RE: Mandatory Inclusionary Housing & Zoning for Quality and Affordability
Good morning.
I am here today to testify in opposition to the pair of zoning text amendments that have been put forward by this administration and the Department of City Planning, known together as “Zoning for Quality and Affordability” (ZQA) and “Mandatory Inclusionary Housing” (MIH).
These text amendments pose an abundance of concerns and questions by my office, the community boards, advocacy groups, elected officials and others from all points on the spectrum of the development and public policy community. These concerns were underlined at the recent meeting of the Bronx Borough Board, where they were unanimously rejected for a wide variety of reasons.
The submission of over 500 pages of text amendments at the same time is an unreasonable burden on most community boards to adequately review and evaluate their local neighborhood impact. These text amendments will govern land use development for our city for decades to come and should not be adopted in such a short period of time. Something so profound as the future development of this city cannot be rushed.
Achieving our city’s affordable housing goals cannot be accomplished in a vacuum. Our goal as a city should not be just to achieve a goal of 200,000 units, but to meet the individual needs of each and every community in this city. Allowing just 60 days for our community boards to weigh in on these proposals is disrespectful to the boards, their members and the neighborhoods they serve, and goes against the spirit of progressive, inclusionary and transparent government.
Despite the impact these combined proposals will have on density, there has been no serious discussion of the social and physical infrastructure necessary to manage the development for which this zoning plan allows.
Are there enough school seats for the children accompanying their parents as they move into new affordable units? What will be the impact on transportation in these communities? Will additional services be provided for seniors? Will new green and public spaces be provided for new residents? What kind of jobs will be created? How can we totally eliminate parking requirements? Will neighborhood residents even be able to get these new apartments?
These questions, and many others, have gone asked and unanswered.
Additionally, the proposal as it stands would not fully realize the goal of truly mixed-income communities. For example, a mix of specific income levels covering a broad range from very low to moderate-incomes within market rate developments should be considered. This range, rather than income averages, would create the true mixed-income neighborhoods that this proposal hopes to achieve.
The “neighborhood-by-neighborhood” approach to planning has been very successful in The Bronx, and these text amendments undermine that success. The borough has adopted no less than 14 rezonings since 2009, yet these proposals will reshape the zoning of this city with one broad brush stroke.
One size does not fit all. Local planning efforts reinforce the principles of inclusion and transparency, and can also mitigate displacement and preserve neighborhoods. These principles have been successful in previous rezonings, and they must be respected moving forward.
This administration has said that MIH and ZQA are the only way to mitigate the problems of displacement that can come with gentrification in New York City. This is simply not the case. While affordable housing is key, these amendments as they stand are not the way to accomplish affordable housing for all New Yorkers. There are multiple issues with the proposed amendments. We need to find a way to ensure that Bronx residents’ needs and all New Yorkers’ needs are met by new zoning, and this proposal does not achieve those ends.
While it has been said that changes will be made to these text amendments in light of community concerns raised regarding their implementation, we have not seen those changes yet. As currently written, I cannot support these zoning text amendments—Mandatory Inclusionary Housing Program and Zoning for Quality and Affordability—and I strongly recommend that the City Planning Commission vote to defeat these proposals.
Thank you.
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