Testimony for the NYC Charter Revision Commission 3/17/25
Thank you Chair and Commissioners for the opportunity to submit testimony before this Charter Revision Commission. We are submitting this testimony on behalf of 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. We believe such an approach can better align and coordinate existing plans, while centering racial, economic, health, and climate equity alongside intentional and representative community engagement, to help build trust and achieve fairer, more informed, and more democratic decisions and outcomes citywide and in our neighborhoods.
To help advance a more equitable and comprehensive approach to planning we call on this commission to:
1. Amend the charter to mandate that NYC create a comprehensive plan on a recurring timeline, with the following essential components:
- Establishment of equity goals, including
- Ensuring an equitable distribution of development and investment
- Increasing access to affordable housing
- Promoting social, economic & racial integration
- Advancing environmental justice, open and green space
- Through the coordination of existing plans’ goals and mandates (such as the Fair Housing Plan, Long-term sustainability plan)
- Establishment of citywide and Community District level targets across a host of issues, including for
- Housing
- School seats & community facilities
- Open space
- Infrastructure & Resiliency
- Through the coordination of existing plans’ quantifiable targets (such as the Fair Housing Plan)
- Committing all 59 Community Districts to create Community District level plans to achieve these targets, with the necessary resources to conduct this process with robust, deliberative and inclusive community engagement, including budgetary and technical assistance needs to achieve this
- Requiring land use, annual expense budget, capital budget and policy decisions to detail how they are in accordance with the comprehensive plan so as to achieve its goals and targets
This is also 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). The Fair Housing Plan already requires the setting of 5-year housing production targets for each Community District - a goal we would seek to require for a host of additional issues through our Comprehensive Planning proposal above.
To begin to advance one crucial component of the outcomes we seek with comprehensive planning, we call on this commission to:
2. Make the Fair Housing Plan more enforceable by amending the charter to
- Encourage and advantage certain ULURP proposals found to be in compliance with reaching Fair Housing Plan targets, by moving them through an expedited process
- This would be done in a tiered fashion where:
- 100% affordable developments with deeply affordable units could be expedited in all geographies
- Mixed-income affordable developments could be expedited only in those geographies deemed both “low-affordability” and not a “high displacement risk area” by the Fair Housing Plan and that did not reach their housing production targets in the most recently completed five year time period
- Such projects would not receive an automatic Council hearing and vote unless a majority of the Council voted to do so
- This would be done in a tiered fashion where:
- Require that the capital budget details how it is advancing and addressing the goals, targets, and obstacles established and identified by the Fair Housing Plan
In addition to these proposals to forward a more equitable and comprehensive approach to planning, we also urge this commission to address the on-going contracting backlog crisis for nonprofit providers - to better ensure on-time payments and contract approvals. This is an existential crisis for the nonprofit sector, with close to 100% of ANHD’s members experiencing registration delays, and some contracts dating back to FY23 still unregistered, forcing organizations to front expenses for these programs with their own limited resources while waiting years for payment. To address this issue we ask this commission to consider amending the charter to address:
- Late contract registration and delayed invoice processing - to ensure payments continue when there are gaps and delays
- Redundant and tedious contracting processes - including unnecessary public hearings
- The establishment of a “multi-year” contract mechanism
In conclusion, we call on this commission to take bold, systemic steps that begin to move NYC 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.
We have included as Appendix A the specific changes to the charter that we are seeking to achieve these proposals. We believe our proposals strike the right balance between meeting citywide needs and empowering local communities to have more meaningful involvement in the planning process. To build a more just and fair city, we call on this Commission to amend the charter to advance comprehensive planning and fair housing so as to better align and consolidate our planning processes, center them in equitable goals to achieve equitable targets, and empower everyday New Yorkers to plan and build neighborhoods where they and future generations can thrive.
Thank you for your time and consideration. We welcome the chance to work with this commission and its staff to realize these recommendations. Please contact Chris Walters, Senior Land Use Policy Associate at ANHD at christopher.w@anhd.org for any questions or follow-up.
Appendix A
Proposed Charter Amendments
1. Comprehensive Planning
Add a comprehensive planning mandate by creating a new Chapter 8-A as follows
Chapter 8-A: Comprehensive Plan
Section 207. Comprehensive Plan
a. Definitions. As used in this section, the following terms have the following meanings:
Community engagement: The term “community engagement” means outreach to and input from a broad, representative group of people from each community district, and the city as a whole, in the opportunity to influence policy decisions, by following best practices for outreach and robust, deliberative participation, through varied methods including but not limited to surveys, education and outreach materials, online platforms, interactive mapping tools, and community meetings facilitated to stimulate dialogue and deliberation involving varied views and interests.
Policy decisions: The term “policy decisions” means choices made by city agencies, commissions, bodies and elected officials as to how best to achieve the equity goals established pursuant to paragraph one of subdivision a of this section.
b. Commencing not later than February 1, 2027 and not less than every ten years thereafter, such agency or inter-agency working group as the mayor shall designate, shall conduct a comprehensive planning process for New York City. Such process shall be conducted in consultation with the appropriate city and state agencies and bodies, and with community engagement, and shall include:
(1) the establishment of equity goals, including but not limited to goals to reducing and eliminating disparities across race, geography, and socioeconomic status in access to opportunity and the distribution of resources and development, increasing access to affordable housing, promoting social, economic, and racial integration, and advancing environmental justice and access to healthy environments, with such goals incorporating those goals developed by existing plans including but not limited to the fair housing plan pursuant to section sixteen-a, and the long-term sustainability plan pursuant to subdivision e of section 20.
