Pratt Center for Community Development

Greenpoint-Williamsburg Rezoning

Greenpoint-Williamsburg Rezoning

Brooklyn Community Board 1
November 16, 2004

Thank you for the opportunity to testify tonight. I am Brad Lander, director of the Pratt Center for Community Development. The Pratt Center is honored to have a history of supporting the Greenpoint-Williamsburg community in shaping development that goes back several decades, to the community’s efforts to insure a fair deal around the S&S factory expansion. Today, like then, the plans proposed by the NYC Department of City Planning need to be dramatically changed before they would make sense for the community and the city.

I urge Community Board to vote no, in the hopes that City Planning will then heed the community’s call for plans that are dramatically better at insuring that future development meets the neighborhood’s needs: affordable housing for a diverse range of residents, preservation of viable manufacturing jobs, appropriate height and scale, and truly public access to its waterfront.

I first want to praise Community Board 1, the North Brooklyn Alliance, the Mobilization against Displacement, and the neighborhood’s strong community organizations (Los Sures, St. Nicholas NPC, Neighbors Against Garbage, Churches United for Fair Housing, and many others) for the thoughtful deliberations you have given to your community’s future. Starting over 10 years ago when you developed comprehensive community 197-a plans to establish a framework for that development, and continuing through the past year. In my opinion, you have established one of the deliberative and participatory processes for considering development that NYC has seen.

As many of you know, I have been especially focused on the issue of guaranteeing affordable housing, and on the strategy of mandatory inclusionary zoning as a critical part of this guarantee. Before I return to this however, let me address two other ways in which I believe that this zoning proposal needs to changed:

Preservation of Viable Manufacturing Jobs

The plan does far too little to preserve viable manufacturing jobs, which are critical for low and moderate income residents of this community and the city, and which are an important part of our economic diversity:

• The plan should not go through without designating East Williamsburg as an industrial employment district, with new provisions that would create certainty for manufacturing business owners. Without such designation, this rezoning will accelerate the already dramatic and illegal conversions taking place there and undermine the industrial park.
• Provisions of the Special Northside Mixed-Use district that protect manufacturing uses and seek to promote balanced and compatible mixed-uses should be strengthened rather than undermined. City Planning should created a balanced mixed-use district, with performance standards, that actually seeks to preserve manufacturing rather than promote steady conversion to exclusively residential development.
• In the absence of these provisions, fewer blocks should be converted from manufacturing to mixed-use, or from Special Northside Mixed-Use to residential.

Creating Truly Public Access to Its Waterfront

The current proposal will not create the kind of continuous, consistent waterfront access that it seeks. Evidence from around the country and the world shows clearly that what works is public ownership of the waterfront, with public investment in bulkheads and in continuous and consistently-designed open space. Just look at the two Hudson River waterfronts – NYC’s successful continuous park along the West Side, versus New Jersey’s mish-mash of partial and inconsistent access. The difference is clear, and due to public ownership. City Planning’s own proposal for the High Line shows the right approach to using public ownership to create dramatic new parks. And here, it would not even be necessary to compensate owners, since the City would be adding to their property values, and since they would not be able to develop this area under the current proposal anyway. Without this step, it could be decades before the community has full access to its waterfront.

Guaranteeing Affordable Housing Through Mandatory Inclusionary Zoning

Finally, but in so many ways most important, the plan is insufficient in guaranteeing affordable housing that a meaningful number of community residents can afford. We recently published this report, Increasing Affordable Housing in NYC: The Case for Inclusionary Zoning. I am attaching relevant pages to my testimony, so I will just hit the highlights here.

• This plan would make possible the development of over 21,000 new units of housing in the coming decades.
• As originally proposed by City Planning, the plan would contain almost no units of affordable housing.
• With modifications recently proposed by HPD, the plan would offer some incentives for affordable housing. The Pratt Center welcomes these new proposals. We appreciate the administration’s recognition of the need to modify its zoning plans to address affordability, the commitment to keep units permanently affordable, and the offer of a range of income tiers. However, the plan still does not come close to guaranteeing sufficient and feasible affordable housing:

- It does not provide a guarantee of any units, and there is a significant chance that few developers will choose it. Despite lobbying by the administration, no developers have yet stepped forth to indicate that they would choose it.
- The plan relies completely on existing subsidy programs, without capturing any additional units as a result of the density bonus it would grant.
- Even if developers opt for it, it will create too few affordable units.
- Most developers who choose to take the program will develop 80/20s, which provide housing only for a very narrow band of people earning around 50% of area median income.

We therefore wish to strongly restate the case for utilizing mandatory inclusionary zoning – in conjunction with other strategies – to guarantee affordable housing in Greenpoint-Williamsburg.

• Mandatory IZ programs are increasingly chosen by large cities as a way to generate affordable units without dampening market-rate development. Boston just increased its requirement from 10% to 13%, without a density bonus. The Republican governor of Massachusetts is supporting new high-density zones that would require 25% affordable units.
• Mandatory IZ has been shown not to dampen development in four credible national policy reviews.
• Mandatory programs produce housing for a more diverse range of incomes.
• Mandatory programs offer better uniformity and predictability.

In our report, we considered a waterfront site in Greenpoint-Williamsburg, Brooklyn, which is being rezoned from manufacturing to residential use. We utilized site-specific zoning and financial data provided by the NYC Departments of City Planning and Housing Preservation and Development (HPD). Conclusions of the analysis reveal:

• 20% of the total new units created could be made affordable (to a mix of families earning from $25,000 to $55,000), with no public subsidy, through mandatory inclusionary zoning.
• The developer would still be able to receive the targeted financial return – 19% annual return on equity – that market-rate condo developers are currently seeking.
• The requirement would lead developers to offer lower acquisition prices for the land than they would without a requirement. However, average existing landowners of would still receive a windfall of over 900% as a result of the rezoning, based on the average prices those owners have paid for their land. (We have attached a chart of sales prices for existing sites in Greenpoint-Williamsburg, which makes clear that there is plenty of room to establish a requirement, with landowners still seeing substantial appreciation).
• Deeper affordability, or additional affordable units, would be possible through the use of public subsidies, including Section 8 housing cost vouchers, tax incentives, or city capital programs.

Mandatory inclusionary zoning will not solve the problem by itself. We believe that there is an important role for a voluntary density bonus, and for financial incentives – but on top of an across-the-board, base requirement that all developers receiving this density windfall should have. One possibility would be to require that every developer include 15% affordable housing at a range of incomes – say 5% below 50% AMI, 5 % below 100% AMI, and 5% below 120% AMI – at the proposed base FAR of 4.0. Then, developers could choose to opt for a density bonus, and use financial subsidies (such as 80/20 or 50/30/20), but only if 30% of the units were affordable – 20% at 50% of AMI, 5% below 100%, and 5% below 120%. These options would be even more profitable than the model we considered in our report.

When used in combination, these strategies – building on a base of mandatory inclusionary zoning, but also including voluntary density bonuses, financial incentives, support for not-for-profit developers, and use of publicly- and church-owned land – can guarantee meaningful affordable housing in Greenpoint-Williamsburg.

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However, until such changes are made, we urge Community Board 1 to vote to reject the proposed rezoning of Greenpoint-Williamsburg, in the hopes that the plan will be dramatically improved to meet the true needs of community residents.