Manhattan Valley Neighbors for Permanent Housing For Homeless v. Koch
The Supreme Court, New York County, affirmed the dismissal of a CPLR article 78 petition brought by petitioners challenging a Board of Estimate decision. Petitioners sought to annul the Board's approval of a plan to rehabilitate city-owned buildings in Manhattan for transitional housing for approximately 71 homeless families, proposing instead permanent housing. They contended the project required an environmental impact statement (EIS) due to the transitional nature of the residency. The court found that the city properly classified the project as a Type II action, exempt from EIS requirements under SEQRA and CEQR, as it involved replacement in kind and not new construction. The court concluded that the Board of Estimate did not act illegally or arbitrarily in exempting the project from an EIS.