Thank you Chair and Commissioners for the opportunity to testify again before this Charter Revision Commission. My name is Barika Williams and I am the Executive Director for The Association for Neighborhood & Housing Development (ANHD). ANHD is a membership organization of NYC neighborhood-based housing and economic development groups, including CDCs, affordable housing developers, supportive housing providers, community organizers, and economic development advocates and service providers. Our mission is to build community power to win affordable housing and thriving, equitable neighborhoods for all New Yorkers. We believe housing justice is economic justice is racial justice.
ANHD also convenes the Thriving Communities Coalition (TCC) – a citywide movement of grassroots organizing, advocacy, policy, and technical assistance groups working across issue areas and neighborhoods. ANHD and TCC are united in the belief that our current ad-hoc approach to planning and land use in New York City does not effectively deliver for most New Yorkers, and that we need meaningful reform to ensure a more equitable distribution of development and investment to truly overcome inequality, exclusion, and displacement.
ANHD and TCC have long called for a comprehensive planning approach for NYC that aligns and coordinates existing plans, centers racial, economic, health, and climate equity alongside intentional, robust, and representative community engagement to help build trust and work to achieve fairer, more informed, more democratic decisions and outcomes citywide and in our
neighborhoods. We shared a proposal with this Commission in February to amend the charter to mandate that NYC create a comprehensive plan on a recurring timeline and we continue to urge you to include this in the ballot questions you put before voters this November.
However, even if this Commission is not prepared to advance comprehensive planning at this time, we believe this is still an opportunity to advance one key component and outcome of comprehensive planning by better aligning land use and budget decisions to achieve the targets set by the Fair Housing Plan (Charter, Section 16-a). This aligns with a crucial goal and consideration of this Commission to move certain discretionary housing proposals on a faster timeline through public review, while ensuring that these proposals are advancing a more equitable distribution of new housing units, and particularly new affordable housing units, throughout the city.
The focus of our testimony today will be on this proposal.
We agree with the Commission’s goal of expediting certain housing proposals but want to stress that any fast-tracking of housing needs to be done following a plan, and specifically a plan rooted in equity. We have that plan in the form of the Fair Housing Plan, an equity-focused plan that is already enshrined in the Charter (Section 16-a) following passage by the City Council after careful crafting, consideration and deliberation, including in coordination with City agencies. Expediting certain housing proposals that match the Fair Housing Plan follows the
model we are trying to promote with comprehensive planning: do upfront, equity-focused planning and then allow proposals that match the plan to move on a faster timeline.
For both planning and legitimacy purposes it is important for this Commission to tie any expedited housing proposals to the Fair Housing Plan. Reforms such as these will be more secure when they are built upon something the Council has already enacted. Though this plan was created by the Council, it is specifically designed to be led by City agencies – reflecting in its very nature a good mix of citywide and local considerations. The Fair Housing Plan already includes clearly defined targets and considerations in thinking about how to more equitably
distribute housing. This includes setting targets at the Community District level for housing units, affordable housing units, deeply affordable housing units, and supportive housing units, while taking into consideration their level of displacement risk, existing affordable housing, and current level of housing production. Lastly, the timeline for the Fair Housing Plan aligns well with the timeline for this Commission – with the plan due in October of this year (2025) and the targets due October 2026.
ANHD calls on this Commission to send voters an amendment to the charter for an amended
Fair Housing Plan that:
- Requires the City Council to vote on the targets set by the City
- As one package, with a majority vote needed for approval
- Empowers community boards to create community plans to outline how to reach the
targets - Expedites housing that meets the targets provided projects are:
- 100% affordable, or
- Mixed income affordable in certain clearly defined neighborhoods
- Ensures the capital budget details how it is responding to the Fair Housing Plan
We provide more details on each of these components below.
