site of something closer to 40,000 square feet, and thus inherit an industrial mantle—and along with it, either the onus of seeking special permission to settle near the people they supply, or consignment to a parcel of increasingly scarce M land.

Designed well, a substation on a 40,000-square-foot plot can blend into the neighborhood as discreetly as one on 10,000 square feet. Like virtually every other type of technology, substation equipment is quieter, cleaner, and more compact today than ever before. Technological advances have made it possible to construct understated, even invisible, substations pretty much anywhere. Increasingly, Con Edison has been building substation façades that harmonize with their surroundings. The Mott Haven substation complex in the Bronx, for example, flaunts cornices and decorative brickwork, windows, and doors to give the appearance of a block of rowhouses. This approach picks up where the IND left off in the 1930s.

Utilities in Europe and Asia construct all kinds of buildings and open space on top of substations, which may be at street level or underground. New York has only one example of this kind of mixed use, 7 World Trade Center (7WTC), whose footprint is just about 40,000 square feet.

LAND AND POWER
The careful use of valuable land in sensitive locations, along with the most economical system of electrical distribution, should be part of New York's power future too. But to achieve such efficiency, the city will have to change the zoning rules governing electrical substations. 7WTC houses Trade Center Substation in part because the Port Authority land on which it stands is exempt from New York City zoning.

Freed of the delays and doubts posed by the land-use approval process, Con Edison could cut years from its facilities planning and the task of getting them on line. In making available the most suitable properties for accommodating vital distribution hubs, the city would also be removing Con Edison's incentive to hold on to the industrial land it owns. Now locked into an M designation, Con Edison's land would be available for rezoning and site-appropriate development.

RETHINKING USE ZONING
Making detailed changes to the ZR text would remove the obstacles to locating substations. CRD's new report, The Neighborly Substation, recommends exactly that, identifying certain technicalities of "use group" assignment, "location within buildings," and "ground floor use in certain locations" as ripe for amendment. The point is to let Con Edison build substations as-of-right in residential and commercial areas and encourage stacking other uses above them. Justified by advances in power technology, the amendments fit well within a tradition of updating the zoning text without challenging its structure.

That structure features lists of land uses specifically permitted in certain zones. But why should a substation—or a school or a grocery store or a doctor's office, for that matter—be allowed on a site, or banned from one, simply because of what it is? The real test should be what it does. How much traffic does it attract? Is it noisy, polluting, hazardous? The particular contents and function of a harmless and inconspicuous structure should not matter to its neighbors.

Given their unpleasant encounters with razor-wired fortresses, communities understandably worry about what a proposed substation will do to the visual and social fabric of their area. Many fear that the installation will someday catch fire or explode. Others fret about the noise of operating machinery or the long-term health effects of exposure to electromagnetic fields (EMF), which are generated by strong electrical current.

In fact, concrete walls, metal shielding, and soundproofing—all standard techniques in substation construction—effectively mitigate all of these nuisances and hazards. (On the basis of a review of thirty years of scientific literature, the World Health Organization recently concluded that "current evidence does not confirm the existence of any health consequences from exposure" to EMF.) Substations can always be made as safe, quiet, and otherwise unobtrusive as any other kind of new development. A restructured zoning resolution could codify acceptable levels of emissions, sound, traffic, etc., in residential, commercial, and industrial areas, for which any new building or installation was responsible—whether substation, fitness center, dry cleaner, or synagogue.

WHAT’S NEXT
Nobody has been lobbying for neighborly substations, which need to be put on the policy agenda. That means leadership from City Hall. Redefining use zoning is even further off.

 


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