(2) the establishment of quantitative citywide and community district level targets including but not limited to targets for housing, school seats, community facilities, open space, and infrastructure and resiliency, with such targets incorporating those targets required by existing plans including but not limited to the fair housing plan pursuant to section sixteen-a.
(3) the creation of community district level plans detailing how best to achieve these targets, including but not limited to through the use of, zoning, capital budgeting, expense budgeting, and policy decisions, designed in coordination with community boards and with the necessary resources provided for community boards to fulfill this role, including community engagement.
c. No later than February 1, 2029, and no later than every tenth February 1 thereafter, the council shall adopt a single resolution establishing paragraphs one, two, and three of subdivision b of section two hundred seven as together encompassing the comprehensive plan for New York City.
d. Once adopted the comprehensive plan shall be considered the “well considered plan” for New York City pursuant to section 20(25) of the state’s General City Law and must be considered by all city agencies, commissions, bodies and elected officials, in future decisions including but not limited to zoning, capital budgeting, expense budgeting, and policy decisions, and such decisions must detail how they are in accordance with the plan.
2. Fair Housing Plan
1. Amend Section 16-a. Fair housing plan and housing reports. by adding a new subdivision as follows
g. Achieving housing production targets. Pursuant to section one hundred ninety-seven-c and section one hundred ninety-seven-d, special consideration shall be given to applications going through the uniform land use review procedure where:
- The application proposes new affordable housing where one hundred percent of the proposed dwelling units are affordable housing dwelling units, and where the weighted average of all income bands for such units does not exceed fifty-five percent of the area median income adjusted for the size of the household.
- The application proposes new affordable housing within a community district that has been deemed a low affordability area and is not concurrently within a community district that has been deemed a high displacement-risk area, provided that the housing production targets for the community district established pursuant to subdivision d of this section were not met during the most recently completed five-year period
2. Amend Section 197-c. Uniform land use review procedure. as follows
b. The following documents shall be filed with the department of city planning: (1) applications under this section, (2) any amendments thereto that are made prior to approval of such applications pursuant to this chapter, (3) any written information submitted by an applicant for purposes of determining whether an environmental impact statement will be required by law, [and] (4) documents or records intended to define or substantially redefine the overall scope of issues to be addressed in any draft environmental impact statement required by law, and (5) a statement of alignment determining if the application matches the criterion established pursuant to subdivision g of section sixteen-a. The department of city planning shall forward a copy of any materials it receives pursuant to this subdivision (whether or not such materials have been certified as complete) within five days to each affected borough president, community board or borough board.
c. The department of city planning shall be responsible for certifying that applications pursuant to subdivision a of this section are complete and ready to proceed through the uniform land use review procedure provided for in this section. The department shall promulgate rules to determine whether such applications align with the criterion established pursuant to subdivision g of section sixteen-a. Upon certification of an application, the department shall give notice of such certification to the council. If an application under this section has not been certified within six months after filing, both the applicant and, if the land use proposed in an application is consistent with the land use policy or strategic policy statement of the affected borough president, the affected borough president shall have the right at any time thereafter to appeal to the city planning commission for certification. The commission shall promptly, but in any event within sixty days of the filing of such an appeal, either certify the application or state in writing what further information is necessary to complete the application. If such an appeal is brought by an affected borough president, the affirmative vote of five members of the commission shall be sufficient to certify the application.
3. Amend Section 197-d. Council Review. as follows
b. The following decisions filed with the council pursuant to subdivision a of this section, shall be subject to review and action by the council:
(1) any decision of the city planning commission to approve or approve with modifications a matter described in paragraph three of subdivision a of section one hundred ninety seven-c, except where it has been deemed to match the criterion in subdivision g of section sixteen-a pursuant to subdivision b of section one hundred ninety seven-c, a matter described in paragraph [or] eight of subdivision a of section one hundred ninety-seven-c, a disposition of residential real property (as defined in this paragraph) pursuant to paragraph ten of subdivision a of section one hundred ninety-seven-c (except for dispositions to companies that have been organized exclusively to develop housing projects for persons of low income), a plan pursuant to section one hundred ninety-seven-a, or a change in the text of the zoning resolution pursuant to sections two hundred or two hundred one. For purposes of this section, residential real property shall mean real property improved by structures, whether or not occupied, built for or converted to a use which is primarily residential, but shall not include property subsequently converted to non-residential use;
(3) any other decision of the city planning commission to approve or approve with modifications a matter described in subdivision a of section one hundred ninety-seven-c, including a matter described in paragraph three of subdivision a of section one hundred ninety-seven-c, that has been deemed to match the criterion in subdivision g of section sixteen-a pursuant to subdivision b of section one hundred ninety-seven-c if within twenty days of the filing of such decision pursuant to subdivision a of this section, the council resolves by the majority vote of all the council members to review the decision of the commission.
4. Amend section 215 Ten-year capital strategy. as follows
c. Any project included in the ten-year capital strategy which addresses the goals and strategies of the fair housing plan pursuant to subdivision b of section sixteen-a or which advances the housing production targets identified at both the citywide and community district level pursuant to subdivision d of section sixteen-a or which addresses the obstacles identified in the most recent strategic equity framework pursuant to subdivision e of section sixteen-a, shall be so identified in the ten-year capital strategy.
[c] d. In the preparation of the preliminary ten-year capital strategy, the department of city planning and office of management and budget shall consider (i) the strategic policy statements of the mayor and the borough presidents pursuant to section seventeen, (ii) relevant citywide, borough and community plans adopted pursuant to section one hundred ninety seven-a, and (iii) the reports pursuant to section two hundred fifty-seven comparing the most recent ten-year capital strategy with the capital budgets and programs adopted for the current and previous fiscal years.