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ANHD Helps Win Deeper MIH Affordability

March 18, 2016

The Association for Neighborhood and Housing Development has been the leading organization calling for a Mandatory Inclusionary Housing (MIH) policy because we believe that the City needs a new baseline for how affordable housing gets built in all communities. Yesterday the City Council announced the negotiated MIH policy that will be voted out of Council Committee today. This will be the strongest Mandatory Inclusionary Housing program in the country and ANHD believes it is deserving of support.

 
ANHD Helps Win Deeper Affordability in Announced Mandatory Inclusionary Housing Policy
 
The Association for Neighborhood and Housing Development has been the leading organization calling for a Mandatory Inclusionary Housing (MIH) policy because we believe that the City needs a new baseline for how affordable housing gets built in all communities. Yesterday the City Council announced the negotiated MIH policy that will be voted out of Council Committee today. This will be the strongest Mandatory Inclusionary Housing program in the country and ANHD believes it is deserving of support.
 
ANHD's member groups had four core principals as we worked for an inclusionary housing policy: 1) MIH must be mandatory, 2) it must be permanently affordable, 3) it must be applied wherever there is a significant upzoning, and, 4) it must include affordability levels at an Area Median Income (AMI) that truly meets the needs of the City. We were encouraged this past summer when the Mayor announced a policy that met the first three goals.
 
We believed that the original Administration proposal, whose rent levels only reached down to 60% of AMI, didn't reach low enough to meet the needs of the many neighborhoods that are facing a rezoning, or the need of the City as a whole. Together with our members and allies in the City Council, we fought to get the AMI's down to below 60%, setting a target of 30% of AMI as both a stand-alone option, and as a required band for averaging within the higher-income options.
 
The final program announced by the City Council yesterday moved MIH in the right direction by setting the lowest income option at 40% of AMI, which  is affordable for families making $31,000. With this change, MIH  now serves an additional 15% of New York City's households - close to half a million families - that would have been left out when the proposal first entered the ULURP process months ago. This change makes New York City's MIH policy significantly more affordable than any other program in the country.
 
We commend Mayor de Blasio for his commitment to a strong MIH policy. We also particularly recognize the efforts of the City Council, and applaud those City Council members who worked with ANHD and our local groups to improve on the originally-proposed policy as it made its way through the ULURP process.
 
The MIH policy that the Mayor and the City Council announced yesterday will have four MIH Options:
  1. An option of 20% of the housing affordable at 40% of AMI. (This option is new, and a direct result of ANHD and community advocacy.)
  2. An option of 25% of the housing affordable at an average of 60% of AMI, and requiring a band of 10% of that housing at 40% of AMI. (This 40% band requirement is new, and a direct result of ANHD and community advocacy.)
  3. An option of 30% of the housing affordable at an average of 80% of AMI.
  4. An option of 30% of the housing affordable at an average of 115% of AMI. This option is not available below 96th Street in Manhattan, and is not available to buildings that use public subsidy (except 421a).
 
Another important change in the final proposal is that developers choosing to locate their MIH affordable units "off-site " are now required  to set aside add an additional 5% of units as affordable housing and are not eligible for the height increase allowed under Zoning for Quality and Affordability. These changes make it more likely that MIH will produce mixed income buildings, and isalso a direct result of ANHD and community advocacy.
 
The Administration also committed to passing legislation to create a Citywide Certificate of No-Harassment Program, one of ANHD's other very important goals. This new program, if properly structured, can be an important new proactive anti-displacement tool, with the potential to make a big difference in the fight against harassment. ANHD has said all along that we will never be able to build our way out of the affordability crisis, and so we are particularly encouraged at the Administration's commitment to working with us and Council to swiftly develop and implement strong legislation to keep low income tenants in their homes.
 
There are some MIH  program details that the City Council is still working out, and we strongly encourage the proposal to allow the 40% AMI Option to be allowed as an average, not a set percent. And, we continue to believe that every option within MIH should require some deep affordability. As the final details are worked out, we encourage the Council to consider requiring some a deep affordability band in the 80% AMI option.
 
But the fight for deeper affordability must continue.
 
But MIH alone still falls short of meeting New York City's affordable housing needs. Almost 30% of our City's households fall below 30% of AMI and even with these positive changes, will still not be served by the MIH program. As a City, we must take up and meet the challenge of housing all of our communities' families. MIH will still fall short of meeting the affordable housing needs of our poor and working families citywide, and particularly falls short of serving the income levels of residents in many of the neighborhoods where local rezonings are proposed.
 
MIH is only one of the tools that we need. We hope and expect to see the Administration work with local community groups to find additional ways to reach the deep levels of affordability that meet the true needs of the neighborhoods where rezonings are proposed, many of which have local median incomes far below the levels that will be served by MIH.
 
ANHD and our groups will continue the push the City to create deeper affordability units in neighborhood rezonings and site rezonings, through City subsidy, and in other housing programs. We will work to make sure that a strong and effective Certificate of No Harassment law is enacted in the coming months. And we look forward to continuing the fight for affordable neighborhoods that truly serves our residents, our communities and our City.
 

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