- Require the Council to vote on the targets set by the City
- Once the targets have been set and released by the City, the City Council would vote to approve them – they would be taken up as one package, with a majority vote needed for approval
- We would see this as an up down vote – meaning that the Council could not amend the targets or exclude any Community Districts
- We believe this step is important to get majority Council approval and buy-in upfront on the targets that the plan establishes
- Empower community boards to create community plans to outline how to reach the targets
- Community Boards should be empowered to create local land use plans outlining their vision for how to reach the Fair Housing targets in their Community Districts
- This is a vitally important step that would increase community participation and proactive community planning by providing communities the opportunity to lay out how they best think these targets can be met through land use changes
- This offers communities a good-faith way to engage if they are not happy about the possibility of expedited proposals – allowing a process where they can put forward their plan for where projects, and land use changes
to meet them, are most appropriate
- This offers communities a good-faith way to engage if they are not happy about the possibility of expedited proposals – allowing a process where they can put forward their plan for where projects, and land use changes
- These plans could then serve as guiding documents for where proposals should be sited (like a 197a plan with more teeth) or they could move forward through ULURP as a neighborhood rezoning
- If the plan would credibly meet the targets they should automatically be approved for certification and a fast-tracked ULURP process
- It is important that this proposal include language ensuring adequate resources for Community Boards to carry out this role
- The intention of these community plans is not to stall development – rezonings (expedited or otherwise) and as-of-right development would continue to move forward while these plans are being created
- The ability to create these plans should be available for all Community Districts, but as a further measure to ensure a more equitable distribution of housing and particularly affordable housing development, this Commission could consider requiring that Community Districts that aren’t meeting their targets are required to create these plans
- Expedite housing that meets the targets, provided projects are:
- 100% affordable
- This definition should be crafted in a way that gets at developments using the deepest HPD term-sheets – we don’t want 100% affordable that is primarily at very high AMIs – our goal is have as many 30-40% AMI units as possible
- In addition to specifying that this applies to 100% affordable, mission-driven development, this could mean including a weighted AMI average or dictating that a certain percentage of units need to be deeply affordable
- This definition should be crafted in a way that gets at developments using the deepest HPD term-sheets – we don’t want 100% affordable that is primarily at very high AMIs – our goal is have as many 30-40% AMI units as possible
- Mixed income affordable in certain clearly defined neighborhoods
- Expediting these types of developments should only be allowed in certain neighborhoods that aren’t doing their part today, specifically those that are defined as:
- “Low-displacement risk” as per the definition in Section 16-a of
the Charter - “Limited affordability”as per the definition in Section 16-a of the
Charter - That have not been hitting their housing targets
- “Low-displacement risk” as per the definition in Section 16-a of
- Expediting these types of developments should only be allowed in certain neighborhoods that aren’t doing their part today, specifically those that are defined as:
- It’s important to have some guardrails and to keep the ability to expedite housing proposals focused specifically on affordable housing development, both 100% affordable and mixed-income
- ANHD believes this is appropriate as increasing the supply of affordable housing is the best way to address the dire housing need in the city
- There are other mechanisms – like expanding the geography for ADUs – to try to get at as-of-right lower density development
- In addition, just because a neighborhood hasn’t produced any housing that shouldn’t further let them off the hook for producing regulated affordable housing
- Proposals that meet either of these criteria could forego automatic Council review by requiring a supermajority of Council to call them up, giving the City Council Speaker the sole authority to call them up
- This Commission could also consider that these expedited ULURP proposals end with a City Planning Commission (CPC) vote, with Council having representation at the CPC hearing and vote
- This Commission could also consider that these expedited ULURP proposals end with a City Planning Commission (CPC) vote, with Council having representation at the CPC hearing and vote
- 100% affordable
- Ensure the capital budget details how it is responding to the Fair Housing Plan
- This should include detailing how it will address the obstacles to increasing the amount of “neighborhood equity investments” in underserved areas identified in the Fair Housing Plan’s strategic equity framework
- It’s important that planning include more than just zoning changes
- This recommendation would increase transparency around what investments are happening to help meet the Fair Housing Plan
- This would not require that Capital Budgets fully meet the plan, simply that they detail where agencies are making investments to help met the Fair Housing Targets
ANHD believes that our full comprehensive planning recommendation remains the best way to move New York City away from a land use and zoning regime that not only has held back equitable housing production but has deepened inequity across a variety of issues that impact every New Yorker. But in the absence of a more robust comprehensive planning proposal we believe our recommendations to better align land use and budget decisions to achieve the targets set by the Fair Housing Plan will have a powerful impact.
We urge this Commission to advance our four recommendations to strengthen the Fair Housing Plan and to send them before voters this November. These recommendations can advance the
Commission’s goal to move certain discretionary housing proposals on a faster timeline through public review, while ensuring that these proposals are advancing a more equitable distribution of new housing units, and particularly new affordable housing units, throughout the city, while empowering local communities to have a proactive role in this process. Thank you.