Thank you for giving us an opportunity to provide testimony on this important topic. Regional Plan Association is a not-for-profit research, planning and advocacy organization that has served the New York metropolitan region for nearly a century. Our Fourth Regional Plan, released in 2017, provides a strategic, values-driven framework for addressing the many challenges our region faces to make it more equitable, healthy, sustainable and prosperous for everyone. Speaker Johnson’s Intro 2186-2020 bill to create a comprehensive plan for New York City would improve upon our existing ad hoc approach to planning and center racial equity in the City’s land use regulations and capital planning.

RPA supports reforms to New York City’s land-use process to make it more responsive to the needs of our communities and be more proactive in addressing long-term challenges that cross boundaries. Issues such as high housing costs, climate change, improvements to the transportation network and equitable economic development cannot be tackled in a piecemeal fashion. We need a framework that aligns regional, citywide and local needs and rebuilds trust in our land-use process. In particular, New York’s existing regulations have failed to deliver needed investments and opportunity, especially in low-income communities of color.

In January 2018, RPA worked with Councilmember Antonio Reynoso and Manhattan Borough President Gale Brewer, along with dozens of stakeholders to release our Inclusive City report - a set of recommendations to reform our land-use process to make it more inclusive and improve outcomes. A major recommendation of this report was to create a proactive comprehensive planning framework. Subsequently, RPA and the Association for Neighborhood and Housing Development (ANHD) worked with other policy and advocacy groups to form the Thriving Communities Coalition and advocate for land-use reforms during the Council’s 2019 Charter Reform process. We expected that after hearing from such a wide array of stakeholders about the need for land-use reform, specifically the need for comprehensive planning, the commission and its staff would have crafted a proposal on how best to develop a citywide comprehensive plan.

That didn’t happen. And the task was left to our legislative body to help reconcile all the different planning processes we currently have. Speaker Johnson’s advocacy of this bill is an important step to help us get to a holistic, predictable way of doing things in this City. This bill provides a solid framework to better coordinate planning, create more transparency and accountability, and address investment needs where they are needed most.

We will be grappling with the consequences of our current health, economic and social crises for years to come. Working together to create a citywide vision that reflects our needs and aspirations for a more prosperous city requires a bold step like this. The proposed comprehensive planning framework improves upon the status quo, will cut down duplicative efforts, improve government accountability, and create a framework to rebuild civic trust.

Trying to tackle the complexity of planning in NYC through one piece of legislation is not easy. This bill doesn’t solve all our problems. Here are specific ways that the bill can be improved to help better realize its goals:

Balancing Top-Down and Bottom-Up

This proposal helps proactively engage communities and have them share their vision for what they want for their city and their neighborhoods. That said, community boards do not have the resources they need to meaningfully engage in such a complex and long-term process. Additionally, the rules governing the adoption of a community board’s land use scenario hurt the intent to rebuild trust in the planning process. We believe that the following changes could help improve this issue:

• Charge the Civic Engagement Commission with Shepherding the Community Process - The intent of this commission aligns with advocates’ calls for an Office of Community Planning. The Commission should be charged with sourcing best practices and technical expertise to support community boards during this process, as designated in the charter. The engagement process should be led by the Commission, who in turn should ensure that community leaders are actively involved throughout the process.
• Fund and Train Community Boards to Educate around the Plan - Community Boards in their current form do not have the resources or capacity to educate their communities about something as complex as a comprehensive plan. A strict minimum budget should be committed that reflects the effort that will be needed to meaningfully engage community boards in a planning effort of this magnitude.
• Develop Outreach Requirements - The City can’t force everyone to participate, but it can set mandates that engagement and input reflects the range of stakeholders and diversity of a given district. There are plenty of standards that can be used to quantify who should be included in the process and best practices for engaging. There should be a commitment to ensuring a true representation of New York is helping in the visioning process, otherwise we risk having only those with power and privilege participating.

Accessible Information

The Conditions of the City report should be a critical planning tool to inform the public and expand our understanding of what long-term investments New York City needs. Better information and the ability to compare across different districts and look at citywide challenges should create an incentive for dialogue and progress. However, as we have seen through the CEQR process, complicated information provided in an ad hoc way does not build trust or understanding. We believe some steps are needed to ensure the public trusts the data and analysis being used:

• Full Transparency - Make sure that sources and methodology are understood and accessible by the public. Researchers and advocates alike should be able to understand how needs are being calculated, and should be able to replicate findings.
• Interactive Platform - If the City is committed to allowing communities to develop their own responses to the citywide needs, tools to help communities look at different options and their impacts should be created. Technology has evolved and it is easy to implement digital tools that help facilitate this kind of scenario planning exercise. RPA and MAS have been working on a citywide index that would help develop an objective baseline of information to start a dialogue, and are happy to discuss how this work could inform the comprehensive planning process.
• Method for Off-Cycle Changes - In any given year, circumstances could change that throw the entire vision into question. The current bill calls for reporting about deviations from the plan which help address this issue a bit. However, a method for triggering a revision based on some set of clear thresholds, or based on critical new information or comprehensive strategy, could help keep the plan more nimble in off-years. This is a slippery slope so there would have to be a clear framework for when revisions are triggered, but this could help address the concerns around the need for the NYC planning process to be ​“nimble.”

Interagency Coordination and Capital Construction

The plan creates a foundation to better align planning and the capital budgeting process through the ten-year capital strategy by requiring agencies to provide cost-estimates of necessary work regardless of whether funding is available. This will help the City understand the types of investments and funding necessary to address communities that have been neglected. However, true interagency coordination is not done through reporting alone. Real collaboration amongst City agencies is needed to reduce costs and inefficiencies and address some of the structural challenges we face. Incentives to encourage better coordination around capital and operating needs across agencies would serve the underlying purpose of the legislation.

Final Thoughts

After 9/11, RPA helped organize the Listening to the City effort, which brought thousands of New Yorkers together to think about the future of the World Trade Center site. It was an opportunity to look past the tragedy and to think about what that area should represent for all of us. Coming out of a pandemic that has claimed too many lives and exacerbated many of our challenges, we think this effort would come at the right time to center racial equity in our planning process and work with all New Yorkers to envision a better future for the entire City.

We know that City government needs to be nimble so that when crises arise, our leaders are not hamstrung in adapting services and projects to meet the moment. However, we have structural challenges to address - segregation, climate change, aging infrastructure and rising inequality - that are a result of decades-old decisions that have created disparities across our communities. This bill to require comprehensive planning in NYC improves our existing framework and would provide all New Yorkers a better understanding of where we’re going. Thank you again for your leadership on this proposal. We hope it moves forward and look forward to working together to make it a success.