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ANHD Analysis of NYC Inclusionary Zoning Proposal
The City has announced its long-awaited Mandatory Inclusionary Zoning Policy. It is a significant step forward in building the equitable city that New Yorkers both want and need.
City Inclusionary Zoning Proposal a Step Forward, but Affordability Must be Fixed
The City has announced its long-awaited Mandatory Inclusionary Zoning Policy. It is a significant step forward in building the equitable city that New Yorkers both want and need. The affordability requirement is expected to apply to all upzonings going forward, meaning any time the city upzones an area, the housing built in that area will include affordable units – no ifs, ands, or buts.
And the city is taking a forward-thinking approach and designing a program that will have an impact well beyond this administration. First, this policy being written into the zoning code, meaning this will not just be a program of this administration, but guide our city’s growth and development in the future. And this housing will be permanently affordable, locking-in affordability for future generations of New Yorkers. ANHD’s recent report: NYC Inclusionary Zoning: A District-by-District Analysis of What Was Lost, Gained, and What Remains, details the number of affordable units we believe can be created under this new mandatory policy.
But if the purpose of this policy is to create inclusive neighborhoods, we need to ask an important question: who will be included and who will be left out. And currently, the rent levels set will leave millions of low-income New Yorkers out of the equation.
There are three options for affordability being proposed:
- Option A) 25% affordable at an average of 60% AMI.
- Option B) 30% affordable at an average of 80% AMI.
- Option C) 30% affordable at an average of 120% AMI.
These levels are, quite simply, not where the need is greatest. 85% of New Yorkers making under 50% of AMI are rent-burdened, and in need of affordable housing. This is compared to less than 10% of New Yorkers making 100% AMI. And in raw numbers, the differences are even starker. There are 14 times more rent-burdened households at 50% AMI and under, than at 100% AMI and up. Any new MIZ policy needs to specifically address this, and require a significant portion of affordable housing for truly low-income New Yorkers across all of these options.
And then there is Option C, which shouldn’t be an option at all. This option is intended to be set in neighborhoods where 120% is on or about the market rate, in order to keep incentivizing market-rate development. Put another way, this option not only doesn’t provide affordability, but is specifically designed to not provide affordability. The option’s purpose is to keep the $2000+ apartments coming, without requiring anything for the lower-income half of New Yorkers. This is at direct cross-purposes with the rest of the proposal. An affordable housing program is for creating affordable housing, not market-rate housing.
Option C may only be applied to select neighborhoods, but this misses the point: an inclusive and affordable city is about all of our neighborhoods – the city shouldn’t be able to choose a select few where these values don’t apply, and low-income New Yorkers are left out.
The framework of the MIZ proposal is serious and strong, and a paradigm shift in our approach to creating an inclusive and diverse city. But let’s make sure that the details of what is ultimately put in place benefit all our citizens, in all our neighborhoods.
for ANHD’s July 2015 report on Mandatory Inclusionary Zoning