Dear Charter Revision commission.

Thank you for the opportunity to testify. My name is Moses Gates, and I am Vice President of Housing and Community Planning at Regional Plan Association, a 103-year-old nonprofit civic association focused on research, planning and advocacy in the New York-New Jersey-Connecticut Metropolitan Area. We are also members of the Thriving Communities Coalition, a citywide alliance of community, faith, housing, land use and environmental organizations dedicated to ending land use injustice in New York City.

I am here today to provide some overarching goals we believe the commission should consider with respect to land use and housing, which we hope can inform the specifics of any proposals to reform the land-use process in New York City that this commission might propose.

We have a problem meeting our growing citywide needs through our current land use process. While today that need is housing, these needs may change throughout different eras - the problems of today were not the problems of yesterday and will not necessarily be the problems of tomorrow. But what has not, and will not, change is the need for our legislative and land-use processes to make progress on the city’s problems through a reasonable process within a reasonable timeframe.

When it comes to individual land-use applications we have two main problems: first, the balance between local and citywide decision making has swung too far toward individual member deference. We need to rebalance this process to ensure input and influence from local elected officials and community voices - but not veto power with respect to citywide needs. How can we decry the exclusionary land-use policies of neighboring municipalities - enabled by hyper local control of the land-use process - and the role they play in our housing crisis when we have much the same problem here in New York City? As pointed out by CHPC in their report ​“Low Density, High Stakes” the low-rise areas of New York City actually do worse in responding to our regional housing needs than the surrounding suburbs. We applaud the city’s recent passage of the ​“City of Yes for Housing,” zoning text amendment which has taken a large step toward addressing this disparity, but these types of needed interventions should not be generational undertakings. We need a more nimble process that can respond to changing city needs quicker.

However, the second problem is that we have no quantification of these citywide needs - for housing, transportation, resiliency or other issues - to judge these land use applications against. This leads us to relitigate broader issues through each individual land-use action in a transactional way. A process which comprehensively enumerates these citywide needs, and privileges applications that meet them, could help create better and more informed land-use changes. A comprehensive framework would have the added benefit of helping us more clearly understand where we should prioritize investments and services to create a more equitable city.

We urge the commission to consider reforms to the land-use process that can address both of these issues such as expanding the powers of the Board of Standards and Appeals to approve needed land use applications that meet citywide needs, for instance applications that help advance affordability or fair housing in New York City, or by creating a fast track project that aligns with established and approved citywide goals and targets. Many other civic associations, such as our partners at the Association for Neighborhood & Housing Development, Citizens Housing & Planning Council, Citizens Budget Commission, New York Housing Conference, Open New York and Enterprise Community Partners have also put forward smart solutions along these lines.

We also urge the commission to consider reforms that encourage more cooperation and coordination between the City Planning Commission and the City Council. One way could be to include some sort of council representation on CPC, another could be to schedule the CPC and Council votes closer together to encourage a parallel track on review and modification. When examining land use proposals we have two great advantages - a City Planning Commission which, throughout its existence and under multiple administrations, has always provided professionalism and planning expertise as well as local elected officials and community representatives who can provide on-the-ground context and knowledge. These two entities should be working in tandem rather than siloed into two separated and noncommunicative tracks during the process.

Thank you for the opportunity to testify, and I look forward to voting on any ballot initiatives in November.

Moses Gates