The Hearst Headquarters Project team respectfully submits the following information requested in CIR Rulings dated 2/4/03 and 6/24/03 as an appeal to those rulings. We are seeking a credit equivalency point for improvements we are making to the existing Columbus Circle Subway Station (CCSS) adjacent to our project in Manhattan. As the prior CIR Rulings have suggested, we developed quantifiable data, based on an independent study of improvements to similar major urban transit systems which demonstrate improvements to CCSS will result in increased ridership. The study, "Evaluating the Effects of Transit Station and Access Improvements; Part 1: Quantifying the Value of Improvements", was developed by Richard Hazlett (City of Chicago Department of Transportation Bureau of Administration and Planning) with S. Falzarano and T. Adler (Resource Systems Group). By means of in-depth computer-based survey of riders and potential riders, the study quantifies the dollar value of improvements to riders on a per trip basis. According to this study, the vertical circulation improvements we are making between the platforms, mezzanines and street are valued at $0.043 per trip. Results from the study further demonstrate that when improvements such as these are made, but no increase in fares is incurred to compensate, ridership will increase. The increase can be calculated using Transit Elasticity Values common in transit analyses of price impacts on ridership. The Victoria Transit Policy Institute, in the "Transit Elasticities and Price Elasticities" study for the Journal of Public Transportation (February 2004), cites transit elasticity values for transit ridership with respect to transit fares as -0.2 to -0.5. Thus, the study indicates that each 1.0% decrease in transit fares causes a 0.2-0.5% increase in ridership. Since our improvements to the CCSS represent a 2.15% decrease in the $2.00 subway fare, ridership would increase by 0.43% to 1.07%. NYCTA figures estimate ridership at CSS to be at 19,466,445 upon completion in 2006. Therefore, our improvements have the potential to increase ridership for 2006 between 83,705 to 208,290 persons. Also, The project\'s Environmental Impact Assessment (Oct. 2002), provided by Allee, King, Rosen, and Flemming with Vollmer associates (submitted to and accepted by the NYC Planning Commission), includes data on Level of Service (LOS) upgrades due to the improvements. The data establishes stair improvements (widening, reversing and adding) alone increase the hourly service capacity from 12,480 to 23,230 passengers. If just two peak hour capacities (am & pm) are considered, these improvements give CCSS the capacity to handle an additional 21,500 passengers daily. This is a very conservative estimate of the additional daily capacity. In addition, none of these studies account for the increase in ridership that will result from providing ADA access where there was none formally. NYCT is in the midst of long term process of providing ADA accessibility to all its subway stations. When projects like ours bear the capital cost of providing ADA accessibility, fares do not have to increase as a result, and as the Hazlett study above indicates, ridership will increase. Detailed descriptions of the CCSS improvements are included in our prior CIRs. In keeping with the intent of SS credit 4.4, we are not providing any parking for this project. However, if we did, the environmental benefits associated with CCSS improvements would far outweigh the benefits of providing 50 carpool parking spaces, which the LEED Credit could require for our project. The subway improvement approach is more appropriate (although considerably more expensive) for a dense urban environment like NYC. Therefore, we again respectfully appeal to the USGBC\'s expertise in environmental stewardship to recognize these improvements as equivalent means of meeting Site Credits 4.4.