Testimony re: Proposed Rules for the Affordable Housing Fast Track Methodology

City Planning Commission

April 1, 2026

Re: Proposed Rules for the Affordable Housing Fast Track Methodology

Thank you for the opportunity to comment on the City Planning Commission’s proposed rule for the Affordable Housing Fast Track Methodology. Pratt Center for Community Development has worked since 1963 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, to advocating for comprehensive planning, to policy reports on strategies to ensure that value created by city rezonings is captured for public good. 

The passage of the Affordable Housing Fast Track established by 2025 ballot question #2 reflects New Yorkers’ recognition of and concern about housing affordability and inequality across our city. In that spirit, we urge the City Planning Commission and the Department of City Planning to prioritize opportunities in the Fast Track rulemaking and broader implementation to mitigate displacement risk and advance fair housing and racial and economic equity.

We understand that the rule is constrained by the underlying Charter amendment, which is narrowly focused on expediting land use review for new housing development, and which establishes that the rate of new affordable housing development be the sole measure for determining where to expedite that review. The Charter does not, for instance, consider exemptions for areas with high displacement risk from the fast track, nor look at overall neighborhood affordability. Given these constraints, we wish to emphasize the importance of considering displacement risk and local affordability needs during pre-certification and the review process. We appreciate that the rule text states the responsibility of the City Planning Commission to “make findings regarding [each] application’s consistency with the Fair Housing Plan” (among other planning considerations). We recommend that the rule text also explicitly refer to all reviewing bodies’ responsibility to consider Racial Equity Reports for applications that require them.

Further, we ask that the rule include some evaluation criteria to promote methodology improvements and alignment with fair housing goals. We propose that the City Planning Commission, in coordination with the Department of Housing Preservation and Development, assess the consistency of the Affordable Housing Fast Track districts identified each five-year cycle with the Fair Housing Plan, and compare new affordable housing creation across districts with the Fair Housing Framework reports required under Local Law 167 including the Citywide and Community District housing production targets. In addition, CPC should analyze the affordability levels of the units created, alongside these reports, to determine whether the Fast Track should prioritize expediting more deeply-affordable homes, to the extent allowable by the Charter. CPC might also consider adding a lookback requirement to assess the accuracy of its calculation of the denominator, the total number of housing units. Whether or not these findings result in changes to the proposed methodology, they should be published publicly alongside the determination of the 12 districts eligible for the fast track. While CPC can propose amendments to its rules at its discretion, it should build into its methodology a process for evaluation and iteration. 

Finally, we suggest that, in addition to calculating the number of new affordable housing units created (per the proposed methodology), CPC analyze and publicly report the number of new affordable housing units approved in land use applications during the five-year cycle. Given that the Charter Revision Commission reports and hearings largely focused on opposition to land use changes to permit housing development, CPC should be evaluating whether the Affordable Housing Fast Track is resulting in an increased number of affordable housing units approved in land use applications. While this may not be a component of the methodology for determining the rate of affordable housing production, and perhaps may be beyond the scope of the proposed rule, it is an essential measure of the impact of the underlying policy and understanding the land use public review process as one of many factors affecting the creation of affordable housing.

For more information, contact

Sylvia Morse

smorse@pratt.edu