Recent land-use decisions and rezonings in New York City seeking to facilitate new housing development have disproportionately affected low-income communities of color. The public remains in the dark about why these places were chosen, how other neighborhoods will contribute to the citywide goal of addressing the affordable housing crisis, and whether sufficient resources exist to aid communities in accommodating growth without displacement.
The current New York City land use and environmental review procedures lack the necessary information and are based on methodologies that do not accurately disclose displacement impacts of residents and local businesses, particularly those in low-income communities of color. In essence, these procedures ignore that social factors are often interrelated and compound over one another, creating different levels of vulnerability and displacement risk.
The proposed legislation requires reporting that would address assessment gaps by disclosing disparities through an examination of different socioeconomic and housing factors that can determine displacement risk levels. These include but are not limited by race and ethnicity, labor force, household composition, housing market trends, overcrowding and eviction rates, among others. Having access to such information would proactively remedy some of the issues raised by RPA in the past.
In 2017 RPA issued Pushed Out: Housing Displacement in an Unaffordable Region. The report found that all across the tri-state area, low and moderate-income residents are being replaced by wealthier populations in walkable neighborhoods with good access to jobs. Moreover, neighborhoods that are both home to significant vulnerable populations and are walkable, job-accessible neighborhoods are 69% Black and Latinx, compared with 26% Black and Latinx in the rest of the region. In this report we recommended incorporating displacement risk into decision making, including land use, grant funding, housing subsidies and tax benefits. More recently, we have continued to articulate these ideas in comments to the Mayor’s Office and City Council regarding modifications to the City’s Environmental Quality Review process (CEQR). In its current form, we find that the proposed legislation is consistent with these conclusions and recommendations.
We also believe that a racial disparity report could facilitate proactive planning in ways that support equitable growth-oriented goals articulated in the city’s fair housing plan Where We Live. The proposed legislation would ensure that these long-term planning efforts move beyond the current administration and are considered priorities into the future. The proposed racial disparity reports could disclose needed information to determine whether a land-use change under consideration would meet local and citywide housing needs that promote integration, and minimize displacement risk of vulnerable residents. Relative to New York City, projects that would seek to facilitate development in wealthier and amenity-rich areas, tend to have lower displacement risk levels, and thus would be more likely to gain support and cross-acceptance if such findings are clearly communicated in the type reports proposed by this legislation. By analyzing the racial impacts of proposed land use actions, New York will be better-positioned to increase housing opportunities across the city as a whole and ensure that low-income people of color can remain in their communities, even in the face of neighborhood change.
Finally, the proposed racial disparity reports are largely aligned with the policy intent of the recently introduced legislation that seeks to implement a comprehensive planning framework. If comprehensive planning moves ahead as currently proposed, racial disparity reports should be incorporated into the analysis of the borough-wide or district wide land-use scenarios that would be required by such a framework. In addition, given that the proposed racial disparity reports would not be part of environmental assessment procedures, action types aligned with citywide goals, and that do not warrant a full review required by CEQR, would continue to be expedited and streamlined as intended by the proposed comprehensive planning framework.
We appreciate the effort the City Council has made seeking to improve transparency and equity in our land use process. It is a good first step in a much larger discussion involving the public, and stakeholders to arrive at critical solutions.
