Pratt Center

September 27, 2018

Pratt Center calls for a comprehensive planning framework to move toward equity

Testimony to the 2019 New York City Charter Revision Commission

By Paula Crespo, Senior Planner

Thank you for the opportunity to testify. For decades, the Pratt Center for Community Development has worked with community-based organizations and low-income communities of color to plan for and realize their futures.

One of the key ways that cities adapt to the array of changes and challenges they face is through their planning processes, which is why this Commission’s charge is so important. Our currently disconnected planning and land use review systems are not meeting the need to overcome the legacy of racist planning policy and to create affordable housing, quality jobs, equitable access to parks and schools, and infrastructure for sustainability.

The land use review process has become one of the few places where unaddressed planning needs can be publicly debated, but if and when communities are equipped to engage, their concerns are often dismissed as “out of scope.”  Other meaningful avenues for addressing these concerns don’t currently exist, frustrating those trying to make positive neighborhood change and address the underlying causes of inequality. At the same time, more powerful, reactionary actors stymie progress toward citywide goals and increase neighborhood inequity.

In particular, the City’s long-term infrastructure needs cannot be met through neighborhood investments that are tied to new housing density but not to pre-existing neighborhood needs, many of which are the result of historic disinvestment in low-income communities of color. 

A comprehensive planning framework can play an essential role to address these failings.

Lessons that have been critical to other cities’ successful use of comprehensive plans include:

  • Merging environmental concerns with land use recommendations
  • Using community plans as building blocks for a citywide framework
  • Using the plan to build accountability and transparency into every decision and expenditure made during implementation

Two issues that comprehensive planning would help address are residential displacement and fair share.


Residential displacement is rampant, yet there is no official measure of risk across the City, and current methods for projecting risk in the context of new development are egregiously flawed. We discuss this and the need for corresponding policies in our report "Flawed Findings: How NYC’s approach to measuring residential displacement risk fails communities," which we will submit to the Commission as an attachment.


The promise of fair share is falling far short of protecting disproportionately burdened communities from new threats to health and safety. Modern data tools and transparent reporting are necessary, as are updated criteria. The City Planning Commission should use heightened review to prevent unfair siting in over-concentrated neighborhoods.

These are just two ways that a comprehensive planning framework could integrate our systems and set goals toward a more equitable city.  Meaningful public participation should be at the heart of any planning process, and it is necessary to advance the participation in low income communities of color. Pratt Center looks forward to working with the members and staff of the Commission and with community members. We’re available for follow-up to elaborate and collaborate on the themes I’ve touched on.

NOTE:  This testimony was prepared by the Pratt Center for Community Development. It does not necessarily reflect the official position of Pratt Institute.