Chelsea Neighborhood Association v. United States Postal Service

Chelsea Neighborhood Association v. United States Postal Service, 389 F. Supp. 1171 [S.D.NY 1975] involved the proposed construction of a vehicle maintenance facility by the United States Post Office in the Manhattan neighborhood of Chelsea. Above the facility, a housing project of approximately 860 units was to be constructed for moderate/low income families and senior citizens. The facility and the proposed housing were considered a "structurally integrated" project. The proposed housing above the facility was "cited [by the relevant EIS] as one of the primary benefits to be derived from the construction of the [facility]," and was a "major factor in the rejection of other alternatives" (389 F. Supp.at 1175, 1180). The Southern District found that the defendants' environmental review under NEPA (the federal counterpart to SEQRA) was insufficient, based on the EIS's "failure to fully disclose to all interested parties the very real possibility that the housing may not and cannot be built" due to the potentially prohibitive cost of the "extensive acoustical treatment" necessary for the coexistence of the residential units and the facility (id. at 1180-1181).