Pratt Center's Comment on the City’s Draft Housing Growth Strategy Report
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 includes facilitating community-based neighborhood plans, analyzing the implementation of Racial Equity Reports, facilitating a community oversight task force on neighborhood rezoning commitments, supporting Community Land Trusts, and advocating for Comprehensive Planning as part of the Thriving Communities Coalition.
We recognize the City’s new Fair Housing Growth Strategy, as mandated by Local Law 126 of 2023, as an important opportunity for the City to better understand and address housing equity in New York City. The Draft Report, however, falls short of meeting this goal as detailed below.
1. The Long-Term Housing Needs Assessment (HNA) (p.15-22) does not clearly “estimate the total number of homes of all types needed citywide” nor “the need for affordable, deeply affordable, and formerly homeless housing” over the next 10 years, as stated on p. 16 and as called for in the Local Law. In assessing the current need, the report estimates the number of units needed for “achieve a healthier vacancy rate,” “house all individuals and families experiencing homelessness,” “reduce involuntary overcrowding,” and “provide housing options for adults who want to live independently,” (p.19) but does not demonstrate what population or housing stock analysis informed these targets. The report then abandons these categories in its estimates of “baseline growth” needs to plan for population growth and “future need,” providing only total numbers of housing units, again without an explanation of the data and analysis that produced them. It would be extremely helpful to policymakers and the public to see analyses of unit/household size, rents, and other housing indicators (including geographic analysis where possible) that later inform the Housing Production Targets and Neighborhood Equity Strategies.
The report cites the goals for affordable, deeply affordable, and formerly homeless housing established in the Mayor’s “Block by Block” Ten-Year Housing Plan (p.22), rather than producing its own analysis of need by these categories or explaining whether or how this aligns with the estimates shared in the preceding pages. While we appreciate the City’s efforts to integrate simultaneous planning efforts, simply referencing the current administration’s affordable housing goals does not constitute an analysis of needs. The City must revise the report to provide a clear explanation of its methodology for assessing long-term housing need (including affordable, deeply affordable, and formerly-homeless housing) and underlying population and housing data, as well as an explanation of how they inform the Housing Production Targets.
2. The Housing Production Targets are not clearly informed by the Housing Needs Analysis, and the methodology for determining District targets excludes several criteria outlined in the Local Law. It is very difficult to discern whether or how the production targets were informed by the long-term housing needs assessment. First, because the HNA does not use the affordable, deeply affordable, and homeless categories in its estimates, nor does it include any submarket analysis, it is difficult to identify which needs are met by which production targets. That said, a total target of 25% affordable units (p.25) does not seem to align with the findings of the HNA. The five-year total unit creation target of 350,000 does represent half of the 700,000 total units identified in the HNA, but the 25,500 deeply affordable homes and 12,750 homes for homeless households together account for 10.9% of that total target, whereas the HNA calls for 53,000 units to address current needs of homeless New Yorkers, or roughly 18% of the total current need, and 40,000 for families doubling up, together totaling 32% of the number of homes estimated to meet current need. The report must be revised to align the HNA and Housing Production Targets analysis and describe how the HNA has informed the production targets. The report would be vastly improved by conducting some analysis of rent levels in both the HNA and the production targets, particularly for non-affordable units.
The District-level analyses and targets also fail to reflect a detailed analysis of need, and should be revised to include the following, in accordance with the Local Law:
Displacement risk data from the Equitable Development Data Explorer (EDDE), potentially including a community district’s status as high displacement-risk area. Incorporating displacement risk into the analysis will help distinguish between different housing needs and appropriate growth targets across Limited Affordability Areas, whether a high-income, dense, less racially diverse area like the Upper East Side which has low displacement risk, or low-density, moderate income areas that is a stronghold for homeowners of color like South Richmond Hill, which has high displacement risk (per the EDDE). The City misses critical opportunities to address fair housing by excluding data on race and displacement from its analysis, at least as communicated in the draft report. The analysis would also be strengthened by accounting for affordability of homeownership and rental housing, including informal units, in 1-3 unit homes in neighborhoods of color.
“Access to transit, employment opportunities, open space, and other neighborhood amenities and public services” and “impacts associated with climate change,” such as flood risk, within each District. These factors do not appear to have been included in the methodology for identifying District targets.
Finally, we encourage the City to develop district level preservation targets, including by affordability levels, based on the existing affordable housing stock and long-term affordability needs.
3. The Strategic Equity Framework presents many important obstacles and strategies to advance fair housing, but the draft report lacks necessary detail that would give the public a sense of where or how the strategies might be implemented. How were obstacles identified, and do they emerge from the HNA? How do strategies align with the housing production targets? For instance, the report proposes a strategy of creating more shared housing in transit oriented districts, (p.47), which seems to align with the HNA finding that more units are needed for adults who want to live independently, but the report does not include any geographic or affordability analysis for shared housing and smaller units. Similarly, the report calls to “encourage larger rental units in neighborhoods with the fewest ‘family size’ homes,” (p.47), which suggests the kind of unit size and geographic analysis we hope to see in a revised HNA.
In addition, we have recommendations to improve some specific strategies the City has identified:
As long-time advocates for safe basement apartment legalization, we support the strategy making it easier to build basement rental apartments in low-density neighborhoods that are mostly owner-occupied (p. 4). The report should note the critical obstacle, however, that the basement pilot program authorized by the State, and currently in development by the City, is restricted to 15 Community Districts, excluding many of the low-density neighborhoods this strategy targets. The strategy could also be revised to include working with the State to expand the program to high-need areas and to secure basement program funding for low- and moderate-income homeowners and tenants.
Strategies to “help the most at-risk New Yorkers pay for air conditioners and related utilities” (p. 52) should be include working with the State to better regulate utility providers and improve access to clean energy and energy affordability programs.
Within Neighborhood Equity Strategies, to advance the strategy to “improve quality of life through investments in streets, sidewalks, and public spaces and increasing access to services in areas with lots of affordable housing” the City should consider an analysis of the implementation of funding commitments made as part of neighborhood rezonings as well as related community oversight bodies (such as the Gowanus Oversight Task Force and the OneLIC Oversight Task Force). In addition, while integrating the Where We Live and the Fair Housing Growth Strategy into the Ten-Year Capital Strategy is an important step forward, we continue to call on the City to develop a Comprehensive Plan.
Thank you for the opportunity to comment on the City’s Fair Housing Growth Strategy. We urge the Department of Housing Preservation and Development (HPD) and the Department of City Planning (DCP) to address these concerns with the draft report before finalizing the Fair Housing Growth Strategy, and we look forward to seeing a revised plan that provides a more detailed analysis of housing affordability needs across the city’s neighborhoods, and production targets that strive to meet those needs to advance housing equity and fair housing goals.