Good morning, my name is Moses Gates and I am the Vice-President for Housing & Neighborhood Planning at Regional Plan Association. RPA is a 103-year old nonprofit civic association focused on research, planning and advocacy in the region. We have long advocated for more housing in central, transit-rich areas like Midtown South. We have also been longtime advocates for many of the specific components that will make this rezoning possible, most notably the recent lifting of the 12.0 residential FAR cap.

Thank you for the opportunity to testify and for putting forth a proposal which makes real progress toward creating the homes we need. We are very much in support of this rezoning, and excited to see it move forward and provide much-needed housing, including affordable housing opportunities in a neighborhood without many. As RPA has enumerated, the region needs well over half-a-million new homes, and this can be a major step toward this.

While this rezoning is for a residential density that has not been allowed for several decades, this is vitaly necessary to create a successful and impactful rezoning that makes progress on our housing crisis. The recent lifting of the 12.0 cap and the passage of City of Yes shows that both the city and state support this level of residential density in concept, and there is no more appropriate place to map it than in a district which is within walking distance to virtually every major subway line, the busiest bus and rail stations in the country, and the largest jobs hub in the western hemisphere.

We do believe this rezoning would be even more effective if also done in conjunction with a rezoning of the areas in the neighborhood not under consideration at this time, namely the Sixth Avenue corridor. This rezoning is focused almost entirely on the side streets of the area. However, the wide streets in the district are even more appropriate places to build much needed housing and we believe an additional study of Sixth Avenue and, where appropriate, Fifth, Seventh and Eighth avenues as well as Broadway should be conducted immediately.

As part of this future study or, if within scope, this current rezoning proposal we urge the Commission to consider either changes to the ​“Covered Pedestrian Space” design guidelines or the creation of a new POPS category that would facilitate the development high-floor public spaces, specifically a publicly accessible observation deck. There are currently no observation decks anywhere in New York City, at any time of day, where a family of three can spend less than $100 to get a view of their own city. London’s program, which has resulted in three separate, free, high-quality observation decks open to the public, could serve as a model for this program.

Another consideration is that this area is not only appropriate for additional housing, it is also perhaps the most appropriate area in the city for additional hotel development. We encourage DCP to take this into account and ensure that the new zoning, in particular the new streetwall requirements, does not impede the ability to easily construct hotels. New York hosting the 2026 FIFA World Cup Championship serves as a powerful reminder that the city must have capacity for a growing tourism and hospitality industry if we are going to remain the preeminent global city in the 21st century. While outside the scope of this rezoning, as part of any future study in the area we urge DCP to examine eliminating the need to obtain a special permit to build hotels in this area.

Lastly, we are concerned about the possibilities for a rezoning that is intended to produce large quantities of mixed-income housing to instead produce small quantities of luxury housing through loopholes in the MIH regulations. These include new developments both utilizing the offsite MIH option as well as the ​“rental/condo” loophole that allows for a segregated building of a base of rental housing on lower floors and a tower of large, expensive condominiums. Non-contextually zoned small lots on side streets in strong markets with high FAR are exactly where supertall condos featuring just a few large, expensive units are produced. Regulations requiring integrated mixed-income buildings can prevent this and support the development of more productive buildings. These regulations need to be as strong as possible and to the extent they are in scope we urge DCP to remove or modify the offsite and rental/condo loopholes.

We believe with these considerations and adjustments, the MSMX proposal will be strengthened and help us meet our goals of creating more housing and developing thriving neighborhoods in the core of Manhattan. As always, RPA is available to discuss concerns or offer insights to help realize our shared priorities.