Thank you for the opportunity to submit testimony. RPA is a non-profit civic organization that conducts research, planning, and advocacy to improve economic opportunity, mobility, environmental sustainability and the quality of life for those who live and work in the New York metropolitan region.

RPA is excited about the New York City Department of City Planning’s (DCP) focus on the SoHo/NoHo area as a neighborhood which could supply much needed affordable housing growth as well as the overall direction of the proposal. More mixed-income housing (MIH) is greatly needed in New York, particularly in areas with access to jobs and mass transit, and in areas which do not currently have affordable housing opportunities for new residents. This is also the type of place where New York’s Mandatory Inclusionary Housing policy is designed to work: High-market neighborhoods in which larger buildings can be built with proper zoning.

In scoping the proposed rezoning we would like to see DCP take a somewhat more expansive look at the geography. Specifically, there are several areas not included in the rezoning where significant potential for affordable housing could exist.

First, we would like to see the area east side of 6th Avenue between Canal and Houston Streets considered, especially the areas which are not part of the existing Sullivan-Thompson Historic District. For instance, between Sullivan Street and Sixth Avenue, south of Spring Street, there are four newly-built large, expensive single-family homes - the type of development that results in high-market areas which are not zoned to allow for enough mixed-income multifamily housing. Encouraging more single-family homes is completely inappropriate in an area like SoHo which has good access to jobs and transit, and which needs more neighborhood retail uses and more affordable housing. This is especially egregious considering Sixth Avenue is a wide street in core Manhattan, the type of street which is best suited for large multifamily buildings. This site of these four townhouses could easily accommodate well over 100 apartments with ground floor neighborhood retail and still not be taller than the building next door. Despite its recent construction, this site could still be a feasible development site with the proper zoning, and we urge its inclusion in the study. In addition, the Houston Street corridor east of Mulberry street, the South Side of Canal Street, and the East side of Lafayette Street could be added to the study area as well.

We would also like to see the R10 designation extended to the north side of Grand Street, and specifically encompass the municipally-owned site at 142 Grand Street. Any development on this site is likely to be 100% affordable housing and as such should be zoned for as much residential use as possible, especially since the south side of Grand Street is also proposed to be rezoned to R10. We would also like to see all of the Canal street corridor have an R10 designation as well, instead of the currently proposed R9X.

We would also like to see the proposal tailored to encourage more housing overall. Currently, the spread between commercial and residential density is too low. Especially in the R7X areas we would like to see the residential floor-area-ratio (FAR) increased.

In conjunction with other changes to be made in the MIH text with this proposal we would like to specifically see one loophole closed, which is in section 23-96 (b) 2 of the Zoning Resolution. This specifically allows MIH projects where ​“all affordable housing units are rental affordable housing and all other dwelling units are homeownership housing” to economically segregate the buildings, putting all the affordable rental housing on lower ​“poor floors” and all of the high-end condos on upper floors, leading not to a mixed-income community but to a two-tiered structure both literally and figuratively. This is not in the spirit of mixed-income housing and neighborhoods, and we urge DCP to eliminate this language in the SoHo/NoHo MIH area, if not the MIH text overall.

Finally, we also highly encourage DCP to coordinate with DOT and other agencies to truly reimagine Canal and Houston streets especially as modern thoroughfares, safe for pedestrians and cyclists, and look for places where the zoning code could encourage this type of transformation.

Thank you for the opportunity to submit testimony, and we look forward to continuing to supports the effort to bring more affordable housing to one of our neighborhoods most in need of it.