Testimony Re: New York City Charter Revision Commission

Thank you, Chair Buery and all the Commissioners for the opportunity to submit testimony to this Charter Revision Commission. Pratt Center for Community Development works for a more just, equitable and sustainable New York City through participatory planning, applied research, and policy advocacy in collaboration with community-based organizations. Our land use and housing justice work ranges from facilitating community plans for neighborhoods across the city to policy reports on strategies to ensure that value created by city rezonings is captured for public good. We call on this Commission to prioritize democracy, participatory planning, and racial and economic justice as it considers revisions to our city’s charter to improve government transparency and responsiveness and to address our city’s housing crisis.

Specifically, we urge this Commission to consider revisions to the City Charter that mandate the City develop and maintain a comprehensive plan that centers racial, economic, health, and climate equity and ensures intentional, robust, and representative community engagement. Pratt Center is a member of the Thriving Communities Coalition (TCC), a citywide movement of more than 15 grassroots organizing, advocacy, policy, and technical assistance groups advocating for a more equitable, participatory, and comprehensive approach to city planning. We echo the testimony of our TCC partners, including the Association for Neighborhood Housing and Development (ANHD), in the recommendations to mandate an enforceable, equity-based comprehensive plan and enforce the city’s Fair Housing Plan.

New York City has never adopted a comprehensive plan to guide land use and resource allocation decisions for present and future needs. The City instead takes an ad hoc approach to planning through neighborhood and developer-initiated rezonings subject to Uniform Land Use Review Procedure (ULURP), which limits consideration of broader community contexts and needs. Communities and elected officials must respond to these proposals without any coherent guiding framework, with inadequate resources, and under a highly contentious process. Our communities, including Community Boards and grassroots groups, are under-resourced in evaluating these proposals; they rely on each other and, in some cases, outside consultants to assist in understanding and evaluating these applications. The role of the public in land use processes, while advisory, do have an impact–particularly with their City Council representatives, who are elected by and serve these communities. Community input has helped deepen projects’ affordability levels and secure funding for schools, parks, public housing, and tenant protections. Communities should not have to rely on piecemeal negotiations to secure public resources, but absent comprehensive and equitable planning, ULURP is the best tool for communities to inform and advocate for their future.

Several of the proposals before this Commission focus on streamlining ULURP to reduce the role of Community Boards or the City Council, or to fast-track projects on City-owned land or with income-restricted housing. Given the lack of resources and other community issues that volunteer Community Board members must attend to, communities are already working on a tight timeline in the public review process. For example, with City of Yes for Economic Opportunity and Housing Opportunity rezoning proposals, less than half of the Community Boards submitted recommendations before the City Planning Commission hearings for these proposals. Further, public review plays an important role in improving income-restricted “affordable” projects, which do not always match the affordability or unit size needs of the city’s diverse communities and neighborhoods. Proposals that point to public disclosure processes as the reason for delays to zoning changes do not address the underlying problem: ULURP and environmental review were designed to add transparency to discretionary decisions, not drive neighborhood or city planning. Weakening public disclosure requirements or reducing checks and balances on executive power would be an anti-democratic, inadequate response to the City’s failure to plan. 

A Comprehensive Plan for New York City that centers racial, economic, health, and climate equity and ensures intentional, robust, and representative community engagement would work to build trust and achieve fairer, more informed, and more democratic outcomes citywide and in our neighborhoods. Ensuring land use proposals comply with our Fair Housing Plan will also reinforce community priorities around affordable, equitable housing. These changes to the charter would also address concerns around the length of land use approval processes, as proposed projects would meet equity goals outlined in the plan and would align with community needs from the start. 

Finally, to meaningfully tackle our housing crisis, comprehensive community-based planning must be paired with deep investments in the preservation and creation of low-income housing, public and collective stewardship of land for permanent affordability, and strong tenant protections. Zoning policy and accompanying review processes are parts of a much larger housing policy toolbox, and cannot on their own meaningfully improve housing affordability for low- and moderate-income New Yorkers. 

This Commission has an opportunity to implement solutions that can create more just and fair processes for a more just and equitable City. We invite the Commission to work with the Thriving Communities Coalition, which has spent years developing policy proposals for comprehensive planning, to explore a Charter revision proposal to create a community-informed, equitable, comprehensive plan.

Note: This reflects the position of Pratt Center for Community Development and not necessarily Pratt Institute.