Housing Policy Analyst, Community Service Society of New York
Before the New York City Charter Revision Commission
September 27, 2018
My name is Oksana Mironova and I am a Housing Policy Analyst at The Community Service Society (CSS), an independent nonprofit organization that addresses some of the most urgent problems facing low-income New Yorkers and their communities.
Thank you for this opportunity to comment on the New York City charter.
1. Public property disposition for public benefit
Given the diminishing supply of public property and the great need for affordable housing, open space, and public facilities, the disposition of public property should serve pressing community needs. We recommend:
- Requiring the city to prioritize public benefit in the sale or lease of all public property, rather than selling or renting it “only for the highest marketable price or rental."
- Defining a process for measuring public benefit that prioritizes the most pressing community needs.
- Developing a comprehensive process for public property disposition that is connected to a city-wide planning framework.
2. Affordability protection
The charter devotes multiple pages to the process of land use review, but does not define the metrics or goals for measuring the impact of the land use actions. While explicit guidance and methodology should be left to the City Environmental Quality Review (CEQR) Technical Manual, major methodological gaps have repeatedly underestimated displacement pressures and socioeconomic impacts resulting from land use changes (see Pratt Center’s Flawed Findings: How NYC’s Approach to Measuring Displacement Risk Fails Communities and RPA’s Inclusive City). We recommend:
- Updating the environmental review language within the charter to be more prescriptive about the goals and methodology of the environmental review process.
- Requiring the mayor, in consultation with community and agency experts, to establish a criteria for measuring displacement risk, including the potential for direct, indirect, chain, and exclusionary displacement.
- Requiring the city planning commission to conduct a city-wide analysis of displacement risk using said criteria. The criteria should be employed with explicit goal of meeting the city’s fair housing goals (as established by Where We Live NYC) and ensuring a no net loss of affordable units.
- Employing the criteria in the environment review process for all future land use actions.
- Requiring the tracking and reporting of displacement and socioeconomic neighborhood change after land use actions are approved, to measure impact.
- Mandating a review of the City Environmental Quality Review Technical Manual by community and agency experts every five years.
3. Develop a framework for comprehensive community planning
Multiple city agencies are currently in the midst of multiple planning efforts, including Housing New York, NextGen NYCHA, Turning the Tide, all long range efforts to address affordability and homelessness; Where We Live NYC, a fair housing effort; as well as OneNYC, an environmental sustainability plan. These plans intersect on the ground with other initiatives, including participatory budgeting, public health initiatives, transit and pubic space projects, all shaping public perception of, and experience with, the planning process. Without coordination, these approaches are at times at odds with each other and do not distribute benefits and burdens equitably across the city.
Without a comprehensive planning framework, neighborhood planning efforts have largely been coupled with rezonings. Since the neighborhoods targeted for rezonings are primarily low-income, residents and elected officials are often placed in an (unenviable) position of trading the potential for displacement for necessary improvements to public facilities.
The charter review presents an opportunity decouple neighborhood planning and the distribution of resources from zoning, a blunt tool which, within itself, is not effective at achieving equitable neighborhood-based outcomes. The city should use existing efforts, including citywide initiatives like Where We Live NYC and local 197a plans, to create a comprehensive citywide planning framework. The process for the development of this framework should:
- Meaningfully engage neighborhood-based organizations and the public at large, in addition to community boards and local elected officials;
- Acknowledge and mitigate displacement and affordability concerns;
- Develop local targets for housing and economic development, displacement protections, public facility citing, and sustainability benchmarks, among others, underpinned by a consideration of racial and economic inequities between neighborhoods.
- Include a process for aligning the city’s long-term capital strategy with the resulting framework.
- Include a process for aligning future land use changes and agency plans with the resulting framework.
Thank you again for the opportunity to offer our recommendations. For more information or if you have any questions, please contact me at 212-614-5412 or email@example.com.
 Peter Marcuse, Gentrification, Abandonment, and Displacement: Connections, Causes, and Policy Responses in New York City, 28 Wash. U.J. Urb. & Contemp. L. 195 (1985)